PLAINTIFF’S AMENDED COMPLAINT PAGE 1

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

TEXARKANA DIVISION

ALEXANDRA DAVIS,

Plaintiff,

VS.

JERRAL W. JONES, DALLAS COWBOYS 

FOOTBALL CLUB, LTD., JAMES 

WILKINSON, TRAILRUNNER 

INTERNATIONAL, LLC, and DONALD JACK, 

JR.

Defendants.

CIVIL ACTION NO. 5:23-CV-00032

JURY TRIAL DEMANDED

PLAINTIFF’S AMENDED COMPLAINT FOR DEFAMATION

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, Alexandra Davis, (“Plaintiff”), and complains of Jerral W. Jones, 

(“Defendant Jones”), Dallas Cowboys, Football Club, LTD., (“Defendant Dallas Cowboys”), 

James Wilkinson (“Defendant Wilkinson”), Trailrunner International, LLC (“Defendant 

Trailrunner”), and Donald Jack, Jr. (“Defendant Jack”) for cause of action would respectfully show 

the Court the following:

PARTIES

1. Plaintiff is a resident of the District of Columbia. 

2. Upon information and belief, Defendant Jerral W. Jones is an individual residing in Dallas 

County, Texas, and is before the Court for all purposes. 

3. Upon information and belief, Defendant Dallas Cowboys is a Texas limited partnership 

with its principal place of business located at One Cowboys Way, Frisco, Texas 75034, and is 

before the Court for all purposes.

4. Upon information and belief, Defendant James Wilkinson is an individual residing in 

Tarrant County, Texas, and is before the Court for all purposes.

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5. Upon information and belief, Defendant Trailrunner is a Texas limited liability company 

having its principal place of business at 1900 W. Kirkwood Blvd. Unit 1400B, Southlake, Texas 

76092-2241, and is before the Court for all purposes. At all times during the complained of acts, 

Defendant Trailrunner employed Defendant Wilkinson.

6. Upon information and belief, Defendant Donald Jack is an individual residing in Pulaski 

County, Arkansas, and is before the Court for all purposes. 

JURISDICTION AND VENUE

7. This Court has jurisdiction pursuant to 28 USC 1332(a) because there is diversity among 

the parties. Plaintiff is a citizen of the District of Columbia, and her residency is diverse from all 

of the Defendants. The amount in controversy exceeds $75,000.00.

FACTUAL BACKGROUND

8. Plaintiff was born in Arkansas on December 16, 1996. Approximately one year previous 

to Plaintiff’s birth, Plaintiff’s mother, Cynthia Davis Spencer (“Cynthia”), was married but was 

estranged and living apart from her husband. 

9. Around this time, Cynthia met and was pursued romantically by Defendant Jones, the wellknown Arkansas native owner and general manager of the Dallas Cowboys’ football NFL 

franchise. After being pursued by Defendant Jones, Cynthia and Defendant Jones began a romantic 

relationship, which included sexual relations.

10. After her relationship with Defendant Jones began, Cynthia briefly reunited with her 

estranged husband. During the brief attempted reconciliation with her husband, Cynthia was 

unaware that she was pregnant with Plaintiff from the relationship with Defendant Jones. 

11. Shortly after Plaintiff was born, Cynthia and her husband began divorce proceedings in 

Arkansas. During the divorce proceedings, Cynthia’s husband legally challenged whether he was 

the biological father of Plaintiff. 

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12. After genetic tests were conducted in accordance with the divorce court’s procedures, it 

was scientifically determined that Cynthia’s husband was not Plaintiff’s biological father. In June 

1998, the divorce court entered a Decree of Divorce, which included a judicial finding and 

adjudication that Cynthia’s husband was not Plaintiff’s biological or legal father. As a result, 

Cynthia’s husband was not ordered to pay child support, and Plaintiff did not have a legal father. 

13. As soon as the genetic testing results came back, Cynthia informed Defendant Jones of the 

results knowing that Defendant Jones was Plaintiff’s biological father. At this time, Defendant 

Jones unequivocally and adamantly stated two things to Cynthia. The first was that he “never was 

going to take a paternity test.” The second thing he vehemently asserted to Cynthia was that he 

would “never meet or have any relationship with the child.”

14. Faced with a potential public scandal, and certainly private problems being a married man 

with an existing family with grown children, Defendant Jones wanted to assure that he would not 

be publicly or privately identified and/or legally declared as Plaintiff’s father. As he stated 

unequivocally to Cynthia, Defendant Jones had no intention of meeting or having any kind of 

relationship with Plaintiff.

15. Defendant Jones, knowing that Cynthia was now a single mother with an infant child, no 

financial resources, and an uncertain financial future at best, immediately set out to negotiate an 

agreement with Cynthia that would exchange money for silence. This was the only way he could 

stay anonymous and achieve his stated objective of never taking a paternity test. Accordingly, with 

the help of his long-time Arkansas friend and lawyer, Defendant Jack, Defendant Jones sought to 

reach a “hush money” deal with Plaintiff’s mother Cynthia.

16. A “hush money” deal was struck. The essence of the deal was that Defendant Jones would 

provide, through indirect means and with his personal identity hidden, ongoing monthly support 

for Cynthia with monies earmarked as “child support” conditioned on Cynthia remaining silent 

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about the fact that Defendant Jones was Plaintiff’s father. If Cynthia failed to maintain such 

silence, the support would end at Defendant Jones’ discretion, and Cynthia would be subject to 

being sued by Defendant Jones, resulting not only in the end of future monthly support but also 

the return of support previously provided. 

17. The primary purpose of the arrangement was designed for Defendant Jones to maintain 

leverage and intimidation over Cynthia to not disclose Defendant Jones’ identity, and to compel 

Cynthia to train Plaintiff from ever disclosing and/or identifying who her father was. 

18. The final deal was memorialized in two written documents (the “Settlement Documents”). 

In addition to binding Cynthia, the Settlement Documents purported to bind Plaintiff, then a oneyear-old child, to confidentiality via her mother’s signature. The Settlement Documents also 

attempt to prevent Plaintiff from ever seeking a legal adjudication that Defendant Jones was her 

father. 

19. In essence two adults, with their own motivations and interests, entered into an agreement 

that purportedly would relieve Defendant Jones of support obligations if Cynthia or Plaintiff ever 

revealed, legally asserted, or even mentioned that Defendant Jones was Plaintiff’s father to anyone 

at any time. 

20. The Settlement Documents were entered into without court approval. Further, at no time 

was Plaintiff’s interest represented by any disinterested party without a conflict of interest.

21. Defendant Jones has continued to have contact with Cynthia over the years, but has 

declined her requests to establish a relationship with, or even meet with, Plaintiff who he knows 

to be his daughter. 

22. Plaintiff is now a twenty-six-year-old woman. She has lived her life fatherless and in secret. 

Her life has revolved around constant fear that if she should tell anyone who her father was, she 

and her mother would lose financial support or worse. Plaintiff grew up in the Dallas area. She

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went to college and graduated from Southern Methodist University in Dallas, a distance less than 

two miles from Defendant Jones’ residence. Plaintiff has had to endure the endless public profiles 

of her father and siblings while forced to remain secret to everyone, including her closest 

confidants. 

23. Despite the emotional obstacles of being abandoned and shunned by her father and forced 

to live in secrecy, Plaintiff excelled academically and professionally. She presently works for a 

United States Congressman from Texas in Washington, D.C., after serving in the White House for 

fourteen months. 

A. Negotiations Prior to Declaratory Judgment Action

24. Plaintiff decided to seek legal guidance as to her rights for the first time as they related to 

Defendant Jones, parentage, and the so-called Settlement Documents. After meeting counsel 

regarding these issues that had dominated her entire life, she decided to seek her legal right to 

confirm biologically who her father was and establish her parentage.

25. Accordingly, on or about January 4, 2022, Plaintiff’s counsel sent an email to general 

counsel of the Defendant Dallas Cowboys, Jason Cohen. The email stated as follows:

I hope this email finds you well in this New Year.

I am about to send Mr. Jones (senior) a letter regarding a claim involving what he may 

perceive to be a sensitive and personal legal matter. I do not want to unnecessarily publish 

the existence of this to other people who might deal with his mail and at the same time I 

need to make sure that Mr. Jones receives and gives due consideration to the matter set 

forth in my letter. To accomplish these goals, I thought I might reach out to you and see if 

you want to accept this letter on behalf of Mr. Jones.

Please let me know that you received this email and whether or not you want to accept this 

letter on his behalf. If you want to talk, please feel free to contact me on my cell xxx xxxxxxx. Thank you.

26. After Mr. Cohen responded that he would accept the letter on Defendant Jones’ behalf, 

Plaintiff’s counsel sent the letter dated January 5, 2021 (actually the year should have been 2022) 

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to Mr. Cohen. The letter was addressed to Defendant Jones in care of Mr. Cohen. See Exhibit 1, 

Letter to Defendant Jones.

27. The letter explains that Plaintiff believes she is Defendant Jones’ biological daughter and 

that counsel was hired to represent her in determining whether Defendant Jones was her biological 

and legal father. The letter advises Defendant Jones that Plaintiff was not trying to harass or 

embarrass him in any way and offered an easy private resolution in accordance with Texas law. 

No money was demanded nor was there any threat to make the matter public. In fact, as set forth 

above, counsel reached out to Mr. Cohen to avoid any staff member or member of Defendant 

Jones’ family from inadvertently seeing the letter’s contents. Plaintiff suggested that she was 

willing to undergo genetic testing to confirm to Defendant Jones whether she was his daughter.

28. Plaintiff sought Defendant Jones’ participation without the necessity of filing a lawsuit to 

avoid potential publicity that the filing of a paternity lawsuit could attract. Plaintiff, neither 

personally nor through her legal counsel, ever threatened to make the matter public nor sought any 

financial compensation. 

29. In response to receiving the email and letter, Plaintiff’s counsel was notified by Mr. Cohen 

that Defendant Jones’ counsel would be in contact shortly. On March 1, 2022, after not receiving 

any contact from Defendant Jones’ counsel, Plaintiff’s counsel reached out to Defendant Jones’ 

counsel and forwarded a copy of the lawsuit that Plaintiff intended to file if Defendant Jones would 

not agree that Plaintiff was not bound by the Settlement Documents entered into when she was 

one year old. Once again, no monetary compensation was sought, much less demanded. 

