Kovalesky V Tabar Answer

John G.
Balestriere
Jillian L. McNeil
BALESTRIERE, FARIELLO & ABRAMS LLP
225 Broadway, 29
th
Floor
New York, NY 10007
Telephone: (212) 374-5401
Facsimile: (212) 208-2613
john.balestriere@balestrierefariello.com
jillian.mcneil@balestrierefariello.com
Attorneys for Defendant-Counterclaim Plaintiff

SUPREME COURT OF THE STATE OF NEW YORK,
NEW YORK COUNTY

ANGELA KOVALESKY,

Plaintiff,

-against-

SAMIR TABAR,
Defendant.

Index No. 151034/2014

VERIFIED ANSWER AND
COUNTERCLAIMS

SAMIR TABAR,

Counter-Plaintiff,

-against-

ANGELA KOVALESKY,

Counter-Defendant.

Defendant Samir Tabar (Tabar), by and through his attorneys, Balestriere,
Fariello & Abrams LLP, upon information and belief, denies each and every allegation
FILED: NEW YORK COUNTY CLERK 03/24/2014
INDEX NO. 151034/2014
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 03/24/2014

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of the Plaintiffs (Plaintiff or Kovalesky) Verified Complaint (the Verified
Complaint), except as follows:
1. Tabar denies the allegations asserted in paragraph 1 of the Verified
Complaint.
Complaint.
3. Tabar admits that he texted one member of Plaintiffs family regarding
Plaintiffs drug use. Tabar denies the remaining allegations asserted in paragraph 3 of
the Verified Complaint.
Complaint.
Complaint.
6. Upon information and belief, Tabar denies the allegations asserted in
paragraph 6 of the Verified Complaint.
Complaint.
Complaint.
9. Paragraph 9 states a legal conclusion to which no response is required.
10. Paragraph 10 states a legal conclusion to which no response is required.

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11. Tabar denies knowledge or information sufficient to form a belief as to the
truth of the allegations asserted in paragraph 11 of the Verified Complaint.
12. Tabar admits the allegations asserted in paragraph 12 of the Verified
Complaint.
Complaint.
Complaint.
Complaint.
Complaint.
Complaint.
Complaint.
Complaint.
Complaint.

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22. Tabar denies the allegations contained in the first sentence of paragraph
22 of the Verified Complaint. Tabar denies knowledge or information sufficient to form
a belief as to the truth of the allegations asserted in paragraph 22 of the Verified
Complaint.
28. Tabar denies that he abuse[d] Plaintiff and denies knowledge or
information sufficient to form a belief as to the truth of the remaining allegations
asserted in paragraph 28 of the Verified Complaint.
30. Tabar admits that he texted Plaintiffs sister regarding Plaintiffs drug use.
Tabar denies the remaining allegations contained in paragraph 30 of the Verified
Complaint.

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31. Denied as the alleged text message referenced in paragraph 30 of the
Verified Complaint, to the extent it exists, speaks for itself.
32. Admitted that on February 26, 2013, Tabar sent an email to
info@catholicpartnership.com.
33. Tabar denies the allegations contained in paragraph 33 of the Verified
Complaint.
35. Tabar denies that he made good on any threat. Tabar denies knowledge
or information sufficient to form a belief as to the truth of the remaining allegations

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Complaint.
43. Paragraph 43 is an improper attempt to use settlement communications as
evidence in violation of CPLR 4547 and should be stricken from the Complaint and
ignored by the Court.
44. Paragraph 44 is an improper attempt to use settlement communications as
evidence in violation of CPLR 4547 and should be stricken from the Complaint and
ignored by the Court.
45. Tabar admits that he had a conversation with Plaintiff over the phone on
May 30, 2013. Tabar denies knowledge or information sufficient to form a belief as to
the truth of the remaining allegations asserted in paragraph 45 of the Verified
Complaint.
47. Tabar admits that after goading him into communications on several
occasions, as Plaintiff admits in the Verified Complaint (see Verified Complaint at 37),
that Kovalesky filed a police report for those communications.
48. Tabar denies any suggestion that he led Kovalesky to believe that he may
come to her residence and further denies any knowledge or information sufficient to

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form a belief as to the truth of the remaining allegations asserted in paragraph 48 of the
Verified Complaint.
49. Tabar admits the allegations asserted in paragraph 45 of the Verified
Complaint.
50. Tabar admits that, based on false allegations, Kovalesky filed a Family
Offense Petition against him and obtained a Temporary Order of Protection on June 25,
2013 through the Kings County Family Court. Tabar denies the remaining allegations
Complaint.
Complaint.
53. Tabar admits that his attorney sent letters to Plaintiffs counsel regarding
public events. Tabar denies the remaining allegations asserted in paragraph 53 of the
Verified Complaint.
54. Tabar denies that he engaged in any campaign. Tabar denies
knowledge or information sufficient to form a belief as to the truth of the remaining
allegations asserted in paragraph 41 of the Verified Complaint.
ANSWER TO FIRST CAUSE OF ACTION
55. Tabar incorporates by reference each of the responses asserted in
paragraphs 1-54, as if set forth again in full.

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Complaint.
Complaint.
Complaint.
Complaint.
Complaint.
ANSWER TO THE SECOND CAUSE OF ACTION
Complaint.
63. Tabar denies that the petition he filed was false and further denies
knowledge or information sufficient to form a belief as to the truth of the allegations
Complaint.

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ANSWER TO THE THIRD CAUSE OF ACTION
Complaint.
Complaint.
ANSWER TO THE FOURTH CAUSE OF ACTION
Complaint.
Complaint.
71. Tabar admits that he contacted a member of Plaintiffs family. Tabar
denies the remaining allegations asserted in paragraph 71.
73. Tabar admits that based on false allegations Kovalesky filed a Family
Offense Petition against him in Kings County Family Court.
Complaint to the extent they suggest he caused Kovalesky physical harm; further Tabar

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denies knowledge or information sufficient to form a belief as to the truth of the
remaining allegations.
Complaint.
Complaint.
Complaint.
Complaint.
Complaint.
ANSWER TO THE FIFTH CAUSE OF ACTION
paragraphs, 1-79, as if set forth again in full.
80. Tabar denies the allegations asserted in misnumbered paragraph 80 of the
Verified Complaint.
Complaint.
Complaint.

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Complaint.
Complaint.
ANSWER TO THE SIXTH CAUSE OF ACTION
Complaint.
Complaint.
ANSWER TO THE SEVENTH CAUSE OF ACTION
Complaint.
Complaint.
Complaint.
Complaint.

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ANSWER TO PRAYER FOR RELIEF
Tabar denies the allegations contained in the Prayer for Relief and denies that
Plaintiff is entitled to any of the relief requested.
FIRST AFFIRMATIVE DEFENSE
(Failure to State a Claim)
93. Plaintiff fails to state facts sufficient to constitute a claim upon which relief
against Defendant can be granted.
SECOND AFFIRMATIVE DEFENSE
(Failure to Properly Commence and Maintain a Lawsuit)
94. Plaintiff has not taken the steps necessary to commence and to maintain a
lawsuit in New York State, including without limitation, properly serving Defendant.

THIRD AFFIRMATIVE DEFENSE
(Conduct Precluding Assertions of Alleged Causes of Action)

95. By and through Plaintiffs conduct, Plaintiff is estopped from asserting the
alleged causes of action against the Defendant.
FOURTH AFFIRMATIVE DEFENSE
(Unclean Hands)
96. Each and every purported claim for relief asserted against Defendant is
barred by the doctrine of unclean hands.
FIFTH AFFIRMATIVE DEFENSE
(Plaintiff Has Not Suffered Damages)
97. Plaintiffs injuries and damages, if any, are speculative and cannot be
shown to exist in fact.

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SIXTH AFFIRMATIVE DEFENSE
(Culpable Conduct)
98. The damages sustained by Plaintiff, if any, were caused in whole or in
part by the culpable conduct of Plaintiff, and the amount of damages recoverable, if
any, should be diminished by the proportion of which the culpable conduct attributable
to Plaintiff bears to the culpable conduct that caused the damages complained of, if any.
SEVENTH AFFIRMATIVE DEFENSE
(Doctrines of Settlement, Satisfaction, Agreement, Release, and/or Set Off)

99. The claims set forth in the Complaint are barred, in whole or in part, by
the doctrines of settlement, satisfaction, agreement, release, and/or set off.
EIGHTH AFFIRMATIVE DEFENSE
(Doctrines of Impossibility, Impracticability, and Frustration of Purpose)
100. Plaintiffs claims are barred, in whole or in part, by the doctrines of
impossibility, impracticability, and frustration of purpose.
NINTH AFFIRMATIVE DEFENSE
(Statute of Limitations)
101. Plaintiffs claims are barred under the applicable statute of limitations.
TENTH AFFIRMATIVE DEFENSE
(Laches)
102. Plaintiffs claims are barred by the doctrine of laches.
ELEVENTH AFFIRMATIVE DEFENSE
(Truth of the Statements)
103. Anything said or written about Kovalesky by Defendant was true and
does not constitute defamation.

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TWELFTH AFFIRMATIVE DEFENSE
(Self-Defense)
104. Plaintiffs claims are barred by the doctrine of self-defense.
THIRTEENTH AFFIRMATIVE DEFENSE
(Contract)
105. Plaintiff was an at-will employee and thus had no contractual relationship
with her employer.
RESERVATION OF DEFENSES
106. Defendant presently has insufficient knowledge or information on which
to form a belief as to whether he may have additional as yet unstated defenses
available. Defendant reserves the right to assert additional defenses in the event
discovery indicates that they would be appropriate.
DEFENDANTS COUNTERCLAIMS
Counterclaim-Plaintiff, Sam Tabar (Tabar), by and through his undersigned
attorneys, brings these Counterclaims against Counterclaim-Defendant Angela
Kovalesky (Kovalesky) and alleges as follows:
1. This action arises from the campaign of tortious and illegal conduct that
Kovalesky engaged in against Tabar and his fiance Scarlett Hauck aka Scarlett Etienne
(Etienne) after Tabar made it clear he was no longer interested in a romantic
relationship with Kovalesky.
2. While Tabar was very ready to move on past a difficult relationship,
Kovalesky unfortunately would not let him. She filed multiple baseless criminal
complaints against him, abused a criminal court order of protection, assaulted Tabar in

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front of others, harassed both Tabar and Etienne, and then filed the pleading here (the
Tortious Interference Complaint) with the intent, and result of causing severe damage
to Tabars reputation and, in turn, his employment prospects in the fields of finance and
law.
3. Kovalesky harassed and stalked Tabar over a period of months sending
hundreds of emails and text messages, and initiating dozens of phone calls. Kovalesky
repeatedly threatened Tabar, warning that Tabar should watch himself and that he had
no idea who he was dealing with.
4. Kovalesky even attempted to extort Tabar, telling him in May 2013, that,
unless he paid her the sum of $1 million and broke up with his fiance, Etienne,
Kovalesky would disrupt and destroy Tabars life. When Tabar refused to accept
her demands, Kovalesky followed through on her threats.
5. Not only has all of this caused Tabar significant stress and out of pocket
costs, but Kovaleskys defamatory Tortious Interference Complaint cost Tabar his law
firm job and, despite his best efforts, has made it enormously difficult for Tabar to
obtain employment in the legal and financial industries for which he has trained and
where he has successfully worked for two decades.
6. Tabar has no choice but to assert the claims here, just as Etienne files her
own lawsuit against Kovalesky, to obtain some remedy for the significant damages
Kovalesky has caused him.

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STATEMENT OF FACTS
Background
7. Sam Tabar was born in Montreal, Canada, and, after graduating from
Oxford University and Columbia Law School, has lived and worked professionally in
Tokyo, Hong Kong, and New York. Tabar has over fourteen years of experience in the
investment management industry, working first in finance at PMA Investment
Advisors and Bank of America Merrill Lynch, and, also, as an associate at Skadden,
Arps, Meagher, Slate & Flom LLP, and at Schulte Roth & Zabel LLP. Prior to Kovalesky
filing the Tortious Interference Complaint, Tabar was successful in his career and had
acquired a good reputation in the investment management field.
8. Tabar and Kovalesky met in 2010 and began dating shortly thereafter.
9. During their relationship, Tabar, who was at the time a resident of Hong
Kong, would travel frequently to New York City for work and for job interviews, and
would occasionally see Kovalesky when in town.
10. This continued over the course of two years, but, in December 2012, Tabar
informed Kovalesky that he did not wish to have a long-term relationship with her or
date her exclusively. This was in part because Kovalesky had already engaged in a
pattern of emailing and calling Tabar ceaselessly, whether or not Tabar responded, and
had shown Tabar her ability to move back and forth from extreme anger to affection in
a matter of minutes.
11. It was after their relationship ended, for a period of just over a year, that
Kovalesky engaged in her misconduct as detailed here.

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Kovalesky, Upset About the End of the Relationship,
Repeatedly Confronts Tabar and Destroys or Converts His Property

12. In the months immediately before December 2012, Tabar and Kovaleskys
relationship began to deteriorate, resulting in a handful of verbal arguments between
the two.
13. On one of these occasions, in November 2012, Kovalesky became so angry
at Tabar that she seized Tabars cellphone and purposefully threw it to the ground.
14. Kovaleskys violent outburst destroyed Tabars cellphone, and caused
Tabar to purchase a replacement cellphone for approximately $500.
15. Shortly thereafter, after Tabar ended the relationship in December 2012,
Kovalesky showed up at Tabars hotel room in New York City uninvited, forced herself
into Tabars room, and physically attacked Tabar, punching him with a closed fist and
leaving him with a bloody nose and red marks across his face. This took place in front
of Tabars longtime friend, Celeste Greenberg (Greenberg). See Affidavit of Celeste
Greenberg, attached hereto as Exhibit A.
16. On the same occasion, Kovalesky turned her anger on Greenberg, who
was simply in the sitting area of Tabars hotel room working on Tabars laptop. When
Greenberg grew uncomfortable and got up to leave, Kovalesky hurled insults at her,
calling her, amongst other things, a Jew turd. Id. Tabar was extremely upset by the
incident and feared that Kovalesky would hurt Greenberg, or would continue to hurt
Tabar.

