86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`STATE OF MINNESOTA
`
`COUNTY OF WRIGHT
`
`7M Films, Inc. and Robert Shinn,
`
`Plaintiffs,
`
`V.
`
`Katherine Manske Paulson aka Katie Joy, and
`Without a Clystal Ball, LLC,
`
`Defendants.
`
`DISTRICT COURT
`TENTH JUDICIAL DISTRICT
`CASE TYPE: CIVIL
`OTHER/MISCELLANEOUS
`
`SUMMONS
`
`THE STATE OF MINNESOTA TO THE AB OVE—NAMED DEFENDANTS.
`1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintist
`Complaint against you is attached to this summons. Do not throw these papers away. They are official
`papers that affect your rights. You must respond to this lawsuit even though it may not yet be filed
`with the Court and there may be no court file number on this summons.
`2. YOU MUST REPLY WITHIN 21 DAYS TO PROTECT YOUR RIGHTS. You
`must give or mail to the person who signed this summons a written response called an Answer within
`21 days of the date on which you received this Summons. You must send a copy of your Answer to
`the person who signed this summons located at:
`Amber]. Stavig (#399419)
`Dudley and Smith, P.A.
`1295 Northland Drive, Suite 250
`Mendota Heights, MN 55120
`3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to
`the Plaintiffs Complaint. In your Answer you must state whether you agree or disagree with each
`paragraph of the Complaint. If you believe the Plaintiff should not be given everything asked for in
`the Complaint, you must say so in your Answer.
`4. YOU WILL LOSE YOUR CASE IF YOU DO NOT SEND A WRITTEN
`RESPONSE TO THE COMPLAINT TO THE PERSON WHO SIGNED THIS
`SUMMONS. If you do not answer within 21 days, you will lose this case. You will not get to tell
`your side of the story, and the Court may decide against you and award Plaintiff everything asked for
`in the complaint. If you do not want to contest the claims stated in the complaint, you do not need
`to respond. A default judgment can then be entered against you for the relief requested in the
`complaint.
`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`5. LEGAL ASSISTANCE. You may wish to get legal help from a lawyer. If you do not have
`a lawyer, the Court Administrator may have information about places where you can get legal
`assistance. Even ifyou cannot get legal help, you must still provide a written Answer to protect
`your rights or you may lose the case.
`6. ALTERNATIVE DISPUTE RESOLUTION. The parties may agree to or be ordered
`to participate in an alternative dispute resolution process under Rule 114 of the Minnesota General
`Rules of Practice. You must still send your written response to the Complaint even if you expect to
`use alternative means of resolving this dispute.
`
`Dated. 51%\IZOZL
`
`DUDLEY AND SMITH, P.A.
`
`By /L«~/ O/M
`
`Amber J. Stavig (#399119)“
`1295 Northland Drive, Suite 250
`Mendota Heights, MN 55120
`Telephone (651) 291—1717
`Facsimile (651) 223—5055
`astavig@dudleyandsmith.com
`Attorneys for Plaintiffs
`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`STATE OF MINNESOTA
`
`COUNTY OF WRIGHT
`
`DISTRICT COURT
`TENTH JUDICIAL DISTRICT
`CASE TYPE: CIVIL
`OTHER/MISCELLANEOUS
`
`7M Films, Inc. and Robert Shinn,
`
`Court File No.
`
`Plaintiffs,
`
`v.
`
`Katherine Manske Paulson aka Katie Joy, and
`Without a Ciystal Ball, LLC,
`
`Defendants.
`
`COMPLAINT
`
`For their Complaint against Defendants Katherine Manske Paulson aka Katie Joy, and
`
`Without a Crystal Ball, LLC, state and allege as follows:
`
`PARTIES
`
`1. Plaintiff 7M Films, Inc.
`
`(“7M”) is a California corporation organized and operating pursuant
`
`to and in accordance with the laws of the State of California.
`
`2. Plaintiff Robert Shinn (“Shinn”) is an individual resident of the State of California.