30. The draft of the lawsuit forwarded to Defendant Jones was a declaratory action, which 

sought a declaration from the court that Plaintiff was not bound by the Settlement Documents that 

Defendant Jones had tried to bind her to since she was an infant. The declaratory action would 

clear the way for Plaintiff to be able to request a Court to require that Defendant Jones be ordered 

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to submit to genetic testing. This action would alleviate the concern that Defendant Jones would 

take overwhelmingly expensive and oppressive actions against Plaintiff or her mother for any 

alleged breach of the SettlementDocuments as neither had the resources to fight and/or compete 

against the billionaire Defendant Jones. 

31. Plaintiff hoped that the lawsuit would not be required, and this last resort could be avoided 

by Defendant Jones submitting to genetic testing. Plaintiff never demanded any money as part of 

the resolution. Plaintiff only sought to establish her parentage and an agreement that Plaintiff was 

not bound by the Settlement Documents entered into when she was one year old. 

32. Defendant Jones was not agreeable to resolving these issues without litigation. 

Disappointed and disheartened, Plaintiff filed a declaratory judgment action (the “First Lawsuit”).1

Plaintiff did not provide any pleadings or documents from the First Lawsuit to the press or contact 

the media in any way to alert the media as to the First Lawsuit’s existence. Again, the First Lawsuit 

did not seek money damages.

33. After filing the First Lawsuit, Defendant Jones’ counsel contacted Plaintiff’s counsel 

asking if Plaintiff would agree to have the First Lawsuit sealed to avoid public media and private 

disclosure. Consistent with Plaintiff’s desire to keep the matter private, Plaintiff immediately 

agreed to Defendant Jones’ request. Unfortunately, before the sealing could be accomplished, the 

filing of the First Lawsuit was apparently picked up by the Dallas Morning News, who 

immediately published a story about it. 

34. After the Dallas Morning News published its story, the First Lawsuit immediately attracted 

local, national, and international attention. At this point, Defendant Jones’ rescinded his request to 

seal the record. 

1 Plaintiff eventually nonsuited the declaratory judgment action and brought a paternity suit in Dallas County Family 

District Court (the “Second Lawsuit”). The Second Lawsuit is still pending after a continuance was granted. 

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B. Scheme to Publicly Defame Plaintiff 

35. Plaintiff never made a demand for money to Defendant Jones in any way associated with 

the request for parentage or filing of the Lawsuit. Regardless, Defendant Jones, with his team of 

lawyers, marketing and media professionals, initiated a deliberate plan and scheme to publicly 

defame Plaintiff. This plan, as set forth below, centered upon attacking his own daughter in the 

world-wide public domain as an “extortionist” and a “shakedown artist” whose motivation was 

money and greed and who was “conspiring” in concert with other “extortionists” to exact money 

from Defendant Jones and his family. This designed campaign was based knowingly on false 

statements and accusations alleged by Defendant Jones and his agents to be truthful facts both in 

court filings and in public statements to the media. The purpose of the false statements were to 

discredit Plaintiff’s character in the public eye.

36. Defendant Jones’ first step in the false and purposeful character assassination attack of 

Plaintiff was the filing of his initial response to the First Lawsuit of a document titled “Plea to The 

Jurisdiction and Subject Thereto Original Answer” (the “Plea to the Jurisdiction”). The Plea to the 

Jurisdiction, filed on March 28, 2022, falsely asserted that Plaintiff sought money from Jones in 

exchange for keeping the matter private.

37. Although completely unrelated to the matters asserted in the Lawsuit and inappropriate in 

a responsive pleading, Defendant Jones falsely stated the following in what was labeled 

“Introduction”:

Plaintiff, a twenty-five-year-old woman currently employed by a United States 

Congressman in Washington D.C., claims that Defendant [Jones] is her 

unacknowledged father. But before making these allegations [Plaintiff] delivered a 

draft of her lawsuit to Defendant and, to borrow her phrase, asked whether he would 

like to ‘make a deal’ to ‘assure that he would not be publicly or privately identified 

and/or declared as Plaintiff’s father.’ (Pet. ¶ 9) When Defendant declined to pay, 

this lawsuit followed.

Plaintiff’s ‘let’s make a deal’ overtures were made at the same time Defendant 

[Jones] and the Dallas Cowboys were the targets of multiple extortion attempts. 

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The potential source(s) of those attempted extortions, including without limitation, 

the Plaintiff [Alexandra Davis] and her agents, will be the subject of other litigation 

which has been filed or will be instituted shortly.

38. Defendants admittedly provided this pleading to media outlets, as they customarily do, to 

ensure that the accusations were picked up by the media. The highly public profile of Defendant 

Jones with his immense public relations resources ensured these wholly false accusations were 

quoted by innumerable media outlets worldwide. The substance of these pleadings was also 

affirmed by Defendants when questioned by the media. Article after article ran with some form of 

headline that referenced Plaintiff as being accused of being an “extortionist” by the famous 

Defendant Jones.

39. Around this same time, Defendant Jones’ daughter, Charlotte Jones Anderson was going 

through a contentious divorce with her husband, Shy Anderson. On March 10, 2022, counsel for 

Defendant Jones wrote a so-called “Preservation Letter” to Shy Anderson’s divorce attorney, 

wherein Defendant Jones accused Mr. Anderson of working with “others” to extort money from 

the Jones family. Plaintiff was specifically named in the letter. Upon information and belief, this 

letter was again provided directly to the media by Defendant Jones and his team to further 

propagate the extortion narrative and to tie Plaintiff to other supposed bad actors who were alleged 

to have been wrongfully seeking money from Defendant Jones and/or his organizations.

40. As a result of the slander campaign by Defendant Jones and his camp, Plaintiff was 

depicted as an extortionist that was in “conspiracy” with others supposedly attempting to extort 

money from the Jones family. These “others” apparently included the Dallas Cowboys 

Cheerleaders, who were allegedly video recorded by the Dallas Cowboys’ longtime chief media 

head while the they were undressing. This scandal, which occurred several years earlier, was the 

subject of media disclosure around the same time as Plaintiff’s existence was being made public, 

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and it was reported that the Cowboys paid money to the cheerleader complainants in exchange for 

nondisclosure.

41. On March 30, 2022, in an interview published by ESPN, Defendant Wilkinson furthered 

the public smear campaign against Plaintiff. Defendant Wilkinson, as spokesperson for Defendant 

Jones and the Dallas Cowboys, stated: “This whole saga and series of recent attacks amounts to 

nothing more than an amateurish coordination among various parties to try to shake down the 

Jones family for money.”

42. This statement was patently false. At no time did Plaintiff attempt to “shake down” 

Defendant Jones, nor did Plaintiff coordinate with any other party or person in seeking her legal 

right to determine her legal father. Defendant Wilkinson’s comments completely lacked any 

factual basis and were false.

43. On March 31, 2022, just days after the Plea to the Jurisdiction pleading accusing Plaintiff 

of being an “extortionist” was filed and provided to the media by Defendants, Defendant 

Wilkinson, acting as a spokesperson for Defendants Jones and the Dallas Cowboys, was quoted as 

reaffirming the allegations in that Pleading that Plaintiff was an “extortionist.” 

44. Not only did Defendant Wilkinson publicly affirm the “extortionist” allegations on behalf 

of himself and all Defendants, but in this interview with ESPN, Defendant Wilkinson and 

Defendant Jack, on behalf of Defendant Jones, accused Plaintiff of being an extortionist and 

portrayed Plaintiff as attempting to “shakedown” Defendant Jones. Defendant Jack provided an 

affidavit to ESPN claiming that Plaintiff had demanded money from Defendant Jones years earlier, 

and that this meant Plaintiff’s recent lawsuit was an extortion attempt. Rather than showing the socalled letter, Defendants Jack and Wilkinson conveniently misrepresented its contents in a 

distorted and self-serving manner to further the “Plaintiff is an extortionist” narrative they 

intentionally created.

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45. Defendants Jack and Wilkinson were referring to a letter written at least five years earlier 

by Plaintiff as a therapeutic exercise at the direction of her therapist. This writing was addressed 

to Defendant Jack, not Defendant Jones, wherein Plaintiff was seeking advice from Defendant 

Jack as a friend and father figure. Upon information and belief, this letter was never provided to 

Defendant Jones but rather was read to Defendant Jack at a dinner years before Plaintiff ever met 

with any attorneys concerning the current lawsuit. The purpose and content of this writing was an 

attempt by Plaintiff to share her anguish about the lack of relationship with her father and plead 

with Defendant Jones for a simple meeting of any kind. 

46. Defendant Jack portrayed the therapeutic writing as Plaintiff being unsatisfied with what 

she received financially from Defendant Jones. In truth and in fact, the therapy assisted letter, was 

a plea by a shunned daughter to her father. Defendant Jack knew his characterization to the media 

was false as did Defendant Jones and Wilkinson. It was falsely characterized as a monetary demand 

to support their objective to discredit Plaintiff by painting her as an extortionist.

47. Nevertheless, Defendants Wilkinson and Jack used this plea for attention by an abandoned 

child made years before any type of litigation was contemplated to distort and misrepresent to 

ESPN in a nationally published article as support for the pleading which accused Plaintiff of being 

an “extortionist” in effect adopting the false allegation that Plaintiff’s lawsuit was an extortion 

attempt when in fact the lawsuit did not seek an economic award. 

48. In addition to adopting the “extortionist” claim, Defendant Wilkinson further stated that 

the statement by Defendant Jack regarding the plea made by Plaintiff years earlier “clearly 

demonstrates that money has always been the ultimate goal here. And sadly, this is just one part 

of a broader calculated and concerted effort that has been going on for some time by multiple 

people with various different agendas.” Despite knowing that the years earlier letter to Defendant 

Jack had nothing to do with the lawsuit, Defendants, once again, not only falsely accused Plaintiff 

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of making a $20 Million dollar demand in connection with the First Lawsuit, but also made the 

unsupported accusation that Plaintiff was working in concert with other people to extort Defendant 

Jones.

