CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

INDEX NO. UNASSIGNED
RECEIVED NYSCEF: 05/21/2018

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
1 of
accepted for filing by the County Clerk.

33

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NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 05/21/2018

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

---------------------------------------------------------------X
ROBIN ANTIN, an individual; and
THE PUSSYCAT DOLLS,
INC., a California corporation,
Plaintiffs,

Index No.:

v.
DAILY MAIL CORPORATION, a
Delaware corporation; DAILY MAIL AND
GENERAL TRUST, a UK public limited
company; and DMG MEDIA LIMITED, a UK
private limited company,

COMPLAINT FOR
DEFAMATION

Defendants.

---------------------------------------------------------------X
Robin Antin ("Ms. Antin") and The Pussycat Dolls, Inc., ("The Pussycat Dolls")
(collectively "Plaintiffs"), bring this action, by KING & BALLOW, their attorneys herein, against
the Daily Mail Corporation, a Delaware corporation, Daily Mail and General Trust ("DMGT"), a
UK public limited company, and DMG Media Limited ("DMG Media"), a UK private limited
company, and assert as follows:
NATURE OF ACTION
1.

This defamation action arises out of the intentional, reckless and malicious

publication by the Daily Mail Corporation, acting as an agent or department ofDMGT and DMG
Media, of false and defamatory statements made by a disgruntled, unreliable and biased person
looking for her fifteen minutes of fame, Kaya Jones ("Jones" or "Ms. Jones"), when the Defendants
knew through their direct prior dealings with Plaintiffs, or should have known, with even the most
basic check, that Ms. Jones was .unreliable and her story obviously false. Instead, for pure
sensationalism, and advertising money, and to grab salacious headlines to sell their product, and

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
2 of
accepted for filing by the County Clerk.

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without caring what it meant for Plaintiffs, their business, or their reputation, the Defendants
published and commented on these defamatory statements with a reckless disregard for the truth.
These statements included statements that: The Pussycat Dolls was not a legitimate recording
group but was instead (1) a "prostitution ring", (2) that Ms. Antin and The Pussycat Dolls got the
members all "hooked on drugs", (3) that all members were abused in this way, (4) that Ms. Antin
"mentally and verbally abused" the members of the group "every second of the day", (5) that Ms.
Antin was the supposed madam of this prostitution ring (referred to by Ms. Jones as the "den
mother from hell"), and (6) that Ms. Antin was somehow responsible for the death of performer
Simone Battle. These statements are false, and the Defendants knew or should have known it.
2.

Indeed, the Defendants have interviewed Ms. Antin, even once at her home, and

members of The Pussycat Dolls, including international star Nicole Scherzinger. Defendants have
even reported numerous times over the years on the huge success of the group, and therefore is
well aware that The Pussycat Dolls were not a front for a prostitution ring, as they reported, the
members were never forced to take illegal substances, and were never sexually or mentally abused.
Defendants knew, based upon their interactions with the members of the group, that nobody had
ever so claimed or even insinuated that these events took place. In fact, the Defendants published
several articles, immediately prior to Ms. Jones' statements, discussing The Pussycat Dolls' plans
on a reunion, but not mentioning Ms. Jones as a part thereof, as she was never an actual member
of the recording group, as the Defendants knew full well. Those articles discussed the positive
feelings the actual members of The Pussycat Dolls had towards Ms. Antin and their excitement to
reunite. Ms. Jones' statements, coming on the heels of these reuniting stories, should have been
easily seen by the Defendants for what they were: fiction perpetrated by a disgruntled person
unhappy that she was not ever an actual member of The Pussycat Dolls (which the Defendants

2
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
3 of
accepted for filing by the County Clerk.

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knew because, as noted above, they have repeatedly identified the members of The Pussycat Dolls,
the latest just weeks before the defamatory articles were published, and did not mentioned Ms.
Jones as being a member), and not being included in the reunion. Nonetheless, the Defendants
published statements in two defamatory articles knowing that the accusations were not only
unlikely to be true but were absolutely untrue. The conduct of the Defendants was not just grossly
negligent, but malicious, and intentional.
3.

Ms. Antin brings this action in an attempt to restore her reputation. The Pussycat

Dolls bring this action in an attempt to restore their business reputation and the reputation of
members of The Pussycat Dolls. As a result of the actions of the Defendants, Ms. Antin went
virtually overnight from a well-respected business woman, to literally being viewed world-wide
as the head of an alleged prostitution ring, and someone who fed performers illegal drugs, abused
them in untold ways, condoned sexual assault of the members of The Pussycat Dolls, and was
supposedly responsible for the death of a performer. Likewise, The Pussycat Dolls, an
entertainment group built on the virtues of being empowered women, is now viewed world-wide
as a group of abused and immoral women, whose operator (Ms. Antin) supposedly perpetrated,
required, and condoned these horrific acts. All of this was false, and the Defendants knew it, or
should have known it, for the many reasons discussed above and below. Plaintiffs seek an award
of compensatory damages, including for the emotional distress, reputational harm, and other
damages caused by the Defendants' publication of these numerous defamatory statements. In
addition, due to the willful and malicious nature of these defamatory statements, Plaintiffs seek an
award of punitive damages.

THE PARTIES
4.

Plaintiff Robin Antin is an individual residing in Los Angeles County, California.

3
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
4 of
accepted for filing by the County Clerk.

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5.

Plaintiff, The Pussycat Dolls, is a corporation organized and existing under the laws

of California, with its principal place of business in California. Ms. Antin is currently the onehundred percent owner of The Pussycat Dolls.
6.

The Daily Mail Corporation in the United States is a corporation existing under the

laws of Delaware and headquartered at 51 Astor Place, 9th Floor, New York, New York 10003.
The Daily Mail Corporation was incorporated in the state of Delaware on June 4, 2002. The Daily
Mail Corporation is owned by DMG Media and DMG Media's parent corporation the DMGT. The
Daily Mail Corporation maintains an online newspaper website titled the "Daily Mail" that is free
and provides access to millions of visitors per month around the world. On October 15, 2017, the
following article was published by Defendants on this website: "'We were all abused': Former
member of Pussycat Dolls Kaya Jones says the band was a front for a 'prostitution ring' and the
singers were 'passed around' and 'abused' by industry executives." On October 17, 2017, the
following was published by Defendants: "EXCLUSIVE: Defiant ex-Pussycat Doll Kaya Jones
tells how top record exec sexually assaulted her in the back of his limo - one day after saying the
band was more 'prostitution ring' than pop group." The online website on which the defamatory
articles were published is owned and/or controlled by all of the Defendants herein. The Daily Mail
Corporation's registered office within the United Kingdom is at Northcliffe House, 2 Derry Street,
Kensington, London, United Kingdom, W8 5TT - which is the same address as the other named
Defendants.
7.

DMGT is a public limited company existing under the laws of the United Kingdom

with a registered office address at Northcliffe House, 2 Derry Street, Kensington, London, United
Kingdom, W8 5TT. Upon information and belief, DMGT operates a multinational portfolio of
media companies, and is the parent company of DMG Media. Upon information and belief, DMG

4
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
5 of
accepted for filing by the County Clerk.