`3. Defendant Katherine Manske Paulson aka Katie Joy (“Katie Joy”) is an adult resident of
`
`Wright County, Minnesota.
`4. Defendant Without a Crystal Ball, LLC (“WCB”) is a Minnesota limited liability company
`organized and operating in accordance with the state laws of Minnesota with a principal
`executive address of 9917 Jasmine Avenue NE, Hanover, MN 55341.
`JURISDICTION AND VENUE
`5. This Court has personal jurisdiction over all Defendants pursuant to Minn. Stat. § 484.01.
`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`FACTUAL BACKGROUND
`
`The Parties.
`
`7M is a talent management company located in the State of California.
`Robert Shinn is the Chief Executive Officer and sole owner of 7M.
`
`Upon information and belief Katie Joy is an internet personality and the owner of WCB.
`KatieJoy through WCB monetizes her social media presence on YouTube, Twitter, Instagram,
`
`TikTok, and Facebook.
`
`Defendant’s Social Media Presence.
`
`10.
`
`Defendant Katie Joy runs and uses various social media usernames on various platforms,
`
`including but not limited to:
`
`a. @withoutacrystalball — Instagram
`b. @cultsyuck — Instagram
`c. @exposing7M — Instagram
`d. Without A Crystal Ball — YouTube
`e. Without a Crystal Ball — Facebook
`f. @woacbofficial — Twitter
`g. @katiejoywoacb — Twitter
`h. @withoutacrystalball — TikTok
`
`11.
`
`12.
`
`Defendant Katie Joy holds herself out as an entertaininent blogger.
`Defendant Katie Joy makes, produces, and uploads “drama” and/ or “tea” videos and internet
`
`postings on her various social media accounts.
`
`13.
`
`Defendant Katie Joy intentionally publishes false and defamatory material to denigrate others
`through sensationalism and fabrication of perceived drama for the sole purpose of enticing
`
`followers and viewers to help Defendants monetize their various social media accounts.
`
`14.
`
`Defendant Katiejoy intentionally engages in “internet trolling” under both her own name and
`various pseudonyms for the purposes of harassment and causing others consternation, grief,
`
`emotional distress, financial ruin, and to otherwise cause damage to their reputations, well—
`
`beings, and livelihoods.
`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`15.
`
`Defendant Kafie Joy has a history of intentionally, maliciously, and/or recklessly publishing
`
`false and/or misleading information about various people and entities, including Plaintiffs,
`
`their clients, and associates.
`
`16.
`
`Defendant Katie Joy currently has at least two other lawsuits in this court for her malicious
`
`17.
`
`and defamatory statements about others.
`Defendant Katie Joy holds herself out as an established YouTube personality and self—
`proclaimed internet troll with a professed obsession with Plaintiffs.
`
`18.
`
`Upon information and belief, Defendant Katie Joy has openly stated that she will not stop
`
`going after Plaintiffs until nobody works with them.
`Upon information and belief, Defendant Katie Joy has hundreds of thousands of followers
`
`19.
`
`on her various platforms.
`
`20.
`
`Upon information and belief, Defendant Katie Joy is determined to continue “exposing”
`
`Plaintiffs, their associates, and any business who contracts with them until they are “ruined.”
`
`21.
`
`Upon information and belief, Defendant Katie Joy has been sharing private and confidential
`information about Plainn'ffs and their associates to her social media pages with the intent of
`
`causing harm to Plaintiffs.
`
`22.
`
`Upon information and belief, Defendant Katie Joy’s improper posts have been published to
`
`and are accessible to the general public, including her posts which contain false and disparaging
`
`information about Plaintiffs.
`
`Social Media Posts Disparaging Plaintiffs
`
`23.
