Thomas Caso

Laura Keith
401 W 53rd St #2C
New York, NY 10019
646.584.6537 (L)
646.584.8070 (T)
laura@showroomsouth.com
tommy4564515@gmail.com

THOMAS CASO, : SUPERIOR COURT OF

LAURA KEITH, : NEW JERSEY

DEFENDANTS :
vs. : LAW DIVISION: CIVIL PART
________________________________ : MONMOUTH COUNTY
:
: Docket No. MON-L-1034-22
SONIA CHOI : Civil Action
PLAINTIFF :
: THOMAS CASO AND
LAURA KEITH’S
COUNTERCLAIM
….........................................................................................................................................................
COUNTERCLAIM

Defendants, Laura Michelle Keith alongside Thomas J. Caso both appearing pro
se, respectfully submit the following by way of counterclaim against Plaintiff, Sonia
Choi, with saying:

COUNT ONE

DEFAMATION, LIBEL, AND SLANDER

1. Plaintiff Choi and has made false, unlawful, and malicious statements about

Defendants Keith and Caso, in Police Reports, sworn statements to the Court,

and identical lawsuits across New Jersey in different jurisdictions. These are
including but not limited to the following false allegations regarding Defendants

Keith and Caso:

a. Claiming Defendant knowingly and willingly gave up rights of

ownership to Weimaraner, Cash

b. Claiming Defendant Keith has never had any ownership rights to

Weimaraner, Cash.

c. Claiming Defendants, made up a whole story of stolen dog, attempting

to minimize, and diminish the pain, horror, and severe emotional

distress Defendants Keith and Caso have been undergoing.

d. Claiming Defendants reached out to her to provide financial assistance

for vet bills, and supplies on several occasions.

e. Claiming that Thomas Caso wanted to surrender the dog, but

Defendant did not wish to do so.

f. Claiming that Thomas Caso did knowingly sign a “Change of

Ownership”, going behind Defendant Keith’s back without her

knowing.

g. Claiming that at least (10) times Defendants Keith and Caso would call

asking Plaintiff to watch their dog, Cash.

h. Claiming that Defendant’s dog, Cash was not in a safe and comfortable

environment.

i. Claiming that Defendants have a history of substance abuse.

j. Claiming that Defendants were having people call her business,

accusing her of stealing puppy, Cash.

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 k. Claiming that Defendants could no longer financially provides care for

puppy, Cash.

l. Claiming that Defendants have spread false allegations or have made

defamatory, libelous, or slanderous statements regarding Plaintiff.

m. Claiming that Defendants have intentionally spread false statements

for purpose of injury to the Plaintiffs reputation.

n. Claiming that Defendants engaged in criminal conduct by committing

the act of burglary.

o. Claiming that Defendants have caused Plaintiff any reputational harm,

emotional distress, and serve to present a substantial risk of death or

serious bodily injury

2. These claims by the Plaintiff have been sworn as truth and submitted in

Certifications, Police Reports, and lawsuits across the state of New Jersey, done

with the intention of injuring Defendant’s character with purpose of interfering

with an investigation on criminal actions, manipulating the Court and legal

process, and with pure malice.

3. Plaintiff Choi has intentionally and continually engaged in said conduct in police

reports, individuals, and in sworn statements submitted to the court with clear

intent to harm, harass, and cause extreme distress. Plaintiff Choi demonstrates a

very clear motive for these actions: malicious harm.

4. Libelous, slanderous, and defamatory Cease and Desists letters, requested by

Plaintiff Choi, on behalf of her lawyer at Mullen Law Firm, have gone out to

countless supporters of Bring Puppy Cash Home, for simply “liking” the page

and anyone who interacts positively with, with threats of legal action if they do

3
 not abide, clarifying this was done intentionally to harm Defendants character,

disseminate legal action towards the theft of our dog, with malicious and

aggressive behavior.

