Case 2:17-cv-00745-JRG Document 2 Filed 11/16/17 Page 1 of 13Filed:
PageID
#:8:05
64AM
Filed:
9/15/2017
Juli Luke
Denton County,
County, County Clerk
Hagenbucher, Deputy
By:
By: Alexa Hagenbucher,

CV-2017-02365
CAUSE NO. ____________________
JASON LEE VAN DYKE
Plaintiff,
v.
V.
MOCKINGBIRD PUBLISHING CO. and
GERARD BELLO II
Defendants.

§§
§§
§§
§§
§§
§§
§§
§§

IN THE COUNTY COURT

AT LAW NO. 22

DENTON COUNTY, TEXAS

PLAINTIFF ’8 ORIGINAL PETITION
PLAINTIFF’S
I.
1.1
1.1

DISCOVERY CONTROL PLAN

Discovery in this case
190 of the Texas
case is intended to be conducted under level 2 of rule 190
Rules of Civil Procedure. Plaintiff seeks
less
seeks damages in the amount of $100,000.00 or less
including damages of any
fees.
expenses, pre-judgment interest, and attorney fees.
costs, expenses,
any kind, costs,

II.
2.1
2.1

PARTIES

Plaintiff is Jason Lee Van Dyke Whose
whose address
is 108
108 Durango Drive, Crossroads, TX
address is
76227.

2.2

(“Mockingbird”), an
Defendant, Mockingbird Publishing Co. (“Mockingbird”),
an Ohio Corporation may
may be
With process by
served with
by and through its registered agent, Robert Ebright, at 2346 Howey

Road,
43211.
Road, Columbus, OH 43211.
2.3

(“B6110”), an
Defendant, Gerard Bello II (“Bello”),
with process
process at
an individual, may
at 675
may be served With

Riverview Drive, Apt. B4, Columbus, OH 43202.
43202.
2.4

Subject matter jurisdiction is appropriate because
because Plaintiff seeks
seeks recovery of monetary
Within the jurisdictional limits of this Court.
damages within

2.5

Personal jurisdiction is
is appropriate as
as to the Defendants pursuant to the Texas Long Arm
Statute because
because Defendants have committed aa tort, in whole or in part, in this state.
state. Tex.

ORIGINAL PETITION

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 Case 2:17-cv-00745-JRG Document 2 Filed 11/16/17 Page 2 of 13 PageID #: 65

Civ.
is one
17.042. Specifically, Bello claims to be aa journalist and is
CiV. Prac. & Rem. Code §
§ 17.042.

,

of the principals of Mockingbird – an Internet website that can be
be accessed throughout
the United States. This lawsuit stems from aa situation in which Bello published false and
defamatory statements about members of the Houston chapter of aa men’s fraternal
organization known as
as “The Proud Boys”. See
See infra ¶ 3.3. Plaintiff is an attorney that
11

wrote aa demand letter to Defendants on behalf of the members of this chapter and others.
Rather than cease
cease and desist in their publication of false and defamatory statements,
Defendants published an article attacking Plaintiff specifically.
se
specifically. It is for the libel per se
contained in that article that Plaintiff now sues.
sues.
2.6

Venue is appropriate in this court pursuant to Tex. Civ.
15.017.
CiV. Prac. & Rem. Code §
§ 15.017.
III.

3.1
3.1

FACTS

Plaintiff is an attorney licensed to practice law in this state as
as well as
as Colorado, Georgia,
and the District of Columbia. Plaintiff’s practice includes the representation of fraternal
organizations of which Plaintiff is
is aa member. Plaintiff has,
has, for example, represented the
Delta Phi Chapter of Theta Chi Fraternity Alumni/Housing Corporation in the past.
past.
Plaintiff is also aa member of aa pro-western men’s fraternal organization known as
as “The
Proud Boys” and has
has assisted individual members of this fraternity in a
a variety of legal
matters.

