Jerome Corsi Vs Infowars

Case 1:19-cv-00656 Document 1 Filed 03/07/19 Page 1 of 109
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
DR. JEROME CORSI, Individually

Denville, NJ, 07834
And
LARRY KLAYMAN, Individually Case Number:

7050 W. Palmetto Park Rd. #15-287
Boca Raton, FL, 33433 COMPLAINT
Plaintiffs
v.
INFOWARS, LLC
100 Congress Ave., 22nd Floor
Austin, TX 78701
And
FREE SPEECH SYSTEMS, LLC

100 Congress Ave., 22nd Floor
Austin, TX 78701
And
ALEX E. JONES, Individually

3019 Alvin Devane Blvd., Suite 300-350
Austin, TX 78741
And
DAVID JONES, Individually

Austin, TX 78741
And
OWEN SHROYER, Individually

Austin, TX 78741
Defendants.
1
INTRODUCTION
Plaintiffs DR. JEROME CORSI (“Plaintiff Corsi or Dr. Corsi”) and LARRY
KLAYMAN (“Klayman”) hereby files this action against INFOWARS, LLC (“Defendant
InfoWars”), FREE SPEECH SYSTEMS, LLC (“Defendant Free Speech Systems”), ALEX E.
JONES (“Defendant Alex Jones”), DAVID JONES (“Defendant David Jones”) and OWEN
SHROYER (“Defendant Shroyer”) for Defamation, Intentional Infliction of Emotional Distress,
and Assault, and violation of the Lanham Act.
JURISDICTION AND VENUE
1.! This Court has diversity jurisdiction over this case pursuant to 28 U.S.C. § 1332,
as the parties are completely diverse in citizenship and the amount in controversy exceeds
$75,000.
2.! This Court has federal question jurisdiction over this case pursuant to 28 U.S.C §
1331.
3.! Venue is proper pursuant to 28 U.S.C. § 1391(b)(2), (3) in that a substantial part
of the events or omissions giving rise to Plaintiffs’ claims arose in this district. Defendants’
actions are targeted to influence Special Counsel Robert Mueller’s Russian collusion
investigation and prosecution of Roger Stone - who is a colleague of the Defendants - which is
centralized in this judicial district, and the defamatory and other illegal acts occurred herein.
THE PARTIES
4.! Plaintiff Corsi is an author and political commentator who publishes works in this
judicial district and nationwide. Plaintiff Corsi is a citizen of New Jersey.
5.! Plaintiff Klayman is a public interest legal advocate, private practitioner and
litigator who represents Plaintiff Corsi with regard to Special Counsel Robert Mueller’s
2
(“Mueller”) Russian collusion investigation. Plaintiff Klayman is also a media personality and
author, columnist and syndicated radio talk show host. Plaintiff Klayman is a citizen of Florida.
6.! Defendant InfoWars is a Texas limited liability company with principal offices
located in Austin, TX.
7.! Defendant Free Speech Systems is a Texas limited liability company with principal
offices located in Austin, TX.
8.! Defendant Alex Jones is a well-known extreme “conspiracy theorist” and media
personality who creates content that is broadcasted on the radio and posted on the internet at
www.infowars.com and elsewhere on the internet and other social media sites. Defendant Alex
Jones is a citizen of Texas.
9.! Defendant David Jones is Defendant Alex Jones’s father and holds the official title
of Director of Human Relations for Defendant Free Speech Systems. On information and belief,
Defendant David Jones is the owner of Defendants InfoWars and Free Speech Systems and he
manages the business activities for Defendants InfoWars and Free Speech Systems, as well as
Defendant Alex Jones’ other companies. Defendant David Jones is a citizen of Texas. At all
material times he worked in concert with the other Defendants and Roger Stone and furthered and
ratified and furthered the illegal acts set forth in this Complaint.
10.! Defendant Shroyer is a newscaster for Defendant InfoWars. Defendant Shroyer is a
citizen of Texas.
GENERAL ALLEGATIONS
11.! Defendant InfoWars and Defendant Free Speech Systems are both owned,
controlled, and operated by Defendant Alex Jones and David Jones. Defendant Free Speech
Systems owns www.infowars.com, where content created by Defendants Alex Jones and Shroyer
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are posted and broadcast into this district, nationally and internationally.
12.! Defendant Alex Jones hosts The Alex Jones Show, which is broadcast on radio
and internet social media networks throughout the United States of America and internationally,
including this judicial district, and online.
13.! Defendant Shroyer hosts The War Room along with Roger Stone (“Stone”), which
is broadcast on radio and internet social media networks throughout the United States of America
and internationally, including this judicial district, and online.
14.! Defendants’ reach and influence are enormous. On information and belief,
Defendant Alex Jones and InfoWars has a radio audience of over two million people. Before it
was banned from YouTube, Defendant Alex Jones’ and InfoWars’ channel had more than 2.4
million subscribers.1
15.! Defendants, each and every one of them, in concert, do substantial business and
promote and sell various goods in this judicial district and nation-wide, including medicine,
supplements, and “tchotchkes” with InfoWars branding. The money earned from these sales
funds the conspiracy between Defendants and Stone to defame, intimidate, coerce and threaten
Plaintiffs in order to try to improperly influence the Mueller Russian collusion investigation and
to coerce false testimony from Plaintiff Corsi favorable to Stone in his upcoming criminal
prosecution.
16.! Stone also does business promotes and sells various goods in this judicial district
and nation-wide, including medicine, supplements, books, and “tchotchkes” with his own
branding. The money earned from these sales funds Stone’s legal defense fund and the
1
Casey Newton, YouTube deletes Alex Jones’ channel for violating its community guidelines,
The Verge, Aug. 6, 2018, available at: https://www.theverge.com/2018/8/6/17656708/youtube-
alex-jones-infowars-account-deleted-facebook-apple-spotify
4
conspiracy between Defendants and Stone to defame, intimidate, coerce and threaten Plaintiffs in
order to try to improperly influence the Mueller Russian collusion investigation and to coerce
false testimony from Plaintiff Corsi favorable to Stone in his upcoming criminal prosecution.
17.! Defendants have a long and sordid history of publishing and broadcasting
defamatory material, including falsely, recklessly and baselessly accusing the families of the
schoolchildren who lost their lives during the 2012 Sandy Hook Elementary School massacre of
staging the massacre and faking the deaths of their children.2
18.! The Sandy Hook families had to endure years of abuse and torture from
Defendants before finally filing suit against numerous parties involved with InfoWars, including
Defendant Alex Jones and Shroyer, for defamation.
19.! As just one example, a Florida woman was arrested for making death threats to a
parent of a Sandy Hook victim.3 According to the U.S. Department of Justice, the motivation
behind the threats was the lies propagated by Defendants that the Sandy Hook massacre was a
hoax.4
20.! Furthermore, Defendant Alex Jones in concert with the other Defendants
propagated and promoted the “Pizzagate” conspiracy on his show, accusing a restaurant called
Comet Ping Pong in the Washington D.C. area of operating a child sex ring in its non-existent
basement that purportedly involved Hillary Clinton and John Podesta. This caused one of his
listeners to shoot up the restaurant after being told by Defendant Jones to “self-investigate” the
2
Aaron Katersky, Families of Sandy Hook shooting victims win legal victory in lawsuit against
InfoWars, Alex Jones, ABC News, Jan. 11, 2019, available at:
https://abcnews.go.com/US/families-sandy-hook-shooting-victims-win-legal-
victory/story?id=60314174
3
Daniella Silva, Conspiracy Theorist Arrested for Death Threats Against Sandy Hook Parent,
NBC News, Dec. 7, 2016, available at: https://www.nbcnews.com/news/us-news/conspiracy-
theorist-arrested-death-threats-against-sandy-hook-parent-n693396
4
Id.
5
“Pizzagate” conspiracy theory.5
21.! Defendants, acting in concert, propagated these outrageous lies with no regard for
the grief of their victims in order to gain notoriety, fame, and profit.
22.! Defendants, acting in concert, as part of their latest scheme for notoriety, fame,
and profit, are now working in concert with Stone to defame, intimidate, and threaten Plaintiffs.
23.! Stone, who recently been indicted on seven counts of perjury, witness tampering
and obstruction of justice by Special Counsel Robert Mueller and then placed under a total gag
order by the jurist, the Honorable Amy Berman Jackson, presiding over his prosecution for, in
part, even threatening her, has appeared numerous times on shows broadcasted by Defendant
InfoWars, and hosted by Defendants Alex Jones and Shroyer, where Stone and Defendants have
published malicious false, misleading, and defamatory statements concerning Plaintiffs.
24.! Again, Stone was recently indicted by Special Counsel Robert Mueller (“Mueller
Indictment”) as part of his “Russian Collusion” investigation for the alleged crimes of perjury,
witness tampering and obstruction of justice. The indictment comprises seven different felony
counts. See Exhibit 1 – Mueller Indictment. Importantly, Dr. Corsi was not accused of any
wrongdoing or illegality in the Mueller Indictment, in which he named as Person 1, a material
witness to the alleged crimes committed by Stone. (Note: The facts set forth in all Exhibits
attached to and referenced in this Complaint are factually incorporated into this Complaint by
reference).
25.! Specifically, the seven count Mueller Indictment against Stone involves alleged
lying under oath - that is, perjury - witness tampering and obstruction of justice by threatening to
5
James Doubek, Conspiracy Theorist Alex Jones Apologizes For Promoting 'Pizzagate', NPR,
Mar. 26, 2017, available at: https://www.npr.org/sections/thetwo-
way/2017/03/26/521545788/conspiracy-theorist-alex-jones-apologizes-for-promoting-pizzagate
6
kill a material witness, Randy Credico (“Credico”) and his service dog, if Credico did not lie to
government authorities concerning his involvement with Roger Stone. Credico is Person 2 in the
Mueller Indictment of Stone. Id. Person 1 in this Mueller Indictment is Dr. Corsi.
26.! Even before Stone was indicted, he began a public relations campaign in this
district, nationally and internationally to maliciously defame, smear, intimidate and threaten Dr.
Corsi and Plaintiff Klayman, Plaintiff Corsi’s lawyer and defense counsel.
27.! As just one example, in an article from The New Yorker, Stone was quoted as
saying about Plaintiff Corsi, “He’s certifiably insane, and he has told multiple provable lies.”6
This malicious defamatory statement, among others, was published in concert with Defendants.
28.! Stone knew that he was going to be indicted, and therefore began this public
relations campaign to maliciously defame smear, intimidate and threaten Plaintiff. Corsi and
Plaintiff Klayman, even before his actual indictment on January 25, 2019, in order to try to
influence public opinion and Special Counsel Robert Mueller – by trying to attribute guilt to
Plaintiff Corsi and not him - as well as to try to raise money for his legal defense. This
defamatory public relations campaign is and continues to be calculated to coerce Plaintiff Corsi
to testify falsely at Stone’s upcoming criminal trial before Judge Jackson. This pattern and
practice of defaming, intimidating and threatening Plaintiff Corsi and Plaintiff Klayman is
pervasive and ongoing, and therefore Plaintiffs reserve the right to amend this Complaint.
Defendants, as alleged herein, are acting in concert with Stone to engage in criminal witness
tampering and obstruction of justice not just with regard to Plaintiff Corsi, who is Person 1 in the
indictment of Stone, and thus a material witness, but also Dr. Corsi’s attorney Larry Klayman.
6
Jeffrey Toobin, Roger Stone’s and Jerome Corsi’s Time in the Barrel, The New Yorker, Feb.
18 & 25 Issue, available at: https://www.newyorker.com/magazine/2019/02/18/roger-stones-and-
jerome-corsis-time-in-the-barrel
7
This action by Defendants, each and every one of them, jointly and severally against Plaintiff
Corsi and his attorney Plaintiff Klayman constitute crimes pursuant to 18 U.S.C. § 1512.
29.! Stone likes to portray himself as Mafia, and indeed on information and belief has
Mafia connections, frequently making reference to Mafia figures who he admires, as well as
other unsavory types who have been alleged to have engaged in unethical and/or illegal behavior.
For example, he frequently makes reference to his heroes being Hyman Roth in the ‘Godfather,”
who was the movie version of Meyer Lansky, and Roy Cohn, not to mention, Richard Nixon, for
his role in Watergate. In this regard, after Stone was indicted he held a press conference on the
courthouse steps of the federal courthouse in Ft. Lauderdale, where he was booked, with his arms
defiantly in the air in the “victory’ pose used by Nixon after he resigned in disgrace as a result of
the Watergate scandal. At the time, Stone had been employed by a Nixon group called CREEP,
or the Committee to Reelect the President. Defendant Stone even has a large tattoo of Richard
Nixon affixed to his back. Thus, given his admiration for persons such as these, particularly
Mafia figures, his actions as pled herein can be taken as threats, as well as being defamatory.
And, Plaintiff Corsi is 72 years old and thus very vulnerable emotionally and physically to these
threats. Stone’s intentional infliction of emotional distress and coercion and threats are intended
to try even cause Plaintiff Corsi to have heart attacks and strokes, in order that Plaintiff will be
unable to testify at Stone’s criminal trial. Tellingly, Stone threatened kill a material witness and
his service dog, Credico, Person 2 in the Mueller Indictment, “Mafia style.” Stone also fashions
himself and indeed has the reputation, at a minimum, as being the preeminent “dirty trickster.”
See “Get Me Roger Stone” on Netflix.
30.! By defaming Plaintiffs, Stone is hoping to not only intimidate Plaintiffs to
severely harm and damage their reputations, but also to coerce and threaten Plaintiff Corsi to
8
testify falsely if subpoenaed to be called as a material witness in Stone’s ensuing criminal trial.
He is also trying divert funds away from Dr. Corsi’s legal defense fund, while boosting his own
legal defense fund.
31.! Defendants and Stone’s conspiracy to defame, smear, intimidate, tamper with and
threaten Plaintiffs is calculated to improperly and illegally influence the Russian collusion
investigation, for which Stone has already been criminally indicted and to coerce false testimony
favorable to Stone at his upcoming prosecution. This illegal conduct is also maliciously intended
to harm Plaintiffs’ reputations and credibility as Stone fears that Dr. Corsi will testify truthfully
if subpoenaed by Special Counsel Mueller at Stone’s upcoming criminal prosecution.
32.! Stone has also used and continues to employ surrogates, either out in the open or
secretly, to defame Plaintiffs, such as Defendants herein, and his “friend” Michael Caputo,
Cassandra Fairbanks, reporter Chuck Ross of The Daily Caller, and Tom Fitton of Judicial
Watch, to name just a few.
33.! Tellingly, in a video published by The Daily Caller, Defendant Shroyer appearing
with Stone, admits that he will serve as a surrogate for Stone if Stone receives a gag order, which
he has. 7 The other Defendants, like Stoyer, are also surrogates of Stone.
34.! Stone’s illegal and improper attempts to influence the Russian collusion
investigation has even been recognized by the presiding judge, the Honorable Amy Berman
Jackson (“Judge Jackson”), who has now issued a complete “gag” order on Stone after Stone
attempted to incite violence against Judge Jackson by putting a picture of her face and gun
crosshairs up on his Instagram account.8
7
https://www.youtube.com/watch?v=SSDkh5RYtGo
8
Judge in Roger Stone case orders hearing after he appeared to threaten her on Instagram,
Washington Post, Feb. 19, 2019, available at:
https://www.washingtonpost.com/politics/2019/02/18/roger-stone-deletes-photo-judge-presiding-
9
35.! In her minute order of February 21, 2019 imposing the total “gag” order on Stone,
Judge Jackson directly cites and references his use of surrogates:
Furthermore, the defendant may not comment publicly about the case indirectly
by having statements made publicly on his behalf by surrogates, family members,
spokespersons, representatives, or volunteers.
36.! Further evidence of Stone’s collaboration with Defendants, as well as Stone’s
pattern and practice of defamatory, intimidating, coercive, threatening and defamatory conduct is
set forth in an amicus curiae brief filed by Plaintiff Klayman on behalf of Plaintiff Corsi in
Stone’s criminal case. Such evidence is attached hereto as Exhibit 2 and incorporated herein by
reference, as well as civil complaint filed by Corsi and Klayman against Stone, and in a civil
complaint filed by Klayman against Fitton. See Exhibits 3, 4, and 5, which are incorporated
herein by reference.
37.! Defendants have, by working in concert with Stone, therefore engaged in illegal
witness tampering, intimidation and threats in violation of 18 U.S.C. § 1512 by virtue of the
defamatory and threatening acts and practices as alleged herein. Not coincidentally, this was
what largely Stone was indicted for by Special Counsel Robert Mueller.
DEFENDANTS’ DEFAMATORY CONDUCT
38.! Stone has appeared numerous times on programs of the Defendants, The Alex
Jones Show and The War Room, which are hosted by Defendant Alex Jones and Shroyer where
numerous false, misleading, malicious and defamatory statements of and concerning Plaintiffs
were made, published, and or ratified by all of the Defendants, each and every one of them.
39.! Plaintiffs have demanded retraction and correction of the defamatory videos and
publications set forth below and generally in this Complaint, but Defendants have refused,
over-his-case-says-he-didnt-mean-threaten-her/?utm_term=.2d3c5afa6326
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thereby ratifying any and all defamatory statements contained therein.
40.! Defendants, at a minimum, acted recklessly, as they have known Plaintiff Corsi
for a long time, and even worked with him and are also familiar with Plaintiff Klayman, so they
were well aware that the statements made by Stone, and their own false, misleading, malicious
and defamatory statements were, indeed, false, as well as their ratification of the malicious false
statements published by Stone on their networks and media sites.
41.! As the content containing the malicious false, misleading, and defamatory
statements were published on the internet, it is proliferated like a “cancerous virus,” and is now
available for viewing from countless sources, thereby exponentially increasing the prejudicial
and defamatory impact and severe damage inflicted on Plaintiffs. Judge Jackson, in issuing her
two gag orders against Stone, herself recognized how postings on the internet proliferate widely
and once made cannot be taken back.
I. The October 26, 2018 Video
42.! In a video from October 26, 2018, Defendant Alex Jones, acting in concert with
the other Defendants, makes several false, misleading, malicious and defamatory statements
about Plaintiff Corsi.9
43.! At 0:45, Defendant Alex Jones maliciously and falsely published that Plaintiff
Corsi “seemed to be extremely mentally degraded to the point of what I would call dementia.”
44.! In the same video, Defendant Alex Jones, acting in concert with the other
Defendants, maliciously fabricates a story where he purportedly saw Plaintiff Corsi at a
steakhouse “on the ground at another table” and that his security staff “thought he was dead in
the elevator.”
45.! At 5:08, Defendant Alex Stone, acting in concert with the other Defendants, after
9
https://www.youtube.com/watch?v=UuXPAn0nZo8
11
accusing Plaintiff Corsi of having suffered a stroke, publishes maliciously that “whatever comes
out of his mouth ain’t the truth.”
46.! Tellingly and not at all coincidentally, Stone appeared as a guest on the same
video, as evidence of Defendants working in concert with Stone.
47.! These malicious false, misleading, and defamatory statements were published by
Defendants to discredit Plaintiff Corsi in order to preserve the reputation of their co-conspirator,
Stone before Mueller’s Russian collusion investigation, as Stone has been indicted and Plaintiff
Corsi named a material witness.
II. The January 18, 2019 Video
48.! Before Stone was indicted, on or about January 18, 2019, he appeared on The War
Room with Defendant Shroyer, where he made several malicious false, misleading, and
defamatory statements in this district, nationally and internationally regarding Plaintiffs (the
“January 18 Video”).10 The same video was published on Stone’s YouTube channel, “Stone Cold
Truth,” on January 18, 2019.11
49.! These malicious false, misleading, and defamatory statements were adopted and
published by each and every one of the Defendants, rendering them joint tortfeasors and jointly
and severally liable.
50.! At 2:09 in the January 18 Video, Stone maliciously and falsely published that
Plaintiff Corsi was “fired from World Net Daily.”
51.! At 2:27 in the January 18 Video, Stone maliciously falsely and misleadingly
published that, “He (Corsi) was perfectly willing to lie, to perjure himself saying that a memo
that he had wrote me was written on the 30th for the purposes of cover-up…. which is further
10
https://www.infowars.com/watch/?video=5c3fbf24fe49383dcf6996e4
11
https://www.youtube.com/watch?v=cJyfgdvtFx8
12
proof that Jerry lied under oath.”
published, “and then states that I knew about John Podesta’s emails being stolen in advance, the
only proof of that is Jerry’s feeble alcohol affected memory – it’s a lie….”
published that “Jerry was prepared to stab a principle Trump supporter in the back, he was
perfectly prepared to bear false witness against me, even though I had done nothing in my entire
life other than help him.”
published that “all I ever did was show Jerry Corsi friendship and support and try to help him
and his family and what I get is Judas Iscariot, the willingness to testify against me and help the
deep state bury me….and then he makes up this story about helping me formulate a cover story.”
55.! At 6:26 in the January 18 Video, Stone maliciously falsely published that “you
can always tell when Jerry Corsi is lying because his lips are moving….”
56.! At 1:25 in the January 18 Video, Stone maliciously falsely published that “He’s
(Klayman) never actually won a courtroom victory in his life.”
57.! At 1:30 in the January 18 Video, Stone maliciously falsely published, “He
(Klayman) was ousted at Judicial Watch. Ask Tom Fitton [the current president of Judicial
Watch] why he left. He was ‘ousted’ because of a ‘sexual harassment complaint.’”
58.! In actuality and truth, Plaintiff Klayman left Judicial Watch on his own accord in
order to run for U.S. Senate in Florida in 2003-2004.
59.! Not coincidentally, Plaintiff Klayman has a jury verdict and judgment against
Fitton’s Judicial Watch for having defamed him with malice. Punitive damages were also
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awarded by the jury in the U.S. District Court for the Southern District of Florida. See Exhibit 5-
1.
60.! At 1:37 in the January 18 Video, Stone maliciously falsely published, “He’s
(Klayman) incompetent, he’s a numbskull, he’s an idiot, he’s an egomaniac, and he could be the
single worst lawyer in America. With him as Jerry Corsi’s lawyer, Corsi may get the electric
chair. So your idea that he’s a good guy is entirely wrong”
61.! In actuality, Plaintiff Klayman has been a practicing attorney for over four
decades and has won numerous cases on behalf of his clients and also against the government for
constitutional and other violations. He is the founder of both Judicial Watch and Freedom
Watch, a former candidate for the U.S. Senate in Florida, a former trial attorney and prosecutor
of the Antitrust Division of the U.S. Department of Justice, where he was a member of the trial
team that successfully broke up the AT&T monopoly and created competition in the
telecommunications industry. Among many other legal victories, Plaintiff Klayman also won
landmark decisions at the chairman and general counsel of Freedom Watch enjoining the illegal
mass surveillance by the National Security Agency. Klayman v. Obama, 1:13-cv-851 (D.D.C).
See Exhibit 6 --Klayman biography, which is incorporated herein by reference. Stone knew this
when he published the malicious false and misleading statements about Klayman and thus
willfully and maliciously defamed Plaintiff Klayman.
published that Plaintiff Klayman is a “piece of garbage.”
published, “For those people out there who think…that Larry Klayman’s IQ is higher than 70,
you’re wrong…”
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64.! Defendants published these malicious false, misleading, and defamatory
statements with malice and with full knowledge that they were false and misleading, and/or at a
minimum, with a reckless disregard for its truthfulness. These statements falsely and
misleadingly state that Plaintiff Corsi was fired from World Net Daily, that he committed perjury
(a federal offense), and that he is an untruthful person. They also create the false and misleading
implication that Plaintiff Klayman is unqualified to be an attorney, public advocate and is a bad
and loathsome person. Plaintiff Klayman is also an author, columnist and nationally syndicated
radio and internet talk show host on Radio America, his show titled “Special Prosecutor with
Larry Klayman.” See www.radioamerica.com. The malicious false and misleading published
statements as alleged herein also severely damaged Plaintiff Klayman personally and
professionally in this regard, particularly since he and his show compete with Defendant
InfoWars and and the other Defendants in media markets in this district, nationally and
internationally. Plaintiff Corsi also competes with Defendant InfoWars and the other Defendants
in media markets in this district, nationally and internationally.
III. Other Malicious Defamatory Publications
65.! In another appearance on InfoWars which was posted to YouTube12 on January
17, 2019, Stone at 6:22 maliciously falsely and misleadingly published that “He [Corsi] was
perfectly willing to bear false witness against me on multiple points that are complete
fabrications.”
66.! In another appearance on InfoWars, this time on The Alex Jones Show from
January 21, 2019, Stone maliciously falsely and misleadingly published that “the good doctor
[Corsi] has told a number of lies. In fact, he’s starting to conflate his lies…. he was perfectly
willing to lie about me…. but now lying about Alex Jones, lying about InfoWars, lying about Dr.
12
https://www.youtube.com/watch?v=GJd8YBDvm1Q
15
(David) Jones, who’s one of the nicest, gentlest, sweetest, most honest men I have ever met, it’s
beyond the pale…. Jerry Corsi can no longer be believed.”13
67.! In the same appearance, Stone maliciously falsely and misleadingly published
that, “I think you’ve [Corsi] been deep state from the beginning. Your whole birther thing is used
as a club to destroy conservatives…. I look forward to our confrontation. I will demolish you.
You’re a fraudster, out of your alcoholic haze you have made up lies about David Jones and Alex
Jones and Roger Stone and now I suspect they want you to lie about the President.” This is
clearly a threat, as well as being maliciously defamatory. It is akin to the threats against Person 2
in the Mueller Indictment, Randy Credico, who Defendant Stone, as set forth in the Mueller
Indictment, based on Stone’s own words contained in his own documentary evidence, threatened
kill along with Credico’s service dog. Later Stone threatened the judge presiding over his
criminal prosecution, the Honorable Amy Berman Jackson.
68.! In the same January 21, 2019 video, at 43:40, Defendant Alex Jones maliciously
and falsely accuses Plaintiff Corsi of being a “spook, back and forth with different agencies,”
falsely saying that Dr. Corsi had worked with different government agencies.
69.! Defendant Alex Jones further maliciously falsely accuses Plaintiff Corsi of
sometimes “not being able to walk,” creating the false and defamatory implication that he is an
alcoholic.
70.! Defendants in concert published these false, misleading, and defamatory
statements in concert with Stone with malice and with full knowledge that they were false and
misleading, and/or at a minimum, with a reckless disregard for their truthfulness. These
statements falsely and misleadingly published that Plaintiff Corsi committed perjury (a federal
offense), is an untruthful person, and is an alcoholic. They also contain threats against Plaintiff
13
https://www.youtube.com/watch?v=ANfe9d7YzL0 (Beginning at 38:00)
16
Corsi and his legal counsel Larry Klayman. Defendants, working in concert with Stone,
obviously believe that in order to advance their interests and improper if not criminal
motivations, they also have to destroy and severely harm the legal counsel of Plaintiff Corsi, who
is representing Plaintiff Corsi before Special Counsel Robert Mueller, congressional committees
and generally and will also counsel Plaintiff Corsi should he be subpoenaed to testify truthfully
in Stone’s upcoming criminal trial for perjury, witness tampering, threatening to kill a material
witness and his service dog, as well as obstruction of justice.
FACTS PERTAINING TO DEFENDANTS’ UNFAIR COMPETITION
71.! In addition to being an investigative journalist/author and a public interest
litigator/advocate, respectively, Plaintiffs Corsi and Plaintiff Klayman are both competitors to
Defendants as conservative media personalities, broadcasters, authors and columnists on social
media and elsewhere.
72.! For instance, Plaintiff Klayman also hosts an online radio show and produces
videos that are posted on the internet, issues press releases, commentary and other publications.
73.! Defendants have made, adopted, and or ratified numerous false or misleading
statements of fact of and concerning Plaintiffs during their various programs and media postings
and publication, which all contain significant advertisement or promotions.
74.! These false and/or misleading facts materially prejudice the viewers and/or
listeners as to the quality, nature, and contents of Plaintiffs’ services, which has caused
significant competitive and commercial injury to Plaintiffs, as well as loss of good will and
reputation.
75.! Plaintiffs, like Defendants, rely on viewer and listener financial support and sales
in order to continue their work. Defendants’ false and/or misleading statements concerning
17
Plaintiffs is meant to, and has, diverted financial support and sales away from Plaintiffs and to
Defendants instead.
FIRST CAUSE OF ACTION

