Marvin Defamation Lawsuit

68-CV-23-682
Filed in District Court

State of Minnesota
11/13/2023 12:18 PM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF ROSEAU NINTH JUDICIAL DISTRICT
David Marvin, Court File No.:

Case Type: Defamation
Plaintiff,
v. SUMMONS
Shana Lanctot; Matt Lanctot; Jeff Johnson; Patti

Johnson; Coreen Lindquist, and Kristin Coauette
Johnson
Defendants.
THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANTS:
1. You are being sued. The Plaintiff has started a lawsuit against you. The Complaint is
attached to this Summons. Do not throw these papers away. They are official papers that start a lawsuit
and affect your legal rights, even if nothing has been filed with the court and even if there is no court
file number on this Summons.
2. You must BOTH reply, in writing, AND get a copy of your reply to the
person/business who is suing you within 21 days to protect your rights. Your reply is called an
Answer. Getting your reply to the Plaintiff is called service. You must serve a copy of your Answer or
Answer and Counterclaim (Answer) within 21 days from the date you received the Summons and Complaint.
ANSWER: You can find the Answer form and instructions on the MN Judicial Branch website
at www.mncourts.gov/forms under the “Civil” category. The instructions will explain in detail how
to fill out the Answer form.
3. You must respond to each claim. The Answer is your written response to the
Plaintiff’s Complaint. In your Answer, you must state whether you agree or disagree with each paragraph
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of the Complaint. If you think the Plaintiff should not be given everything asked for in the Complaint,
you must say that in your Answer.
4. SERVICE: You may lose your case if you do not send a written response to the
Plaintiff. If you do not serve a written Answer within 21 days, you may lose this case by default. You
will not get to tell your side of the story. If you choose not to respond, the Plaintiff may be awarded
everything they asked for in their Complaint. If you agree with the claims stated in the Complaint, you
do not need to respond. A default judgment can then be entered against you for what the Plaintiff
asked for in the Complaint.
To protect your rights, you must serve a copy of your Answer on the person who signed this
Summons in person or by mail at this address:
LARSON • KING, LLP

30 East Seventh Street, Ste. 2800
Saint Paul, MN 55101
5. Carefully read the Instructions (CIV301) for the Answer for your next steps.
6. Legal Assistance. You may wish to get legal help from an attorney. If you do not
have an attorney and would like legal help:
 Visit www.mncourts.gov/selfhelp and click on the “Legal Advice Clinics” tab to get
more information about legal clinics in each Minnesota county.
 Court Administration may have information about places where you can get legal
assistance.
NOTE: Even if you cannot get legal help, you must still serve a written Answer to protect
your rights or you may lose your case.
7. Alternative Dispute Resolution (ADR). The parties agree to or be ordered to
participate in an ADR process under Rule 114 of the Minnesota Rules of Practice. You must still
serve your written Answer, even if you expect to use ADR.
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68-CV-23-682
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Date: LARSON KING, LLP

'3'1013
-
11-
By DMZM
David M. Wilk (222860)
Mark A. Solheim (213226)
Patrick H. O'Neill, III (0399111)
2800 Wells Fargo Place
30 E. Seventh Street
St. Paul, MN 55101
Tel: (651) 3126500
Fax: (651) 3126618
[email protected]
mso][email protected]
[email protected]
Attorneys for Plaintiff

68-CV-23-682
State of Minnesota
11/13/2023 12:18 PM
STATE OF MINNESOTA DISTRICT COURT
COUNTY OF ROSEAU NINTH JUDICIAL DISTRICT
David Marvin, Court File No.:

