- . . 16'} (?18 521.2 - 11 12 I 13fCase Document 1 Filed 01/15/19 Page 1 Of 20" . CRISTINA BALAN (Pro Se) - - 4698 ?Arbors Circle :Mukilteo, WA-98275 . - . Jm 425-205-0200 ?lm 'cbalan.i2019@m ail,-com M?mm UNITED STATES DISTRICT COURT - DISTRICT OF WASHINGTON CRISTINA BALANCOMPLAINT FOR ?mum?, DEFAMATION . AND-REQUEST FOR INIUNCTION TESLA MOTORS INC, DEMAND FOR JURY . . 17 . . COMPLAINT AND REQUEST FOR INIONCTION - 1 JAN 15 2019 SP CASE 9 0 00 Complaint ?lOd: January 15, 2019 - ii :12; 13. 14". 16 1.7" 1s 19 "21 Case . Document 1 Filed 01/15/19 Page? 2 of 20 Plaintiff, Cristina Balan, ?les this Complaint for Defamatien against Defer-remit Tesla Motors Inc., as presented here. I 1. INTRODUCTION . Plaintiff, Cristina "Balan, is a well-respected, business P3130112 I. I I I spe?i?lizing in design and-engineering, based in Mukiteo, WA. Tesla is a corperaticn based in Palo Alto California, knan worldwide for two general ?preduet types, Electrical Vehicles and clean energy products.. 2. Mrs. Balan 1s most recognized for her critical work on Tesla's 'rvehieles, as InemoriaIiZed by her- engraved name on Tesla vehicle battery tame, I Where her work was heavily-focused for during her work at Tesla from 2919 to . 7 . .2014 In fact, Tesla stated recently is still uses methodolegies Ms. Balan created to I date. Ms Balsa invested many years in her education, professional experience,? relationships, and repntatien Tesla willfully, and repeatedly, that; Steps to publicly defame Ms Balan, and speci?cally, devalue these lifetime investments. 3. . On September 2.017, the Pest published an article about Mrs. Balan?s career, also referencing her relaticnShip with Defendant. This article appeared to describe Balsa and her circumstance 111 a positive light. She holds that the original statements were true, I . OnSeptember 1rth 2017, Defendant published multiplefalseand defamatory statements on the Hui?ngton Post, settling the score with the Plainti??, after the article questioned to Tesla?s CEO comminnents and rules. Defendant COMPLAINT AND REQUEST FOR INIUNCTION - 2 110 11 ?1221": Case DoCumentl Filed 01/15/19 Page 3,0f 20 stated clearly, 111 a rm intended for worldwide and instant dish-mutton, that Ms. Balan? acts were clearly criminal".- - S. Some of the acts Balan Was accused of included theft of company . money mdmsources, for aprojectthatvalue more than $10, 000. Mrs. Balmwas laceused of using the company 5 resources, without management approval. Defenders then claimed this was an attempt to complete a persona project Balsa developed on her own. 6 Ms. Balan maintained an adversarial legal relatiomhip with Tesla for i the past 4 years, beginning an arbitration over a former employment relationship 7 that ended in 2014 - While engaged in this: adversarial legal relationship, the I .1 Defendant published multiple false and defamatory statements about Mrs. Balm, in an unlawful and malicious fashion. 7. Plaintiff and Arbitrator Warner are in this case, and have bean eflhe .samenimdmatMs Balan? these felonious activities ever took place, including the trip to New York. 4 8. 7 Defendant was unable to produce any "records or credit card charges, plane tickets, meals, Cars, of the claims they made, and that Tesla her of travelling to New York 111 Nov 2013, a place that to this day, Mrs. Balm has never been. Regardless, Defendant did ?not take any action to resolve the matter. 9. Balan has attempted diligently to convince Defendant to remove the .- false and defamatory statements from the interact. Plainti??s fornim' attorney . . 1'0 "1118'- . ?19 Should be enjoined from destroying any evidence relevantto Ms. Balan? a claims .. 