The Volokh Conspiracy
Mostly law professors | Sometimes contrarian | Often libertarian | Always independent
Pre-Judgment Attachment in Libel Cases
An interesting remedy that I've seen a few cases; here is the most recent one, Hussain v. Quraishi, decided May 20 by Judge Matthew T. Wax-Krell (Conn. Super. Ct. Tolland Jud. Dist.) (plaintiffs Hussain and Garcia are the owner and practice manager of plaintiff VCare Family Practice LLC, which owns the medical office Shifa Clinic):
… Quraishi worked as an independent contractor at the Clinic doing IT work. In 2017, the plaintiffs began having issues with Quraishi, which ultimately led to Hussain applying for a civil protection order against Quraishi, which the Court granted on October 12, 2018.
After that, Quraishi stopped harassing the plaintiffs, but in July of 2025, for reasons unknown to the plaintiffs, Quraishi began posting on Facebook repeatedly about them.
In the Facebook posts, he accused them of various crimes and fraudulent actions, including, among other claims, fraud and identity theft, Medicare and Medicaid fraud, and using a deceased doctor as their medical director.
As a result, on July 7, 2025, Hussain applied for a civil protection order against Quraishi, which the Court granted on July 21, 2025. On that same date, Garcia applied for a restraining order against Quraishi (they had briefly dated in 2015), which the Court granted on July 16, Quraishi was ultimately arrested for violating the restraining order.
Despite the entry of the civil protection order and the restraining order, Quraishi continued posting about the plaintiffs throughout July of 2025 and then from November of 2025 through April of 2026. These posts included more allegations of perjury, witchcraft, identify theft, Medicare and Medicaid fraud, theft of intellectual property, counterfeiting of documents, filing false statements to the police and the courts, and fraudulent billing.
The plaintiffs deny all of the allegations made by the plaintiff [presumably intended to say "defendant" -EV] in his Facebook posts….
For purposes of obtaining a prejudgment remedy, the plaintiffs do not have to establish that they will prevail, only that there is probable cause to sustain the validity of their claims. Under this standard, the court concludes on the evidence presented that there is probable cause to sustain the validity of the plaintiffs' claim against the defendant.
Quraishi's Facebook posts contain serious allegations against the plaintiffs, particularly given their professional roles in operating a primary care clinic. He accuses them of fraudulent billing, Medicare and Medicaid fraud, and countless other fraudulent actions. Quraishi's Facebook posts are detailed extensively in the plaintiffs' exhibits.
In addition to the allegations against the plaintiffs, many of Quraishi's Facebook posts contain inflammatory, threatening language directed at the plaintiffs. For example, Quraishi wrote on Facebook "Hussain, I'm not just coming for you … I'm going after your family line. And my not yet born children will continue if they must … In this situation I'm like Liam Neeson's character from the movie Taken … 'I have a very special set of skills.'" In another post regarding Hussain and Garcia, Quraishi wrote, "I would've gone full Liam Neeson on you[ ] … I'll let the 5 US Federal Agencies handle you and your whole coven."
In another of his Facebook posts, he wrote that Hussain "is a high level criminal in a medical masonic mafia and he should be placed into either (1) the original Alcatraz prison in San Francisco; (2) the new alligator Alcatraz in Florida." In another Facebook post, Quraishi wrote "the whole world is going to watch you … burn in the hottest inferno hell has provisioned." In yet another Facebook post, Quraishi wrote "a gay male nurse and smelly jew bribed a little piggie." In another Facebook post, Quraishi accuses the plaintiffs, as well as three Judges of the Rockville Superior Court of "racketeering."
Garcia testified that Quraishi has 822 followers on Facebook, and that his posts may have been seen by more people if any of his followers shared his posts with others.
Garcia also testified that Quraishi's Facebook posts have affected her and the Clinic. She testified that the staff is scared, and that she has to review Facebook to see Quraishi's state of mind before she goes to work. She testified that they are particularly vigilant at the Clinic, where they have cameras "all over," and the staff is monitoring who comes in. She testified that she has worked very hard to get where she is, and that it is upsetting to be accused of what Quraishi has accused her of in his Facebook posts. She believes that the posts have harmed her personal and professional reputation. Patients and family members have called the Clinic to ask if they have seen what Quraishi is posting about them….
The court concluded there was probable cause that plaintiffs will prevail on their claims for defamation, intentional infliction of emotional distress, negligent infliction of emotional distress, and false light invasion of privacy, and, therefore granted a prejudgment remedy:
Based on the defendant's Facebook posts, there is probable cause that a judgment in the amount of the prejudgment remedy sought, or in an amount greater than the amount of the prejudgment remedy sought, taking into account any defenses, counterclaims or set-offs, will be rendered in the matter in favor of the plaintiffs….
The plaintiffs shall be authorized to attach and/or garnish any or all of the following to the amount of $300,000.00.
- To attach the defendant Mansoor Quraishi's interest in 2 Davenport Road, West Hartford, Connecticut; and
- To attach and/or garnish such other assets, property or obligations held by or on behalf of the defendant Mansoor Quraishi as may be identified by defendant's disclosure pursuant to the plaintiffs' motion for disclosure of assets….