`
`Upon information and belief, Defendant Katie Joy has made the following social media posts
`which include false statements of fact, malicious and misleading statements, and defamatory
`
`statements about Plaintiffs and their associates:
`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`Date of
`Statement
`
`2/27/2022
`
`2/27/2022
`
`2/28/2022
`
`3/1/2022
`
`3/1/2022
`
`3/1/2022
`
`3/1/2022
`
`3/1/2022
`
`3/2/2022
`
`Descriptions of False Allegations
`Miranda Derrick was lured into a church (7m), 7M is associated
`with the 7 mountains of influence, 7M believes they need to take
`over all spheres of the world for Christ to return to the earth, The
`M in 7M stands for mountains of influence - a Pentecostal belief
`to take over the world among others, please see post for specifics.
`7M is using religion to control time, money, and resources of
`dancers that were vulnerable to abuse due to their economic status
`and they are abusing dancers.
`The dancers managed by 7M films management don’t pick their
`own music, sets, clothes, or dances
`B-Dash is a Victim of the Shinns, he was used to lure Miranda
`Derrick in to 7M, claims Miranda Derrick did not cut ties with her
`family before she was involved with 7M, 7M has been grooming
`Miranda Derrick, 7M made Miranda think her family is abusive,
`7M is preying on vulnerable dancers, mis-states promises made by
`7M to its clients, 7M controls its clients lives, 7M blocks friends
`and family of its clients from reaching them.
`7M is committing crimes including human trafficking, 7M stopped
`Miranda Derrick from being by herself, 7M clients are all a part of
`the Shinn’s church, Robert Shinn believes he gets prophecies from
`God, 7M cuts off all of its clients from speaking with people
`outside of their organization, 7M is a cult, 7M is like Jim Jones'
`cult, 7M monitors its clients when they are "outside", 7M
`psychologically abuses its clients, 7M doesn't allow Miranda
`Derrick to drive, see post for specific allegations.
`7M controls its clients lives, its abnormal for management teams
`to manage their client’s social media accounts, 7M controls
`everything its clients do, please see post for all specific allegations.
`7M is destroying their client's lives, please see posts for specific
`allegations.
`7M and Robert are predatory, Robert Shinn's church is tricking
`girls into following them, 7M and Robert Shinn are shaming
`people into joining their church, Miranda and Derrick's marriage
`is fake and they are lying about it, 7M doesn't promote its female
`clients, 7M is a cult, the Shinn's have been searching for people to
`prey on, 7M does not pay its dancers, Shirley Kim is "always
`watching" 7M‘s clients, see post for specific allegations.
`
`3/2/2022 7M's clients are all falsely married to their spouses.
`
`Link
`
`https://www.instagram.com/p/Ca
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`https://www.instagram.com/p/Ca
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`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`Every person at 7M has changed their names and has a different
`alias, 7M's clients cannot do anything without consulting Daniel
`Joseph including buying t—shirt and seeing friends and family,
`Robert Shinn tells his clients ifthey are not submitting to him they
`are not submitting to God, if clients miss church 7M takes away
`business opportunities from them, 7M's clients have meetings 4
`times a week and are forced to "work their way into church," ifyou
`are pulled out of church you cannot do jobs and your pay is taken
`away, Miranda Derrick missed a family funeral because 7M
`wouldn't pay her if she went, Robert Shinn has access to all of his
`client's bank accounts and brings it up in church, 7M doesn't pay
`their clients, their clients don't know how much they are being
`paid, Robeit Shinn is telling clients they must submit to him and if
`they obey they will be blessed by God.
`Dancer’s lives are so tightly controlled that they can’t do anything
`without speaking to Daniel first, Daniel
`Joseph controls the
`dancers every move.
`7M is controlling their clients social media, friends and family are
`is
`being blocked from contacting 7M's clients, management
`isolating their clients and dictating their every move.
`The dancers are worked constantly by the management, Robert
`Shinn told its clients that God told them the magic required for
`TikTok algorithms.
`Robert Shinn is telling his clients Christ wants them to be a certain
`way, 7M is a cult, Robert Shinn believes he has been selected by
`God, Robert Shinn is manipulative, 7M is underpaying their
`clients, 7M is exploiting their clients, Robert Shinn is abusing
`clients of 7M.
