CHRIS DERDSE Clerli of the Superior Smurf By Jessica Remain Deputy Date 10/12/2019 Tim! 12:30:22 Description MUM Harrison, Pro Per :53 Arlene, Pm -- mm mm 2694"; Jeremy Brunaugh. Pm Per Russell Jaffe, Pm Per Arizona Superinr Conn Murieope County Jennirer Harrison, Lesa Antone, Russell lerre, Case Numbcr: Jeremy Brunaugh (Individuals) CV20 1 ., 6 5 2 3 Plaintiffs, COMPLAINT vs Katie Hobbs (indivlduai) Defendanl Plaintiffs Jennifer Harrison ("Harrison"), Lesa Antone ("Anlone"), Russell Jzfie ("Jame") and leremy anaugh ("Bronaugh") hereby complain and fol causes ofactinn allege as fo|lnws l. PlaimiiTs are individuals and are new, and at all limes menlioned in ihis complaint, residenis orMancopu County, Arizona. 2. Plaimifi's are individual, private citizens and constituents ofMaricopa Counly, Arizona. PlainliffHamson resldes in Peoria. Arizona and works as a real estate agent. PlaintiffAnlone resides in Lilchficid Park, Arizona and is relired. PlainliiTanaugh lives in Goodyear, Arizona and is self--employed. Pleiniimelie resides in Litchfield Park. Arizona and works in me heallhcarc profession. Plaintiffs have in are past enjoyed a good simiwwnm reputation, both generally and in their profession, specifically Harrison in the real estate profession and Jaffe in the healthcare profession. . Defendant Katie Hobbs (?Hobbs?) is an individual, and is now and at all times mentioned in this complaint a resident of Maricopa County, Arizona. Hobbs is a married woman. . Defendant Hobbs was the former ?Senate Minority Leader? for the Arizona State Senate while committing the offense listed in this complaint and is the current candidate for Secretary of State in the State of Arizona. . On April 29, 2018, defendant Hobbs maliciously tweeted a photo of the Plaintiffs, while representing herself as the Senate Minority Leader for the Arizona State Senate, on Twitter. Pictured in the photograph was Plaintiflc Harrison, Harrison?s spouse, Plaintiff Antone, Plaintiff Bronangh, Plaintiff Jaffe and and Governor Doug Ducey while Plainti?'s were attending the ?Mohave County Republican Committee?s Patriot Dinner? in Mohave County, Arizona. While candidly posed for the photograph, Plaintiff Antone made an hand gesture in the group photograph. Defendant Hobbs did not attend this event and it is unknown to the Plaintiffs how Hobbs obtained this photo. Defendant Hobbs posted the Plaintiff?s photo on her public Twitter, while representing herself as the Senate Minority Leader of the Arizona State Senate, and captioned the photo of the Plaintiffs as follows: ?Governor Darcey, i hope yon realize this woman is flashing a white snprernacist sign. These are part of the gronp that shows up at the Capitol w/ Ale-15?s and harass elementary school children and democratic staff, calling thorn illegals. You most denounce?. . Defendant Hobbs maliciously and intentionally published a false, libelous statement about Plaintiffs, knowing the statement was false or acted reckless disregard for the truth as a public ?gure. As the State Senate Minority Leader, Hobbs has an implied perceived credibility in the community and this comes with the responsibility to act in good faith towards honest discourse on all platforms. Instead, Defendant Hobbs acted recklessly in using social media to make intentional, libelous, defamatory comments about the Plaintiffs, whom are private citizens, in an attempt to smear Governor Ducey and advance Defendant Hobbs? political agenda. Defendant Hobbs wanted to portray to her social media audience that Governor Ducey was posing with ?white supremacists?. This is precisely the false story that Defendant Hobbs implied to her audience and to the media when she stated ?This woman is ?ashing a white supremacist sign?. Swami stoma who c?w?l?ia" [cum ID :?i?hmiWnMM-WW} 10. 12. I3. The defamatory truest referred to the Plaintiffs; included the Plaintiff" photograph; was made of and concerning Plaintiffs; and was so understood by those who read the tweeted statement and photo. The false statement and photo was then retweeted 245 more times by 245 separate individuals making the false statement and photo go viral. . Defendant Hobbs tagged and noti?ed Arizona Republic/AZ Central reporter, Richard Ruelas (@Ruelaswritings) in the defamatory tweet, sequentially causing Plaintiffs photo with false ?white supremacy? story to be published in articles and aired over all local television news channels for two days in Arizona. Plaintiff?s photo and false white supremacy story was on the front page of the Arizona Republic newspaper, distributed throughout the comm unity. The entire statement that ?Plainti??s were flashing a white supremacist hand gesture; that Plaintiffs showed up at the Capitol with weaponry; that Plaintiffs harassed elementary school children and that Plaintiffs called democratic staff illegals? is false as it pertains to the Plaintiffs. The tweet is libelous on its face. It clearly exposes Plaintiffs to hatred, contempt, ridicule, loss of business, termination of employment, death threats and obloquy because Plaintiffs are not white supremacists, nor is the AOK hand gesture any type of secret white