Defamation
76.! Plaintiffs re-alleges and incorporates by reference the allegations in the preceding
paragraphs of the Complaint as if fully set forth herein.
77.! Acting in concert Defendants published malicious, false, misleading and
defamatory statements of and concerning Plaintiffs in this judicial district, nationwide, and
worldwide.
78.! These false and misleading statements were published with malice, as Defendants
knew that they were false and misleading, or at a minimum acted with a reckless disregard for
the truth.
79.! Plaintiffs have been severely harmed and damaged by these false and misleading
statements because they subjected him to hatred, distrust, ridicule, contempt, and disgrace.
80.! Plaintiffs have been damaged by these false and misleading statements because
they severely injured Plaintiff Corsi and Plaintiff Klayman in their profession and businesses, as
well as severely injured and damaged them personally, financially and in terms of their good will
and reputations.
SECOND CAUSE OF ACTION

Defamation Per Se
82.! Acting in concert, Defendants as alleged herein, published numerous false,
misleading and defamatory statements to severely harm and damage Plaintiffs, which were
18
republished elsewhere, and through surrogates, which published the falsity that Plaintiffs have
committed crimes, including perjury, and engaged in moral turpitude in the form of alcoholism,
and committed sexual misconduct, as set forth in the preceding paragraphs.
83.! These false, misleading and defamatory statements were published in this district
and on the internet and elsewhere, domestically and for the entire world to see and hear and in so
doing Defendants published false and misleading facts, inter alia, that Plaintiffs’ conduct,
characteristics or a condition are incompatible with the proper exercise of their lawful business,
trade, profession or office, as well as personally.
knew that they were false and misleading, and/or at a minimum acted with a reckless disregard
for the truth.
85.! This statements are per se defamatory because they falsely and misleadingly
published that Plaintiff Corsi committed perjury and Plaintiff Klayman had committed sexual
misconduct which are federal offense and felony. Defamation per se gives rise to the
presumption that severe harm and damage has arisen by virtue of the malicious false and
misleading statements.
86.! These malicious false, misleading, and defamatory statements are defamatory per
se and these false and misleading statements severely harmed and damaged Plaintiff Corsi in this
profession and business as a journalist, author and political commentator, whose credibility is the
most important trait, as well as personally and Plaintiff Klayman in his profession as a public
interest and private advocate and litigator and as an author, columnist and radio and internet
radio talk show and syndicated host, as well as personally.
THIRD CAUSE OF ACTION