49. In the same ESPN article, Defendant Wilkinson also stated publicly to the media that 

Plaintiff’s counsel had previously met with Defendant Jones’ counsel and had demanded money. 

Again, this is a false statement made with the intent to continue the scheme of defaming Plaintiff. 

No such demand for money was ever made by Plaintiff’s counsel.

50. Defendant Wilkinson also added “[t]here was never a discussion about a nonmonetary 

resolution. Money was always part of the deal.” Again, a categorically false statement made by 

Defendant Wilkinson, who was never part of any discussions with Plaintiff or her counsel, to 

intentionally and maliciously further spin the false narrative that Plaintiff demanded money and 

was an “extortionist.”

51. Defendant Wilkinson’s final quote in the ESPN article was “[n]ow they've changed their 

story yet again. First it wasn't about money. Now it is about money. And now they are on three 

sides of a two-sided issue. They are all over the map here. Pick a story and stick with it. This is 

clownish.” Again, Defendant Wilkinson knowingly created a false narrative by first suggesting 

that Plaintiff had changed her story and second stating “Now it is about money,” when no story 

had changed and there had not been any demand or lawsuit for money. 

52. Defendant Jack also used this media platform to falsely state that Plaintiff’s motivation in 

the lawsuit was money. Defendant Jack stated that he got “a far different impression of Davis’ 

motives.” Defendant Jack deceptively and knowingly based this statement about Plaintiff’s 

“motives” upon a letter written by Plaintiff years earlier at her therapist’s recommendation. Instead 

of simply producing the letter for the media and the public to interpret its meaning, Defendant Jack 

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knowingly and falsely characterized its contents to buttress the public smear campaign that 

Plaintiff was “extorting” or “shaking down” Defendant Jones.

53. Throughout their smear campaign against Plaintiff, Defendants either knew the statements 

being made by them were false or they knew enough facts such that they should have entertained 

serious doubts as to the truth of their defamatory statements. 

54. All Defendants in this suit are closely intertwined with Defendant Jones. Defendant Jones 

and all the Defendants were involved in continuing and contentious litigation with Plaintiff 

Alexandra Davis in the early months of 2022 when the defamatory statements were published. 

55. On information and belief, Defendants were additionally closely working with Van Natta, 

the author of the defamatory ESPN articles. Hundreds of texts and emails were exchanged in early 

2022 between Van Natta and Defendant Wilkinson and/or a member of Defendant TrailRunner 

regarding Plaintiff and Defendant Jones.

56. On information and belief, Defendant Wilkinson conceived a story line in advance even 

though the evidence and facts did not support it. He told Van Natta to protect him once Van Natta 

reported the story. More than once, Defendant Wilkinson knowing that the storyline was false, told 

Van Natta to not quote him, that he was not the source of the statements, and to report the statement 

as fact instead of quoting a source for the articles. He told Van Natta that Defendant Jones gave 

him permission to fire missiles when referring to Plaintiff and the articles about her.

57. On information and belief, Defendant Wilkinson was even concerned about the veracity of 

the publication himself. When a Defendant Trailrunner staff member congratulated Wilkinson on 

the lies he spread to Van Natta, Defendant Wilkinson responded for the staff member to cover his 

legal fees. Defendant Wilkinson anticipated litigation over his statements because he knew from 

the beginning they were false or, at a minimum, he entertained serious doubts as to their truth.

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58. On information and belief, Defendants Wilkinson and Trailrunner did not stop at spreading 

lies to Van Natta. Part of their strategy was to ensure all news outlets reported the statements 

Defendant Wilkinson had given to Van Natta. If a published article did not contain the statements 

made by Defendants Wilkinson and/or Jack, Defendant TrailRunner reached out to the publisher 

to make sure they had the new defamatory statements as well. For example, an article in Bleacher 

Report on March 31, 2022, did not contain the statements made by Defendants Wilkinson and 

Jack. Defendant Trailrunner staff, at the direction of Defendant Wilkinson, specifically reached 

out to the publisher requesting the information from the second ESPN article be included. Bleacher 

Report then updated the article to include defamatory statements in its article as well.

59. On information and belief, Defendants Wilkinson and Trailrunner only concern was 

furthering their smear campaign against Plaintiff. For example, after Defendant Trailrunner 

reached out to Benedetto Vitale, a writer for Clutch Points, Vitale changed his original article to 

the following untrue information, based on Defendant Wilkinson and Trailrunner’s outreach: 

“Alexandra Davis and her mother, Cynthia Spencer-Davis, requested $20 million to keep the 

relationship confidential...Alexandra Davis and her mother are still seeking $20 million.”

60. On information and belief, Defendant Wilkinson, on behalf of Defendant Jones, wanted 

the image of Plaintiff as an extortionist to appear in the ESPN March 31st article. Defendant 

Wilkinson advised Van Natta to include the extortion language from the evidence preservation 

letter in his article.

61. On information and belief, Wilkinson and the other Defendants had copies of all pleadings. 

They had copies of all communications between Davis and Defendant Jones regarding the 

parentage and declaratory judgment action (as evidenced by Defendants leaking those documents 

to the press). Nowhere in those communications or court documents does it state Plaintiff was 

seeking any money at all. Defendant Wilkinson ignored all of this to portray to the press that 

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Plaintiff was a “shakedown artist” and an “extortionist” In relation to her lawsuit Again, at a 

minimum, Defendant Wilkinson and the other Defendants had enough facts such that they would

and/or should entertain serious doubts as to the truth of Defendants Wilkinson, Jack, and 

Trailrunner’s statements. 

AGENCY

62. At all times during the complained of acts, Defendant Wilkinson was acting as the agent 

and/or public spokesperson for Defendants Jones and Dallas Cowboys. Defendant Wilkinson’s 

defamatory comments were made within his general authority as an agent for Defendant Jones and 

Defendant Dallas Cowboys. 

63. At all times during the complained of acts, Defendant Wilkinson was in the course and 

scope of his employment with Defendant Trailrunner. Defendant Wilkinson’s defamatory 

comments were made within his general authority as an employee for Defendant Trailrunner.

64. With Defendant Wilkinson as his and the Dallas Cowboys’ spokesperson, Defendants 

Jones and Dallas Cowboys knew they retained a very prominent and notoriously known person in 

the world of public relations and world-wide media. Defendant Wilkinson has a successful, but 

highly controversial, history in the world of media. With his background in political and 

government related public relations and media work, Defendant Wilkinson has been publicly 

criticized for his role in various controversial and criticized media campaigns, notably in 

promoting the Iraq War and the story of Jessica Lynch. Perhaps his most controversial public 

relations work involved the original government narrative around the tragic death of Pat Tillman, 

the former NFL player who left the NFL to volunteer in the Army after 9-11 who was initially 

portrayed as a martyr for war killed in battle when in fact he was killed by friendly fire, a hugely 

embarrassing event for the Bush White House and the Pentagon at the time. 

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65. Ron Suskind of the Washington Post wrote that Defendant Wilkinson was the “spinmeister 

of the Iraq War.” Likewise, in the book Where Men Win Glory: the Odyssey of Pat Tillman, the 

legendary award-winning journalist and author Jon Krakauer referred to Defendant Wilkinson as 

a “major propagandist.” By using Defendant Wilkinson for public relations on this matter, 

Defendants Jones and Dallas Cowboys knew that that he would effectively spread the false 

narrative that gives rise to this lawsuit.

CAUSE OF ACTION

A. Count One-Statutory Defamation 

66. Plaintiff incorporates the above paragraphs setting forth the factual basis for Plaintiff’s causes 

of action and hereby incorporates such as if fully set forth herein.

67. Defendants made and published numerous false factual statements to third parties, including 

but not limited to mainstream and print media. 

68. In addition, as described in more detail above, Defendants made the following false verifiable 

statement of fact, including but not limited to:

a. Defendant Jones in Defendant’s Plea To The Jurisdiction And Subject Thereto Original 

Answer falsely and maliciously stated “[Plaintiff] delivered a draft of her lawsuit to 

Defendant and, to borrow her phrase, asked whether he would like to ‘make a deal’ to 

‘assure that he would not be publicly or privately identified and/or declared as 

Plaintiff’s father.’ When Defendant declined to pay, this lawsuit followed;”

b. Defendant Jones in Defendant’s Plea To The Jurisdiction And Subject Thereto Original 

Answer also falsely and maliciously accused Plaintiff of being in some sort of 

conspiracy with other “extortionist” attempting to extort money from Defendant Dallas 

Cowboys and Defendant Jones;

c. On March 10, 2022, Defendant Jones wrote a “Preservation Letter” to Shy Anderson’s 

divorce attorney wherein Defendant Jones accused Mr. Anderson of working with 

“others” to extort money from the Jones family. He identified Plaintiff as one of such 

persons;

d. On March 30, 2022, in an interview with ESPN, Defendant Wilkinson, as spokesperson 

for Defendant Jones and Defendant Dallas Cowboys, stated: “This whole saga and 

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series of recent attacks amounts to nothing more than an amateurish coordination 

among various parties to try to shake down the Jones family for money;”

e. On March 31, 2022, Defendant Wilkinson, acting as spokesperson for Defendant Jones 

and Defendant Dallas Cowboys, was quoted in an ESPN article as reaffirming the 

allegation that Plaintiff was an “extortionist:” Defendant Wilkinson falsely stated that 

the “dinner meeting with Jack supports the allegation” that Plaintiff is an “extortionist;” 

f. On March 31, 2022, in an interview with ESPN, Defendant Wilkinson and Defendant 

Jack, on behalf of Defendant Jones and Defendant Dallas Cowboys, accused Plaintiff 

of being an “extortionist” and portrayed Plaintiff as attempting to “shakedown” 

Defendant Jones. Defendant Jack provided an affidavit to ESPN claiming that Plaintiff 

had demanded money from Defendant Jones, three to four years earlier, and that this 

meant Plaintiff’s recent lawsuit was an extortion attempt;

g. In this same published article with ESPN on March 31, 2022, Defendant Wilkinson 

also used this years earlier plea for attention by Plaintiff as support for the pleading, 

which accused Plaintiff of being an “extortionist;”

h. In the March 31, 2022 ESPN article, Wilkinson further stated that the statement by Jack 

regarding the plea made by Plaintiff years earlier “clearly demonstrates that money has 

always been the ultimate goal here. And sadly, this is just one part of a more broad 

calculated and concerted effort that has been going on for some time by multiple people 

with various different agendas;”

i. In the March 31, 2022 ESPN article, Defendant Wilkinson also falsely stated that 

