Case 2:20-cv-09623-AB-PLA Document 1 Filed 10/20/20 Page 1 of 63 Page ID #:1

1 UTZURRUM LAW OFFICES, A.P.C.

Joe Utzurrum, Esq.
2 Cal Bar Number 171701
11620 Wilshire Blvd. Ste. 900
3 Los Angeles, California 90025
Tele 310.887.1837
4 Email joe@ulawoffices.com
5
Attorneys for Plaintiff, JOSEPH R.
6 MEEHAN
7
8
9
UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
JOSEPH R. MEEHAN, ) Case No.
12 )
Plaintiff, ) COMPLAINT FOR DAMAGES
13 ) AND DEMAND FOR JURY TRIAL
vs. )
14 ) 1. Libel
15 PELLE TSICHLIS aka PELLE ) 2. Libel Per Se
PRIMEAU, ) 3. Trade Libel
16 )
Defendants. ) 4. False Light
17 ) 5. Intentional interference with
) Prospective Economic
18 ) Advantage
) 6. Negligent Interference with
19 ) Prospective Economic
20 )
Advantage
)
21 ) 7. Intentional Infliction of
) Emotional Distress
22 ) 8. Negligent Infliction of Emotional
) Distress
23 ) 9. Permanent Injunction
) 10. Declaratory Relief
24 )
25 Plaintiff, JOSEPH R. MEEHAN, an individual, hereby, by and through
26 his counsel of record, allege as follows:
27
28 ////
Complaint for Damages and
UTZURRUM LAW OFFICES, A.P.C. Demand for Jury Trial
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I. JURISDICTION AND VENUE

1 1. This court has original jurisdiction under 28 U.S.C. §1332, because all
2 Plaintiffs are citizens of the state of California and defendant are citizens
3 of states other than the state of California. Additionally, the amount in
4 controversy in this matter exceeds $75,000.00, exclusive of costs and
5 interests as more specifically plead infra.
6 2. Venue is proper under U.S.C. §1391(b)(2), because a substantial amount
7 of the events and omissions giving rise to the claim occurred in the Central
8 District of California, and otherwise were knowingly directed at harming a
9 citizen of the State of California and the citizen’s ability to take part in his
10 occupation within the State of California, as more specifically plead infra.
11 II. PARTIES
12 3. Plaintiff, JOSEPH R. MEEHAN (Meehan or Plaintiff) is, and was, at all
13 times relevant, domiciled in Los Angeles, California and thus a citizen of
14 California. Plaintiff is referred to in the complaint herein by “Joey Ryan”
15 which is one of Plaintiff’s professional wrestling pseudonym or persona.
16 4. Pelle Tsichlis (Defendant) also known as Pelle Primeau, is, and was at all
17 relevant times, domiciled in the State of Pennsylvania and thus a citizen of
18 the State of Pennsylvania.
19 III. FACTS COMMON TO ALL CLAIMS
20 5. In early 2000, Plaintiff began training to become a professional wrestler of
21 the kind that is a theatrical performance as opposed to the competitive
22 Olympic style Greco-Roman and freestyle wrestling.
23 6. Before making his debut, Plaintiff spent approximately seven months
24 training, which included fitness training, learning wrestling moves and
25 learning how to develop a character and persona that an audience would
26 find entertaining, among other things.
27
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7. Plaintiff made his professional wrestling debut on or about September

1 2000.
2 8. Plaintiff wrestled using various names, personas and characters, with his
3 most notable being that of “Joey Ryan”. The character and persona of
4 “Joey Ryan” was created and used in wrestling shows by Plaintiff
5 beginning on or about 2001.
6 9. Plaintiff was also involved in wrestling promotions and in one instance was
7 one of six founders of a successful Southern California promotions called
8 Pro Wrestling Guerrilla, known as “PWG”.
9 10. Plaintiff formed and is the principal of “Bar Wrestling” wherein the
10 wrestling shows promoted by Bar Wrestling would be held in various bars
11 in Southern California, including and notably, a popular establishment
12 called the Bootleg Theater in Los Angeles that is also a popular social
13 venue, American Legion Hall in Baldwin Park and Glass House in
14 Pomona.
15 11. Any and all persons, including defendant, who know Plaintiff and the
16 wrestling character “Joey Ryan”, knows that the two are related to,
17 associated with, principals of and owners and promoters of Bar Wrestling
18 and that Bar Wrestling is a Los Angeles, California based promotion that
19 operates in Los Angeles, California.
20 12. In addition to promotions, Plaintiff is, and was, a talented and
21 entertaining wrestler and has made wrestling appearances in some of the
22 more nationally recognized promotions, including World Wrestling
23 Entertainment (WWE) and Ring of Honor (ROH), Lucha Underground
24 (Lucha) and Impact Wrestling (Impact).
25 13. Through the years “Joey Ryan” became a popular wrestling character
26 and thus on or about 2011, ten years after Plaintiff’s creation of “Joey
27 Ryan”, Plaintiff produced merchandise that Plaintiff would sell at wrestling
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shows and on his website, for example, socks, t-shirts, sweatshirts, hats,
1 toys, pins, comic books, autograph pictures, etc. that depict the “Joey
2 Ryan” likeness, posed and in action.
3 14. Having the ability to derive income from selling merchandise is one of
4 the goals of professional wrestlers and is common for professional
5 wrestlers after the wrestler achieves a higher level of popularity, which
6 would be a market indicator on determining the probability of success of
7 merchandise sales and justify incurring the cost of production.
8 15. For the past twenty years, Plaintiff spent a great deal of resources,
9 including, time and money, in promoting himself as a wrestler and
10 promoting his wrestling shows, including Bar Wrestling, as well as
11 developing innovative ways to keep his wrestling character “Joey Ryan”
12 popular and/or interesting to the wrestling community.
13 16. The popularity of a wrestler may be determined by how many persons
14 are interested in the wrestler’s activities and thoughts. Over the last fifteen
15 years or so “social networking” or “social media” applications and websites
16 have been one of the go-to indicators of the level of popularity and public
17 interest in persons and subject matters.
18 17. Plaintiff has performed in twelve different countries and over half of the
19 United States. Beginning in 2016, Plaintiff’s popularity and interest have
20 grown to performing in more than two hundred events per year.
21 18. Twitter is a social networking or social media service where users can
22 publish or post messages and statements in order to interact with other
23 users. The messages are called “tweets”. Registered users can publish or
24 post messages and statements, but non-registered users can only read
25 them. Unless the registered users change the default setting, tweets can
26 be read by any person who can access twitter.com. That is to say Twitter
27 is not an application that is meant to make the user’s messages more
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private. In the instant case the defendant had, and has, her Twitter
1 messages, i.e., tweets, retweets, replies, and likes, accessible and
2 displayed to any person who can access Twitter.
3 19. Twitter also permits account holders to “follow” each other so that each
4 user can be directly notified of posts made by other accountholders.
5 20. Twitter explains what a “Like” is in its “Help Center” webpage, “Likes
6 are represented by a small heart and are used to show appreciation for a
7 Tweet. You can view the Tweets you've liked from your profile page by
8 clicking or tapping into the Likes tab.”
9 21. Twitter explains what a “Retweet” is in its “Help Center” webpage, “A
10 Retweet is a re-posting of a Tweet. Twitter's Retweet feature helps you
11 and others quickly share that Tweet with all of your followers. You can
12 Retweet your own Tweets or Tweets from someone else. Sometimes
13 people type ‘RT’ at the beginning of a Tweet to indicate that they are re-
14 posting someone else's content. This isn't an official Twitter command or
15 feature, but signifies that they are quoting another person's Tweet.” As
16 such, resending messages to the public and other users are made by the
17 volitional act of the Twitter accountholder. Defendant’s retweets were
18 made by the volitional act of the defendant.
19 22. Generally, a hashtag, i.e., “#”, that is followed by specific characters
20 make content more discoverable on social media platforms and assist in
21 engaging with other social media users based on a common theme or
22 interest. Clicking on or searching any hashtag directs a user to
23 every social media post using the same hashtag, whether Twitter,
24 Instagram, Facebook, etc. Twitter explains what a hashtag is in its “Help
25 Center” webpage,
26 A hashtag—written with a # symbol—is used to index
27 keywords or topics on Twitter. This function was
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created on Twitter, and allows people to easily follow

1 topics they are interested in.
Using hashtags to categorize Tweets by keyword
2
• People use the hashtag symbol (#) before a
3 relevant keyword or phrase in their Tweet to
categorize those Tweets and help them show more
4
easily in Twitter search.
5 • Clicking or tapping on a hashtagged word in any
message shows you other Tweets that include that
6
hashtag.
7 • Hashtags can be included anywhere in a Tweet.
8 • Hashtagged words that become very popular
are often trending topics.
9
10 23. Instagram is another social networking or social media service that
11 allows users to upload videos and photos and uses hashtags to connect

12 users in the same manner as Twitter. When one user wants to check on

13 and routinely get updates on another Instagram account holder, the user

14 can “follow” another Instagram user, much like Twitter.

15 24. Instagram uses what it calls “stories” for Instagram accountholders to

16 more closely directly connect with their followers. Stories are posts of

17 videos, photos and statements made by the Instagram account holder that

18 are made directly available to the Instagram accountholder’s followers and

19 remain available for twenty-four hours. After an item is posted to the

20 accountholder’s story, those following are notified of the story post.

21 25. Up until June 2020 Plaintiff had 157,000 followers on his Instagram
22 account and 143,000 followers on his Twitter account.

23 26. Plaintiff has a Twitter “handle” of “JoeyRyanOnline”, which is to say that

24 such is the manner in which Plaintiff is identified in his Twitter social media

25 account. The Twitter handle is usually identified by the characters

26 following “@”. Additionally, a social media “handle” is the manner in which

27 a person is identified in the social media application/website.

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27. In or around June 2020, “#SpeakingOut” is a social media trend and

1 community that is being used to accuse wrestlers, promotors,
2 personalities and journalists of sexual misconduct.
3 28. Patreon is website or platform that allow artists and creators to publish
4 content, e.g., videos’, photos, etc. and also allows users to interact
5 through chat, for example, by paying monthly membership fee. By paying
6 the membership fee persons become “patrons”. Plaintiff is and was a
7 member of Patreon and does, and did, have subscribers who paid Plaintiff
8 monthly membership fees that paid for access to Plaintiff’s posted videos,
9 photos, media, etc.
10 29. Cameo is website to create income stream. As Cameo.com describes
11 on its “Frequently Asked Questions” webpage, “Cameo operates the
12 CAMEO™ Marketplace — through our website and app — that lets fans
13 book a personalized video shout-out — a CAMEO video — from their
14 favorite talent. Our mission is to create the most personalized and
15 authentic fan experiences in the world.”
16 30. As to all of the defendant’s conduct above and below described,
17 specifically since defendant has published his statements on social
18 networking sites, Plaintiff has,
19 a. Lost followers on his Twitter account of at least 11,000 followers
20 and is no longer getting 1,000 followers per month as Plaintiff
21 was prior to defendant’s statements;
22 b. Lost followers on his Instagram account at least 8,000 followers
23 and is no longer getting 1,000 followers per month as Plaintiff
24 was prior to defendant’s statements;
25 c. Lost venues for his Bar Wrestling promotions, including Bootleg
26 Theatre in Los Angeles, American Legion Hall in Baldwin Park
27 and Glass House in Pomona;
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d. Lost revenues from Bar Wrestling in the amount of $1,500.00 per

1 month from distribution and streaming services and $2,000.00
2 per event with two events per month;
3 e. Lost revenues from merchandising in the amount of $1,000.00
4 per month;
5 f. Lost revenues in his Patreon account in the amount of $3,000.00
6 per month;
7 g. Lost revenues in his Cameo account in the amount of $500.00
8 per month;
9 h. Lost revenues from Twitch account in the amount of $1,000.00
10 per month plus subscription shares and tips from subscribers;
11 i. Lost revenues from Wrestling Performance Bookings of
12 $8,000.00 to $10,000.00 per month.
13 IV. FALSE STATEMENTS MADE ABOUT PLAINTIFF
14 31. Defendant, Pelle Tsichlis (Defendant), also known as Pelle Primeau,
15 performs as a professional wrestler and entertainer.
16 32. As of September 10, 2020, Defendant had 277 “Following” and 545
17 “Followers” on his Twitter account wherein he used the handle
18 “primeau31”.
19 33. On or about June 20, 2020, Defendant used his Twitter account with
20 the handle “primeau31” to make the statement, “You actively pursued my
21 fiance and were instrumental in helping ruin my life. You are the lowest
22 form of human scum on the face of the earth. You’re going to burn. Your
23 time is up. And you fucking deserve it. Twitter.com/JoeyRyanOnline…”
24 (Defendant’s First Statement)
25 34. Defendant’s First Statement was published at the beginning of the
26 #SpeakingOut movement. Defendant’s Frist Statement was not intended
27 by Defendant to “speakout” about a sexual assault but so that Defendant
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could be part of, and be a participant in, a movement that was gaining
1 traction in the professional wrestling community. Defendant intended on
2 being included in the class of victims that encompassed the #speakingout
3 movement, albeit Defendant’s intentions were misplaced. The
4 #SpeakingOut movement did not include persons whose partners
5 committed infidelities with unknowing participants in infidelity. Defendant’s
6 First Statement was made to cast Plaintiff in a false light, for example, that
7 Plaintiff was a “homewrecker” of some sort. Although the incident of his
8 partner cheating on Defendant eight years prior to Defendant’s statements
9 herein described and Plaintiff did have a sexual encounter with the woman
10 Defendant refers to in Defendant’s First Statement, Plaintiff did not
11 “pursue” the woman and moreover had no idea that the woman was in any
12 way engaged or was in a committed relationship with Defendant, or any
13 other person.
14 35. As of June 20, 2020, Defendant’s First Statement was ”Retweeted” at
15 least 215 times, with 962 “Likes”.
16
17 36. On or about June 20, 2020, Defendant used his Twitter account with
18 the handle “primeau31” to make the statement, “o.k. I have something
19 new to share. If you know me I grew up in Philly, [sic] have a lot of friends
20 there. This is [sic] account from a friend of mine whom [sic] has zero
21 relation to the wrestling industry that looked at my Twitter tonight 2015
22 #SpeakingOut #JosephRyanMeehan #JoeyRyan” and then attached what
23 appears to be a series of text messages between Defendant and a
24 purported unidentified woman. The unidentified woman described a
25 sexual encounter with Plaintiff wherein Plaintiff made sexual advances
26 without the consent of the unidentified woman. The attached text
27 messages from the unidentified woman states, “I met up with him on a
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tinder date!!!” Defendant texted, “…what. Joey Ryan??”. The unidentified

