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IN THE COURT OF COMMON PLEAS OF

WASHINGTON COUNTY, PENNSYLVANIA

JESSE WHITE,
EILEEN WHITE,
and
NICOLE WHITE,
Plaintiffs
vs.
SHARLENE WATAZYCHYN,
Defendant.

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Civil Division
No.: 2015-3987

COMPLAINT

Filed on behalf of Plaintiffs by:

Jesse J. White, Esq.
PA I.D. # 91152
Law Office of Jesse White
3350 Millers Run Road
P.O. Box 384
Cecil, PA 15321
724-743-4444

_____________________________________________________________________________________
IN THE COURT OF COMMON PLEAS OF
WASHINGTON COUNTY, PENNSYLVANIA

JESSE WHITE,
EILEEN WHITE,
and
NICOLE WHITE,
Plaintiffs
vs.
SHARLENE WATAZYCHYN,
Defendant.

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Civil Division
No.: 2015-3987

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.
LAWYER REFERRAL SERVICE
119 South College Street
Washington, PA 15301
724-225-6710

SOUTHWESTERN PA LEGAL AID SOCIETY

10 West Cherry Avenue
Washington, PA 15301
724-225-6710

_____________________________________________________________________________________
IN THE COURT OF COMMON PLEAS OF
WASHINGTON COUNTY, PENNSYLVANIA

JESSE WHITE,
EILEEN WHITE,
and
NICOLE WHITE,
Plaintiffs
vs.
SHARLENE WATAZYCHYN,
Defendant.

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Civil Division
No.: 2015-3987

COMPLAINT
AND NOW comes the Plaintiffs, Jesse White, Eileen White and Nicole White, who file this
Complaint in Civil Action against Defendant, Sharlene Watazychyn, and in support thereof
avers the following:
1.!

Plaintiffs Jesse and Eileen White are a married coupled, residing at 26 White Lane,
McDonald, PA 15057.

2.!

Plaintiff Nicole White, is an adult individual residing at 135 Fannie Street, McDonald
PA 15057.

3.!

The Defendant, Sharlene Watazychyn, is an adult individual residing at 673 Castile

Run Road, Waynesburg PA 15370.

4.!

Defendant is the mother of plaintiffs Jesse and Nicole White and the mother-in-law of
plaintiff Eileen White.

5.!

From December 2006 November 2014, Plaintiff Jesse White was a public figure,
serving as State Representative for the 46th District of Pennsylvania.

6.!

On February 5, 2015, Defendant filed a Complaint against Plaintiff Jesse White in the
Washington County Court of Common Pleas at case number 2015-631.

7.!

The complaint alleges that Jesse White is liable for theft of identity, misuse of
plaintiffs name and identity, invasion of privacy, and slander of credit in

connection with a Citibank credit card in Defendants name for which Plaintiff Jesse
White was an authorized user.
8.!

Sharlene Watazychyn never made a single payment on the aforementioned Citibank

credit card.

9.!

Jesse White made every single payment on the aforementioned Citibank credit card.

10.!

The complaint was filed with the Washington County Prothonotary and immediately
given to numerous news sources for publication, including but not limited to KDKATV, The Washington Observer-Reporter, The Pittsburgh Post-Gazette and the
Pittsburgh Tribune Review.

11.!

Plaintiff Jesse White was not served the Complaint until thirty-four days later on
March 11, 2015.

12.!

The Complaint filed by Defendant Sharlene Watazychyn is the culmination of a

lengthy family dispute stemming largely from an incident which occurred on or about
July 26, 2014, when Plaintiff Eileen White sent Defendant a message on the social
media website Facebook, expressing concern about Defendants drug use in
conjunction with driving with and babysitting her newborn son.

13.!

Defendant Sharlene Watazychyn has a long history of illegal drug use that continues
to the present day; said abuse includes marijuana, prescription drugs including
Vicodin and Xanax, and cocaine at various points.

14.!

Defendant Sharlene Watazychyn also grows large quantities of marijuana on her

property at 673 Castile Run Road, Waynesburg PA, 15370.

15.!

In addition to using it herself, Defendant Sharlene Watazychyn sells the marijuana she
grows illegally.

16.!

Defendant Sharlene Watazychyn has a history of using drugs while driving, including
using drugs while transporting her minor grandchildren.

17.!

In or around 1984, Defendant Sharlene Watazychyn attempted suicide by taking a

large amount of prescription drugs in the presence of Plaintiff Jesse White, who was
approximately six years old at the time.

18.!

Following the aforementioned episode, the Plaintiffs Jesse White and Nicole White
were removed from the home of Defendant Sharlene Watazychyn by police and placed
into the care of relatives during Defendant Sharlene Watazychyns hospitalization and
attempted rehabilitation.

19.!

Shortly after Plaintiffs Jesse and Eileen White had their first child in June 2014,
Defendant Sharlene Watazychyn came to the home smelling strongly of marijuana to
the point where the newborn smelled of marijuana after she left.

20.!

Defendant Sharlene Watazychyns drug use associated with visits with Plaintiffs
Jesse White and Eileen Whites infant son was directly acknowledged by Brittany
Boardley, Defendants daughter and half-sister of Plaintiffs Jesse White and Nicole
White. In a Facebook message defending Sharlene Watazychyns conduct, Boardley
said, Mom smoked hours before we left, used perfume, eat pizza, and washed her
hands before she held him. There is no way he smelled like pot for hours after we left.
See Exhibit B, attached

21.!

When confronted about the concerns of drug use, Defendant Sharlene Watazychyn
went into what can only be described as an extended mental health episode, fueled by
self-medication with illegal drugs.

