Professional Documents
Culture Documents
Charles C. Johnson
LE
9*
DEC 09
2015
32'
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CHARLES C. JOHNSON,
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And
GREG HOWARD, in his individual
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Hold Service: Gawker Media
114 5th Ave:
New York, NY
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Defendants.
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1..
president and owner of Got News, LLC, a media company which owns
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3.
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-and
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4.
New York.
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6.
mummpII
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belief.
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10.
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12.
December of 2014.
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1
and commentary.
15.
17.
ll
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l3
14
15
l6
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18.
18
19
Blew Up
in Its
Face, published
20
http://wwwmotherjones.com/media/2015/07/gawker-conde-nastfallout
by Mother Jones on July 24, 2015.
21
timeline-denton.
22
Stories
23
24
you-lovedthisyearhulkhogans-mesmerizingsex-tape.
25
26
27
(http://deadspin.com/why-yourcardinalssuck-1443513646
28
16,
2015 (http://deadspin.com/eatshitcardinals1711726377
last
Seems To Be
Ley, Everyone Involved In The Cardinals Hacking Scandal
An Idiot,
(http://deadspin.com/everyone
Tom
19.
20.
OKOOONmU'IvhUJNl-l
21.
Similarly,
%kbumnmmmmmwe%kmmkmmsEmwnmmmmwmawmkmpmgs
its
not meant to be
a reporter's notebook."
22.
NNNNNNNNNHIHliiiHiil
FBI Investigates
the
St.
Louis Cardinals For Hacking the Astros, June 16, 2015 (http://deadspin.corn/report-)i-
oouowmpHouomqmmpiI
is
last
This ad clearly
which knows
2
is
marketing to
Plaintiffs
is
2015 (http://deadspin.com/moronusa
5,
4,
when he visited
is
an ad on the page
from
St.
Louis, Missouri.
http://www.theguardian.com/technology/2008/mar/09/gawker
(last
accessed Oct.
9.
2015).
23.
24.
CD\IO\U1J>UJNH
10
ll
12
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15
interesting than
in
much more
Denton: Well, used to think it had to do with legai reasons and people being too fearful of libel. But actually,
now think the larger factor is a journalist's desire for respectability - not wanting to expose themselves, not
i
wanting to say, "Hey we've heard this, were not completely sure whether its true." People are talking about
this. Werejust going to share with you as we would share with our colleagues what we have.
16
lot of
l8
19
Dentonlhat
l7
That
is stiil
important to
it
it
is
more of the tips to be published, Maybe not published under Johns name but published
under a tipsters name or under a tipster's anonymous handle. would like them to be published.
20
21
25.
22
23
right.
regardless of whether or
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25
Excerpt from, Jay Rayner, The Brit Dishing The Dirt
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27
http://www.theguardian.com/technology/2008/mar/09/gawker
28
(last
accessed Oct.
9.
2015).
526548
last
accessed October
8,
2015).
in other
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ll
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l3
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time."4
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28.
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29.
James
Silver,
Gawk, Don t Talk - Interview With Nick Denton, The Guardian, Monday 11 December 2006
(http://www.theguardian.com/technology/2006/dec/1 1/news.mondaymediasection
last
accessed October
9,
2015).
We Wont. published
John Cook, entitled A Judge Told Us to Take Down Our Hulk Hogan Sex Tape Post.
http://gawker.com/ajudgetold-usto-takedownourhu1kby gawker.com on April 25, 2013, available online at
gawker.com on
hogansextapepo481328088 and Jessica, entitled Introducing Gawker Stalker, published by
March
3
14,
11
Gawker.
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32.
sites.3
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15
16
17
33.
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it
by other users that Gawker will coopt the blog and bring
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34.
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between paid staff content and unpaid staff content. And this is
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vision:4
by design, because it is part of Nick Dentons
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24_
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Gawker
John Lennon, born October 9, 1940, was shot and killed by a deranged fan.
https://en.wikipedia.org/wiki/Death_of_John_Lennon (last accessed October 9, 2015).