`7M is a cult and the cult is that they are preying on black dancers,
`exploiting them, and convincing them people don't like them for
`being black.
`Shinn's ruined relationship between the Derrick’s and Miranda
`Derrick's family.
`7M is a religious cult, tells people to not interact with 7M or their
`clients because they are a cult, cult leaders commit crimes, 7M is
`exploiting their clients, see post for specific allegations. Telling
`people street addresses associated with Robert Shinn.
`All of 7M and Robert Shinn's clients are Victims, Shinns are cult
`leaders, Robert Shinn is a narcissistic person, Robert Shinn asks
`his clients to live on his property, Robert Shinn told someone that
`God instructed him to teach young women about sex, Robert Shinn
`has conditioned people not to think, Robert Shinn targets young
`women to induce them into his cult.
`Katie Joy admits to contacting the LA Clippers to get them to
`cancel their contract with 7M and their clients.
`
`3/3/2022
`
`3/3/2022
`
`3/3/2022
`
`3/3/2022
`
`3/4/2022
`
`3/5/2022
`
`3/6/2022
`
`3/7/2022
`
`3/8/2022
`
`3/8/2022
`
`https://www.instagram.com/tv/C
`aqELDDBOEW/?utm_source=ig
`web copy link
`
`https://www.instagram.com/p/Ca
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`
`https://www.instagram.com/p/Ca
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`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`Robert Shinn‘s church is forcing the Derrick's to live in a property
`3/9/2022 ownedby them, 7M is a cult engaging in human trafficking.
`Robert Shinn 1s a cult leader, Robert Shinn does not allow chents
`to own their own car, Robert Shinn is spying on his clients,
`
`,
`
`,
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`,
`
`.
`
`3/9/2022
`
`https://www.instagram.com/p/Ca
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`3/9/2022 7M 1s a cult, Robert Shmn sexually abuses women.
`web copy link
`s://www.instagram.com/ /Ca
`h
`Fact: WOACB located the home she & B—Dash share. The home 3$RSSMJg/?uml source=i§ we
`is also home to Raino. Shirley Kim is a listing agent for the home.
`b copy link
`Posting private information about Robert Shinn's address,
`claiming a property is a cult compound, 7M is forcing clients to
`https‘l/www instagram com/p/Ca
`live in bad neighborhoods, Robert Shinn is stealing money from 49Gr uuzg/7ut1n source=ig we
`3/10/2022 his clients.
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`3/10/2022 homes owned by the church or managed by the church.
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`Robert Shinn directed Miranda Derrick to meet w1th her
`https://www.instagram.com/tv/C
`parents:
`Joseph of 7M controls all of the chents
`7M 15 a cult, Daniel
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`The dancers are 11v1ng under tight control & not allowed to do CZEZIcngK/mtrgn source=ig_
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`In a sworn deposition, Robert Shinn admitted that he used millions
`of dollars in church donations to flirther his business & for his own
`fortune.
`
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`
`_
`
`,
`
`3/9/2022
`
`3/10/2022
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`3/10/2022
`
`States th1s 15 not about Miranda Derrick, it is about Robert Shnm.
`3/10/2022 7M is a cult using race to distract people from the real issues.
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`3/10/2022
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`3/10/2022
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`3/10/2022
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`3/10/2022
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`3/10/2022
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`https://www.instagram.com/p/Ca
`6Py9JMij0/?utm_source=ig_web
`copy link
`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`Robert Shinn propositions women for inappropriate contact,
`Robert Shinn curses people who don't give him money, Robert
`Shinn demands his clients "submit" to him, Robert Shinn accesses
`his client's bank accounts, Robert Shinn forces his clients to
`divorce their spouses, Robert Shinn takes money from his church
`to fund his lifestyle, Robert Shinn does not pay his clients, Robert
`Shinn won’t let people use their own vehicles, Robert Shinn forces
`people to put their kids in daycare.
