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Stanton L. Stein, Esq. (SBN: 45997)

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lstein@linerlaw.com Maribeth Annaguey, Esq, (SBN: 228431\ mannaguey@linerl aw. com Ashley R. Yeargan, Esq. (SBN:259523) ay eat gan@linerl aw, com LTNER GRODE STEIN YANKELEVITZ SUNSHINE REGENSTREIF & TAYLOR LLP I100 Clendon Avenue, l4th Floor Los Angeles, California 90024-3 503 6 Telephone: (310) 500-3500 Facsimile: (3 l0) 500-3501 Attomeys for Plaintiff Elisabeth Thieriot

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vs.

SUPERIOR COURT OF THE STATE OF CALIFORNIA

couNTY oF LOS ANGELES, CENTRAL DISTRICT

t2 Elisabeth Thieriot, an individual, Plaintiff,

Case No.

BC 48 4 88 ?

COMPLAINT FOR (r) DEFAMATTON (2) FALSE LrcrrT TNVASTON OF

PRTVACY

l5 The WrapNews; Inc.; Steve Pond, an individual;

and DOES

through 20, inclusive, Defendants.

t6 t7

DEMAI{D FOR JURY TRTAL

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crCase No.

COMP
00204t9ru0

l/

523764vO1

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2
3

PlaintiffElisabeth Thieriot ('Ms. Thieriot" or "Plaintiff'), as and for her Complaint against
Defendants The WrapNews, Inc. and Steve Pond

(ointly "The Wrap") and Does I through

20

inclusive (collectively, "Defendants"), alleges as follows:

4
5

I.

INTRODUCTION

l.

This action exposes the continuing demise ofjournalistic integrity as more and more

online publications, purporting to be serious news outlets, race to be the first to post online
sensational and inflammatory articles without the requisite research and with total disregard for the

truth. Some reporters

and publications, in a rush to "scoop" the story, team up

with and rely upon

highly questionable "sources" without any real investigation. Couple this with an unscrupulous,
an ax to grind and you have the perfect

t0 dishonest individual with

poison. So it is here. The Wrap with a well-publicized and lengthy

ll
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14

facilitated a fraudulent act of revenge by Raul Julia-Levy, u

T*

t2 history of making false statements to the police and in legal proceedings, in an attempt to wreak
havoc on Etisabeth Thieriot's

life.

Ms. Thieriot is a well-respected philanthropist, author and

ex-wife of the former publisher of The San Francisco Chionicle. Relying solely on Julia-Levy and
documents based on claims made by Julia-Levy, and despite information totally annihilating Julia-

l5

t6 Levy's credibility, The Wrap threw caution to the wind in its reckless pursuit for more hits on its
r7 website. In doing so, The Wrap has perverted the truth about Julia-Levy's fraud on Ms. Thieriot

l8

and his attempt to hijack a very important

film project, which Ms. Thieriot financed, about Mayan

l9 findings and

artifacts (the "Documentary"). The Wrap has portrayed Ms. Thieriot as the villain

20 even though she is, in fact, the victim of Julia-Levy's fraud. This perversion not only defames and

2l severely damages
22
23

a respected, innocent and decent human

being it creates a fraud on the public.

Indeed, since the

ill-advisd posting

and as clearly foreseeable, several other media outlets have re-

published the article with clearly even less investigation than The Wrap. This has just distorted the
facts even more. Now, the headlines, in the United States, Mexico and around the world, read that

24
25
.9
:JI

Ms. Thieriot is "wanted" in Mexico and convey that she is a criminal on the run. These serious
accusations are completely false. This recklessness must be stopped and the perpetrators must be

26 27 28

,L
:c,

held responsible.

Case No.

COMPLAIN
00m48910011 5231&v05

I
2
I

2.

