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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI (Eastern Division) CHARLES JOHNSON and GOT NEWS, LLC
: : : Plaintiffs, : : Case No. 14:15-cv-001137 v. : : GAWKER MEDIA, LLC, J.K. TROTTER, : and GREG HOWARD : : Defendants. : DECLARATION OF JONATHON C. BURNS I, Jonathon Burns, declare: 1.
I am a partner in the law firm of The Burns Law Firm, LLC, and counsel for
Plaintiffs in the above-captioned matter. I am competent to testify as to the facts set forth below, and, if called as a witness, could and would testify to such facts based on personal knowledge and under oath. I submit this declaration for the purpose of submitting additional exhibits in support of Plaintiffs’ Responses to Defendants Motion to Dismiss and Special Motion to Strike Pursuant to the California anti-SLAPP Statute. 2.
Attached hereto as Exhibit 1 is a true and correct copy of an article by James
West, entitled “Gawker Took Only One Day to Report and Vet the Story That Blew Up in Its Face,” which was published by Mother Jones on July 24, 2015, and is available online at http://www.motherjones.com/media/2015/07/gawker-conde-nast-fallout-timeline-denton. 3.
Attached hereto as Exhibit 2 is a true and correct copy of an article by A.J.
Daulerio, entitled “The Story Behind the Stories You Loved This Year: Hulk Hogan’s Mesmorizing Sex Tape,” which was published by gawker.com on December 26, 2012, and is
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available online at http://gawker.com/5971314/the-story-behind-the-stories-you-loved-this-yearhulk-hogans-mesmerizing-sex-tape. 4.
Attached hereto as Exhibit 3 is a true and correct copy of an article by A.J.
Daulerio, entitled “Even For a Minute, Watching Hulk Hogan Have Sex in a Canopy Bed is Not Safe For Work but Watch it Anyway,” which was published by gawker.com on October 4, 2012, and is available online at http://gawker.com/5948770/even-for-a-minute-watching-hulk-hoganhave-sex-in-a-canopy-bed-is-not-safe-for-work-but-watch-it-anyway. 5.
Attached hereto as Exhibit 4 is a true and correct copy of an article by John Cook,
entitled “A Judge Told Us to Take Down Our Hulk Hogan Sex Tape Post. We Won’t.” which was published by gawker.com on April 25, 2013, and is available online at http://gawker.com/ajudge-told-us-to-take-down-our-hulk-hogan-sex-tape-po-481328088. 6.
Attached hereto as Exhibit 5 is a true and correct copy of an article by Jessica,
entitled “Introducing Gawker Stalker,” which was published by gawker.com on March 14, 2006, and is available online at http://gawker.com/160338/introducing-gawker-stalker-maps. 7.
Attached hereto as Exhibit 6 is a true and correct copy of an article by Emily
Gould, entitled “How The Gawker Stalker Map Works: A Guide For Dummies, Outraged Famous People, and Old Folk.,” which was published by gawker.com on April 9, 2007, and is available online at http://gawker.com/250593/how-the-gawker-stalker-map-works-a-guide-fordummies-outraged-famous-people-and-old-folk. 8.
Attached hereto as Exhibit 7 is a true and correct copy of an article by Jay Rayner,
entitled “The Brit dishing the dirt on America,” which was published by The Guardian on March 9, 2008, and is available online at http://www.theguardian.com/technology/2008/mar/09/gawker.
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9.
Attached hereto as Exhibit 8 is a true and correct copy of an article by Ben
McGrath, entitled “Search and Destroy, Nick Denton’s blog empire,” which was published by The New Yorker on October 18, 2010, and is available online at http://www.newyorker.com/magazine/2010/10/18/search-and-destroy-ben-mcgrath. 10.
Attached hereto as Exhibit 9 is a true and correct copy of an article by James
Silver, entitled “Gawk, don’t talk,” which was published by The Guardian on December 11, 2006, and is available online at http://www.theguardian.com/technology/2006/dec/11/news.mondaymediasection. 11.