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Media and the Daily Mail Corporation are agents ofDMGT, and DMGT operates through its agent,
the Daily Mail Corporation, in the United States. Alternatively, the control by DMGT over DMG
Media and the Daily Mail Corporation is so complete that the companies are in fact merely a
department of DMGT. DMGT thus transacts substantial business in New York through its
agents/departments DMG Media and the Daily Mail Corporation, including publishing the Daily
Mail articles containing the defamatory articles discussed herein, which are the basis of this action.
Upon information and belief, DMGT purposely avails itself to the benefits and privileges of
conducting business in the State of New York through its agents/department DMG Media and the
Daily Mail Corporation.
8.

DMG Media is a private limited company existing under the laws of the United

Kingdom with a registered office address at Northcliffe House, 2 Derry Street, Kensington,
London, United Kingdom, W8 STT. Upon information and belief, DMG Media owns the Daily
Mail Corporation, Mail Online, the Mail on Sunday, Metro, Wocher, Jobsite and Jobrapido. The
Daily Mail, including the online Daily Mail, is published by DMG Media and upon information
and belief is the second-biggest-selling daily newspaper in the United Kingdom. Upon information
and belief, DMG Media is a subsidiary of DMGT and acts as its agent, while the Daily Mail
Corporation acts as its agent in the United States. Upon information and belief, DMG Media
transacts substantial business in New York through its agent the Daily Mail Corporation, which
has its principal place of business in the United States in New York, including the publishing of
the defamatory articles that are the basis of this action. Upon information and belief, DMG Media
purposely avails itself to the benefits and privileges of conducting business in the State of New
York through its agent the New York based Daily Mail Corporation.

5
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
6 of
accepted for filing by the County Clerk.

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RECEIVED NYSCEF: 05/21/2018

9.

The registered office address for all three companies in the United Kingdom is

listed at www.gov.uk/government/organisations/companies-house at the same address of
Northcliffe House, 2 Derry Street, Kensington, London, United Kingdom, W8 5TT.

JURISDICTION AND VENUE
10.

This Court has general personal jurisdiction over the Daily Mail Corporation

because Defendant has continuous and systematic contacts within the State of New York as to
render the corporation essentially at home. Specifically, Daily Mail maintains a strong presence in
New York and has a head office located at 51 Astor Place, 9th Floor, New York, New York 10003.
11.

This Court has specific personal jurisdiction over the Daily Mail Corporation

because the suit-related conduct creates a substantial connection with the State of New York,
which include (1) distribution of the above named news articles within the State of New York; (2)
the cause of action alleged herein arise out of the Daily Mail Corporation's activities in the State
of New York, including having its physical office in New York; and (3) the Daily Mail Corporation
is, at a minimum, constructively aware of its continuous and substantial commercial interactions
with New York residents.
12.

This

Court has specific personal jurisdiction over DMGT because its

agent/department, the Daily Mail Corporation, (1) transacts substantial business within the State
of New York, including having its principal place of business in New York as discussed above;
(2) purposely avails itself to the benefits and privileges of conducting business in the State of New
York; (3) is physically present within the State of New York; and (4) there is a substantial
relationship between the transacted business and the claims asserted in this litigation.
13.

This Court has specific personal jurisdiction over DMG Media because its agent,

the Daily Mail Corporation, (1) transacts substantial business within the State of New York; (2)

6
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
7 of
accepted for filing by the County Clerk.

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purposely avails itself to the benefits and privileges of conducting business in the State of New
York; (3) is physically present within the State of New York; and (4) there is a substantial
relationship between the transacted business and the claims asserted in this litigation. Hereinafter,
DMGT, DMG Media, and the Daily Mail Corporation are all collectively referred to herein as the
"Daily Mail" or "Defendants."
14.

Venue is proper in this court as one of the Defendants resides in the City, County

and State of New York.

FACTUAL ALLEGATIONS
A. Background
15.

The Pussycat Dolls is a world renowned all-female dance and singing group

established in 1995 by Robin Antin as a modem dance troupe performing weekly shows at The
Viper Room, a nightclub in Los Angeles, California, and eventually at The Roxy ("The Pussycat
Dolls Show"). The Pussycat Dolls Show had a revolving cast of several dancers and singers that
performed popular music from the 50s and 60s. The revolving cast included guest celebrities such
as Christina Aguilera, Carmen Electra, Christina Applegate, Britney Spears, and Gwen Stefani,
among others. After years of performing on stage, The Pussycat Dolls Show successfully made
the transition from a singing and dance show into a recording group known simply as The Pussycat
Dolls.
16.

In 2003, Ms. Antin started a joint venture with Interscope Records, a division of

Universal Music Group, to develop The Pussycat Dolls as a franchise. The Pussycat Dolls
consisted of Nicole Scherzinger, Carmit Bachar, Ashley Roberts, Jessica Sutta, Melody Thorton,
and Kimberly Watt. Ms. Jones auditioned for the recording group, along with many others, but

7
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
8 of
accepted for filing by the County Clerk.

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 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

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was not one of the primary singers or performers. Her credits are restricted to two songs as backup
vocalist in 2004.
17.

The Pussycat Dolls released its first single "Don't Cha" in April 2005, which was

followed by the release of their debut album "PCD" in September 2005. "Don' t Cha" features rap
artist Busta Rhymes, who also co-wrote the song with its producer, artist Cee-Lo Green. The debut
single "Don't Cha" reached number two on the Billboard Hot 100, was nominated for Top Selling
Single of the Years at the 2005 Billboard Music Awards and won the award for Hot R&B/HipHop Songs Sales at the 2006 Billboard R&B/Hip-Hop Awards. By May 2011, the song had 2.9
million sales according to Nielsen SoundScan and was certified Platinum by the RIAA for
shipment of a million copies of the single.
18.

Following the success of "Don't Cha," the debut album, "PCD" has sold over 7

million albums worldwide. Three years after the release of "PCD", The Pussycat Dolls released
their second album, "Doll Domination." In total, The Pussycat Dolls have sold over 54 million
records worldwide. The Pussycat Dolls went on hiatus in 2010.
19.

The Pussycat Dolls have always stood for female empowerment and sisterhood.

The Pussycat Dolls motto is: "Inside every woman is a Pussycat Doll." By stating that The
Pussycat Dolls was in reality a prostitution ring, and not a recording group, the Daily Mail has
greatly harmed the business reputation of The Pussycat Dolls. Further, The Pussycat Dolls recently
announced that they intended to reunite the group after approximately almost a decade on hiatus.
This announcement and the circumstances surrounding the reunion were reported on extensively
by the Daily Mail. The articles released by the Daily Mail on this topic show that they knew, or
should have known, that the allegations raised by Ms. Jones were completely without merit and
originated from a biased and untrustworthy source with a vendetta against Ms. Antin and The

8
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
9 of
accepted for filing by the County Clerk.

33

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CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

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RECEIVED NYSCEF: 05/21/2018

Pussycat Dolls originating from the group rejecting her as a member over a decade ago, and not
including her in the planned reunion now.
20.

