Lucille Iacovelli
3 Deer Hollow Road
Forestdale, MA 02644
DECLARATION OF RICHARD E. BERGERON III
I have witnessed Lucille Iacovelli’s frail condition, and she is not capable of harming anyone. She can barely leave her tiny apartment for necessities.
I have communicated myself with Arlene Mulley with good intentions in mind only to be met with a barrage of hateful, unprovoked attacks on me with threats to sue me and report me to the FBI. I had simply suggested that her sister would like to see her. (See Exhibit 1)
I have been working on writing a book about Lucille Iacovelli since late 2006. She is the victim of a plastic surgery operation that caused significant damage to her facial tissue and impaired her ability to breathe. She was featured on the HBO Documentary “Plastic Disasters.”
Lucille Iacovelli’s sister is the antithesis of Lucille, who is the kindest person you could ever meet. Mulley is verbally abusive, angry for no reason. Her behavior is indicative of a serious mental instability. She would have to be delusional to believe Lucille is even capable of abuse.
Mulley sent me an email (see exhibit) that labeled me as a “sexual preditor” with absolutely no evidence of any kind that I was anything of the sort. I simply let her know that her sister was hoping to visit with her.
Ms. Mulley is attempting to use the court systems to wage some delusional and illegitimate family feud with her helpless sister.
Lucille would not do anything abusive or violent, and she has been the victim of the abuse Mulley attempts to pin on her. Mulley is abusive by nature. Lucille is not.
Ms. Mulley has become increasingly abusive to me in several email dispatches, phone calls, and defamatory blogs.
I have tried to engage in a civil conversation with Ms. Mulley only to have her hang up before I could even begin a conversation with her.
I have instructed Ms. Mulley numerous times to stop contacting me, but she continues to harass me incessantly with phone calls and emails.
Ms. Mulley not only makes regular harassing phone calls to me, but she also takes the time to leave disturbing messages such as one where she promised “You and Lucille will fry!”
Despite the fact that I continue to tell Ms. Mulley that I want nothing to do with her, that I have not written anything about her as part of Lucille’s book project, and that I have nothing against this woman, Mulley continues to make contact with me and will not answer her own phone without spouting insults (which I recorded for posterity) like “gay boy” and “gumshoe.”
Ms. Mulley is under the impression that I am a private investigator. I am nothing of the sort, though I do engage in investigative reporting. I am a writer, editor, and Webmaster. I am not a licensed or trained private investigator, but Ms. Mulley has posted blogs containing claims that I am a private investigator, that I live in “mommy’s basement,” and that I am using my father’s name to harass her through the Webster Police Department. My mother is dead, and I do not live in a basement. I did mention my father’s name when I spoke to the Webster Police about Mulley’s disturbing calls, but I never made any attempt to leverage his name to get any favorable treatment.
Mulley has contacted me by phone from her own home number, which is in my incoming calls record on my Internet phone. I have also received calls from Hubbard Hospital, where Ms. Mulley is employed. No message was left, but several phone calls came through from that number. I contacted Human Resources at Hubbard a couple months ago to inform them of Mulley’s harassment, and for a while there was no contact. However, it seems Ms. Mulley has been bragging that she is beyond reproach at her workplace because she is the only expert in her field employed by the hospital.
I have repeatedly informed Ms. Mulley that I will initiate civil litigation against her if her harassment continues and she continues to post her defamatory blogs about me. She has refused to leave me alone and continues to write untrue things about me.
Mulley has absolutely no reason to harbor any kind of grudge against me, and I have had nothing to do with her except for writing her a letter telling her that her sister was thinking about her and would appreciate a visit. I have shown great patience in allowing Mulley the opportunity to change her ways, and she has continuously gone into periods of being nice and apologetic only to change back to being mean and spiteful shortly thereafter. (See the May, 2008 email in Exhibit 2)
Ms. Mulley’s behavior has become increasingly verbally abusive and threatening. This unjustified harassment is incredibly frustrating to deal with considering I have done absolutely nothing to provoke this woman in any way.