Defamation by Implication
19
88.! Acting in concert, Defendants published numerous false, misleading and
defamatory statements about Plaintiffs, as set forth in the preceding paragraphs.
89.! These false, misleading and defamatory statements were published on the internet
and published and republished elsewhere in this district, domestically and for the entire world to
see and hear.
knew that they were false and misleading, and/or at a minimum acted with a reckless disregard
for the truth.
91.! These statements created the false and misleading implication that Plaintiff Corsi
is dishonest, committed perjury and is an alcoholic, and that Plaintiff Klayman committed sexual
misconduct and is incompetent, among other false and misleading statements as pled in the
preceding paragraphs.
92.! Plaintiffs have been severely harmed and damaged by these false and misleading
statements because they subject him to hatred, distrust, ridicule, contempt, and disgrace.
93.! Plaintiffs has been damaged by these malicious false and misleading statements
because the statements severely harmed and damaged Plaintiffs in their professions as
journalists, authors, columnists, pubic interest and private practitioner lawyers and radio talk
show hosts, whose credibility is the most important trait, as well as personally.
FOURTH CAUSE OF ACTION

Intentional Infliction of Emotional Distress
20
95.! Acting in concert, Defendants engaged in extreme and outrageous conduct by
threatening Plaintiffs, in concert with Stone, who has made death threats to at least one witness
involved in Special Counsel Mueller’s Russian collusion investigation, Person 2 Randy Credico,
as well as incited violence against Judge Amy Berman Jackson by posting a meme on Instagram
with a crosshairs and gun pointed at the jurist’s head, for which Stone was sanctioned with a total
gag order and threat of incarceration if this type of violative conduct of the Court’s gag order
occurred again, which it apparently has. See Exhibit 7.
96.! Defendants knowingly and intentionally threatened Plaintiffs, in a manner similar
to other death threats co-conspirator Stone made to at least one material witness, involved in
Special Counsel Mueller’s Russian collusion investigation, such as Randy Credico, Person 2 in
the Mueller Indictment, as well as Judge Amy Berman Jackson.
97.! Defendants’ extreme and outrageous conduct directly caused Plaintiffs severe
emotional distress and resulting severe harm and damage.
FIFTH CAUSE OF ACTION

Assault
99.! Acting in concert, Defendants placed Plaintiffs in apprehension of an imminent
harmful or offensive contact and physical harm and death, by coercing and threatening Plaintiffs,
in a similar manner that co-conspirator Stone has used to make death threats to at least one
material witness involved in Special Counsel Mueller’s Russian collusion investigation, such as
Person 2 in the Mueller Indictment, Randy Credico and Judge Amy Berman Jackson.
21
100.! The threats issued by Defendants are credible, as co-conspirator Stone portrays
and sees himself as a “Mafia” figure, as set forth above.
101.! Furthermore, as set forth above, acting in concert Defendants have a pattern and
practice of calling their followers “to arms,” which has resulted in deadly violence against their
victims.
102.! Plaintiffs did not consent to Defendants’ conduct.
103.! As a direct and proximate result of Defendants’ wrongful conduct, Plaintiffs
suffered conscious pain, suffering, severe emotional distress and the fear of imminent serious
bodily injury or death, and other mental and physical injuries, and Plaintiffs were severely
harmed and damaged thereby.
SIXTH CAUSE OF ACTION

Unfair Competition – Lanham Act 15 U.S.C. § 1125(a)
105.! Defendants have and are engaged in acts of unfair competition in violation of the
Lanham Act, 15 U.S.C. § 1125(a) and common law
106.! Defendants have made false and/or misleading statements that have deceived
and/or had the tendency to deceive a substantial segment of the receiving audience.
107.! Defendants’ false and/or misleading statements misrepresent the nature,
characteristics, and qualities of Plaintiff Klayman and Plaintiff Corsi’s goods or services.
108.! Defendants false and/or misleading statements are material because that were
highly likely to mislead and influence supporters’ decisions to provide financial support and
sales to Defendants instead of Plaintiffs
109.! These false and misleading statements were made in interstate commerce, as they
22
were widely broadcast on radio, on the internet, in social media, and elsewhere in this district,
nationally and internationally.
110.! Plaintiffs have suffered significant damages, which are ongoing, due to
Defendants’ false and/or misleading statements. By law these damages are calculated based on
Defendants’ gross sales and receipts, which are trebled, plus an award of attorneys fees and
costs.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:
a.! Awarding Plaintiffs compensatory including actual, consequential, incidental and
punitive damages for malicious tortious concerted conduct, jointly and severally in an amount to
be determined at trial and in excess of $50, 000,000 U.S. Dollars for each Plaintiff.
b.! Awarding Treble Damages Under the Lanham Act, 15 U.S.C. 1125(a).
c.! Awarding Plaintiffs attorney fees and costs
d.! Granting such other relief as the Court deems appropriate and necessary including
preliminary and permanent injunctive relief.
PLAINTIFFS DEMAND TRIAL BY JURY ON ALL CLAIMS SO TRIABLE.
Dated: March 7, 2019 Respectfully Submitted,
/s/ Larry Klayman

Larry Klayman, Esq.
KLAYMAN LAW GROUP, P.A.
D.C. Bar Number: 334581
2020 Pennsylvania Ave NW #800
Washington, DC, 20006
Telephone: (310)-595-0800
Email: leklayman@gmail.com
Counsel for Plaintiffs Corsi and

Klayman
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EXHIBIT 1

UNITED STATES OF AMERICA * CRIMINAL NO.

*
v. * Grand Jury Original
*
ROGER JASON STONE, JR., * 18 U.S.C. §§ 1001, 1505, 1512, 2
*
Defendant. *
*
*
*
*******
INDICTMENT
The Grand Jury for the District of Columbia charges:
Introduction
1. By in or around May 2016, the Democratic National Committee (“DNC”) and the
Democratic Congressional Campaign Committee (“DCCC”) became aware that their computer
systems had been compromised by unauthorized intrusions and hired a security company
(“Company 1”) to identify the extent of the intrusions.
2. On or about June 14, 2016, the DNC—through Company 1—publicly announced that it
had been hacked by Russian government actors.
3. From in or around July 2016 through in or around November 2016, an organization
(“Organization 1”), which had previously posted documents stolen by others from U.S. persons,
entities, and the U.S. government, released tens of thousands of documents stolen from the DNC
and the personal email account of the chairman of the U.S. presidential campaign of Hillary
Clinton (“Clinton Campaign”).

a. On or about July 22, 2016, Organization 1 released documents stolen from the
DNC.
b. Between on or about October 7, 2016 and on or about November 7, 2016,
Organization 1 released approximately 33 tranches of documents that had been
stolen from the personal email account of the Clinton Campaign chairman, totaling
over 50,000 stolen documents.
4. ROGER JASON STONE, JR. was a political consultant who worked for decades in U.S.
politics and on U.S. political campaigns. STONE was an official on the U.S. presidential campaign
of Donald J. Trump (“Trump Campaign”) until in or around August 2015, and maintained regular
contact with and publicly supported the Trump Campaign through the 2016 election.
5. During the summer of 2016, STONE spoke to senior Trump Campaign officials about
Organization 1 and information it might have had that would be damaging to the Clinton
Campaign. STONE was contacted by senior Trump Campaign officials to inquire about future
releases by Organization 1.
6. By in or around early August 2016, STONE was claiming both publicly and privately to
have communicated with Organization 1. By in or around mid-August 2016, Organization 1 made
a public statement denying direct communication with STONE. Thereafter, STONE said that his
communication with Organization 1 had occurred through a person STONE described as a “mutual
friend,” “go-between,” and “intermediary.” STONE also continued to communicate with members
of the Trump Campaign about Organization 1 and its intended future releases.
7. After the 2016 U.S. presidential election, the U.S. House of Representatives Permanent
Select Committee on Intelligence (“HPSCI”), the U.S. Senate Select Committee on Intelligence
(“SSCI”), and the Federal Bureau of Investigation (“FBI”) opened or announced their respective
2
investigations into Russian interference in the 2016 U.S. presidential election, which included
investigating STONE’s claims of contact with Organization 1.
8. In response, STONE took steps to obstruct these investigations. Among other steps to
obstruct the investigations, STONE:
a. Made multiple false statements to HPSCI about his interactions regarding
Organization 1, and falsely denied possessing records that contained evidence of
these interactions; and
b. Attempted to persuade a witness to provide false testimony to and withhold
pertinent information from the investigations.
Other Relevant Individuals
9. Person 1 was a political commentator who worked with an online media publication during
the 2016 U.S. presidential campaign. Person 1 spoke regularly with STONE throughout the
campaign, including about the release of stolen documents by Organization 1.
10. Person 2 was a radio host who had known STONE for more than a decade. In testimony
before HPSCI on or about September 26, 2017, STONE described Person 2 (without naming him)
as an “intermediary,” “go-between,” and “mutual friend” to the head of Organization 1. In a
follow-up letter to HPSCI dated October 13, 2017, STONE identified Person 2 by name and
claimed Person 2 was the “gentleman who confirmed for Mr. Stone” that the head of
Organization 1 had “‘[e]mails related to Hillary Clinton which are pending publication.’”
Background
STONE’s Communications About Organization 1 During the Campaign
11. By in or around June and July 2016, STONE informed senior Trump Campaign officials
that he had information indicating Organization 1 had documents whose release would be
3
damaging to the Clinton Campaign. The head of Organization 1 was located at all relevant times
at the Ecuadorian Embassy in London, United Kingdom.
12. After the July 22, 2016 release of stolen DNC emails by Organization 1, a senior Trump
Campaign official was directed to contact STONE about any additional releases and what other
damaging information Organization 1 had regarding the Clinton Campaign. STONE thereafter
told the Trump Campaign about potential future releases of damaging material by Organization 1.
13. STONE also corresponded with associates about contacting Organization 1 in order to
obtain additional emails damaging to the Clinton Campaign.
a. On or about July 25, 2016, STONE sent an email to Person 1 with the subject line,
“Get to [the head of Organization 1].” The body of the message read, “Get to [the
head of Organization 1] [a]t Ecuadorian Embassy in London and get the pending
[Organization 1] emails . . . they deal with Foundation, allegedly.” On or about the
same day, Person 1 forwarded STONE’s email to an associate who lived in the
United Kingdom and was a supporter of the Trump Campaign.
b. On or about July 31, 2016, STONE emailed Person 1 with the subject line, “Call
me MON.” The body of the email read in part that Person 1’s associate in the
United Kingdom “should see [the head of Organization 1].”
c. On or about August 2, 2016, Person 1 emailed STONE. Person 1 wrote that he was
currently in Europe and planned to return in or around mid-August. Person 1 stated
in part, “Word is friend in embassy plans 2 more dumps. One shortly after I’m
back. 2nd in Oct. Impact planned to be very damaging.” The phrase “friend in
embassy” referred to the head of Organization 1. Person 1 added in the same email,
“Time to let more than [the Clinton Campaign chairman] to be exposed as in bed w
4
enemy if they are not ready to drop HRC. That appears to be the game hackers are
now about. Would not hurt to start suggesting HRC old, memory bad, has stroke –
neither he nor she well. I expect that much of next dump focus, setting stage for
Foundation debacle.”
14. Starting in early August 2016, after receiving the August 2, 2016 email from Person 1,
STONE made repeated statements about information he claimed to have learned from the head of
Organization 1.
a. On or about August 8, 2016, STONE attended a public event at which he stated, “I
actually have communicated with [the head of Organization 1]. I believe the next
tranche of his documents pertain to the Clinton Foundation, but there’s no telling
what the October surprise may be.”
b. On or about August 12, 2016, STONE stated during an interview that he was “in
communication with [the head of Organization 1]” but was “not at liberty to discuss
what I have.”
c. On or about August 16, 2016, STONE stated during an interview that “it became
known on this program that I have had some back-channel communication with
[Organization 1] and [the head of Organization 1].” In a second interview on or
about the same day, STONE stated that he “communicated with [the head of
Organization 1]” and that they had a “mutual acquaintance who is a fine
gentleman.”
d. On or about August 18, 2016, STONE stated during a television interview that he
had communicated with the head of Organization 1 through an “intermediary,
somebody who is a mutual friend.”
5
e. On or about August 23, 2016, Person 2 asked STONE during a radio interview,
“You’ve been in touch indirectly with [the head of Organization 1]. . . . Can you
give us any kind of insight? Is there an October surprise happening?” STONE
responded, “Well, first of all, I don’t want to intimate in any way that I control or
have influence with [the head of Organization 1] because I do not. . . . We have a
mutual friend, somebody we both trust and therefore I am a recipient of pretty good
information.”
15. Beginning on or about August 19, 2016, STONE exchanged written communications,
including by text message and email, with Person 2 about Organization 1 and what the head of
Organization 1 planned to do.
a. On or about August 19, 2016, Person 2 sent a text message to STONE that read in
part, “I’m going to have [the head of Organization 1] on my show next Thursday.”
On or about August 21, 2016, Person 2 sent another text message to STONE,
writing in part, “I have [the head of Organization 1] on Thursday so I’m completely
tied up on that day.”
b. On or about August 25, 2016, the head of Organization 1 was a guest on Person 2’s
radio show for the first time. On or about August 26, 2016, Person 2 sent a text
message to STONE that stated, “[the head of Organization 1] talk[ed] about you
last night.” STONE asked what the head of Organization 1 said, to which Person 2
responded, “He didn’t say anything bad we were talking about how the Press is
trying to make it look like you and he are in cahoots.”
c. On or about August 27, 2016, Person 2 sent text messages to STONE that said, “We
are working on a [head of Organization 1] radio show,” and that he (Person 2) was
6
“in charge” of the project. In a text message sent later that day, Person 2 added,
“[The head of Organization 1] has kryptonite on Hillary.”
d. On or about September 18, 2016, STONE sent a text message to Person 2 that said,
“I am e-mailing u a request to pass on to [the head of Organization 1].” Person 2
responded “Ok,” and added in a later text message, “[j]ust remember do not name
me as your connection to [the head of Organization 1] you had one before that you
referred to.”
i. On or about the same day, September 18, 2016, STONE emailed
Person 2 an article with allegations against then-candidate Clinton
related to her service as Secretary of State. STONE stated, “Please
ask [the head of Organization 1] for any State or HRC e-mail from
August 10 to August 30—particularly on August 20, 2011 that
mention [the subject of the article] or confirm this narrative.”
ii. On or about September 19, 2016, STONE texted Person 2 again,
writing, “Pass my message . . . to [the head of Organization 1].”
Person 2 responded, “I did.” On or about September 20, 2016,
Person 2 forwarded the request to a friend who was an attorney with
the ability to contact the head of Organization 1. Person 2 blind-
copied STONE on the forwarded email.
e. On or about September 30, 2016, Person 2 sent STONE via text message a
photograph of Person 2 standing outside the Ecuadorian Embassy in London where
the head of Organization 1 was located.
7
f. On or about October 1, 2016, which was a Saturday, Person 2 sent STONE text
messages that stated, “big news Wednesday . . . now pretend u don’t know me . . .
Hillary’s campaign will die this week.” In the days preceding these messages, the
press had reported that the head of Organization 1 planned to make a public
announcement on or about Tuesday, October 4, 2016, which was reported to be the
ten-year anniversary of the founding of Organization 1.
g. On or about October 2, 2016, STONE emailed Person 2, with the subject line
“WTF?,” a link to an article reporting that Organization 1 was canceling its “highly
anticipated Tuesday announcement due to security concerns.” Person 2 responded
to STONE, “head fake.”
h. On or about the same day, October 2, 2016, STONE texted Person 2 and asked,
“Did [the head of Organization 1] back off.” On or about October 3, 2016, Person
2 initially responded, “I can’t tal[k] about it.” After further exchanges with
STONE, Person 2 said, “I think it[’]s on for tomorrow.” Person 2 added later that
day, “Off the Record Hillary and her people are doing a full-court press they [sic]
keep [the head of Organization 1] from making the next dump . . . That’s all I can
tell you on this line . . . Please leave my name out of it.”
16. In or around October 2016, STONE made statements about Organization 1’s future
releases, including statements similar to those that Person 2 made to him. For example:
a. On or about October 3, 2016, STONE wrote to a supporter involved with the Trump
Campaign, “Spoke to my friend in London last night. The payload is still coming.”
b. Also on or about October 3, 2016, STONE received an email from a reporter who
had connections to a high-ranking Trump Campaign official that asked, “[the head
8
of Organization 1] – what’s he got? Hope it’s good.” STONE responded in part,
“It is. I’d tell [the high-ranking Trump Campaign official] but he doesn’t call me
back.”
c. On or about October 4, 2016, the head of Organization 1 held a press conference
but did not release any new materials pertaining to the Clinton Campaign. Shortly
afterwards, STONE received an email from the high-ranking Trump Campaign
official asking about the status of future releases by Organization 1. STONE
answered that the head of Organization 1 had a “[s]erious security concern” but that
Organization 1 would release “a load every week going forward.”
d. Later that day, on or about October 4, 2016, the supporter involved with the Trump
Campaign asked STONE via text message if he had “hear[d] anymore from
London.” STONE replied, “Yes - want to talk on a secure line - got Whatsapp?”
STONE subsequently told the supporter that more material would be released and
that it would be damaging to the Clinton Campaign.
17. On or about October 7, 2016, Organization 1 released the first set of emails stolen from the
Clinton Campaign chairman. Shortly after Organization 1’s release, an associate of the high-
ranking Trump Campaign official sent a text message to STONE that read “well done.” In
subsequent conversations with senior Trump Campaign officials, STONE claimed credit for
having correctly predicted the October 7, 2016 release.
The Investigations
18. In or around 2017, government officials publicly disclosed investigations into Russian
interference in the 2016 U.S. presidential election and possible links to individuals associated with
the campaigns.
9
a. On or about January 13, 2017, the chairman and vice chairman of SSCI announced
the committee would conduct an inquiry that would investigate, among other
things, any intelligence regarding links between Russia and individuals associated
with political campaigns, as well as Russian cyber activity and other “active
measures” directed against the United States in connection with the 2016 election.
b. On or about January 25, 2017, the chairman and ranking member of HPSCI
announced that HPSCI had been conducting an inquiry similar to SSCI’s.
c. On or about March 20, 2017, the then-director of the FBI testified at a HPSCI
hearing and publicly disclosed that the FBI was investigating Russian interference
in the 2016 election and possible links and coordination between the Trump
Campaign and the Russian government.
d. By in or around August 2017, news reports stated that a federal grand jury had
opened an investigation into matters relating to Russian government efforts to
interfere in the 2016 election, including possible links and coordination between
the Trump Campaign and the Russian government.
STONE’s False Testimony to HPSCI
19. In or around May 2017, HPSCI sent a letter requesting that STONE voluntarily appear
before the committee and produce:
Any documents, records, electronically stored information