In an online feature article posted on May 9,2012,t1t\ed Mayan Mystery: Doc

Financier Accased of Fleeingwith Film Footage (the "Story"), The Wrap published false and
defamatory statements that Ms. Thieriot fled Mexico in contravention of a government order, stole

4
5

film footage and equipment, and filmed on goverrrment land without authorization. Each of which
is false. The Wrap knew that the Story was false, or at the very least, it had to have entertained
serious doubts in light of information The Wrap

6 7 8

receivdthe day belore publishing the Story that

its key,

if not only,

source Julia-Levy was not credible. Nevertheless, The Wrap intentionally and

recklessly went forward with the Story -- even after being told not to proceed in light of the fraudulent statements by Julia-Levy upon which it was relying. By its intentional and reckless conduct, The Wrap has caused substantial harm to Ms. Thieriot, in complete disregard of the truth
and without eveS a semblance ofjoumalistic integrity. This suit seeks to set the record straight and

l0

ll
l3

t2 obtain recompense for the injuries Ms. Thieriot has suffered.

II.

THE PARTIES

t4

34,

PlaintiffElisabeth Thieriot is a philanthropist and businesswoman, She presently in California.

and based thereon alleges, that Defendant The

l5 maintains

a residence

l6

Plaintiffis informed and believes,

l7 WrapNews, Inc. owns

and operates the websit e, Thel{rap.com) anonline publication found at and based thereon alleges,

l8 www.thewrap.com (the "Website"). Plaintiff is informed and believes,

r9 that TheWrapNews,'Inc. is based in and does business in Los Angeles, California. plaintiff is
20

informed and believes, and based thereon alleges, that the Story at issue in this action was
and was both available to and targeted to readers

2l published by The WrapNews, Inc. on the Website

22
23

in the State of California and the County of Los Angeles,

5.

Plaintiffis informed and believes, and based thereon alleges, that Defendant Steve

24
25
.ft
l,rl

Pond, a reporter and the by-lined author of the Story at issue, is based in the State of California and
the County of Los Angeles.

Plaintiffis informed and believes, and based thereon alleges, that the

26
27

Story at issue in this action was authored by Pond and was both available to and targeted to readers

,F
:ql

in the State of Califomia and the County of Los Angeles.

28

00204E9rc01/ 523764\ns

r(

I
2
3

6.

Plaintiffis informed

and believes, and based thereon alleges, that pursuant to Code

of Civil Procedure $ 474, the fictitiously named Defendants sued herein as Does I ttrough 20,
inclusive, and each of them, were in some manner responsible or legally liable for the actions,

4 events, hansactions and circumstances alleged herein. The true names'and capacities of such
5

fictitiously named Defendants, whether individual, corporate, associate, or otherwise, are presently
unknown to Plaintiffand

6 7 8 9

Plaintiffwill

seek leave of the Court to amend the Complaint to assert the

true names and capacities of such fictitiously named Defendants when the same have been ascertained. For convenience, each reference to "Defendants" shall include the Doe Defendants.
and each of them.

l0

7.

Plaintiff is informed and beliEves, and based thereon alleges, that Defendants, and

ll
l3 t4 l5

each of them, are and were at all times herein mentioned, the agents, servants, employees, or

joint

t2 venturers of each of the other Defendants, and at all times herein mentioned were acting within the
course and scope of said agency, employment, or service in furtherance of the

joint venture.

III.

TIIE FALSE AND DEFAMATORY PUBLICATION

8.

On May 9,2012, The Wrap published the Story accusing Ms. Thieriot, explicitly

l6
t7

and/or implicitly, of:

(a) O) (c) 9.

Fleeing Mexico in violation of a government order; Stealing footage and equipment related to the Documentary; and,

l8 t9

Filming on federal ground in Mexico without authorization from the

20 applicable authorities (the "Accusations"),

2l
22
23

The Wrap referenced "documents" it obtained, including a letter from the attorney

general in the Mexican state of Campeche and a letter allegedly from the National Institute

of

Anthropology and History.

