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SUPREME COURT OF THE STATE OF NEW YORK


COUNTY OF NEW YORK

VICTOR WEIR-VORONOV,

Plaintiff,

-against-


J OHN WEIR-VORONOV,
Defendant.






SUMMONS

Index No.





TO THE ABOVE NAMED DEFENDANTS:

YOU ARE HEREBY SUMMONED to answer the Complaint in this Action and to
serve a copy of your Answer on the plaintiffs attorneys within 20 days after service of the
summons (or within 30 days after service is complete if the 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 Complaint.

Dated: New York, New York
September 18, 2014
Yours, etc.,


______________________________
DANIEL S. SZALKIEWICZ, ESQ.
Daniel Szalkiewicz & Associates, P.C.
Attorneys for Plaintiff
7 Dey Street, Suite 900B
New York, New York 10007
Tel: (212) 706-1007
Fax: (914) 500-2315
daniel@lawdss.com

To: J ohn Weir Voronov
FILED: NEW YORK COUNTY CLERK 09/18/2014 10:58 AM
INDEX NO. 159191/2014
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 09/18/2014

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

VICTOR WEIR-VORONOV,

Plaintiff,

-against-


J OHN WEIR-VORONOV,
Defendant.



NOTICE OF ELECTRONIC
FILING

Index No.


PLEASE TAKE NOTICE that the matter captioned above, which has been
commenced by filing of the accompanying documents with the County Clerk, is subject to
mandatory electronic filing pursuant to Section 202.5-bb of the Uniform Rules for the Trial
Courts. This notice is being served as required by Subdivision (b) (3) of that Section.
The New York State Courts Electronic Filing System (NYSCEF) is designed for the
electronic filing of documents with the County Clerk and the court and for the electronic
service of those documents, court documents, and court notices upon counsel and self-
represented parties. Counsel and/or parties who do not notify the court of a claimed exemption
(see below) as required by Section 202.5-bb(e) must immediately record their representation
within the e-filed matter on the Consent page in NYSCEF. Failure to do so may result in an
inability to receive electronic notice of document filings.
Exemptions from mandatory e-filing are limited to: 1) attorneys who certify in good
faith that they lack the computer equipment and (along with all employees) the requisite
knowledge to comply; and 2) self-represented parties who choose not to participate in e-filing.
For additional information about electronic filing, including access to Section 202.5-bb, consult
the NYSCEF website at www.nycourts.gov/efile or contact the NYSCEF Resource Center at
646- 386-3033 or efile@courts.state.ny.us.
Dated: New York, New York
September 18, 2014

DANIEL S. SZALKIEWICZ, ESQ.
Daniel Szalkiewicz & Associates, P.C.
Attorneys for Plaintiff
7 Dey Street, Suite 900B
New York, New York 10007
Tel: (212) 706-1007
Fax: (914) 500-2315
To: J ohn Weir Voronov

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

VICTOR WEIR-VORONOV,

Plaintiff,

-against-


J OHN WEIR-VORONOV,
Defendant.






VERIFIED COMPLAINT

Index No.





Plaintiff VICTOR WEIR-VORONOV (Voronov or Plaintiff), by his attorneys Daniel
Szalkiewicz & Associates, P.C., as and for his Complaint against the defendant J OHN WEIR-
VORONOV (hereinafter Weir or Defendant) alleges, upon information and belief, as
follows:
NATURE OF THE ACTION
1. This action arises from Weirs defamatory and false statements accusing Voronov
of attempted rape and sexual misconduct in front of over 2,500,000 million viewers, and the
spreading of salacious lies concerning Voronovs sexual health. Weirs actions were undertaken
maliciously, to injure Voronov in his profession, his business and out of a desire to embarrass,
harm and hold Voronov to public scorn and ridicule. However, destroying Voronovs reputation
was not enough for Weir. Rather, Weirs behavior turned violent, and on more than three
occasions Weir engaged in heinous acts of domestic violence, battering Voronov and leaving
him permanently scarred.
2. The parties, Weir and Voronov, married on December 30, 2012. At that time,
Weir told the media marrying Victor has been the greatest moment in my life and I will work

