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ST ATE OF MlNNESOT A

DfSTRICT COURT
COUNTY OF DAKOTA
FIRST JUDICIAL DISTRICT
New School Communications, Inc. a
Minnesota Corporation,
Blois Olson
Plaintifs,
V.
Michael B. Brodkorb, and
www.minneotademocratesexposed.com,
Defendants.
STATE OF MINNESOTA )
)
S.
COUNTY OF RAMSEY
)
Court File No. 19-CX-06-6432
AFIAV OF
MICHAEL B. BRODKORB
Michael B. Brodkorb, being frst duly swor under oat, states a follows:
1. I am a resident of the City of Eagan, County of Dakota. I have frsthand knowledge
of the matters asserted herein.
2. I am the author and creator of the inteet
www.minnesotademocratesexposed.com and have been since its incepton i June 2004.
blog
3. www.minnesotademocratescxposed.cm is a interet based forum dedicated t fee
speech and open discussion about local, state and national politics, curent issue and events, and
promoting conserative ideologies. Additionally, www.minnesotademocrateexposed.com is
dedicated to a truthfl discussion on te activities, statements, and tactics of Minnesota Democrats
so as to allow the electorate a fll, fair and unbiased evaluation of democratic candidates for ofce.
4. ww .minneotndemocratesexposed.com bas been quoted and cite on multiple
occAsions as a creible source of information by the following news organizations:
a. St. Paul Pioneer Pres;
b. Minneapolis Star Tribune;
c. National Joural; and
d. Associate< Press.
5. From its inception until shorly afer this lawsuit was sered upn me
www.minncsotndemocrates_.QQ_ d.com was authored anonymously so the content placed into
circulation was not overshadowed, by the readers, with preconceived opinions based upon the
backgound, employent histor and reputation of its author.
6. As a result of Plaintifs' lawsuit against me and
www.minnesotademocratesexposed.com I was forced to discntinue reporting on te
Humphrey/owley story.
7. On December 28, 2005, www.minnesotademocrateexposed.com reported that
Hubert H. "Buck" Humphrey, U (hereinafer referred to as "Buck Humphrey") approached the
Colleen Rowley campaig for Unite States Congess (hereinafer rfr to as "the Rowley
Campaign") with a proposal to do consulting work. It was frther reported that Buck Humphrey's
proposal was rejected by the Rowley Campaig. Se, Exhibit A, Attached to Plaintifs Complant.
8. At the time of the submission of the proposal to the Rowley Campaig, Buck
Humphrey was employed as a "Senior Counselor" with New School Communications, Inc. and had
been since March 2005. See, Exhibit A attached hereto.
9. It is my understanding that New School Communications, Ic. is owned by Blois
Olson (hereinafer referred to as "Olson"), a Democratic stategist, political commentator ad DFL
co-editor of the political newsletter Politics in Minnesota.
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10. ln response to the Humphrey/Rowley story Olson contacte
W.minne.cotHdemocrHtesexposed.com va emal a fllows:
"I don't know who you are but your story is ABSOLUTELY
FALSE. New School Communications does not do any political
work, Buck Huphrey may have pursued (sic) a work with Rowley
PRIOR to his employment at New School but we do not do any
campaig work. I demand a retaction immediately."
Emphasis original. See, Exhibit B, attached herelo.
11. w.minnesotademocratesexposed.com posted Olson's email, m its entirety,
within nineteen minutes of its recipt.
12. On December 29, 2005, Olson's attorey, Steven H. S11ton, cmmenced the current
lawsuit against www.minnesotademocratesexposed.com and your Afant, individually.
13. Upon infomtation and belief, immeiately upon service of the lawsuit upon your
afant Olson or his attorey released a copy of te Summons and Complaint to te Associated
Press.
14. Olson then used his status a a radio and television celebrty to gain appearces on
two radio talk show progams to discuss the lawsuit.
Jirther your Afant saycth not.
Michael B. Brodkorb
Subscribd swor to before
me thi ay of ) , 2006.
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