24
25
.tt

l0'

Ms. Thieriot is informed and believes, and based thereon alleges, that the allegations

in the letters and the story are based solely on Julia-Levy's false claims.

it
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26 27
28

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0020489ro01/ 523764v05

l.

Ms. Thieriot is informed and believes, and based thereon alleges, that to establish

2
3

credibility, The Wrap posted alongside the Story a letter purportedly from the Attomey General from the Mexico state of Carirpeche bearing an official seal (the "AG Leuer"). The Wrap failed to
include an English translation of the letter, which only appears in Spanish. A trug and correct copy

4
5

of the letter that appeared on the website is attached hereto as Exhibit c.

6
7

12.

Ms. Thieriot is informed and believes, and based thereon alleges, that the inclusion

of the AG Letter in its native language without translation was intended to give credibility to the
statements in the Story that the Mexican government was requiring Ms. Thieriot to stay in Mexico and turn over the

8 9

film footage and equipment that Julia-Levy claims she stole.

l0

13.

Ms. Thieriot is informed and believes, and based thereon alleges, that each of the

l1 documents The Wrap relies on are based on Julia-Levy's fraudulent claims to Mexican authorities.

l2 To date, there

have been no findings of wrongdoing by Ms. Thieriot or charges against Ms. based on Julia.Levy's claims.

l3 Thieriot by any government entity

t4

14'

Indeed, the AG Letter says nothing about Ms. Thieriot being required to stay in
than provide a statement of her version of the dispute.

l5 Mexico or do anything other

A true and

l6 correct copy of a certified translation of the letter is attached hereto as Exhibit D.

t7

15. 16.
ry.

To the contrarS the AG Letter specifically says that upon providing her statement,
leave the facilities of the corresponding Attorney's

l8 Ms. Thieriot "may l9

20

office." (Exhibit D).

As discussed in more detail below, each of the Accusations in the Story are false.

2l
22
23

,17.

Ms. Thieriot formed R & E Productions, LLC ("R & E"). R & E's business was to

24
25

"produce and control all rights" to the feature lenglh documentary motion picture titled: Revelations of the Mayans: 2012 and Beyond (previously referred to herein as the

26
.n

"Documentary").

;{

27 28

18.

Julia-Levy and Ms. Thieriot were Minaging Members of R & E. They were ro

produce the Documentary

jointly.

0020 499

100 |

523

764y05

19. 20.

Ms. Thieriot solely financed the entire production and was the only Investment

2
3

MemberofR&8.
Julia-Levy was responsible for acquiring for R & E the equipment necessary to film

4 the Documentary with the funds that Ms. Thieriot had invested in R
5

& E. The equipment

was to be

purchased and/or rented in R

& E's

name.

6 7 8 9

21. 22. 23.

In or about April 2012, shooting for the Documentary began in Mexico under Julia-

Levy's direction. A day later, Ms. Thieriot joined the crew on-location.
Ms. Thieriot is informed and believes, and based thereon alleges, that prior to her

arrival, Julia-levy used the crew hired for the Documentary to film interviews on unrelated topics.

t0

After four days of filming, the crew moved to a new location -- Campeche -- where

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Julia-Levy stopped the production of the Documentary. Ms. Thieriot is informed and believes, and
based thereon alleges, that one of Julia-Levy's motivations to stop production was his

inability to

get a passport to travel to Cuatemala.

t4

24. 25.

Ms. Thieriot and Julia-Levy agreed to cease production and to relieve Julia-Levy
and R

of

l5 his involvement with the Documentary

&

E.

l6 l7

Following Julia-Levy's decision to stop production, Ms. Thieriot is informed and

believes, and based thereon alleges, that Julia-Levy initiated a campaign of retaliation and.revenge
and

l8 against Ms' Thieriot by (a) atternpting to prevent further production in subsequent locations, l9 (b) filing false claims against her with the Mexican authorities.
20

26.
belonged to R

Ms. Thieriot is informed and believes, and based thereon alleges, that Julia-Levy

2l
22 23

used fraudulently-obtained receipts and permits to enlist the police to help him steal equipment that

&

E or was rented for R

& E with Ms. Thieriot's money by Eduardo Vertiz, the

executive producer of Mexico hired by R &

E. Ms. Thieriot is further informed

and believes, and

24 based thereon alleges, that Julia-Levy claimed to be a local resident and provided false documents
25
1t

to rent the equipment in his name individually instead of R

&

E.

