See Nolan`s full complaint here
Transcription
See Nolan`s full complaint here
Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk CAMPBELL COUNTY CIRCUIT COURT COMMONWEALTH OF KENTUCKY Presiding Judge: HON. JULIE REINHARDT WARD (617222) Case No. 16-CI-____________ COMPLAINT AND JURY DEMAND Plaintiff Timothy Nolan (“Plaintiff”), alleges the following: Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000001 of 000016 ) ) TIMOTHY L. NOLAN ) ) PLAINTIFF, ) ) V. ) ) MICHAEL COMBS ) A/K/A “Mike T Wing Combs” ) 5 Fernwood Court ) Alexandria, KY 41001 ) ) HAROLD STEPHENS ) 12 Yellowwood Court ) Alexandria, KY 41001 ) ) KENNETH TURNER ) 577 Drycreek Rd. ) Cold Spring, KY 41076 ) ) TYLER OWEN ) 23 Retreat St. ) Southgate, KY 41017 ) THE GOP FACTS COMMITTEE, a general ) ) partnership and/or unincorporated association ) JOHN DOE 1-10, unknown general or limited ) ) partners of the GOP Facts Committee. ) ) JOHN DOE 11-20, anonymous speakers, ) DEFENDANTS. ) Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk JURISDICTION AND VENUE The Court can exercise personal jurisdiction over Defendants on the basis of Defendants’ presence in the State of Kentucky, and /or under KRS 454.210. The Court has jurisdiction over the subject matter of this action pursuant to K.R.S.23A.010 as this case is a justiciable cause of action not exclusively vested in another court and involves an actual controversy among the Parties. The amount in controversy, excluding interest, costs, and attorney’s fees, is equal or exceeds the jurisdictional requirement of this Court, and the amounts at issue exceed the jurisdictional limits of the District Court. Timothy Nolan lives in California, Kentucky, and is a resident of Campbell County. Defendant Michael Combs (“Combs”) resides in Campbell County, Kentucky. Defendant HARRY STEPHENS resides in Campbell County, Kentucky. Defendant KENNY TURNER resides in Campbell County, Kentucky. Defendant TYLER OWEN resides in Campbell County, Kentucky. Defendant THE GOP FACTS COMMITTEE is a general partnership and/or unincorporated association created by operation of the laws of the Commonwealth of Kentucky, and doing business in Campbell County and elsewhere in the state of Kentucky. Presiding Judge: HON. JULIE REINHARDT WARD (617222) PARTIES JOHN DOE 1-10 are unknown general or limited partners of the GOP FACTS COM : 000002 of 000016 COMMITTEE. 2 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk JOHN DOE 11-20 are anonymous speakers who upon information and belief published the defamatory statements detailed herein within the state of Kentucky, and/or who reside in the District. JURY DEMAND Plaintiff demands a trial by jury on all issues so triable. STATEMENT OF FACTS Plaintiff Timothy Nolan. Plaintiff was born and raised in Northern Kentucky as were several generations of both sides of his family. boxer. Plaintiff had dreamed of being a boxer, but was forbidden from doing so by his mother. Plaintiff focused on his studies instead. Plaintiff graduated from Covington Latin School, and earned his bachelors in philosophy and theology from Thomas Moore College. Plaintiff graduated from the Salmon P. Chase College of Law in 1973, and was admitted to practice law in Kentucky and Ohio that same year. Plaintiff settled in his current residence in 1980, and has lived there since that time with his wife, Julia, and their three children: Taunya, Tim II, and Tifany. Presiding Judge: HON. JULIE REINHARDT WARD (617222) Plaintiff had always admired his maternal grandfather who was a formidable bare-knuckle Plaintiff was as a public defender for Hamilton County during his first year as a practicing the Executive Director of the Legal Aid Society in Kentucky. In that position, Plaintiff was responsible for opening three offices for the Legal Aid Society of Northern Kentucky and became involved with the Community Action Commission, a 3 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000003 of 000016 attorney. After that first year, Plaintiff was hired as an assistant law professor at Chase, and Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk federal agency which focused on providing legal representation to indigent persons of all races. Plaintiff also worked with Head Start, which offers a preschool program devoted primarily to helping African American and other disadvantaged children succeed in school. Plaintiff also brought and prevailed in a class action suit against the Newport Board of Education that resulted in a modification of board policy, and which had a disparate impact on African American families among others. Since 1970, Plaintiff has been a member in good standing of the Knights of Columbus, a Catholic charitable organization which helps the disabled. Plaintiff has never been a member of the Ku Klux Klan, (the “KKK”), much less is he the to helping indigent persons of all races. Sometime in 1975, Plaintiff established the Hamilton County Legal Assistance Corporation, whose mission was to provide legal assistance to juvenile offenders in Cincinnati Ohio. Plaintiff went on to become the Newport City Solicitor in 1976. In 1978, Plaintiff was elected as a district court judge for Campbell County, a position that he kept through 1986. Thereafter, Plaintiff went into private practice, but had to retire in 1999 after being diagnosed with a pituitary brain tumor. His symptoms include depression and anxiety, for which he is Presiding Judge: HON. JULIE REINHARDT WARD (617222) leader of a chapter of that organization. On the contrary, Plaintiff’s legal career was devoted Since then, Plaintiff has kept busy with real estate ventures and local politics. Plaintiff continues to live in the family home in California, Kentucky. 4 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000004 of 000016 being treated by medical professionals. Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk Normal Activities Throughout his career to the present, Plaintiff has remained active in the Northern Kentucky community, both politically and socially. Plaintiff is an active member of Republican Party of Kentucky. (The “RPK”). Plaintiff has served as the campaign chairman for his daughter who was elected Campbell County Circuit Court Clerk in 2010, and has furthermore spearheaded single-issue campaigns at the school board, county and state level. Plaintiff is currently involved in the fight against the heroin epidemic. Sometime in late 2015 or early 2016, Governor Matt Bevin’s Administration (the “Bevin Boxing and Wrestling Commission (the “Commission”). The Bevin Administration offered to appoint Plaintiff to the Commission. Plaintiff was eager to participate as a Commissioner, and the discussions renewed Plaintiff’s love and interest in boxing. Plaintiff began exploring the steps that he could take as a Commissioner to expand commercial opportunities for boxing, and mixed martial arts in the Northern Kentucky region. On May 17, 2016, Bevin announced the names of the appointed members of the Kentucky Boxing and Wrestling Commission, which included Plaintiff. Presiding Judge: HON. JULIE REINHARDT WARD (617222) Administration”), approached Plaintiff about the Bevin’s plan to reform the Kentucky Defendant Combs Combs has served as a board member for the Campbell County School System, and has been active in the RPK. Plaintiff and Combs have been acquainted with each other for about two decades. 5 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000005 of 000016 Combs, like Plaintiff has been politically active in the region for some time. Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk Plaintiff has had occasion to oppose Combs on various issues, including Combs’s candidacy for County Commissioner, the organizational workings of the RPK, Campbell County School Board issues, and other political and other regional issues, including a contentious campaigns surrounding tax increase plans proposed by Campbell County, and the Campbell County School Board, respectively. Sometime in the early 2000’s, the pair had an altercation at the annual Campbell County fair. An anonymous speaker, who is believed to be associated with Combs and the other Defendants, and who is known on the whistleblower-newswire.com website as the “Bluegrass Bureau Chief Ken CamBoo” posted a picture on that site which depicted an accompanying the Picture stated: ALSO IN NORTHERN KENTUCKY: Bluegrass Bureau Chief Ken CamBoo says this picture was posted on Facebook and then taken off, according to his source. It was taken at the Rabbit Hole. A bar in southern Campbell County and supposedly owned by former Judge Tim Nolan, is the father of Court Clerk Taunya Jack Nolan. Everybody’s wondering if this is a new form of Campbell County political fund raising for Nolan’s kid and those he is backing in 2014. Or maybe it’s his version of the new door-to-door campaign uniform. Attached hereto as Exhibit A, (the “Whistleblower Posting”); also available at: http://whistleblower-newswire.com/2013/11/10/ (as of the date of this writing). Presiding Judge: HON. JULIE REINHARDT WARD (617222) unidentified person wearing a Ku Klux Klan robe and hood. (the “Picture”). The caption purportedly because they were “appalled by … the recent coup attempt by some Republicans and Tea Party leaders to oust Republican leadership in Campbell County.” At that time, the 6 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000006 of 000016 In September 2014, Combs and some of his associates formed the “GOP Facts Committee” Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk stated purpose of the Committee was to “dispel misinformation from those who tried to expel party leaders in Campbell County.” Sometime in 2015, Combs and his associates launched the website known as “GOP Facts.” The home page of the website states that the site: … has been created to make the FACTS known to members of the GOP which have been innundated [sic] with falsehoods, untruths, half truths, rumors and all forms of deception regarding the motivations of members of the Tea Party as well as candidates and elected officials. Below you will find a series of buttons that link [sic] to information pertaining to the button title. Some are individuals, some are situations and issues. Attached hereto as Exhibit B, (the “Homepage”); also available at: http://gopfacts.org/ (as of The mission statement page for the Website furthermore states in part that : “…We cannot risk a compounding of economic decline because of the political gang actions of a few… We have too much at stake to remain silent and more important we have too much respect for our neighbors and friends to have to tolerate these bully attacks anymore.” (the “Mission Statement Webpage.” See Exhibit C. The Mission Statement Webpage identifies Combs as: “Mike Combs Campbell County citizen, business owner and chairman, GOP Facts committee.” The contents of the Website reveal that in furtherance of its mission, the GOP Facts Presiding Judge: HON. JULIE REINHARDT WARD (617222) the date of this writing). Committee targets politically active Northern Kentucky residents who support individuals, support violates the “loyalty pledge” contained in the preamble of the rules of the RPK. Such targeted individuals are designated by a red star on the Homepage and have pages devoted to what the Committee alleges are acts of disloyalty. The names of three such 7 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000007 of 000016 or candidates that are opposed to those supported by the Committee on the grounds that such Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk individuals were prominently posted on the Homepage from time to time since the launching of the website. Defamatory Publication Upon information and belief, the Committee reposted the picture that had been posted on the Whistleblower site, in early 2016, with the following caption: Here is a picture taken right off of Timmy Boy's Facebook page, with Tim in full Klan regalia trying to recruit people to join the Klan at the bar that he owns in Southern Campbell County. The real question is how could they possiby [sic] make any profit with Timmy guzzling down all the stock? Attached as Exhibit E is a copy of the page posted about Plaintiff on the Website (the “Nolan Page”); also available at: http://www.gopfacts.org/nolan.htm (as of the date of this writing). Sometime in early March 2016, Plaintiff was appointed as the Chair of the Campbell County Trump Campaign. Plaintiff was also involved in the RPK’s selection process for state delegates chosen to cast their votes for the presidential candidate at the Republican National Convention, which is to be held in July 2016. Presiding Judge: HON. JULIE REINHARDT WARD (617222) It has come to our attention here at GOPFacts that washed up Judge and racist Tim Nolan will be serving as a representative for Presidential candidate Donald Trump at the March 5th Caucus in Campbell County. One has to wonder if The Donald knows that he is about to be represented by one of Campbell County's most vehement racists. As part of that process, Plaintiff actively participated in opposing the slate of delegates that and was named as one of the 15 delegates who were to proceed to the delegate convention for the 4th Congressional District that was held sometime in April 2016. (The “4th District Convention”). 8 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000008 of 000016 Combs supported at the Campbell County level. Plaintiff was successful in his opposition Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk During that time, Combs and the other Defendants began publicizing the Nolan Page, and/or circulating the Picture via email to a number of prominent RPK members, including but not limited to the chairman of the Kentucky Trump Campaign. Plaintiff is not the person pictured in “full Klan regalia,” nor has he ever tried to recruit people to join the KKK. Plaintiff was unaware that Combs and other Defendants were advancing the defamatory campaign within the RPK, until he was approached by a well-respected African American member of the Republican Party at the 4th District Convention. That individual pulled Plaintiff aside, told him about having received a disturbing email from or a racist. Plaintiff assured the individual that he was not a member of the KKK or a racist. A few days later, Plaintiff’s friend alerted Plaintiff that Turner had sent the Picture to third parties and that the issue was becoming a controversy in other areas of Plaintiff’s life. Plaintiff was further notified about the publications by the Trump Campaign and others who had received emails that provided the Picture and other defamatory statements. Plaintiff had to speak with the Trump Campaign to assure them that he was not a racist, nor had he ever been associated with the KKK. Plaintiff was able to retain his position as chair of with the Presiding Judge: HON. JULIE REINHARDT WARD (617222) Combs and/or his associates, and asked Plaintiff whether he was a member of the KKK and/ On May 17, 2016, Governor Matt Bevin announced the reformation of the Kentucky Boxing and Wrestling Commission, and designated Plaintiff as an appointee to that board. Plaintiff 9 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000009 of 000016 Trump Campaign. Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk was humbled and honored for the appointment and was looking forward to promoting the sports and making them safer for all participants. Upon hearing the news, Combs and other Defendants again began publicizing the post to stop the appointment of Plaintiff to the Commission by sending emails to Governor Bevin, Bevin Administration employees, and others. Shortly thereafter, Brett Gaspard, the Executive Director of Boards and Commissions for the Bevin administration, reached out to Plaintiff to ask him about the picture. Again, Plaintiff had to assure Gaspard that he was not or had ever been a member of the KKK or a racist. that one of its appointees was associated with the KKK and requested that Plaintiff not use social media. Plaintiff assured Gaspard that he was not a member of the KKK or a racists, and that he did not have a problem with taking down his Facebook profile. A short time later, Gaspard relayed to Plaintiff Governor Bevin’s preference that Plaintiff decline the appointment and asked that Plaintiff do so. Plaintiff refused to succumb to Defendants’ smear campaign and tried to reassure Gaspard that the statements were fabrications that were being proffered to destroy his reputation. Gaspard then told Plaintiff that he would get back to him regarding the Bevin Presiding Judge: HON. JULIE REINHARDT WARD (617222) Gaspard warned Plaintiff that the Bevin Administration would not tolerate the perception Other effects of the publication. Starting in about 2009, Plaintiff’s wife was diagnosed with cancer and became seriously ill. Plaintiff was the person primarily responsible for her care while her physical condition was 10 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000010 of 000016 Administration’s final position on the issue. Plaintiff never heard back from Gaspard. Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk deteriorating. Plaintiff took care of the home and provided emotional support for his wife of 49 years. By March 2016, Plaintiff’s wife saw the defamatory statements and over time because significantly distraught. In addition to the significant concerns that the pair faced with her imminent death, Plaintiff had to devote significant efforts to alleviate her concerns and severe emotional distress; all of which exacerbated his anxiety over his wife’s conditions and increased the toll that they were taking on the family. After a seven year battle with cancer, Plaintiff’s wife, passed away on March 17, 2016, in the midst of Defendants’ attack on Plaintiff’s character. Commission during which time he and his fellow appointees were to be formally sworn in as commissioners. About 10 minutes prior to the start of the meeting, Plaintiff was approached by a lawyer who told him that Governor Bevin had rescinded the appointment – that Plaintiff would not be serving on the Commission. Plaintiff remains intent on pursuing his passion for boxing and other western martial arts as a promoter, and has taken steps to license and launch a boxing and mixed martial arts promotion company. Plaintiff is concerned about the effect that Defendants’ accusations of Presiding Judge: HON. JULIE REINHARDT WARD (617222) On May 20, 2016, Plaintiff drove to Frankfort, Kentucky, to attend the first meeting of the racism will have on his ability to successfully participate in a marketplace that is enthusiasts. As of the date of this writing, Plaintiff has been forced to have uncomfortable discussions about the issue with newly acquainted colleagues and entrepreneurs in the boxing world, 11 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000011 of 000016 predominated by African American athletes, trainers, agents, promoters, and boxing Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk who unlike his longtime friends do not have sufficient experience with Plaintiff to know that he is not a racist, or a member of the KKK. Plaintiff cannot move forward absent judicial relief. COUNT I – DEFAMATION Plaintiff repeats and re-alleges paragraphs 1 through 69 as if fully restated hereunder. Defendants published, by and through the Website, web postings, emails, instant messaging, social media postings, and/or in-person or telephonic conversations, the false statement that Plaintiff is a member of the KKK, and “one of Campbell County’s most vehement racists ….[who] is attempting to recruit people to join the Klan…” Defendant’s statements were and remain false as Plaintiff has never been, nor is he currently a member of the KKK, nor is he an alcoholic, nor is he a racist. Defendants knew that Plaintiff was neither a racists nor an alcoholic, and acted with the malicious intent of causing the recipients of the publication to believe that Plaintiff is a vehement racist, an active member of the KKK responsible for the recruitment of new members to the organization, and an alcoholic. The recipients of the defamatory statement reasonably understood the defamatory statements to mean that Plaintiff is a virulent racist, an active member of the KKK responsible for the Presiding Judge: HON. JULIE REINHARDT WARD (617222) The Defamatory statements further implied that Plaintiff is an alcoholic. Defendants cannot claim that the statements were incapable of bearing a defamatory meaning because, on their face, the defamatory statements can reasonably be understood by any 12 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000012 of 000016 recruitment of new members, and an alcoholic. Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk recipient that they were based on facts undisclosed by Defendants concerning Plaintiff’s affiliation with the KKK, racist viewpoints and/or alcoholism. Nor could Defendants reasonably believe that defaming Plaintiff was necessary to accomplish any legitimate end. Defendants maliciously intended to damage Plaintiff’s political reputation, bring Plaintiff into public hatred, contempt, or ridicule. Indeed, the statements caused Plaintiff to be shunned and avoided by the Bevin Administration, thereby impairing Plaintiff’s political activities and depriving him of the ability to participate in his lifelong passion for western martial arts. published the defamatory statements with the improper objective of harming Plaintiff’s reputation within the community, the RPK, and Campbell County in general. COUNT II – TORTIOUS INTERFERENCE WITH A BUSINESS EXPECTANCY Plaintiff repeats and re-alleges paragraphs 1 through 79 as if fully restated hereunder. Plaintiff had a valid expectancy of being appointed to Kentucky Boxing and Wrestling Commission by Governor Bevin. Defendants were aware of Plaintiff’s expectancy as the forthcoming appointment was well publicized; and Defendants were monitoring Plaintiff’s political and social activities. Presiding Judge: HON. JULIE REINHARDT WARD (617222) Defendants furthermore with wanton abandonment and reckless disregard for the truth, defamatory statements directly to members of the Bevin Administration, the Trump Campaign, and the Campbell County community and were motivated to harm his reputation and impair his political and business activities. 13 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000013 of 000016 Defendants intentionally interfered with the anticipated appointment by publishing Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk Defendants’ action led to the rescission of the expected appointment 10 minutes before it was scheduled to occur. Plaintiff was forced to endure the embarrassment and the very public humiliation of having been rejected by the Bevin administration. Defendants’ defamatory statements are interfering with Plaintiff’s ability to function normally as a boxing promoter because that particular marketplace is dominated by African American athletes, trainers, agents and promoters, who will likely take a dim view on doing business with a person who is alleged to be a member of the KKK. COUNT III – CIVIL CONSPIRACY Together Defendants, individually or as partners of the GOP Committee, arrived at and agreed to acting in concert to achieve a plan of harming Plaintiff’s reputation, or otherwise impairing his political activities by the use of defamatory statements. Defendants took concerted and separate actions, which when combined together are sufficient to establish that they furthered the achievement of their mutual objective of defaming Plaintiff in the eyes of the Trump Campaign, the Bevin Administration, the RPK, and his community. Defendants furthermore achieved their objective by creating doubts in the minds of both the Presiding Judge: HON. JULIE REINHARDT WARD (617222) Plaintiff repeats and re-alleges paragraphs 1 through 86 as if fully restated hereunder. Bevin Administration and the Trump campaign, representatives of which expressed their Wrestling Commission, and as a Chair for the Trump Campaign, respectively. As a result of the publication and the adverse reaction by the recipients thereof, Plaintiff was not appointed to the Commission after having been nominated for the appointment. Plaintiff 14 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk COM : 000014 of 000016 concerns about Plaintiff’s fitness to serve as a commissioner on the Kentucky Boxing and Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk was also forced into the uncomfortable position of having to deny the spurious allegations of racism to the Trump Campaign. DIRECT AND SPECIAL DAMAGES Plaintiff repeats and re-alleges paragraphs 1 through 91 as if fully restated hereunder. As a result of: (a) Defendants having maliciously, intentionally and recklessly published a untrue and defamatory statement about Plaintiff; (b) tortious interference with his expectancy of being appointed to the Kentucky Boxing and Wrestling Commission; and (c) engaging in a civil conspiracy to damage Plaintiff’s reputation and standing in the community; Plaintiff: (i) has suffered irreparable harm to his reputation with the RPK and the Bevin impacted Plaintiff’s ability to pursue his community, business, and political activities; (ii) has suffered and continues to suffer severe emotional distress, which has exacerbated his medical conditions and the emotional pain and suffering experienced by Plaintiff’s terminally ill wife in the final days of her life; (iii) has been forced to endure the embarrassment and the very public humiliation of having been rejected by the Bevin Administration; (iv) has had his reputation