The first document filed in a lawsuit is called the Complaint. It’s generally capitalized when used in this context.

My Complaint was received by the Middlesex Superior Court, located in the Commonwealth of Massachusetts, on February 24, 2026 and is as follows:

COMMONWEALTH OF MASSACHUSETTS
SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT
MIDDLESEX COUNTY

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JENNA KOERPER BROWNSON,
   Plaintiff,
v.

ERICA PODGORNI,
   Defendant, Individually

MATTHEW NORDHAUS,

Defendant, Individually and as an Agent for the Town of Littleton

CHARLES DECOSTE,

Defendant, Individually and as an Agent for the Town of Littleton

GARY WILSON,

Defendant, Individually and as an Agent for the Town of Littleton

MARK CRORY,

Defendant, Individually and as an Agent for the Town of Littleton.

MATTHEW PINARD

Defendant, as Agent for the Town of Littleton

TOWN OF LITTLETON

Defendant through its Agents NORDHAUS, DECOSTE, WILSON, PINARD, CRORY

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COMPLAINT FOR DEFAMATION (PER SE) AGAINST PODGORNI, NORDHAUS,

DECOSTE, WILSON, and CRORY

COMPLAINT FOR THE VIOLATION OF PLAINTIFF’S CIVIL RIGHTS UNDER

42 U.S.C. § 1983 AGAINST NORDHAUS, DECOSTE, WILSON, CRORY, AND PINARD, ACTING AS AGENTS FOR THE TOWN OF LITTLETON

REQUEST FOR DECLARATORY AND INJUNCTIVE RELIEF

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I. PARTIES

1. Plaintiff is an individual residing in Littleton, Middlesex County, Massachusetts and an attorney in good standing, duly licensed to practice law in the Commonwealth of Massachusetts with a law practice located in Littleton, Massachusetts.
2. Defendant Erica Podgorni is an individual residing in Littleton, Middlesex County, Massachusetts.
3. Defendant Matthew Nordhaus is an individual residing in Littleton, Middlesex County, Massachusetts and at all relevant times was a member of the Littleton Select Board.
4. Defendant Charles Decoste is an individual residing in Littleton, Middlesex County, Massachusetts and at all relevant times was a member of the Littleton Select Board.
5. Defendant Gary Wilson is an individual residing in Littleton, Middlesex County, Massachusetts and at all relevant times was a member of the Littleton Select Board.
6. Defendant Mark Crory is an individual employed by the Town of Littleton, Middlesex County, Massachusetts and at all relevant times was the Executive Director of the Littleton Community Television, hereinafter “LCTV.”
7. Defendant Matthew Pinard is an individual employed by the Town of Littleton, Middlesex County, Massachusetts and at all relevant times was the Chief of Police for the Littleton Police Department.
8. Defendant Town of Littleton is a town in Middlesex County that is governed by a five (5) member Select Board.

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II. NATURE OF THE ACTION

9. This is a civil action for damages and declaratory and injunctive relief arising from defamatory statements, constitutional violations under 42 U.S.C. § 1983, and related state law claims committed by Defendants under the color of state law and in their individual capacities.

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III. JURISDICTION AND VENUE

10. This Court has subject matter jurisdiction pursuant to M.G.L. c. 212, § 3 as this action seeks damages in excess of $75,000 and includes claims arising under Massachusetts common law and federal civil rights law.
11. This Court has concurrent jurisdiction over Plaintiff’s federal civil rights claims under 42 U.S.C. § 1983.
12. Venue is proper in this Court pursuant to M.G.L. c. 223, § 1 because the Defendants reside and/or are employed in Middlesex County and the acts and omissions giving rise to this action occurred in Middlesex County.
13. Plaintiff seeks damages in an amount not less than $75,000, exclusive of interest, costs, and attorneys’ fees.

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IV. FACTUAL ALLEGATIONS

14. Plaintiff was elected to serve on the Littleton’s Board of Selectmen in May 2013 for a three-year term.

15. In December 2013, the Board of Selectmen voted unanimously to forgo a traditional open search for its next chief of police and to move forward with the one candidate recommended by then-Chief of Police John Kelly.

16. The one candidate put forward by Kelly was then-Deputy Chief Matthew King.

17. In late January 2014, Plaintiff received credible information from then-Sergeant David Leslie that in 1997, when both King and Kelly were sergeants with the Littleton Police Department, King had digitally raped a woman.
18. Leslie alleged the digital rape occurred in the neighboring town of Ayer, in a duplex owned by King.
19. Leslie alleged that the victim and her mother rented one side of King’s duplex from King; King lived on the other side.
20. Leslie alleged that the victim filed a report with the Ayer Police detailing the digital rape.
21. Leslie alleged that King paid the victim twenty-five thousand dollars ($25,000.00) to not pursue the matter in criminal court.
22. Leslie stated that the matter was never pursued by the victim of King’s digital rape.
23. Leslie provided Plaintiff with a copy of a March 27, 1997 interdepartmental memo from then-Chief of Police Thomas O’Dea to all staff at Littleton Police Department.
24. O’Dea’s memo stated, “1. Sgt. King has been placed on paid administrative leave as of 27 March 97, for reasons of my own as Chief of Police. 2. The purpose of this message is to inform you of this fact and to advise you that this is departmental business and shall remain so. You are not to discuss this matter with any member of the public, including your family, your friends, other police officers and members of any Boards or other public officials. You may consider this a “gag order”. 3. Should you recieve (sic) any type of questions regarding this matter, you are to refer the party to my office only. Thomas W. O’Dea Chief of Police.”
25. Plaintiff concluded from Leslie’s statements and O’Dea’s memo that there had been a cover-up in 1997 relative to the allegation that King had digitally raped his tenant.
26. In early February 2014, Plaintiff brought this credible information to the other members of the Board of Selectmen.
27. In mid-February 2014, Plaintiff was excluded from the investigation into the allegation of King’s digital rape by a bogus sexual harassment investigation.
28. When no evidence was found to support the claim of sexual harassment, Plaintiff was forced to resign from the Board of Selectmen under threat of exposure by Kelly of Plaintiff’s inappropriate relationship with Kelly, threat to Plaintiff’s bar license, threat to Plaintiff’s husband’s professional license (as a mental health counselor), among other life-altering matters.
29. In the summer of 2021, Plaintiff announced, via Plaintiff’s blog (www.jennabrownson.com), her intention to publish a memoir about Plaintiff’s ten (10) months of service of Littleton’s Board of Selectmen.
30. Plaintiff titled the memoir GINNED UP.
31. Plaintiff was motivated to publish GINNED UP to put an end the speculation and rumors that continued to persist relative to Plaintiff’s resignation.
32. The first “episode” of GINNED UP was scheduled to be published on the evening of July 19, 2021.

33. On July 19, 2021, just hours before the scheduled publication of Episode One, Attorney Howard M. Cooper of Todd & Weld, LLP, sent Plaintiff an email.

34. Attorney Cooper’s July 19, 2021 email stated, “Please be informed that this office represents former Littleton Police Chief, John Kelly (“Mr. Kelly”). As you know, Mr. Kelly served with honor and distinction as the Littleton Chief of Police and is a respected member of his community. Mr. Kelly is aware that you are in the process of publishing via the Internet your so-called “memoirs.” He is also aware from your prior postings that you intend to include him in your publication. Please be informed that we will be monitoring what you publish about Mr. Kelly. If you publish or in any way promote false and defamatory statements or information of and concerning Mr. Kelly, portray him in a false light in your publication, or otherwise invade his privacy, he will take legal action against you. To the extent you are unclear at all as to the meaning of this communication, I suggest you have your legal counsel call me.”

35. Plaintiff received two more similarly themed letters from Attorney Cooper in the fall of 2021.

36. Plaintiff continued the weekly publication of GINNED UP episodes, fully aware that each episode was being “monitored” for content that might be construed as being either a false or defamatory statement and for content that might portray the former Littleton Police Chief in a false light or as invading his privacy.

37. From July 2021 to May 2022, Plaintiff published GINNED UP, recounting Plaintiff’s ten (10) months of service on Littleton’s Board of Selectmen.
38. GINNED UP was published over the course of forty (40) consecutive “episodes” on Substack at jennabrownson.substack.com.
39. GINNED UP was publicly available and made free to read.
40. GINNED UP established, through the publication of approximately two hundred eighty thousand words (280,000), that the Littleton Police Department—under then-Chief Kelly’s administration—and the then-Board of Selectmen members—Ted Doucette, Alex McCurdy, Jim Karr, and Joseph Knox—engaged in a cover-up of the alleged digital rape committed by King.
41. Not one person in a position of power, influence, or authority for the Town of Littleton has ever refuted publicly Plaintiff’s account of the rape cover-up.
42. In May 2022, Defendant Gary Wilson was elected to serve a three-year term on Littleton’s Select Board.
43. Defendant Wilson was appointed by the Select Board to serve on LCTV’s Advisory Committee.
44. Defendant Wilson attended his first meeting of LCTV’s Advisory Board on September 21, 2022.
45. Defendant Wilson currently serves as the Vice Chair of LCTV”s Advisory Board; the chair’s seat is vacant.
46. Nine months after the complete publication of GINNED UP—on or about February 28, 2023, Defendant Erica Podgorni published statements concerning Plaintiff on Facebook.
47. Specifically, Defendant Podgorni stated on social media that Plaintiff “had blackmailed the Chief of Police while a member of the Select Board.”
48. Plaintiff served on Littleton’s Select Board, then called the “Board of Selectmen,” from May 2013 to March 2014, nearly a decade before the Defendant Podgorni’s social media statement.
49. At the time of Defendant Podgorni’s statement, Plaintiff was not a public official and held no public office.
50. Defendant Podgorni’s statement accused Plaintiff of committing the crime of blackmail, a criminal offense involving moral turpitude.
51. Defendant Podgorni’s statement was, and remains, false.
52. Defendant Podgorni’s statement was presented as a statement of fact, and not one of opinion, rhetoric, or hyperbole.
53. On or about February 28, 2023, Defendant Podgorni published the statement in a Facebook group titled “Constructive Conversations for Littleton Women,” which at the time had approximately one hundred ninety-six (196) members.
54. On or about February 28, 2023, Defendant Podgorni published the same statement in a Facebook group titled “Littleton Common,” which at the time had approximately four hundred ten (410) members.
55. Both Facebook groups allowed Defendant Podgorni’s statement to be viewed by members of the community who would otherwise be beyond Defendant Podgorni’s immediate contacts.