20.? . CaSe Document 1 Filed 01/15/19 Page 4 of 20 requested the removal during the arbitration. Tesla refused. In September 20*, [20.13 mamas commence a demand to remove the false statements; Tesla - oontactedB?arionOctober 2018,01aimingto conferingoodfaith. These conversations did not lead to resolution, and the false shims remained. I. 10. It Was not until a friend ost Balan? sent a letter directly to Huf?ngton Post, that Hu?'mgton Post?s counsel, got involved This comment from . - Tesla, seeming Balan of clearly felonious behavior, remained on the internet until-c 7 approximately Deemnbet 20m, 2018,3pproximate1y 15 moaths. To date, Tesla has - - taken no action to mitigate the damages caused by these acts. Post showed "a sign of. good faith, by removing the note almost immediately after receiving notice of Arbitrator Warner?s conclusions, but they also removed the entire article Without any redaCtion._ .e Plaintiff brings this action to enjoin Defendant,- Tesla, ?om further damaging Ms Balan. Tesla acted' in malice, abusing both their public in?uence, and the relationship with Balsa as a litigant Tesla should be enjoined from communicating false and defamatory statements about Ms Balan. Tesla has exhibited a willingness to destroy and or conceal evidence as referenced herein through exhibits illustrating behavior during arbitration. Tesla and enjoined-friars failing to preserve the same ammo REQUEST FOR antibiotics 4 she had multiple tv shows and was part of dozens of articles internationally. . - Including how to be a woman in automotive; Plaintiff currently owns and operates. - . .a Design Hesse business called Tesseract Motors LLC in Washington state. . 14 I "The-Defendant .15' I :16 Rd, Pam-Alto California that produces electrical vehicles and solarpanel . 19 . 2.0 2-1 Case Documentl Filed 01/15/19 PageSbf 20 11;? THE-PARTIESTOTHISCOMPLAINTV1- Plaintiff: 12. Plaintif?CristinaBalan, "Balan", Butane, is awell? respected, business person, specializing in engineering, withaI degree from University of Ms. Balan is most recognized. fer her critical Work on Tesle?s vehicle batteries, resulting in Tesla Awarding her by engraving her name hits) the battery modules. Her methodologies are still used in Tesla. - l3. MsBalan is also a public speaker, because of her career echieirements - in automotive industry she was even invited to host a TEDX Talk in automotive; 14. Defendant, Tesla Inc., "Tesla", is a eorporatien ?om Creek 17. systeins. Its reported mission is try-accelerate the worlds transition to clean and sustainable energy I 15. . Defendant is led by CEO Elon Musk. As M2013, Meek was reported to have a net worth of $20.2 Billion and is listed by Ferbes as the 46th- COWLAM AND REQUEST FOR mmcnoN - 5 10 is 7 - 13 '14 15. (17' '18 .19. it 20-? 21.1 11 A :Case Document 1 Filed 01/15/19' Page 6'of 20 . I richest person in the world. In Dwainber ef2016, Musk was ranked let on the Forbes List of the Most Pewer?? People. At all times relevant to this I action, Musk manttained a known public following thmugh Twitter, 3. leading soci31 network, cf over 21 million followers. JURISDICTION-AND VENUE 16.- This Court has diversity jurisdiction pursuant to 28' U. S. C. I 1332(a)(2) ever this defamation. Ms. Balan IS a resident of The State of - ?Washington, living in Mukitee since 2014, being a grew card resident ofthe United States 17. i Defendant, Tesla Inc., is a corporate citizen of Califernia, add: its principle place of business, in Palo Alto California. . 18. Defendant Can be served with summons and complaint at it's I headquarters in California, or through its Agent of Serve, registered with the State of Secretary of State. '16 1' l9 Ms. BalanandTeslaare citizens ofdi??erent states, andthemattertn .centreversy is exceeds the sum or value of $75, 000 .00 exclusive of nearest and costs Plainti??estimates actualdamages Tesla?s maliciously acted towards her. 20. This Ceurt has jurisdiction of this civil action pursuant to 28 S. C. 1332.As the direct and proximate result of Tesla defamatory accusations, Ms. comm AND REQUEST FOR INJUNCTION - 6 10 "n I 12 .I 13.' - 1.5 .. 