Attached hereto as Exhibit 10 is a true and correct copy of an article by Eriq
Gardner, entitled “Gawker’s Nick Denton Explains Why Invasion of Privacy is Positive for Society,” which was published by The Hollywood Reporter on May 22, 2013, and is available online at http://www.hollywoodreporter.com/thr-esq/gawkers-nick-denton-explains-why526548. 12.
Attached hereto as Exhibit 11 is a true and correct copy of an article by Gawker
Sources, entitled “Which Beloved Comedian Likes to Force Female Comics to Watch Him Jerk Off?,” which was published by gawker.com on March 19, 2012, and is available online at http://gawker.com/5894527/which-beloved-comedian-likes-to-force-female-comics-to-watchhim-jerk-off. 13.
Attached hereto as Exhibit 12 is a true and correct copy of an article by Jordan
Sargent, entitled “Louis C.K. Will Call You Up to Talk About His Alleged Sexual Misconduct,” which was published by gawker.com on May 15, 2015, and is available online at http://defamer.gawker.com/louis-c-k-will-call-you-up-to-talk-about-his-alleged-s-1687820755.
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14.
Attached hereto as Exhibit 13 is a true and correct copy of an article by Richard
Lawson, entitled “ Which Actor is Crazy, Violent, and Gay?” which was published by gawker.com on August 18, 2008, and is available online at http://gawker.com/5038208/whichactor-is-crazy-violent-and-gay. 15.
Attached hereto as Exhibit 14 is a true and correct copy of an article by Richard
Lawson, entitled “The People Have Spoken, And They Think James Franco Is a Rapist,” which was published by gawker.com on August 22, 2008, and is available online at http://gawker.com/5040524/the-people-have-spoken-and-they-think-james-franco-is-a-rapist. 16.
Attached hereto as Exhibit 15 is a true and correct copy of an article by Larry
Womack, entitled “Anyone Else Think James Franco Should Sue the Hell Out of Gawker?” which was published by Huffington Post on July 17, 2015, and is available online at http://www.huffingtonpost.com/larry-womack/james-franco-gawker_b_7816032.html. 17.
Attached hereto as Exhibit 16 is a true and correct copy of an article by James
West, entitled “Gawker Took Only One Day to Report and Vet the Story That Blew Up in Its Face,” which was published by Mother Jones on July 24, 2015, and is available online at http://www.motherjones.com/media/2015/07/gawker-conde-nast-fallout-timeline-denton. 18.
Attached hereto as Exhibit 17 is a true and correct copy of an article by Jordan
Sargent, entitled “Conde Nast’s CFO Tried to Pay $2,500 for a Night With a Gay Porn Star,” which was published by gawker.com on February 16, 2015, and has been removed, available at https://archive.is/EUkg0#selection-1198.0-1200.0. 19.
Attached hereto as Exhibit 18 is a true and correct copy of a screenshot of several
articles posted by deadspin.com by various authors, comprising of search results for “athlete
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dong,” on deadspin.com. The page is available online at http://deadspin.com/search?q=athlete+dong. 20.
Attached hereto as Exhibit 19 is a true and correct copy a screenshot of the Kinja
leaderboard as well as a linkedin.com page for Collin Krum. The Leaderboard is available at https://kinja.com/stats/leaderboard. The linkedin account is available at https://www.linkedin.com/pub/collin-krum/71/161/992. 21.
Attached hereto as Exhibit 20 is a true and correct copy of a screenshot of the
Kinja leaderboard as well as screenshots from Kevin Purdy’s personal website. The leaderboard is available at https://kinja.com/stats/leaderboard. The personal website is available at http://thepurdman.com/bio/. 22.
Attached hereto as Exhibit 21 is a true and correct copy of a screenshot of Gawker
Media’s Quantcast data, available at https://www.quantcast.com/gawker.com#!generalInterestsCard. 23.
Attached hereto as Exhibit 22 is a true and correct copy of a screenshot of Gawker
Media’s Quantcast data, available at https://www.quantcast.com/gawker.com#!generalInterestsCard. 24.