Plaintiff’s counsel had previously met with Defendant Jones’ counsel and had 

demanded money;

j. In the March 31, 2022 ESPN article, Defendant Wilkinson also falsely stated “[t]here 

was never a discussion about a nonmonetary resolution. Money was always part of the 

deal;”

k. In the March 31, 2022 ESPN article, Defendant Wilkinson’s further falsely stated 

“[n]ow they've changed their story yet again. First it wasn't about money. Now it is 

about money. And now they are on three sides of a two-sided issue. They are all over 

the map here. Pick a story and stick with it. This is clownish;” and,

l. In the March 31, 2022 ESPN article, Defendant Jack falsely stated that Plaintiff’s 

motives in the lawsuit against Defendant Jones was money. Defendant Jack falsely 

stated that he got “a far different impression of Davis’ motives.” Defendant Jack based 

this statement about Plaintiff’s “motives” upon the therapeutic letter written by Plaintiff 

years earlier at her therapist’s recommendation to align Plaintiff as an “extortionist.”

m. Defendants Wilkinson and Trailrunner reached out to numerous publishers to repeat their 

defamatory statements about Plaintiff being an extortionist. This outreach ensured any 

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articles published about the issues included the defamatory information about Plaintiff in 

the article. Specifically, Defendants Wilkinson and Trailrunner wanted it known and 

placed in every article that Plaintiff was seeking $20 million in the context of the 

declaratory judgment action and parentage action. Multiple publications updated and 

republished this defamatory information after Defendants reached out to request the 

addition of the defamatory information. 

69. The above statements were published by Defendants without privilege or authorization.

70. Additionally, as described in more detail below, Defendants made the following false 

verifiable statement of fact with knowledge that the statements were false or with reckless disregard 

for their truth when communicating them: 

a. On March 31, 2022, Defendant Wilkinson, acting as spokesperson for Defendant 

Jones and Defendant Dallas Cowboys, was quoted in an ESPN article as reaffirming 

the allegation that Plaintiff was an “extortionist:” Defendants knew that Plaintiff was 

not an extortionist and had not attempted to extort any money or anything of value in 

exchange for her 2022 lawsuit. Defendant Wilkinson falsely stated that the “dinner 

meeting with Jack supports the allegation” that Plaintiff is an “extortionist.” Defendant 

Wilkinson knew that this “dinner meeting” that Plaintiff had with Defendant Jack had 

been years earlier and was not in any way related to the 2022 lawsuit. Defendants were 

not even aware of the “dinner meeting” with Defendant Jack when Plaintiff filed her 

2022 lawsuit. Defendants did not discover about the dinner meeting until after the 

lawsuit was filed and then knowing that the “dinner meeting” had nothing to do with 

the 2022 lawsuit knowingly falsely stated that the “dinner meeting” was a demand 

related to the 2022 Lawsuit. 

b. On March 31, 2022, in an interview with ESPN, Defendant Wilkinson and Defendant 

Jack, on behalf of Defendant Jones and Defendant Dallas Cowboys, accused Plaintiff 

of being an “extortionist” and portrayed Plaintiff as attempting to “shakedown” 

Defendant Jones. Defendant Jack provided an affidavit to ESPN claiming that Plaintiff 

had demanded money from Defendant Jones, three to four years earlier, and that this 

meant Plaintiff’s recent lawsuit was an extortion attempt or a “shakedown” of 

Defendant Jones. Defendants knew that Plaintiff was not an extortionist and had not 

attempted to extort any money or anything of value in exchange or “shakedown” 

Defendant Jones relating to her 2022 lawsuit. Defendant Wilkinson knew that this 

“dinner meeting” that Plaintiff had with Defendant Jack had been years earlier and 

was not in any way related to the 2022 lawsuit. Defendants were not even aware of 

the “dinner meeting” with Defendant Jack when Plaintiff filed her 2022 lawsuit. 

Defendants did not discover about the dinner meeting until after the lawsuit was filed 

and then knowing that the “dinner meeting” had nothing to do with the 2022 lawsuit 

knowingly falsely stated that the “dinner meeting” was a “shakedown” related to the 

2022 Lawsuit.

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c. In this same published article with ESPN on March 31, 2022, Defendant Wilkinson 

also used this years earlier plea for attention by Plaintiff as support for the pleading, 

which accused Plaintiff of being an “extortionist.” Defendants knew that Plaintiff was 

not an extortionist and had not attempted to extort any money or anything of value in 

exchange for her 2022 lawsuit. Defendant Wilkinson falsely stated that the “dinner 

meeting with Jack supports the allegation” that Plaintiff is an “extortionist.” Defendant 

Wilkinson knew that this “dinner meeting that Plaintiff had with Defendant Jack had 

been years earlier and was not in any way related to the 2022 lawsuit. Defendants were 

not even aware of the “dinner meeting” with Defendant Jack when Plaintiff filed her 

2022 lawsuit. Defendants did not discover about the dinner meeting until after the 

lawsuit was filed and then knowing that the “dinner meeting” had nothing to do with 

the 2022 lawsuit knowingly falsely stated that the “dinner meeting” was a demand 

related to the 2022 Lawsuit.

d. In the March 31, 2022 ESPN article, Wilkinson further stated that the statement by 

Jack regarding the plea made by Plaintiff years earlier “clearly demonstrates that 

money has always been the ultimate goal here. And sadly, this is just one part of a 

more broad calculated and concerted effort that has been going on for some time by 

multiple people with various different agendas. Defendants knew that Plaintiff was 

not an extortionist and had not attempted to extort any money or anything of value in 

exchange for her 2022 lawsuit. Defendant Wilkinson knew that this “dinner meeting 

that Plaintiff had with Defendant Jack had been years earlier and was not in any way 

related to the 2022 lawsuit. Defendants were not even aware of the “dinner meeting” 

with Defendant Jack when Plaintiff filed her 2022 lawsuit. Defendants did not 

discover about the dinner meeting until after the lawsuit was filed and then knowing 

that the “dinner meeting” had nothing to do with the 2022 lawsuit knowingly falsely 

stated that the “dinner meeting” was a demand related to the 2022 Lawsuit. Defendants 

knew that Plaintiff’s goal was not money in the 2022. Defendants were told by 

Plaintiff that Plaintiff was not seeking money but only a declaration of parentage from 

Defendant Jones. Defendants had been told by Plaintiff that in regard to her 2022 

lawsuit that Plaintiff only sought a Declaration of Parentage from Defendant Jones 

and money was not even an issue. Despite being told this, Defendants dug up a “dinner 

meeting” with Defendant Jack where Plaintiff has sought paternal advice from 

Defendant Jack and mentioned that Defendant Jones’ son had paid $20 Million dollars 

to his illegitimate son and turned this into a demand for $20 Million dollars on 

Defendant Jones in connection with Plaintiff seeking parentage in 2022. Defendants 

further used this “dinner meeting” from years earlier to portray Plaintiff as part of a 

concerted effort in 2022 with “others” to get money from Defendant Jones. Defendants 

knew that Plaintiff was not working in concert with any “others.” Before the 

Defendants falsely stated that Plaintiff was working in concert with “others,” 

Defendants had been told by Plaintiff that she was not working in concert with any 

“others.” 

e. In the March 31, 2022 ESPN article, Defendant Wilkinson also falsely stated that 

Plaintiff’s counsel had previously met with Defendant Jones’ counsel and had 

demanded money. Defendants were aware that when they made this statement to 

ESPN that no demand for money had been made by Plaintiff’s counsel. Prior to 

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Defendants making this statement, Plaintiff’s counsel had specifically informed 

Defendants that money was not even part of the discussion. The only matters discussed 

between Plaintiff’s counsel and Defendant Jones’ counsel for the Parentage Action 

was that Defendant Jones enter into a Declaration of Parentage. Defendant Wilkinson 

had been informed when he made the statement that money had never been demanded 

from Plaintiff’s counsel which is why Defendants had to dig up the years earlier 

“dinner meeting” with Defendant Jack and state that the “dinner meeting” with 

Defendant Jack was a $20 Million dollar demand related to the 2022 lawsuit. 

Defendants knew this was false and there had never been a demand for money made 

by Plaintiff’s counsel.

f. In the March 31, 2022 ESPN article, Defendant Wilkinson also falsely stated “[t]here 

was never a discussion about a nonmonetary resolution. Money was always part of the 

deal.” Defendants were aware that when they made this statement to ESPN that no 

demand for money had been made by Plaintiff’s counsel. Prior to Defendants making 

this statement, Plaintiff’s counsel had specifically informed Defendants that money 

was not even part of the discussion. The only matters discussed between Plaintiff’s 

counsel and Defendant Jones’ counsel for the Parentage Action was that Defendant 

Jones enter into a Declaration of Parentage. Defendant Wilkinson had been informed 

when he made the statement that money had never been demanded from Plaintiff’s 

counsel which is why Defendants had to dig up the years earlier “dinner meeting” with 

Defendant Jack and state that the “dinner meeting” with Defendant Jack was a $20 

Million dollar demand related to the 2022 lawsuit. Defendants knew this was false and 

that the only discussions related to the 2022 lawsuit was the nonmonetary resolution 

of Defendant Jones entering into a Declaration of Parentage.

g. In the March 31, 2022 ESPN article, Defendant Wilkinson’s further falsely stated 

“[n]ow they've changed their story yet again. First it wasn't about money. Now it is 

about money. And now they are on three sides of a two-sided issue. They are all over 

the map here. Pick a story and stick with it. This is clownish.” Defendants knew when 

they made this statement that the 2022 lawsuit had never been about money. 

Defendants knew that the story had not changed. Defendants knew the “story” was 

still not about money. In fact, nothing had changed. Defendants just falsely made this 

statement to make people think something with Plaintiff’s 2022 lawsuit had changed. 

