This is the lawsuit where El Dragon is bringing criminal charges of criminal defamation, and criminal threats against 6 parents who spoke about the school sharing their experiences on medium, facebook and even private messages.
PDF of original filing is on botom of the page
The entire document is attached at bottom (in Spanish)
Here is the Translated text:Three Parts:
Part 1 Charges against the defendants
Part 2 Allegations.
Part 3 Demands
Patricia de Rosa Hernández, lawyer of the Bar Association of Madrid, with number 76,468, in the name and on behalf of the Association EL DRAGON GROWING IN FREEDOM, as evidenced by the copy of the power of attorney that is attached as Document Number One , before the Court I appear and as best proceeds in Law, I SAY:
That in accordance with what is established in article 804 of the LECrim, in relation to articles 139 and following of Law 15/2015, of July 2, Voluntary Jurisdiction, by means of the present writing I come to request celebration before the Lawyer of the Administration of Justice of csc Court of ACT OF CONCILIATION PRIOR TO THE INTERPOSITION OF QU ERELLA FOR ALLEGED CRIME OF SERIOUS INJURIES of articles 208 and 211 of the Criminal Code against DON PEDRO ABELLA LANGA, of legal age, with DNI number XXXXXX and address in XXXXXXXXXXXXXXXXXXXXXXXX, DONA EVA CABALLERO FERNANDEZ, of legal age, with ID number XXXXXXX and address in xxxxxxxxxxxxxxxxxxxxx, DONA MYRIAN XXXXXXXX, of legal age, with DNI, number xxxxxxxxxx and address in xxxxxxxxxxxxxxxxx, and DONA ORQUIDEA ALARCÓN JULIA, of legal age, with DNI number xxxxxxxx and address in xxxxxxxxxxxxxxxxxxxxxxx, AND FOR ALLEGED CRIME OF SERIOUS INJURIES of articles 208 and 211 of the Penal Code and FOR ALLEGED CRIME OF THREATS of article 171 of the same legal text against & DON VLADIMIR TEICHBERG, of legal age, with NIE number xxxxxxxxxxxxx and address in xxxxxxxxxxxxxxxxxxxxxxxx and DONA MARIA DIAZ RUIZ, m ayor of age, with DNI number xxxxxxxxx and address at San Lorenzo de El Escorial Timoteo Padros street number 31, 3rd right; in order that they agree to recognize the ends that are listed below, and based on the following:
FIRST. My principal owns the El Dragón International School School, located in Torrelodones, Monterrey street number 6, where the defendants’ children have been studying their education.
On April 4, 2018, the defendants carry out various actions against the Educational Center consisting of publishing through instant messaging (whatsapp) and on social Internet sites and comments, comments and insulting expressions that undermine the prestige and honor of the School:
D “EVA CABALLERO FERNANDEZ, makes use of the whatsapp group that the Center shares with families, and this goes against the norms of its use perfectly known by her, to disapprove The professionals of the Center, for not having acted according to the particular criteria that they considered appropriate in an incident that occurred on the school bus, and with the sole purpose of discrediting the Educational Center and its professionals before the rest of the families. , which is accompanied as Document Number Two, the defendant imputes to the Center and its Director the commission of acts of pride, humiliation and threats, manipulation of to students and families, repression and aggressive forms against parents, and even bullying and hiding cases of sexual abuse.
