CRAIG A. EDMONSTON,

ELECTRONICALLY FILED
9/11/2019 12:19 PM
Kern County Superior Court
By Esmeralda Salinas, Deputy

Esq. S.B.N. 128694

LAW OFFICES OF CRAIG A. EDMONSTON
2204 Truxtun Avenue, Bakersfield, CA 93301
Phone (661) 324-1 1 10 Fax (661) 324-1571

.h

KYLE J. HUMPHREY, Esq. S.B.N. 118477
THE LAW OFFICES OF KYLE J. HUMPHREY
2211 17th

Street,

CA 93301

Bakersfield,

Phone (661) 327-1360
Attorney for

Plaintiff,

\OOOQQKII

SUPERIOR COURT OF CALIFORNIA COUNTY OF KERN

METROPOLITAN DIVISION
10
11

CRAIG HARRISON,

CASE NO.: BCV-19-102587
Plaintiff,

12

COMPLAINT FOR DAMAGES FOR
DEFAMATION (LIBEL and SLANDER);
CIVIL CODE SECTION 3294

v.

13

JUSTIN GILLIGAN aka RYAN DIXON and
14

DOES

1-50 Inclusive,

15

Defendants.

16

COMES NOW,

plaintiff,

CRAIG HARRISON and complains

and allege as follows:

17
18
1.

Plaintiff, is

and

at all

times mentioned herein was a resident of the County of Kern,

19
State 0f California.

20
21
2.

Plaintiff is

informed and believes that

at all times

mentioned herein, defendant

22

JUSTIN GILLIGAN aka

RYAN DIXON

was an

individual doing business in the

23

County of Kern,

State of California.

The

identities

24
25
3.

true

names,

and capacities of defendants designated herein

as

DOES

26
1

through 50, Inclusive and each 0fthem are presently unknown to plaintiff. Plaintiff

27
28
1

COMPLAINT FOR DAMAGES FOR PERSONAL INJURY

 Will

amend

this

complaint to substitute the true names of said defendants, and each

of them, when such true names,

identities

Plaintiff alleges that at all times herein

aka

RYAN DIXON

and

DOES

ad capacities are ascertained.

mentioned defendants JUSTIN

GILLIGAN

1-50 and each 0f them were the agents, employees,

representatives, partners and co-venturers of each 0f the remaining defendants

and

\OOO\)O\Ul-b

committed

all acts

and omissions alleged herein

in the course

and scope 0f such

agency and employment.

10

On

11

GILLIGAN

12

maliciously published and re-published false, defamatory, libelous, and slanderous

13

statements including allegations 0f sexual misconduct 0f and concerning plaintiff

or about

May
aka

21,

2019 and July

31,

2019 and

RYAN DIXON and Does

thereafter, defendants

JUSTIN

1-50 and each of them negligently and

14

CRAIG HARRISON. The

15

statements included but were not limited t0 “that

16

touching,

17

inappropriate With children, giving gifts and money, saying sexual jokes, touching

18

and being alone With them”;

19

controlling lives ofyounger men entrusted to

20

“he made sexual advances toward

21

the years”.

lies,

subject false, defamatory, libelous and slanderous
I

am a Victim 0f his

inappropriate

manipulation and abuse of power”; “I witnessed him being

“I

have also witnessed him taking advantaga and

him that had drug or alcohol problems”;

me which I rej ected which caused tension through

22
23

Plaintiff alleges that the

above statements and

24

libelous and slanderous

0n

25

maliciously and With reckless disregard for the falsity (serious doubts as t0 the truth)

26

of the allegations. As a result of the publication and re-publication 0f the

27

aforementioned defamatory,

28

CRAIG HARRISON has sustained permanent damage and injury to his good name

their face

all

0f them were

false,

defamatory,

and were made were made negligently and

false, libelous

and slanderous statements,

2
COMPLAINT FOR DAMAGES FOR PERSONAL INJURY

plaintiff

 and reputation and has incurred and will continue t0 incur general and non-economic

damages

for emotional distress, worry, anxiety, fear

and humiliation

in an

amount

according to proof.
LII-bUJN

As a further
false,

legal result of the publication

and re-publication 0f the aforementioned

defamatory libelous and slanderous statements, plaintiff CRAIG HARRISON

has sustained special and economic damages for past present and future special and
\DOONON

economic damages including medical

bills,

loss 0f

income and impairment 0f

earning capacity in an amount according t0 proof.

10
11

As

12

libelous

13

presumed damages

a further legal result 0f the publication of the aforementioned false, defamatory,

and slanderous statements,
in the

plaintiff

amount according

CRAIG HARRISON

has sustained

t0 proof.

14
15

The publication and re—publication of the aforementioned false, defamatory,

16

and slanderous statements was done with malice, oppression and reckless disregard

17

for and serious doubts ofthe truth 0fthe statements thereby entitling plaintiff CRAIG

18

HARRISON t0 an award of exemplary and punitive damages against said defendants

19

pursuant to California Civil Code Section —3294, et seq. in an amount according to

20

proof.

libelous

21

22
23

Wherefore,

GILLIGAN

aka

plaintiff,

CRAIG HARRISON demands judgment

RYAN DIXON

and

DOES

against defendants

JUSTIN

1—50 and each of them, as follows:

24
25

For general and non-economic damages in an amount according to proof;

26

For special damages and economic damages in an amount according to proof;

27
28

PWN

For presumed damages in an amount according t0 proof;
For exemplary damages in an amount according

t0 proof;

3

COMPLAINT FOR DAMAGES FOR PERSONAL INJURY

 5.

For costs of suit;

6.

For such other and further relief as the court deems just and proper.

th

Dated: September 3E, 2019

LAW OFFICES OF CRA G A. DMONSTON

\DOOVO‘xk/l

By:
Crai

Attorney

A.
r

dm‘dnston, Esq.

pl intiff, Craig Harrison

10
11

12
13

14
15

16

17
18

19

20
21

22
23

24
25

26

27
28
4
COMPLAINT FOR DAMAGES FOR PERSONAL INJURY