SCOTT WEIGHT (14027)

ESPLIN | WEIGHT
290 West Center Street
P.O. Box L IF YOU DO NOT RESPOND TO THIS
Provo, Utah 84603-0200 DOCUMENT WITHIN APPLICABLE
Telephone: 801.373.4912 TIME LIMITS, JUDGMENT COULD BE
Facsimile: 801.371.6964 ENTERED AGAINST YOU AS
Attorney for Plaintiff REQUESTED.

IN THE FOURTH JUDICIAL DISTRICT COURT

UTAH COUNTY, STATE OF UTAH

PAUL BRYANT,
Plaintiff, ORIGINAL COMPLAINT AND JURY
DEMAND
vs.
MEGAN STEWART,
RHONDA FUEZ, (Tier 1)
DOES 1 THROUGH 10
Case:
Defendants. Judge:

COMES NOW the Plaintiff Paul Bryant (Paul), by and through counsel, Scott Weight of
Esplin Weight, and for cause of action against the named Defendants and alleges as follows:
JURISDICTION AND VENUE

1. At all relevant times mentioned herein, Plaintiff was a resident of Utah County, State of
Utah.
2. At all relevant times mentioned herein, Defendant, Megan Stewart was a resident of Utah
County, State of Utah and may be subject to service at her home address of 3324 North
150 West, Lehi, Utah, 84043.
3. At all relevant times mentioned herein, Defendant Rhonda Fuez was a resident of Utah
and may be subject to service at her home address of 141 West 3430 North, Lehi, Utah,
84043.

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4. At all relevant times mentioned herein, on information and belief, Does I-X were
residents of Utah County, State of Utah.
5. The alleged actions and inactions forming the basis of this Complaint occurred at all
relevant times in Utah County, State of Utah.
6. The amount claimed in this matter is less than $50,000 (Tier 1).
7. Venue is properly laid with this Court in accordance with the provisions of Utah Code
Annotated § 78B-3-307.
GENERAL ALLEGATIONS

8. Plaintiff hereby references and incorporates as if fully set forth herein and at this point
the allegations of the previous paragraphs.
9. On or about March 15, 2022, Plaintiff, Paul Bryant and Defendants, Megan Stewart and
Rhonda Fuez were residents of “The Walk at Ivory Ridge”, a sub-association within
“Ivory Ridge” in Lehi, Utah, a “Master” private homeowner’s community (HOA).
10. “The Walk at Ivory Ridge” consists of 113 Townhomes closely spaced and sharing
significant common areas, walkways, parking, and amenities. These common areas and
amenities include private swimming pools and private playground areas which are for the
exclusive use of the members and guests of the HOA community.
11. Plaintiff is a registered sex offender in Utah, registration no. 2302423, which fact is
publicly accessible through the Utah Department of Corrections on their website.
12. UCA 77-41-110 (1)(B) provides that “members of the public are not allowed to use the
sexual offender registry information to harass or threaten offenders or members of their
families;” and (1)(C) provides that “harassment, stalking, or threats against offenders or
their families are prohibited and doing so may violate Utah criminal laws.”
13. To access the pool area at Ivory Ridge, a resident must use a keycard, which is monitored
and recorded in a computer system. The same action to access the pool is also necessary
to access the weight room, but which is not in the same room as the pool.
14. Due to recent Covid-19 restrictions, the private pool had been practically shut down to

