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Rachel C. Strickland John Langford

Aaron E. Nathan Rachel Goodman
James H. Burbage UNITED TO PROTECT DEMOCRACY
M. Annie Houghton-Larsen 82 Nassau Street, #601
WILLKIE FARR & GALLAGHER LLP New York, NY 10038
787 Seventh Avenue Telephone: (202) 579-4582
New York, NY 10019 john.langford@protectdemocracy.org
Telephone: (212) 728-8000 rachel.goodman@protectdemocracy.org
rstrickland@willkie.com
anathan@willkie.com Von A. DuBose (pro hac vice forthcoming)
jburbage@willkie.com DUBOSE MILLER LLC
mhoughton-larsen@willkie.com 75 14th Street NE
Suite 2110
Michael J. Gottlieb Atlanta, GA 30309
Meryl Governski (admitted pro hac vice) Telephone: (404) 720-8111
WILLKIE FARR & GALLAGHER LLP dubose@dubosemiller.com
1875 K Street NW
Washington, DC 20006
mgottlieb@willkie.com
mgovernski@willkie.com

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK

In re: Chapter 11

RUDOLPH W. GIULIANI Case No. 23-12055 (SHL)

a/k/a RUDOLPH WILLIAM GIULIANI,

Debtor.

RUBY FREEMAN and WANDREA’ ArSHAYE

MOSS, Adv. Pro. No. _________
Plaintiffs,
v. COMPLAINT FOR INJUNCTIVE
RELIEF
RUDOLPH W. GIULIANI
a/k/a RUDOLPH WILLIAM GIULIANI,

Defendant.
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INTRODUCTION

1. This is an action for injunctive relief to permanently bar Defendant Rudolph W.

Giuliani (“Defendant”) from continuing his malicious campaign against Plaintiffs Ruby Freeman

and Wandrea’ ArShaye “Shaye” Moss (“Plaintiffs”). Undeterred by facts, logic, decency,

professional discipline, court orders in multiple jurisdictions, a criminal indictment, a multi-

million dollar jury verdict, or declaring bankruptcy as a result, Mr. Giuliani has entered year four

of intentionally defaming Ms. Freeman and Ms. Moss—repeating the very same lies that Plaintiffs

engaged in fraud during their service as election workers during the 2020 presidential election.

2. Enough is enough. Contrary to his delusions of grandeur, the law does apply to Mr.

Giuliani, and it is beyond time to make him follow it. As the Supreme Court of the United States

held more than fifty years ago, injunctive relief is the appropriate remedy for those, like Mr.

Giuliani, who continue to publish speech already held to be unprotected. See, e.g., Pittsburgh Press

Co. v. Pittsburgh Comm’n on Hum. Rels., 413 U.S. 376, 390 (1973); Kingsley Books, Inc. v. Brown,

354 U.S. 436, 441 (1957). This Court should promptly impose that remedy.

3. Mr. Giuliani has already been found liable for defamation and intentional infliction

of emotional distress for disseminating these same lies in Freeman et al. v. Giuliani, No. 21-cv-

3354 (D.D.C.) (the “Freeman Litigation”). After the United States District Court for the District

of Columbia (the “D.C. District Court”) entered default judgment on liability against Mr.

Giuliani—based in part on his own attempts to stipulate to liability for nearly identical statements

as are at issue here—the case proceeded to a jury trial on damages. At trial, Mr. Giuliani heard Ms.

Freeman and Ms. Moss testify about the devastating consequences of his campaign of lies. On

December 15, 2023, a jury entered a unanimous verdict awarding Plaintiffs over $148 million in

combined compensatory and punitive damages, and on December 18, 2023, the D.C. District Court

entered final judgment on that jury award, while declaring that Mr. Giuliani engaged in defamation

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per se, intentional infliction of emotional distress, and a civil conspiracy to commit the same. The

Court specifically declared that Mr. Giuliani’s claims about Plaintiffs are false, that Mr. Giuliani

acted with actual malice, and his conduct was intentional, malicious, wanton, and willful.