On August 5, 2015, the Daily Mail ran the first of three articles, preceding the

defamatory articles at issue in this litigation, discussing the potential reunion of The Pussycat Dolls
titled, "EXCLUSIVE: Don't cha wish they'd get back together? They will! Pussycat Dolls' creator
says original line-up is preparing for the biggest reunion since the Spice Girls." The article
discusses The Pussycat Dolls in detail and contains an in-depth interview of Ms. Antin. In the
article, Ms. Antin told the Daily Mail: "The history ofreunions is something that everyone always
wants and looks forward to and I believe that, when the time comes for the Pussycat Dolls reunion,
it will be massive" .. . "I have spoken with all of the girls about it a lot and I truly believe that's
going to happen in the very near future" "I just spoke to Nicole and told her about the interview
and she said, 'You can tell them I'm totally down for it."' At no time does the article mention any
accusations of wrongdoing by Ms. Antin or scandal involving The Pussycat Dolls.
21.

The August 5, 2015 Daily Mail article, however, does reveal information and facts

known by the Daily Mail. Namely, the article notes: (1) that The Pussycat Dolls consists of six
members, which does not include Ms. Jones, (2) that the group parted ways in 2009 due to personal
differences and not due to any scandalous, immoral or illegal acts, (3) that The Pussycat Dolls
were treated fairly and appropriately at all times, and (4) that The Pussycat Dolls was not a front
for a prostitution ring but instead an internationally renowned group that had topped the charts in
15 countries and sold millions of records worldwide. Although the Daily Mail knew many, if not
all of these points, they were omitted or contradicted by the Daily Mail's defamatory October 15
and October 17, 2017 articles.

9
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
10 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

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22.

Additionally, the August 5, 2015 article reveals that the Daily Mail knew that Ms.

Antin treated the members of The Pussycat Dolls respectfully and was looked up to fondly by the
members of The Pussycat Dolls by quoting Ms. Antin "I was their sister, their mother, their
therapist, their friend, but that's just who I am. I'm very nurturing."
23.

On October 2, 2017, the Daily Mail published an article titled, "'The girls feel the

time is right to let bygones be bygones': Nicole Scherzinger 'is poised for dramatic Pussycat Dolls
reunion' ... seven years after their acrimonious split." The acrimonious split was attributed to
simple jealously and natural internal friction between the members. The article was published
approximately two weeks prior to the Daily Mail's defamatory October 15 and October 17, 2017
articles and discusses the recently publicly announced decision by Ms. Antin and The Pussycat
Dolls to reunite after a long hiatus.
24.

The Daily Mail's October 2, 2017 article demonstrates that the Daily Mail had

extensive knowledge of Ms. Antin and the members of The Pussycat Dolls with the author stating,
"Rumours [sic] of the reunion with the other Pussycat Dolls have been gathering pace for years as
the band's founder Robin Antin told MailOnline she was doing 'everything' she could to make it
happen ... " The article demonstrates that the Daily Mail had close personal contact with Ms. Antin
and could have easily reached out to her, or other members of The Pussycat Dolls, prior to running
the defamatory articles to attempt verification of the allegations.
25.

On October 9, 2017, just days prior to the Daily Mail's publishing of the first

defamatory article accusing The Pussycat Dolls of being a prostitution ring and Ms. Antin of
numerous illegal acts, the Daily Mail ran another article discussing the upcoming reunion of The
Pussycat Dolls titled, "'Nicole Scherzinger and her fellow Pussycat Dolls CONFIRM band

10
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
11 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

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reunion ... following reports the girls had finally 'put their differences behind them' after eight
years." This article provides additional commentary on The Pussycat Dolls' upcoming reunion.
26.

The October 9, 2017 article demonstrates that Daily Mail knew that The Pussycat

Dolls were a world-famous recording group that had millions of fans across the globe and not a
prostitution ring. The article noted that The Pussycat Dolls had topped the charts for six years and
"The Pussycat Dolls delighted fans by confirming they are getting back together on Monday, after
eight years apart." At no time does the article mention any accusations of wrongdoing by Ms.
Antin or scandal involving The Pussycat Dolls.
27.

These articles, taken together, demonstrate that the Daily Mail was intimately

familiar with Ms. Antin and The Pussycat Dolls. Based on the Daily Mail's familiarity with Ms.
Antin and The Pussycat Dolls they knew, or should have known, that any accusations of forced
drug use by Ms. Antin, forced prostitution, or any other illegal activity were completely baseless
and without merit. Based on the Daily Mail's relationship and previous reporting on Ms. Antin
and The Pussycat Dolls they knew, or should have known, that the statements in its October 15
and 17, 2017 articles was inherently improbable. As there was no hint that the statements presented
were true, the Daily Mail had a duty to further investigate the claims prior to publishing.
28.

Further, two of the articles published by the Daily Mail were written immediately

before the publishing of the October 15 and 17, 2017 articles containing and discussing Ms. Jones'
defamatory allegations. As the Daily Mail was aware that Ms. Jones was not, nor ever had been,
an official member of The Pussycat Dolls, and was not part of any planned reunion, they knew or
should have known that any allegations raised by Ms. Jones were inherently improbable. Further,
the Daily Mail knew, or should have known, that Ms. Jones was an unreliable source, biased
against Ms. Antin and The Pussycat Dolls due to her failure to be chosen to be a member of the

11
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
12 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

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group and reunion. Due to the timing of Ms. Jones' statements in relation to the recent reunion
announcement by The Pussycat Dolls, the Daily Mail knew, or should have known, that there were
obvious reasons to doubt the veracity of the statements. It is clear from Ms. Jones' statements that
she harbored an extreme vendetta against Ms. Antin and the members of The Pussycat Dolls.
29.

The Daily Mail ' s October 15 and 17, 2017 articles portray Ms. Jones as a "member"

of The Pussycat Dolls. However, as the Daily Mail was well aware, Ms. Jones was never an official
member of The Pussycat Dolls. The extent of Ms. Jones' credits in The Pussycat Dolls is when
she auditioned and served as a backup vocalist on the song Sway released in 2004 and the song

We Went As Far as We Felt Like Going also released in 2004. The Daily Mail knew Ms. Jones
was not a member based on their own recent, prior articles. Furthermore, had the Daily Mail
performed any investigation into this matter, such as reviewing album credits available on the
Internet, they would have also seen this information. Like many of the statements made by Ms.
Jones in relation to The Pussycat Dolls, her self-portrayal as a core member or "leader" of The
Pussycat Dolls is a fantasy. Ms. Jones was also not a part of The Pussycat Dolls Show, which
consisted of about twenty women, or, as noted, part of The Pussycat Dolls recording group, which
consisted of Nicole Scherzinger, Carmit Bachar, Ashley Roberts, Jessica Sutta, Melody Thorton,
and Kimberly Wyatt.
30.

The Daily Mail had knowledge that Ms. Jones was not a member of The Pussycat

Dolls, as mentioned above, as they published the names of the individual members of the group in
the August 5, 2015 article and just days prior to the defamatory article, the Daily Mail released an
article reaffirming that the Pussycat Dolls "founded by Robin Antin, led by Nicole but also made
up of Carmit Bachar, Ashley Roberts, Melody Thornton, Kimberly Wyatt and Jessica Sutta ... were
plan[ing] to reunite." No mention of Ms. Jones was made in this article.

