Terpeshore Maras Dominion Complaint

IN THE UNITED STATES DISTRICT COURT FOR THE
MIDDLE DISTRICT OF TENNESSEE

NASHVILLE DIVISION
Terpsehore Maras,
Plaintiff, Civil Action No. : _____________
v. JURY DEMAND
US DOMINION, INC., DOMINION

VOTING SYSTEMS, INC., and
DOMINION VOTING SYSTEMS
CORPORATION,
Defendants,
VERIFIED COMPLAINT
COMES NOW Plaintiff Terpsehore Maras, by and through undersigned counsel and pursuant
to 28 U.S.C. § 1332, hereby files this Verified Complaint for defamation and would show unto this
Honorable Court the following:
I. PARTIES
1. Plaintiff Terpsehore Maras (hereinafter “Plaintiff”) is a resident of the State of Ohio
and she currently resides in Cleveland, Ohio.
2. Defendant US Dominion, Inc. is a resident of Colorado with a principal place of
business located at 1201 18th Street, Suite 210, Denver, Colorado 80202.
3. Defendant Dominion Voting Systems, Inc. is a resident of Colorado with a principal
place of business located at 1201 18th Street, Suite 210, Denver, Colorado 80202.
4. Defendant Dominion Voting Systems Corporation is a resident of Colorado with a
principal place of business located at 1201 18th Street, Suite 210, Denver, Colorado 80202.
Case 3:21-cv-00636 Document 1 Filed 08/16/21 Page 1 of 8 PageID #: 1

II. JURISDICTION AND VENUE
5. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1332 as complete
diversity exists and the matter in controversy exceeds $75,000 exclusive of interests and costs.
6. The Defendants, US Dominion, Inc., Dominion Voting Systems, Inc. and Dominion,
are subject to the general personal jurisdiction of this Court pursuant to Fed. R. Civ. P. 4(k)(1)(A) and
because of systematic and continuous contacts within the State of Tennessee render it at home here.
Tennessee Secretary of State, Business Entity Detail for Dominion Voting Systems, Inc.,
https://tnbear.tn.gov/Ecommerce/FilingDetail.aspx?CN=2292552400502470381420042441691820
58244126001138 (last accessed August 16, 2021).
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7. The Defendants transact business in Williamson County, Tennessee.
8. The Defendants are subject to the general personal jurisdiction of this Court pursuant
to Tenn. Code Ann. § 20-2-223.
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9. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)(2). Defendants’
defamatory statements were published in this District, Defendants regularly conduct business within
this District by supplying Williamson County, Tennessee with electronic voting machines and
Defendants’ receive revenue from conducting business in this District.
III. STATEMENT OF FACTS
10. On November 29, 2020, Plaintiff Terpsehore Maras swore under oath and penalty of
perjury that the testimony she provided was true and correct to the best of her knowledge.
11. On December 2, 2020, Plaintiff’s Affidavit was filed as Exhibit 13 in Sidney Powell’s
election fraud case styled, Tyler Bowyer et al. v. Doug Ducey, in his official capacity as the Governor
of the State of Arizona et al., United States District Court for the District of Arizona, Case No. 2:20-
cv-02321-DJH.
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12. Plaintiff is the Declarant/Affiant who signed the Affidavit attached as Exhibit 13.
13. Plaintiff’s sworn testimony explained the foundations of her expert opinions and
personal knowledge then addressed the concerns she had regarding foreign interference in our
elections through hardware components from companies based in foreign countries with adverse
interests among other concerns. Complaint, ¶ 80, Bowyer v. Ducey, Case No. 2:20-cv-02321-DJH (D.
Az. 2020) (attached as Exhibit 1).
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14. According to the Court’s Order, entered December 9, 2020, the United States District
Court for the District of Arizona stated: “But perhaps more concerning to the Court is that the ‘expert
reports’ reach implausible conclusions often because they are derived from wholly unreliable
sources.” Order, p. 25. Bowyer v. Ducey, Case No. 2:20-cv-02321-DJH (D. Az. 2020) (attached hereto
as Exhibit 2).
15. The Court’s Order never stated that Plaintiff’s sources were wholly unreliable.
16. The Court’s Order never mentioned Terpsehore Maras’ name.
17. The Court’s Order never discussed Plaintiff’s testimony.
18. The Court’s Order never stated Plaintiff’s testimony was false.
19. On January 8, 2021, Dominion filed suit against Sidney Powell, Sidney Powell, P.C.
and Defending the Republic, Inc. for defamation and deceptive trade practices.
20. In suing Sidney Powell for defamation, Dominion defamed Plaintiff.
21. Dominion falsely stated that “The ‘wholly unreliable sources’ put forward by Powell
and Wood in that case (whose declarations were posted on Powell’s fundraising website) included
Terpsichore [sic] Maras-Lindeman [sic], Russell Ramsland, William, Briggs, and Josh Merritt a.k.a.
‘Spyder.’” Complaint, ¶ 82, Bowyer v. Ducey, Case No. 2:20-cv-02321-DJH (D. Az. 2020).
22. Every single Paragraph in Terpsehore Maras’ Affidavit is sworn testimony given
under oath and penalty of perjury. Affidavit of Terpsehore Maras (attached as Exhibit 3)
23. Defendants using plaintiff’s affidavit as evidence for defamation.
24. The Defendants libeled and defamed Plaintiff in a defamation suit against Sidney
Powell.
25. Defendants have not disproved any allegation in Plaintiff’s Affidavit.
26. Defendants have not disproved any Paragraph in Plaintiff’s Affidavit.
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27. Defendants cannot disprove any Paragraph in Plaintiff’s Affidavit
28. The Defendants have libeled Plaintiff in Plaintiffs’ Complaint, In the United States
District Court for the District of Columbia, Case No. 1:21-cv-00040, filed January 8, 2021. (attached
hereto as Exhibit 4).
29. Therefore, the Defendants are declaring that the Plaintiff is guilty of the crime of
perjury by portraying it as false information.
30. Dominion had no applicable privilege or legal authorization to make these false and
defamatory and libelous statements about the Plaintiff.
31. Dominion published the above-referenced statements with actual malice, knowing or
recklessly disregarding that they are false.
32. Plaintiff is entitled to punitive damages pursuant to Tenn. Code Ann. § 29-39-104, as
there is clear and convincing evidence and sworn testimony that Defendants have not proven false.
33. Plaintiff contends that the punitive damages cap is unconstitutional pursuant to The
Constitution of the State of Tennessee, Art. I, Sections 6 and 17.
34. Dominion’s statements are defamatory per se.
35. Dominion’s false statements have exposed Plaintiff to the most extreme hatred and
contempt and has harmed Plaintiff’s professional reputation and her credibility.
36. There are no accusations that could do more damage to Plaintiff’s integrity, ethics and
honesty.
WHEREFORE, as a result of the foregoing, Plaintiff would respectfully request that proper
process be issued and served on Defendants, requiring them to Answer under oath with a Verified
Answer in the time period allotted by law, and that this Honorable Court would award Judgment in
Plaintiff’s favor against the Defendants as follows:
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1. awarding Plaintiff compensatory damages of not less than $1,700,000,000;
2. awarding Plaintiff punitive damages of not less than $1,700,000,000;
3. awarding Plaintiff all expenses and costs, including attorneys’ fees;
4. awarding Plaintiff pre- and post-judgment interest;
5. granting a narrowly tailored permanent injunction requiring the removal of all the
Defendants’ statements that are determined to be false and defamatory and enjoining
the Defendants from repeating such statements in the future;
6. such other relief as the Court deems appropriate; and
7. Plaintiff’s further demand a jury of twelve persons to try all issues joined herein.
Respectfully submitted this 16th day of August, 2021.
THE NEWMAN LAW FIRM
By: /s/Russell A. Newman _