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17. Because she refused to leave the hotel room, Tabar left Kovalesky in the
room and escorted Greenberg out of the hotel. When Greenberg left, she could still see
the red marks on Tabars face from Kovaleskys punches. Id.
18. When Tabar returned to the room, Kovalesky, still angry, threw Tabars
laptop on the ground and eventually left the hotel. As a result, Tabars laptop was
destroyed and rendered unusable, causing Tabar to later replace the laptop himself at a
cost of approximately $1,500.
19. The next day, Tabar left the hotel and noticed Kovalesky in the lobby
waiting for him. Tabar was unaware of any legitimate reason for Kovalesky to be at the
hotel. When Tabar made eye contact with Kovalesky, she rushed towards him and
struck him in the face with a closed fist, causing a laceration to his lip.
20. As a result of these incidents, hotel staff switched Tabars room and
changed the name of his registration at the hotel front desk. The hotel also was
prepared to contact security and notify Tabar in the future if Kovalesky appeared in the
hotel at any time.
21. Also in December 2012, Tabar purchased a leather jacket for $1,495,
intending to give it to a friend as a gift. Although the jacket was not intended for
Kovalesky and Tabar never gave the jacket to her, Kovalesky took the jacket from
Tabars hotel room, and began wearing it without Tabars permission.
22. When Tabar demanded that Kovalesky return the jacket, she refused,
depriving Tabar of the ability to use his property as he had intended.

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23. Later, in January 2013, Kovalesky again appeared without warning at
Tabars hotel room in New York City pleading with Tabar to continue their relationship
and requesting that Tabar engage in sexual relations with her. When Tabar refused,
Kovalesky became enraged and began throwing and knocking over items she found in
the hotel room, including a chair, books, and a tray.
24. At this time, Kovalesky seized Tabars new cellphone (which was the
replacement for the first cellphone Kovalesky destroyed), and threw the new cellphone
to the ground. Kovaleskys violent outburst again destroyed Tabars cellphone, and
caused Tabar to purchase a second replacement cellphone for approximately $500.
25. Because Kovalesky had become so enraged and violent on this occasion,
Tabar called the police who forcibly removed Kovalesky from the hotel room.
Kovalesky Becomes So Angry and Jealous That She Filed a Baseless Domestic
Violence Complaint Against Tabar, Which Was Later Dismissed in its Entirety

26. Upon learning in February 2013 that Tabar was dating Etienne, who is
now Tabars fiance, Kovalesky became jealous and enraged.
27. On February 15, 2013, Kovalesky contacted Jessica Choay, a good friend of
Tabars about whom Kovalesky later made defamatory statements. Kovalesky used a
false Facebook account, under the name of Kat Johansson, to contact Jessica. See
February 15, 2013 Facebook Message, attached hereto as Exhibit B. In the message,
Kovalesky asks, Are you sleeping with Sam Tabar? Because I am too . . . . And yes its
true he might tell you otherwise, but Im with him in Brooklyn now. We had a lovely
Valentines Day. You can keep him. I dont want him. Have fun! Id.

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28. Tabar knew that this was, in fact, Kovalesky because, amongst other
reasons, Kat Johansson relayed information to Tabars friend that only Kovalesky
had, including the room number he was staying in at his hotel. Id. This was only the
first in a series of messages Kovalesky sent to Tabars friends and family using a false
name.
29. The following night, Kovalesky again showed up at Tabars hotel room in
New York City and began to argue with Tabar. As Kovalesky became more irrational
and angered, Tabar called the police. Kovalesky left the hotel room and spoke with the
police downstairs.
30. Tabar filed a complaint with the police. See February 16, 2013 New York
State Domestic Incident Report, attached hereto as Exhibit C. The police determined
that Tabar had a verbal disagreement with his ex-girlfriend. She wants to get back
together, [complaining victim, Samir Tabar] wants to end [the] relationship and stay
friends. No injuries. Both parties agree to go their separate ways. Id.
31. In the days that followed, despite telling the police that she wanted to
move on, Kovalesky used false and malicious allegations against Tabar in order to
initiate a domestic violence proceeding in Kings County Criminal Court. See February
26, 2013 Criminal Complaint, attached hereto as Exhibit D (the First Baseless Criminal
Complaint). Kovalesky alleged that Tabar kicked, strangled, and pushed her, causing
injury and fear. Id.
32. But these allegations were entirely false. Tabar never engaged in the
conduct of which Kovalesky accused him.

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33. Tabar has always denied the allegations which Kovalesky made against
him in support of her eventually dismissed complaint. However, even though
Kovaleskys First Baseless Complaint was eventually dismissed in its entirety, Tabar
was arrested on February 28, 2013 and had to spend a night in jail, suffering emotional
trauma as a direct result of her false accusations.
34. Kovalesky also used her false allegations against Tabar to obtain
temporary orders of protection against Tabar, which prohibited Tabar from contacting
Kovalesky in any way. A temporary order of protection is granted between each court
appearance in most domestic violence actions, regardless of whether the court has
determined that the purported defendant engaged in the alleged misconduct. The last
of the temporary orders of protection that resulted from the First Baseless Criminal
Complaint was granted on April 17, 2013.
35. The charges stemming from Kovaleskys First Baseless Criminal
Complaint were dismissed in Tabars favor on June 10, 2013. See Certificate of
Disposition, Number 47288, attached hereto as Exhibit E.
Kovalesky Embarks on a Campaign of Harassment and Disparagement Toward
Tabar and His Fiance

36. In early 2013, Kovalesky began a campaign to stalk, harass, annoy,
embarrass and cause emotional distress to Tabar, his fiance and their acquaintances.
37. From February 2013 until June 2013, Kovalesky bombarded Tabar with
emails and text messages to such an extent that, on some days, Tabar received over fifty

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electronic communications initiated by Kovalesky. Also during that time period,
according to phone records, Kovalesky initiated over forty calls to Tabar.
38. Kovalesky first threated to contact Tabars family, including his mother
and his brother, as well as Tabars friends and associates, and relay to them the false
allegations Kovalesky made in her First Baseless Criminal Complaint.
39. Kovalesky then followed through on her threats and disparaged Tabar to
his family and friends, revealing the false accusations she had made against Tabar in an
effort to embarrass, disparage, and cause Tabar further emotional distress. See, e.g.,
May 31, 2013 Email from Kovalesky to Tabars mother, Francine Tabar at 5:41am,
attached hereto as Exhibit F (. . . .I wanted to continue our conversation from this past
February . . . . Samir is in legal trouble).
Kovaleskys Communications Alternate Between Threats and Insults to Affectionate
Statements and Demands that Tabar Continue the Romantic Relationship

40. During the same time period, Kovaleskys communications were erratic
and alternated between disparaging and threatening statements about Tabar and his
fiance, to demands that Tabar continue the romantic relationship with Kovalesky.
41. Only two days after she had Tabar arrested, and after she had obtained a
temporary order of protection, Kovalesky, e-mailed Tabar stating, I know that you
cannot respond to this . . . . I just heard that the order of protection will not be lifted
until April 17th its outrageous and completely sad. My lawyer and I are going to do
what we can on our end to get a limited order of protection so that we can talk . . . . I
am allowed to contact you. This e-mail is not illegal. I know that you . . . wish you

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could respond. Im sorry that you cant. All I want to hear is your voice telling me that
youre doing ok . . . . I dont know if youre mad at me . . . . I will miss you so much.
Im so sorry that this is happening. Its just awful. See March 1, 2013 Email from
Kovalesky to Tabar, attached hereto as Exhibit G.
42. One week later, on March 9, 2013, Kovalesky emailed Tabar, again while a
temporary order of protection was in effect, writing [h]ave I told you how much I hate
that I cant talk to you? I feel like I have so much to say to you, and it feels like forever
until Im going to see you again . . . . Its horrible when you cant control or do anything
about it. I just want you to know that Im here for you. I wish that I could hold you . . ..
Anyway, I wanted you to wake up to an email from me. See March 9, 2013 Email from
Kovalesky to Tabar, attached hereto as Exhibit H.
43. On April 29, 2013 Kovalesky apparently tracked Etienne and Tabar via
Etiennes account on Instagram, a photo and video sharing and social networking site
on which Etienne, like other users, published media to be seen by her followers on
the service. Kovalesky saw on Etiennes Instagram account an image of Tabar on
vacation in Los Angeles, and called Tabar at least six times that day beginning one hour
after Etienne posted the photo of Tabar. Kovalesky later admitted that she kn[e]w that
you [Tabar was] with Scarlett in CA. . . . May 30, 2013 Email from Kovalesky to Tabar
at 5:35am, attached hereto as Exhibit I.
44. This was the first incident in a long series of incidents in which Kovalesky
reacted to posts on Etiennes social media accounts and used them to harass and stalk
Tabar, and, frequently, Etienne.

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45. Less than two weeks later, on May 9, 2013, Tabar received dozens of
harassing text messages from Kovalesky stating, among other things, Im better than
you, and I am beautiful, fun, funny, creative, [and] loving . . . . See May 9, 2013
Text Messages, attached hereto as Exhibit J, at 10:39pm; see also Id. at 8:02pm (Suck it
up. It will be over soon because of ME).
46. Despite Kovaleskys First Baseless Criminal Complaint providing
Kovalesky with a Temporary Order of Protection in her favor and which prevented
Tabar from contacting Kovalesky in any way, she repeatedly wrote Tabar that she was
angry because Tabar would not spend time with her. See Id. at 7:53pm (You do
everything possible not to see me . . . . You need to accommodate me like I
accommodate you. Im sick of loving a ghost, and someone, quite frankly, who is
seemingly only real in my head); see also Id. at 10:17pm (You refuse to make plans
with me, and the one weekend it would be easy for me to get away to accommodate
you, you make plans with someone else!).
47. The next morning, despite telling Tabar [y]ou are so weird. I cant take it
anymore less than an hour earlier, Kovalesky appeared to be completely over her
anger and began text messaging Tabar about a party, stating Omg, I was at a kostume
kult meeting. If you even think you might be in the city on 6/1, buy a ticket to their
party. I sent you the link. See May 10, 2013 Text Messages, attached hereto as Exhibit
K, at 6:54am and 8:43am. Kovalesky went on to tell Tabar that I love my baby Samir . .
. . I owe you a lot for showing me a lot of big sides of who I am. . . . Id. at 11:57am and
6:01pm.

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48. Tabar did not wish to spend any time with Kovalesky. Tabar avoided
Kovalesky, and made efforts to ensure they did not cross paths, including having his
attorney notify Kovaleskys attorney of events Tabar planned to attend, and refusing to
set plans with Kovalesky. See, e.g., August 21, 2013 Letter from Jeremy Saland to Bruce
Connolly, attached hereto as Exhibit L.
49. Kovalesky continued to text message and email Tabar throughout the
month of May, alternating between affectionate and understanding messages in one
moment (see May 23, 2013 Email from Kovalesky to Tabar at 11:59am, attached hereto as
Exhibit M ([y]ou are destined for more greatness . . . . Above all else, know that Im
here for you), and accusatory and angry in the next. See May 27, 2013 Text Messages,
attached hereto as Exhibit N, at 7:57am and 8:02am (Youre such a loser . . . your life is
a lie and your mind is sick).
50. At around this time, trying to diffuse any problems, Tabar asked his
friends and family not to communicate with Kovalesky, either in person or through
social media. But this caused Kovalesky to become even angrier and to escalate her
harassing behavior.
51. In at least April 2013, Kovalesky had begun monitoring Tabars fiances
blog, Facebook, and Instagram accounts. Etienne used social media extensively to
promote her performances as a disc jockey (DJ), and for a travel-writing venture in
which she would post photographs from the various hotels she stayed in during her
travels.

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52. In May 2013, Etienne was forced to block Kovalesky on her private
Facebook profile after her fiance Tabar informed her about a message Kovalesky sent
him via text message that indicated Kovalesky had been stalking Etienne on social
networks, specifically Facebook. See May 27, 2013 Text Messages, at 7:57am and
8:24am, attached hereto as Exhibit N.
53. It appears, though, that at that time, and as she had in February,
Kovalesky began using false Facebook accounts to stalk Etienne, and, thus, Tabar,
through Etiennes Facebook posts.

Kovaleskys Harassment Escalates
54. As a result, on May 27, 2013, Kovalesky stated to Tabar via text message
talk your shit and have people block me. It makes me laugh you still have no idea
who you are dealing with . . . [y]ou have no idea how far youve pushed me. See May
27, 2013 Text Messages, at 7:58am and 8:24am, attached hereto as Exhibit N.
55. Within hours after sending these threatening texts, Kovalesky wrote Tabar
an email stating that she no longer wanted to speak with him. See May 27, 2013 Email
from Kovalesky to Tabar at 11:00am, attached here to as Exhibit O (Sam, I dont want
us to talk anymore). Tabar wrote back stating that he would respect her wishes. See
May 27, 2013 Email from Tabar to Kovalesky at 11:36am, attached hereto as Exhibit P.
56. But, minutes later, Kovalesky began emailing Tabar, leveling a series of
harassing untruths about Tabar and others, including accusations about Etienne, who

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was Tabars girlfriend at the time and is now his fiance. See May 27, 2013 Email from
Kovalesky to Tabar at 11:46am, attached hereto as Exhibit Q.
57. Despite the fact that Etienne had blocked Kovalesky from her Facebook
account earlier in May 2013, Kovalesky appeared to continue to follow Etienne online
using a false Facebook profile. Kovaleskys anger seemed to be the result of her
discovery on Facebook of an editorial photo of Etienne, which Tabar had liked. See
Facebook Screenshot of Photo, dated May 26, 2013, attached hereto as Exhibit R; see also
May 27, 2013 Email from Kovalesky to Tabar at 11:46am, attached hereto as Exhibit Q.
(referring to an image of Etienne on Etiennes Facebook page and stating [g]o crazy
over how I found this out, I just dont care).
58. Tabar first attempted to diffuse the situation by not responding to
Kovaleskys allegations. As the evening progressed, however, he grew frustrated and
upset and told Kovalesky [y]ou are putting a lot of emphasis on things I find silly and
trivial Angela. If you want to [do] this just as things are turning a corner in terms of a
real situation, its your call. Goodnight. See May 27, 2013 Email from Tabar to
Kovalesky at 11:50am, attached hereto as Exhibit S.
59. Kovalesky continued sending email after email about Etiennes Facebook
photo and Tabars association with Etienne. See May 27, 2013 Email from Kovalesky to
Tabar at 11:55am, attached hereto as Exhibit T (referring to the same image of Etienne
on Etiennes Facebook page); May 27, 2013 Email from Kovalesky to Tabar at 2:30pm,
attached hereto as Exhibit U (referring to the same image of Etienne as common filth,
and referring to Etienne as common trash and a tramp); May 27, 2013 Email from

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Kovalesky to Tabar at 4:19pm, attached hereto as Exhibit V (Sam, you are such a loser .
. . you are most definitely pathetic . . . . Scarlett is a common tramp . . . a pathetically
lonely person).
60. After seeing this barrage of emails, Tabar asked Kovalesky to please stop
stalking. May 27, 2013 Email from Tabar to Kovalesky at 5:50pm, attached hereto as
Exhibit W. Kovalesky responded by writing Im done because Im done with you. I
was just laughing showing my friends this stuff. Dont worry! May 27, 2013 Email
from Kovalesky to Tabar at 5:51pm, attached hereto as Exhibit X.
61. But Kovalesky was not done. She continued to email Tabar through the
night, calling Tabar a loser . . . just like the whores in your pathetic life. May 27, 2013
Email from Kovalesky to Tabar at 8:09pm, attached hereto as Exhibit Y; see also May 27,
2013 Email from Kovalesky to Tabar at 5:53pm, attached hereto as Exhibit Z (You need
some deep, spiritual attention. Like, yesterday); May 27, 2013 Email from Kovalesky
to Tabar at 6:02pm, attached hereto as Exhibit AA (telling Tabar to just hang with your
hood rats).
62. In these emails Kovalesky also leveled disparaging remarks about Tabars
former girlfriends and platonic female friends, stating that one of them has the ugliest
nose and hands Ive ever seen in my life, one looks mousey, one is a troll and a
loser, and another is a fat slob. May 27, 2013 Email at 4:19pm from Kovalesky to
Tabar, attached hereto as Exhibit V.

