1

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

DR. JEROME CORSI, Individually

Denville, NJ, 07834

And

LARRY KLAYMAN, Individually

7050 W. Palmetto Park Rd. #15-287

Boca Raton, FL, 33433

 Plaintiffs

v.

INFOWARS, LLC

100 Congress Ave., 22nd Floor

Austin, TX 78701

And

FREE SPEECH SYSTEMS, LLC

100 Congress Ave., 22nd Floor

Austin, TX 78701

And

ALEX E. JONES, Individually

3019 Alvin Devane Blvd., Suite 300-350

Austin, TX 78741

And

DAVID JONES, Individually

3019 Alvin Devane Blvd., Suite 300-350

Austin, TX 78741

And

OWEN SHROYER, Individually

3019 Alvin Devane Blvd., Suite 300-350

Austin, TX 78741

Defendants.

 Case Number: 

 

 COMPLAINT 

 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 1 of 109
2

INTRODUCTION

Plaintiffs DR. JEROME CORSI (“Plaintiff Corsi or Dr. Corsi”) and LARRY 

KLAYMAN (“Klayman”) hereby files this action against INFOWARS, LLC (“Defendant 

InfoWars”), FREE SPEECH SYSTEMS, LLC (“Defendant Free Speech Systems”), ALEX E. 

JONES (“Defendant Alex Jones”), DAVID JONES (“Defendant David Jones”) and OWEN 

SHROYER (“Defendant Shroyer”) for Defamation, Intentional Infliction of Emotional Distress,

and Assault, and violation of the Lanham Act.

JURISDICTION AND VENUE

1. This Court has diversity jurisdiction over this case pursuant to 28 U.S.C. § 1332, 

as the parties are completely diverse in citizenship and the amount in controversy exceeds 

$75,000.

2. This Court has federal question jurisdiction over this case pursuant to 28 U.S.C § 

1331.

3. Venue is proper pursuant to 28 U.S.C. § 1391(b)(2), (3) in that a substantial part 

of the events or omissions giving rise to Plaintiffs’ claims arose in this district. Defendants’

actions are targeted to influence Special Counsel Robert Mueller’s Russian collusion 

investigation and prosecution of Roger Stone - who is a colleague of the Defendants - which is 

centralized in this judicial district, and the defamatory and other illegal acts occurred herein.

THE PARTIES

4. Plaintiff Corsi is an author and political commentator who publishes works in this 

judicial district and nationwide. Plaintiff Corsi is a citizen of New Jersey.

5. Plaintiff Klayman is a public interest legal advocate, private practitioner and

litigator who represents Plaintiff Corsi with regard to Special Counsel Robert Mueller’s 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 2 of 109
3

(“Mueller”) Russian collusion investigation. Plaintiff Klayman is also a media personality and 

author, columnist and syndicated radio talk show host. Plaintiff Klayman is a citizen of Florida. 

6. Defendant InfoWars is a Texas limited liability company with principal offices 

located in Austin, TX. 

7. Defendant Free Speech Systems is a Texas limited liability company with principal 

offices located in Austin, TX.

8. Defendant Alex Jones is a well-known extreme “conspiracy theorist” and media 

personality who creates content that is broadcasted on the radio and posted on the internet at 

www.infowars.com and elsewhere on the internet and other social media sites. Defendant Alex 

Jones is a citizen of Texas.

9. Defendant David Jones is Defendant Alex Jones’s father and holds the official title 

of Director of Human Relations for Defendant Free Speech Systems. On information and belief, 

Defendant David Jones is the owner of Defendants InfoWars and Free Speech Systems and he

manages the business activities for Defendants InfoWars and Free Speech Systems, as well as 

Defendant Alex Jones’ other companies. Defendant David Jones is a citizen of Texas. At all 

material times he worked in concert with the other Defendants and Roger Stone and furthered and 

ratified and furthered the illegal acts set forth in this Complaint.

10. Defendant Shroyer is a newscaster for Defendant InfoWars. Defendant Shroyer is a 

citizen of Texas.

GENERAL ALLEGATIONS

11. Defendant InfoWars and Defendant Free Speech Systems are both owned, 

controlled, and operated by Defendant Alex Jones and David Jones. Defendant Free Speech 

Systems owns www.infowars.com, where content created by Defendants Alex Jones and Shroyer 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 3 of 109
4

are posted and broadcast into this district, nationally and internationally.

12. Defendant Alex Jones hosts The Alex Jones Show, which is broadcast on radio 

and internet social media networks throughout the United States of America and internationally, 

including this judicial district, and online. 

13. Defendant Shroyer hosts The War Room along with Roger Stone (“Stone”), which 

is broadcast on radio and internet social media networks throughout the United States of America

and internationally, including this judicial district, and online.

14. Defendants’ reach and influence are enormous. On information and belief, 

Defendant Alex Jones and InfoWars has a radio audience of over two million people. Before it 

was banned from YouTube, Defendant Alex Jones’ and InfoWars’ channel had more than 2.4 

million subscribers.1

15. Defendants, each and every one of them, in concert, do substantial business and 

promote and sell various goods in this judicial district and nation-wide, including medicine, 

supplements, and “tchotchkes” with InfoWars branding. The money earned from these sales 

funds the conspiracy between Defendants and Stone to defame, intimidate, coerce and threaten 

Plaintiffs in order to try to improperly influence the Mueller Russian collusion investigation and 

to coerce false testimony from Plaintiff Corsi favorable to Stone in his upcoming criminal 

prosecution.

16. Stone also does business promotes and sells various goods in this judicial district 

and nation-wide, including medicine, supplements, books, and “tchotchkes” with his own 

branding. The money earned from these sales funds Stone’s legal defense fund and the 

 1 Casey Newton, YouTube deletes Alex Jones’ channel for violating its community guidelines, 

The Verge, Aug. 6, 2018, available at: https://www.theverge.com/2018/8/6/17656708/youtubealex-jones-infowars-account-deleted-facebook-apple-spotify

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 4 of 109
5

conspiracy between Defendants and Stone to defame, intimidate, coerce and threaten Plaintiffs in 

order to try to improperly influence the Mueller Russian collusion investigation and to coerce 

false testimony from Plaintiff Corsi favorable to Stone in his upcoming criminal prosecution.

17. Defendants have a long and sordid history of publishing and broadcasting 

defamatory material, including falsely, recklessly and baselessly accusing the families of the 

schoolchildren who lost their lives during the 2012 Sandy Hook Elementary School massacre of 

staging the massacre and faking the deaths of their children.2

18. The Sandy Hook families had to endure years of abuse and torture from 

Defendants before finally filing suit against numerous parties involved with InfoWars, including 

Defendant Alex Jones and Shroyer, for defamation. 

19. As just one example, a Florida woman was arrested for making death threats to a 

parent of a Sandy Hook victim.3 According to the U.S. Department of Justice, the motivation 

behind the threats was the lies propagated by Defendants that the Sandy Hook massacre was a 

hoax.4

20. Furthermore, Defendant Alex Jones in concert with the other Defendants

propagated and promoted the “Pizzagate” conspiracy on his show, accusing a restaurant called 

Comet Ping Pong in the Washington D.C. area of operating a child sex ring in its non-existent 

basement that purportedly involved Hillary Clinton and John Podesta. This caused one of his 

listeners to shoot up the restaurant after being told by Defendant Jones to “self-investigate” the 

 2 Aaron Katersky, Families of Sandy Hook shooting victims win legal victory in lawsuit against 

InfoWars, Alex Jones, ABC News, Jan. 11, 2019, available at: 

https://abcnews.go.com/US/families-sandy-hook-shooting-victims-win-legalvictory/story?id=60314174

3 Daniella Silva, Conspiracy Theorist Arrested for Death Threats Against Sandy Hook Parent, 

NBC News, Dec. 7, 2016, available at: https://www.nbcnews.com/news/us-news/conspiracytheorist-arrested-death-threats-against-sandy-hook-parent-n693396

4 Id. 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 5 of 109
6

“Pizzagate” conspiracy theory.5

21. Defendants, acting in concert, propagated these outrageous lies with no regard for 

the grief of their victims in order to gain notoriety, fame, and profit. 

22. Defendants, acting in concert, as part of their latest scheme for notoriety, fame,

and profit, are now working in concert with Stone to defame, intimidate, and threaten Plaintiffs. 

23. Stone, who recently been indicted on seven counts of perjury, witness tampering 

and obstruction of justice by Special Counsel Robert Mueller and then placed under a total gag 

order by the jurist, the Honorable Amy Berman Jackson, presiding over his prosecution for, in 

part, even threatening her, has appeared numerous times on shows broadcasted by Defendant 

InfoWars, and hosted by Defendants Alex Jones and Shroyer, where Stone and Defendants have 

published malicious false, misleading, and defamatory statements concerning Plaintiffs.

24. Again, Stone was recently indicted by Special Counsel Robert Mueller (“Mueller

Indictment”) as part of his “Russian Collusion” investigation for the alleged crimes of perjury, 

witness tampering and obstruction of justice. The indictment comprises seven different felony

counts. See Exhibit 1 – Mueller Indictment. Importantly, Dr. Corsi was not accused of any 

wrongdoing or illegality in the Mueller Indictment, in which he named as Person 1, a material 

witness to the alleged crimes committed by Stone. (Note: The facts set forth in all Exhibits 

attached to and referenced in this Complaint are factually incorporated into this Complaint by 

reference).

25. Specifically, the seven count Mueller Indictment against Stone involves alleged

lying under oath - that is, perjury - witness tampering and obstruction of justice by threatening to 

 5 James Doubek, Conspiracy Theorist Alex Jones Apologizes For Promoting 'Pizzagate', NPR, 

Mar. 26, 2017, available at: https://www.npr.org/sections/thetwoway/2017/03/26/521545788/conspiracy-theorist-alex-jones-apologizes-for-promoting-pizzagate

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 6 of 109
7

kill a material witness, Randy Credico (“Credico”) and his service dog, if Credico did not lie to 

government authorities concerning his involvement with Roger Stone. Credico is Person 2 in the 

Mueller Indictment of Stone. Id. Person 1 in this Mueller Indictment is Dr. Corsi.

26. Even before Stone was indicted, he began a public relations campaign in this 

district, nationally and internationally to maliciously defame, smear, intimidate and threaten Dr. 

Corsi and Plaintiff Klayman, Plaintiff Corsi’s lawyer and defense counsel.

27. As just one example, in an article from The New Yorker, Stone was quoted as 

saying about Plaintiff Corsi, “He’s certifiably insane, and he has told multiple provable lies.”6

This malicious defamatory statement, among others, was published in concert with Defendants.

28. Stone knew that he was going to be indicted, and therefore began this public 

relations campaign to maliciously defame smear, intimidate and threaten Plaintiff. Corsi and 

Plaintiff Klayman, even before his actual indictment on January 25, 2019, in order to try to 

influence public opinion and Special Counsel Robert Mueller – by trying to attribute guilt to 

Plaintiff Corsi and not him - as well as to try to raise money for his legal defense. This 

defamatory public relations campaign is and continues to be calculated to coerce Plaintiff Corsi 

to testify falsely at Stone’s upcoming criminal trial before Judge Jackson. This pattern and 

practice of defaming, intimidating and threatening Plaintiff Corsi and Plaintiff Klayman is 

pervasive and ongoing, and therefore Plaintiffs reserve the right to amend this Complaint. 

Defendants, as alleged herein, are acting in concert with Stone to engage in criminal witness 

tampering and obstruction of justice not just with regard to Plaintiff Corsi, who is Person 1 in the 

indictment of Stone, and thus a material witness, but also Dr. Corsi’s attorney Larry Klayman. 

 6 Jeffrey Toobin, Roger Stone’s and Jerome Corsi’s Time in the Barrel, The New Yorker, Feb. 

18 & 25 Issue, available at: https://www.newyorker.com/magazine/2019/02/18/roger-stones-andjerome-corsis-time-in-the-barrel

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 7 of 109
8

This action by Defendants, each and every one of them, jointly and severally against Plaintiff 

Corsi and his attorney Plaintiff Klayman constitute crimes pursuant to 18 U.S.C. § 1512.

29. Stone likes to portray himself as Mafia, and indeed on information and belief has 

Mafia connections, frequently making reference to Mafia figures who he admires, as well as 

other unsavory types who have been alleged to have engaged in unethical and/or illegal behavior. 

For example, he frequently makes reference to his heroes being Hyman Roth in the ‘Godfather,”

who was the movie version of Meyer Lansky, and Roy Cohn, not to mention, Richard Nixon, for 

his role in Watergate. In this regard, after Stone was indicted he held a press conference on the 

courthouse steps of the federal courthouse in Ft. Lauderdale, where he was booked, with his arms 

defiantly in the air in the “victory’ pose used by Nixon after he resigned in disgrace as a result of 

the Watergate scandal. At the time, Stone had been employed by a Nixon group called CREEP, 

or the Committee to Reelect the President. Defendant Stone even has a large tattoo of Richard 

Nixon affixed to his back. Thus, given his admiration for persons such as these, particularly

Mafia figures, his actions as pled herein can be taken as threats, as well as being defamatory.

And, Plaintiff Corsi is 72 years old and thus very vulnerable emotionally and physically to these 

threats. Stone’s intentional infliction of emotional distress and coercion and threats are intended 

to try even cause Plaintiff Corsi to have heart attacks and strokes, in order that Plaintiff will be 

unable to testify at Stone’s criminal trial. Tellingly, Stone threatened kill a material witness and 

his service dog, Credico, Person 2 in the Mueller Indictment, “Mafia style.” Stone also fashions 

himself and indeed has the reputation, at a minimum, as being the preeminent “dirty trickster.” 

See “Get Me Roger Stone” on Netflix.

30. By defaming Plaintiffs, Stone is hoping to not only intimidate Plaintiffs to 

severely harm and damage their reputations, but also to coerce and threaten Plaintiff Corsi to 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 8 of 109
9

testify falsely if subpoenaed to be called as a material witness in Stone’s ensuing criminal trial. 

He is also trying divert funds away from Dr. Corsi’s legal defense fund, while boosting his own 

legal defense fund.

31. Defendants and Stone’s conspiracy to defame, smear, intimidate, tamper with and 

threaten Plaintiffs is calculated to improperly and illegally influence the Russian collusion 

investigation, for which Stone has already been criminally indicted and to coerce false testimony 

favorable to Stone at his upcoming prosecution. This illegal conduct is also maliciously intended 

to harm Plaintiffs’ reputations and credibility as Stone fears that Dr. Corsi will testify truthfully 

if subpoenaed by Special Counsel Mueller at Stone’s upcoming criminal prosecution.

32. Stone has also used and continues to employ surrogates, either out in the open or 

secretly, to defame Plaintiffs, such as Defendants herein, and his “friend” Michael Caputo,

Cassandra Fairbanks, reporter Chuck Ross of The Daily Caller, and Tom Fitton of Judicial 

Watch, to name just a few.

33. Tellingly, in a video published by The Daily Caller, Defendant Shroyer appearing 

with Stone, admits that he will serve as a surrogate for Stone if Stone receives a gag order, which 

he has. 7 The other Defendants, like Stoyer, are also surrogates of Stone.

34. Stone’s illegal and improper attempts to influence the Russian collusion 

investigation has even been recognized by the presiding judge, the Honorable Amy Berman 

Jackson (“Judge Jackson”), who has now issued a complete “gag” order on Stone after Stone

attempted to incite violence against Judge Jackson by putting a picture of her face and gun 

crosshairs up on his Instagram account.8

 7 https://www.youtube.com/watch?v=SSDkh5RYtGo

8 Judge in Roger Stone case orders hearing after he appeared to threaten her on Instagram, 

Washington Post, Feb. 19, 2019, available at: 

https://www.washingtonpost.com/politics/2019/02/18/roger-stone-deletes-photo-judge-presidingCase 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 9 of 109
10

35. In her minute order of February 21, 2019 imposing the total “gag” order on Stone, 

Judge Jackson directly cites and references his use of surrogates:

Furthermore, the defendant may not comment publicly about the case indirectly 

by having statements made publicly on his behalf by surrogates, family members, 

spokespersons, representatives, or volunteers.

