COMMONWEALTH OF MASSACHUSETTS

MIDDLESEX, ss SUPERIOR COURT DEPARTMENT

OF THE TRIAL COURT

______________________________

Yong Li, )

   Plaintiff, )

v. ) CIVIL ACTION NO.     1881CV03670

Yanling (Rebecca) Zeng, )

____________________Defendant. )

PLAINTIFF’S REPLY TO DEFENDANT’S ANSWER TO

THE COMPLAINT

Reply to  §1-§13 of Defendant’s Answer to Complaint

.

With Respect to Defendant’s Answer as “Admit that there was a post but denied as to the translation provided by Plaintiff”, Plaintiff is willing to see if Defendant to provide her own translation.

Reply to the First Affirmative Defense

(referred some facts from the proposed Amended Complaint for convenient. If necessary in the end, Plaintiff will provide another Fact Statement in the future.)

Defendant raised up the question “... how the allegedly defamatory statements have caused her damages”,  here is Plaintiff’s replay:

• Foreseeable damage was caused by Defendant’s defamatory words. Plaintiff was removed from the WeChat group named “SFFS v. Harvard University Discrimination against Asian Students” due to Defendant’s Defamatory statements.  This removal jeopardizes the Plaintiff’s reputation, which is vital to her work in providing civil rights services, and also as the CEO of the nonprofit organization, Green Bees Multicultural Inc.

• Plaintiff is an activist committed to civil rights; “she joined the NAACP and ACLU, set up her own civil rights team, and provided a web service named “Call me please if you were mistreated by your boss” [the Chinese word is ‘老板整你请找我’]”. Since 2010, Plaintiff and her team have helped new immigrants who encountered difficulties in the U.S.  Plaintiff set up a nonprofit organization, Green Bees Multicultural Inc., and she is the CEO (chief executive officer) of the organization.” (§4, the Amended Complaint)   It is readily foreseeable that the Defendant’s defamatory statements could affect Plaintiff’s services and activities.  

• The organization, Green Bees Multicultural Inc., had filed Co-Amicus Brief for the case Students for Fair Admissions, Inc. v. President and Fellows of Harvard #: 1:14-cv-14176-ADB in United States District Court District of Massachusetts.  

Reply to the Second Affirmative Defense

Defendant’s malice can be showed in three way:

• Defendant was angry with Plaintiff because Plaintiff’s did not hire her to sale the house.

• Defendant posted false and defamatory “pink-news (sex gossip)” about Plaintiff into 437 members group of WeChat without any regret.

• Defendant refused to settle before the case go to court, and Defendant answered :“Good, I’m waiting to see who will pay the compensation (The original Chinese words are: 好的，我等着看谁应该付赔偿费用).” (§18, the proposed Amended Complaint). Defendant believes she is affordable to hire attorney and she is able to buy justice.

• Defendant has a hobby to unveil Plaintiff’s WeChat ID. Defendant took advantage of her role as a real estate agent in visiting Plaintiff’s house to come to know who Plaintiff was, and what the Plaintiff’s WeChat ID.

Reply to the Third Affirmative Defense

Defendant could claim some posts in WeChat ID were based on opinion. However, what is the “pink-news (sex gossip)” based on ?

Reply to the Fourth Affirmative Defense

Defendant tried to label this case as “frivolous” because “Plaintiff is a professional pro se” and because “ [Defendant] is a successful real estate agent in the Commonwealth of Massachusetts.”  Yet, Defendant revealed her intention, and that is: she is affordable to hire attorney, and she believes that she is able to buy justice. That is why she was deliberately to spread rumors about Plaintiff without any regret, and that is why she refused to settle before this case to go to court.

Respectfully submitted,

Yong Li

/s/_

Name: Yong Li (pro se)

Date: February 25, 2019

CERTIFICATE OF SERVICE

I hereby certify the a true copy of the above document was

served upon each party appearing defendant (or her attorney) on some day, by first class mail, or by email.

/s/ Yong Li (Pro Se)  Date: February 25, 2019