22.!

Defendant Sharlene Watazychyn claimed to be suicidal and disappeared for several

days at one point, during which she was self-medicating with various drugs.

23.!

In an apparent effort to distract attention from her own actions, Defendant Sharlene
Watazychyn immediately accused Plaintiff Jesse White of using her Citibank credit
card without her knowledge or authorization.

24.!

Defendant Sharlene Watazychyn claimed she had no knowledge of Plaintiff Jesse

Whites use of the card prior to July 2014, which is simply a complete and utter
falsehood.

25.!

On May 30, 2014, Defendant Sharlene Watazychyn exchanged email messaged with
Plaintiff Jesse White and Randy Merchant of Golden Oak Lending regarding a
potential refinancing of Defendants home. At Defendant Sharlene Watazychyns
specific request, Plaintiff Jesse White sent Mr. Merchant statements from the Citi
account going back over a year. See Exhibit C, attached

26.!

On May 31, 2014, Defendant Sharlene Watazychyn wrote Plaintiff Jesse White the
following message via Facebook:
did you get the message I forwarded you from Randy Merchant? I realize that
it is a pain in the ass but it will save Mark and I a lot of money. I have to prove
that you are responsible for the $40000 in Sallie Mae and Citi bank.
See Exhibit D, attached. (emphasis added)

27.!

Defendant Sharlene Watazychyn acknowledge that Plaintiff Jesse White had been
authorized to use her credit card for over a decade. On November 2, 2003, Watazychyn
forwarded an email containing a statement for another credit card to Plaintiff Jesse
White with the message, this may be the card you have. See Exhibit E, attached

28.!

Defendant Sharlene Watazychyn knowingly stated false information on the Complaint

filed with the Washington County Court of Common Pleas at No. 2015-631.

29.!

Within moments of the filing of the Complaint, numerous media outlets were alerted of
the filing and presumably were given copies of the Complaint by Defendant or
someone on her behalf.

30.!

At 6:08 AM on February 6, 2015, Defendant Sharlene Watazychyn posted a one-word

status on her Facebook account. The status was the word smile. See Exhibit F,
attached

31.!

Just hours later, KDKA television reporter Andy Sheehan, who has a well-established
history of investigative reporting that placed Plaintiff Jesse White in a negative
light, showed up without warning at Whites legal office with a television camera
crew. This was a clear attempt to damage Whites reputation with yet another in a
series of heavily biased gotcha stories engineered by Whites political enemies,
some of whom are substantial advertisers on KDKA.

32.!

At approximately the same time, Sheehan and Defendant Sharlene Watazychyn

became connected as friends on Facebook (See Exhibit G, attached), despite
Defendant Watazychyn previously referring to Sheehan as an asshole who was
trying to get Pulitzer prize on [Jesse Whites] back. See Exhibit H, attached

33.!

The story was picked up and published by several media outlets, including KDKA-TV,
The Washington Observer-Reporter, the Pittsburgh Post-Gazette, the Pittsburgh
Tribune-Review, the Almanac, and WJPA Radio. See Exhibit I, attached

34.!

Defendant issued statements on the record in numerous cases in reference to the

Complaint.

35.!

Approximately ten days prior to filing her Complaint, Defendant contacted the
Pennsylvania State Police in an attempt to pursue criminal charges against Plaintiff
Jesse White.

36.!

After reviewing the evidence and speaking to the parties, the Pennsylvania State
Police determined there was no criminal activity to pursue, and expressly informed
Defendant of that fact.

37.!

In numerous interviews with the media both personally and through her attorney,
Charles Kurowski, Defendant made inferences and direct statements to imply that the
conduct of the Plaintiff may have been criminal in nature, despite personal knowledge
to the contrary.

38.!

These statements by Defendant and her counsel Charles Kurowski, which imply
criminal conduct on the part of the Plaintiff Jesse White, are completely false.

39.!

Defendants counsel Charles Kurowski is quoted on KDKA television on February 5,

2015, as claiming Plaintiffs actions were fraud, which is both a criminal and civil
offense. Defendant made no effort whatsoever to clarify that the alleged actions were
civil and not criminal in nature.

40.!

Plaintiff Jesse White requested a clarification from Defendants counsel Charles

Kurowski to the media on the specific issue of implied criminality, which was flatly
refused by Defendant through her counsel.

41.!

A Pittsburgh Tribune Review article dated February 7, 2015, states the following:
[Sharlene] Watazychyn denied having any addiction or mental health issues.
Absolutely not, she said. Hes grasping at straws to make me look irrational.

42.!

Defendant Sharlene Watazychyns own words clearly prove that statement, designed
to protect her reputation at the expense of Plaintiffs Jesse White and Eileen White, is a
bald-faced lie.

43.!

On August 9, 2014, Defendant Sharlene Watazychyn left a voicemail on Plaintiff Jesse

Whites cell phone stating, inter alia, What are you telling people about me? Do they
know the truth? That Ive always smoked pot. See Exhibit J, attached

44.!

Defendant Sharlene Watazychyn exhibited an obsession with maximizing her

estimated inheritance from her estranged father, Peter Cassidy.

45.!

On February 6, 2015, upon hearing about how his daughter, Defendant Sharlene
Watazychyn, went public with her false statements in an attempt to damage Plaintiffs,
Peter Cassidy, who was 87 years old at the time, was admitted to the Intensive Care
Unit at Canonsburg Hospital with serious heart problems.

46.!