3.2

This lawsuit stems from aa demand letter that was
was sent by
by Plaintiff to Defendants on or
around September 5,
is attached
copy of the demand letter is
5, 2017. A true and correct copy

“A” and incorporated by
hereto as
by reference herein.
as Exhibit “A”
3.3

On information and belief, Defendants are associated with aa domestic terrorist collective
known as
as “Antifa” that prides itself on harassing, defaming, and committing acts of

ORIGINAL PETITION

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 Case 2:17-cv-00745-JRG Document 2 Filed 11/16/17 Page 3 of 13 PageID #: 66

violence
persons and groups that espouse
Violence against persons
espouse conservative groups. In this instance,
Defendants wrongfully accused members of the Houston, Texas and Columbus, Ohio
chapters of “The Proud Boys” of the following: (a)
(a) being “neo-Nazis”; (b)
(b) engaging in aa
hate crime by
mailboxes; (c)
by placing hand-drawn swastikas into mailboxes;
(c) engaging in “ethnic
cleansing” during hurricane relief efforts in the Houston area;
area; and (d)
(d) roaming the nation
in an effort to commit acts
be noted in this
acts of mass
mass murder against minorities. It should be
case
was present with the Houston Proud Boys during Hurricane Harvey
case that Plaintiff was
relief efforts and assisted them in rescuing residents in need of evacuation and in the
distribution of relief supplies such as
as food, bottled water, cleaning supplies, and other
items to residents of areas
hurricane.
areas affected by
by the hurricane.
3.4

Plaintiff sent aa demand letter for Defendants to issue aa retraction of these statements
(which clearly meet the criteria for defamation per
per se)
se) and Defendants responded by
by

“B” on their website.
publishing the letter attached hereto as
as Exhibit “B”
(( Count One: Libel Per Se)
Se )
3.5
3.5

Defendant published the following defamatory statements of fact concerning Plaintiff:
(a)
(a)

Plaintiff is aa white
White nationalist, aa nazi, and/or aa neo-nazi;

(b)
(b)

Plaintiff was convicted of weapons charges and domestic Violence;
violence;

(c)
(0)

Plaintiff is prohibited under federal law from possessing firearms
firearms and is currently
in Violation
violation of federal law for possessing firearms;
firearms; and

(d)
(d)

Plaintiff has
has committed professional misconduct through the unauthorized
practice of law or through unlawful “forum shopping”.

3.6

The statements published by
by Defendant are false. Specifically:
Specifically:

ORIGINAL PETITION

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(a)
(a)

Plaintiff is
white nationalist, aa nazi, aa neo-nazi,
is not now, nor has
has he ever been,
been, aa White
or aa member of any
affiliated with “national socialism” in any
way.
any organization affiliated
any way.
These accusations by
by Defendants clearly “injure aa living person’s reputation and
thus expose the person to public hatred, contempt, or ridicule, or financial
financial injury”
and “impeach aa person’s honesty, integrity, Virtue,
virtue, or reputation.” Tex. Civ.
CiV. Prac.
& Rem. Code §§ 73.001.

(b)
(b)

Plaintiff has
violence. Plaintiff was convicted
has never been convicted of domestic Violence.
of aa misdemeanor firearm charge while
While living in the State of Michigan in 2000.
That conviction was legally set
by aa court order on or around
set aside and expunged by
September 28,
28, 2006. Plaintiff has not since been convicted of any
any crime other

“C” misdemeanor traffic
Defendants’ statements to the
than Class “C”
violations. Defendants’
traffic Violations.
contrary falsely charge Plaintiff with the commission of aa crime and constitute
libel per se.
Assocs. v.
se. Leyendecker & Assocs.
v. Wechter,
Wechter, 683 S.W.2d 369,
369, 374 (Tex.
1 984).
1984).

(d)
(d)

Plaintiff is not prohibited under federal law from possessing firearms,
firearms, and thus,
his possession of firearms
firearms is
is not contrary to federal law. In fact, Plaintiff has
has a
a
license to carry issued by
is authorized by
by the State of Texas and is
by the Texas
Department of Public Safety to teach the Texas license to carry class.
Defendants’ statements impute the commission of aa federal felony to Plaintiff and
Defendants’

constitute libel per se.
56. Id.
(e)
(6)

Plaintiff is
is not engaged in the unauthorized practice of law in Ohio or any
any other
state.
state. He has
has not engaged in forum shopping or committed any
any other act with
respect to Defendants which constitutes the unauthorized practice of law.