Defendant uses the “dinner meeting” with Defendant Jack that occurred years earlier 

to falsely convey the impression to the public that Plaintiff’s current action of seeking 

parentage was related that “dinner meeting.” Defendants knew when making this 

statement that the 2022 lawsuit had no connection to the many years earlier “dinner 

meeting” with Defendant Jack. Defendants knew when they made this statement that 

Plaintiff had not demanded money or $20 Million dollars from Defendant Jones years 

earlier. Defendants knew when they made this statement that the “dinner meeting” had 

absolutely nothing to do with the 2022 lawsuit. and,

h. In the March 31, 2022 ESPN article, Defendant Jack falsely stated that Plaintiff’s 

motives in the lawsuit against Defendant Jones was money. Defendant Jack falsely 

stated that he got “a far different impression of Davis’ motives.” Defendant Jack 

based this statement about Plaintiff’s “motives” upon the therapeutic letter written by 

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Plaintiff years earlier at her therapist’s recommendation to align Plaintiff as an 

“extortionist.” When Defendant Jack made these false statements, Defendant Jack 

knew that the years earlier “dinner meeting” had nothing to do with the 2022 lawsuit 

and that Plaintiff’s motive in her 2022 lawsuit was not money. Defendant Jack when 

making these statements knew that Plaintiff’s motives at the time were to merely seek 

parentage and not money of any sort. Defendant Jack had been told that 2022 lawsuit 

was not about money but Plaintiff seeking her parentage from her father. Yet despite 

this knowledge, Defendant Jack still falsely stated that Plaintiff’s motive in her 2022 

lawsuit was money. Defendant Jack was instructed by Defendants to make this false 

statements so Defendants could falsely claim that Plaintiff’s 2022 lawsuit was about 

money. Defendants prepared the statement by Defendant Jack to be presented to the 

press so they could create this false narrative that Plaintiff was just somebody trying 

to “shakedown” or “extort” money from Defendant Jones rather than just a daughter 

seeking parentage. Defendant knowing this was a false narrative about Plaintiff 

agreed to make these statements to the media to assist his long-time friend Defendant 

Jones’ public image by attacking Plaintiff with what he knew were lies about Plaintiff 

71. Defendants’ false statements were defamatory. The statements accuse directly and impute to 

Plaintiff the commission of crimes for which Plaintiff could be punished and imprisoned. Such 

statements are defamation per se/statutory defamation. The statements accuse directly and impute to 

Plaintiff a lack of integrity and an unfitness to perform her duties in the political realm of her career, 

as well as other injurious and disparaging character implications. These statements prejudice Plaintiff 

in her career in politics where reputation is everything.

72. The specific text of the statements communicated by Defendants are explicitly defamatory. 

The statements say she is an “extortionist” and a “shakedown artist,” and that the statements 

communicate that meaning as well. The defamatory statements also imply defamation in both the 

gists of the entire publications and the specific sections of the publications with the defamatory 

statements. 

73. Plaintiff is not a public official or a public figure. However, should this Court construe 

Plaintiff as a limited public figure, the facts demonstrate Defendants acted with actual malice.2

2 Plaintiff in no way concedes in any way that she is a public figure in any capacity by pleading and establishing actual 

malice. She maintains she is a private figure. However, for the purposes of this Amended Complaint, Plaintiff amends 

her pleadings to show facts establishing actual malice in compliance with the Court’s Order. 

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74. Defendants acted with actual malice and reckless disregard for the truth in saying and 

communicating these false, defamatory, factual statements:

a. Defendants Wilkinson, Trailrunner, and Jack abandoned all ethical and professional 

standards in their communications and publications of the defamatory statements at issue.

b. Acting in concert with Defendants Jones, Dallas Cowboys, and Jack, Defendants 

Wilkinson and Trailrunner conceived a storyline in direct contrast to the evidence and 

facts in Defendants’ possession and then deliberately sought to make the evidence 

conform to the preconceived story by false portraying those facts and lying. Defendants 

intentionally created a verifiably false narrative they knew was false (i.e. Plaintiff’s 

lawsuit was part of a concerted effort among Plaintiff and othersto extort and shake down 

the Jones family for money; Plaintiff demanded $20 million in association with the First 

Lawsuit; etc.). Defendants Wilkinson and Trailrunner spoon-fed the defamatory narrative 

to a writer with ESPN, who then regurgitated the preconceived narrative throughout the 

country. Additionally, when other media outlets failed to include the pertinent defamatory 

lies propulgated by Defendant Wilkinson and Trailrunner, Defendants ensured the articles 

were modified by reaching out to the publishers.

c. Defendants Wilkinson and Trailrunner possessed all communications between Davis and 

Jones, as well as copies of the pleadings and other relevant documents. The specific 

evidence possessed by Defendants prior to their defamatory statements establish not only 

that the statements issued by Defendants were false, but also that Defendants knew the 

statements were false. Defendants had a copy of the Petition from the First Lawsuit 

specifically stating the relief requested by Plaintiff. That relief was not a request or 

demand for money at all, and especially not a demand for $20 million dollars. Defendants 

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consciously and intentionally ignored this known and available evidence and proceeded 

to defame Plaintiff with the preconceived narrative that she was an extortionist. 

d. Defendants intentionally created a verifiably false narrative with ESPN that Plaintiff’s 

lawsuit was part of a concerted effort among Plaintiff and others to extort and shake down 

the Jones family for money. To accomplish this goal Defendants falsely stated that 

Plaintiff had demanded $20 Million dollars related to her lawsuit. Additionally, 

Defendants knew that Plaintiff was not working in concert or in any way with any other 

people in seeking parentage from Defendant Jones. 

e. Defendants provided the Preservation Letter, the Plea to Jurisdiction, and the Affidavit of 

Donald Jack to the media, all of which contained knowingly false statements that Plaintiff 

was an extortionist, seeking money from the Jones family, and working in concert with 

others to extort money from the Jones Family. Defendants then furthered this false 

narrative by making knowingly false statements to ESPN to paint Plaintiff in a false light 

in the media as a shake down artist and extortionist. When Defendants made these 

statements to ESPN and created this knowingly false defamatory image of Plaintiff, 

Defendants knew that Plaintiff was not seeking money from the Jones family or acting in 

concert with any others to shake down the Jones family. 

f. Not once did Defendant Jones or any of his agents ever deny that Plaintiff was Defendant 

Jones’ daughter. Instead, Defendant Jones chose the avenue of calling his own daughter 

an “extortionist” merely to make his own public image less despicable by attempting to 

discredit Plaintiff’s reputation and character in the public eye. These statements and 

documents were all provided to ESPN in an attempt to better Defendant Jones’ PR image 

in the media at the expense of his own daughter. 

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g. At all times, Defendants knew that the statements in the documents and the statements 

made by the Defendants in speaking to the media were false. Despite this knowledge, 

Defendants provided these documents to ESPN, made statements for the ESPN articles

and actively intended to defame Plaintiff in the public. Defendants knew that the claimed 

Letter that Plaintiff had allegedly read to Defendant Jack years earlier had absolutely 

nothing to do with the First Lawsuit or Parentage Action. Yet Defendants falsely stated 

that the Letter showed money had always been the motivation behind the First Lawsuit 

and that a $20 Million shakedown attempt had been made in relation to the First Lawsuit. 

Defendants knew these statements were false, and Defendants knew there had not been 

any $20 Million shake down attempt in relationship to Plaintiff seeking Parentage in 2022. 

h. Surprisingly, Defendants worked with ESPN to the extent of even coordinating that the 

story portray Plaintiff has an extortionist and shake down artist demanding $20 Million 

dollars in association with her 2022 lawsuit. Defendants knew that it was false that 

Plaintiff had never demanded any money much less $20 Million dollars in relationship to 

her lawsuit. Yet with the knowledge that it was false that Plaintiff had demanded money 

in relation to her Lawsuit set forth to provide ESPN the Plea to Jurisdiction, the 

Preservation Letter, the Jack Affidavit regarding a 2017 dinner with Plaintiff, and quotes 

that Plaintiff was currently shaking down the Jones’ family all to create a false impression 

of Plaintiff’s 2022 lawsuit that they knew had nothing to do with the 2017 writing to 

Defendant Jack wherein Plaintiff sought Defendant Jack’s advice on how to address her 

relationship with her Father, Defendant Jones. 

i. Upon information and belief, Defendants discussed among themselves that they knew that 

the statements they were making to ESPN were false and that Defendants were creating a 

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false narrative with the March 31, 2022 article and decided to make the statements to 

ESPN despite knowing they were false. 

j. Defendants had a contentious relationship with Plaintiff, even before she officially filed 

the First Lawsuit. All Defendants had a strong motive to lie about Davis as well as a 

motive to fabricate a narrative to negatively portray and defame her. 

k. The author of the ESPN article (Van Natta) and Defendant Wilkinson worked closely 

together to ensure Defendant Wilkinson’s promoted false narrative was portrayed. 

l. The veracity of the statements was not Defendants Wilkinson or Trailrunner’s concern. 

Rather, the story line Defendants conceived in advance to discredit Plaintiff to the media 

was the only motivation Defendants considered. 

m. Defendant Wilkinson even anticipated litigation after making his defamatory statements, 

telling a coworker to pay his legal fees instead of giving him his autograph. Defendant 

Wilkinson would have no need to fear litigation if his statements were a true and accurate 

portrayal of the facts. Instead, he feared litigation because he knew the statements he made 

were false or, at a minimum, he entertained serious doubts as to the truth of what he was 

saying. 

n. Defendant Wilkinson and the other Defendants had copies of all pleadings. They had 

copies of all communications between Davis and Defendant Jones (as evidenced by 

Defendants leaking those documents to the press). Nowhere in those communications or 

court documents does it state Plaintiff was seeking any money at all, much less $20 

million. Defendants ignored all of the actual facts to portray to the press that Plaintiff was 

a “shakedown artist” and an “extortionist.” Again, at a minimum, Defendant Wilkinson 

and the other Defendants had enough facts such that they would entertain serious doubts 

as to the truth of their statements. 