1 woman texted, “Like when I first got my apartment and he kept trying to
2 come to my house and I had him kicked out of a bar because he kept
3 touching my legs and trying to go up my skirt! …I’m SO glad I got him
4 kicked out. It sounded so familiar like I know this person. Yup. Fucking
5 Tinder. 2014? 2015? Maybe. He said he was traveling and I was like okay
6 whatever, let’s go out for drinks and if [sic] course, sweeney’s cause it was
7 close and if I need someone kicked out they’re gone and flagged. …That’s
8 terrifying. He was pushy af [as fuck] and kept touching me and making me
9 feel so weird.” (Defendant’s Second Statement)
10 37. Defendant’s Second Statement was false in that Plaintiff never went on
11 a date through Tinder (dating application) in Philadelphia at bar called
12 Sweeny’s in 2014 or 2015. Plaintiff has never used or been a member of
13 the application Tinder. Defendant fabricated the messages with the
14 unidentified woman in order to be a part of the #SpeakingOut movement,
15 inter alia, in order to stay connected to the professional wrestling
16 community.
17 38. The Inqusitr is a news and media website founded on or about 2007.
18 39. On or about June 22, 2020, in response to Defendant First Statement
19 and Defendant Second Statement, the publication Inquisitr stated “In a
20 series of tweets posted early Sunday morning, independent wrestler Pelle
21 Defendant expressed anger over Ryan’s statement, accusing the Impact
22 mainstay [i.e., Plaintiff] of “actively” pursuing his fiancée and “helping ruin
23 [his] life” in the process. In these posts Defendant claimed Ryan did this
24 by constantly sending selfies to the woman, telling her a variety of sexually
25 suggestive things, and getting her involved in his hard-partying lifestyle.”
26
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40. Defendant was fully aware in making Defendant’s First Statement and
1 Defendant’s Second Statement that others would republish the statements
2 because of the #SpeakingOut movement.
3
4 1. Posts September 3, 2020
5 41. On or about September 3, 2020, Defendant used his Twitter account
6 with the handle “primeau31” to make the statement, “It’s hilarious that y’all
7 turned off replies but we haven’t forgotten that @joeyryanonline is a
8 sexual abuser. twitter.com/BarWrestling/s…” (Defendant’s Third
9 Statement)
10 42. Defendant’s Third Statement falsely accuses Plaintiff of being a person
11 who commits sexual abuse and was intended by Defendant to cast
12 Plaintiff in a false light. By adding Plaintiff’s promotion Bar Wrestling to
13 Defendant’s Third Statement, Defendant implied that Bar Wrestling was
14 promoted and operated by a person who commits sexual abuse and thus
15 must not be supported by any person, financially or otherwise, and thus
16 prevent Plaintiff from earning income through Bar Wrestling.
17 43. As of September 5, 2020, Defendant’s Third Statement was
18 ”Retweeted” at least 5 times, with 19 “Likes
19
20 44. On or about September 3, 2020, Defendant used his Twitter account
21 with the handle “primeau31” to make the statement in an attachment
22 showing a photo of a sign stating “I’m with a rapist” next to a drawing of a
23 hand/finger directing the reader to another screenshot of a post made by
24 Plaintiff on Plaintiff’s YouTube channel thanking supporters for visiting
25 Plaintiff’s YouTube channel and watching wrestling videos that Plaintiff
26 posted, that is to say Plaintiff was thanking his customers. (Defendant’s
27 Fourth Statement)
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45. By adding Plaintiff’s YouTube channel to Defendant’s Fourth

1 Statement, Defendant implied that Plaintiff’s business through YouTube
2 was operated by a person who had committed the felony of rape and must
3 not be supported by any person, financially or otherwise and thus prevent
4 Plaintiff from earning income through YouTube.
5 46. As of September 9, 2020, Defendant’s Fourth Statement was
6 ”Retweeted” at least 3 times, with 6 “Likes”.
7
8 47. On or about September 3, 2020, Defendant used his Twitter account
9 with the handle “primeau31” to make the statement, “reminder that Joey
10 Ryan (Joseph Meehan) is an accused serial sexual predator and that
11 watching any of the videos uploaded onto his YouTube channel
12 @BarWrestling playlist is giving him money.” Defendant then attached a
13 screenshot of a post made by Plaintiff on Plaintiff’s YouTube channel
14 thanking supporters for visiting Plaintiff’s YouTube channel and watching
15 wrestling videos Plaintiff posted. (Defendant’s Fifth Statement)
16 48. By adding Plaintiff’s YouTube channel and promotion Bar Wrestling to
17 Defendant’s Fifth Statement, Defendant directly stated that that Plaintiff’s
18 business through YouTube and business related to Bar Wrestling was
19 operated by a serial sexual predator, that included crimes classified as
20 felonies, and must not be supported by any person, financially or
21 otherwise and thus prevent Plaintiff from earning income through YouTube
22 and Bar Wrestling.
23 49. As of September 9, 2020, Defendant’s Fifth Statement was
24 ”Retweeted” at least 34 times, with 59 “Likes”.
25
26 50. On or about September 3, 2020, Defendant used his Twitter account
27 with the handle “primeau31” to make the statement, “He’s bragging about
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how many views he’s getting. Piece of garbage. Report that channel.”
1 Defendant then attached a screenshot of a post made by Plaintiff on
2 Plaintiff’s YouTube channel thanking supporters for visiting Plaintiff’s
3 YouTube channel and watching wrestling videos Plaintiff posted and then
4 stated, “It’s better if we completely de-platform Joey Ryan instead of him
5 reposting this until we forget. If you’re not blocked go to @BarWrestling on
6 Twitter and report them. Go to their Youtube and report it. Don’t let this
7 predator make another dime.” (Defendant’s Sixth Statement)
8 51. Defendant’s Sixth Statement is an unequivocal call to action by
9 defendant to his followers and any person who happens on Defendant’s
10 Twitter account to prevent Plaintiff from earning income through YouTube
11 and Bar Wrestling.
12 52. As of September 9, 2020, Defendant’s Sixth Statement was Replied to
13 1 time, ”Retweeted” at least 18 times, with 36 “Likes”.
14
15 53. On or about September 3, 2020, Defendant used his Twitter account
16 with the handle “primeau31” to make the statement, “Keep the trash out of
17 wrestling. Hey @BarWrestling – you’re the trash” with an attachment of a
18 screenshot of a post made by Plaintiff on Plaintiff’s YouTube channel
19 thanking supporters for visiting Plaintiff’s YouTube channel and watching
20 wrestling videos Plaintiff posted. (Defendant’s Seventh Statement)
21 54. Defendant’s Seventh Statement is an unequivocal call to action by
22 defendant to his followers and any person who happens on to Defendant’s
23 Twitter account to prevent Plaintiff from earning income through YouTube
24 and Bar Wrestling
25 55. As of September 9, 2020, Defendant Seventh Statement was
26 ”Retweeted” at least 2 times, with 16 “Likes”.
27
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56. On or about September 3, 2020, Defendant used his Twitter account

1 with the handle “primeau31” to make the statement, “THEY CAN’T
2 HANDLE THE LOGIC FOLKS” then attached Twitter messages between
3 Primeau, using the name Pelle Defendant and a Twitter user named Willie
4 Gerardo (Gerardo) who gave support to Plaintiff, “no you sound more like
5 your bitter!! Yeah if he messed up he did but move on!!” Defendant replied
6 “Yes, I should move on and not the serial sexual assaulter [referring to
7 Plaintiff] that denies the wrongdoing. How embarrassing for you to have
8 no response to sound logic and rational thought.” Gerardo responded,
9 “Good luck hopefully don’t see you in a posting on here or a Mugshot!!”
10 Defendant responded, “No worries I don’t molest women so I’ll be good!”
11 (Defendant’s Eighth Statement)
12 57. Defendant’s Eighth Statement was false in accusing Plaintiff of
13 molesting women. Plaintiff has never molested any woman. On the same
14 day Defendant had accused Plaintiff of committing sexual crimes against
15 women and in Defendant’s Eighth Statement the sexual crime of
16 molestation, which is a sexual assault and battery upon a woman without
17 consent. Defendant’s reference to molesting women was meant to and
18 was understood by the readers of Defendant’s Eighth Statement that
19 Plaintiff had committed similar sexual crimes as in Defendant’s past and
20 future statements herein and inter alia was meant to prevent Plaintiff from
21 earning any income from Plaintiff’s business ventures related to
22 professional wrestling.
23 58. As of September 9, 2020, Defendant Eighth Statement was Replied to
24 4 times and had 6 “Likes”.
25
26 59. On or about September 3, 2020, Defendant used his Twitter account
27 with the handle “primeau31” to make the statement, “If you have Twitter
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and want to signal boost I made a shareable post – the traction is good on
1 Twitter rn [right now] but I’m not seeing much on Facebook re Meehan
2 and Bar Wrestling” and then created a link to a Defendant’s Twitter page
3 that made the further statement “Pelle Primeau *** Twitter friends and
4 family, especially non-wrestling business: we need your help urgently in a
5 signal boost, marking this public and shareable*** yes man is Joseph
6 Ryan Meehan, formally “Joey Ryan’. He was removed from wrestling after
7 over 20 women came out with their stories of being sexually assaulted (to
8 put it very mildly) buy this man. His serial predatory actions have been
9 well documented over the course of the last 3 months and wrestling is
10 attempting to move on from his brand after the stories have come out. He
11 is the owner of Bar Wrestling, and have recently begun an ad campaign
12 on social media for a YouTube channel leading you to believe it’s Bar
13 Wrestling as its own private entity, uploading their entire match library for
14 free (with YouTube ads) – THE LINK WILL TAKE YOU TO THE “JOEY
15 RYAN” YOUTUBE PAGE AS HE HAS ALL THE MATCHES UPLOADED
16 THERE IN AN ATTEMPT TO MONETIZE AND MAKE MONEY OFF OF
17 PROFESSIONAL WRESTLING TO THOSE WHO WOULDN'T KNOW
18 OTHERWISE. Please, if you know ANYONE who casually watches
19 wrestling here and there when they’re bored on YouTube, or watch weekly
20 on TV, SHARE this status and let me know to NOT watch Bar Wrestling
21 on YouTube, do NOT allow Joe Meehan to make a DIME off of
22 professional wrestling any more. Please help us stop this man every time
23 he tries to worm his way back.” The Twitter page further attaches
24 screenshots of Plaintiff’s social media page that has photos of Plaintiff.
25 (Defendant’s Ninth Statement)
26 60. Defendant’s Ninth Statement is an unequivocal call to action by
27 defendant to his followers and any person who happens on Defendant’s
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Twitter account to prevent Plaintiff from earning income through YouTube,