WHEREFORE, Laura Keith and Thomas Caso demand judgement

against Plaintiff Choi for the following: (a) IMMEDIATE RETURN OF

WEIMARANER DOG NAMED CASH, (b) compensatory damages, consequential,

and incidental damages, (c) legal fees, (d) cost of suit expenses, (e) all travel

expenses and other related expenses due to said counts for entire time period

puppy Cash has been gone, (f) emotional therapy expenses needed for mental

health due to said counts, (g) pre and post-judgement interest (h) and further

relief as the court may deem equitable and just.

COUNT TWO

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

1. Defendants Keith and Caso repeat each of the foregoing allegations as though

fully set forth at length herein.

2. Defendants Keith and Caso have suffered and continues to suffer severe

emotional distress, Post Traumatic Stress Disorder, and emotional injury due to

Plaintiff Choi’s intentional infliction of pain, with her attempts to disseminate

any investigation on the theft of Defendants dog, and the malicious conduct.

3. As direct and proximate cause of said conduct and all counts listed, Defendant,

Keith has, and continues to suffer conditions of severe emotional distress, Post

Traumatic Stress Disorder, which are including but not limited to depression,

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panic attacks, seizures, extreme stress, causing weight loss, skin conditions, hair

loss, inadequate sleep, loss of appetite, unable to work, unable to engage in

public social events, unable engage in reasonable everyday life routines. Direct

results of said related intentional infliction of extreme stress include, but are not

limited to:

a. worrying about the safety, security, and well–being of puppy Cash, since

having raised him from 8 weeks old.

b. Missing our puppy’s every move, in every step of our lives.

c. Not knowing, when, if, how, we will ever be able to get our puppy Cash

home safely, is a mother’s worst nightmare.

d. The pain. The pure pain carries an enormous glooming emptiness over our

home and entire lives.

e. Having never been involved in, or even have seen a lawsuit in my life, how

to proceed and what the steps will be going forward.

f. The financial burden of the countless initiatives, necessary measures, and

all other constituents that have been accompanied as a result.

g. The constant worry, the constant heartache, the constant depression, the

constant anxiety, the constant thought of what else can I do every second

of every day for an entire year to get our child/ family member/ puppy

home is too much for any person to EVER have to endure. It is a complete

disgrace that a person could actually commit this crime and continue

living their lives.

5
 h. The constant paranoia feeling of being watched, recorded, and stalked,

given we have been consistently harassed by linked individuals to Choi and

conspirator David Grippi.

4. An entire year of Defendants Keith and Caso’s life have been virtually

taken away and destroyed due to said counts of Plaintiff Choi,

5. AN ENTIRE YEAR of our dog Cash’s life has been virtually taken away due

to said counts of Plaintiff Choi, and conspirator David Grippi. Missing his second

birthday, missing an entire Spring Season, missing an entire Summer Season,

Holiday’s without his family. As a young pup, the irreparable harm and

emotional distress on our poor dog is just unbearable to think about.

6. Unable to ask for relief sought of the last entire year with our dog to be replaced,

as that is something we can NEVER get back.

7. The thought that crosses my mind too often, that our poor puppy thinks we

abandoned him, breaks me more than anything.

8. Any quality of life has been abruptly, maliciously, and unlawfully

taken away from us.

9. Reporting false claims of a “burglary” at Plaintiff’s home when her supposed

“friend” came to give her a wellness check for being unresponsive while dog-

sitting. This resulted in an innocent man, with a completely clean record, getting

arrested, and in jail for 9 days with no bail. Plaintiff Choi invited this man to her

wedding less than a month before. The abundance of lies told by Choi are

EASILY proven and demonstrate a complete disregard for the Court, laws,

authorities, respect for herself, dignity, and any reasonable human decency.

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 WHEREFORE, Laura Keith and Thomas Caso demand judgement

against Plaintiff Choi for the following: (a) IMMEDIATE RETURN OF

WEIMARANER DOG NAMED CASH, (b) compensatory damages, consequential,

and incidental damages, (c) legal fees, (d) cost of suit expenses, (e) all travel

expenses and other related expenses due to said counts for entire time period

puppy Cash has been gone, (f) emotional therapy expenses needed for mental

health due to said counts, (g) pre- and post-judgement interest (h) and further

relief as the court may deem equitable and just.