Attached hereto as Exhibit 23 is a true and correct copy of a screenshot of Gawker
Media’s Quantcast data, available at https://www.quantcast.com/gawker.com#!generalInterestsCard. 25.
Attached hereto as Exhibit 24 is a true and correct copy of an article by Henry
Blodget, entitled “Why Gawker Media Is Kicking Everyone’s Ass,” which was published by Business Insider on April 8, 2010, and is available online at
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http://www.businessinsider.com/henry-blodget-why-gawker-media-is-kicking-everyones-ass2010-4. 26.
Attached hereto as Exhibit 25 is a true and correct copy of an article by Mac
Slocum, entitled “To grow, Gawker turns its attention to unique users,” which was published by NiemanLab on January 7, 2010, and is available online at http://www.niemanlab.org/2010/01/togrow-gawker-turns-its-attention-to-unique-users/. 27.
Attached hereto as Exhibit 26 is a true and correct copy of an article by Greg
Sterling, entitled “Study: What Makes You Click On A Headline?,” which was published by Marketing Land on January 14, 2014, and is available online at http://marketingland.com/whatmakes-you-click-on-a-headline-70364. 28.
Attached hereto as Exhibit 27 is a true and correct copy of an article by Andrew
Phelps, entitled “I can’t stop reading this analysis of Gawker’s editorial strategy,” which was published by NiemanLab on March 21, 2012, and is available online at http://www.niemanlab.org/2012/03/i-cant-stop-reading-this-analysis-of-gawkers-editorialstrategy/. 29.
Attached hereto as Exhibit 28 is a true and correct copy of an article by Milo
Yiannopoulos, entitled “Here Are All The People Who Should Sue Gawker Media,” which was published by Breitbart.com on July 17, 2015, and is available online at http://www.breitbart.com/big-journalism/2015/07/17/here-are-all-the-people-who-should-suegawker-media/. 30.
Attached hereto as Exhibit 29 is a true and correct copy of an article by Gabriel
Snyder, entitled “Gawker Gives Up Pageview Addiction, Quickly Picks Up a Monthly Uniques Habit,” which was published by gawker.com on January 5, 2010, and is available online at
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http://gawker.com/5440807/gawker-gives-up-pageview-addiction-quickly-picks-up-a-monthlyuniques-habit. 31.
Attached hereto as Exhibit 30 is a true and correct copy of an article by Nick
Denton, entitled “Taking a post down,” which was published by kinja.com on July 17, 2015, and is available online at http://nick.kinja.com/taking-a-post-down-1718581684. 32.
Attached hereto as Exhibit 31 is a true and correct copy of an article by Eric
Wemple, entitled “Conde Nast exec story: Gawker is keeping its sleaze game in shape,” which was published by The Washington Post on July 17, 2015, and is available online at https://www.washingtonpost.com/blogs/erik-wemple/wp/2015/07/17/conde-nast-exec-storygawker-is-keeping-its-sleaze-game-in-shape/. 33.
Attached hereto as Exhibit 32 is a true and correct copy of an article by
pagesix.com staff, entitled “Just Asking,” which was published by Page Six on August 18, 2008, and is available online at http://pagesix.com/2008/08/18/just-asking-88/. 34.
Attached hereto as Exhibit 33 is a true and correct copy of an article by Charles C.
Johnson, entitled “Exclusive: Is The Gawker Story An Elaborate Hoax? Sure Looks That Way,” which was published by gotnews.com on July 17, 2015, and is available online at http://gotnews.com/breaking-exclusive-is-the-gawker-story-an-elaborate-hoax-sure-looks-thatway/. 35.
Attached hereto as Exhibit 34 is a true and correct copy of an article by Richard
Lawson, entitled “So Really, Which Actor Raped His Gay Lover?” which was published by gawker.com on August 8, 2008, and is available online at http://gawker.com/5040051/so-reallywhich-actor-raped-his-gay-lover.
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36.