1.4 '16; 19' 20- 2'1 13 Case Document 1 Filed 01/15/19. Page 7 of 20 . Benn su?'ereddamage to her reputation in Washington, andCalifomianational and international basis. The were nerbalized and Written, in the State hf . California, and published and republished to all of the United States, and internationally 22. As one of the largest, and most publicized auto makers the meet powerful and publicized people on earth', Tesla knew that the . . false aeousntione Would he centeyed to a worldwide and personally I .. audience 232. In this notion, Ms Balan seeks a recovery for the worldwide damage I that she has suffered to her reputation - 2244. 1 This court has both general and specific jurisdiction over- Tesla. 25. Venue is proper in this Court, pursuant to 28' 1391(2))(1): . IV. FACTUAL BACKGROUND A. Harrington Post Article about .Ms Balan 26. On September 83?, 2017, the Huf?ngton Post reporter approached Ms. I Balan and asked her to interview her about her career, but also why her relationship with Defendant ended. This article appeared to describe Mrs. Bninn and her? circumstance in a positive light. She holds that the original statements - i I A. This was not-Ms. Balan ?rst US'artiele, WSJ Was he ?rSt . f7 00W AND REQUEST-FOR MUNCTION 7 .: 13:.reporters Where stopped to ask the question if Elon Musk resolved or not his Bolas . 15' - . I emails and serious evidence, (:0nt safety, quality and management W5 . 16 19. '20 I21 10' 11' 12. 1-3, Case Docu'mentl Filed 01/15/19 Page8-of 20 I 27. Dining her-interview Ms Balao told her story of what happened after with serious consents, to Defendant?s CEO email sent in 2013 called ?communication Within Tesla? which be explicit details what will happen if - someone from Tesla Will force thechain of commands; ?Instead of a problem getting sol-lied quickly, where a personin onedept . talks to a; person in- another dept and: makes the right thing happm, people- are forcedto talk to their manager who talksto their manager who talks to the manager in the other dept who talks to someone on his team Then the "info has to flow back the other way again. This l8 incredibly dumb Any manager who allows this to happen let alone encourages it, will soon . ?nd- themselves working at another company No kidding.? ?Anyone at Tesla can and should emailltalk to anyone else according to what they think' Is the fastest way to solve a problem for the bene?t of the Whole company. You men talk to your manager's manager without his - permission, you can talk directly to a VP In another dept you oon- talk to - me, you can talk to anyone without anyone also 8 permission. Moreover you should consider yourself obligated to do so until the right thing happens. A full and true copy of the email is attached in EXHIBIT B. 28.? - The reporter Paul-Alexander, was shocked to hear how many other from an entire team, not just Ms Balan and concluded his article by saying: 1.7 - ?Part of her claim ls that she wastired for doing precisely what Musk ordered his employees to do in his now-famous email -- come to him with information and snows about Tesla. When she did, Musk was not only ohmhonsive but one was ?red. No kidding. A full and use copy ofthe article is attached in EXHIBIT A 3 CW AND REQUEST FOR mmonon - '10 11 '13" .14.. - 15 1'7H'j?wa1rants arespense?. .19 '20 [21 12' 16-. 18: 2 .. ?Case Document 1 Filed 01/15/19 Page-9 of 20 .. B. Tesla?s Defamatary Statements Added to He?ngtan Past ar?cle led a reply to Hu?'ntgten Post?s article, stating multiple false and defanImg claims Ma 29 InreastimtOnSeptember11?h 2017, Defendant natal-1. speci?cally, Defendant stated 1n the EXHIBIT A 39 .3 ?Ms Balan spent company time working en a ?secret project withoet her managers approval an .31.. ?booked an mapproved trip to New Yerk at Tesla? expense to visit a I potential supplier for her own personally-created project i 32; ?Ms Balen was unhappy with a particular supp1ier thet was selected by an internal group of subject matter experts who extensively studied the issue 3 She teak it upon herself to ?nd an alternative supplier that had no prior selevnnt . expenenee? 