Biden Summons and Complaint
Biden Summons and Complaint
Biden Summons and Complaint
You are hereby summoned to answer the Complaint in this action and to serve a copy of
your answer, or, if the Complaint is not served with this Summons, to serve a notice of appearance
on the Plaintiff’s attorneys at the address below within 20 days after the service of this Summons,
exclusive of the day of service, or within 30 days after the service is complete if this Summons is
not personally delivered to you within the State of New York; and in case of your failure to appear
or answer, judgment will be taken against you by default for the relief demanded in the Complaint.
FOX CORPORATION
2121 Avenue of the Stars, Suite 900
Los Angeles, CA 90067
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
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Geragos & Geragos, APC, as and for his Complaint, hereby alleges:
STATEMENT OF FACTS
President and his family, Defendants FOX NEWS NETWORK, LLC, FOX CORPORATION, and
JOHN and JANE DOES 1-100 (hereafter collectively “Defendants” or “Fox”) targeted Mr. Biden
in an effort to harass, annoy, alarm, and humiliate him, and tarnish his reputation.
2. To this end, and without Mr. Biden’s consent,1 Fox produced an entirely fictional
six-part “mock trial” entitled “The Trial of Hunter Biden”, which first became available for
streaming on Fox Nation on October 21, 2022. The miniseries was described by Fox as “a riveting
look at the unresolved legal situation of President Joe Biden’s son, Hunter.” As Fox explained,
the mock trial captures “how a possible Hunter Biden trial might look.” (Emphasis added).
1
As acknowledged in the miniseries, “Mr. Hunter Biden has not authorized this exercise, he is not
participating in this trial in any fashion, and has had no involvement in the preparations.”
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
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filings for various reasons, readers should be aware that documents bearing this legend may not have been
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TRIA
HUNTERB
Biden’s personality through a form of treatment distinct from the dissemination of news or
information. Indeed, the entire miniseries is fictionalized and based on a nonexistent criminal
case. The two charges which are the subject of the mock trial are (1) whether Mr. Biden violated
the Foreign Agents Registration Act (“FARA”), and (2) whether he committed bribery—neither
of which Mr. Biden has been charged with. As Judge Joe Brown, a longtime TV judge and the
“presiding judge” in the miniseries, states at the outset of the program: “This is a mock trial. It is
not a real proceeding. To be clear, Hunter Biden has not been implicated in or charged in any
crimes arising from his activities, alleged activities. Of course, this is not a real trial. It is a mock
trial.” In other words, the miniseries is fictionalized; it is not a news event. It was made for the
purpose of trade and advertising, and merely exploits Mr. Biden’s name, image, and likeness for
entertainment and not as news—the so-called “evidence” which is presented during the mock trial
includes actual emails sent to and from Mr. Biden as well as actual photographs depicting him
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
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filings for various reasons, readers should be aware that documents bearing this legend may not have been
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(including nonconsensual intimate images which are the subject of this action, as discussed below).
Additionally, the mock trial features individuals acting as themselves as witnesses testifying on
behalf of the prosecution including John Paul Mac Isaac—the Delaware shop owner who obtained
a laptop which he claims Mr. Biden dropped off at his repair shop—and Miranda Devine, a New
York Post columnist and Fox News contributor who authored the book Laptop from Hell: Hunter
Biden, Big Tech, and the Dirty Secrets the President Tried to Hide.
5. While using certain true information, the series intentionally manipulates the facts,
distorts the truth, narrates happenings out of context, and invents dialogue intended to entertain.
Thus, the viewer of the series cannot decipher what is fact and what is fiction, which is highly
and likeness, “The Trial of Hunter Biden” unlawfully publishes numerous intimate images (both
still and video) of Mr. Biden depicting him in the nude, depicting an unclothed or exposed intimate
part of him, as well as engaged in sex acts (hereafter the “Intimate Images”).
7. Fox published and disseminated these Intimate Images to its vast audience of
millions as part of an entertainment program in order to humiliate, harass, annoy, and alarm Mr.
Biden and to tarnish his reputation. It should be noted that when these same images were posted
on Twitter (now X) as part of an organized effort by exiled Chinese billionaire Guo Wengui and
his followers, Twitter promptly had these images removed as violative of its revenge porn policies
and other terms of service. See, e.g., Ryan Bort, Republicans Are Furious Twitter Took Down Pics
https://www.rollingstone.com/politics/politics-news/republicans-twitter-took-down-hunter-
biden-dick-pics-1234675974/.