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o. Defendants started by using a court pleading to falsely plant this image of Plaintiff as an 

“extortionist” who was conspiring with others in multiple extortion attempts. Then, 

Defendants provided this defamatory and frivolous pleading to the press. Next Defendants 

adopted this defamatory pleading in a national press interview. Defendants knowingly and 

falsely stated that Plaintiff’s motive for the lawsuit in 2022 was money and referred to 

Plaintiff as being part of a “shake down” and conspiring with other alleged bad and illegal 

actors.

p. As shown above, Defendants, in making the false and defamatory statements acted not 

only negligently but also acted with malice, i.e Defendants acted with the knowledge that 

their statements were false at the time and knowingly made all the false statements about 

Plaintiff despite knowing such statements were false or, at a minimum, acted with reckless 

disregard for whether the statements were true or false.

75. As a direct result of Defendants’ defamatory statements, Plaintiff’s reputation was injured and 

she was exposed to public hatred, contempt, and ridicule. The statements also exposed Plaintiff to 

financial injury by impeaching Plaintiff’s honesty, integrity, virtue, and reputation. 

B. Count Two-Common Law Defamation 

76. Plaintiff incorporates the above paragraphs setting forth the factual basis for Plaintiff’s causes 

of action and hereby incorporates such as if fully set forth herein.

77. Defendants made and published numerous false factual statements to third parties, including 

but not limited to mainstream and print media. 

78. In addition, as described in more detail above, Defendants made the following false verifiable 

statement of fact, including but not limited to:

a. Defendant Jones in Defendant’s Plea To The Jurisdiction And Subject Thereto Original 

Answer falsely and maliciously stated “[Plaintiff] delivered a draft of her lawsuit to 

Defendant and, to borrow her phrase, asked whether he would like to ‘make a deal’ to

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‘assure that he would not be publicly or privately identified and/or declared as 

Plaintiff’s father.’ When Defendant declined to pay, this lawsuit followed;”

b. Defendant Jones in Defendant’s Plea To The Jurisdiction And Subject Thereto Original 

Answer also falsely and maliciously accused Plaintiff of being in some sort of 

conspiracy with other “extortionist” attempting to extort money from Defendant Dallas 

Cowboys and Defendant Jones;

c. On March 10, 2022, Defendant Jones wrote a “Preservation Letter” to Shy Anderson’s 

divorce attorney wherein Defendant Jones accused Mr. Anderson of working with 

“others” to extort money from the Jones family. He identified Plaintiff as one of such 

persons;

d. On March 30, 2022, in an interview with ESPN, Defendant Wilkinson, as spokesperson 

for Defendant Jones and Defendant Dallas Cowboys, stated: “This whole saga and 

series of recent attacks amounts to nothing more than an amateurish coordination 

among various parties to try to shake down the Jones family for money;”

e. On March 31, 2022, Defendant Wilkinson, acting as spokesperson for Defendant Jones 

and Defendant Dallas Cowboys, was quoted in an ESPN article as reaffirming the 

allegation that Plaintiff was an “extortionist:” Defendant Wilkinson falsely stated that 

the “dinner meeting with Jack supports the allegation” that Plaintiff is an “extortionist;”

f. On March 31, 2022, in an interview with ESPN, Defendant Wilkinson and Defendant 

Jack, on behalf of Defendant Jones and Defendant Dallas Cowboys, accused Plaintiff 

of being an “extortionist” and portrayed Plaintiff as attempting to “shakedown” 

Defendant Jones. Defendant Jack provided an affidavit to ESPN claiming that Plaintiff 

had demanded money from Defendant Jones, three to four years earlier, and that this 

meant Plaintiff’s recent lawsuit was an extortion attempt;

g. In this same published article with ESPN on March 31, 2022, Defendant Wilkinson 

also used this years earlier plea for attention by Plaintiff as support for the pleading,

which accused Plaintiff of being an “extortionist;”

h. In the March 31, 2022 ESPN article, Wilkinson further stated that the statement by Jack 

regarding the plea made by Plaintiff years earlier “clearly demonstrates that money has 

always been the ultimate goal here. And sadly, this is just one part of a more broad 

calculated and concerted effort that has been going on for some time by multiple people 

with various different agendas;”

i. In the March 31, 2022 ESPN article, Defendant Wilkinson also falsely stated that 

Plaintiff’s counsel had previously met with Defendant Jones’ counsel and had 

demanded money;

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j. In the March 31, 2022 ESPN article, Defendant Wilkinson also falsely stated “[t]here 

was never a discussion about a nonmonetary resolution. Money was always part of the 

deal;”

k. In the March 31, 2022 ESPN article, Defendant Wilkinson’s further falsely stated 

“[n]ow they've changed their story yet again. First it wasn't about money. Now it is 

about money. And now they are on three sides of a two-sided issue. They are all over 

the map here. Pick a story and stick with it. This is clownish;” and,

l. In the March 31, 2022 ESPN article, Defendant Jack falsely stated that Plaintiff’s 

motives in the lawsuit against Defendant Jones was money. Defendant Jack falsely 

stated that he got “a far different impression of Davis’ motives.” Defendant Jack based 

this statement about Plaintiff’s “motives” upon the therapeutic letter written by Plaintiff 

years earlier at her therapist’s recommendation to align Plaintiff as an “extortionist.”

m. Defendants Wilkinson and Trailrunner reached out to numerous publishers to repeat their 

defamatory statements about Plaintiff being an extortionist. This outreach ensured any 

articles published about the issues included the defamatory information about Plaintiff in 

the article. Specifically, Defendants Wilkinson and Trailrunner wanted it known and 

placed in every article that Plaintiff was seeking $20 million in the context of the 

declaratory judgment action and parentage action. Multiple publications updated and 

republished this defamatory information after Defendants reached out to request the 

addition of the defamatory information.

79. The above statements were published by Defendants without privilege or authorization.

80. Additionally, as described in more detail below, Defendants made the following false 

verifiable statement of fact with knowledge that the statements were false or with reckless disregard 

for their truth when communicating them: 

a. On March 31, 2022, Defendant Wilkinson, acting as spokesperson for Defendant 

Jones and Defendant Dallas Cowboys, was quoted in an ESPN article as reaffirming 

the allegation that Plaintiff was an “extortionist:” Defendants knew that Plaintiff was 

not an extortionist and had not attempted to extort any money or anything of value in 

exchange for her 2022 lawsuit. Defendant Wilkinson falsely stated that the “dinner 

meeting with Jack supports the allegation” that Plaintiff is an “extortionist.” Defendant 

Wilkinson knew that this “dinner meeting” that Plaintiff had with Defendant Jack had 

been years earlier and was not in any way related to the 2022 lawsuit. Defendants were 

not even aware of the “dinner meeting” with Defendant Jack when Plaintiff filed her 

2022 lawsuit. Defendants did not discover about the dinner meeting until after the 

lawsuit was filed and then knowing that the “dinner meeting” had nothing to do with 

the 2022 lawsuit knowingly falsely stated that the “dinner meeting” was a demand 

related to the 2022 Lawsuit. 

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b. On March 31, 2022, in an interview with ESPN, Defendant Wilkinson and Defendant 

Jack, on behalf of Defendant Jones and Defendant Dallas Cowboys, accused Plaintiff 

of being an “extortionist” and portrayed Plaintiff as attempting to “shakedown” 

Defendant Jones. Defendant Jack provided an affidavit to ESPN claiming that Plaintiff 

had demanded money from Defendant Jones, three to four years earlier, and that this 

meant Plaintiff’s recent lawsuit was an extortion attempt or a “shakedown” of 

Defendant Jones. Defendants knew that Plaintiff was not an extortionist and had not 

attempted to extort any money or anything of value in exchange or “shakedown” 

Defendant Jones relating to her 2022 lawsuit. Defendant Wilkinson knew that this 

“dinner meeting” that Plaintiff had with Defendant Jack had been years earlier and 

was not in any way related to the 2022 lawsuit. Defendants were not even aware of 

the “dinner meeting” with Defendant Jack when Plaintiff filed her 2022 lawsuit. 

Defendants did not discover about the dinner meeting until after the lawsuit was filed 

and then knowing that the “dinner meeting” had nothing to do with the 2022 lawsuit 

knowingly falsely stated that the “dinner meeting” was a “shakedown” related to the 

2022 Lawsuit.

c. In this same published article with ESPN on March 31, 2022, Defendant Wilkinson 

also used this years earlier plea for attention by Plaintiff as support for the pleading, 

which accused Plaintiff of being an “extortionist.” Defendants knew that Plaintiff was 

not an extortionist and had not attempted to extort any money or anything of value in 

exchange for her 2022 lawsuit. Defendant Wilkinson falsely stated that the “dinner 

meeting with Jack supports the allegation” that Plaintiff is an “extortionist.” Defendant 

Wilkinson knew that this “dinner meeting that Plaintiff had with Defendant Jack had 

been years earlier and was not in any way related to the 2022 lawsuit. Defendants were 

not even aware of the “dinner meeting” with Defendant Jack when Plaintiff filed her 

2022 lawsuit. Defendants did not discover about the dinner meeting until after the 

lawsuit was filed and then knowing that the “dinner meeting” had nothing to do with 

the 2022 lawsuit knowingly falsely stated that the “dinner meeting” was a demand 

related to the 2022 Lawsuit.

d. In the March 31, 2022 ESPN article, Wilkinson further stated that the statement by 

Jack regarding the plea made by Plaintiff years earlier “clearly demonstrates that 

money has always been the ultimate goal here. And sadly, this is just one part of a 

more broad calculated and concerted effort that has been going on for some time by 

multiple people with various different agendas. Defendants knew that Plaintiff was 

not an extortionist and had not attempted to extort any money or anything of value in 

exchange for her 2022 lawsuit. Defendant Wilkinson knew that this “dinner meeting 

that Plaintiff had with Defendant Jack had been years earlier and was not in any way 

related to the 2022 lawsuit. Defendants were not even aware of the “dinner meeting” 

with Defendant Jack when Plaintiff filed her 2022 lawsuit. Defendants did not 

discover about the dinner meeting until after the lawsuit was filed and then knowing 

that the “dinner meeting” had nothing to do with the 2022 lawsuit knowingly falsely 

stated that the “dinner meeting” was a demand related to the 2022 Lawsuit. Defendants 

knew that Plaintiff’s goal was not money in the 2022. Defendants were told by 

Plaintiff that Plaintiff was not seeking money but only a declaration of parentage from 

