Covington Kids

PLAINTIFF’S COMPLAINT WITH JURY DEMAND
FILED AUGUST 1, 2019
KENTON CIRCUIT/DISTRICT COURT

FILED
KENTON CIRCUIT/DISTRICTCOURT
AUG O1 2019
JOHN C. MIDDLETON

1 Robert E. Barnes, pro hoc pending
2 Barnes Law
601 South Figueroa Street, Suite 4050
3 Los Angeles, CA. 90017
213.330.3341
4 robertbarnes!i))barneslawllp.com

5 Kevin L. Murphy
Murphy Landen Jones PLLC
6 2400 Chamber Center Drive, Suite 200 Ft. Mitchell, KY 41017
7 859.578.3060 KMurphy(@mljfirm.com

KENTON COUNTY CIRCUIT COURT

JOHN DOES 1 THROUGH 8

Plaintiffs

DEBORAH HAALAND
400 GOLD A VENUE SW, SUITE 680 ALBUQUERQUE, NM 87102

ANA VIOLET A NA V ARRO FLORES 2907 COLUMBUS BLVD.
CORAL GABLES, FL 33134

ELIZABETH WARREN
1550 MAIN STREET, SUITE 406 SPRINGFIELD, MA 01103

MAGGIE HABERMAN
817 W. END AVENUE, APT. 4E NEW YORK, NY 10025-5318

KATHY GRIFFIN
11782 SOUTHAMPTON COURT LOS ANGELES, CA 90077-1360

MATTHEW JOHN DOWD 307 W. MONROE STREET AUSTIN, TX 78704-3023

REZAASLAN
1954 PINEHURST ROAD
LOS ANGELES, CA 90068-3730 27

PLAINTIFFS' COMPLAINT WITH JURY DEMAND

KEVIN M. KRUSE
121 BERTRAND DRIVE PRINCETON, NJ 08540

3
JEFFREY SHAUN KING

214 DUFFIELD STREET BROOKLYN, NY 11201-5339

5
ADAM EDELEN

6 7 8

EDELEN STRATEGIC VENTURES 300 EAST MAIN STREET, STE. 210 LEXINGTON, KY 40507

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AND

CLARA JEFFERY
3809 20TH STREET, APT. 305

9
SAN FRANCISCO, CA 94114-3058

JODI JACOBSON
7315 WISCONSIN AVE., STE. 400W BETHESDA, MD 20814

INTRODUCTION

Defendants

A field trip to our nation's capital for a group of minors from Covington, Kentucky turned into a social media nightmare that changed their futures forever. Several of our Senators, most-famous celebrities, and widely read journalists, collectively used their large social media platforms, perceived higher credibility and public followings to lie and libel minors they never met, based on an event they never witnessed. These defendants called for the kids to be named and shamed, doxxed and expelled, and invited public retaliation against these minors from a small town in Kentucky. The defendants circulated false statements about them to millions of people around the world. The video ofthe entire event, known to the defendants, exposed all oftheir factual claims against the kids as lies. The defendants were each individually offered the opportunity to correct, delete, and/or apologize for their false statements, but each refused, continuing to circulate the false statements about these children to this very day on their social media platforms they personally control. This suit follows.

NOW COMES John Doe 1 through 8, identified by photograph and video as the "Covington Boys" to those who know them, and known individually by their friends and acquaintances as the subject of the defamatory statements

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complained of herein within this Complaint, bring this suit, by and through their parent and legal guardian, against 2

U.S. Senator Elizabeth Warren, U.S. Congresswoman Deb Haaland, New York Times lead political reporter Maggie

Haberman, media figure and celebrity Kathy Griffin, ABC analyst Matthew Dowd, former CNN analyst Reza Aslan

Adam Edelen, Professor Kevin M. Kruse, media analyst Shaun King, Mother Jones editor Clara Jeffery and media 5

reporter Jodi Jacobson. The plaintiffs repeatedly offered each defendant publicly the opportunity to retract, correct,

or delete their offending and defamatory statements, but each refused, continuing to share their defamatory

comments with the public to this very day. No individual plaintiff seeks damages from any defendant in excess of 8

fortune; they bring this suit to protect future families from experiencing the nightmare the defendants caused these kids to experience.
P ARTIES

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1. JOHN DOE 1-8, are all minors, who bring this action through their parents, who at all times pertinent, reside in Kenton County, Kentucky, in and around the area of Covington, Kentucky.

the cost of a four-year tuition at the University of Kentucky. Plaintiffs file this Complaint for neither fame nor

2. JOHN DOE 1-8 are students who, at all times pertinent, attend Covington Catholic High School in Park Hills, Kentucky.

3. DEB HAALAND, at all times pertinent, is a natural person ofthe age ofmajority, residing in New Mexico.

ANNA NAVARRO, at all times pertinent, is a natural person ofthe age ofmajority, residing in Florida.
ELIZABETH WARREN, at all times pertinent, is a natural person ofthe age ofmajority, residing in

Massachusetts.
6. MAGGIE HABERMAN, at all times pertinent, is a natural person ofthe age ofmajority, residing in

Virginia.