29

63. Tabar responded by stating [y]oure really too much. Not everyone has
to be perfect to be friends. Please stop stalking, Angie. See May 27, 2013 Email From
Tabar to Kovalesky at 5:50pm, attached hereto as Exhibit W.
64. Nonetheless, Kovalesky continued to email Tabar well into the following
day. See, e.g., May 28, 2013 Email from Kovalesky to Tabar at 3:04am, attached hereto as
Exhibit BB (I still think youre trash . . . . You are embarrassing . . . [f]ix your fucking
life). Kovalesky also told Tabar that she would be in contact with Tabars criminal
defense attorney, Jeremy Saland, presumably regarding her complaint against Tabar,
which, because Kovalesky was not willing to swear out to the truthfulness of her
allegations and had not signed a corroborating affidavit, was only days away from
being dismissed under CPLR 30.30. Id.
65. Shortly thereafter, on the same day, Kovalesky began to ask Tabar where
he was and where he was travelling to that day. See May 28, 2013 Email from
Kovalesky to Tabar at 3:46am, attached hereto as Exhibit CC (Where are you going?);
see also May 28, 2013 Email from Kovalesky to Tabar at 3:48am, attached hereto as
Exhibit DD (And dont lie to me. Ill find out the truth).
66. When Tabar would not tell her where he was going, Kovalesky again
threatened him, stating [y]ou should really fucking answer me. And with the fucking
truth. May 28, 2013 Email from Kovalesky to Tabar at 3:52am, attached hereto as
Exhibit EE; see also May 28, 2013 Email from Kovalesky to Tabar at 3:57am, attached
hereto as Exhibit FF (lol, youre fucking with me again, arent you?! You never learn,
do you?); May 28, 2013 Email from Kovalesky to Tabar at 4:03am, attached hereto as

30

Exhibit GG (something is up because your phone has been off for more than 24
hours).
67. Shortly thereafter, Kovalesky threatened Tabar even further, writing
[a]nd why would common, trampy Scarlett block someone like me on Facebook unless
you said something to her? You better watch your fucking self, asshole. That I am very
fucking serious about . . . . You talk shit about me, and I will fucking bring it to you like
no one else. See May 28, 2013 Email from Kovalesky to Tabar at 4:31am, attached
hereto as Exhibit HH.
68. But the next day, Kovalesky sent Tabar an email entitled Peace, stating
you have my friendship right now . . . remember you are the best the best in the
west. Good luck tomorrow. May 29, 2013 Email from Kovalesky to Tabar at 9:06am,
attached hereto as Exhibit II.
69. When Tabar would not respond to Kovalesky, Kovalesky warned, [i]f
you dont respond back to this, Im contacting your brother or your parents. I want to
skype. When can we do that? See May 29, 2013 Email from Kovalesky to Tabar at
5:46am, attached hereto as Exhibit JJ.
70. Less than two hours later, when Tabar did not respond, Kovalesky
followed through on her threat and emailed Tabars brother. See May 29, 2013 Email
from Kovalesky to Tabar at 7:11am, attached hereto as Exhibit KK (I just emailed your
brother. Please tell him to check his Facebook messages).
71. Shortly thereafter, Kovalesky contacted Tabars attorney regarding a
proposed confidentiality agreement. She then emailed Tabar threatening further legal

31

action, stating [y]ou have no right to lie to others about me forcing them to block me
on Facebook . . . . I will be allowed to take you to court if I sense this is continuing. I
will subpoena Scarlett and anyone else necessary. May 29, 2013 Email from Kovalesky
to Tabar at 8:13am, attached hereto as Exhibit LL.
72. Tabar repeatedly asked Kovalesky to please leave me alone . . . . Please
stop screwing around with other peoples lives. Just stop it. Leave me alone. I am not
bugging you or sending messages to your friends etc. I am not trying to get involved in
your life. See May 30, 2013 Email from Tabar to Kovalesky at 2:59am, attached hereto
as Exhibit MM.
73. When Kovalesky told Tabar that she would be pursuing another
temporary order of protection for the express purpose of preventing Tabar from
attending a music festival called Burning Man, Tabar responded, Angela, there are
massive ramifications for me if you pursue this . . . I literally will never be able to get a
job because it will be on the public record . . . . Just lets leave each other alone.
B[urning] M[an] is a public event and I am happy to stay away from you. See May 30,
2013 Email from Tabar to Kovalesky at 9:08am, attached hereto as Exhibit NN.
74. From Kovaleskys emails, Tabar understood that Kovalesky was
threatening to file further false complaints with the police, as she had in February, in
order to get back at Tabar. Tabar was frightened about what Kovalesky would do.
Kovalesky had already made the First Baseless Criminal Complaint against Tabar,
which not only resulted in his arrest, but affected Tabars life and ability to earn a
livelihood going forward.

32

75. At the time, Tabar knew that the criminal charges against him were very
close to being dismissed in their entirety, but, based on her threats, feared that
Kovalesky would make even more false accusations that would lengthen the process
and further harm Tabar.
76. As it turns out, this is precisely what Kovalesky did.
Kovalesky Tracks Down Tabar and Threatens to Disrupt His Life If He Does Not Pay
Her $1 Million

77. Three days later, Kovalesky tracked down Tabar though Etiennes social
media accounts, doing exactly what she threatened on May 28, 2013 when she stated
that she would find out the truth. May 28, 2013 Email from Kovalesky to Tabar at
3:48am, attached hereto as Exhibit DD. On May 30, 2013, Kovalesky discovered from
reading Etiennes blog and Facebook page that Tabar and Etienne had in fact taken a
trip together overseas where Etienne was due to perform. See May 29, 2013 Facebook
Screenshot, attached hereto as Exhibit OO. Kovalesky told Tabar I know that youre
with [Scarlett] now. May 30, 2013 Email from Kovalesky to Tabar at 5:35am, attached
hereto as Exhibit I.
78. Although neither Tabar nor Etienne had notified Kovalesky of their trip,
Kovalesky tracked down their hotel information, including the room number, and
called Tabar and his fiance on their hotel room phone.
79. During this conversation Kovalesky yelled at Tabar and threatened him
that if he did not leave the hotel immediately, break off his relationship with Etienne,

33

and pay Kovalesky the sum of $1 million, she was going to go to the police and disrupt
their lives.
80. When Tabar asked Kovalesky why are you doing this, Kovalesky
answered, because I want to destroy you.
81. During this conversation Kovalesky referred to Tabars fiance using
various disparaging and insulting names including whore, slut, and cunt.
Kovalesky yelled so that loudly that Etienne could hear seemingly the entirety of the
phone conversation.
82. As this was not the first time Kovalesky had harassed Tabar in this way,
Tabar and Etienne took her threats very seriously. In fact, as described supra at 7-23,
Kovalesky had a history of showing up at Tabars hotel rooms, without advance notice
and without being invited, in order to harass, assault and disparage Tabar.
83. Thus, on May 31, 2013, after Kovaleskys harassing phone call, Tabar and
his fiance were fearful of Kovaleskys threats and maintained a genuine belief that she
was capable of, and in fact would, seek to cause them physical harm and continue to
harass them. Further, because Kovalesky had only days earlier told Tabar to watch
himself (May 28, 2013 Email from Kovalesky to Tabar at 4:31am, attached hereto as
Exhibit HH), Tabar feared that Kovalesky would seek to harm him in any way possible,
including through making additional false complaints to the police.
84. As a result, Plaintiff and his fiance were forced to abandon the remainder
of their stay at the resort where Kovalesky had telephoned them and switch hotels, so
that Kovalesky would be unaware of their whereabouts and would not be able to

34

further harm and harass them. Out of fear of Kovaleskys threatened conduct, they
even ended their trip early, incurring thousands in additional financial expenses as a
result of changing their travel plans on short notice.
85. When Kovalesky did not receive the $1 million she sought to extort from
Tabar, she made good on her threats to disrupt and destroy Tabars life and
reported Tabar to the police for communicating with her, resulting in the filing of a
family court petition for an order of protection based on allegations that were identical
to those she made in her First Baseless Criminal Complaint on June 25, 2013 (see June 25,
2013 Family Offense Petition, attached hereto as Exhibit PP, as well as a second baseless
criminal complaint. See June 26, 2013 Criminal Complaint, attached hereto as Exhibit
QQ (the Second Baseless Criminal Complaint).
Kovalesky Uses the Call She Initiated With Tabar to Maliciously File a Second
Complaint with the Police

86. Even though Kovalesky had initiated the communications with Tabar, she
intended to make it seem like Tabar had, in fact, violated the April 17, 2013 temporary
order of protection issued as a result of the First Baseless Criminal Complaint.
87. In the Second Baseless Criminal Complaint, Kovalesky alleged that Tabar
contacted her via telephone and email in violation of the April 17, 2013 Temporary
Order of Protection. See Second Baseless Criminal Complaint, attached hereto as
Exhibit QQ.
88. In this same vein, without any basis in fact, and motivated solely by ill
will and jealousy, Kovalesky made false statements in that Tabar had changed his

35

mailing address to her home address in violation of the April 17, 2013 Temporary Order
of Protection.
89. Tabar learned that he would be arrested for a second time because of these
false statements, this time for a technical violation of the Order of Protection. Thus on
or around June 26, 2013, Tabar surrendered and was incarcerated. Tabar was
handcuffed and spent eighteen hours in a holding cell.
90. As a result, Etienne flew back to New York from a performance in India in
order to make a statement to the District Attorney supporting Tabars defenses to
Kovaleskys Second Baseless Criminal Complaint.
91. Kovaleskys factually untrue statements were designed by Kovalesky
solely to harass and annoy Tabar and keep him entangled in meritless legal proceedings
for technical violations of the temporary order of protection due to any responses to
Kovaleskys ceaseless text messages, emails, and phone calls. Kovalesky used the
criminal proceedingsbased on her false allegationsto retaliate against Tabar for
terminating their romantic relationship.
92. While he maintained his innocence, Tabar pleaded to a lesser offense of
disorderly conduct (a non-criminal offense) on August 12, 2013 in order simply to move
on with his life. See Certificate of Disposition, Number 37126, attached hereto as Exhibit
RR.
Tabar Obtains an Order of Protection Against Kovalesky in Family Court
93. By July 2013, Defendants behavior had become so unpredictable, caused
him and his loved ones so much stress, and made Tabar genuinely fear whether there

36

were limits to what Kovalesky would do, that Tabar was forced to file a petition for an
order of protection against Kovalesky in the Kings County Family Court due to
Defendants acts of disorderly conduct, aggravated harassment, menacing,
reckless endangerment, assault, stalking, and criminal mischief. See July 19,
2013 Family Offense Petition, attached hereto as Exhibit SS.
94. The Family Court consequently entered a temporary order of protection
which prohibited Kovalesky from contacting Tabar in any way.

Tabar Is Fired From His Job As a Direct Result of Kovaleskys Baseless Lawsuit

95. Approximately six months later, and, exactly as she had threatened,
Kovalesky filed a wholly unsupported civil lawsuit against Tabar on February 5, 2014,
with the express intent to further disrupt Tabars life and destroy him.
96. Like her previously filed baseless criminal complaints, Kovaleskys
Tortious Interference Complaint is based on numerous false allegations. For example,
in her Tortious Interference Complaint, Kovalesky alleges that Tabar threatened her
with a knife. But this is flatly contradicted by Kovaleskys own statement to the police
regarding the purported incident. See the First Baseless Criminal Complaint, attached
hereto as Exhibit D.
97. As a direct result of Kovaleskys initiation of this Tortious Interference
Action (the Tortious Interference Action), and apparently exactly as desired and
threatened, Tabar has suffered immense damage to his reputation and career.

37

98. Prior to February 5, 2014, Tabar had been on leave for one month to take
care of his parents, but intended to return to his job at Schulte, Roth & Zabel LLP
(Schulte). Tabar specialized in capital markets, which is a highly reputation-driven
field.
99. Immediately after Kovalesky filed her complaint, her false allegations
were disseminated throughout multiple media outlets, including the New York Post,
the New York Daily News, legal news website Above the Law, and the ABA Journal.
100. That same day, Tabar received a voice message from Stuart Freedman
(Freedman), a managing partner at Schulte asking to speak with Tabar. Freedman
followed up by email telling Tabar that they needed to talk as soon as possible as
Schulte had already received a number of calls from the press asking for comment on
the lawsuit.
101. Shortly after he received Freedmans email, Tabar returned the call.
Freedman was joined on the call by another Schulte partner, Alan Waldenberg. The
two spoke with Tabar and told him that they were terminating his employment. The
Schulte attorneys told Tabar that the lawsuit was simply too embarrassing to the firm,
and could hurt Schultes good name if Tabar remained.
102. Immediately thereafter, Schulte took down Tabars firm email address and
all reference to Tabar on its website. This all occurred within days of Kovalesky filing
the Tortious Interference Complaint.
103. Tabar sustained special grievances due to Kovaleskys filing and
prosecution of the Tortious Interference Action, including, but not limited to, lost

38

employment opportunities and severed business relationships, costing him at least
hundreds of thousands of dollars in his once successful career.
Kovaleskys Baseless Lawsuit Is Now Preventing Tabar from Finding New
Employment

104. In the month and a half since he was terminated from Schulte, Tabar has
actively sought new employment. He has not been successful.
105. For example, on one occasion, Tabar spoke with a potential employer
who was interested in offering him a job with a salary starting at $250,000 base plus
commission. But, when the potential employer learned of the Tortious Interference
Action, told Tabar that he simply could not hire him at this time.
106. On another occasion, Tabar spoke with a business contact regarding
prospective employment, who told Tabar that he was an ideal candidate. However, the
recruiter explained, due to the allegations in the Tortious Interference Complaint and
the public dissemination of the allegations included in it, she could not recommend
Tabar to any of her clients.
107. Like Schulte, these prospective employers simply did not wish to deal
with the embarrassment of the Tortious Interference Action, even knowing that the
claims are false.
108. This is because the field Tabar works in capital markets and investment
management depends substantially on reputation. Because Kovalesky intentionally
set out to destroy Tabars reputation, he is no longer able to find a job in that field. This

39

is a direct result of the false allegations Kovalesky made in her complaint and
distributed to the press, all with the express intent to harm Tabar and disrupt his life.
FIRST CAUSE OF ACTION
(Tortious Interference with Business Relationship)
109. Tabar had a business relationship with Schulte Roth & Zabel LLP.
110. Kovalesky knew Tabar was employed by Schulte, and that his field was
driven by reputation and trust.
111. Kovalesky interfered with Tabars relationship with Schulte by filing the
sham Tortious Interference Action and disseminating the false allegations to the press.
112. Kovalesky was motivated to file the Tortious Interference Complaint for
the specific purpose of harming Tabar.
113. Kovalesky used wrongful means by first attempting to extort $1 million
from Tabar. Kovalesky told Tabar that, if he did not pay her $1 million, Kovalesky
would disrupt and destroy his life.
114. Kovalesky then proceeded to engage in a campaign to publicly disrupt
and destroy Tabars life, including his career.
115. Kovalesky also used wrongful means by initiating the Tortious
Interference Action against Tabar in bad faith.
116. The Tortious Interference Action is not reasonably calculated to obtain a
favorable outcome and no reasonable litigant could expect success on the merits.
Kovalesky bases her action on plainly false allegations, including that Tabar was
convicted of a crime.