Attached hereto as Exhibit 35 is a true and correct copy of an article by Richard
Lawson, entitled “’Gay Rapist’ Actor Surprisingly Cool About His Sexuality,” which was published by gawker.com on September 29, 2008, and is available online at http://gawker.com/5056330/gay-rapist-actor-surprisingly-cool-about-his-sexuality. 37.
Attached hereto as Exhibit 36 is a true and correct copy of an article by Chuck
Ross, entitled “Exclusive: Interview With The Gay Porn Star Behind That Terrible Gawker Article,” which was published by The Daily Caller on July 17, 2015, and is available online at http://dailycaller.com/2015/07/17/exclusive-interview-with-the-gay-porn-star-behind-thatterrible-gawker-article/. 38.
Attached hereto as Exhibit 40 is a true and correct copy of a screenshot taken by
John C. Burns while accessing gawker.com from St. Louis, Missouri on October 4, 2015. 39.
Attached hereto as Exhibit 41 is a series of articles from deadspin.com,
comprising of a true and correct copy of an article by Drew Magary, entitled, “Eat Shit, Cardinals,” which was published by deadspin.com on June 16, 2015, and is available online at http://deadspin.com/eat-shit-cardinals-1711726377. A true and correct copy of an article by Drew Magary, entitled “Moron USA Today Columnist Thinks The Cardinals Poop Vanilla Sprinkles,” which was published by deadspin.com on March 5, 2015, and is available online at http://deadspin.com/moron-usa-today-columnist-thinks-the-cardinals-poop-van-1689616561. A true and correct copy of an article by Tom Ley, entitled, “Everyone Involved In The Cardinals Hacking Scandal Seems To Be An Idiot,” which was published by deadspin.com on June 16, 2015, and is available online at http://deadspin.com/everyone-involved-in-the-cardinals-hackingscandal-seem-1711682201. A true and correct copy of an article by Samer Kalaf, entitled, “Report: FBI Investigates St. Louis Cardinals For Hacking The Astros,” which was published by
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deadspin.com on June 16, 2015, and is available online at http://deadspin.com/report-fbiinvestigates-st-louis-cardinals-for-hackin-1711673515. A true and correct copy of an article by Drew Magary, entitled “Why Your Cardinals Suck,” which was published by deadspin.com on October 10, 2013, and is available online at http://deadspin.com/why-your-cardinals-suck1443513646. 40.
Attached hereto as Exhibit 42 is a true and correct copy of an article by Nick
Denton, entitled “Introducing group chats in Kinja,” which was published by kinja.com on February 6, 2014, and is available online at http://product.kinja.com/introducing-group-chats-inkinja-1517330082. 41.
Attached hereto as Exhibit 43 is a true and correct copy of an article by Nick
Denton, entitled “How do Kinja group chats work?,” which was published by kinja.com on February 6, 2014, and is available online at http://product.kinja.com/how-do-kinja-group-chatswork-1517522198. 42.
Attached hereto as Exhibit 44 is a true and correct copy of a screenshot taken by
John C. Burns while accessing two gawker.com articles. 43.
Attached hereto as Exhibit 45 is a true and correct copy of kinja’s “Discussions”
section, accessed online at http://help.gawker.com/customer/en/portal/topics/849655discussions/articles. 44.
Attached hereto as Exhibit 46 is a true and correct copy of kinja’s “General
Questions” section, which counsel could no longer access online as of the present date. 45.
Attached hereto as Exhibit 47 is a true and correct copy of an article by Robby
Soave, entitled “Gawker Helps Gay Escort Blackmail Timothy Geithner’s Brother, Ted Cruz Is
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the Hero of The Story,” which was published by reason.com on July 17, 2015, and is available online at https://reason.com/blog/2015/07/17/gawker-helps-gay-escort-blackmail-timoth. 46.
Attached hereto as Exhibit 48 is a true and correct copy of an article by Maggie
Rosetao, entitled “World Future 2015 [Part 4]: The Future of Kinja,” which was published by kinja.com on August 25, 2015, and is available online at http://maggierosetao.kinja.com/worldfuture-2015-part-4-the-future-of-kinja-1726375719. 47.