KATHY GRIFFIN, at all times pertinent, is a natural person of the age of majority, residing in California.
MATTHEW DOWD, at all times pertinent, is a natural person ofthe age ofmajority, residing in

Michigan.
9. REZA ASLAN, at all times pertinent, is a natural person of the age of majority, residing in California.

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10. KEVIN M. KRUSE, at all times pertinent, is a natural person of the age of majority, residing in New Jersey.

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15. On Friday January 18, 2019, each ofthe John Does was part ofa group ofCovington Catholic High School students who traveled by bus from Park Hills, Kentucky to Washington D.C. to attend the March for Life. None was a public figure or publicly known to much ofthe world prior to this trip.

SHAUN KING, at all times pertinent, is a natural person of the age of majority, residing in New York.
ADAM EDELEN, at all times pertinent, is a natural person ofthe age ofmajority, residing in Kentucky.
CLARA JEFFERY, at all times pertinent, is a natural person of the age of majority, residing in California.
JODI JACOBSON, at all times pertinent, is a natural person ofthe age ofmajority, residing in Maryland.

FACTS

16. The Covington Boys arrived at the Lincoln Memorial and encountered the Black Hebrew Israelites. Members ofthe Black Hebrew Israelites made offensive statements to the Covington Boys, including calling them "incest babies," "dirty-ass crackers," and "future school shooters." Some ofthe Covington Boys asked the chaperones ifthey could do their school cheers to drown out the Black Hebrew Israelites.

17. After the interaction with the Black Hebrew Israelites, Native American activist Nathan Phillips approached the Covington Boys. Phillips approached the Covington Boys from a distance and walked past clear pathways to the steps to the Lincoln Memorial. The Covington Boys did not move toward Phillips or otherwise actively approach or surround Phillips, block Phillips, taunt Phillips, or ever chant "build the wall" at Phillips. The Covington Boys did not interrupt or interfere with any Indigenous People's March.

18. Phillips beat on a drum and joined the students as they engaged in school cheers, including the sports cheer made famous by the New Zealand rugby team known as the Haka dance that celebrates the tribal traditions of the Maori tribe. Several of the students joined with Phillips, and some did so by mirroring the sports chant ofthe Florida State Seminole and the Atlanta Braves, with their famous tomahawk chop. No one voiced any objection to this at the time. Soon after, the students left the Lincoln Memorial without incident or any apparent controversy beyond being harassed ~y the notorious Black Hebrew Israelites. What the

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19. As they arrived home, the Covington Boys uncovered a social media lynch mob had formed, advanced by prominent politicians, journalists with big-pedigree publications, and social celebrities with large social media platforms and public followings. The defendants used the perception oftheir enhanced credibility to make statements about the Covington Boys without disclosing all the relevant facts, omitting critical exculpatory facts, and implying many false facts about them. The defendants called for public punishment of the Covington Boys, including <loxing them, naming and shaming them publicly, that they be "punched in the face," and their expulsion from school. The target of the lynch mob was the Covington Boys, their reputation and their future. Each ofthe statements complained ofherein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were identified by photo image throughout th world, and each ofthe statements was interpreted by their friends, family and associates as about them personally.

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Covington Boys did not know is what was happening to them on social media.

20. An accurate video as to what occurred in the incident was available online on Jan. 19 and known to the defendants, when Shar Y aqataz Banyamyan, one o f the Hebrew Israelites who was present for the encounter between Phillips and Nicholas, posted a 1 hour and 46-minute video on Facebook (the "Banyamyan Video"). The video made clear the statements made against the Covington Boys were false.

21. At 8:31 a.m. on Jan. 19, Congresswoman DEB HAALAND made the following Tweet ofand concerning the Covington Boys: "This Veteran put his life on the line for our country. The Covington boys' blatant display of hate, disrespect, and intolerance is a signal of how common decency has decayed under this administration. Heartbreaking." See Exhibit A. Haaland omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist of the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and

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blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to mock an elderly native American in the middle of an indigenous march. Each of the statements complained ofherein was known by the friends, family and associates ofeach John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained ofherein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained of herein as they were identified by photo image throughout the world, and each ofthe statements was

22. At 10:58 a.m. on Jan. 19, CNN contributor ANNA NAVARRO tweeted ofand concerning the Covington Boys: "Must Watch: Native-American elder taunted by racist MAGA-hat wearing teens, speaks and cries for America, the country he defended and sacrificed and wore the uniform for. It is people like Nathan Phillips who make America great. Thank you for your dignity, sir." See Exhibit B. Navarro omitted the tru fact, and instead implied the following facts were true in her statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with

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chants of"build the wall" to mock an elderly native American in the middle of an indigenous march. Each ofthe statements complained ofherein was known by the friends, family and associates ofeach John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained ofherein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained ofherein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

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23.