including e-mail, communication, recordings, data and tangible
things (including, but not limited to, graphs, charts, photographs,
images and other documents) regardless of form, other than those
widely available (e.g., newspaper articles) that reasonably could
lead to the discovery of any facts within the investigation’s publicly-
announced parameters.
On or about May 22, 2017, STONE caused a letter to be submitted to HPSCI stating that “Mr.
10
Stone has no documents, records, or electronically stored information, regardless of form, other
than those widely available that reasonably could lead to the discovery of any facts within the
investigation’s publicly-announced parameters.”
20. On or about September 26, 2017, STONE testified before HPSCI in Washington, D.C. as
part of the committee’s ongoing investigation. In his opening statement, STONE stated, “These
hearings are largely based on a yet unproven allegation that the Russian state is responsible for the
hacking of the DNC and [the Clinton Campaign chairman] and the transfer of that information to
[Organization 1].” STONE further stated that “[m]embers of this Committee” had made certain
“assertions against me which must be rebutted here today,” which included “[t]he charge that I
knew in advance about, and predicted, the hacking of Clinton campaign chairman[’s] email, [and]
that I had advanced knowledge of the source or actual content of the [Organization 1] disclosures
regarding Hillary Clinton.”
21. In the course of his HPSCI testimony, STONE made deliberately false and misleading
statements to the committee concerning, among other things, his possession of documents
pertinent to HPSCI’s investigation; the source for his early August 2016 statements about
Organization 1; requests he made for information from the head of Organization 1; his
communications with his identified intermediary; and his communications with the Trump
Campaign about Organization 1.
STONE’s False and Misleading Testimony About His Possession of Documents Pertinent to
HPSCI’s Investigation
22. During his HPSCI testimony, STONE was asked, “So you have no emails to anyone
concerning the allegations of hacked documents . . . or any discussions you have had with third
parties about [the head of Organization 1]? You have no emails, no texts, no documents
whatsoever, any kind of that nature?” STONE falsely and misleadingly answered, “That is correct.
11
Not to my knowledge.”
23. In truth and in fact, STONE had sent and received numerous emails and text messages
during the 2016 campaign in which he discussed Organization 1, its head, and its possession of
hacked emails. At the time of his false testimony, STONE was still in possession of many of these
emails and text messages, including:
a. The email from STONE to Person 1 on or about July 25, 2016 that read in part,
“Get to [the head of Organization 1] [a]t Ecuadorian Embassy in London and get
the pending [Organization 1] emails . . . they deal with Foundation, allegedly.”;
b. The email from STONE to Person 1 on or about July 31, 2016 that said an associate
of Person 1 “should see [the head of Organization 1].”;
c. The email from Person 1 to STONE on or about August 2, 2016 that stated in part,
“Word is friend in embassy plans 2 more dumps. One shortly after I’m back. 2nd
in Oct. Impact planned to be very damaging.”;
d. Dozens of text messages and emails, beginning on or about August 19, 2016 and
continuing through the election, between STONE and Person 2 in which they
discussed Organization 1 and the head of Organization 1;
e. The email from STONE on or about October 3, 2016 to the supporter involved with
the Trump Campaign, which read in part, “Spoke to my friend in London last night.
The payload is still coming.”; and
f. The emails on or about October 4, 2016 between STONE and the high-ranking
member of the Trump Campaign, including STONE’s statement that Organization
1 would release “a load every week going forward.”
12
24. By falsely claiming that he had no emails or text messages in his possession that referred
to the head of Organization 1, STONE avoided providing a basis for HPSCI to subpoena records
in his possession that could have shown that other aspects of his testimony were false and
misleading.
STONE’s False and Misleading Testimony About His Early August 2016 Statements
25. During his HPSCI testimony on or about September 26, 2017, STONE was asked to
explain his statements in early August 2016 about being in contact with the head of Organization 1.
STONE was specifically asked about his statement on or about August 8, 2016 that “I’ve actually
communicated with [the head of Organization 1],” as well as his statement on or about August 12,
2016 that he was “in communication with [the head of Organization 1]” but was “not at liberty to
discuss what I have.”
26. STONE responded that his public references to having a means of contacting Organization
1 referred exclusively to his contact with a journalist, who STONE described as a “go-between, as
an intermediary, as a mutual friend” of the head of Organization 1. STONE stated that he asked
this individual, his intermediary, “to confirm what [the head of Organization 1] ha[d] tweeted,
himself, on July 21st, that he ha[d] the Clinton emails and that he [would] publish them.” STONE
further stated that the intermediary “was someone I knew had interviewed [the head of
Organization 1]. And I merely wanted confirmation of what he had tweeted on the 21st.” STONE
declined to tell HPSCI the name of this “intermediary” but provided a description in his testimony
that was consistent with Person 2.
27. On or about October 13, 2017, STONE caused a letter to be submitted to HPSCI that
identified Person 2 by name as the “gentleman who confirmed for Mr. Stone” that the head of
Organization 1 had “‘[e]mails related to Hillary Clinton which are pending publication.’”
13
28. STONE’s explanation of his August 2016 statements about communicating with the head
of Organization 1 was false and misleading. In truth and in fact, the first time Person 2 interviewed
the head of Organization 1 was on or about August 25, 2016, after STONE made his August 8 and
August 12, 2016 public statements. Similarly, at the time STONE made his August 2016
statements, STONE had directed Person 1—not Person 2—to contact the head of Organization 1.
And Person 1—not Person 2—had told STONE in advance of STONE’s August 8 and August 12,
2016 public statements that “[w]ord is friend in embassy plans 2 more dumps,” including one in
October. At no time did STONE identify Person 1 to HPSCI as another individual STONE
contacted to serve as a “go-between,” “intermediary,” or other source of information from
Organization 1. STONE also never disclosed his exchanges with Person 1 when answering
HPSCI’s questioning about STONE’s August 8 and August 12, 2016 statements.
STONE’s False and Misleading Testimony About Requests He Made for Information from the
Head of Organization 1
29. During his HPSCI testimony, STONE was asked, “[W]hat was the extent of the
communication with [the intermediary]?” STONE replied, “I asked him to confirm . . . that the
tweet of [the head of Organization 1] of the 21st was accurate, that they did in fact have . . . Hillary
Clinton emails and that they would release them.” STONE was then asked, “Did you ask [the
intermediary] to communicate anything else to [the head of Organization 1]?” STONE falsely and
misleadingly responded, “I did not.” STONE was then asked, “Did you ask [the intermediary] to
do anything on your own behalf?” STONE falsely and misleadingly responded, “I did not.”
30. In truth and in fact, STONE directed both Person 1 and Person 2 to pass on requests to the
head of Organization 1 for documents that STONE believed would be damaging to the Clinton
Campaign. For example:
a. As described above, on or about July 25, 2016, STONE sent Person 1 an email that
14
read, “Get to [the head of Organization 1] [a]t Ecuadorian Embassy in London and
get the pending [Organization 1] emails . . . they deal with Foundation, allegedly.”
b. On or about September 18, 2016, STONE sent a text message to Person 2 that said,
“I am e-mailing u a request to pass on to [the head of Organization 1],” and then
emailed Person 2 an article with allegations against then-candidate Clinton related
to her service as Secretary of State. STONE added, “Please ask [the head of
Organization 1] for any State or HRC e-mail from August 10 to August 30—
particularly on August 20, 2011 that mention [the subject of the article] or confirm
this narrative.”
c. On or about September 19, 2016, STONE texted Person 2 again, writing “Pass my
message . . . to [the head of Organization 1].” Person 2 responded, “I did,” and the
next day Person 2, on an email blind-copied to STONE, forwarded the request to
an attorney who had the ability to contact the head of Organization 1.
STONE’s False and Misleading Testimony About Communications with His Identified
Intermediary
31. During his HPSCI testimony, STONE was asked repeatedly about his communications
with the person he identified as his intermediary. STONE falsely and misleadingly stated that he
had never communicated with his intermediary in writing in any way. During one exchange,
STONE falsely and misleadingly claimed only to have spoken with the intermediary
telephonically:
Q: [H]ow did you communicate with the intermediary?

A: Over the phone.
Q: And did you have any other means of communicating with
the intermediary?
A: No.
Q: No text messages, no – none of the list, right?
15
A: No.
Later during his testimony, STONE again falsely denied ever communicating with his
intermediary in writing:
Q: So you never communicated with your intermediary in