Attached hereto as Exhibit 49 is a true and correct copy of a screenshot taken by
John C. Burns of kinja’s leaderboard, available online at https://kinja.com/stats/leaderboard. 48.
Attached hereto as Exhibit 50 is a true and correct copy of a screenshot taken by
John C. Burns of kinja’s leaderboard, available online at https://kinja.com/stats/leaderboard. 49.
Attached hereto as Exhibit 51 is a true and correct copy of a screenshot taken by
John C. Burns of kinja’s leaderboard, available online at https://kinja.com/stats/leaderboard. 50.
Attached hereto as Exhibit 52 is a true and correct copy of an article by Caitlin
Petre, entitled “The Traffic Factories: Metrics at Chartbeat, Gawker Media, and The New York Times,” which was published by Tow Center for Digital Journalism on May 7, 2015, and is available online at http://towcenter.org/research/traffic-factories/. 51.
Attached hereto as Exhibit 53 is a series of screenshots and an article. The
screenshots are true and correct copies taken by John Burns of kinja.com’s Burner Account Support, accessible at http://help.gawker.com/customer/portal/articles/1192515-what-is-aburner-account-. An article by J.K. Trotter, entitled “How to Leak to Gawker Anonymously,” which was published by gawker.com on August 1, 2014, and is available online at http://gawker.com/how-to-leak-to-gawker-anonymously-1613394137.
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52.
Attached hereto as Exhibit 54 is a series of screenshots captured by John Burns,
and are true and correct copies of several Twitter user’s homepages who follow Gawker Media on Twitter and reside in Missouri. 53.
Attached hereto as Exhibit 55 is a series of screenshots captured by John Burns,
and are true and correct copies of tweets published by Greg Howard and others containing defamatory content about Plaintiffs. 54.
Attached hereto as Exhibit 56 is a series of screenshots captured by John Burns,
and are true and correct copies of tweets published by Gawker.com advertising defamatory articles about Plaintiffs. 55.
Attached hereto as Exhibit 57 is a series of screenshots captured by John Burns,
and are true and correct copies of tweets published by Gawker.com containing defamatory content about Plaintiffs. 56.
Attached hereto as Exhibit 58 is a screenshot captured by John Burns of a true and
correct copy of a Missouri Twitter user’s homepage. 57.
Attached hereto as Exhibit 59 is a series of screenshots captured by John Burns of
a true and correct copies of a Missouri Twitter users’ homepages who follow gawker media. 58.
Attached hereto as Exhibit 60 is a series of screenshots captured by John Burns of
a true and correct copies of a Missouri Twitter users’ homepages who follow Greg Howard. 59.
Attached hereto as Exhibit 61 is a true and correct copy of an article by Charles C.
Johnson, entitled “@Gawker Blogger Calls For Hackers To Steal #Darren Wilson’s Money,” which was published by gotnews.com on September 9, 2014, and is available online at http://gotnews.com/gawker-blogger-calls-hackers-steal-officer-darrenwilsons-money/.
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60.