4. Mr. Giuliani’s campaign of tortious conduct continued during the Freeman

Litigation, including declaring to reporters that his statements were all “true” after leaving the

courthouse after the first day of trial. Plaintiffs brought a second action for injunctive relief in the

D.C. District Court, seeking to put an end to Mr. Giuliani’s continued defamatory lies. See

Freeman v. Giuliani, No. 23-cv-3754 (D.D.C. Dec. 18, 2023). Three days later, Mr. Giuliani filed

a bankruptcy petition in this Court, automatically staying Plaintiffs’ action for injunctive relief.

5. Since being found liable for defamation in the Freeman Litigation, and then filing

his chapter 11 petition in this Court, Mr. Giuliani has acted as if he is operating in a law-free zone

in which there are no consequences for anything he does. He has continued to spread the very same

lies that he previously conceded made him liable for defamation in the Freeman Litigation. For

example, Mr. Giuliani stipulated to his own liability, and was subsequently held liable, for

claiming Ms. Freeman and Ms. Moss “deliberately threw people out and counted the ballots in

private[;]” and “counted [ballots] more than one time—three, four, five, six, seven times, eight

times.”1 Since filing his chapter 11 petition, Mr. Giuliani has claimed that Ms. Freeman and Ms.

Moss “excluded the public . . . threw them out, [and] cased the joint like I said[;]”2 and were

“counting the ballots four times. One two, one two, four times four times four times.”3

1
Freeman v. Giuliani, No. 21-cv-3354 (D.D.C. May 10, 2022), ECF. 22, Ex. A at ¶¶ 66, 90.
2
Rudy W. Giuliani (@RudyGiuliani), America’s Mayor Live (397): The Stunning Lack of Leadership at These So-
Called Elite Universities (April 30, 2024, 8:00 PM),
https://twitter.com/RudyGiuliani/status/1785459381741801931 at 53:03–53:10.
3
Rudy W. Giuliani (@RudyGiuliani), America’s Mayor Live (384): The Fall of New York City & How the Giuliani
Playbook Can Spur a Revival, (April 11, 2024, 8:00 PM), https://twitter.com/i/broadcasts/1lPKqbpkgMYGb at

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6. Mr. Giuliani made these statements knowing the impact his past defamation had on

Ms. Freeman and Ms. Moss and knowing the harm that ongoing defamation would cause. He also

made these statements after being warned by this Court not to do so.4 Mr. Giuliani cannot be

permitted to use the bankruptcy system as a shield while continuing his baseless attacks on

Plaintiffs. Left unchecked, Mr. Giuliani’s statements will dramatically increase post-petition

claims against his estate and drain it of any distributable value for his creditors. Plaintiffs

accordingly bring this adversary proceeding for injunctive relief to put a stop to Mr. Giuliani’s

continuing, knowing defamation, once and for all.

PARTIES

7. Plaintiffs Ruby Freeman and Wandrea’ “Shaye” Moss were plaintiffs in the

Freeman Litigation, and hold a final money judgment in the amount of $146,206,113.00, plus post-

judgment interest, entered in that litigation. Plaintiffs are creditors in the Defendant’s Chapter 11

bankruptcy case, In re Rudolph W. Giuliani, No. 23-12055 (SHL).

8. Defendant Rudolph W. Giuliani is the debtor in Case No. 23-12055 (SHL) and was

a defendant in the Freeman Litigation.

JURISDICTION AND VENUE

9. This Court has subject-matter jurisdiction over this adversary proceeding pursuant

to 28 U.S.C. § 1334. Venue is proper in this District under 28 U.S.C. § 1409(a) because this

adversary proceeding relates to In re Rudolph W. Giuliani, No. 23-12055-SHL, a Chapter 11 case

pending in this District. Plaintiffs consent to entry of final orders or judgment by this Court.

1:08:27–1:08:32.
4
See Jan. 19, 2024 Hr’g Tr. 70:25–72:7, In re Rudolph W. Giuliani, No. 23-12055 (SHL) (Bankr. S.D.N.Y.).

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BACKGROUND

10. The Freeman Complaint filed in the Freeman Litigation and the voluminous

evidentiary record presented at trial set forth in detail the facts underlying Plaintiffs’ judgment

against Mr. Giuliani. As relevant here, all facts alleged in the Freeman Complaint are deemed

admitted by operation of the default judgment entered against Mr. Giuliani in that case. A copy of

the operative complaint in that action is attached to this Complaint as Exhibit A and incorporated

herein by reference. Plaintiffs summarize the relevant facts here to provide background for the

claims at issue in this adversary proceeding.