26

.*
rs

27 28

00204t9/00

l/

523764v05

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2

27.

Ms. Thieriot is informed and believes, and based thereon alleges, that Julia-Levy

then tried to use the fact that the equipment was in his individual name as a basis to claim

ownership and mislead the police into believing Ms. Thieriot took the equipment without legal
4 right.
5

V.

TIIE ACCUSATION THAT MS. TiIIERIOT FLED MEXICO IN VIOLATION OF A

GOVERNMENT ORDER IS FALSE

6 7 8 9 10

28.

As of the filing of this Complaint, there is no order against Ms. Thieriot requiring

that she stay in Mexico. There have been no findings or convictions against Ms. Thieriot based on
any ofJulia-Levy's allegations. The AG

L.ttT,which The Wrap published to give credibility to its

statements against Ms. Thieriot, does not require that she stay in Mexico.

ll

29.

Ms. Thieriot is informed and believes, and based thereon alleges, that based solely

t2 on Julia-Levy's allegations, the Mexican authorities indicated that they wanted a statement from l3 Ms. Thieriot. This is to be expected in any investigation when
a

claim is made, even if completely

t4
15

false.

30.
claims,

To date, however, Vts. thieriot has not been ordered to appear in Mexico or before

16 17 18

any other legal authority for further proceedings in connection with Julia-Levy's trumped up

u.

TIIE ACCUSATTqN THAT MS. TrrrERrOT STOLE FOOTAGE ANp

EOUIPMENT RELATED TO THE DOPPMENTARY IS FALSE

l9
20

31.

Ms. Thieriot paid for the footage and equipment (some of which was rented rather
at issue. Ms. Thieriot understood that Julia-Levy would acquire the

2l than purchased outright)

22
23

equipment and that he would do so under the umbrella of R formed to produce the Documentary.

&

E, the production company she had

24
25

32.
permission,

Ms. Thieriot is informed and believes, and based thereon alleges, that Julia-Levy

acquired the equipment under his name individually without Ms. Thieriot's prior knowledge or

it
Il

26

.p'

.t)

}27
28

oozo4lg'loolt

sniavos

I
2
3

33.

Ms. Thieriot is not in possession of any of the equipment at issue. In fact, The Wrap

failed to include, let alone mention, another letter issued by the Attorney General on April 18,
subsequent to the

AG Letter that The Wrap published, in which the Attorney General specifically

4 states that the equipment is in the possession of a third party -- not Ms. Thieriot. Attached hereto
5 as

Exhibit E is a true and correct certified English hanslation of this April 18, 2012 Letter.

6
7
8

vll.

THE A9CIJ.$ATION TIIAT MS. TH"IERIOT FIITMED oN FEDERAL GROUND

WITHOUT AUTIIORIZATION IS FALSE

34.

Ms. Thieriot is informed and believes, and based thereon alleges, that prior to her

involvement, another pioducer working on the Documentary properly prepared the paperwork for
the permits to be issued in the name of the production company previously slated to produce the

t0

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13

Documentary.

35.

Upon the formation of R & E, Ms. Thieriot is informed.and believes, and based

thereon alleges, that the permits were to be changed to R

& E's name. Instead, Julia-Levy

changed

t4 the permit applications

so that they would be issued in his name

individually and not R & E's

l5
16

name.

t7

36. 37 -

Julia-Levy did this without Ms. Thieriot's knowledge or permission. Ms. Thieriot is informed and believes, and based thereon alleges, that Julia-Levy

l8

engaged in the fraud described at Paragraphs 31,32,35 in order to ultimately steal the and sell

t9 Documentary, promote
20

it

as his

own, and/or extort Ms. Thieriot for additional money.