Attached hereto as Exhibit 62 is a series of articles. A true and correct copy of an
article by Charles C. Johnson, entitled “Exclusive: What We Found On #MichaelBrown’s Instagram Account,” which was published by gotnews.com on September 5, 2014, and is available online at http://gotnews.com/found-michaelbrowns-instagram-account/. A true and correct copy of an article by Charles C. Johnson, entitled “Exclusive: Here Are #MichaelBrown Anti-Women, Violent Tweets,” which was published by gotnews.com on September 5, 2014, and is available online at http://gotnews.com/michaelbrown-misogynistic-violent-tweets/. A true and correct copy of an article by Charles C. Johnson, entitled “Breaking Report: DOJ Is Threatening #Ferguson Prosecutor With Bias Order Over No Indictment,” which was published by gotnews.com on November 21, 2014, and is available online at http://gotnews.com/breakingreport-doj-threatening-ferguson-prosecutor-bias-order-no-indictment/. A true and correct copy of an article by Charles C. Johnson, entitled “Breaking: Cops: #MichaelBrown Stepfather Inciting #Ferguson Race Riot is Blood Gangbanger,” which was published by gotnews.com on November 26, 2014, and is available online at http://gotnews.com/breaking-cops-michaelbrownstepfather-inciting-ferguson-race-riot-blood-gangbanger/. A true and correct copy of an article by Charles C. Johnson, entitled “Breaking: Real DeAndre Joshua Was a Drug Dealer #Ferguson,” which was published by gotnews.com on November 26, 2014, and is available online at http://gotnews.com/breaking-real-deandre-joshua-drug-dealer-ferguson/. A true and correct copy of an article by Charles C. Johnson, entitled “Breaking: Here’s #MichaelBrown’s Gangbanger “Step Dad’s” Rap Sheet #Ferguson,” which was published by gotnews.com on September 26, 2014, and is available online at http://gotnews.com/breaking-heres-michaelbrowns-gangbangerstep-dads-alleged-criminal-record-ferguson/.
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61.
Attached hereto as Exhibit 63 is a series of articles. A true and correct copy of an
article by Charles C. Johnson, entitled “Why We Sued St. Louis County Court To Get Michael Brown’s Juvenile Arrest Records,” which was published by gotnews.com on August 22, 2014, and is available online at http://gotnews.com/sued-st-louis-county-court-get-michael-brownsjuvenile-arrest-records/. A true and correct copy of an article by Charles C. Johnson, entitled “What Happened Today at #MichaelBrown Juvenile Court,” which was published by gotnews.com on September 3, 2014, and is available at http://gotnews.com/happened-todaymichaelbrown-juvenile-court/. A true and correct copy of an article by Charles C. Johnson, entitled “Breaking: Judge Denies #MichaelBrown Gotnews.com Suit,” which was published by gotnews.com on September 10, 2014, and is available online at http://gotnews.com/breakingjudge-denies-michaelbrown-gotnews-com-suit/. A true and correct copy of an article by Charles C. Johnson, entitled “GotNews Is Reinitiating The Lawsuit To Get #MichaelBrown’s Juvenile Records,” which was published by gotnews.com on November 25, 2014, and is available online at http://gotnews.com/gotnews-reinitiating-lawsuit-get-michaelbrowns-juvenile-records/. A true and correct copy of an article by Charles C. Johnson, entitled “Breaking: GotNews Wins First Stage of Appeal on #MichaelBrown Records #Ferguson #EricGarner,” which was published by gotnews.com on December 5, 2014, and is available online at http://gotnews.com/breakinggotnews-wins-first-stage-appeal-michaelbrown-records-ferguson-ericgarner/. A true and correct copy of an article by Charles C. Johnson, entitled “Breaking: GotNews Appeals #MichaelBrown Lawsuit To Missouri Supreme Court,” which was published by gotnews.com on May 8, 2015, and is available online at http://gotnews.com/breaking-gotnews-appeals-michaelbrown-lawsuitto-missouri-supreme-court/.
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62.
Attached hereto as Exhibit 64 is a true and correct copy of an article by Chuck
Ross, entitled “DOJ: Underage Prostitution Allegations Against Robert Menendez Backed By ‘Corroborating Evidence’,” which was published by The Daily Caller on August 24, 2015, and is available online at http://dailycaller.com/2015/08/24/doj-underage-prostitution-allegationsagainst-robert-menendez-backed-by-corroborating-evidence/. 63.
Attached hereto as Exhibit 65 is a true and correct copy of an article by Rhonda
Shwartz, Brian Ross, and Ned Berkowitz, entitled “The Menendez Prostitution ‘Scandal’: How It Happened,” which was published by ABC news on March 6, 2013, and is available online at http://abcnews.go.com/Blotter/robert-menendez-prostitution-scandalhappened/story?id=18664472. 64.
Attached hereto as Exhibit 66 is a true and correct copy of a screenshot taken by
John C. Burns of gotnews.com’s website traffic by Google analytics. 65.