Ms. Mulley has actually warned me that she will get a restraining order against me and repeatedly makes mention of all her great lawyers and her friends in the court system.
I declare under penalty of perjury under the laws of the State of Massachusetts, that the foregoing is true and correct.
DATED
this 7th day of August, 2008
__________________________________
Richard E. Bergeron, III
147 Old County Road
East Sandwich, MA 02537
617-209-4325
EXHIBIT 1
from Rich Bergeron <rich.bergeron@gmail.com>
to arlmulley@hotmail.com,
arlenemulley@netzero.net,
date Sat, Oct 6, 2007 at 4:03 PM
subject Lucille
Hello,
I am writing in regards to your sister Lucille. Though I'm sure you are aware that she has had tremendous difficulty since undergoing her last operation, lately she seems completely despondent and has a tough time even getting out of the house for errands. I am a writer here in town and plan to write a book about Lucille's ordeal through the years since her first surgery. She has been very kind to me and is always going out of her way to struggle through each day without asking for help. Through all that she manages to drive over to my house every now and then to drop off home baked goods and other gifts.
She constantly speaks about how much she misses you and would like to see you again. In these past few months since meeting Lucille she has been like a mother to me, which is something I have not had since my own mother died when I was a child. Coming from a huge Irish Catholic family myself, I know how important family is. It is always good to reconnect. Lucille is in need of some major support at this point in her life. Each day she goes through without being able to enjoy life to the fullest, it's as if she loses another piece of herself and takes one step closer to giving up entirely.
I know she wants to see this book come to fruition, and I have been putting as much time in as I can on it. I would love to speak with you at some point as well to get some more background on what she's been through and the before and after track of her ordeal. Anything you could offer would be much appreciated.
If you could find the time to visit her, she could certainly use some company. She is miraculously able to hide her pain from most of the people she interacts with, but when things are bad it is hard not to notice. She is convinced she does not have much time left, though I believe that her will to live is incredibly strong. Still, she needs some kind of support system and someone who truly understands her to lift her spirits in order to get through this latest slump. Feel free to call me anytime or send me an email. Even a phone call to her might help right now. She's really run down after just getting over a horrible fever. Hopefully she's on the mend by now, but just a regular day is hard enough. Battling another sickness on top of what she has to endure is ten times as bad for her as it would be for anyone else. I hope you two can reconnect and spend some time together. She really adores you and discusses you whenever I visit her.
Thanks,
--
Rich Bergeron
Editor/Writer/Webmaster
617-209-4325
~~~~~~~~~~~~~~~~
Reply
from arlenemulley@netzero.net <arlenemulley@netzero.net>
to rich.bergeron@gmail.com,
date Sun, Oct 7, 2007 at 10:13 AM
subject Re: Lucille
whoever you are,
don't e-mail me again. you do not know my sister like i have for the past 45 years.
we don't want anything to do with her. good luck to you sucker, you're in for the ride of your natiral life. you'll never be rid of her now.
i beg you, don't contact me again regaurding lucille iacovelli.
arlene mulley rrt-nps
from arlenemulley@netzero.com <arlenemulley@netzero.com>
to RICH.BERGERON@gmail.com,
date Thu, Feb 21, 2008 at 8:29 PM
subject MR. BERGERON
mailed-by netzero.com
DEAR MR. BERGERON,
I HAVE NO IDEA WHO YOU ARE OR WHAT YOU EXPECT TO GET FROM E-MAILING ME SO AT THIS TIME I AM REPORTING YOU TO THE FEDERAL BEUREAU OF INVESTIGATION OF INTERNET FRAUD DIVISION BECAUSE I BELEIVE YOU COULD POSSIBLY BE, IN MY OPPINION, A SEXUAL PREDITOR. PLEASE DO NOT E-MAIL OR CONTACT ME IN ANY WAY.