11. On December 3, 2020, Mr. Giuliani began spreading the lie that non-partisan

election workers at State Farm Arena in Fulton County, Georgia—including Ms. Freeman and Ms.

Moss—”stole” the Presidential Election in Georgia from former President Trump. In the days and

weeks that followed, Mr. Giuliani accused Ms. Freeman and Ms. Moss of excluding election

observers under false pretenses, fabricating a water leak to exclude observers, hiding illegal ballots

in suitcases, counting illegal ballots multiple times, and passing a USB drive to alter the vote tally.5

He spread these lies on multiple platforms and encouraged others to do the same.6 Strangers who

believed Mr. Giuliani’s lies contacted Ms. Freeman and Ms. Moss, harassing the women online,

by phone, and, eventually, in person.7

12. After enduring the effects of Mr. Giuliani’s lies for over a year, Ms. Freeman and

Ms. Moss initiated the Freeman Litigation on December 23, 2021.

5
See Ex. A ¶¶ 4, 38, 59, 61, 66, 69, 91, 99, 100, 107, 134, 166.
6
Id. ¶¶ 5, 12, 18.
7
Id. ¶¶ 139–162.

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13. On August 31, 2023, the D.C. District Court found that Mr. Giuliani had

“intentionally and willfully ignored” his obligation to preserve evidence, and engaged in “willful

shirking of his discovery obligations.” As a consequence of that “willful discovery misconduct,”

the D.C. District Court entered a default judgment as to liability against Mr. Giuliani as a sanction

under Federal Rule of Civil Procedure 37. That default judgment had the effect of deeming as true

the factual allegations in the operative complaint in the Freeman Litigation. A copy of the order

granting a default judgment is attached to this Complaint as Exhibit B and incorporated herein by

reference.

14. A jury trial was held to quantify the damages owed to Plaintiffs as a result of Mr.

Giuliani’s liability on Plaintiffs’ claims. On December 15, 2023, a federal jury returned a

unanimous verdict awarding Ms. Freeman and Ms. Moss approximately $148 million in

compensatory and punitive damages. A copy of the Verdict Form is attached to this Complaint as

Exhibit B and incorporated herein by reference.

15. Following the verdict, Plaintiffs’ counsel asked Mr. Giuliani to enter into an

agreement to stop publishing these and any similar false claims about Plaintiffs. Mr. Giuliani

refused.

16. On December 18, 2023, Plaintiffs and Mr. Giuliani entered a Joint Stipulation

Regarding Entry of Final Judgment, which requested that the D.C. District Court enter Declaratory

Judgment as to multiple facts, including that:

(1) that the Actionable Statements set forth in the Amended Complaint are false;
(2) that those statements are defamatory and defamatory per se; (3) that those
statements were of and concerning Plaintiffs; (4) that Defendant made those
statements with actual malice; (5) that Defendant published those statements to
third parties without privilege; and (6) that those statements caused Plaintiff harm.8

8
Joint Stipulation Regarding Entry of Final Judgment, Freeman v. Giuliani, No. 21-cv-3354 (D.D.C. December 18,

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A copy of the Joint Stipulation is attached as Exhibit D and incorporated herein by reference.

17. The D.C. District Court entered final judgment (the “Final Judgment”) the same

day. A copy of the Final Judgment is attached as Exhibit E and incorporated herein by reference.

That Final Judgment included the precise declaratory relief to which Mr. Giuliani had stipulated,

including a declaration that the statements challenged in Plaintiffs’ operative complaint

[(1)] are false; (2) that those statements are defamatory and defamatory per se; (3)
that those statements were of and concerning plaintiffs; (4) that defendant made
those statements with actual malice; (5) that defendant published those statements
to third parties without privilege; and (6) that those statements caused plaintiffs
harm.9

Accordingly, the Final Judgment’s express declaratory relief conclusively establishes all the

elements of defamation per se with respect to Mr. Giuliani’s statements, and those determinations

extend to Mr. Giuliani’s substantially identical post-petition statements alleged in this Complaint.

