Supreme Court of Pennsylvania Northampton County Prothonotary E-Filed - 5 Dec 2024 12:07:38 PM

Case Number: C-48-CV-2024-11856

Court of Common Pleas For Prothonotary Use Only: TIM
Civil Cover Sheet ES
Docket No: TA
MP
NORTHAMPTON
_______________________________ County

The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
Complaint Writ of Summons Petition
S Transfer from Another Jurisdiction Declaration of Taking
E
Lead Plaintiff’s Name: Lead Defendant’s Name:
C
TAIBA SULTANA PA CITIZENS PAC
T
Dollar Amount Requested: within arbitration limits
I Are money damages requested? Yes No (check one) X outside arbitration limits
O
N Is this a Class Action Suit? Yes X No Is this an MDJ Appeal? Yes No

A Matthew Mobilio, Esquire

Name of Plaintiff/Appellant’s Attorney: _____________________________________________________________________
Check here if you have no attorney (are a Self-Represented [Pro Se] Litigant)

Nature of the Case: Place an “X” to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.

TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
Intentional Buyer Plaintiff Administrative Agencies
Malicious Prosecution Debt Collection: Credit Card Board of Assessment
Motor Vehicle Debt Collection: Other Board of Elections
Nuisance ________________________ Dept. of Transportation
Premises Liability ________________________ Statutory Appeal: Other
S Product Liability (does not include _________________________
mass tort) Employment Dispute: _________________________
E Slander/Libel/ Defamation Discrimination
Employment Dispute: Other Zoning Board
C Other:
________________________
_________________________ Other:
T _________________________ ________________________ _________________________
I Other: _________________________
MASS TORT ________________________
O Asbestos ________________________
N Tobacco
Toxic Tort - DES
Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste Ejectment Common Law/Statutory Arbitration
Other: Eminent Domain/Condemnation Declaratory Judgment
B _________________________ Ground Rent Mandamus
_________________________ Landlord/Tenant Dispute Non-Domestic Relations
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PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial Quo Warranto
Dental Partition Replevin
Legal Quiet Title Other:
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Other Professional: ________________________ _________________________
_________________________ ________________________
_________________________

Updated 1/1/2011
 Northampton County Prothonotary E-Filed - 5 Dec 2024 12:07:38 PM
Case Number: C-48-CV-2024-11856

NOTICE
Pennsylvania Rule of Civil Procedure 205.5. (Cover Sheet) provides, in part:

Rule 205.5. Cover Sheet

(a)(1) This rule shall apply to all actions governed by the rules of civil procedure except

the following:

(i) actions pursuant to the Protection from Abuse Act, Rules 1901 et seq.

(ii) actions for support, Rules 1910.1 et seq.

(iii) actions for custody, partial custody and visitation of minor children, Rules

1915.1 et seq.

(iv) actions for divorce or annulment of marriage, Rules 1920.1 et seq.

(v) actions in domestic relations generally, including paternity actions, Rules

1930.1 et seq.

(vi) voluntary mediation in custody actions, Rules 1940.1 et seq.

(2) At the commencement of any action, the party initiating the action shall complete

the cover sheet set forth in subdivision (e) and file it with the prothonotary.

(b) The prothonotary shall not accept a filing commencing an action without a

completed cover sheet.

(c) The prothonotary shall assist a party appearing pro se in the completion of the form.

(d) A judicial district which has implemented an electronic filing system pursuant to

Rule 205.4 and has promulgated those procedures pursuant to Rule 239.9 shall be exempt from the

provisions of this rule.

(e) The Court Administrator of Pennsylvania, in conjunction with the Civil Procedural

Rules Committee, shall design and publish the cover sheet. The latest version of the form shall be

published on the website of the Administrative Office of Pennsylvania Courts at www.pacourts.us.

 Northampton County Prothonotary E-Filed - 5 Dec 2024 12:07:38 PM
Case Number: C-48-CV-2024-11856

IN THE COURT OF COMMON PLEAS OF NORTHAMPTON COUNTY, PENNSYLVANIA

CIVIL DIVISION

Taiba Sultana
227 Vista Drive
Easton, PA 18042
Plaintiff

v.
NO.
PA Citizens PAC
205 S. 7th Street
Easton, PA 18042-4315
CIVIL ACTION

Defendant

NOTICE TO DEFEND

You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights important to you.

YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO

NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.

IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO

PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.

NORTHAMPTON COUNTY BAR ASSOCIATION

LAWYER REFERRAL SERVICE
P.O. BOX 4733
EASTON, PENNSYLVANIA 18042
TELEPHONE: (610) 258-6333
 Northampton County Prothonotary E-Filed - 5 Dec 2024 12:07:38 PM
Case Number: C-48-CV-2024-11856

MOBILIO WOOD ATTORNEYS FOR PLAINTIFF

BY: MATTHEW MOBILIO, ESQUIRE
E-MAIL: matt@mobiliolaw.com
I.D. # 209439
4728 HAMILTON BOULEVARD
ALLENTOWN, PA 18103
PHONE: (610) 882-4000
FAX: (866) 793-7665

IN THE COURT OF COMMON PLEAS OF NORTHAMPTON COUNTY, PENNSYLVANIA

CIVIL DIVISION

Taiba Sultana
227 Vista Drive
Easton, PA 18042
Plaintiff

v.
NO.
PA Citizens PAC
205 S. 7th Street
Easton, PA 18042-4315
Defendant CIVIL ACTION

COMPLAINT IN CIVIL ACTION

AND NOW, come the Plaintiff, Taiba Sultana, by and through her attorneys, Mobilio

Wood, and hereby submits the instant Complaint and avers as follows:

I. PARTIES

1. Plaintiff, Taiba Sultana (hereinafter “Plaintiff”) is an adult individual with a

residential address of 227 Vista Drive, Easton, PA 18042.

2. At all relevant times to the matters at issue before the court, Plaintiff Sultana was a

member of the Easton City Council and candidate for the democratic nomination for the 136th

district for the State House of Pennsylvania candidate.

3. Defendant, PA Citizens PAC, (hereinafter “PAC”) is a political action committee,

registered as such with the Pennsylvania Department of State.

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Case Number: C-48-CV-2024-11856

4. At all times material hereto, Raymond Lahoud was the Chairperson of PAC.

5. In addition, Mr. Lahoud was, at all times material hereto, acting as the actual or

apparent agent of PAC, and had express, implied and/or apparent authority to act on behalf of PAC

in paying for, creating, distributing and/or contributing to the contents of the signage and the

statements made online individually and by and through the PAC.

II. CHRONOLOGY OF FACTS

6. In or around the beginning of April of 2024, PAC was formed with, what appears

to be the sole intent of maliciously harming Plaintiff’s reputation in order to cause her to lose the

2024 democratic primary for the 136th district for the State House of Pennsylvania.

7. The sole funder of the PAC was chairman, Raymond Lahoud.

8. Shortly after its formation, PAC began distributing and displaying yard signs that

said, “VOTE NO TAIBA SULTANA. CRAZY. CHAOTIC. CRIMINAL.”

9. PAC’S public Facebook page also stated, “Tomorrow is election day. You have a

choice to make. One of those choices cannot be for Crazy, Chaotic, Criminal Taiba Sultana”.

10. On April 17, 2024, PAC’s Facebook page referred to Plaintiff as “lying about the

police”, “trying to create animosity between the citizens and the police”, that she “beat her kid

while on city council”, fails to “maintain her property”, “misses meetings”, has “an unpaid state

tax lien” and is a “complete nutcase”.

11. On April 23, 2024, PAC’s Facebook page referred to Plaintiff as “antisemitic”.

12. PAC’s Facebook page also referred to Plaintiff as a holocaust denier.

13. PAC’s public Facebook page also suggested that Plaintiff was “stalking” another

individual, and that Plaintiff is a “bully”

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Case Number: C-48-CV-2024-11856

14. These statements constitute factual assertions and not opinion as they can be proven

to be true or false through objective evidence.

15. As a direct result of these malicious attacks, PAC’s supporters began to verbally

attack and threaten Plaintiff online.

16. Specifically, on PAC’s Facebook page, its supporters referred to Plaintiff as being

“Hamas”, that she is a terrorist, dangerous, she is antisemitic and she should “move back to your

country”.