By way of example,
Gawk, Dont Talk Interview With Nick Denton," The Guardian, Monday 11 December 2006
October 9, 2015).
(http://www.theguardian.com/technology/2006/dec/l l/news.mondaymediasection last accessed
2James
3
Silver,
http://product.kinja.com/introducinggroup
Excerpt from Nick Denton, Introducing Group Chats In Kinja,
chatsinkinja-l517330082. February 6, 2014. Last accessed Oct. 8, 2015.
feature at
its
It is
heart,
Each group chat has an instigator, typically but not necessarily the blog
owner or one of their authors. The instigator can launch a topic with a news
or opinion piece with a headline; or just with a question to another user.
CD\IO\U'II>UJN
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35.
19
(1)
20
As with many other sectors, the news will become increasingly depending
on gathering information from every person possible, especially those who
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have firsthand accounts of an event or those who are experts in the topic
being discussion. How can we highlight and maximize this in our system?
22
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24
25
the latest Kinja template display subsequent discussion with the same
graphical treatment and respect as the authors starter post. The exchange
should read like a questionand-answer session, the classic web chat
10
14
article
37.
26
27'
sites.1
28
future-2015-part-4the-futureofkinja17263757l9 (last
5,
2015 http://maggierosetao.kinja.com/world-
accessed Oct.
9,
2015).
38.
OKDmNONU'lQ-UJNH
respectively.3
40.
SecureDrop.
2
3
See http://gawker.com/stats/leaderboard
(last
1d.
Id.
Paid writers get a bonus for the number of unique visitors they bring to Gawker sites.
New York Times,
See Caitlin Petre, The Trafc Factories: Metrics at Chartbeat, Gawker Media, and The
http://towcenter.org/research/trafcpublished by Tow Center for Digital Journalism on May 7, 2015, available at
factories/.
10
43.
dime-mm
10
ll
In it, Trotter
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J .K. Trotter,
(last
accessed Oct.
9,
2015).
Oct. 9, 2015).
3
anonymously-1613394137
2
Keeping
its
Sleaze
Game
(last
a direct competitor of Gawker. See Erik Wemple, Conde Nast Exec Story:
in Shape, The Washington Post, July 17, 2015
is
ll
accessed
Gawker is
homosexual escort.
'
49.
50.
52.
best.
10
ll
12
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l3
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prostitute and porn star Leif Derek Truitt (porn alias Brodie
Sinclair) a man the Gawker article referred to as "Ryan."
55.
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last
27
(http://www.gotnews.com/breakingexclusiveisthegawkerstory-anelaboratehoax-sure-looksthatway/
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last
accessed Oct.
9,
2015).
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blackmail Geithner.l
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CD\IONU1J>WNJ|
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l4
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since 1980 the numbers 666 have been selected as the winning
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Is
Robby Soave, Gawker Helps Gay Escort Blackmail Timothy Geithners Brother, Ted Cruz
the
Hero of the
2
One Day to Report and Vet the Story That Blew Up in Its Face, Mother Jones,
Gawker
James West,
Took Only
5/07/gawkercondenastfallouttimelinedenton last
Friday July 24, 2015 (http://www.motherjones.com/media/20 l
accessed October 9, 2015).
3
in Shape, The Washington Post, July
Erik Wemple, Conde Nast Exec Story: Gawker is Keeping its Sleaze Game
(https://www.washingtonpost.com/blogs/erik-wemple/wp/ZO15/07/17/condenastexecstorygawkeris
17, 2015
keepingitssleazegameinshape/ last accessed Oct.
9,
2015)
13
61.
information.
Cb\lO\U1Il->UJNH
wish
news outlet.2
62.
}_|
"gayshaming.3
63.
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his family."4
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64.
65.
19
was at Gawker
wrote
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Chuck Ross, Interview With The Gay Porn Star Behind That
Terrible
2015 (http://dailycaller.com/2015/07/17/exclusiveinterview-with-thegayporn-starbehindthatterriblegawker
article/ last accessed Oct. 9, 2015).
2
3
M.