12
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
13 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

INDEX NO. UNASSIGNED
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31.

Ms. Jones' limited involvement with The Pussycat Dolls occurred when she was

one of the ten or more women who auditionedin the hope of being selected to be a member of The
Pussycat Dolls recording group. These women were given the opportunity to perform during a
trial period to determine which performer would make the final cut for The Pussycat Dolls
recording group. Ms. Jones did not make the cut to become a member and parted ways before The
Pussycat Dolls recording group was officially created. Ms. Jones has no involvement whatsoever
in the success of The Pussycat Dolls recording group or in the release of their internationally
successful album "PCD" in 2005 . As explained herein, this has led Ms. Jones to harbor extreme
resentment toward Ms. Antin and The Pussycat Dolls, a fact the Daily Mail knew based upon the
very comments within the defamatory statements published by them. All of this information was
also known or reasonably should have known to the Daily Mail.
32.

The publishing by the Daily Mail of these grossly defamatory and indeed malicious

statements and comments thereon have caused irreparable harm to the business reputation of Ms.
Antin and The Pussycat Dolls. The group, and Ms. Antin, once viewed as standing for women's
empowerment, have now been portrayed by the Daily Mail as a "den mother" (madam), prostitutes
and drug pushers and abusers. The Pussycat Dolls and Ms. Antin relies on their business reputation
in order to sell tickets to concerts, albums, and merchandise.
33.

The Daily Mail knew, or should have known, that the statements presented by Ms.

Jones were untrue. For years, the Daily Mail has interviewed and ran stories on Ms. Antin and the
members of The Pussycat Dolls on a variety of topics. At no time during this period were there
any hints of the statements published by the Daily Mail in the defamatory articles. Further, due to
their close relationship with Ms. Antin, and knowledge of the members of the group, including the
world-famous Nicole Scherzinger, the Daily Mail could have, had they chosen to, easily reached

13
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
14 of 33
accepted for filing by the County Clerk.

 INDEX NO. UNASSIGNED

CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

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RECEIVED NYSCEF: 05/21/2018

out to Ms. Antin in an attempt to verify the accusations presented by Ms. Jones. However, no such
contact was made. Instead, the Daily Mail quickly published and commented on Ms. Jones'
defamatory statements in order to grab the public's attention and generate views on their website.
B. The Publications
The First Defamatory Article Published by the Daily Mail

34.

On October 15, 2017, the Daily Mail, acting as the agent of the DMGT and DMG

Media, published "We were all abused: Former member of Pussycat Dolls Kaya Jones says the
band was a front for a 'prostitution ring' and the singers were 'passed around' and 'abused' by
industry executives." The article was published to a worldwide audience on the Daily Mail's
website. A true and correct copy of the online edition of the article is attached hereto as Exhibit
A.

35.

The October 15, 2017 Daily Mail article contained the following false and

defamatory statements concerning Robin Antin and The Pussycat Dolls:
a. "A former member of the Pussycat Dolls has claimed that the girl group operated as a
'prostitution ring', with the members forced into sex with entertainment executives." Statement made by Daily Mail author Keith Griffith in Daily Mail article dated October
15, 2017.
b. "Kaya Jones, 33, made the explosive accusation in a series of tweets on Saturday and
Sunday, accusing managers and executives of taking advantage of the group she joined as
a teenager in 2003." - Statement made by Daily Mail author Keith Griffith in Daily Mail
article dated October 15, 2017.
c. "My truth. I wasn't in a girl group. I was in a prostitution ring. Oh & we happened to sing
& be famous. While everyone who owned us made the $" - Statement published in Daily
Mail article dated October 15, 2017.
d. "How bad was it? People ask-bad enough that I walked away from my dreams,
bandmates&a 13 million .dollar record deal. We knew we were going to # 1" - Statement
published in Daily Mail article dated October 15, 2017.

14
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
15 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

INDEX NO. UNASSIGNED
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e. "Jones' allegations date back at least a decade, and did not name specific men who took
part in the alleged abuse." - Statement made by Daily Mail author Keith Griffith in Daily
Mail article dated October 15, 2017.
f.

"To be apart of the team you must be a team player. Meaning sleep with whoever they say.
If you don't they have nothing on you to leverage" - Statement published in Daily Mail
article dated October 15, 2017.

g. "It's best to not get defensive & attack when you're guilty. Sorry our house of cards is
done. Everyone will soon know the truth ... " - Statement published in Daily Mail article
dated October 15, 2017.
h. "I love how predators enjoy playing the victim. Pathetic" - Statement published in Daily
Mail article dated October 15, 2017.
1.

"Jones said that part of being in the girl group was being told to sleep with executives." Statement made by Daily Mail author Keith Griffith in Daily Mail article dated October
15,2017.

j.

"'Executives, and managers, and agents and other artists that are on the label, if you don't
want to sleep with an executive they'll pass you to that. Or sometimes they' ll continue to
pass the girl, so she's just passed around', Jones explained in a recorded interview with
Info Wars.com" - Statement made by Daily Mail author Keith Griffith in Daily Mail article
dated October 15, 2017 referencing Kaya Jones Interview published via YouTube on
October 13, 2017.

k. "Yes I said leverage. Meaning after they turn you out or get you hooked on drugs they use
it against you. Correct. Victimizing the victim again" - Statement published in Daily Mail
article dated October 15, 2017.

I. "Why don't we report it? Because we are all abused! I personally have been warned if I
tell I will ... you know end up dead or no more career" - Statement published in Daily
Mail article dated October 15, 2017.
m. "Jones also leveled stark accusations in apparent reference to the 2014 suicide of Simone
Battle, a member of G.R.L., another girl group founded by Pussycat-mastermind Antin." Statement made by Daily Mail author Keith Griffith in Daily Mail article dated October
15, 2017.
n. "I want the den mother from hell to confess why another 1 of her girl group girls committed
suicide? Tell the public how you mentally broke us" - Statement published in Daily Mail
article dated October 15, 2017.
15
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
16 of 33
accepted for filing by the County Clerk.

 INDEX NO. UNASSIGNED

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o. "She later added: 'It's best to not get defensive & attack when you're guilty. Sorry your
house of cards is done. Everyone will soon know the truth ... "' - Statement published in
Daily Mail article dated October 15, 2017.
p.

"Robin & the record label made all the money. We as Pussycat Dolls were paid $500 a
week. While we were being abused & used. Fact!" - Statement published in Daily Mail
article dated October 15, 2017.

q. "To anyone thinking I've made this up, why would I want to have a target on my back/
claim to have been used & abused? Not exactly a good look" - Statement published in
Daily Mail article dated October 15, 2017.
36.

Based on the Daily Mail's previous relationship with Ms. Antin and The Pussycat

Dolls, the Daily Mail knew or should have known that these statements were false, defamatory,
and malicious but nonetheless published such statements. The statements could have easily been
verified as false by numerous people easily accessible to the Daily Mail, and the Daily Mail knew
or should have known they came from an inherently unreliable person as explained herein. In other
words, these statements state that "all" members were subjected to this disgusting conduct. It
would have been easy to investigate the truth of those allegations if the Daily Mail cared by
reaching out to any of the world famous past members of the group. The Daily Mail did not do so
because it did not care. The Daily Mail not only did no investigation, but it ignored all of the
evidence it possessed to the contrary, including articles published just weeks before.
37.