1 Bar Wrestling and any, and all, past, present or future ventures related to
2 professional wrestling. The Statement taken as whole, vis-à-vis the many
3 accusatory statements by Defendant of Plaintiff committing sexual crimes
4 upon women, was understood by all readers of Defendant’s Ninth
5 Statement that Plaintiff had committed numerous sexual crimes. Plaintiff
6 has never committed the acts that Defendant accused Plaintiff of
7 committing. Defendant’s Ninth Statement is an assault on Plaintiff’s right
8 to make any form of income big or small in the professional wrestling
9 world, past, present and future.
10 61. As of September 9, 2020, Defendant’s Ninth Statement was
11 ”Retweeted” at least 3 times, with 2 “Likes”.
12
13 62. On or about September 3, 2020, Defendant used his Twitter account
14 with the handle “primeau31” to make the statement, “It’s better if we
15 completely de-platform Joey Ryan instead of reposting this until we forget.
16 If you’re not blocked go to @BarWrestling on Twitter and report them. Go
17 to their Youtube and report it. Don’t let this predator make another dime.”
18 (Defendant’s Tenth Statement)
19 63. Defendant’s Ninth Statement is an unequivocal call to action by
20 defendant to his followers and any person who happens on Defendant’s
21 Twitter account to prevent Plaintiff from earning income through YouTube,
22 Bar Wrestling and any, and all, past, present or future ventures related to
23 professional wrestling.
24 64. As of September 9, 2020, Defendant’s Tenth Statement was Replied
25 to 3 times, ”Retweeted” at least 34 times, with 89 “Likes”.
26
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65. On or about September 3, 2020, Defendant used his Twitter account

1 with the handle “primeau31” to make the statement, “Even if you were to
2 use AdBlock or what the more view this has the more likely it is to be other
3 people’s recommended videos who might not know and he will still get
4 paid. He does not deserve to get any more from a scene he took
5 advantage of and harmed so much. Joey Ryan owns and operates Bar
6 Wrestling and is putting ads on these videos featuring stars of AEW,
7 WWE, and elsewhere to get money since he lost all his jobs because is a
8 sexual predator (ewrestlingnews.com/news/15-secual…) Supporting this
9 is supporting him. Don’t watch.” (Defendant’s Eleventh Statement)
10 66. Defendant’s Eleventh Statement is an unequivocal call to action by
11 defendant to his followers and any person who happens on Defendant’s
12 Twitter account to prevent Plaintiff from earning income through YouTube,
13 Bar Wrestling and any, and all, past, present or future ventures related to
14 professional wrestling. The Statement taken as whole, vis-à-vis the many
15 accusatory statements by Defendant of Plaintiff committing sexual crimes
16 upon women, was understood by all readers of Defendant’s Eleventh
17 Statement that Plaintiff had committed numerous sexual crimes. Plaintiff
18 has never committed the acts that Defendant accused Plaintiff of
19 committing. Defendant’s Twelfth Statement is an assault on Plaintiff’s right
20 to make any form of income big or small in the professional wrestling
21 world, past, present and future.
22 67. As of September 9, 2020, Defendant’s Eleventh Statement was
23 ”Retweeted” at least 38 times, with 72 “Likes”.
24
25 68. On or about September 3, 2020, Defendant used his Twitter account
26 with the handle “primeau31” to make the statement, “Joey Ryan owns and
27 operates Bar Wrestling and is putting ads on these videos featuring stars
28
Complaint for Damages and
Demand for Jury Trial
17
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of AEW, WWE, and elsewhere to get money since he lost all his jobs
1 because is a sexual predator (ewrestlingnews.com/news/15-sexual…)
2 Supporting this is supporting him. Don’t watch.” (Defendant’s Twelfth
3 Statement)
4 69. Defendant’s Twelfth Statement is an unequivocal call to action by
5 defendant to his followers and any person who happens on Defendant’s
6 Twitter account to prevent Plaintiff from earning income through YouTube,
7 Bar Wrestling and any, and all, past, present or future ventures related to
8 professional wrestling. The Statement taken as whole, vis-à-vis the many
9 accusatory statements by Defendant of Plaintiff committing sexual crimes
10 upon women, was understood by all readers of Defendant’s Twelfth
11 Statement that Plaintiff had committed numerous sexual crimes. Plaintiff
12 has never committed the acts that Defendant accused Plaintiff of
13 committing. Defendant’s Twelfth Statement is an assault on Plaintiff’s right
14 to make any form of income big or small in the professional wrestling
15 world, past, present and future.
16 70. As of September 9, 2020, Defendant’s Twelfth Statement was Replied
17 to 3 times and ”Retweeted” at least 133 times, with 170 “Likes”.
18
19 71. On or about September 3, 2020, Defendant used his Twitter account
20 with the handle “primeau31” to make the statement, “Hi @BarWrestling is
21 there a reason you blocked replies?? Maybe because you’re Joe Meehan
22 trying to get royalties? Don’t worry we’ll make sure this doesn’t work
23 (handshake emoji) htwitter.com/BarWrestling/s…” (Defendant’s
24 Thirteenth Statement)
25 72. Defendant’s Thirteenth Statement is an unequivocal call to action by
26 defendant to his followers and any person who happens on Defendant’s
27 Twitter account to prevent Plaintiff from earning income related to Bar
28
Complaint for Damages and
Demand for Jury Trial
18
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Wrestling. The handshake emoji was essentially saying “let’s all agree” to
1 terminate Plaintiff’s income stream from professional wrestling forever.
2 73. As of September 9, 2020, Defendant’s Thirteenth Statement had 7
3 “Likes”.
4
5 74. On or about September 3, 2020, Defendant used his Twitter account
6 with the handle “primeau31” to make the statement, “as a reminder Joey
7 Ryan ran Bar Wrestling and these videos are straight up on his YouTube
8 account [sic] watching these matches, no matter how many of your
9 favorites are in them, generates revenue for an accused serial sexual
10 predator twitter.com/BarWrestling/s…” (Defendant’s Fourteenth
11 Statement)
12 75. Defendant’s Fourteenth Statement is an unequivocal call to action by
13 defendant to his followers and any person who happens on Defendant’s
14 Twitter account to prevent Plaintiff from earning income through YouTube,
15 Bar Wrestling and any, and all, past, present or future ventures related to
16 professional wrestling. The Statement taken as whole, vis-à-vis the many
17 accusatory statements by Defendant of Plaintiff committing sexual crimes
18 upon women, was understood by all readers of Defendant’s Twelfth
19 Statement that Plaintiff had committed numerous sexual crimes. Plaintiff
20 has never committed the acts that Defendant accused Plaintiff of
21 committing. Defendant’s Twelfth Statement is an assault on Plaintiff’s right
22 to make any form of income big or small in the professional wrestling
23 world, past, present and future.
24 76. As of September 9, 2020, Defendant’s Fourteenth Statement was
25 Replied 1 time, ”Retweeted” at least 12 times, with 16 “Likes”.
26
27
28
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Demand for Jury Trial
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Case 2:20-cv-09623-AB-PLA Document 1 Filed 10/20/20 Page 20 of 63 Page ID #:20

2. Posts September 4, 2020

1 77. On or about September 4, 2020, Defendant used his Twitter account
2 with the handle “primeau31” to make the statement using attachments that
3 purported to be screenshots of Twitter messages between Defendant
4 using the name Pelle Tsichils and another Twitter user named Steve
5 Robbins (Robbins). Robbins expressed support for Plaintiff in the
6 message with, “I think it is sad that you [Defendant] can’t move on from
7 something that your ex did years ago. It’s okay buddy time heals all
8 wounds. …I think you’re pathetic for hiding behind this warrior gimmic
9 because your girl cheated on you.” Defendant responded, “We all know
10 he’s [referring to Plaintiff] a sexual predator” and “Have fun grabbing some
11 of the AMAZING Mexican food from that taco truck with Joe tonight bro!”
12 (Defendant’s Fifteenth Statement)
13 78. The reference to the “taco truck” was a reference by Defendant to an
14 accusation against Plaintiff by an accuser that before Plaintiff assaulted
15 the accuser, Plaintiff “took me [the accuser] straight to a bar where I only
16 had a few drinks (strong mixed cocktails) and it got me pretty messed up”.
17 79. Plaintiff published a video on youtube.com on or about July 18, 2020
18 refuting the false accusations made by another person. In the video
19 Plaintiff explained that the “bar” where the accuser had drinks with Plaintiff
20 served food from a taco truck in the parking lot where the two also ate
21 dinner. The accuser then stated that Plaintiff assaulted her after dinner
22 and drinks. Defendant’s Fifteenth Statement implied, that (1) Robbins and
23 Plaintiff planned to assault women after getting them drunk at the “taco
24 truck”; that (2) Robbins was in a relationship with Plaintiff and enjoyed
25 getting assaulted by Plaintiff in the manner Hasler falsely claimed she was
26 assaulted; and, or, that (3) Defendant was warning Robbins not to meet
27 Plaintiff at the taco truck or Plaintiff would assault him.
28
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20
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80. The implication was false and since Plaintiff never assaulted any
1 person and did not use alcohol or other intoxicant to assault women.
2 81. As of September 9, 2020, Defendant’s Fifteenth Statement was
3 Replied to 1 time and had 1 “Likes”.
4
5 3. Posts on August 31, 2020
6 82. On or about August 31, 2020, Defendant used his Twitter account with
7 the handle “primeau31” to make the statement, “Hi if you’re new here this
8 morning don’t allow Joe Meehan back in professional wrestling (thumbs
9 up emoji)(4 handshake emoji’s)” The post included a direct link to
10 Defendant’s Video, infra, Defendant posted on YouTube and an
11 attachment that when clicked would play Defendant’s Video while using
12 the Twitter application. (Defendant’s Sixteenth Statement)
13 83. Defendant’s Sixteenth Statement is an unequivocal call to action by
14 defendant to his followers and any person who happens on Defendant’s
15 Twitter account to prevent Plaintiff from earning income through YouTube,
16 Bar Wrestling and any, and all, past, present or future ventures related to
17 professional wrestling. The Statement taken as whole, vis-à-vis the many
18 accusatory statements by Defendant of Plaintiff committing sexual crimes
19 upon women, was understood by all readers of Defendant’s Sixteenth
20 Statement that Plaintiff had committed numerous sexual crimes. Plaintiff
21 has never committed the acts that Defendant accused Plaintiff of
22 committing. Defendant’s Sixteenth is an assault on Plaintiff’s right to make
23 any form of income big or small in the professional wrestling world, past,
24 present and future.
25 84. As of September 9, 2020, Defendant’s ???? Statement was Replied to
26 1 time with 2 “Likes”.
27
28
Complaint for Damages and
Demand for Jury Trial
21
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4. Posts on August 30, 2020

1 85. On or about August 30, 2020, Defendant used his Twitter account with
2 the handle “primeau31” to make the statement, “Yknow I’m having a
3 conversation with a friend RN and honestly – if you’re working on a show
4 that Joe Meehan gets booked on, and you don’t cancel that date you’re
5 every bit as guilty and accountable as the promotor. You can @ me on
6 this one, I got off work today.” (Defendant’s Seventeenth Statement)
7 86. Defendant’s Seventeenth Statement is an unequivocal call to action by
8 defendant to his followers and any person who happens on Defendant’s
9 Twitter account to prevent Plaintiff from earning income through YouTube,
10 Bar Wrestling and any, and all, past, present or future ventures related to
11 professional wrestling. The Defendant’s Seventeenth Statement taken as
12 whole, vis-à-vis the many accusatory statements (here “guilty” and
13 “accountable”) by Defendant of Plaintiff committing sexual crimes upon
14 women, was understood by all readers of Defendant’s Seventeenth
15 Statement that Plaintiff had committed numerous sexual crimes. Plaintiff
16 has never committed the acts that Defendant accused Plaintiff of
17 committing. Defendant’s Seventeenth Statement is an assault on Plaintiff’s
18 right to make any form of income big or small in the professional wrestling
19 world, past, present and future.
20 87. As of September 9, 2020, Defendant’s Seventeenth Statement was
21 Replied to 1 time and Retweeted 4 times with 11 Likes.
22
23 5. Posts on August 26, 2020
24 88. On or about August 26, 2020, Defendant used his Twitter account with
25 the handle “primeau31” to make the statement, “Please do not forget Bar
26 Wrestling was founded and is owned by Joey Ryan. This is not them
27 giving you “FREE wrestling” out of love I tis Joey’s way to continue to
28
Complaint for Damages and
Demand for Jury Trial
22
Case 2:20-cv-09623-AB-PLA Document 1 Filed 10/20/20 Page 23 of 63 Page ID #:23

make money by putting ads on “free videos” featuring notable talent. Do

1 not give this man your views. Twitter.com/BarWrestling/s…” (Defendant’s
2 Eighteenth Statement)
3 89. Defendant’s Eighteenth Statement is an unequivocal call to action by
4 defendant to his followers and any person who happens on Defendant’s
5 Twitter account to prevent Plaintiff from earning income related to Bar
6 Wrestling forever.
7 90. As of September 9, 2020, Defendant’s Eighteenth Statement was
8 Replied to 8 time and Retweeted 238 times with 372 Likes.
9
10
11 91. On or about August 26, 2020, Defendant used his Twitter account with
12 the handle “primeau31” to make the statement, “Hi Joe Meehan!! I hope
13 you get some time to watch this, and everyone knows to not watch a
14 single video from the Bar Wrestling YouTube account. (smiley face emoji)
15 Eat shit you jerk off. I’ll haunt you like a fucking ghost. (emojis)” and
16 included a direct link to Defendant’s Video, infra, he posted on YouTube.
17 Within the same string of tweets, Defendant made the statement, “Here’s
18 evidence of another WWE performer who’s engaged in preying on
19 children online. I hope you’re not okay with sponsoring a company who
20 hand-waves this activity.” (Defendant’s Nineteenth Statement)
21 92. Defendant’s Nineteenth Statement is an unequivocal call to action by
22 defendant to his followers and any person who happens on Defendant’s
23 Twitter account to prevent Plaintiff from earning income through YouTube,
24 Bar Wrestling and any, and all, past, present or future ventures related to
25 professional wrestling. The Defendant’s Nineteenth Statement taken as
26 whole, vis-à-vis the many accusatory by Defendant of Plaintiff committing
27 sexual crimes upon women, was understood by all readers of Defendant’s
28
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Demand for Jury Trial
23
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Nineteenth Statement that Plaintiff had committed numerous sexual