18. The same day, because of Mr. Giuliani’s refusal to agree to stop spreading his lies

about Plaintiffs, Plaintiffs filed suit for injunctive relief in the D.C. District Court. A copy of the

operative complaint in that action is attached to this Complaint as Exhibit F and incorporated

herein by reference. That lawsuit was automatically stayed as a result of Mr. Giuliani initiating

this bankruptcy proceeding on December 21, 2023, and remains stayed now.

19. Since filing his bankruptcy petition, Mr. Giuliani has taken advantage of the

automatic stay of Plaintiffs claim for injunctive relief to continue to spread the very same lies for

which he has already been held liable in the Freeman Litigation. For example:

2023), ECF No. 138 (the “Joint Stipulation”) (internal citations omitted); Ex. D at 2.
9
See Final Judgment, Freeman v. Giuliani, No. 21-cv-3354 (D.D.C. December 18, 2023), ECF No. 142 (internal
citations omitted); Ex. E at 2.

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20. On January 5, 2024, Mr. Giuliani appeared on his daily Twitter live cast, America’s

Mayor Live, and said the following:

[t]he case was in Georgia, the two women, I could play the tapes for you right
now of one of them counting ballots four times. I wasn’t allowed to play it at the
trial, she’ll probably put me in jail if I play them. God forbid you should find out
the truth. Because we don’t live in a free country any longer. We’re free as long as
we do what the Biden regime requires us to do, which is to submit to the lie that the
election of 2020 was legitimate. Submit to the lie that these women didn’t do
multiple counts of the ballot. Submit to the lie that Atlanta, Georgia didn’t engage
in election fraud, it would almost be inconsistent in who they are if they didn’t
engage in election fraud.10

21. On January 8, 2024, Mr. Giuliani appeared on his second Twitter live cast,

America’s Mayor Confidential, and said:

I was not allowed to put it in a defense. I was not allowed to take the videos of the
women of the woman, one of the women, I had a clear video of her quadruple
and triple counting the same ballots. You can look at it 100 times you can analyze
it 50 ways to Sunday that’s exactly what she was doing.11

22. On March 25, 2024, Mr. Giuliani appeared on America’s Mayor Live and said:

I mean, I pointed to the evidence that I had, and the evidence that I had, including
those women who were, you know, counting up the votes a couple of
times…about those women are – it’s my opinion. It’s my opinion. You can go look
on tape for yourself. You decide, you decide: were they counting the votes more
than one time or weren’t they, you can see it!12

10
Rudy W. Giuliani (@RudyGiuliani), America’s Mayor Live E315 Joe Biden Says My Name in Re-Election
Campaign Announcement - My Response, (Jan. 5, 2024, 8:00 PM),
https://x.com/RudyGiuliani/status/1743437296396013678?s=20 at 15:01–16:04.
11
Rudy W. Giuliani (@RudyGiuliani), Setting the Record w/ Cara Castronuova (X9), America’s Mayor
Confidential, (Jan. 8, 2024, 9:00 PM), https://twitter.com/RudyGiuliani/status/1744461285696151749 at 18:57–
19:24.
12
Rudy W. Giuliani (@RudyGiuliani), America’s Mayor Live (E371): Appeals Court Rules Against Judge Engoron
in Phony Fraud Case YET AGAIN, (March 25, 2024, 8:00 PM), https://twitter.com/i/broadcasts/1eaKbgYdEeZGX
at 1:11:04–1:11:58.

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23. On April 11, 2024, Mr. Giuliani spoke at an event in Tulsa, Oklahoma, which he

livestreamed on America’s Mayor Live. During the live cast, Mr. Giuliani said the following about

security footage from State Farm Arena depicting Plaintiffs:

Fir- Fir- First, I was sued by the two women who were counting multiple ballots
in Georgia. We have them, one of them on tape doing it. And I’m sued because
I offered an opinion that they were doing it on radio and television. So I’m sued for
defamation. And I also pointed out that anybody could see it on tape that
wanted to . . . for these women, who I wasn’t allowed to put in evidence, the tape
that shows them doing what I said they did . . . they don’t have the evidence
that I can show you tonight of them counting the ballots four times. One two,
one two, four times four times four times.13