Attached hereto as Exhibit 67 is a series of articles. A true and correct copy of an
article by Max Read, entitled “Why Should Anyone ‘Respect’ the Law?,” which was published by gawker.com on December 4, 2014, and is available online at http://gawker.com/why-shouldanyone-respect-the-law-1666634274. A true and correct copy of an article by Charlie R. Braxton, entitled “Another Mississippi Murder,” which was published by gawker.com on October 11, 2014, and is available online at http://gawker.com/another-mississippi-murder1644679499. A true and correct copy of an article by Gabrielle Bluestone, entitled “How the System Treats Cops Differently: The Essential Guide,” which was published by gawker.com on December 11, 2014, and is available online at http://gawker.com/how-the-system-treats-copsdifferently-the-essential-g-1668194863.
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66.
Attached hereto as Exhibit 68 is a true and correct copy of an article by Adam
Weinstein, entitled “Is Ratfucking Journalis Dead?” which was published by gawker.com on July 8, 2014, and is available online at http://gawker.com/is-ratfucking-journalism-dead-1601527887. 67.
Attached hereto as Exhibit 69 is a true and correct copy of an article by J.K.
Trotter, entitled “Which of These Disgusting Chuck Johnson Rumors are True?” which was published by gawker.com on December 15, 2014, and is available online at http://gawker.com/which-of-these-disgusting-chuck-johnson-rumors-are-true-1669433099. 68.
Attached hereto as Exhibit 70 is a true and correct copy of an article by Greg
Howard, entitled “Wait, Did Clowntroll Blogger Chuck Johnson Shit On The Floor One Time?” which was published by deadspin.com on December 9, 2014, and is available online at http://theconcourse.deadspin.com/wait-did-clowntroll-blogger-chuck-johnson-shit-on-the1668919746. 69.
Attached hereto as Exhibit 71 is a true and correct copy of an article by J.K.
Trotter, entitled “What Is Chuck Johnson, and Why? The Web’s Worst Journalist, Explained,” which was published by gawker.com on December 9, 2014, and is available online at http://gawker.com/what-is-chuck-johnson-and-why-the-web-s-worst-journal-1666834902. 70.
Attached hereto as Exhibit 72 is a true and correct copy of an article by J.K.
Trotter, entitled “The Daily Caller Can’t Quit Chuck Johnson,” which was published by gawker.com on December 9, 2014, and is available online at http://gawker.com/the-daily-callercan-t-quit-chuck-johnson-1668910086. 71.
Attached hereto as Exhibit 73 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “Wait, Did Clowntroll Blogger Chuck Johnson Shit On The Floor One Time?”
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72.
Attached hereto as Exhibit 74 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion of gawker.com user Cmcalumna. 73.
Attached hereto as Exhibit 75 is a true and correct copy of an article by Greg
Howard, entitled “Charles Barkley Has Nothing To Say To America,” which was published by deadspin.com on December 4, 2014, and is available online at http://deadspin.com/charlesbarkley-has-nothing-to-say-to-america-1666864783. 74.
Attached hereto as Exhibit 76 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “What Is Chuck Johnson, and Why? The Web’s Worst Journalist, Explained,” 75.
Attached hereto as Exhibit 77 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “Which of These Disgusting Chuck Johnson Rumors are True?” 76.
Attached hereto as Exhibit 78 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “Which of These Disgusting Chuck Johnson Rumors are True?” 77.
Attached hereto as Exhibit 79 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “Which of These Disgusting Chuck Johnson Rumors are True?” 78.
Attached hereto as Exhibit 80 is a true and correct copy of a screenshot captured
by John C. Burns of the first published tweet regarding the defamatory rumors that Charles Johnson defecated on the floor, posted December 9, 2014 by @Bearpigman.
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79.
Attached hereto as Exhibit 81 is a true and correct copy of a screenshot captured
by John C. Burns of a tweet by Greg Howard linking and endorsing his article, “Wait, Did Clowntroll Blogger Chuck Johnson Shit On The Floor One Time?” 80.