56. At all relevant times, Defendant Podgorni was the founder of the Facebook group “Constructive Conversations for Littleton Women.”
57. At all relevant times, Defendant Podgorni was one of four moderators of the Facebook group “Constructive Conversations for Littleton Women.”
58. At all relevant times, Defendant Podgorni exercised authority over content published and maintained within “Constructive Conversations for Littleton Women.”
59. At all relevant times, Defendant Podgorni had the authority to ban members of “Constructive Conversations for Littleton Women.”
60. On information and belief, Defendant Podgorni continued, after the initial false statement on or about February 28, 2023, to make further false statements about Plaintiff within the Facebook group “Constructive Conversations for Littleton Women,” repeatedly reasserting Plaintiff’s alleged criminality as a matter of fact, arising from the same false statement.
61. On information and belief, the statements continued thereafter during private, behind-the-scenes debates among the four moderators of “Constructive Conversations for Littleton Women,” where Defendant Podgorni repeatedly reasserted Plaintiff’s alleged criminality as a matter of fact, arising from the same false statement.
62. By publicly accusing Plaintiff of committing a crime—particularly one involving the Chief of Police—Defendant Podgorni directly impugned Plaintiff’s honesty, integrity, and fitness to practice law, thereby irreparably harming Plaintiff’s professional reputation and capacity to earn a living.
63. Defendant’s conduct subjected Plaintiff to public contempt, ridicule, and reputational harm within the community.
64. Defendant Podgorni’s actions were knowing, intentional, and undertaken with reckless disregard for the severe and foreseeable harm such accusations would cause to Plaintiff.
65. Defendant Podgorni’s statements were not made in connection with any petitioning activity, governmental proceeding, or request for governmental action.
66. In the spring of 2023, Plaintiff read POVERTY, BY AMERICA by Matthew Desmond and learned that 6.3% of Littletonians live under the poverty line.
67. On July 24, 2023, Plaintiff began writing at her Substack and on her blog about the history and present status of the cannabis industry in Littleton and its intersection with Littleton’s Select Board, the governing body with exclusive authority to grant the Host Community Agreements (HCA) that allow various cannabis entities to operate in Littleton.
68. Plaintiff titled this series POT TWIST.
69. POT TWIST advocated for the idea that local poverty in Littleton could be solved were the Select Board to grant HCAs to mission-driven entities, such as B-Corps, that would commit to giving the business’s profits to the 6.3% of Littletonians living in poverty.
70. POT TWIST’s early posts addressed the matter of Select Board member Matthew Nordhaus’s wife, who had been granted an HCA by the Select Board in the spring of 2020 but had not—three years on—opened her retail cannabis business.
71. From July 24, 2023 to November 6, 2023, Plaintiff wrote sixteen posts in POT TWIST, at a rate of approximately one a week.
72. On August 23, 2023, Littleton’s Town Moderator Tim Goddard asked Plaintiff to fill the seat on the Finance Committee that the Town Moderator has sole authority of appointment.
73. Plaintiff accepted Goddard’s appointment and was sworn-in as a member of the Finance Committee by the Town of Littleton’s Clerk, Diane Crory on August 23, 2023.
74. On August 24, 2023, Goddard texted the following to Plaintiff: “Just so you know, certain board members are claiming the terms of your agreement with the town prohibit you from serving in an elected capacity. To which I said that is an appointed board. Not to worry. I spoke with the chair. Wanted to know if I was aware. Said I didn’t know about any agreement and not sure it would be legal to prevent someone from running anyway. I’m sure you can guess who’s complaining.”
75. On August 24, 2023, Goddard confirmed that “the chair” was then-Select Board Chair Defendant Wilson.
76. On August 24, 2023, Plaintiff texted Goddard the following: “In case you’ve gone looking for this “agreement,” there is none. The statement that I agreed to never run for public office, out loud or in writing, is false. Not (sic) such agreement exists. Whoever is saying this is defaming me. I can (sic) begin to tell you how much this town has broken my heart. I’m not sure what I did to make people dislike me or believed hateful and false things. Ever since I brought to light the allegation that Matt King digitally raped a woman and then paid her to drop it (sic) the case, my life’s been difficult here. I guess crossing the police gets you somewhere in Littleton. And the sad thing is that I care about town and have been excluded. In practical terms, they didn’t need me to enter into an agreement with the town, my fear of harm has kept me away. So, they won. The rapist got his fully funded pension and the 3^rd woman in 300 years of Littleton is forced to resign and then subjected thereafter to a lot of pain. There is no agreement with the town. That is a lie.”
77. On August 25, 2023, Plaintiff and Defendant Wilson had this text exchange:

Plaintiff: “Hi Gary, Tim Goddard told me that you said l might not be able to serve on FinComm because of an “agreement” l made with the town. Who told you about this agreement? Jenna.”

Defendant Wilson: “I asked if there was an agreement.”

Plaintiff: “What would make you believe that an agreement such as that existed?”

Defendant Wilson: “Don’t read into it. From the information you shared with me on the circumstances and the resignation from the Select board, I asked town counsel if there was anything preventing you from serving on FINCOM or any boards. I personally don’t believe there is but want to do my due diligence as Chair as I’m sure there will be questions and I want to be able to answer truthfully. If you’d rather I ask you directly I will, but I thought it would sound like I’m against you volunteering your willingness to serve and that is not the case at all. I was just informing Tim that I reached out to Town Counsel as he was the appointing authority and didn’t inform me of your application (which is a courtesy, but not necessary)”

Plaintiff: “There’s no way to not read into it. You asked if there was anything preventing me from serving on FinComm. I suspect I’m the first person whose name has led you to make an inquiry of that sort. I never told you of any agreement. So, I’ll ask again: What would make you believe that any such agreement existed? For l surely never told you that such an agreement existed.”

Defendant Wilson: “Jenna I’m not going to go back and forth on this. You told me directly you had a relationship with an employee of the town while on the SB. You resigned your position from the board. My first concern is for the employees and ability to effectively manage. I ASKED TOWN COUNSEL if there was anything preventing you from being on a board or committee in the town to include ethical or moral findings or any agreement around the circumstances of your departure. If you are failing to see your circumstances as unique, than all I can tell you is that I would inquire about any Statutory Board applicant that left under your circumstance.”

Plaintiff: “What l told you ought to have left you with the impression that l was forced off the board for bringing to light allegations the Matt King digitally raped a young woman and then reportedly paid her to drop it. That’s the piece people fail to see in all this. The rape. My “relationship” with Kelly was irrelevant until Kelly et al. found a way to make it relevant. When l told the story of my 10 months on the board, l was threatened by Kelly’s lawyer in three separate letters. Guess what? I wasn’t sued. Because what l wrote was true, Gary. They wouldn’t have hesitated for a moment if I’d written anything libelous/invasion of privacy/ false light. People can’t sue those who tell the truth. I was terrified in March 2014 to speak up. I wish I’d had the courage to have stood up and spoken truth to power then. So, what I’ve learned from trying to serve my hometown is that if you go up against the police, your male board members will allow a bogus sexual harassment claim to be made (unfounded) and then when that doesn’t work, terror is the next choice. Again, life’s been not the best thanks to the boys in blue and their political cronies.”

Defendant Wilson: “Im (sic) sorry as I don’t want to bring this all back to light and was keeping it internalized as much as possible. I look forward to working with you on the FINCOM.”

78. On September 5, 2023, Defendant Matthew Nordhaus was a member of Littleton’s Select Board.

79. During the Select Board’s regular public meeting on September 5, 2023, Defendant Nordhaus stated the following from his seat at the Select Board table: “Recently our Town Moderator appointed Jenna Brownson to the Finance Committee, an appointment that I am deeply troubled by. Jenna Brownson—not in my words, but in her own written words—admitted to behavior that could easily be defined as abuse of authority and sexual harassment of a subordinate employee and attempted extortion while she was a member if the Select Board in 2014. Middlesex Superior Court records are publicly available which contain Ms. Brownson’s own written admission of this corruption. The Town of Littleton should not allow a person with this track record to serve on our Finance Committee. In my opinion, it is irresponsible and fiscally negligent. To my knowledge, the Select Board has no authority in this matter. Whether or not there are legal grounds to deny her a seat on this statutory board, it is my personal opinion that she should not be allowed in any position of responsibility, especially over your tax dollars. I couldn’t live with myself if I let this go without making sure Littleton residents were informed.”

80. Defendant Charles Decoste was present at the September 5, 2023 Select Board meeting.

81. Defendant Wilson was present at the September 5, 2023 Select Board meeting.

82. The September 5, 2023 Select Board meeting was broadcast live by LCTV.

83. The September 5, 2023 Select Board meeting was recorded by LCTV.

84. The September 5, 2023 Select Board meeting is publicly available at LCTV’s YouTube channel.

85. To date, the September 5, 2023 Select Board Meeting has been viewed seventy-eight (78) times at LCTV’s YouTube channel.

86. Defendant Nordhaus maintains a public Facebook page titled “Matthew Nordhaus, Littleton Select Board.”

87. “Matthew Nordhaus, Littleton Select Board” has two hundred eight-seven (287) followers.

88. On September 6, 2023, Defendant Nordhaus, on his “Matthew Nordhaus, Littleton Select Board” Facebook page, posted the video clip of his statement from the September 5, 2023 Select Board meeting.

89. Defendant Nordhaus’s September 6, 2023 post was titled “My statement during last night’s SB meeting regarding a troubling appointment to the Finance Committee.”

90. Defendant Nordhaus’s September 6, 2023 post received seven (7) comments.

91. Defendant Nordhaus’s September 6, 2023 post has had “1.6k” views.

92. Defendant Nordhaus’s September 6, 2023 post was shared five (5) times, including by the Facebook page “Residents for a Better Littleton,” a public page with “1.8k followers.”

93. Defendant Nordhaus’s statement accused Plaintiff of “abuse of authority.”

94. Defendant Nordhaus’s statement was presented as a statement of fact, and not one of opinion, rhetoric, or hyperbole.
95. Defendant Nordhaus’s statement was, and remains, false.
96. Defendant Nordhaus’s statement accused Plaintiff of “sexual harassment.”
97. Defendant Nordhaus’s statement was presented as a statement of fact, and not one of opinion, rhetoric, or hyperbole.
98. Defendant Nordhaus’s statement was, and remains, false.
99. Defendant Nordhaus’s statement accused Plaintiff of committing the crime of “attempted extortion,” a criminal offense involving moral turpitude.
100. Defendant Nordhaus’s statement was, and remains, false.
101. Defendant Nordhaus’s statement accused Plaintiff of “corruption.”
102. Defendant Nordhaus’s statement was presented as a statement of fact, and not one of opinion, rhetoric, or hyperbole.
103. Defendant Nordhaus’s statement was, and remains, false.
104. At all relevant times, Defendant Nordhaus exercised authority over the content published and maintained at “Matthew Nordhaus, Littleton Select Board.”
105. By publicly accusing Plaintiff of committing a crime, Defendant Nordhaus directly impugned Plaintiff’s honesty, integrity, and fitness to practice law, thereby irreparably harming Plaintiff’s professional reputation and capacity to earn a living.
106. Defendant Nordhaus’s conduct subjected Plaintiff to public contempt, ridicule, and reputational harm within the community.
107. Defendant Nordhaus’s actions were knowing, intentional, and undertaken with reckless disregard for the severe and foreseeable harm such accusations would cause to Plaintiff.
108. On September 9, 2023, Plaintiff and Defendant Wilson had this text exchange:

Plaintiff: “Just so I have my facts straight: You said (in all caps) that you, on your own volition, reached out to TC. [Town Counsel] Tim Goddard told me that you reached out to TC after MN [Matthew Nordhaus] told you that I’d entered into an agreement to not run for elected office. Which is it?”

Defendant Wilson: “Everything I do as Chair or otherwise is if (sic) my own volition. I asked TC if there was anything on record. What MN shared with me was the court records from the private lawsuit that he believed would prevent you from running. I shared it with TC as well after the fact but informed Mathew that anything he wanted to do was on his own volition and I specifically said I would not address it as chair and the matter was closed as far as I was concerned.”

