Of iie CXiaT-OMRT OF THE T THE VIRGINIA: ALBEMARLE CIRCUIT COURT IN THE CIRCUIT COURT FOR THE COUNTDATOF ALBEMARILEL5: 59:53 TESTE: _ DEVIN G. NUNES ) CLERK/DEPUTY CLERK ) Plaintiffs, ) ) v. ) Case No. s ) ) TRIAL BY JURY THE MCCLATCHY COMPANY ) IS DEMANDED ELIZABETH A. “LIZ” MAIR, ) ) -and- ) ) MAIR STRATEGIES, LLC ) ) Defendants. ) a) COMPL. Plaintiff, Devin G. Nunes, by counsel, files the following Complaint against defendants, The McClatchy Company (“McClatchy”), Elizabeth A. “Liz” Mair (“Mair”), and Mair Strategies, LLC (“Mair Strategies”), jointly and severally. Plaintiff seeks (a) compensatory damages and punitive damages in an amount not less than $150,000,000, (b) prejudgment interest on the principal sum awarded by the Jury from May 23, 2018 to the date of Judgment at the rate of six percent (6%) per year pursuant to § 8.01-382 of the Virginia Code (1950), as amended (the “Code”), injunctive relief, and (d) court costs ~ arising out of defendants’ defamation per se and common law conspiracy.I. INTRODUCTION 1. This is a case about character assassination and @ public company that weaponized its powerful pen and used it as a terrible sword. 2. Throughout 2018, McClatchy and its reporter, MacKenzie Mays, acting in concert with a Virginia political operative and her handlers, schemed to defame Plaintiff and destroy his reputation, ‘The central purpose of the scheme was to interfere with Plaintiff's Congressional investigation of corruption by the Clinton campaign and alleged “collusion” between the Trump campaign and Russia during the 2016 presidential election.’ Using the enormous power of McClatchy’s nation-wide resources, McClatchy ‘ MeClatchy is well-known for publishing false stories meant to advance the false narrative that associates of Donald J. Trump colluded with Russia to hack the 2016 presidential election. In April 2018, for instance, McClatchy published an article representing that Justice Department Special Counsel Robert Mueller had evidence that Donald Trump’s lawyer, Michael Cohen, secretly visited Prague during the 2016 presidential campaign. [https://www.meclatchyde.com/news/politics-government/white- house/article208870264.htm! (“Mueller Has Evidence Cohen Was In Prague In 2016, Confirming Part Of Dossier”)]. The McClatchy story was presented as confirmation of an essential claim of the “Steele dossier” (a collection of allegations of collusion between Trump associates and Russia that were manufactured by a former British spy, Christopher Steele, cited in the most prominent accusations against the President’s team). According to the Steele dossier, Cohen was a leading figure in the Trump-Russia collusion/conspiracy. The dossier represents that Cohen went to Prague in 2016 to have a conspiratorial meeting with Russian officials about the Kremlin’s campaign to hack the 2016 USS. presidential election. McClatchy’s story about Cohen was not confirmed by any other media outlet, and Mueller’s indictment of Cohen did not allege Cohen had this meeting in Prague or that he conspired with Russians at all to hack the U.S. election McClatchy further attempted to defend the dossier’s veracity with a follow-up piece claiming Cohen's cell phone had sent signals off cell towers in the Prague vicinity. huips://www.meclatchydc.con/news/investigations/article219016820.htm! (“Cell signal puts Cohen outside Prague around time of purported Russian meeting”)]. Once again, no other media outlet could confirm the McClatchy story, which, like the previous story, was thoroughly contradicted by both Mueller’s Cohen indictment and Mueller’s final Report. {see htips://assets.documenteloud,org/documents/5779700/AG-March-24-2019-Letter-to- House-and-Senate.pdf (“The Special Counsel’s investigation did not find that the ‘Trump campaign or anyone associated with it conspired or coordinated with Russia in its efforts to influence the 2016 U.S. presidential election.”)].and its co-conspirators relentlessly attacked Plaintiff both in print and digitally — falsely and maliciously accusing Plaintiff of horrible crimes and improprieties, falsely attributing to him knowledge he did not have, implying that he was involved with cocaine and underage prostitutes, and imputing to Plaintiff dishonesty, unethical behavior, lack of integrity, and an unfitness to serve as a United States Congressman. Defendants’ statements were knowingly false and grossly offensive. They evince a heedless, palpable and reckless disregard for the truth. 3 True and honorable journalists serve a vital role in our republic, informing the American people about crucial matters that affect their lives and the country at large ‘The Defendants in this case abandoned the role of journalist, and chose to leverage their considerable power to spread falsehoods and to defame the Plaintiff for political and financial gain. IL. PARTH 4, Plaintiff, Devin G. Nunes (“Nunes” or “Plaintif™), is a citizen of California, Born October 1, 1973, Nunes has served inthe United States House of Representatives since 2003. He currently represents California's 22" Congressional District, which is located in the San Joaquin Valley and includes portions of Tulare and Fresno Counties. He and his wife have three daughters. He is the author of the book, Restoring the Republic, which was published in September 2010. Nunes was bom in Tulare, California, His family is of Portuguese descent, having emigrated from the Azores to California, From childhood, he worked on a farm that his family operated in Tulare County for three generations. Nunes raised cattle as a teenager, used his savings to begin a harvesting business, and then bought his own farmland with his brother.