tarnished, which has and will in the future preclude him from Presiding Judge: HON. JULIE REINHARDT WARD (617222) Administration, and to his standing in the community, which has negatively fully engaging in political and social activities. COM : 000015 of 000016 WHEREFORE, Plaintiff respectfully requests and prays that this Court, sitting in equity and at law, enter a judgment: 15 Filed 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk Filed 16-CI-00522 (i) 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk Preliminarily enjoining Defendants from posting, publishing or otherwise disseminating to third parties, the Picture and the defamatory statements identified herein on the Website, by email, on social media, or elsewhere; (ii) Finding Defendants jointly and severally liable for defamation; (iii) Finding Defendants jointly and severally liable for the tort of civil conspiracy; (iv) Permanently enjoining Defendants from posting, publishing, or otherwise disseminating to any third parties, the Picture and the defamatory statements identified herein verbally, by use of the Website, by email, social media, or otherwise. Awarding Plaintiff $250,000.00 as compensation for the damage to Plaintiff’ reputation, loss of income and business opportunities, and the pain and suffering that resulted from Defendants’ actions; (vi) Awarding Plaintiff punitive damages; and (vii) Awarding reasonable attorney fees and the costs of bringing this action; and (viii) Awarding any other relief that the Court deems just and equitable given the circumstances. Respectfully submitted /s/ J. Christian Dennery J. Christian Dennery, Esq. (KBA 95878) COM : 000016 of 000016 P.O. Box 121241 Covington, KY 41012 Tel: (859) 445-5495 Fax: (859) 286-6726 jcdennery@dennerypllc.com Date: Friday, June 10, 2016 16 Filed 16-CI-00522 06/10/2016 Presiding Judge: HON. JULIE REINHARDT WARD (617222) (v) Taunya Nolan Jack, Campbell Circuit Clerk Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire EXHIBIT A DAILY ARCHIVES: NOVEMBER 10, 2013 Sunday, November 10, 2013 The Whistleblower Week in Review OUR NUMBER ONE “TOTALLY INSINCERE APOLOGY IN AMEICAN HISTORY” THIS WEEK WAS when President Clinton apologized to the nation for lying about having sex with Monica EXH : 000001 of 000021 Presiding Judge: HON. JULIE REINHARDT WARD (617222) Lewinsky OUR NUMBER TWO “TOTALLY INSINCERE APOLOGY IN AMEICAN HISTORY” THIS WEEK WAS Jimmy Swaggart apologized to God after he was caught in a sex scandal with a prostitute. Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 1/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire Presiding Judge: HON. JULIE REINHARDT WARD (617222) I HAVE SINNED AND OUR NUMBER THREE “ANTI-OBAMACARE VIDEO” THIS WEEK WAS Obama admitted he’s EXH : 000002 of 000021 a Liar and sort-of apologized for Lying About ObamaCare! Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 2/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire MONDAY in our Special “Indecision 2013” E-dition, The Blower said, “This Year’s Long Noxious Nightmare Is Almost Over!” We Won’t Endorse…. by Charles Foster Kane Beloved Whistleblower Publisher Before every election, The Whistleblower is always deluged with calls, faxes, text messages, and e-mails asking which candidates and issues we plan to endorse. As the o䎩쟠cial publication for all that scrambling, speculation, mudslinging, and back-stabbing which will be forever known as Indecision 2013, our readers have every right to expect nothing less. But the fact that only one day before the elections, after all of our penetrating reporting and scathing commentary, there can be any doubt about which candidates or issues we might cheer or jeer is Presiding Judge: HON. JULIE REINHARDT WARD (617222) further tribute to the astounding even-handedness of our always fair-and-balanced journalism. [READ MORE HERE] TUESDAY in our O䎩쟠cial “Election Day Debacle” E-dition, The Blower asked, “Which candidates were we supposed to vote for anyway?” and our “Real E-Mails from Real EXH : 000003 of 000021 Subscribers” included: Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 3/21 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire Presiding Judge: HON. JULIE REINHARDT WARD (617222) Filed 6/7/2016 With his latest poll numbers in the crapper, I bet Obama’s glad Election Day tomorrow is not a doEXH : 000004 of 000021 over of the 2012 elections. — Whistleblower Senior National Political A䎰뵠airs Analyst Britt Humus Almost as glad as we are that tomorrow isn’t early voting for the Mid-term elections in 2014.— Harry Reid and his Disingenuous DemocRATS in the Senate Thankfully we’ll still have 1,172 days left to cover during the Dark Ages of Obama’s Second Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 4/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire Term (unless he’s impeached). —Obama Supporters in the Press How pathetic was it when we said “Obama only misspoke” when he lied about keeping your health insurance? —New York Times [READ MORE HERE] WEDNESDAY in our Special “Twenty-First Anniversary Edition” E-dition (1992-2013), The Blower reported, “Fraud at the Polls” We’re Still Staying Around : The Whistleblower Newswire came out of retirement twenty-one years ago on the day after Election Day in 1992 following our decision to suspend publication a year earlier. Hurley the Historian says we had to return. Our November 5, 1991 Edition # 75 of the original Whistleblower print edition was supposed to Presiding Judge: HON. JULIE REINHARDT WARD (617222) be our ñnal edition. But after witnessing an endless barrage of biased reporting and the unmitigated mess the news media made of Campaign ’92, the results of that year’s elections were not all that surprising. Voters in ’92, 95% of whom learned all they knew by watching daily distortions on local and national TV newscasts, sent to the White House, a draft-dodging, tax-evading, dope-smoking, pants-dropping, wife-cheating liar whom The Blower predicted would surely drag this nation down to the level of Arkansas. America got a leader it truly deserved— more arrogant than JFK, fewer scruples than LBJ, and rivaling the Carter-Mondale administration for sheer stupidity. [READ MORE HERE] EXH : 000005 of 000021 THURSDAY, in our Special “Post-Election Gloating” E-dition, The Blower said, “We Told You So!” Make ‘Em Eat Crow! Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 5/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire Is it over? Have the people 䎟往nally spoken? Every Election Day, fewer people of interest show up at the Board of Elections on Election Night. This year the food was so bad, the homeless sent it back. Maybe it was all that crow being served. Whistleblower Senior National Political A䎰뵠airs Analyst Britt Humus says now with only 362 more days until the 2014 Elections, Political Pundits are trying to 䎟往gure out what Tuesday’s o䎰뵠-year elections imply for next year’s races. Presiding Judge: HON. JULIE REINHARDT WARD (617222) For one thing, Exit Polling in Virginia shows ObamaCare lost. Vulnerable DemocRATS must have watched in dismay as DemocRAT Terry McAuli䎰뵠e barely clung to victory on Tuesday. The TEA Party gubernatorial candidate was way behind in the weeks leading up to the election, yet closed phenomenally in the last two weeks because of ObamaCare, despite not having Republican leadership behind him, being massively outspent, and an Obama bundler funding the “libertarian” who siphoned o䎰뵠 at least 5% points. Defenseles DemocRATS should now see what ObamaCare can do to their races in 2014. Plus, Gallup says Obama’s Approval has now dropped to 39% in Gallup as Obama Supporters in the Press continue to struggle to explain his lies. Maybe that’s why Obama will be skipping the 150th anniversary of the Gettysburg Address on November 19, because he disagrees with Abe Lincoln´s claim that you can´t fool all of the people all of the time. EXH : 000006 of 000021 [READ MORE HERE] FRIDAY, in our Special “Post-Election Analysis” E-dition, The Blower asked, “Do Cincinnati Voters Now Have a Government They Truly Deserve?” Waiting for Foxy Roxy’s Supporters to Demand a Recount Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 6/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire At today’s meeting of the Conservative Agenda, Political Insiders were asking Beloved Whistleblower Publisher Charles Foster Kane why all those Foxy Roxy Liberals and The Fishwrap are suddenly going bonkers, just because the 䎟往rst thing Diminutive DemocRAT John Cranley did after being elected Mayor of Cincinnati was to pronounce