VIRGINIA: IN THE CIRCUIT COURT FOR THE COUNTY OF ROCKINGHAM

)
CHRISTOPHER WILMORE, )
)
PLAINTIFF, )
)
v. ) Case No. CL17001198-00
)
DEANNA REED, )
Serve: 231 Broad Street )
Harrisonburg, VA 22802 )
)
)
and )
)
STEVEN THOMAS, )
Serve: 231 Broad Street )
Harrisonburg, VA 22802 )
)
)
)
)
DEFENDANTS. )
___________________________________ )

COMPLAINT

COME NOW Plaintiff, CHRISTOPHER WILMORE, by and through undersigned

counsel, and in support of his Complaint against Defendants state as follows:

PRELIMINARY STATEMENT

This is a classic case of an elected official abusing the publics trust. While using the

authority, influence, and power that comes with being the Mayor of Harrisonburg, Deanna Reed

has conspired with her paramour and life partner, Steven Thomas, to willfully and maliciously

injure Plaintiffs reputation, trade, business or profession. The named Defendants have conspired

to file false criminal complaints, police reports and protective order claims against Plaintiff in an

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effort to harass and intimidate Plaintiff, all in an effort to damage the Plaintiffs reputation, punish

him for his association with his employer, and injure his trade and business in the community.

The falsity and meritless nature of Mayor Reeds criminal complaint and request for a

protective order against Mr. Wilmore was recently exposed by an Honorable Judge, who found

that Reeds story flatly contradicted her paramours story and in any event, Reed and Thomas

failed to present a shred of evidence that even came close to supporting any allegation of stalking

or criminal conduct. Bottom line: Reed and her paramour, Thomas, conspired toand indeed

didlie on Mr. Wilmore in a way that has seriously damaged his reputation and good will within

his community.

Just as bad, Reed watched as the Honorable Judge had to restrain Thomas from passing

around defamatory and libelous fliers inside the courtroom, and the Honorable Judge had to

provide a courtroom recess so that Thomas could temper his erratic and firecracker emotional

instability. In truth, Reed embarrassed herself and the City of Harrisonburg by knowingly filing a

false criminal complaint in both an ethically and legally misguided attempt to justify the criminal

conduct of her paramour, Thomas. Defendants conduct is prohibited by law and as such Plaintiff

files this suit against these named Defendants pursuant to Va. Code 18.2-499 and 500.

PLAINTIFF, DEFENDANTS AND RELEVANT THIRD PARTIES

1. Plaintiff Christopher Wilmore is a citizen of Virginia and resident of Harrisonburg,

Virginia. Mr. Wilmore is married and has a young, three-month old daughter, and Mr.

Wilmore runs a profitable business throughout the state.

2. Defendant Deanna Reed is the current Mayor of Harrisonburg. Ms. Reed is not married,

but has a live-in boyfriend, Defendant Steven Thomas, who is the co-conspirator in this

case. Ms. Reed currently lives in Harrisonburg, Virginia.

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3. Defendant Steven Thomas is a resident of Harrisonburg, Virginia and is the live-in

boyfriend of Defendant Deanna Reed, the co-conspirator in this case. Thomas has a

violent criminal history, to include offenses against the public such as Malicious Bodily

Injury, Breaking and Entering, and Robbery. Thomas routinely shows up to public

hearings to create disturbances and has been physically removed from several meetings

by police before his girlfriend became Mayor of Harrisonburg.

JURISDICTION AND VENUE

4. All of the relevant conduct giving rise to the causes of action herein set forth occurred

in the County of Rockingham, Virginia, or the City of Harrisonburg, VA.

5. Venue is authorized in the County of Rockingham, Virginia pursuant to Va. Code

8.01-262 1, 3, and 4, though Plaintiffs reserve the right to move to transfer venue in

light of the allegations in this Complaint.

MATERIAL FACTS

A. Background information

6. Prior to the events that form the basis of this Complaint, Steven Thomass has an

extensive criminal record, including violent charges such as Robbery and Malicious

Wounding.

7. Steven Thomas has been the paramour of Deanna Reeves, at all times relevant to this

Complaint.

8. Deanna Reeves is the current Mayor of Harrisonburg, Virginia.

9. Steven Thomas, prior to April 11, 2017the date that Steven Thomas threatened Mr.

Wilmore and retrieved a weapon to physically assault Mr. Wilmoreroutinely made

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 disparaging comments about Mr. Wilmores employer Nexus Services, Inc, such as

Nexus Services being crooked and that he did not trust Nexus Services.

10. Steven Thomass disparaging comments about Mr. Wilmores employer, Nexus

Services, were routinely made at government sanctioned public meetings.

11. Steven Thomas and Mr. Wilmore have a mutual friend, and their mutual friend

arranged a meeting between Mr. Wilmore and Mr. Thomas to discuss the numerous

disparaging comments made about Mr. Wilmores employer, Nexus Services. The

meeting took place in a public area, in September 2016; the meeting did not result in

any altercation whatsoever.

12. After the subject meeting, Mr. Wilmore never communicated with Steven Thomas

again until April 2017, the date on which Steven Thomas threatened Mr. Wilmore and

retrieved a weapon (thought to be a gun) to use against Mr. Wilmore.

13. After the subject meeting that took place in September 2016 between Thomas and Mr.

Wilmore, Steven Thomas provoked an altercation with a different Nexus Employee,

and Thomas sought the arrest of said employeebut law enforcement agents refused

to arrest Nexuss employee, stating that the employee had done nothing unlawful.

14. Thomas has called said Nexus employee a nigger and monkey and these statements

have been captured by video.

B. Thomas threatens Mr. Wilmore and brandishes a weapon at him

15. Prior to April 1, 2017, Mr. Wilmore had been driving down broad street, located in

Harrisonburg, for over a decade, to take the fastest route possible to reach highway 81.