1 crimes. Additionally, Defendant’s Nineteenth Statement accused Plaintiff
2 of committing crimes upon “children” and refers to Plaintiff as “another
3 WWE performer”. Plaintiff has never committed the acts that Defendant
4 accused Plaintiff of committing including the accusation related to “preying
5 on children online”. Defendant’s Nineteenth Statement is an assault on
6 Plaintiff’s right to make any form of income big or small in the professional
7 wrestling world, past, present and future.
8 93. As of September 9, 2020, Defendant’s Nineteenth Statement was
9 Retweeted 4 times time with 6 “Likes”.
10
11 6. Posts on August 9, 2020
12 94. On or about August 9, 2020, Defendant used his Twitter account with
13 the handle “primeau31” to make a series of statements to prevent Plaintiff
14 from making any income in professional wrestling and attached a link to
15 Defendant’s Video, infra, he posted on YouTube. Defendant stated,
16 a. “Lately people have unfollowed me for calling out antisemitism in the
17 Black community and for pointing out Joey Ryan is a horrible rapist.”
18 b. With a link to the Defendant’s Video and a photo of Plaintiff with a red
19 circle and red slash superimposed over Plaintiff and the words “A
20 Responses, a Call for Action” Plaintiff stated, “Hoping to get a public
21 commitment to never do business with Joseph “Joey Ryan” Meehan.
22 @HeyHeyItsConrad @StarcastEvents @PWTees @ColtCabana
23 @MartyDeRosa @CodyRhodes @TonyKhan” The persons and entities
24 named after the “@” were all related to professional wrestling and
25 professional wrestling promotions.
26 c. With a link to the Defendant’s Video and a photo of Plaintiff with a red
27 circle and red slash superimposed over Plaintiff and the words “A
28
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Demand for Jury Trial
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Case 2:20-cv-09623-AB-PLA Document 1 Filed 10/20/20 Page 25 of 63 Page ID #:25

Responses, a Call for Action” Plaintiff stated, “I’ve never asked for
1 anything/favors. Breaking that rule today. @GCWrestling
2 @beyondwrestling @aiwrestling @JohnThorneAIW @Lauderdale11
3 @BLPMIkey @RockstarProWres @ParadigmProWres @FrelanceWres
4 @ringofhonor @IMPACTWRESTLING @BLabelPro @TheDannyCage
5 @4MonsterFactory @dannydemanto @ICWNHB”
6 d. With a link to the Defendant Video and a photo of Plaintiff with a red
7 circle and red slash superimposed over Plaintiff and the words “A
8 Responses, a Call for Action” Plaintiff stated, “Calling on Accountability
9 and Public Commitment. Looking forward to everyone’s actions
10 speaking for themselves moving forward @NWA @Billy
11 @CWFHMarquez @ScrapDaddyAP”
12 e. With a link to the Defendant’s Video and a photo of Plaintiff with a red
13 circle and red slash superimposed over Plaintiff and the words “A
14 Responses, a Call for Action” Plaintiff stated, “@ShutupExcalibur
15 @OfficialPWG @BeingtheElite It would be very helpful for a
16 clarification from Pro Wrestling Guerilla on post-pandemic plans re:
17 Joseph Meehan.”
18 f. With a link to the Defendant’s Video and a photo of Plaintiff with a red
19 circle and red slash superimposed over Plaintiff and the words “A
20 Responses, a Call for Action” Plaintiff stated, “Attempting to call major
21 independent promotions to commit publicly and unify against Joe
22 Meehan @ryansatin @SeanRossSapp @FightfulWrestle
23 @BleacherReport @MikePWInsider @PWInsider.com @OfficialPWI
24 @davemeltzerWON @thewadekeller @PWTorch @WrestlingSheet”
25 g. With a link to the Defendant’s Video and a photo of Plaintiff with a red
26 circle and red slash superimposed over Plaintiff and the words “A
27 Responses, a Call for Action” Plaintiff stated, “asking for a commitment
28
Complaint for Damages and
Demand for Jury Trial
25
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to not shoot any shows featuring Joseph Meehan moving forward

1 @indiewrestling @smartmarkvideo @IWTV_JP”
2 (Defendant’s Twentieth Statement)
3 95. Defendant’s Twentieth Statement is an unequivocal call to action by
4 defendant to his followers and any person who happens on Defendant’s
5 Twitter account to prevent Plaintiff from earning income through YouTube,
6 Bar Wrestling and any, and all, past, present or future ventures related to
7 professional wrestling. The Defendant’s Twentieth Statement taken as
8 whole, vis-à-vis the many accusatory by Defendant of Plaintiff committing
9 sexual crimes upon women, was understood by all readers of Defendant’s
10 Twentieth Statement that Plaintiff had committed numerous sexual
11 crimes.” Plaintiff has never committed the acts that Defendant accused
12 Defendant’s Twentieth Statement is an assault on Plaintiff’s right to make
13 any form of income big or small in the professional wrestling world, past,
14 present and future.
15 96. As of September 9, 2020, Defendant’s Twentieth Statement was
16 Replied to, Retweeted and Liked multiple times.
17
18 7. Posts on August 8, 2020
19 97. On or about August 8, 2020, Defendant used his Twitter account with
20 the handle “primeau31” to make the statement, “Good Morning, I’m
21 challenging everyone in wrestling to do the right thing together for once:”
22 then added a link to the Defendant’s Video which could immediately be
23 viewed by clicking on a photo of Plaintiff with a red circle and red slash
24 superimposed over Plaintiff with the words “A Responses, a Call for
25 Action”. (Defendant’s Twenty-First Statement)
26 98. Prior to publishing Defendant’s Twenty-First Statement , Defendant
27 made a series of statements using his Twitter account with the handle
28
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Demand for Jury Trial
26
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“primeau31” first “Ready to shoot in 20 minutes” and added a photo of

1 Defendant’s studio showing various computer screens, including showing
2 false accusations of women made against Plaintiff that Defendant used in
3 the backdrop in the Defendant’s Video. The next statement, “Editing”. The
4 next statement, “Rendering” and the last “Uploading”. The statements
5 were apparently intended by Defendant to create anticipation of the
6 publishing of Defendant’s Video similar to a buildup and promotion of an
7 upcoming entertainment event. Defendant was apparently letting the world
8 know that Defendant was making and publishing a video that would ruin
9 Plaintiff and that was of great significance and importance to any person in
10 professional wrestling.
11 99. To make it clear that the Defendant Video was intended to damage,
12 really destroy, Plaintiff, on August 7, 2020, Defendant used his Twitter
13 account with the handle “primeau31” to make the statement, “ask if he
14 knows he’s on the tracks, the train is on its way in about an hour or so”
15 then attached a screenshot a photo of Plaintiff identifying the photo as
16 “Joey Ryan”.
17 100. As of September 9, 2020, Defendant’s Twenty-First Statement was
18 Replied to 4 time and Retweeted 31 times with 35 Likes.
19
20 101. On or about August 8, 2020, Defendant used his Twitter account with
21 the handle “primeau31” to make the statement, “Hey JoeyRyanOnline I’m
22 sure you vanity search first thing in the morning anyway but I thought I’d
23 help you out and send it to you. Enjoy it.” Then, “Good Morning, I’m
24 challenging everyone in wrestling to do the right thing together for once:”
25 then added a link to the Defendant Video”. (Defendant’s Twenty-Second
26 Statement)
27
28
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Demand for Jury Trial
27
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102. Defendant’s Twenty-Second Statement is an unequivocal call to action

1 by defendant to his followers and any person who happens on
2 Defendant’s Twitter account to prevent Plaintiff from earning income
3 through YouTube, Bar Wrestling and any, and all, past, present or future
4 ventures related to professional wrestling. The Defendant’s Twenty-
5 Second Statement taken as whole, vis-à-vis the many accusatory by
6 Defendant of Plaintiff committing sexual crimes upon women, was
7 understood by all readers of Defendant’s Twenty-Second Statement that
8 Plaintiff had committed numerous sexual crimes.” Plaintiff has never
9 committed the acts that Defendant accused Defendant’s Twenty-Second
10 Statement is an assault on Plaintiff’s right to make any form of income
11 103. As of September 9, 2020, Defendant’s Twenty-Second Statement was
12 Retweeted 3 times with 4 Likes.
13
14 104. On or about August 8, 2020, Defendant used his Twitter account with
15 the handle “primeau31” to make the statement, “Patreon and Cameo will
16 be contacted this evening: Deplatforming works.” (Defendant’s Twenty-
17 Third Statement)
18 105. Patreon is a website or platforms that allow artists and creators to
19 publish content, e.g., videos’, photos, etc. and also allow users to interact
20 through chat, for example, by paying monthly membership fee. By paying
21 the membership fees persons become “patrons”. Cameo is another
22 interactive income stream through video messaging. Plaintiff is and was a
23 member of Patreon and Cameo and does, and did, have subscribers who
24 paid Plaintiff the monthly membership fees.
25 106. Defendant was fully aware that Plaintiff used the platforms to generate
26 income. Defendant statement of “deplatforming works” was an indication
27 that Defendant intended to prevent Plaintiff from generating income
28
Complaint for Damages and
Demand for Jury Trial
28
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through Plaintiff’s use of Patreon and Cameo, in Defendant’s quest to

1 prevent Plaintiff from realizing any income related to professional
2 wrestling.
3 107. As of September 9, 2020, Defendant’s Twenty-Third Statement was
4 Replied to 1 time with 11 Likes.
5
6 8. Posts on August 7, 2020
7 108. On or about August 7, 2020, Defendant created a thirty-seven-minute
8 video (Defendant’s Video) that was viewed at least 808 times on
9 YouTube by September 18, 2020. The video was posted on YouTube and
10 made available on Twitter. In the video. Defendant sits in front of a
11 backdrop of screenshots of many of the Defamatory Statements above
12 listed.
13 109. In Defendant’s Video, Defendant was serious and was without any
14 sense or indication that his statements were meant to be taken as a joke.
15 In fact, Defendant screamed or spoke with a raised voice throughout the
16 Defendant’s Video and was visibly angry.
17 110. In Defendant’s Video, Defendant states that Plaintiff does “not [take] no
18 for an answer” in reference to Plaintiff’s sexual encounters with women
19 and that Plaintiff “used power and influence” to assault women.
20 111. In Defendant’s Video, Defendant makes it clear that Defendant knows,
21 and has known, that Plaintiff lives in Los Angeles and his lived in Los
22 Angeles in his professional wrestling career when he said, “Especially
23 when he is flying from So Cal. He just wants to do his work. Do his shot
24 and then get back on the plane right back to So Cal” and when he said,
25 “One Joseph Ryan Meehan out of Southern California”
26 112. In Defendant’s Video, Defendant made his intent clear about destroying
27 Plaintiff financially, “We are taking ‘Joey Ryan’ away from “Joseph Ryan
28
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Meehan” “the very least we can do is make sure that the ‘Joey Ryan’
1 brand is laid out to rest.” That is to say that Defendant was aware of the
2 high value in the brand of “Joey Ryan” the wrestler and that Defendant
3 intended on ruining the Joey Ryan brand to such a degree that Plaintiff
4 could never again profit, financially or otherwise, from the “Joey Ryan
5 brand”.
6 113. In Defendant’s Video, after naming professional wrestlers who were in
7 the past accused of involvement in scandal, Defendant states that those
8 wrestlers “are still here. And are still making money off the business. Not
9 you [referring to Plaintiff]. We’re putting our foot down. We’re not letting
10 you back in the ring. I will remind professional wrestling every single day if
11 I have to. I will get on Twitter. I will get on social media. I will email
12 promotors. I will email bookers. …Your house of cards and your ilk, it’s
13 going to start to fall.…And if I can’t do it myself. If I’m not in locker rooms
14 myself. Then I’m calling on [names of over thirty names of persons and
15 business entities involved in professional wrestling promotions]. …Keep
16 him [referring to Plaintiff] out of wrestling. …Don’t ever let this man have
17 access to money from the professional wrestling business ever again.
18 …Joseph Meehan will never step foot in your rings again.”
19
20 114. On or about August 7, 2020, Defendant used his Twitter account with
21 the handle “primeau31” to make the statement, “I’m out here to make sure
22 he never steps foot in a ring again. If that’s my legacy then so be it, if Im
23 [sic] ever remembered for anything let it be the man who held him
24 [Plaintiff] accountable.” (Defendant’s Twenty-Fourth Statement)
25 115. Defendant uses the word “accountable” to mean that Plaintiff assaulted
26 women and committed sexual crimes against women, especially in the
27 face of Defendant’s other statements published prior to Defendant’s
28
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Twenty-Fourth Statement and on the same day when Defendant