Dainty DemocRAT Mayor Mark Mallory’s Trolley Folly dead in its tracks. “Actually keeping a campaign promise is indeed rare these days,” Kane explained, “but the really unbelievable part of that story is…that campaign promise keeping politician turned out to be a DemocRAT. Maybe that’s why our Quote for Today Committee chose Bernard Baruch’s “Vote for the man who promises least. He’ll be the least disappointing.” And Hurley the Historian says on this date in 1994, for the 䎟往rst time in 40 years, the Presiding Judge: HON. JULIE REINHARDT WARD (617222) Republican Party under the leadership of Newt Gingrich won control of both the U.S. House of Representatives and the Senate in midterm Congressional elections, but until Republicans stop sending RINOs to Washington and elect a Conservative President, America will continue o䎰뵠 course toward the abyss. [READ MORE HERE] SATURDAY in our Special “Saturday Morning Quarterback” E-dition, The Blower reported, “More Hindsight and Second-Guessing! EXH : 000007 of 000021 Sensible Suggestions Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 7/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire Tired OverTaxed Payer Tino Delgato says, “Unfortunately the majority now consists of those who do not pay taxes and are on one or more government entitlement or welfare programs. If Obama gets all those illegal Presiding Judge: HON. JULIE REINHARDT WARD (617222) immigrants citizenship he’ll have further increased that majority, except for the ones who already vote. The government will be run by those who do not pay taxes and like Obama have never had a real job. Remember the old saying circa 1776 “no taxation without representation.” It is back. Go Figure!!! Romney was really right about the 47% Thomas Jeöerson would’ve agreed, when he said, “The democracy will cease to exist when you take away from those who are willing to work and give to those who would not.” Our Good Friend Bobby Leach says we should start working to repeal the 19th Amendment (the one giving women the right to vote) and test all male o䎰뵠spring for excess levels of estrogen in their systems. After watching John Boehner, Bitch McConnell, and the RINOs in Congress these days, it looks like treatment needs to begin immediately Also, this just in from our Portly Pundit: The TEA Party is right. The GOP needs to stick to their values and pick better candidates, not that all those Dumbed-Down, Self-Absorbed, Media-In䎣艀uenced, Celebrity-Obsessed, Politically-Correct, Uninformed, Short-Attention- EXH : 000008 of 000021 Span, Free-Stu䎰뵠 Grabbing, Low-Information Obama supporters would ever notice the di䎰뵠erence. [READ MORE HERE] THE SEEDIEST KIDS OF ALL Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 8/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire Although our campaign is not associated with the Failed United Way, your liberal guilt giving throughout the year still makes it all possible. SEEDIEST KIDS OF ALL HOT LINE Presiding Judge: HON. JULIE REINHARDT WARD (617222) e-mail your stories about worthy waifs today. OBAMA-CARRION HEADLINES EXH : 000009 of 000021 (WE’RE PICKING THE BONES CLEAN) OBAMACARE UPDATES: 52 Million Americans Have Or Will Lose Their Health Insurance Because of ObamaCare… Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 9/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire OBAMACARE RIDICULED: Jon Stewart Is Not Done With ObamaCare, Even As The Comedy Central Comedian Scorches Obama’s “Total Ignorance On Scandals.” SILLY SEBELIUS: Obama Now Refuses To Say If He Has Con䎟往dence In Kathleen Sebelius… Who Says “If We Delay ObamaCare People Will Die Of Cancer Or Diabetes” OBAMACARE SIDE EFFECTS: Loyal Obama Supporters Lose Their Insurance As WSJ Reports ObamaCare Enrollees “Older Than Expected”… OBAMA-CORRUPTION: Firm Tied To Obama Won $100K No-Bid Contract To Design Mooch’s “Let’s Move” Logo… COUNTING OBAMA’S LIES: Video shows 36 Times Obama Promised You Could Keep Your Plan If You Liked It… OBAMA’S POLITICAL PRIORITIES: Obama Working Hard Trying To Solve ObamaCare Issues… By Lolling Around In Florida At Three Fundraisers. GOP STRATERGY: House Oversight Committee Chairman Darrell Issa Has Issued A Subpoena To Top Obama Administration Technology O䎩쟠cial Todd Park Requiring Him To Testify At A Hearing On The Bumpy ObamaCare Rollout On Wednesday. Presiding Judge: HON. JULIE REINHARDT WARD (617222) MORE OBAMANATIONS HEADLINES OBAMA SCANDAL UPDATE: Obama Admin Awards More Contracts To Company That Built Healthcare.Gov OBAMA’S ORGANIZING FOR ACTION PAC’S Excuse On Why Individual Health Plans Are Being Cancelled: 62% Didn’t O䎰뵠er Maternity Care – Reality: 81% Of The Population Can’t Get Pregnant… MORE THREATS AND INTIMIDATION: Blue Cross Blue Shield Says Obama Regime Told Them Not To Release ObamaCare Enrollment Numbers… OBAMANOMICS 101: Number Of Americans Not In The Labor Force Climbs To Another Record High In October: 91,541,000 As Real Unemployment Jumps To 13.8% In October… OBAMA’S FOREIGN POLICY SUCCESSES: Netanyahu Slams Obama’s “Very, Very Bad Deal” With Iran… MILITARY MADNESS: Veteran Who Lost Hand And Legs In Combat Gets Bill From Veteran’s A䎰뵠airs OBAMA’S WHITE HOUSE SPOKES DWEEB JAY CARDBOARD Admits ObamaCare Website Still EXH : 000010 of 000021 Won’t Work Properly After November 30th Deadline… OUR LATE NIGHT JOKE WATCHER liked Jay Leno’s “President Obama Saw Gravity Today. Not The Film, His Poll Numbers. Not Good!” For Some Reason, Obama’s Popularity Numbers Are Lower Than Those Of Toronto Mayor Rob Ford, So Leno Suggested The President Would Be “Better O䎰뵠 Smoking Crack Than Passing ObamaCare!” He Also Mocked The President’s New Big “IF” About ObamaCare, Saying “He’s Such A Good Speaker, He Almost Believed It Himself. And Then His Pants Caught Fire!” Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire FLASHBACK FUN: Obama Advisor Valerie Jarrett’s 1996 Collectivist “It Takes A Village” Speech THE LATEST POLLS: Only 37% Approve Of Obama’s Handling Of ObamaCare, 59% Disapprove, Down 20 Points Since January SPIES LIKE US: Army Gen. Keith Alexander, Presiding Judge: HON. JULIE REINHARDT WARD (617222) Director Of The National Security Agency, Defended His Agency, Saying What His Sta䎰뵠 Does “Is Bring Back More U.S. Soldiers, Airmen And Marines” Alive From Dangerous Postings. MISTEROBAMA’S AMERICA HEADLINES EXH : 000011 of 000021 HEADLINES ACROSS AMERICA: Washington Post Doubts Sincerity Of The Obama “Apology” After White House Refuses To Say If Obama Regrets His Broken “Keep Your Plan” Promise… DISHONEST DEMOCRATS: Amazingly, Not A Single Democrat In Congress Reportred To Prison Since Jesse Jackson, Jr. Reported To The Facility In North Carolina Last Week. MORE FREE STUFF: GOP Gov. Bobby Jindal Moves To Strip Food Stamp Bene䎟往ts From Welfare Leeches Who Stripped Walmart Shelves Clean, Even As Welfare Leeches Openly Selling Their EBT Cards On Craigslist, Other Social Media Sites… Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 11/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire DEMOCRAT FAMILY VALUES: Dem Sen. Joe Donnelly Complains To White House His Son’s Health Insurance Was Cancelled Because Of ObamaCare… POLITICS AS USUAL: Vulnerable 2014 Democrats Unload On Obama Presiding Judge: HON. JULIE REINHARDT WARD (617222) RACIAL HEALING UPDATES: Libs Cry Racism After Country Music Awards Mocks ObamaCare… GAY NEWS UPDATE: Obama Says He’s “Overjoyed” Illinois Will Allow Gay Marriage… DELUSIONAL DEMOCRATS: Obama’s Top Economic Adviser: ObamaCare Responsible For De䎟往cit Reduction, Not Sequester Cuts… SENILE IN THE SENATE: Harry Reid Claims TEA Party “Anarchists Have Taken Over” Congress… JOE BIDEN JUST BEING HIMSELF: Biden Calls The Wrong Marty Walsh…For The Second Time! MOONBAT MANIACS: Tom Cruise Says My Job Acting Is As Grueling As Ighting In Afghanistan. TEA PARTY TERRORISTS: Dem Senate Candidate Compares Tea Party Actions During Shutdown To Al-Qaeda Terrorists Carrying Out 9/11… OUR DEVOLVING CULTURE DURING THE AGE OF OBAMA: Florida School District Suspends Teacher For Requiring Students Place Hand Over Their Hearts During Pledge Of Allegiance… EXH : 000012 of 000021 LIBERAL AGENDA HEADLINES MEDIA MENDACITY: PMSNBC’s Chris Matthews Implies Elephantine New Jersey Governor Chris Christie Crushes His Wife During Sex… MURDERING MUSLIM UPDATE: Iowa Islamic Leader Wants Sexual Abuse Charges Dropped Because It Violates His Religious Freedom… Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 12/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire AMNESTY FOR FUTURE DEMOCRATS: Obama’s Approval Rating Among