36. Further evidence of Stone’s collaboration with Defendants, as well as Stone’s 

pattern and practice of defamatory, intimidating, coercive, threatening and defamatory conduct is 

set forth in an amicus curiae brief filed by Plaintiff Klayman on behalf of Plaintiff Corsi in 

Stone’s criminal case. Such evidence is attached hereto as Exhibit 2 and incorporated herein by 

reference, as well as civil complaint filed by Corsi and Klayman against Stone, and in a civil 

complaint filed by Klayman against Fitton. See Exhibits 3, 4, and 5, which are incorporated 

herein by reference.

37. Defendants have, by working in concert with Stone, therefore engaged in illegal 

witness tampering, intimidation and threats in violation of 18 U.S.C. § 1512 by virtue of the 

defamatory and threatening acts and practices as alleged herein. Not coincidentally, this was 

what largely Stone was indicted for by Special Counsel Robert Mueller.

DEFENDANTS’ DEFAMATORY CONDUCT

38. Stone has appeared numerous times on programs of the Defendants, The Alex 

Jones Show and The War Room, which are hosted by Defendant Alex Jones and Shroyer where 

numerous false, misleading, malicious and defamatory statements of and concerning Plaintiffs 

were made, published, and or ratified by all of the Defendants, each and every one of them.

39. Plaintiffs have demanded retraction and correction of the defamatory videos and 

publications set forth below and generally in this Complaint, but Defendants have refused, 

 

over-his-case-says-he-didnt-mean-threaten-her/?utm_term=.2d3c5afa6326

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 10 of 109
11

thereby ratifying any and all defamatory statements contained therein.

40. Defendants, at a minimum, acted recklessly, as they have known Plaintiff Corsi 

for a long time, and even worked with him and are also familiar with Plaintiff Klayman, so they 

were well aware that the statements made by Stone, and their own false, misleading, malicious 

and defamatory statements were, indeed, false, as well as their ratification of the malicious false 

statements published by Stone on their networks and media sites.

41. As the content containing the malicious false, misleading, and defamatory 

statements were published on the internet, it is proliferated like a “cancerous virus,” and is now 

available for viewing from countless sources, thereby exponentially increasing the prejudicial 

and defamatory impact and severe damage inflicted on Plaintiffs. Judge Jackson, in issuing her 

two gag orders against Stone, herself recognized how postings on the internet proliferate widely 

and once made cannot be taken back.

I. The October 26, 2018 Video

42. In a video from October 26, 2018, Defendant Alex Jones, acting in concert with 

the other Defendants, makes several false, misleading, malicious and defamatory statements 

about Plaintiff Corsi.9

43. At 0:45, Defendant Alex Jones maliciously and falsely published that Plaintiff

Corsi “seemed to be extremely mentally degraded to the point of what I would call dementia.” 

44. In the same video, Defendant Alex Jones, acting in concert with the other 

Defendants, maliciously fabricates a story where he purportedly saw Plaintiff Corsi at a 

steakhouse “on the ground at another table” and that his security staff “thought he was dead in 

the elevator.” 

45. At 5:08, Defendant Alex Stone, acting in concert with the other Defendants, after 

 9 https://www.youtube.com/watch?v=UuXPAn0nZo8

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 11 of 109
12

accusing Plaintiff Corsi of having suffered a stroke, publishes maliciously that “whatever comes 

out of his mouth ain’t the truth.”

46. Tellingly and not at all coincidentally, Stone appeared as a guest on the same 

video, as evidence of Defendants working in concert with Stone. 

47. These malicious false, misleading, and defamatory statements were published by 

Defendants to discredit Plaintiff Corsi in order to preserve the reputation of their co-conspirator, 

Stone before Mueller’s Russian collusion investigation, as Stone has been indicted and Plaintiff

Corsi named a material witness. 

II. The January 18, 2019 Video

48. Before Stone was indicted, on or about January 18, 2019, he appeared on The War 

Room with Defendant Shroyer, where he made several malicious false, misleading, and 

defamatory statements in this district, nationally and internationally regarding Plaintiffs (the 

“January 18 Video”).10 The same video was published on Stone’s YouTube channel, “Stone Cold 

Truth,” on January 18, 2019.11

49. These malicious false, misleading, and defamatory statements were adopted and 

published by each and every one of the Defendants, rendering them joint tortfeasors and jointly 

and severally liable. 

50. At 2:09 in the January 18 Video, Stone maliciously and falsely published that 

Plaintiff Corsi was “fired from World Net Daily.”

51. At 2:27 in the January 18 Video, Stone maliciously falsely and misleadingly 

published that, “He (Corsi) was perfectly willing to lie, to perjure himself saying that a memo 

that he had wrote me was written on the 30th for the purposes of cover-up.... which is further 

 10 https://www.infowars.com/watch/?video=5c3fbf24fe49383dcf6996e4

11 https://www.youtube.com/watch?v=cJyfgdvtFx8

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 12 of 109
13

proof that Jerry lied under oath.”

52. At 2:55 in the January 18 Video, Stone maliciously falsely and misleadingly

published, “and then states that I knew about John Podesta’s emails being stolen in advance, the 

only proof of that is Jerry’s feeble alcohol affected memory – it’s a lie....”

53. At 3:35 in the January 18 Video, Stone maliciously falsely and misleadingly 

published that “Jerry was prepared to stab a principle Trump supporter in the back, he was 

perfectly prepared to bear false witness against me, even though I had done nothing in my entire 

life other than help him.”

54. At 4:20 in the January 18 Video, Stone maliciously falsely and misleadingly

published that “all I ever did was show Jerry Corsi friendship and support and try to help him 

and his family and what I get is Judas Iscariot, the willingness to testify against me and help the 

deep state bury me....and then he makes up this story about helping me formulate a cover story.” 

55. At 6:26 in the January 18 Video, Stone maliciously falsely published that “you 

can always tell when Jerry Corsi is lying because his lips are moving....”

56. At 1:25 in the January 18 Video, Stone maliciously falsely published that “He’s 

(Klayman) never actually won a courtroom victory in his life.”

57. At 1:30 in the January 18 Video, Stone maliciously falsely published, “He 

(Klayman) was ousted at Judicial Watch. Ask Tom Fitton [the current president of Judicial 

Watch] why he left. He was ‘ousted’ because of a ‘sexual harassment complaint.’”

58. In actuality and truth, Plaintiff Klayman left Judicial Watch on his own accord in 

order to run for U.S. Senate in Florida in 2003-2004.

59. Not coincidentally, Plaintiff Klayman has a jury verdict and judgment against 

Fitton’s Judicial Watch for having defamed him with malice. Punitive damages were also 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 13 of 109
14

awarded by the jury in the U.S. District Court for the Southern District of Florida. See Exhibit 5-

1. 

60. At 1:37 in the January 18 Video, Stone maliciously falsely published, “He’s 

(Klayman) incompetent, he’s a numbskull, he’s an idiot, he’s an egomaniac, and he could be the 

single worst lawyer in America. With him as Jerry Corsi’s lawyer, Corsi may get the electric 

chair. So your idea that he’s a good guy is entirely wrong”

61. In actuality, Plaintiff Klayman has been a practicing attorney for over four 

decades and has won numerous cases on behalf of his clients and also against the government for 

constitutional and other violations. He is the founder of both Judicial Watch and Freedom 

Watch, a former candidate for the U.S. Senate in Florida, a former trial attorney and prosecutor 

of the Antitrust Division of the U.S. Department of Justice, where he was a member of the trial 

team that successfully broke up the AT&T monopoly and created competition in the 

telecommunications industry. Among many other legal victories, Plaintiff Klayman also won 

landmark decisions at the chairman and general counsel of Freedom Watch enjoining the illegal 

mass surveillance by the National Security Agency. Klayman v. Obama, 1:13-cv-851 (D.D.C). 

See Exhibit 6 --Klayman biography, which is incorporated herein by reference. Stone knew this 

when he published the malicious false and misleading statements about Klayman and thus 

willfully and maliciously defamed Plaintiff Klayman.

62. At 2:01 in the January 18 Video, Stone maliciously falsely and misleadingly 

published that Plaintiff Klayman is a “piece of garbage.”

63. At 4:11 in the January 18 Video, Stone maliciously falsely and misleadingly 

published, “For those people out there who think...that Larry Klayman’s IQ is higher than 70, 

you’re wrong...”

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 14 of 109
15

64. Defendants published these malicious false, misleading, and defamatory

statements with malice and with full knowledge that they were false and misleading, and/or at a 

minimum, with a reckless disregard for its truthfulness. These statements falsely and 

misleadingly state that Plaintiff Corsi was fired from World Net Daily, that he committed perjury 

(a federal offense), and that he is an untruthful person. They also create the false and misleading 

implication that Plaintiff Klayman is unqualified to be an attorney, public advocate and is a bad 

and loathsome person. Plaintiff Klayman is also an author, columnist and nationally syndicated 

radio and internet talk show host on Radio America, his show titled “Special Prosecutor with 

Larry Klayman.” See www.radioamerica.com. The malicious false and misleading published 

statements as alleged herein also severely damaged Plaintiff Klayman personally and 

professionally in this regard, particularly since he and his show compete with Defendant 

InfoWars and and the other Defendants in media markets in this district, nationally and 

internationally. Plaintiff Corsi also competes with Defendant InfoWars and the other Defendants 

in media markets in this district, nationally and internationally.

III. Other Malicious Defamatory Publications

65. In another appearance on InfoWars which was posted to YouTube12 on January 

17, 2019, Stone at 6:22 maliciously falsely and misleadingly published that “He [Corsi] was 

perfectly willing to bear false witness against me on multiple points that are complete 

fabrications.”

66. In another appearance on InfoWars, this time on The Alex Jones Show from 

January 21, 2019, Stone maliciously falsely and misleadingly published that “the good doctor 

[Corsi] has told a number of lies. In fact, he’s starting to conflate his lies.... he was perfectly 

willing to lie about me.... but now lying about Alex Jones, lying about InfoWars, lying about Dr. 

 12 https://www.youtube.com/watch?v=GJd8YBDvm1Q

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 15 of 109
16

(David) Jones, who’s one of the nicest, gentlest, sweetest, most honest men I have ever met, it’s 

beyond the pale.... Jerry Corsi can no longer be believed.”

13

67. In the same appearance, Stone maliciously falsely and misleadingly published

that, “I think you’ve [Corsi] been deep state from the beginning. Your whole birther thing is used 

as a club to destroy conservatives.... I look forward to our confrontation. I will demolish you. 

You’re a fraudster, out of your alcoholic haze you have made up lies about David Jones and Alex 

Jones and Roger Stone and now I suspect they want you to lie about the President.” This is 

clearly a threat, as well as being maliciously defamatory. It is akin to the threats against Person 2 

in the Mueller Indictment, Randy Credico, who Defendant Stone, as set forth in the Mueller 

Indictment, based on Stone’s own words contained in his own documentary evidence, threatened 

kill along with Credico’s service dog. Later Stone threatened the judge presiding over his 

criminal prosecution, the Honorable Amy Berman Jackson.

68. In the same January 21, 2019 video, at 43:40, Defendant Alex Jones maliciously 

and falsely accuses Plaintiff Corsi of being a “spook, back and forth with different agencies,” 

falsely saying that Dr. Corsi had worked with different government agencies.

69. Defendant Alex Jones further maliciously falsely accuses Plaintiff Corsi of 

sometimes “not being able to walk,” creating the false and defamatory implication that he is an 

alcoholic.

70. Defendants in concert published these false, misleading, and defamatory

statements in concert with Stone with malice and with full knowledge that they were false and 

misleading, and/or at a minimum, with a reckless disregard for their truthfulness. These 

statements falsely and misleadingly published that Plaintiff Corsi committed perjury (a federal 

offense), is an untruthful person, and is an alcoholic. They also contain threats against Plaintiff 

 13 https://www.youtube.com/watch?v=ANfe9d7YzL0 (Beginning at 38:00)

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 16 of 109
17

Corsi and his legal counsel Larry Klayman. Defendants, working in concert with Stone, 

obviously believe that in order to advance their interests and improper if not criminal 

motivations, they also have to destroy and severely harm the legal counsel of Plaintiff Corsi, who 

is representing Plaintiff Corsi before Special Counsel Robert Mueller, congressional committees

and generally and will also counsel Plaintiff Corsi should he be subpoenaed to testify truthfully 

in Stone’s upcoming criminal trial for perjury, witness tampering, threatening to kill a material 

witness and his service dog, as well as obstruction of justice.

FACTS PERTAINING TO DEFENDANTS’ UNFAIR COMPETITION

71. In addition to being an investigative journalist/author and a public interest 

litigator/advocate, respectively, Plaintiffs Corsi and Plaintiff Klayman are both competitors to 

Defendants as conservative media personalities, broadcasters, authors and columnists on social 

media and elsewhere.

72. For instance, Plaintiff Klayman also hosts an online radio show and produces 

videos that are posted on the internet, issues press releases, commentary and other publications.

73. Defendants have made, adopted, and or ratified numerous false or misleading 

statements of fact of and concerning Plaintiffs during their various programs and media postings 

and publication, which all contain significant advertisement or promotions.

74. These false and/or misleading facts materially prejudice the viewers and/or 

listeners as to the quality, nature, and contents of Plaintiffs’ services, which has caused 

significant competitive and commercial injury to Plaintiffs, as well as loss of good will and 

reputation.

75. Plaintiffs, like Defendants, rely on viewer and listener financial support and sales 

in order to continue their work. Defendants’ false and/or misleading statements concerning 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 17 of 109
18

Plaintiffs is meant to, and has, diverted financial support and sales away from Plaintiffs and to 

Defendants instead.

FIRST CAUSE OF ACTION

Defamation

76. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

77. Acting in concert Defendants published malicious, false, misleading and 

defamatory statements of and concerning Plaintiffs in this judicial district, nationwide, and 

worldwide.

78. These false and misleading statements were published with malice, as Defendants 

knew that they were false and misleading, or at a minimum acted with a reckless disregard for 

the truth.

79. Plaintiffs have been severely harmed and damaged by these false and misleading 

statements because they subjected him to hatred, distrust, ridicule, contempt, and disgrace.

80. Plaintiffs have been damaged by these false and misleading statements because 

they severely injured Plaintiff Corsi and Plaintiff Klayman in their profession and businesses, as

well as severely injured and damaged them personally, financially and in terms of their good will 

and reputations.

SECOND CAUSE OF ACTION

Defamation Per Se

81. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

82. Acting in concert, Defendants as alleged herein, published numerous false, 

misleading and defamatory statements to severely harm and damage Plaintiffs, which were 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 18 of 109
19

republished elsewhere, and through surrogates, which published the falsity that Plaintiffs have

committed crimes, including perjury, and engaged in moral turpitude in the form of alcoholism,

and committed sexual misconduct, as set forth in the preceding paragraphs. 

83. These false, misleading and defamatory statements were published in this district 

and on the internet and elsewhere, domestically and for the entire world to see and hear and in so 

doing Defendants published false and misleading facts, inter alia, that Plaintiffs’ conduct, 

characteristics or a condition are incompatible with the proper exercise of their lawful business, 

trade, profession or office, as well as personally.

84. These false and misleading statements were published with malice, as Defendants

knew that they were false and misleading, and/or at a minimum acted with a reckless disregard 

for the truth.

85. This statements are per se defamatory because they falsely and misleadingly 

published that Plaintiff Corsi committed perjury and Plaintiff Klayman had committed sexual 

misconduct which are federal offense and felony. Defamation per se gives rise to the 

presumption that severe harm and damage has arisen by virtue of the malicious false and 

misleading statements.

86. These malicious false, misleading, and defamatory statements are defamatory per 

se and these false and misleading statements severely harmed and damaged Plaintiff Corsi in this 

profession and business as a journalist, author and political commentator, whose credibility is the 

most important trait, as well as personally and Plaintiff Klayman in his profession as a public 

interest and private advocate and litigator and as an author, columnist and radio and internet 

radio talk show and syndicated host, as well as personally.

THIRD CAUSE OF ACTION

Defamation by Implication

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 19 of 109
20

87. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

88. Acting in concert, Defendants published numerous false, misleading and 

defamatory statements about Plaintiffs, as set forth in the preceding paragraphs.

89. These false, misleading and defamatory statements were published on the internet 

and published and republished elsewhere in this district, domestically and for the entire world to 

see and hear. 

90. These false and misleading statements were published with malice, as Defendants

knew that they were false and misleading, and/or at a minimum acted with a reckless disregard 

for the truth.