ORIGINAL PETITION

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Plaintiff is
is licensed to practice law in Texas,
Texas, Colorado, Georgia, and the District
of Columbia. He is
is licensed to practice in numerous federal courts including the
U.S.
Ohio. Accordingly, Defendants’
US. District Court for the Northern District of Ohio.
statements have caused injury to Plaintiff in his office, profession, or occupation
as
as an attorney and constitute libel per se.
se. Hancock v.
v. Variyam,
Variyam, 400 S.W.3d 59,
59, 64
(Tex. 2013).
3.7

It should also be
be noted that the published letter contains several other false and
defamatory statements.
statements. For example, it states that Plaintiff is aa member of the Council
for Conservative Citizens. Plaintiff is not now, and has
has never been,
been, aa member of this
organization.
white
organization. Furthermore, it states that Plaintiff has an account on aa popular White
supremacist website known as
is also false and
as “Stormfront”. While this statement is
defamatory, Plaintiff has
se. These
has chosen to limit this lawsuit to his claims for libel per se.
two accusations do not meet the statutory definition
definition of libel. They are,
are, however, relevant
to demonstrating that Defendants have acted with negligence at
at the very least,
least, if not
actual malice.

3.8

This is
is a
a claim for defamation per se
56 against a
a media defendant over a
a matter of private

Plaintiff’ s damages are
concern. Accordingly, Plaintiff’s
are presumed.
IV.
4.1
4.1

PRAYER

thati
Plaintiff prays that—
a.
a.

Defendants be
be cited to appear and answer;

b.
b.

Plaintiff be
be granted judgment for nominal damages,
damages, plus general damages
in the amount of at least $60,000.00;

c.
0.

Plaintiff be
be granted judgment for prejudgment and postjudgment interest
at the highest legal or contractual rate allowed by
by law;

ORIGINAL PETITION

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d.
d.

Plaintiff be
be granted judgment for all costs of court; and

e.
6.

Plaintiff be
be granted all further relief to which Plaintiff may
may be entitled.
Respectfully submitted,
/s/ Jason Lee Van Dyke
Jason L. Van Dyke
State Bar No. 24057426
108
108 Durango Drive
Crossroads, TX 76227
P7
P
– (469)
(469) 964-5346
F 7– (972)
(972) 421-1830
Email: jason@vandykelawfirm.com

ORIGINAL PETITION

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“A”
EXHIBIT “A”

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Jason L. Van Dyke
Atiorney & Counselor at Law
Licensed in Texas, Colorado, Georgia and The Dislricl

ol'Cqmhiu

September 5, 2017

Mockingbird Publishing Co.
and Gerard Belle 11
2346 Howey Road
Columbus, OH 4321

via CMRRR N0. 7016 2710 0000 9323 9190
and First Class US. Mail

1

NOTICE OF INTENT TO FILE LAWSUIT

Dear Mr. Bello:

This firm represents the Dallas/Ft. Worth and Houston chapters of The Proud Boys and
this correspondence constitutes notice of their intent to file a lawsuit against you for the false and
defamatory article authored by you and published by Mockingbird Publishing Co. a/k/a The
Mockingbird titled “Nee-Nazi Group Targets Residents in South Campus Area”. My firm will
also be associating with lawyers from Ohio to obtain damages on behalfof Ohio chapters of The
Proud Boys that were libeled by your article. Specifically, your article contains the following
false and defamatory statements:
(1) The article falsely states that The Proud Boys are a “Nee-Nazi Group”;
(2) The article falsely states that members of the Houston chapter were flashing “white
power” or “nazi” hand signs (the article contains a photograph of members of the
Houston chapter carrying guns, but not flashing any hand signs reasonably associated
with “white power” or national socialism);
(3) The article falsely states that the Ohio Proud Boys placed hand-drawn swastikas into
mailboxes and mail slots in an attempt at unlawful intimidation;

(4) The article falsely states that the Ohio Proud Boys were in Houston, when in fact, the
only chapters providing hum'cane relief in Houston were from the Houston, Dallas/Ft.
Worth, San Antonio, Austin, and Miami chapters;
(5) The article falsely states that the fraternity members who undertook an anti-looting
patrol were performing “ethnic cleansing"; and

I08 Durango Drive
Crossroads, TX 76227
P — (469) 96-6-5346
F — (972) 421-1830
jnsonoflvandykela\\1‘ rm.com

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(6) The article falsely states that The Proud Boys are roaming the nation trying to shoot
people.