Case Type: Defamation
Plaintiff,
v. COMPLAINT
Shana Lanctot; Matt Lanctot; Jeff Johnson; Patti JURY TRIAL DEMANDED
Johnson; Coreen Lindquist; and Kristin Coauette
Johnson,
Defendants.
Plaintiff David Marvin (“Marvin”), for his Complaint against Defendants Shana Lanctot; Matt
Lanctot; Jeff Johnson; Patti Johnson; Coreen Lindquist; and Kristin Coauette Johnson, (collectively
“Defendants”) states and alleges as follows:
NATURE OF THE ACTION
1. This case is about baseless allegations, wild fabrications, and false statements made by
Shana Lanctot, Matt Lanctot, Jeff Johnson, Patti Johnson, and Coreen Lindquist, and Kristin Coauette
Johnson, against David Marvin, designed to damage his reputation in the Warroad community.
2. Marvin, the longtime head coach of the Warroad Girls Hockey Team, recently led the
team to back-to-back state championships in 2022 and 2023.
3. Despite the team’s successes, Shana Lanctot and the other Defendants have repeatedly
leveled false accusations of criminal activity, sexual harassment, and abuse against Marvin and have
invited and encouraged others to do the same.
4. Defendants’ false statements must stop and Marvin is entitled to relief for the damage
already done to his reputation by Defendants’ untrue allegations.