24. On April 13, 2024, Mr. Giuliani reposted clips of his April 11, 2024 statements on

America’s Mayor Live to his Instagram. The clip includes Mr. Giuliani’s claims that the

“judgement was $145 million for these women, I wasn’t allowed to put in evidence the tape

that shows them doing what I said they did” and “I can show you tonight [evidence] of them,

counting the ballots four times, one two one two four times four times four times.”14

25. On April 30, 2024 Mr. Giuliani appeared on America’s Mayor Live and showed

clips of security footage from State Farm Arena. He told viewers:

 He was ahead when they stol- stole it from him too in Georgia. 47, 44 Ted. So at
the night of the election, Georgia stops counting at remember it’s the whole thing
about the was there a was there a- a complete like water main break or wasn’t there?
Well, there wasn’t a water main break but there’s tape and the tape shows
you[;]15

 in the key time when they excluded the public. The key time when they threw
them out. The key time when they cased the joint like I said. The key time
when they were counting votes. I’m going to show you this again. We’ve done it

13
Rudy W. Giuliani (@RudyGiuliani), America’s Mayor Live (384): The Fall of New York City & How the Giuliani
Playbook Can Spur a Revival, (April 11, 2024, 8:00 PM), https://twitter.com/i/broadcasts/1lPKqbpkgMYGb at
1:06:40–1:08:32.
14
Rudy W. Giuliani (@therudygiuliani), Instagram (Apr. 13, 2024), https://www.instagram.com/p/C5taWK3NQrO.
15
Rudy W. Giuliani (@RudyGiuliani), America’s Mayor Live (397): The Stunning Lack of Leadership at These So-
Called Elite Universities (April 30, 2024, 8:00 PM),
https://twitter.com/RudyGiuliani/status/1785459381741801931 at 49:02–49:27.

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before. I have- Now, I have some of it. Not anywhere near the scope of they’re
doing it but all you got to do is do it once to go to federal prison, we should have
them doing it 12, 15 tim- uh about 12 times. I’ll tell you what it looks like it looks
like this. We’ll watch some tomorrow night takes a little while to find it. Well you
want to look for it while I’m doing this? So they take the ballots and they put it
in. The ballots gets finished, they take them out. And they’re supposed to do
that with it. They put them in again. And they do it four times[;]16

 So they put it in. They count it second time, take it back, reorganize the same
ballots, put it in the fourth time. I take it out, let it go and do you see this? You
see one of them who’s involved in my case, do it twice. And then you see her
cohort who isn’t involved in the case but worked for them, do it two or three
times. Now, if we had all of the tape, you’d see a lot more of it. You’d see a lot
more of it[;]17 and

 the original tapes, which show these women run around like chickens without a
head, excluding the people. I mean, it’s we shouldn’t even be fighting about
this. You see how empty that was? They were counting ballots for sure.
Nobody disputes this while it was empty like that. That’s a violation of Georgia
law. And it makes all of the ballots arguably invalid. I certainly have a right to
argue it. When it looks like that you can’t count votes. And another section at
exactly this time, they’re counting votes. But there’s no members of the public
around and violates Georgia law.18

26. These are the exact same lies already held to be false and defamatory by the D.C.

District Court.

27. Mr. Giuliani’s persistence in making these statements after all that has transpired,

coupled with his refusal to agree to refrain from continuing to make such statements, make clear

that he intends to continue in his campaign of targeted defamation and harassment. Accordingly,

there is an overwhelming, ongoing, and imminent risk that Mr. Giuliani will inflict substantial

reputational and emotional harm on Plaintiffs. This has to stop.

16
Id. at 53:02–53:55.
17
Id. at 54:56–55:29.
18
Id. at 56:00–56:40.

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28. Plaintiffs lack an adequate remedy at law. Mr. Giuliani has asserted his own

insolvency in his chapter 11 case. In his words, Mr. Giuliani’s “filing was precipitated by the

issuance of a $148 million dollar verdict entered against the Debtor along with numerous other

lawsuits currently pending.”19 His assets are estimated to be worth up to $10 million.20 His debts

total over $150 million, which does not account for the five creditors with unliquidated claims

against Mr. Giuliani—Mr. Eric Coomer, Ph.D, Ms. Noelle Dunphy, Mr. Robert Hunter Biden,

Smartmatic USA Corp., and US Dominion Inc.21 Absent injunctive relief, Plaintiffs will continue

to suffer injuries that Mr. Giuliani has no ability to compensate.