1 published Defendant’s Video. Defendant implied that Plaintiff was going to
2 pay for his sexual crimes against women because Defendant was
3 intending on being the person that prevents Plaintiff from ever again
4 engaging in professional wrestling.
5 116. As of September 9, 2020, Defendant’s Twenty-Fourth Statement was
6 had 12 Likes.
7
8 9. Posts on July 18, 2020
9 117. On or about July 18, 2020, Defendant used his Twitter account with the
10 handle “primeau31” to make the statement, “joey ryan raped my friend!
11 But you know, he was ‘nice’ when he sold you a t-shirt so I understand
12 how hard this must be for you to believe. he raped someone I love! …”
13 (Defendant’s Twenty-Fifth Statement)
14 118. The statement is meant to have greater impact because it is a
15 statement of another person vouching for the credibility of the rape
16 accusation.
17 119. It is a false statement that Plaintiff committed the crime of rape upon
18 any person in any way shape or form.
19 120. As of September 10, 2020, Defendant’s Twenty-Fifth Statement was
20 Replied to 1 time and was Retweeted 11 times with 92 Likes.
21
22 10. Posts on July 19, 2020
23 121. On or about July 19, 2020, Defendant used his Twitter account with the
24 handle “primeau31” to make the statement, “@JoeyRyanOnline just
25 watched where you talk about me. …I’m sure it is hard to remember all
26 occasions where you tried to force yourself onto girls.” (Defendant’s
27 Twenty-Sixth Statement)
28
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122. It is a false statement that Plaintiff forced himself on any person for
1 sexual gratification.
2 123. As of September 10, 2020, Defendant’s Twenty-Sixth Statement was
3 Replied to 4 time and was Retweeted 21 times with 200 Likes..
4 I. CLAIM I
5 (Libel against Defendant)
124. Plaintiff incorporates by reference paragraphs 1 through 123 as though
6
fully set forth herein.
7
125. Defendant made and published the defamatory statements as
8
specifically described above and herein,
9
a. Defendant’s Second Statement;
10
b. Defendant’s Fourth Statement;
11
c. Defendant’s Fifth Statement;
12
d. Defendant’s Eighth Statement;
13
e. Defendant’s Ninth Statement;
14
f. Defendant’s Eleventh Statement;
15
g. Defendant’s Twelfth Statement;
16
h. Defendant’s Fifteenth Statement;
17
i. Defendant’s Sixteen Statement;
18
j. Defendant’s Seventeenth Statement;
19
k. Defendant’s Nineteenth Statement;
20
l. Defendant’s Twentieth Statement;
21
m. Defendant’s Twenty-Second Statement;
22
n. Defendant’s Twenty-Fourth Statement;
23
o. Defendant’s Twenty-Fifth Statement;
24
p. Defendant’s Twenty-Sixth Statement; and
25
q. Defendant’s Video
26
126. Defendant used at least Twitter, including on and in each of their own
27
Twitter subscriptions, accounts, identities, and handles, to write, and
28
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thereby publish, the defamatory statements described above and

1 incorporated by reference herein, which included, that (1) Plaintiff
2 assaulted women; (2) Plaintiff committed a sexual battery on women; (3)
3 Plaintiff committed (1) and (2) in a manner that would be considered a
4 felony;(4) women engaged in sexual acts with Plaintiff without the consent
5 of those women; and/or (5) women were forced by Plaintiff to engage in
6 sexual acts with Plaintiff, forced meaning the use of fear, threat and
7 intimidation.
8 127. On information and belief, defendant did use other social media
9 websites to write, and thereby publish, the defamatory statements
10 described above and incorporated by reference herein.
11 128. Prior to publishing the defamatory statements, defendant was fully
12 aware that Twitter and the other social media websites used to publish
13 defendant’s defamatory statements described above and incorporated by
14 reference herein had members and subscribers located worldwide and
15 were connected to the professional wrestling industry, because defendant
16 was users, subscribers, account holders of Twitter and had Twitter
17 handles and thus understood how Twitter and social media websites
18 worked.
19 129. Prior to publishing the defamatory statements, defendant was fully
20 aware that Twitter had a membership of approximately in excess of three
21 hundred million persons and that by publishing the defamatory
22 statements, the defamatory statements would be read by hundreds to
23 thousands of Twitter’s membership, because defendant was users,
24 subscribers, account holders of Twitter and had Twitter handles and thus
25 understood how Twitter and social media websites worked.
26 130. Prior to publishing the defamatory statements, defendant was fully
27 aware that publishing the defamatory statements described above and
28
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incorporated by reference herein would reach the eyes and ears of at

1 least hundreds to thousands of persons, and that after defendant did
2 publish the defamatory statements described above and incorporated by
3 reference herein that the published defamatory statements did reach the
4 eyes and ears of at least hundreds to thousands of persons, because
5 defendant was users, subscribers, account holders of Twitter and had
6 Twitter handles and thus understood how Twitter and social media
7 websites worked.
8 131. Defendant published the defamatory statements described above and
9 incorporated by reference herein fully aware that Plaintiff lived in Los
10 Angeles, California and that Plaintiff was a professional wrestler and
11 promotor in the state of California. Defendant was fully aware that Plaintiff
12 was a principal of Bar Wrestling and that Bar Wrestling promoted wrestling
13 matches in bars in Los Angeles, California.
14 132. Defendant was fully aware that Defendant defamatory statements
15 described above and incorporated by reference herein would cause a
16 negative effect on Plaintiff as a professional wrestler and wrestling
17 promotor, i.e., defendant intended that the defamatory statements would
18 prevent Plaintiff from practicing as a professional wrestler and further
19 wrestling promotions. In addition, defendant was fully aware that because
20 of the defamatory statements, Plaintiff’s reputation would be damaged in
21 the community in California and the virtual community located in the world-
22 wide-web that were related to Plaintiff’s as a professional wrestler and
23 wrestling promotor
24 133. It was, is, and has always been, untrue, and false, that (1) Plaintiff
25 assaulted women; (2) Plaintiff committed a sexual battery on women; (3)
26 Plaintiff committed (1) and (2) in a manner that would be considered a
27 felony;(4) women engaged in sexual acts with Plaintiff without the consent
28
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of those women; and/or (5) women were forced by Plaintiff to engage in

1 sexual acts with Plaintiff, forced meaning the use of fear, threat and
2 intimidation.
3 134. Defendant’s defamatory statements were not privileged and Plaintiff did
4 not consent to the publication of the defamatory statements. Plaintiff, in
5 fact, implored defendant to stop the publication of the defamatory
6 statements. Defendant responded by repeating more statements that (1)
7 Plaintiff assaulted women; (2) Plaintiff committed a sexual battery on
8 women; (3) Plaintiff committed (1) and (2) in a manner that would be
9 considered a felony;(4) women engaged in sexual acts with Plaintiff
10 without the consent of those women; and/or (5) women were forced by
11 Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of
12 fear, threat and intimidation.
13 135. Prior to publishing the defamatory statements, defendant knew and
14 otherwise were fully aware that the defamatory statements were not true.
15 136. Prior to publishing the defamatory statements, defendant acted in
16 reckless disregard for the truth in the defamatory statements by not
17 conducting any diligence, inquiry and investigation as to whether or not
18 the defamatory statements were true or false.
19 137. Prior to publishing the defamatory statements, defendant failed to use
20 reasonable care to determine the truth or falsity in the defamatory
21 statements by not conducting reasonable diligence, inquiry and
22 investigation as to whether or not the defamatory statements were true or
23 false.
24 138. The hundreds to thousands of person who did read defendant’s
25 defamatory statements on Twitter and other social media websites
26 understood the defamatory statements to be of and concerning Plaintiff
27 and were understood by the hundreds to thousands of persons to mean
28
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that (1) Plaintiff assaulted women; (2) Plaintiff committed a sexual battery
1 on women; (3) Plaintiff committed (1) and (2) in a manner that would be
2 considered a felony;(4) women engaged in sexual acts with Plaintiff
3 without the consent of those women; and/or (5) women were forced by
4 Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of
5 fear, threat and intimidation.
6 139. Because of the facts and circumstances that were known to the
7 hundreds to thousands of readers of the defamatory statements, including
8 that Plaintiff was a professional wrestler and wrestling promotor in
9 California,
10 (1)The defamatory statements tended to injure Plaintiff as a
11 professional wrestler and wrestling promotor, and otherwise injure
12 Plaintiff whether or not as a professional wrestler and wrestling
13 promotor;
14 (2)The defamatory statements exposed Plaintiff to hatred, contempt,
15 ridicule, and shame by (1) persons residing in California; (2) persons
16 involved and interested in professional wrestling and wrestling
17 promotions; and (4) those persons using the world-wide-web
18 interested in Plaintiff, professional wrestling and wrestling
19 promotions; and
20 (3)The defamatory statements discouraged others from associating or
21 dealing with Plaintiff.
22 140. Defendant knew that the listeners and readers of the defamatory
23 statements would be compelled to republish the defamatory statements to
24 others by word of mouth, electronic communication and through social
25 media websites and the persons who did hear and did read the
26 defamatory statements did republish the defamatory statements to others,
27 because defendant was users, subscribers, account holders of Twitter and
28
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had Twitter handles and thus understood how Twitter and social media
1 websites worked.
2 141. Defendant’s defamatory statements caused Plaintiff to lose
3 employment and income.
4 142. Defendant’s defamatory statements caused Plaintiff’s California and
5 virtual community to shun him, avoid him and hate him and further caused
6 Plaintiff’s California and virtual community to stop being his friend, stop
7 following him, or otherwise end any, and all, connection and association to
8 Plaintiff.
9 143. Plaintiff’s personal and professional reputation were harmed as a result
10 of defendant’s defamatory statements and such reputation is continuing to
11 be harmed because defendant continue to make the same defamatory
12 statements as described and continue to permit the defamatory
13 statements to go viral on social media websites.
14 144. Plaintiff sustained reputational and financial harm to his businesses,
15 professions and occupations as a result of the defamatory statements.
16 145. Plaintiff was damaged as set forth below and as follows,
17 WHEREFORE Plaintiff prays that this court grant relief in compensatory
18 damages against each defendant and in favor of Plaintiff in the amount of
19 $5,000.000.00, for an order retracting and correcting the defamatory
20 statements, for equitable relief based on principles that are fair and just, and
21 for judgment as also set forth below.
22 WHEREFORE, Plaintiff prays for judgment as set forth below.
23 II. CLAIM II
24 (Libel Per Se against defendant)
25 146. Plaintiff incorporates by reference paragraphs 1 through 145 as though
26 fully set forth herein.
27 147. Defendant made and published the defamatory statements as
28 specifically described above and herein,
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a. Defendant’s Second Statement;

1 b. Defendant’s Fourth Statement;
2 c. Defendant’s Fifth Statement;
3 d. Defendant’s Eighth Statement;
4 e. Defendant’s Ninth Statement;
5 f. Defendant’s Eleventh Statement;
6 g. Defendant’s Twelfth Statement;
7 h. Defendant’s Fifteenth Statement;
8 i. Defendant’s Sixteen Statement;
9 j. Defendant’s Seventeenth Statement;
10 k. Defendant’s Nineteenth Statement;
11 l. Defendant’s Twentieth Statement;
12 m. Defendant’s Twenty-Second Statement;
13 n. Defendant’s Twenty-Fourth Statement;
14 o. Defendant’s Twenty-Fifth Statement;
15 p. Defendant’s Twenty-Sixth Statement; and
16 q. Defendant’s Video
17 148. Defendant used at least Twitter, including on and in each of their own
18 Twitter subscriptions, accounts, identities, and handles, to write, and
19 thereby publish, the defamatory statements described above and
20 incorporated by reference herein, which included, that (1) Plaintiff
21 assaulted women; (2) Plaintiff committed a sexual battery on women; (3)
22 Plaintiff committed (1) and (2) in a manner that would be considered a
23 felony;(4) women engaged in sexual acts with Plaintiff without the consent
24 of those women; and/or (5) women were forced by Plaintiff to engage in
25 sexual acts with Plaintiff, forced meaning the use of fear, threat and
26 intimidation.
27
28
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149. On information and belief, defendant did use other social media
1 websites to write, and thereby publish, the defamatory statements
2 described above and incorporated by reference herein.
3 150. Prior to publishing the defamatory statements, defendant was fully
4 aware that Twitter and the other social media websites used to publish
5 defendant’s defamatory statements described above and incorporated by
6 reference herein had members and subscribers located worldwide and
7 were connected to the professional wrestling industry, because defendant
8 was users, subscribers, account holders of Twitter and had Twitter
9 handles and thus understood how Twitter and social media websites
10 worked.
11 151. Prior to publishing the defamatory statements, defendant was fully
12 aware that Twitter had a membership of approximately in excess of three
13 hundred million persons and that by publishing the defamatory
14 statements, the defamatory statements would be read by hundreds to
15 thousands of Twitter’s membership, because defendant was users,
16 subscribers, account holders of Twitter and had Twitter handles and thus
17 understood how Twitter and social media websites worked.
18 152. Prior to publishing the defamatory statements, defendant was fully
19 aware that publishing the defamatory statements described above and
20 incorporated by reference herein would reach the eyes and ears of at
21 least hundreds to thousands of persons, and that after defendant did
22 publish the defamatory statements described above and incorporated by
23 reference herein that the published defamatory statements did reach the
24 eyes and ears of at least hundreds to thousands of persons, because
25 defendant was users, subscribers, account holders of Twitter and had
26 Twitter handles and thus understood how Twitter and social media
27 websites worked.
28
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153. Defendant published the defamatory statements described above and