Plaintiff: “So the notion that an agreement existed between myself and the town came to you sua sponte? Are you aware of other such agreements between the town and citizens of Littleton where the citizen has signed their right to run for office away? Does Littleton have agreements where people sacrifice their right to vote?”

Defendant Wilson: “I’ll reiterate what I already told you. You are the one that informed me of the circumstances for your departure. Your tone is accusatory and non productive (sic). My goal is to keep the towns best interest at the forefront of every decision.”

Plaintiff: “Well then, maybe you ought to have stopped Matthew from saying something you well could have predicted he was going to say the moment my name flowed from his lips. Or alternatively, once he was done abusing the power of his office, during an open meeting you were in charge of, you could’ve addressed it right then. If you for a moment you think l don’t have Littleton’s best interests at heart, you don’t know me or you’ve believed the lies that you’ve heard about me. I want to end poverty here. People in positions of power and authority know what happened nearly ten years ago. No one wants to talk about the rape. And the cops. And the collision (sic) by one SB member after another. It’s not good, Gary. And the fact that nearly ten years later people are still trying to silence and marginalize me might be on account of the fact that Littleton has not done right by me and l keep loving it anyhow. You’ve yet to answer my simple question: Did the notion that an agreement existed between myself and the town come to you all on your own, or did Matthew tell you that such an agreement existed and thereafter you asked TC? Because our Town Moderator told me that your call to TC came after Matthew told you about a non-existent fictitious agreement.”

Defendant Wilson: “I can’t comment on here say (sic) and I have nothing further to add.”

Plaintiff: “Got it.”

109. In late 1999 or early 2000, Plaintiff was working for the then-Department of Social Services (DSS) as an investigator of child abuse and neglect.

110. Because Plaintiff’s work at the time included going to people’s homes unannounced with the power to remove abused and/or neglected children, Plaintiff’s co-workers suggested that Plaintiff “get mace.”

111. Plaintiff learned that to “get mace,” Plaintiff would need to complete a Hunters’ Education/Gun Safety course.

112. Plaintiff attended and passed this requisite Hunters’ Education/Gun Safety course.

113. To become licensed to “get mace,” Plaintiff was informed that the chief of police in Plaintiff’s town of residence—at the time Ayer, Massachusetts—would be the final authority on whether Plaintiff would be allowed to “get mace” or any other firearm.

114. It was with this history, education, and experience that on September 9, 2023, Plaintiff texted Defendant/Chief of Police Matthew Pinard of Littleton Police Department—where Plaintiff was living at the time and feeling an ever increasing sense of fear—the following: “How long does it take to get a gun permit, Chief?”

115. Defendant Pinard—the “final authority” on whether Plaintiff could become licensed in Littleton, Massachusetts—has never replied to Plaintiff’s inquiry by text or by any other mode of communication.

116. On September 10, 2023, Plaintiff texted this to Defendant Wilson: “Everyone has to make a choice, Gary. Up until your claim that you can’t comment on “here say” (fyi, it’s “hearsay”), l thought you were the sort of person who would choose honesty over subterfuge, but now I’m not so sure. However, I’m giving you the opportunity to make a better choice, i.e., better than your cowardly last text, because l believe that you do care about Littleton. I’m going to spell out for you what l suspect happened: Matthew finds out on 8/23 I’ve been appointed to FinComm and begins a backdoor campaign to make sure that l cannot serve. (This alone is anti-democratic because Matthew has no say in Tim’s choice.) Tim alerts me on 8/24 that you’re asking TC about an agreement between me and the town. Based on our texts and my conversations with Tim, l believe that Matthew told you that such an agreement existed between me and the town where l agreed to never again run for elected office and you, given what l shared with you about my time on the BoS, thought that maybe such an agreement did exist (not that it would matter since FinComm is appointed). You then (maybe without thinking critically) called TC to ask about this fictional agreement and were told that no such agreement existed. (Side note: do l impress you as the sort of person who would agree to not exercise my right to participate in government? Moreover, post-ousting from the BoS, l ran for public office (library trustee) and this “she-can’t-run” agreement didn’t get brought up—because it doesn’t exist.) Tim told you to have anyone with concerns about his appointment to call him. Tim’s received zero calls. When Matthew realizes that he’s not going to get his way, he uses his position on SB to air his wife’s personal grievances, referencing the lawsuit between her and me over the business (Littleton Apothecary) that holds a lucrative license that your board oversees. Think about all this from the vantage of a fly on the wall. It’s an open secret among those of us paying attention that there’s something going on with that license—you yourself expressed concerns. So, everyone has a choice. You chose to believe Matthew’s preposterous claim that our town, as a governmental body, would be a party to a (fascist?) contract. Is that the sort of town we live it in, Gary? Is that the sort of town you want to live in? Personally, l think you made a mistake and the fact that you’re now digging your heels in (as evidenced by quick read of your text replies) tells me that you’re feeling defensive. And l think you feel this way because you made a mistake in believing the hateful, inaccurate, fascist representations of your peer board member instead of taking a moment to think critically about any of it. Frankly, this could’ve ended with you telling Matthew, “Even if such an agreement did exist, she’s appointed.” But you took it to the next step and called TC. Matthew’s statement puts 01460 at risk of getting sued. You do see that, right? I have zero interest in suing the town. I’ve got no time for that. I’m trying to abolish poverty here, Gary. I’m making my choice to be on the right side of history here in Littleton. You’ve got yours to make too. There’s nothing shameful in admitting that you got played by Matthew.”