40

117. The lawsuit conceals an attempt by Kovalesky to interfere directly in
Tabars business relationships in order to disrupt his life, as she threatened she would.
118. Kovalesky caused injury and harm to Tabar by depriving Tabar of the
economic benefit he would have obtained through his employment at Schulte where he
was making an annual salary of $235,000, and had the prospects not only for raises, but
for annual bonuses, and for continued employment for years to come.
119. Tabar was injured in an amount to be determined at trial.

SECOND CAUSE OF ACTION
(Tortious Interference with Prospective Employment or Advantage)
120. Prior to the commission of the wrongful acts by Kovalesky, Tabar was
reputed, esteemed, and sought after in the legal and investment banking communities.
121. Kovalesky tortiously and falsely claimed that Tabar engaged in extreme
misconduct and was convicted of a crime. These statements were widely disseminated
throughout the legal community, including through popular legal media websites such
as Above the Law and the ABA Journal, and falsely characterized Tabars conduct and
character. These statements were false, misleading, defamatory, libelous, and without
legal excuse, as described supra 99-104.
122. Kovaleskys false and defamatory statements, false reports to the police,
misrepresentations, Tortious Interference Complaint, and persistent and baseless
harassment have injured Tabar in his good name, reputation, and business.

41

123. Because Tabars career in the investment banking and legal fields is based
on trust and reputation, Kovalesky has harmed Tabars ability to work in the future.
124. Tabar has attempted to mitigate the damages he is suffering by actively
seeking employment. However, on multiple occasions, Tabar has been told that
Kovaleskys lawsuit is simply too embarrassing for any company in his field to risk
employing Tabar.
125. Kovalesky caused this harm for the express purpose of disrupting Tabars
life.
126. Tabar has been injured in an amount to be determined at trial.
THIRD CAUSE OF ACTION
(Malicious Prosecution)
127. Plaintiff repeats and re-alleges each and every allegation set forth in the
foregoing paragraphs as if fully set forth herein.
128. On February 28, 2013, Kovalesky filed the First Baseless Criminal
Complaint, making entirely false allegations against Tabar. Tabar was arrested as a
result and spent the night in jail. Consequently, the court also granted several
temporary orders of protection in favor of Kovalesky from February 2013 to June 10,
2013.
129. On June 26, 2013, Kovalesky filed the Second Baseless Criminal
Complaint, this time for violation of the April 17, 2013 temporary order of protection
granted as a result of the First Baseless Criminal Complaint. Immediately prior to filing
the Second Baseless Criminal Complaint, Kovalesky sent hundreds of emails and text

42

messages over the course of five days to Tabar. She also tracked Tabar at a hotel
overseas and called him, threatening to disrupt and destroy Tabars life if he did
not pay her $1 million and did not end his relationship with his fiance. Kovalesky
used these communications, which she initiated, as the basis for the Second Baseless
Criminal Complaint.
130. Also in June 2013, Kovalesky filed a Family Offense Petition in the Kings
County Family Court and obtained another temporary order of protection against
Tabar. The Family Offense Petition was based entirely on the same false allegations that
Kovalesky made against Tabar in the First Baseless Criminal Complaint.
131. Defendants actions are indicative of the fact that she intended to do harm
without excuse or justification.
132. As a result of Plaintiffs falsely reporting these incidents to the police,
Defendant was falsely imprisoned on two occasions.
133. There was no probable cause for the criminal proceedings against Samir,
as the facts and circumstances described in the aforesaid paragraphs would not lead a
reasonably prudent person in like circumstances to believe Plaintiff was guilty.
134. In fact, criminal charges arising from the First Baseless Criminal
Complaint were dismissed entirely on June 10, 2013. The charges arising from
Kovaleskys Second Baseless Criminal Complaint regarding Tabars purported violation
of the Order of Protection were also dismissed when Tabar pleaded to a lesser, non-
criminal offense of disorderly conduct on August 12, 2013.

43

135. The criminal proceedings were instituted in actual malice, and with a
wrong and improper motive. Kovalesky has repeatedly stated both verbally and in
writing that she wishes to inflict pain, distress, and difficulty upon Tabar and his
fiance Scarlett Etienne.
136. Tabar spent over $55,475 in legal fees fighting the First and Second
Baseless Criminal Complaints, and the Family Offense Petition.
137. As a direct and proximate result of Kovaleskys filing of false criminal
complaints, Tabar has suffered economic damages, and has suffered and continues to
suffer non-economic damages, including mental and emotional injury and detrimental
psychological trauma in an amount to be determined at trial.
FOURTH CAUSE OF ACTION
(Abuse of Process)
139. On February 28, 2013, Kovalesky, with ill will and jealousy, used false and
malicious allegations to commence and maintain a domestic violence action against
Tabar.
140. On June 26, 2013 Kovalesky, with ill will and jealousy, used false and
malicious allegations to file a complaint against Tabar for violating the April 17, 2013
temporary order of protection. Kovalesky told the police that Tabar had contacted her
in violation of the temporary order of protection.

44

141. But Tabar did not contact Kovalesky. Instead, Kovalesky stalked Tabar
and his fiance on social media and determined that the two were staying in a hotel in
overseas. Kovelsky then called the hotel and was put through to Tabars hotel room.
Kovalesky proceeded to threaten Tabar that she would go to the police and disrupt
and destroy Tabars and his fiances lives unless Tabar paid Kovalesky $1 million
and ended his relationship with Etienne.
142. When Tabar refused to pay her $1 million, Kovalesky went to the police
and reported Tabar for violating the temporary order of protection, despite the fact that
it was Kovalesky who repeatedly contacted Tabar while the temporary order of
protection was in place, including over forty phone calls, and hundreds of emails and
text messages.
143. Kovaleskys use of legal process against Tabar was intended to vex, annoy
and harass Tabar, and was intended to, and continues to, cause substantial disruption
to Tabars career and assets generally, and his professional and personal activities
specifically.
144. Defendant could never have achieved these ulterior objectives through
proper use of litigation.
145. Defendants abuse of process was intended toand didcause benefit to
Defendant and harm to the Plaintiff. The economic and other harms inflicted upon
Plaintiff are without excuse or justification, and are outside the normal contemplation of
litigation.

45

146. As a direct and proximate result of Defendants abuse of process, Plaintiff
was forced to incur costs and expenses, including but not limited to attorneys fees and
costs of litigation, as well as lost wages, lost time from work, and significant other
consequential and incidental damages, including those damages which resulted from
Plaintiffs overnight imprisonment for false domestic violence allegations, for which the
Defendant is responsible and legally liable.
147. Defendant acted maliciously, without cause, without regard to Plaintiffs
legal rights, and with the intent to oppress Plaintiff, entitling Plaintiff to punitive
damages.

FIFTH CAUSE OF ACTION
(Trespass to Chattel)
149. On two separate occasions, once in November 2012 and once in January
2013, with no right or authority, Kovalesky threw Tabars cellphones to the ground and
destroyed them.
150. On another occasion in 2012, with no right or authority, Kovalesky
intentionally threw Tabars laptop computer to the ground completely destroying it and
rendering it unusable.

46

151. Tabar replaced the cellphones and laptop himself for a total cost of
approximately $2,500.
152. As a direct and proximate result of Kovaleskys destructive conduct,
Tabar has incurred damages of $2,500.
SIXTH CAUSE OF ACTION
(Conversion)
154. In December 2012, Kovalesky began exercising dominion and control over
a leather jacket owned by Tabar without permission or consent.
155. Tabar, as the true owner of the jacket, had at all relevant times an
immediate and superior right of possession over the jacket.
156. To date, Kovalesky has not returned the jacket to Tabar, its rightful owner,
and upon information and belief, she currently possess and exercises dominion and
control over the jacket to the exclusion of Tabar.
SEVENTH CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)
158. In the February 2013, Kovalesky began a campaign to stalk, harass, annoy,
embarrass and cause extreme emotional distress to Tabar, his fiance, and their families
and acquaintances.

47

159. On February 28, 2013, Kovalesky used false and malicious allegations
against Tabar to the First Baseless Criminal Complaint.
160. As a result of Kovaleskys false report, Tabar was arrested and spent the
night in jail, suffering emotional trauma and mental anguish.
161. Shortly thereafter Kovalesky contacted Tabars family including his
mother, father, brother, and ex-girlfriend alerting them to her domestic violence
application and the false allegations contained therein, in an effort to embarrass and
disparage Tabar.
162. The temporary order of protection, issued as a result of these proceedings,
required that Tabar refrain from contacting Kovalesky. However, Kovalesky repeatedly
contacted Tabar via e-mail and text message, and tracked him on social media websites
such as Facebook and Instagram, in order to goad Tabar into breaking the temporary
order of protection.
163. Kovalesky used the instances in which she had contacted Tabar to file the
Second Baseless Criminal Complaint against Tabar, alleging that he had violated the
temporary order of protection.
164. As a result, Tabar was arrested for a second time and forced to spend 18
hours in a holding cell.
165. From February 2013 to June 2013, Kovalesky sent Tabar hundreds of
harassing text messages and emails, repeatedly called Tabar after he asked her to stop
contacting him, defamed Tabars fiance, and leveled offensive and disparaging
remarks about many of Tabars acquaintances.

48

166. On May 31, 2013 after discovering that Tabar and his fiance had taken a
trip together overseas, by monitoring Tabar and his fiances social media accounts on
Instagram and Facebook, Kovalesky called Tabar and his fiance on their hotel room
phone.
167. During this conversation, Kovalesky threatened Tabar that if he did not
leave the hotel immediately, end his relationship with Etienne, and pay her the sum of
$1 million, she was going to go to the police and disrupt their lives and destroy
Tabar.
168. After Kovaleskys harassing and threatening phone call, Tabar and his
fiance were fearful of Kovaleskys threats and maintained a genuine belief that she was
capable of, and in fact would, seek to cause them physical harm and continue to harass
them.
169. As a result, Tabar and his fiance were forced to abandon the remainder of
their stay at the resort where Kovalesky had telephoned them and switch hotels so that
Kovalesky would be unaware of their whereabouts and would not be able to further
harm and harass them, and end their trip early, incurring substantial financial expenses
from the airlines for changing their travel plans at the last minute.
170. Kovaleskys conduct was intentional and malicious.
171. Kovaleskys conduct was extreme and outrageous and is utterly
intolerable in a civilized society.
172. Kovaleskys conduct was calculated to, and did, cause emotional distress
to Tabar.

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173. As a direct and proximate result of Kovaleskys intentional infliction of
emotional distress, including but not limited to her campaign of harassment, threats of
harm, attempts at extortion, and defamatory remarks, Tabar has suffered economic
damages, and has suffered and continues to suffer non-economic damages, including
mental and emotional injury and detrimental psychological trauma in an amount to be
determined at trial.
PRAYER FOR RELIEF
WHEREFORE, Counterclaim-Plaintiff prays for the following relief:

(a) On the first, second, third, fourth, and seventh causes of action,
Plaintiff requests compensatory damages in an amount to be
determined at trial;

(b) On the first, second, third, fourth, and seventh causes of action,
Plaintiff requests punitive damages in an amount to be determined at
trial;

(c) On the fifth cause of action, Plaintiff requests judgment in an amount
no less than $2,400;

(d) On the sixth cause of action, Plaintiff requests judgment in an amount
no less than $2,000; and

(e) Such other and further relief as is just and proper.

FURTHER, Counterclaim-Plaintiff respectfully requests that judgment be entered as
follows:
(a) Dismissing the Verified Complaint with prejudice;
(b) Awarding Counterclaim-Plaintiff attorneys fees;
(c) Awarding Counterclaim-Plaintiff such other and further relief as this
Court may deem just and proper.

Exhibit A

Exhibit B

Exhibit C

Exhibit D

Exhibit E

Exhibit F

From: Angela Kovalesky <a.kovalesky@gmail.com>
Subject: Samir
Date: May 31, 2013 at 5:41:55 AM EDT
To: Francine Tabar <francinetabar@gmail.com>

Hi Francine,

I hope that this finds you well, and I hope that you don't mind that I reach out to you, but I
wanted to continue our conversation from this past February.
Samir is in legal trouble. As you know, he was harassing and trying to blackmail me in February.
That's when I called you in an effort to try to get him to stop. I know that he told you that we
were just having an argument, but it was more than that.

When he returned from Hong Kong, he physically hurt me... hitting, kicking, punching and
spitting. He told me that he would get help, and he is not. I've tried to support him through this,
but I can't do it anymore. It's too hard. He needs counseling, and he needs to take care of his
anger issues.
I know that he will be upset with me for telling you this, but if he hides what is happening and
doesn't address it, he won't get better. He told me that he talked to Karim about this stuff, so I
thought he was talking to someone in the family about it, but that doesn't seem to be the case.
Anyway, if no one is helping him through this, I'm afraid that what happened to me might
happen to someone else.
Again, I'm sorry to share this with you, but I thought that you should know, and I thought that
maybe you could help him. His next court date is in NYC on June 10th.
Feel free to call me if you want to talk about this, ok? 646-318-1770
Love,
Angela

Exhibit G

Exhibit H

Exhibit I
From: Angela Kovalesky <a.kovalesky@gmail.com>
Date: Thu, May 30, 2013 at 5:35 AM
Subject:
To: Sam Tabar <samtabar@gmail.com>
I want you to know that you are the absolute worst thing that has ever happened to me. You
are a liar and abuser, and you justify things by technicalities, and you treat people like shit.
There is a cycle with abusers: luring, isolation, abuse; which is exactly what you did to me.
Your lies are what boggles my mind the most. I know that you were with Scarlett in CA, and I
know that you're with her now. Singapore for work? I hope so. I don't need you in NYC. I am not
going to let you do to me to other people. Had you shown any remorse, gone to any classes,
really worked on yourself, this would not be happening. I cannot let you continue this pattern.
I am contacting Justin today to explore possibilities in court. You should probably make sure
that you are able to speak to Jeremy.
And shame on you for how you treat your brother. I feel so bad for him. You are a monster.