Defendant Jones. Defendants had been told by Plaintiff that in regard to her 2022 

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lawsuit that Plaintiff only sought a Declaration of Parentage from Defendant Jones 

and money was not even an issue. Despite being told this, Defendants dug up a “dinner 

meeting” with Defendant Jack where Plaintiff has sought paternal advice from 

Defendant Jack and mentioned that Defendant Jones’ son had paid $20 Million dollars 

to his illegitimate son and turned this into a demand for $20 Million dollars on 

Defendant Jones in connection with Plaintiff seeking parentage in 2022. Defendants 

further used this “dinner meeting” from years earlier to portray Plaintiff as part of a 

concerted effort in 2022 with “others” to get money from Defendant Jones. Defendants 

knew that Plaintiff was not working in concert with any “others.” Before the 

Defendants falsely stated that Plaintiff was working in concert with “others,” 

Defendants had been told by Plaintiff that she was not working in concert with any 

“others.” 

e. In the March 31, 2022 ESPN article, Defendant Wilkinson also falsely stated that 

Plaintiff’s counsel had previously met with Defendant Jones’ counsel and had 

demanded money. Defendants were aware that when they made this statement to 

ESPN that no demand for money had been made by Plaintiff’s counsel. Prior to 

Defendants making this statement, Plaintiff’s counsel had specifically informed 

Defendants that money was not even part of the discussion. The only matters discussed 

between Plaintiff’s counsel and Defendant Jones’ counsel for the Parentage Action 

was that Defendant Jones enter into a Declaration of Parentage. Defendant Wilkinson 

had been informed when he made the statement that money had never been demanded 

from Plaintiff’s counsel which is why Defendants had to dig up the years earlier 

“dinner meeting” with Defendant Jack and state that the “dinner meeting” with 

Defendant Jack was a $20 Million dollar demand related to the 2022 lawsuit. 

Defendants knew this was false and there had never been a demand for money made 

by Plaintiff’s counsel.

f. In the March 31, 2022 ESPN article, Defendant Wilkinson also falsely stated “[t]here 

was never a discussion about a nonmonetary resolution. Money was always part of the 

deal.” Defendants were aware that when they made this statement to ESPN that no 

demand for money had been made by Plaintiff’s counsel. Prior to Defendants making 

this statement, Plaintiff’s counsel had specifically informed Defendants that money 

was not even part of the discussion. The only matters discussed between Plaintiff’s 

counsel and Defendant Jones’ counsel for the Parentage Action was that Defendant 

Jones enter into a Declaration of Parentage. Defendant Wilkinson had been informed 

when he made the statement that money had never been demanded from Plaintiff’s 

counsel which is why Defendants had to dig up the years earlier “dinner meeting” with 

Defendant Jack and state that the “dinner meeting” with Defendant Jack was a $20 

Million dollar demand related to the 2022 lawsuit. Defendants knew this was false and 

that the only discussions related to the 2022 lawsuit was the nonmonetary resolution 

of Defendant Jones entering into a Declaration of Parentage.

g. In the March 31, 2022 ESPN article, Defendant Wilkinson’s further falsely stated 

“[n]ow they've changed their story yet again. First it wasn't about money. Now it is 

about money. And now they are on three sides of a two-sided issue. They are all over 

the map here. Pick a story and stick with it. This is clownish.” Defendants knew when 

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they made this statement that the 2022 lawsuit had never been about money. 

Defendants knew that the story had not changed. Defendants knew the “story” was 

still not about money. In fact, nothing had changed. Defendants just falsely made this 

statement to make people think something with Plaintiff’s 2022 lawsuit had changed. 

Defendant uses the “dinner meeting” with Defendant Jack that occurred years earlier 

to falsely convey the impression to the public that Plaintiff’s current action of seeking 

parentage was related that “dinner meeting.” Defendants knew when making this 

statement that the 2022 lawsuit had no connection to the many years earlier “dinner 

meeting” with Defendant Jack. Defendants knew when they made this statement that 

Plaintiff had not demanded money or $20 Million dollars from Defendant Jones years 

earlier. Defendants knew when they made this statement that the “dinner meeting” had 

absolutely nothing to do with the 2022 lawsuit. and,

h. In the March 31, 2022 ESPN article, Defendant Jack falsely stated that Plaintiff’s 

motives in the lawsuit against Defendant Jones was money. Defendant Jack falsely 

stated that he got “a far different impression of Davis’ motives.” Defendant Jack 

based this statement about Plaintiff’s “motives” upon the therapeutic letter written by 

Plaintiff years earlier at her therapist’s recommendation to align Plaintiff as an 

“extortionist.” When Defendant Jack made these false statements, Defendant Jack 

knew that the years earlier “dinner meeting” had nothing to do with the 2022 lawsuit 

and that Plaintiff’s motive in her 2022 lawsuit was not money. Defendant Jack when 

making these statements knew that Plaintiff’s motives at the time were to merely seek 

parentage and not money of any sort. Defendant Jack had been told that 2022 lawsuit 

was not about money but Plaintiff seeking her parentage from her father. Yet despite 

this knowledge, Defendant Jack still falsely stated that Plaintiff’s motive in her 2022 

lawsuit was money. Defendant Jack was instructed by Defendants to make this false 

statements so Defendants could falsely claim that Plaintiff’s 2022 lawsuit was about 

money. Defendants prepared the statement by Defendant Jack to be presented to the 

press so they could create this false narrative that Plaintiff was just somebody trying 

to “shakedown” or “extort” money from Defendant Jones rather than just a daughter 

seeking parentage. Defendant knowing this was a false narrative about Plaintiff 

agreed to make these statements to the media to assist his long-time friend Defendant 

Jones’ public image by attacking Plaintiff with what he knew were lies about Plaintiff 

81. Defendants’ false statements were defamatory. The statements accuse directly and impute to 

Plaintiff the commission of crimes for which Plaintiff could be punished and imprisoned. Such 

statements are defamation per se. The statements accuse directly and impute to Plaintiff a lack of 

integrity and an unfitness to perform her duties in the political realm of her career, as well as other 

injurious and disparaging character implications. These statements prejudice Plaintiff in her career in 

politics where reputation is everything.

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82. The specific text of the statements communicated by Defendants are explicitly defamatory. 

The statements say she is an “extortionist” and a “shakedown artist,” and that the statements 

communicate that meaning as well. The defamatory statements also imply defamation in both the 

gists of the entire publications and the specific sections of the publications with the defamatory 

statements. 

83. Plaintiff is not a public official or a public figure. However, should this Court construe 

Plaintiff as a limited public figure, the facts demonstrate Defendants acted with actual malice.3

84. Defendants acted with actual malice and reckless disregard for the truth in saying and 

communicating these false, defamatory, factual statements:

a. Defendants Wilkinson, Trailrunner, and Jack abandoned all ethical and professional 

standards in their communications and publications of the defamatory statements at issue.

b. Acting in concert with Defendants Jones, Dallas Cowboys, and Jack, Defendants 

Wilkinson and Trailrunner conceived a storyline in direct contrast to the evidence and 

facts in Defendants’ possession and then deliberately sought to make the evidence 

conform to the preconceived story by false portraying those facts and lying. Defendants 

intentionally created a verifiably false narrative they knew was false (i.e. Plaintiff’s 

lawsuit was part of a concerted effort among Plaintiff and other to extort and shake down 

the Jones family for money; Plaintiff demanded $20 million in association with the First 

Lawsuit; etc.). Defendants Wilkinson and Trailrunner spoon-fed the defamatory narrative 

to a writer with ESPN, who then regurgitated the preconceived narrative throughout the 

country. Additionally, when other media outlets failed to include the pertinent defamatory 

3 Plaintiff in no way concedes in any way that she is a public figure in any capacity by pleading and establishing actual 

malice. She maintains she is a private figure. However, for the purposes of this Amended Complaint, Plaintiff amends 

her pleadings to show facts establishing actual malice in compliance with the Court’s Order. 

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lies propulgated by Defendant Wilkinson and Trailrunner, Defendants ensured the articles 

were modified by reaching out to the publishers.

c. Defendants Wilkinson and Trailrunner possessed all communications between Davis and 

Jones, as well as copies of the pleadings and other relevant documents. The specific 

evidence possessed by Defendants prior to their defamatory statements establish not only 

that the statements issued by Defendants were false, but also that Defendants knew the 

statements were false. Defendants had a copy of the Petition from the First Lawsuit 

specifically stating the relief requested by Plaintiff. That relief was not a request or 

demand for money at all, and especially not a demand for $20 million dollars. Defendants 

consciously and intentionally ignored this known and available evidence and proceeded 

to defame Plaintiff with the preconceived narrative that she was an extortionist. 

d. Defendants intentionally created a verifiably false narrative that Defendants knew was 

false with ESPN that Plaintiff’s lawsuit was part of a concerted effort among Plaintiff and 

others to extort and shake down the Jones family for money. To accomplish this goal 

Defendants falsely stated that Plaintiff had demanded $20 Million dollars related to her 

lawsuit when Defendants knew this was false. Additionally, Defendants knew that 

Plaintiff was not working in concert or in any way with any other people in seeking 

parentage from Defendant Jones. 

e. Defendants provided the Preservation Letter, the Plea to Jurisdiction, and the Affidavit of 

Donald Jack to the media, all of which made the knowingly false statements that Plaintiff 

was an extortionist, seeking money from the Jones family, and working in concert with 

others to extort money from the Jones Family. Defendants then furthered this false 

narrative by making knowingly false statements to ESPN to paint Plaintiff in a false light 

in the media as a shake down artist and extortionist. When Defendants made these 

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statements to ESPN and created this knowingly false defamatory image of Plaintiff, 

Defendants knew that Plaintiff was not seeking money from the Jones family or acting in 

concert with any others to shake down the Jones family. 

f. Not once did Defendant Jones or any of his agents ever deny that Plaintiff was Defendant 

Jones’ daughter. Instead, Defendant Jones chose the avenue of calling his own daughter 

an “extortionist” merely to make his own public image less despicable by attempting to 

discredit Plaintiff’s reputation and character in the public eye. These statements and 

documents were all provided to ESPN in an attempt to better Defendant Jones’ PR image 

in the media at the expense of his own daughter. 

g. At all times, Defendants knew that the statements in the documents and the statements 

made by the Defendants in speaking to the media were false. Despite this knowledge, 

Defendants provided these documents to ESPN, made statements for the ESPN articles

and actively intended to defame Plaintiff in the public. Defendants knew that the claimed 

Letter that Plaintiff had allegedly read to Defendant Jack years earlier had absolutely 

nothing to do with the First Lawsuit or Parentage Action. Yet Defendants falsely stated 

that the Letter showed money had always been the motivation behind the First Lawsuit 

and that a $20 Million shakedown attempt had been made in relation to the First Lawsuit. 