117. Defendant Wilson did not reply to Plaintiff’s September 10, 2023 text.
118. On September 16, 2023, in response to demands from Defendant Podgorni made on the Facebook page “Constructive Conversations for Littleton Women” that Plaintiff “explain herself,” Plaintiff recorded and published a video statement on Plaintiff’s Substack.
119. The text of Plaintiff’s statement, which was subsequently published at Plaintiff’s blog on April 26, 2024—two days after Candidates’ Night 2024—is as follows: “If you’ve spent any time in local politics in Littleton, you probably know what happened—nine and a half years ago—when I went up against the police in my hometown. If you’re not into local politics or are new in town, you’ve likely heard rumors. Two years ago, I published my account of my experience on our town’s Board of Selectmen. I titled it GINNED UP. Over the course of forty weeks, I went into excruciating detail about what happened during my short time on the board in serialized form. Some people paid to read it, many were provided with free subscriptions. Hours before the very first episode was published, I received a letter from an attorney representing our former police chief, John Kelly. I was informed that they would be keeping a close eye on what I would be writing and wouldn’t hesitate to sue me if they found something actionable. As an attorney myself, I knew that in order to not get sued, all I had to do was tell the truth. About a month into my weekly publication, I got another threatening letter from John Kelly’s lawyer. I kept publishing. A month after that, I got a third letter, which, concluded with this zinger: “Absent the immediate removal of your writings from the Internet . . . a lawsuit will follow.” I removed nothing. I published one episode and then another and another. It took a full month for me to believe that they weren’t going to try to stop me. But let’s be clear: when I announced that I was going to publish what happened over the course of a year of my life while on Littleton’s Board of Selectmen, John Kelly, through his lawyer, threatened to sue me. Three times. And I was not sued. I was not sued because I told the truth. In GINNED UP, I described how, in January of 2014, then-sergeant David Leslie brought me credible allegations that Littleton’s chief-to-be, Matt King, had digitally raped a woman. Rape in the digital age refers to the forcible and unwanted penetration of a person’s fingers inside the body of another person. It has nothing to do with cybercrime. David Leslie told me that Matt King, in addition to digitally raping a woman, also paid her $25,000.00 to not go forward with the allegation. Within three days of bringing this information to Ted Doucette, Littleton’s then-Town Administrator Keith Bergman, and town counsel Tom Harrington, I was on the receiving end of a bogus sexual harassment investigation. This was the first method by which my tenure on the board was threatened. No sexual harassment was found, because no sexual harassment occurred. When ousting me that way didn’t work, John Kelly put me in fear. I did not resign because I wanted to, I resigned because I was terrified that my life would be ruined—because that was what John Kelly predicted would happen. Take a moment to understand that, between July 2021 and April 2022, I published a lot of very critical, deeply unflattering words about the behaviors and actions of many of our town employees and many of our then-town officials. I’d brought credible allegations of a violent sex crime to the attention of town employees and elected town officials and was forced out of office. I do not know if Ted Doucette, Alex McCurdy, Joe Knox, Jim Karr, Keith Bergman, Tom Harrington, and Bonnie Fleck looked into the allegation of digital rape or the allegation that the rape victim was paid to not go forward. What I do know is that Matt King became Littleton’s police chief—just as John Kelly had wanted. This was what happened in Littleton: I brought forward credible allegations that Littleton’s next chief of police had committed a violent sex crime and paid the victim not to go forward and was forced out of office. Anything else you’ve heard is a lie.”
120. Plaintiff’s POT TWIST posts went from weekly to daily, starting on November 16, 2023 and continuing until January 21, 2024, i.e., sixty-seven (67) days in a row, including both Christmas or New Year.
121. In POT TWIST, Plaintiff wrote many critical and unflattering things about Defendant Nordhaus relative to his dual roles of Select Board member and spouse to one of the licensees who was/is allowed—by an HCA negotiated between Nordhaus’s spouse and Littleton’s Select Board, of which he was/is a member—to sell recreational cannabis in Littleton.
122. Defendant Nordhaus is directly addressed in twenty-one (21) of those sixty-seven (67) daily posts.
123. In POT TWIST, Plaintiff wrote many critical and unflattering things about Defendant Decoste in his role as Select Board member.
124. Defendant Decoste is directly addressed in eight (8) of those sixty-seven (67) daily posts.
125. In the spring of 2024, Plaintiff submitted nominating papers so that Plaintiff’s name would appear on the ballot as a candidate for Littleton’s Select Board.
126. Plaintiff ran as a single-issue candidate on a platform to “End Local Poverty.”
127. On April 24, 2024, Plaintiff and Defendant Decoste participated in the annual Rotary-sponsored Candidates’ Night as the two candidates for one Select Board seat.
128. LCTV broadcast 2024 Candidates’ Night live before a live audience who were permitted to submit questions anonymously.
129. Defendant Wilson was present in the audience at 2024 Candidates’ Night.
130. Plaintiff believes Defendant Nordhaus watched 2024 Candidates’ Night.
131. During said Candidates’ Night, Town Moderator Tim Goddard asked Plaintiff, “Please explain the events surrounding your stepping down the last time you served on the Select Board. Is it true that at the time you agreed not to serve on any town boards in the future?”
132. Plaintiff answered, “Great. I’m so glad that that question came up. Okay, so, with respect to this idea that my resignation included my signing something that said I would never run for public office: that doesn’t sound like me. And do you want to live in a town where the leadership asks its citizens to sign agreements that they don’t run for office or maybe that they don’t vote? Is that the town we want to live in? Not the town I want to live in. I have never signed anything that said I would not run for public office. With respect to what happened leading to my resignation, that’s been asked and answered over and over and over again. I believe that people would like me to say something that is in some way titillating or interesting to them. It concerns me that this is still so very interesting to all of you. And for me to talk about it again is hurtful to the people who are close to me; it’s hurtful to the people who are close to the other people involved with all of this. I’m really not interested in hurting people in that way anymore, and I’d like to see all of us move on from that. If you would like me to share my perspective of it in a couple of sentences, it’s going to be empty because it will be taken in a way that’s not comprehensible. I wrote about this over the course of forty weeks. I wrote two hundred and eighty thousand words (280,000) explaining what my time on that board at that time was like. And I was told that people were going to keep an eye on me, going to keep a watch: make sure I didn’t publish anything that was in any way inflammatory—not “inflammatory”—ah, sorry—invasion of privacy or libel or slander or any of that. I was threatened with lawsuits. And I think this is where they made their biggest mistake: they told me they’d be reading and they read what I wrote, every week, and I was never sued for slander or libel or invasion of privacy because truth is a hundred percent defense to any sort of those claims. I was not sued because I told the truth over the course of two hundred and eighty thousand words. And for those of you who continue to hold an opinion, you’ve been misinformed. I don’t know what to tell you. I tried to share with you what my experience was: the good, the bad, the complicated. And a lot of people read it, and many did not. That’s okay. As far as who I was ten years ago, I was really frightened. That’s who I was. I was frightened. I crossed, I crossed people with power and I was punished and I’m okay with that because I have learned great things. I believe this town has been able to teach me wonderful and important lessons, and I’m trying to make meaning out of this community by trying to do a big project: a solving-poverty project. I’m kind of bored with that old story. It’s boring and it’s been asked and answered and told and dissected and I’m really kind of tired of it.”
133. Defendant Decoste was allowed to reply to Plaintiff’s statement. He said, “I would like nothing more than to not be discussing this at Candidates’ Night but the fact of the matter is Jenna did pull papers and she’s sitting next to me right now. I don’t believe there was any document that she signed or agreement she made. But the fact of the matter is there was something there. She mentioned that she wrote about it. And Jenna’s seeking a seat on the Select Board, a seat she held prior and resigned from it. I feel as though she would be a huge liability for the town to sit on the board again. She almost cost us, I would imagine, several million dollars in a lawsuit from the employee that was involved.”
134. Plaintiff, in a state of shock, interrupted and said, “Holy shit. I can’t believe you just said that.”
135. Defendant Decoste stated, “Yeah, I did.”
136. Plaintiff replied, “Wow. Wow.”
137. Defendant Decoste went on and said, “Beyond that, I don’t think we can trust someone who sent ransom notes through the mail to try to get somebody that she was a supervisor to to do something that she wanted them to do.”
138. Plaintiff can be heard saying, “Wow, wow, wow, wow.”
139. Defendant Decoste said, “You wrote about it.”
140. Plaintiff said, “I did write about it. You didn’t read it though, Chuck, so you don’t know what you’re talking about.” [Defendant Decoste uses “Chuck” instead of “Charles.”]
141. Defendant Decoste ended his statement with, “You know what you did; we know what you did; and I don’t think that would be a good fit for the Select Board.”
142. Defendant Decoste’s statement accused Plaintiff of having “sent ransom notes through the mail.”
143. Defendant Decoste’s statement was presented as a statement of fact, and not one of opinion, rhetoric, or hyperbole.
144. Defendant Decoste’s statement was, and remains, false.
145. By publicly accusing Plaintiff of having “sent ransom notes through the mail”—an act associated with and generally understood to be related to the commission of a crime, Defendant Decoste directly impugned Plaintiff’s honesty, integrity, and fitness to practice law, thereby irreparably harming Plaintiff’s professional reputation and capacity to earn a living.
146. Defendant Decoste’s conduct subjected Plaintiff to public contempt, ridicule, and reputational harm within the community.
147. Defendant Decoste’s actions were knowing, intentional, and undertaken with reckless disregard for the severe and foreseeable harm such accusations would cause to Plaintiff.
148. After 2024 Candidates’ Night, LCTV posted a link to 2024 Candidates’ Night to its LCTV YouTube channel.
149. According to Defendant/LCTV’s Executive Director Mark Crory, 2024 Candidates’ Night has been viewed three hundred and ninety-three (393) times.
150. On June 14, 2024, Plaintiff made a Public Records Request to the Keeper of Record of the Ayer Police Department, specifically for a copy of the police report or records relative to an incident that occurred “in early 1997, likely March 1997 at 21-23 Willard Street of and concerning Matthew King” regarding an “Allegation of rape.”
151. On June 21, 2024, Robert Mackie, the Department Assistant for the Ayer Police Department emailed the following to Plaintiff, “Good Morning, I received your request for a report related to Matthew King in March 2017. Unfortunately, at this time your request is denied for the below reason: In accordance with the Public Records Access Regulations, M.G.L. Chapter 4, §7(26) (a) – The Statute Exemption, Specifically Chapter 265 § 24C States any record containing an investigation or complaint of assault with intent to rape shall be withheld from public record.”
152. On June 21, 2024, Plaintiff replied by email to Mackie as follows: “Hold up, Mr. Mackie, I just check the two MGLs that you cited. I’m not interested in the victim’s identity, and that’s the only portion of the public report that is not subject to a Public Records request. The rest of what Ayer Police Department has relative to my request most certainly is a public record. You are still within the 10-day allotment to provide the record. Maybe you can speak to someone on your end and have that person read over the MGLs you cited so that I can get this request within the lawful time period. Thanks, and have a nice weekend, Jenna” [Emphasis from original email reply.]
153. On June 28, 2024, Plaintiff emailed Mackie the following: “Dear Mr Mackie, Will you be providing me the public record I’ve sought (in its redacted form, of course, to protect the victim’s identity) by the end of today? I do believe today is your ten-day deadline. Regards, Jenna”
154. On July 2, 2024, Mackie emailed Plaintiff the following: “Good Afternoon, You may appeal our response to the Supervisor of Public Records pursuant to 950 CMR 32.08(1)(d). By law, the Supervisor is required to respond within 10 business days of receipt of your appeal. You may also seek judicial review of an unfavorable response by commencing a civil action in the superior court, under G.L. c. 66, § 10A(c). I have provided there (sic) information below: CONTACT US Secretary of the Commonwealth Massachusetts Public Records Division One Ashburton Place Boston, MA 02108”
155. Soon thereafter, Plaintiff appealed Mackie’s lack of record production to the Secretary of the Commonwealth Massachusetts Public Records Division.
156. On July 18, 2024, Patrick Pierce from the Secretary of the Commonwealth Massachusetts Public Records Division directed Mackie to disclose whether there were any records held by Ayer Police Department that would be responsive to Plaintiff’s Public Record Request.
157. On August 1, 2024, Mackie emailed Plaintiff the following: “Good Morning, I received your appeal request for a report related to Matthew King in March 1997. We have researched our files and have located the report related to your request: 9701-202-OF. Unfortunately, at this time your request is denied for the below reason: Report 9701-202-OF falls within a Report of Rape, Sexual Assault or Domestic Violence and in accordance with the Public Records Access Regulations, M.G.L. Chapter 4, §7(26) (a) – The Statute Exemption, Specifically Chapter 41 § 97D States All reports of rape and sexual assault or attempts to commit such offenses shall not be public record.”
158. Ayer Police Department holds in its records Report # 9701-202-OF which relates to Plaintiff’s Public Records Request of June 14, 2024, i.e., about an incident “in early 1997, likely March 1997 at 21-23 Willard Street of and concerning Matthew King” regarding an “Allegation of rape.”
159. In Mackie’s August 1, 2024 email, Plaintiff was reminded of the appeals process with the Secretary of the Commonwealth.
160. On August 1, 2024, Plaintiff, by email, appealed Mackie’s lack of record production to Patrick Pierce at the Secretary of the Commonwealth Massachusetts Public Records Division by writing the following: “While I’m pleased that Ayer PD responded in time, on Day Ten, I’m disappointed, though not surprised, that once again, Ayer PD is denying my lawful public records request. Therefore, and I hope of no surprise to Ayer PD, once again, I write to you to formally appeal today’s denial of my public records request on the same grounds that I set forth on July 3, 2024, over four weeks ago, (see below) when Ayer PD denied my initial public record request on July 2, 2024. Nothing has changed. The law remains the same relative to public records of rape. The victim’s name is not public; the rest is. I respectfully request that you immediately direct the Ayer Police Department to release the public record it has in its possession, i.e., 9701-202-OF, with the victim’s identifying information redacted, of course. As before, I ask that you confirm receipt of this (second) appeal. Thank you for your diligence in this matter, Jenna Brownson”
161. On August 20, 2027, Plaintiff made a Public Records Request of the Records Access Officer for the Town of Ayer, Robert Pontbriand, requesting “My PRR is for any public records kept by either the Town of Ayer or the Ayer Police Department. Since March 1997, has anyone (apart from myself) made a Public Records Request for the record held by Ayer Police Department (seemingly labeled 9701-202-OF) that concerns an allegation of rape, Matthew King (deceased), and 21-23 Willard Street?”
162. On August 23, 2024, Plaintiff emailed the four men (Alex McCurdy, Jim Karr, Joseph Knox, and Ted Doucette) who served with Plaintiff (May 2013-March 2014) on Littleton’s (then-titled) Board of Selectmen the following: “Hello, Alex, Jim, Joe, and Ted, Recently, I made a public record request, seeking any record in the town’s possession that shows that the Board of Selectmen made its own public record request to the Ayer Police Department between February 11, 2014 (the day I brought the allegation that Matthew King had digitally raped a woman in Ayer) and whatever day in September 2014 that Matthew King was appointed by the four of you to be the chief law enforcement officer in Littleton. Diane was quick to point out that only town emails are searchable, and I was quick to remember that none of us used a town-based email. We all used our personal emails back then. So, I thought I’d ask the four of you if you might have in your email “sent” folder, the public record request that you sent to the Town of Ayer, seeking the public record, specifically the police report that investigated the allegation of that crime. Let me know if you find anything. Of course, if you would prefer to talk, I’m available: 978.760.0482. TTYS, Jkb P.S. If I don’t hear anything by Monday, I’ll presume nothing is forthcoming.”
163. On August 24, former Selectman Karr replied “all” the following: “I am trying to remember was this before or after……. A …… You tried to have an affair with a direct report to the Board of Selectmen while you where (sic) a Member OR B……. You brought your husband to one of our meetings with bail money because you thought you where (sic) getting arrested for blackmail Either way I have nothing for you and please delete any and all contact information you have for me as i (sic)NEVER let me repeat NEVER want to be contacted by YOU or any of your associatesagain.” [Emphasis Karr’s]
164. On August 24, 2024, Plaintiff replied “all” the following: “Thanks for getting back to me, Jim. I see you’re sticking to the defamatory script. Cool. Nothing from you. Got it. Gentlemen? What say the rest of you? Are you also going to adopt Jim’s narrative, or are you going to help me to ensure this sort of thing doesn’t happen again in town? Let me know, Jenna” On August 26, 2024, Plaintiff sent Alex McCurdy, Joseph Knox, and Ted Doucette the following: “Ted, Joe, and Alex, The world’s a different place from ten years ago Women are tired of it Ask around Ask your daughters and granddaughters That said, the general ignore-her strategy is duly noted (by myself and your daughters and granddaughters) Out of fairness, I’m going to let you know that if l don’t hear back from you by the end of the day–and you’re welcome to call if you don’t want to put anything in writing–I’m going to write you three an open letter, which you may then choose to further ignore but you’ll also be left to wonder who might not be ignoring me I’m running out of time and refuse to leave it this way”
165. Plaintiff did not and has not received a reply from Alex McCurdy.
166. Plaintiff did not and had not received a reply from Joseph Knox.
167. Plaintiff did not and has not received a reply from and Ted Doucette.
168. On August 27, 2024, Robert Mackie emailed Plaintiff the following: “Good Afternoon, I have received your request for any record related to a public records request for the Ayer Police Record 9701-202-OF other than yourself [Jenna Koerper Brownson]. We have researched our records and have found no records pertaining to your request.”
169. No one in 2014—elected to serve or employed by the Town of Littleton—requested the police record held by the Ayer Police Department alleging a rape committed by King as part of an investigation into King’s alleged criminal conduct prior to the Board of Selectmen appointing King to serve as Littleton’s chief of police.
170. On August 27, Mackie emailed Plaintiff the following: “Good Afternoon, I received your second appeal [SPR24/2181] request for a report related to Matthew King in March 1997. We have researched our files and have located the report related to your request: 9701-202-OF. Unfortunately, at this time your request is denied for the below reason: Report 9701-202-OF falls within a Report of Rape, Sexual Assault or Domestic Violence and in accordance with the Public Records Access Regulations, M.G.L. Chapter 4, §7(26) (a) – The Statute Exemption, Specifically Chapter 41 § 97D States All reports of rape and sexual assault or attempts to commit such offenses shall not be public record. You may appeal our response to the Supervisor of Public Records pursuant to 950 CMR 32.08(1)(d). By law, the Supervisor is required to respond within 10 business days of receipt of your appeal. You may also seek judicial review of an unfavorable response by commencing a civil action in the superior court, under G.L. c. 66, § 10A(c).”
171. On August 27, 2024, Plaintiff made a third appeal to the Secretary of the Commonwealth, specifically: “Dear Supervisor of Records, Will you be exercising your statutorily granted powers, as found in G.L. c. 66 sec. 10A(b), in this matter? I would appreciate knowing whether you intend to bring this matter to the attention of the Attorney General. Thank you for your time, Jenna”
172. On September 5, 2024, having not heard back from the Secretary, Plaintiff emailed the following: “Dear Supervisor of Records, The courtesy of a reply would be appreciated as to whether you intend to refer this matter to the Attorney General’s Office. I thank you in anticipation of your reply, Jenna”
173. Plaintiff did not receive any communication from the Secretary of the Commonwealth relative to its statutorily granted powers found in G.L. c. 66 sec. 10A(b).
174. On September 11, 2024, Littleton Police Department on its Facebook page “Littleton, MA Police Department” posted this: “The Littleton Police Department is proud to announce the installation of a memorial bench in front of the police station in honor of the late Chief Matthew King, who passed away on July 3, 2023. The bench stands as a permanent tribute to Chief King’s 36 years of dedicated service to the Littleton community. Chief King was hired in 1982 as a patrolman and held many other ranks, including Sergeant and Lieutenant. He eventually served as Chief from 2014 to 2018. As a Chief of Police, he was known for his steadfast commitment to public safety, his deep compassion for the residents of Littleton, and his leadership in advancing the department’s role in the community. His loss has been deeply felt by all who knew him, both within the department and across the town he devoted his life to protecting. This memorial bench is located outside the Littleton Police Station, it is accessible to the public, and provides a space for reflection and remembrance. This unique monument is just one of many ways his legacy will continue to live on.#RememberingChiefKingLittleton Community Television.” [Emphasis LPD’s Facebook page]
175. Plaintiff commented on LPD’s September 11, 2024 post writing, “May this monument see the same fate as those put up to honor Jefferson Davis.”
176. On October 31, 2024, Plaintiff sent an email, titled “Changing the Law” to Massachusetts State Senator Jamie Eldridge: “Dear Jamie, I’d like an hour of your time to discuss changing the law as it relates to the release of public records. When could you find time for that? Jenna”