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 very limited use. It was completely shut down at one point in 2020. On June 1, 2020, it
was very limited how many people/families could be at the pool at any given time.
Restrictions included making reservations, signing a waiver, and only staying for a
maximum of two hours. Scanning the resident’s keycard was required for entry. The pool
is currently only open from Memorial Day to Labor Day.
15. U.C.A. 76-8-506 makes it a crime to “knowingly give[] or cause[] to be given false
information to any peace officer or any state or local government agency or personnel
with a purpose of inducing the recipient of the information to believe that another has
committed an offense” and to “knowingly give[] or cause[] to be given to any peace
officer, any state or local government agency or personnel, . . . information concerning
the commission of an offense, knowing that the offense did not occur or knowing that he
has no information relating to the offense or danger.”
16. Paul is currently the President of the sub-association “The Walk at Ivory Ridge.” He has
been and remains actively involved in its day-to-day affairs.
17. On 03/15/2022, acting in the capacity of association president, Paul contacted Defendant
Megan Stewart, a renter within the HOA properties, residing at 3324 N. 150 W., Lehi,
Utah, 84043 by going to her residence to give her notice of several violations of the HOA
rules.
18. Upon receiving notice of these violations, Ms. Stewart shut the front door of her
residence on Paul.
19. On information and belief as reported by Sgt. J. Smith of the Lehi Police Department, on
03/17/2022, two days after Mr. Bryant informed Ms. Stewart of the HOA violations, the
Lehi Police Department received a telephone call from a resident of The Walk, who
Plaintiff believes to be Rhonda Fuez, who complained that Paul was violating his “status”
because he was “constantly” at the private playground with his therapy dog and felt like it
was “grooming behavior”, though Ms. Fuez admitted she knew it to be a private
playground. She also complained that Paul had been using the private pool.
20. On March 16, 2022, Ms. Fuez emailed the Utah Sex Offender and Kidnap Registry

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 (“USO”) and stated that Paul is constantly at the playground with hid dog and that he
brings the dog to schools. These statements are false and Ms. Feuz has never observed
Paul taking his dog to “schools.”
21. In this same email to USO she intended to imply morally inappropriate behavior from
Paul by stating he was outside her window taking pictures of the playground.
22. On March 17, 2022, Ms. Feuz reported to Lehi Police, that Paul goes to the private
playground with his dog and stated the reason for Paul doing this is “a little bit of
grooming going on.” She also stated he said “hello” to children at the playground.
23. In her conversation with Lehi Police she said that Paul takes his dog to church and
“obviously there’s some interaction going on” with kids at the church.
24. Ms. Feuz further reported she has ran into Paul and his dog a few times at the pool.
25. Ms. Feuz reported that Paul was at the playground area and waved to her children
between 12:30PM and 1PM on March 15, 2022.
26. Ms. Feuz stated she had seen a neighbor, Shayla’s son being interested in Paul’s dog.
27. Ms. Feuz stated Paul was playing in the playground with his dog and that he was “on the
slides” and “everywhere” at a time when her grandchildren “were out there” on the
playground.
28. Sgt. Smith and Det. Matfau from Lehi Police, then went to Paul’s home and interviewed
him outside his home, in full view of the nearby community residents, reading him his
Miranda rights.
29. On information and belief, on 03/22/2022 Sgt. Smith reported that he contacted Megan
Stewart by phone and interviewed her at the request of Sgt. Colqui, who had himself been
contacted by Ms. Stewart in a complaint against Paul.
30. On information and belief, Sgt. Smith reported that Ms. Stewart told him that she was
aware of Paul’s previous court cases and that “she knows of a couple other incidents that
she didn’t see on the court records.” She also told Sgt. Smith that “she was aware of an
incident where Paul was using his phone under a bathroom stall taking pictures of a
young boy at church.”

