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FILED: SUFFOLK COUNTY CLERK 05/25/2023 07:37 PM INDEX NO. 613381/2023
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/25/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
LIANA HEGDE
Plaintiff, Index No.
v. SUMMONS
JANINE KING
Defendant.
To the above-named Defendant:
You are hereby summoned to answer the complaint in this action, and to serve a copy of your
answer on the plaintiff’s attorney within 20 days after the service of this summons, exclusive of
the day of service (or within 30 days after the service is complete if this summons is not
personally delivered to you within the State of New York); and in case of your failure to appear
or answer, judgment will be taken against you by default for the relief demanded in the
accompanying complaint.
The basis of the venue designated is that Plaintiff resides in Suffolk County.
Dated: May 25, 2023 CAMERON STRACHER, PLLC
By: /s/ Cameron Stracher
Cameron Stracher
51 Astor Place, 9th Floor
New York, NY 10003
(646) 992-3850
(646) 992-4241 (fax)
Counsel for Plaintiff Liana Hegde
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF SUFFOLK
LIANA HEGDE
Plaintiff, Index No.
v. COMPLAINT
JANINE KING
Defendant.
Plaintiff Liana Hegde (“Plaintiff”), by and through her undersigned counsel, as her
Complaint against defendant Janine King (“Defendant”), alleges as follows:
Preliminary Statement
1. This case arises from false and defamatory statements made by Defendant about
Plaintiff in various postings on the Internet in connection with the murder of Plaintiff’s mother.
Parties and Jurisdiction
1. Plaintiff is a medical doctor. She lives in New York State and resides in Suffolk
County.
2. Defendant is Plaintiff’s aunt. She lives in New York State and resides in Oneida
County.
3. This Court has jurisdiction of this action pursuant to New York Civil Practice
Law and Rules (“CPLR”) Section 301 because both parties live in New York State.
4. Venue is proper in Suffolk County pursuant to CPLR § 503(a) because Plaintiff
resides in that County.
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Factual Allegations
5. Plaintiff’s mother, Mary Yoder, was poisoned with colchicine on July 20, 2015.
She died two days later, on July 22, 2015.
6. Forensic evidence revealed that the colchicine used to poison Mary was ordered
through an email account set up by Kaitlyn Conley, the on-again, off-again girlfriend of Adam
Yoder, Mary’s son. DNA evidence linked Conley to both the vial of colchicine and an
anonymous letter accusing Adam Yoder of the murder and identifying the location of colchicine.
7. On November 6, 2017, following a jury trial, Kaitlin Coney was found guilty of
poisoning Mary and convicted of first-degree manslaughter. She was subsequently sentenced to
twenty-three years in prison.
8. Despite the jury verdict holding Conley responsible for Mary’s death,
Defendant has posted frequently on the website titled “Free Kaitlyn Conley,” available at
www.freekaitlynconley.com (the “Website”), where her articles proclaim Conley’s innocence
and claim that Conley was the victim of a conspiracy that led to her conviction.
9. Defendant also posts frequently on the Facebook group of the same name,
available at www.facebook.com/FreeKaitlynConley (the “Facebook Group”), where she has
made similar claims about Conley’s innocence and the conspiracy that led to her conviction.
10. On both the Website and the Facebook Group Defendant has made false and
defamatory statements about Plaintiff’s alleged involvement in the conspiracy to convict Conley,
has falsely accused Plaintiff of stalling the investigation into the truth of Mary’s murder, and has
falsely accused Plaintiff of murdering her mother-in-law.