33 ?She also illegally recorded hiternal conversations within Tesla anyone? 5 penmssion, Which 1s slearly criminal sentient? 34. Tesla continue by saying that ?particularly emails that are not relevant to on: mission or the job at hand or are clearly suspect or nnsleading? dentist 35.?sontra1yto Ms Balan? 5 claims, despite her own iniseonduet, she was I 'neyer- ?red from Tesla. She voluntarily resigned- not just once, but an multiple occasions.? comment-1n REQUEST Foe . 9 10' 711 "12' 13' 14' '15 ?.17 18' 15' i 19* It Case Documentl Filed 01/15/19 Page '10 of 20 36 ?Ms. Balan left Tesla the ?rst time because we had preVioHSly pmvided her with a special 10-month living stipend as an accommodation to help . her with family issues, and she wanted that stipend to be extended even ?n?rer. When we did not extend it, she qui ?Also contrary to her claims, she never once I informed the company she had any kind of sigr??cant tnedieal problem prior to her resignation? 3.7. Tesla in their maneuvers to. convince everyone how eerreet?ley are in holding the absolute truth, they say Anyone in engineering, legal, executive, ntedical, and any other ?elds, that ?Anyone looking objectively at Ms. Balan?s. theeries Can see that they are patently false, and frankly, completely nonsensical an see that Balan?s theories are ?f?patently false, and frankly, completely nonsensical.? I I I . C. Balan?s Claims and Factual Background . I .. 38 - Combined with everything that was said from Paragraph 1 ?ne 37 Ma. Balsn States the following 39 Ms Balsa Never" spent company time working 011 a ?secret project? without her manager? 5 approval? Ms Balan project was approved by the highest level at Tesla after Elon Musk, Doug Field. Rich Holey the VP of Product Excellence was involved along with other 3 directors, quite a-few managers and technicians Mr Holey eonfmned as the EXHIBIT shows: I . '10? - . :11 1'4 .16- .- 17?. 19' 21 .il 15. and planning for schedule a trip, with approval, but canceled after. 18 II was asked to look into by her own .direet director Eric Bach. When she come? up. Case Documentl Filed 01/15/19 Page 11 0120 ?Cristina I had a conversation with Doug Field tonight and he IS still interested exploring the visor concept? Ms Balsa also had the Financial approval as well, as seen on I EXHIBIT D- the purchase order signed and ordered by Doug Field ashad about the project he said: ?This one is no?brainer: let?s spend the money. It might be to late for but this could be a big feature on future vehicles?. Doug Field and an entire team of high-level executives.?_ support Ms B- Balan In her patent idea EXHIBIT think this IS a really important technolon for Tesla. still . obsessed with the idea of eliminating traditional swarm with technology? . 40. .. Ms._ Balan Never been to New York in herlife, business or pleasure. Tesla could neverproduce any evidence of the expenses they claim they paid. or I booking for any ?unapproved trip to New York at Tesla's?. It was a discussion 41. Ms Balan patent idea was Not for her" own pemona?y?areamd protest" Was for a feature that could help Tesla products, not her personally Idea that she with an even more amazing idea, she was told by her direct manager at the time that a woman 5 brain will never be about to do a project or a patent like this; luckily not ererycme at Tesla felt the same way; -- CWTANDREQUESTFOR ll . 710 117 '12 - 13 . '14 1-15 '16 17 13- ?201 '21. case Documentl Filed 01/15/19 Page12 of 20 -. - =42. Ms B31311 was not ?mshappy with a particular 31111131131? she was . 