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very hard to make him proud and happy... I am so happy to have found my match. Finding
someone to share your life with is one of the most important things a human can do and was
preached to me by my mother. Victor is the epitome of a gentleman, as handsome as he is clever
and loving.
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3. Weirs affections were short-lived, as thirteen months later, Weir viciously
attacked Voronov following a domestic dispute. Weir inflicted several wounds all over
Voronovs body, including a bite mark on Voronovs left bicep causing Voronov to later receive
a tetanus shot. After the police were called, a criminal complaint was filed. Fearing for his
safety, Voronov was forced to obtain a temporary restraining order against Weir.
4. Around this same time, Weir reclaimed his spot in the public eye by providing
commentary with fellow figure skater Tara Lapinski for NBC during the 2014 Sochi Winter
Olympic Games. While on screen Weir presented himself as a loving individual, in reality Weir
was subjecting his spouse Voronov to a life of abuse and public humiliation.
5. In or around February 2014, the parties filed for divorce as rumors began to swirl
of Weirs violent tendencies. In a blatant bid to rebrand his image from that of a battering
partner, Weir appeared on a nationally televised program and accused Voronov of causing the
domestic dispute by attempting to rape Weir. This atrocious statement was false.
6. Naively thinking Weir could change, the parties attempted to reconcile. At Weirs
direction, Voronov further agreed not to pursue his criminal complaint against Weir.
7. Unfortunately, Voronovs conciliatory actions were met by Weirs volatile temper
later that same month. At the parties home, Weir violently punched Voronov and proceeded to
angrily throw dangerous objects at Voronov. In an effort to free himself of his abuser, Voronov
was forced to obtain another temporary restraining order.

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http://www.people.com/people/article/0,,20557918,00.html

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8. Finally, in a fit of jealously, Weir publically accused Voranov of having herpes
or some sort of sexually transmitted disease. These statements are also false.
9. Weirs verbally abusive behavior towards Voronov escalated into a crusade of
defamation, with Weir uttering slanderous per se statements and texting libelous per se
statements to third parties. These statements falsely charge Voronov, an attorney, with
impersonating the court, committing attempted rape and sexual misconduct, and contracting a
sexually transmitted disease. The statements are each false and are intended to specifically target
Voronov.
10. When searching Plaintiffs name on Google, over 140,000 results are generated
and Weirs defamatory statements made during televised interviews appear in the top five
results.
STATEMENT OF FACTS PERTAINING TO ALL CAUSES OF ACTION
THE PARTIES AND JURISDICTION
11. Plaintiff is, and at all times relevant to this action has been, an individual residing
in the State of New J ersey, County of Bergan.
12. Plaintiff is a Georgetown University Law Center graduate and admitted to
practice law in the State of New York.
13. Plaintiff is not a public official or public figure.
14. Upon information and belief, Defendant Weir is a resident of the State of New
J ersey. Weir is an American figure skater, the 2008 Word bronze medalist, a two-time Grand
Prix Final bronze medalist, and a three-time U.S. national champion.
15. Venue is proper under C.P.L.R. 509 and this Court has jurisdiction over Weir
under C.P.L.R 301 and 302(a)(1).

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16. That at all times herein mentioned, Defendant was non-domiciliary of the State of
New York. However, defendant did transact sufficient of his business within the State of New
York, and derived substantial revenue in the State of New York, to subject himself to the
jurisdiction of the courts of the State of New York.
WEIR DEFAMES VORONOV
The Defamatory Access Hollywood Interview
17. On or about March 20, 2014, following the parties initial filing for divorce, Weir
appeared in an interview on the television show Access Hollywood.
18. In an effort to increase the viewership of the segment, Weir publicized the
interview on his twitter account, calling it the only interview [Weir] will give about [Weirs]
divorce:

See https://twitter.com/J ohnnyGWeir/status/446699387167993856, accessed September 16,
2014.
19. The above publication, or tweet, was republished, or retweeted 66 times and
140 people marked it as a favorite. In addition, Weirs 204,000 followers on Twitter
immediately notification of this publication.
20. During the interview, Weir spun lies as easily he performed a triple salchow,
giving little to no disregard for the truth. Throughout his performance, Weir made several
slanderous and defamatory statements concerning Voronov.

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21. Specifically, at 5:55 into the interview, Weir stated:
But a few times of course it did get physical. Some of my closest friends
have seen him hit me before andIve been slapped, but slapping is
enough for me. That is hitting.