D. VLADIMIR TEICHBERG, couple of D. “Eva Caballero, published in the blog MEDIUM a writing entitled Adventures in the” Democratic “School The Dragon Chapter I. How the director of the educational center of my heroes came to do 3 Greetings Nazis in the middle of a reunion of parents and teachers on bullying and sexual harassment in potencla, whose copy is accompanied as Document Number Three, which attacks and attacks the Center (adducing it is a dictatorship or sect, tolerant to harassment and with “stories of Stalinist purges of teachers”), against the professionals who work in it (through expressions such as “ethically impeded personnel”, incompetent and “vengeful character of this administration”) and, especially, against the Director, D Bárbara Serrano, whom he describes as a dictator, liar, defamatory and corrupt, and whom he accuses of showing signs of anti-Semitism and the use of symbols of genocide and hatred, to conclude with a clear appeal to families that are part of the school in order to put them against the school, encouraging them to carry out conducts aimed at creating a confrontation with the Center (“For the families that are still in El Dragón, for the sake of your children, read carefully what I said. You may not like my style, but you should consider how safe your children are in this institution. Ask the administration questions and refuse to pay the fees until you answer them, demand to see the school accounts to see how much they are actually spending on our children’s education and how much is the profit margin. Ask how many children have been expelled because their parents asked questions during the past 5 years, how many teachers were fired for showing their concerns, how many people have threatened to sue to keep this fraud a secret “), and encouraging against those other families that may be interested in being part of it (“For those of you who are considering The Dragon for your children, consider yourself warned.) Barbara and Juan have built a democratic school that will make Franco proud.”)
And all for the sole purpose of promoting a defamatory campaign against the Center and with a more than evident desire to publicly disseminate and publicize its partisan disqualifications (“I intend to work with other affected families to help them tell their story to the whole world about the reality of this project“), which are based on disqualifying the educational system that is taught in it and impute to your teaching and administrative personnel facts of such gravity and falsehood that they go beyond being mere judgments of value of their particular experience in the Center, to become clear criminal behaviors whose only intention is to discredit the fame and prestige that precedes it, to the point of getting his disappearance as an Educational Center.
Likewise, in its spirit of giving the greatest coverage and dissemination, it extends its attacks on other social networks such as FACEBOOK, as verified by Document Number Four, or in the directory of alternative pedagogies LUDUS, as can be seen in Document number Five that is accompanied to this writing, which threatens to spread their false accusations of tolerating harassment and retaliation against students, and their insults to the Director and their non-existent gestures of Nazi Salute, in the Association of Schools and New England Colleges (NEASC), which is the American agency under which The Dragon International School has obtained its accreditation as an international school, as verified in the commentary published in the aforementioned directory and which is accompanied as Document Number Six .
That, in the same way, the defendant participates and has contributed to the dissemination of the publications made by two other defendants, Mr. Pedro Abella Langa y Do. Myriam Varela, in the social networks of FACOBOOK AND MEDIUM. Accompanying, as Document number Seven, the publication, dated April 5, in its public FACEBOOK profile of the story that Mr. Pedro Abella Langa publishes against the Center in the MEDIUM social network, and, as Document number Eight, the publications , of dates 5 and 6 of April, in his profile of FACEBOOK of the testimonies that D. Myriam Varela in turn publishes in that same social network.
DA, MYRIAN XXXXXXXX, on April 4, 5 and 6, publishes various insulting and insulting comments against the Educational Center and its management team in its own profile of the social network platform FACEBOOK, which, far from being simple value judgments or mere disqualifications of their experience in the Center, constitute an attack against the reputation and prestige of the Center and its professionals, who are accused of committing a crime of harassment against another family, granting such comments the maximum advertising by disseminating them, spreading them and sharing them with other users of that social network. It is accompanied as Document number Twelve, copy of the publications made by the one reported in your FACEBOOK profile.
Likewise, the defendant has participated, and has contributed to the dissemination of the publications made by the defendants, Mr. Vlad Teichberg and Mr. Pedro Abclla Langa, on the social networks of FACOBOOK AND MEDIUM. Accompanying, as Document number Thirteen, the publication, dated April 5, in your public FACEBOOK profile of the story that Mr. Vlad Teichberg publishes against the Center in the MEDIUM social network, and, as Document number Fourteen, the publication, dated April 6, in his FACEBOOK profile of the story that Mr. Pedro Abella Langa publishes against the Center in the MEDIUM social network.