According to a text message from Defendants brother, Barry Cassidy, to Plaintiff

Jesse White at the time Peter Cassidy was admitted to the hospital, He was so upset
yesterday he was babbling Sharlene really hit him hard on this she is
responsible. See Exhibit K, attached

47.!

Barry Cassidy then contacted Protective Services on behalf of Peter Cassidy and had
Defendant Sharlene Watazychyn restricted from seeing Peter Cassidy because of her
impact on his fragile health.

48.!

After a series of complications, Peter Cassidys condition deteriorated and he passed

away on May 23, 2015.

49.!

As a result of her fathers passing, Defendant Sharlene Watazychyn received

substantial life insurance proceeds and stands to inherit a sizable portion of the Estate
of Peter Cassidy.

50.!

For reasons she refuses to specify, Defendant Sharlene Watazychyn is actively

working to prevent Plaintiff Jesse White from receiving any inheritance bequeathed to
him by his grandfather, Peter Cassidy.

51.!

Defendant Sharlene Watazychyn has and continues to engage in a calculated and

malicious course of conduct to ruin the reputation of Plaintiffs Jesse White, Eileen
White and Nicole White.

52.!

Defendant Sharlene Watazychyn repeatedly engaged in threatening and harassing

behavior towards Plaintiffs despite repeated requests to simply leave them alone.

53.!

This obsession manifested itself in various ways towards Plaintiffs as Defendant

Sharlene Watazychyn took calculated steps to discredit Plaintiffs in an attempt to

maximize her inheritance at the expense of Plaintiffs. Defendants obsession with

money was evident in numerous Facebook and text messages between her and both
Plaintiffs Jesse White and Nicole White. See Exhibit L, attached.
54.!

On August 9, 2014, Defendant Sharlene Watazychyn left a voicemail on Plaintiff Jesse

Whites cell phone stating, inter alia, Im gonna blow it up. I told you not to label me a
drug user and all of a sudden its a problem that I smoke pot when all of this stuff
about the credit card came out Im gonna clear my shit, and thats how its gonna
be and if you dont think I wont drive to fucking Harrisburg and show it to them
people, I will. Im gonna go get copies made and I might make copies for everybody
This will be done. This will be done. Believe me son, this will be done. See Exhibit
J, attached

55.!

On July 28, 2014, Defendant Sharlene Watazychyn left a voicemail on Plaintiff Jesse
Whites cell phone stating, inter alia, Im getting Chuck Kurowski to be my attorney
Im embarrassed that youre my son. And that is the truth. And I am gonna everything
I can to fucking slam you. See Exhibit J, attached

56.!

On January 1, 2015, Defendant Sharlene Watazychyn sent a text message to Plaintiff

Nicole White stating, inter alia, And oh yea..we voted you cunt of the year over
here..Cody was the first to vote. How about how you used himrewrite it Nicole
Lynn. See Exhibit M, attached

57.!

Defendant has threatened on numerous occasions to use her lawyer Charles Kurowski
to attempt to take custody of Plaintiffs Jesse and Eileen Whites minor son (who she
has only seen three times since birth) and Plaintiff Nicole Whites two minor children.
These threats are utterly without basis in law or fact and serve only to intimidate and
harass Plaintiffs by attempting to take their children away from them.

58.!

As a result of Defendant Sharlene Watazychyns conduct, Plaintiff Eileen White, who

is pregnant, was forced to take prescription medication to cope with the stress and
anxiety of Defendants repeated and unrelenting attacks.

59.!

Taking these medications while pregnant are not recommended, as they could create
complications for both mother and child, but Defendants conduct left Plaintiff Eileen
White with no choice.
COUNT I DEFAMATION

60.!

Paragraphs 1-59 are incorporated by reference as though fully set forth herein.

61.!

Defendants false statements to the media were intended to harm the reputation of
Plaintiff Jesse White, and by extension Plaintiff Eileen White, as to lower him in the
estimation of the community or to deter third persons from associating or dealing with
him, and are therefore defamatory under Pennsylvania law.

62.!

Although Plaintiff Jesse White had previously served as a member of the

Pennsylvania House of Representatives from 2006-2014, he held no elected or

appointed public office at the time the statements were made by Defendant and
therefore was not a public figure.
63.!

Defendant Sharlene Watazychyn was aware that Plaintiff Jesse White was planning to
run for Magisterial District Judge in the 2015 Primary Election and went to the media
literally days before the nominating petition period started in an attempt to damage his
chances of winning.

64.!

Plaintiff Jesse White lost the 2015 Primary Election.

65.!

Defendants communications to the media intended to ascribe to Plaintiff Jesse

Whites conduct, character, or a condition that would adversely affect his fitness for
the proper conduct of his proper business, trade or profession, and are therefore
defamatory under Pennsylvania law.

66.!

Defendants overall comments to the media were defamatory in that they implied
criminal conduct on behalf of Plaintiff Jesse White that Defendant knew or should
have known was untrue.

67.!

Defendants specific comment to the Pittsburgh Tribune-Review, made through her

lawyer Charles Kurowski, that the PA State Police are looking into it is defamation
per se, as the comment clearly intends to imply criminality where Defendant knew or
should have known none existed.

68.!

These statements were made by Defendant to the media and published to potentially
hundreds of thousands of readers and viewers in the Greater Pittsburgh area. The
story was also picked up by the Associated Press and therefore visible worldwide.

69.!

A reasonably prudent person would understand Defendants statements to be

defamatory and directed specifically at the Plaintiff.

70.!