COUNT THREE

Harassment, Bullying, and Threats

1. Defendants Keith and Caso repeat each of the foregoing allegations as though fully

set forth at length herein.

2. Consistent harassment, threats, and bullying commencing on or about March 2022,

including but not limited to, alias names of Thomas Wells, Chris Reese, Anthony

Edison, showing a clear connection, result, and resemblance of Plaintiff Choi and

Plaintiff Grippi’s intentional acts of immoral and unlawful conduct.

3. Impersonating the Superior Court of Monmouth County, making a call to Caso and

myself on our way to the Replevin Hearing on July 7Th, 2022, telling us our Hearing

date had been rescheduled until July 11 th. When we called Judge Andrea Marshall’s

chambers office: we were told no one had called us, it had not been rescheduled. This

unlawful act was recorded.

7
4. Threats to Caso and Keith under alias name, Chris Reese, that the FBI is after us, and

is ready to come get us if we don’t take everything down immediately, with continued

harassment of calling and texting up until the most recent of August 13th.

5. Attempts to manipulate authorities and the Legal Justice System with falsehoods in

order to disseminate an investigation into the theft of our dog.

6. Threats of extreme violence including the threat of life to someone who has

supported our efforts in the return of our dog.

7. Plaintiff Choi downplayed the severity of said threat in paragraph 6 in attempts to

manipulate the Court.

8. Reporting false claims of a “burglary” at her home in Pennsylvania, when a friend

came to give her a wellness check for being unresponsive while dog-sitting. There

was no burglary, Caso and Keith spoke with her brother and was never asked to

leave. This resulted in an innocent man, with a completely clean record, getting

arrested, and in jail for 9 days with no bail. Plaintiff Choi shows a complete disregard

for the government expenses involved, and the impact on individuals.

9. The spread of false statements directly and indirectly all-over social media at

Defendant and Caso about very detailed information of our case after a Hearing.

10. Involving third party individuals to engage, claiming our extremely painful situation

is a scam, as if it weren’t painful enough.

11. Every listed number of harassments, threat, or bullying tactic is a direct result of

Plaintiff Choi’s deception and unlawful acts.

WHEREFORE, Thomas Caso and Laura Keith demand judgement against

Plaintiff Choi for the following: (a) IMMEDIATE RETURN OF WEIMARANER

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 DOG NAMED CASH, (b) compensatory damages, consequential, and incidental

damages, (c) legal fees, (d) cost of suit expenses, (e) all travel expenses and other

related expenses due to said counts for entire time period puppy Cash has been

gone, (f) emotional therapy expenses needed for mental health due to said

counts, (g) pre and post-judgement interest (h) and further relief as the court

may deem equitable and just.

COUNT FOUR

FRIVOLOUS LITIGATION

1. Defendants Thomas Caso and Laura Keith repeat each and every allegation set

forth in Counts One, Two, and Three of the written counterclaim as if set forth at

length herein.

2. The complaints filed by Plaintiff Choi were commenced, used and continued in

bad faith, seemingly for the purpose of covering up the criminal actions she has

conducted, disseminating an investigation on such, and intentional and

aggressive malicious harm. This was clearly done without any rational thinking

or logic involved.

3. When Choi filed the complaint and continued the pursuit of the same, Choi knew

that the claim was without any reasonable basis in law or equity and could not be

supported by a good-faith argument.

4. All reports to authorities contain false narratives, wasting everyone’s time and

money. Plaintiff Choi has no truths to her defamatory and slanderous statements

and carries ZERO evidence.

9
5. Reporting false claims of a “burglary” at Plaintiff’s home, when a friend came to

give her a wellness check for being unresponsive while dog-sitting. This resulted

in an innocent man, with a completely clean record, getting arrested, and in jail

for 9 days with no bail. Plaintiff Choi shows a complete disregard for the

government expenses involved, and the impact on an innocent individual she

used to claim, “a friend”.