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5. Marvin seeks judicial intervention to prevent further harm to his reputation and to
obtain monetary compensation for the great harm that Defendants’ false statements have already
caused.
PARTIES
6. David Marvin is an upstanding member of the Warroad community, the current head
coach of the Warroad Girls Hockey Team, and a longtime supporter of Warroad High School student-
athletes.
7. Marvin has served as the head coach of the Warroad Girls Hockey team for 17 seasons.
In that time, he has led the team to thirteen state tournament appearances and four state titles. The
vast majority of the girls Marvin has coached have gone on to attend college or university and some
continued to play hockey after high school.
8. Marvin’s dedication to the Minnesota hockey community and the Warroad Girls
Hockey program over almost two decades of coaching is beyond dispute. In addition to his coaching
position, Marvin serves on the board of the MAX Foundation, an organization he founded to honor
his son, Max Marvin, and generate support and awareness for young people experiencing mental
health issues.
9. Shana Lanctot is a resident of the Red Lake Falls, Minnesota who formerly resided in
Warroad, Minnesota and is a parent of former Warroad Girls Hockey players.
10. Matt Lanctot is a resident of Red Lake Falls, Minnesota who formerly resided in
Warroad, Minnesota and is a parent of former Warroad Girls Hockey players.
11. Jeff Johnson is a resident of Warroad, Minnesota and a parent of a current Warroad
Girls Hockey player.
12. Patti Johnson is a resident of Warroad, Minnesota and a parent of a current Warroad
Girls Hockey player.
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13. Coreen Lindquist is a resident of Warroad, Minnesota and a parent of a former
Warroad Girls Hockey player.
14. Kristin Coauette Johnson is a former resident of Warroad currently residing in
Arizona, and a parent of a former Warroad Girls Hockey player.
JURISDICTION AND VENUE
15. This Court has subject matter jurisdiction over this matter pursuant to Minn. Stat.
§ 484.01, subd. 1.
16. This Court has personal jurisdiction over Minnesota residents Coreen Lindquist, Patti
Johnson, Jeff Johnson, Shana Lanctot, and Matt Lanctot.
17. This Court has personal jurisdiction over Kristin Coauette Johnson under Minn. Stat.
§ 543.19. Kristin Coauette Johnson recently relocated to Arizona but continues to make frequent trips
to Minnesota and the Warroad area and her actions, within the State of Minnesota and outside of
Minnesota, as detailed below, have caused injury to Marvin in Minnesota.
18. Venue in this Court is proper under Minn. Stat. § 542.09 because one or more
Defendants reside within Roseau County and all of the events giving rise to the Complaint took place
within this judicial district.
FACTUAL ALLEGATIONS
19. For months Defendants have conducted a campaign to harm Marvin’s reputation and
have him removed as a coach for the Warroad Girls Hockey Team. Among other things, Defendants
have made reports about Marvin to the Warroad High School administration, including the athletic
department. The school investigated those allegations and later renewed Marvin’s coach contract.
Unsatisfied, Defendants then moved their campaign to social media and continued to harm Marvin’s
reputation.
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20. For example, Defendant Coreen Lindquist was notified on April 14, 2023, that the
school had already investigated—and rejected—allegations of sexual harassment she brought forward.
21. Nevertheless, Defendants continued to press Warroad High School not to renew
Marvin’s contract and to instead terminate him from his coaching position. Defendants or those they
are aligned with presented alleged statements to Warroad High School in an effort to force the school
to terminate Marvin. On or about October 11, 2023, Warroad High School issued a statement that
made clear that no action was taken against Marvin in response to the allegations. Instead, the school
hired Marvin as a coach for the 2023-2024 season.
22. Defendants then turned their attention to social media to further their false allegations
against Marvin.
The October 30 Letter
23. On or about October 30, 2023, Defendants Jeff and Patti Johnson, Coreen Lindquist,
or Matt and Shana Lanctot published an open letter regarding the “Warroad Girls Hockey Program”
that falsely alleged that Marvin and other members of the Warroad coaching staff engaged in
inappropriate and criminal conduct towards current and former members of the Warroad Girls
Hockey team. The October 30 Letter is attached to the Complaint as Exhibit A.
24. From the nature of the allegations and the letter itself, it is clear that Marvin, as the