11. Specifically, on the Website, Defendant has made the following false and
defamatory statements about Plaintiff, implying that Plaintiff attempted to stall the investigation
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into the truth of Mary’s murder and that Plaintiff was involved in a conspiracy to frame Conley
for Mary’s murder:
a. “Immediately following her death, their daughter Liana Yoder Hegde, a licensed
physician, advised family and friends that Mary died from a condition called
Ascending Cholangitis. By accident, a full month later, I learned this was not true
and that Mary’s death had been ruled unknown pending toxicology report… I
confronted Liana and she begged me to silence.”
b. “[Mary’s husband, Bill Yoder] had Mary’s body cremated within just days of her
death, without informing our family. Bill and Liana successfully stalled the
medical and police investigations. This gave Bill and Adam [Yoder] time to set
Katie up and time for the Yoders to craft the story they would tell the authorities.”
c. “Repeatedly, I asked Liana if the police were involved and if not, when would
they be. Each time, she told me that the FDA hadn’t signed off yet and their sign-
off was required before the police could begin investigating. Later we learned
this was not true.”
d. “The criminal investigation of Mary’s murder was stalled 3 months because of
Bill, Liana, and the Medical Examiner.”
e. “I have little doubt that it was Bill and Liana who put it into the sheriffs heads that
Katie killed Mary to bring Adam [Yoder] back into [Katie’s] arms.”
12. Not content to falsely accuse Plaintiff of involvement in covering up her own
mother’s murder, Defendant also falsely accused Plaintiff of orchestrating the death of her
mother-in-law. Specifically, on the Website, Defendant wrote: “Liana may have benefited
financially from her mother-in-law Tara’s death … If Liana and [her husband] came into money
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when Tara died, you can be sure Bill Yoder did too, as Liana was essentially [her father’s] sugar
momma and one of the reasons Tara didn’t like him.”
13. In addition, on the Facebook Group, in response to a comment posted by “Patti
Ann” on April 20, 2023, Defendant wrote that “I think it’s pretty clear now to most people” that
Defendant committed perjury while testifying at Conley’s trial.
First Cause of Action
(Defamation)
14. Plaintiff re-alleges and incorporates by reference the allegations in paragraphs 1
through 13 of this Complaint as if set forth fully herein.
15. The statements by Defendant set forth above in paragraphs 11 through 13 were
false.
16. The false statements were “of and concerning” Plaintiff.
17. Defendant made the false statements about Plaintiff either knowing they were
false, or with reckless disregard for the truth.
18. Specifically, Defendant knew that a jury convicted Conley of Mary’s murder, and
that Plaintiff was never arrested, charged, or named as a suspect, co-conspirator, or “person of
interest” in Mary’s murder.
19. Defendant also knew that Plaintiff’s mother-in-law died of natural causes, and
that neither police nor prosecutors have ever stated that Plaintiff’s mother-in-law was murdered.
20. The false statements are not protected by any privilege or authorization.
21. Plaintiff has been seriously damaged as a direct and proximate result of
Defendant’s publication of the false statements, the full amount of which will be proven at trial.
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In addition, the false statements constitute defamation per se because they charge Plaintiff with
criminal actions.
22. Defendant’s conduct was willful, malicious and oppressive, in that Defendant
knew that the false statements would harm Plaintiff. As such, in addition to compensatory
damages and/or presumed damages, Plaintiff demands punitive damages relating to Defendant’s
publication of the above-referenced false statements, in an amount to be determined at trial.
Demand for Jury Trial
Plaintiff demands a trial by jury.
Prayer for Relief
WHEREFORE, Plaintiff respectfully requests:
A. An award of damages in an amount to be determined at trial, but believed to be in
excess of five million dollars ($5,000,000);