ARLENE B. MULLEY
EXHIBIT 2
MOST RECENT E-MAILS FROM ARLENE MULLEY:
from CARDIOARL@aol.com
to RICHBERGERON@gmail.com
date Tue, Aug 5, 2008 at 1:05 PM
subject Check out Rich.bergeron's Playlist - thanks for your gumshow photo's for the....
Click here: Rich.bergeron's Playlist - Rich Bergeron's Free Speech Fight - MyFlashFetish.com
from CARDIOARL@aol.com
date Sun, Aug 3, 2008 at 11:56 AM
subject Check out Aggressive White Collar Criminal Charges Defense - United Defense G
Click here: Aggressive White Collar Criminal Charges Defense - United Defense Group NOW THIS IS FUN
from CARDIOARL@aol.com
to LUCIACOVELLI@gmail.com
cc RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 8:07 PM
subject Check out lucille iacovelli hate and jealousy: NO COMMENT FROM WRITERFORTRUTH
Click here: lucille iacovelli hate and jealousy: NO COMMENT FROM WRITERFORTRUTH, THIS TIME
from ARLENE MULLEY <arlmulley@hotmail.com>
to richbergeron@gmail.com
date Wed, Jul 30, 2008 at 9:54 PM
subject FW: Check out lucille iacovelli hate and jealousy: RICH BEGERON PRIVATE INVE...
i'm waiting
From: CARDIOARL@aol.com
Date: Wed, 30 Jul 2008 21:26:34 -0400
Subject: Fwd: Check out lucille iacovelli hate and jealousy: RICH BEGERON PRIVATE INVE...
To: arlmulley@hotmail.com
--Forwarded Message Attachment--
Date: Wed, 30 Jul 2008 21:05:13 -0400
From: rich.bergeron@gmail.com
To: CARDIOARL@aol.com
Subject: Re: Check out lucille iacovelli hate and jealousy: RICH BEGERON PRIVATE INVES...
You are an idiot. You're so willing to try to needlessly attack innocent people that you are going to ruin your own life doing it. I'll have you tied up in litigation for a long time, and you'll lose.
from CARDIOARL@aol.com
to RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 9:31 PM
subject Fwd: Check out lucille iacovelli hate and jealousy: RICH BEGERON PRIVATE INVE...
HAHAHAHAHAHAHAHAHAHAHAPOOR INDIGENT $$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$
GOOD LUCK TO YOU PI ALL MY ASSETTS ARE IN MY FAMILY'S TRUST. HAHAHAHAHAHAHA
from CARDIOARL@aol.com
to RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 9:31 PM
subject Fwd: Check out lucille iacovelli hate and jealousy: RICH BEGERON PRIVATE INVE...
I'LL WIN YOU RETATRD!!!
________________________________________________________________________________________________
from CARDIOARL@aol.com
to rich.bergeron@gmail.com
date Wed, Jul 30, 2008 at 9:02 PM
subject Re: Check out lucille iacovelli hate and jealousy: RICH BEGERON PRIVATE INVES...
SEE YOU IN BARNSTABLE COURT. WE'LL MAKE A VACATION OF IT. GOOD LUCK WITH THAT.
FREEDOM OF SPEACH IS GOOD FOR YOU AND BETTER FOR ME.
ARLENE MULLEY
PS. WHY WOULD I BE ANONYMOUS, I HAVE NOTHING TO HIDE, LIME YOU DO
from CARDIOARL@aol.com
to rich.bergeron@gmail.com
date Wed, Jul 30, 2008 at 9:25 PM
subject Re: Check out lucille iacovelli hate and jealousy: RICH BEGERON PRIVATE INVES...
I CAN WAIT FOR A LONG TIME GO FOR IT!!!!!!!!
ARLENE MULLEY RRT-NPS
ARE YOU SO UPSET BECAUSE YOU AND LUCILLE HAVE NO MONEY YOU ARE WILLING TO SUE ANYONE. THANKS FOR THAT EVIDENCE , PUNK. AND GOOD LUCK WITH YOUR LAWSUIT AGAINST ME. HAVE FUN, I WILL.