16. On or about April 3, 2017, Mr. Wilmore was driving down Broad street, with his wife

and new-born daughter, coming back from his job. When Mr. Wilmore reached the

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 intersection of Broad street and Rock street, Mr. Thomas was physically standing in

the road, blocking Mr. Wilmore from driving his car forward without hitting Thomas.

At that moment, Mr. Thomas told Deanna Reed to get in a vehicle that was parked on

the side of the road immediately adjacent to the intersection where Mr. Thomas was

standing and blocking Mr. Wilmores pathway. Once Deanna Reed was in said

vehicle, Thomas begins cursing at Mr. Wilmore, using the word bitch in front of Mr.

Reeds wife and baby daughter. Wilmore then rolls down his window and ask Mr.

Thomas to refrain from using profanity such as Bitch in front of his wife and baby

daughter. Thomas then immediately states I got something for you; tells Deanna

Reed to get inside, and runs into Deanna Reed home, quickly reappearing with a

weapon in his hand. Fearing for his life, Wilmore fled with his wife and child.

17. Deanna Reed witnessed the entire incident descried in paragraph 14 because she was

with Mr. Thomas during the entire time Thomas interacted with Mr. Wilmore as

described in paragraph 14.

18. On the same day that Thomas threatened Wilmore and retrieved a weapon to use

against Mr. Wilmore, Mr. Wilmore sought a protective order against Thomas.

C. Mayor Reed abuses her authority to help her out of control boyfriend escape
criminal charges foryet againthreatening a resident and attempting to
commit violent acts.

19. After Wilmore sought a protective order against Mayor Reeds paramour (Thomas)

Reed suddenly sought a protective order against Wilmore.

20. After Wilmore sought a protective order against Mayor Reeds paramour (Thomas)

Reed suddenly filed a criminal complaint against Wilmore.

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21. Prior to Wilmore seeking a protective order against Mayor Reeds paramour, Reed

had never filed a criminal complaint against Wilmore.

22. Prior to Wilmore seeking a protective order against Mayor Reeds paramour, Reed

had never made any complaints to police about Mr. Wilmore, as evidenced by the

uncontroverted fact that no law enforcement officer had ever spoke to Wilmore

pursuant to an investigation or otherwise about any allegations of harassment or

stalking regarding Mayor Reed.

23. Prior to Wilmore seeking a protective order against Mayor Reeds paramour, Reed

had never requested any law enforcement agency to investigate Mr. Wilmore in

relation to any allegation of harassment/stalking with respect to Mayor Reed or her

paramour, Thomas.

24. At the time that Reed filed a criminal complaint, and sought a protective order, against

Wilmore, Reed presented no evidenceother than self-serving statementsthat

Wilmore had engaged in a pattern of harassing/stalking Reed.

25. After Wilmore sought a protective order against Mayor Reeds paramour (Thomas),

law enforcement has shown up at Wilmores house to discuss his action of seeking a

protective order against Reeds paramour, Thomas.

26. Mayor Reed labeling Mr. Wilmore as a stalker has severely damaged his reputation

per se, while also causing loss profits to his personal training business because the

number of women he normally trains has declined. now cited this incident as the

reason not to contract with him for his services.

27. In an April 13, 2017 hearing on the protective order requested by Mayor Reed, the

Court ruled that there was no cause for a protective order.

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 28. In an April 13, 2017 hearing on the protective order requested by Mayor Reed,

Deanna Reed presented zero evidence to support her petition for protective order

against Wilmore.

29. In the April 13, 2017 hearing on the protective order requested by Mayor Reed, the

Judge remarked from the bench that the Defendants stories contradicted one another.

CONCLUSION

Sadly, Reed, the Mayor, has allowed her erratic, temperamental, and violent paramour,

Thomas, to hi jack her credibility, sound judgement, and ethical compassto the detriment of

Wilmores personal and professional reputation.

COUNT I CIVIL CONSPIRACY AGAINST DEFENDANTS

1. Plaintiff incorporates by reference all of the preceding allegations.

2. Based on all the incorporated facts to support this Count I, Defendants combined,

associated, agreed, mutually understood and concerted together for the purpose of

willfully and maliciously injuring Plaintiff in his reputation, trade, business or profession.

3. Plaintiff was damaged by Defendants actions.

4. Plaintiff is entitled to recover no less than the specified sum on $550,000 while also being

entitled to recover three-fold damages, costs and attorneys fees pursuant to Va. Code

18.2-499 and 500.

JURY DEMAND

Plaintiff hereby demand a trial by jury on all triable issues.

WHEREFORE Plaintiff respectfully requests that this Court enter judgment against

Defendants, jointly and severally, in the amount not less than $550,000 in compensatory, treble,

and punitive damages, plus costs and attorneys fees. Plaintiff further respectfully request that

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this Court provide such other and further relief as may be appropriate under the circumstances of

this case.

Respectfully submitted this 14th day of April, 2017.

CHRISTOPHER WILMORE
By Counsel

Nexus Caridades Attorneys Inc.

Counsel for Plaintiff

BY:
Jessica Sherman Stoltz (VSB#90172)
113 Mill Place Pkwy, Suite 105A
Verona, VA 24482
Direct: 540-255-4365
jstoltz@nexuscaridades.com

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 CERTIFICATE

I hereby certify that a true copy of the foregoing was faxed and mailed via first class
mail, postage prepaid as indicated on this 14th day of April, 2017 to:

Ms. Deanna Reed

231 Broad Street
Harrisonburg, VA 22802

Mr. Steven Thomas

231 Broad Street
Harrisonburg, VA 22802

Jessica Sherman Stoltz