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 31. On information and belief, Ms. Fuez sent a text message to an individual on 05/04/2022
wherein she stated, “Recently, we had to (sic) run in where my granddaughters were
outside playing at the playground and he (referring to Mr. Bryant) was with his ‘so
called’ service dog on the playground. Ivory Ridge has tried to have Bryant removed
from using the community pool. They lost in court. He seems to be able to win with a
certain judge on his side.”
32. There has never been any court case filed between the Ivory Ridge HOA and Paul
Bryant, nor has he or Ivory Ridge either prevailed or “lost” in court against one another,
nor is there any judge who has been predisposed to favor Paul in any matter.
33. Any and all allegations made by Megan Stewart and/or Rhonda Fuez of other cases of
sexual impropriety, grooming, or any inappropriate behavior towards children by Paul
Bryant stated herein are false.
34. The false statements of Ms. Stewart have caused Paul mental anguish, stress, are
embarrassing, and harassing, and have caused him to pay attorney’s fees to defend
himself against false statements.
35. On information and belief, Sgt. Smith, Lehi Police, reported that Ms. Stewart stated,
“Paul was always at the pool all summer long under the guise of being the HOA
president who had responsibilities there.” (Italics and underline added).1
36. Upon information and belief, the Ivory Ridge pool access records for Ms. Stewart will
show that Ms. Stewart’s visits to the pool and any visit Paul would have made to the pool
were not at the same dates and times.
37. Ms. Stewart’s allegations that Paul was “always at the pool all summer long”, was
knowingly false.
38. Upon information and belief, Ms. Stewart also reportedly stated that Paul “checks his

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This statement by Ms. Stewart that Paul was “always at the pool all summer long” was made in the context of
Rhonda Fuez having initially asserted just five days earlier that Paul was “constantly at the park”, and Ms. Stewart
herself also asserting that Paul was checking his mailbox “all day long”, despite the physical impossibility that any
two of those statements could simultaneously be true.

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 mail 10 times per day and then loops back around the park and waits for kids to ask him
to pet his dog.” She stated that “Paul checks his mailbox all day long and that everyone
notices this.” (Underline added). She reportedly told Sgt. Smith that “she would watch
Paul as he would go get his mail and then little kids would approach Paul and his service
dog so they could pet the dog”, and that “If Paul was really just checking his mail, he
wouldn’t be doing it so many times” implying that he was doing this to groom children to
be sexually assaulted by Paul.
FIRST CAUSE OF ACTION AGAINST DEFENDANT, RHONDA FUEZ
(Defamation)

39. Plaintiff hereby references and incorporates as if fully set forth herein and at this point
the allegations of the previous paragraphs.
40. Defendant, Rhonda Fuez published, either through verbal communications and/or written
communications, defamatory statements about Plaintiff, Paul Bryant.
41. Defendant’s published statements were defamatory because the same call into question
Paul’s honesty, integrity, virtue, and/or reputation and have necessarily exposed Paul to
public hatred, contempt and/or ridicule.
42. The statements Defendant published, either through verbal communications and/or
written communications, were false.
43. As a proximate cause of Defendant’s publication of the false and defamatory statements,
Plaintiff, Paul Bryant has suffered and continues to suffer the following harms and losses:
a. Injury to his reputation in the community and/or communities where Defendant
published or caused to be published the defamatory statements at issue;
b. Threat of and actual criminal prosecution;
c. Mental and emotional anguish and distress in the past; and
d. Mental and emotional anguish and distress in the future.
SECOND CAUSE OF ACTION AGAINST DEFENDANT, RHONDA FUEZ
(Defamation per se)

44. Plaintiff hereby references and incorporates as if fully set forth herein and at this point

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 the allegations of the previous paragraphs.
45. The statements Defendant, Rhonda Fuez, either through verbal communications and/or
written communications, allege Plaintiff, Paul Bryant engaged in criminal conduct.
46. Those statements are false.
47. Such publication(s) constitute defamation per se and Plaintiff is therefore entitled to
presumed damages in addition to any and all damages heretofore and hereinafter pled.
THIRD CAUSE OF ACTION AGAINST DEFENDANT, RHONDA FUEZ
(Intentional Infliction of Emotional Distress)

48. Plaintiff hereby references and incorporates as if fully set forth herein and at this point
the allegations of the previous paragraphs.
49. At the relevant times Defendant, Rhonda Fuez published the defamatory statements about
Plaintiff, Paul Bryant, Defendant acted with outrageous and intolerable conduct.
50. Defendant intended to cause emotional distress and/or acted with reckless disregard of
the probability of causing emotional distress.
51. Plaintiff, Paul Bryant suffered severe and/or extreme emotional distress caused by
Defendant’s conduct.
FOURTH CAUSE OF ACTION AGAINST DEFENDANT, RHONDA FUEZ
(Punitive Damages)