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
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filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 4 of 15
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8. In publishing and disseminating these Intimate Images, Fox knew that these private
and confidential images were hacked, stolen, and/or manipulated digital material which were
intended to remain private and confidential, but which had been unlawfully procured and
9. The unlawful publication and dissemination of the Intimate Images by Fox was not
made for a legitimate public purpose, where the miniseries featuring a mock trial is not accurately
reporting on newsworthy events but rather, is a fictionalized trial of a nonexistent case against Mr.
10. “The Trial of Hunter Biden” was widely advertised and it was originally available
for streaming on Fox Nation, as well as other streaming platforms including DirecTV, Apple TV,
11. In addition to Fox Nation’s two million paid subscribers, it is reported that DirecTV
has around 11.3 million subscribers in the U.S., Apple TV has around 25 million paid subscribers
and an additional 50 million viewers who access the service via promotions, Roku Channel has
around 81.6 million active accounts worldwide, and YouTube TV has more than 8 million
subscribers. On information and belief, the reach of the Intimate Images in “The Trial of Hunter
12. On April 23, 2024, attorneys for Mr. Biden sent Fox a demand to, inter alia, remove
“The Trial of Hunter Biden” from all of its streaming platforms including Fox Nation, to direct
third-party streaming services to remove “The Trial of Hunter Biden” from their respective
streaming platforms, and to preserve evidence related to Fox’s unlawful publication and
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
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filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 5 of 15
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13. On or about April 30, 2024, Fox removed “The Trial of Hunter Biden” from Fox
Nation’s streaming platform. However, promotional reels and clips of the mocu-series have not
been removed by Fox. For instance, one such reel posted on Fox Nation’s Facebook page on
October 18, 2022 has 3,400 views and is still accessible as of the date of this filing. See
https://www.facebook.com/foxnation/videos/the-trial-of-hunter-biden-now-
streaming/1405624696633819/.
14. On information and belief, “The Trial of Hunter Biden” is still available for
streaming on certain third-party streaming platforms. Clips of “The Trial of Hunter Biden”
containing the Intimate Images of Mr. Biden also remain accessible online and in the public
domain.
15. On information and belief, subscribers who downloaded “The Trial of Hunter
Biden” prior to its removal from Fox Nation on or about April 30, 2024 may forever possess,
watch, duplicate, and/or further disseminate the program containing the Intimate Images of Mr.
Biden.
16. The unauthorized publication and dissemination of the Intimate Images has caused
Mr. Biden severe emotional distress, humiliation, and mental anguish, as well as irreparable injury
17. Mr. Biden brings this action under New York Civil Rights Law Section 52-b
seeking monetary damages and injunctive relief for Defendants’ gross wrongdoing. He also
asserts claims for the intentional infliction of emotional distress and for unjust enrichment.
18. On information and belief, Fox’s publication and dissemination of the Intimate
Images was a knowing, intentional, and calculated violation of the law, warranting punitive
damages.
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
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filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 6 of 15
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19. As one of the leading media conglomerates in the world, Fox has a robust in-house
legal department which includes separate practice groups for litigation, labor and employment,
practices, music, distribution, sports, digital and data security, and mergers and acquisitions. Fox
also has a designated Chief Legal and Policy Officer, who oversees all legal, compliance, and
regulatory matters for Fox, and it has a General Counsel and Deputy General Counsel, as well as
20. The fact that Fox pays substantial salaries and fees to such counsel for its oversight
and handling of legal and compliance matters has been widely reported. By way of example,
according to a Securities & Exchange Commission (SEC) filing dated August 9, 2023, Viet Dinh,
who was the Chief Legal and Policy Officer of Fox Corporation from 2018 until the end of 2023
(which covers the period in which “The Trial of Hunter Biden” was produced and first made
available for streaming), earned $12.1 million in total compensation at the end of 2020, $12.4
million at the end of 2021, $11.2 million at the end of 2022, and $10.7 million at the end of 2023.
Upon his departure as the Chief Legal Officer of Fox, Mr. Dinh received a $23 million cash
settlement and Fox agreed to pay him $5 million for a two-year term as a “special adviser.”