Hispanics Drops To Lowest Level Since 2011, 49%… BABY KILLING UPDATE: NYC Mayor-Elect Bill De Blasio Pledges To Open More Abortion Clinics GLOBAL WARMING: John Kerry Is “Amazed” That Some Presiding Judge: HON. JULIE REINHARDT WARD (617222) Americans Still Don’t Grasp Urgency Of Global Warming… GUNCONTROL: NRA Beat Nanny Bloomberg’s AntiGun Group In 65 Of 67 Virginia House Races. UNION BLUES: Obama Gives Back Door Pay-O䎰뵠 To Unions Angry Over ObamaCare SCALPING THE REDSKINS: Minneapolis Dem Mayor Calls For Boycotting Redskins Over “Derogatory” Name…After Crackhead D.C. Councilman Marion Barry Calls Redskins Name “Despicable,” An “A䎰뵠ront To All Americans”… MORE POLITICAL CORRECTNESS: Washington University Muslim Group Says Student’s Osama Bin Laden Halloween Costume Is O䎰뵠ensive To Muslims…As UC Berkeley Bans Term “Illegal Immigrant” After Students Hold “Drop The I-Word Campaign”… EXH : 000013 of 000021 LIBERAL BRAINWASHING: Planned Parenthood Wants To Teach Preschoolers About Having Sex…As Common Core Sneaks Liberal Politics Into Elementary School Classrooms… TIME OUT FOR SOMETHING PATRIOTIC: Seven First-Class Passengers Give Up Their Seats To Marines Returning From Afghanistan… MORE DUMBED DOWN DIVERSITY: Pro-ObamaCare Group Providing $500K Grant To Get Hollywood To Write ObamaCare Propaganda Into Story Lines… Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 13/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire HEADLINES CLOSER TO HOME IN CINCINNATI: The City continued to piss away lots of money on Dainty DemocRAT Mayor Mark Mallory’s Trolley Folly this week, because Diminutive DemocRAT Mayorelect John Cranley was unable to stop the stupid spending until Cincinnati City Clown-cil says so. IN COLUMBUS: Ohio Presiding Judge: HON. JULIE REINHARDT WARD (617222) Republicans celebrated when DemocRAT Gubernatorial Candidate Ed FitzGerald’s transparency and management of county government and the local economy took a big hit this week when the interim Cuyahoga County 䎟往scal o䎩쟠cer Mark Parks told the Cuyahoga County Council that Moody’s was downgrading Cuyahoga County’s bond rating for the 䎟往rst time in a “very long time.” Ohio TEA Party Guy Tom Zawistowski, President of the Ohio Citizens PAC, accused the Ohio Republican “Party” of using the legislative process to gain personal political advantage in the 2014 elections. Isn’t that their job? HOMO HOTLINE: When the US Senate passed that historic Gay Agenda Bill this week, you know Ohio Senator Rob “Fighting for Fagellas” Portman thought it was “fabulous!” EXH : 000014 of 000021 SHAKEDOWN IN THE CITY: Belligerent Black Blogger Nate “Rhymes With Hate” Livingston says his favorite corrupt Black Couple (Steve and Alicia Reece) are back to their old tricks. This time they’re trying to do a Jesse Jackson-style SHAKEDOWN of the Port Authority. Is John CRANLEY really helping them? WHERE’S OUR CIGAR? A Press Release from Congressman “Bronze Star” Brad Wenstrup’s o䎩쟠ce announced the birth of Brad, Jr. in Cincinnati on Saturday, weighing 6 pounds, 15 ounces, so there’s no way The Blower can say anything bad about him today. NOT JUST ANOTHER SPEAKING ENGAGEMENT: Revered Former Congressman Bob McEwen Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 14/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire will be telling people what it means to be a Conservative at a local EmpowerU event next week. CH SNITCH AT 1000 MAIN STREET wonders if it’s true Ditzy DemocRAT Juvenile Court Judge Traci Hunter 䎟往led bar complaints against Hamilton County Prosecutor “Jaywalking Joe” Deters and his very competent assistants. Couldn’t a judge face discipline for 䎟往ling bogus bar complaints? And when Sheriö Jimmy’s Oôce sent out a press release on Edward Greenwood’s arrest, we asked The Blower’s Legal Dream Team Chairman Scott Greenwood if Edward was a relative, and if the ACLU Mouthpiece planned to represent the guy to defend the family name? “Dear God, no,” Scott said, “but I might petition the court to change his name to Deters.” YOU GOT MAIL: Whistleblower Senior Spoiled Sports Editor Andy FurBall says Cincinnati Reds Hall of Famer Johnny Bench got his “Insurance Discontinued!” notice because of ObamaCare this week. MORE FREE CHOW FOR VETERANS: Draft Dodger Bill Cunningham says other Freeloaders Pretending to be Veterans can hardly believe all the places they can scam a free meal on Veterans Day, while as Anderson Township Veterans Society rented a bus or the First Presiding Judge: HON. JULIE REINHARDT WARD (617222) Annual Veterans Day Grub Crawl, when Anderson Veterans could visit every one of the 48 area restaurants o䎰뵠ering Free Food to past and present members of the military on Veterans Day. ALSO IN ANDERSON: Winning Township Trustee Gerth Pappas is wondering if the reason Disgraced and Defeated and Township Trustee Kevin “Big Spanky” O’Brien is bothering to collect some of his yard signs is so he can run against “In Russ We Trust” Jackson in two years. Meanwhile, Du䎰뵠y “The Kevin Slayer” Beischel says most Anderson area candidates have removed their signs with the exception of John Piehowicz who continues to leave his signs up. Like most Loser DemocRATS, he’s probably waiting for someone else to go around and pick them up for him. MEANWHILE IN MILFORD, The MILFord the Police Association is meeting to decide what the heck to do after Tuesday’s election results. Ever since the former mayor Amy Brewer put the MILF in MILFord when she routinely placed calls for assistance to the police department. (And the assistance she was getting was beyond the call to duty.) Other women have decided to run for city Clown-cil in order to get the same type of assistance. This year, three women won the three seats up for election. The extra work load placed EXH : 000015 of 000021 upon the police threatens to bust the overtime budget when all three place calls for similar assistance in the coming months. HEADLINES FROM THE SOUTH SHORE Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 15/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire THIS WEEK IN KENTON CIRCUIT COURT: The latest and greatest e-dition of Our Good Friend Kenton County Commonwealth’s Attorney E Rob Sanders unadulterated e-newsletter is probably on your cyber news stands now. The Blower was hoping this week’s edition would feature some of the new arrivals at Terry “The Smiling Jailer” Carl’s Kenton County Escape Center, but the Robster says “No, they’re just the same really ugly criminals we’ve used in the last two weekly e-ditions.” Get a gander at these “Dregs of Society!” ALSO IN NORTHERN KENTUCKY: Bluegrass Bureau Chief Ken CamBoo says this picture was posted on Facebook and then taken o䎰뵠, according to his source. It was taken at the Rabbit Hole. A bar in southern Campbell County and supposedly owned by former Judge Tim Nolan, is the father of Court Clerk Presiding Judge: HON. JULIE REINHARDT WARD (617222) Taunya Jack Nolan. Everybody’s wondering if this is a new form of Campbell County political fund raising for Nolan’s kid and those he is backing in 2014. Or maybe it’s his version of the new door-to-door campaign uniform. AND FROM THE NATIONAL NEWSWIRE: Fox News reported this message from Bill in Kentucky: “Putting things in perspective: March 21, 2010 to October 1, 2013 is 3 years, 6 months, 10 days. December 7, 1941 to May 8, 1945 is 3 years, 5 months, 1 day. What this means is that in the time we were attacked at Pearl Harbor to the day Germany surrendered is not enough time for this progressive federal government to build a working webpage. Mobilization of millions, building tens of thousands of tanks, planes, jeeps, subs, cruisers, destroyers, torpedoes, millions upon millions of guns, bombs, ammo, etc. Turning the tide in North Africa, Invading Italy, D-Day, Battle of the Bulge, Race to Berlin – all while we were also 䎟往ghting the Japanese in the Paci䎟往c!! And in that amount of time – The Obama administration can’t EXH : 000016 of 000021 build a working webpage. More Political Insight This Week FECKLESS FISHWRAPPERS: The Fishwrap asked readers to beg Mayor-elect John Cranley to renege on his promise to stop the stupid streetcar spending, and then they published all Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 16/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire those whiny Liberal letters. HURLEY THE HISTORIAN says on this date in 1989, crowds of East Germans were still tearing down the Berlin Wall, and you really have to wonder if any of that would’ve ever happened if Obama was just being “more 䎣艀exible” with the Russians. MAYBE