________________________________________________________________________________________________
from CARDIOARL@aol.com
to FJMANCINIO@aol.com
cc RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 9:21 PM
subject Check out Blogger: lucille iacovelli hate and jealousy - Post a Comment
Click here: Blogger: lucille iacovelli hate and jealousy - Post a Comment BERGERON THREATENED ME UNK!!!!
from CARDIOARL@aol.com
to FJMANCINIO@aol.com
cc RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 9:23 PM
subject Check out Blogger: lucille iacovelli hate and jealousy - Post a Comment
Click here: Blogger: lucille iacovelli hate and jealousy - Post a Comment ANOTHER THREAT UNK !!!!!
from CARDIOARL@aol.com
to LUCIACOVELLI@gmail.com
cc RICHBERGERON@gmail.com (Yes, this is you.) Learn more
date Wed, Jul 30, 2008 at 7:45 PM
subject Check out lucille iacovelli hate and jealousy
Click here: lucille iacovelli hate and jealousy NOW EVERYBODY WILL KNOW HAHAHAHAHA
from CARDIOARL@aol.com
to LUCIACOVELLI@gmail.com
cc RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 7:59 PM
subject Check out lucille iacovelli hate and jealous
Click here: lucille iacovelli hate and jealousy SEE YA IN COURT!! HAHAHAHAHAHAHA
ONE OF MY RESPONSES THAT DID NOT DETER MS. MULLEY’S HARASSMENT:
from Rich Bergeron <rich.bergeron@gmail.com>
to CARDIOARL@aol.com
date Wed, Jul 30, 2008 at 8:26 PM
subject Re: Check out lucille iacovelli hate and jealousy
Arlene,
I have nothing to do with you, nothing against you, and am doing nothing to deserve your repeated public attacks. For one your continuous mention of my mother is offensive. My mother is dead, and I do not live with her. She died when I was 7. I have also not tried to use my father's name to get anything done in Webster. You know nothing about my writing or the lawsuit I am engaged in with Xyience and Fertitta Enterprises. I am counter-suing both of them for $15 million, and the case against me brought by Xyience alone is all smoke and mirrors with no substance. The more you draw me into this the more I am thinking about accompanying Lucille to court and/or writing up a statement for her about your repeated harassment of me for no apparent reason. I'm sure the judge will take that into account in addition to whatever evidence Lucille can collect of your abusive and disturbing messages.
If you would like to do something smart stop defaming me and remove the posts about me. I have enough already to file a formal suit against you for harassment and defamation. I will file locally and force you to travel to Barnstable court. You will have to pay a lawyer to represent you while I won't. I am already serving as my own lawyer against major corporations and the case is now over a year old. My opponents have spent about $300,000 in legal fees while I have expended practically nothing. Keep on pushing this issue and you will find yourself in deeper legal trouble than you have ever been in. You'll have to scrap all your plans to develop that land you wrote about when you get bogged down in those kinds of legal fees.
I have you on tape ranting and raving, and even your own posts are schizophrenic. One moment you try to suck up to me and the other you are slamming me for no reason whatsoever. Whatever you have going on with Lucille is between you and her. I do not want to get involved, but your behavior is forcing me to.
If you do not immediately remove everything about me and stop harassing me, I will write a formal letter to your employer explaining what's going on. I will also formally warn Hubbard Hospital that they will also be sued if this continues seeing as some of this behavior happened while you were working there and IP addresses confirm that.
I do not understand what your problem is. Why would you attack me like this? You are only making me into more of an advocate for Lucille and more likely to help her force you to be accountable for your actions. I have written nothing about you that is in any way negative, and so far I have refused to stoop to your level because I am not who you think I am. I am fair, honest, and patient. However, when you make a nice guy mad, he takes it personally. You've already made one arch enemy in your own sister. Don't make one out of a complete stranger you know nothing about.
from CARDIOARL@aol.com
to rich.bergeron@gmail.com
date Wed, Jul 30, 2008 at 8:49 PM
subject Re: Check out lucille iacovelli hate and jealousy
I DIN'T READ YOUR WHOLE E-MAIL, BUT GOOD LUCK WITH WHAT YOU WANT, I WOULD LOVE FOR YOU TO SUE ME.!!!!!!!!