See http://www.accesshollywood.com/johnny-weir-opens-up-on-dramatic-divorce-part-2-
exclusive_video_2076237, accessed September 16, 2014.
22. The phrases get physical, seen him hit me Ive been slapped and that is
hitting is intended to be understood and is understood to mean that Voronov engaged in the
serious crime of assault in the third degree. This event never happened and Weirs statements are
false.
23. At 2:31 into part two of the interview (the 2:31 Statement), Weir said:
I went to sleep because I had to work the next day, and he came invery
not himselfand asked me to lay with him in the biblical sense, and when
I refused, the altercation between us started. I was defending myself.



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See http://www.accesshollywood.com/johnny-weir-opens-up-on-dramatic-divorce-part-2-
exclusive_video_2076237, accessed September 16, 2014.

24. The phrase lay with him in the biblical sense as used in the interview is
intended to be understood and is understood to mean sexual relations. The statement as a whole
is intended to be understood and is understood to mean that Voronov violated New York Penal
Law (PL) 110.00 and 130.35 (attempted rape in the first degree), PL 110.00 and 130.30
(attempted rape in the second degree), PL 110.00 and 130.65 (attempted sexual abuse in the
first degree), PL 110.00 and 130.45 (attempted criminal sexual act in the second degree), and
PL 110.00 and 130.50 (attempted criminal sexual act in the first degree), each serious crimes.
The 2:31 Statement is false.
25. In fact, a police report was taken and Weir never once alleged that Voronov
attempted to rape him. Upon information and belief, the fabrications contained in the 2:31
Statement were done with the sole intention are destroying Voronovs reputation, done with
malice, and a total disregard for the truth.
26. During the week the Access Hollywood Interview aired, Access Hollywoods
viewership increased by 13% from the previous ratings period
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to become the number three
magazine show of the week, tied with TMZ and surpassing Extra and The insider.
27. An estimated TWO AND A HALF MILLION viewers saw the interview.
28. Following the defamatory interview, a plethora of media outlets wrote stories
concerning the Defendants defamatory statements.
29. By way of example, on March 21, 2014, E! Online published the following
statement:

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http://www.tvnewscheck.com/article/75207/basketball-bounces-syndie-ratings

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Weir continued. So, we had a fight and then I went to sleep because I had
to work the next day, and he came invery not himselfand asked me to
lay with him in the biblical sense, and when I refused, the altercation
between us started. I was defending myself, and it's unfortunate that there
was a mark left on his body, because as soon as the police came to our
home, the first thing he did was show this mark, so I knew then he didn't
really care that much and all he is out to do is hurt me.

See http://www.eonline.com/news/523484/johnny-weir-divorce-drama-skater-opens-up-
about-domestic-violence-and-nude-photos-ex-victor-voronov-repsonds, accessed
September 16, 2014.
30. Fox Sports
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, Radar Online
4
, Celebuzz
5
, Dlisted
6
, and US Weekly
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, along with
countless other internet periodicals, republished the defamatory quotes.
31. The interview still remains in circulation as a two-part online series.
The Defamatory Twitter Posting
32. On or about August 17, 2014, Weir published the following false tweet:

See https://twitter.com/J ohnnyGWeir/status/500914688595476480, accessed September 16,
2014.

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http://www.foxsports.com/olympics/story/johnny-weir-cites-alleged-violence-as-one-of-the-reasons-for-divorce-
from-victor-voronov-032114
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http://radaronline.com/exclusives/2014/03/johnny-weir-victor-voronov-split-estranged-husband-truth-on-his-side-
source/
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http://www.celebuzz.com/2014-03-24/victor-voronov-feels-duped-by-estranged-husband-johnny-weir/
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http://dlisted.com/2014/03/21/so-thats-the-real-reason-for-their-divorce-johnny-weirs-husband-destroyed-one-of-
his-birkins/
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http://www.usmagazine.com/celebrity-news/news/johnny-weir-calls-marriage-to-victor-voronov-threatening-
friends-have-seen-him-hit-me-2014213