21. On information and belief, the reason Fox maintains a robust legal department and
pays hefty amounts to such counsel is because it knows that the laws affecting its operations are
ever-changing. For instance, in its 2022 and 2023 Annual Report to shareholders, Fox explained
that “[t]he Company is subject to complex laws, regulations, rules, industry standards, and
contractual obligations related to privacy and personal data protection, which are evolving,
inconsistent and potentially costly.” Fox represented that it “monitors and considers these laws
and regulations, particularly with respect to the design and operation of digital content services
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
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filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 7 of 15
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and legal and regulatory compliance programs” and that “the Company expends significant
resources to comply with privacy and data protection laws.” Fox even forewarned its shareholders
that “[v]iolations of [such] laws and regulations could result in significant monetary fines and other
penalties, private litigation, require us to expend significant resources to defend, remedy and/or
22. On information and belief, during the production of “The Trial of Hunter Biden,”
and certainly prior to the date on which the series first became available for streaming on Fox
Nation on October 21, 2022, Fox knew that the majority of states had in effect laws against the
nonconsensual disclosure of sexually explicit images and videos (also known as “revenge porn”
laws). Specifically, on information and belief, Fox knew that its use of the Intimate Images in
“The Trial of Hunter Biden” would violate New York state’s revenge porn laws including New
York Civil Rights Law Section 52-b and Penal Law Section 245.15 (making the unlawful
23. On information and belief, despite knowing that the publication and dissemination
of the Intimate Images would violate New York civil and criminal laws, Fox chose to publish and
24. This would not be the first time that Fox knowingly engaged in unlawful conduct.
For instance, in the recent Dominion Voting Systems (“Dominion”) lawsuit against Fox (which
Fox settled at the start of trial for $787.5 million), internal text messages and emails produced
during discovery revealed that the fact-checking and research division of the network (the so-called
“Brain Room”) had clearly concluded that the claims that Dominion’s voting machines had been
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
8
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 8 of 15
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rigged to steal the 2020 presidential election were false but that Fox chose to air this
25. On information and belief, in an analogous situation here, Fox disregarded the
known legal implications of unlawfully publishing and disseminating the Intimate Images in order
to humiliate, harass, annoy, and alarm Mr. Biden, to tarnish his reputation, and for financial gain.
In other words, like in the Dominion case, Fox knew its conduct was unlawful but it did it anyway.
26. Defendants’ conduct was so egregious and done so clearly with malice and/or
reckless indifference to Mr. Biden’s interests, wellbeing, and reputation that in addition to all the
damages which Mr. Biden is entitled to, Defendants should also be required to pay punitive
damages to punish them for their intentional conduct and to deter Fox and others similarly situated
THE PARTIES
27. Plaintiff Robert Hunter Biden is an individual residing in Los Angeles, California.
28. Defendant Fox News Network, LLC (“Fox News”) is formed and organized under
the laws of Delaware and it has its principal place of business in New York, New York. It is
demand service, which offers, among other things, next-day streaming of Fox News primetime
programs. According to its website, “FOX Nation is an entertainment streaming service brought
(emphasis added). On information and belief, Fox Nation is currently the only subscription video-
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
9
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 9 of 15
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on-demand from Fox. As of February 26, 2024, Fox Nation reportedly had over two million paid
30. Defendant Fox News is wholly owned by Defendant Fox Corporation, an American
multinational mass media company which is incorporated in Delaware and has its principal place
31. At all relevant times herein, Defendants John and Jane Does 1 through 100 were
executives, officers, employees, agents, and representatives of Fox who perpetrated the
wrongdoing alleged herein. At this time, Plaintiff is not privy to the names or identities of the
individual defendants, John and Jane Does 1-100, as such knowledge is within the exclusive
possession of Fox. Pursuant to CPLR § 1024, the names “John and Jane Does 1-100” are fictitious
and meant as placeholders for the individuals at Fox who directed and/or participated in the
production of “The Trial of Hunter Biden,” and specifically, in the unlawful publication and
32. This Court has jurisdiction over the parties and the subject matter of this action
33. This Court has jurisdiction over this action because the amount of damages Plaintiff
seeks, exclusive of punitive damages, interest, costs, disbursements, and attorneys’ fees, exceeds
the jurisdictional limits of all lower courts which would otherwise have jurisdiction and meets the
34. Venue is proper in New York County pursuant to CPLR § 503 because Defendants
reside in New York County and a substantial part of the events giving rise to the claims occurred
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
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filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 10 of 15
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35. Mr. Biden repeats and realleges the allegations stated above as if fully set forth
herein.