Attached hereto as Exhibit 82 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “What is Chuck Johnson, and Why? The Web’s Worst Journalist, Explained.” 81.
Attached hereto as Exhibit 83 is a true and correct copy of an email exchange
between J.K. Trotter and Plaintiff Charles C. Johnson. 82.
Attached hereto as Exhibit 84 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “Wait, Did Clowntroll Blogger Chuck Johnson Shit On The Floor One Time?” 83.
Attached hereto as Exhibit 85 is a true and correct copy of an article by Ruby
Cramer, entitled “Cory Booker: Yes, I Live In Newark,” which was published by buzzfeed.com on October 14, 2013, and is available online at http://www.buzzfeed.com/rubycramer/corybooker-yes-i-live-in-newark#.yvOPjJ9xy. 84.
Attached hereto as Exhibit 86 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “What is Chuck Johnson, and Why? The Web’s Worst Journalist, Explained.” 85.
Attached hereto as Exhibit 87 is a true and correct copy of an email exchange
between Greg Howard and Plaintiff Charles C. Johnson. 86.
Attached hereto as Exhibit 88 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “What is Chuck Johnson, and Why? The Web’s Worst Journalist, Explained.”
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87.
Attached hereto as Exhibit 89 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “Wait, Did Clowntroll Blogger Chuck Johnson Shit On The Floor One Time?” 88.
Attached hereto as Exhibit 90 is a true and correct copy of a screenshot captured
by John C. Burns of the published discussion section for the article, “Wait, Did Clowntroll Blogger Chuck Johnson Shit On The Floor One Time?” 89.
Attached hereto as Exhibit 91 is a true and correct copy of a verified affidavit
made by Plaintiff Mr. Charles C. Johnson. 90.
Attached hereto as Exhibit 92 is a true and correct copy of a data chart displaying
data on website traffic for GotNews.com in the St. Louis, Missouri region from February 1, 2015 through July 31, 2015. 91.
Attached hereto as Exhibit 93 is a true and correct copy of a screenshot captured
by John C. Burns of the published tweet made by Defendant Greg Howard on June 18, 2015. It I available online at https://twitter.com/greghoward88/status/611624963754328064. 92.
Attached hereto as Exhibit 94 is a true and correct copy of a data chart from
Quantcast displaying data on recent website traffic for gotnews.com. 93.
Attached hereto as Exhibit 95 is a true and correct copy of an article by Matt
Bonesteel, entitled “Jason Whitlock says Deadspin writer made up anecdote about him,” which was published by the Washington Post on October 15, 2015, and is available online at https://www.washingtonpost.com/news/early-lead/wp/2015/10/15/jason-whitlock-says-deadspinwriter-made-up-anecdote-about-him/. 94.
Attached hereto as Exhibit 96 is a true and correct copy of an article by Jake
O’Donnell, entitled “Jason Whitlock Goes All-In On Deadspin, Greg Howard Responds With
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Pure Fire,” which was published by sportsgrid.com on October 15, 2015 and is available online at http://www.sportsgrid.com/uncategorized/jason-whitlock-goes-all-in-in-fued-with-deadspingreg-howard-responds/. 95.
Attached hereto as Exhibit 97 is a true and correct copy of a post by Charles C.
Johnson on his personal Facebook account. 96.
Attached hereto as Exhibit 98 is a series of screenshots captured by John Burns,
and are true and correct copies of several Twitter user’s homepages who follow J.K. Trotter on Twitter and reside in Missouri. 97.
Attached hereto as Exhibit 99 is a table of defamatory statements.
THE BURNS LAW FIRM, LLC _/s/ John C. Burns John C. Burns #66462MO 1717 Park Avenue St. Louis, MO 63104 Phone: (314) 339-8388 Fax: (314) 932-2171
[email protected] Attorney for Plaintiffs
CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing was served, via the Court’s electronic notification system, on October 12, 2015, upon all parties of record. /s/ John C. Burns
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