91. These statements created the false and misleading implication that Plaintiff Corsi

is dishonest, committed perjury and is an alcoholic, and that Plaintiff Klayman committed sexual 

misconduct and is incompetent, among other false and misleading statements as pled in the 

preceding paragraphs. 

92. Plaintiffs have been severely harmed and damaged by these false and misleading 

statements because they subject him to hatred, distrust, ridicule, contempt, and disgrace.

93. Plaintiffs has been damaged by these malicious false and misleading statements 

because the statements severely harmed and damaged Plaintiffs in their professions as 

journalists, authors, columnists, pubic interest and private practitioner lawyers and radio talk 

show hosts, whose credibility is the most important trait, as well as personally.

FOURTH CAUSE OF ACTION

Intentional Infliction of Emotional Distress

94. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 20 of 109
21

paragraphs of the Complaint as if fully set forth herein.

95. Acting in concert, Defendants engaged in extreme and outrageous conduct by 

threatening Plaintiffs, in concert with Stone, who has made death threats to at least one witness 

involved in Special Counsel Mueller’s Russian collusion investigation, Person 2 Randy Credico, 

as well as incited violence against Judge Amy Berman Jackson by posting a meme on Instagram 

with a crosshairs and gun pointed at the jurist’s head, for which Stone was sanctioned with a total 

gag order and threat of incarceration if this type of violative conduct of the Court’s gag order 

occurred again, which it apparently has. See Exhibit 7.

96. Defendants knowingly and intentionally threatened Plaintiffs, in a manner similar 

to other death threats co-conspirator Stone made to at least one material witness, involved in 

Special Counsel Mueller’s Russian collusion investigation, such as Randy Credico, Person 2 in 

the Mueller Indictment, as well as Judge Amy Berman Jackson.

97. Defendants’ extreme and outrageous conduct directly caused Plaintiffs severe 

emotional distress and resulting severe harm and damage.

FIFTH CAUSE OF ACTION

Assault

98. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

99. Acting in concert, Defendants placed Plaintiffs in apprehension of an imminent 

harmful or offensive contact and physical harm and death, by coercing and threatening Plaintiffs, 

in a similar manner that co-conspirator Stone has used to make death threats to at least one 

material witness involved in Special Counsel Mueller’s Russian collusion investigation, such as 

Person 2 in the Mueller Indictment, Randy Credico and Judge Amy Berman Jackson.

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 21 of 109
22

100. The threats issued by Defendants are credible, as co-conspirator Stone portrays 

and sees himself as a “Mafia” figure, as set forth above.

101. Furthermore, as set forth above, acting in concert Defendants have a pattern and 

practice of calling their followers “to arms,” which has resulted in deadly violence against their 

victims.

102. Plaintiffs did not consent to Defendants’ conduct.

103. As a direct and proximate result of Defendants’ wrongful conduct, Plaintiffs

suffered conscious pain, suffering, severe emotional distress and the fear of imminent serious 

bodily injury or death, and other mental and physical injuries, and Plaintiffs were severely 

harmed and damaged thereby.

SIXTH CAUSE OF ACTION

Unfair Competition – Lanham Act 15 U.S.C. § 1125(a)

104. Plaintiffs re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

105. Defendants have and are engaged in acts of unfair competition in violation of the 

Lanham Act, 15 U.S.C. § 1125(a) and common law

106. Defendants have made false and/or misleading statements that have deceived 

and/or had the tendency to deceive a substantial segment of the receiving audience.

107. Defendants’ false and/or misleading statements misrepresent the nature, 

characteristics, and qualities of Plaintiff Klayman and Plaintiff Corsi’s goods or services.

108. Defendants false and/or misleading statements are material because that were 

highly likely to mislead and influence supporters’ decisions to provide financial support and 

sales to Defendants instead of Plaintiffs

109. These false and misleading statements were made in interstate commerce, as they 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 22 of 109
23

were widely broadcast on radio, on the internet, in social media, and elsewhere in this district, 

nationally and internationally.

110. Plaintiffs have suffered significant damages, which are ongoing, due to 

Defendants’ false and/or misleading statements. By law these damages are calculated based on

Defendants’ gross sales and receipts, which are trebled, plus an award of attorneys fees and 

costs.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:

a. Awarding Plaintiffs compensatory including actual, consequential, incidental and 

punitive damages for malicious tortious concerted conduct, jointly and severally in an amount to 

be determined at trial and in excess of $50, 000,000 U.S. Dollars for each Plaintiff.

b. Awarding Treble Damages Under the Lanham Act, 15 U.S.C. 1125(a).

c. Awarding Plaintiffs attorney fees and costs

d. Granting such other relief as the Court deems appropriate and necessary including 

preliminary and permanent injunctive relief. 

 PLAINTIFFS DEMAND TRIAL BY JURY ON ALL CLAIMS SO TRIABLE.

Dated: March 7, 2019 Respectfully Submitted, 

 /s/ Larry Klayman 

Larry Klayman, Esq.

KLAYMAN LAW GROUP, P.A.

D.C. Bar Number: 334581

2020 Pennsylvania Ave NW #800

Washington, DC, 20006

Telephone: (310)-595-0800

Email: leklayman@gmail.com

Counsel for Plaintiffs Corsi and 

Klayman

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 23 of 109
EXHIBIT 1

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 24 of 109
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA

v. 

ROGER JASON STONE, JR., 

Defendant.

*

* 

* 

* 

* 

* 

* 

* 

* 

*

*******

CRIMINAL NO.

Grand Jury Original

18 U.S.C. §§ 1001, 1505, 1512, 2 

INDICTMENT

The Grand Jury for the District of Columbia charges: 

Introduction 

1. By in or around May 2016, the Democratic National Committee (“DNC”) and the 

Democratic Congressional Campaign Committee (“DCCC”) became aware that their computer 

systems had been compromised by unauthorized intrusions and hired a security company 

(“Company 1”) to identify the extent of the intrusions. 

2. On or about June 14, 2016, the DNC—through Company 1—publicly announced that it

had been hacked by Russian government actors. 

3. From in or around July 2016 through in or around November 2016, an organization 

(“Organization 1”), which had previously posted documents stolen by others from U.S. persons, 

entities, and the U.S. government, released tens of thousands of documents stolen from the DNC

and the personal email account of the chairman of the U.S. presidential campaign of Hillary

Clinton (“Clinton Campaign”). 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 25 of 109
2

a. On or about July 22, 2016, Organization 1 released documents stolen from the 

DNC. 

b. Between on or about October 7, 2016 and on or about November 7, 2016, 

Organization 1 released approximately 33 tranches of documents that had been 

stolen from the personal email account of the Clinton Campaign chairman, totaling 

over 50,000 stolen documents. 

4. ROGER JASON STONE, JR. was a political consultant who worked for decades in U.S. 

politics and on U.S. political campaigns. STONE was an official on the U.S. presidential campaign 

of Donald J. Trump (“Trump Campaign”) until in or around August 2015, and maintained regular 

contact with and publicly supported the Trump Campaign through the 2016 election. 

5. During the summer of 2016, STONE spoke to senior Trump Campaign officials about 

Organization 1 and information it might have had that would be damaging to the Clinton 

Campaign. STONE was contacted by senior Trump Campaign officials to inquire about future 

releases by Organization 1. 

6. By in or around early August 2016, STONE was claiming both publicly and privately to

have communicated with Organization 1. By in or around mid-August 2016, Organization 1 made 

a public statement denying direct communication with STONE. Thereafter, STONE said that his 

communication with Organization 1 had occurred through a person STONE described as a “mutual 

friend,” “go-between,” and “intermediary.” STONE also continued to communicate with members

of the Trump Campaign about Organization 1 and its intended future releases. 

7. After the 2016 U.S. presidential election, the U.S. House of Representatives Permanent 

Select Committee on Intelligence (“HPSCI”), the U.S. Senate Select Committee on Intelligence 

(“SSCI”), and the Federal Bureau of Investigation (“FBI”) opened or announced their respective 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 26 of 109
3

investigations into Russian interference in the 2016 U.S. presidential election, which included 

investigating STONE’s claims of contact with Organization 1. 

8. In response, STONE took steps to obstruct these investigations. Among other steps to

obstruct the investigations, STONE: 

a. Made multiple false statements to HPSCI about his interactions regarding 

Organization 1, and falsely denied possessing records that contained evidence of 

these interactions; and 

b. Attempted to persuade a witness to provide false testimony to and withhold 

pertinent information from the investigations. 

Other Relevant Individuals 

9. Person 1 was a political commentator who worked with an online media publication during 

the 2016 U.S. presidential campaign. Person 1 spoke regularly with STONE throughout the 

campaign, including about the release of stolen documents by Organization 1. 

10. Person 2 was a radio host who had known STONE for more than a decade. In testimony 

before HPSCI on or about September 26, 2017, STONE described Person 2 (without naming him) 

as an “intermediary,” “go-between,” and “mutual friend” to the head of Organization 1. In a 

follow-up letter to HPSCI dated October 13, 2017, STONE identified Person 2 by name and 

claimed Person 2 was the “gentleman who confirmed for Mr. Stone” that the head of

Organization 1 had “‘[e]mails related to Hillary Clinton which are pending publication.’” 

Background 

STONE’s Communications About Organization 1 During the Campaign 

11. By in or around June and July 2016, STONE informed senior Trump Campaign officials

that he had information indicating Organization 1 had documents whose release would be

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 27 of 109
4

damaging to the Clinton Campaign. The head of Organization 1 was located at all relevant times

at the Ecuadorian Embassy in London, United Kingdom. 

12. After the July 22, 2016 release of stolen DNC emails by Organization 1, a senior Trump 

Campaign official was directed to contact STONE about any additional releases and what other 

damaging information Organization 1 had regarding the Clinton Campaign. STONE thereafter 

told the Trump Campaign about potential future releases of damaging material by Organization 1. 

13. STONE also corresponded with associates about contacting Organization 1 in order to

obtain additional emails damaging to the Clinton Campaign. 

a. On or about July 25, 2016, STONE sent an email to Person 1 with the subject line, 

“Get to [the head of Organization 1].” The body of the message read, “Get to [the 

head of Organization 1] [a]t Ecuadorian Embassy in London and get the pending 

[Organization 1] emails . . . they deal with Foundation, allegedly.” On or about the 

same day, Person 1 forwarded STONE’s email to an associate who lived in the

United Kingdom and was a supporter of the Trump Campaign. 

b. On or about July 31, 2016, STONE emailed Person 1 with the subject line, “Call

me MON.” The body of the email read in part that Person 1’s associate in the 

United Kingdom “should see [the head of Organization 1].” 

c. On or about August 2, 2016, Person 1 emailed STONE. Person 1 wrote that he was

currently in Europe and planned to return in or around mid-August. Person 1 stated

in part, “Word is friend in embassy plans 2 more dumps. One shortly after I’m 

back. 2nd in Oct. Impact planned to be very damaging.” The phrase “friend in

embassy” referred to the head of Organization 1. Person 1 added in the same email, 

“Time to let more than [the Clinton Campaign chairman] to be exposed as in bed w 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 28 of 109
5

enemy if they are not ready to drop HRC. That appears to be the game hackers are

now about. Would not hurt to start suggesting HRC old, memory bad, has stroke – 

neither he nor she well. I expect that much of next dump focus, setting stage for

Foundation debacle.” 

14. Starting in early August 2016, after receiving the August 2, 2016 email from Person 1, 

STONE made repeated statements about information he claimed to have learned from the head of 

Organization 1. 

a. On or about August 8, 2016, STONE attended a public event at which he stated, “I 

actually have communicated with [the head of Organization 1]. I believe the next 

tranche of his documents pertain to the Clinton Foundation, but there’s no telling 

what the October surprise may be.” 

b. On or about August 12, 2016, STONE stated during an interview that he was “in

communication with [the head of Organization 1]” but was “not at liberty to discuss 

what I have.” 

c. On or about August 16, 2016, STONE stated during an interview that “it became 

known on this program that I have had some back-channel communication with

[Organization 1] and [the head of Organization 1].” In a second interview on or 

about the same day, STONE stated that he “communicated with [the head of 

Organization 1]” and that they had a “mutual acquaintance who is a fine 

gentleman.” 

d. On or about August 18, 2016, STONE stated during a television interview that he 

had communicated with the head of Organization 1 through an “intermediary, 

somebody who is a mutual friend.” 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 29 of 109
6

e. On or about August 23, 2016, Person 2 asked STONE during a radio interview, 

“You’ve been in touch indirectly with [the head of Organization 1]. . . . Can you 

give us any kind of insight? Is there an October surprise happening?” STONE

responded, “Well, first of all, I don’t want to intimate in any way that I control or 

have influence with [the head of Organization 1] because I do not. . . . We have a 

mutual friend, somebody we both trust and therefore I am a recipient of pretty good 

information.” 

15. Beginning on or about August 19, 2016, STONE exchanged written communications, 

including by text message and email, with Person 2 about Organization 1 and what the head of 

Organization 1 planned to do. 

a. On or about August 19, 2016, Person 2 sent a text message to STONE that read in

part, “I’m going to have [the head of Organization 1] on my show next Thursday.” 

On or about August 21, 2016, Person 2 sent another text message to STONE,

writing in part, “I have [the head of Organization 1] on Thursday so I’m completely 

tied up on that day.” 

b. On or about August 25, 2016, the head of Organization 1 was a guest on Person 2’s 

radio show for the first time. On or about August 26, 2016, Person 2 sent a text

message to STONE that stated, “[the head of Organization 1] talk[ed] about you 

last night.” STONE asked what the head of Organization 1 said, to which Person 2 

responded, “He didn’t say anything bad we were talking about how the Press is

trying to make it look like you and he are in cahoots.” 

c. On or about August 27, 2016, Person 2 sent text messages to STONE that said, “We

are working on a [head of Organization 1] radio show,” and that he (Person 2) was

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 30 of 109
7

“in charge” of the project. In a text message sent later that day, Person 2 added, 

“[The head of Organization 1] has kryptonite on Hillary.” 

d. On or about September 18, 2016, STONE sent a text message to Person 2 that said, 

“I am e-mailing u a request to pass on to [the head of Organization 1].” Person 2 

responded “Ok,” and added in a later text message, “[j]ust remember do not name 

me as your connection to [the head of Organization 1] you had one before that you 

referred to.” 

i. On or about the same day, September 18, 2016, STONE emailed

Person 2 an article with allegations against then-candidate Clinton 

related to her service as Secretary of State. STONE stated, “Please

ask [the head of Organization 1] for any State or HRC e-mail from 

August 10 to August 30—particularly on August 20, 2011 that 

mention [the subject of the article] or confirm this narrative.” 

ii. On or about September 19, 2016, STONE texted Person 2 again, 

writing, “Pass my message . . . to [the head of Organization 1].” 

Person 2 responded, “I did.” On or about September 20, 2016, 

Person 2 forwarded the request to a friend who was an attorney with

the ability to contact the head of Organization 1. Person 2 blindcopied STONE on the forwarded email. 

e. On or about September 30, 2016, Person 2 sent STONE via text message a 

photograph of Person 2 standing outside the Ecuadorian Embassy in London where 

the head of Organization 1 was located. 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 31 of 109
8

f. On or about October 1, 2016, which was a Saturday, Person 2 sent STONE text

messages that stated, “big news Wednesday . . . now pretend u don’t know me . . . 

Hillary’s campaign will die this week.” In the days preceding these messages, the

press had reported that the head of Organization 1 planned to make a public 

announcement on or about Tuesday, October 4, 2016, which was reported to be the 

ten-year anniversary of the founding of Organization 1. 

g. On or about October 2, 2016, STONE emailed Person 2, with the subject line 

“WTF?,” a link to an article reporting that Organization 1 was canceling its “highly 

anticipated Tuesday announcement due to security concerns.” Person 2 responded 

to STONE, “head fake.” 

h. On or about the same day, October 2, 2016, STONE texted Person 2 and asked, 

“Did [the head of Organization 1] back off.” On or about October 3, 2016, Person 

2 initially responded, “I can’t tal[k] about it.” After further exchanges with

STONE, Person 2 said, “I think it[’]s on for tomorrow.” Person 2 added later that 

day, “Off the Record Hillary and her people are doing a full-court press they [sic] 

keep [the head of Organization 1] from making the next dump . . . That’s all I can

tell you on this line . . . Please leave my name out of it.” 