THAT’S WHY OUR QUOTE FOR TODAY COMMITTEE chose Ronald Reagan’s immortal command during his immortal speech in Berlin on June 12, 1987, when he said “Mr. Gorbachev, tear down this wall.” GOING GALT means recognizing that the needs of others do not give them a claim to your time, e䎰뵠ort, and achievements. Presiding Judge: HON. JULIE REINHARDT WARD (617222) LIBERAL LUNACY: In Human Events’ “365 Ways to Drive a Liberal Crazy,” #316 is to tell a joke: Q. Why should liberals be buried 100 feet below the ground? A. Because deep down they are really good people. NOW HERE’S THE LATEST FROM BUNKY TADWELL, THE BARD OF CLEVES: A Government You Deserve City Clown-cil is a sorry lot But that is nothing new. So you folks should not complain too much Since they were voted in by you. THIS WEEK AT A MEETING OF THE CONSERVATIVE AGENDA: Political Insiders were asking EXH : 000017 of 000021 Beloved Whistleblower Publisher Charles Foster Kane asking about those satirical “Return to Patronage County” columns appearing in The Blower these days. “Patronage County is not a real place,” Kane explained, “although a lot of people think the Politicians in Patronage County remind them of the elected o䎩쟠cials in their own counties— Commissioners Filch, Pilfer, and Swindle are just some of the examples.” This week’s episode is “No Explanations,” is written by a brand new writer who just happened to choose the name of James Jay Schifrin. [SEE IT HERE] AND COMING UP IN “THE WEEK THAT WILL BE”: Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 17/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire Monday is the Veterans Day Federal holiday and members of the military past and present will be eating free at patriotic restaurants all over town and all good Obama-bashing Veterans will counting the 1,167 days remaining during Obama’s total clusterfuck administration. Tuesday Real Subscribers will be bombarding us with their Real E-Mails. Wednesday we’ll be “Going Galt” and to avoid paying taxes. Thursday we’ll be getting ready for National Philanthropy Day, but this year we’re just going to tell all those begging bastards to “We’re done Presiding Judge: HON. JULIE REINHARDT WARD (617222) giving. Now go ask Obama.” The 䎟往rst line of next Friday’s limerick is: “This year on Veteran’s Day.” And Saturday, we’ll be returning to Patronage County for our weekly visit, sort of like when Garrison Keillor visits Lake Wobegon. EXH : 000018 of 000021 The Libtard Show by Dixon Diaz Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 18/21 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire Presiding Judge: HON. JULIE REINHARDT WARD (617222) Filed 6/7/2016 WEEK IN REVIEW HOT LINE e-mail your revolutionary recaps today EXH : 000019 of 000021 Some political score-keeping items in today’s Blower were sent in by our equally political scorekeeping subscribers, but let’s face it, we could always use a lot more. Whistleblower Link of the Day Keller’s Riverside Store CHL radio ad Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 19/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire EXH : 000020 of 000021 Presiding Judge: HON. JULIE REINHARDT WARD (617222) Keller's Riverside Store CHL radio ad Note: We guarantee Blackberry subscribers who don’t go home and see links and pictures on their computers are not going to appreciate all of this good stu䎰뵠 today. Current Whistleblower Policies and Disclaimers can be found here Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 20/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 10 | November | 2013 | Whistleblower Newswire This entry was posted in Uncategorized on November 10, 2013 [http://whistleblower- EXH : 000021 of 000021 Presiding Judge: HON. JULIE REINHARDT WARD (617222) newswire.com/2013/11/10/special-the-week-that-was-e-dition-68/] . Filed 16-CI-00522 http://whistleblowernewswire.com/2013/11/10/ 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 21/21 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk EXHIBIT B Presiding Judge: HON. JULIE REINHARDT WARD (617222) GOP Facts.org has been created to make the FACTS known to members of the GOP which have been innundated with falsehoods, untruths, half truths, rumors and all forms of deception regarding the motivations of members of the Tea Party as well as candidates and elected officials. EXH : 000001 of 000001 Below you will find a series of buttons that link to information pertaining to the button title. Some are individuals, some are situations and issues. Please click on the "mission statement" button to get a better understanding of what this page is all about. © GOPFACTS COMMITTEE 2015 Filed http://gopfacts.org/ 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 1/1 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk EXHIBIT C Campbell County is not only a community we live in but a community many of us have invested in, started businesses in, encouraged people to believe in. We literally have our futures at stake. Our community is poised for a strong and vibrant future. The acĕons by a few truly threatens our community value. The vicious aĥacks on our schools, respecĕve city councils, our libraries, even our public works services will make one who may consider our area to think twice. We are coming out of a lost decade of economic value. We cannot risk a compounding of economic decline because of the poliĕcal gang acĕons of a few. We want our community to thrive. Our community has issues but these people have done nothing but aĥack each and everything aĥempted and what has been done. We have too much at stake to remain silent and more important we have too much respect for our neighbors and friends to have to tolerate these bully aĥacks anymore. ...Mike Combs Campbell County ciĕzen, business owner and chairman, GOP Facts commiĥee Filed http://gopfacts.org/mission.htm 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 1/2 EXH : 000001 of 000002 Presiding Judge: HON. JULIE REINHARDT WARD (617222) GOP Facts Mission Statement 16-CI-00522 06/10/2016 Filed http://gopfacts.org/mission.htm 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk EXH : 000002 of 000002 Presiding Judge: HON. JULIE REINHARDT WARD (617222) Filed 6/7/2016 Taunya Nolan Jack, Campbell Circuit Clerk 2/2 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk TRUTH on the "Red Star incident" Tea partiers have referred to the "Red star incident" over and over to try to claim unfairness on the part of the GOP against tea party members. What they don't want to tell you is that the tea party leadership in Campbell County is NOT comprised of "good" conservative Republicans. The following is the TRUTH about the "Red Star" incident that all Republicans will want to know. The preamble of the bylaws of the Republican Party of Kentucky state the following: EXH : 000001 of 000005 PREAMBLE: "We are the Party of the open door. With these Rules, we seek to transfer the transcendent principle into accepted practice. But written Rules are no substitute for personal commitment. As Republicans, we are and we must be committed to encouraging the broadest possible participation in the affairs of our Party. We must and we do encourage every Kentuckian to seek that level of Party leadership for which his or her talents and energy recommend Filed http://gopfacts.org/redstar.htm 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk Presiding Judge: HON. JULIE REINHARDT WARD (617222) EXHIBIT D 1/5 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk them. No false distinctions of age, race, sex or religion shall bar anyone from any Party position. Devotion to our Party’s principles and loyalty to its candidates ARE and should be the only qualifications for holding any position in the Republican Party . . . the Party of the open door." You may download a copy of the official RPK rules on the RPK website located here: http://rpk.org/wpcontent/uploads/2013/10/OfficialRepublicanPartyofKentucky Rules.pdf Our party invites ALL Republicans to be involved with the only REQUIREMENT to be in leadership is loyalty to the party and our candidates. Every four years the Republican party reorganizes from bottom to top. Elections are held for all positions of leadership. Elections are decided by Republicans who turn out to participate in the process. On March 3rd, 2012 the Campbell County Republican Party held their reorganization as is required by RPK rules. 