Exhibit J
5/9/13, 8:24:20 AM: Angela Kovalesky: Tip: find a girl with bad self
confidence like you, pretend you're cool like your brother and continue to
be unfulfilled and happy since you can't prioritize or treat a woman like
she should be treated.

5/9/13, 8:24:30 AM: Angela Kovalesky: I'm better than you.

5/9/13, 8:27:42 AM: Angela Kovalesky: 1ff29984f91722296f38fbb09a821e1b.jpg
<attached>

5/9/13, 8:27:54 AM: Angela Kovalesky: 88b03ab838b397027b1276c63ef54088.jpg
<attached>

5/9/13, 8:28:11 AM: Angela Kovalesky: c7571f29454a52100686d79767aaf779.jpg
<attached>

5/9/13, 8:28:21 AM: Angela Kovalesky: 2a37f4d8a29d2191f7e707a4a7eef4bb.jpg
<attached>

5/9/13, 8:28:48 AM: Angela Kovalesky: All fucking over.

5/9/13, 8:30:46 AM: Angela Kovalesky: And you should talk to randa more
about being in an unfulfilled relationship with #2 since you'll need to
squeeze into that spot soon.

5/9/13, 8:50:09 AM: Angela Kovalesky: You could have told your boring
cousin to go to HK this weekend, but you tell her to see you the ONE
weekend I can see you. You are PATHETIC.

5/9/13, 8:50:59 AM: Angela Kovalesky: Have fun with boring Scarlet and
your brother in HK too. Jesus, you ARE lame and boring!

5/9/13, 8:51:08 AM: Angela Kovalesky: And not fun in bed.

5/9/13, 8:51:35 AM: Angela Kovalesky: And not deep, totally superficial

5/9/13, 8:51:40 AM: Angela Kovalesky: Your ring is weird

5/9/13, 8:51:57 AM: Angela Kovalesky: Your bandaids that you give out
while dancing are weird

5/9/13, 8:53:19 AM: Angela Kovalesky: And you treat your parents like shit

5/9/13, 1:09:03 PM: Angela Kovalesky: And you treat me like shit. Had you
given me 1% of the love I've given you over the last 10 days, this would
not be happening.

5/9/13, 1:10:07 PM: Angela Kovalesky: You ask me not to go to parties, you
stand me up, you lie, you won't let me see your dad, you act weird with me
in the hotel, you break a promise to make plans with me before you
leave... You just suck.

5/9/13, 1:10:58 PM: Angela Kovalesky: YOU created this mess but you're
incapable of taking any responsibility for yourself, as always.

5/9/13, 1:11:39 PM: Angela Kovalesky: You want love? Try giving it.

5/9/13, 5:24:32 PM: Samir Tabar: I have tried hard for us

5/9/13, 5:25:21 PM: Samir Tabar: You always abandon me in my hour of need

5/9/13, 5:25:34 PM: Samir Tabar: And you expect for me to be all hunky
dory

5/9/13, 7:53:52 PM: Angela Kovalesky: I'm abandoning you?! You do
everything possible not to see me. Go see your cousin and get it over with
then see me when I have 4 days off. She doesn't work. She can be flexible.
I have a life, and it's not as easy for me. You need to accommodate me
like I accommodate you. I'm sick of loving a ghost, and someone, quite
frankly, who is seemingly only real in my head. I'm not sure what I'm
leaving you in the lurch about, but this "you tell me to jump and I ask
how high" shit is ending. I have no more juice for it.

5/9/13, 7:54:47 PM: Angela Kovalesky: And stop bringing up why this is
happening. You know why.

5/9/13, 8:00:26 PM: Angela Kovalesky: I'm sorry this is happening. It
hurts me too, but I'm sick of you pretending this is just bad luck; you
created this... like a machine.

5/9/13, 8:02:40 PM: Angela Kovalesky: Suck it up. It will be over soon
because of ME. I AM the only one who continually stands by you and
simultaneously gets shit on by you ALL of the time. Why don't you think
about that?

5/9/13, 8:06:22 PM: Angela Kovalesky: And you haven't tried hard for us,
Samir. You try when you need something like comfort, but not more than
that. I am a free spirit, and I deserve to share more than just your
burdens with you. This anger... These words... It's me getting out of the
unfun corner you try to paint me in all of the time so you can go off to
parties and discard me when you feel like it.

5/9/13, 10:17:16 PM: Angela Kovalesky: And I just want to say that I've
tried to foster something good for us. You refuse to make plans with me,
and the one weekend it would be easy for me to get away to accommodate
you, you make plans with someone else! It's too crazy. Don't ever tell me
that you love and care about me. That's not love or caring.

5/9/13, 10:19:49 PM: Angela Kovalesky: I also want you to know that I am
not angry or yelling. I know it's hard to gauge over whatsapp.

5/9/13, 10:31:48 PM: Angela Kovalesky: You really upset me, Samir.

5/9/13, 10:39:11 PM: Angela Kovalesky: I'm sick of the machine that blames
me for everything, nips any fun that could exist between us in the bud and
puts me second to his social life. I am beautiful, fun, funny, creative,
loving, and deserve someone who sees and loves that about me.

5/10/13, 1:30:25 AM: Angela Kovalesky: Anyway, just focus on your
interview. If you have time to Skype, we can do that later. I don't want
back and forth via whatsapp.

Exhibit K
5/10/13, 6:42:46 AM: Angela Kovalesky: You ok?

5/10/13, 6:54:40 AM: Angela Kovalesky: Ugh

5/10/13, 6:54:54 AM: Angela Kovalesky: You are so weird. I can't take it
anymore.

5/10/13, 6:55:32 AM: Samir Tabar: I am not weird.

5/10/13, 6:55:50 AM: Samir Tabar: I am sleep deprived and very tired from
a very difficult flight(s).

5/10/13, 6:55:59 AM: Samir Tabar: Please let me breathe.

5/10/13, 7:19:58 AM: Samir Tabar: Can't you be gentle? I am not strong
these days from all the wound.

5/10/13, 7:30:50 AM: Angela Kovalesky: X

5/10/13, 8:43:54 AM: Angela Kovalesky: Omg, I was at a kostume kult
meeting. If you even think you might be in the city on 6/1, buy a ticket
to their party. I sent you the link.

5/10/13, 11:00:50 AM: Samir Tabar: It's funny how you got deeper into a
scene I introduced you to

5/10/13, 11:01:07 AM: Samir Tabar: What exactly where you doing before all
that? ;-)

5/10/13, 11:54:34 AM: Angela Kovalesky: In a deep sleep x

5/10/13, 11:57:45 AM: Angela Kovalesky: I love my baby Samir

5/10/13, 12:17:51 PM: Samir Tabar: You should give me credit for opening
that world to you.

5/10/13, 6:01:03 PM: Angela Kovalesky: I do. So much, but I owe you a lot
for showing me a lot of big sides of who I am x

5/10/13, 6:01:52 PM: Angela Kovalesky: How was the interview?

Exhibit L

Exhibit M
From:AngelaKovalesky<a.kovalesky@gmail.com>
Sent:Thursday,May23,201311:59AM
To:samtabar@gmail.com
Subject:Fwd:WhyIKNOWChallengesareBlessings
Youaredestinedformoregreatness...
Trytoreflectonthehowsandwhyswhiletakingsomeresponsibility.Itwillhelpyoutohealandunderstandwhatyoumightneedto
dotoavoidthesethingsinthefuture.I'lldothesame,mylove.
Aboveallelse,knowthatI'mhereforyou.Ican'talwaysbethepunchingbag,butIwilldowhatIcanforyou.Always.
SentfrommyiPhone
Beginforwardedmessage:
From:"KarenBerg"<noreply@mailer2.kabbalahmail.com>
Date:May23,2013,11:14:22AMEDT
To:a.kovalesky@gmail.com
Subject:WhyIKNOWChallengesareBlessings
ReplyTo:noreply@mailer2.kabbalahmail.com
WhyIKNOWChallengesareBlessings
ThursdayMay23,2013
Manytimes,ItweetandpostonmyFacebookpageabouttheideathatthechallengeswefaceinlifeareactually
concealedblessings.Forme,thisisntjustaniceideaorclich:ItssomethingIexperienceandapplyinmylife.Id
liketosharewithyouapersonalexperiencethatIspokeaboutinmyrecentlecturetouronreincarnationandisthe
focusofthisexcerptfrommybook,GodWearsLipstick.
Myfatherdiedin1942duringWorldWarII,rightbeforeIwasborn.Motherwaslookingtomakealifeforherself,so
Ispentmostofmytimewithmygrandmother.Iwasreallyclosetoher,andwithherhelp,Iraisedmyself.Eventually,
mymothermarriedmystepdad.Youwouldthinkafterthissecondmarriage,mylifewouldhavesettleddown,butit
didnt.Altogether,Iwentto13differentpublicschools.
Itwasanomadic,unstableexperienceoneinwhichInevergottheprotectionofanormalhouseholdorfamily.And
externally,Iwasamess.Iwasfiveyearsbehindinreading,andmyclassmatesmadefunofme.Theydcallme
stupid.Onenight,somekidsthrewmeintoaconstructionpit.Istartedcrying.Icouldntgetout.IwasafraidI
woulddiedownthere.
WhyamItellingyouallofthis?IsityoursympathyIseek?Notatall.
Thatincidentwasaturningpointinmylife.ItwasthefirsttimeIeverfeltthepresenceofGod,whichcametomeas
avoiceinmyhead.
Whyareyoucrying?thevoiceasked.Dontyouunderstandwhatshappening?Youwatch.Youllsee.Theresa
reasonforeverythingthatscomedowninyourlife.Iwasonlytenyearsoldatthetime,butsincethatmoment,I
havealwaysknownthattherewasaforcegreaterthanmeandmylittleexistence.IwasbeingshapedforthelifeI
wouldlead.
AccordingtoKabbalah,whetherornotyouseeitssignificanceatthetime,everythinginyourlifehappensforareason.
Althoughyoumightbelievethisstatementintellectually,ifyoulookhonestlyatyourlife,youllprobablyfindthatyou
dontactasthoughabeautifuldesignisreallybehindeachevent.Mostpeoplethinktheirexperiencesaremostly
randomcoincidences.AccordingtoKabbalah,however,thereisnosuchthingascoincidence.Everythingis
preordained.
Thatbeingtrue,anychallengeyouencounterinlifeispartofadesignwhoseintentistohelpyougrowandchange.
Themorearduousthedifficulty,thegreatertheopportunityitaffordsyoutomendyourwaysinordertoconnectto
theLight.Thisistrueevenoftheworstsituations.Infact,themorenegativitythereisinaninteraction,themore
potentialtherewillbetorevealLight.
Ifthisstoryinspiresyoutoconnectwiththeblessingsthatareconcealedwithinyourchallenges,pleasepostyourstory
belowtoencourageandinspireothers!
Haveagreatweek.
LoveandLight,
Karen
Thisemailwassentby:
TheKabbalahCentreInternational
1100SRobertsonBlvdLosAngeles,CA90035,USA
Thisisapostonlyemail.Pleasedonotreplytothismessage.
Forallinquiries,visithttp://www.kabbalah.com/about/contact
orsendanemailtosupport@kabbalah.com
Ifyouwishtounsubscribefromthislist,pleaseclickhere

Exhibit N
5/27/13, 7:56:27 PM: Angela Kovalesky: Hi

5/27/13, 7:57:04 PM: Angela Kovalesky: Glad you like Scarlett's nipples.
I'm so glad we are over! You're such a loser.

5/27/13, 7:58:18 PM: Angela Kovalesky: And talk your shit and have people
block me. It makes me laugh that you still have no idea who you're
dealing with.

5/27/13, 7:58:53 PM: Angela Kovalesky: Read everything that I sent you
from yesterday... except the I love you... those days are GONE.

5/27/13, 8:02:27 PM: Angela Kovalesky: Just go share your pathetic,
unsophisticated, "me and my friends try way too hard" life with your bad
attitude and bad self-esteem with someone else - you're a liar, your life
is a lie and your mind is sick

5/27/13, 8:24:15 PM: Angela Kovalesky: This final straw is around
respect. You do not respect me. You have no idea how far you've pushed
me. I am done.