head coach of the “Warroad Girls Hockey Program,” was the focus of the false statements.
25. The October 30 Letter falsely accused Marvin of “sexually harassing comments and
public urination in front of minor players” and “Sexual Harassment – Minn. Stat. § 609.749,” as well
as “Intentional infliction of emotional distress” and “Hazing under Minn. Stat. § 135A.155,” among
other things.
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26. The intended, actual, and reasonable interpretation of these false statements is that
Marvin engaged in criminal conduct, sexually harassed and hazed members of the Warroad Girls
Hockey Team, and violated Minn. Stat. § 609.749.
27. These statements and the reasonable inferences drawn from them constitute false
statements of fact.
28. The October 30 Letter also called for replacement of the “existing girls hockey
coaches” to “protect all players from the horrific experiences that our children have endured as well
as so many before them in the girls hockey program.”
29. The October 30 Letter directed all readers to contact Defendants Jeff and Patti
Johnson, Coreen Lindquist, or Matt and Shana Lanctot for “further information or statements”
regarding these allegations.
30. The October 30 Letter was jointly drafted, approved, and publicized by Defendants
Jeff and Patti Johnson, Coreen Lindquist, and/or Matt and Shana Lanctot.
31. Shana Lanctot shared the October 30 Letter on her Facebook page and, on
information and belief, provided the letter to third parties, including but not limited to Valley News
Live and makers of the podcast “Grand Forks Best Source.”
32. Media outlets, including Sports Illustrated, also publicized the false statements and
baseless allegations contained in the October 30 Letter.
Shana Lanctot and Coreen Lindquist Defame Marvin on the Grand Forks Best Source
Podcast
33. On or about October 30, 2023 Shana Lanctot participated in an interview with the
host of the podcast Grand Forks Best Source. The interview was made available through the Grand
Forks Best Source podcast feed and video of the interview was posted on YouTube.
34. The entire October 30 Letter was read on air. Shana Lanctot was prompted by the
host to “name names” and she expressly singled out David Marvin as the subject of the letter.
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35. Shana Lanctot further stated that the October 30 Letter was intended to address
“mistreatment of players by David Marvin” and doubled down on the allegations of “sexual
harassment” contained in the October 30 Letter.
36. Coreen Linquist called into the podcast, and joined in making additional defamatory
statements regarding Marvin regarding his conduct and other members of the coaching staff.
37. The intended, actual, and reasonable interpretation of these false statements made by
Shana Lanctot during the interview was that Marvin engaged in criminal conduct and sexually
harassed, mistreated, and/or abused members of the Warroad Girls Hockey Team.
38. The intended, actual, and reasonable interpretation of these false statements made by
Coreen Lindquist during the interview was that Marvin sexually harassed, mistreated, and/or abused
members of the Warroad Girls Hockey Team.
statements of fact.
Shana Lanctot defames Marvin on social media and invites others to do the same.
40. Shana Lanctot continued to publish defamatory statements about Marvin on social
media after her podcast interview.
41. In one Facebook post, Shana Lanctot encouraged others to watch Athlete A, a
documentary film about numerous sexual assaults by a physician connected to USA Gymnastics and
a cover-up regarding that abuse. Shana Lanctot’s Facebook post indicates that, “[t]he amount of
children that it was happening to without anyone else knowing about it reminds me of the Warroad
High School Girls Hockey program. Even the cover up feels familiar.” In the context of Shana
Lanctot’s other allegations of sexual harassment and abuse, this Facebook post further defamed
Marvin.
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42. Shana Lanctot also took to her personal page on X, the social media platform formerly
known as Twitter, to publicize her podcast appearance and again falsely accuse Marvin of misconduct
and abuse:
43. Additionally, she used the same account to comment on a post from the Minnesota
State High School League, again falsely accusing Marvin of abuse of members of the Warroad Girls
Hockey team:
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44. Warroad High School officials released a statement after the October 30 Letter was
publicized, expressing support for “Marvin and his staff” and discouraging “parents of past and
present players” form “sharing false information about the program and staff.”