Defendant also contacted some of Plaintiff Jesse Whites legal clients and told them
he had been untrustworthy in his representation, even though the services rendered
were done pro bono for Defendants husband and his family on a matter in which
Plaintiff Jesse White had no interest whatsoever and actually expended $750.00 in his
own expenses along the way.

71.!

Defendants statements were negligent in nature.

72.!

Defendants statements were malicious in nature.

73.!

Plaintiffs suffered special harm in the form of lost business in his law practice,
including clients who disengaged Plaintiff as a result of Defendants statements.

74.!

Plaintiffs suffered impairment of reputation and standing in the community, personal

humiliation, and mental anguish and suffering as a result of Defendants statements
and is entitled to damages.

75.!

Defendants conduct was outrageous because of her personal motive and/or his
reckless indifference to the rights of others, especially her own children and by
extension her own grandchildren.

76.!

Defendants conduct was malicious, reckless, willful, and oppressive towards

Plaintiffs.

77.!

Plaintiffs are entitled to punitive damages.

WHEREFORE, the Plaintiffs Jesse White and Eileen White demand judgment against the
Defendant in an amount in excess of fifty thousand dollars ($50,000), exclusive of interest and
costs.
COUNT II COMMERCIAL DISPARAGEMENT
78.!

Paragraphs 1-77 are incorporated by reference as though fully set forth herein.

79.!

Plaintiff Jesse White runs his own law practice, currently located at 3350 Millers Run
Road, Suite 102, Cecil, PA 15321.

80.!

Plaintiff Jesse White has operated this business since February 1, 2004.

81.!

The business is a sole proprietorship belonging solely to Plaintiff Jesse White.

82.!

Defendants statements implying criminality of Plaintiff Jesse White were false.

83.!

A lawyers reputation in the community is essential to cultivating client relationships.

84.!

A false implication of criminality is damaging to that reputation.

85.!

Defendant intended the publication of his statements to cause financial loss, or he

should have reasonably recognized the publication would result in financial loss.

86.!

Plaintiff Jesse White, and by extension Plaintiff Eileen White, did in fact suffer a
financial loss as a result of Defendants statements.

87.!

Defendant knew or should have known that his statements were false and in reckless
disregard of their truth or falsity.

WHEREFORE, the Plaintiffs Jesse White and Eileen White demand judgment against the
Defendant in an amount in excess of fifty thousand dollars ($50,000), exclusive of interest and
costs.
COUNT III INTENTIONAL INTERFERENCE WITH A CONTRACTUAL RELATIONSHIP
88.!

Paragraphs 1-87 are incorporated by reference as though fully set forth herein.

89.!

Plaintiff Jesse White had contractual relationships with individuals to perform legal
services that had been established prior to Defendant Sharlene Watazychyn making
false claims in her lawsuit and in the media after releasing the lawsuit.

90.!

The Monday after Defendant Sharlene Watazychyns false claims were published in
various media outlets, the clients who had previously retained Jesse White to handle
their legal interests abruptly cancelled said representation.

91.!

As evidenced by Defendants own words and writings, she purposely intended to

harm Plaintiff Jesse White, and by extension Plaintiff Eileen White, by preventing the
relationship from occurring or harming the relationship.

92.!

Defendant lacked privilege or justification for her actions.

93.!

Plaintiff Jesse White, and by extension Plaintiff Eileen White, suffered actual damage
resulting from Defendants conduct.

WHEREFORE, the Plaintiffs Jesse White and Eileen White demand judgment against the
Defendant in an amount in excess of fifty thousand dollars ($50,000), exclusive of interest and
costs.
COUNT IV INVASION OF PRIVACY: PUBLIC DISCLOSURE OF PRIVATE FACTS
94.!

Paragraphs 1-93 are incorporated by reference as though fully set forth herein.

95.!

This count is limited to Plaintiff Eileen White, the wife of Plaintiff Jesse White and
daughter-in-law of Defendant Sharlene Watazychyn.

96.!

Plaintiff Eileen White has never held public office of any kind.

97.!

Plaintiff Eileen White is not a public figure by any objective standard.

98.!

Defendant Sharlene Watazychyns actions by making false representations to the

media were substantially certain to become public knowledge.

99.!

Defendant Sharlene Watazychyns disclosed private facts (many of which were

untrue) that had not already been made public.

100.!

The publicity, which included Plaintiff Eileen Whites wedding photos being displayed
on a KDKA news broadcast in a way intended to imply wrongdoing in which she
presumably was involved, would be highly offensive to a reasonable person.

101.!

Defendant Sharlene Watazychyns conduct would outrage or cause substantial mental

suffering, shame or humiliation to a person of ordinary sensibilities.

102.!

The private facts disclosed by Defendant, including financial details of Plaintiff Eileen
Whites wedding, were not of legitimate concern to the public.

WHEREFORE, the Plaintiff Eileen White demands judgment against the Defendant in an
amount in excess of fifty thousand dollars ($50,000), exclusive of interest and costs.

COUNT V INVASION OF PRIVACY: FALSE LIGHT

103.!

Paragraphs 1-102 are incorporated by reference as though fully set forth herein.

104.!

This count is limited to Plaintiffs Jesse White and Eileen White.

105.!

Plaintiff Eileen White has never held public office of any kind.

106.!

Plaintiff Eileen White is not a public figure by any objective standard.

107.!

Defendant Sharlene Watazychyn made public statements, including but not limited to
her denial of drug use and mental health problems and lying about the true nature of
the credit card she permitted Plaintiff Jesse White to use, that were untrue and created
a false impression about Plaintiffs Jesse White and Eileen White.

108.!