177. On November 9, 2024, Plaintiff sent a follow-up email to Sen. Eldridge, which is as follows: “Hi, Jamie, Now that the election is over, I’m hopeful you will find time to meet with me. On Monday, as I held your sign for two hours, standing outside the Littleton Middle School, I was left wondering whether you, as my elected state senator, actually care about changing the law as it relates to public records. Here’s an article you might find of interest, presuming you have any interest at all: [Plaintiff provided a link to an October 22, 2022 NPR article titled “How a Massachusetts Law intended to protect sex assault victims protects perpetrators”] The title of the article alone indicates to me that the law needs to be changed.” Plaintiff provided her cell phone for ease of communication in the email. The title of the article alone indicates to me that the law needs to be changed.”
178. On November 10, 2024, Sen. Eldridge emailed Plaintiff the following: “Hi Jenna, sorry for the delay. It’s been a tough week, and extremely busy leading up to Election Day. I would be willing to meet with you, after Thanksgiving. However, I must admit I am a bit hesitant, because when I meet with constituents, it’s generally a confidential meeting, and one not written about online or on a blog. May I ask your intentions? In addition, I do hope you can appreciate that the language you use in reaching out to elected officials comes across as rather snide, self-righteous, and that only you know best. For example on public records, I have been extremely active on reforming our public records law, including the law major reform around 2014, and the Senate sponsor of the Sunlight Act. I have also worked on the major issue that is mentioned in the article you sent, but this session the coercive control and gun bills got all of the attention, in terms of domestic violence and the police. You wrote, “Here’s an article you might find of interest, presuming you have any interest at all.” I mean, why write “presuming you have any interest at all?” I don’t think you’ll find many other legislators who work on as many issues as I do, so I am confused by your hostility. Maybe you don’t mean it, but I hope I can be frank in commenting on how I took some of your email. Please write back when you can, and then my staff can arrange a time for us to meet. Sincerely, Jamie”
179. Having recently read, ON TYRANNY: TWENTY LESSONS FROM THE TWENTIETH CENTURY by Timothy Snyder, Plaintiff found Sen. Eldridge’s request for confidentiality as anti-American and opted not to reply to Sen. Eldridge’s “Comply in Advance” condition to speak about changing the law.
180. In mid-March 2025, Plaintiff submitted nominating papers so that Plaintiff’s name would appear on the ballot as a candidate for Littleton’s Select Board.
181. On March 25, 2025, Plaintiff wrote an open letter, titled “Open Letter to the Administrators of Facebook’s Constructive Conversations for Littleton” and posted it on Plaintiff’s Substack and on Plaintiff’s blog. The text of the post is as follows: “Dear Jan Huber OCallaghan, Erica Podgorni, Elieen Wedegartner, and Katie Carruth. Soon after I pulled nomination papers to run for a seat on our town’s Select Board, I reached out to one of the members of your Facebook group—Constructive Conversations for Littleton Women (CCLW)—and asked her to keep an eye out for anything that might be published in your group about me. You see, I suspected that once word got out that I was seeking elected office in town that, again, CCLW would allow untrue claims to be made about me. Within hours, my suspicions were confirmed. I received several screenshots containing false and defamatory statements, all of which cast doubt about my fitness for public office by placing me in a false light. I know for a fact that at least one of you knows that these statements were false. Moreover, I have reason to believe that all four of you know, or should have known, that what was being alleged was based on lies. And yet, you allowed the defamatory words to remain on the page and, in letting the chips fall where they may, allowed speculative negative comments to pile up. On Sunday evening, after much damage had been done to my reputation, I asked Jan who the administrators of the page were, on Monday afternoon she wrote, “Why do you ask?” I replied, “Jan, To my mind, yours is not a serious question I’d suggest you consider why I’d be asking who is in control of what is permitted on that page, a page that you all banned me from a year ago. I’m truly disgusted.” Her response: “Well, I for one, am doing my best to keep the conversations constructive, which is challenging. I am most interested in what the top 3 priorities of each of the candidates are. That’s what I’d like to see focused on.” My reply, “Your efforts are insufficient to counter the defamation that’s occurring on the page you manage.” Then, Jan wrote, “And how would you know that given that screenshots are against the rules as are reporting specific comments by specific people? Furthermore, this is something I volunteered to do. I am not a professional moderator nor to (sic) I strive to be. I am just doing what I can to try to contribute to constructive conversation. I’m no miracle worker. Jan’s evasive, distancing language gave me pause. Here was a moderator of a group with over two hundred members, ostensibly, women living in Littleton who have an interest in participating in “constructive conversations,” disclaiming nearly all responsibility for the content of these knowingly false posts and further asserting that only someone with god-like power would be able to effectively moderate the posts in CCLW. I wrote, “No one’s asking you to work miracles. I’m only suggesting you use some critical thinking skills and see how your failure to do so is allowing actionable speech to proliferate.” We are living in dangerous and unstable times. People are having a harder and harder time knowing what to believe and when community members, such as yourselves, fail to quash false statements—about me or any other person who becomes fodder for your “constructive” conversations—you become the handmaidens of misinformation. Truth matters, and by your willful disregard for the truth, you have damaged me. While I’ve been given to understand that some remediation has occurred, that some of these scabrous untruths have been removed, the damage has been done, and the case law is clear. Please take this open letter as my demand that you cease and desist from allowing future untruths to be published at CCLW. Furthermore, all past falsehoods—about me or anyone else you’ve allowed to be defamed at CCLW—ought to be removed. I’ll reiterate: I’m truly disgusted, Jenna”
182. On April 10, 2025, Plaintiff posted both on Plaintiff’s Substack and on Plaintiff’s blog the following, under the heading “The Memorialization of a Rapist”: “In 1997, a woman filed a police report with Ayer Police Department. In it, she alleged that Matt King had raped her. At the time, King was a sergeant with the Littleton Police Department, and Tom O’Dea was Littleton’s chief of police. After placing King on paid administrative leave “for reasons of my own as Police Chief,” O’Dea wrote a memorandum to all staff, dated March 27, 1997, informing them that this was “departmental business” and advising: “You may consider this a ‘gag order.’ ” People in positions of power and influence knew of King’s rape in 1997. They covered it up then. Seventeen years later, in 2014, Littleton Police Sergeant David Leslie informed the Littleton Board of Selectmen (as it was known at that time) of the rape allegation against King. Leslie further reported that King had paid his rape victim $25,000.00 to not move forward with the criminal case. Sergeant Leslie explained that King had borrowed money for the payoff, including $5,000.00 from a now-deceased Littleton business owner, who was later visited by two Littleton Police officers: then-sergeant Matthew Pinard (now Littleton PD’s police chief) and then-sergeant Jeff Patterson (now Littleton’s Deputy Police Chief). Reportedly, these two Littleton cops told the business owner that the debt would not be repaid. In 2014, when Sergeant David Leslie spoke out about the rape, people in positions of power and influence were told of King’s 1997 rape. Candidly, looking back now, it seems that many of those people in positions of power and influence already knew about the rape. One might presume that a full and exonerating investigation—which, at minimum, would’ve included getting a copy of the 1997 police report from Ayer PD—had occurred since King became chief on September 30, 2014. On August 19, 2024, I sent this public records request to Littleton’s TA and town clerk:

The next day, Littleton’s town clerk informed me that there were no records “responsive to this request,” that is, no records exist because back in 2014 no one in those positions of power in Littleton asked Ayer for the police report of King’s 1997 rape. Jim Karr didn’t ask for the report. Joe Knox didn’t ask for the report. Alex McCurdy didn’t ask for the report. Ted Doucette didn’t ask for the report. Keith Bergman didn’t ask for the report. Bonnie Holston didn’t ask for the report. Tom Harrington, Esq. didn’t ask for the report. Of course, Littleton’s town clerk couldn’t search the personal email accounts of those people. So, on August 20, 2024, I sent this public records request to Ayer:

On August 27, 2024, I received this:

Since 1997, no one except me has ever asked Ayer Police Department for the King rape report. In September 2024, this was published on the Littleton Police Department’s Facebook page:

For twenty-eight years, people in positions of power and influence have either actively engaged in covering up King’s rape or have kept quiet about this shameful open secret in our little town. Nearly three decades of the abuse of power and wielding of influence has resulted in the Town of Littleton having a memorial bench to King, installed on September 11, 2024, on Littleton-owned land, right in front of the police department. People in positions of power and influence have memorialized a rapist. My name will appear on the ballot for a seat on Littleton’s Select Board. Election Day is May 10, 2025. My first policy objective: Rid our town of the rapist’s bench. I don’t want to live in a town that allows this to happen. Do you?”