D. PEDRO ABELLA LANGA, publishes a message in the whatsapp group that the Center shares with the families, whose copy is accompanied as Document Number Nyeve, and this against the norms of its use perfectly known by clla, to attack the decisions adopted by the Center through defamation against the good name, fame and honor of its Director, and the disclosure of false facts, disqualifications and insults to his person, and this with the sole purpose of discrediting the Center and its management team , and create and provoke in the other families a confrontation with him and a distrust of the Center itself.
Likewise, and with the same disseminating purpose, but with a clear objective of reaching a greater number of people, both knowledgeable and involved in the Center and unaware of it, publishes in its “blog” of MEDIUM the first installment of the history in which a democratic school silences parents who disagree with issues relating to the school, its management and operation, whose copy is attached as Document number Ten, which shows its particular version of the events described above, with the sole purpose of discrediting the Center and cause the greatest damage to the reputation that precedes it.
Finally, on May 3, 2018, the defendant, Mr. Abella, extends such expressions and comments against the School Center before the Association of Schools and Colleges of New England (NEASC), which is the American agency under which The Dragon International School has
obtained its accreditation as an international school, as verified in the e-mail sent that is accompanied as Document number 11
D “. ORQUIDEA ALARCÓN JULLA, through whatsapp instant messaging, circulates a message, which is accompanied as Document number Fifteen, under which encourages a negative evaluation of the Center on the Google website, detailing the process for it. Thus, it indicates: “Put The Free School Dragon in the google search”, (adding the explanatory image), to continue indicating * You get this. You give reviews and you get the stars. Put a ‘, ending with the words “Well, run like the pólvord’. Message that presupposing is makingreach all your contacts WhatsApp, among which must be the teacher DCL School Center for QUC also was sent.
As a result of this, the Educational Center has received numerous negative reviews from people who do not have any relationship or real connection with the Center because they are not or have not been families whose children have completed their education there, which we accompany as Document Number Sixteen. , among whom are relatives and friends of the defendant, as is the case of his brother, D. Victor Alarcón Juliá, who refers to the Center in terms of “The closest thing to a sect * cn the Google website, which it is accompanied as Document number Diccisiçte. or “A creepy board of directors, this school is the closest thing to a sect” in the directory of Pedagogies Alternativas LUDUS, which is accompanied as Document number Eighteen,
and even to involve people who previously maintained an excellent relationship and opinion of the Center, but that due to their friendship relationship with the researched one they now join the campaign orchestrated by her to discredit and harass the Center in social networks, this is the case of Do. Ana Pérez Hinojosa, who, after leaving the Center Educational for economic reasons, send whatsapp to the Director of the same, which is accompanied as Document number nineteen, the letter written by his daughter and directed to The Dragon, which manifests, as does the mother in the message, how she misses the Center, while a short time later, on the occasion of the message that the researcher has disseminated and the friendly relationship with her, the defendant and her husband, D. X avi Beltrán (former teacher of the center), lash out at the same center they were previously addressed with flattery, in their comments and negative reviews on Google, as evidenced by Document Number Twenty.
Likewise, the defendant is disseminating by the same means of instant messaging another personal message against the Center, which is accompanied as Document number Twenty-one, based on false accusations of personal abuse by one of the co-founders of the Center (ex-husband and father of his children). , of manipulation towards the teaching staff of the Center (to whom it refers with “companions”) and of instrumentalization of the students, and all this for the benefit of personal interest, in the message, and that its author, supposed friend of D ” . Orquidea, writes at the request of the latter (“I write this email at your request …”), is intended to publicize your false accusations against your ex-husband and father of your children, co-founder of the Educational Center (* transmit a case of abuse Towards a friend named Orquidea, through her daughters, she is the mother of Clara and Angel, two pekes of about 10 years, who go to El Dragón International School in Torrelodones, Juan Morán, co-owner of her former husband and father of his children. “), which includes the Educational Center itself (” As for the school, the co-owners have used all the companions against them and have even instrumentalized the creatures that come to this center by putting them in this subject of Adults.”); and all with the sole purpose of spreading their campaign to discredit and defame the Center (“I write this email by request wanting it to be disseminated as much as possible by uncovering what lies behind this school that is presented as respectful of the pekes.)