45. In response to this statement, Lanctot accused Marvin of exposing himself in front of
unidentified minor players:
46. On or about October 31, 2023, Shana Lanctot created a Facebook group named “We
Hear You 56763” and reposted the October 30 Letter and her Grand Forks Best Source interview to
the group. As of November 13, 2023, the group has over 440 members.
47. The purported purpose of the group was to allow “people to share their experiences
and come together to promote positive change and to get justice for the girls who have been mistreated
in the Warroad Girls Hockey program. One abused child is one too many. #bebetterwarroad.” But
the real purpose of the Facebook group was to provide a forum for Defendants and others to defame
Marvin.
48. Shana Lanctot, her daughter, and an anonymous account named “You Matter” serve
as the administrators of the group. On information and belief, “You Matter” is controlled or
maintained by Shana Lanctot. Shana Lanctot set up and maintains the group to allow anonymous
posting. On information and belief, Shana Lanctot is the creator of all or some of the anonymous
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posts. These anonymous posts include additional false allegations of “sexual harassment” and “abuse”
by Marvin.
49. Shana Lanctot posted an unauthorized recording of a meeting between school
administrators and Defendant Lindquist to the group’s page. Shana Lanctot characterizes the
discussion as related to “sexual assault/harassment” and alleges it that it shows a lack of action on the
part of the school district against Marvin and other coaches related to “unwanted sexual advances”:
50. The intended, actual, and reasonable interpretation of these false statements is that
Marvin engaged in criminal conduct and sexually harassed, mistreated, and/or abused members of the
Warroad Girls Hockey Team.
statements of fact.
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52. Shana Lanctot was also successful in inducing others to republish her defamatory
statements and make defamatory statements through the group and elsewhere on social media.
53. For example, Kristin Coauette Johnson, republished, promoted, and advanced the
defamatory statements contained in the October 30 Letter.
54. On or about October 31, 2023, Kristin Coauette Johnson “shared” the October 30
Letter on her own personal Facebook feed, republishing and applauding the “brave parent group”
who authored the defamatory letter:
55. The intended, actual, and reasonable interpretation of Kristin Coauette Johnson’s
republication of the false statements contained in the October 30 letter was that Marvin sexually
harassed, mistreated, and/or abused members of the Warroad Girls Hockey Team.
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56. Kristin Coauette Johnson also “shared” the video recording of the Grand Forks Best
Source, republishing the defamatory statements made by Shana Lanctot and Coreen Lindquist in the
recording, and encouraging others to “listen to and share” the defamatory statements contained in the
video:
57. The intended, actual, and reasonable interpretation Kristin Coauette Johnson’s
republication of the false statements made by Shana Lanctot and Coreen Lindquist during the
interview was that Marvin engaged in criminal conduct and sexually harassed, mistreated, and/or
abused members of the Warroad Girls Hockey Team.
58. Upon information and belief, Shana Lanctot and all other Defendants have
communicated similar oral statements to third parties and other written statements and/or social
media posts regarding Marvin.
59. All Defendants refuse to stop making defamatory statements despite officials from
Warroad High School expressly telling them that they are “sharing false information.” In early
November 2023, after Defendants issued the October 30 Letter, Warroad High School issued a
statement acknowledging that “for over 10 month, a few parents of past and present players have
been sharing false information.” The school pointed out “two important facts”: first, all allegations
that had been brought forth were reviewed as part of the school’s “due diligence”; and second, after
all of that work, “the school board voted to renew coaches contracts.” Several days later, the school
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issued another statement confirming that “[t]he concerns raised by some individuals . . . have already
been addressed.” Nevertheless, Defendants persist in making and encouraging defamatory comments,
requiring Marvin to seek the Court’s assistance to stop the harm Defendants are causing and obtain
an order requiring them to compensate Marvin for the damage they have caused.
CLAIMS
COUNT ONE – DEFAMATION –