`
`Katherine Paulson has accessed and distributed to the public
`confidential court documents covered by protective order
`Shinn admitted to setting up a shell company Mission 20:20 in
`order to form other companies underneath the organization. He
`would start a business as DBA and only incorporate after it became
`“profitable.” The businesses generated limited income but rather
`were used to funnel donations from the church to Robert Shinn as
`“payroll” “bonuses” and “interest.” The fact was the money he
`received via these businesses were donations made by Lydia
`Chung and her trust. Shinn took out loans from Shekinah Church
`for these businesses to pay himself via payroll, bonuses and
`interest. he’s using the church shell non-profit to defraud people
`and enrich himself by funneling donations to shell for-profit
`companies
`
`3/10/2022
`
`3/11/2022
`
`3/11/2022
`
`3/1 1/2022
`
`Katherine Paulson has accessed and distributed to the public
`confidential court documents covered by protective order
`
`3/11/2022 Claims improper management of church funds
`
`3/13/2022
`
`3/1 1/2022 Holding the dancers captive
`As of today, the church is conducting commercial business fiom
`the property out of ordinance and zoning.
`Robert Shinn & his team are controlling every move these dancers
`make. They control their money, time, and they are forcing them
`to live in property they either own or manage. The dancers are
`being hurt by Robert Shinn. The dancers are not paid by brands,
`don’t run their own social media, and Aren’t making any of their
`own choices. They aren’t allowed to answer questions &
`everything must go through Hannah Shinn. They are working long
`hours. The Shinns are paying them a percentage after they are paid.
`Then the dancers are required to pay them rent, tithe the church &
`donate to Robert Shinn.
`
`3/ 15/2022
`
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`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`Robert allegedly takes away privileges such as going to church,
`Bible study, spending time with others in the church, work
`opportunities, and collabs. While he lives in a large home & drives
`a Bentley, he has all the dancers living in homes grouped together.
`The homes are through the church & they pay rent to the church.
`We asked her “are the women at risk of sexual exploitation by
`they are at risk of sexual
`Robert Shinn?” Lydia said “yes,
`exploitation.”
`Robert Shinn forcing couples to divorce, cut offfamily, and having
`them live in separate houses divided by sex. Relationships have
`been cut off by the dancers because of Robert’s coercion. Robert
`is taking away privileges & punishes dancers who do not submit.
`He demands full submission. They are not allowed to ask questions
`because questions are evil. the number of personal injury claims
`that have been filed against Shinn or church members related to
`their cars, and you start to see the threats are notjust spiritual. Then
`add that Lydia Chung stated yesterday that the women are at risk
`of sexual exploitation.
`Mac Cosmetics has confirmed to multiple people that they are not
`partnered with 7M & have no plans to partner with them in the
`future.
`She alleged that after meeting Robert, he isolated her from her
`husband, convinced her that he was influenced by demons because
`her husband didn’t support Shekinah Church, convinced her to
`divorce her husband, moved her into a home with other women
`from the church, and then took full control of her life. Lydia was a
`recent immigrant from Korea when she first met Robert & his
`sister Catherine. She was also a trustee of a large fund in Korea
`which held millions of dollars. She alleged that over several years,
`Robert Shinn & Catherine Yi gained access to her bank accounts.
`she alleged they forged signatures and
`During this time,
`transferred money out of her trust to the church.
`Former members allege he’s forced divorces, arranged marriages,
`and has had trysts with many women at church. One source alleges
`that one loyal woman was used as bait for real estate agents. They
`allege Robert would send the woman on dates with agents as bait
`to get listings for their company. "So please, please continue to
`spread this out that people need to stop collabing with 7m or
`working with them. " As long as they are working for Robert, they
`are being exploited. I’ve had multiple dancers reach out to say the
`male dancers are actively trying to get young females to join the
`group.
`
`3/15/2022
`
`3/16/2022
`
`3/17/2022
`
`3/l 7/2022
`
`3/17/2022
`
`3/18/2022
`
`Shinns exploit followers under the guise of religion to hand over
`their fortunes.
`
`3/18/2022
`
`https://www.instagram.com/p/Cb
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`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`3/19/2022 7M controls its clients' bank accounts.