52. Plaintiffs hereby references and incorporates as if fully set forth herein and at this point
the allegations of the previous paragraphs.
53. At the relevant times when Defendant, Rhonda Fuez published the defamatory statements
about Plaintiff, Paul Bryant, Defendant had actual knowledge the statements were false.
54. At the relevant times Defendant published the defamatory statements about Plaintiff, Paul
Bryant, Defendant acted both willfully and maliciously.
55. At the relevant times Defendant published the defamatory statements about Plaintiff, Paul
Bryant, Defendant manifested a knowing and reckless indifference toward, and a
disregard of, the rights of others, including Plaintiff, Paul Bryant.
56. Consequently, and in addition to any and all compensatory damages already pled,

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 Plaintiff is further entitled to punitive damages.
FIFTH CAUSE OF ACTION AGAINST DEFENDANT, RHONDA FUEZ
(Negligence Per Se)

57. U.C.A. 76-8-506 makes it a crime to “knowingly give[] or cause[] to be given false
information to any peace officer or any state or local government agency or personnel
with a purpose of inducing the recipient of the information to believe that another has
committed an offense” and to “knowingly give[] or cause[] to be given to any peace
officer, any state or local government agency or personnel, . . . information concerning
the commission of an offense, knowing that the offense did not occur or knowing that he
has no information relating to the offense or danger.”
58. UCA 77-41-110 (1)(B) provides that “members of the public are not allowed to use the
sexual offender registry information to harass or threaten offenders or members of their
families;” and (1)(C) provides that “harassment, stalking, or threats against offenders or
their families are prohibited and doing so may violate Utah criminal laws.”
59. Ms. Feuz, based on the foregoing statutes, has a legal duty to be truthful and honest in
speaking to police.
60. Ms. Feuz also has a legal duty to refrain from using Paul’s offender status to harass or
stalk him.
61. Ms. Feuz breached her legal duty pursuant to the above stated facts and applicable
statutes.
62. Ms. Feuz is a member of the public.
63. As a result of Ms. Feuz’s breach of her legal duty, Paul has suffered damages in the form
of attorney’s fees, stress, anxiety, and more.
FIRST CAUSE OF ACTION AGAINST DEFENDANT, MEGAN STEWART
(Defamation)

64. Plaintiff hereby references and incorporates as if fully set forth herein and at this point
the allegations of the previous paragraphs.
65. Defendant, Megan Stewart published, either through verbal communications and/or

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 written communications, defamatory statements about Plaintiff, Paul Bryant.
66. Defendant’s published statements were defamatory because the same call into question
Paul’s honesty, integrity, virtue, and/or reputation and have necessarily exposed Paul to
public hatred, contempt and/or ridicule.
67. The statements Defendant published, either through verbal communications and/or
written communications, were false.
68. As a proximate cause of Defendant’s publication of the false and defamatory statements,
Plaintiff, Paul Bryant has suffered and continues to suffer the following harms and losses:
a. Injury to his reputation in the community and/or communities where Defendant
published or caused to be published the defamatory statements at issue;
b. Threat of and actual criminal prosecution;
c. Mental and emotional anguish and distress in the past; and
d. Mental and emotional anguish and distress in the future.
SECOND CAUSE OF ACTION AGAINST DEFENDANT, MEGAN STEWART
(Defamation per se)