By taking her story to the press a full thirty-four days before serving Jesse White with
her lawsuit, specifically by going to reporters who have a history of negative coverage
of Jesse White like Andy Sheehan of KDKA-TV, Defendant Sharlene Watazychyn
attempted to selectively publicize the facts in a manner creating a false impression.

109.!

Defendants false statements constitute a major misrepresentation of Plaintiffs Jesse

White and Eileen Whites character, history, activities or beliefs such that serious
offense may be reasonable expected to be taken by a reasonable person in plaintiffs
position.

110.!

Defendant Sharlene Watazychyn had knowledge of and acted in reckless disregard as

to the falsity of the publicized matter and as to the false light in which Plaintiffs Jesse
White and Eileen White were placed.

111.!

Plaintiffs Jesse White and Eileen White suffered mental distress as a result of
Defendants actions.

WHEREFORE, the Plaintiffs Jesse White and Eileen White demand judgment against the
Defendant in an amount in excess of fifty thousand dollars ($50,000), exclusive of interest and
costs.
COUNT VI INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
112.!

Paragraphs 1-111 are incorporated by reference as though fully set forth herein.

113.!

Defendant Sharlene Watazychyn has and continues to engage in a pattern of behavior

intentionally intended to cause emotional distress of Plaintiffs Jesse White, Eileen
White and Nicole White.

114.!

The conduct of Defendant Sharlene Watazychyn towards Plaintiffs Jesse White,

Eileen White and Nicole White is extreme and outrageous.

115.!

The conduct of Defendant Sharlene Watazychyn towards Plaintiffs Jesse White,

Eileen White and Nicole White is intentional and reckless.

116.!

The conduct of Defendant Sharlene Watazychyn towards Plaintiffs Jesse White,

Eileen White and Nicole White has caused emotional distress.

117.!

The conduct of Defendant Sharlene Watazychyn towards Plaintiffs Jesse White,

Eileen White and Nicole White has caused distress that was, and continues to be,
severe in nature.

118.!

The Plaintiffs are entitled to punitive damages.

WHEREFORE, the Plaintiffs Jesse White, Eileen White and Nicole White demand judgment
against the Defendant in an amount in excess of fifty thousand dollars ($50,000), exclusive of
interest and costs.

Respectfully Submitted,
______________________
Jesse J. White, Esq.
Plaintiff

"A"

"B"

"C"

"D"

"E"

"F"

"G"

"H"

"I"

Mother sues ex-state representative over $30,000 in

charges
WASHINGTON,PA
AnexPennsylvanialawmakerisbeingsuedbyhismotherforallegedlyusinghernametoopenacredit
accountandrackingupnearly$30,000incharges.
SharleneWatazychynfiledthelawsuitagainstformerstateRep.JesseWhiteonThursdayin
WashingtonCountyCourt.
ShesaysWhiteforgedhersignaturetocashcreditlinechecksandmadenumerouschargesincluding
PittsburghPenguinsseasonticketsandhisLasVegaswedding.
WhitelostinNovemberafterfourterms.Hewascriticizedduringthecampaignforallegedlyusing
assumedonlinepersonastoattackopponents.
WhitetoldaPittsburghTVStationthathismotherhasavendettaagainsthimandhas"clearlylostit."
Hesayshewasauthorizedtousetheaccount,ismakingpaymentsonthebalanceandisconfidenthe'll
prevail.
Copyright2015byWTAE.comTheAssociatedPresscontributedtothisreport.Allrightsreserved.Thismaterialmaynotbepublished,
broadcast,rewrittenorredistributed..

Ex-Pa. Rep. Jesse White's mother sues him,

claiming credit card fraud
February 7, 2015 12:01 AM

By Janice Crompton / Pittsburgh Post-Gazette

Former state Rep. Jesse White has been sued by his own mother, who accuses him of impersonating
her to obtain a credit card and racking up nearly $28,000 in debt, according to her lawsuit, filed
Thursday in Washington County Common Pleas Court.
Saying his actions were vindictive and childish, Mr. Whites mother, Sharlene Watazychyn, said she
didnt learn about the credit charges -- including those for his destination wedding in Las Vegas in
December 2012 and Penguins season tickets -- until July.
But Mr. White, 36, of Cecil, said his mother opened the credit account for him more than 10 years
ago to help him establish a law practice and that the current situation was prompted by a dispute
over her visits with her grandson.
After he and his wife, Eileen, placed conditions on when she could babysit their newborn son, she
flipped out, Mr. White said.
In her complaint, Ms. Watazychyn, of Waynesburg, said she had no knowledge of the credit card and
discovered that her son applied for and opened the revolving charge account online with CitiBank.
The defendant is skilled in the use of the Internet and it is believed the defendant undertook online
posing as his mother in order to obtain a revolving line of credit for his own personal use, the
complaint states. Plaintiff never applied for such an account and so never used said account.
Mr. White was the subject of controversy in the summer of 2013, when it was revealed that he
impersonated other people online on social media and message board sites, including some of his
political enemies and constituents, one of whom he called dumber than a box of rocks. The
Democrat lost to Republican newcomer Jason Ortitay in November after serving four terms in the
state Legislature.

Along with the credit card charges, Mr. White obtained cash advances of $3,500, $4,500 and $3,000
by forging his mothers signature on checks,the suit alleges. The debt totaled $27,816.
Ms. Watazychyn, who said she was unable to obtain a loan due to the debt, has accused her son of
identity theft, invasion of privacy and slander of credit. She is seeking compensatory and punitive
damages.
Mr. White said police had investigated the accusations at his mothers urging and found them to be
untrue.
They agreed with me; there was no case, said Mr. White, who said his mother has left 14 voice mails
on his phone, saying she would wreck his political career.
I am astonished that she would choose to open this up, Mr. White said.
Neither Ms. Watazychyn nor her attorneys could be reached Friday.