`
`Robert Shinn barely works and lives off the work of his cult
`followers.
`
`3/19/2022
`
`3/19/2022
`
`3/19/2022
`
`3/19/2022
`
`3/1 9/2022
`
`3/19/2022
`
`3/19/2022
`
`Her pastor & his Wife “the woman of god” is also her manager.
`They dictate her whole schedule.
`Members must fully obey and submit to a Robert & Hannah or
`face consequences says the former members.
`Robert & Hannah continue to force Miranda to respond to claims
`while having her accuse her family of doing What they are
`seemingly doing to her.
`Please remember there are dozens of Mirandas that have been
`victimized by the Shinns.
`Call to stop people from becoming clients of 7M or working with
`them, Miranda Derrick has been kidnapped by 7M.
`Members are instructed to give 10% tithe, 10% gift of thanks to
`the church, 10% love gift to Robert. Robert encourages that tithes
`should be more than 10% because the bigger the tithe the bigger
`the blessing Former members say they were given allowances by
`Robert & could not deviate from that allowance The church
`members stopped having weddings because weddings are wasteful
`and the money is not for weddings but the gospel Travel is not
`allowed because it’s considered “selfish” and “doing things for
`yourself”. You cannot miss any church meetings & there are
`numerous meetings during the week. Members are taught to
`submit to Robert & not question. Those who submit can be
`rewarded with gifts like “luxury bags, expensive clothing,
`jewelry,” says the source.
`
`3/20/2022 Robert stole the money he used to buy his vehicle.
`Pastors using undue influence to not only be the mentor & dictator
`of the lives of the talent but also managing & producing their
`careers is a massive conflict of interest.7M is using a church to run
`fog-profit companies & control their members.
`
`3/21/2022
`
`3/23/2022 Robert Shinn has waterboarded members of his church.
`
`https://www.instagram.com/reel/
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`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`Robert Shinn refers to his followers as the Mighty Nation. He is
`taking scripture from Isaiah 60:22 Which says “the least ofhis will
`become a thousand, the smallest the mighty nation. At the right
`time, I, the lord, will make it happen.” His beliefs of separation of
`followers from family, isolating them through a beliefthat they are
`is absolutely dangerous & can lead to drastic
`selected by god,
`events like Waco & Jonestown.
`
`3/23/2022
`
`https://www.instagram.com/p/Cb
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`
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`
`No Link
`
`No Link
`
`No Link
`
`3/30/2022
`
`3/30/2022
`
`3/31/2022
`
`3/23/2022 Calls on supporters to harrass Sponsor Forever 21
`Claims Miranda Derrick's paid post about the Do Fasting App is
`Robert Shinn forcing his clients to not eat. Multiple claims about
`Robert Shinn's personal health and relationship with food, Robert
`Shinn forces clients to be thin, claiming Robert Shinn shamed
`clients for being overweight.
`Again reposting Miranda Derrick's paid sponsorship ofDo Fasting
`App and claiming she is the Victim of a cult, that 7M's clients are
`under mind control.
`ATT has cut
`ties with 7M client
`following the allegations
`regarding 7M being a cult and the way they treat their dancers.
`Instagram story stating that Robert Shinn targeted his clients and
`exploits them.
`Instagram story stating that Robert Shinn and B—Dash abandoned
`their children.
`Instagram story bragging about being the go to for all information
`about the cult leader Robert Shinn.
`
`3/31/2022
`
`3/31/2022
`
`3/31/2022
`
`Continued Disparagement
`
`24.
`
`On March 10, 2022, Plaintiffs send a cease—and—desist letter to Defendant instructing her to
`
`disconfinue any and all claims about 7M, Robert Shjnn, Miranda Derrick, and any clients,
`dancers, associates, etc. of theirs in addifion to removing all postings she had already made
`
`regarding the same.
`
`25.