Nick Denton, Taking a Post Down, July
accessed Oct.
9,
17,
2015 (http://nick.kinja.com/takingapostdown1718581684
last
2015).
Id.
17,
Womack, Anyone Else Think James Franco Should Sue the Hell Out of Gawker," Hufngton Post, July
last accessed Oct. 10,
(http://www.hufngtonpost.com/larry-womack/jamesfrancogawker_b_7816032.html
2015
Larry
2015)
6
Id.
14
66.
(b)
ibWN
10
ll
previous post, that James Franco is the rapist that The New York
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69.
A month later, in
'17
ne
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20
specifically.
(and admittedly questionable) emails saying the same thing, one providing
tumor
explicit details. So who the heck knows, but for whatever reason the
had traction. Which makes us queasy. But now the actor is on the cover of
Get magazine this month, acting cairn, collected, and confident in his
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heterosexuality, so we're
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70.
25
all
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Richard Lawson, The People Have Spoken And They Think James Franco Is a
(http://gawker.com/5040524/the-people-havespokenand-theythink-james-francoisarapist
28
2015).
Rapist,
last
15
CJLOCD\IO'\U'|vl>CMI\Jl--|
71.
NMNNNNNNNlllIlllllH
that any anonymous emails naming Franco as the gay rapist were
mQONLNIhWNHOKOCDQONmrtll
events.
73.
Out,
is
10,2015)
16
74.
75.
mummawm
comedian
[masturbating].
76.
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Gawker
March,
Comics
19,
jerk-ofcommenF48089921
last
accessed Oct.
9,
2015.)
2hi
l7
to
79.
WNH
Jordan
website called "Defamer"1 published an article written by
His
Sargent entitled, "Louis C.K. Will Call You Up To Talk About
80.
OKDCDQOIU'IVP
pseudonym "Jason."
Jason explained that two female friends of his had
81.
described
been mistreated by Louis C.K., but the only incident
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Louis C.K.
by "Jason" is supposedly from 2014, wherein
purportedly came up behind the one friend, grabbed her by the
telephone number.
The section written by paid:Gawkercontentcreators
83.
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unpaid
does not accuse Louis C.K. However, many anonymous,
contentcreators (Kinja commenters) do name Louis C.K. in the
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article:
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I
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27
28
Defamer
is
content theme
is
self-explanatory.
http://defamer.gawker.com.
2
His Alleged Sexual Misconduct," Defamer-Gawker,
Jordan Sargent, Louis C.K. Will Call You Up to Talk About
last
2015 (http://defamer.gawker.com/louis-ckwill-call-you-upto-talkabouthis-alleged-s1687820755
May 5,
18
first allegation of
March of 2012, we ran a blind item titled Which Beloveti Comedian hikes
described an
to liaise Female Comics to Watch Him Eerie GER which
prior
incident that had supposedly taken place in Aspen a few years
involving our nations
84.
substantiation whatsoever.
ll
85.
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unsubstantiated tips.
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91.
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matter.
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92.
kept
initiator, and their content creation is subject to being
of the
under a removable veil until "approval" by the initiator
standalone writing.
Readers can, at their own option, lift the veil and
View the content created by non-initiating content creators,
94.
28
1
20
profiles.
-1O
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97.
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20
writings.
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marked place
A hyperlink is an electronic link providing direct access from one distinctively
document. http://www.merriamin a
a different
hypertext or hypermedia document to another in the same or
Webster.com/dictionary/hyperlink last accessed June 17, 2015.
21
99.
The Brown death and the Ferguson Riots were among the
market for
top media stories in the St. Louis, Missouri media
UJN
2014.
100. The riots destroyed large swaths of Ferguson,
occasions
Missouri, nearly overran police positions on multiple
and resulted in multiple US Department of Justice
investigations, public official firings, and additional riots
Okoooqmmp
Governor
throughout the St. Louis region, such that the Missouri
was forced to dispatch more than 2,000 National Guardsmen.