Return to Story

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Former state Rep. White stole identity, charged $28K in

her name, mother says in lawsuit
By Jason Cato
Saturday, Feb. 7, 2015, 12:01 a.m.
Updated 23 hours ago

Having borne near-constant attacks and criticism as a

lawmaker, former state Rep. Jesse White has another feud to
deal with of the family variety.
White's mother, Sharlene Watazychyn, 57, of Waynesburg filed
a 33-page complaint this week in Washington County courts
that accuses her son of identity theft and making more than
$28,000 in unauthorized charges on an account in her name.
I don't know who this kid is since he's been elected,
Watazychyn said Friday. When the facts come out, it will come
out how much this boy lies.
White, 36, a Cecil Democrat, returned Friday to Western
Pennsylvania from South Carolina. White, an attorney, said he
has not seen the lawsuit but insisted the allegations are not true
Former state Rep. Jesse White
and they stem from his mother's history of substance abuse and
mental illness.
This lawsuit is frivolous. The whole thing is just absurd, White
said. I will handle it quickly and effectively.
Watazychyn denied having any addiction or mental health
issues.
Absolutely not, she said. He's grasping at straws to make me
look irrational.
Watazychyn's attorney, Charles Kurowski, said his client discovered the account in July when trying to refinance
her mortgage. He said that besides the civil suit, Watazychyn told state police about the matter.
My understanding is they are looking into it, Kurowski said.
State police could not be reached.
In the lawsuit filed Thursday, Kurowski stated that White opened a revolving Citi Bank account in Watazychyn's
name and had been using it without her authority.
It has an outstanding balance of $27,816.55, statements show. The account's credit limit is $29,100.
Among the charges on the account are payments to the Washington County Bar Association, White's law office
and the Pittsburgh Penguins for season tickets. Other payments include travel and other expenses related to
White's 2012 wedding in Las Vegas.
Watazychyn accused her son of signing her name on three checks cashed on the account for $11,000.
White maintains that he has long been authorized to use the Citi Bank account, which he said his mother opened
for him to use when he started his professional career. He said his mother is aware of this and that he has voice
mail messages and other evidence.
I can prove this so easily, White said.
In his Facebook statement, White said he and his wife, Eileen, expressed concerns to his mother last summer
after the birth of their son because they were not comfortable with her driving the baby while using or under the
influence of illegal drugs. That conversation did not go well, White said.
It is unfortunate, but not at all shocking, he wrote. This suit is another example of my mother's refusal to
address an underlying problem.

White contends the lawsuit was filed soon after he made it known that he might run for a vacant district judge
seat.
In November, White lost a re-election bid for the 46th District House seat he held since 2006. White was
criticized when it was discovered in 2013 that he used online alter egos to attack his critics on the Internet.
Kurowski said the lawsuit has nothing to do with politics.
He actually thinks he could be elected? I can't believe it. This guy is something, he said. I don't have any
politics against him other than how could you do this to your own mother?
Jason Cato is a writer for Trib Total Media. Reach him at 412-320-7936 or jcato@tribweb.com.
Copyright 2015 Trib Total Media

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VOICEMAIL TRANSCRIPTS FROM SHARLENE WATAZYCHYN TO JESSE WHITE
7/28/14 13:45:01
I just left my meeting about you, and umm, my dad told me what you did nine years ago,
when you went, and you even went to the bank and told them to watch for a $50,000 check
that I was gonna try and cash. Jesse, you ruined my life. That ruined my fucking life. I almost
had a nervous breakdown. It ruined my life. It ruined my relationship with my father, which I
am actually repairing, but you ruined my life. You did that to me nine years ago and was just
like "fuck you". You knew better.
You've been to get my inheritance. You told my dad that I was a thief and I was going to steal
$50,000. Why in the fuck would I do anything but want to crush you right now? Think aboutI am. I talked to my dad; I'm getting Chuck Kurowski's gonna be my attorney. You don't
wanna answer my phone calls when I tried to call you with dad sitting right there? That's
fine. You know you think you know everything, well you don't know everything. And the fact
that I just found out that you did do that and you did tell my Dad I tried I to, ummm... tried to
cash. You would do that to me? You gotta be fucking kidding me. I'm embarrassed that
you're my son. And that is the truth. And I am gonna everything I can to fucking slam you. I
am done. You are rude. You are heartless. And you are cold. And if you think anything
otherwise you are a fool.
And you know what? I have nothing else to say to you, Do you know what that put me
through? I'm your mother and you did that to me. Your mother. Went to my father and
created all this fucking shit for your mother. Ha. Whatever. Don't listen to this; I don't care.
I'm doing what I gotta do. I got advice from Pete and Chuck Kurowski is my first motherfucking call.
7/29/14 10:13:37
This is Sharlene. I talked to Mark; he absolutely does not want to have a meeting with you
and that's not a good idea anyway after everybody says he was wishy-washy and spineless.
That all got back to him from Bob. Ummm. Yeah. He... that wouldn't be good for you, Jesse. It
just wouldn't be. He's ready to snap.
Ummm. I guess the thing that upsets me the most and I didn't make this clear yesterday. Two
things. One is that you know, through all this, and I know you got the card fraudulently and
I'm not even going there. I know it for a fact. And that the information is coming in the mail....
So you can keep saying whatever you want and saying I'm a liar, but Im not a liar. And you
keep pushing this and I'm gonna prove to everybody I'm not a liar. Now you've got to
understand you need to call me and you need to say, "Yes mom, I did do this." But no, Jess,
you're still saying no, and I'm not gonna look like the liar on this- you are. And it's up to you.
This is the time you need to be a little bit mature and grow up and say "yeah I did do it,
mom", but that's up to you.
And the second thing is the thing about my dad and the thing you did to me nine years ago.
And you lied to me. To my face. When I repeatedly asked you about it. When I almost had a
nervous breakdown, when all that stupid shit happened. When I lost my mother. That's what
you did to me. You had the bank waiting for me. Looking out for me to cash a check. How
embarrassing is that to me, let alone you? Do you want to talk about embarassing anybody?