At 1:08 p.m. on Jan. 19, 2019, SHAUN KING, a writer-in-residence at Harvard Law School's Fair Punishment Project, made the made the following Tweet ofand concerning the Covington Boys: "I am so

interpreted by their friends, family and associates as about them personally.

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deeply grieved and angry by this as young kids in MAGA hats surrounded and mocked a beloved Native American elder yesterday. When your power is centered in your whiteness, mocking others who are unlike you makes you feel strong. But it's weak. And despicable." See Exhibit C. King omitted the true fact, and instead implied the following facts were true in his statements and the links attached thereto with the gist o the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to mock an elderly native American in the middle ofan indigenous march. Each ofthe statements

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native American elder, with chants of"build the wall" to mock an elderly native American in the middle of an indigenous march. Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phon

complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained of herein as they were identified by photo image throughout the world, and each ofthe statements was interpreted by their friends, family and associates as about them personally.

24. At 1:14 p.m., ADAM EDELEN, a blue-checkmark-approved Twitter personality, retweeted an article with false factual statements about the Covington Boys, and validated the false factual claims of the article by referring to the kids as "outrageous and abhorrent behavior," that requires they "read a history book on ho America's indigenous people have been treated," and that they "need to do some serious soul-searching." Edelen omitted the true facts, and instead implied the following facts were true in his statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a

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calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were identified by photo image throughout the

25. At 2:45 p.m. on Jan. 19, New York Times reporter MAGGIE HABERMANN made the following Tweet ofand concerning the Covington Boys: "When adults stand by and say nothing..." in reference to a retweet that Habermann posted by Andrew Ujifusa that said,. "In another video from this now-infamous incident involving a Native American Vietnam vet, a young person scoffs at the idea of stolen land..." See Exhibits D & E. Habermann omitted the true fact, and instead implied the following facts were true in his statements and the links attached thereto with the gist of the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to mock an elderly native American in the middle ofan indigenous march. Each ofthe statements complained ofherein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained ofherein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were identified by photo image throughout the world, and each ofthe statements was interpreted by their friends, family and associates as about them personally.

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26. At 6:04 p.m.; former CNN TV personality REZA ASLAN made the following Tweet ofand concerning th Covington Boys with a picture of fellow Covington student at the Lincoln Memorial: "Honest question. Have you ever seen a more punchable face than this kid's?" See Exhibit F. Aslan omitted the true fact, and instead implied the following facts were true in his statements and the links attached thereto with the gist o the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event,

world, and each of the statements was interpreted by their friends, family and associates as about them personally.

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surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to mock an elderly native American in the middle ofan indigenous march. Each ofthe statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained of herein as they were identified by photo image throughout the world, and each ofthe statements was

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interpreted by their friends, family and associates as about them personally.
27. At 6:45 p.m. Congresswoman DEB HAALAND made the following Tweet ofand concerning the

Covington Boys: "A Native American War veteran was seen being harassed and mocked by a group of MAGA hat-wearing teens." See Exhibit G. Haaland omitted the true fact, and instead implied the following facts were true in her statements and the links attached thereto with the gist of the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to mock an elderly native American in the middle of an indigenous march. Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained ofherein as they

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were identified by photo image throughout the world, and each of the statements was interpreted by their

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tweeted: "There are dozens of students laughing and egging on the behavior. Will be interesting to see if anyone is actually expelled, as officials suggest is possible." See Exhibit H. Haberman omitted the true fact, and instead implied the following facts were true in her statements and the links attached thereto with

friends, family and associates as about them personally.
28. At 7:08 p.m. on Jan. 19, 2019, New York Times reporter MAGGIE HABERMAN (@maggieNYT)

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29. At 7:15 p.m., on Jan. 19, U.S. Senator ELIZABETH WARREN made the following Tweet ofand concerning the Covington Boys: "Omaha elder and Vietnam War veteran Nathan Phillips endured hateful taunts with dignity and strength, then urged us all to do better." See Exhibit I. Warren omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to mock an elderly native American in the middle of an indigenous march. Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained ofherein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained ofherein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