supremacy hand gesture. The Plaintiffs have not carried 1 5 weaponry to the Arizona Capitol. The Plaintiffs have never harassed elementary school children and the Plaintiffs have not called democratic staff illegal. . The libelous statement made by Defendant Hobbs, including the Plaintiff?s photograph, was seen and read on or about April 29, 2018 by hundreds of thousands of Arizona residents on social media, print and on local television news. With the ongoing Arizona State elections, the photo and false statements are still circulating in further attempts to smear Governor Ducey during his re?election for Governor, exposing Plaintiffs to further ridicule. As a direct result of Defendant Hobbs publishing such false statements on social media and the slanderous story going viral, the angry readers of this ?ctitious story published Plaintiff?s personal and business information online, exposing their home addresses and places of employment trying to ?expose the white supremacists? - as Hobbs has made them believe. As a proximate result of the above described publication, Plaintiff Harrison has suffered termination and loss of employment, damage to reputation, defamation of character, ammo-p Elysian mug nameless? [Seam ID: 14. emotional distress, anxiety and fear, humiliation, shame, modification, threats to personal and family safety and ?nancial loss. Plaintiff Harrison received numerous harassing calls and messages to her broker, stating that Harrison is a ?white supremacist?. Harrison?s broker asked her to leave the brokerage as a direct result of the bad publicity and ongoing phone calls and messages to the brokerage. Harrison incurred loss of wages and was forced tojoin another brokerage, incurring more marketing costs with new brokerage information on materials pertinent to Harrison?s profession. As a proximate result of the above described publication, Plaintiff Antone?s personal home address was published online and Antone was forced to install a home security system due to strangers knocking On her door and death threats to her family, calling Antone a white supremacist. Plaintiff Antone has suffered damage to reputation, defamation ofcharacter, emotional distress, anxiety and fear, humiliation, shame, mortification, threats to personal and family safety. As a proximate result of the above described publication, Plaintiff .iaffe has suffered damage to reputation, defamation of character, emotional distress, anxiety and fear, humiliation, shame, mortification, threats to personal and family safety. Plaintiff Jaife was ridiculed at work, reprimanded by his employer and his position in the company was threatened and hangs in jeopardy. As a proximate result of the above described publication, Plaintiff Bronaugh has suffered loss of employment, damage to reputation, defamation of character, emotional distress, anxiety and fear, humiliation, shame, modification, threats to personal and family safety. Plaintiff Bronaugh was a member of a sports syndicate affiliated with the Arizona Cardinals Football Team called ?The Bird Gang? and was asked to step away from the organization when his photo was aired on local news and he was slandered as a ?white supremacist?. The Plaintiffs ask the court for $20,000.00 in compensatory damages. The above described publication was not privileged because it was published by Defendant Hobbs with malice, hatred, ill will and the desire to injure Plaintiffs by smearing the Governor to advance a political agenda by swaying public Opinion of the Governor's recent political policy. Because of Defendant Hobbs? malice in publishing and requesting AZCentral/AZ Republic to publish, Plaintiffs seek punitive damages in the total amount of $20,000.00, or a total amount to be established by the court. Libel: the written or published communication of a false assertion of fact to a third-party, which subsequently results in harm or damage to another?s reputation. A statement that brings a plaintiff into disrepute, contempt, or ridicule, or impeaches a Plaintiff?s honesty, integrity, virtue or reputation. Muddy Sigurd ma?m?r?m?? Seulzm Whether a statement is considered defamatory or not is determined by the ?natural and probable effect a reading of the entire statement, in context, would have on the mind of the average reader?. Four elements of defamation under Arizona State Law: 1. Defendant made, said or wrote a. false statement of fact; 2. Statement was communicated to a third party; 3. Statement caused material harm to Plaintiffs; 4. At the time the statement was made, the Defendant knew the statement was false or acted in reckless disregard for the truth and/or was negligent in determining the truth Plaintiffs demand judgment against Defendant for: 1. Compensatory damages: 2. Punitive damages; 3. Interest allowed by law; 4. Cost of suit and 5. Such other and further relief as this court may deem just and proper. Dated: 10/1 1/2018 Plaintiff Jennifer Harrison Dated: 10/ 1 1/201 8 Plaintiff Lesa Antone {seen @Wr?m Dated: 10/1 1/2018 Plaintiff Jeremy Bronaugh Dated: 10/11/2018 Plaintiff Russell Jaffe . Enctrankal?y Signed wing stamina? [5mm ID Tweet your reply