1111113ppy to lie 311d c111 the quality for any supplier as she was 35ka to 43. Ms Balsa Never ?took it upon herself to ?nd an ali3m3'tiee supplier that hadhep?orreelevantemenenee? evidences for. 44; 011 one-point Ms 331311 assistant manager let her know what projects are eeming downthepipe. As the EXHIBIT will show A week latershewas 11111011113311 for the ?n time to the supplier Tesla IS accusing Ms Balsa 3f mking 7 1111011 herself to ?nd them and present herself and the project she was working 03, 73313311313113 45. Ms Balsa disagree with the fact she sent ?particuiarly emails that are not relevant to our mission. or the job at hand or are clearly suspect or misleadim? does not We a response?; When people are threated because 111w rise quality .1 er safety isms, 'when theyworriedthat they will be deported ifthey trytode- -- 1' what?s right and We are talkingas-aii entire team,Ms Balsa strongly believes it is ?warrant 3 13313311313? those emails and cVidence contain criminal behairior! -46. . MS B31311 never did anythingcrimmal At iseristhestatement Tesla - mark that Ms. Balan' 3 11311311131, was clearly criminal. ?She also illegally recorded internal conversatiohs Withiri Tesla without anyone? a permission which is clearly criminal 331161161." 11011 1131311011011- 12 I 3:10. 11 - r12 13' 14- 4715 . i 19. 1 21' 16 7' Case Document 1 Filed 01/15/19 Page 13 of 2-0 . ?47. Ms. Balsa was not charged with acriminal action. I . 48. A criminal conviction for the act Tesla accused Ms. Balan of, would I require 8 much greater Showingof evidence, namely, proof beyond a reasonable. .7 ?doubt to a more] certainty, IfTesla felt Ms. Balsa had broken the law, and damaged Tesla, it iconld have pursued criminal and or civil action through the appropriate channels I i_ available when Ms Balan presented the evidence of serious acts inside Tesla. The .1 only thinng. Balan wantedwas to show her CEO what Was going on. Tesla did not pursue civil action, nor was criminal action brought swat- Ms Balan. Tesla knew the statute of limitations, which would have arisen if their accuSation were . true, has ma out. I I I I I 50. Consequently,Tesla's right as a US. citizen to haveany'court of competent jurisdiction rule on the matter-?3 merits, and to stake its claim to that ruhng, has also been extinguished through waiver. . I 51 Tesla did not state its opmion was that Balan' behavior was 52. Tesla statedthat Balan's behavior was 'clearly-criminal'. Tesla intended this claim to represent their conclusions, and to Cause others to arrive at I the me conclusion. In short, Tesla claim of criminal behavior could not at the tithe, have been less ?Clear' At the time Tesla admitted they warned Ms Bali-mi to I 5 destroy the comm an]: REQUEST son INJUNCTION - 13 '16WA11thewerkwas giving backtoMs. BalanlikehdthinghmeMTwo - 17? .18 . 19'. 21 Case Document 1 Filed 01/15/19 Page 14 or 20 53. Ms Balsa net/er "She. voluntarily resigned - not just once but on mum headstone. She was forced out after opening an internal investigatien which Tesla . 1 . I Never ?investigated extensively?, if not other colleagues of Ms Balsa will be ?red and deported. Ms Balsa was petri?ed and then sent her resignation. 54. Ms. Balan did not ?left Tesla the ?rst time? because the ?living stipend? was not ?extended even timber?.- It was because she teldTesla they are - treating the law, as. she was miselaSSi?ed. Ms Bialan we the masses-eaten. IF Tesla wenld have not breakmg the law and paid accordineg Ms. Balan; . there net have been two resignation discussions. 55. Ms Balan disagree on the statements ?Also centrary to her claims, she? to her resignation? . Net Formally, but Tesla knew thru an internal pm'ty that Ms. Balsa was part 021?, the fact Ms. Balsa-will ?nd out in 5 days if the multiple-111111015 she just found out] she has on her breasts could be cancer. This happened two days . after Ms. Balan agreed to retract her resignation for miselassi?catien and Tesla days after the Cancer nears, Tesla ?ehange their min and told 115$.an 15 her last day. 56 Later Ms. Balan reqmsted all the emails of her last week, but Tesla legal eemseler testi?ed that the entire cempany, everyone, lost 3 weeks of emails, . bet on one-point jnst? some emaiIS? from the ?glite period ?0er AND REQeasr son 11111111011011 - 14 10 11- '12 14 15 are ..17 i . 21 13- .. 