Garth Brooks Complaint - Redacted

Case 3:24-cv-00547-HTW-LGI Document 17 Filed 10/08/24 Page 1 of 6
IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
NORTHERN DIVISION
TROYAL GARTH BROOKS PLAINTIFF
VS. CIVIL ACTION NO: 3:24-cv-547-HTW-LGI
DEFENDANT
AMENDED COMPLAINT
(TRIAL BY JURY DEMANDED)
Plaintiff Troyal Garth Brooks files this lawsuit to obtain relief from Defendant
ongoing attempted extortion, defamation, false light invasion of privacy, and
intentional infliction of emotional distress through outrageous conduct including the publication
and threatened wider publication of false allegations of sexual misconduct that would irreparably
harm Plaintiff’s reputation, family, career and livelihood.
PARTIES
1. Plaintiff is an adult resident citizen of Tennessee.
2. Defendant is an adult resident citizen of Mississippi.
JURISDICTION AND VENUE
3. This Court has subject matter jurisdiction under 28 U.S.C. § 1332 because
complete diversity of citizenship exists between the parties and the amount in controversy
exceeds the sum of $75,000.00 exclusive of interest and costs.
4. Venue is proper under 28 U.S.C. § 1391 because Defendant resides in this judicial
district and division.
FACTS
5. Plaintiff is a celebrity and public figure who resides in Tennessee.

6. Defendant worked professionally with Plaintiff as an independent contractor for
approximately fifteen years before she relocated from Tennessee to Mississippi in May 2020.
7. Soon after moving to Mississippi, Defendant apparently encountered financial
difficulties and asked Plaintiff for financial assistance. Plaintiff complied out of loyalty,
friendship, and a desire to improve Defendant’s condition. But Defendant’s demands for
financial assistance only increased, with Defendant ultimately asking Plaintiff for salaried
employment and medical benefits.
8. When Plaintiff advised he could not agree to Defendant’s demands for salaried
employment and medical benefits, she responded with false and outrageous allegations of sexual
misconduct she claims occurred years ago.
9. Specifically, on July 17, 2024, an attorney acting at Defendant’s direction sent
Plaintiff and others with whom Plaintiff professionally works an ostensibly “confidential”
demand letter alleging a litany of sexual misconduct by Plaintiff ranging from allegations of
sexual “grooming,” creation of a sexually hostile work environment, unwanted sexual touching,
and sexual assault. Defendant also alleged a belief that Plaintiff planned to hire someone to
murder her. The July 17 demand letter was the first time Plaintiff learned of these allegations,
none of which has any basis in fact.
10. Defendant threatened in the July 17 demand letter to “publicly file” an enclosed
draft civil complaint against Plaintiff repeating the same fabricated allegations unless Plaintiff
agreed to pay Defendant millions of dollars not to file the suit. The letter referred to various
celebrity sexual misconduct lawsuits featuring multi-million dollar jury awards.
11. In a follow-up letter dated August 23, 2024, Defendant, through her attorney,
offered to refrain from publicly filing her false and defamatory lawsuit against Plaintiff in
2
exchange for a multi-million dollar payment. She threatened that if Plaintiff failed to meet this
demand, he would face exposure of many millions of dollars “based on [his] net worth.”
12. Defendant’s allegations are not true. Defendant is well aware, however, of the
substantial, irreparable damage such false allegations would do to Plaintiff’s well-earned
reputation as a decent and caring person, along with the unavoidable damage to his family and
the irreparable damage to his career and livelihood that would result if she made good on her
threat to “publicly file” her fabricated lawsuit. Indeed, such knowledge no doubt explains why
Defendant threatened to file suit through a “confidential” demand letter rather than simply filing
suit to redress her alleged (but untrue) injuries.
CLAIMS FOR RELIEF
13. Defendant’s publication of such false allegations and her threat to file a lawsuit
more widely publicizing such false allegations against Plaintiff has given rise to a justiciable
controversy between the parties entitling Plaintiff to a declaratory judgment pursuant to 28
U.S.C. § 2201 that Defendant’s allegations of sexual misconduct are untrue.
14. Defendant’s false allegations and her threats to wrongfully assassinate Plaintiff’s
character through the public airing of such revulsive and untrue allegations have caused Plaintiff
emotional distress including anxiety and fear for himself and his family. Defendant’s attempted
extortion of Plaintiff for millions of dollars through such untrue, lewd allegations constitutes
intentional, outrageous conduct that was intended to and did in fact cause Plaintiff serious mental
injury, amounting to an intentional infliction of emotional distress for which Plaintiff is entitled
to recover compensatory and punitive damages.
15. Defendant has defamed Plaintiff by intentionally publishing her July 17 letter and
enclosed draft complaint containing these false allegations of sexual misconduct to persons other
than Plaintiff. Defendant intentionally published these statements to others with knowledge that
3
the statements were false and defamatory. Defendant’s publication of these defamatory
statements was not privileged but was made with malice, ill will, and for the improper purpose of
extorting an unwarranted payment from Plaintiff. Defendant’s intentional defamation of Plaintiff
entitles Plaintiff to recover compensatory and punitive damages.
16. Defendant’s malicious publication of her false allegations of sexual misconduct
also placed Plaintiff in a false light that would be highly offensive to any reasonable person.
Defendant intentionally published these statements with knowledge of their falsity and with
knowledge of the false light in which the statements would place Plaintiff. Defendant’s
publication of these false allegations was not privileged but was made with malice, ill will, and
for the improper purpose of extorting an unwarranted payment from Plaintiff. Defendant’s
intentional false light invasion of privacy entitles Plaintiff to recover compensatory and punitive
damages.
17. Plaintiff is also entitled to preliminary and permanent injunctive relief prohibiting
Defendant from continuing her attempted extortion, defamation, and false light invasion of
privacy, and from making good on her threats to more widely publicize her false allegations
against Plaintiff. Plaintiff will suffer irreparable harm to his reputation, his family, and his career
and livelihood if Defendant is not so enjoined. Monetary damages cannot adequately
compensate Plaintiff for these injuries. Defendant will suffer no hardship from an injunction of
her wrongful conduct, while Plaintiff will suffer irreparable harm if no injunction is issued.
Finally, the public interest will not be disserved by the requested injunction because the public
has no interest in furthering Defendant’s extortionate scheme through the publication of her false
and salacious allegations.
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ACCORDINGLY, Plaintiff requests that the Court award him the following relief:
(a) a declaratory judgment that Defendant’s allegations against him of sexual misconduct
are untrue;
(b) compensatory damages proximately caused by Defendant’s intentional infliction of
emotional distress, defamation, and false light invasion of privacy, including
incidental and consequential damages;
(c) punitive damages in an amount sufficient to deter similar future behavior;
(d) preliminary and permanent injunctive relief prohibiting Defendant from continuing
her extortionate behavior and from further publicizing her false allegations against
Plaintiff;
(e) Plaintiff’s reasonable costs and attorneys’ fees;
(f) pre-judgment and post-judgment interest; and
(g) such other relief as the Court deems appropriate.
PLAINTIFF DEMANDS A TRIAL BY JURY.