16. In or around October 2016, STONE made statements about Organization 1’s future 

releases, including statements similar to those that Person 2 made to him. For example: 

a. On or about October 3, 2016, STONE wrote to a supporter involved with the Trump 

Campaign, “Spoke to my friend in London last night. The payload is still coming.” 

b. Also on or about October 3, 2016, STONE received an email from a reporter who 

had connections to a high-ranking Trump Campaign official that asked, “[the head 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 32 of 109
9

of Organization 1] – what’s he got? Hope it’s good.” STONE responded in part, 

“It is. I’d tell [the high-ranking Trump Campaign official] but he doesn’t call me

back.” 

c. On or about October 4, 2016, the head of Organization 1 held a press conference 

but did not release any new materials pertaining to the Clinton Campaign. Shortly 

afterwards, STONE received an email from the high-ranking Trump Campaign 

official asking about the status of future releases by Organization 1. STONE

answered that the head of Organization 1 had a “[s]erious security concern” but that 

Organization 1 would release “a load every week going forward.” 

d. Later that day, on or about October 4, 2016, the supporter involved with the Trump 

Campaign asked STONE via text message if he had “hear[d] anymore from 

London.” STONE replied, “Yes - want to talk on a secure line - got Whatsapp?” 

STONE subsequently told the supporter that more material would be released and 

that it would be damaging to the Clinton Campaign. 

17. On or about October 7, 2016, Organization 1 released the first set of emails stolen from the 

Clinton Campaign chairman. Shortly after Organization 1’s release, an associate of the highranking Trump Campaign official sent a text message to STONE that read “well done.” In

subsequent conversations with senior Trump Campaign officials, STONE claimed credit for

having correctly predicted the October 7, 2016 release. 

The Investigations 

18. In or around 2017, government officials publicly disclosed investigations into Russian 

interference in the 2016 U.S. presidential election and possible links to individuals associated with

the campaigns. 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 33 of 109
10

a. On or about January 13, 2017, the chairman and vice chairman of SSCI announced 

the committee would conduct an inquiry that would investigate, among other 

things, any intelligence regarding links between Russia and individuals associated 

with political campaigns, as well as Russian cyber activity and other “active 

measures” directed against the United States in connection with the 2016 election. 

b. On or about January 25, 2017, the chairman and ranking member of HPSCI

announced that HPSCI had been conducting an inquiry similar to SSCI’s. 

c. On or about March 20, 2017, the then-director of the FBI testified at a HPSCI

hearing and publicly disclosed that the FBI was investigating Russian interference 

in the 2016 election and possible links and coordination between the Trump 

Campaign and the Russian government. 

d. By in or around August 2017, news reports stated that a federal grand jury had 

opened an investigation into matters relating to Russian government efforts to

interfere in the 2016 election, including possible links and coordination between 

the Trump Campaign and the Russian government. 

STONE’s False Testimony to HPSCI

19. In or around May 2017, HPSCI sent a letter requesting that STONE voluntarily appear 

before the committee and produce: 

Any documents, records, electronically stored information 

including e-mail, communication, recordings, data and tangible 

things (including, but not limited to, graphs, charts, photographs, 

images and other documents) regardless of form, other than those 

widely available (e.g., newspaper articles) that reasonably could 

lead to the discovery of any facts within the investigation’s publiclyannounced parameters.

On or about May 22, 2017, STONE caused a letter to be submitted to HPSCI stating that “Mr.

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 34 of 109
11

Stone has no documents, records, or electronically stored information, regardless of form, other 

than those widely available that reasonably could lead to the discovery of any facts within the 

investigation’s publicly-announced parameters.” 

20. On or about September 26, 2017, STONE testified before HPSCI in Washington, D.C. as

part of the committee’s ongoing investigation. In his opening statement, STONE stated, “These 

hearings are largely based on a yet unproven allegation that the Russian state is responsible for the 

hacking of the DNC and [the Clinton Campaign chairman] and the transfer of that information to

[Organization 1].” STONE further stated that “[m]embers of this Committee” had made certain

“assertions against me which must be rebutted here today,” which included “[t]he charge that I 

knew in advance about, and predicted, the hacking of Clinton campaign chairman[’s] email, [and] 

that I had advanced knowledge of the source or actual content of the [Organization 1] disclosures 

regarding Hillary Clinton.” 

21. In the course of his HPSCI testimony, STONE made deliberately false and misleading 

statements to the committee concerning, among other things, his possession of documents 

pertinent to HPSCI’s investigation; the source for his early August 2016 statements about 

Organization 1; requests he made for information from the head of Organization 1; his 

communications with his identified intermediary; and his communications with the Trump 

Campaign about Organization 1. 

STONE’s False and Misleading Testimony About His Possession of Documents Pertinent to

HPSCI’s Investigation 

22. During his HPSCI testimony, STONE was asked, “So you have no emails to anyone 

concerning the allegations of hacked documents . . . or any discussions you have had with third 

parties about [the head of Organization 1]? You have no emails, no texts, no documents 

whatsoever, any kind of that nature?” STONE falsely and misleadingly answered, “That is correct. 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 35 of 109
12

Not to my knowledge.” 

23. In truth and in fact, STONE had sent and received numerous emails and text messages

during the 2016 campaign in which he discussed Organization 1, its head, and its possession of

hacked emails. At the time of his false testimony, STONE was still in possession of many of these 

emails and text messages, including: 

a. The email from STONE to Person 1 on or about July 25, 2016 that read in part, 

“Get to [the head of Organization 1] [a]t Ecuadorian Embassy in London and get

the pending [Organization 1] emails . . . they deal with Foundation, allegedly.”; 

b. The email from STONE to Person 1 on or about July 31, 2016 that said an associate 

of Person 1 “should see [the head of Organization 1].”; 

c. The email from Person 1 to STONE on or about August 2, 2016 that stated in part, 

“Word is friend in embassy plans 2 more dumps. One shortly after I’m back. 2nd 

in Oct. Impact planned to be very damaging.”; 

d. Dozens of text messages and emails, beginning on or about August 19, 2016 and 

continuing through the election, between STONE and Person 2 in which they 

discussed Organization 1 and the head of Organization 1; 

e. The email from STONE on or about October 3, 2016 to the supporter involved with

the Trump Campaign, which read in part, “Spoke to my friend in London last night. 

The payload is still coming.”; and 

f. The emails on or about October 4, 2016 between STONE and the high-ranking 

member of the Trump Campaign, including STONE’s statement that Organization 

1 would release “a load every week going forward.” 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 36 of 109
13

24. By falsely claiming that he had no emails or text messages in his possession that referred

to the head of Organization 1, STONE avoided providing a basis for HPSCI to subpoena records 

in his possession that could have shown that other aspects of his testimony were false and 

misleading. 

STONE’s False and Misleading Testimony About His Early August 2016 Statements 

25. During his HPSCI testimony on or about September 26, 2017, STONE was asked to

explain his statements in early August 2016 about being in contact with the head of Organization 1. 

STONE was specifically asked about his statement on or about August 8, 2016 that “I’ve actually 

communicated with [the head of Organization 1],” as well as his statement on or about August 12, 

2016 that he was “in communication with [the head of Organization 1]” but was “not at liberty to

discuss what I have.” 

26. STONE responded that his public references to having a means of contacting Organization 

1 referred exclusively to his contact with a journalist, who STONE described as a “go-between, as

an intermediary, as a mutual friend” of the head of Organization 1. STONE stated that he asked 

this individual, his intermediary, “to confirm what [the head of Organization 1] ha[d] tweeted, 

himself, on July 21st, that he ha[d] the Clinton emails and that he [would] publish them.” STONE

further stated that the intermediary “was someone I knew had interviewed [the head of 

Organization 1]. And I merely wanted confirmation of what he had tweeted on the 21st.” STONE

declined to tell HPSCI the name of this “intermediary” but provided a description in his testimony 

that was consistent with Person 2. 

27. On or about October 13, 2017, STONE caused a letter to be submitted to HPSCI that 

identified Person 2 by name as the “gentleman who confirmed for Mr. Stone” that the head of

Organization 1 had “‘[e]mails related to Hillary Clinton which are pending publication.’” 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 37 of 109
14

28. STONE’s explanation of his August 2016 statements about communicating with the head 

of Organization 1 was false and misleading. In truth and in fact, the first time Person 2 interviewed 

the head of Organization 1 was on or about August 25, 2016, after STONE made his August 8 and 

August 12, 2016 public statements. Similarly, at the time STONE made his August 2016 

statements, STONE had directed Person 1—not Person 2—to contact the head of Organization 1. 

And Person 1—not Person 2—had told STONE in advance of STONE’s August 8 and August 12, 

2016 public statements that “[w]ord is friend in embassy plans 2 more dumps,” including one in

October. At no time did STONE identify Person 1 to HPSCI as another individual STONE

contacted to serve as a “go-between,” “intermediary,” or other source of information from 

Organization 1. STONE also never disclosed his exchanges with Person 1 when answering 

HPSCI’s questioning about STONE’s August 8 and August 12, 2016 statements. 

STONE’s False and Misleading Testimony About Requests He Made for Information from the 

Head of Organization 1 

29. During his HPSCI testimony, STONE was asked, “[W]hat was the extent of the 

communication with [the intermediary]?” STONE replied, “I asked him to confirm . . . that the 

tweet of [the head of Organization 1] of the 21st was accurate, that they did in fact have . . . Hillary

Clinton emails and that they would release them.” STONE was then asked, “Did you ask [the 

intermediary] to communicate anything else to [the head of Organization 1]?” STONE falsely and 

misleadingly responded, “I did not.” STONE was then asked, “Did you ask [the intermediary] to

do anything on your own behalf?” STONE falsely and misleadingly responded, “I did not.” 

30. In truth and in fact, STONE directed both Person 1 and Person 2 to pass on requests to the 

head of Organization 1 for documents that STONE believed would be damaging to the Clinton 

Campaign. For example: 

a. As described above, on or about July 25, 2016, STONE sent Person 1 an email that 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 38 of 109
15

read, “Get to [the head of Organization 1] [a]t Ecuadorian Embassy in London and 

get the pending [Organization 1] emails . . . they deal with Foundation, allegedly.” 

b. On or about September 18, 2016, STONE sent a text message to Person 2 that said, 

“I am e-mailing u a request to pass on to [the head of Organization 1],” and then 

emailed Person 2 an article with allegations against then-candidate Clinton related

to her service as Secretary of State. STONE added, “Please ask [the head of 

Organization 1] for any State or HRC e-mail from August 10 to August 30—

particularly on August 20, 2011 that mention [the subject of the article] or confirm 

this narrative.” 

c. On or about September 19, 2016, STONE texted Person 2 again, writing “Pass my

message . . . to [the head of Organization 1].” Person 2 responded, “I did,” and the 

next day Person 2, on an email blind-copied to STONE, forwarded the request to

an attorney who had the ability to contact the head of Organization 1. 

STONE’s False and Misleading Testimony About Communications with His Identified 

Intermediary 

31. During his HPSCI testimony, STONE was asked repeatedly about his communications 

with the person he identified as his intermediary. STONE falsely and misleadingly stated that he

had never communicated with his intermediary in writing in any way. During one exchange, 

STONE falsely and misleadingly claimed only to have spoken with the intermediary 

telephonically: 

Q: [H]ow did you communicate with the intermediary? 

A: Over the phone. 

Q: And did you have any other means of communicating with

the intermediary? 

A: No. 

Q: No text messages, no – none of the list, right? 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 39 of 109
16

A: No. 

Later during his testimony, STONE again falsely denied ever communicating with his 

intermediary in writing: 

Q: So you never communicated with your intermediary in

writing in any way? 

A: No. 

Q: Never emailed him or texted him? 

A: He’s not an email guy. 

Q: So all your conversations with him were in person or over 

the phone. 

A: Correct. 

32. In truth and in fact, as described above, STONE and Person 2 (who STONE identified to

HPSCI as his intermediary) engaged in frequent written communication by email and text

message. STONE also engaged in frequent written communication by email and text message

with Person 1, who also provided STONE with information regarding Organization 1. 

33. Written communications between STONE and Person 1 and between STONE and Person 2 

continued through STONE’s HPSCI testimony. Indeed, on or about September 26, 2017—the day

that STONE testified before HPSCI and denied having ever sent or received emails or text

messages from Person 2—STONE and Person 2 exchanged over thirty text messages. 

34. Certain electronic messages between STONE and Person 1 and between STONE and 

Person 2 would have been material to HPSCI. For example: 

a. In or around July 2016, STONE emailed Person 1 to “get to” the head of 

Organization 1 and obtain the pending emails. 

b. In or around September 2016, STONE sent messages directing Person 2 to pass a 

request to the head of Organization 1. 

c. On or about January 6, 2017, Person 2 sent STONE an email that had the subject 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 40 of 109
17

line “Back channel bs.” In the email, Person 2 wrote, “Well I have put together 

timelines[] and you [] said you have a back-channel way back a month before I had

[the head of Organization 1] on my show . . . I have never had a conversation with

[the head of Organization 1] other than my radio show . . . I have pieced it all

together . . . so you may as well tell the truth that you had no back-channel or there’s 

the guy you were talking about early August.” 

STONE’s False and Misleading Testimony About Communications with the Trump Campaign 

35. During his HPSCI testimony, STONE was asked, “did you discuss your conversations with

the intermediary with anyone involved in the Trump campaign?” STONE falsely and misleadingly 

answered, “I did not.” In truth and in fact, and as described above, STONE spoke to multiple 

individuals involved in the Trump Campaign about what he claimed to have learned from his 

intermediary to Organization 1, including the following: 

a. On multiple occasions, STONE told senior Trump Campaign officials about 

materials possessed by Organization 1 and the timing of future releases. 

b. On or about October 3, 2016, STONE wrote to a supporter involved with the Trump 

Campaign, “Spoke to my friend in London last night. The payload is still coming.” 

c. On or about October 4, 2016, STONE told a high-ranking Trump Campaign official 

that the head of Organization 1 had a “[s]erious security concern” but would release

“a load every week going forward.” 

Attempts to Prevent Person 2 from Contradicting STONE’s False Statements to HPSCI

36. On or about October 19, 2017, STONE sent Person 2 an excerpt of his letter to HPSCI that 

identified Person 2 as his “intermediary” to Organization 1. STONE urged Person 2, if asked by

HPSCI, to falsely confirm what STONE had previously testified to, including that it was Person 2 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 41 of 109
18

who provided STONE with the basis for STONE’s early August 2016 statements about contact 

with Organization 1. Person 2 repeatedly told STONE that his testimony was false and told him 

to correct his testimony to HPSCI. STONE did not do so. STONE then engaged in a prolonged 

effort to prevent Person 2 from contradicting STONE’s false statements to HPSCI. 

37. In or around November 2017, Person 2 received a request from HPSCI to testify voluntarily 

before the committee. After being contacted by HPSCI, Person 2 spoke and texted repeatedly with

STONE. In these discussions, STONE sought to have Person 2 testify falsely either that Person 2 

was the identified intermediary or that Person 2 could not remember what he had told STONE. 

Alternatively, STONE sought to have Person 2 invoke his Fifth Amendment right against selfincrimination. For example: 

a. On or about November 19, 2017, in a text message to STONE, Person 2 said that 

his lawyer wanted to see him (Person 2). STONE responded, “‘Stonewall it. Plead

the fifth. Anything to save the plan’ . . . Richard Nixon.” On or about November 

20, 2017, Person 2 informed HPSCI that he declined HPSCI’s request for a 

voluntary interview. 

b. On or about November 21, 2017, Person 2 texted STONE, “I was told that the house 

committee lawyer told my lawyer that I will be getting a subpoena.” STONE

responded, “That was the point at which your lawyers should have told them you 

would assert your 5th Amendment rights if compelled to appear.” 

c. On or about November 28, 2017, Person 2 received a subpoena compelling his 

testimony before HPSCI. Person 2 informed STONE of the subpoena. 

d. On or about November 30, 2017, STONE asked Person 1 to write publicly about 

Person 2. Person 1 responded, “Are you sure you want to make something out of 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 42 of 109
19

this now? Why not wait to see what [Person 2] does. You may be defending 

yourself too much—raising new questions that will fuel new inquiries. This may

be a time to say less, not more.” STONE responded by telling Person 1 that 

Person 2 “will take the 5th—but let’s hold a day.” 

e. On multiple occasions, including on or about December 1, 2017, STONE told 

Person 2 that Person 2 should do a “Frank Pentangeli” before HPSCI in order to

avoid contradicting STONE’s testimony. Frank Pentangeli is a character in the film

The Godfather: Part II, which both STONE and Person 2 had discussed, who 

testifies before a congressional committee and in that testimony claims not to know 

critical information that he does in fact know. 

f. On or about December 1, 2017, STONE texted Person 2, “And if you turned over 

anything to the FBI you’re a fool.” Later that day, Person 2 texted STONE, “You 

need to amend your testimony before I testify on the 15th.” STONE responded, “If

you testify you’re a fool. Because of tromp I could never get away with a certain

[sic] my Fifth Amendment rights but you can. I guarantee you you are the one who 

gets indicted for perjury if you’re stupid enough to testify.” 