Defendants knew these statements were false, and Defendants knew there had not been 

any $20 Million shake down attempt in relationship to Plaintiff seeking Parentage in 2022. 

h. Surprisingly, Defendants worked with ESPN to the extent of even coordinating that the 

story portray Plaintiff has an extortionist and shake down artist demanding $20 Million 

dollars in association with her 2022 lawsuit. Defendants knew that it was false that 

Plaintiff had never demanded any money much less $20 Million dollars in relationship to 

her lawsuit. Yet with the knowledge that it was false that Plaintiff had demanded money 

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in relation to her Lawsuit set forth to provide ESPN the Plea to Jurisdiction, the 

Preservation Letter, the Jack Affidavit regarding a 2017 dinner with Plaintiff, and quotes 

that Plaintiff was currently shaking down the Jones’ family all to create a false impression 

of Plaintiff’s 2022 lawsuit that they knew had nothing to do with the 2017 writing to 

Defendant Jack wherein Plaintiff sought Defendant Jack’s advice on how to address her 

relationship with her Father, Defendant Jones. 

i. Upon information and belief, Defendants discussed among themselves that they knew that 

the statements they were making to ESPN were false and that Defendants were creating a 

false narrative with the March 31, 2022, article and decided to make the statements to 

ESPN despite knowing they were false. 

j. Defendants had a contentious relationship with Plaintiff, even before she officially filed 

the First Lawsuit. All Defendants had a strong motive to lie about Davis as well as a 

motive to fabricate a narrative to negatively portray and defame her. 

k. The author of the ESPN article (Van Natta) and Defendant Wilkinson worked closely 

together to ensure Defendant Wilkinson’s promoted false narrative was portrayed. 

l. The veracity of the statements was not Defendants Wilkinson or Trailrunner’s concern. 

Rather, the story line Defendants conceived in advance to discredit Plaintiff to the media 

was the only motivation Defendants considered. 

m. Defendant Wilkinson even anticipated litigation after making his defamatory statements, 

telling a coworker to pay his legal fees instead of giving him his autograph. Defendant 

Wilkinson would have no need to fear litigation if his statements were a true and accurate 

portrayal of the facts. Instead, he feared litigation because he knew the statements he made 

were false or, at a minimum, he entertained serious doubts as to the truth of what he was 

saying. 

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n. Defendant Wilkinson and the other Defendants had copies of all pleadings. They had 

copies of all communications between Davis and Defendant Jones (as evidenced by 

Defendants leaking those documents to the press). Nowhere in those communications or 

court documents does it state Plaintiff was seeking any money at all, much less $20 

million. Defendants ignored all of the actual facts to portray to the press that Plaintiff was 

a “shakedown artist” and an “extortionist.” Again, at a minimum, Defendant Wilkinson 

and the other Defendants had enough facts such that they would entertain serious doubts 

as to the truth of their statements. 

o. Defendants started by using a court pleading to falsely plant this image of Plaintiff as an 

“extortionist” who was conspiring with others in multiple extortion attempts. Then, 

Defendants provided this defamatory and frivolous pleading to the press. Next Defendants 

adopted this defamatory pleading in a national press interview. Defendants knowingly and 

falsely stated that Plaintiff’s motive for the lawsuit in 2022 was money and referred to 

Plaintiff as being part of a “shake down” and conspiring with other alleged bad and illegal 

actors.

p. As shown above, Defendants, in making the false and defamatory statements acted not 

only negligently but also acted with malice, i.e. Defendants acted with the knowledge that 

their statements were false at the time and knowingly made all the false statements about 

Plaintiff despite knowing such statements were false or, at a minimum, acted with reckless 

disregard for whether the statements were true or false.

85. As a direct result of Defendants’ defamatory statements, Plaintiff’s reputation was injured and 

she was exposed to public hatred, contempt, and ridicule. The statements also exposed Plaintiff to 

financial injury by impeaching Plaintiff’s honesty, integrity, virtue, and reputation. 

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DAMAGES

86. Plaintiff incorporates the above paragraphs setting forth the factual basis for Plaintiff’s causes 

of action and hereby incorporates such as if fully set forth herein.

87. As a direct and proximate result of Defendants’ false and defamatory statements published, 

Plaintiff has endured shame, embarrassment, humiliation, and mental pain and anguish. Additionally, 

Plaintiff has and will in the future be seriously injured in her business reputation, good name, and 

standing in the community, and will be exposed to the hatred, contempt, and ridicule of the public in 

general as well as of her business associates, clients, friends, and relatives. Consequently, Plaintiff 

seeks actual and special damages in a sum within the jurisdictional limits of this Court. 

88. Plaintiff is in the occupation of politics. Her career path began in college where she interned 

in Washington D.C. Plaintiff served in the Whitehouse for fourteen months which required a high 

security clearance. Plaintiff currently is a congressional aide. Defendants public attack on Plaintiff as 

an “extortionist” and “shake down artist” has injured her reputation not only in the public arena of 

politics but has damaged her ability to work in the future in her occupation. 

89. By their false statements of fact and character assignation, Defendants have been successful 

in their smear campaign to destroy the reputation of Plaintiff. The first thing any prospective employer 

does today is Google search of a prospective employee. The Google search “Alexandra Davis 

extortionist” results in over 4,000,000 hits alone. The Google search “Alexandra Davis shakedown 

artist” results in over 2,000,000 results. This does not take into account the other search engines, 

numerous print publications of the same nature, nor television broadcasts. Many of the referenced 

articles resulting from these searches display a headline in some form or another referring to Plaintiff 

to be claimed by Defendant Jones as extorting him. 

90. Defendant Jones is probably the most well-known, most powerful team owner in the NFL. 

He certainly is the most public. The Dallas Cowboys franchise is estimated to be perhaps the most 

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valuable sports franchise in the world, and certainly in the NFL. Defendant Jones has been lauded by 

many experts as a marketing genius, and his vast fortune and power attests to that. The Dallas 

Cowboys have a marketing division that is headed by Defendant Jones’ namesake son. 

91. Defendants Jones and Dallas Cowboys publicity profile and associations extend gigantically 

to the corporate world and include corporate and charitable partnerships. Defendant Jones’ influence 

also extends into politics, Plaintiff’s chosen career. Defendant Jones is a huge benefactor and 

contributor to mostly Republican candidates nationally and in Texas. In November 2022, Defendant 

Jones was reported to have made $900,000 in “last minute” donation to the top three Republican 

candidates in Texas alone. The effects of Defendant Jones characterizing Plaintiff as an “extortionist”, 

a “shakedown artist” and someone who is “conspiring” with others who he claims are extorting him 

is permanently and indelibly deleterious to Plaintiff’s reputation in her chosen occupation in the 

political arena. 

92. Plaintiff’s current employer has received defamatory communications referring to Plaintiff 

as an “extortionist.” For example, as recent as December 24, 2022, Plaintiff’s employer received the 

following message on Twitter: “You may want to get rid of your congressional aid Alexandra Davis 

because extortion seems to be her thing.” This is just one example of the obvious damage to Plaintiff’s 

career in the political arena where public opinion dictates your employment. 

PUNITIVE DAMAGES

93. Plaintiff incorporates the above paragraphs setting forth the factual basis for Plaintiff’s causes 

of action and hereby incorporates such as if fully set forth herein.

94. The above-described defamatory statements were published maliciously by the Defendants. 

Defendants specifically intended to injure Plaintiff with their actions. As shown above, Defendants 

either knew the statements about Plaintiff were false, or Defendants recklessly disregarded the truth 

of the statements. At a minimum, Defendants entertained serious doubts about the truth of their 

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PLAINTIFF’S AMENDED COMPLAINT PAGE 39

statements. In fact, the false statements were communicated with such utter recklessness as to indicate 

a conscious indifference to the rights, safety, or welfare of Plaintiff with actual, subjective awareness 

that their conduct involved an extreme degree of risk of harm to Plaintiff. Thus, the award of 

exemplary damages in an amount in excess of the minimal jurisdictional limits of this court is 

justified.

WHEREFORE, upon final trial Plaintiff requests the following relief:

1. Actual damages;

2. Special damages;

2. Punitive damages;

3. Costs of suit; and

4. Any other and further relief, both general and special, at law or in equity, to which 

Plaintiff may be justly entitled.

Respectfully submitted,

BERGMANGRAY LLP

/s/ Jay K. Gray______________

Jay K. Gray

State Bar No. 08324050

Andrew A. Bergman

State Bar No. 02196300

4514 Travis Street

Travis Walk, Suite 300

Dallas, Texas 75205

214-528-2444 

214-599-0602 [fax]

gray@bergmangray.com

bergman@bergmangray.com

ATTORNEYS FOR PLAINTIFF

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PLAINTIFF’S AMENDED COMPLAINT PAGE 40

KEIL LAW FIRM, PLLC

406 Walnut Street

Texarkana, Arkansas 71854

Telephone: (870) 772-4113

Facsimile: (870) 773-2967

BY: /s/ Matt Keil______________

Matt Keil, TX Bar No. 11181750

mkeil@kglawfirm.com

Erin Keil, TX Bar No. 24120462

ekeil@kglawfirm.com

Hailee Amox, TX Bar No. 24085176

hamox@kglawfirm.com

ATTORNEYS FOR PLAINTIFF

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