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the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to mock an elderly native American in the middle of an indigenous march. Each ofthe statements complained ofherein was known by the friends, family and associates ofeach John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

30. At 2:05 a.m. on Jan. 20 comedienne KATHY GRIFFIN called for the doxing ofthe Covington Boys, which several people then acted upon, linking the Covington Boys to their photos and names, and widely

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circulated on social media: "Ps. The reply from the school was pathetic and impotent. Name these kids. I want NAMES. Shame them. If you think these fuckers wouldn't dox you in a heartbeat, think again." See Exhibit J. GRIFFIN then requested, five minutes later: "Names please. And stories from people who can identify them and vouch for their identity. Thank you." See Exhibit K. Griffin omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist o the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event,

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surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to mock an elderly native American in the middle ofan indigenous march. Each of the statements complained ofherein was known by the friends, family and associates ofeach John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal

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attacks on them each individually. They were known to be the subject ofthe statements complained of herein as they were identified by photo image throughout the world, and each ofthe statements was interpreted by their friends, family and associates as about them personally.

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31. At 1:16 p.m. on Jan. 21, ChiefPolitical Analyst for ABC News MATTHEW DOWD made the following Tweet ofand concerning the Covington Boys: "Folks, let us not let these kids, their parents and their school offthe hook. Regardless of what led up to this, this is awful." See Exhibit M. Dowd omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to mock an elderly native American in the middle of an indigenous march. Each

of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening

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33. At 5:23 p.m. on Tuesday Jan. 22, 2019, KEVIN M. KRUSE Tweeted: "No, the accusation was that this kid and his friends mocked an elderly Native American war veteran and, hey, they did. They also taunted women and shouted "it's not rape if you enjoy it" but sure, they're the real victims. According to his PR firm anyway." See Exhibit 0. Kruse omitted the true facts, and instead implied the following facts were true in his statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder

emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained ofherein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

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32. At 1:27 p.m. on Jan. 21, CLARA JEFFERY the Editor-in-ChiefofMother Jones magazine, made the following Tweet ofand concerning the Covington Boys: "The tapes that have emerged do show the BHI [Black Hebrew Israelites] doing their usual end-times ranting. But they also show the Covington Catholic kids: making cavemen gestures at BHI; tomahawk chanting at Natives; taunting random women; chants of "build the wall" and "it's not rape ifyou enjoy it." See Exhibit N. Jeffery omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist of the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to a Native American elder to taunt him, while also falsely accusing the teens of taunting women with the chant "it's not rape ifyou enjoy it." Each ofthe statements complained ofherein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained ofherein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

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and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to a Native American elder to taunt him, while also falsely accusing the teens of taunting women with the chant "it's not rape if you enjoy it." Each ofthe statements complained ofherein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the

subject of the statements complained of herein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.
On Jan. 22, 2019, JODI JACOBSON, the president and editor in chiefofthe website Rewire.News, authored an article published on Rewire.News titled "White-Washing White Supremacy: Media Rushes to Excuse Covington Catholic Students." A true and correct copy of said communication is attached hereto as Exhibit Q. JACOBSON'S article erroneously claimed Covington Boys wore blackface to caricature black students, harassed young women at the Memorial (claiming they chanted "it's not rape if you enjoy it"),

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and ridiculed the native American elder for the purposes of harassment. Jacobson omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to a Native American elder to taunt him, while also falsely accusing the teens of taunting women with the chant "it's not rape if you enjoy it." Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received

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34.

death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were

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family and associates as about them personally.
35. EachofthecomplainedofstatementshereinbyeachofthedefendantsconcerningtheCovingtonBoys

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36. Each of the defendants made these statements knowing they both omitted true facts and implied false facts, including the false factual claim the Covington Boys interrupted an indigenous people's march, stopped, blocked and surrounded a native American elder war veteran for the purposes oftaunting, harassing, and mocking him with chants ofbuild the wall, aggregating these lies into public denunciations, calls for public doxing, and public demands of school expulsion, to induce public contempt upon the plaintiffs.

identified by photo image throughout the world, and each of the statements was interpreted by their friends,

were known by friends and acquaintances of each of the John Doe plaintiffs to be in reference to and concerning them individually. This is evident by the fact they were quickly subject to public ridicule, scorn and criticism personally and individually, as well as threatening phone calls, hate mail to their homes, individual email addresses, and social media accounts, and personally threatened with everything from expulsion and denial of college admission to being put through a physical shredder and having their school burned with them in it.