TN

VI[.

THE WRAP POSTS THE STORY

. UNpERM{.NIN-G

THE FACE OF INFORMATION

2l
22
23

THE CREprBrLrTy oF,,ITS.KEy WTTNESS

38.

The Wrap published the Story despite receiving information, prior to publishing it,

that Julia-Levy is not credible and has a well-publicizedhistory of making false statements of fact

24
25
..8

to governmental agencies.

39-

Ms. Thieriot's representatives offered to investigate the allegations and provide facts

i{
.F.

26 27 28

to The Wrap upon further investigation. The Wrap pressed forward and published the Story anyway making

:: IV

it internationally

and immediately accessible.

,|
Case No.
002M8910011 523754v05

I
2
3

40.

Specifically, on Tuesday, May 8,2012, Pond spoke with Ms. Thieriot's

representatives by telephone. During that call, Ms. Thieriot's representative cited to an article published by the Los Angeles Times and discussed another published by The New York Times,

4 reporting on Julia-Levy's history of making false claims. True and correct copies of these articles
5 are attached hereto as Exhibits

A and B respectively.
Times article (Exhibit A) reports that during the murder trial of Phil

6
7
8

41.

The

los Angeles

Spector in 2007, the defense intended to call Raul Julia-Levy as a defense witness to testiff about
the demeanor of the victim, who was Julia-Levy's former girlfriend (and an alleged prostitute). The

los Angeles

Times article reported that the prosecutor submitted a "3-inch-thick document

l0

assailing the credibility of Julia Levy."

ll
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42.

Specifically, the los Angeles Times reported:

The prosecution, in its filing, contended that Julia Levy -- whom they list as having- six-aliase_s -- fiad a history of making fitse statementi tg Police.and in^legdfilings. Levy's '1ong and viriea history of runins with law enforcement" includei chargei of driving under ihe influence, drug posses-siop fol sale, domdstic violenci, child cruelty, sexual assault and T.rultiple allegations of providing faise identification to police, ihe prosecutor,s frling statJd.

l4
t5

l6
l7

A Sheriff s D_epartment investigation report included in the prosecutor's filing said Julia Levy had used fake names and social Security numbers and falsely claimed to have attended Harvard
University and USC. (emphasis added).

l8
r9

43.

Ms. Thieriot is informed and believes, and based thereon alleges, that in light of the

20 prosecution's

filing described in Paragraph 4l above, Julia-Levy was excused from the courffoom
and never again mentioned throughout that trial.

2l without providing any testimony

22
23

4'

The Story published by The Wrap, however, fails to mention Julia-Levy's history

of

making false statements to police and in legal filings, which is a material fact given that the claims
against Ms. Thieriot are entirely based on Julia-Levy's statements.

24 25

.!

45.

The article in The New York Times (Exhibit B) detailed Julia-Levy's claim to be the

:Jl

26

son of a famous late actor, Raul Julia. As reported

in

The New York Times,Julia's

widow denied

.F

:rl

27 Julia-Levy's claim and insisted on a DNA test, which as of the time of the publication had not
28

occurred.

0020489N011 523764vo5

46.

Ms. Thieriot's representatives pointed out each of the above articles to Pond and

2 advised him not to rely on an obviously unreliable source. Additionally, Ms. Thieriot's
i J

representatives requested additional time to investigate the facts and documents and offered to

4 provide those facts and documents to Pond.

)
6 7 8 9

47.
name.

Nevertheless, the following day, on May 9,2012,The Wrap published the Story and

in so doing, aided Julia-Levy in his vendetta against Ms. Thieriot to try to destroy her and her good

48.