1 incorporated by reference herein fully aware that Plaintiff lived in Los
2 Angeles, California and that Plaintiff was a professional wrestler and
3 promotor in the state of California. Defendant was fully aware that Plaintiff
4 was a principal of Bar Wrestling and that Bar Wrestling promoted wrestling
5 matches in bars in Los Angeles, California.
6 154. Defendant was fully aware that Defendant defamatory statements
7 described above and incorporated by reference herein would cause a
8 negative effect on Plaintiff as a professional wrestler and wrestling
9 promotor, i.e., defendant intended that the defamatory statements would
10 prevent Plaintiff from practicing as a professional wrestler and further
11 wrestling promotions. In addition, defendant was fully aware that because
12 of the defamatory statements, Plaintiff’s reputation would be damaged in
13 the community in California and the virtual community located in the world-
14 wide-web that were related to Plaintiff’s as a professional wrestler and
15 wrestling promotor
16 155. It was, is, and has always been, untrue, and false, that (1) Plaintiff
17 assaulted women; (2) Plaintiff committed a sexual battery on women; (3)
18 Plaintiff committed (1) and (2) in a manner that would be considered a
19 felony;(4) women engaged in sexual acts with Plaintiff without the consent
20 of those women; and/or (5) women were forced by Plaintiff to engage in
21 sexual acts with Plaintiff, forced meaning the use of fear, threat and
22 intimidation.
23 156. Defendant’s defamatory statements were not privileged and Plaintiff did
24 not consent to the publication of the defamatory statements. Plaintiff, in
25 fact, implored defendant to stop the publication of the defamatory
26 statements. Defendant responded by repeating more statements that (1)
27 Plaintiff assaulted women; (2) Plaintiff committed a sexual battery on
28
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women; (3) Plaintiff committed (1) and (2) in a manner that would be
1 considered a felony;(4) women engaged in sexual acts with Plaintiff
2 without the consent of those women; and/or (5) women were forced by
3 Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of
4 fear, threat and intimidation.
5 157. Prior to publishing the defamatory statements, defendant knew and
6 otherwise were fully aware that the defamatory statements were not true.
7 158. Prior to publishing the defamatory statements, defendant acted in
8 reckless disregard for the truth in the defamatory statements by not
9 conducting any diligence, inquiry and investigation as to whether or not
10 the defamatory statements were true or false.
11 159. Prior to publishing the defamatory statements, defendant failed to use
12 reasonable care to determine the truth or falsity in the defamatory
13 statements by not conducting reasonable diligence, inquiry and
14 investigation as to whether or not the defamatory statements were true or
15 false.
16 160. The hundreds to thousands of person who did read defendant’s
17 defamatory statements on Twitter and other social media websites
18 understood the defamatory statements to be of and concerning Plaintiff
19 and were understood by the hundreds to thousands of persons to mean
20 that (1) Plaintiff assaulted women; (2) Plaintiff committed a sexual battery
21 on women; (3) Plaintiff committed (1) and (2) in a manner that would be
22 considered a felony;(4) women engaged in sexual acts with Plaintiff
23 without the consent of those women; and/or (5) women were forced by
24 Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of
25 fear, threat and intimidation.
26 161. Because of the facts and circumstances that were known to the
27 hundreds to thousands of readers of the defamatory statements, including
28
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that Plaintiff was a professional wrestler and wrestling promotor in

1 California,
2 (1) The defamatory statements tended to injure Plaintiff as a professional
3 wrestler and wrestling promotor, and otherwise injure Plaintiff whether
4 or not as a professional wrestler and wrestling promotor;
5 (2) The defamatory statements exposed Plaintiff to hatred, contempt,
6 ridicule, and shame by (1) persons residing in California; (2) persons
7 involved and interested in professional wrestling and wrestling
8 promotions; and (4) those persons using the world-wide-web interested
9 in Plaintiff, professional wrestling and wrestling promotions; and
10 (3) The defamatory statements discouraged others from associating or
11 dealing with Plaintiff.
12 162. Defendant knew that the listeners and readers of the defamatory
13 statements would be compelled to republish the defamatory statements to
14 others by word of mouth, electronic communication and through social
15 media websites and the persons who did hear and did read the
16 defamatory statements did republish the defamatory statements to others,
17 because defendant was users, subscribers, account holders of Twitter and
18 had Twitter handles and thus understood how Twitter and social media
19 websites worked.
20 163. Defendant’s defamatory statements caused Plaintiff to lose
21 employment and income.
22 164. Defendant’s defamatory statements caused Plaintiff’s California and
23 virtual community to shun him, avoid him and hate him and further caused
24 Plaintiff’s California and virtual community to stop being his friend, stop
25 following him, or otherwise end any, and all, connection and association to
26 Plaintiff.
27 165. Plaintiff’s personal and professional reputation were harmed as a result
28
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of defendant’s defamatory statements and such reputation is continuing to

1 be harmed because defendant continue to make the same defamatory
2 statements as described and continue to permit the defamatory
3 statements to go viral on social media websites.
4 166. Plaintiff sustained reputational and financial harm to his businesses,
5 professions and occupations as a result of the defamatory statements.
6 167. Plaintiff was damaged as set forth below and as follows,
7 WHEREFORE Plaintiff prays that this court grant relief in compensatory
8 damages against each defendant and in favor of Plaintiff in the amount of
9 $5,000.000.00, for an order retracting and correcting the defamatory
10 statements, for equitable relief based on principles that are fair and just, and
11 for judgment as also set forth below.
12 WHEREFORE, Plaintiff prays for judgment as set forth below.
13 III. CLAIM III
14 (Trade Libel against defendant)
15 168. Plaintiff incorporates by reference paragraphs 1 through 167 as though
16 fully set forth herein.
17 169. Defendant made and published the defamatory statements as
18 specifically described above, which among other things falsely accused
19 Plaintiff of committing and rendering unprofessional and substandard
20 services as a professional wrestler, wrestling promotor, and additionally
21 tarnished the “Joey Ryan” brand name. Plaintiff has spent over twenty
22 years in developing his brand by promoting his wrestling, personality, and
23 character portrayal of “Joey Ryan” more immediately, through social
24 media websites, including Twitter, Facebook, YouTube, Patreon and
25 Cameo. Patreon and Cameo garnered monthly revenues to Plaintiff..
26 170. Defendant made and published the defamatory statements as
27 specifically described above and herein,
28
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a. Defendant’s First Statement through Defendant’s Twenty-Sixth

1 Statement; and
2 b. Defendant’s Video
3 171. Defendant used at least Twitter, including on and in each of their own
4 Twitter subscriptions, accounts, identities, and handles, to write, and
5 thereby publish, the defamatory statements described above and
6 incorporated by reference herein, which included, that (1) Plaintiff
7 assaulted women; (2) Plaintiff committed a sexual battery on women; (3)
8 Plaintiff committed (1) and (2) in a manner that would be considered a
9 felony;(4) women engaged in sexual acts with Plaintiff without the consent
10 of those women; and/or (5) women were forced by Plaintiff to engage in
11 sexual acts with Plaintiff, forced meaning the use of fear, threat and
12 intimidation.
13 172. On information and belief, defendant did use other social media
14 websites to write, and thereby publish, the defamatory statements
15 described above and incorporated by reference herein.
16 173. Prior to publishing the defamatory statements, defendant was fully
17 aware that Twitter and the other social media websites used to publish
18 defendant’s defamatory statements described above and incorporated by
19 reference herein had members and subscribers located worldwide and
20 were connected to the professional wrestling industry, because defendant
21 was users, subscribers, account holders of Twitter and had Twitter
22 handles and thus understood how Twitter and social media websites
23 worked.
24 174. Prior to publishing the defamatory statements, defendant was fully
25 aware that Twitter had a membership of approximately in excess of three
26 hundred million persons and that by publishing the defamatory
27 statements, the defamatory statements would be read by hundreds to
28
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thousands of Twitter’s membership, because defendant was users,

1 subscribers, account holders of Twitter and had Twitter handles and thus
2 understood how Twitter and social media websites worked.
3 175. Prior to publishing the defamatory statements, defendant was fully
4 aware that publishing the defamatory statements described above and
5 incorporated by reference herein would reach the eyes and ears of at
6 least hundreds to thousands of persons, and that after defendant did
7 publish the defamatory statements described above and incorporated by
8 reference herein that the published defamatory statements did reach the
9 eyes and ears of at least hundreds to thousands of persons, because
10 defendant was users, subscribers, account holders of Twitter and had
11 Twitter handles and thus understood how Twitter and social media
12 websites worked.
13 176. Defendant published the defamatory statements described above and
14 incorporated by reference herein fully aware that Plaintiff lived in Los
15 Angeles, California and that Plaintiff was a professional wrestler and
16 promotor in the state of California. Defendant was fully aware that Plaintiff
17 was a principal of Bar Wrestling and that Bar Wrestling promoted wrestling
18 matches in bars in Los Angeles, California.
19 177. Defendant was fully aware that Defendant defamatory statements
20 described above and incorporated by reference herein would cause a
21 negative effect on Plaintiff as a professional wrestler and wrestling
22 promotor, i.e., defendant intended that the defamatory statements would
23 prevent Plaintiff from practicing as a professional wrestler and further
24 wrestling promotions. In addition, defendant was fully aware that because
25 of the defamatory statements, Plaintiff’s reputation would be damaged in
26 the community in California and the virtual community located in the world-
27
28
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wide-web that were related to Plaintiff’s as a professional wrestler and

1 wrestling promotor
2 178. It was, is, and has always been, untrue, and false, that (1) Plaintiff
3 assaulted women; (2) Plaintiff committed a sexual battery on women; (3)
4 Plaintiff committed (1) and (2) in a manner that would be considered a
5 felony;(4) women engaged in sexual acts with Plaintiff without the consent
6 of those women; and/or (5) women were forced by Plaintiff to engage in
7 sexual acts with Plaintiff, forced meaning the use of fear, threat and
8 intimidation.
9 179. Defendant’s defamatory statements were not privileged and Plaintiff did
10 not consent to the publication of the defamatory statements. Plaintiff, in
11 fact, implored defendant to stop the publication of the defamatory
12 statements. Defendant responded by repeating more statements that (1)
13 Plaintiff assaulted women; (2) Plaintiff committed a sexual battery on
14 women; (3) Plaintiff committed (1) and (2) in a manner that would be
15 considered a felony;(4) women engaged in sexual acts with Plaintiff
16 without the consent of those women; and/or (5) women were forced by
17 Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of
18 fear, threat and intimidation.
19 180. Prior to publishing the defamatory statements, defendant knew and
20 otherwise were fully aware that the defamatory statements were not true.
21 181. Prior to publishing the defamatory statements, defendant acted in
22 reckless disregard for the truth in the defamatory statements by not
23 conducting any diligence, inquiry and investigation as to whether or not
24 the defamatory statements were true or false.
25 182. Prior to publishing the defamatory statements, defendant failed to use
26 reasonable care to determine the truth or falsity in the defamatory
27 statements by not conducting reasonable diligence, inquiry and
28
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investigation as to whether or not the defamatory statements were true or

1 false.
2 183. The hundreds to thousands of person who did read defendant’s
3 defamatory statements on Twitter and other social media websites
4 understood the defamatory statements to be of and concerning Plaintiff
5 and were understood by the hundreds to thousands of persons to mean
6 that (1) Plaintiff assaulted women; (2) Plaintiff committed a sexual battery
7 on women; (3) Plaintiff committed (1) and (2) in a manner that would be
8 considered a felony;(4) women engaged in sexual acts with Plaintiff
9 without the consent of those women; and/or (5) women were forced by
10 Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of
11 fear, threat and intimidation.
12 184. Because of the facts and circumstances that were known to the
13 hundreds to thousands of readers of the defamatory statements, including
14 that Plaintiff was a professional wrestler and wrestling promotor in
15 California,
16 (1) The defamatory statements tended to injure Plaintiff as a professional
17 wrestler and wrestling promotor, and otherwise injure Plaintiff whether
18 or not as a professional wrestler and wrestling promotor;
19 (2) The defamatory statements exposed Plaintiff to hatred, contempt,
20 ridicule, and shame by (1) persons residing in California; (2) persons
21 involved and interested in professional wrestling and wrestling
22 promotions; and (3) those persons using the world-wide-web interested
23 in Plaintiff, professional wrestling and wrestling promotions; and
24 (3) The defamatory statements discouraged others from associating or
25 dealing with Plaintiff.
26 185. Defendant knew that the listeners and readers of the defamatory
27 statements would be compelled to republish the defamatory statements to
28
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others by word of mouth, electronic communication and through social