6. The filing of the complaint by Choi on Caso and Keith was frivolous as there is

absolutely no evidence to back up any of her malicious lies, and in violation of

N.J.S.A. 2A:15-59.1

WHEREFORE, Thomas Caso and Laura Keith demand judgement

against Plaintiff Choi, for the following: (a) IMMEDIATE RETURN OF

WEIMARANER DOG NAMED CASH, (b) compensatory damages, consequential,

and incidental damages, (c) legal fees, (d) cost of suit expenses, (e) all travel

expenses and other related expenses due to said counts for entire time period

puppy Cash has been gone, (f) emotional therapy expenses needed for mental

health due to said counts, (g) pre and post-judgement interest (h) and further

relief as the court may deem equitable and just.

COUNT FIVE

MALICOUS PROSECUTION

1. Defendants Keith and Caso repeat each of the foregoing allegations as though

fully set forth at length herein.

2. Plaintiff Choi has wrongfully subjected defendants Keith and Caso to the

prosecutorial process with malicious motives.

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3. Plaintiff has intentionally and knowingly given false sworn statements to the

Court and to authorities in Police Reports with intent to incriminate.

4. Plaintiff has intentionally and knowingly given false sworn statements to the

Court and to authorities in Police Reports with intent to harass.

5. Plaintiff has intentionally and knowingly given false sworn statements to the

Court and to authorities in Police Reports with intent to cause emotional

infliction of harm.

6. Plaintiff has caused irreparable damage to both Defendants Keith and Caso, and

likely their dog, Cash. Severe trauma of their dog being stolen resulting in PTSD

in addition those listed in Count two.

WHEREFORE, Thomas Caso and Laura Keith demand judgement

against Plaintiff Choi, for the following: (a) IMMEDIATE RETURN OF

WEIMARANER DOG NAMED CASH, (b) compensatory damages, consequential,

and incidental damages, (c) legal fees, (d) cost of suit expenses, (e) all travel

expenses and other related expenses due to said counts for entire time period

puppy Cash has been gone, (f) emotional therapy expenses needed for mental

health due to said counts, (g) pre and post-judgement interest (h) and further

relief as the court may deem equitable and just.

SEPERATE DEFENSES

FIRST AFFIRMATIVE DEFENSE

Plaintiff did in fact steal Defendants Keith and Caso’s dog by way of deception
and forgery.
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 SECOND AFFIRMATIVE DEFENSE

Damages, if any, sustained by the plaintiff are the result of her own

actions.

THIRD AFFIRMATIVE DEFENSE

Any Statements made by Defendants Keith and Caso were made speaking the
truth, and with the only sole intent for the return of their beloved dog, who was
unlawfully taken from them.

FOURTH AFFIRMATIVE DEFENSE

Plaintiff gives an abundance of lies in the complaint that would not be able to be
backed by any evidence as they are simply false.

FIFTH AFFIRMATIVE DEFENSE

Plaintiff’s claim is barred and must be dismissed as frivolous litigation pursuant

to N.J.S.A. 2A:15-59.

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 THIRD PARTY COMPLAINT AGAINST DAVID GRIPPI

COUNT ONE

DEFAMATION, LIBEL, AND SLANDER

1. David Grippi and has made false, unlawful, and malicious statements about

Defendants Keith and Caso, in Police Reports, sworn statements to the Court,

and identical lawsuits across New Jersey in different jurisdictions. These are

including but not limited to the following false allegations regarding Defendants

Keith and Caso:

a. Claiming Defendant knowingly and willingly gave up rights of

ownership to Weimaraner, Cash

b. Claiming Defendant Keith has never had any ownership rights to

Weimaraner, Cash.

c. Claiming that Thomas Caso wanted to surrender the dog, but

Defendant did not wish to do so.

d. Claiming that Thomas Caso did knowingly sign a “Change of

Ownership”, going behind Defendant Keith’s back without her

knowing.

