UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

RANDY A. HAMDAN, an individual, Case No.______________________

Hon._________________________

Plaintiff,

v.

MATT FINSTON, an individual

Defendant.

HOWARD & HOWARD ATTORNEYS PLLC

Michael F. Wais (P45482)

Jeff A. Hoover (P71447) 

Attorneys for Plaintiff

450 West Fourth Street

Royal Oak, MI 48067-2557

(248) 645-1483

mwais@howardandhoward.com

jhoover@howardandhoward.com

COMPLAINT AND JURY DEMAND

NOW COMES, Plaintiff, Randy A. Hamdan, and for his Complaint against Defendant 

Matt Finston, states as follows:

JURISDICTION

1 Plaintiff Randy A. Hamdan is a resident of the State of Michigan.

2. Defendant Matt Finston is a resident of the State of California.

3. The amount in controversy exceeds $75,000.00, exclusive of interest and costs.

4. Jurisdiction is otherwise appropriate in this Court pursuant to 28 U.S.C § 1332.

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BACKGROUND

5. HH Group, LLC is a substantial holder of shares of common stock in Creative 

Edge Nutrition, Inc., a publicly held corporation trading under the ticker symbol FITX.

6. Plaintiff is the sole member of HH Group, LLC. 

7. In approximately June of 2014, Defendant began a campaign to publicly defame 

and cast Plaintiff and Creative Edge Nutrition, Inc. in a false light through a series of internet 

posts containing false and defamatory statements regarding Plaintiff. 

8. Just a few examples of Defendant’s false and defamatory statements regarding 

Plaintiff are as follows:

a. That Plaintiff has a “fraudulent past”. (See Exhibit A).

b. That Plaintiff and HH Group, LLC were issued 420 Million shares of 

stock in Creative Edge Nutrition Inc. (ticker symbol FITX) for $0.001 per 

share. (See Exhibit B).

c. That “Vgpr didn’t survive Hamden”, implying that Plaintiff caused Vega 

Biofuels Inc. to fail or go out of business. (See Exhibit C).

d. That “DNAX is another”, implying that Plaintiff caused DNA Brands, Inc. 

to fail or go out of business. (See Exhibit D).

e. That Plaintiff “dumped” FITX stock “into the promotion three years ago”.

(See Exhibit E).

f. That Plaintiff is “a serial pump and dump and he’s been charged by the 

SEC for it.” (See Exhibit F).

g. That Plaintiff is “a known pump and dump”. (See Exhibit G).

h. That Plaintiff is “an investor relations ponzi”. (See Exhibit H).

i. Plaintiff has posted statements implying that Amineh A. Hamdan and 

Fihmiya Anwar Hamdan (Plaintiff’s parents) are associated with 

Hezballah and/or are engaged in or associated with terrorism -- for the 

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purpose of further implying that Plaintiff and his family are tied to 

Hezballah and terrorism. (See Exhibit I).

j. That Plaintiff is “using more profiles to harass and intimidate and pump”.

(See Exhibit J).

9. Upon information and belief, Defendant has made and published numerous other 

false and defamatory statement regarding both Plaintiff and Creative Edge Nutrition, Inc.

10. Based upon information and belief, Defendant is undertaking this campaign of 

defamation against Plaintiff and Creative Edge Nutrition, Inc. as part of a stock price 

manipulation scheme whereby he is “short selling” Creative Edge Nutrition, Inc.’s stock and 

attempting to profit by driving the stock price downward.

11. On July 3, 2014, Plaintiff’s attorneys sent Defendant a letter pursuant to MCL 

600.2911(2)(b) demanding that Defendant issue a retraction of all of the false and defamatory 

statements he has made against Plaintiff. (See Exhibit K).

12. To date, Defendant has failed to respond to this letter or publish any type of 

retraction.

13. Instead, Defendant has continued his defamatory internet campaign against 

Plaintiff and Creative Edge Nutrition, Inc. with a July 23, 2014 article posted on 

www.seekingalpha.com. However, this time Defendant was careful not to mention Plaintiff by 

name. (See Exhibit L).

14. Plaintiff has suffered significant financial losses as well as damages to his 

reputation and business prospects. This is not to mention the grave danger Defendant has placed 

Plaintiff and his family in by insinuating that they are connected to Hezballah and terrorism.

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COUNT I 

DEFAMATION

15. Plaintiff incorporates paragraphs 1-14 above as if fully restated herein.

16. As set forth above, Defendant made numerous false statements and comments 

regarding Plaintiff as part of an internet based campaign by Defendant to defame Plaintiff.

17. Defendant published these remarks to an infinite number of third parties on the 

internet with knowledge of the falsity of the statements or in reckless disregard of their truth or 

falsity.

18. The repeated publication of these false and defamatory statements by Defendant 

has resulted in severe damage to Plaintiff’s reputation, has caused Plaintiff to suffer severe 

emotional distress, has placed Plaintiff’s family in grave danger, and has caused Plaintiff 

significant economic loss, including but not limited to driving down the stock price of Creative 

Edge Nutrition, Inc. and interfering with Plaintiff’s ability to invest in publicly traded companies. 

19. As Defendant’s defamatory and false statements against Plaintiff were made with 

a malicious intent and have held Plaintiff up to hatred, scorn, contempt, and/or ridicule, they 

constitute defamation per se.