writing in any way?
A: No.
Q: Never emailed him or texted him?
A: He’s not an email guy.
Q: So all your conversations with him were in person or over
the phone.
A: Correct.
32. In truth and in fact, as described above, STONE and Person 2 (who STONE identified to
HPSCI as his intermediary) engaged in frequent written communication by email and text
message. STONE also engaged in frequent written communication by email and text message
with Person 1, who also provided STONE with information regarding Organization 1.
33. Written communications between STONE and Person 1 and between STONE and Person 2
continued through STONE’s HPSCI testimony. Indeed, on or about September 26, 2017—the day
that STONE testified before HPSCI and denied having ever sent or received emails or text
messages from Person 2—STONE and Person 2 exchanged over thirty text messages.
34. Certain electronic messages between STONE and Person 1 and between STONE and
Person 2 would have been material to HPSCI. For example:
a. In or around July 2016, STONE emailed Person 1 to “get to” the head of
Organization 1 and obtain the pending emails.
b. In or around September 2016, STONE sent messages directing Person 2 to pass a
request to the head of Organization 1.
c. On or about January 6, 2017, Person 2 sent STONE an email that had the subject
16
line “Back channel bs.” In the email, Person 2 wrote, “Well I have put together
timelines[] and you [] said you have a back-channel way back a month before I had
[the head of Organization 1] on my show . . . I have never had a conversation with
[the head of Organization 1] other than my radio show . . . I have pieced it all
together . . . so you may as well tell the truth that you had no back-channel or there’s
the guy you were talking about early August.”
STONE’s False and Misleading Testimony About Communications with the Trump Campaign
35. During his HPSCI testimony, STONE was asked, “did you discuss your conversations with
the intermediary with anyone involved in the Trump campaign?” STONE falsely and misleadingly
answered, “I did not.” In truth and in fact, and as described above, STONE spoke to multiple
individuals involved in the Trump Campaign about what he claimed to have learned from his
intermediary to Organization 1, including the following:
a. On multiple occasions, STONE told senior Trump Campaign officials about
materials possessed by Organization 1 and the timing of future releases.
b. On or about October 3, 2016, STONE wrote to a supporter involved with the Trump
Campaign, “Spoke to my friend in London last night. The payload is still coming.”
c. On or about October 4, 2016, STONE told a high-ranking Trump Campaign official
that the head of Organization 1 had a “[s]erious security concern” but would release
“a load every week going forward.”
Attempts to Prevent Person 2 from Contradicting STONE’s False Statements to HPSCI
36. On or about October 19, 2017, STONE sent Person 2 an excerpt of his letter to HPSCI that
identified Person 2 as his “intermediary” to Organization 1. STONE urged Person 2, if asked by
HPSCI, to falsely confirm what STONE had previously testified to, including that it was Person 2
17
who provided STONE with the basis for STONE’s early August 2016 statements about contact
with Organization 1. Person 2 repeatedly told STONE that his testimony was false and told him
to correct his testimony to HPSCI. STONE did not do so. STONE then engaged in a prolonged
effort to prevent Person 2 from contradicting STONE’s false statements to HPSCI.
37. In or around November 2017, Person 2 received a request from HPSCI to testify voluntarily
before the committee. After being contacted by HPSCI, Person 2 spoke and texted repeatedly with
STONE. In these discussions, STONE sought to have Person 2 testify falsely either that Person 2
was the identified intermediary or that Person 2 could not remember what he had told STONE.
Alternatively, STONE sought to have Person 2 invoke his Fifth Amendment right against self-
incrimination. For example:
a. On or about November 19, 2017, in a text message to STONE, Person 2 said that
his lawyer wanted to see him (Person 2). STONE responded, “‘Stonewall it. Plead
the fifth. Anything to save the plan’ . . . Richard Nixon.” On or about November
20, 2017, Person 2 informed HPSCI that he declined HPSCI’s request for a
voluntary interview.
b. On or about November 21, 2017, Person 2 texted STONE, “I was told that the house
committee lawyer told my lawyer that I will be getting a subpoena.” STONE
responded, “That was the point at which your lawyers should have told them you
would assert your 5th Amendment rights if compelled to appear.”
c. On or about November 28, 2017, Person 2 received a subpoena compelling his
testimony before HPSCI. Person 2 informed STONE of the subpoena.
d. On or about November 30, 2017, STONE asked Person 1 to write publicly about
Person 2. Person 1 responded, “Are you sure you want to make something out of
18
this now? Why not wait to see what [Person 2] does. You may be defending
yourself too much—raising new questions that will fuel new inquiries. This may
be a time to say less, not more.” STONE responded by telling Person 1 that
Person 2 “will take the 5th—but let’s hold a day.”
e. On multiple occasions, including on or about December 1, 2017, STONE told
Person 2 that Person 2 should do a “Frank Pentangeli” before HPSCI in order to
avoid contradicting STONE’s testimony. Frank Pentangeli is a character in the film
The Godfather: Part II, which both STONE and Person 2 had discussed, who
testifies before a congressional committee and in that testimony claims not to know
critical information that he does in fact know.
f. On or about December 1, 2017, STONE texted Person 2, “And if you turned over
anything to the FBI you’re a fool.” Later that day, Person 2 texted STONE, “You
need to amend your testimony before I testify on the 15th.” STONE responded, “If
you testify you’re a fool. Because of tromp I could never get away with a certain
[sic] my Fifth Amendment rights but you can. I guarantee you you are the one who
gets indicted for perjury if you’re stupid enough to testify.”
38. On or about December 12, 2017, Person 2 informed HPSCI that he intended to assert his
Fifth Amendment privilege against self-incrimination if required to appear by subpoena. Person 2
invoked his Fifth Amendment privilege in part to avoid providing evidence that would show
STONE’s previous testimony to Congress was false.
39. Following Person 2’s invocation of his Fifth Amendment privilege not to testify before
HPSCI, STONE and Person 2 continued to have discussions about the various investigations into
Russian interference in the 2016 election and what information Person 2 would provide to
19
investigators. During these conversations, STONE repeatedly made statements intended to
prevent Person 2 from cooperating with the investigations. For example:
a. On or about December 24, 2017, Person 2 texted STONE, “I met [the head of
Organization 1] for f[i]rst time this yea[r] sept 7 . . . docs prove that. . . . You should
be honest w fbi . . . there was no back channel . . . be honest.” STONE replied
approximately two minutes later, “I’m not talking to the FBI and if your smart you
won’t either.”
b. On or about April 9, 2018, STONE wrote in an email to Person 2, “You are a rat.
A stoolie. You backstab your friends-run your mouth my lawyers are dying Rip
you to shreds.” STONE also said he would “take that dog away from you,”
referring to Person 2’s dog. On or about the same day, STONE wrote to Person 2,
“I am so ready. Let’s get it on. Prepare to die [expletive].”
c. On or about May 21, 2018, Person 2 wrote in an email to STONE, “You should
have just been honest with the house Intel committee . . . you’ve opened yourself
up to perjury charges like an idiot.” STONE responded, “You are so full of
[expletive]. You got nothing. Keep running your mouth and I’ll file a bar
complaint against your friend [the attorney who had the ability to contact the head
of Organization 1].”
20
COUNT ONE
(Obstruction of Proceeding)
40. Paragraphs 1 through 39 of this Indictment are re-alleged and incorporated by reference as
if fully set forth herein.
41. From in or around May 2017 through at least December 2017, within the District of
Columbia and elsewhere, the defendant ROGER JASON STONE, JR., corruptly influenced,
obstructed, impeded, and endeavored to influence, obstruct, and impede the due and proper
exercise of the power of inquiry under which any inquiry and investigation is being had by either
House, and any committee of either House and any joint committee of the Congress, to wit:
STONE testified falsely and misleadingly at a HPSCI hearing in or around September 2017;
STONE failed to turn over and lied about the existence of responsive records to HPSCI’s requests
about documents; STONE submitted and caused to be submitted a letter to HPSCI falsely and
misleadingly describing communications with Person 2; and STONE attempted to have Person 2
testify falsely before HPSCI or prevent him from testifying.
All in violation of Title 18, United States Code, Sections 1505 and 2.
21
COUNTS TWO THROUGH SIX

(False Statements)
43. On or about September 26, 2017, within the District of Columbia and elsewhere, in a matter
within the jurisdiction of the legislative branch of the Government of the United States, the
defendant ROGER JASON STONE, JR., knowingly and willfully made and caused to be made
materially false, fictitious, and fraudulent statements and representations, to wit:
Count False Statement
2 STONE testified falsely that he did not have

emails with third parties about the head of
Organization 1, and that he did not have any
documents, emails, or text messages that refer
to the head of Organization 1.
3 STONE testified falsely that his August 2016

references to being in contact with the head of
Organization 1 were references to
communications with a single “go-between,”
“mutual friend,” and “intermediary,” who
STONE identified as Person 2.
4 STONE testified falsely that he did not ask the

person he referred to as his “go-between,”
“mutual friend,” and “intermediary,” to
communicate anything to the head of
Organization 1 and did not ask the
intermediary to do anything on STONE’s
behalf.
5 STONE testified falsely that he and the person

he referred to as his “go-between,” “mutual
friend,” and “intermediary” did not
communicate via text message or email about
Organization 1.
6 STONE testified falsely that he had never

discussed his conversations with the person he
referred to as his “go-between,” “mutual
22
Count False Statement
friend,” and “intermediary” with anyone

involved in the Trump Campaign.
All in violation of Title 18, United States Code, Sections 1001(a)(2) and 2.
COUNT SEVEN
(Witness Tampering)
45. Between in or around September 2017 and present, within the District of Columbia and
elsewhere, the defendant ROGER JASON STONE, JR., knowingly and intentionally corruptly
persuaded and attempted to corruptly persuade another person, to wit: Person 2, with intent to
influence, delay, and prevent the testimony of any person in an official proceeding.
All in violation of Title 18, United States Code, Section 1512(b)(1).
________________________
Robert S. Mueller, III
Special Counsel
U.S. Department of Justice
A TRUE BILL:
________________________
Foreperson
23
Date: January 24, 2019
24
EXHIBIT 2
UNITED STATES DISTRICT COURT

____________________________________
)
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. ) Case No.: 1:19-CR-00018-ABJ
)
ROGER J. STONE, JR., )
)
Defendant. )
___________________________________ )
MOTION FOR LEAVE TO FILE AMICI CURIAE BRIEF
Movant Dr. Jerome Corsi (“Dr. Corsi”) through counsel, hereby moves this Court for
leave to file an amici curiae brief in support of entry of an order pursuant to Local Criminal Rule
57.7(c), or colloquially, a “gag order.”
Dr. Corsi’s amicus brief, attached hereto as Exhibit 1, sets forth the compelling reasons
why a “gag order” is necessary in this case, as he is named as Person 1, a material witness, in
Defendant Roger Stone’s (“Defendant Stone”) indictment. Defendant Stone has engaged in a
public relations campaign to defame, smear, intimidate and threaten both Dr. Corsi and his
counsel, Mr. Larry Klayman, which is the same conduct that he was indicted for in the first
place. Because Defendant Stone’s defamation, witness tampering, intimidation, and threats with
regard to Dr. Corsi and his counsel Mr. Klayman are not technically part of this criminal
prosecution, Dr. Corsi’s interests and position are not adequately represented by any party. Dr.
Corsi’s amicus brief will aid this Court in ruling upon the entry of an order pursuant to LCrR
57.7(c)
The United States has taken no position with regard to filing of an amicus brief, and
1
counsel for Defendant Stone has not substantively responded to Dr. Corsi’s request for consent.
Dated: February 8, 2019 Respectfully submitted,
/s/ Larry Klayman ____

Larry Klayman, Esq.
KLAYMAN LAW GROUP, PA
D.C. Bar No:
Washington, DC 20006
Tel: 310-595-0800
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was filed
electronically and served through the court’s ECF system to all counsel of record or parties on
February 8, 2019
/s/ Larry Klayman

Larry Klayman, Esq.
2
[SUB]EXHIBIT 1
UNITED STATES DISTRICT COURT

____________________________________
)
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. ) Case No.: 1:19-CR-00018-ABJ
)
ROGER J. STONE, JR., )
)
Defendant. )
___________________________________ )
AMICI CURIAE BRIEF OF DR. JEROME CORSI
Under Local Criminal Rule 57.7(b)(1):
[i]t is the duty of the lawyer or law firm not to release or authorize the release of
information or opinion which a reasonable person would expect to be
disseminated by means of public communication, in connection with pending or
imminent criminal litigation with which the lawyer or the law firm is associated,
if there is a reasonable likelihood that such dissemination will interfere with a fair
trial or otherwise prejudice the due administration of justice.
Furthermore, LCrR 57.7(c), which offers additional specific guidance with regard to highly
publicized cases - which this instant case certainly qualifies as – grants the Court with authority
to issue a “special order governing such matters as extrajudicial statements by parties, witnesses
and attorneys likely to interfere with the rights of the accused to a fair trial by an impartial jury.”
As set forth in Gentile v. State Bar of Nevada, 501 U.S. 1030, 1075 (1991):
The limitations are aimed at two principal evils: (1) comments that are likely to
influence the actual outcome of the trial, and (2) comments that are likely to
prejudice the jury venire, even if an untainted panel can ultimately be found. Few,
if any, interests under the Constitution are more fundamental than the right to a
fair trial by “impartial” jurors, and an outcome affected by extrajudicial
statements would violate that fundamental right.
Here, Defendant Roger Stone (“Defendant Stone”) has already begun a public relations
1
campaign meant specifically to influence the outcome of his upcoming trial and which are meant
to prejudice the jury venire. Defendant Stone is doing so by engaging in witness tampering,
defamation, and intimidation and coercion with regard to Dr. Corsi, who is named as Person 1 in
Defendant Stone’s indictment. As such, Dr. Corsi will likely subpoenaed to be called as a
material witness in Defendant Stone’s upcoming trial. Again he is Person 1 in the Mueller
Indictment.
Defendant Stone is attempting to smear, defame, and discredit, tamper and threaten Dr.
Corsi so that when Dr. Corsi is called as a witness, the jurors will have a false impression of Dr.
Corsi as a liar, perjurer, and alcoholic. This would, obviously, improperly and unethically benefit
Defendant Stone. In fact, Defendant Stone’s targeted efforts to defame, coerce, intimidate and
threaten Dr. Corsi have resulted in a lawsuit filed in the U.S. District Court for the District of
Columbia, which is attached hereto as Exhibit A and incorporated by reference.
Should this Court have any doubt as to Defendant Stone’s improper motivations and
already implemented and continuing designs to taint the jury venire, the content and article
written by Sara Murray and Sam Fossum titled, Roger Stone, facing gag order, launches
counterattack, should put any such doubts to bed. Exhibit B. It is only one of many such analyses
and accounts. It is clear that Defendant Stone’s strategy will be to use the media and publicity to
argue his case and to try to get public sentiment on his side, as well as to tamper with witnesses
like Dr. Corsi, which is exactly the type of conduct that LCrR 57.7 was meant to preclude.
Accordingly, Movant Dr. Corsi respectfully requests that this Court issue an order
pursuant to LCrR 57.7(c) ordering Defendant Stone and his counsel from making statements to
the media or in public settings that pose a substantial likelihood of material prejudice to this case
and which in the context of Stone himself and in their ferocity also amount to witness tampering
2
and obstruction of justice. See Exbibit A – Corsi Complaint.
Dated: February 8, 2019 Respectfully submitted,
/s/ Larry Klayman ____

Larry Klayman, Esq.
KLAYMAN LAW GROUP, PA
D.C. Bar No: 334581
Washington, DC 20006
Tel: 310-595-0800
3
[SUB]EXHIBIT A
See
EXHIBIT B
2/8/2019 RogerDocument
Case 1:19-cv-00656 Stone, facing gag1
order,Filed
launches counterattack - CNNPolitics
03/07/19 Page 58 of 109
Roger Stone, facing gag order, launches