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33. As of September 10, 2014, the post was retweeted 35 times and marked as
favorite by 111 users.
34. The tweet tends to injure Voronov in his trade, business or profession by accusing
Voronov, an officer of the court, and an esteemed attorney, of impersonating a judicial figure.
The Defamatory Text Messages
35. Not satisfied with slandering Voronov in front of a national audience, Weirs
crusade to destroy Voronovs good name continued through text messages to third parties.
36. On or about May 2014, Weir texted a third party, named Victor, in Russian
stating:

37. The messages translated state Hello Victor. What happened with [Plaintiff]? I
just want you to know that he is crazy, not working anywhere, and he has Herpes. Did you guys
have sex? I think the only reason he is your friend is because he wants to make me angry. He
tries to spend time with figure skaters for this purpose. And Im positive he has some sort of
sexually transmitted disease also. So be careful because he is sick/illness.
38. The text messages were intended to be understood, and were understood, to mean
that the plaintiff suffers from a sexually transmitted disease. The statements made by Weir in the
text messages are false.

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39. During this same time, Weir made the identical allegations to at least one New
York resident. This allegation was also false.

WEIR ASSAULTS VORONOV
40. Throughout the course of the parties marriage, Weir engaged in a course of
conduct to inflict serious physical harm on the Plaintiff.
41. While the incidents of physical abuse were plentiful, during several Voronov
feared for his safety, and had no choice to but to contact the police.
42. On J anuary 22, 2014, the parties were residing in the same apartment. When the
parties decided to go to bed, Voronov chose to leave the nightlight on. Weir proceeded to throw
a tantrum that became violent. Weir, unable to control his ferocious tendencies, severely injured
Voronov by beating and biting him. Out of fear that Weir transmitted a disease, the Plaintiff was
required to obtain a tetanus shot.

[Pictures taken from police report.]

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43. On March 21, 2014, a day after Weir gave the defamatory Access Hollywood
Interview, as described supra, Weird closed-fist punched Voronov, and threw multiple objects at
Plaintiff.
44. Even after filing for divorce, Weirs course of violence did not cease.
45. On or about May 17, 2014, Weir illegally attempted to steal Voronovs
prescription pills in an effort to abuse the narcotics. Voronov, an officer of the court, refused to
allow Weir to steal his medication. Weir became aggressive, and physically assaulted Voronov
in order to steal the medication. Weir inflicted cuts, scratches, rug burns, and bruises on
Voronov.
46. Fearing for his safety, Voronov was forced to flee to the bathroom and call the
police. Weir continued to yell and threaten Voronov, and Voronov remained locked in the
bathroom until the police arrived.
47. As demonstrated below, the altercation left Plaintiff bruised and battered.


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[Pictures taken from police report.]
48. As a result of the foregoing occurrences, Voronov sustained serious injuries and
suffered pain, shock and mental anguish. These injuries and their effects will be permanent and
as a result thereof, Voronov incurred, and will continue to incur, expenses for medical care and
attention. Additionally, Voronov was, and will continue to be, rendered unable to perform his
normal activities and duties and has sustained a resultant loss therefrom
FIRST CAUSE OF ACTION
(Libel)

49. Plaintiff repeats and realleges the allegations stated above as if fully set forth
herein.
50. The statements published by Defendant Weir regarding Plaintiff are and were
false when made.
51. Defendant Weir acted with knowledge of the falsity of these statements and the
implications therefrom, reckless disregard for the truth, and/or with malicious intent, both
presumed and actual, in knowingly publishing such false statements to third parties.
52. These statements defame and otherwise impugn Plaintiffs character, integrity,
reputation, charge him with a serious crime, and disparaged the Plaintiff in his profession, trade
and/or business and are libelous per se.

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53. The statements are libelous per se, so that general damages may be presumed as a
matter of law.
54. However, even if the damages are not presumed, Plaintiff has suffered special
damages in that the lies Defendant has spread has severely injured his reputation in the legal
profession, and countless other economic damages brought on by the wrongful assertion of fraud
and theft.
55. That by reason of the foregoing, Plaintiff has been damaged in a sum of money
having a present value which exceeds the jurisdictional limits of all lower courts which would
have otherwise have jurisdiction of this matter.