Louis
101. Johnson personally traveled throughout the St.
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provided
102. Local and national law enforcement sources
Michael
Johnson with credible information which suggested that
Brown, as a juvenile, was implicated in a murder.
invested tens
103. As a result of these leads, Johnson has
20
Missouri courts to
of thousands of dollars in trying to convince
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25
filed
104. In pursuit of this objective, Johnson has
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temporarily
St. Louis County in midSeptember 2014, Johnson
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22
as
106. Upon discovering that the records were not reviewed
November, 2014.
was
107. On or about December 4, 2014, a preliminary writ
ooqoxmpH
12
records.
109. As a result of his reporting, and his exposure of
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14
facts which did not fit the common and hackneyed narrative
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December
4,
10
ll
America. "3
115. In his article, Howard stated:
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l3
This conversation
is
over; there
is
killing
14
of Eric Garner, and there really isnt one to be had on the degradation,
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l6
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tadngabout
21
ChaesBandeydoesnotknowrwhatthefudrheetaudngabout
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2
3
See, e.g.,
Adam
rd.
e_e
Greg Howard,
December 4, 2014,
8,
2014 (http://gawkercoin/is
1666864783.
24
jci; Gregiiznese
2333.524 $32578:
"5:1
2/4
eoiy
.a?
fme;
on
Greg Howard
Tgifgofigi
'hhm
Nah, I mean
wrong,
12
too.
think
2
"Km.ef
if
13
this. If you
11
isn't a debate.
seems
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Records, #Ferguson.1
118. In retaliation, on December 9, 2014, Defendants Howard
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28
25
9,
drew
false light, and injured Plaintiffs by stating that Johnson
attention to himself as a result of his flawed reporting in the
Senate Republican Primary race in Mississippi. ("hes drawn
attention for his (flawed) reporting in the Senate Republican
l
http://gawker.com/whatis-chuckjohnsonandwhy-theweb-sworstjournal-1666834902
2015.
'
26
last
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12
13
"racist."
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18
reporting in an
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23
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25
reported.
125. however, the article Trotter cites to is itself
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27
28
See Exhibit
16.
Yes, I Live In
14,
(http://www.buzzfeed.com/rubycramer/corybookeryes-i-livein-newark#.lmZ1
2015).
27
2013
15Wm1
last
accessed Oct.
9,
OOCOQONUTIDUJN
6,
2015) by the
NNNNNNNNNHlIHHHrIlIHIaia
been corroborated.4
2013, http://abcnews.go.com/Blotter/robert-menendezprostitution-scandalhappened/story?id=18664472
last accessed June 17, 2015.
Backed By Corroborating
3
Chuck Ross, DOJ: Underage Prostitution Allegations Against Robert Menendez
March
6,
4M.
28
that
129. Trotter cites as proof that Johnson fabricated
an article by ABC
is, completely invented the Menendez story,
News,1 which does not reach a conclusion and at best for Trotter,
article.
130. Trotter, on the other hand, reports that conclusively,
11
Menendez.
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13
14
injured Plaintiffs.
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happened/story?id=18664472
last
accessed Oct.
9,
2015).
29
a
136. She then let slip her motivation for releasing such
problems."
same reasons he was in college, his public pooping
on
137. Cmcalumna published false information about Johnson
mummbww
ll
12
13
14
15
16
17
18
December
9, 2014,1
19
but
simply described upperclassmen talking about it "regularly"
20
it."2
yet that it was an "undisputed fact that he did
140. At 1:44 p.m. on December 9, 2014,3 anonymous unpaid
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24
25
26
27
28
2
3
See
Plaintiffs
Ex. 18.
Id.
Id.
30
on
Facebook wall for dissemination to former classmates of his
I
Facebook. "This is from his Facebook account late last night.
Friend is
141. Notably, the letter posted by CCJ Facebook
hours
exactly the same as the one Greg Howard would publish two
OO\IO\U1J>LUNl-
Facebook
142. Greg Howard did not have access to Johnsons
page, because they were not Facebook friends.
10
CCJ
143. On December 10, 2014,2 Trotter would respond to
12
13
post?"