JOHN DOE 1 THROUGH 8 ARE MINORS & PRIVATE FIGURES

DOES 1-8, at all times pertinent to this action, were minors.
DOES 1-8 had no notoriety of any kind to their community at large at any time prior to this event.
DOES 1-8 did not make public appearances for political reasons at any time prior to this event.
DOES 1-8 have not inserted themselves into the forefront of any public issue at any time prior to this

event.

41. Eachofthestatementsmadehereinwereidentifiedbythefriends,family,associates,andothersasofand concerning each of the John Does individually. They were doxed and publicly identified by name after the request for that to occur by defendants above, identified by photo in video and photo images shared around the world, and the context of the statements made them individually identified as the ones being spoken about. They were publicly attacked, personally threatened, and subject to individual investigation based on them being individually identified as the subject of the above offending statements of fact from the

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defendants with large social media platforms and an audience who took the defendants' at their word duet the defendants status as elected officials and prominent members ofthe press.

without privilege "[a] Native American War veteran was seen being harassed and mocked by a group of MAGA hat-wearing teens." A true and correct copy of said communication is attached hereto as Exhibit H. Haaland omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to mock an elderly native American in the middle of an indigenous march. Each ofthe statements complained ofherein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained ofherein that they received death threats, hate mail, threatening phon calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

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44. HAALAND's communication was false and defaming as none of DOES 1-8 harassed or mocked anyone, and particularly no Native American "War Veterans." This comment is deliberately directed against DOES 1-8, all minors, and communicated to at least 68,000 third parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1-8 in their school, their community, and the nation at large.

FIRST CAUSE OF ACTION: DEF AMA TION PER SE
DOES 1-8 against DEB HAALAND
42. DOES 1-8 reassert and incorporate by reference paragraphs the other paragraphs of this Complaint as if

fully restated herein.
43. HAALAND, known on Twitter as @Deb4CongressNM, published to approximately 68,000 third parties,

PLAINTIFFS' COMPLAINTWITH illRY DEMAND - 15

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45. HAALAND's false and defamatory communication injured DOES 1-8 as it disgraced and degraded the plaintiffs and held them up to public hatred, contempt, ridicule, and/or caused them to be shunned and avoided.

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47. NAVARRO, known on Twitter as @ananavarro, published to approximately 1.1 million third parties, without privilege, "Must Watch: Native-American elder taunted by racist MAGA-hat wearing teens, speaks and cries for America, the country he defended and sacrificed and wore the uniform for. It is people like Nathan Phillips who make America great. Thank you for your dignity, sir..". A true and correct copy of said communication is attached hereto as Exhibit B. Navarro omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to mock an elderly native American in the middle of an indigenous march. Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained of herein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

SECOND CAUSE OF ACTION: DEFAMATION PER SE
DOES 1-8 against ANNA NAVARRO
46. DOES 1-8 reassert and incorporate by reference paragraphs the other paragraphs of this Complaint as if

fully restated herein.

48. NAVARRO's communication was false and defaming as she accuses DOES 1-8, ofovert racism and taunting, not exhibited. This comment is deliberately directed against DOES 1-8, all minors, and communicated to at least 1.1 million third parties without privilege, knowing DOES 1-8 were from

PLAINTIFFS' COMPLAINTWITH JURY DEMAND - 16

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fully restated herein.
51. GRIFFIN, known on Twitter as @kathygriffin, published to approximately 2.1 million third parties,

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Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1-8 in their school, their

community, and the nation at large.
49. NAVARRO's false and defamatory communication injured DOES 1-8 as it disgraced and degraded the

plaintiffs and held them up to public hatred, contempt, ridicule, and/or caused them to be shunned and avoided.

THIRD CAUSE OF ACTION: DEFAMATION PER SE
DOES 1-8 against KATHY GRIFFIN
50. DOES 1-8 reassert and incorporate by reference paragraphs the other paragraphs of this Complaint as if

without privilege "Ps. The reply from the school was pathetic and impotent. Name these kids. I want NAMES. Shame them. If you think these fuckers wouldn't dox you in a heartbeat, think again." Griffin then followed up with, "Names please. And stories from people who can identify them and vouch for their identity. Thank you." See Exhibit L. A true and correct copy of said communication is attached hereto as Exhibits Land K. Griffin omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to a Native American elder to taunt him. Each ofthe statements complained ofherein was known by the friends, family and associates ofeach John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally. Griffin's call to dox the plaintiffs succeeded, as their names were identified to the broader

PLAINTIFFS' COMPLAINTWITH JURY DEMAND -17

54. DOES 1-8 reasserts and incorporates by reference paragraphs the other paragraphs of this Complaint as if fully restated herein.