17. As a direct result of PAC’s malicious attacks, Plaintiff also began receiving private

messages referring to her as evil, antisemitic and referencing her child having its “head cut off

from God”.

18. Defendant knew that its allegations were false because no reasonable person devoid

of malicious intent could make the aforementioned assertions, despite a lack of evidence to support

such.

19. Despite its knowledge as to the falsity of its allegations, Defendant has failed and

refused to cease distribution and publication of the statements, which constitutes an intentional

and malicious attack on the character and reputation of the Plaintiff.

20. Plaintiff lost the primary as a direct result of PAC’s defamatory statements.

21. “Pennsylvania Law closely guards the ability of a person whose reputation has been

injured by defamatory statements to obtain redress for such injury”. Schanne v. Addis, 121 A.3d

942 (Pa. 2015).

22. In fact, the Pennsylvania Constitution places reputational interest “on the same

level as those pertaining to life, liberty, and property”. American Future Systems v. Better

Business Bureau, 592 Pa. 66, 923 A.2d 389 (2007); See Pa. Const. art. I § 1 (“All men… have
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Case Number: C-48-CV-2024-11856

certain inherent and indefeasible rights, among which are those of enjoying and

defendant…reputation…”); id. § 11 (“[E]very man for an injury done him in… reputation shall

have remedy by due course of law…”); see also Norton v. Glenn, 580 Pa. 212, 225-26, 860 A.2d

48, 56 (2004)(“The right of a man to the protection of his own reputation from unjustified invasion

and wrongful hurt reflects no more than our basic concept of the essential dignity and wroth of

every human being…”(quoting Milkovich v. Lorain Journal Co., 497 U.S. 1, 22, 110 S.Ct. 2695,

2708, 111 L.Ed 2d 1(1990))).

COUNT I – DEFAMATION (SLANDER AND LIBEL)

(Plaintiff vs. Defendant)

23. The above paragraphs are incorporated below as if fully set forth at length.

24. The aforesaid statements clearly and explicitly referred to Plaintiff.

25. These statements were defamatory because they were malicious and intended to

harm and did harm the reputation of Plaintiff so as to lower Plaintiff in the opinion of the public.

26. Defendant had no privilege to make these false and defamatory statements.

27. Defendant was malicious, reckless and/or intentional with respect to their repeated

false and defamatory statements concerning Plaintiff.

WHEREFORE, Plaintiff demands judgment in her favor and against Defendant and that

this Honorable Court issue an order:

a) Directing Defendant to pay monetary damages to Plaintiff for the harm suffered to

Plaintiff as a result of the loss of reputation;

b) Awarding attorneys’ fees and expenses on all counts herein;

c) Punitive damages; and

d) All other relief as this Court deems just and equitable.

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Case Number: C-48-CV-2024-11856

COUNT II – INVASION OF PRIVACY (FALSE LIGHT)

(Plaintiff vs. Defendant)

28. The above paragraphs are incorporated below as if fully set forth at length.

29. By distributing the aforementioned false statements, Defendant has given publicity

to the matter and have placed Plaintiff in a false light to the public.

30. The false light is highly offensive to Plaintiff and would be to a reasonable person.

31. Defendant knew or acted in reckless disregard as to the falsity of the publicized

statements and the false light in which Plaintiff was placed.

WHEREFORE, Plaintiff demands judgment in her favor and against Defendant and that

this Honorable Court issue an order:

a) Directing Defendants to pay monetary damages to Plaintiff for the harm suffered to

Plaintiff as a result of the loss of reputation;

b) Awarding attorneys’ fees and expenses on all counts herein;

c) Punitive damages; and

d) All other relief as this Court deems just and equitable.

MOBILIO WOOD

BY:

DATED: 12/05/24 MATTHEW MOBILIO, ESQUIRE

Attorneys for Plaintiff
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Case Number: C-48-CV-2024-11856

VERIFICATION

I, TAIBA SULTANA do hereby state that the facts set forth above in the Second Amended

Complaint are true and correct to the best of my knowledge, information and belief and that I

expect to be able to prove the same at a hearing held in this matter. I understand that the statements

herein are made subject to the penalties of 18 Pa. C.S. § 4904 (relating to unsworn falsification to

authorities).

Date: ____________
12/05/2024 _______________________________________
TAIBA SULTANA