29. Even if Mr. Giuliani were not insolvent and could conceivably recompense

Plaintiffs, an injunction is the only way to stop Mr. Giuliani from continuing to spread the specific

claims about Plaintiffs already held to be false, defamatory, and unprotected.

CAUSE OF ACTION: DEFAMATION PER SE

30. Plaintiffs incorporate all paragraphs in this Complaint as if fully set forth herein.

31. As has been conclusively determined in the Freeman Litigation, Mr. Giuliani’s

statements are false statements of and concerning Plaintiffs, that accuse Ms. Freeman and Ms.

Moss of criminal acts and therefore, are defamatory per se.22

32. Mr. Giuliani published, caused to publish, or reasonably could have foreseen the

publication of post-petition defamatory statements about Ms. Freeman and Ms. Moss, including

by and through his agents and by republishing the statements on his website, social media accounts,

19
In re Rudolph W. Giuliani, No. 23-12055 (SHL), ECF No. 5 ¶ 5.
20
In re Rudolph W. Giuliani, No. 23-12055 (SHL), ECF No. 1 at 6.
21
In re Rudolph W. Giuliani, No. 23-12055 (SHL), ECF No. 2.
22
Freeman v. Giuliani, No. CV 21-3354 (BAH), 2022 WL 16551323, at *8 (D.D.C. Oct. 31, 2022).

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and media programs—including but not limited to America’s Mayor Live, America’s Mayor

Confidential—which are republished on multiple platforms, including but not limited to Twitter/X,

Rumble, YouTube, Instagram, and Gettr.

33. As reasonably foreseeable—and intended—these statements caused Plaintiffs

significant reputational and emotional harm, and if repeated will continue to cause Plaintiffs

significant reputational and emotional harm.

34. As has been conclusively determined in the Freeman Litigation, Mr. Giuliani has

made these statements with actual malice, i.e., with the knowledge that they are false.

35. As has been conclusively determined in the Freeman Litigation, Mr. Giuliani had

and has no applicable privilege or legal authorization to continue to make false statements about

Ms. Freeman and Ms. Moss. He did not and does not neutrally report allegations about Ms.

Freeman and Ms. Moss. Further, Mr. Giuliani’s statements can be reasonably understood to imply

provably false facts and are not First Amendment protected statements of opinion.

PRAYER FOR RELIEF

Plaintiffs respectfully request that the Court enter judgment:

a) Permanently enjoining Mr. Giuliani from repeating the defamatory statements for

which he has been held liable in the Freeman Litigation, and any substantially

similar statements, pursuant to Federal Rule of Bankruptcy Procedure 7065 and

Federal Rule of Civil Procedure 65; and

b) Granting Plaintiffs such other and further relief as this Court deems just and proper.

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Dated: May 10, 2024 /s/ Rachel C. Strickland

Michael J. Gottlieb Rachel C. Strickland

Meryl C. Governski (admitted pro hac vice) Aaron E. Nathan
WILLKIE FARR & GALLAGHER LLP James H. Burbage
1875 K Street NW M. Annie Houghton-Larsen
Washington, DC 20006 WILLKIE FARR & GALLAGHER LLP
mgottlieb@willkie.com 787 Seventh Avenue
mgovernski@willkie.com New York, NY 10019
Telephone: (212) 728-8000
Von A. DuBose (pro hac vice forthcoming) Facsimile: (212) 728-8111
DUBOSE MILLER LLC rstrickland@willkie.com
75 14th Street NE anathan@willkie.com
Suite 2110 jburbage@willkie.com
Atlanta, GA 30309 mhoughton-larsen@willkie.com
Telephone: (404) 720-8111
dubose@dubosemiller.com John Langford
Rachel Goodman UNITED TO PROTECT
DEMOCRACY
82 Nassau Street, #601
New York, NY 10038
Telephone: (202) 579-4582
john.langford@protectdemocracy.org
rachel.goodman@protectdemocracy.org

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