While I would normally permit a publication such as yours the opportunity to make a
correction and issue a retraction, it’s clear from the context of the article and your willful
disregard for the facts that making such a demand will be fruitless. Accordingly, demand is for
you and Mockingbird Publishing Co. to immediately and permanently remove the offending
article. Second, demand is made for you and Mockingbird Publishing Co. to cease and desist
all fiJture false and defamatory articles conceming any chapter ofThc Proud Boys. Finally,
demand is also made to payment in the amount of$]0,000.00 in damages to “The Proud Boys”
as full and final settlement of the damages to the reputations of those depicted by your article to
the organization as a whole and its individual members. Please direct your payment to this
office.
You must either comply with all of the demands contained herein within founeen (14)
of your receipt of this letter, or in the alternative, provide my office with a reasonably time
frame by which you will comply. Should you fail to do so, I have been authorized to initiate a
days

lawsuit against you.

‘

I

son L. Van Dyke

Attorney & Counselor at Law

108 Durnugo Drive
Crossroads, TX 7627.7
P — (469) 964—5346
F — (972) 421-1830

jasoa'nndykclnwfirmmum

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“B”
EXHIBIT “B”

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2:17-cv-00745-JRG Document 2 Filed 11/16/17 Page 11 of 13 PageID #: 74

MENU

THE MOCKWGBIRD
.ILL THE NEWS THAT'S FIT TU PROVE

)1

HOME (/)
WHITE NATIONALIST
WITH LAWSUIT.
NAT‘ONAL‘ST LAWYER THREATENS THE MOCKINGBIRD
MOCK‘NGB‘RD W‘TH
LAWSU‘T READ OUR RESPONSE
RESPONSE
(I) /I WH‘TE

White Nationalist Lawyer Threatens the Mockingbird with
Lawsuit. Read Our Response

Author:
Autho
Gerry
Icontentlgerm-bello)
Germ Bello (/content/gerry-bello)

F pram-am

,Tweel

‘

I

(http://www.heise.de
(http://www.heise.de
IcUarlikeIIZ-Klicks/ct/artikel/2-Klicksinvestigative effectiveness
sh back and spin. There is no better push
push back the threat of a
effective fuer-mehrconfirmsjournalistic
Nothing confirms
journalistic integrity and investigative
like push
Ema”;
frivolous lawsuit. A frivolous lawsuit has no purpose
intimidate,,'and
t Datenschutznd to drain resources when itit is used in
in an attempt to
purpose other than to
1333879.html)
a prospect head
head on,
urglass sand and treasure,
silence the press. Facing such a
thing for aa new
properthing
treasure, is the proper
o the cost in hourglass
on, regardless of
source to do.
do. It is what is expected of if we are to defend the public trust that is placed in us to find and report the truth.
source
(http://www.mockinqbirdpaper.com/contentlneo-nazi-qroup-tarqetsA recent article about neo-nazi activity in
in the OSU campus
camgus area (http://www.mockingbirdpaper.com/content/neo-nazi-group-targetsresidents-south-camgus-area1 has given the Mockingbird,
trust. The article,
chance to earn to that public trust.
residents-south-campus-area)
Mockingbird, and myself personally,
personally, a chance
“Proud Boys”,
Boys", elicited our first actual cease and desist letter, which is
concerning the not proud enough to sign their swaztika fliers “Proud
is
in short, are (1)
included for reader download at the bottom of
this article. Their demands, in
ofthis
(1) Make the article go away (2)
(2) Don't write about
No. No.
No. And No.
us again (3)
(3) Gimme $10,000. The answer is going to be No.