183. On April 11, 2025, Plaintiff posted the following at Plaintiff’s Substack and Plaintiff’s blog, under the title “The “Nothing to See for Now” LCC”: “On March 13, 2023, the Littleton Select Board’s agenda included “Cannabis Host Community Agreements.” When the agenda item came up at the Select Board meeting, the matter was postponed. To operate a cannabis business in Massachusetts, the cannabis business must hold a Host Community Agreement with the municipality where the business is conducted. In Littleton, the municipal entity that enters into HCAs with cannabis businesses is the Select Board, i.e., to get an HCA, the business needs the approval of the Select Board. One week later, on March 20, 2023, Gary Wilson and Chuck Decoste formed an LLC by filing a Certificate of Organization with the Secretary of the Commonwealth. At the time the LLC was formed, Wilson was the vice chair of the Littleton Select Board and Decoste was the board’s clerk. [Plaintiff’s post included screenshot of the Certificate of Organization.] After Middlesex (sic) Constable Services, LLC was formed, Wilson and Decoste were seen here in Littleton, opening a bank account: [Plaintiff’s post included photo of Middlesex Savings Bank in Littleton.] One week after Wilson’s and Decoste’s LLC was organized as a business entity, the Littleton Select Board took up the postponed agenda item relative to Cannabis Host Community Agreements. The minutes from that March 27, 2023 meeting are:

Neither Wilson nor Decoste registered their LLC with the Town of Littleton, i.e., no business certificate exists for Wilson’s and Decoste’s LLC at Littleton’s Clerk’s office despite the LCC’s Littleton address. Neither Wilson nor Decoste filed an annual report with the Secretary of the Commonwealth for 2024 or 2025 despite the requirement to do so. [Plaintiff’s post included the text of this requirement from the Corporations Division.] Minuteman Constable Services, LLC has no webpage, though it does have a LinkedIn account where the LLC’s activity is non-existent:

Gary Wilson and Chuck Decoste, the co-managers of Minuteman Constable Services, LLC, are, today, two of the five current members of Littleton’s Select Board. My name will appear on the ballot for a seat on Littleton’s Select Board. Election Day is May 10, 2025. My second policy objective: Get Minuteman Constable Services, LLC, i.e., Gary Wilson and/or Chuck Decoste, to disclose the banking records of their LLC.”

184. As with all other Candidates’ Nights, Plaintiff knew that LCTV would be livestreaming and recording 2025 Candidates’ Night for LCTV’s YouTube channel.
185. As with all other Candidates’ Nights, Plaintiff knew that LCTV would—post-recording—post a link to 2025 Candidates’ Night at LCTV’s YouTube channel.
186. On April 16, 2024, Plaintiff and Defendant Wilson—along with candidate Mark Rambacher—participated in the annual Rotary-sponsored Candidates’ Night as the three candidates for two Select Board seats.
187. LCTV broadcast 2025 Candidates’ Night live before a live audience who were permitted to submit questions anonymously.
188. Defendant Decoste was present in the audience at 2025 Candidates’ Night.
189. Plaintiff believed Defendant Nordhaus watched 2025 Candidates’ Night.

190. The candidates were asked by Town Moderator Tim Goddard, “Have you ever financially profited off of your board position as it relates to cannabis licenses?”

191. Defendant Wilson’s answer was as follows: “Absolutely not. It’s just a, is it a yes or no question? I mean, I really don’t have anything to add. You know, it’s no, and it’s a, it’s an affront to me. It’s an assault on me to have someone question my integrity, and the fact that that question exists, and I know why it exists. I’ve seen the, I was told to go look at a Facebook post. And you know, I can speak a little bit more on it, but I really don’t want to even give it credit because it’s so disgustingly inappropriate and wordy that, you know, I would say that it boarded lines on extortion. [Plaintiff can be heard laughing at this statement.] So, I want to be very careful to go any further on answering that question because I believe the state views, I know it’s funny, Ms. Bronson, but the state views extortion as someone that maliciously accuses someone of a crime to benefit themselves, and the benefit themselves here obviously is to be on the Select Board without any evidence in just absolute terms, makes this body a mockery at every level. So, I’m not going to, you know, go any further. I’m not going to attack Ms. Bronson, who I historically have had no issue with. [Defendant Wilson then addressed Plaintiff.] We, you know, we’re very cordial, I would say, with each other. I’ve never had any issue with Ms. Bronson until this one thing, so.”

192. Defendant Wilson repeatedly referred to Plaintiff using “Bronson,” not “Brownson.”

193. Immediately after Defendant Wilson’s statement, Plaintiff said, “I have a response because what I wrote did not allege that you had taken money. [Wilson scoffed.] Excuse me, I’ll just read it.”

194. Plaintiff then read Plaintiff’s April 11, 2025 post. [Paragraph 183 supra.]

195. Defendant Wilson’s statement accused Plaintiff of having committed the crime of extortion, a criminal offense involving moral turpitude.

196. Defendant Wilson’s statement was presented as a statement of fact, and not one of opinion, rhetoric, or hyperbole.
197. Defendant Wilson’s statement was, and remains, false.
198. By publicly accusing Plaintiff of extortion, Defendant Wilson directly impugned Plaintiff’s honesty, integrity, and fitness to practice law, thereby irreparably harming Plaintiff’s professional reputation and capacity to earn a living.
199. Defendant Wilson’s conduct subjected Plaintiff to public contempt, ridicule, and reputational harm within the community.
200. Defendant Wilson’s actions were knowing, intentional, and undertaken with reckless disregard for the severe and foreseeable harm such accusations would cause to Plaintiff.
201. After 2025 Candidates’ Night, LCTV posted a link to 2025 Candidates’ Night to its LCTV YouTube channel.
202. On April 17, 2025, on the morning after Candidates’ Night 2025, Plaintiff posted the following, titled “Now in the Permanent Public Record,” at Plaintiff’s Substack and on Plaintiff’s blog: “After gathering sixty-two signatures, ensuring my name would be on the ballot, I knew I’d be invited to Candidates’ Night. I also knew the event would be recorded by LCVT, making it part of the permanent public record of the Town of Littleton. My blog and my Substack are not part of the public record, and the people I’ve written about have dismissed much, if not all, of what I’ve shared, encouraging people to “ignore her.” Last night, I made myself unignorable. I did this so that I could put into the permanent public record our town’s open secret of a decadeslong cover-up of a rape, committed by a Littleton police officer, and the Board of Selectmen who did nothing to stop that man from becoming Littleton’s police chief in 2014. Today, and since September 11, 2024, a memorial bench to this rapist has been sitting right outside LPD, and it must be removed. No future victim of rape should have to walk past that when seeking the help of our police, and no person of conscious, including the good cops out there, should tolerate the bench’s ongoing presence outside a house built to protect and serve the people of our town, most especially the future victims of violent sexual crimes. That was only reason* I got into the race: to get a seat at Candidates’ Night to advocate for the removal of the rapist’s bench and to put into the permanent public record what happened in 1997, in 2014, and what is happening right now. Two hundred nineteen days and counting. People in positions of power, pointedly the police and elected officials, have known about the rape and the cover-up since 1997, and now, after Candidates’ Night, the rest of you know as well. The recording can be found HERE. [The link to LCTV’s YouTube recording of Candidates’ Night 2025 was included in Plaintiff’s post.] You can start at 55:30. * I have since come up with various other policy objectives.”
203. On October 29, 2025, Plaintiff wrote the following email to Defendant Crory: “Dear Mark, I hope this email finds you well. I’ve spent quite a bit of time scouring the LCTV Youtube channel in search of the recording of the most recent Rotary Candidates’ Night, i.e., 2025. No luck. Would you please send me the link? Thanks, Jenna”
204. Before Defendant Crory replied to Plaintiff’s email, Plaintiff sent a follow-up email, which reads as follows: “Update: I found the link to the video. When I click on it, this comes up:

Why is this video now “private” and “unavailable?” And, more importantly, who designated this video as “private” and “unavailable?” I look forward to your reply, Jenna”