DEFENDANTS JEFF AND PATTI JOHNSON, COREEN LINDQUIST, AND
MATT AND SHANA LANCTOT
60. Marvin realleges and incorporates the above allegations as though fully restated herein.
61. Defendants Jeff and Patti Johnson, Coreen Lindquist, or Matt and Shana Lanctot
jointly drafted and published the October 30 Letter.
62. The October 30 Letter contains false statements of fact, including but not limited to,
claims that Marvin engaged in sexual harassment, hazing, or committed a crime under Minn. Stat.
§ 609.749.
63. The statements in the October 30 Letter are directed at Marvin.
64. The statements in the October 30 Letter are reasonably interpreted to be directed at
Marvin.
65. The statements in the October 30 Letter inferring or directly accusing Marvin of sexual
harassment and criminal activity are defamatory per se.
66. The statements in the October 30 Letter were made without exercising reasonable
care.
67. The statements in the October 30 Letter were made with reckless disregard of the
truth or with knowledge that they were false.
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68. The statements in the October 30 Letter published by Defendants Jeff and Patti
Johnson, Coreen Lindquist, or Matt and Shana Lanctot have harmed the reputation of Marvin in the
eyes of others.
69. As a direct and proximate cause of Defendants Jeff and Patti Johnson, Coreen
Lindquist, or Matt and Shana Lanctot’s false statements of fact in the October 30 Letter, Marvin has
been damaged in excess of $50,000.
COUNT TWO – DEFAMATION – SHANA LANCTOT & COREEN LINDQUIST
71. After publication of the October 30 Letter, Shana Lanctot and Lindquist acted on their
own and/or in concert with third parties to continue publishing false statements about Marvin.
72. Shana Lanctot’s oral statements in the interview she provided to Grand Forks Best
Source included false statements of fact regarding Marvin, including but not limited to, allegations of
abuse, mistreatment, and sexual harassment of member of the Warroad Girls Hockey team.
73. Lindquist’s oral statements in the interview she provided to Grand Forks Best Source
included false statements of fact regarding Marvin, including but not limited to, allegations of abuse,
mistreatment, and sexual harassment of member of the Warroad Girls Hockey team.
74. The statements in the Grand Forks Best Source interview inferring or directly accusing
Marvin of sexual harassment, mistreatment, and abuse are defamatory per se.
75. The statements in the Grand Forks Best Source interview were made without
exercising reasonable care.
76. The statements in the Grand Forks Best Source interview were made with reckless
disregard of the truth or with knowledge that they were false.
77. The statements in the Grand Forks Best Source interview by Lindquist and Shana
Lanctot have harmed the reputation of Marvin in the eyes of others.
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78. As a direct and proximate cause of Defendants’ false statements of fact in the Grand
Forks Best Source interview, Marvin has been damaged in excess of $50,000.
COUNT THREE – DEFAMATION – SHANA LANCTOT
80. Shana Lanctot expanded the scope of the defamatory statements contained in the
October 30 Letter and the Grand Forks Best Source interview to include false allegations of sexual
harassment, abuse, and sexual abuse against Marvin.
81. Shana Lanctot’s social media posts, as detailed above, included false statements of fact
regarding Marvin, including but not limited to, allegations of abuse, mistreatment, and sexual
harassment of member of the Warroad Girls Hockey team.
82. The statements in the social media posts inferring or directly accusing Marvin of sexual
harassment, mistreatment, and abuse are defamatory per se.
83. The statements in the social media posts were made without exercising reasonable
care.
84. The statements in the social media posts were made with reckless disregard of the
truth or with knowledge that they were false.
85. The statements in the social media posts Shana Lanctot have harmed the reputation
of Marvin in the eyes of others.
86. As a direct and proximate cause of the false statements made by Shana Lanctot in her
social media posts, Marvin has been damaged in excess of $50,000.
COUNT FOUR – DEFAMATION – KRISTIN COAUETTE JOHNSON
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88. Kristin Coauette Johnson republished the defamatory statements contained in the
October 30 Letter and the Grand Forks Best Source interview, false allegations of sexual harassment,
abuse, and sexual abuse against Marvin via social media.
89. Kristin Coauette Johnson made direct statements, including but not limited to the
social media posts detailed above, inferring or directly accusing Marvin of sexual harassment,
mistreatment, and abuse.
90. Kristin Coauette Johnson’s social media posts, as detailed above, included false
statements of fact regarding Marvin, including but not limited to, allegations of abuse, mistreatment,
and sexual harassment of member of the Warroad Girls Hockey team.
91. Kristin Coauette Johnson republished these statements despite the fact that she knew,
or had reason to know, that the material was false and defamatory.
92. Kristin Coauette Johnson’s statements and her republication of the October 30 Letter
and Grand Forks Best Source interview that inferred or directly accused Marvin of sexual harassment,
mistreatment, and abuse are defamatory per se.
93. Kristin Coauette Johnson’s statements in the social media posts were made without
exercising reasonable care.
94. Kristin Coauette Johnson’s republication of the October 30 Letter and Grand Forks
Best Source interview was made without exercising reasonable care.
and Grand Forks Best Source interview were made with reckless disregard of the truth or with
knowledge that they were false.
and Grand Forks Best Source interview have harmed the reputation of Marvin in the eyes of others.
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97. As a direct and proximate cause of the false statements made by Shana Lanctot in her
social media posts, Marvin has been damaged in excess of $50,000.
COUNT FIVE – INJUNCTIVE RELIEF – ALL DEFENDANTS
99. Defendants’ defamatory statements have caused Marvin irreparable harm for which
there is no adequate remedy at law.
100. Defendants’ conduct and continued defamatory activity demonstrate that Marvin will
continue to suffer irreparable harm during the pendency of this lawsuit.
101. An injunction is necessary to prevent further irreparable harm to Marvin pending a
final determination by the Court on the merits of these claims.
102. Absent relief, Defendants will continue engaging in defamatory conduct towards
Marvin, impairing Marvin’s ability to obtain, and the Court’s ability to order, effective relief.
103. Marvin seeks an injunction pursuant to Minn. R. Civ. P. 65, enjoining Defendants
from making further defamatory statements involving sexual harassment, mistreatment, or abuse of
Warroad Girls Hockey players.
PRAYER FOR RELIEF
WHEREFORE, Marvin requests the following relief:
1. Judgment in its favor in an amount in excess of $50,000, plus applicable interests and
costs.
2. An injunction, enjoining Defendants from making further defamatory statements
involving sexual harassment, mistreatment, or abuse of Warroad Girls Hockey players.
3. For such other and further relief as the Court deems just, equitable, or proper.
JURY DEMAND
Plaintiff demands a trial by jury on all claims and defenses so triable.
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Date: I \ -
l5 2°13