B. An award of punitive damages in an amount to be determined at trial;
C. Costs of suit and legal fees and costs incurred herein; and
D. Such other and further relief as the Court deems just and proper.
Dated: May 25, 2023 Respectfully submitted,
CAMERON STRACHER, PLLC
By: /s/ Cameron Stracher
Cameron Stracher
51 Astor Place, 9th Floor
New York, NY 10003
(646) 992-3850
(646) 992-4241 (fax)
Counsel for Plaintiff Liana Hegde
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Preview
FILED: SUFFOLK COUNTY CLERK 05/25/2023 07:37 PM INDEX NO. 613381/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/25/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK LIANA HEGDE Plaintiff, Index No. v. SUMMONS JANINE KING Defendant. To the above-named Defendant: You are hereby summoned to answer the complaint in this action, and to serve a copy of your answer on the plaintiff’s attorney within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the accompanying complaint. The basis of the venue designated is that Plaintiff resides in Suffolk County. Dated: May 25, 2023 CAMERON STRACHER, PLLC By: /s/ Cameron Stracher Cameron Stracher 51 Astor Place, 9th Floor New York, NY 10003 (646) 992-3850 (646) 992-4241 (fax) Counsel for Plaintiff Liana Hegde 1 of 6 FILED: SUFFOLK COUNTY CLERK 05/25/2023 07:37 PM INDEX NO. 613381/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/25/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK LIANA HEGDE Plaintiff, Index No. v. COMPLAINT JANINE KING Defendant. Plaintiff Liana Hegde (“Plaintiff”), by and through her undersigned counsel, as her Complaint against defendant Janine King (“Defendant”), alleges as follows: Preliminary Statement 1. This case arises from false and defamatory statements made by Defendant about Plaintiff in various postings on the Internet in connection with the murder of Plaintiff’s mother. Parties and Jurisdiction 1. Plaintiff is a medical doctor. She lives in New York State and resides in Suffolk County. 2. Defendant is Plaintiff’s aunt. She lives in New York State and resides in Oneida County. 3. This Court has jurisdiction of this action pursuant to New York Civil Practice Law and Rules (“CPLR”) Section 301 because both parties live in New York State. 4. Venue is proper in Suffolk County pursuant to CPLR § 503(a) because Plaintiff resides in that County. 1 2 of 6 FILED: SUFFOLK COUNTY CLERK 05/25/2023 07:37 PM INDEX NO. 613381/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/25/2023 Factual Allegations 5. Plaintiff’s mother, Mary Yoder, was poisoned with colchicine on July 20, 2015. She died two days later, on July 22, 2015. 6. Forensic evidence revealed that the colchicine used to poison Mary was ordered through an email account set up by Kaitlyn Conley, the on-again, off-again girlfriend of Adam Yoder, Mary’s son. DNA evidence linked Conley to both the vial of colchicine and an anonymous letter accusing Adam Yoder of the murder and identifying the location of colchicine. 7. On November 6, 2017, following a jury trial, Kaitlin Coney was found guilty of poisoning Mary and convicted of first-degree manslaughter. She was subsequently sentenced to twenty-three years in prison. 8. Despite the jury verdict holding Conley responsible for Mary’s death, Defendant has posted frequently on the website titled “Free Kaitlyn Conley,” available at www.freekaitlynconley.com (the “Website”), where her articles proclaim Conley’s innocence and claim that Conley was the victim of a conspiracy that led to her conviction. 9. Defendant also posts frequently on the Facebook group of the same name, available at www.facebook.com/FreeKaitlynConley (the “Facebook Group”), where she has made similar claims about Conley’s innocence and the conspiracy that led to her conviction. 10. On both the Website and the Facebook Group Defendant has made false and defamatory statements about Plaintiff’s alleged involvement in the conspiracy to convict Conley, has falsely accused Plaintiff of stalling the investigation into the truth of Mary’s murder, and has falsely accused Plaintiff of murdering her mother-in-law. 11. Specifically, on the Website, Defendant has made the following false and defamatory statements about Plaintiff, implying that Plaintiff attempted to stall the investigation 2 3 of 6 FILED: SUFFOLK COUNTY CLERK 05/25/2023 07:37 PM INDEX NO. 613381/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/25/2023 into the truth of Mary’s murder and that Plaintiff was involved in a conspiracy to frame Conley for Mary’s