38. On or about December 12, 2017, Person 2 informed HPSCI that he intended to assert his 

Fifth Amendment privilege against self-incrimination if required to appear by subpoena. Person 2 

invoked his Fifth Amendment privilege in part to avoid providing evidence that would show 

STONE’s previous testimony to Congress was false. 

39. Following Person 2’s invocation of his Fifth Amendment privilege not to testify before 

HPSCI, STONE and Person 2 continued to have discussions about the various investigations into 

Russian interference in the 2016 election and what information Person 2 would provide to

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 43 of 109
20

investigators. During these conversations, STONE repeatedly made statements intended to

prevent Person 2 from cooperating with the investigations. For example: 

a. On or about December 24, 2017, Person 2 texted STONE, “I met [the head of 

Organization 1] for f[i]rst time this yea[r] sept 7 . . . docs prove that. . . . You should 

be honest w fbi . . . there was no back channel . . . be honest.” STONE replied 

approximately two minutes later, “I’m not talking to the FBI and if your smart you 

won’t either.” 

b. On or about April 9, 2018, STONE wrote in an email to Person 2, “You are a rat. 

A stoolie. You backstab your friends-run your mouth my lawyers are dying Rip

you to shreds.” STONE also said he would “take that dog away from you,” 

referring to Person 2’s dog. On or about the same day, STONE wrote to Person 2, 

“I am so ready. Let’s get it on. Prepare to die [expletive].” 

c. On or about May 21, 2018, Person 2 wrote in an email to STONE, “You should 

have just been honest with the house Intel committee . . . you’ve opened yourself 

up to perjury charges like an idiot.” STONE responded, “You are so full of 

[expletive]. You got nothing. Keep running your mouth and I’ll file a bar 

complaint against your friend [the attorney who had the ability to contact the head 

of Organization 1].” 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 44 of 109
21

COUNT ONE

(Obstruction of Proceeding)

40. Paragraphs 1 through 39 of this Indictment are re-alleged and incorporated by reference as

if fully set forth herein. 

41. From in or around May 2017 through at least December 2017, within the District of 

Columbia and elsewhere, the defendant ROGER JASON STONE, JR., corruptly influenced, 

obstructed, impeded, and endeavored to influence, obstruct, and impede the due and proper 

exercise of the power of inquiry under which any inquiry and investigation is being had by either 

House, and any committee of either House and any joint committee of the Congress, to wit:

STONE testified falsely and misleadingly at a HPSCI hearing in or around September 2017; 

STONE failed to turn over and lied about the existence of responsive records to HPSCI’s requests 

about documents; STONE submitted and caused to be submitted a letter to HPSCI falsely and 

misleadingly describing communications with Person 2; and STONE attempted to have Person 2 

testify falsely before HPSCI or prevent him from testifying. 

All in violation of Title 18, United States Code, Sections 1505 and 2. 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 45 of 109
22

COUNTS TWO THROUGH SIX

(False Statements)

42. Paragraphs 1 through 39 of this Indictment are re-alleged and incorporated by reference as

if fully set forth herein. 

43. On or about September 26, 2017, within the District of Columbia and elsewhere, in a matter

within the jurisdiction of the legislative branch of the Government of the United States, the

defendant ROGER JASON STONE, JR., knowingly and willfully made and caused to be made

materially false, fictitious, and fraudulent statements and representations, to wit: 

Count False Statement

2 STONE testified falsely that he did not have

emails with third parties about the head of 

Organization 1, and that he did not have any

documents, emails, or text messages that refer

to the head of Organization 1. 

3 STONE testified falsely that his August 2016

references to being in contact with the head of

Organization 1 were references to

communications with a single “go-between,” 

“mutual friend,” and “intermediary,” who 

STONE identified as Person 2. 

4 STONE testified falsely that he did not ask the

person he referred to as his “go-between,” 

“mutual friend,” and “intermediary,” to

communicate anything to the head of 

Organization 1 and did not ask the 

intermediary to do anything on STONE’s

behalf. 

5 STONE testified falsely that he and the person

he referred to as his “go-between,” “mutual 

friend,” and “intermediary” did not 

communicate via text message or email about 

Organization 1. 

6 STONE testified falsely that he had never

discussed his conversations with the person he 

referred to as his “go-between,” “mutual

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 46 of 109
23

Count False Statement

friend,” and “intermediary” with anyone

involved in the Trump Campaign. 

All in violation of Title 18, United States Code, Sections 1001(a)(2) and 2. 

COUNT SEVEN

(Witness Tampering)

44. Paragraphs 1 through 39 of this Indictment are re-alleged and incorporated by reference as

if fully set forth herein. 

45. Between in or around September 2017 and present, within the District of Columbia and 

elsewhere, the defendant ROGER JASON STONE, JR., knowingly and intentionally corruptly 

persuaded and attempted to corruptly persuade another person, to wit: Person 2, with intent to

influence, delay, and prevent the testimony of any person in an official proceeding. 

All in violation of Title 18, United States Code, Section 1512(b)(1). 

 ________________________ 

 Robert S. Mueller, III

 Special Counsel 

U.S. Department of Justice 

A TRUE BILL:

________________________ 

Foreperson 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 47 of 109
24

Date: January 24, 2019 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 48 of 109
EXHIBIT 2

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 49 of 109
1

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

____________________________________

)

UNITED STATES OF AMERICA, )

)

Plaintiff, )

)

 v. ) Case No.: 1:19-CR-00018-ABJ

)

ROGER J. STONE, JR., )

)

Defendant. )

___________________________________ )

MOTION FOR LEAVE TO FILE AMICI CURIAE BRIEF

Movant Dr. Jerome Corsi (“Dr. Corsi”) through counsel, hereby moves this Court for 

leave to file an amici curiae brief in support of entry of an order pursuant to Local Criminal Rule 

57.7(c), or colloquially, a “gag order.”

Dr. Corsi’s amicus brief, attached hereto as Exhibit 1, sets forth the compelling reasons

why a “gag order” is necessary in this case, as he is named as Person 1, a material witness, in 

Defendant Roger Stone’s (“Defendant Stone”) indictment. Defendant Stone has engaged in a 

public relations campaign to defame, smear, intimidate and threaten both Dr. Corsi and his 

counsel, Mr. Larry Klayman, which is the same conduct that he was indicted for in the first 

place. Because Defendant Stone’s defamation, witness tampering, intimidation, and threats with 

regard to Dr. Corsi and his counsel Mr. Klayman are not technically part of this criminal 

prosecution, Dr. Corsi’s interests and position are not adequately represented by any party. Dr. 

Corsi’s amicus brief will aid this Court in ruling upon the entry of an order pursuant to LCrR 

57.7(c)

The United States has taken no position with regard to filing of an amicus brief, and 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 50 of 109
2

counsel for Defendant Stone has not substantively responded to Dr. Corsi’s request for consent. 

Dated: February 8, 2019 Respectfully submitted,

/s/ Larry Klayman ____

Larry Klayman, Esq. 

KLAYMAN LAW GROUP, PA

D.C. Bar No:

 2020 Pennsylvania Ave NW #800

 Washington, DC 20006 

 Email: leklayman@gmail.com

Tel: 310-595-0800

 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was filed 

electronically and served through the court’s ECF system to all counsel of record or parties on 

February 8, 2019

/s/ Larry Klayman

Larry Klayman, Esq. 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 51 of 109
[SUB]EXHIBIT 1 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 52 of 109
1

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

____________________________________

)

UNITED STATES OF AMERICA, )

)

Plaintiff, )

)

 v. ) Case No.: 1:19-CR-00018-ABJ

)

ROGER J. STONE, JR., )

)

Defendant. )

___________________________________ )

AMICI CURIAE BRIEF OF DR. JEROME CORSI

Under Local Criminal Rule 57.7(b)(1): 

[i]t is the duty of the lawyer or law firm not to release or authorize the release of

information or opinion which a reasonable person would expect to be

disseminated by means of public communication, in connection with pending or

imminent criminal litigation with which the lawyer or the law firm is associated,

if there is a reasonable likelihood that such dissemination will interfere with a fair

trial or otherwise prejudice the due administration of justice.

Furthermore, LCrR 57.7(c), which offers additional specific guidance with regard to highly 

publicized cases - which this instant case certainly qualifies as – grants the Court with authority 

to issue a “special order governing such matters as extrajudicial statements by parties, witnesses 

and attorneys likely to interfere with the rights of the accused to a fair trial by an impartial jury.” 

As set forth in Gentile v. State Bar of Nevada, 501 U.S. 1030, 1075 (1991):

The limitations are aimed at two principal evils: (1) comments that are likely to 

influence the actual outcome of the trial, and (2) comments that are likely to 

prejudice the jury venire, even if an untainted panel can ultimately be found. Few, 

if any, interests under the Constitution are more fundamental than the right to a 

fair trial by “impartial” jurors, and an outcome affected by extrajudicial 

statements would violate that fundamental right.

Here, Defendant Roger Stone (“Defendant Stone”) has already begun a public relations 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 53 of 109
2

campaign meant specifically to influence the outcome of his upcoming trial and which are meant 

to prejudice the jury venire. Defendant Stone is doing so by engaging in witness tampering,

defamation, and intimidation and coercion with regard to Dr. Corsi, who is named as Person 1 in 

Defendant Stone’s indictment. As such, Dr. Corsi will likely subpoenaed to be called as a 

material witness in Defendant Stone’s upcoming trial. Again he is Person 1 in the Mueller 

Indictment.

Defendant Stone is attempting to smear, defame, and discredit, tamper and threaten Dr. 

Corsi so that when Dr. Corsi is called as a witness, the jurors will have a false impression of Dr. 

Corsi as a liar, perjurer, and alcoholic. This would, obviously, improperly and unethically benefit 

Defendant Stone. In fact, Defendant Stone’s targeted efforts to defame, coerce, intimidate and 

threaten Dr. Corsi have resulted in a lawsuit filed in the U.S. District Court for the District of 

Columbia, which is attached hereto as Exhibit A and incorporated by reference. 

Should this Court have any doubt as to Defendant Stone’s improper motivations and 

already implemented and continuing designs to taint the jury venire, the content and article 

written by Sara Murray and Sam Fossum titled, Roger Stone, facing gag order, launches 

counterattack, should put any such doubts to bed. Exhibit B. It is only one of many such analyses 

and accounts. It is clear that Defendant Stone’s strategy will be to use the media and publicity to 

argue his case and to try to get public sentiment on his side, as well as to tamper with witnesses 

like Dr. Corsi, which is exactly the type of conduct that LCrR 57.7 was meant to preclude. 

Accordingly, Movant Dr. Corsi respectfully requests that this Court issue an order 

pursuant to LCrR 57.7(c) ordering Defendant Stone and his counsel from making statements to 

the media or in public settings that pose a substantial likelihood of material prejudice to this case

and which in the context of Stone himself and in their ferocity also amount to witness tampering 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 54 of 109
3

and obstruction of justice. See Exbibit A – Corsi Complaint.

Dated: February 8, 2019 Respectfully submitted,

/s/ Larry Klayman ____

Larry Klayman, Esq. 

KLAYMAN LAW GROUP, PA

D.C. Bar No:

2020 Pennsylvania Ave NW #800

Washington, DC 20006

Email: leklayman@gmail.com

Tel: 310-595-0800

334581

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 55 of 109
[SUB]EXHIBIT A

,QWHQWLRQDOO\2PLWWHG

See0DLQ([

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 56 of 109
EXHIBIT B

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 57 of 109
2/8/2019 Roger Stone, facing gag order, launches counterattack - CNNPolitics

https://www.cnn.com/2019/02/07/politics/roger-stone-gag-order-counterattack/index.html 1/3

Roger Stone, facing gag order, launches

counterattack

Updated 6:30 PM ET, Thu February 7, 2019

By Sara Murray and Sam Fossum, CNN

Washington (CNN) — In the days since a federal judge warned Roger Stone that he could soon face a gag order,

Stone has peddled conspiracy theories, claimed he can't get a fair trial and criticized the judge.

"This is a lynching. This is a legal lynching of me," Stone said in a recent interview on the fringe right-wing website

Infowars.

Stone was arrested last month in a pre-dawn raid and charged with obstruction of justice, making false statements

and witness tampering as part of special counsel Robert Mueller's Russia investigation. On Friday, federal

prosecutors and Stone's legal team are due to submit briefs on the merits of a gag order.

But rather than toning down his rhetoric, Stone appears to be abiding by the principles he espouses in his books.

For instance, Stone's Rule #81: "Admit Nothing; Deny Everything; Launch Counterattack."

It's a dubious legal strategy.

"I would say that it's a terrible idea for Stone to be doing this," said CNN legal analyst Shan Wu. "I can't imagine a

worse idea."

Judge Amy Berman Jackson informed Stone last week that she was considering a gag order. She was quick to

put similar restrictions on former Trump campaign chairman Paul Manafort's case, which she is also presiding over

in Washington. Jackson, an appointee of President Barack Obama, said she was cognizant of Stone's First

Amendment right to free speech, but she wanted to protect his right to a fair trial and ensure it was possible to

select an unbiased jury.

Stone's response, delivered via an Instagram post this week: "I will continue to defend myself unless an Obama

appointed judge decides to suspend my first amendment rights." In another post, Stone exclaimed, "Fair Trial in

DC? Impossible."

Stone, in his public diatribes, has claimed he is being targeted because he works for Infowars and supported

Trump. And he has continued his long tradition of hyping fact-free conspiracy theories.

In one Instagram post, Stone is shaking hands William Binney, a former National Security Agency ocial who has

turned into a vocal critic of the agency. "Bill Binney explained to me why the forensic evidence shows the DNC was

never hacked by anyone including the Russians," Stone wrote.

US intelligence agencies have concluded Russian intelligence hacked the DNC and other top Democrats, and used

platforms like WikiLeaks to disseminate the stolen material.

Stone concluded his post with a series of hashtags including "#sethrich."

Seth Rich was a Democratic National Committee staer who was fatally shot in Washington in 2016. Police said

evidence indicates Rich was the victim of a robbery gone wrong. But far-right activists and news organizations

spread a conspiracy theory -- with no evidence -- that Rich was killed for leaking a trove of DNC emails to

WikiLeaks.

Both Fox News and the Washington Times ended up retracting stories based on the murder-as-leaking-retribution

conspiracy plot, but the lore has lived on, to the devastation of Rich's family.

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 58 of 109
2/8/2019 Roger Stone, facing gag order, launches counterattack - CNNPolitics

https://www.cnn.com/2019/02/07/politics/roger-stone-gag-order-counterattack/index.html 2/3

As for Stone, he recently settled a lawsuit unrelated to the Mueller probe in which he admitted to making false

statements on Infowars about a Chinese businessman and apologized for his commentary.

Stone's attorney and Mueller's oce declined to comment.

Prior legal woes aside, Stone's eagerness to discuss his case publicly -- and in colorful fashion -- could make the

judge more inclined to put a gag order on the case.

Stone and his attorneys have vowed to fight any such eort and are expected to make the case that Stone's

livelihood depends on his ability to speak freely.

"I make a living writing and speaking," Stone argued in a recent Infowars appearance. "So they would be depriving

me of making a living if I am entirely gagged."

Jackson appears to have anticipated that defense. In court last Friday, the judge said she was only considering

limiting Stone's ability to talk about the case.

"+e would still be free to discuss foreign relations, immigration or Tom Brady," Jackson said.

If she does crack down on public comments on the case, Stone's legal team could also appeal the move. Last

year, Stone added First Amendment and constitutional law expert Bruce Rogow to his legal team.

Stone may have a solid legal premise for an appeal, Wu said, although most defendants consider it a risky move.