We're way beyond that. We're way beyond that. The moment you showed me that disregard
for the last nine years you came to my house and acted like you did. You know, you were all
nice and loving and Christmas presents and we went to Florida and all that. That was all just
a fucking lie. You went behind my back over money and tried to break my relationship with
my father. And that is the truth. You wanna admit that? You call me and we'll talk about it.
You don't want to admit that? That's fine because I'm not gonna be the liar. You're gonna be
the liar. And I'm seriously not worried about pursuing this at all. I feel very clear-headed and
very strongly about it. I'm going to the cemetery right now to visit my mother for more... it's
almost like spiritual guidance from her, I would say. I'm really changing, Jess. That's it.
7/30/14 17:23:11
I just received a ridiculous phone call from my father. I'd better watch what I say because you
might play this for him. Ummm. you know, all of a sudden I'm calling Elizabeth Cowden and
I'm burying you. That's what he said. I went over to see him for advice. He told me to bury
you. He told me to call Chuck Kurowski, the guy who works for Kusturiss, I didn't even know
who he was talking about at first. That all came out of Pete Cassidy's mouth. That didn't
come out of my mouth.
And that's the bullshit thing that Dad did, number one. Number two, now he's threatening to
uh... write me out of the will completely, pay off your debt for $28,000 and I don't know what
else because I'm not agreeing to some big meeting with him. The biggest mistake I made was
asking for his advice. Just a dumb, stupid mistake on my part. Mark doesn't want to meet
with my family members... duh. Who could figure that? But that's mine... that's my problem.
That's where I'm at in my life right now. I never said I was going to destroy you. I haven't
said anything to anybody. I'm just sitting, trying to comprehend what I'm gonna do and
praying to the Good Lord that Mark can get this fucking loan. His truck broke down. He had
to get his truck towed, which made him not having that loan and being able to buy that
second car all the more sweeter for me. So I don't know if you start to get what goes on with
all the repercussions, but once again all this happened, you never apologized, admitted you
did it, and I'm out the inheritance again.
So I don't know. I suggest you call me back because I never threatened anybody. Like I said
before, I don't know what I'm doing. For the hundredth time. Everyone else knows what I'm
doing, but I don't know what I'm doing. And I'm not going to be threatened by my dad one
more time, cause that will make me go... that'll turn me into a crazy person. Probably right
about that.
7/31/14 07:41:02
Mark told me you wouldn't answer. I can't believe you don't answer. What the fuck is wrong
with you? Yeah, after this threat from my father last night, your stepfather is on the warpath.
He never thought he was getting that inheritance, but he was waiting, you know, Dad
threatened to sue him twice, so that was like fucking blew up big time and made my life
tough right now. So I would really appreciate it if you could call me back in the next 10 or 15
minutes, because ummm... I never threatened to call Elizabeth Cowden, that's fucking stupid.
And he is the one who said about Chuck Kurowski- none of that came from me. I'm so over all
your... over whoever's dumb drama. I'm over it. I'm done. I'm absolutely done. I would
appreciate a phone call back in 10 or 15 minutes, so I can get this fucking done and resolved
before i lose my mind. Jesus Christ.

7/31/14 8:52:23
For someone who is so contrite, you won't return a phone call. I asked you to call back when
Mark was awake in that 15 - 20 minute timespan. You blew me off again. Either you call me
back immediately or I am done with this nonsense. I have already conceded that my father is
not going to give me any money, and I've already conceded that the carrot will no longer be
held over my head. But the fact that that's where he went really has me pissed. Really has me
thinking fuck all of you. Now I'm giving you this last opportunity to call me, I'm giving you
the opportunity right now- what is it- Wednesday at whatever time it is to call me back within
the next five or ten minutes. That is it. I'm done! Completely and totally done. You want to
make this thing go away, you call me back so I can figure out what the fuck is going on. And I
don't care about my father's money- never was going to be mine anyway, and if he pays off
that loan I'll make sure everybody knows about it. I ain't getting that money anyhow- I don't
care. Mark doesn't care about protecting the Cassidy name- it's nothing to Mark. So, you got
like 5 or 10 minutes and that's it. I'm completely done- don't come to me later and say
anything. I try to contact you, you keep blowing me off. It's ridiculous. Done.
7/31/14 10:04:30
I don't know why you hung up on me; you're so stupid. And yeah, that was an insult. Not a
threat, it was an insult. Ummm.. Whenever you said you were trying to pay this off and you
were hoping to get ahold of some money, are you... I need to know if you're like... I guess
what I'm trying to say is that you had $28,000 over 10 years is a long time. So if you're going
to make other payment arrangements, or going to pay more or whatever it's going to be, you
don't need to talk to me, God forbid you talk to me, but you could send me a text so I have
something to go back to Mark with. I have to have something to go back to Mark with and
going back with threats is not fucking working. So please text me something to let me know
at what amount you... what your payment schedule plan is. So I can go back and tell Mark
that when he gets up today, and I need that today before... please, don't fuck with me now.
Please. Bye.
8/09/14 12:31:06
You know what Jess I was just on Facebook and I noticed I hadn't seen anything from Lisa in
a long time. Then I looked and she defriended me. Eileen's mother defriended me. What in
the hell did I do to Eileen's mother for her to defriend me?
I'm gonna blow it up. I told you not to label me a drug user and all of a sudden it's a problem
that I smoke pot when all of this stuff about the credit card came out. I told you not to do it to
me, and you're doing it anyway. I'm not going to put up with this. I'm going to clear my shit,
and that's how it's gonna be. And if you wanna crawl in your coccoon and say I'm a bad
fucking person, which you already have, that is fine. But it's not going down this way, Jess.
This is not right and I'm not laying down, and that's the bottom line. And I will set my name
straight with every one of these people.
I have all the paperwork, Jesse, and if you don't think I won't drive to fucking Harrisburg and
show it to them people, I will. I'm gonna go get copies made and I might make packets for
everybody. I have never been pissed off at you more in my life. I'm not good enough to be her
friend on fucking Facebook? I never did a goddamn thing to her, not one thing. Nor did I do
one thing to Eileen. This will be done. This will be done. Believe me, son. This will be done.