205. Defendant Crory replied by email only, “Jenna, I can make a copy of the Candidates Night 2025 for you. Do you want it on a flash drive or a DVD? Mark”
206. Plaintiff replied by email as follows: “Hi, Mark, Frankly, I’d like to see the video available online, where it ought to be. And I renew my questions: Why is this video now “private” and “unavailable?” And, more importantly, who designated this video as “private” and “unavailable?” Jenna”
207. Defendant Crory replied by email with “The video ran right up to and including Election Day in May of 2025. I designated the video Private after the election. If you would like a copy, I will make you one. You can then do with it as you see fit. Mark.”
208. Plaintiff replied by email, “Well, Mark, to be fair, every other Candidates’ Night is available at the LCTV’s Youtube channel. Yes, I would like a copy. I can come by today to get it. Shall I bring my own flash drive, or are you providing one? Jenna.”
209. Later that day, on October 29, 2025, Plaintiff went to the LCTV studios and received a flash drive with Candidates’ Night 2025 from Defendant Crory.
210. On November 3, 2025, Plaintiff emailed the following to Defendant Crory: “Mark, Five days ago, when I asked why Candidates’ Night 2025 had been made ‘private’ and ‘unavailable’ at LCTV’s Youtube channel, all the other Candidates’ Nights were neither private and nor unavailable at LCTV’s Youtube channel. Today, however, a search of LCTV’s channels shows, as of this moment, only one available. It seems someone has made all but the 2022 Candidates’ Nights ‘private’ and ‘unavailable.’ Was this your doing, or were you directed to remove them all (except the one which was seemingly overlooked) by someone else? If you were following orders, who made the orders? Looking forward to your reply, Jenna”
211. Defendant Crory replied by email with, “Jenna – Thanks for letting me know. I guess I missed one. You had pointed out to me that the others were still available, so I made them private. If anyone, like yourself, wants to get a copy of a past candidate’s night it’s a lot easier to make one from the YouTube video than finding the DVD.”
212. According to Defendant/LCTV’s Executive Director Mark Crory, 2025 Candidates’ Night had been viewed six hundred and twenty-two (622) times from the time of posting, on or about April 17, 2025, to the date of removal by Defendant Crory, on or about May 10, 2025.
213. Plaintiff did not and had not “blackmailed the Chief of Police” despite Defendant Podgorni’s statement to the contrary,
214. Plaintiff did not exercise any “abuse of authority” despite Defendant Nordhaus’s statement to the contrary.
215. Plaintiff did not commit “sexual harassment” despite Defendant Nordhaus’s statement to the contrary.
216. Plaintiff did not commit “attempted extortion” despite Defendant Nordhaus’s statement to the contrary.
217. Plaintiff did not commit “corruption” despite Defendant Nordhaus’s statement to the contrary.
218. Plaintiff never “sent ransom note through the mail” despite Defendant Decoste’s statement to the contrary.
219. Plaintiff did not commit “extortion” despite Defendant Wilson’s statement to the contrary.
220. Defendant Crory allowed and broadcast, i.e., published, Defendants’ Nordhaus’s, Decoste’s, and Wilson’s defamatory statements to the community of Littleton and beyond as the Executive Director of LCTV by posting the September 5, 2023 Select Board Meeting (Defendant Nordhaus), 2024 Candidate’s Night (Defendant Decoste), and 2025 Candidates’ Night (Defendant Wilson).
221. Plaintiff has never been arrested for the criminal conduct alleged by Defendants Podgorni, Nordhaus, Decoste, and Wilson.
222. Plaintiff has never been charged for the criminal conduct alleged by Defendants Podgorni, Nordhaus, Decoste, and Wilson.
223. Plaintiff has never been indicted for the criminal conduct alleged by Defendants Podgorni, Nordhaus, Decoste, and Wilson.
224. No Complaint has been filed against Plaintiff for the criminal conduct alleged by Defendants Podgorni, Nordhaus, Decoste, and Wilson.
225. For the last twelve (12) years, Plaintiff has spoken and written about the cover-up of former Police Chief King’s rape, criticizing both the police and the board that supervises the police, i.e., the then-Board of Selectmen/current-Select Board.
226. Beginning in July 2023—with the publication of POT TWIST—Plaintiff has spoken and written about the actions and non-actions the Select Board (of whom Defendants Nordhaus, Decoste, and Wilson were/are members at all relevant times) took relative to the municipal licensing of cannabis businesses in town.
227. Plaintiff undertook speaking and writing about town-related issues, believing that citizens of Littleton would want to know about these matters of public interest.
228. In response to Plaintiff’s criticism, people in positions of power and authority—Defendant/Facebook moderator of “Constructive Conversations for Littleton Women” Podgorni in February 2023, Defendant/Selectboard Member Nordhaus in September 2023, Defendant/Select Board Member Decoste in April 2024, and Defendant/Select Board member Wilson in April 2025—have written and spoken lies about Plaintiff, effectively ruining Plaintiff’s capacity to earn a living as a lawyer.
229. In 2021, Plaintiff’s law/mediation practice earned forty-three thousand five hundred one dollars ($43,501.00).
230. Plaintiff’s 2021 earnings were realized primarily in the second half of 2021 after the COVID vaccine became available and people began to emerge out of the pandemic.
231. In 2022, Plaintiff’s law/mediation practice earned seventeen thousand nine hundred twenty-five dollars ($17,925.00).
232. In 2023, Plaintiff’s law/mediation practice earned four thousand six hundred nine dollars ($4,609.00).
233. In 2024, Plaintiff’s law/mediation practice earned ten thousand fifty-three dollars ($10,053.00).
234. In 2025, Plaintiff’s law/mediation practice earned two thousand one hundred fifty dollars ($2,150) from five (5) short-term clients.
235. To date, in 2026, Plaintiff has had zero income ($0.00) and has had to loan Plaintiff’s law/mediation practice one thousand nine hundred dollars ($1,900.00) from personal saving to cover operating expenses.

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V. COUNT I — DEFAMATION (PER SE)

AGAINST DEFENDANTS PODGORNI, NORDHAUS, DECOSTE, WILSON, and CRORY

236. Plaintiff repeats, realleges, and incorporates by reference Paragraphs 1 through 235 as if fully set forth herein.

237. Defendants published statements to third parties accusing Plaintiff of criminal conduct, including but not limited to allegations that Plaintiff had:

a. “Blackmailed the Chief of Police.” (Defendant Podgorni);

b. Exercised an “abuse of authority,” committed “sexual harassment,” “attempted extortion,” and committed “corruption.” (Defendant Nordhaus);

c. “Sent ransom notes through the mail.” (Defendant Decoste);

d. Committed “extortion.” (Defendant Wilson).

238. These statements were published in public Facebook groups (Defendant Podgorni), during a publicly held Select Board Meeting (Defendant Nordhaus), during 2024 Candidates’ Night (Defendant Decoste), and during 2025 Candidates’ Night (Defendant Wilson).

239. LCTV, under the leadership of Defendant Crory, posted the publicly held Select Board Meeting of September 5, 2024, 2024 Candidates’ Night, and 2025 Candidates’ Night on LCTV’s YouTube channel.
240. The statements made by Defendants Podgorni, Nordhaus, Decoste, and Wilson were statements of fact, or were presented as factual assertions, not mere opinion or rhetorical hyperbole.
241. The Defendants’ statements were and are false.
242. Plaintiff has never committed blackmail, extortion, or sent ransom notes, and no criminal charge, investigation, or finding supports such accusations.
243. Accusations of blackmail, extortion, and ransom constitute allegations of serious crimes involving moral turpitude.
244. Such accusations constitute defamation per se under Massachusetts law.
245. As a direct and proximate result of Defendants’ publication of these false statements, Plaintiff suffered:

a. Damage to reputation;

b. Damage to professional standing as an attorney in good standing;

c. Harm to earning capacity;

d. Emotional distress;

e. Other consequential damages.

COUNT II — 42 U.S.C. § 1983: FIRST AMENDMENT RETALIATION

AGAINST DEFENDANTS NORDHAUS, DECOSTE, WILSON, and CRORY AS INDIVIDUAL DEFENDANTS ACTING UNDER COLOR OF STATE LAW

246. Plaintiff repeats, realleges, and incorporates by reference Paragraphs 1 through 245 as if fully set forth herein.

247. At all relevant times, Defendants Nordhaus, Wilson, Decoste, and Crory were acting under color of state law and within the scope of their authority as officials/employes and thereby agents of the Town of Littleton.

248. Plaintiff engaged in constitutionally protected activity, including:

a. Publishing GINNED UP and POT TWIST;

b. Speaking publicly about alleged governmental misconduct;

c. Petitioning the government concerning cannabis licensing and public corruption;

d. Accepting appointment to the Finance Committee.

249. Plaintiff’s speech addressed matters of public concern: police misconduct, criticism of public officials, an alleged governmental cover-up, municipal licensing practices, and campaign speech.

250. Defendants were aware of Plaintiff’s protected speech and petitioning activity.

251. In response to Plaintiff’s protected speech and petitioning activity, Defendant Nordhaus publicly accused Plaintiff, in his official capacity at a Select Board meeting, of abuse of authority, sexual harassment, attempted extortion, and corruption from his seat at the Select Board table during the Select Board’s September 5, 2023 open, public meeting.

252. Defendant Nordhaus further amplified these accusations by publishing them on his official Facebook page titled “Matthew Nordhaus, Littleton Select Board.”

253. Defendants Wilson and Decoste, both present at the September 5, 2023 meeting, failed to correct or disavow the knowingly false accusations made under color of state law.

254. Defendant Crory, through LCTV, broadcast and preserved the defamatory accusations from the September 5, 2023 Select Board Meeting as official municipal programming.

255. In response to Plaintiff’s protected speech and petitioning activity, Defendant Decoste—during 2024 Candidates’ Night, from behind the debate table as a candidate for reelection to the Select Board—publicly accused Plaintiff of having “sent ransom notes through the mail”—an act associated with and generally understood to be related to the commission of a crime.

256. Defendant Wilson was present at 2024 Candidates Night and failed to correct or disavow the knowingly false accusation—by a fellow Select Board member—made under the color of state law.

257. Defendant Crory, through LCTV, broadcast and preserved the defamatory accusations from 2024 Candidates; Night as official municipal programming.

258. In response to Plaintiff’s protected speech and petitioning activity, Defendant Wilson—during 2025 Candidates’ Night, from behind the debate table as a candidate for reelection to the Select Board—publicly accused Plaintiff of “extortion,” explicitly referencing Plaintiff’s writing and defining “extortion” in criminal terms and relating the same to Plaintiff’s campaign.

259. Defendant Decoste was present at 2025 Candidates Night and failed to correct or disavow the knowingly false accusation—by a fellow Select Board member—under the color of state law.

260. Defendant Crory, through LCTV, broadcast and preserved the defamatory accusations from 2025 Candidates; Night as official municipal programming.

261. Defendants’ actions—publicly accusing a political critic of criminal conduct—would deter a person of ordinary firmness from continuing to engage in protected speech and petitioning activity.

262. Defendants’ actions were motivated, at least in substantial part, by Plaintiff’s protected speech and petitioning activity.

263. Defendants’ conduct would chill and did chill Plaintiff’s exercise of Plaintiff’s First Amendment rights.

264. It was clearly established at the time of the Defendants’ conduct that governmental officials may not retaliate against an individual for engaging in protected political speech and petitioning activities.

265. Defendants are therefore not entitled to qualified immunity.

266. As a direct and proximate result of Defendants’ coordinated publication of false criminal accusations, Plaintiff suffered reputational injury, emotional distress, constitutional injury, economic harm, and community isolation though Defendants’ manufacturing of public doubt in Plaintiff’s ability to serve in public roles.

COUNT III — 42 U.S.C. § 1983: SECOND AMENDMENT RETALIATION/DEPRIVATION

AGAINST DEFENDANT PINARD AS INDIVIDUAL DEFENDANT ACTING UNDER COLOR OF STATE LAW

267. Plaintiff repeats, realleges, and incorporates by reference Paragraphs 1 through 266 as if fully set forth herein.

268. Plaintiff has rights protected under the Second Amendment to the United States Constitution.

269. Defendant Pinard, as the final authority for the granting of gun licenses to residents of Littleton, Massachusetts—of which Plaintiff was one at all relevant times—ignored Plaintiff’s inquiry relative to securing for herself a gun permit.

270. Defendant Pinard engaged in passive retaliatory conduct toward Plaintiff based on Plaintiff’s historical criticism of the Littleton Police Department, which counts as Plaintiff exercising constitutionally protected rights, including protected speech critical of Littleton Police Department.

271. Defendant Pinard’s adverse governmental action prohibited Plaintiff’s lawful exercise of Second Amendment rights and was done so under color of state law and without lawful justification.

272. Governmental retaliation, through passive rejection of Plaintiff’s interest in securing a gun permit, violated Plaintiff’s Second Amendment rights.

273. Plaintiff’s denied Second Amendment right by Defendant Pinard was based on Plaintiff’s exercise of First Amendment rights, i.e., protected speech and petitioning activity.

274. As a result of such conduct, Plaintiff suffered constitutional injury and is unable to defend herself with a firearm in violation of Plaintiff’s Second Amendment right to do so.

COUNT IV — 42 U.S.C. § 1983: FIRST AMENDMENT VIEWPOINT DISCRIMINATION AND RETALIATORY SUPPRESSION

AGAINST DEFENDANT CRORY AS INDIVIDUAL DEFENDANT ACTING UNDER THE COLOR OF SATE LAW

275. Plaintiff repeats, realleges, and incorporates by reference Paragraphs 1 through 274 as if fully set forth herein.

276. Candidates’ Nights and their recordings by LCTV constituted a public forum or limited public forum for political expression.
277. Following Plaintiff’s critical protected speech, Defendant Crory caused the removal, privatization, and/or restriction of public access to recordings of the event.
278. Such removal departed from historical practice in which recordings remained publicly accessible.
279. The removal or restriction was motivated, in whole or in part, by Defendant Crory’s disagreement with Plaintiff’s viewpoint.
280. Viewpoint discrimination in a public forum violates the First Amendment.
281. As a direct and proximate result, Plaintiff suffered harm.