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55. WARREN, known on Twitter as @ewarren, published to approximately 2.3 million third parties, without privilege "Omaha elder and Vietnam War veteran Nathan Phillips endured hateful taunts with dignity and strength, then urged us all to do better." A true and correct copy of said communication is attached hereto as Exhibit J. Warren omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist of the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to a Native American elder to taunt him. Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

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public in a range of social media platforms, and they subsequently received a range of threats.
52. GRIFFIN's communication was intentionally defaming as she openly calls for shame of DOES 1-8. This

comment is deliberately directed against DOES 1-8, all minors, and communicated to at least 2.1 million third parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1-8 in their school, their community, and the nation at large.

53. GRIFFIN's defamatory communication injured DOES 1-8 as it disgraced and degraded the plaintiffs and held them up to public hatred, contempt, ridicule, and/or caused them to be shunned and avoided.

FOURTH CAUSE OF ACTION: DEFAMATION PER SE DOES 1-8 against ELIZABETH WARREN

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56. WARREN's communication was false and defaming as she accuses DOES 1-8, of overt taunting, not exhibited. This comment is deliberately directed against DOES 1-8, all minors, and communicated to [how many] third parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1-8 in their school, their community, and the nation at large.

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fully restated herein.

57. WARREN's communication injured DOES 1-8 as it disgraced and degraded the plaintiffs and held them up to public hatred, contempt, ridicule, and/or caused them to be shunned and avoided.

FIFTH CAUSE OF ACTION: DEFAMATION PER SE
DOES 1-8 against MAGGIE HABERMAN
58. DOES 1-8 reassert and incorporate by reference paragraphs the other paragraphs ofthis Complaint as if

59. HABERMAN, known on Twitter as @maggieNYT, published to approximately 1.08 million third parties, without privilege "When adults stand by and say nothing..." A true and correct copy of said communication is attached hereto as Exhibit D. Haberman also published to some 1.08 million third parties, without privilege, "There are dozens ofstudents laughing and egging on the behavior. Will be interesting to see if anyone is actually expelled, as officials suggest is possible." A true and correct copy of said communication is attached hereto as Exhibit I. Haberman omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to a Native American elder to taunt him. Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained ofherein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends,

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SIXTH CAUSE OF ACTION: DEFAMATION PER SE
DOES 1-8 against MATTHEW DOWD
62. DOES 1-8 reassert and incorporate by reference paragraphs the other paragraphs ofthis Complaint as if

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family and associates as about them personally.
60. HABERMAN's communication was false and defaming as she accuses DOES 1-8, of egging on behavior

worthy ofexpulsion from schoo1, not exhibited. This comment is deliberately directed against DOES 1-8, all minors, and communicated to [how many] third parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1-8 in their school their community, and the nation at large.

61. HABERMAN's communication injured DOES 1-8 as it disgraced and degraded the plaintiffs and held them up to public hatred, contempt, ridicule, and/or caused them to be shunned and avoided.

fully restated herein.

63. DOWD, known on Twitter as @matthewjdowd, published to approximately 137,000 third parties, without privilege "Folks, let us not let these kids, their parents and their school off the hook. Regardless of what led up to this, this is awful." A true and correct copy of said communication is attached hereto as Exhibit N. Dowd omitted the true facts, and instead implied the following facts were true in his statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to a Native American elder to taunt him. Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained ofherein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained ofherein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

PLAINTIFFS' COMPLAINTWITH JURY DEMAND - 20

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64. DOWD's communication was false and defaming as she accuses DOES 1-8, of awful behavior, not exhibited. This comment is deliberately directed against DOES 1-8, all minors, and communicated to 137,000 third parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1-8 in their school, their community, and the nation at large.

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66. DOES 1-8 reasserts and incorporates by reference paragraphs the other paragraphs ofthis Complaint as if fully restated herein.

65. DOWD's communication injured DOES 1-8 as it disgraced and degraded the plaintiffs and held them up to public hatred, contempt, ridicule, and/or caused them to be shunned and avoided.

SEVENTH CAUSE OF ACTION: DEFAMATION PER SE DOES 1-8 against REZA ASLAN

67. ASLAN, known on Twitter as @rezaaslan, published to approximately 289,000 third parties, without privilege "Honest question. Have you ever seen a more punchable face than this kid's?" A true and correct copy of said communication is attached hereto as Exhibit G. Asian omitted the true facts, and instead implied the following facts were true in his statements and the links attached thereto with the gist of the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to a Native American elder to taunt him. Each ofthe statements complained ofherein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained ofherein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained ofherein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

PLAINTIFFS' COMPLAINTWITH JURY DEMAND - 21

70. DOES 1-8 reasserts and incorporates by reference paragraphs the other paragraphs ofthis Complaint as if fully restated herein.