20'. - Case Documenti Filed 01/15/19 Page 15 of 20 Tesla? IT expert could not explain how that happened.- 57. . A few months later Tesla approached Ms Balsa and asked her about her health Sbe responded she 13 Men, and her tumors are not cancer; soon a?er 5- Tesla asked Balan to return to Tesla, but with the conditions to forget what I happened 3-4 months before, between her and Tesla related to cancer Balsa agree hacked by clear evidence and she strongly disagree that ?they are patently false, - and frankly, completely nonsensical? . 59. Ms. Balan took multiple steps to attempt to mitigate her damages ?Ms Balsa obstructed her attorney to take reasonable action to remedy the Illegal act He stated that he had called Tesla, but the reply was not be removed. - 60 Mr. Balsa attorney prepared a statement to sand 8 comment to Burlington Post to remove the comment or post a reply; She did what she was instructed. Humugtbu Poet did nothing; bay refuse to publish Ms Balm commentlast result until the current litigation Will close and Ms Balsa Wrote" on her blog what She thought was Imtrue in Teslais now. Mr; Balsa my main her an renal is very malicious and should stop updating her blog for now. 625 Ms Balsa laWyer asked her to focus on ?nalized her current low] case 3 if - with Tesla at that time before opening the Defamation lawsuit", but that changed COW AND REQUEST FOR WCTION- 15 58. Ms. Balan?s claims are not theories are facts not only objective but are I - I I 10 11_- 131 14 15Case Document 1 Filed 01/15/19 Page 16 of 20 -1 after Tesla?s CEO Elon Musk, stated publicly on August 2018 that his and automatically his company legal position is that if a person publishes statements - about you that damage you, and you don't sue the person who is the source of the statements, they must be true. Mr. Musk?s total followers worldwide on Twitter, currently sits at approximately 22.5 million followers. 63. All of "the false and defamatory accusations by Tesla against Balan, . were published without privilege and with actual knowledge of falsity, or with a reckless disregard for truth or falsity. 64. At the time when Tesla made the defamatory statements Tesla knew Ms. Balan was suffe?ng from PTSD from the way Tesla threated her to destroy her evidences and for her ?nals moment at Tesla and knewing that Tesla still made those defamatory statements 65. On Sect 20, 2018 Ms. Balan' Sent 3 letter of intent and: email to Tesla?s CEO Elon Musk. EXHIBIT and 66. In the end of October Tesla?s counselor contacted Ms Balan to discuss - her demands. The most critical one was for Tesla to remove its note. 67. Instead of retracting its false accusations, and ceasing its of litigant abuse, the defendant didn?t take any action to insure the defaming comments were retracted and stop been publicized worldwide, mdsdensely within i audiences of Ms. Balan's professional ?eld. - 16 10 :1'1 ?-12 13 .14? - .16. .. :17 18- 19: 2t Case Document 1 Filed 01/15/19 Page 17 of 20 v. CAUSE or ACTION FOR DEFAMATION . Ms Balsa reasserts and incorporates by reference paragraph 1 - 67 of this complaint, i 69-. Tesla?s publications in: Exhibit A, as referenced inparagraphs 29, 30, 31; '32, 3'3, 34, 35, 36, 37 are hereinafter referred to as the "Falseand Defamatory Accusations." 170.1 The United States has passed multiple civil and criminal pieces of i 3 legislation, to proteCt both small, medium, and large basinesses, heed-the types of . illegal activity Tesla accused Balan of. Tesla's False and Defamatory-Accusations. falsely accused Balan of Spending company money without approval. (2) . Booking an unapproved trip to New York. (3) Producing a secret project for Tesla-'5 Windshields, at Tesla's expense, withOut their howledge, and fer Balan?s- personal gain. (4) Installed said windshield in Tesla's vehicle, without the company's knowledge or approval. (5) Performed acts Which were clearly criminal 1. I 71d . Balan did not "spend company money without proper approval. . 