"Most defendants don't want to do that because they don't want to run afoul of the judge," Wu said. "+e doesn't

care."

rogerjs...

40.2k followers

View More on Instagram

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 59 of 109
2/8/2019 Roger Stone, facing gag order, launches counterattack - CNNPolitics

https://www.cnn.com/2019/02/07/politics/roger-stone-gag-order-counterattack/index.html 3/3

Indeed, Stone is still racking up appearances and using nearly all of them to hammer the tactics used in the predawn raid at his Florida home.

"This was a show of force, this was something you would expect from Nazi *ermany or Soviet Russia. It was

chilling," Stone told Infowars.

Stone has also compared the law enforcement presence the morning of his arrest to the forces deployed against

drug lord Joaquìn *uzmÊn, known as "El Chapo," and Osama bin Laden, the former al 4aeda leader who was

killed by US Special Forces in a 2011 raid.

Stone's vocal complaints even sparked a response from ex-convict and former football star O.J. Simpson, who

drew on his own experience with FBI raids, according to a video posted on celebrity news website TM=.

"The FBI can be wrong," Simpson said, "But to try to compare to El Chapo and Bin Laden? +ey man, Bin Laden

was carried out in a bag, not walked out in handcus."

Simpson's parting words for Stone: "Man up. Stop crying."

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 60 of 109
EXHIBIT 3

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 61 of 109
1

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

DR. JEROME CORSI, Individually

Denville, NJ, 07834

 Plaintiff

v.

ROGER STONE, Individually

4300 Bayview Drive

Fort Lauderdale, FL, 33308

Defendant.

 Case Number: 

 

 COMPLAINT 

 

INTRODUCTION

Plaintiff, DR. JEROME CORSI (“Plaintiff” or “Corsi”) hereby files this action against 

ROGER STONE (“Defendant Stone”) for Defamation, Intentional Infliction of Emotional 

Distress and Assault

JURISDICTION AND VENUE

1. This Court has diversity jurisdiction over this case pursuant to 28 U.S.C. § 1332, 

as the parties are completely diverse in citizenship and the amount in controversy exceeds 

$75,000.

2. Venue is proper pursuant to 28 U.S.C. § 1391(b)(2), (3) in that a substantial part 

of the events or omissions giving rise to Plaintiff Corsi’s claims arose herein.

THE PARTIES

3. Plaintiff, Dr. Jerome Corsi, is an author and political commentator who publishes 

works in this judicial district and nationwide. Plaintiff Corsi is a citizen of New Jersey.

4. Defendant, Roger Stone, is an individual and a citizen of Florida and a resident of 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 62 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 1 of 12
2

Fort Lauderdale, Florida. Defendant Stone was recently indicted by Special Counsel Robert Mueller 

as part of the alleged “Russian Collusion’ investigation. His address is 4300 Bayview Drive, Fort 

Lauderdale, FL, 33308 

GENERAL ALLEGATIONS

5. Defendant Stone was recently indicted by Special Counsel Robert Mueller 

(“Mueller Indictment”) as part of his “Russian Collusion” investigation for the alleged crimes of

perjury, witness tampering and obstruction of justice. The indictment comprises seven different 

felony counts. See Exhibit 1 – Mueller Indictment. Importantly, Plaintiff Corsi was not accused 

of any wrongdoing or illegality in the Mueller Indictment, in which he named as Person 1, a 

material witness to the alleged crimes committed by Stone.

6. Specifically, the seven count Mueller Indictment against Defendant Stone 

involves alleged lying under oath - that is, perjury - witness tampering and obstruction of justice 

by threatening to kill a material witness, Randy Credico (“Credico”) and his dog if Credico did 

not lie to government authorities concerning his involvement with Roger Stone. Credico is 

Person 2 in the Mueller Indictment of Defendant Stone. Id. Person 1 in this Mueller Indictment is 

Plaintiff Corsi.

7. Even before Defendant Stone was indicted, he began a public relations campaign

in this district, nationally and internationally to smear, intimidate and threaten Plaintiff Corsi, a 

material witness in the “Russian Collusion” investigation. Plaintiff Corsi is listed as Person 1 in 

the Mueller Indictment and was not indicted along with Defendant Stone, as he testified 

truthfully to the grand jury and in interviews.

8. To the contrary, Plaintiff Corsi has never defamed or disparaged Defendant Stone.

9. Defendant Stone knew that he was going to be indicted, and therefore began this 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 63 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 2 of 12
3

public relations campaign to smear, defame, intimidate and threaten Plaintiff Corsi, even before 

his actual indictment on January 25, 2019, in order to try to influence public opinion and Special 

Counsel Robert Mueller – by trying to attribute guilt to Plaintiff Corsi and not him - as well as to 

try to raise money for his legal defense. This pattern and practice of defaming, intimidating and 

threatening Plaintiff Corsi, and his legal counsel, is ongoing, so Plaintiff Corsi reserves the right 

to amend this Complaint. 

10. Defendant Stone likes to portray himself as Mafia, frequently making reference to 

Mafia figures who he admires, as well as other unsavory types who have been alleged to have 

engaged in unethical and/or illegal behavior. He frequently makes reference to his heroes being 

Hyman Roth in the ‘Godfather,” who was the movie version of Meyer Lansky, and Roy Cohn, 

not to mention, Richard Nixon, for his role in Watergate. In this regard, after Stone was indicted 

he held a press conference on the courthouse steps of the federal courthouse in Ft. Lauderdale, 

where he was booked, with his arms defiantly in the air in the “victory’ pose used by Nixon after 

he resigned in disgrace as a result of the Watergate scandal. At the time, Stone had been 

employed by a Nixon group called CREEP, or the Committee to Reelect the President. 

Defendant Stone even has a large tattoo of Richard Nixon affixed to his back. Thus, given his 

admiration for persons such as these, particularly Mafia figures, his actions as pled herein can be 

taken as threats, as well as being defamatory. And, Plaintiff Corsi is 72 years old. Defendant 

Stone’s intentional infliction of emotional distress and coercion and threats are intended to try 

even cause Plaintiff Corsi to have heart attacks and strokes, in order that Plaintiff will be unable 

to testify at Stone’s criminal trial. Tellingly, Defendant Stone threatened kill a material witness 

and his dog, Credico, Person 2 in the Mueller Indictment, “Mafia style.” Defendant Stone also 

fashions himself and indeed has the reputation, at a minimum, as being the preeminent “dirty 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 64 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 3 of 12
4

trickster.” See “Get Me Roger Stone” on Netflix.

11. Plaintiff Corsi has been named as a material witness to Defendant Stone’s 

upcoming prosecution, which has prompted Defendant Stone to try to intimidate, coerce and 

threaten Plaintiff Corsi by defaming him and threatening him with physical violence, which is 

ironically what he was criminally indicted for, in part.

12. By defaming Plaintiff Corsi, Defendant Stone is hoping to not only intimidate 

Plaintiff Corsi to severely harm and damage his reputation, but also to coerce and threaten

Plaintiff Corsi to testify falsely if subpoenaed to be called as a material witness in Defendant 

Stone’s ensuing criminal trial. He is also trying divert funds away from Plaintiff Corsi’s legal 

defense fund, while boosting his own legal defense fund.

13. Defendant Stone has also used and continues to employ surrogates, either out in 

the open or secretly, to defame Plaintiff Corsi, such as his “friend” Michael Caputo, Alex Jones 

and J. Owen Stroyer of InfoWars, Cassandra Fairbanks, and reporter Chuck Ross of The Daily 

Caller, to name just a few. More surrogates will be identified during discovery and they may be 

joined, with leave of court to amend this Complaint, as defendants herein. The use of surrogates 

is consistent with Defendant Stone’s reputation as a “dirty trickster” who works as well under 

“cover of darkness” to harm and damage others who he sees for whatever reason as adversaries, 

political or otherwise as in the case of Plaintiff Corsi. Plaintiff Corsi is not Defendant Stone’s 

adversary, as he simply is committed as Person 1 in the Mueller Indictment to testify truthfully if 

subpoenaed to testify at Stone’s criminal trial.

14. Defendant Stone is no stranger to defamation lawsuits. As reported by Splinter 

News, Defendant Stone was forced to - as part of a settlement in another defamation suit –

apologize in newspapers and on social media for lying about Chinese Businessman Guo Wengui 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 65 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 4 of 12
5

on InfoWars, after having falsely published that Mr. Wengui is a “turncoat criminal who is 

convicted of crimes here and in China.”1

15. Defendant Stone has therefore engaged in illegal witness tampering and 

intimidation, in violation of 18 U.S.C. § 1512 by virtue of the defamatory and threatening acts 

and practices as alleged herein. Not coincidentally, this was what largely he was indicted for by 

Special Counsel Robert Mueller.

DEFENDANT STONE’S DEFAMATORY STATEMENTS

16. Before Defendant Stone was indicted, on or about January 18, 2019, he appeared 

on InfoWars, where he made several false, misleading and defamatory statements in this district, 

nationally and internationally regarding Plaintiff Corsi (the “InfoWars Video”).2 The same video 

was published on Defendant Stone’s YouTube channel, “Stone Cold Truth,” on January 18, 

2019.3

17. At 2:09 in the InfoWars Video, Defendant Stone falsely publishes that Plaintiff 

Corsi was “fired from World Net Daily.”

18. At 2:27 in the InfoWars Video, Defendant Stone falsely and misleadingly 

publishes that, “He (Corsi) was perfectly willing to lie, to perjure himself saying that a memo 

that he had wrote me was written on the 30th for the purposes of cover-up.... which is further 

proof that Jerry lied under oath.”

19. At 2:55 in the InfoWars Video, Defendant Stone falsely and misleadingly

publishes, “and then states that I knew about John Podesta’s emails being stolen in advance, the 

only proof of that is Jerry’s feeble alcohol affected memory – it’s a lie....”

 1 Sophie Weiner, Roger Stone Lied About a Chinese Businessman on InfoWars and Now He Has 

to Tell Everyone, Splinter News, Dec. 17, 2018, available at: https://splinternews.com/rogerstone-lied-about-a-chinese-businessman-on-infowar-1831162926

2 https://www.infowars.com/watch/?video=5c3fbf24fe49383dcf6996e4

3 https://www.youtube.com/watch?v=cJyfgdvtFx8

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 66 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 5 of 12
6

20. At 3:35 in the InfoWars Video, Defendant Stone falsely and misleadingly 

publishes that “Jerry was prepared to stab a principle Trump supporter in the back, he was 

perfectly prepared to bear false witness against me, even though I had done nothing in my entire 

life other than help him.”

21. At 4:20 in the InfoWars Video, Defendant Stone falsely and misleadingly

publishes that “all I ever did was show Jerry Corsi friendship and support and try to help him and 

his family and what I get is Judas Iscariot, the willingness to testify against me and help the deep 

state bury me....and then he makes up this story about helping me formulate a cover story.” 

22. At 6:26 in the InfoWars Video, Defendant Stone falsely publishes that “you can 

always tell when Jerry Corsi is lying because his lips are moving....”

23. Defendant Stone made these false, misleading and defamatory statements with 

malice and with full knowledge that they were false and misleading, and/or at a minimum, with a 

reckless disregard for its truthfulness. These statements falsely and misleadingly state that 

Plaintiff Corsi was fired from World Net Daily, that he committed perjury (a federal offense), 

and that he is an untruthful person.

24. On January 2, 2019, Defendant Stone published an article on www.infowars.com 

titled “ROGER STONE BELIEVES JEROME CORSI WORKS FOR MUELLER4” in which 

Defendant Stone falsely, misleadingly, and maliciously writes, “Before you decide that Corsi is a 

hero you should be well aware of the fact that the good doctor was prepared to bear false witness 

against others in the Trump orbit if he thought it would save his own skin.”

25. Defendant Stone made these false, misleading and defamatory statements with 

malice and with full knowledge that they were false and misleading, and/or at a minimum, with a 

reckless disregard for its truthfulness. These statements falsely and misleadingly state that 

 4 https://www.infowars.com/roger-stone-the-treachery-of-jerome-corsi/

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 67 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 6 of 12
7

Plaintiff Corsi committed perjury (a federal offense), and that he is an untruthful person.

26. In another appearance on InfoWars, which was posted to YouTube5 on January 

17, 2019, Defendant Stone at 6:22 falsely and misleadingly publishes that “He [Corsi] was 

perfectly willing to bear false witness against me on multiple points that are complete 

fabrications.”

27. In another appearance on InfoWars, which was posted to YouTube6 on January 

24, 2019, Defendant Stone at 5:58 falsely and misleadingly publishes that “the good doctor 

[Corsi] has told a number of lies. In fact, he’s starting to conflate his lies.... he was perfectly 

willing to lie about me.... but now lying about Alex Jones, lying about InfoWars, lying about Dr. 

Jones, who’s one of the nicest, gentlest, sweetest, most honest men I have ever met, it’s beyond 

the pale.... Jerry Corsi can no longer be believed.”

28. In the same appearance, Defendant Stone at 8:34 falsely and misleadingly

publishes that, “I think you’ve [Corsi] been deep state from the beginning. Your whole birther 

thing is used as a club to destroy conservatives....I look forward to our confrontation. I will 

demolish you. You’re a fraudster, out of your alcoholic haze you have made up lies about David 

Jones and Alex Jones and Roger Stone and now I suspect they want you to lie about the 

President.” This is clearly a threat, as well as being defamatory. It is akin to the threats against 

Person 2 in the Mueller Indictment, Randy Credico, who Defendant Stone, as set forth in the 

Mueller Indictment, based on Stone’s own words contained in his own documentary evidence, 

threatened kill along with Credico’s dog.

29. Defendant Stone made these false, misleading and defamatory statements with 

malice and with full knowledge that they were false and misleading, and/or at a minimum, with a 

 5 https://www.youtube.com/watch?v=GJd8YBDvm1Q

6 https://www.youtube.com/watch?v=fXUlJZRxe6E

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 68 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 7 of 12
8

reckless disregard for their truthfulness. These statements falsely and misleadingly state that 

Plaintiff Corsi committed perjury (a federal offense), is an untruthful person, and is an alcoholic. 

They also contain threats against Plaintiff Corsi.

FIRST CAUSE OF ACTION

Defamation

30. Plaintiff re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

31. Defendant Stone published malicious, false, misleading and defamatory 

statements of and concerning Plaintiff Corsi in this judicial district, nationwide, and worldwide.

32. These false and misleading statements were published with malice, as Defendant 

Stone knew that they were false and misleading, or at a minimum acted with a reckless disregard 

for the truth.

33. Plaintiff Corsi has been severely harmed and damaged by these false and 

misleading statements because they subjected him to hatred, distrust, ridicule, contempt, and 

disgrace.

34. Plaintiff Corsi has been damaged by these false and misleading statements 

because they injured Plaintiff Corsi in his profession and business as a journalist and author, 

whose credibility is the most important trait, as well as severely injured and damaged him 

personally.

SECOND CAUSE OF ACTION

Defamation Per Se

35. Plaintiff re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

36. Defendant Stone, as alleged herein, published numerous false, misleading and 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 69 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 8 of 12
9

defamatory statements to severely harm and damage Plaintiff Corsi, which were republished 

elsewhere, and through surrogates, which publish the falsity that Plaintiff Corsi has committed 

crimes, including perjury, and engaged in moral turpitude in the form of alcoholism, as set forth 

in the preceding paragraphs. 

37. These false, misleading and defamatory statements were published in this district 

and on the internet and elsewhere, domestically and for the entire world to see and hear and 

specifically Stone published false and misleading facts, inter alia, that Plaintiff’s conduct, 

characteristics or a condition is incompatible with the proper exercise of his lawful business, 

trade, profession or office.

38. These false and misleading statements were published with malice, as Defendant 

Stone knew that they were false and misleading, and/or at a minimum acted with a reckless 

disregard for the truth.

39. This statements are per se defamatory because they falsely and misleadingly 

publish that Plaintiff Corsi committed perjury, which is a federal offense and felony. Defamation 

per se gives rise to the presumption that severe harm and damage has arisen by virtue of the false 

and misleading statements.

40. These false, misleading, and defamatory statements are defamatory per se and

these false and misleading statements severely harmed and damaged Plaintiff Corsi in his 

profession and business as a journalist and author, whose credibility is the most important trait, 

as well as personally.

THIRD CAUSE OF ACTION

Defamation by Implication

41. Plaintiff re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 70 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 9 of 12
10

42. Defendant Stone published numerous false, misleading and defamatory 

statements about Plaintiff Corsi, as set forth in the preceding paragraphs.