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71. ADAM EDELEN, a blue-checkmark-approved Twitter personality, retweeted an article with false factual statements about the Covington Boys, and validated the false factual claims ofthe article by referring to the kids as "outrageous and abhorrent behavior," that requires they "read a history book on how America's indigenous people have been treated," and that they "need to do some serious soul-searching." Edelen omitted the true facts, and instead implied the following facts were true in his statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to mock an elderly native American in the middle of an indigenous march. Each ofthe statements complained ofherein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phon calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were identified by photo image throughout the

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68. ASLAN's communication was false and defaming as he accuses DOES 1-8, of behavior deserving ofbein punched in the face, not exhibited. This comment is deliberately directed against DOES 1-8, all minors, and communicated to hundreds ofthousands ofthird parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1-8 in their school their community, and the nation at large.

69. ASLAN's communication injured DOES 1-8 as it disgraced and degraded the plaintiffs and held them up to public hatred, contempt, ridicule, and/or caused them to be shunned and avoided.

EIGHTH CAUSE OF ACTION: DEFAMATION PER SE DOES 1-8 against ADAM EDELEN

PLAINTIFFS' COMPLAINTWITH JURY DEMAND - 22

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72.

world, and each ofthe statements was interpreted by their friends, family and associates as about them personally.
EDELEN's communication was false and defaming as he accuses DOES 1-8, of engaging in outrageous conduct of threatening a native American elder. This comment is deliberately directed against DOES 1-8, all minors, and communicated to hundreds of thousands of third parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1-8 in their school, their community, and the nation at large.

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74.

73.

DOES 1-8 reasserts and incorporates by reference paragraphs the other paragraphs of this Complaint as if fully restated herein.
KRUSE, known on Twitter as @KevinMKruse, published to approximately 284,000 third parties, without privilege "No, the accusation was that this kid and his friends mocked an elderly Native American war veteran and, hey, they did. They also taunted women and shouted "it's not rape if you enjoy it" but sure, they're the real victims. According to his PR firm anyway." A true and correct copy of said communication is attached hereto as Exhibit P. Kruse omitted the true facts, and instead implied the following facts were true in his statements and the links attached thereto with the gist of the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of"build the wall" to mock an elderly native American in the middle of an indigenous march, and falsely accused the plaintiffs of threatening women with chants of"it's not rape if you enjoy it." Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were

NINTH CAUSE OF ACTION: DEFAMATION PER SE DOES 1-8 against KEVIN M. KRUSE

PLAINTIFFS' COMPLAINTWITH JURY DEMAND - 23

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identified by photo image throughout the world, and each of the statements was interpreted by their friends,

TENTH CAUSE OF ACTION: DEFAMATION PER SE DOES 1-8 against SHAUN KING

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77. DOES 1-8 reasserts and incorporates by reference paragraphs the other paragraphs of this Complaint as if fully restated herein.

family and associates as about them personally.
75. KRUSE's communication was false and defaming as he accuses DOES 1-8, of mocking a war veteran,

taunting women and making a statement about rape - none ofwhich were exhibited. This comment is deliberately directed against DOES 1-8, all minors, and communicated to [284,000] third parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion ofDOES 1-8 in their school, their community, and the nation at large.

76. KRUSE's communication injured DOES 1-8 as it disgraced and degraded the plaintiffs and held them up to public hatred, contempt, ridicule, and/or caused them to be shunned and avoided.

78. KING, known on Twitter as @shaunking, published to approximately 1.1 million third parties, without privilege "I am so deeply grieved and angry by this as young kids in MAGA hats surrounded and mocked a beloved Native American elder yesterday. When your power is centered in your whiteness, mocking others who are unlike you makes you feel strong. But it's weak. And despicable." A true and correct copy ofsaid communication is attached hereto as Exhibit C. King omitted the true facts, and instead implied the following facts were true in his statements and the links attached thereto with the gist of the false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to mock an elderly native American in the middle of an indigenous march, and falsely accused th plaintiffs of threatening women with chants of"it's not rape if you enjoy it." Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained ofherein

PLAINTIFFS' COMPLAINTWITH JURY DEMAND -24

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80. KING's communication injured DOES 1-8 as it disgraced and degraded the plaintiffs and held them up to public hatred, contempt, ridicule, and/or caused them to be shunned and avoided.

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that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject ofthe statements complained of herein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

79. KING's communication was false and defaming as he accuses DOES 1-8, of overt racism and taunting an weak and despicable behavior - none of which was exhibited. This comment is deliberately directed against DOES 1-8, all minors, and communicated to 1.1 million third parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1 8 in their school, their community, and the nation at large.