72. Balan did not book an unapproved trip to New York I . I 73. - 'Balan did not produce a secret project for Tesla?sears at Tesla's I unapproved expense Without their howledge, and for her personal interests 74. Balan did not install a windshield in reelelevehieleo) without the company's knoWledge or approval. 75. Helen did not perform acts Which were clearly criminal COMPLAINT AND REQUEST FOR INJUNCTION 17 10 11 '12 p13. [14? 15- :316 7.17 18 I 19'. 20- - 21 Case Document 1 Filed 01/15/19 Page 18 of 20 .76. The False and Defamatory Accusatious were published Without I privilege and were published With actual malice. 77. - Some of The False and Defamatory Accusations are defamatory per se, and damages to Ms. Balan are presumed as a matter of 111W. 1.178. The False and Defamatory Accusations are libelous on weir face 111 that they are defamatory of Ms. Balan without necessity of explanatory matter or - 1 other extr-inSic facts, and/or they impute to Balan criminal conduct. I .79. - The False 311d Defamatory Accusations directly and proximately I caused substantial and permanent damage to Balan. 80. Tesla published the Felse and Defamatory Accusations With actual malice; that is,- with knowledge of falsity or a reckless disregard for the truth or . -'falSity. 81. Tesla has never retracted the statements. '82. Tesla published the statements, and manipulated their placemeut, Tesla was upset about the article placing Balau 111 a positive realistic light, and the I possibility others will asked Mr. Musk again if he received Ms. Balan emails and 3 A critical infermatiou I I. I I I I Clearly ?ustrated from Huf?ngton Post's positive piece about Balau, Tesla sought to take swift and ?nal action, to destroy the reputation of Balan 84. Tesla ls liable for damages for each False and Defamatory Accusations, as Tesla had 3 years of litigations, depositions and discovery with COW AND REQUEST FOR WMCTION - 18 10 11 13 - corporation or a family, without regard for American Civil LawCase Document 1 Filed 01/15/19 Page 19 of 20 7 Ms Baler: and they were time at the time-they. wrote this article note, of all the . ins and outs. All the Exhibits that are presented here Tesla had them for years. 85. I Belan has suffered an incredible amount of emotional distress as a I result of Tesla 3 False and Defamatory Accusations Exhibit A 86. Because Tesla published the False and Defamatory Accusations with I I 3 both Constitutional and common law malice, Ms. Balan is entitled to an aWard of punitive daniages to punish it for its wrongdoing and deter him iron: rweatmg - such inappropriate behavior the future against others. 87. I Todd 5 conduct was willful and demonstrates a desire to dominate, and to control, not just ?nancial returns, but the individuals laboring for mom. I I I . I88. - Tesla' conductshows desire to control its public Weeption, md a . Willingness to catastrOphically damage individuals who opposethat view, be it a - I. WHEREFORE, Plainti??, Cristina Balan, respectfully prays for judgment against . Defendant, Tesla Inc., as follows: Judgement be entered against Defendant, Tesla Inc, for cempensatory damages y_ in an amount in excess of Seventy-Five Thousand Dollars to be calculatedatTnal I 7 I . I i Judgement be entered against Plaintiff Tesla Inc, for punitive a e: in an . mount doterrhined at trial, in an amount that is just by the evidence, and serving to . punish Tesla, and deter it from repeating such conduct. I COMPLAJNTANDREQUEST - 19 10 .11; - 16- 17. "f9,w 20 21. I12I 14f 15 . 18 Case Documentl Filed 01/15/19 jPageI20I0f20I . A px?liminalyinjunction be issued against Defendant, ommg- Test; .. theFalse and Defamatory Accusations, and" enjoining them from making- False and _IDcf?.mat0ry Accusa??ns In the ?xture. I I I I That all ofthis action bIe taxed to Defendant; and I (6) That theCourt grantall such other and further relief that theCourt . I _Iand proper JURY TRIAL DEMANDED Dated January 15, 201-9 CRISTINA BADAN Tamar - 7 AND REQUEST FOR INIUNCTION 20