`
`Defendants did not respond to the cease-and—desist letter and are continuing to post false
`allegadons about Plaintiffs and their various clients and associates daily, if not hourly. Plaintiffs
`reserve the right to amend these pleadings to include any and all posts made after the last of
`
`the listed posts and incorporate them herein.
`
`10
`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`26.
`
`As a direct result of Defendants’ false and defamatory statements, Plainfiffs’ reputation and
`
`standing in the community has been irreparably harmed.
`COUNT I
`
`DEFAMATION
`
`27.
`
`28.
`
`29.
`
`Plaintiffs restate and incorporate by reference all paragraphs previously set forth.
`Katie Joy communicated all of the posts outlined in this Complaint (the “False Statements”)
`to hundreds of thousands of people through her various social media accounts.
`The False Statements are categorically false.
`
`30.
`
`Katie Joy knew the False Statements to be false when she made them, or at the very least acted
`
`with reckless disregard for their truth.
`
`31.
`
`Katie Joy made the False Statements with actual malice.
`
`32.
`
`Katie Joy made the False Statements to further her own financial interests. She monetized
`
`the web traffic from these sensational and false claims.
`
`33.
`
`The False Statements have caused, and continue to cause Plainfiffs significant reputational
`
`harm, mental distress, humiliation, hatred, contempt, and embarrassment.
`
`34.
`
`As a direct and proximate result of the conduct of Defendants’ False Statements, Plaintiffs
`
`have been shunned, avoided, and injured in their occupation or business.
`
`35.
`
`By refusing to take down the defamatory posts and continuing to create new content with
`
`additional defamatory statements on multiple platforms, Katie Joy continues to make false,
`
`misleading, and defamatory statements.
`As a direct and proximate result of Defendants’ false and defamatory statements, Plaintiffs
`
`36.
`
`have suffered damages in an amount to be proven at trial, but reasonably believed to exceed
`
`$1,000,000.00.
`
`11
`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`DEFAMATION PER SE
`
`37.
`
`38.
`
`Plaindffs restate and incorporate by reference all paragraphs previously set forth.
`Katie Joy communicated the False Statements to hundreds of thousands of people through
`
`her various social media accounts.
`
`39.
`
`40.
`
`Katie Joy contacted individuals and organizations directly to disparage Plaintiffs.
`All of the False Statements made by Katie Joy as outlined in Section C of the Factual
`Background of this Complaint are categorically false.
`
`41.
`
`Katie Joy knew the False Statements were false when she made them, or at the very least acted
`
`with reckless disregard for their truth.
`
`42.
`
`Katie Joy made the False Statements with actual malice.
`
`43.
`
`Katie Joy made the False Statements to further her own financial interests. She moneflzed the
`
`web traffic from these sensational and false claims.
`
`44.
`
`The False Statements accuse Plaintiffs of committing crimes of moral turpitude. These
`
`allegations have harmed Plaintiffs in their trade and in their personal lives.
`
`45.
`
`The False Statements have caused, and continue to cause Plaintiffs significant reputational
`
`46.
`
`47.
`
`harm, mental distress, humiliation, hatred, contempt and embarrassment.
`As a direct and proximate result of the conduct of Defendants’ False Statements, Plaintiffs
`
`have been shunned, avoided, and injured in their occupation or business.
`As a direct and proximate result of Defendants’ false and defamatory statements, Plaintiffs
`
`have suffered damages in an amount to be proven at trial, but reasonably believed to exceed
`
`$1,000,000.00.
`
`12
`
`

`

`86-CV-22-1722
`
`Filed in District Court
`State of Minnesota
`4/5/2022 9:36 AM
`
`TORTIOUS INTERFERENCE OF CONTRACT
`
`48.
`
`P1ainti£fs restate and incorporate by reference all paragraphs previously set forth.
`
`49.
`
`Defendants have and continue to post statements on social media that no business or other
`
`person should engage in business with Plaintiffs.
`
`50.
`
`Defendants have and continue to disparage any company who is known to have a contract
`
`with Plaintiffs.
`
`51.
`
`Defendants have and continue to use social media t