JURISDICTION AND VENUE
- Pursuant to Code of Civil Procedure §§ 395 and 395.5, jurisdiction is proper in California
because the harms and obligations alleged herein occurred in this judicial district, and the
amount of Plaintiff’s damages exceed the jurisdictional minimum of this Court.
2. This Court has personal jurisdiction over Defendants pursuant to Code of Civil Procedure
§ 410.10. Defendants, through their internet postings, manifested the intent to target and
focus on Plaintiff’s personal and professional reputation. Therefore, Plaintiff was directly
impacted and injured by Defendants’ wrongful actions in Los Angeles County.
3. Venue is proper before this Court because, inter alia, Defendants reside and/or do business in
Los Angeles County, and/or each of the acts, events, occurrences, or transactions referred to
herein occurred in Los Angeles County, and/or had the proximate effect of causing damages
to Plaintiff therein.
PARTIES
4. Plaintiff Kapish Haldia (“Plaintiff”) is, and at all times mentioned herein, was an individual
residing or doing business in Los Angeles, California.
5. Defendant Cody Mattingly (“Defendant”) is, and at all times mentioned herein, was an
individual residing or doing business in Los Angeles, California.
6. The true names of Does 1 through 20, inclusive, are unknown to Plaintiff at this time.
7. Plaintiff sues those Doe Defendants (collectively “Doe Defendants”) by such fictitious names
pursuant to Code of Civil Procedure § 474.
8. Plaintiff is informed and believes, and based on that information and belief alleges that each
of the defendants designated as a Doe is legally responsible for the events and happenings
referred to in this complaint, and unlawfully caused the injuries and damages.
COMPLAINT
9. Plaintiff is informed and believes, and based on that information and belief alleges that at all
times mentioned in this complaint, defendants were the principals, agents, co-conspirators,
and/or employees of their co-defendants, and in doing the things alleged in this complaint,
were acting within the course and scope of such agency and employment.
COMMON FACTS AND GENERAL ALLEGATIONS
10. Plaintiff is not a public official, public figure, or limited-purpose public figure within the
meaning of California Civil Code §§ 45, et seq.
11. Plaintiff is a successful businessman and holds a good reputation in the community.
12. Plaintiff signed up for an online dating website several years ago which required all members to be
over the age of eighteen years.
13. On or about February 26, 2022, Plaintiff started communicating with an individual on the online
dating website.
14. Plaintiff was not soliciting sex from any minor.
15. Plaintiff did not arrange a meeting with any minor or a person that he believed to be a minor.
16. Plaintiff was not motivated by an abnormal or unnatural sexual interest in any children.
17. Plaintiff did not intend to expose or have any minor expose his genitals, pubic or rectal area or
to engage in lewd or lascivious behavior with any minor at the meeting.
18. On or about February 26, 2022, Plaintiff confirmed a date with that individual who he had met on
the online dating website.
19. On or about February 26, 2022, an individual showed up on Plaintiff’s property and started flashing
a light in his face and recording him without consent. Plaintiff had never met that individual and did
not know him.
20. On or about February 26, 2022, Plaintiff’s video was posted on the following websites: (1)
Instagram account
u/peoplevpreds; (2) YouTube account People v. Preds; (3) Instagram account
u/netpredators; and 4)
www.netpredators.com.
21. Plaintiff’s personal information was listed on
https://www.instagram.com/peoplevpreds/?hl=en
wherein multiple comments were posted, including, but not limited to, threats of violence,
requests from the general public to contact Plaintiff’s employer to get him fired, and messages
to Plaintiff stating that he should commit suicide.
22. Plaintiff has received multiple voicemails from the unknown individual who video recorded
him outside Plaintiff’s property screaming and threatening to call his employer.
23. Plaintiff’s private phone number, email, address and other personal information were posted on
https://netpredators.com/kapish-haldia which also published his relatives’ phone numbers and
personal information. Defendant’s conduct constitutes “doxing” which is illegal in this jurisdiction.
24. Defendant posted Plaintiff’s picture on
https://mobile.twitter.com/netpredators and stated: “Venice,
California; Kapish, a vice president at Highview Capitol, invited a 15 year old boy over.”
25. The videos were created and published by Defendant wherein Plaintiff was falsely referred to as a
“pedophile” on the internet.
26. The videos were edited by Defendants which in fact their social media accounts have a history of
editing videos and photoshopping conversationsto cause harm against their victims.
27. On or about February 26, 2022, Plaintiff’s videos were seen by the general public and multiple
comments were posted on the above-listed websites.
28. Furthermore, the Instagram account @peoplevpreds encouraged its followers to contact Plaintiff’s
employer, family, and friendsto disseminate the false statements.
29. On or about February 28, 2022, Plaintiff and his family and friends received false, derogatory, and
homophobic remarks that stem for the video.
30. Plaintiff’s parents started getting messages on their personal mobile numbers and social
media accounts, including, but not limited to, their company accounts stating their son is a
pedophile
