NOTE: This piece first appeared on FLGulfNews.com.
By Richard Luthmann
The Complaint No One Can Defend
Danesh Noshirvan, the notorious TikTok agitator and self-described “justice warrior,” has filed a Third Amended Complaint (TAC) in the Fort Myers federal court that has lawyers and legal observers gasping. With help from his increasingly erratic attorney, Nicholas “Chia Pet” Chiappetta, the new filing reads less like a lawsuit and more like a deranged digital ransom note.
Instead of clarifying facts, the TAC fuels a fire of conspiracies. It names Fort Myers businesswoman and socialite Jennifer Couture and world-renowned plastic surgeon Dr. Ralph Garramone, her husband, as masterminds behind an imaginary cyberattack plot, then falsely links them to “white supremacists,” Proud Boys, and rogue paralegals.
“This isn’t a complaint. It’s a slander manifesto,” said one attorney familiar with the case. “Paragraph after paragraph reads like Antifa ghostwrote it on an acid trip.”
And what’s the court doing about it? Not much.
Judges John Steele and Kyle Dudek have allowed the suit to fester through three prior iterations of a wayward legal complaint.
Now, with this fourth installment, observers are asking: How much longer will the federal bench indulge this courtroom cosplay?
Delusional Danesh Sinking Fast: Salacious Lies and Smeared Reputations
The TAC is bloated with defamatory trash. Channeling Cruella Deville and Leona Helmsley, paragraph 42 accuses Couture of thinking people are “beneath her.”
Delusional Danesh’s “bullshit artistry” isn’t done there. Paragraph 55 labels her “mentally unstable.” Projection anyone?
Danesh has advocated for outlandish measures, palpably including the dissolving of his young son’s penis, in the name of “Woke gender transition.”
Paragraphs 46 through 50 accuse her of a “violent crime,” despite video evidence showing what an eight-year-old would find as otherwise.
Danesh’s favorite punching bag, Joey Camp, isn’t even a defendant, yet he has been mentioned 490 times.
Chiappetta weaves a fantasy that Couture and Garramone “directed” Camp in some elaborate plot. Deposition transcripts reveal that the reason they met and engaged him was for Internet reputation defense, due to Danesh’s protracted campaign of defamation, slander, and digital extortion.
“It’s amazing how an ambulance chaser like Nick Chiappetta can twist hiring someone to take false and harmful information off of Google into a QAnon-fueled blood pact,” said one Southwest Florida lawyer. “
Delusional Danesh wades into a Mariana Trench of Malarkey. Paragraph 43 implies that Garramone’s marriage to Couture is “transactional.” Paragraphs 82–86 further attempt to link them to hate groups without a scintilla of proof.
“It’s character assassination dressed in Times New Roman,” said another litigator. “It’s malicious, false, and calculated. [Chiappetta] should be ashamed.”
Noshirvan, who claims credit for getting people fired, arrested, or doxxed, now plays the “victim.”
Yet text messages, videos, and sworn testimony reveal a darker truth: Danesh and a teenage follower targeted Couture’s 13-year-old daughter and called her office 18 times in one day.
The girl? Ellie Botyos—a known agitator, Danesh proudly weaponized in his online army.
Delusional Danesh Sinking Fast: Legal Malpractice or Legal Suicide?
Nicholas Chiappetta has now filed four complaints, each more disconnected than the last. He’s still falsely calling Camp a paid agent, even after discovery proved otherwise.
He ignores sworn testimony. He labels actual, commercially produced OnlyFans adult content as “simulated” and omits facts that undermine his narrative. Like the fact that at depositions, his wife, Hannah Butcher Noshirvan, admitted to “sucking [her] husband’s d— on camera.”
“Chiappetta isn’t litigating. He’s laundering lies,” said a source close to the defense.
Worse, Chiappetta uses an email nearly identical to one from a former opposing counsel, Patrick Trainor, creating confusion.
Those charitable to “Nick the Nick” call it “borderline fraud.” In reality, the “Bunko Barrister” is engaged in serious misconduct that smacks of criminal impersonation and aggravated identity theft.
Chiappetta admitted the fraud. Per filed court documents, he admitted to Trainor that he “…made a Yahoo.com email account in 2023 utilizing the email address ptesq1@yahoo.com. After the account was made, I never used the account. See below…Childish perhaps in retrospect. But definitely nothing nefarious as you falsely allege.”