Later today, or
tomorrow, September 15th,
following letter will be sent officially as a
iflI feel like it,
a response. Our dedicated readers
ortomorrow,
151h, if
it, the following
in Texas officially.
L. Van Dyke wish to evade service of
chance to enjoy it long before it arrives in
ofaa
should have a chance
officially. Should Mr. Jason L.
registered letter,
from his actions that Mr.
a newspaper for him to enjoy. It is clear
constitutes the publishing of an open letter in a
clearfrom
letter, this article constitutes
in a
a letter.
Van Dyke monitors this publication
publication as well as any internet address associated with this author, as will also be outlined in

Forthe
Proud Boys, the letter begins now:
For
the Enjoyment of the reader and the edification of the Proud

L. Van Dyke esquire,
Dear Mr. Jason L.

letter dated the 5th
Through our statutory agent we received your letter
51h of September 2017.
201 7. We have read your objections to our work, and
your demands to cease and desist. After that we had a
a long hardy belly laugh. The letter has been shown to attorneys with which we
have an ongoing relationship
in free speech
suggested that II not pay
relationship and specialize in
speech law. They suggested
you actually bring suit as they
pay them until you
batting average when
are fully confident II can handle you
100% batting
you and this action without much help from them. Just so you
you know, II have a 100%
appearing Pro-Se in federal labor court, State Court in
in Ohio and State Court in Texas as both plaintiff and defendant,
defendant, both civil and
criminal.

Since you
alleging Libel, please do realize that we are familiar with the relevant case law. That would be New York
V Sullivan
Times V.
York Times
you are alleging
Ohio" II can assume that you
“associating with attorneys in
and derivative cases under federal, Texas and Ohio law. Since you
in Ohio”
you claim to be “associating
you
in the Northern District of Texas, the
are still confused about venue,
venue, and can not decide if you
you are going to bring your so-called action in
Southern District of Ohio, or the State Courts of either Texas or Ohio. Are you
based on judges?
you shopping based on case law or based
is to sue Mockingbird Publishing
Publishing and myself
in State Court in
in Texas. It is
is not clear what exactly you
Perhaps your threat is
twice, once in
myselftwice,
you
intend to do other than silence the free press and collect a
a hefty payday.
happen.
payday. Neither of those things will ever happen.

“Proud
Nee-Nazis. What you
One of the your core allegations is that the so-called Proud Boys are not Neo-Nazis.
is that you
a “Proud
you failed to disclose is
you are a
Boy" yourself,
is included
profile. A screenshot of said profile
profile is
Boy”
yourself, of the third degree, or at least that you
you claim to be so on your Facebook profile.
below. Are you
under contract with the Proud Boys? Are you
in house counsel?
you under
you acting as their in

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Inigo

mumu anu shuclw Siudcmu!
man Tram Cm

Lam-u. Wawr‘
B

a.

an

cmu

l9

Buy-

You claim to be representing or finding
finding representation for Proud Boys
in Ohio. Proud Boys, as a
a legal entity, as opposed
opposed to an informal
informal
Boys in
in Ohio. Persons claiming
claiming membership have committed various acts of low
low grade intimidation here, but they
association, do not exist in
have
have not filed any
threatening a
a lawsuit in
in one, possibly two venues for a
a client
any paperwork with the Secretary of State's office. You are threatening
“association with"
in “association
that has no corporate existence in
with” lawyers
lawyers you do not care to name. Sir, you are a lawyer demanding monetary
damages for articles written in
in another state where you
not admitted
admitted to the bar on behalf of a
a group of anonymous clients that have
you are not
no
no way of retaining
retaining you. For that, you
nothing but a
a copy of this letter sent to the Texas bar association.
association.
you get nothing
Fort Worth Chapter (assuming
II can only assume that your basis for any action would be your own personal affiliation with The Dallas Fort
neo-nazis. You
you
affiliation of yours is an element of proof that the Proud
Proud Boys are in
in fact neo-nazis.
you joined the closest one to you).
you). This personal affiliation
sir, are a nazi. This makes your clients, when they are your close political affiliates, nazis as well.