ARLENE MULLEY RR-NPS
from CARDIOARL@aol.com
to RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 8:50 PM
subject Fwd: Check out lucille iacovelli hate and jealousy
DEAR RICH,
GOOD LUCK WITH YOUR ENCOUNTERS. SEE YOU IN COURT. ARLENE MULLEY
from CARDIOARL@aol.com
to RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 8:54 PM
subject Fwd: Check out lucille iacovelli hate and jealousy
HUBBARD REGIONAL HOSPITAL
340 THOMPSON RD.
WEBSTER, MA YOU SHOULD PUT ATTN. WILLIAM FALKOWSKI CEO OR PAULA BIGELOW
DIRECTOR OF PATIENT CARE SERVICES
OR MASS. REGISTRY IN MEDICINE, WELL YOU CAN FIGURE IT OUT, GOOD LUCK WITH THAT RICH. ARLENE
from CARDIOARL@aol.com
to RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 8:55 PM
subject Fwd: Check out lucille iacovelli hate and jealousy
TOO LATE TO SUE ME FOR ASSETTS, I PUT THEM IN A FAMILY MEMBERS NAME. I AM INDIGENT\LIKE YOU AND LUCILLE HAHAHAHAHAHAHA
from CARDIOARL@aol.com
to LUCIACOVELLI@gmail.com
cc RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 8:08 PM
subject Check out lucille iacovelli hate and jealousy: RICH BEGERON PRIVATE INVESTIGT
Click here: lucille iacovelli hate and jealousy: RICH BEGERON PRIVATE INVESTIGTOR HAHAHAHAHAHA
LOSERS
from CARDIOARL@aol.com
to LUCIACOVELLI@gmail.com
cc RICHBERGERON@gmail.com
date Wed, Jul 30, 2008 at 8:22 PM
subject Check out An Ironic Twist - Bipolar disorder - Zimbio
Click here: An Ironic Twist - Bipolar disorder - Zimbio SEND IT TO THE MAGISTRATE HAHAHAHAHAHA
from ARLENE MULLEY <arlmulley@hotmail.com>
to richbergeron@gmail.com
date Wed, Jul 30, 2008 at 9:50 PM
subject i will win, try me, i am waiting!
like oj i will win, exept i am innocent, but good luck hahahahahahah
i have more money than you have lies hahahahahahahaha
ps rich, you really should be over your mothers death, unless you're a mamas boy. hahahahahahahah
i win you'll see, go for it hahahahahahahahaha
i can guarantee it. ask my sister, she knows why...(i think)
from arlenemulley@netzero.com <arlenemulley@netzero.com>
to richbergeron@gmail.com
date Wed, Jul 30, 2008 at 10:05 PM
subject why would you want me to take down??????????
I refuse to remove whatever your retarded mind thinks is defamatory, good luck suing me with my maffia atty. hahahahahaha
you sound really intimidated by what i wrote, i assume you didn't see the other websites on pi's which you are the STAR!! did i spell that right? I learned all this from lucille the fraud. you don't scare me, i'm smarter than you'll ever be. wheres your education??? up your pi ass?
arlene b. mulley rrt-nps
you can report me to the NBRC also. good luck!!!
from arlenemulley@netzero.com <arlenemulley@netzero.com>
to richbergeron@gmail.com
date Wed, Jul 30, 2008 at 10:08 PM
subject do you not know i am reading everything you write via remote, u r not the only pi, the only retarded one tho hahahahaha
______________________________________________________________________________________________
from arlenemulley@netzero.com <arlenemulley@netzero.com>
to rich.bergeron@gmail.com
date Sun, May 11, 2008 at 6:32 PM
subject Re: Come join me on FIGHTBOOK.COM...