Right.
Yet, the federal court has yet to reprimand him or even acknowledge the concerns of criminal impersonation.
Much like Delusional Danesh’s Doxxing, the court’s silence on Nick the Nick’s Nefarious Nudnikery seems to mean that it is open season. Doxxing, disinformation, and impersonation – there is apparently a “license” to engage in all these activities in connection with federal court litigation in the Middle District of Florida.
A defense source pulls no punches: “This is not zealous representation. It is strategic malice, and it should be sanctioned.”
Legal experts agree that the TAC fails to meet even the basic pleading standards established under Twombly and Iqbal. It lacks particularity. It’s loaded with vague generalizations, irrelevant conspiracy theories, and defamatory guilt-by-association tactics that Judge Steele warned off when he dismissed the prior operative pleading.
Rule 12(b)(6)? Almost a formality.
Delusional Danesh Sinking Fast: The SCOTUS Doxxer’s Antics
So far, the Middle District of Florida has stood by. No injunction or sanctions. No gag orders. Not even a strong admonition from the bench.
Just a green light to continue the charade.
That silence has a cost. Garramone and Couture now live under threat. They’ve hired private security. Their child has been harassed. And the court’s inaction has allowed a known doxxer to parade his delusions in federal court.
In the wake of the leaked draft of the Supreme Court’s Dobbs v. Jackson decision in May 2022, Danesh Noshirvan led a targeted doxxing campaign against conservative Justices.
He published the home addresses of Justices Alito, Thomas, Barrett, Gorsuch, and Kavanaugh across multiple social media platforms, encouraging protestors to “make noise” outside their residences.
The posts, amplified by his large online following, contributed to coordinated demonstrations and escalated security concerns.
Chief Justice John Roberts later cited such incidents in his 2024 Year-End Report on the Federal Judiciary, warning of the grave dangers posed by online doxxing and intimidation of judges.
Have the courts failed? It’s a question that we must ask. In the apparent vacuum of leadership, Noshirvan has only escalated his attacks.
In April, Duane Morris LLP and its partner, civil-rights lawyer Julian Jackson‑Fannin, received chilling death threats tied directly to Danesh Noshirvan’s online campaign. Fannin, a Black attorney and Vice President of the Wilkie D. Ferguson Jr. Bar Association, and his Miami office were branded “racist” by Noshirvan via social media and mass emails. They were pilloried with peril.
The threats extended to Fannin’s elderly mother in Georgia, reportedly inspiring harassing phone calls and menacing messages to her home.
Duane Morris lodged an emergency hearing request on April 23, citing the violence that erupted in response to Noshirvan’s allegations. Judge Steele delayed action for a month, allowing Noshirvan’s campaign of lies and threats of violence to continue without hindrance.
Months later, there is neither a legal decision nor accountability for Danesh’s violent federal court antics.
Judges Steele and Dudek: Time to Act
They’re not exaggerating. Danesh bragged about getting others “taken down,” including Aaron De La Torre, a Texas coach who later took his own life.
Judges Steele and Dudek now face a reckoning: Will they continue to let this court become a full-blown three-ring circus—or will they finally slam the gavel on this malicious lawfare?
What makes this all the more perplexing is that these are some of the best judges in the country, in an era where, according to the American Bar Association, confidence in the federal judiciary is at an all-time low.
Nominated by President Bill Clinton, Judge Steele has been a respected jurist for over three decades, steady and fair.
President Trump just nominated Judge Dudek, a graduate of the Antonin Scalia School of Law, for a full Article III appointment. If anyone does not suffer fools or political hacks, it’s President Trump.
In any event, the defense must be ready. Serve a Rule 11 sanctions letter. Lock and load motions to dismiss, to strike, for sanctions, and more definite statements. Pillory Delusional Danesh and the dishonest Chia Pet with a counterclaim if those don’t work. Scorch the earth to root out “cancel culture court.”
It’s the least anyone who’s taken an oath to defend the federal courts can do.
“This [TAC] isn’t just defective—it’s delusional,” said one source. “If this survives, it’s open season in the courts.”
By continuing to entertain Noshirvan, the court has effectively invited a “License to Doxx and Defame,” and no one is safe. The next hearing could be the final act—or the beginning of a judicial disgrace.
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