2016-29214 / Court: 129

5/5/2016 9:06:30 AM
Chris Daniel - District Clerk Harris County
Envelope No. 10468955
By: Bonnie Lugo
Filed: 5/4/2016 9:41:06 AM

CAUSE NO: ___________

Plaintiff
VS.
KATHERINE LOUISE BLANCHETTE
Defendant

IN THE DISTRICT COURT OF

HARRIS COUNTY, T E X A S

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JUSTIN ALAN KEITER

_________ JUDICIAL DISTRICT

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TO THE HONORABLE JUDGE OF SAID COURT:

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PLAINTIFFS ORIGINAL PETITION

AND REQUEST FOR DISCLOSURE

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COMES NOW, Justin Alan Keiter (Plaintiff), and files this, his Original Petition and

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Request for Disclosure against Katherine Louise Blanchette (Blanchette or Defendant), and

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would respectfully show unto this Court and Jury as follows:

Discovery in this matter may be conducted under Level 2 of the Texas Rules of

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I. DISCOVERY CONTROL PLAN

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Civil Procedure.

Pursuant to Rule 194 of the Texas Rules of Civil Procedure, Defendant is requested

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II. REQUEST FOR DISCLOSURE

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to disclose the information and material described in Rule 194.2 within fifty (50) days of the
service of this request.

3.1
Texas.

III. PARTIES

Plaintiff Justin Keiter is and was, at all times material, a resident of Harris County,

3.2

Defendant Katherine Blanchette is and was, at all times material, a resident of

Brazoria County, Texas, and may be served with process at 2703 Royal Creek Ct., Pearland, Texas,
77584.

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IV. VENUE
Venue is mandatory in this Court as Plaintiff resided in Harris County, Texas when

his causes of action accrued. Tex. Civ. Prac. & Rem. Code 15.017. Further, all or a substantial
part of the events or omissions giving rise to Plaintiffs claims occurred in Harris County, Texas.

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V. FACTS

Plaintiff Justin Keiter is a 10-year Assistant Harris County District Attorney.

5.2

Plaintiffs father, Aaron Keiter, plead guilty in 2011 to conspiracy to conduct and

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attempt to conduct financial transactions affecting interstate and foreign commerce in violation of

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Title 21 U.S.C. 841 (a)(1) and 846 in the U.S. Southern District of Texas.
Defendant was allegedly a victim of Aaron Keiters.

5.4

Plaintiff was neither a party to nor a witness to the prosecution of his father, and

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Plaintiff has never been accused of or otherwise deemed to have had any involvement with his

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fathers business activities by any law enforcement or governmental agency.

In 2012, possibly earlier, Defendant began issuing statements to various parties,

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5.5

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including media outlets and governmental agencies, asserting that, among other things:

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Assistant Harris County DA Justin Keiter uses his DEA thug friends to Raid the
office of a Physician who provided Evidence against Justin Keiters father, Aaron
Keiter.1

ADA Justin Keiter used his DEA thugs to write a JUDGELESS WARRANT to
attempt to terrorize Dr. Blanchette by Trashing Her Office, in an attempt to get even
for Dr. Blanchette helping put Justins father away for another 20 years.2

See Exhibit A (random capitalization original).

Id.

District Attorney DEVON ANDERSON is Covering up Crimes of ADA Justin

Keiter and others.3

Justin Keiter has been Covering up Crimes of his father for Years and Even told
his father how to HIDE Dr. Blanchettes Life Savings.4

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These statements were made in faxes sent by Defendant and are attached hereto as Exhibits A
and B. These statements have also been made elsewhere by Defendant in both print and speech.
5.6

Upon information and belief, Defendant has made various other claims to third

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parties regarding Plaintiff, including, but not limited to, accusations that he has made death threats

On January 12, 2016, by and through the undersigned counsel, and in accordance

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5.7

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against others related to his fathers case.

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with Tex. Civ. Prac. & Rem. Code 73.005, Plaintiff sent a letter to Defendant requesting that she:

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1) immediately cease and desist her unlawful defamation of Justin Keiter and his professional

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activities; 2) issue a public apology and/or retraction within ten (10) days of her receipt of the letter

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via the same media she used to issue the defamatory statements; and 3) provide prompt written

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assurance within ten (10) days of her receipt of the letter that she would cease and desist from

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As of the date of this filing, Defendant has not performed any of the actions

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further defamation of Justin Keiters character and reputation.

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demanded and/or requested in 5.7 above, nor has she ceased issuing defamatory statements

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regarding Plaintiff.
5.9

Upon information and belief, Defendant recently contacted the Houston Sun

Newspaper and made defamatory statements about Plaintiff despite the January 12, 2016 cease
and desist letter sent by Plaintiff.

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Id.
See Exhibit B (random capitalization original).

5.10

Upon information and belief, Defendant has recently made defamatory statements

about Plaintiff to other third parties despite the January 12, 2016 cease and desist letter sent by
Plaintiff.
Defendants actions have caused Mr. Keiter and his family extensive harm.

VI. CAUSES OF ACTION

Defamation

Defendant Blanchette has published unambiguous statements of fact that refer to

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Plaintiff, a private individual and public official, directly, and the statements involved his personal

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affairs, official conduct, and/or the performance of his official duties. These statements constitute

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Defendants actions constitute libel per se under statute as the statements she has

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libel per se and slander per se.

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made have 1) injured Mr. Keiters reputations and thus exposed him to public hatred, contempt or

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ridicule, and/or financial injury, and 2) impeached Mr. Keiters honesty, integrity, virtue, and/or

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Defendants actions constitute libel per se under common law as 1) the statements

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reputation.

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have injured Mr. Keiter in his office, reputations, and/or occupation, and 2) she has falsely charged

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Mr. Keiter with the commission of a crime.

Defendants actions constitute slander per se as her statements have 1) have injured

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Mr. Keiter in his office, reputations, and/or occupation, and 2) she has falsely charged Mr. Keiter
with the commission of a crime.
6.5

Defendants statements were and are false and she made them negligently and with

knowledge of or reckless disregard for their falsity.

VII. DAMAGES
7.1

Plaintiff seeks the following damages related to his above causes of action:
a. actual damages;
b. exemplary damages;

e. costs of court; and

f. prejudgment and post-judgment interest.

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c. attorneys fees;

VIII. CONDITIONS PRECEDENT

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All conditions precedent have been performed or have occurred.

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Plaintiff herein requests a trial by jury.

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IX. JURY DEMAND

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WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendant be cited to

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appear and answer herein and that, upon final hearing, Plaintiff takes judgment against Defendant

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for all damages sustained, plus pre-judgment and post-judgment interest, all costs of Court,

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attorneys fees, and all other relief to which he may be justly entitled.

Respectfully submitted,
ANDERSON BURNSIDE PLLC
//s// Blair H. Burnside
Blair H. Burnside
State Bar No. 24050357
Jonathan C. Anderson
State Bar No. 24040433
1627 W. Alabama
Houston, Texas 77025
Telephone: (713) 325-0301
Facsimile: (713) 325-0302
Email: bburnside@andersonburnside.com

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2016-29214 / Court: 129

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2016-29214 / Court: 129