WHEREFORE, Plaintiff seeks a Judgment against Defendant in an amount the Court deems 

just and equitable, including exemplary and punitive damages, plus attorneys' fees, interest and 

costs, and such other relief the Court deems appropriate.

COUNT II

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

20. Plaintiffs incorporate paragraphs 1-19 above as if fully restated herein.

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21. Defendant’s defamatory and wrongful conduct, as detailed above, was intentional. 

22. Defendant’s defamatory and wrongful conduct, as detailed above, was extreme, 

outrageous, and of such character as not to be tolerated by a civilized society.

23. Indeed, Defendant’s defamatory and wrongful conduct, as detailed above, was for 

an ulterior motive or purpose, most notably to manipulate the stock price of Creative Edge 

Nutrition, Inc. for Defendant’s own profit.

24. Defendant’s defamatory and wrongful conduct has caused Plaintiff to suffer 

severe and serious emotional distress.

25. The repeated publication of these false and defamatory statements by Defendant 

has resulted in severe damage to Plaintiff’s reputation, has caused Plaintiff to suffer severe 

emotional distress, has placed Plaintiff’s family in grave danger, and has caused Plaintiff 

significant economic loss, including but not limited to driving down the stock price of Creative 

Edge Nutrition, Inc. and interfering with Plaintiff’s ability to invest in publicly traded companies. 

WHEREFORE, Plaintiff seeks a Judgment against Defendant in an amount the Court deems 

just and equitable, including exemplary and punitive damages, plus attorneys' fees, interest and 

costs, and such other relief the Court deems appropriate.

COUNT III

TORTIOUS INTERFERENCE WITH BUSINESS RELATIONSHIPS

26. Plaintiffs incorporate paragraphs 1-25 above as if fully restated herein.

27. As set forth above, Plaintiff is an indirect shareholder of Creative Edge Nutrition, 

Inc.

28. Defendant’s repeated defamatory and false statements regarding Plaintiff have 

caused Plaintiff and Creative Edge Nutrition, Inc. to be held Plaintiff up to hatred, scorn, 

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contempt, and/or ridicule

29. Defendant, by his unwarranted, negligent, intentional, reckless, and false

accusation against Plaintiff have interfered with Plaintiff’s business relationship with Creative 

Edge Nutrition, Inc., and his business relationship with other publicly held companies.

30. Defendants wrongful conduct has resulted in severe damage to Plaintiff’s 

reputation, has caused Plaintiff to suffer severe emotional distress, has placed Plaintiff’s family 

in grave danger, and has caused Plaintiff significant economic loss, including but not limited to 

driving down the stock price of Creative Edge Nutrition, Inc., harming Plaintiff’s relationship 

with Creative Edge Nutrition, Inc., and interfering with Plaintiff’s ability to invest in publicly 

traded companies. 

WHEREFORE, Plaintiff seeks a Judgment against Defendant in an amount the Court deems 

just and equitable, including exemplary and punitive damages, plus attorneys' fees, interest and 

costs, and such other relief the Court deems appropriate.

COUNT IV

FALSE LIGHT DEFAMATION

31. Plaintiff incorporates paragraphs 1-30 above as if fully restated herein.

32. As set forth above, Defendant made numerous false statements and comments 

regarding Plaintiff as part of an internet based campaign by Defendant to defame Plaintiff.

33. Defendant published these remarks to an infinite number of third parties on the 

internet with knowledge of the falsity of the statements or in reckless disregard of their truth or 

falsity.

34. The repeated publication of these false and defamatory statements by Defendant 

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has placed Plaintiff in a false and negative light in the public eye.

35. The repeated publication of these false and defamatory statements by Defendant 

has also resulted in severe damage to Plaintiff’s reputation, has caused Plaintiff to suffer severe 

emotional distress, has placed Plaintiff’s family in grave danger, and has caused Plaintiff 

significant economic loss, including but not limited to driving down the stock price of Creative 

Edge Nutrition, Inc. and interfering with Plaintiff’s ability to invest in publicly traded companies. 

WHEREFORE, Plaintiff seeks a Judgment against Defendant in an amount the Court deems 

just and equitable, including exemplary and punitive damages, plus attorneys' fees, interest and 

costs, and such other relief the Court deems appropriate.

REQUEST FOR RELIEF

WHEREFORE, Plaintiff seeks a Judgment against Defendant in an amount the Court deems 

just and equitable, including exemplary and punitive damages, plus attorneys' fees, interest and 

costs, and such other relief the Court deems appropriate.

HOWARD & HOWARD ATTORNEYS PLLC

Dated: July 28, 2014 By: /s/ Michael F. Wais

Michael F. Wais (P45482)

Jeffrey A. Hoover (P71447) 

Attorneys for Plaintiff

450 West Fourth Street

Royal Oak, MI 48067

(248) 645-1483

Email: mwais@howardandhoward.com

DEMAND FOR TRIAL BY JURY

Plaintiffs hereby reaffirm their demand trial by jury in this matter.

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Respectfully submitted, 

HOWARD & HOWARD ATTORNEYS PLLC

Dated: July 28, 2014 By: /s/ Michael F. Wais

Michael F. Wais (P45482)

Jeffrey A. Hoover (P71447) 

Attorneys for Plaintiff

450 West Fourth Street

Royal Oak, MI 48067

(248) 645-1483

Email: mwais@howardandhoward.com

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