counterattack
By Sara Murray and Sam Fossum, CNN
Updated 6:30 PM ET, Thu February 7, 2019
Washington (CNN) — In the days since a federal judge warned Roger Stone that he could soon face a gag order,
Stone has peddled conspiracy theories, claimed he can't get a fair trial and criticized the judge.
"This is a lynching. This is a legal lynching of me," Stone said in a recent interview on the fringe right-wing website
Infowars.
Stone was arrested last month in a pre-dawn raid and charged with obstruction of justice, making false statements
and witness tampering as part of special counsel Robert Mueller's Russia investigation. On Friday, federal
prosecutors and Stone's legal team are due to submit briefs on the merits of a gag order.
But rather than toning down his rhetoric, Stone appears to be abiding by the principles he espouses in his books.
For instance, Stone's Rule #81: "Admit Nothing; Deny Everything; Launch Counterattack."
It's a dubious legal strategy.
"I would say that it's a terrible idea for Stone to be doing this," said CNN legal analyst Shan Wu. "I can't imagine a
worse idea."
Judge Amy Berman Jackson informed Stone last week that she was considering a gag order. She was quick to
put similar restrictions on former Trump campaign chairman Paul Manafort's case, which she is also presiding over
in Washington. Jackson, an appointee of President Barack Obama, said she was cognizant of Stone's First
Amendment right to free speech, but she wanted to protect his right to a fair trial and ensure it was possible to
select an unbiased jury.
Stone's response, delivered via an Instagram post this week: "I will continue to defend myself unless an Obama
appointed judge decides to suspend my first amendment rights." In another post, Stone exclaimed, "Fair Trial in
DC? Impossible."
Stone, in his public diatribes, has claimed he is being targeted because he works for Infowars and supported
Trump. And he has continued his long tradition of hyping fact-free conspiracy theories.
In one Instagram post, Stone is shaking hands William Binney, a former National Security Agency o cial who has
turned into a vocal critic of the agency. "Bill Binney explained to me why the forensic evidence shows the DNC was
never hacked by anyone including the Russians," Stone wrote.
US intelligence agencies have concluded Russian intelligence hacked the DNC and other top Democrats, and used
platforms like WikiLeaks to disseminate the stolen material.
Stone concluded his post with a series of hashtags including "#sethrich."
Seth Rich was a Democratic National Committee sta er who was fatally shot in Washington in 2016. Police said
evidence indicates Rich was the victim of a robbery gone wrong. But far-right activists and news organizations
spread a conspiracy theory -- with no evidence -- that Rich was killed for leaking a trove of DNC emails to
WikiLeaks.
Both Fox News and the Washington Times ended up retracting stories based on the murder-as-leaking-retribution
conspiracy plot, but the lore has lived on, to the devastation of Rich's family.
https://www.cnn.com/2019/02/07/politics/roger-stone-gag-order-counterattack/index.html 1/3
order,Filed
03/07/19 Page 59 of 109
As for Stone, he recently settled a lawsuit unrelated to the Mueller probe in which he admitted to making false
statements on Infowars about a Chinese businessman and apologized for his commentary.
Stone's attorney and Mueller's o ce declined to comment.
Prior legal woes aside, Stone's eagerness to discuss his case publicly -- and in colorful fashion -- could make the
judge more inclined to put a gag order on the case.
Stone and his attorneys have vowed to fight any such e ort and are expected to make the case that Stone's
livelihood depends on his ability to speak freely.
"I make a living writing and speaking," Stone argued in a recent Infowars appearance. "So they would be depriving
me of making a living if I am entirely gagged."
Jackson appears to have anticipated that defense. In court last Friday, the judge said she was only considering
limiting Stone's ability to talk about the case.
" e would still be free to discuss foreign relations, immigration or Tom Brady," Jackson said.
If she does crack down on public comments on the case, Stone's legal team could also appeal the move. Last
year, Stone added First Amendment and constitutional law expert Bruce Rogow to his legal team.
rogerjs…
40.2k followers
View More on Instagram
Stone may have a solid legal premise for an appeal, Wu said, although most defendants consider it a risky move.
"Most defendants don't want to do that because they don't want to run afoul of the judge," Wu said. " e doesn't
care."
order,Filed
03/07/19 Page 60 of 109
Indeed, Stone is still racking up appearances and using nearly all of them to hammer the tactics used in the pre-
dawn raid at his Florida home.
"This was a show of force, this was something you would expect from Nazi ermany or Soviet Russia. It was
chilling," Stone told Infowars.
Stone has also compared the law enforcement presence the morning of his arrest to the forces deployed against
drug lord Joaqu n uzm n, known as "El Chapo," and Osama bin Laden, the former al aeda leader who was
killed by US Special Forces in a 2011 raid.
Stone's vocal complaints even sparked a response from ex-convict and former football star O.J. Simpson, who
drew on his own experience with FBI raids, according to a video posted on celebrity news website TM .
"The FBI can be wrong," Simpson said, "But to try to compare to El Chapo and Bin Laden? ey man, Bin Laden
was carried out in a bag, not walked out in handcu s."
Simpson's parting words for Stone: "Man up. Stop crying."
EXHIBIT 3
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DR. JEROME CORSI, Individually

Denville, NJ, 07834
Plaintiff
v. Case Number:
ROGER STONE, Individually COMPLAINT

4300 Bayview Drive
Fort Lauderdale, FL, 33308
Defendant.
INTRODUCTION
Plaintiff, DR. JEROME CORSI (“Plaintiff” or “Corsi”) hereby files this action against
ROGER STONE (“Defendant Stone”) for Defamation, Intentional Infliction of Emotional
Distress and Assault
1.! This Court has diversity jurisdiction over this case pursuant to 28 U.S.C. § 1332,
as the parties are completely diverse in citizenship and the amount in controversy exceeds
$75,000.
2.! Venue is proper pursuant to 28 U.S.C. § 1391(b)(2), (3) in that a substantial part
of the events or omissions giving rise to Plaintiff Corsi’s claims arose herein.
THE PARTIES
3.! Plaintiff, Dr. Jerome Corsi, is an author and political commentator who publishes
works in this judicial district and nationwide. Plaintiff Corsi is a citizen of New Jersey.
4.! Defendant, Roger Stone, is an individual and a citizen of Florida and a resident of
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Fort Lauderdale, Florida. Defendant Stone was recently indicted by Special Counsel Robert Mueller
as part of the alleged “Russian Collusion’ investigation. His address is 4300 Bayview Drive, Fort
Lauderdale, FL, 33308
GENERAL ALLEGATIONS
5.! Defendant Stone was recently indicted by Special Counsel Robert Mueller
(“Mueller Indictment”) as part of his “Russian Collusion” investigation for the alleged crimes of
perjury, witness tampering and obstruction of justice. The indictment comprises seven different
felony counts. See Exhibit 1 – Mueller Indictment. Importantly, Plaintiff Corsi was not accused
of any wrongdoing or illegality in the Mueller Indictment, in which he named as Person 1, a
material witness to the alleged crimes committed by Stone.
6.! Specifically, the seven count Mueller Indictment against Defendant Stone
involves alleged lying under oath - that is, perjury - witness tampering and obstruction of justice
by threatening to kill a material witness, Randy Credico (“Credico”) and his dog if Credico did
not lie to government authorities concerning his involvement with Roger Stone. Credico is
Person 2 in the Mueller Indictment of Defendant Stone. Id. Person 1 in this Mueller Indictment is
Plaintiff Corsi.
7.! Even before Defendant Stone was indicted, he began a public relations campaign
in this district, nationally and internationally to smear, intimidate and threaten Plaintiff Corsi, a
material witness in the “Russian Collusion” investigation. Plaintiff Corsi is listed as Person 1 in
the Mueller Indictment and was not indicted along with Defendant Stone, as he testified
truthfully to the grand jury and in interviews.
8.! To the contrary, Plaintiff Corsi has never defamed or disparaged Defendant Stone.
9.! Defendant Stone knew that he was going to be indicted, and therefore began this
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public relations campaign to smear, defame, intimidate and threaten Plaintiff Corsi, even before
his actual indictment on January 25, 2019, in order to try to influence public opinion and Special
Counsel Robert Mueller – by trying to attribute guilt to Plaintiff Corsi and not him - as well as to
try to raise money for his legal defense. This pattern and practice of defaming, intimidating and
threatening Plaintiff Corsi, and his legal counsel, is ongoing, so Plaintiff Corsi reserves the right
to amend this Complaint.
10.! Defendant Stone likes to portray himself as Mafia, frequently making reference to
Mafia figures who he admires, as well as other unsavory types who have been alleged to have
engaged in unethical and/or illegal behavior. He frequently makes reference to his heroes being
Hyman Roth in the ‘Godfather,” who was the movie version of Meyer Lansky, and Roy Cohn,
not to mention, Richard Nixon, for his role in Watergate. In this regard, after Stone was indicted
he held a press conference on the courthouse steps of the federal courthouse in Ft. Lauderdale,
where he was booked, with his arms defiantly in the air in the “victory’ pose used by Nixon after
he resigned in disgrace as a result of the Watergate scandal. At the time, Stone had been
employed by a Nixon group called CREEP, or the Committee to Reelect the President.
Defendant Stone even has a large tattoo of Richard Nixon affixed to his back. Thus, given his
admiration for persons such as these, particularly Mafia figures, his actions as pled herein can be
taken as threats, as well as being defamatory. And, Plaintiff Corsi is 72 years old. Defendant
Stone’s intentional infliction of emotional distress and coercion and threats are intended to try
even cause Plaintiff Corsi to have heart attacks and strokes, in order that Plaintiff will be unable
to testify at Stone’s criminal trial. Tellingly, Defendant Stone threatened kill a material witness
and his dog, Credico, Person 2 in the Mueller Indictment, “Mafia style.” Defendant Stone also
fashions himself and indeed has the reputation, at a minimum, as being the preeminent “dirty
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trickster.” See “Get Me Roger Stone” on Netflix.
11.! Plaintiff Corsi has been named as a material witness to Defendant Stone’s
upcoming prosecution, which has prompted Defendant Stone to try to intimidate, coerce and
threaten Plaintiff Corsi by defaming him and threatening him with physical violence, which is
ironically what he was criminally indicted for, in part.
12.! By defaming Plaintiff Corsi, Defendant Stone is hoping to not only intimidate
Plaintiff Corsi to severely harm and damage his reputation, but also to coerce and threaten
Plaintiff Corsi to testify falsely if subpoenaed to be called as a material witness in Defendant
Stone’s ensuing criminal trial. He is also trying divert funds away from Plaintiff Corsi’s legal
defense fund, while boosting his own legal defense fund.
13.! Defendant Stone has also used and continues to employ surrogates, either out in
the open or secretly, to defame Plaintiff Corsi, such as his “friend” Michael Caputo, Alex Jones
and J. Owen Stroyer of InfoWars, Cassandra Fairbanks, and reporter Chuck Ross of The Daily
Caller, to name just a few. More surrogates will be identified during discovery and they may be
joined, with leave of court to amend this Complaint, as defendants herein. The use of surrogates
is consistent with Defendant Stone’s reputation as a “dirty trickster” who works as well under
“cover of darkness” to harm and damage others who he sees for whatever reason as adversaries,
political or otherwise as in the case of Plaintiff Corsi. Plaintiff Corsi is not Defendant Stone’s
adversary, as he simply is committed as Person 1 in the Mueller Indictment to testify truthfully if
subpoenaed to testify at Stone’s criminal trial.
14.! Defendant Stone is no stranger to defamation lawsuits. As reported by Splinter
News, Defendant Stone was forced to - as part of a settlement in another defamation suit –
apologize in newspapers and on social media for lying about Chinese Businessman Guo Wengui
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on InfoWars, after having falsely published that Mr. Wengui is a “turncoat criminal who is
convicted of crimes here and in China.”1
15.! Defendant Stone has therefore engaged in illegal witness tampering and
intimidation, in violation of 18 U.S.C. § 1512 by virtue of the defamatory and threatening acts
and practices as alleged herein. Not coincidentally, this was what largely he was indicted for by
Special Counsel Robert Mueller.
DEFENDANT STONE’S DEFAMATORY STATEMENTS
16.! Before Defendant Stone was indicted, on or about January 18, 2019, he appeared
on InfoWars, where he made several false, misleading and defamatory statements in this district,
nationally and internationally regarding Plaintiff Corsi (the “InfoWars Video”).2 The same video
was published on Defendant Stone’s YouTube channel, “Stone Cold Truth,” on January 18,
2019.3
17.! At 2:09 in the InfoWars Video, Defendant Stone falsely publishes that Plaintiff
Corsi was “fired from World Net Daily.”
18.! At 2:27 in the InfoWars Video, Defendant Stone falsely and misleadingly
publishes that, “He (Corsi) was perfectly willing to lie, to perjure himself saying that a memo
that he had wrote me was written on the 30th for the purposes of cover-up…. which is further
proof that Jerry lied under oath.”
publishes, “and then states that I knew about John Podesta’s emails being stolen in advance, the
only proof of that is Jerry’s feeble alcohol affected memory – it’s a lie….”
1
Sophie Weiner, Roger Stone Lied About a Chinese Businessman on InfoWars and Now He Has
to Tell Everyone, Splinter News, Dec. 17, 2018, available at: https://splinternews.com/roger-
stone-lied-about-a-chinese-businessman-on-infowar-1831162926
2
3
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publishes that “Jerry was prepared to stab a principle Trump supporter in the back, he was
perfectly prepared to bear false witness against me, even though I had done nothing in my entire
life other than help him.”
publishes that “all I ever did was show Jerry Corsi friendship and support and try to help him and
his family and what I get is Judas Iscariot, the willingness to testify against me and help the deep
state bury me….and then he makes up this story about helping me formulate a cover story.”
22.! At 6:26 in the InfoWars Video, Defendant Stone falsely publishes that “you can
always tell when Jerry Corsi is lying because his lips are moving….”
23.! Defendant Stone made these false, misleading and defamatory statements with
malice and with full knowledge that they were false and misleading, and/or at a minimum, with a
reckless disregard for its truthfulness. These statements falsely and misleadingly state that
Plaintiff Corsi was fired from World Net Daily, that he committed perjury (a federal offense),
and that he is an untruthful person.
24.! On January 2, 2019, Defendant Stone published an article on www.infowars.com
titled “ROGER STONE BELIEVES JEROME CORSI WORKS FOR MUELLER4” in which
Defendant Stone falsely, misleadingly, and maliciously writes, “Before you decide that Corsi is a
hero you should be well aware of the fact that the good doctor was prepared to bear false witness
against others in the Trump orbit if he thought it would save his own skin.”
reckless disregard for its truthfulness. These statements falsely and misleadingly state that
4
https://www.infowars.com/roger-stone-the-treachery-of-jerome-corsi/
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Plaintiff Corsi committed perjury (a federal offense), and that he is an untruthful person.
26.! In another appearance on InfoWars, which was posted to YouTube5 on January
17, 2019, Defendant Stone at 6:22 falsely and misleadingly publishes that “He [Corsi] was
perfectly willing to bear false witness against me on multiple points that are complete
fabrications.”
27.! In another appearance on InfoWars, which was posted to YouTube6 on January
24, 2019, Defendant Stone at 5:58 falsely and misleadingly publishes that “the good doctor
[Corsi] has told a number of lies. In fact, he’s starting to conflate his lies…. he was perfectly
willing to lie about me…. but now lying about Alex Jones, lying about InfoWars, lying about Dr.
Jones, who’s one of the nicest, gentlest, sweetest, most honest men I have ever met, it’s beyond
the pale…. Jerry Corsi can no longer be believed.”
28.! In the same appearance, Defendant Stone at 8:34 falsely and misleadingly
publishes that, “I think you’ve [Corsi] been deep state from the beginning. Your whole birther
thing is used as a club to destroy conservatives….I look forward to our confrontation. I will
demolish you. You’re a fraudster, out of your alcoholic haze you have made up lies about David
Jones and Alex Jones and Roger Stone and now I suspect they want you to lie about the
President.” This is clearly a threat, as well as being defamatory. It is akin to the threats against
Person 2 in the Mueller Indictment, Randy Credico, who Defendant Stone, as set forth in the
Mueller Indictment, based on Stone’s own words contained in his own documentary evidence,
threatened kill along with Credico’s dog.
5
https://www.youtube.com/watch?v=GJd8YBDvm1Q
6
https://www.youtube.com/watch?v=fXUlJZRxe6E
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reckless disregard for their truthfulness. These statements falsely and misleadingly state that
Plaintiff Corsi committed perjury (a federal offense), is an untruthful person, and is an alcoholic.
They also contain threats against Plaintiff Corsi.

Defamation
30.! Plaintiff re-alleges and incorporates by reference the allegations in the preceding
31.! Defendant Stone published malicious, false, misleading and defamatory
statements of and concerning Plaintiff Corsi in this judicial district, nationwide, and worldwide.
32.! These false and misleading statements were published with malice, as Defendant
Stone knew that they were false and misleading, or at a minimum acted with a reckless disregard
for the truth.
33.! Plaintiff Corsi has been severely harmed and damaged by these false and
misleading statements because they subjected him to hatred, distrust, ridicule, contempt, and
disgrace.
34.! Plaintiff Corsi has been damaged by these false and misleading statements
because they injured Plaintiff Corsi in his profession and business as a journalist and author,
whose credibility is the most important trait, as well as severely injured and damaged him
personally.