69. Plaintiff hereby references and incorporates as if fully set forth herein and at this point
the allegations of the previous paragraphs.
70. The statements Defendant, Megan Stewart, either through verbal communications and/or
written communications, allege Plaintiff, Paul Bryant engaged in criminal conduct.
71. Those statements are false.
72. Such publication(s) constitute defamation per se and Plaintiff is therefore entitled to
presumed damages in addition to any and all damages heretofore and hereinafter pled.
THIRD CAUSE OF ACTION AGAINST DEFENDANT, MEGAN STEWART
(Intentional Infliction of Emotional Distress)

73. Plaintiff hereby references and incorporates as if fully set forth herein and at this point
the allegations of the previous paragraphs.
74. At the relevant times Defendant, Megan Stewart published the defamatory statements
about Plaintiff, Paul Bryant, Defendant acted with outrageous and intolerable conduct.

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75. Defendant intended to cause emotional distress and/or acted with reckless disregard of
the probability of causing emotional distress.
76. Plaintiff, Paul Bryant suffered severe and/or extreme emotional distress caused by
Defendant’s conduct.
FOURTH CAUSE OF ACTION AGAINST DEFENDANT, MEGAN STEWART
(Punitive Damages)

77. Plaintiff hereby references and incorporates as if fully set forth herein and at this point
the allegations of the previous paragraphs.
78. At the relevant times when Defendant, Megan Stewart published the defamatory
statements about Plaintiff, Paul Bryant, Defendant had actual knowledge the statements
were false.
79. At the relevant times Defendant published the defamatory statements about Plaintiff, Paul
Bryant, Defendant acted both willfully and maliciously.
80. At the relevant times Defendant published the defamatory statements about Plaintiff, Paul
Bryant, Defendant manifested a knowing and reckless indifference toward, and a
disregard of, the rights of others, including Plaintiff, Paul Bryant.
81. Consequently, and in addition to any and all compensatory damages already pled,
Plaintiff is further entitled to punitive damages.
FIFTH CAUSE OF ACTION AGAINST DEFENDANT, MEGAN STEWART
(Negligence Per Se)

1. U.C.A. 76-8-506 makes it a crime to “knowingly give[] or cause[] to be given false

information to any peace officer or any state or local government agency or personnel
with a purpose of inducing the recipient of the information to believe that another has
committed an offense” and to “knowingly give[] or cause[] to be given to any peace
officer, any state or local government agency or personnel, . . . information concerning
the commission of an offense, knowing that the offense did not occur or knowing that he
has no information relating to the offense or danger.”
2. UCA 77-41-110 (1)(B) provides that “members of the public are not allowed to use the

10
 sexual offender registry information to harass or threaten offenders or members of their
families;” and (1)(C) provides that “harassment, stalking, or threats against offenders or
their families are prohibited and doing so may violate Utah criminal laws.”
3. Ms. Stewart, based on the foregoing statutes, has a legal duty to be truthful and honest in
speaking to police.
4. Ms. Stewart also has a legal duty to refrain from using Paul’s offender status to harass or
stalk him.
5. Ms. Stewart breached her legal duty pursuant to the above stated facts and applicable
statutes.
6. Ms. Stewart is a member of the public.
7. As a result of Ms. Stewart’s breach of her legal duty, Paul has suffered damages in the
form of attorney’s fees, stress, anxiety, and more.
FIRST CAUSE OF ACTION AGAINST JOHN DOES I-X
(Defamation, Defamation per se, Negligent Infliction of Emotional Distress and Punitive
Damages, Negligence Per Se)

8. Plaintiff hereby references and incorporates as if fully set forth herein and at this point
the allegations of the previous paragraphs.
9. On information and belief, John Does I-X engaged in the very same conduct previously
alleged against Defendants, Rhonda Fuez and Megan Stewart which serves as the basis
for the foregoing causes of action against Rhonda Fuez and Megan Stewart.
10. Plaintiffs hereby allege any and all previously stated causes of action and claims of
damages, including the factual basis therefore, against John Does I-X.
Dated this 10th day of October, 2022.

ESPLIN | WEIGHT

__________________________________
SCOTT WEIGHT
Attorney for Plaintiff

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