On or about October 23, 2017, Plaintiffs contacted the Defendants to request a

retraction of the publication. Plaintiffs' retraction letter was mailed via overnight FedEx delivery
to the contact address listed for all three of the Defendants at Northcliffe House, 2 Derry Street,
Kensington, London, United Kingdom, W8 5TT. The FedEx confirmation number was
788191804848 . B. Bimel, signing on behalf of the Daily Mail, received the request on October 26,
2017.
16
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
17 of 33
accepted for filing by the County Clerk.

 INDEX NO. UNASSIGNED

CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 05/21/2018

38.

The Daily Mail has not apologized to Plaintiffs and has not responded to Counsel

regarding the retraction request. This is further evidence of their malice, and further support for
punitive damages.
The Second Defamatory Article Published by the Daily Mail

39.

On October 17, 2017, the Daily Mail, acting as the agent of DMGT and DMG

Media, published "Exclusive: Defiant ex-Pussycat Doll Kaya Jones tells how top record exec
sexually assaulted her in the back of his limo - one day after saying the band was more 'prostitution
ring' than pop group." The article was published to a worldwide audience on the Daily Mail's
website. A true and correct copy of the online edition of the article is attached hereto as Exhibit
B.

40.

The October 17, 2017 Daily Mail article contained the following false and

defamatory statements concerning Plaintiffs:
a. "Kaya Jones, the Defiant ex-Pussycat Doll who called the pop group a 'prostitution ring,'
has detailed the sex abuse she said she went through while she was still a member of the
band." - Statement made by Daily Mail author Martin Gould in Daily Mail article dated
October 17, 2017.
b. "Jones, who left the Dolls after three years in 2005, told DailyMail.com in an exclusive
interview she and other members of the scantily clad all-girl group were regularly abused
by music industry executives." - Statement made by Daily Mail author Martin Gould in
Daily Mail article dated October 17, 2017.
c. "It wasn't sex for money per se, but sexual favors were expected of the Dolls." - Statement
made by Daily Mail author Martin Gould in Daily Mail article dated October 17, 2017.
d. "'I have lost count of the number of times my car didn't turn up at the end to take me home.
'Oh, so-and-so will give you a ride home,' I was always told. 'Ifl accepted, the same thing
would happen again. How many times does a girl hoping to make it big have to push an
older man off her?"'
e. "I stopped and thought to myself: 'What are you doing? This girl wants to be me. If she
succeeds she will have to cope with sexual predators and verbal and mental abuse, she'll
17
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
18 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

INDEX NO. UNASSIGNED
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suffer from eating disorders, she'll consider suicide." - Statement published in Daily Mail
article dated October 17, 2017.
f. "Then I read that the Pussycat Dolls are planning a reunion. That would mean more girls
being abused just the way we were. Why wouldn't it happen again? - it's all the same
people involved." - Statement published in Daily Mail article dated October 17, 2017.
g. "Jones first made her allegations in a series of tweets over the weekend. 'My truth. I wasn't
in a girl group. I was in a prostitution ring. Oh & we happened to sing & be famous. While
everyone who owned us made the $,' she wrote early on Friday morning". - Statement
published in Daily Mail article dated October 17, 2017.
h. "She followed that up with a second tweet. 'How bad was it? people ask - bad enough
that I walked away from my dreams, bandmates & a 134 million dollar record deal. We
knew we were going to #1. '"- Statement published in Daily Mail article dated October 17,
2017.
1.

"Minutes later came a third tweet. 'To be apart (sic) of the team you must be a team player,'
she wrote. 'Meaning sleep with whoever they say. If you don't they have nothing on you
to leverage."' - Statement published in Daily Mail article dated October 17, 2017.

j.

"Then a fourth. 'Why don't we report it? Because we are all abused! I personally have been
warned if I tell I will . .. you know end up dead or no more career."'- Statement published
in Daily Mail article dated October 17, 2017.

k. "Jones blames band founder Robin Antin - whom she dubbed 'the den mother from hell'
for many of the problems. She claims band members were paid just $500 a week as Antin
got rich." - Statement published in Daily Mail article dated October 17, 2017 .

1. "Jones also leveled stark accusations in apparent reference to the 2014 suicide of Simone
Battle, a member of G.R.L., another girl group founded by Pussycat mastermind" Statement made by Daily Mail author Martin Gould in Daily Mail article dated October
17, 2017.
m. "I want the den mother from hell to confess why another 1 of her girl group girls committed
suicide? Tell the public how you mentally broke us." Statement published in Daily Mail
article dated October 17, 2017.
n. "'She mentally and verbally abused us every second of the day, Jones told DailyMail.com.
'She would tell me how fat my a** was or how small another girl's breasts were."' Statement published in Daily Mail article dated October 17, 2017.

18
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
19 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

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o. '"She even took all our baby pictures for a project she called 'Before The Dolls Were
Dolls.' It was all in such a rush that I didn't even have time to make copies. 'When I asked
for them back she said she had thrown them in the trash. So, basically, I lost all my
childhood pictures."' - Statement published in Daily Mail article dated October 17, 2017.

41.

Based on the Daily Mail's previous relationship with Ms. Antin and The Pussycat

Dolls, the Daily Mail knew or should have known that the statements were false, defamatory, and
malicious but nonetheless published and commented on the statements. The statements could have
easily been verified as false by numerous people easily accessible to the Daily Mail, and the Daily
Mail knew or should have known they came from an inherently unreliable person, as discussed
herein.
42.

On or about October 23, 2017, Plaintiffs contacted the Defendants to request a

retraction of the publication. Plaintiffs' retraction letter was mailed via overnight FedEx delivery
to the contact address listed for all three of the Defendants at Northcliffe House, 2 Derry Street,
Kensington, London, United Kingdom, W8 5TT. The FedEx confirmation number was
788191804848. B. Bimel, signing on behalf of the Daily Mail, received the request on October 26,
2017.
43.

The Daily Mail has not apologized to Plaintiffs and has not responded to Counsel

regarding the retraction.
C. The Publication by the Daily Mail Was Not Just Grossly Negligent But Was Malicious

44.

The publication by the Daily Mail is defamatory per se as it asserts that The

Pussycat Dolls was not a legitimate recording group, but instead was a prostitution ring, that Ms.
Antin and The Pussycat Dolls condoned the sexual assault of its members, and that The Pussycat
Dolls, and Ms. Antin, were involved in a serious criminal offense as well as immoral and notorious
conduct. The same is true of the statement that the members of The Pussycat Dolls and Ms. Antin

19
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
20 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

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hooked its members on illegal drugs and abused them in untold ways. While all of these statements,
and the publication of them by the Daily Mail without any investigation at all when they knew the
statements were not likely to be true, are reprehensible, perhaps the most disturbing is the vile
publication of the statement that Ms. Antin was somehow responsible for the tragic suicide of
entertainer Simone Battle. There is absolutely nothing asserted that supports that statement, and
such a horrific statement cannot just be published without any investigation at all. All of these
statements are false. The Pussycat Dolls was not a prostitution ring (they sold 54 million records),
The Pussycat Dolls were not sexually assaulted, and certainly not with the knowledge or consent
of Ms. Antin, and Ms. Antin did not distribute or force consumption of illegal drugs on any member
of The Pussycat Dolls or any other individual.
45.