Defamation Per Se
36.! Defendant Stone, as alleged herein, published numerous false, misleading and
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defamatory statements to severely harm and damage Plaintiff Corsi, which were republished
elsewhere, and through surrogates, which publish the falsity that Plaintiff Corsi has committed
crimes, including perjury, and engaged in moral turpitude in the form of alcoholism, as set forth
in the preceding paragraphs.
37.! These false, misleading and defamatory statements were published in this district
and on the internet and elsewhere, domestically and for the entire world to see and hear and
specifically Stone published false and misleading facts, inter alia, that Plaintiff’s conduct,
characteristics or a condition is incompatible with the proper exercise of his lawful business,
trade, profession or office.
Stone knew that they were false and misleading, and/or at a minimum acted with a reckless
disregard for the truth.
39.! This statements are per se defamatory because they falsely and misleadingly
publish that Plaintiff Corsi committed perjury, which is a federal offense and felony. Defamation
per se gives rise to the presumption that severe harm and damage has arisen by virtue of the false
and misleading statements.
40.! These false, misleading, and defamatory statements are defamatory per se and
these false and misleading statements severely harmed and damaged Plaintiff Corsi in his
profession and business as a journalist and author, whose credibility is the most important trait,
as well as personally.

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42.! Defendant Stone published numerous false, misleading and defamatory
statements about Plaintiff Corsi, as set forth in the preceding paragraphs.
43.! These false, misleading and defamatory statements were published on the internet
and published and republished elsewhere in this district, domestically and for the entire world to
see and hear.
Stone knew that they were false and misleading, and/or at a minimum acted with a reckless
disregard for the truth.
45.! These statements created the false and misleading implication that Plaintiff Corsi
is dishonest, committed perjury and is an alcoholic, among other false and misleading statements
as pled in the preceding paragraphs.
46.! Plaintiff Corsi has been severely harmed and damaged by these false and
misleading statements because they subject him to hatred, distrust, ridicule, contempt, and
disgrace.
47.! Plaintiff Corsi has been damaged by these false and misleading statements
because the statements severely harmed and damaged Plaintiff Corsi in his profession as a
journalist and author, whose credibility is the most important trait, as well as personally.
FOURTH CAUSE OF ACTION

Intentional Infliction of Emotional Distress
49.! Defendant Stone engaged in extreme and outrageous conduct by threatening
Plaintiff Corsi, in concert with Stone, who has made death threats to at least one witness
involved in Special Counsel Mueller’s Russian collusion investigation, Person 2 Randy Credico.
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50.! Defendant Stone knowingly and intentionally threatened Plaintiff Corsi, in a
manner similar to other death threats he made to at least one material witness, involved in
Special Counsel Mueller’s Russian collusion investigation, such as Randy Credico, Person 2 in
the Mueller Indictment.
51.! Defendant Stone’s extreme and outrageous conduct directly caused Plaintiff Corsi
severe emotional distress and resulting severe harm and damage.
FIFTH CAUSE OF ACTION

Assault
53.! Defendant Stone placed Plaintiff Corsi in apprehension of an imminent harmful or
offensive contact and physical harm and death, by coercing and threatening Plaintiff Corsi, in a
similar manner he has used to make death threats to at least one material witness involved in
Special Counsel Mueller’s Russian collusion investigation, such as Person 2 in the Mueller
Indictment, Randy Credico.
54.! The threats issued by Defendant Stone are credible, as he portrays himself as a
“mafia” figure, as set forth above.
55.! Plaintiff Corsi did not consent to Defendant Stone’ conduct.
56.! As a direct and proximate result of Defendant Stone’s wrongful conduct, Plaintiff
Corsi suffered conscious pain, suffering, severe emotional distress and the fear of imminent
serious bodily injury or death, and other mental and physical injuries, and Plaintiff was severely
harmed and damaged thereby.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Dr. Jerome Corsi prays for judgment against Defendant Stone as
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follows:
a.! Awarding Plaintiff Corsi compensatory including actual, consequential, incidental and
punitive damages for malicious tortious conduct in an amount to be determined at trial and in
excess of $25, 000,000 U.S. Dollars. While Stone feigns being financially destitute as a result of
his legal problems and uses this to raise money for his legal defense fund, on information and
belief he is wealthy, perhaps hiding his wealth in overseas bank accounts.
b.! Awarding Plaintiff Corsi attorney’s fees and costs.
c.! Granting any further relief as the Court deems appropriate including preliminary and
permanent injunctive relief, as well as the entry of a gag order against Defendant Stone in his
criminal prosecution before this Court in order that he be prevented from intimidating, coercing
and threatening material witnesses, such as Plaintiff Corsi, who are likely to be subpoenaed to
testify at his trial. In this regard, Plaintiff Corsi will also, with leave of court requested, file an
amicus brief arguing for a gag order on Defendant Stone in the related criminal case United
States of America v. Stone, 19-cr-18 (D.D.C).
Dated: February 7, 2019 Respectfully Submitted,
/s/ Larry Klayman

Larry Klayman, Esq.
D.C. Bar Number: 334581
Washington, DC, 20006
Telephone: (310)-595-0800
Counsel for Plaintiff
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FOR THE SOUTHERN DISTRICT OF FLORIDA
LARRY KLAYMAN, Individually
Plaintiff
v.
Case Number:
THOMAS J. FITTON, Individually
Defendant.
COMPLAINT FOR DEFAMATION
Plaintiff, LARRY KLAYMAN (“Plaintiff” or “Klayman”) hereby files this action against
THOMAS J. FITTON (“Defendant Fitton”) for Defamation, Defamation Per Se, and Defamation
by Implication.
1.! This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §
1332 under diversity of citizenship. The parties are citizens of different states and the amount in
controversy exceeds $75,000.
2.! Venue is proper pursuant to 28 U.S.C. § 1391(b)(2) as this is the judicial district
in which a substantial part of the events or omissions giving rise to the claim occurred.
THE PARTIES
3.! Plaintiff, Larry Klayman, is an individual and a citizen of Florida. Plaintiff is a
well-known private lawyer and conservative public interest advocate and litigator, as well as a
syndicated national radio talk show host on Radio America, his weekly show appropriately titled
“Special Prosecutor with Larry Klayman.” Plaintiff Klayman conceived of and founded both
Judicial Watch, Inc. and Freedom Watch, Inc. He is a former federal prosecutor of the Antitrust
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Division of the U.S. Department of Justice, where he was on the trial team that broke up the AT&T
monopoly.
4.! Defendant, Thomas Fitton, is an individual and a citizen of the District of Columbia,
whose address is 5245 42nd St NW, Washington, DC 20015. Defendant Fitton is the current
President of Judicial Watch, which was conceived of and founded by Plaintiff Klayman. He is not a
lawyer and at the time that Klayman left Judicial Watch on September 19, 2003 to run for the U.S.
Senate in Florida, Defendant Fitton had not graduated from college. When Plaintiff Klayman hired
him years earlier as an assistant, he lied to Klayman that he had graduated from George Washington
University. Since then Defendant Fitton has had a book written for him by “ghost writer,” Ben
Shapiro, effectively claiming credit for Plaintiff Klayman’s accomplishments in conceiving of,
founding and running Judicial Watch for almost ten (10) years. Plaintiff Klayman was thus
conspicuously and maliciously written out of the history of Judicial Watch. The book is titled
“Corruption Chronicles” and remains on sale on the internet and in book stores. Defendant Fitton
has also falsely testified multiple times under oath that he does not know who founded Judicial
Watch, as he continues to try to spread the false narrative and impression he or someone other than
Klayman founded Judicial Watch, in order to boost his own standing in the conservative community
and elsewhere, as the expense of Plaintiff Klayman. In short, and regrettably Defendant Fitton, as
set forth below, is a ‘serial liar” and dishonest.
STANDING
5.! Plaintiff has standing to bring this action because he has been directly affected
and victimized by the unlawful conduct complained herein. His injuries are proximately related
to the conduct of Defendant Fitton, individually and working in concert with Roger Stone as set
forth below.
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FACTS
6.! Defendant Fitton has engaged in a pattern and practice of defaming Plaintiff
Klayman since Plaintiff’s voluntary departure from Judicial Watch, Inc. to run for the U.S.
Senate in Florida in 2003-2004.
7.! For instance, in 2013, a federal jury in the Southern District of Florida awarded
Plaintiff Klayman judgment in the sum of $181,000, including punitive damages against Judicial
Watch for having maliciously defamed Plaintiff. See Exhibit 1 – Jury Verdict and Judgment.
This jury verdict and judgment is final.
8.! Defendant Fitton is now conveniently and incredibly working with Roger Stone
(“Stone”) to again defame Plaintiff Klayman.
9.! Stone was recently indicted on seven (7) felony counts by Special Counsel Robert
Mueller (“Mueller Indictment”) as part of his “Russian Collusion” investigation for the alleged
crimes of perjury, witness tampering and obstruction of justice. See Exhibit 2 – Mueller
Indictment.
10.! Specifically, the seven count Mueller Indictment against Defendant Stone
involves alleged lying under oath - that is, perjury - witness tampering and obstruction of justice
by threatening to kill a material witness, Randy Credico (“Credico”) and his dog if Credico did
not lie to government authorities concerning his involvement with Roger Stone. Credico is
Person 2 in the Mueller Indictment of Defendant Stone. Id. Person 1 in this Mueller Indictment is
Dr. Jerome Corsi, another material witness, who is Plaintiff Larry Klayman’s client.
11.! Stone has since engaged in a public relations campaign to illegally smear,
intimidate, coerce and threaten Dr. Jerome Corsi (“Dr. Corsi”), a witness in the “Russian
Collusion” investigation, and who is being legally represented by Plaintiff Klayman.
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12.! Stone knew that he was going to be indicted, and therefore began this illegal
public relations campaign to smear and defame Dr. Corsi and his lawyer, Larry Klayman, even
before his actual indictment on January 25, 2019, in order to try to influence public opinion and
Special Counsel Robert Mueller – by illegally trying to attribute guilt to Dr. Corsi and not him -
as well as to try to raise money for his legal defense. This pattern and practice of defaming Dr.
Corsi and his lawyer Larry Klayman is ongoing, so Plaintiff reserves the right to amend this
Complaint. Stone has recently been sued by Dr. Corsi for defamation, intentional infliction of
emotional distress and assault.
13.! Dr. Corsi has been named as a material witness to Stone’s upcoming prosecution,
which has prompted Stone to try to intimidate, coerce and threaten Dr. Corsi by defaming him
and his defense counsel, Plaintiff Klayman, which is ironically what he has been indicted for.
And, the way to also “get to” Dr. Corsi is for Defendant Stone to also defame his lawyer,
Plaintiff Larry Klayman
14.! By defaming Dr. Corsi and Plaintiff Klayman, Defendant Fitton and Stone are
working in concert as joint tortfeasors hoping to not only intimidate Dr. Corsi and his counsel to
severely harm and damage their reputations, but also to coerce and threaten Dr. Corsi to testify
falsely if subpoenaed to be called as a material witness in Defendant Stone’s ensuing criminal
trial, as well as to impede and harm Dr. Corsi’s criminal defense. They are also acting in concert
to divert funds away from Dr. Corsi’s legal defense fund, while boosting Stone’s legal defense
fund.
15.! Before Defendant was indicted, on or about January 18, 2019, he appeared on
InfoWars, where he made several false, misleading and defamatory statements in this district,
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nationally and internationally regarding Plaintiff Klayman (the “InfoWars Video”).1 The same
video was published on Defendant Stone’s YouTube channel, “Stone Cold Truth,” on January
18, 2019.2
16.! At 1:30, Stone published, “He (Klayman) was ousted at Judicial Watch. Ask Tom
Fitton [the current president of Judicial Watch] why he left. He left because of a sexual
harassment complaint.”
17.! Stone made this false, defamatory statement at the direction of Defendant Fitton,
whom he attributes this false and defamatory statement to.
18.! Defendant Fitton knew that Plaintiff Klayman was not ousted at Judicial Watch as
a result of a sexual harassment complaint, but, in actuality, Plaintiff Klayman left Judicial Watch
on his own accord and voluntarily in order to run for U.S. Senate in Florida.
19.! Defendant Fitton with malice and/or a reckless disregard for the truth knew that
Plaintiff Klayman did not leave Judicial Watch as a result of a sexual harassment complaint.
20.! Defendant Fitton knowingly published this false and defamatory statement to
Stone, who in turn republished it during interviews which were broadcast by him and his
surrogates in this district, nationally and internationally for the entire world to hear and see. On
information and belief Fitton has also recently published, within the last two years up to the
present, this and other false and misleading statements to others to severely harm and damage
Plaintiff Klayman, such as to the Council for National Policy, the American Conservative Union,
the Scaife Foundation, other conservative organizations, groups and donors, and media
publications and television networks such as Fox News, to name just a few. As a non-lawyer
who currently runs Judicial Watch, Defendant Fitton feels competitive with Klayman, and as
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result of what in effect is an “inferiority complex” since he is a non-lawyer who tries to pass
himself in the media off as a lawyer and legal expert as the current head of Judicial Watch, thus
has engaged in a concerted campaign to severely damage and harm Klayman’s reputation,
professional and personal reputation, and family. By severely harming Plaintiff Klayman’s
reputation and standing in the legal, media and related communities, Defendant Stone’s
malicious intent is to boost his own reputation and standing at the expense of Klayman, who
conceived of, founded and successfully ran Judicial Watch for nearly ten (10) years, making it
the preeminent conservative public interest group fighting against corruption and for ethics and
justice in government and the legal profession.
21.! Defendant Fitton, in concert with Stone, have therefore also engaged in illegal
witness tampering of Dr. Corsi and his lawyer Plaintiff Klayman in violation of 18 U.S.C. § 1512
by virtue of the defamatory acts and practices as alleged herein.

Defamation
23.! Defendant Fitton published the malicious, false and defamatory statement that
Plaintiff Klayman was ousted at Judicial Watch due to a sexual harassment complaint to Stone,
who in turn, and in concert with Defendant Fitton, republished this false and defamatory
statement on the internet domestically, internationally and elsewhere for the entire world to see
and hear.
24.! This false and misleading statement was published with malice, as Defendant
Fitton knew that it was false and misleading, or at a minimum acted with a reckless disregard for
the truth.
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25.! Plaintiff Klayman has been severely harmed and damaged by this and other false
and misleading statements, more of which will be uncovered in discovery, because it subjected
him to hatred, distrust, ridicule, contempt, and disgrace.
26.! Plaintiff Klayman has been severely damaged by this false and misleading
statement because the malicious statement injured Plaintiff Klayman in his profession and
business as a public interest and private lawyer and nationally syndicated radio talk show host
who promotes ethics in government and the legal profession, as well as personally.

