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Plaintiffs allege repeated solicitations to advertise, refusal to advertise, and subsequent publication of allegedly untrue and defamatory statements online. The filing also asserts diversity jurisdiction and proper venue in Maryland, describing intentional or reckless publication of defamatory information and resulting injury. The complaint names parties, jurisdiction, venue, and action claims including retaliation through the website’s content.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/complaint-summary-of-the-action/279865/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/complaint-summary-of-the-action/279865.png","ImageObject",442,249,{"name":88,"@type":89},"Felix Montgomery","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-30","2026-09-16",true,{"@type":98,"interactionType":99,"userInteractionCount":40},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"Who are the plaintiffs and defendants in the complaint?","Question",{"text":108,"@type":109},"The plaintiffs are the Penobscot Indian Nation, Global Direct Sales, LLC, Christopher Russell, and Ryan Hill. The defendants include Aaron Krowne and multiple related individuals and entities connected to the Mortgage Lender Implod-O-Meter and ml-implode.com website.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"What conduct do plaintiffs allege the defendants committed?",{"text":113,"@type":109},"Plaintiffs allege the defendants repeatedly solicited them to advertise, and after they declined, defendants published allegedly untrue and defamatory statements on the website.",{"name":115,"@type":106,"acceptedAnswer":116},"On what legal grounds does the complaint assert the court’s authority and location?",{"text":117,"@type":109},"The complaint states jurisdiction under 28 U.S.C. § 1332 based on diversity, and venue is proper in the District of Maryland under 28 U.S.C. § 1391 because substantial events occurred and caused injury in Montgomery County, Maryland.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},279865,1790217395,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":40,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":135,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":47},549768064778,"https://ap-avatar.wpscdn.com/davatar_6f874abed73319feea01a86fa6f0fab8","UNITED STATES DISTRICT COURT  \nFOR THE DISTRICT OF MARYLAND  \nGLOBAL DIRECT SALES, LLC, PENOBSCOT )  \nINDIAN NATION, CHRISTOPHER RUSSELL )  \nand RYAN HILL, )  \n7824 Cessna Avenue )  \nGaithersberg, MD 20879 )  \n)  \nPlaintiffs, )  COMPLAINT  \n)  \n-v- )  \n)  \nAARON KROWNE, individually and d/b/a THE )  \nMORTGAGE LENDER IMPLOD-O-METER and ) Case No.:  \nML-IMPLODE.COM, KROWNE CONCEPTS, )  \nINC., IMPLODE-EXPLODE HEAVY )  \nINDUSTRIES, INC., JUSTIN OWINGS, KRISTA )  \nRAILEY, STREAMLINE MARKETING, INC. and )  \nLORENA LEGGETT, )  \n)  \nDefendants. )  \n__________________________________________ )  \nPlaintiffs, the Penobscot Indian Nation, Global Direct Sales, LLC, Christopher Russell and Ryan Hill, by their attorneys Kantrowitz, Goldhamer and Graifman, P.C. and The Mason Law Firm, LLP, as and for their complaint against defendants, Aaron Krowne, individually and [d/b/a The Mortgage Lender Implod-O-Meter and ML-Implode.com](d/b/a The Mortgage Lender Implod-O-Meter and ML-Implode.com), Krowne Concepts, Inc., Implode-Explode Heavy Industries, Inc., Justin Owings, Krista Railey, Streamline Marketing, Inc. and Lorena Leggett, allege as follows:  \nSUMMARY OF THE ACTION  \n1. The Penobscot Indian Nation (“PIN”) is a federally recognized Native American Government which created The Grant America Program™, a government grant program that provides low to moderate-income homebuyers with a down payment grant to be used towards the  \npurchase of a home. Plaintiff Global Direct Sales, LLC (“GDS”) is a Maryland limited liability company. PIN and Global Direct Sales, LLC (“GDS”) are parties to an Agreement to develop, organize and operate a downpayment assistance (“DPA”) program wholly owned by PIN. GAP was established to help low to moderate income homebuyers realize the dream of home ownership by providing down payment assistance grants.  \n2. Defendants Aaron Krowne, Justin Owings, Krowne Concepts, Inc. and/or Implode-Explode Heavy Industries, Inc., own and operate the Mortgage Lender Implode-O[Meter and the website ml-implode.com](Meter and the website ml-implode.com) (collectively the “website”).  \n3. Beginning in or about June 2008 and continuing into August 2008, Defendant Lorena Leggett on behalf of Defendants repeatedly solicited Plaintiffs to advertise on Defendants’ website. In August 2008, Plaintiffs advised Defendants that it would not advertise on Defendants’ website.  \n4. On September 15, 2008, after Plaintiffs declined to advertise on Defendants’website, Defendants published an article on their website containing untrue and defamatory statements regarding Plaintiffs.  \n5. Defendant Krista Reily individual and/or through her company Defendant Streamline Marketing, Inc. wrote the untrue and defamatory article, Defendants Krowne and Owings own and control the content on the website and are responsible for the website’s employee’s solicitation of Plaintiffs and the retaliatory, untrue and defamatory article published on the website when Plaintiffs declined to advertise with Defendants.  \nJURISDICTION AND VENUE  \n6. This Court has jurisdiction over this action under 28 U.S.C. § 1332 (Diversity Jurisdiction) because the matter in controversy exceeds the sum or value of $75,000, exclusive of interest and costs, and is between citizens of different States.  \n7. Venue is proper in the District Court for the District of Maryland pursuant to 28 U.S.C. 1391(b) and 1391 (c) in that a substantial part of the events giving rise to the claims asserted herein occurred in and are causing injury in Montgomery County, Maryland.  \n8. Defendants intentionally and/or recklessly published defamatory information about Plaintiff Global Direct Sales, a Maryland company and Maryland resident, Russell and Hill, both Maryland residents and published the same via Internet within the state of Maryland, including Montgomery County and Defendants’ publishing of defamatory information resulted in significant injury and harm. Additionally, Defendants solicited Plaintiffs in M","cbCaiaZyACpn3IkA","https://ap.wps.com/l/cbCaiaZyACpn3IkA","pdf",38425,13,"English","# SUMMARY OF THE ACTION\n## JURISDICTION AND VENUE\n## PARTIES","[{\"question\":\"Who are the plaintiffs and defendants in the complaint?\",\"answer\":\"The plaintiffs are the Penobscot Indian Nation, Global Direct Sales, LLC, Christopher Russell, and Ryan Hill. The defendants include Aaron Krowne and multiple related individuals and entities connected to the Mortgage Lender Implod-O-Meter and ml-implode.com website.\"},{\"question\":\"What conduct do plaintiffs allege the defendants committed?\",\"answer\":\"Plaintiffs allege the defendants repeatedly solicited them to advertise, and after they declined, defendants published allegedly untrue and defamatory statements on the website.\"},{\"question\":\"On what legal grounds does the complaint assert the court’s authority and location?\",\"answer\":\"The complaint states jurisdiction under 28 U.S.C. § 1332 based on diversity, and venue is proper in the District of Maryland under 28 U.S.C. § 1391 because substantial events occurred and caused injury in Montgomery County, Maryland.\"}]","Complaint - Summary of the Action | PDF",1789528569]