2. Claims by David Grippi have been submitted in Certifications, Police Reports,

and lawsuits across the state of New Jersey, done with the intention of injuring

Defendant’s character with purpose of interfering with an investigation on

criminal actions, manipulating the Court and legal process, and with pure malice.

3. David Grippi has intentionally and continually engaged in said conduct in police

reports, individuals, and in sworn statements submitted to the court with clear
 intent to harm, harass, and cause extreme distress. David Grippi demonstrates a

very clear motive for these actions: malicious harm.

WHEREFORE, Laura Keith and Thomas Caso demand judgement against David Grippi

for the following: (a) IMMEDIATE RETURN OF WEIMARANER DOG NAMED CASH,

(b) compensatory damages, consequential, and incidental damages, (c) legal fees, (d)

cost of suit expenses, (e) all travel expenses and other related expenses due to said

counts for entire time period puppy Cash has been gone, (f) emotional therapy expenses

needed for mental health due to said counts, (g) pre and post-judgement interest (h)

and further relief as the court may deem equitable and just.

COUNT TWO

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

1. Defendants Keith and Caso repeat each of the foregoing allegations as though

fully set forth at length herein.

2. Defendants Keith and Caso have suffered and continues to suffer severe

emotional distress, Post Traumatic Stress Disorder, and emotional injury due to

David Grippi’s intentional infliction of pain, caused by the attempts to

disseminate any investigation on the theft of Defendants dog, and the malicious

conduct.

3. As direct and proximate cause of said conduct and all counts listed, Defendant,

Keith has, and continues to suffer conditions of severe emotional distress, Post

Traumatic Stress Disorder, which are including but not limited to depression,

panic attacks, seizures, extreme stress, causing weight loss, skin conditions, hair
loss, inadequate sleep, loss of appetite, unable to work, unable to engage in

public social events, unable engage in reasonable everyday life routines. Direct

results of said related intentional infliction of extreme stress include, but are not

limited to:

a. worrying about the safety, security, and well–being of puppy Cash, since

having raised him from 8 weeks old.

b. Missing our puppy’s every move, in every step of our lives.

c. Not knowing, when, if, how, we will ever be able to get our puppy Cash

home safely, is a mother’s worst nightmare.

d. The pain. The pure pain carries an enormous glooming emptiness over our

home and entire lives.

e. Having never been involved in, or even have seen a lawsuit in my life, how

to proceed and what the steps will be going forward.

f. The financial burden of the countless initiatives, necessary measures, and

all other constituents that have been accompanied as a result.

g. The constant worry, the constant heartache, the constant depression, the

constant anxiety, the constant thought of what else can I do every second

of every day for an entire year to get our child/ family member/ puppy

home is too much for any person to EVER have to endure. It is a complete

disgrace that a person could actually commit this crime and continue

living their lives.

h. The constant paranoia feeling of being watched, recorded, and stalked,

given we have been consistently harassed by linked individuals to Choi and

conspirator David Grippi.

4. An entire year of Defendants Keith and Caso’s life have been virtually

taken away and destroyed due to said counts of David Grippi

5. AN ENTIRE YEAR of our dog Cash’s life has been virtually taken away due

to said counts of Plaintiff Choi, and conspirator David Grippi. Missing his second

birthday, missing an entire Spring Season, missing an entire Summer Season,

Holiday’s without his family. As a young pup, the irreparable harm and

emotional distress on our poor dog is just unbearable to think about.

6. Unable to ask for relief sought of the last entire year with our dog to be replaced,

as that is something we can NEVER get back.

7. The thought that crosses my mind too often, that our poor puppy thinks we

abandoned him, breaks me more than anything.

8. Any quality of life has been abruptly, maliciously, and unlawfully

taken away from us.

WHEREFORE, Laura Keith and Thomas Caso demand judgement

against David Grippi for the following: (a) IMMEDIATE RETURN OF

WEIMARANER DOG NAMED CASH, (b) compensatory damages, consequential,

and incidental damages, (c) legal fees, (d) cost of suit expenses, (e) all travel

expenses and other related expenses due to said counts for entire time period

puppy Cash has been gone, (f) emotional therapy expenses needed for mental

health due to said counts, (g) pre- and post-judgement interest (h) and further

relief as the court may deem equitable and just.