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18
19
I
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21
22
Blogger
writing on deadspin.com, entitled, "Wait, Did Clowntroll
"Howard
Chuck Johnson Shit On The Floor One Time?" (hereafter,
First).3
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25
creator
145. At 4:19 p.m. on December 9, 2014,4 content
"IkerCatsillas" posts a discussion piece (directed at Trotter)
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28
2
3
Id
kt
http://theconcourse.deadspin.com/waitdid-clowntroll-bloggerchuck-johnson-shitonthe1668919746
Id.
31
last
scoop this
on the First Trotter article: "Please J.K. You gotta
poop story for us. For journalism.
article.
posted
146. On December 9, 2014 (at 4:20 p.m.), Trotter
\]
Chuck
another article entitled, "The Daily Caller Cant Quit
Johnson."2
Johnson
147. In the article, Trotter repeatedly states that
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12
13
that Johnson
a false light, and injured Plaintiffs reporting
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Republic."3
2014,
149. Between 2:00 p.m. and 2:14 p.m. on December 9,
questions:4
Greg Howard emailed Charles Johnson and asked various
for
"Chuck, we just got a tip that you wrote up a Facebook post
happened
your past classmates. Just checking to see it actually
of the
and is accurate. [The email goes on to quote a portion
letter posted by CCJ Facebook Friend to the First Trotter
25
26
27
28
Id.
December
The Daily Caller Cant Quit Chuck Johnson, published by gawker.com on
http://gawker.com/thedai1y-caller-cant-quitchuck-johnson1668910086.
2014, available online at
9,
3
Id.
See
11am
(2 p.m. Eastern
as
1am because
Time).
32
it
in California at
though."
151. At 2:14 pm. on December 9, 2014,3 Johnson emailed
OkommU'Iwb
on the
Howard, stating, "Oh, and the comments about me shitting
post
floor were made up," referencing the Cmcalumna discussion
Johnson: "If you have time, we got a tip that you had a 2002
NMNNNNNNNFIllllHIIll
ever occurred.
"instigated" his
154. At 4:00 p.m., Greg Howard initiated/
mummhwmwowmqmmpII
On The
piece, Wait, Did Clowntroll Blogger Chuck Johnson Shit
accessed Oct.
9,
2015).
33
additional
solicit additional tips, photos, and context from
Kinja contentcreators.
mummpI-A
content
156. In Howard First, Defendant Howard also created
amongst other noninitiating contentcreators, soliciting
information from them as well as adopting and advertising
10
11
12
13
14
15
16
First
defamatory content published by Cmcalumna on the Trotter
View
website, encouraging other readers and content creators to
the defamatory statements by hyperlinking to Cmcalumnas
published Content. ("Ill tell you what. There is some goodass
at
kinja to be had re: Chuck shitting on the floor one time over
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17
20
21
22
advised to view.
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24
25
26
"goodass kinja,"
159. Stating that particular content is
content, serves
as Well as instantly providing the link to said
Defendant
as express endorsement of the linked content, and
27
View
Howard intended to direct as many readers as possible to
28
mumm-wm
for,
Howard First.
161. Instead of basing his reporting of the public
ll
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13
14
10
15
16
17
18
19
to
162. However, as mentioned, Howard doesnt have access
on
this page. And in any event there were no comments made
Johnsons Facebook page during this time that referenced or
20
21
22
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24
25
before..."3
26
27
28
See
See
35
lied, nor does he provide any evidence that Johnson was ever
caught lying.
167. At 4:34 p.m. on December 9, 2014,1 Gawker writer Jordan
GDQONU'IIh-UJNH
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11
12
13
14
15
16
17
18
breaking news, team, there was never any proof that he actually
was the one who pooped on the floor. Someone did poop on the
floor and just to sort of troll the Mountain King himself,
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24
25
26
27
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no
one time over at Gawker") in which she clarifies that she has
"I think you
proof of the defecation incident having occurred:
Id.
Id.
gawker.com on December
36
9,
occurred m
appear.