The Daily Mail cannot publish these statements without an attempt to verify

anything. In light of their own previous reporting, the Daily Mail knew, or should have known,
that these statements were false or at the very least highly unlikely to be true, and came from an
unreliable source, who was biased against Ms. Antin, but nevertheless published and commented
on these spurious and scurrilous allegations verbatim without checking the source or doing even a
basic investigation. It literally would have taken seconds to determine that these statements were
false.
46.

Any one of the many actual members of The Pussycat Dolls, or those who

performed with them, or auditioned, many of whom are world famous entertainers still, could have
been asked if any of these statements were true, and the Daily Mail would have been told no. The
Daily Mail had interviewed Ms. Antin on a number of occasions and clearly had direct access to
her and other members of the group if needed. Immediate corroboration or refutation was therefore
available. It is clear, however, that the Daily Mail was not interested in determining if there were

20
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
21 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

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any truth to Ms. Jones' statements. In contrast to situations where a person alleges that he or she
was the victim of a private crime or private sexual assault by another, the published statement here
was that every woman in The Pussycat Dolls was made to prostitute herself, and were the victims
of sexual assault, and forced to take drugs against their will, and that this recording group (at the
time co-owned by the largest music organization in the world, Universal Music Group, but now
100 percent owned by Ms. Antin), was a prostitution ring, not a recording group, even though it
has sold fifty-four million records. The Daily Mail could have taken their pick of literally dozens
of personalities to contact to see if there was an inkling of truth to it, but did not do so because
they wanted sensationalism, and were not interested in the truth. The conduct of the Daily Mail
was malicious and reckless, and they should now be held responsible for the enormous damage
the Plaintiffs have suffered as a direct result of that conduct, including being responsible for
punitive damages.
4 7.

Indeed, former Pussycat Doll members have publicly mentioned how professional

The Pussycat Dolls experience was in video interviews available on YouTube; for example, Jessica
Sutta stated during an interview with ABC News in 2010 that there was "no tension" upon leaving
the Pussycat Dolls. "It was a business relationship, it was just time for me to go. There were no
hurtful things said, it was always professional." She further stated, "Deep down in my heart I
know I'll always be a Pussycat Doll, it was the most incredible experience, I traveled the world,
developed as an artist and am very grateful for every single one of them." Pussycat Dolls member,
Carmit Bachar, in a 2009 interview with E! expressed her continuing support for the group while
it was on hiatus, stating "We went through so much together, we are like sisters, we're family.
Nothing can take that away." Ashely Roberts, a member of both The Pussycat Dolls Show and
The Pussycat Dolls, stated in a 2012 interview, "I'm just very thankful and grateful that I got to be

21
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
22 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

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in the group when it was at its peak and we got to do what we got to do. Cause we were sisters and
we were magic." As noted, these videotaped interviews are available for viewing on YouTube,
and provides concrete evidence that the statements of Ms. Jones were unlikely to be true.
48.

The Daily Mail should have known that Ms. Jones was highly unreliable, and that

the statements were unlikely to be true, for a number of other reasons: (1) a review of the credits
from the songs of The Pussycat Dolls, would have shown the Daily Mail that Ms. Jones was not
one of The Pussycat Dolls and the extent .o f her credits was as a backup vocalist on two songs in
2004, (2) the Daily Mail had previously written about Ms. Antin and The Pussycat Dolls on a
number of occasions and have never reported that Ms. Jones was a member of the group, (3) the
alleged horrific and supposedly criminal events occurred approximately 13 years ago and Ms.
Jones is only asserting them now. Indeed, Ms. Jones has had no success in the entertainment
industry to speak of and is virtually unknown. That she emerged out of nowhere, approximately
13 years later, to raise these baseless claims, alone should have shown the Daily Mail that she was
unreliable and the assertions were probably untrue, (4) the alleged events did not involve only Ms.
Jones but supposedly all members of The Pussycat Dolls; yet, no other woman has ever complained
despite supposedly all being the victims of sexual assault and forced into prostitution and drug
abuse, (5) other members, like Ms. Sutta above, have spoken publicly glowingly of their time with
The Pussycat Dolls, (6) the Daily Mail previously reported that the group split up due to personal
reasons and not as a result of any of the actions Ms. Jones claims occurred, (7) Ms. Jones, who had
been denied membership to The Pussycat Dolls, made her statements directly after Ms. Antin and
The Pussycat Dolls announced plans for a reunion, a fact that the Daily Mail reported on twice,
and (8) Ms. Jones did not provide a single name for corroboration. Ms. Jones did not say this
woman, or that woman, can verify what I say is true. This alone shows how unreliable she is, and

22
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
23 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

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how unlikely the statements are to be true. Indeed, any one of these facts should have alerted the
Daily Mail to the fact that the statements were obviously false, but, in combination, these facts
show something worse: that the Daily Mail acted even more than maliciously. The Daily Mail
absolutely acted intentionally and in a willful and wanton manner. One can literally see them
salivating over the despicable and scandalous headlines they would write in order to attract views
on the internet.
49.

Ms. Jones' resentment and bias toward Ms. Antin, which the Daily Mail also knew

or should have known, is found right within Ms. Jones' own statements published and commented
on by the Daily Mail: among other things, she complains, as noted above, that (1) she was
supposedly forced to give up on her dreams and leave The Pussycat Dolls due to this supposed
environment leaving her chance at stardom behind, (2) Ms. Antin supposedly got rich while Ms.
Jones and others made $500 per week, and (3) she speaks with obvious venom and spite about Ms.
Antin and the Pussycat Dolls, referring to Ms. Antin as "the den mother from hell." These
statements alone alerted the Daily Mail to her spite and unreliability if they cared. The timing of
this onslaught should also have alerted the Daily Mail of the vendetta against Ms. Antin and The
Pussycat Dolls. Approximately one week prior to Ms. Jones' defamatory allegations, The Pussycat
Dolls announced that the group was planning a reunion after being on hiatus for almost a decade.
Ms. Jones was apparently greatly distressed to learn of this possible reunion, since, as noted, she
has been biased against Ms. Antin as a result of her failure to be chosen as a member of The
Pussycat Dolls. Though Ms. Jones has provided several different stories to the media as to what
triggered her onslaught of defamatory statements, this appears to be the primary motivating factor.
Likely, Ms. Jones saw this announcement as the perfect opportunity to finally take a shot at Ms.
Antin and The Pussycat Dolls in a way that would cause the most damage to their reputation. One

23
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
24 of 33
accepted for filing by the County Clerk.

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of her defamatory statements made this clear: "Then I read that the Pussycat Dolls are planning a
reunion. That would mean more girls being abused just the way we were. Why wouldn't it happen
again? -

it's all the same people involved."