LARSON KING, LLP
-
By
0M2
David M. Wilk (222860)
Mark A. Solheirn (213226)
Patrick H. O'Neill, III (0399111)
2800 Wells Fargo Place
30 E. Seventh Street
St. Paul, MN 55101
Tel: (651) 3126500
Fax: (651) 3126618
[email protected]
[email protected]
[email protected]
Attorneys for Plaintiff
ACKNOWLEDGMENT
The undersigned hereby acknowledges that sanctions may be imposed under Minnesota
Statute Section 549.211.
David M. Wilk
48826228-3408
l7
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EXHIBIT A
COMPLAINT
JURY TRIAL DEMANDED
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Marvin Defamation Lawsuit

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Marvin Defamation Lawsuit

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68-CV-23-682

Filed in District Court

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF ROSEAU NINTH JUDICIAL DISTRICT

David Marvin, Court File No.:

Shana Lanctot; Matt Lanctot; Jeff Johnson; Patti

THIS SUMMONS IS DIRECTED TO THE ABOVE-NAMED DEFENDANTS:

file number on this Summons.

to fill out the Answer form.

you must say that in your Answer.

asked for in the Complaint.

Summons in person or by mail at this address:

LARSON • KING, LLP

have an attorney and would like legal help:

7. Alternative Dispute Resolution (ADR). The parties agree to or be ordered to

serve your written Answer, even if you expect to use ADR.

Date: LARSON KING, LLP

Attorneys for Plaintiff

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF ROSEAU NINTH JUDICIAL DISTRICT

David Marvin, Court File No.:

“Defendants”) states and alleges as follows:

NATURE OF THE ACTION

team to back-to-back state championships in 2022 and 2023.

invited and encouraged others to do the same.

already done to his reputation by Defendants’ untrue allegations.

continued to play hockey after high school.

Warroad, Minnesota and is a parent of former Warroad Girls Hockey players.

Warroad, Minnesota and is a parent of former Warroad Girls Hockey players.

Girls Hockey player.

Girls Hockey player.

13. Coreen Lindquist is a resident of Warroad, Minnesota and a parent of a former

Warroad Girls Hockey player.

14. Kristin Coauette Johnson is a former resident of Warroad currently residing in

Arizona, and a parent of a former Warroad Girls Hockey player.

JURISDICTION AND VENUE

Johnson, Jeff Johnson, Shana Lanctot, and Matt Lanctot.

Minnesota, as detailed below, have caused injury to Marvin in Minnesota.

within this judicial district.

hired Marvin as a coach for the 2023-2024 season.

The October 30 Letter

Hockey team. The October 30 Letter is attached to the Complaint as Exhibit A.

Hockey Team, and violated Minn. Stat. § 609.749.

as so many before them in the girls hockey program.”

regarding these allegations.

Live and makers of the podcast “Grand Forks Best Source.”

baseless allegations contained in the October 30 Letter.

harassment” contained in the October 30 Letter.

members of the Warroad Girls Hockey Team.

media after her podcast interview.

unidentified minor players:

49. Shana Lanctot posted an unauthorized recording of a meeting between school

Warroad Girls Hockey Team.

defamatory statements contained in the October 30 Letter.

who authored the defamatory letter:

abused members of the Warroad Girls Hockey Team.

media posts regarding Marvin.

COUNT ONE – DEFAMATION –

jointly drafted and published the October 30 Letter.

63. The statements in the October 30 Letter are directed at Marvin.

harassment and criminal activity are defamatory per se.

truth or with knowledge that they were false.

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