Basic
time your were in
Basic research noted your 2000 arrest and conviction on weapons charges and domestic violence.
violence. At that time
in possession
semi-fictional terrorist manual. You also had a
aa of the Turner
Zion, a
Turner Diaries, a
a neo-nazi semi-fictional
a copy of the Protocols of
of the Elders of
a classic of
oion,
anti-Semitic forgery. The former book was written by
by the late William Pierce, the former head of the National Alliance. That man was an
self-described Hitlerian. There is
unapologetic
unapologetic and self-described
is a
a direct line from you
him to George Lincoln Rockwell,
Rockwell, who actually wore
you through him
swastika armbands. You
is a known white supremacist organization,
Conservative Citizens, which is
swastika
You were also a member of the Council of Conservative
organization,
albeit one lacking the more
jackboots uniforms.
more traditional robes and / or
orjackboots
How
How you came to pass the bar fitness
fitness exam with a
a domestic violence conviction and a
a weapons conviction is
is a
a mystery
is
mystery to me. What is
in possession of firearms,
much less claim to be an instructor with said convictions. Is
Is the ATF aware
also a mystery is how you can be in
firearms, much
of your apparent violations of federal firearms
firearms while under disability.
firearms law? You appear, on social media,
in possession of
offirearms
media, to be in
regarding the repeal
repeal of certain
certain firearms laws, on the neo-nazi website Stormfront,
II also noted a post regarding
WNLaw. II
Stormfront, by
by a profile called WNLaw.
assume the WN
WN stands forWhite
for White Nationalist as opposed to What Now. This appears to be you. Is
Is this you? Are you
you rambling on about
neo-nazi website
some ill-conceived petition
website while claiming that you and your friends are not
petition drive so you can legally have guns on a
a neo-nazi
I'm just doing my
neo-nazis? Did
Did II get that right? I'm
diligence here... since you seem to insist.
neo-nazis?
my due diligence

Your claims in short are without merit. Since this letter
letter may
colorful
may well be evidence some day II will spare the judge and the jury more colorful
language describing the deficit
deficit of merit your claims, and you
language
you as a human being, seem to lack.
Ilam
am going to assume that the letter should be delivered to 108
108 Durrango Drive as it is
is on your letterhead as your office. That is a
a lovely
home
home that doubles as your office.
office. I  see that you
you and your father teamed up to buy that nice little foreclosure and benefit somehow from
2011. II guess bottom feeding runs in your family.
the sub-prime mortgage crisis in 2011.
I  welcome
am prepared,
welcome your suit should you
it. Ilam
a number of firms who would be
be pleased to
prepared, and so are a
you be foolish enough to file it.
motivated their requests for participation. II personally do not
represent me against you. Both my
buffoonery, have motivated
my friendship, and your buffoonery,
take well to threats. Threatening
Threatening me is
is like attempting
attempting coitus with a
a garbage
garbage disposal.
disposal. It is
is pointless, painful and makes you
you look more
ridiculous on the internet than you already were.
were.
Should you bring your suit it will be noted that II do have a cause of action against you as well, along with your anonymous
anonymous clients. Your
post to my
fundraiser was proximate to so-called “shitposting” by
my recent gofundme fundraiserwas
by people II can only assume are also Proud Boys in
house" then purchase my
standing. The one who said he would sooner “slam his dick in a car door while leaving the keys in
in the house”
good standing.
my
latest book was a
a real winner.
winner.
You, and your neo-nazi associates directly interfered with my
the guise of political opposition. Since your goal was the
underthe
my business under
speech."
press organization
organization we will not
not dignify your conduct with the term “free speech.”
shutdown of a press
The threats and the harassment
harassment will cease now. There will be no further contact from you.

Good Day Sir,
Sir,
Gerry Bello
Publisher and Editor in Chief
Publishing
Mockingbird Publishing

BarAssociation
Association, Colorado State Bar Association,
Association, Georgia State Bar
CC: Texas State Bar Association,
Association
Associated Documents:
Documents:
 etler.pdf (http://www.mockingbirdpaper.com/sites/default/files/van%20dyke%20letter.pdf)
(http://www.mockinqbirdpgper.com/sites/defauIUfiles/van%20dvke%20letter.Qdfl
dvke letter.pdf
.4 van dyke

Tags:
Tags:
- white supremacists
sugremacists (/tags/white-supremacists)
ltags/white—sugremacists)

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 White Nationalist Lawyer Threatens the Mockingbird with Lawsuit.
Lawsuit. Rea...

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http://www.mockingbirdpaper.com/content/white-nationalist-lawyer-thre...
http://www.mockingbirdpaper.com/content/white-nationalist-lawyer—thre...

Proud Boys (/tags/proud-boys)
ltags/Qroud-boys)
o Censorship
Censorshig (/tags/censorship)
ltags/censorshig)
- Fail (/tags/fail)
flags/fail

Case 2:17-cv-00745-JRG Document 2 Filed 11/16/17 Page 13 of 13 PageID #: 76
o

reserved.
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