COUNT THREE

Harassment, Bullying, and Threats

1. Defendants Keith and Caso repeat each of the foregoing allegations as though fully

set forth at length herein.

2. Consistent harassment, threats, and bullying commencing on or about March 2022,

including but not limited to, alias names of Thomas Wells, Chris Reese, Anthony

Edison, showing a clear connection, result, and resemblance of Plaintiff Choi and

Plaintiff Grippi’s intentional acts of immoral and unlawful conduct.

3. Impersonating the Superior Court of Monmouth County, making a call to Caso and

Keith on their way to the Replevin Hearing on July 7Th, 2022, stating the Hearing

date had been rescheduled until July 11 th. It was notified to Judge Andrea Marshall’s

chamber’s office: we were told no one had called us, it had not been rescheduled.

This unlawful act was recorded.

4. Threats to Caso and Keith under alias name, Chris Reese, that the FBI is after us, and

is ready to come get us if we don’t take everything down immediately, with continued

harassment of calling and texting up until the most recent of August 13 th.

5. Attempts to manipulate authorities and the Legal Justice System with falsehoods to

disseminate an investigation into the theft of our dog.

6. Threats of extreme violence including the threat of life to someone who has

supported our efforts in the return of our dog.

7. The spread of false statements directly and indirectly all-over social media at

Defendant and Caso about very detailed information of our case after a Hearing.

8. Involving third party individuals to engage, claiming our extremely painful situation

is a scam, as if it weren’t painful enough.

9. Every listed number of harassments, threat, or bullying tactic is a direct result of

Plaintiff Choi’s deception and unlawful acts by both Choi and Grippi.
 WHEREFORE, Thomas Caso and Laura Keith demand judgement against

David Grippi for the following: (a) IMMEDIATE RETURN OF WEIMARANER

DOG NAMED CASH, (b) compensatory damages, consequential, and incidental

damages, (c) legal fees, (d) cost of suit expenses, (e) all travel expenses and other

related expenses due to said counts for entire time period puppy Cash has been

gone, (f) emotional therapy expenses needed for mental health due to said

counts, (g) pre and post-judgement interest (h) and further relief as the court

may deem equitable and just.

COUNT FOUR

MALICOUS PROSECUTION

1. Defendants Keith and Caso repeat each of the foregoing allegations as though

fully set forth at length herein.

2. David Grippi has wrongfully subjected defendants Keith and Caso to the

prosecutorial process with malicious motives.

3. David Grippi has intentionally and knowingly given false sworn statements to the

Court and to authorities in Police Reports with intent to incriminate.

4. David Grippi has intentionally and knowingly given false sworn statements to the

Court and to authorities in Police Reports with intent to harass.

5. David Grippi has intentionally and knowingly given false sworn statements to the

Court and to authorities in Police Reports with intent to cause emotional

infliction of harm.
6. David Grippi has caused irreparable damage to both Defendants Keith and Caso,

and likely their dog, Cash. Severe trauma of their dog being stolen resulting in

PTSD in addition those listed in Count two.

WHEREFORE, Thomas Caso and Laura Keith demand judgement

against David Grippi, for the following: (a) IMMEDIATE RETURN OF

WEIMARANER DOG NAMED CASH, (b) compensatory damages, consequential,

and incidental damages, (c) legal fees, (d) cost of suit expenses, (e) all travel

expenses and other related expenses due to said counts for entire time period

puppy Cash has been gone, (f) emotional therapy expenses needed for mental

health due to said counts, (g) pre and post-judgement interest (h) and further

relief as the court may deem equitable and just.

 CERTIFICATION OF SERVICE

I hereby certify that a copy of the within pleading was served within the time
prescribed by Rule 4:6-1.

RESPECTFULLY,

THOMAS J. CASO

March 13, 2022

______________________________

LAURA MICHELLE KEITH

March 13, 2023

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