murder: a. “Immediately following her death, their daughter Liana Yoder Hegde, a licensed physician, advised family and friends that Mary died from a condition called Ascending Cholangitis. By accident, a full month later, I learned this was not true and that Mary’s death had been ruled unknown pending toxicology report… I confronted Liana and she begged me to silence.” b. “[Mary’s husband, Bill Yoder] had Mary’s body cremated within just days of her death, without informing our family. Bill and Liana successfully stalled the medical and police investigations. This gave Bill and Adam [Yoder] time to set Katie up and time for the Yoders to craft the story they would tell the authorities.” c. “Repeatedly, I asked Liana if the police were involved and if not, when would they be. Each time, she told me that the FDA hadn’t signed off yet and their sign- off was required before the police could begin investigating. Later we learned this was not true.” d. “The criminal investigation of Mary’s murder was stalled 3 months because of Bill, Liana, and the Medical Examiner.” e. “I have little doubt that it was Bill and Liana who put it into the sheriffs heads that Katie killed Mary to bring Adam [Yoder] back into [Katie’s] arms.” 12. Not content to falsely accuse Plaintiff of involvement in covering up her own mother’s murder, Defendant also falsely accused Plaintiff of orchestrating the death of her mother-in-law. Specifically, on the Website, Defendant wrote: “Liana may have benefited financially from her mother-in-law Tara’s death … If Liana and [her husband] came into money 3 4 of 6 FILED: SUFFOLK COUNTY CLERK 05/25/2023 07:37 PM INDEX NO. 613381/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/25/2023 when Tara died, you can be sure Bill Yoder did too, as Liana was essentially [her father’s] sugar momma and one of the reasons Tara didn’t like him.” 13. In addition, on the Facebook Group, in response to a comment posted by “Patti Ann” on April 20, 2023, Defendant wrote that “I think it’s pretty clear now to most people” that Defendant committed perjury while testifying at Conley’s trial. First Cause of Action (Defamation) 14. Plaintiff re-alleges and incorporates by reference the allegations in paragraphs 1 through 13 of this Complaint as if set forth fully herein. 15. The statements by Defendant set forth above in paragraphs 11 through 13 were false. 16. The false statements were “of and concerning” Plaintiff. 17. Defendant made the false statements about Plaintiff either knowing they were false, or with reckless disregard for the truth. 18. Specifically, Defendant knew that a jury convicted Conley of Mary’s murder, and that Plaintiff was never arrested, charged, or named as a suspect, co-conspirator, or “person of interest” in Mary’s murder. 19. Defendant also knew that Plaintiff’s mother-in-law died of natural causes, and that neither police nor prosecutors have ever stated that Plaintiff’s mother-in-law was murdered. 20. The false statements are not protected by any privilege or authorization. 21. Plaintiff has been seriously damaged as a direct and proximate result of Defendant’s publication of the false statements, the full amount of which will be proven at trial. 4 5 of 6 FILED: SUFFOLK COUNTY CLERK 05/25/2023 07:37 PM INDEX NO. 613381/2023 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 05/25/2023 In addition, the false statements constitute defamation per se because they charge Plaintiff with criminal actions. 22. Defendant’s conduct was willful, malicious and oppressive, in that Defendant knew that the false statements would harm Plaintiff. As such, in addition to compensatory damages and/or presumed damages, Plaintiff demands punitive damages relating to Defendant’s publication of the above-referenced false statements, in an amount to be determined at trial. Demand for Jury Trial Plaintiff demands a trial by jury. Prayer for Relief WHEREFORE, Plaintiff respectfully requests: A. An award of damages in an amount to be determined at trial, but believed to be in excess of five million dollars ($5,000,000); B. An award of punitive damages in an amount to be determined at trial; C. Costs of suit and legal fees and costs incurred herein; and D. Such other and further relief as the Court deems just and proper. Dated: May 25, 2023 Respectfully submitted, CAMERON STRACHER, PLLC By: /s/ Cameron Stracher Cameron Stracher 51 Astor Place, 9th Floor New York, NY 10003 (646) 992-3850 (646) 992-4241 (fax) Counsel for Plaintiff Liana Hegde 5 6 of 6