43. These false, misleading and defamatory statements were published on the internet 

and published and republished elsewhere in this district, domestically and for the entire world to 

see and hear. 

44. These false and misleading statements were published with malice, as Defendant 

Stone knew that they were false and misleading, and/or at a minimum acted with a reckless 

disregard for the truth.

45. These statements created the false and misleading implication that Plaintiff Corsi

is dishonest, committed perjury and is an alcoholic, among other false and misleading statements 

as pled in the preceding paragraphs. 

46. Plaintiff Corsi has been severely harmed and damaged by these false and 

misleading statements because they subject him to hatred, distrust, ridicule, contempt, and 

disgrace.

47. Plaintiff Corsi has been damaged by these false and misleading statements 

because the statements severely harmed and damaged Plaintiff Corsi in his profession as a 

journalist and author, whose credibility is the most important trait, as well as personally.

FOURTH CAUSE OF ACTION

Intentional Infliction of Emotional Distress

48. Plaintiff re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

49. Defendant Stone engaged in extreme and outrageous conduct by threatening 

Plaintiff Corsi, in concert with Stone, who has made death threats to at least one witness 

involved in Special Counsel Mueller’s Russian collusion investigation, Person 2 Randy Credico.

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 71 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 10 of 12
11

50. Defendant Stone knowingly and intentionally threatened Plaintiff Corsi, in a 

manner similar to other death threats he made to at least one material witness, involved in 

Special Counsel Mueller’s Russian collusion investigation, such as Randy Credico, Person 2 in 

the Mueller Indictment.

51. Defendant Stone’s extreme and outrageous conduct directly caused Plaintiff Corsi

severe emotional distress and resulting severe harm and damage.

FIFTH CAUSE OF ACTION

Assault

52. Plaintiff re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

53. Defendant Stone placed Plaintiff Corsi in apprehension of an imminent harmful or 

offensive contact and physical harm and death, by coercing and threatening Plaintiff Corsi, in a 

similar manner he has used to make death threats to at least one material witness involved in 

Special Counsel Mueller’s Russian collusion investigation, such as Person 2 in the Mueller 

Indictment, Randy Credico.

54. The threats issued by Defendant Stone are credible, as he portrays himself as a 

“mafia” figure, as set forth above.

55. Plaintiff Corsi did not consent to Defendant Stone’ conduct.

56. As a direct and proximate result of Defendant Stone’s wrongful conduct, Plaintiff 

Corsi suffered conscious pain, suffering, severe emotional distress and the fear of imminent 

serious bodily injury or death, and other mental and physical injuries, and Plaintiff was severely 

harmed and damaged thereby.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Dr. Jerome Corsi prays for judgment against Defendant Stone as 

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 72 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 11 of 12
12

follows:

a. Awarding Plaintiff Corsi compensatory including actual, consequential, incidental and 

punitive damages for malicious tortious conduct in an amount to be determined at trial and in 

excess of $25, 000,000 U.S. Dollars. While Stone feigns being financially destitute as a result of 

his legal problems and uses this to raise money for his legal defense fund, on information and 

belief he is wealthy, perhaps hiding his wealth in overseas bank accounts.

b. Awarding Plaintiff Corsi attorney’s fees and costs.

c. Granting any further relief as the Court deems appropriate including preliminary and 

permanent injunctive relief, as well as the entry of a gag order against Defendant Stone in his 

criminal prosecution before this Court in order that he be prevented from intimidating, coercing 

and threatening material witnesses, such as Plaintiff Corsi, who are likely to be subpoenaed to 

testify at his trial. In this regard, Plaintiff Corsi will also, with leave of court requested, file an 

amicus brief arguing for a gag order on Defendant Stone in the related criminal case United 

States of America v. Stone, 19-cr-18 (D.D.C).

Dated: February 7, 2019 Respectfully Submitted, 

 /s/ Larry Klayman 

Larry Klayman, Esq.

KLAYMAN LAW GROUP, P.A.

D.C. Bar Number: 334581

2020 Pennsylvania Ave NW #800

Washington, DC, 20006

Telephone: (310)-595-0800

Email: leklayman@gmail.com

Counsel for Plaintiff

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 73 of 109 Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 12 of 12
;35=

NTENTIONALLY /MITTED 3EE

-AINX

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 74 of 109
EXHIBIT 4

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 75 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 76 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 77 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 78 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 79 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 80 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 81 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 82 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 83 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 84 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 85 of 109
Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 86 of 109
;35=

NTENTIONALLY /MITTED 3EE

-AINX

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 87 of 109
EXHIBIT 5

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 88 of 109
1

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

LARRY KLAYMAN, Individually

 Plaintiff

v.

THOMAS J. FITTON, Individually

Defendant.

 Case Number: 

 

 

 

COMPLAINT FOR DEFAMATION

Plaintiff, LARRY KLAYMAN (“Plaintiff” or “Klayman”) hereby files this action against 

THOMAS J. FITTON (“Defendant Fitton”) for Defamation, Defamation Per Se, and Defamation 

by Implication.

JURISDICTION AND VENUE

1. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. § 

1332 under diversity of citizenship. The parties are citizens of different states and the amount in 

controversy exceeds $75,000. 

2. Venue is proper pursuant to 28 U.S.C. § 1391(b)(2) as this is the judicial district 

in which a substantial part of the events or omissions giving rise to the claim occurred.

THE PARTIES

3. Plaintiff, Larry Klayman, is an individual and a citizen of Florida. Plaintiff is a 

well-known private lawyer and conservative public interest advocate and litigator, as well as a 

syndicated national radio talk show host on Radio America, his weekly show appropriately titled 

“Special Prosecutor with Larry Klayman.” Plaintiff Klayman conceived of and founded both

Judicial Watch, Inc. and Freedom Watch, Inc. He is a former federal prosecutor of the Antitrust 

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 1 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 89 of 109
2

Division of the U.S. Department of Justice, where he was on the trial team that broke up the AT&T 

monopoly.

4. Defendant, Thomas Fitton, is an individual and a citizen of the District of Columbia, 

whose address is 5245 42nd St NW, Washington, DC 20015. Defendant Fitton is the current 

President of Judicial Watch, which was conceived of and founded by Plaintiff Klayman. He is not a 

lawyer and at the time that Klayman left Judicial Watch on September 19, 2003 to run for the U.S. 

Senate in Florida, Defendant Fitton had not graduated from college. When Plaintiff Klayman hired 

him years earlier as an assistant, he lied to Klayman that he had graduated from George Washington 

University. Since then Defendant Fitton has had a book written for him by “ghost writer,” Ben 

Shapiro, effectively claiming credit for Plaintiff Klayman’s accomplishments in conceiving of, 

founding and running Judicial Watch for almost ten (10) years. Plaintiff Klayman was thus 

conspicuously and maliciously written out of the history of Judicial Watch. The book is titled 

“Corruption Chronicles” and remains on sale on the internet and in book stores. Defendant Fitton 

has also falsely testified multiple times under oath that he does not know who founded Judicial 

Watch, as he continues to try to spread the false narrative and impression he or someone other than 

Klayman founded Judicial Watch, in order to boost his own standing in the conservative community

and elsewhere, as the expense of Plaintiff Klayman. In short, and regrettably Defendant Fitton, as 

set forth below, is a ‘serial liar” and dishonest.

STANDING

5. Plaintiff has standing to bring this action because he has been directly affected 

and victimized by the unlawful conduct complained herein. His injuries are proximately related 

to the conduct of Defendant Fitton, individually and working in concert with Roger Stone as set 

forth below.

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 2 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 90 of 109
3

FACTS

6. Defendant Fitton has engaged in a pattern and practice of defaming Plaintiff 

Klayman since Plaintiff’s voluntary departure from Judicial Watch, Inc. to run for the U.S. 

Senate in Florida in 2003-2004.

7. For instance, in 2013, a federal jury in the Southern District of Florida awarded 

Plaintiff Klayman judgment in the sum of $181,000, including punitive damages against Judicial 

Watch for having maliciously defamed Plaintiff. See Exhibit 1 – Jury Verdict and Judgment. 

This jury verdict and judgment is final.

8. Defendant Fitton is now conveniently and incredibly working with Roger Stone 

(“Stone”) to again defame Plaintiff Klayman.

9. Stone was recently indicted on seven (7) felony counts by Special Counsel Robert 

Mueller (“Mueller Indictment”) as part of his “Russian Collusion” investigation for the alleged 

crimes of perjury, witness tampering and obstruction of justice. See Exhibit 2 – Mueller 

Indictment.

10. Specifically, the seven count Mueller Indictment against Defendant Stone 

involves alleged lying under oath - that is, perjury - witness tampering and obstruction of justice 

by threatening to kill a material witness, Randy Credico (“Credico”) and his dog if Credico did 

not lie to government authorities concerning his involvement with Roger Stone. Credico is 

Person 2 in the Mueller Indictment of Defendant Stone. Id. Person 1 in this Mueller Indictment is 

Dr. Jerome Corsi, another material witness, who is Plaintiff Larry Klayman’s client.

11. Stone has since engaged in a public relations campaign to illegally smear, 

intimidate, coerce and threaten Dr. Jerome Corsi (“Dr. Corsi”), a witness in the “Russian 

Collusion” investigation, and who is being legally represented by Plaintiff Klayman. 

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 3 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 91 of 109
4

12. Stone knew that he was going to be indicted, and therefore began this illegal 

public relations campaign to smear and defame Dr. Corsi and his lawyer, Larry Klayman, even 

before his actual indictment on January 25, 2019, in order to try to influence public opinion and 

Special Counsel Robert Mueller – by illegally trying to attribute guilt to Dr. Corsi and not him -

as well as to try to raise money for his legal defense. This pattern and practice of defaming Dr. 

Corsi and his lawyer Larry Klayman is ongoing, so Plaintiff reserves the right to amend this 

Complaint. Stone has recently been sued by Dr. Corsi for defamation, intentional infliction of 

emotional distress and assault.

13. Dr. Corsi has been named as a material witness to Stone’s upcoming prosecution, 

which has prompted Stone to try to intimidate, coerce and threaten Dr. Corsi by defaming him 

and his defense counsel, Plaintiff Klayman, which is ironically what he has been indicted for.

And, the way to also “get to” Dr. Corsi is for Defendant Stone to also defame his lawyer, 

Plaintiff Larry Klayman

14. By defaming Dr. Corsi and Plaintiff Klayman, Defendant Fitton and Stone are 

working in concert as joint tortfeasors hoping to not only intimidate Dr. Corsi and his counsel to 

severely harm and damage their reputations, but also to coerce and threaten Dr. Corsi to testify 

falsely if subpoenaed to be called as a material witness in Defendant Stone’s ensuing criminal 

trial, as well as to impede and harm Dr. Corsi’s criminal defense. They are also acting in concert 

to divert funds away from Dr. Corsi’s legal defense fund, while boosting Stone’s legal defense 

fund.

15. Before Defendant was indicted, on or about January 18, 2019, he appeared on 

InfoWars, where he made several false, misleading and defamatory statements in this district, 

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 4 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 92 of 109
5

nationally and internationally regarding Plaintiff Klayman (the “InfoWars Video”).1 The same 

video was published on Defendant Stone’s YouTube channel, “Stone Cold Truth,” on January 

18, 2019.2

16. At 1:30, Stone published, “He (Klayman) was ousted at Judicial Watch. Ask Tom 

Fitton [the current president of Judicial Watch] why he left. He left because of a sexual 

harassment complaint.”

17. Stone made this false, defamatory statement at the direction of Defendant Fitton, 

whom he attributes this false and defamatory statement to. 

18. Defendant Fitton knew that Plaintiff Klayman was not ousted at Judicial Watch as 

a result of a sexual harassment complaint, but, in actuality, Plaintiff Klayman left Judicial Watch 

on his own accord and voluntarily in order to run for U.S. Senate in Florida.

19. Defendant Fitton with malice and/or a reckless disregard for the truth knew that 

Plaintiff Klayman did not leave Judicial Watch as a result of a sexual harassment complaint.

20. Defendant Fitton knowingly published this false and defamatory statement to 

Stone, who in turn republished it during interviews which were broadcast by him and his 

surrogates in this district, nationally and internationally for the entire world to hear and see. On 

information and belief Fitton has also recently published, within the last two years up to the 

present, this and other false and misleading statements to others to severely harm and damage 

Plaintiff Klayman, such as to the Council for National Policy, the American Conservative Union, 

the Scaife Foundation, other conservative organizations, groups and donors, and media 

publications and television networks such as Fox News, to name just a few. As a non-lawyer 

who currently runs Judicial Watch, Defendant Fitton feels competitive with Klayman, and as 

 1 https://www.infowars.com/watch/?video=5c3fbf24fe49383dcf6996e4

2 https://www.youtube.com/watch?v=cJyfgdvtFx8

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 5 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 93 of 109
6

result of what in effect is an “inferiority complex” since he is a non-lawyer who tries to pass 

himself in the media off as a lawyer and legal expert as the current head of Judicial Watch, thus 

has engaged in a concerted campaign to severely damage and harm Klayman’s reputation, 

professional and personal reputation, and family. By severely harming Plaintiff Klayman’s 

reputation and standing in the legal, media and related communities, Defendant Stone’s 

malicious intent is to boost his own reputation and standing at the expense of Klayman, who 

conceived of, founded and successfully ran Judicial Watch for nearly ten (10) years, making it 

the preeminent conservative public interest group fighting against corruption and for ethics and 

justice in government and the legal profession.

21. Defendant Fitton, in concert with Stone, have therefore also engaged in illegal 

witness tampering of Dr. Corsi and his lawyer Plaintiff Klayman in violation of 18 U.S.C. § 1512

by virtue of the defamatory acts and practices as alleged herein.

FIRST CAUSE OF ACTION

Defamation

22. Plaintiff re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

23. Defendant Fitton published the malicious, false and defamatory statement that 

Plaintiff Klayman was ousted at Judicial Watch due to a sexual harassment complaint to Stone, 

who in turn, and in concert with Defendant Fitton, republished this false and defamatory 

statement on the internet domestically, internationally and elsewhere for the entire world to see 

and hear.

24. This false and misleading statement was published with malice, as Defendant 

Fitton knew that it was false and misleading, or at a minimum acted with a reckless disregard for 

the truth.

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 6 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 94 of 109
7

25. Plaintiff Klayman has been severely harmed and damaged by this and other false 

and misleading statements, more of which will be uncovered in discovery, because it subjected 

him to hatred, distrust, ridicule, contempt, and disgrace.

26. Plaintiff Klayman has been severely damaged by this false and misleading 

statement because the malicious statement injured Plaintiff Klayman in his profession and 

business as a public interest and private lawyer and nationally syndicated radio talk show host

who promotes ethics in government and the legal profession, as well as personally.

SECOND CAUSE OF ACTION

Defamation Per Se

27. Plaintiff re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint.

28. Defendant Fitton published to Stone the malicious false, misleading and 

defamatory statement that Plaintiff Klayman was ousted at Judicial Watch due to a sexual 

harassment complaint, who in turn, and in concert with Defendant Fitton, republished this 

malicious false and defamatory statement on the internet in this district, domestically and 

internationally and elsewhere for the entire world to see and hear.

29. Under Florida Law, “it is established...that an oral communication is 

actionable per se - that is, without a showing of special damage - if it imputes to another (a) a 

criminal offense amounting to a felony, or (b) a presently existing venereal or other loathsome 

and communicable disease, or (c) conduct, characteristics or a condition incompatible with the 

proper exercise of his lawful business, trade, profession or office, or (d) the other being a woman, 

acts of unchastity.” Wolfson v. Kirk, 273 So. 2d 774, 777 (Fla. Dist. Ct. App. 1973).

30. This false and misleading statement was published with malice, as Defendant 

Fitton knew that it was false and misleading, or at a minimum acted with a reckless disregard for 

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 7 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 95 of 109
8

the truth.