282. Defendant Crory’s conduct, as an agent for the state and under color of state law, violated Plaintiff’s rights under the First Amendment to the United States Constitution, actionable under 42 U.S.C. § 1983.

COUNT V — MUNICIPAL LIABILITY: MONELL CLAIM

AGAINST DEFENDANT TOWN OF LITTLETON, LITTLETON POLICE DEPARTMENT, AND LCTV

283. Plaintiff repeats, realleges, and incorporates by reference Paragraphs 1 through 282 as if fully set forth herein.

284. The Town of Littleton is a municipal entity subject to liability under 42 U.S.C. § 1983 pursuant to Monell v. Department of Social Services of the City of New York, 436 U.S. 658 (1978).

285. The constitutional violations described herein were caused by:

a. Official policies, customs, or practices of the Town of Littleton, Massachusetts;
b. Decisions of final municipal policymakers; and/or
c. Deliberate indifference to constitutional rights.

286. Members of the Select Board act as final policymakers for the Town of Littleton with respect to public governance, official communications, and many public appointments.

287. Defendant Nordhaus’s public accusations were made from the official Select Board dais, during an official open public meeting, livestreamed and later held out by LCTV as official municipal content.
288. Defendant Decoste’s public accusations were made as a candidate for reelection during 2024 Candidates’ Night, an official town event which was livestreamed and later held out by LCTV as official municipal content.
289. Defendant Wilson’s public accusations were made as a candidate for reelection during 2025 Candidates’ Night, an official town event which was livestreamed and later held out by LCTV as official municipal content.
290. The Town of Littleton ratified and adopted the conduct by:

a. Allowing the accusations to stand uncorrected;

b. Broadcasting and archiving the statements through LCTV;

c. Failing to discipline or repudiate the constitutional violations.

291. The Littleton Police Department, through Chief Pinard, maintained customs or practices of suppressing and retaliating against speech critical of the Department.

292. LCTV, as a Town-controlled media arm, functioned as a municipal instrumentality in broadcasting and preserving retaliatory content which contained false statements about Plaintiff that alleged criminal conduct by Plaintiff.
293. The Town’s failure to train, supervise, and discipline officials regarding constitutional limits on retaliation against protected speech constitutes deliberate indifference.
294. The municipal policies and customs were the moving force behind the constitutional violations suffered by Plaintiff.
295. As a direct and proximate result of these municipal policies and customs, Plaintiff suffered deprivation of her constitutional rights.
296. Plaintiff’s damages exceed $75,000.

COUNT VI — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

AGAINST ALL DEFENDANTS

297. Plaintiff repeats, realleges, and incorporates by reference Paragraphs 1 through 296 as if fully set forth herein.

298. Defendant Podgorni’s conduct—including repeatedly and publicly accusing Plaintiff of committing a serious crime, amplifying that accusation in multiple public forums, and continuing to reassert Plaintiff’s alleged criminality while exercising authority as a group moderator—was extreme and outrageous, and exceeded all bounds of decency tolerated in a civilized society.
299. Defendant Podgorni intended to cause Plaintiff emotional distress, or acted with reckless disregard of the high probability that Defendant Podgorni’s conduct would cause such distress.
300. Defendant Podgorni knew or reasonably should have known that falsely accusing an attorney and former public official of blackmailing the Chief of Police would foreseeably cause severe emotional harm.
301. As a direct and proximate result of Defendant Podgorni’s conduct, Plaintiff suffered severe emotional distress, including anxiety, depression, distress, and harm to personal and professional well-being.
302. As a direct and proximate result of Defendant Podgorni’s conduct, Plaintiff suffered a panic attack, resulting in a fractured tooth.
303. Defendant Podgorni’s conduct was a substantial factor in causing Plaintiff’s emotional distress and permanently damaged body, i.e., the fractured tooth that over the last three years has fallen out in pieces and will need to be fully extracted.
304. Defendant Nordhaus’s conduct—including publicly accusing Plaintiff of committing the crime of attempted extortion, abuse of authority, sexual harassment, and corruption and then further amplifying that accusation on his political Facebook page, which was shared widely—was extreme and outrageous, and exceeded all bounds of decency tolerated in a civilized society.
305. Defendant Nordhaus intended to cause Plaintiff emotional distress, or acted with reckless disregard of the high probability that Defendant Nordhaus’s conduct would cause such distress.
306. Defendant Nordhaus knew or reasonably should have known that falsely accusing an attorney and former public official of attempted extortion, abuse of authority, sexual harassment, and corruption would foreseeably cause severe emotional harm.
307. As a direct and proximate result of Defendant Nordhaus’s conduct, Plaintiff suffered severe emotional distress, including anxiety, depression, distress, and harm to personal and professional well-being.
308. Defendant Nordhaus’s conduct was a substantial factor in causing Plaintiff’s emotional distress.
309. Defendant Decoste’s conduct—including publicly accusing Plaintiff of having “sent ransom notes through the mail,” an act associated with and generally understood to be related to the commission of a crime—was extreme and outrageous, and exceeded all bounds of decency tolerated in a civilized society.
310. Defendant Decoste intended to cause Plaintiff emotional distress, or acted with reckless disregard of the high probability that Defendant Decoste’s conduct would cause such distress.
311. Defendant Decoste knew or reasonably should have known that falsely accusing an attorney and former public official of having “sent ransom notes through the mail” would foreseeably cause severe emotional harm.
312. As a direct and proximate result of Defendant Decoste’s conduct, Plaintiff suffered severe emotional distress, including anxiety, depression, distress, and harm to personal and professional well-being.
313. Defendant Decoste’s conduct was a substantial factor in causing Plaintiff’s emotional distress.
314. Defendant Wilson’s conduct—including publicly accusing Plaintiff of “extortion”—was extreme and outrageous, and exceeded all bounds of decency tolerated in a civilized society.
315. Defendant Wilson intended to cause Plaintiff emotional distress, or acted with reckless disregard of the high probability that Defendant Wilson’s conduct would cause such distress.
316. Defendant Wilson knew or reasonably should have known that falsely accusing an attorney and former public official of “extortion” would foreseeably cause severe emotional harm.
317. As a direct and proximate result of Defendant Wilson’s conduct, Plaintiff suffered severe emotional distress, including anxiety, depression, distress, and harm to personal and professional well-being.
318. Defendant Wilson’s conduct was a substantial factor in causing Plaintiff’s emotional distress.
319. Defendant Crory’s conduct—livestreaming, broadcasting, and holding out defamatory content, wherein Plaintiff was accused of criminality, as official municipal content—was extreme and outrageous, and exceeded all bounds of decency tolerated in a civilized society.
320. Defendant Crory intended to cause Plaintiff emotional distress, or acted with reckless disregard of the high probability that Defendant Crory’s conduct would cause such distress.
321. Defendant Crory knew or reasonably should have known that publicizing false statements accusing an attorney and former public official of criminality would foreseeably cause severe emotional harm.
322. As a direct and proximate result of Defendant Crory’s conduct, Plaintiff suffered severe emotional distress, including anxiety, depression, distress, and harm to personal and professional well-being.
323. Defendant Crory’s conduct was a substantial factor in causing Plaintiff’s emotional distress.
324. Defendant Pinard’s conduct—ignoring Plaintiff’s inquiry on how to secure a gun permit, knowing Plaintiff’s decadeslong vegetarianism and fear of retaliation from those who Plaintiff criticized in Plaintiff’s writing—was extreme and outrageous, and exceeded all bounds of decency tolerated in a civilized society.
325. Defendant Pinard intended to cause Plaintiff emotional distress, or acted with reckless disregard of the high probability that Defendant Pinard’s conduct would cause such distress.
326. Defendant Pinard knew or reasonably should have known that Plaintiff was living in fear and wished to protect herself through becoming licensed to have a gun.
327. As the statutory “final authority” on gun permits in Littleton, Defendant Pinard ought to have been able to foresee the severe emotional harm this would cause Plaintiff.
328. As a direct and proximate result of Defendant Pinard’s conduct, Plaintiff suffered severe emotional distress, including anxiety, depression, distress in believing that Plaintiff would never be allowed a gun permit since the “final authority” did not have the interest in even replying to Plaintiff’s inquiry.
329. Defendant Pinard’s conduct, and Plaintiff’s subsequent inability to arm herself for protection, was a substantial factor in causing Plaintiff’s emotional distress.

COUNT VII – DECLARATORY AND INJUNCTIVE RELIEF

330. Plaintiff repeats, realleges, and incorporates by reference Paragraphs 1 through 329 as if fully set forth herein.

331. An actual controversy exists regarding Defendants’ ongoing violation of Plaintiff’s constitutional rights.
332. Plaintiff seeks declaratory judgment that Defendants’ actions violated the First and Second Amendments.
333. Plaintiff further seeks injunctive relief prohibiting further retaliatory conduct and requiring removal of unconstitutional publications made under color of state authority.
334. Defendants’ actions have caused ongoing reputational harm.
335. There exists a substantial likelihood of continued repetition or dissemination of the defamatory statements.
336. Plaintiff lacks an adequate remedy at law to prevent ongoing harm.
337. Issuance of such injunctive relief is necessary to prevent further irreparable harm, preserve the status quo, and prevent spoliation of evidence.

COUNT VIII – ATTORNEY’S FEES Under 42 U.S.C. § 1988

338. Plaintiff repeats, realleges, and incorporates by reference Paragraphs 1 through 337 as if fully set forth herein.

339. Pursuant to 42 U.S.C. § 1988, Plaintiff is entitled to reasonable attorney’s fees and costs upon prevailing on her § 1983 claims.

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VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court:

A. Enter judgment in favor of Plaintiff and against all Defendants on all Counts;

B. Award general and special damages in an amount exceeding $75,000, exclusive of interest and costs;

C. Award damages for emotional distress;

D. Award punitive damages to the extent permitted by law;

E. Grant preliminary and permanent injunctive relief as follows:

a. Order removal of defamatory posts and recordings;
b. Prohibit further publication of false criminal accusations; and
c. Order the preservation of all electronically stored information related to the allegations (Facebook posts, Moderator logs, Private messages, Municipal emails, Communications on personal devices, text messages), including all communications—past, present, and future—between and among the Defendants;

F. Grant declaratory judgment that Defendants’ actions violated the First and Second Amendments;

G. Order the removal of the King memorial bench from Littleton town property, i.e., from where it was installed outside the front door of Littleton Police Department; and

H. Award costs, interest, and such other relief as the Court deems just and proper.

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IX. JURY DEMAND

Plaintiff demands a trial by jury on all issues so triable.

Respectfully submitted,

/s/ Jenna Koerper Brownson

Jenna Koerper Brownson, JD (Pro Se)

142 Harvard Road

Littleton, MA 01460

978.760.0482

jenna_koerper_brownson@yahoo.com

DATED: February 23, 2026

For those readers with the patience to have gotten through my Complaint, I’ll be back tomorrow with why I’m doing this and why I’m doing this now.

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