Exhibit O
Sent:Monday,May27,201311:00AM
To:SamTabar
Subject:Hey
I'lltrytomakethisasshortaspossible.
Whateverisgoingonbetweenusneedstoend.Iknowthatsoundslikedrama,andIknowyoususpectthatthisisanother
exampleofmelashingout,butI'mnot.I'mcryingabitasItypethis,andIknowexactlywhatI'mdoing.
ThetruthisthatthethingsthatIsaidtoyouyesterdayaretrue.YouarenotthepersonthatIthoughtyouwere,andIdon'tlikethe
personthatI'vebeendealingwithsincelastOctober.Youhavenotchangedonebit,andforallIknow,you'regettingworse.
Thisisnotaboutyouandyourdemons,thoughthat'sreasonenoughformetowalkaway.It'saboutmeworkingonmyselfand
knowingthatIdeservebetter.Idon'tlikewhatyoudowithyourlifeorthepeopleyouassociatewith,andnoneofthatisgoingto
change.Youdisrespectme,andIsincerelydonotwanttobringlittlepeopleintotheworldwithsomeonelikethat.Yourdemons
becomemine,andIdon'twantyoursanymore.IfellinlovewithyoubecauseIsawalotofmyowndarkstuffinyou,andthetruth
isthatI'vebeenworkingonmystuffanditdoesn'texistasmuchanymore...dealingwithyouistoomuch,andIdon'tknowwhat
weare...mostlybecausewearenothing.
Sam,Idon'twantustotalkanymore.Youbringmedown.Mylifehassomanywonderfulthingsgoingonbytheendofthisyear,
mysalarywillhavedoubled,andI'llbeworkingonareallycoolprogramthatwillhavemeinAfricaquiteabit,mywebsitewill
launch,I'mbuyingaplacedowninMiami,I'mcreatingahomeandcommunitywithreallylovelypeopleinWilliamsburgand
WynwoodandI'mreadyfortheloveinmylifetokeephealingme.I'mopentoit.
Anyway,youknowthatIcan'tbefriendswithyou.Idon'twanttoseeyouwhenyougettoNYC,andIdon'twanttoknowwhen
you'rehereandwhenyouleave.Ifyourlawyerneedssomething,havehimcontactme.I'masalwayswillingtohelpinanyway
thatIcanlegally.Icannotbeyourfriendthroughthisthough.Hopefullyyoucancontinuetotalktoyourbrother,andifnot,itwill
beoversoonanyway.Iamveryhappythisiscomingtoanendforyousothatyoucanmoveonaswell.
Pleasestayoutofmylife.Thisishard,andIdon'twantthisanymore.IfIgetanythingnegativefromyouviawhatsapp,Iwillneed
toblockyou.Ihopethatyouunderstand.
Angela

Exhibit P
From:SamTabar<samtabar@gmail.com>
To:AngelaKovalesky
Subject:Re:Hey
Iwillrespectyourwishes,butit'sprobablythecoldestandmostilltimedemaileverwritten.It'syourlossinwaysyoudon'teven
know.
OnMay27,2013,at11:29PM,AngelaKovalesky<a.kovalesky@gmail.com>wrote:
Tellmethatyouunderstandthisemail,andpromisemethatyouwillleavemealone...eveninseveresituationslike
somethinghashappenedtoyourfather.Thosethingsarenotformetoworryaboutandtrytohelpanymore.Doyou
understand?Wearereallyovernow,ok?
Forwardedmessage
From:AngelaKovalesky
Date:Monday,May27,2013
Subject:Hey
To:SamTabar<samtabar@gmail.com>
Whateverisgoingonbetweenusneedstoend.Iknowthatsoundslikedrama,andIknowyoususpectthatthisis
anotherexampleofmelashingout,butI'mnot.I'mcryingabitasItypethis,andIknowexactlywhatI'mdoing.
ThetruthisthatthethingsthatIsaidtoyouyesterdayaretrue.YouarenotthepersonthatIthoughtyouwere,andI
don'tlikethepersonthatI'vebeendealingwithsincelastOctober.Youhavenotchangedonebit,andforallIknow,
you'regettingworse.
Thisisnotaboutyouandyourdemons,thoughthat'sreasonenoughformetowalkaway.It'saboutmeworkingon
myselfandknowingthatIdeservebetter.Idon'tlikewhatyoudowithyourlifeorthepeopleyouassociatewith,and
noneofthatisgoingtochange.Youdisrespectme,andIsincerelydonotwanttobringlittlepeopleintotheworld
withsomeonelikethat.Yourdemonsbecomemine,andIdon'twantyoursanymore.IfellinlovewithyoubecauseI
sawalotofmyowndarkstuffinyou,andthetruthisthatI'vebeenworkingonmystuffanditdoesn'texistasmuch
anymore...dealingwithyouistoomuch,andIdon'tknowwhatweare...mostlybecausewearenothing.
Sam,Idon'twantustotalkanymore.Youbringmedown.Mylifehassomanywonderfulthingsgoingonbythe
endofthisyear,mysalarywillhavedoubled,andI'llbeworkingonareallycoolprogramthatwillhavemeinAfrica
quiteabit,mywebsitewilllaunch,I'mbuyingaplacedowninMiami,I'mcreatingahomeandcommunitywithreally
lovelypeopleinWilliamsburgandWynwoodandI'mreadyfortheloveinmylifetokeephealingme.I'mopentoit.
Anyway,youknowthatIcan'tbefriendswithyou.Idon'twanttoseeyouwhenyougettoNYC,andIdon'twant
toknowwhenyou'rehereandwhenyouleave.Ifyourlawyerneedssomething,havehimcontactme.I'mas
alwayswillingtohelpinanywaythatIcanlegally.Icannotbeyourfriendthroughthisthough.Hopefullyyoucan
continuetotalktoyourbrother,andifnot,itwillbeoversoonanyway.Iamveryhappythisiscomingtoanendfor
yousothatyoucanmoveonaswell.
Pleasestayoutofmylife.Thisishard,andIdon'twantthisanymore.IfIgetanythingnegativefromyouvia
whatsapp,Iwillneedtoblockyou.Ihopethatyouunderstand.
Angela

Exhibit Q
To:SamTabar
Subject:Re:Hey
No,Sam.Icannotbewithsomeoneeverwhofeelsit'soktolikephotosofothersonFacebookshowingtheirtits...oranyone
whoneedstobefriendswiththosesortofpeople.GocrazyoverhowIfoundthisout,Ijustdon'tcare.That'snottheheartofthe
issue.Thiswasjustthestrawthatbrokethecamelsback.AllthestuffIsaidtoyouyesterdayaretrue.ThethingsIwroteinthe
firstemailaretrue.You'rejustnotwhoIwant.I'vetriedtomakeyoubetter.Thepeoplewhosurroundyouareyourreflection,
andIjustwantpeoplewhoarealotmoresophisticated,intelligentandclassy.Idon'tdosmokeandmirrorsanymore.Idon'tdo
fake.Idon'tdofeignedaffection.
Today,IwillbedeletingeveryphotothatIhaveofthetwoofustogether.Ihaveneverwipedsomeoneoutlikethis...it'sbizarre.
OnMon,May27,2013at11:36AM,SamTabar<samtabar@gmail.com>wrote:
Iwillrespectyourwishes,butit'sprobablythecoldestandmostilltimedemaileverwritten.It'syourlossinwaysyoudon'teven
know.
Tellmethatyouunderstandthisemail,andpromisemethatyouwillleavemealone...eveninseveresituationslike
somethinghashappenedtoyourfather.Thosethingsarenotformetoworryaboutandtrytohelpanymore.Doyou
understand?Wearereallyovernow,ok?
Forwardedmessage
Subject:Hey
Whateverisgoingonbetweenusneedstoend.Iknowthatsoundslikedrama,andIknowyoususpectthatthisis
anotherexampleofmelashingout,butI'mnot.I'mcryingabitasItypethis,andIknowexactlywhatI'mdoing.
ThetruthisthatthethingsthatIsaidtoyouyesterdayaretrue.YouarenotthepersonthatIthoughtyouwere,andI
don'tlikethepersonthatI'vebeendealingwithsincelastOctober.Youhavenotchangedonebit,andforallIknow,
you'regettingworse.
Thisisnotaboutyouandyourdemons,thoughthat'sreasonenoughformetowalkaway.It'saboutmeworkingon
myselfandknowingthatIdeservebetter.Idon'tlikewhatyoudowithyourlifeorthepeopleyouassociatewith,and
noneofthatisgoingtochange.Youdisrespectme,andIsincerelydonotwanttobringlittlepeopleintotheworld
withsomeonelikethat.Yourdemonsbecomemine,andIdon'twantyoursanymore.IfellinlovewithyoubecauseI
sawalotofmyowndarkstuffinyou,andthetruthisthatI'vebeenworkingonmystuffanditdoesn'texistasmuch
anymore...dealingwithyouistoomuch,andIdon'tknowwhatweare...mostlybecausewearenothing.
Sam,Idon'twantustotalkanymore.Youbringmedown.Mylifehassomanywonderfulthingsgoingonbythe
endofthisyear,mysalarywillhavedoubled,andI'llbeworkingonareallycoolprogramthatwillhavemeinAfrica
quiteabit,mywebsitewilllaunch,I'mbuyingaplacedowninMiami,I'mcreatingahomeandcommunitywithreally
lovelypeopleinWilliamsburgandWynwoodandI'mreadyfortheloveinmylifetokeephealingme.I'mopentoit.
Anyway,youknowthatIcan'tbefriendswithyou.Idon'twanttoseeyouwhenyougettoNYC,andIdon'twant
toknowwhenyou'rehereandwhenyouleave.Ifyourlawyerneedssomething,havehimcontactme.I'mas
alwayswillingtohelpinanywaythatIcanlegally.Icannotbeyourfriendthroughthisthough.Hopefullyyoucan
continuetotalktoyourbrother,andifnot,itwillbeoversoonanyway.Iamveryhappythisiscomingtoanendfor
yousothatyoucanmoveonaswell.
Pleasestayoutofmylife.Thisishard,andIdon'twantthisanymore.IfIgetanythingnegativefromyouvia
whatsapp,Iwillneedtoblockyou.Ihopethatyouunderstand.
Angela

Exhibit R

Exhibit S
To:AngelaKovalesky
Subject:Re:Hey
YousureareputtingalotofemphasisonthingsIfindsillyandtrivialAngela.Ifyouwanttothisjustasthingsareturningacomerin
termsofarealsituation,it'syourcall.Goodnight.
No,Sam.Icannotbewithsomeoneeverwhofeelsit'soktolikephotosofothersonFacebookshowingtheir
tits...oranyonewhoneedstobefriendswiththosesortofpeople.GocrazyoverhowIfoundthisout,Ijustdon't
care.That'snottheheartoftheissue.Thiswasjustthestrawthatbrokethecamelsback.AllthestuffIsaidtoyou
yesterdayaretrue.ThethingsIwroteinthefirstemailaretrue.You'rejustnotwhoIwant.I'vetriedtomakeyou
better.Thepeoplewhosurroundyouareyourreflection,andIjustwantpeoplewhoarealotmoresophisticated,
intelligentandclassy.Idon'tdosmokeandmirrorsanymore.Idon'tdofake.Idon'tdofeignedaffection.
Today,IwillbedeletingeveryphotothatIhaveofthetwoofustogether.Ihaveneverwipedsomeoneoutlikethis...
it'sbizarre.
Iwillrespectyourwishes,butit'sprobablythecoldestandmostilltimedemaileverwritten.It'syourlossinways
youdon'tevenknow.
Tellmethatyouunderstandthisemail,andpromisemethatyouwillleavemealone...eveninsevere
situationslikesomethinghashappenedtoyourfather.Thosethingsarenotformetoworryaboutand
trytohelpanymore.Doyouunderstand?Wearereallyovernow,ok?
Forwardedmessage
Subject:Hey
Whateverisgoingonbetweenusneedstoend.Iknowthatsoundslikedrama,andIknowyoususpect
thatthisisanotherexampleofmelashingout,butI'mnot.I'mcryingabitasItypethis,andIknow
exactlywhatI'mdoing.
ThetruthisthatthethingsthatIsaidtoyouyesterdayaretrue.YouarenotthepersonthatIthought
youwere,andIdon'tlikethepersonthatI'vebeendealingwithsincelastOctober.Youhavenot
changedonebit,andforallIknow,you'regettingworse.
Thisisnotaboutyouandyourdemons,thoughthat'sreasonenoughformetowalkaway.It'saboutme
workingonmyselfandknowingthatIdeservebetter.Idon'tlikewhatyoudowithyourlifeorthe
peopleyouassociatewith,andnoneofthatisgoingtochange.Youdisrespectme,andIsincerelydo
notwanttobringlittlepeopleintotheworldwithsomeonelikethat.Yourdemonsbecomemine,andI
don'twantyoursanymore.IfellinlovewithyoubecauseIsawalotofmyowndarkstuffinyou,and
thetruthisthatI'vebeenworkingonmystuffanditdoesn'texistasmuchanymore...dealingwithyouis
toomuch,andIdon'tknowwhatweare...mostlybecausewearenothing.
Sam,Idon'twantustotalkanymore.Youbringmedown.Mylifehassomanywonderfulthingsgoing
onbytheendofthisyear,mysalarywillhavedoubled,andI'llbeworkingonareallycoolprogram
thatwillhavemeinAfricaquiteabit,mywebsitewilllaunch,I'mbuyingaplacedowninMiami,I'm
creatingahomeandcommunitywithreallylovelypeopleinWilliamsburgandWynwoodandI'mready
fortheloveinmylifetokeephealingme.I'mopentoit.
Anyway,youknowthatIcan'tbefriendswithyou.Idon'twanttoseeyouwhenyougettoNYC,and
Idon'twanttoknowwhenyou'rehereandwhenyouleave.Ifyourlawyerneedssomething,havehim
contactme.I'masalwayswillingtohelpinanywaythatIcanlegally.Icannotbeyourfriendthrough
thisthough.Hopefullyyoucancontinuetotalktoyourbrother,andifnot,itwillbeoversoonanyway.I
amveryhappythisiscomingtoanendforyousothatyoucanmoveonaswell.
Pleasestayoutofmylife.Thisishard,andIdon'twantthisanymore.IfIgetanythingnegativefromyou
viawhatsapp,Iwillneedtoblockyou.Ihopethatyouunderstand.
Angela