31. This malicious false, misleading and defamatory statement was published on the 

internet in this district, domestically and internationally for the entire world to see and hear and 

specifically Defendant Fitton published these malicious false and misleading “facts,” inter alia, 

that Plaintiff’s conduct, characteristics or a condition is incompatible with the proper exercise of 

his lawful business, trade, profession or office

32. This malicious false and misleading statement is per se defamatory because it

falsely accuses Plaintiff Klayman of being ousted from Judicial Watch because of sexual

harassment - thereby falsely imputing a criminal and sexually related offense upon Plaintiff 

Klayman – as well as being “ousted” as the chairman and general counsel of Judicial Watch

because of an actual sexual harassment complaint, as well as the other false and misleading 

published statements alleged herein. To the contrary, on information and belief Fitton himself 

hypocritically had and may continue to have an “intimate personal relationship” with another 

director and member of the board of Judicial Watch, Paul Orfanedes, which on information and 

belief may constitute sexual harassment, as Defendant Fitton is Orfanedes’ superior as a result of 

Fitton being the president of Judicial Watch. Defendant Fitton also sits on the board of directors

along with Orfanedes, one of only three (3) directors, all of whom are also employed by Judicial 

Watch. By maliciously defaming Plaintiff Klayman, Defendant Fitton intended and intends to 

deflect attention away from his issues, vulnerabilities and conduct.

33. This false, misleading, and defamatory statement concerning Plaintiff Klayman is 

defamatory per se and this false and misleading statement, and others which will be uncovered in 

discovery, severely harmed and damaged Plaintiff Klayman in his profession and business as a 

lawyer and advocate and as a nationally syndicated radio talk show host, as they concern conduct 

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 8 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 96 of 109
9

and characteristics incompatible with being a lawyer and radio talk show host who promotes 

ethics in government and the legal profession. Damage is presumed by law when defamation per 

se is shown.

THIRD CAUSE OF ACTION

Defamation by Implication

34. Plaintiff re-alleges and incorporates by reference the allegations in the preceding 

paragraphs of the Complaint as if fully set forth herein.

35. Defendant Fitton published to Stone the false, misleading and defamatory 

statement that Plaintiff Klayman was ousted at Judicial Watch due to a sexual harassment 

complaint, who in turn, and in concert with Defendant Fitton, republished this false and 

defamatory statement on the internet in this district, domestically and internationally and 

elsewhere for the entire world to see and hear.

36. This false, misleading and defamatory statement was published with malice, as 

Defendant Fitton knew that it was false, or at a minimum acted with a reckless disregard for the 

truth.

37. This malicious statement created the false and misleading implication that 

Plaintiff Klayman has engaged been subject to a sexual harassment complaint and was ousted

from Judicial Watch for this reason and committed criminal sexual offenses, as well as other 

matters of moral turpitude as set forth in this Complaint.

38. Plaintiff Klayman has been severely harmed damaged by this published statement 

because it subjected him to hatred, distrust, ridicule, contempt, and disgrace.

39. Plaintiff Klayman has been damaged by malicious this false and misleading 

statement, and others which will be disclosed during discovery, because the statements severely 

harmed and damaged Plaintiff Klayman in his profession and business as a public advocate and 

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 9 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 97 of 109
10

as a syndicated radio talk show host who promotes ethics in government and the legal profession, 

and personally, as pled herein.

40. On information and belief Defendant Fitton’s defamatory conduct, in concert with 

Stone and individually, is on-going and as more defamatory conduct is uncovered through 

discovery and otherwise, this defamatory conduct will be subject to a motion to amend this 

Complaint.

41. Defendant Fitton’s malicious intent to severely harm and damage Plaintiff 

Klayman is largely based on an “inferiority complex” that he is not a lawyer and thus he feels 

competitive with Klayman. Indeed, at the time that Plaintiff left Judicial Watch on September 19, 

2003, to run for the U.S. Senate in Florida Fitton had not graduated from college, his having lied 

to Klayman that he did have a bachelor’s degree from George Washington University. This false 

statement fraudulently induced Klayman to offer him a job at the public interest organization. As 

a non-lawyer Fitton inappropriately does not have the background and expertise to now head 

Judicial Watch and make expert legal commentary on television, radio, the internet and in print,

as Judicial Watch was conceived to in effect be and is a public interest law firm.

42. Plaintiff Klayman has steadfastly demanded that Defendant Fitton refrain from 

making the malicious false and misleading statement as alleged herein, but he has refused and 

Fitton has also refused to correct this and other false and misleading statements in the past, 

regrettably necessitating the need for this and other legal complaints. The false and misleading 

statement published in concert with Stone has since been republished by others to severely harm 

and damage Plaintiff Klayman and his client Dr. Corsi. Defendant Fitton’s campaign to severely 

harm and damage Plaintiff Klayman is maliciously intended to boost his own standing at the 

expense of Plaintiff Klayman in the conservative community, media and with donors and 

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 10 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 98 of 109
11

elsewhere and it continues unabated. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Larry Klayman prays for judgment against Defendant Fitton as 

follows:

a. Awarding Plaintiff Klayman compensatory including actual, consequential, incidental

and punitive damages for malicious tortious conduct as alleged herein in an amount to be 

determined at trial and in excess of $35, 000,000 U.S. Dollars.

b. Awarding Plaintiff Klayman attorney’s fees and costs.

c. Granting any such further relief as the Court deems appropriate including preliminary and 

permanent injunctive relief.

PLAINTIFF KLAYMAN DEMANDS A JURY TRIAL ON ALL COUNTS SO TRIABLE.

Dated: February 11, 2019 Respectfully Submitted, 

 /s/ Larry Klayman 

Larry Klayman, Esq.

FL Bar No. 246220 

KLAYMAN LAW GROUP, P.A.

c/o 2020 Pennsylvania Ave., N.W.

Suite 800

Washington, D.C. 20006

Telephone: (310) 595 - 0800

Email: leklayman@gmail.com

Case 1:19-cv-20544-XXXX Document 1 Entered on FLSD Docket 02/11/2019 Page 11 of 11 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 99 of 109
Case 1:19-cv-20544-XXXX Document 1-1 Entered on FLSD Docket 02/11/2019 Page 1 of 1 Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 100 of 109
;35=

NTENTIONALLY /MITTED 3EE

-AINX

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 101 of 109
EXHIBIT 6

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 102 of 109
Larry Klayman, founder of Judicial Watch and 

Freedom Watch, is known for his strong 

public interest advocacy in furtherance of 

ethics in government and individual freedoms 

and liberties. During his tenure 

at Judicial Watch, he obtained

a court ruling that Bill Clinton 

committed a crime, the first 

lawyer ever to have done so 

against an American president. 

Larry became so famous for 

fighting corruption in the 

government and the legal 

profession that the NBC hit 

drama series "West Wing" 

created a character after him: 

Harry Klaypool of Freedom 

Watch. His character was 

played by actor John Diehl.

In 2004, Larry ran for the U.S. 

Senate as a Republican in Florida's primary. 

After the race ended, he founded Freedom 

Watch.

Larry graduated from Duke University with 

honors in political science and French 

literature. Later, he received a law degree from 

Emory University. During the administration 

of President Ronald Reagan, Larry was a 

Justice Department prosecutor and was on the 

trial team that succeeded in breaking up the 

telephone monopoly of AT&T, thereby 

creating competition in the 

telecommunications industry.

Between Duke and Emory, Larry worked for 

U.S. Senator Richard Schweiker (R-Pa.) 

during the Watergate era. He has also studied 

abroad and was a stagiaire for the Commission 

of the European Union in its Competition 

Directorate in Brussels, Belgium. During law 

school, Larry also worked for the U.S. 

International Trade Commission in 

Washington, D.C.

Larry speaks four languages—

English, French, Italian, and 

Spanish—and is an 

international lawyer, among his 

many areas of legal expertise 

and practice.

The author of two books, Fatal 

Neglect and Whores: Why and 

How I Came to Fight the 

Establishment, Larry has a 

third book in the works dealing 

with the breakdown of our 

political and legal systems. His 

current book, Whores, is on 

now sale at WND.com, Amazon.com, 

BarnesandNoble.com, Borders.com, and all 

major stores and booksellers.

Larry is a frequent commentator on television 

and radio, as well as a weekly columnist, on 

Friday, for WND.com. He also writes a regular 

blog for Newsmax called "Klayman's Court."

Larry has been credited as being the 

inspiration for the Tea Party movement. (See 

"Larry Klayman - The One Man TEA Party," 

by Dr. Richard Swier, http://fwusa.org/KFA)

Support the work of

Freedom Watch at

www.FreedomWatchUSA.org

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 103 of 109
EXHIBIT 7

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 104 of 109
2/2/2019 'istrict of ColumEia liYe dataEase

https://ecf.dcd.uscourts.goY/cgi-Ein/'ktRpt.pl"23771919011-/B1B0-1 1/1

0,N87( 2R'(R as to R2*(R -. S72N(, -R. 2n )eEruar\ 19, 2019, the Court ordered the defendant to show

cause at a hearing to Ee held on )eEruar\ 21, 2019 as to wh\ the media communications order entered in this

case 3 and/or defendant
s conditions of release 21 should not Ee modiÀed or reYoked. $ hearing was held on

this date. )or the reasons set forth on the record, and Eased upon the entire record, including the sealed exhiEit to

the hearing 2 , the testimon\ of the defendant, the arguments of counsel, and the suEmissions of the

parties 28 29 Àled in connection with the potential imposition of a media communications order, the Court

entered the following order at the hearing: the conditions of defendant
s pretrial release 21 are hereE\ modiÀed to

include the condition that, and the )eEruar\ 1, 2019 media communications order 3 is hereE\ modiÀed to

proYide that, the defendant is prohiEited from making statements to the media or in puElic settings aEout the

Special Counsel
s inYestigation or this case or an\ of the participants in the inYestigation or the case. 7he

prohiEition includes, Eut is not limited to, statements made aEout the case through the following means: radio

Eroadcasts interYiews on teleYision, on the radio, with print reporters, or on internet Eased media press releases

or press conferences Elogs or letters to the editor and posts on )aceEook, 7witter, ,nstagram, or an\ other form

of social media. )urthermore, the defendant ma\ not comment puElicl\ aEout the case indirectl\ E\ haYing

statements made puElicl\ on his Eehalf E\ surrogates, famil\ memEers, spokespersons, representatiYes, or

Yolunteers. 7he order to show cause is hereE\ Yacated. Signed E\ -udge $m\ %erman -ackson on 2/21/19.

'0. (ntered: 02/21/2019

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 105 of 109
3/4/2019 Roger Stone suggests Robert Mueller framed him despite gag order

https://www.cnbc.com/2019/03/03/roger-stone-suggests-robert-mueller-framed-him-despite-gag-order.html 2/6

Stone deleted the only image in that multi-image post that included

"Who framed Roger Stone" language shortly after CNBC emailed

his lawyer to ask about it.

Stone's post was put online less than 48 hours after the judge, Amy

Berman Jackson, ordered lawyers for the admitted Republican "dirty

trickster" to explain why they did not tell her earlier about the

planned publication of a book by Stone that could violate her gag

order on him.

TRENDING NOW

­

¬

ã



]

LIVE, NEWS-MAKING DISCUSSIONS

UNIQUE, IN-PERSON EXPERIENCES

LEARN MORE + JOIN US

Gundry MD

Constant Fatigue Is A Warning Sign – See The Simple

Fix

House Democrats

unveil a sweeping

'Medicare-for-all' bill —

here's what's in it

Michael Cohen's

testimony gives both

sides fodder in a

possible impeachment

fight

A 'shock and awe' rally

scenario that could rip

the market 7% higher

Bloomberg aides

interview staffers in

New Hampshire, Iowa

as the billionaire

considers 2020 run

These are the cities

where you can live

comfortably on

$50,000 a year

Michael Cohen says

prosecutors are

investigating previously

undisclosed

wrongdoing related to

Trump

1. Brett Kavanaugh:

State laws blocking

taxpayer-funded

church repairs are

'pure discrimination'

2. Southwest Airlines

starts selling its first

Hawaii flights, from

$49 one way

3. Tesla's onslaught of

announcements is

raising red flags

about demand for its

cars

Roger Stone

suggests Robert

by Taboola



/MARKETSLWATCHLIST CN

.BC TV

0MENU

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 106 of 109
3/4/2019 Roger Stone suggests Robert Mueller framed him despite gag order

https://www.cnbc.com/2019/03/03/roger-stone-suggests-robert-mueller-framed-him-despite-gag-order.html 3/6

Stone announced on Instagram in January that he was coming out

with the book, "The Myth of Russian Collusion: The Inside Story of

How Trump Really Won."

In her gag order in U.S District Court in Washington, D.C., Jackson

barred Stone from "making statements to the media or in public

settings about the Special Counsel's investigation or this case or any

of the participants in the investigation or the case."

The gag extends to "posts on Facebook, Twitter, Instagram or any

other form of social media." If Stone violates the order, Jackson

could order him jailed without bail until his trial.

Jackson had slapped that order on Stone on Feb. 21 after he posted

on Instagram a photo showing the judge's face next to a rifle scope's

crosshair.

Stone's new post is comprised of a rotating series of images that ask

for money to support Stone's defense to charges that he lied to

Congress and tampered with a witness.

One says, "I am committed to proving my innocence. But I need

your help." Another photo, which shows a young Stone standing

­

¬

ã



]

Jon Swaine

@jonswaine

Roger Stone now directly attacking the federal judge presiding

over his case and posting a pic of her head beside crosshairs

9,929 11:12 AM - Feb 18, 2019

10.2K people are talking about this

Mueller 'framed' him

in Instagram post that

could violate gag

order

5. 'Beverly Hills, 90210'

and 'Riverdale' star

Luke Perry died at 52

after suffering a

massive stroke



/MARKETSLWATCHLIST CN

.BC TV

0MENU

Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 107 of 109
3/4/2019 Roger Stone suggests Robert Mueller framed him despite gag order

https://www.cnbc.com/2019/03/03/roger-stone-suggests-robert-mueller-framed-him-despite-gag-order.html 4/6

behind Trump years ago, says, "I've always had Trump's back. Will

you have mine?" Two other images tout a "Roger Stone Did Nothing

Wrong" t-shirt and "Stone Cold Truth" sweatshirt.

The post originally had an image showing Stone wearing eyeglasses

under the words "Who Framed Roger Stone," a reference to the

movie "Who Framed Roger Rabbit." The image has been on the

Internet for some time.

A spokesman for Mueller declined to comment Sunday. Stone's

lawyer did not immediately respond to a request for comment.

Stone, who remains free on a $250,000 signature bond, was

arrested in Florida in late January and has pleaded not guilty to the

seven counts against him, including making false statements to

Congress, witness tampering and obstructing justice.

Mueller has said Stone lied to Congress about his alleged efforts to

have WikiLeaks release material hacked by Russian agents from

Democrats, including Hillary Clinton's campaign chairman, during

the 2016 campaign that ended with Trump's victory.

­

¬

ã



Shelby Holliday ]

@shelbyholliday

New in Instagramland: Roger Stone, using Insta stories (which

disappear after 24 hrs), suggests he’s being framed.

2,224 10:40 AM - Mar 3, 2019

2,253 people are talking about this



Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 108 of 109
3/4/2019 Roger Stone suggests Robert Mueller framed him despite gag order

https://www.cnbc.com/2019/03/03/roger-stone-suggests-robert-mueller-framed-him-despite-gag-order.html 5/6

An indictment alleges Stone was in contact with top-ranking Trump

campaign officials about efforts to leak damaging information about

Clinton right before Election Day.

Dan Mangan

Reporter

­

¬

ã



]

FROM THE WEB Sponsored Links by Taboola

Progressive

Wikibuy

Health Headlines

Man Who Called DOW 20,000 Has Surprising New Prediction

Investing Outlook

These German hearing aids are going viral

hear.com

If Your Indoor Cat Vomits (Do This Every Day)

Ultimate Pet Nutrition

Drivers who switch save an average of $668 on car insurance.

Before you renew Amazon Prime, read this

U.S. Cardiologist: It's Like a Pressure Wash for Your Insides

MORE FROM CNBC

House Judiciary Committee chair Nadler says Trump obstructed

justice, will request documents

Trump will be 'very tough to beat' in 2020 if he gets three things

right: Scaramucci

Cohen brings Trump's net worth statements to hearing. Here's how

to read them

Trump, from Vietnam, berates 'Da Nang Dick' Blumenthal for war

record

Michael Cohen: 'I fear' Trump won't peacefully give up the White

House if he loses the 2020 election

GOP Rep. tweets at Michael Cohen on eve of hearing: Does your

wife 'know about your girlfriends?'

by Taboola



Case 1:20-cv-00298-LY Document 1 Filed 03/07/19 Page 109 of 109