50.

Although Ms. Jones' statements implicated every member of The Pussycat Dolls

Show and The Pussycat Dolls as being victimized, prostituted, and/or drugged and that Ms. Antin
was somehow responsible for such treatment, to the best of Plaintiffs' knowledge, the Daily Mail
has not contacted any of the individuals involved with these groups to investigate the truth of the
allegations prior to its publications. As reflected in the statements released by several former
Pussycat Dolls members condemning Ms. Jones' unfounded allegations, had the Daily Mail
reached out to these well respected and credible entertainers, they would have quickly learned that
the accusations of Ms. Jones simply have no basis in truth. Unfortunately for Ms. Antin and The
Pussycat Dolls, no investigation was performed by the Daily Mail.
51.

Since these entertainers were not given a chance to comment prior to publication,

any statements and responses released by former members of The Pussycat Dolls Show or the
Pussycat Dolls were necessarily made after the Daily Mail published its defamatory articles and
therefore the damages to Plaintiffs' reputation had already been done. One simply cannot put the
genie back in the bottle after the articles were circulated around the world, stating that The Pussycat
Dolls are a prostitution ring. No denial made after this occurs can remedy the damage.

D. The Statements Are Of And Concerning Robin Antin And The Pussycat Dolls
52.

The defamatory statements, including commentary by the Daily Mail writers,

explicitly and unambiguously, refer to Robin Antin and the individual members of The Pussycat
Dolls. The numerous defamatory statements published by the Daily Mail, refer to Robin Antin and
The Pussycat Dolls by name throughout, or were made of and concerning Robin Antin and The

24
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
25 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

INDEX NO. UNASSIGNED
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Pussycat Dolls and were so understood by those who read the statements to be about Robin Antin
and the individual members of The Pussycat Dolls.
53.

Indeed, as noted above, Ms. Antin is the founder, manager, lead choreographer, and

one-hundred percent owner of The Pussycat Dolls. Any individual familiar with The Pussycat
Dolls would understand that the defamatory statements published by Daily Mail were referring to
Ms. Antin as she is synonymous with The Pussycat Dolls to those familiar with the group.
Similarly, the reference to the "den mother" of The Pussycat Dolls would also be understood by
any individual familiar with The Pussycat Dolls to be referring to Ms. Antin. Overnight, Ms. Antin
went from being a relatively private individual and businesswoman to being referenced in
newspapers literally around the world, by a completely unreliable source, as running a criminal
enterprise, and the individual members of The Pussycat Dolls went from being a respected
recording group that sold tens of millions of records to being a regarded as a criminal enterprise.
54.

The Daily Mail' s publications of these defamatory statements have caused great

harm to Ms. Antin personally, professionally, and have drawn national attention to her as a private
citizen in a negative light. Ms. Antin is a successful and well-respected business woman for her
work as a choreographer and entrepreneur in the entertainment industry. Ms. Antin relies on her
income from her career as a choreographer and manager for her livelihood and has since lost
business as a direct result of the Daily Mail's publications. Plaintiffs have asked that the Daily
Mail retract their Publications, which they have brazenly refused to do.
55.

The publication of Ms. Jones' defamatory claims had an immeasurable and

unquestionably negative impact on Ms. Antin's reputation. Ms. Antin had an impeccable
reputation as a business person and has never before been accused of any wrongful conduct related
to her management of The Pussycat Dolls or any other associated acts. As an individual who has

25
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
26 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

INDEX NO. UNASSIGNED
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dedicated her career to nurturing and training professional and amateur entertainers, Ms. Antin
now has been labeled by the Daily Mail as an abuser. Ms. Antin has received numerous emails and
messages from individuals across the globe containing statements of shame, scorn and hatred for
her supposed involvement in the abuse of Ms. Jones and other members of The Pussycat Dolls /
G.R.L. Furthermore, these messages of hate have not only been directed at Ms. Antin but at her
family. Since the publication of Ms. Jones' statements, Ms. Antin has been required to take
protective steps in order to shield her family from receiving the same negative message that are
directed towards her after several initial messages were unfortunately received by them.
56.

The publication of Ms. Jones' defamatory claims has also had an immeasurably

negative impact on the business reputation of The Pussycat Dolls. Shortly before Ms. Jones'
defamatory statements, The Pussycat Dolls had announced plans to reunite. One of the central
themes of the all women group is female empowerment. The Daily Mail's articles directly
impacted the groups reputation in this regard and in tum has caused incalculable damage to any
effort to reunite by the group.
57.

That the publications were reasonably susceptible of carrying the defamatory

meanings ascribed by this Complaint is underscored by the fact that these defamatory meanings
were precisely the meanings immediately ascribed to the publications by average readers, other
media outlets and commentators throughout the world.
PLAINTIFFS ARE PRIVATE FIGURES

58.

Plaintiffs are private figures, and as such need only plead and prove that the

defendant acted in negligent or grossly irresponsible manner. Plaintiffs, however, also alleges
actual malice by the Daily Mail. Ms. Antin as founder, manager, and choreographer worked
primarily behind the scenes and does not actively seek the attention of the media. The Pussycat

26
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
27 of 33
accepted for filing by the County Clerk.

 INDEX NO. UNASSIGNED

CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 05/21/2018

Dolls officially went on hiatus in 2010 and have not thrust themselves into the forefront of any
particular public controversy in order to influence its resolution.
59.

Ms. Jones' statements do not rise to the level of being a public controversy. The

outcome of the dispute between Ms. Jones, Ms. Antin and The Pussycat Dolls does not affect the
general public or some segment of the general public in a significant or appreciable way.
COUNT ONE
Defamation for Statements in The October 15, 2017
Online Edition of The Daily Mail Article

60.

Plaintiffs repeat and re-allege the allegations of paragraphs 1 through 59 above as

though set forth in full herein.
61.

The Defendants published or caused to be published false and defamatory

statements in their October 15, 2017 article, which did and had the tendency to expose Plaintiffs
to hatred, contempt, ridicule and/or disgrace.
62.

By such publication, the Defendants did cause harm to Plaintiffs' reputation.

63.

The defamatory statements in the Daily Mail articles are of and concerning Ms.

Antin and The Pussycat Dolls, and reasonably understood to be about Ms. Antin and The Pussycat
Dolls.
64.

The defamatory statements in the Daily Mail articles are false.

65.

The defamatory statements in the Daily Mail articles are not privileged.

66.

At the time of publication, the Defendants knew these statements were false, or

recklessly disregarded the truth of the statements. Alternatively, the Defendants had serious doubts
as to the truth of these statements and a high degree of awareness that they were probably false,
and therefore were required investigate their veracity before publishing them. The failure to do so
amounts to actual malice, and well beyond even gross negligence.
27
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
28 of 33
accepted for filing by the County Clerk.

 INDEX NO. UNASSIGNED

CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 05/21/2018

67.

The Defendants did not act with due consideration for the standards of information

gathering and dissemination ordinarily followed by responsible parties.
68.