8/09/14 14:14:12
How dare you say I want drama? How fucking dare you, Jesse? That's bullshit. You're the
one who started all this fucking drama, not me. I didn't... what did you tell Lisa that would
make her not want to be my friend on Facebook? What are you telling people about me? Do
they know the truth? That I've always smoked pot. That didn't just happen the day I found
out you frauded me the $30,000. You're pushing me in a corner. You owe me. I don't owe you
anything. I am... I don't want any fucking drama. I haven't talked to you in a goddamned
week to stay the hell away from me. So how dare you go there with the drama? But I'm not
going to have you do this to me, and if that means that I'm causing drama, then get ready for
it, because I'm gonna cause drama. I am. Solobay's in... fucking my town tomorrow. With
fucking Pam Snyder.
8/09/14 15:21:59
What did I ever say hateful about your little boy? Really? That I didn't know him? That I
never got to meet him? That I never bonded with him? Yes, I've said all of those things. I
never said anything mean about your baby- that's ridiculous, number one. And number two,
you're gonna act like this is... you know the truth and I know you know the truth. And right
now you are pushing me into that corner where I feel like I have to show that this bullshit and
that this a "wag the dog" or "wag the tail" or whatever the hell it is. And it's a hell of a time
for you, keep pulling your... pushing your... uh, hand on my like this is really ballsy of you.
I'm not going to let you do this to me, I'm not. I'm absolutely not. I won't bother you again.
Believe me. Believe me. I will not. Don't have to worry about that.
8/13/14 15:44:51
Jesse, this is your mother, Sharlene. I just want you to know I'm contacting an attorney. Just
got off the phone with protective services; they claim I'm abusing my father, repeatedly
calling him and asking for money, over and over and over. Ummm, I can substantiate that
that has not... never happened and I'm gonna give them all my phone records and I'm hoping
he gives them his, but I'm going to go get an attorney and this shit's coming out. It's coming
out. I am done, Jess. You've thrown everything... you're still throwing mud. And by the way, I
have witnesses who heard just what I said so I didn't say anything improper, I'm not acting
crazy. I'm very, very angry and I'm just done. I'm over it. Done.
8/19/14 7:49:41
Jesse, this is Sharlene. I need those letters from when my father threatened to sue me. I
believe it was three times but I'm not quite sure. I know it was two. I want those letters
mailed to me, I would really appreciate it. If I have to get my attorney to get ahold of you, I
will. I'll do it. I'd really appreciate if you'd just send them to me instead of being have to go
through my attorney. And once again, it's the letters, because I have to prove that I'm
harassing him to get that money. So I need those couple letters. Thank you.
1/26/15 14:45:28
Hey! I need you to call me back within the hour or I'm going to come to your house to get this
supposed email I sent you that says 'Go ahead and open up up a credit card in my name?' I
just got off the phone with the state police, and I really want to see this document. Thank you.
And I will expect a phone call very soon!

1/26/15 16:18:40
Hey this is Sharlene. I would really... Officer Brown asked me to ask you really nicely, so
perhaps it wasn't nice enough so I'm asking you nicely AGAIN, because he assured me that
you'd give them to me no problem. Except those couple documents showing that, specifically
that 2003 email that shows I allowed you to open that account. And... and... as soon as you
show that to me, and that's substantiated, I swear I will drop everything, but I need to see
that. Thank you.
1/27/15 12:32:47
May I please have a copy of the papers you gave the state police? Again, they told me that
you said you would be glad to give them to me, and they... that's all. So could you please give
them to me? Um... I want to know what documentation you have so I could read it. I'm just
curious. So please call me back. You can email it to me because you know my email address
real well I heard. So please do. I would really appreciate it so much. Thank you and have a
blessed day.
3/25/15 18:40:00
I just left my Dads and you started your shit again. And now its all about money again,
Jesse. Im not youre fucking lying to him again. Youre fucking lying. Youre telling them
that I wont let you call me. That is not the truth. Im not doing this.
4/12/15 08:54:00
Jesse I saw your Facebook thing. That was pathetic. That was really pathetic. I was really
embarrassed by that. I was really embarrassed by what you wrote. I couldnt believe youd
write that about your mother. I love you. Bye.

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