36. Mr. Biden had a reasonable expectation that the Intimate Images, when taken,
37. The Intimate Images depict an unclothed or exposed intimate part of Mr. Biden.
38. The Intimate Images depict Mr. Biden engaging in sexual conduct, as defined in
39. Mr. Biden is readily identifiable by his face in the Intimate Images; moreover, the
dialogue in “The Trial of Hunter Biden” makes clear that the Intimate Images are of Mr. Biden.
40. The Intimate Images were disseminated and published by Defendants without Mr.
Biden’s consent.
41. The Intimate Images were disseminated and published by Defendants for the
42. The publication and dissemination of the Intimate Images in “The Trial of Hunter
Biden” was not made in relation to a matter of legitimate public concern nor is it otherwise
protected by the First Amendment of the United States Constitution. On the contrary, the six-part
mock trial is a fictionalized trial of a nonexistent case against Mr. Biden which was intended solely
the trial of this action, his attorneys’ fees and court costs, and injunctive relief.
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
11
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accepted for filing by the County Clerk. 11 of 15
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44. Because Defendants’ actions were willful, malicious, and deliberate, evinced a high
degree of moral turpitude, and demonstrated a conscious disregard for Plaintiff’s interests,
wellbeing, and reputation, Mr. Biden is also entitled to an award of punitive damages to punish
Defendants for their intentional conduct and to deter Fox and others similarly situated from
45. Plaintiff repeats and realleges the allegations stated above as if fully set forth herein.
47. Defendants’ conduct was so extreme in degree and so outrageous in character that
48. Defendants’ purpose in sharing the Intimate Images was to harass, annoy, alarm,
and humiliate him, tarnish his reputation, and cause others to view him in a negative light.
49. In publishing and disseminating the Intimate Images, Defendants intended to cause
Mr. Biden severe emotional distress, or alternatively, recklessly disregarded the likelihood that
such conduct would tend to cause severe emotional distress. Such outrageous behavior is beyond
50. As a direct and proximate result of Defendants’ conduct, Plaintiff suffered severe
emotional distress.
the trial of this action, said amount being sufficient to compensate Plaintiff for his severe injuries.
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
12
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 12 of 15
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52. Because Defendants’ actions were willful, malicious, and deliberate, evinced a high
degree of moral turpitude, and demonstrated a conscious disregard for Plaintiff’s interests,
wellbeing, and reputation, Mr. Biden is also entitled to an award of punitive damages to punish
Defendants for their intentional conduct and to deter Fox and others similarly situated from
(Unjust Enrichment)
53. Plaintiff repeats and realleges the allegations stated above as if fully set forth herein.
54. In unlawfully publishing and disseminating the Intimate Images of Mr. Biden in
violation of New York law, Defendants financially benefited from “The Trial of Hunter Biden” at
55. It would be against equity and good conscience to allow Defendants to retain the
profits from “The Trial of Hunter Biden,” which should be disgorged and paid to Mr. Biden as
restitution.
56. Mr. Biden herein demands a trial by jury for all issues in this action.
WHEREFORE, Mr. Biden respectfully prays for a judgment against Defendants Fox
News Network, LLC, Fox Corporation, and John and Jane Does 1-100 as follows:
b. An award of punitive damages in an amount exceeding the jurisdictional limits of all lower
courts to be determined by the trier of fact;
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
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accepted for filing by the County Clerk. 13 of 15
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c. An order directing Defendants to take down, remove and delete any publication of an Intimate
Image of Mr. Biden and to permanently destroy any Intimate Image of Mr. Biden in their
possession, custody, or control;
h. Such other and further relief as this Court may deem just and proper.
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
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VERIFICATION
TINA GLANDIAN, an attorney duly admitted to practice before the Courts of the State of
1. I am the attorney for the Plaintiff in the above-entitled action with offices located
2. I have read the foregoing Complaint and know the contents thereof to be true to my
own knowledge, except as to the matters therein stated to be alleged on information and belief,
4. The grounds of my belief as to all matters not stated upon my own knowledge are
based upon conversations with the Plaintiff and a review of materials relevant to this matter.
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
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accepted for filing by the County Clerk. 15 of 15