Dated: October 8, 2024.
Respectfully submitted,
TROYAL GARTH BROOKS
By: /s/ R. David Kaufman

R. David Kaufman,
One of His Attorneys
5
OF COUNSEL:
R. David Kaufman, MSB No. 3526

dkaufman@brunini.com
M. Patrick McDowell, MSB No. 9746
pmcdowell@brunini.com
BRUNINI, GRANTHAM, GROWER & HEWES, PLLC
P.O. Drawer 119
Jackson, MS 39205
Telephone: (601) 948-3101
Facsimile: (601) 960-6902
Daniel M. Petrocelli (pro hac vice)

dpetrocelli@omm.com
Megan K. Smith (pro hac vice)
megansmith@omm.com
O’MELVENY & MYERS LLP
1999 Avenue of the Stars, Suite 800
Los Angeles, CA 90067
Telephone: (310) 553-6700
Facsimile: (310) 246-6779
Eric J. Amdursky (pro hac vice)
eamdursky@omm.com
O’MELVENY & MYERS LLP
2765 Sand Hill Road
Menlo Park, CA 94025
Telephone: (650) 473-2600
Facsimile: (650) 473-2601
CERTIFICATE OF SERVICE
I hereby certify that on this date I electronically filed the foregoing with the Clerk of the
Court using the ECF system, which sent notification of such filing to all counsel of record.
Dated: October 8, 2024.
/s/ R. David Kaufman

R. David Kaufman

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Case 3:24-cv-00547-HTW-LGI Document 17 Filed 10/08/24 Page 1 of 6

IN THE UNITED STATES DISTRICT COURT

TROYAL GARTH BROOKS PLAINTIFF

VS. CIVIL ACTION NO: 3:24-cv-547-HTW-LGI

ongoing attempted extortion, defamation, false light invasion of privacy, and

harm Plaintiff’s reputation, family, career and livelihood.

1. Plaintiff is an adult resident citizen of Tennessee.

2. Defendant is an adult resident citizen of Mississippi.

JURISDICTION AND VENUE

exceeds the sum of $75,000.00 exclusive of interest and costs.

district and division.

5. Plaintiff is a celebrity and public figure who resides in Tennessee.

6. Defendant worked professionally with Plaintiff as an independent contractor for

7. Soon after moving to Mississippi, Defendant apparently encountered financial

employment and medical benefits.

misconduct she claims occurred years ago.

9. Specifically, on July 17, 2024, an attorney acting at Defendant’s direction sent

none of which has any basis in fact.

celebrity sexual misconduct lawsuits featuring multi-million dollar jury awards.

substantial, irreparable damage such false allegations would do to Plaintiff’s well-earned

suit to redress her alleged (but untrue) injuries.

CLAIMS FOR RELIEF

controversy between the parties entitling Plaintiff to a declaratory judgment pursuant to 28

U.S.C. § 2201 that Defendant’s allegations of sexual misconduct are untrue.

to recover compensatory and punitive damages.

extorting an unwarranted payment from Plaintiff. Defendant’s intentional defamation of Plaintiff

entitles Plaintiff to recover compensatory and punitive damages.

16. Defendant’s malicious publication of her false allegations of sexual misconduct

and livelihood if Defendant is not so enjoined. Monetary damages cannot adequately

and salacious allegations.

(b) compensatory damages proximately caused by Defendant’s intentional infliction of

emotional distress, defamation, and false light invasion of privacy, including

incidental and consequential damages;

(c) punitive damages in an amount sufficient to deter similar future behavior;

(e) Plaintiff’s reasonable costs and attorneys’ fees;

(f) pre-judgment and post-judgment interest; and

(g) such other relief as the Court deems appropriate.

PLAINTIFF DEMANDS A TRIAL BY JURY.

TROYAL GARTH BROOKS

By: /s/ R. David Kaufman

R. David Kaufman, MSB No. 3526

Daniel M. Petrocelli (pro hac vice)

Eric J. Amdursky (pro hac vice)

Dated: October 8, 2024.

/s/ R. David Kaufman

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