The defamatory statements alleged herein concerning Ms. Antin are defamatory

per se because they accuse Ms. Antin of criminal and immoral conduct, describe her as unfit to
perform duties of her profession, foreseeably would harm Ms. Antin in her profession, and directly
implicated Ms. Antin in numerous illegal matters.
69.

The defamatory statements concerning The Pussycat Dolls and its members are

defamatory per se because they charge the group with criminal conduct, tend to injure the group
in their trade, business or profession and impute immoral and unchaste behavior.
70.

In light of Ms. Antin's standing in the community, the nature of the statements

made about her, the extent to which those statements were circulated, and the tendency of such
statements to injure someone such as Ms. Antin, the defamatory statements in the Daily Mail's
article has directly and proximately caused Ms. Antin to suffer significant damages, including loss
of income, damage to her reputation, humiliation, embarrassment, mental suffering, shame and
emotional distress. These damages are ongoing in nature and will continue to be suffered in the
future. Ms. Antin is therefore entitled to presumed damages in an amount to be determined at trial.
71.

As a direct and proximate result of the Defendants' conduct, the reputation of The

Pussycat Dolls and its members has been damaged and it has sustained and will continue to sustain
loss of potential income in amounts that will be established at trial. The false and defamatory
statements published by the Defendants concerning the professional and business reputation of
The Pussycat Dolls were made maliciously and with intent to destroy The Pussycat Dolls'
professional reputation. As a direct and proximate result of the aforementioned conduct, the

28
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
29 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

INDEX NO. UNASSIGNED
RECEIVED NYSCEF: 05/21/2018

reputation of The Pussycat Dolls has been damaged and it has sustained and will continue to sustain
loss of potential income in amounts that will be established at trial.
72.

The publication of the defamatory statements in the Daily Mail's articles, as well

as via the dissemination of the Daily Mail's articles through social media, caused Plaintiffs to
suffer additional damages, all of which were foreseeable to the Defendants.
73.

The Defendants published their articles with actual knowledge that stories attacking

Ms. Antin and The Pussycat Dolls would inflame passions, which drives viewership and online
viewing.
74.

The Defendants' actions were malicious, willful, and wanton, and evidence a

conscious disregard for Plaintiffs' rights. Accordingly, punitive damages are appropriate.
75.

As a direct and proximate result of the Defendants' misconduct, Plaintiffs are

entitled to compensatory, special and punitive damages in an amount to be proven at trial.
COUNT TWO
Defamation for Statements in The October 17, 2017
Online Edition of The Daily Mail Article

76.

Plaintiffs repeat and re-allege the allegations of paragraphs 1 through 75 above as

though set forth in full herein.
77.

The Defendants published or caused to be published false and defamatory

statements in their October 17, 2017 article, which did and had the tendency to expose Plaintiffs
to hatred, contempt, ridicule and/or disgrace.
78.

By such publication, the Defendants did cause harm to Plaintiffs' reputation.

79.

The defamatory statements in the Daily Mail article are of and concerning Ms.

Antin and The Pussycat Dolls, and reasonably understood to be about Ms. Antin and The Pussycat
Dolls.

29
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
30 of 33
accepted for filing by the County Clerk.

 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.)

NYSCEF DOC. NO. 1

INDEX NO. UNASSIGNED
RECEIVED NYSCEF: 05/21/2018

80.

The defamatory statements alleged herein are false.

81.

The defamatory statements alleged herein are not privileged.

82.

At the time of publication, the Defendants knew these statements were false, or

recklessly disregarded the truth of the statements. Alternatively, the Defendants had serious doubts
as to the truth of these statements and a high degree of awareness that they were probably false,
and therefore were required investigate their veracity before publishing them. The Defendants'
failure to do so amounts to actual malice.
83.

The publication of these false statements without any proper investigation was

malicious and well beyond grossly negligent and showed a reckless disregard for the truth.
84.

The Defendants did not act with due consideration for the standards of information

gathering and dissemination ordinarily followed by responsible parties.
85.

The Defendants' statements concerning Ms. Antin are defamatory per se because

they accuse Ms. Antin of criminal and immoral conduct, describe her as unfit to perform duties of
her profession, foreseeably would harm Ms. Antin in her profession, and directly implicated Ms.
Antin in numerous illegal matters. In light of Ms. Antin's standing in the community, the nature
of the statements made about her, the extent to which those statements were circulated, and the
tendency of such statements to injure someone such as Ms. Antin, the defamatory statements in
the articles have directly and proximately caused Ms. Antin to suffer significant damages,
including loss of income, damage to her reputation, humiliation, embarrassment, mental suffering,
shame and emotional distress. These damages are ongoing in nature and will continue to be
suffered in the future. Ms. Antin is therefore entitled to presumed damages in an amount to be
determined at trial.

30
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
31 of 33
accepted for filing by the County Clerk.

 INDEX NO. UNASSIGNED

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NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 05/21/2018

86.

The aforementioned defamatory statements concerning The Pussycat Dolls and its

members are defamatory per se because they charge the group with criminal conduct, tend to injure
the group in their trade, business or profession and impute immoral and unchaste behavior. The
false and defamatory statements published by the Defendants concerning the professional and
business reputation of The Pussycat Dolls were made maliciously and with intent to destroy The
Pussycat Dolls' professional reputation. As a direct and proximate result of the Defendants'
conduct, the reputation of The Pussycat Dolls has been damaged and it has sustained and will
continue to sustain loss of potential income in amounts that will be established at trial.
87.

The publication of the defamatory statements in the Daily Mail's article, as well as

via the dissemination of the Daily Mail's article through social media, caused Plaintiffs to suffer
additional damages, all of which were foreseeable to the Defendants.
88.

The Defendants published their article with actual knowledge that stories attacking

Ms. Antin and The Pussycat Dolls would inflame passions, which drives viewership and online
v1ewmg.
89.

The Defendants' actions were malicious, willful, and wanton, and evidence a

conscious disregard for Plaintiffs' rights. Accordingly, punitive damages are appropriate.
90.

As a direct and proximate result of the Defendants' misconduct, Plaintiffs are

entitled to compensatory, special and punitive damages in an amount to be proven at trial.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs prays for judgment against the Defendants and for the following relief:
1.

An award of compensatory damages, including both general and special damages

according to proof at the time of trial;
2.

An award of punitive damages according to proof at the time of trial;

31
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
32 of 33
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 INDEX NO. UNASSIGNED

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NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 05/21/2018

3.

An award of Plaintiffs' cost associated with this action, including but not limited

attorneys' fees and such other relief as the Court deems just and necessary.

Dated: May 21, 2018

Respectfully submitted,

z;;LOW
5,!3wJ,,

. .

Richard S. Busch (3985884)
1999 A venue of the Stars, Suite 1100
Century City, CA 90067
Tel: (424) 253-1255
Fax: (888) 688-0482
rbusch@kingballow.com

Elliot Schnapp (12409 4
Gordon Gordon & Schnapp, P.C.
30 Broad Street, 21st floor
New York, New York 10004
Tel: 212-355-3200
Fax: 212-355-3292
elliot.schnapp@ggslawfirm.com

Attorneys for Plaintiffs

32
This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
33 of 33
accepted for filing by the County Clerk.