1 media websites and the persons who did hear and did read the
2 defamatory statements did republish the defamatory statements to others,
3 because defendant was users, subscribers, account holders of Twitter and
4 had Twitter handles and thus understood how Twitter and social media
5 websites worked.
6 186. Defendant’s defamatory statements caused Plaintiff to lose
7 employment and income.
8 187. Defendant’s defamatory statements caused Plaintiff’s California and
9 virtual community to shun him, avoid him and hate him and further caused
10 Plaintiff’s California and virtual community to stop being his friend, stop
11 following him, or otherwise end any, and all, connection and association to
12 Plaintiff.
13 188. Plaintiff’s personal and professional reputation were harmed as a result
14 of defendant’s defamatory statements and such reputation is continuing to
15 be harmed because defendant continue to make the same defamatory
16 statements as described and continue to permit the defamatory
17 statements to go viral on social media websites.
18 189. Plaintiff sustained reputational and financial harm to his businesses,
19 professions and occupations as a result of the defamatory statements.
20 190. Plaintiff was damaged as set forth below and as follows,
21 WHEREFORE Plaintiff prays that this court grant relief in compensatory
22 damages against each defendant and in favor of Plaintiff in the amount of
23 $5,000.000.00, for an order retracting and correcting the defamatory
24 statements, for equitable relief based on principles that are fair and just, and
25 for judgment as also set forth below.
26 WHEREFORE, Plaintiff prays for judgment as set forth below.
27 ///////
28
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1 IV. CLAIM IV
2 (False Light against defendant)
3 191. Plaintiff incorporates by reference paragraphs 1 through 190 as though
4 fully set forth herein.
5 192. Defendant published the defamatory statements as specifically
6 described above and incorporated herein, as
7 a. Defendant’s Second Statement;
8 b. Defendant’s Fourth Statement;
9 c. Defendant’s Fifth Statement;
10 d. Defendant’s Eighth Statement;
11 e. Defendant’s Ninth Statement;
12 f. Defendant’s Eleventh Statement;
13 g. Defendant’s Twelfth Statement;
14 h. Defendant’s Fifteenth Statement;
15 i. Defendant’s Sixteen Statement;
16 j. Defendant’s Seventeenth Statement;
17 k. Defendant’s Nineteenth Statement;
18 l. Defendant’s Twentieth Statement;
19 m. Defendant’s Twenty-Second Statement;
20 n. Defendant’s Twenty-Fourth Statement;
21 o. Defendant’s Twenty-Fifth Statement;
22 p. Defendant’s Twenty-Sixth Statement; and
23 q. Defendant’s Video
24 and the statements showed Plaintiff in a false light.
25 193. The false light was highly offensive to a reasonable person in Plaintiff’s
26 position, because Plaintiff did not rape, assault, commit sexual battery on
27 any person.
28
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194. Defendant knew that the publication of the defamatory statements

1 would create a false impression that (1) Plaintiff assaulted women; (2)
2 Plaintiff committed a sexual battery on women; (3) Plaintiff committed (1)
3 and (2) in a manner that would be considered a felony;(4) women
4 engaged in sexual acts with Plaintiff without the consent of those women;
5 and/or (5) women were forced by Plaintiff to engage in sexual acts with
6 Plaintiff, forced meaning the use of fear, threat and intimidation.
7 195. Defendant’s defamatory statements were not privileged and Plaintiff did
8 not consent to the publication of the defamatory statements. Plaintiff, in
9 fact, implored defendant to stop the publication of the defamatory
10 statements.
11 196. Prior to publishing the defamatory statements, defendant knew that
12 publishing the defamatory statements would create a false impression
13 about Plaintiff.
14 197. Prior to publishing the defamatory statements, defendant acted in
15 reckless disregard for the truth in the defamatory statements by not
16 conducting any diligence, inquiry and investigation as to whether or not
17 the defamatory statements were true or false.
18 198. Prior to publishing the defamatory statements, defendant failed to use
19 reasonable care to determine the truth or falsity in the defamatory
20 statements by not conducting reasonable diligence, inquiry and
21 investigation as to whether or not the defamatory statements were true or
22 false.
23 199. Plaintiff sustained reputational and financial harm as result of
24 defendant’s publication of the defamatory statements.
25 WHEREFORE Plaintiff requests that this court grant relief in
26 compensatory damages against each defendant and in favor of Plaintiff in the
27 amount of $5,000.000.00, for an order retracting and correcting the
28
Complaint for Damages and
Demand for Jury Trial
50
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defamatory statements and any equitable relief based on principles that are
1 fair and just.
2 WHEREFORE, Plaintiff prays for judgment as set forth below.
3 V. CLAIM V
4 (Intentional Interference with Prospective Economic Advantage against
defendant)
5 200. Plaintiff incorporates by reference paragraphs 1 through 199 as though
6 fully set forth herein.
7 201. In October 2019, it was widely reported in the wrestling community,
8 including through an online news reporting agency called
9 SoCalUncensored.com, that Plaintiff “signed a multi-year contract with
10 Impact Wrestling. This marks his return to the promotion, as he was
11 previously under contract with the company from 2012 to 2013.” Impact
12 Wrestling is one of the larger and more successful wrestling promotions
13 that are more recognized by the general public, for example like WWE. As
14 such, it was well known that the “Joey Ryan” character was a commodity
15 sought after by one of the top wrestling promotions, i.e., believed to be
16 entertaining and would draw viewer interest. Although Plaintiff was “under
17 contract” with Impact Wrestling, Plaintiff was free to pursue his ventures
18 and promotions as an independent wrestler, which is not the usual case.
19 With the exception of Plaintiff’s Impact contract, usually the independent
20 wrestler is not free to wrestle with, and in, other promotions, without the
21 consent of the promotion. The professional wrestler is no longer
22 “independent” and is disincentivized from pursuing other ventures and
23 shows because if contracted with the bigger promotion, presumably the
24 wrestler is receiving consideration that outweighs life as an independent
25 wrestler.
26 202. Plaintiff sought other business relationships throughout his career
27 including in and around June 2020 through the present.
28
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Demand for Jury Trial
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203. Defendant, at all times referenced and mentioned herein, was well
1 aware that Plaintiff was an independent wrestler and that in order to make
2 a sustainable income from wrestling the independent wrestler must seek
3 multiple ventures, promotions and performances in shows. Plaintiff is, and
4 was, himself an independent wrestler and on information and belief, is,
5 and was, involved in professional wrestling promotions at all times
6 relevant. As such, Defendant was aware that Plaintiff needed to pursue
7 relationships with multiple promotions. It was widely known in the
8 professional wrestling community, of which defendant was a part, that
9 Plaintiff’s contract with Impact was not exclusive.
10 204. In addition to being under contract with Impact Wrestling, plaintiff had
11 past, current and at least potential relationships with the over thirty
12 wrestling promotors and promotions in referenced in Defendant’s First
13 Statement through Twenty-Sixth Statement and Defendant’s Video,
14 including, but not limited to, Impact Wrestling, PWE and ECWA Wrestling.
15 205. Defendant published the statements as specifically described above
16 and incorporated herein, as
17 a. Defendant’s First Statement through Defendant’s Twenty-Sixth
18 Statement; and
19 b. Defendant’s Video
20 206. Defendant has been monitoring Plaintiff’s professional wrestling career,
21 especially after Defendant’s partner cheated on Defendant with an
22 unknowing Plaintiff, that is to say that Plaintiff was unaware of the
23 relationship that Defendant had with the partner. As such, Defendant was
24 aware that his call to action directed to the over thirty wrestling promotors
25 and promotions referenced in Defendant’s First Statement through
26 Twenty-Sixth Statement and Defendant’s Video targeted Plaintiff’s past,
27 present and future business relationships, i.e., contractual relationships,
28
Complaint for Damages and
Demand for Jury Trial
52
Case 2:20-cv-09623-AB-PLA Document 1 Filed 10/20/20 Page 53 of 63 Page ID #:53

and that the response that Defendant sought, and seeks, is that the over
1 thirty wrestling promotors and promotions, never work with and create any
2 relationship or contract with Plaintiff that would result in Plaintiff receiving
3 consideration, monetary, fame, notoriety, or otherwise, related to
4 professional wrestling.
5 207. Defendant’s statements were a call to action for every promotor in
6 professional wrestling to agree to ban, blackball and prevent Plaintiff from
7 being a part of, doing business with and in, and deriving any benefit, e.g.
8 money, fortune, fame, notoriety, or otherwise from professional wrestling.
9 208. Defendant’s statements were also a call to action to prevent Plaintiff
10 from income related to his promotion of professional wrestling via social
11 media, YouTube, Patreon, Cameo, etc.
12 209. Defendant used false statements of fact that destroyed Plaintiff’s
13 reputation and otherwise placed Plaintiff in a false light offensive to the
14 reasonable person by painting falsely that Plaintiff committed offensive or
15 criminal acts, including that (1) Plaintiff assaulted women; (2) Plaintiff
16 committed a sexual battery on women; (3) Plaintiff committed (1) and (2)
17 in a manner that would be considered a felony;(4) women engaged in
18 sexual acts with Plaintiff without consent; and/or (5) women were forced
19 by Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use
20 of fear, threat and intimidation.
21 210. Defendant’s statements were false and Plaintiff did not, and had not,
22 (1) assaulted women; (2) committed a sexual battery on women; (3)
23 committed (1) and (2) in a manner that would be considered a felony;(4)
24 engage in sexual acts with women without consent; and/or (5) forced
25 women to engage in sexual acts with Plaintiff, forced meaning the use of
26 fear, threat and intimidation.
27 211. Defendant’s conduct was intended by each defendant, or carried out in
28
Complaint for Damages and
Demand for Jury Trial
53
Case 2:20-cv-09623-AB-PLA Document 1 Filed 10/20/20 Page 54 of 63 Page ID #:54

reckless disregard, and otherwise was substantially certain to result in loss

1 Plaintiff’s relationships, including those contractual, business, and
2 financially beneficial to Plaintiff.
3 212. As a result of Defendant’s conduct, at least to date PWE and ECWA
4 Wrestling have expressly agreed to ban, blackball and prevent Plaintiff
5 from being a part of, doing business with and in, and deriving any income
6 from professional wrestling. Impact Wrestling has also terminated its
7 contract with Plaintiff.
8 213. As a result of Defendant’s conduct, Plaintiff did lose hundreds of
9 subscribers, and thus income, from promotions related to social media,
10 YouTube, Patreon, Cameo, etc.
11 214. Defendant has lost income and business opportunity as a result of
12 Defendants conduct in publishing,
13 a. Defendant’s First Statement through Defendant’s Twenty-Sixth
14 Statement; and
15 b. Defendant’s Video.
16 WHEREFORE Plaintiff prays that this court grant relief in compensatory
17 damages against each defendant and in favor of Plaintiff in the amount of
18 $5,000.000.00, for an order retracting and correcting the defamatory
19 statements, for equitable relief based on principles that are fair and just, and
20 for judgment as also set forth below.
21 WHEREFORE, Plaintiff prays for judgment as set forth below.
22 VI. CLAIM VI
23 (Negligent Interference with Prospective Economic Advantage against
defendant)
24 215. Plaintiff incorporates by reference paragraphs 1 through 214 as though
25 fully set forth herein.
26 216. In October 2019, it was widely reported in the wrestling community,
27 including through an online news reporting agency called
28
Complaint for Damages and
Demand for Jury Trial
54
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SoCalUncensored.com, that Plaintiff “signed a multi-year contract with

1 Impact Wrestling. This marks his return to the promotion, as he was
2 previously under contract with the company from 2012 to 2013.” Impact
3 Wrestling is one of the larger and more successful wrestling promotions
4 that are more recognized by the general public, for example like WWE. As
5 such, it was well known that the “Joey Ryan” character was a commodity
6 sought after by one of the top wrestling promotions, i.e., believed to be
7 entertaining and would draw viewer interest. Although Plaintiff was “under
8 contract” with Impact Wrestling, Plaintiff was free to pursue his ventures
9 and promotions as an independent wrestler, which is not the usual case.
10 With the exception of Plaintiff’s Impact contract, usually the independent
11 wrestler is not free to wrestle with, and in, other promotions, without the
12 consent of the promotion. The professional wrestler is no longer
13 “independent” and is disincentivized from pursuing other ventures and
14 shows because if contracted with the bigger promotion, presumably the
15 wrestler is receiving consideration that outweighs life as an independent
16 wrestler.
17 217. Plaintiff sought other business relationships throughout his career
18 including in and around June 2020 through the present.
19 218. Defendant, at all times referenced and mentioned herein, was well
20 aware that Plaintiff was an independent wrestler and that in order to make
21 a sustainable income from wrestling the independent wrestler must seek
22 multiple ventures, promotions and performances in shows. Plaintiff is, and
23 was, himself an independent wrestler and on information and belief, is,
24 and was, involved in professional wrestling promotions at all times
25 relevant. As such, Defendant was aware that Plaintiff needed to pursue
26 relationships with multiple promotions. It was widely known in the
27 professional wrestling community, of which defendant was a part, that
28
Complaint for Damages and
Demand for Jury Trial
55
Case 2:20-cv-09623-AB-PLA Document 1 Filed 10/20/20 Page 56 of 63 Page ID #:56

Plaintiff’s contract with Impact was not exclusive.