Defamation Per Se
paragraphs of the Complaint.
28.! Defendant Fitton published to Stone the malicious false, misleading and
defamatory statement that Plaintiff Klayman was ousted at Judicial Watch due to a sexual
harassment complaint, who in turn, and in concert with Defendant Fitton, republished this
malicious false and defamatory statement on the internet in this district, domestically and
internationally and elsewhere for the entire world to see and hear.
29.! Under Florida Law, “it is established…that an oral communication is
actionable per se - that is, without a showing of special damage - if it imputes to another (a) a
criminal offense amounting to a felony, or (b) a presently existing venereal or other loathsome
and communicable disease, or (c) conduct, characteristics or a condition incompatible with the
proper exercise of his lawful business, trade, profession or office, or (d) the other being a woman,
acts of unchastity.” Wolfson v. Kirk, 273 So. 2d 774, 777 (Fla. Dist. Ct. App. 1973).
30.! This false and misleading statement was published with malice, as Defendant
Fitton knew that it was false and misleading, or at a minimum acted with a reckless disregard for
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the truth.
31.! This malicious false, misleading and defamatory statement was published on the
internet in this district, domestically and internationally for the entire world to see and hear and
specifically Defendant Fitton published these malicious false and misleading “facts,” inter alia,
that Plaintiff’s conduct, characteristics or a condition is incompatible with the proper exercise of
his lawful business, trade, profession or office
32.! This malicious false and misleading statement is per se defamatory because it
falsely accuses Plaintiff Klayman of being ousted from Judicial Watch because of sexual
harassment - thereby falsely imputing a criminal and sexually related offense upon Plaintiff
Klayman – as well as being “ousted” as the chairman and general counsel of Judicial Watch
because of an actual sexual harassment complaint, as well as the other false and misleading
published statements alleged herein. To the contrary, on information and belief Fitton himself
hypocritically had and may continue to have an “intimate personal relationship” with another
director and member of the board of Judicial Watch, Paul Orfanedes, which on information and
belief may constitute sexual harassment, as Defendant Fitton is Orfanedes’ superior as a result of
Fitton being the president of Judicial Watch. Defendant Fitton also sits on the board of directors
along with Orfanedes, one of only three (3) directors, all of whom are also employed by Judicial
Watch. By maliciously defaming Plaintiff Klayman, Defendant Fitton intended and intends to
deflect attention away from his issues, vulnerabilities and conduct.
33.! This false, misleading, and defamatory statement concerning Plaintiff Klayman is
defamatory per se and this false and misleading statement, and others which will be uncovered in
discovery, severely harmed and damaged Plaintiff Klayman in his profession and business as a
lawyer and advocate and as a nationally syndicated radio talk show host, as they concern conduct
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and characteristics incompatible with being a lawyer and radio talk show host who promotes
ethics in government and the legal profession. Damage is presumed by law when defamation per
se is shown.

35.! Defendant Fitton published to Stone the false, misleading and defamatory
statement that Plaintiff Klayman was ousted at Judicial Watch due to a sexual harassment
complaint, who in turn, and in concert with Defendant Fitton, republished this false and
defamatory statement on the internet in this district, domestically and internationally and
elsewhere for the entire world to see and hear.
36.! This false, misleading and defamatory statement was published with malice, as
Defendant Fitton knew that it was false, or at a minimum acted with a reckless disregard for the
truth.
37.! This malicious statement created the false and misleading implication that
Plaintiff Klayman has engaged been subject to a sexual harassment complaint and was ousted
from Judicial Watch for this reason and committed criminal sexual offenses, as well as other
matters of moral turpitude as set forth in this Complaint.
38.! Plaintiff Klayman has been severely harmed damaged by this published statement
because it subjected him to hatred, distrust, ridicule, contempt, and disgrace.
39.! Plaintiff Klayman has been damaged by malicious this false and misleading
statement, and others which will be disclosed during discovery, because the statements severely
harmed and damaged Plaintiff Klayman in his profession and business as a public advocate and
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as a syndicated radio talk show host who promotes ethics in government and the legal profession,
and personally, as pled herein.
40.! On information and belief Defendant Fitton’s defamatory conduct, in concert with
Stone and individually, is on-going and as more defamatory conduct is uncovered through
discovery and otherwise, this defamatory conduct will be subject to a motion to amend this
Complaint.
41.! Defendant Fitton’s malicious intent to severely harm and damage Plaintiff
Klayman is largely based on an “inferiority complex” that he is not a lawyer and thus he feels
competitive with Klayman. Indeed, at the time that Plaintiff left Judicial Watch on September 19,
2003, to run for the U.S. Senate in Florida Fitton had not graduated from college, his having lied
to Klayman that he did have a bachelor’s degree from George Washington University. This false
statement fraudulently induced Klayman to offer him a job at the public interest organization. As
a non-lawyer Fitton inappropriately does not have the background and expertise to now head
Judicial Watch and make expert legal commentary on television, radio, the internet and in print,
as Judicial Watch was conceived to in effect be and is a public interest law firm.
42.! Plaintiff Klayman has steadfastly demanded that Defendant Fitton refrain from
making the malicious false and misleading statement as alleged herein, but he has refused and
Fitton has also refused to correct this and other false and misleading statements in the past,
regrettably necessitating the need for this and other legal complaints. The false and misleading
statement published in concert with Stone has since been republished by others to severely harm
and damage Plaintiff Klayman and his client Dr. Corsi. Defendant Fitton’s campaign to severely
harm and damage Plaintiff Klayman is maliciously intended to boost his own standing at the
expense of Plaintiff Klayman in the conservative community, media and with donors and
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elsewhere and it continues unabated.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Larry Klayman prays for judgment against Defendant Fitton as
follows:
a.! Awarding Plaintiff Klayman compensatory including actual, consequential, incidental
and punitive damages for malicious tortious conduct as alleged herein in an amount to be
determined at trial and in excess of $35, 000,000 U.S. Dollars.
b.! Awarding Plaintiff Klayman attorney’s fees and costs.
c.! Granting any such further relief as the Court deems appropriate including preliminary and
permanent injunctive relief.
PLAINTIFF KLAYMAN DEMANDS A JURY TRIAL ON ALL COUNTS SO TRIABLE.
Dated: February 11, 2019 Respectfully Submitted,
/s/ Larry Klayman

Larry Klayman, Esq.
FL Bar No. 246220
c/o 2020 Pennsylvania Ave., N.W.
Suite 800
Washington, D.C. 20006
Telephone: (310) 595 - 0800
11
Case 1:19-cv-00656 1-1 Entered
Document 1 Filedon03/07/19
FLSD Docket
Page02/11/2019
100 of 109 Page 1 of 1
;35=
-AINX
EXHIBIT 6
Larry Klayman, founder of Judicial Watch and of the European Union in its Competition
Freedom Watch, is known for his strong Directorate in Brussels, Belgium. During law
public interest advocacy in furtherance of school, Larry also worked for the U.S.
ethics in government and individual freedoms International Trade Commission in
and liberties. During his tenure Washington, D.C.
at Judicial Watch, he obtained
a court ruling that Bill Clinton Larry speaks four languages—
committed a crime, the first English, French, Italian, and
lawyer ever to have done so Spanish—and is an
against an American president. international lawyer, among his
Larry became so famous for many areas of legal expertise
fighting corruption in the and practice.
government and the legal
profession that the NBC hit The author of two books, Fatal
drama series "West Wing" Neglect and Whores: Why and
created a character after him: How I Came to Fight the
Harry Klaypool of Freedom Establishment, Larry has a
Watch. His character was third book in the works dealing
played by actor John Diehl. with the breakdown of our
political and legal systems. His
In 2004, Larry ran for the U.S. current book, Whores, is on
Senate as a Republican in Florida's primary. now sale at WND.com, Amazon.com,
After the race ended, he founded Freedom BarnesandNoble.com, Borders.com, and all
Watch. major stores and booksellers.
Larry graduated from Duke University with Larry is a frequent commentator on television
honors in political science and French and radio, as well as a weekly columnist, on
literature. Later, he received a law degree from Friday, for WND.com. He also writes a regular
Emory University. During the administration blog for Newsmax called "Klayman's Court."
of President Ronald Reagan, Larry was a
Justice Department prosecutor and was on the Larry has been credited as being the
trial team that succeeded in breaking up the inspiration for the Tea Party movement. (See
telephone monopoly of AT&T, thereby "Larry Klayman - The One Man TEA Party,"
creating competition in the by Dr. Richard Swier, http://fwusa.org/KFA)
telecommunications industry.
Between Duke and Emory, Larry worked for Support the work of
U.S. Senator Richard Schweiker (R-Pa.) Freedom Watch at
during the Watergate era. He has also studied www.FreedomWatchUSA.org
abroad and was a stagiaire for the Commission
EXHIBIT 7
2/2 /2019 istrict
Case 1:19-cv-00656 Document 1 of Filed
Colum ia03/07/19
li e data ase Page 105 of 109
N R R as to R R . S N , R. n e ruar 19, 2019, the Court ordered the defendant to show

cause at a hearing to e held on e ruar 21, 2019 as to wh the media communications order entered in this
case 3 and/or defendant s conditions of release 21 should not e modi ed or re oked. hearing was held on
this date. or the reasons set forth on the record, and ased upon the entire record, including the sealed exhi it to
the hearing 2 , the testimon of the defendant, the arguments of counsel, and the su missions of the
parties 28 29 led in connection with the potential imposition of a media communications order, the Court
entered the following order at the hearing: the conditions of defendant s pretrial release 21 are here modi ed to
include the condition that, and the e ruar 1 , 2019 media communications order 3 is here modi ed to
pro ide that, the defendant is prohi ited from making statements to the media or in pu lic settings a out the
Special Counsel s in estigation or this case or an of the participants in the in estigation or the case. he
prohi ition includes, ut is not limited to, statements made a out the case through the following means: radio
roadcasts inter iews on tele ision, on the radio, with print reporters, or on internet ased media press releases
or press conferences logs or letters to the editor and posts on ace ook, witter, nstagram, or an other form
of social media. urthermore, the defendant ma not comment pu licl a out the case indirectl ha ing
statements made pu licl on his ehalf surrogates, famil mem ers, spokespersons, representati es, or
olunteers. he order to show cause is here acated. Signed udge m erman ackson on 2/21/19.
ntered: 02/21/2019
https://ecf.dcd.uscourts.go /cgi- in/ ktRpt.pl 23771919 011 - 1 0-1 1/1

3/4/2019 Case 1:19-cv-00656RogerDocument
Stone suggests Robert
1 FiledMueller03/07/19
framed him despite
Pagegag order
106 of 109
Stone deleted the only image in that multi-image post that included
Constant Fatigue Is A Warning Sign – See The Simple
"Who framed Roger Stone" language shortly after CNBC emailed Fix
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Stone's post was put online less than 48 hours after the judge, Amy
Berman Jackson, ordered lawyers for the admitted Republican "dirty 2. Southwest Airlines
starts selling its first
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Roger Stone
suggests Robert
https://www.cnbc.com/2019/03/03/roger-stone-suggests-robert-mueller-framed-him-despite-gag-order.html 2/6
framed him despite
Pagegag order
107 of 109
Stone announced on Instagram in January that he was coming out Mueller 'framed' him
with the book, "The Myth of Russian Collusion: The Inside Story of in Instagram post that
How Trump Really Won." could violate gag
order
In her gag order in U.S District Court in Washington, D.C., Jackson
5.
barred Stone from "making statements to the media or in public 'Beverly Hills, 90210'
settings about the Special Counsel's investigation or this case or any and 'Riverdale' star
of the participants in the investigation or the case." Luke Perry died at 52
after suffering a
The gag extends to "posts on Facebook, Twitter, Instagram or any massive stroke
other form of social media." If Stone violates the order, Jackson
could order him jailed without bail until his trial.
Jackson had slapped that order on Stone on Feb. 21 after he posted
on Instagram a photo showing the judge's face next to a rifle scope's
crosshair.
MARKETS WATCHLIST CNBC TV MENU
Jon Swaine
@jonswaine
Roger Stone now directly attacking the federal judge presiding

over his case and posting a pic of her head beside crosshairs
9,929 11:12 AM - Feb 18, 2019
10.2K people are talking about this
Stone's new post is comprised of a rotating series of images that ask
for money to support Stone's defense to charges that he lied to
Congress and tampered with a witness.
One says, "I am committed to proving my innocence. But I need
your help." Another photo, which shows a young Stone standing
framed him despite
Pagegag order
108 of 109
behind Trump years ago, says, "I've always had Trump's back. Will
you have mine?" Two other images tout a "Roger Stone Did Nothing
Wrong" t-shirt and "Stone Cold Truth" sweatshirt.
The post originally had an image showing Stone wearing eyeglasses
under the words "Who Framed Roger Stone," a reference to the
movie "Who Framed Roger Rabbit." The image has been on the
Internet for some time.
Shelby Holliday
@shelbyholliday
New in Instagramland: Roger Stone, using Insta stories (which

disappear after 24 hrs), suggests he’s being framed.
2,224 10:40 AM - Mar 3, 2019
2,253 people are talking about this
A spokesman for Mueller declined to comment Sunday. Stone's
lawyer did not immediately respond to a request for comment.
Stone, who remains free on a $250,000 signature bond, was
arrested in Florida in late January and has pleaded not guilty to the
seven counts against him, including making false statements to
Congress, witness tampering and obstructing justice.
Mueller has said Stone lied to Congress about his alleged efforts to
have WikiLeaks release material hacked by Russian agents from
Democrats, including Hillary Clinton's campaign chairman, during
the 2016 campaign that ended with Trump's victory.
framed him despite
Pagegag order
109 of 109
An indictment alleges Stone was in contact with top-ranking Trump
campaign officials about efforts to leak damaging information about
Clinton right before Election Day.
Dan Mangan
Reporter
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Jerome Corsi Vs Infowars

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What is the lawsuit about?

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Who are the plaintiffs and defendants in the lawsuit?

Case 1:19-cv-00656 Document 1 Filed 03/07/19 Page 1 of 109

IN THE UNITED STATES DISTRICT COURT

DR. JEROME CORSI, Individually

LARRY KLAYMAN, Individually Case Number:

FREE SPEECH SYSTEMS, LLC

ALEX E. JONES, Individually

DAVID JONES, Individually

OWEN SHROYER, Individually

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

and Assault, and violation of the Lanham Act.

JURISDICTION AND VENUE

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

located in Austin, TX.

offices located in Austin, TX.

Jones is a citizen of Texas.

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

including this judicial district, and online.

and internationally, including this judicial district, and online.

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

Defendant Alex Jones and Shroyer, for defamation.

“Pizzagate” conspiracy theory.5

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

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

See “Get Me Roger Stone” on Netflix.

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

legal defense fund.

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

Watch, to name just a few.

crosshairs up on his Instagram account.8

Judge Jackson directly cites and references his use of surrogates:

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

DEFENDANTS’ DEFAMATORY CONDUCT

thereby ratifying any and all defamatory statements contained therein.

statements published by Stone on their networks and media sites.

and once made cannot be taken back.

I. The October 26, 2018 Video

about Plaintiff Corsi.9

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

out of his mouth ain’t the truth.”

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

Corsi named a material witness.

II. The January 18, 2019 Video

Truth,” on January 18, 2019.11

and severally liable.

Plaintiff Corsi was “fired from World Net Daily.”

proof that Jerry lied under oath.”

life other than help him.”

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

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

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

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

willfully and maliciously defamed Plaintiff Klayman.

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

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

in media markets in this district, nationally and internationally.

III. Other Malicious Defamatory Publications

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

beyond the pale…. Jerry Corsi can no longer be believed.”13