DEAR RICH,
I REALLY FEEL BAD ABOUT THE THINGS I SAID TO YOU. I EVEN MADE COMMENTS ON MY WEBSITE MALICIOUSSISTERATHRUZ TODAY. I KNOW IT'S THE HORMONES. I AM ALMOST 3 MONTHS PREGNANT.
I REALIZE YOU HAVE NOTHING TO DO WITH MY SISTER FEUD WITH ME AND I SHOULD NEVER HAVE E-MAILED AND CALLED YOU WITH SUCH CRAP.
I DON'T EXPECT YOU TO FORGIVE ME, I SAID THINGS I DIDN'T MEAN, AND
I DON'T EVEN KNOW YOU. I'M SURE YOU ARE A SMART GUY, BEING A WRITER AND ALL. I USED TO TAKE TYQUANDO(I CAN'T SPELL TODAY,SORRY) SO YOUR
MIXED MARTIAL ARTS BACKGROUND IS VERY IMPRESSIVE.
I'M SORRY I CALLED YOU UGLY BECAUSE YOU ARE NOT! I SAW YOU ON FACEBOOK. YOU HAVE NICE CAMERAS TOO.
I HONESTLY HOPE LUCILLE DOESN'T MAKE YOU HER NEXT VITIM. DON'T YOU
KNOW WHAT SHE HAS DONE TO PEOPLE IN THE PAST? YOU ARE AN INTERSTING 30 YEAR OLD PROFESSIONAL WRITER AND MARTIAL ARTIST, WHAT IS IT YOU HAVE IN COMMON WITH A 60 YEAR OLD FRAUD? MAKE SURE SHE DOESN'T BRING YOU DOWN WITH HER.
I WANTED TO COOPERATE WITH YOU, BUT WHEN I FOUND OUT YOU KNEW LUCILLE I GUESS I FREAKED OUT BECAUSE I WANT NOTHING TO DO WITH HER.
YOU HAVE NO IDEA WHAT IT WAS LIKE FOR THE PAST 44 YEARS OF MY LIFE, TRYING TO AVOID HER. SHE IS TOO NEEDY. DOES SHE ASK MANY
FAVORS OF YOU? YOU SHOULD SAY NO TO HER AND SEE HOW SHE REACTS.
NEVER MIND, DON'T DO THAT, I DID AND LOOK WHERE IT GOT ME.
YOU CAN E-MAIL ME ANYTIME AT THIS E-MAIL ADRESS. MY UNCLE MADE ME CLOSE THE HOTMAIL ACCT. LUCILLE STARTED FOR ME, BEFORE I EVEN HAD A COMPUTER. YOU DON'T KNOW HER LIKE I DO, SHE IS BAD NEWS., BUT YOU
SEEM LIKE A DECENT GUY. I WOULD LIKE TO MEET YOU SOMEDAY, BUT YOU MUST HATE ME.
SORRY FOR EVERYTHING,
ARLENE
Incoming phone calls believed to be from Arlene Mulley have come from these numbers on the following dates:
8/1/2008*:
A Toupin
185 Maple St
Douglas, MA 01516
(508) 476-2389
(ARLENE’S HOME)
*Four calls from this number came in on this date, and three messages were left, which are included as Exhibit 3. There are at least a dozen calls from this number in my phone records from various different dates.
8/2/2208
Hubbard Regional Hospital
340 Thompson Rd
Webster, MA 01570-1512
(508) 943-2600
(Two calls came in from this number on this date with no messages left)
SOUTHBRIDGE SAVINGS BANK
86 Worcester Rd
Webster, MA 01570-2106
(508) 949-2600
(one call came in from this number at 8:32 AM)
August 3, 2008:
Umass Memorial Medical Center
281 Lincoln St
Worcester, MA 01605-2138
(508) 334-1000
(one call came from this number, and Ms. Mulley is the only medical professional I know in the Worcester area)
1