Russell A. Newman, BPR # 033462
6688 Nolensville Road
Suite 108-22
Brentwood, TN 37027
(615) 554-1510 (Telephone)
(615) 283-3529 (Facsimile)
E-mail:russell@thenewmanlawfirm.com
Attorney for Plaintiff Terpsehore Maras
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IN THE UNITED STATES DISTRICT COURT FOR THE

MIDDLE DISTRICT OF TENNESSEE

Plaintiff, Civil Action No. : _____________

US DOMINION, INC., DOMINION

Honorable Court the following:

1. Plaintiff Terpsehore Maras (hereinafter “Plaintiff”) is a resident of the State of Ohio

and she currently resides in Cleveland, Ohio.

2. Defendant US Dominion, Inc. is a resident of Colorado with a principal place of

3. Defendant Dominion Voting Systems, Inc. is a resident of Colorado with a principal

4. Defendant Dominion Voting Systems Corporation is a resident of Colorado with a

Case 3:21-cv-00636 Document 1 Filed 08/16/21 Page 1 of 8 PageID #: 1

58244126001138 (last accessed August 16, 2021).

to Tenn. Code Ann. § 20-2-223.

Defendants’ receive revenue from conducting business in this District.

III. STATEMENT OF FACTS

Az. 2020) (attached as Exhibit 1).

16. The Court’s Order never mentioned Terpsehore Maras’ name.

17. The Court’s Order never discussed Plaintiff’s testimony.

20. In suing Sidney Powell for defamation, Dominion defamed Plaintiff.

23. Defendants using plaintiff’s affidavit as evidence for defamation.

25. Defendants have not disproved any allegation in Plaintiff’s Affidavit.

26. Defendants have not disproved any Paragraph in Plaintiff’s Affidavit.

hereto as Exhibit 4).

perjury by portraying it as false information.

defamatory and libelous statements about the Plaintiff.

recklessly disregarding that they are false.

Constitution of the State of Tennessee, Art. I, Sections 6 and 17.

34. Dominion’s statements are defamatory per se.

Plaintiff’s favor against the Defendants as follows:

2. awarding Plaintiff punitive damages of not less than $1,700,000,000;

3. awarding Plaintiff all expenses and costs, including attorneys’ fees;

4. awarding Plaintiff pre- and post-judgment interest;

the Defendants from repeating such statements in the future;

6. such other relief as the Court deems appropriate; and

Respectfully submitted this 16th day of August, 2021.

THE NEWMAN LAW FIRM

By: /s/Russell A. Newman _

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