Exhibit T
To:SamTabar
Subject:Re:Hey
Agrownwomanputtingaphotoofhertits,someonewhowasyourbrother'sslutandprobablyyoursnow,isnotsomeoneIwant
toassociatewith.Iknowthatyoudon'tseeanythingwrongwithit,andIguessIdidn'ttoountilIgothealthy.Healthypeopledo
notdothatkindofstuff.Peoplewithselfconfidence,peoplewhoneedattentionandpeoplewhoarelonelyreachoutinthose
ways...andagainIdon'twantthatinmylife.Iamtoogoodforthatkindofenergy,andIdon'twantmypartnertodealinthat
either...soit'snotreallysilly.Thepeopleyouchoosetoassociatewithandthebehavioryourencourageisnotsilly.That'swhat
youdevotedyourenergyto,andit'spathetic.AndI'msorrytosayit,butallofthepeopleinyourlifearepathetic,it'sjusttrue.
YousureareputtingalotofemphasisonthingsIfindsillyandtrivialAngela.Ifyouwanttothisjustasthingsareturningacomerin
termsofarealsituation,it'syourcall.Goodnight.
No,Sam.Icannotbewithsomeoneeverwhofeelsit'soktolikephotosofothersonFacebookshowingtheir
tits...oranyonewhoneedstobefriendswiththosesortofpeople.GocrazyoverhowIfoundthisout,Ijustdon't
care.That'snottheheartoftheissue.Thiswasjustthestrawthatbrokethecamelsback.AllthestuffIsaidtoyou
yesterdayaretrue.ThethingsIwroteinthefirstemailaretrue.You'rejustnotwhoIwant.I'vetriedtomakeyou
better.Thepeoplewhosurroundyouareyourreflection,andIjustwantpeoplewhoarealotmoresophisticated,
intelligentandclassy.Idon'tdosmokeandmirrorsanymore.Idon'tdofake.Idon'tdofeignedaffection.
Today,IwillbedeletingeveryphotothatIhaveofthetwoofustogether.Ihaveneverwipedsomeoneoutlikethis...
it'sbizarre.
Iwillrespectyourwishes,butit'sprobablythecoldestandmostilltimedemaileverwritten.It'syourlossinways
youdon'tevenknow.
Tellmethatyouunderstandthisemail,andpromisemethatyouwillleavemealone...eveninsevere
situationslikesomethinghashappenedtoyourfather.Thosethingsarenotformetoworryaboutand
trytohelpanymore.Doyouunderstand?Wearereallyovernow,ok?
Forwardedmessage
Subject:Hey
Whateverisgoingonbetweenusneedstoend.Iknowthatsoundslikedrama,andIknowyoususpect
thatthisisanotherexampleofmelashingout,butI'mnot.I'mcryingabitasItypethis,andIknow
exactlywhatI'mdoing.
ThetruthisthatthethingsthatIsaidtoyouyesterdayaretrue.YouarenotthepersonthatIthought
youwere,andIdon'tlikethepersonthatI'vebeendealingwithsincelastOctober.Youhavenot
changedonebit,andforallIknow,you'regettingworse.
Thisisnotaboutyouandyourdemons,thoughthat'sreasonenoughformetowalkaway.It'saboutme
workingonmyselfandknowingthatIdeservebetter.Idon'tlikewhatyoudowithyourlifeorthe
peopleyouassociatewith,andnoneofthatisgoingtochange.Youdisrespectme,andIsincerelydo
notwanttobringlittlepeopleintotheworldwithsomeonelikethat.Yourdemonsbecomemine,andI
don'twantyoursanymore.IfellinlovewithyoubecauseIsawalotofmyowndarkstuffinyou,and
thetruthisthatI'vebeenworkingonmystuffanditdoesn'texistasmuchanymore...dealingwithyouis
toomuch,andIdon'tknowwhatweare...mostlybecausewearenothing.
Sam,Idon'twantustotalkanymore.Youbringmedown.Mylifehassomanywonderfulthingsgoing
onbytheendofthisyear,mysalarywillhavedoubled,andI'llbeworkingonareallycoolprogram
thatwillhavemeinAfricaquiteabit,mywebsitewilllaunch,I'mbuyingaplacedowninMiami,I'm
creatingahomeandcommunitywithreallylovelypeopleinWilliamsburgandWynwoodandI'mready
fortheloveinmylifetokeephealingme.I'mopentoit.
Anyway,youknowthatIcan'tbefriendswithyou.Idon'twanttoseeyouwhenyougettoNYC,and
Idon'twanttoknowwhenyou'rehereandwhenyouleave.Ifyourlawyerneedssomething,havehim
contactme.I'masalwayswillingtohelpinanywaythatIcanlegally.Icannotbeyourfriendthrough
thisthough.Hopefullyyoucancontinuetotalktoyourbrother,andifnot,itwillbeoversoonanyway.I
amveryhappythisiscomingtoanendforyousothatyoucanmoveonaswell.
Pleasestayoutofmylife.Thisishard,andIdon'twantthisanymore.IfIgetanythingnegativefromyou
viawhatsapp,Iwillneedtoblockyou.Ihopethatyouunderstand.
Angela

Exhibit U
Sent:Monday,May27,20132:30PM
To:SamTabar
Subject:Re:PSInstantCrush
Anapology?Areyoukidding?YouarefriendswithScarlett.Idonotwanttobearoundanyonelikeyou/her.Youlikedaphoto
ofhershowinghertitstotheworld.Ichoosenottobewithalowlifewhospendstimelikingandlookingatthatcommonfilth,and
Ichoosenottobewithsomeonewhowastesanyenergysupportingpeoplewithsuchlowselfesteemandridiculousbehavior.
Thosetwothingsaretruths,andIdon'toweyouanapology.Youowemeanapologyforwastingmytime,andyouoweyourself
anapologyforpretendingtobebetterthancommontrashallofthetime.It'sboring,andIdon'twastetimeonthethingsyoufind
tobeworthyofyourtimeasa41yearold.That'sjustme.I'mnotapologizing.Enjoyyourtramps!
OnMon,May27,2013at1:35PM,SamTabar<samtabar@gmail.com>wrote:
Goddoyoueverowemeamapologyforbringsooff
OnMay28,2013,at12:01AM,AngelaKovalesky<a.kovalesky@gmail.com>wrote:
>Ithinkit'saboutapersonwhochooses#2because#1wastoohardandheisregretfulthathedidn'tstayandfight...sonow
he'sstuckwiththeeasyone,the#2,butcan'tgetover#1...
>
>Goodluckwithyour#2.Ihopeyougethealthy,butI'vegivenuponseeingit,andI'msickoflivingonyourlevel.Iknowthat's
hardtohear,butgetbetter,Sam.Foryoursake.Lifeistoogoodforthewaythatyouchoosetolive...andyou're41.

Exhibit V
To:SamTabar
Subject:Ijustsawmorestu...
Sam,youaresuchaloser.IcannotbelievethatIwasted21/2yearsonyou.ThereisnothinginyourworldthatIenvyorwant.
Jesus,youaremostdefinitelypathetic.
Scarlettisacommontramp.Shehasbadselfesteemandapatheticallylonelyperson.
EmiliehastheugliestnoseandhandsthatI'veeverseeninmylife.Thatyouevenlikeanyofherohotosshowshowyourtastehas
mostdefinitelyfallentonewlows.
Jessicalooksmousey.Herlingerieisuglytoo.
Celesteisatroll.Anyonedoingwhatshedoesatherageisaloser.
Kimberlyisafatslob.Thatyouevenlikelookingatnakedphotosofhershowshowgrossyouare.
Thesearethepeopleyouchoosetohangoutwith,giveyourtimeandassociatewith.Youmirrorthesepeople.Ihaveneverbeen
soturnedoffinmylifebysomeonethatIusedtolove.Youdisgustme.Youarea41yearoldloser.Iwouldn'thireyoueither...
youknow,peopledolookatFacebookstuff.Growup,getalifeandgetsomeclass.Youareadisgustingoldmanyourealizethe
medianagethatyouhangoutwithislike29,right?Youaredisgusting.

Exhibit W
To:AngelaKovalesky
Subject:Re:Ijustsawmorestu...
You'rereallytoomuch.Noteveryonehastobeperfecttobefriends.
Pleasestopstalking,Angie.
>Sam,youaresuchaloser.IcannotbelievethatIwasted21/2yearsonyou.ThereisnothinginyourworldthatIenvyorwant.
Jesus,youaremostdenitelypathec.
>
>Scarleisacommontramp.Shehasbadselfesteemandapathecallylonelyperson.
>
>EmiliehastheugliestnoseandhandsthatI'veeverseeninmylife.Thatyouevenlikeanyofherohotosshowshowyour
tastehasmostdenitelyfallentonewlows.
>
>Jessicalooksmousey.Herlingerieisuglytoo.
>
>Celesteisatroll.Anyonedoingwhatshedoesatherageisaloser.
>
>Kimberlyisafatslob.Thatyouevenlikelookingatnakedphotosofhershowshowgrossyouare.
>
>Thesearethepeopleyouchoosetohangoutwith,giveyourmeandassociatewith.Youmirrorthesepeople.Ihavenever
beensoturnedoinmylifebysomeonethatIusedtolove.Youdisgustme.Youarea41yearoldloser.Iwouldn'thireyou
either...youknow,peopledolookatFacebookstu.Growup,getalifeandgetsomeclass.Youareadisgusngoldman;you
realizethemedianagethatyouhangoutwithislike29,right?Youaredisgusng.

Exhibit X

To:SamTabar
I'mdonebecauseI'mdonewithyou.Iwasjustlaughingshowingmyfriendsthisstuff.Don'tworry!
But,seriously,getsomerealfriends...
>
>Scarlettisacommontramp.Shehasbadselfesteemandapatheticallylonelyperson.
>
>EmiliehastheugliestnoseandhandsthatI'veeverseeninmylife.Thatyouevenlikeanyofherohotosshowshowyourtaste
hasmostdefinitelyfallentonewlows.
>
>
>
>
>Thesearethepeopleyouchoosetohangoutwith,giveyourtimeandassociatewith.Youmirrorthesepeople.Ihavenever
beensoturnedoffinmylifebysomeonethatIusedtolove.Youdisgustme.Youarea41yearoldloser.Iwouldn'thireyou
either...youknow,peopledolookatFacebookstuff.Growup,getalifeandgetsomeclass.Youareadisgustingoldmanyou
realizethemedianagethatyouhangoutwithislike29,right?Youaredisgusting.

Exhibit Y
Subject:Reminder
Youaresuchaloser.Icannotbelievehowmuchyoufooledme,butI'msuperhappyyourpoisonnolongerexistsinmylife.
Everyonewhotrulyknowsyoudespisesyou.Youareafakeandacon.Yoursoulisdarkandugly...justlikethewhoresinyour
patheclife.Canyoubelieveyouareinyour40shangingoutwithslutsintheir20s?Loser.
Now,I'mdoneandfeelbeerthatyouknowhowItrulyfeelaboutyou.AndI'mhappythatInowseetherealyou.
SentfrommyiPhone

Exhibit Z
To:SamTabar
BTW,areyougoingtoThailand?Ididn'tthinkso...
I'mtryingtothinkofotherplacesyoucanseekout20yearold"friends",butcan'tthinkofany.
Youneedsomedeep,spiritualattention.Like,yesterday.
>
>
>EmiliehastheugliestnoseandhandsthatI'veeverseeninmylife.Thatyouevenlikeanyofherohotosshowshowyourtaste
hasmostdefinitelyfallentonewlows.
>
>
>
>
>Thesearethepeopleyouchoosetohangoutwith,giveyourtimeandassociatewith.Youmirrorthesepeople.Ihavenever
beensoturnedoffinmylifebysomeonethatIusedtolove.Youdisgustme.Youarea41yearoldloser.Iwouldn'thireyou
either...youknow,peopledolookatFacebookstuff.Growup,getalifeandgetsomeclass.Youareadisgustingoldmanyou
realizethemedianagethatyouhangoutwithislike29,right?Youaredisgusting.

Exhibit AA

To:SamTabar
Well,good.Atleastyouhaveonepersoninyourlifewithsomesubstance.Ohwait,I'mnotinyourlifeanymore.It'sok,goodness
doesn'tsticktoyou,sojusthangwithyourhoodrats.
Yeah.You'rereallyanenlightenednonjudgementalpersonyourself.Youaretotallyspirituallyaccomplished.Iadmireyouso
muchAngie.
BTW,areyougoingtoThailand?Ididn'tthinkso...
I'mtryingtothinkofotherplacesyoucanseekout20yearold"friends",butcan'tthinkofany.
Youneedsomedeep,spiritualattention.Like,yesterday.
>Sam,youaresuchaloser.IcannotbelievethatIwasted21/2yearsonyou.ThereisnothinginyourworldthatI
envyorwant.Jesus,youaremostdefinitelypathetic.
>
>
>EmiliehastheugliestnoseandhandsthatI'veeverseeninmylife.Thatyouevenlikeanyofherohotosshowshow
yourtastehasmostdefinitelyfallentonewlows.
>
>
>
>
>Thesearethepeopleyouchoosetohangoutwith,giveyourtimeandassociatewith.Youmirrorthesepeople.I
haveneverbeensoturnedoffinmylifebysomeonethatIusedtolove.Youdisgustme.Youarea41yearoldloser.
Iwouldn'thireyoueither...youknow,peopledolookatFacebookstuff.Growup,getalifeandgetsomeclass.
Youareadisgustingoldmanyourealizethemedianagethatyouhangoutwithislike29,right?Youaredisgusting.

Exhibit BB

Sent:Tuesday,May28,20133:04AM
Subject:Jeremy
Iwillbecontacngyourlawyerlateraboutafewthings.I'mtellingyouthissoyouhaveaheadsupanddon'tgocrazywhenhe
tellsyouI'vecontactedhim.
Isllthinkyou'retrashanduerlypathec.Getyourfuckingshittogether.Youareafuckingpunchline;tome,toCelesteand
everyoneelseinyourlifewhousedtorespectyou.Ican'timaginethatthisisn'tyourboom...I'membarrassedthatwewere
inaseriousrelaonship.Imean,doyouhavenoselfrespect?YouarelookingforthingsinalloftheWRONGplaces.Ihave
neverbeenmoreashamedofanyoneinmyenrelife.I'mserious.Iswearonyourfatherthatthisistrue.
Get.It.Together.Stopbeingsofuckingaverage.You'renot.Ihavezerorespectforyourightnow.Zero.Iknowthissounds
mean,buteverythingaboutyourlifeisdisgusng;thepartsthatyoucancontrolmorethanthepartsyoucan't.Whatiswrong
withyou?!?!It'snotcute,Sam.IfIneedtobethebadguyandbetruthful,sobeit.
Iamuerlyabbergastedathowlameyourlifehasbecome.Youareembarrassing.Ican'tbelievethatthepersonIcherished
morethananythingissuchaloser...Fixyourfuckinglife,anddon'ttellmeyou'retryingwhenclearlyyouarepungpeople
whoaresofuckinglamearoundyou!Iamshocked.
Ifyouwanttohavearealconversaon,youcanemailmeback,otherwisedonotbother.YouknowthatIhaveverystrict
standardsonthoseIputinmylife,andthepersonyouarenowdoesnotmakethecut.Ijustcan'tstopthinkingabouthow
pathecyou'vebecome...andI'mnotsadbecauseI'msoshocked.YouknowthatI'malwayshonestwithyou,soCHANGEand
doyourselfaworldofgood.
SentfrommyiPhone

Exhibit CC

To:SamTabar
Subject:Re:
Whereareyougoing?
SentfrommyiPhone
OnMay28,2013,at3:37AM,SamTabar<samtabar@gmail.com>wrote:
>Angeladonotplaywithre.Thisismylifeandhasreallifemeramicaons.Youcannotgothere.Youcommitedtomethat
youwould.Youpromised.
>
>Iamleavingonaightsoon.Iamnowinnervousconvulsionsbecauseyouarefuckingwithmeinthis.Thisismajorandhas
liferamicaonsAngela.Donotdothisatthislastminute.Iknowyouweregoingtoforthis.Donotmakemynightmarescome
true.

Exhibit DD

To:SamTabar
Subject:Re:
Anddon'tlietome.I'llndoutthetruth.
SentfrommyiPhone
>
true.

Exhibit EE

To:SamTabar
Subject:Re:
Youshouldreallyfuckinganswerme.Andwiththefuckingtruth.
SentfrommyiPhone
>
true.

Exhibit FF

To:SamTabar
Subject:Re:
lol,you'refuckingwithmeagain,aren'tyou?!Youneverlearn,doyou?
SentfrommyiPhone
>
true.