D. MARÍA DIAZ RUIZ, publishes in the directory of alternative pedagogies LUDUS, under the nickname Arima Azdi, which are accompanied as Document number Twenty-two, and on the GOOGLE page an insulting review, which is accompanied as Documentnumber Twenty-three (“Finally is discovering the fraud of this organization with MUCH profit motive. “), with the clear threat on the continuation of the School Center (” It escapes to all logic that continue working but soon they will stop doing it, fortunately !! “), and this with the sole purpose of causing the closure of the Educational Center, an objective that has already been attempted by the defendant and her partner when, in March 2017, they terminate their son in the Cent ro, demand the payment of the fees paid while their son was studying their education in it, under the threat of denouncing the Center in the Educational Inspection (threatsthat were carried out at that time) and flooding the opinion forums (threat that they meet today).
That from the date on which the injurious comments were published up to the present, they have been able to be visualized by a large number of users of the aforementioned pages and social networks, which affects in a detrimental way the prestige and reputation of the Educational Center and of the professionals that compose it, causing serious moral damages toprofessionals, especially the Director, who, due to these facts, is on medical leave, and significant patrimonial damages with the economic losses caused by the drop of three students as a result of these facts, as well as the lost profits to be forced to beremoved from the directory of LUDUS with the publicity that this meant for families interested in enrolling in him their children.
That, as a consequence of all the above, by means of this ballot the defendants are required in this conciliation, so that:
1- They agree to recognize all the extremes that have been mentioned and their lack of truthfulness
2- They are required expressly and formally in this act so that in the non-extendable term of FIVE days, counted as of this act ofconciliation, indemnify my client for the moral damages and the damages caused in the honor and prestige of the EducationalCenter and the professionals who work in it, as a consequence of the behavior of the defendants, referred to in the previousevents in the following amounts:
– – –
D4, EVA CABALLERO FERNÁNDEZ, in the amount of 20,000 euros.
D. VLADIMIR TEICHBERG, in the amount of 150,000 euros.
D.PEDRO ABELLA LANGA, in the amount of 80,000 euros.
D, MYRIAN XXXXXXXX, in the amount of 60,000 euros.
D.ORQUIDEA ALARCÓN JULIA, in the amount of 150,000 euros.
Do. MARÍA DIAZ RUIZ, in the amount of 60,000 euros.
Also requesting the payment of the costs of the prescnt act of conciliation that are set at the amount of 600 euros.
3.- That in the case of non-recognition of each and every one of the ends of this letter, and / or not proceed to compensate my client in the sums indicated within the aforementioned period, will be filed against the defendants of conciliation complaint criminal for the crime of serious insults and threats.
4.- That the defendants immediately withdraw the vexatious and insulting comments against the Educational Center and the professionals who work there published on the Google and LUDUS websites, on the Facebook social network and on the blog of MEDIUM.
This previous Conciliation Act is formulated as a requirement required by Article 804 LECrim, given that the events reported could be constitutive of a crime of serious injuries of articles 208 and 211 of the Penal Code allegedly committed by D. Pedro Abella Langa, D. Eva Caballero Fernández, D “. Myrian XXXXXXXX and D “Alarcón Juliá Orchid and of a crime of serious insults of articles 208 and 211 of the Penal Code and a crime of threats of article 171 of the same legal text allegedly committed by D. Vladimir Teichberg and D”. Maria Diaz Ruiz, and prior to the filing of the relevant criminal complaint, which will urge the imposition of the corresponding penalty and will be interested that the defendants compensate in the sums claimed for the damages suffered by my client as a consequence of such behavior.