167 Republicans attended to be part of the election process. ALL attendees were held to the same standard (tea party members or not) The requirements to be elected to leadership positions within the party were as follows: EXH : 000002 of 000005 1. The person had to be on a list provided by the Republican Party of Kentucky proving that the person voted in the last general election. 2. The person had to not have given financial support to nonRepublicans in a partisan race in the last two years. 3. The person had to not have shown support by written document for a non Republcan in a partisan race in the last two years. Take note that the requirements do not require nor disqualify for tea party membership Each person was required to sign in to verify Campbell County residency as well as their adherance Filed http://gopfacts.org/redstar.htm 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk Presiding Judge: HON. JULIE REINHARDT WARD (617222) Filed 6/7/2016 2/5 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk to the above qualifications. As each person signed in they were given a 3" X 5" index card to identify that they had checked in and identified the participant's precinct name and number. If a paricipant failed any of the above qualifications their index card was stamped with a red star to indicate that the person could still participate but did not qualify to hold office ie: precinct captain, cocaptain, etc. Out of the 167 people who attended only 7 were disqualified. Those seven disqualified participants were: Presiding Judge: HON. JULIE REINHARDT WARD (617222) 1. Jack Decker Alexandria 2. Erik Hermes Cold Spring 3. Jim Pfister Melbourne 4. Linda Pfister Melbourne 5. Joseph Powers Fort Thomas 6. Lloyd Rogers Alexandria 7. Philip Robbins Fort Thomas These individuals were still allowed to vote and paricipate in the reorganization process even though they were disqualified from holding office themselves. No organization would accept as it's leadership an individual who has recently worked against it. This disqualification in no way limited the participation in elections but simply disqualified the participant from holding office. Here is a link to the Kentucky Enquirer article 3/9/2012 about the Republican reorganization. red star article.pdf EXH : 000003 of 000005 There have been many intentional falsehoods put forth by the few who were disqualified in this process. Disloyalty to their party is certainly an embarassment and the disqualified members looked vigorously for someone to blame other than themselves. crying foul does not eliminate the TRUTH that these individuals supported candidates outside the Republican Party, were disloyal, then attempted what Lloyd Rogers through his own statements referred to as a "takeover" of the county party. Filed http://gopfacts.org/redstar.htm 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 3/5 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk Thank goodness that because the State GOP preamble makes the requirements for holding a leadership position in the party so clear this "takeover" was avoided. When the current county GOP administration was elected, Democrats held a lead of over 3000 registrants and controlled all but three Campbell County offices. As of December of 2014, Republicans lead in registrations in Campbell County for the first time in history and are close to 1000 ahead. (that is a net gain of 4000 voters since the current administration was elected in 2008). Subsequently, after the 2014 election cycle, Republicans now controll ALL county offices in Campbell County. Presiding Judge: HON. JULIE REINHARDT WARD (617222) Senator Jim Bunning understood what was at stake and the accomplisments that had been made in the prior four years of this administration. Click HERE to watch a short commercial featuring Senator Bunning urging Campbell County Republicans to participate in the process. Take notice of the use of the "Red Star" in the campaigns of the individuals who ran for office on a "Tea Party" ticket even though they were on the ballot as "Republicans". Many are familiar with the term RINO (Republican In Name Only). There is more than one type of RINO. In many cases the term RINO is used to describe a person who is registered Repbublican but believes in Democrat ideology. EXH : 000004 of 000005 In the case of the RINOS in Campbell County, the RINOs are people who register as Republicans so that they may sabotage the legitimate Republican Party and gain power for their own personal gain through intimidation and deceit, claiming Libertarian ideology. Loyal and dedicated true Republicans need to know of the gang actions of these few individuals who are working together to damage Republicans for their own objectives. © GOPFACTS COMMITTEE 2015 Filed http://gopfacts.org/redstar.htm 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 4/5 16-CI-00522 06/10/2016 Filed http://gopfacts.org/redstar.htm 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk EXH : 000005 of 000005 Presiding Judge: HON. JULIE REINHARDT WARD (617222) Filed 6/7/2016 Taunya Nolan Jack, Campbell Circuit Clerk 5/5 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk EXHIBIT E TRUTH about Tim Nolan Presiding Judge: HON. JULIE REINHARDT WARD (617222) It has come to our a태en鋙on here at GOPFacts that washed up Judge and racist Tim Nolan will be serving as a representa鋙ve for Presiden鋙al candidate Donald Trump at the March 5th Caucus in Campbell County. One has to wonder if The Donald knows that he is about to be represented by one of Campbell County's most vehement racists. EXH : 000001 of 000005 Here is a picture taken right off of Timmy Boy's Facebook page, with Tim in full Klan regalia trying to recruit people to join the Klan at the bar that he owns in Southern Campbell County. The real ques鋙on is how could they possiby make any profit with Timmy guzzling down all the stock? Filed http://www.gopfacts.org/nolan.htm 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 1/5 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk Presiding Judge: HON. JULIE REINHARDT WARD (617222) Filed 6/7/2016 EXH : 000002 of 000005 Campbell County was listed that week in the Whistleblower. We at GOPFacts do not believe this is the type of publicity Campbell County needs. "CLICK HERE to read the Whistle Blower ar鋙cle" Even MORE TRUTH about Tim Nolan Filed http://www.gopfacts.org/nolan.htm 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 2/5 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk Presiding Judge: HON. JULIE REINHARDT WARD (617222) 16-CI-00522 Here is a picture of Lloyd Rogers and failed District Judge Timmy Nolan (he s鋙ll thinks he's a Judge, just ask him) at the Debate in 2010 where Kevin Sell and Ken Rech鋙n wiped the floor with the has been Judge and 1 term Judge Execu鋙ve when they a태empted to change the form of Campbell County government for their usual mo鋙va鋙on (personal gain). Side Note: The issue failed and sadly (for them) "www.ccjop.com" landed in the trash heap of history As if all the lawsuits against Campbell County and all the other self serving ac鋙vi鋙es Judge Timmy has a태empted and failed... Failed Judge Tim Nolan a태empts to take over the Republican Party in Campbell Filed http://www.gopfacts.org/nolan.htm 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 3/5 EXH : 000003 of 000005 Filed 6/7/2016 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk County and fails again. Isn't a "Judge" supposed to know the rules? Here is the complaint that "Judge" Timmy Nolan wrote a태emp鋙ng to oust the current and LEGITIMATE Republican Leadership in Campbell County. "CLICK HERE to read the le태er." Presiding Judge: HON. JULIE REINHARDT WARD (617222) Even though the le태er looks like it was wri태en by a second grader, it was indeed penned by "Judge" Timmy himself. EXH : 000004 of 000005 Even though it looks as if Timmy rounded up a group of people for his a태empted takeover only six people actually listened to the failed Judge and signed the pe鋙鋙on. 1. His Daughter Taunya Nolan Jack 2. His son in law Jeff jack 3. His personal stooge Larry Robinson 4. The stooge's wife Mrs. Robinson 5. Gina Parry 6. Fred O태o Filed http://www.gopfacts.org/nolan.htm 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 4/5 Filed 6/7/2016 16-CI-00522 06/10/2016 Taunya GOP Facts Nolan Jack, Campbell Circuit Clerk "CLICK HERE to read the response by the former Fourth District Republican Chairman Kevin Sell" Presiding Judge: HON. JULIE REINHARDT WARD (617222) "CLICK HERE to read the response by the Republican State Chairman Steve Robinson to Larry, Timmy and crew." EXH : 000005 of 000005 © GOPFACTS COMMITTEE 2015 Filed http://www.gopfacts.org/nolan.htm 16-CI-00522 06/10/2016 Taunya Nolan Jack, Campbell Circuit Clerk 5/5