1 219. In addition to being under contract with Impact Wrestling, plaintiff had
2 past, current and at least potential relationships with the over thirty
3 wrestling promotors and promotions in referenced in Defendant’s First
4 Statement through Twenty-Sixth Statement and Defendant’s Video,
5 including, but not limited to, Impact Wrestling, PWE and ECWA Wrestling.
6 220. Defendant published the statements as specifically described above
7 and incorporated herein, as
8 a. Defendant’s First Statement through Defendant’s Twenty-Sixth
9 Statement; and
10 b. Defendant’s Video
11 221. Defendant has been monitoring Plaintiff’s professional wrestling career,
12 especially after Defendant’s partner cheated on Defendant with an
13 unknowing Plaintiff, that is to say that Plaintiff was unaware of the
14 relationship that Defendant had with the partner. As such, Defendant was
15 aware that his call to action directed to the over thirty wrestling promotors
16 and promotions referenced in Defendant’s First Statement through
17 Twenty-Sixth Statement and Defendant’s Video targeted Plaintiff’s past,
18 present and future business relationships, i.e., contractual relationships,
19 and that the response that Defendant sought, and seeks, is that the over
20 thirty wrestling promotors and promotions, never work with and create any
21 relationship or contract with Plaintiff that would result in Plaintiff receiving
22 consideration, monetary, fame, notoriety, or otherwise, related to
23 professional wrestling.
24 222. Defendant’s statements were a call to action for every promotor in
25 professional wrestling to agree to ban, blackball and prevent Plaintiff from
26 being a part of, doing business with and in, and deriving any benefit, e.g.
27 money, fortune, fame, notoriety, or otherwise from professional wrestling.
28
Complaint for Damages and
Demand for Jury Trial
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223. Defendant’s statements were also a call to action to prevent Plaintiff

1 from income related to his promotion of professional wrestling via social
2 media, YouTube, Patreon, Cameo, etc.
3 224. Defendant used false statements of fact that destroyed Plaintiff’s
4 reputation and otherwise placed Plaintiff in a false light offensive to the
5 reasonable person by painting falsely that Plaintiff committed offensive or
6 criminal acts, including that (1) Plaintiff assaulted women; (2) Plaintiff
7 committed a sexual battery on women; (3) Plaintiff committed (1) and (2)
8 in a manner that would be considered a felony;(4) women engaged in
9 sexual acts with Plaintiff without consent; and/or (5) women were forced
10 by Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use
11 of fear, threat and intimidation.
12 225. Defendant’s statements were false and Plaintiff did not, and had not,
13 (1) assaulted women; (2) committed a sexual battery on women; (3)
14 committed (1) and (2) in a manner that would be considered a felony;(4)
15 engage in sexual acts with women without consent; and/or (5) forced
16 women to engage in sexual acts with Plaintiff, forced meaning the use of
17 fear, threat and intimidation.
18 226. Defendant’s conduct was negligent, and otherwise was substantially
19 certain to result in loss Plaintiff’s relationships, including those contractual,
20 business, and financially beneficial to Plaintiff.
21 227. As a result of Defendant’s conduct, at least to date PWE and ECWA
22 Wrestling have expressly agreed to ban, blackball and prevent Plaintiff
23 from being a part of, doing business with and in, and deriving any income
24 from professional wrestling. Impact Wrestling has also terminated its
25 contract with Plaintiff.
26 228. a result of Defendant’s conduct, Plaintiff did lose hundreds of
27 subscribers, and thus income, from promotions related to social media,
28
Complaint for Damages and
Demand for Jury Trial
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YouTube, Patreon, Cameo, etc.

1 229. Defendant has lost income and business opportunity as a result of
2 Defendants conduct in publishing,
3 a. Defendant’s First Statement through Defendant’s Twenty-Sixth
4 Statement; and
5 b. Defendant’s Video.
6 WHEREFORE Plaintiff prays that this court grant relief in compensatory
7 damages against each defendant and in favor of Plaintiff in the amount of
8 $5,000.000.00, for an order retracting and correcting the defamatory
9 statements, for equitable relief based on principles that are fair and just, and
10 for judgment as also set forth below.
11 WHEREFORE, Plaintiff prays for judgment as set forth below.
12 VII. CLAIM VII
13 (Intentional Infliction of Emotional Distress against defendant)
14 230. Plaintiff incorporates by reference paragraphs 1 through 229 as though
15 fully set forth herein.
16 231. Defendant published the statements as specifically described above
17 and incorporated herein, as
18 a. Defendant’s First Statement through Defendant’s Twenty-Sixth
19 Statement; and
20 b. Defendant’s Video
21 232. Defendant’s conduct was outrageous.
22 233. Defendant’s conduct was intended by each defendant, or carried out in
23 reckless disregard, to cause Plaintiff emotional distress.
24 234. Plaintiff suffered severe emotional distress.
25 235. Defendant’s conduct was a substantial factor in causing Plaintiff’s
26 emotional distress.
27 WHEREFORE Plaintiff prays that this court grant relief in compensatory
28 damages against each defendant and in favor of Plaintiff in the amount of
Complaint for Damages and
Demand for Jury Trial
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Case 2:20-cv-09623-AB-PLA Document 1 Filed 10/20/20 Page 59 of 63 Page ID #:59

$5,000.000.00, for an order retracting and correcting the defamatory

1 statements, for equitable relief based on principles that are fair and just, and
2 for judgment as also set forth below.
3 WHEREFORE, Plaintiff prays for judgment as set forth below.
4 VIII. CLAIM VIII
5 (Negligent Infliction of Emotional Distress against Defendant)
6 236. Plaintiff incorporates by reference paragraphs 1 through 235 as though
7 fully set forth herein.
8 237. Defendant published the defamatory statements as specifically
9 described above and incorporated herein as,
10 a. Defendant’s First Statement through Defendant’s Twenty-Sixth
11 Statement; and
12 b. Defendant’s Video
13 238. Prior to publishing the defamatory statements, defendant failed to use
14 reasonable care to determine the truth or falsity in the defamatory
15 statements by not conducting reasonable diligence, inquiry and
16 investigation as to whether or not the defamatory statements were true or
17 false.
18 239. Defendant was at least negligent.
19 240. Plaintiff suffered severe emotional distress.
20 241. Defendant’s negligent conduct was a substantial factor in causing
21 Plaintiff’s emotional distress.
22 WHEREFORE Plaintiff prays that this court grant relief in compensatory
23 damages against each defendant and in favor of Plaintiff in the amount of
24 $5,000.000.00, for an order retracting and correcting the defamatory
25 statements, for equitable relief based on principles that are fair and just, and
26 for judgment as also set forth below.
27 WHEREFORE, Plaintiff prays for judgment as set forth below.
28
Complaint for Damages and
Demand for Jury Trial
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IX. CLAIM IX
1 (Injunctive Relief - against defendant)
2 242. Plaintiff incorporates by reference paragraphs 1 through 241 as though
3 fully set forth herein.
4 243. Defendant has caused irreparable harm to Plaintiff’s businesses, in
5 reputation, in income, in the goodwill in the business that no amount of
6 damages could adequately compensate Plaintiff for injuries he sustained,
7 is sustaining and will sustain, because defendant’s defamatory statements
8 continue to be posted on internet websites such as Twitter, and defendant
9 continue to assert that the statements are true thereby destroying
10 Plaintiff’s reputation and business in an ongoing and continuous manner.
11 244. Defendant continues to publish the defamatory statements on social
12 media making it impossible for Plaintiff to practice as a professional
13 wrestler and wrestling promotor and thus limiting Plaintiff’s income,
14 making the harm ongoing.
15 245. Defendant’s conduct is a substantial factor in Plaintiff’s ongoing harm.
16 246. Plaintiff prays this court for an order enjoining defendant, and each of
17 them, from making and publishing any, and all, defamatory statements
18 that (1) Plaintiff assaulted women; (2) Plaintiff committed a sexual battery
19 on women; (3) Plaintiff committed (1) and (2) in a manner that would be
20 considered a felony;(4) women engaged in sexual acts with Plaintiff
21 without the consent of those women; and/or (5) women were forced by
22 Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of
23 fear, threat and intimidation.
24 247. Plaintiff prays this court for an injunction ordering defendants, and each
25 of them, to retract the defamatory statements and to take the defamatory
26 statements down from the websites in which the statements were made
27 and published, specifically defendant should retract and take down any,
28 and all, defamatory statements made and published by defendant that 1)
Complaint for Damages and
Demand for Jury Trial
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Plaintiff assaulted women; (2) Plaintiff committed a sexual battery on

1 women; (3) Plaintiff committed (1) and (2) in a manner that would be
2 considered a felony;(4) women engaged in sexual acts with Plaintiff
3 without the consent of those women; and/or (5) women were forced by
4 Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of
5 fear, threat and intimidation; and any iteration of such statements.
6 X. CLAIM X
7 (Declaratory Relief against Defendant)
8 248. Plaintiff incorporates by reference paragraphs 1 through 241 as though
9 fully set forth herein.
10 249. So that Plaintiff may present to social media websites that the herein
11 defamatory statements violate the terms and conditions of social media
12 websites, if they do, regarding publication of false and defamatory
13 statements that tend to harass and harm other persons, Plaintiff prays that
14 this this court declare as false statements that 1) Plaintiff assaulted
15 women; (2) Plaintiff committed a sexual battery on women; (3) Plaintiff
16 committed (1) and (2) in a manner that would be considered a felony;(4)
17 women engaged in sexual acts with Plaintiff without the consent of those
18 women; and/or (5) women were forced by Plaintiff to engage in sexual
19 acts with Plaintiff, forced meaning the use of fear, threat and intimidation.
20 XI. PRAYER FOR RELIEF
21 Plaintiff, MEEHAN, prays as to the first through eighth claims:
22 1. Award Plaintiff $200,000.00 in economic damages as to each
23 defendant or the amount lost by Plaintiff as a result of defendant’s
24 conduct multiplied by the months from June 21, 2020 to the date of the
25 award of economic damages;
26 2. Award Plaintiff $5,000,000.00 as to each defendant in non-economic
27 damages.
28 3. Order an injunction permanently restraining and enjoining defendant as
Complaint for Damages and
Demand for Jury Trial
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set forth in Claim VII including:

1 a. Preventing defendant from making and publishing the defamatory
2 statements or any iteration of the defamatory statements as set forth
3 above and herein;
4 b. Ordering defendant to retract the defamatory statements as set forth
5 above and herein;
6 c. Ordering defendant to direct any, and all, websites that defendant posted
7 the defamatory statements as set forth above and herein, to delete the
8 defamatory statements;
9 4. Award Plaintiff his actual damages;
10 5. Award Plaintiff his costs, investigatory fees and expenses to the fullest
11 extent provided by law;
12 6. Award punitive and exemplary damages against defendant and in favor
13 of Plaintiff in the sum of $10,000,000.00 by reason of defendants’, and
14 each of them, malice, hatred, ill-will, despicable and intentional acts.
15 7. Awarding Plaintiff such additional and further relief as the Court deems
16 just and proper.
17 Dated: October 20, 2020
18 UTZURRUM LAW OFFICES, A.P.C.
19
20
21 By: /s/ Joe Utzurrum
22 Joe Utzurrum, Attorney for Plaintiff,
JOSEPH R. MEEHAN
23
24
25
26
27
28
Complaint for Damages and
Demand for Jury Trial
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Case 2:20-cv-09623-AB-PLA Document 1 Filed 10/20/20 Page 63 of 63 Page ID #:63

UTZURRUM LAW OFFICES, A.P.C.

1 Joe Utzurrum, Esq.
Cal Bar Number 171701
2 11620 Wilshire Blvd. Ste. 900
Los Angeles, California 90025
3 Tele 310.887.1837
Email joe@ulawoffices.com
4
5 Attorneys for Plaintiff, JOSEPH R.
MEEHAN
6
7
8
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11 JOSEPH R. MEEHAN, ) Case No.
)
12 Plaintiff, ) DEMAND FOR JURY TRIAL
13 )
vs. )
14 )
PELLE TSICHLIS aka PELLE )
15 PRIMEAU )
)
16 Defendants, )
17 )
Plaintiff, JOSEPH R. MEEHAN, hereby, by and through its counsel of
18
record, request and demand that the case and matters therein be tried in
19
front of a jury.
20
Dated: October 20, 2020
21
UTZURRUM LAW OFFICES, A.P.C.
22
23
24
By: /s/ Joe Utzurrum
25 Joe Utzurrum, Attorney for Plaintiff,
26 JOSEPH R. MEEHAN
27
28
Complaint for Damages and
Demand for Jury Trial
63