ELEVENTH CAUSE OF ACTION: DEFAMATION PER SE DOES 1-8 against CLARA JEFFERY

81. DOES 1-8 reasserts and incorporates by reference paragraphs the other paragraphs of this Complaint as if fully restated herein.

82. JEFFERY, known on Twitter as @ClaraJeffery, published to approximately 113,000 third parties, without privilege "The tapes that have emerged do show the BHI [Black Hebrew Israelites] doing their usual end- times ranting. But they also show the Covington Catholic kids: making cavemen gestures at BHI; tomahawk chanting at Natives; taunting random women; chants of "build the wall" and "it's not rape ifyou enjoy it." A true and correct copy of said communication is attached hereto as Exhibit 0. Jeffery omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a native American elder, with chants of "build the wall" to mock an elderly native American in the middle of an indigenous march, and falsely accused the plaintiffs of threatening women with chants of"it's not rape if

PLAINTIFFS' COMPLAINTWITH JURY DEMAND - 25

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84. JEFFERY's communication injured DOES 1-8 as it disgraced and degraded the plaintiffs and held them up to public hatred, contempt, ridicule, and/or caused them to be shunned and avoided.

you enjoy it." Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject of the statements complained of herein that they received death threats, hate mail, threatening phone calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

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83. JEFFERY's communication was false and defaming as she accuses DOES 1-8, ofa number of actions not exhibited: making caveman gestures, taunting random women, chanting "build the wall" and saying "it's not rape if you enjoy it." This comment is deliberately directed against DOES 1-8, all minors, and communicated to [how many] third parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1-8 in their school, their community, and the nation at large.

TWELFTH CAUSE OF ACTION: DEFAMATION PER SE DOES 1-8 against JODI JACOBSON

85. DOES 1-8 reasserts and incorporates by reference paragraphs the preceding paragraphs of this Complaint as if fully restated herein.

86. JACOBSON, the president and editor in chief of the website Rewire.News, authored an article published on Jan. 22, 2019 on Rewire.News titled "White-Washing White Supremacy: Media Rushes to Excuse Covington Catholic Students." A true and correct copy of said communication is attached hereto as Exhibit Q. Jacobson omitted the true facts, and instead implied the following facts were true in her statements and the links attached thereto with the gist ofthe false statements made about the plaintiffs was that the kids interrupted an indigenous march, stopped and blocked a Native American elder and Vietnam War veteran from continuous participation in that event, surrounded him in a threatening manner, and taunted him, as a

PLAINTIFFS' COMPLAINTWITH JURY DEMAND -26

87. JACOBSON'S communication was false and defaming as she accuses DOES 1-8, of a number of actions not exhibited: racism, being aggressive and disrespectful to Nathan Phillips, harassing young women, saying "it's not rape if you enjoy it." These comments were deliberately directed against DOES 1-8, all minors, and communicated to [how many] third parties without privilege, knowing DOES 1-8 were from Covington, Kentucky, with the intent to negatively influence the opinion of DOES 1-8 in their school, their community, and the nation at large.

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88. JACOBSON'S article went on to make false statements about Covington Catholic High School, including erroneously claiming that the school's students had worn blackface and body paint to caricature black students on the opposing team during basketball games.

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native American elder, with chants of"build the wall" to mock an elderly native American in the middle of an indigenous march, and falsely accused the plaintiffs ofthreatening women with chants of"it's not rape if you enjoy it." Each of the statements complained of herein was known by the friends, family and associates of each John Doe to be about them individually. Indeed, they were individually identified as the subject ofthe statements complained ofherein that they received death threats, hate mail, threatening phon calls, threatening emails, and other personal attacks on them each individually. They were known to be the subject of the statements complained of herein as they were identified by photo image throughout the world, and each of the statements was interpreted by their friends, family and associates as about them personally.

89. JACOBSON'S article injured DOES 1-8 as it disgraced and degraded the plaintiffs and held them up to public hatred, contempt, ridicule, and caused them to be shunned and avoided.

DAMAGES

90. False and Defamatory Accusations against the plaintiffs are defamatory per se, as they are libelous on their face without resort to additional facts, and as clearly demonstrated here, DOES 1-8 were subjected to public hatred, contempt, scorn, obloquy, and shame. The conduct ofthe plaintiffs, based on the false facts the defendants placed and circulated into the court of public opinion, led to these lifetime labels on these minors: "display of hate, disrespect and intolerance"; "heartbreaking"; "decency decayed"; "racist"; "cried

PLAINTIFFS' COMPLAINTWITH JURY DEMAND -27

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Respectfully submitted this 1st day of August, 2019.

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2400 Chamber Center Drive, Suite 200 P.O. Box 17534
Fort Mitchell, KY 41017
Attorney for Plaintiffs

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