Ms' Thieriot is informed and believes, and based thereon alleges, that by the time

Ms- Thieriot's representative spoke with Pond, The Wrap had decided to run the Story irrespective Ms. Thieriot's representatives.

l0 of the information it obtained from

ll
12

49.

As of the filing of this Complaint, the Story remains accessible on the Website and

on the Internet through the various republications spawned from The Wrap's initial post. Indeed,
the accusations contained in the Story have been repeated and republished throughout the world in

l3

t4 various media includin g on television (the,.Republications,,).

l5

50.

As expected, the Republications further distort the tnrth and have resulted in.

l6

headlines that Ms. Thieriot is "Wanted" in Mexico suggesting she is a criminal on the run from the

t7 law.

l8
t9
20

FIRST CAUSE OF ACTION

[For Libel Per Se]

[By Elisabeth Thieriot Against All Defendants]

2l
22
23

51. 52. 53-

PlaintiffThieriot repeats and realleges each and every allegation contained in

paragraphs 1 through 50, inclusive, above, as

if fully set forth herein.

The Story as a whole and each of the Accusations are false.

The Story as a whole and each of the Accusations are of and conceming Ms.

24 2s
.9 ::i

Thieriot and persons who read the Story reasonably understand the references therein to be
references to Ms. Thieriot,

26 27
28

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:q

002ftE9ruO1/ 523?64v05

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2
3

54.

The Story as a whole and each of the Accusations are defamatory on their face

of

Ms. Thieriot and expose her to hatred, contempt, ridicule and obloqun and/or cause her to be
shunned or avoided and tend to injure her in her occupation.

4
5

55.

Upon information and belief, Ms. Thieriot alleges that the Story as a whole and each

of the Accusations were made by each of the Defendants with knowledge of their falsity or with
reckless disregard for their truth or falsity.

7
8

56'

Upon information and betie{, Ms. Thieriot alleges that the Story as a whole and each

of the Accusations were made by each of the Defendants in a grossly inesponsible manner with

9 want of due care.

t0

57.

Several news publications have picked up the Story and are running the

ll
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Republications on their online websites as

well. Defendants' conduct resulted in the

r2 Republications which caused additional and further damage to Ms. Thieriot.

58.

As a direct and proximate result of the above-described conduct by Defendants, Ms.

t4 Thieriot

has suffered general and special damages in an amount to be determined at trial but

l5 l6 l7
l8

believed to be no less than One Million Dollars ($1,000,000.00), including without limitation,
damage to Ms. Thieriot's reputation, career and standing in the community.

59.

Upon information and beliei Ms. Thieriot alleges that each Defendant's conduct

was done with oppression, fraud and malice and that, therefore, the conduct of each Defendant

r9 justifies an award of punitive and exemplary damages.

20

60.

Upon information and belief, Plaintiffalleges that, uirless enjoined and restrained by

2l
22
23

the Court, Defendants

will republish,

repeat and continue to disserninate the Story, all to the

continuing injury of Plaintiff; that such continued republication, repetition and dissemination of the
defamatory and offensive falsehoods

will

cause irreparable harm to

Plaintiffby damaging her

24 reputation and adversely affecting her philanthropic and business efforts as well as her personal
25
.[r

relationships- Upon information and beliel Plaintiffalleges that she lacks an adequate remedy at law insofar as damages will be very difficult to calculate for such on-going injuries. By reason
the foregoing,

:{
,1r,"

26 27
28

of

:: :!|

Plaintiffis entitled to a permanent injunction enjoining and restraining Defendants,

Case No.
00204E9/00 | / 523764v05

I and each of thern, and all peisons acting in concert with thern, from republishing, repeating,
2
3

distributing or otherwise disseminating the Story.

sEcoNp CAUSE OF ACTrp.I

[For False Light Invasion of privacy]

4
5 6
7

[By Elisabeth Thieriot Against All Defendants] 6l

'

PlaintiffThieriot repeats and realleges each and every allegation contained in

Paragraphs

I through 50, inclusive,

above, as

if fully

set forth herein.