\DQNGU'IIbbJNl-I
NNNNNNNNNHIiIIlHIIIJ
8.
"We need
his article, Howard himself tweeted on Twitter:1
See
Plaintiffs
Ex. 29.
37
11
12
retraction.
177. On December 12, 2014, at 12:42 p.m.,1 Trotter emailed
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17
Im
Charles Johnson: "Hi Charles, Im a reporter at Gawker, and
writing because weve received a pair of allegations involving
them.2 The
you, and wanted to give you an opportunity to address
19
20
18
21
22
23
24
25
26
convicted of
by the San Bernardino County Sheriff and later
to have
this; and that, in 2007, you successfully petitioned
irecords of the incident expunged. Is this allegation true? The
27
28
Plaintiffs
2
discusses
is
Id.
ki
38
is
information to
any other questions, or if you need any other
address these allegations. My working deadline is midnight EST,
require more
but that is flexible, so please let me know if you
time."
I honestly
178. Johnson responded:1 "Neither story is true.
oxoooqcnmhwm
who
follow up with Johnson: "The first story comes from a person
witnessed the
says they were physically present, and personally
conversation. Weve verified that this person attended Claremont
with you. This person provided a very specific account of the
incident. The second story comes a person [sic] who is friends
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that.
180. On or about December 15, 2014, Trotter wrote,
2
3
Id.
hi
http://gawker.com/which-of-thesedisgusting-chuckjohnsonrumorsaretrue1669433099
2015.
39
last
and incitation.
11
12
13
14
15
16
17
18
19
public.
20
21
22
23
24
25
26
27
28
See
Plaintiffs Ex.
1.
40
last
whom
fucking it. Johnson is, however, the kind of guy about
random people make up and circulate rumors about him being
it.
arrested in 2002 for pinning a sheep to a fence and fucking
the fourth
186. However, similar to Lawsons conclusions in
ooqnpwwrI
12
1o
'13
14
15
16
17
18
19
20
21
22
23
,up
25
26
24
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28
41
mummpil
11
12
ChekhovsGum(ItsGonnaPop!).
190. However, Defendant Trotter acknowledged that
13
14
15
16
17
18
19
20
spite.
191. Thus, as evidenced by the writing in Trotter Third,
21
22
23
24
25
26
and published.
27
28
them as being classmates of Johnson, but does not describe the basis of his knowledge that they
used burner Gawker content creator
were, in fact, classmates of Johnson. Trotter also describes them as having
content-creator account.
proles. A burner prole is slang for an anonymously created noninitiating
1
Trotter describes
42
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true than false, even though Trotter and Howard had serious
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publicly defecated.
196. Thus, any reader would be left with the impression
"
ucked a sheep.
43
198. Defendant Trotter wrote that his source had told him
not divulge any information about his source and the basis of
knowledge;
200. Defendant Trotter continues on to describe his attempt
12
13
14
15
16
17
18
since the cops didn't catch him mid-act, were used as the basis
for his conviction. He was pantsdown, pinning the sheep against
19
20
a kid experimenting).
21
22
23
24
25
26
27
28
\OCDQOU'IvbWNI-l
is
is something you grow into. on the other hand, @chuckcjohnson
a prodigy.
article]
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45
their
209. A significant number of Gawker's readers visit
sites primarily to read the discussion/comments sections.
210. Defendant Howards @greghoward88 Twitter account
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"tweet"
213. On December 15, 2015, @gawker published a
oouowmtIIomooxlmm-wNIIo
one.
Johnson.
46
11
12
13
14
15
16
17
18
19
20
21
22
to defame Plaintiffs.
23
24
25
26
27
28
&
Id
47
lawsuit to defend his good name and the related costs from
mQONsWNHOKomxlONU'IvP-WNIJO
Counts
Complaint.
227. This claim arose in St. Louis County, Missouri.
228. However, the claim is also cognizable in California
48
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u
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a.
9,
No
NH
in Newark."
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2.
Nu
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ii.
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college.
ii.
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problems.
50
2.
koooqmmtI-I
iv.
know Plaintiff:
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1.