Exhibit GG

To:SamTabar
Subject:Re:
Well,somethingisupbecauseyourphonehasbeenoformorethan24hours,soI'llassumeyou'relyinglikeusual.
SentfrommyiPhone
>FuckingSingaporeassholeandthenbacktoHongKong
>
>OnMay28,2013,at3:52PM,AngelaKovalesky<a.kovalesky@gmail.com>wrote:
>
>>Youshouldreallyfuckinganswerme.Andwiththefuckingtruth.
>>
>>SentfrommyiPhone
>>
>>OnMay28,2013,at3:37AM,SamTabar<samtabar@gmail.com>wrote:
>>
>>>Angeladonotplaywithre.Thisismylifeandhasreallifemeramicaons.Youcannotgothere.Youcommitedtome
thatyouwould.Youpromised.
>>>
>>>Iamleavingonaightsoon.Iamnowinnervousconvulsionsbecauseyouarefuckingwithmeinthis.Thisismajorandhas
true.

Exhibit HH

To:Asshole
Andwhywouldcommon,trampyScarleblocksomeonelikemeonFacebookunlessyousaidsomethingtoher?Youbeer
watchyourfuckingself,asshole.ThatIamveryfuckingseriousabout.I'mnotlikeyourotherexes.Youtalkshitaboutme,andI
willfuckingbringittoyoulikenooneelse.Icouldcarelessaboutyouandyournobodies,sowatchit.Iamnotprotecngus
anymore,soyouhavenothingtoworryabout.Iwilllaunchnopreempvestrike,butIwillalwaysprotectmyself...Knowthat.
SentfrommyiPhone

Exhibit II

To:SamTabar
Subject:Peace
Idon'tknowifyouwantthis,butyouhavemyfriendshiprightnow.Iknowhowhardthismustbeforyou,andgiventhesortof
peopleinyourlife,Ifeelbadabandoningyouwhenyoumightneedme.
So,letmeremindyouofafewthings...
YouareoneofthemostcompetentpeoplethatIknow.Youhaveaskillsetthatnotmanyshare.Rememberyourstrengthsand
alwayshighlightthem.Youareverycharming,sojustbackitwithasmuchconfidenceasyoucanmuster.
TakedowneverythingthathastodowithpartiesandBurningManfromyourFacebookpage.Ifyouhaveanyprofessionalthings
onyourwallthatareworthmentioning,makesurethattheyarepublic.Youdonothaveapartner/wife,sopeoplewanttofeellike
you'restableandgrounded...theylookatthisstuff,anditmakesadifference.Believeme,Iknow.
Continuetomakesureyouareorganized...bothinyourhotelandbeforemeetings.Getlotsofrestandconcentrateonlyonthe
possibilitiesthatareinfrontofyou.Iflifearoundyouisorganized,yourmindwillbetoo.
Mostofall,rememberyouarethebestthebestinthewest.
Goodlucktomorrow.

Exhibit JJ

Sent:Wednesday,May29,20135:46AM
To:SamTabar
Ifyoudon'trespondbacktothis,I'mcontactingyourbrotheroryourparents.Iwanttoskype.Whencanwedothat?

Exhibit KK

To:SamTabar
Ijustemailedyourbrother.PleasetellhimtocheckhisFacebookmessages.
SentfrommyiPhone

Exhibit LL

To:SamTabar
Subject:Jeremy
Hewillbeemailingyoutodaytotalkabouttheconfidentialityagreement.Iwanthimtoaddsomethingstatingthatifyoutalkabout
metoothers,aboutthissituationoranythingelseinaderogatoryway,Iwillhavejustcausetobringyoutocourt.
Andletmebreakitdownforyoumore...
YouhavenorighttolietoothersaboutmeforcingthemtoblockmeonFacebook.Theonlypersonthatwouldhavedonethatis
you,whichmeansyouareassaultingmypersonandmyreputationbecauseofthedomesticviolencethatoccurredfinFebruary.
IwillbeallowedtotakeyoutocourtifIsensethisiscontinuing.IwillsubpoenaScarlettandanyoneelsenecessary.
Thanksforyourcooperation.I'mlookingforwardtothisbeingover.ThisisthepaperworkIwastellingKarimabout,sojusttake
careofitinadvanceofyourcourtdateplease.
Angela

Exhibit MM

To:AngelaKovalesky
Angela,pleaseleavemealone.IamdonewithSingapore.Iamgonnahavedownmewithmyselfandfriends.Iamgoingto
takeiteasyforafewdays.Iamgoingtozoneoutandbeacveandhealthy.
Legally,ifyouwanttoscrewmylifeup,that'syourcall.Shameonyouifyoudo.Shameonyou.
JeremyspoketomeandI'mhappytogiveyouwhatyouwant.It'sridiculoustothinkI'dspreadthataround.Lastly,it'stotally
outoflinetoemailCeleste.Pleasestopscrewingaroundwithotherpeople'slives.Juststopit.Leavemealone.Iamnot
buggingyouorsendingmessagestoyourfriendsetc.Iamnottryingtogetinvolvedinyourlife.
Leavemealone.

Exhibit NN

To:AngelaKovalesky
Subject:Re:
Angela,therearemassiveramificationsformeifyoupursuethis.Jeremyhasinformedmeoftheramifications.Ifyoudothis,I
literallywillneverbeabletogetajobbecauseitwillbeonpublicrecord.
YoucangotoBurningMan,doanythingyouwant.Justlet'sleaveeachotheralone.Ifyouwantafinancialcompensationabout
something,wecandothat.BMisapubliceventandIamhappytostayawayfromyou.
PLEASEDONOTDOTHIS,IBEGYOU.PLEASEDONOTFUCKMYLIFEUP.STOPTHETORTURINGME,
PLEASE!!!!!!!!!!!!!!
OnThu,May30,2013at4:13PM,AngelaKovalesky<a.kovalesky@gmail.com>wrote:
Iwillbepursuingapartialorderofprotection.Iwillaskforittoextendthroughoutthesummersinceyou'vethreatenedmeabout
BurningMan.Ican'thaveyouthereunderthosethreats.Ijustcannnot.I'msorry.Iknowthatyou'vewantedtogothisyear,butI
needtotakeyourthreatsseriously.
HavefuninBali.I'lltalktoJeremy,nosweat,butI'llprobablybegettingmyownlawyerfromnowon.
OnThu,May30,2013at2:58AM,SamTabar<samtabar@gmail.com>wrote:
Angela,pleaseleavemealone.IamdonewithSingapore.Iamgonnahavedowntimewithmyselfandfriends.Iamgoingtotakeit
easyforafewdays.Iamgoingtozoneoutandbeactiveandhealthy.
Legally,ifyouwanttoscrewmylifeup,that'syourcall.Shameonyouifyoudo.Shameonyou.
JeremyspoketomeandI'mhappytogiveyouwhatyouwant.It'sridiculoustothinkI'dspreadthataround.Lastly,it'stotallyout
oflinetoemailCeleste.Pleasestopscrewingaroundwithotherpeople'slives.Juststopit.Leavemealone.Iamnotbuggingyou
orsendingmessagestoyourfriendsetc.Iamnottryingtogetinvolvedinyourlife.
Leavemealone.

Exhibit OO

Exhibit PP

/
F.C.A. 812,818,821
FMOLYCOURT: STATEOFNEW YORK
. COlJ'NTY OF laNGS .
-- ---.. --'" --X
Angeln Kovalesky (3/26179),
Petitioner,
-aglM:<l-
Samir Tabar (6/12172),
Respondent.
- - - ----- -----..- - - --- - ..X
TO THE FAMILY COURT:
Fonn 8-2
(Family Offense Petition)
207 f/i'v
DocketNo.:
FAl\1JLY
OFF,ENSE PETITION
f
,I
i'
/
t.,
r
The w;tdersigned.Pe4,tioner, respeqtfuily shows t,hat:
" l'I';;40s at, Ave'l.1.fe,
", , Brooklyn" NYU21L " , '.'. .,.'
'. ' .
2.Respondent, SmnirTabar,resides il:l an unknown address.
3.Upon informatioD and belief the Respondent who is in Iln intimate
relationship with the Petitioner cotntnj.tted an act or acts, wh.i.ch constitute:
(disorderly conduct) (aggTavatcd harassment in the second
(harnssmentin the degt"Q) tile seco eel (mcnacittg
inthe second degree) (menacing inthe third degree! 'eckli:ss endangennent)
(assault in the second degree) (assaultiu the third degree) (attempted assault)
(sWking in tbe first degree) (smlking in the $econd degree)(stalking in the
third degree) tsfAliCll1g In llie IIJWIJ' (criwincl
misconduct) (forcible touching) (sexual abuse in the third degree) (sex\llIl
abuse in the second degree) (criminal obstrl1ction ofbte'athing Or blood
..iJ;culation) (strangulation in the second degroe) (strangulation in the first
degree) toward Petitioner, in that:
In reverse cbronologi..lIl order;
(a) On or about Febl'UEliy 7tb, zon, at Petitioner's apartrocnt, Respondent
punched Petitioner with a list in Petitioner's arms and legs,
kickedPetitioner repeatedly, head.b\ltled Petitioller in the ribs, ;,pit on
Petitiol\er and strangled Petitioner with Respondent's lorellI1l:l Wl!il'
Petitioner could noi breathe. Petitioner called 911 atabout2:30arn
inunediately following i:his attack, at which point Respondent left
, .'
I;
1
/
I
,
S2.[68T62T2T:01
bbb99899TST
Y
'
"
/
,/. .
',I
.. . _-
c
4. The following aggravating circumstances, if any, are present in thiS case;
A. Use ofa dangerOus lns,trUment against petitioner by the ReSp6ndent, .
B. History of;e;peated vioiations by the Respondent,
." .
. , , ' . . , . .
C. Behavior Md occUrrences which cpnstltute an immediate and oUgoing .-.
dRAgee to the Petition'lt. .'
1. Upon nuonnClhorl "Cla. bohU, \11. '1'ldmYJ, JII'IIWI'lJ;nOw.c>.1 or j '",:n..1]
COt1rt proceedings involving the ,re"'Pondent have been filed:
.None/not applicable
: . , ...
. ,
5.Indicate whether a previous application has beenm3de to any court qr judge .
for the relief' requested herd.ll and, usc, therelier, liMy,granted and the date
of such relief: . .
.6, (Upon licensed license
application pending to carry, possesS,repail:, seUorcifuerwise dispose of the
folJowilili:'llrearms [if known, specifytypc offirean:ns, type ofliClmSe(s), date
of issuance oflicensees) and expiration datc(s), whether license has been
suspended or revoked and, ifso, the date ofsu,cllaction and. if not curi:ently
licenscd, whether licen.seappUeation ispcnding]:
",' ..
. NQnc/notapplicable ..
.. :. .;,
...., .
",
3
None/not applicable .
7.(Upon information and Respondep.tis in possession .'.
lioeo.ses and unlicensed:fi:reaJ:mJl [specifynlimber and.type .'
whether licensed or unIicepsed,ifk.npwil]; " '"
, None/not applicab!; . '
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8.(0pon iuforination and belief) There is ,subshmtial risk that ti::spondentinay .
use or thl'caten to use a fuc;ijffi1llJl1awfully llgainst petitioner (and members of
petitioner's family or household) for the following reasoDs:
None/not applicable
WHEREFORE, petitioner prays
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XERWCAIION
being duly sworn, ',says that she is the Petitioner in the above entitled
proceeding. and that the foregt/fig petition Is 1nle,"to her ,own' knowlodge, except ll,'l to
matters therein stated tobell.lleged on information and belief and totb,ese matters she
beHeves it to be trui:.' " .
sky
On the 25th day of June 2013, before me petsol1Jl!ly camcPetitiouer, to me,
known to be the indh'idua.! described and who executed the foregoing o(rense
petition, and ac,knowledged that she executed said family offense petition.
NOTARYPUBLIC
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GPj 11201U
lib tu.rther ordered thaI this lempOl'lllj' order ofprOl.<:lioo re,nain in foreo until and including Augost 05, 2013;
but ifyou./lill to appolll"in. oourt 011 this the order mtly be extended and contInue in effeclll1llil 0 date by the Court.
[02J jj't,m assoul, "W""",.d m01lO.Oing, rockloss
s=gulatlon, criJuinal obstructioll ofbrc.lhing or clrculation, disorderly crilnin.1 mi.cW.J; .OXllal abu'e,
s=1 misconduct, forciblo touching, intimidation, threat'! or any criminal offillUe agnlnsl Angola Kovalosky
(DOB: 03/26/1979);
ENTltR
Hunutable William Fl'Anc Perry
25, 2013 Doted:
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The FamIly Court Act provides that presentlltion ora copy ofthis order ofprotection to My police officer or offiCilT
acting punll""t to hi. or her specilll duties IUlthonzcs, and somelim requil'c., tho officer to mcst perjon who is oJIeged to .
have violatod its terms and to bring him or ber befor. the court to pctmltiesauthorized by law,
Yedoralluw requlr.. thai this order i. offcctivo owidc, os well 05 insIde, New York Slale. It must be hOllQ..d and
enforoed by state and 1rlba' includi.ng courts of a stale, tho District of Columbia, a commonwolllth, territory or
ofthe Utiited State.. lfthe poIson r<:,tr'lnod by tho order is an intimate portner oflhe prote<led party WId hlls or will be affordod
ressooable notioeand opportunity to bo heord in aeoordonee with state lawsufficient to protect duo proc.ss right. (18 U.S.C.
226S, 2266).
It I. 0 redero) crIme to:
oro.. state line. 10 violnto this order or to stalk, lwa;I,or commit domestio violenoo agninsr IIfi inrimote porrn.r Or family momber;
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1"1,,_/ 'r'ln'IU'III, '" ,,11, .., Ii"".. III 'III "",",,,":1 :........hilt:! thb Ordur ttlIrtlLinO' .in Cltl'8." f.t'tat.1
Is a limited exception form1lilor)' or law cnforcelllOllt offioer. but <only while they ore on duty) : and
buy, possess or trllllSfer 0 handgun, rifle, shotgutl or other firelUIll or aaununllion after 0 eOoviotlon or. domestic
vlolenc.o..latod orfrne involviog the use or attempted use ofphy,ical forea or 0 deadly weapon ogainst on intimale portner or
family member. even after this Order h.., expired (18 U,S,C, 922(g)(8), 922(1)(9), 2261, 2261 A, 2262).
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PURSUANT TO SECTION 1113 OF nmFAMILy C01JR.T AC;t, AN APPEAL FROM D1IS ORDER MUST BE TAKI!N
WllHIN 30 DAYS OF RECEIPT OF THE ORDER. BY APPELLANT IN COURT, 3S DAYS FROM THE DATE OF
MAILING OF THE ORDER TO APPELLANT BY nlE CiEro:: OF COURT, OR. 30 DAYS AFTI:m. SERVICE BY A
PARTY OR THE AHORNEY FOR THE CHll.D UPON THE APPEI.LANT, WHICflEYER IS EARLIEST,
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