SECOND CAUSE OF ACTION
(Slander)

56. Plaintiff repeats and realleges the allegations stated above as if fully set forth
herein.
57. The statements spoken by Defendant Weir regarding Plaintiff are and were false
when made.
58. Defendant Weir acted with knowledge of the falsity of these statements and the
implications therefrom, reckless disregard for the truth, and/or with malicious intent, both
presumed and actual, in knowingly publishing such false statements to third parties.
59. These statements defame and otherwise impugn Plaintiffs character, integrity,
reputation, charge him with a serious crime, and disparaged the Plaintiff in his profession, trade
and/or business and are libelous per se.
60. The statements are libelous per se, so that general damages may be presumed as a
matter of law.

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61. However, even if the damages are not presumed, Plaintiff has suffered special
damages in that the lies Defendant Weir has spread has severely injured his reputation in the
legal profession, and countless other economic damages brought on by the wrongful assertion of
fraud and theft.
62. That by reason of the foregoing, Plaintiff has been damaged in a sum of money
having a present value which exceeds the jurisdictional limits of all lower courts which would
have otherwise have jurisdiction of this matter.

THIRD CAUSE OF ACTION
(Assault)

63. Plaintiff repeats and realleges the allegations stated above as if fully set forth
herein.
64. That on or about J anuary 22, 2014, March 21, 2014, and May 17, 2014, while
Plaintiff was lawfully present at their marital residence, Defendant Weir, did injure Plaintiff by
physically striking and assaulting him and utilizing unnecessary, excessive, unlawful force and
brutality as a result of which Plaintiff was caused to sustain serious and permanent personal
injuries.
65. That on or about J anuary 22, 2014, March 21, 2014, and May 17, 2014, while
Plaintiff was lawfully present in his home, he was caused to be carelessly, negligently and
recklessly physically assaulted, beaten and battered by Defendant Weir, and was caused to
sustain severe, permanent personal injuries.
66. That the aforementioned occurrences took place due to the carelessness,
recklessness and negligence of Defendant Weir.

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67. That due to the within occurrence, Plaintiff was caused to sustain serious injuries
and to have suffered pain, shock and mental anguish: that these injuries and their effects will be
permanent; that as a result thereof, plaintiff has been caused to incur and will continue to incur
expenses for medical care and attention; that Plaintiff was and will continue to be rendered
unable to perform his normal activities and duties and has sustained a resultant loss therefrom.
68. That as a result of the aforementioned, Plaintiff, has been damaged in an amount
which exceeds the jurisdictional limits of all lower courts which would otherwise have
jurisdiction over this matter.

FOURTH CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)

69. Plaintiff repeats and realleges the allegations stated above as if fully set forth
herein.
70. Defendant Weirs sole purpose of publicizing the defamatory statements via
various media outlets and Defendants own Twitter account was to harass Plaintiff, and publish
to the whole world false and defamatory statements.
71. Defendant Weir has intentionally posted the defamatory statements to inflict
emotional distress by continuing to embarrass and humiliate Plaintiff each day his Twitter
account remains active and each day the interview remains available on the internet.
72. Defendant intended to cause severe, emotional distress or recklessly disregarded
the likelihood that such conduct would tend to cause severe emotional distress. Such outrageous
behavior is beyond the limits of decency and intolerable in a civilized society.

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73. That by reason of the foregoing, Plaintiff has been damaged in a sum of money
having a present value which exceeds the jurisdictional limits of all lower courts which would
otherwise have jurisdiction.
FIFTH CAUSE OF ACTION
(Prima Facie Tort)

74. Plaintiff repeats and realleges the allegations stated above as if fully set forth
herein.
75. Defendant Weir purposefully inflicted harm on Plaintiff by alleging the Plaintiff
has a sexually transmitted disease, commits serious crimes, and impersonates the Court.
76. As a result, Plaintiff suffered special damages.
77. Defendant Weir had no excuse or justification for the assertion that Plaintiff has a
sexually transmitted disease, commits serious crimes, and impersonates the Court.
78. That as a result of the foregoing, Plaintiff was damaged in a sum which
exceeds the jurisdictional limits of all lower courts which would otherwise have
jurisdiction.

WHEREFORE, Plaintiff requests judgment against Defendant:
(a) for damages in an amount to be determined at trial;
(b) the costs of this action; and
(c) such other and further relief as the Court may deem just and proper,

Dated: New York, New York
September 18, 2014
Daniel Szalkiewicz & Associates, P.C.


__________________________
By: Daniel S. Szalkiewicz, Esq.