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Wrightwood.
The father of the friend got suspicious when they
z"\
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ref
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235.
the statements.
236. The statements tend to deprive plaintiff of the
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
53
lawsuit to defend his good name and the related costs from
OkOGJNONU'IIbWNIl
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respondeat superior.
mummpIIomooqmmtII
and costs, and such other and further relief, as the court shall
deem proper.
Counts III and IV: Defamation and Injurious Falsehood
(Against Defendants Gawker and Howard)
232. Plaintiff restates and incorporates by reference, as
if fully set forth herein, all prior allegations of this
Complaint.
54
HN
Hw
Hb
and incompetent journalist and also that during his college life
Hm
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9,
Hm
No
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i.
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ii.
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floorshitting incident"
In the Comments section, titled "Greg Howards
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i.
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patently false.
240. The statements described in paragraphs 245249 (and
\OmQGWDHWNI-J
the statements.
242. She statements tend to deprive plaintiff of the
Ho
HH
HN
Hm
Hp
Hm
Hm
Hu
Hm
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NH
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respondeat superior.
245. As a direct result of the publication of the
all to
jeopardy, and Plaintiff has suffered emotional injury,
\OmmmID-UJNH
lawsuit to defend his good name and the related costs from
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mummwHowmqmmtH-o
Complaint.
58
\OmQONU'InbOONI-l
NNNNNNNNNHHHHHHHHHH
Johnson and Got News, LLC have been damaged in reputation and
have suffered pecuniary damages of lost business and lost
59
in an
his good name and the related costs from attorney's fees,
10
11
12
reasonable, together with interest and costs, and such other and
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
of depriving
235. Defendants have conspired for the purpose
I
the
Plaintiffs their right to file a defamation lawsuit under
Zinermon
Fourteenth Amendment of the United States Constitution.
v.
mummpII
10
ll
12
13
14
15
16
17
18
which
by refusing and potentially destroying any information
would allow the anonymous content creators to be identified.
237. Defendant Gawker has demonstrated a track record and a
20
21
22
off as "news."
19
23
24
25
26
use-of
238. Defendants are state actors by virtue of their
CDA
230,
27
28
61
an
239. When a state actor inserts itself between
such
individual and the individuals realization of his rights,
is Constitutionally impermissible.
Charles C.
240. As a result of the foregoing, Plaintiffs
mQONWvbWNI-l
and
Johnson and Got News, LLC have been damaged in reputation
lost
have suffered pecuniary damages of lost business and
as
business investments, due to damaged business reputation,
defend
well as the need for Plaintiff to file this lawsuit to
fees, in an
his good name and the related costs from attorneys
V
11
12
l3
14
15
16
17
18
19
20
21
22
23
24
Dated this
25
28
ER
9,
2015
(44.
Char es C. aon
26
27
k
CE
INDEX OF EXHIBITS
62
EXHIBIT
m\l0\U1vl>-LA)Ni-'
DOCUMENT
'
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12
13
11
14
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17
15
18
20
21
19
22
24
25
23
26
27
28
KomQONUlIh-UJNlI
HN
Hu
HH
10.
Ha
Hm
Hu
Hm
ll.
Hm
No
NH
Ho
NA
12.
Nw
l3.
Np
Nm
Nm
Nu
14.
Nm
64
15.
l6.
l7.
18.
19.
20.
mummpIlooooqmmhwwwo
21.
"TheOneWhoKnocks" 12/15/2014
22.
23.
"Russianist" 12/15/2014
65
24.
"ihatepickinggames" 12/15/2014
25.
"cassienyc" 12/15/2014
ooqoxmprI
26.
27.
"yankeeinchucktown" 12/15/2014
ll
12
13
28.
14
15
17
18
16
29.
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20
30.
21
22
31.
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32.
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28
33.
12/9/2014
34.
article 12/9/2014
(XJ\IO\U1.PUJN
35.
10
11
college. 6/18/2015
36.
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13
37.
38.
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39.
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40.
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advertising
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41.
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42.
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68