8 9

62'
Defendants.

The Story as a whole and each of the Accusations werc widely publicized by the

l0

ll

63' '64'

The story as a whole and each of the Accusations are false. The Story as a whole and each of the Accusations are of and concerning Ms.

l2 Thieriot

and persons who read the Story reasonably understand the references therein to be

l3 references to Ms. Thieriot,

l4 l5

65'

To the extent that all or any part of the Story as a whole or any of the Accusations

are found not to be defamatory

of Ms. Thieriot, the Story and the Accusations place Ms. Thieriot

l6 in a false light which would

t7

be highly offensive to a reasonable person,

66'

upon information and belief, Ms. Thieriot alleges that the Story as a whole and each

l8 of the Accusations were made by each of the Defendants with knowledge of their falsity or with
t9 reckless disregard for their truth or falsity.
20
67

'

upon information and belief, Ms. Thieriot alleges that the Story as a whole and each

2r of the Accusations were made by each of the Defendants in a grossly inesponsible manner with )) want of due care.
23

68' 69'

Defendants' conduct resulted in the Republications which caused additional and

24 25
fr

further damage to Ms. Thieriot.

As a direct and proximate result of the above-described conduct by Defendants, Ms.

.$.

26 Thieriot has suffered general and special damages in an amount to be determined at trial but 27 28

:$

believed to be no less than one Million Dollars ($1,000,000.00), including damage to Ms.

Thieriot's reputation, career and standing in the community.

:-mmrill
0020489n0t/ 523764v05

I
2
3

70.

Upon information and belief, Ms. Thieriot alleges that each Defendant's conduct

was done with oppression, fraud and malice and that, therefore, the conduct of each Defendant

justifies an award ofpunitive and exemplary damages.

71.

Upon information and belief, Plaintiffalleges that, unless enjoined and restrained by

)
6
7 8

the Coun, Defendants

will republish,

repeat and continue to disseminate the Story and the

Accusations all to the continuing injury of Plaintiff; that such continued republication, repetition
and dissemination of the defamatory and offensive falsehoods

will

cause ineparable harm to

Plaintiffby damaging her reputation and adversely affecting her philanthropic and business efforts
as

well

as her personal

relationships. Upon information and belief, Plaintiff alleges that she lacks

l0

an adequate rernedy at law insofar as damages

will be very difficult to calculate for

such on-going

1l injuries. By reason of the foregoing Plaintiffis entitled to a permanent injunction enjoining and

t2 restraining Defendants, and each of them, and all persons acting in concert with thern, from l3 republishing, repeating, distributing or otherwise disseminating the Story or the Accusations to the

t4 extent such are found in the Action l5

to be false and/or to portray Ms. Thieriot in a false light.

PBAYPB FOR BELIEF

WHEREFORE, Plaintiff prays for judgment as follows
:

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AS TO THE FIRST CAUSE OF ACTIO.N FOR LIBEL:

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For actual and special damages in an amount to be determined at the trial of this

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action, but believed not to be les6 than one Million Dollars ($1,000,000.00); For punitive damages; For a permanent injunction;

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TNVASION OF PRTVACY:

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4' 5. 6.

For actual and special damages in an amount to be determined at the trial of the

action, but believed not to be less than one Million Dollars ($1,000,000.00); For punitive damages; For a permaneni injunction;

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AS TO ALL CLAIMS AND CAUSES OF ACTION:

7. 8. 9.

For costs of suit herein incurred; For interest on any monetary award to plaintiffs at the legal rate; and,
For such other and further relief as the court may deem just and proper.

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Datdd: May 14,2012

GR

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:-"By:

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Elisabeth Thieriot

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0020489n0U 523764v05

Case No,

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DEMAND FOR JURY TRIAL

PlaintiffElisabeth Thieriot dernands trial by jury on all matters and issues so triable,

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Dated: May 14,2012

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for Plaintiff
Elisabeth Thieriot

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0020489/00

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