Electronically FILED by Superior Court of California, County of Los Angeles on 01/31/2020 06:08 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by R. Clifton,Deputy Clerk

20STCV04212
Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: John Doyle

1 LTL ATTORNEYS LLP

Enoch H. Liang (Bar No. 212324)
2 enoch.liang@ltlattorneys.com
Caleb H. Liang (Bar No. 261920)
3
caleb.liang@ltlattorneys.com
4 300 S. Grand Ave., 14th Floor
Los Angeles, California 90071
5 Telephone: (213) 612-8900
Facsimile: (213) 612-3773
6
Attorneys for Plaintiff
7
SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
COUNTY OF LOS ANGELES
9

10

11 MICHAEL SANCHEZ, an individual, CASE NO.

Plaintiff, COMPLAINT
12
vs. Trial Date: None Set
13
DEMAND FOR JURY TRIAL
14 JEFFREY PRESTON BEZOS, an individual,
and GAVIN DE BECKER, an individual, and
15 DOES 1 through 10, inclusive.

16 Defendants.
17

18 Plaintiff Michael Sanchez (“Mr. Sanchez” or “Plaintiff”), by and through his undersigned

19 counsel, complains and alleges against Jeffrey Preston Bezos (“Mr. Bezos”), and Gavin de Becker

20 (“Mr. de Becker”) (collectively, “Defendants”):

21 NATURE OF THE ACTION

22 1. This complaint arises from defamatory statements made by Defendants concerning

23 Mr. Sanchez.

24 2. In connection with the public disclosure of Mr. Bezos’ extramarital relationship with

25 Wendy Lauren Sanchez (“Ms. Sanchez”), Mr. Sanchez’s sister, Defendants falsely stated that Mr.

26 Sanchez was the source of graphic, nude photographs of Mr. Bezos. They additionally peddled
27 rumors to reporters that Mr. Sanchez was involved in a conservative conspiracy with high-profile

28 political operatives, including Roger Stone and Carter Page, and the Saudi government to take down
-1-
COMPLAINT
 1 Mr. Bezos. More recently, Defendants falsely stated that Mr. Sanchez has been shopping around a

2 story about the extramarital affair of Mr. Bezos’ brother, Mark Bezos. These false statements have

3 caused substantial and continuing harm to Mr. Sanchez, including to his professional reputation and

4 his relationships with family members and others.

5 3. Defendants’ smears of Mr. Sanchez initially came on the heels of a story in The

6 National Enquirer, published on January 10, 2019, that publicized the relationship between Mr.

7 Bezos and Ms. Sanchez. Mr. Bezos asked Mr. de Becker to identify the source of the graphic, nude

8 photographs of Mr. Bezos. As Ms. Sanchez’s manager, Mr. Sanchez not only cooperated in the

9 investigation, but also sought to respond to potential public backlash against Ms. Sanchez, her family

10 or her career. Mr. Sanchez never dreamed he would be scapegoated for the graphic photographs

11 because he never had possession of the graphic photographs in question.

12 4. Mr. Sanchez nevertheless became a target in Mr. de Becker’s investigation for Mr.

13 Bezos. When Mr. Sanchez became aware of this, he immediately reached out to Mr. de Becker, Ms.

14 Sanchez and Mr. Bezos to remove any remaining doubt that he might have been the source or part

15 of a conservative-Saudi conspiracy to harm Mr. Bezos. His pleas fell on deaf ears.

16 5. Over the next few months, Mr. Sanchez watched with horror as the false narrative of

17 his alleged betrayal of his sister spread like wildfire, fed by both acts and omissions by the

18 Defendants. Further, Defendants continued to publicly spread to news outlets factually false

19 narratives, including that Mr. Sanchez was the source of the graphic, nude photographs of Mr. Bezos.

20 One such article, which was published by The Washington Post, was reviewed and approved by Mr.

21 Bezos, the owner of The Washington Post, and Mr. de Becker. Defendants also subsequently, and

22 quite falsely, claimed that Mr. Sanchez has been shopping around a story regarding an extramarital

23 affair involving Mark Bezos to multiple media outlets. Neither Defendant has corrected his false

24 statements.

25 6. During that time, news outlets confirmed that the false and defamatory statements

26 were proffered by Mr. Bezos’ representatives, or by Mr. de Becker, himself, and at no time did either
27 Defendant repudiate the false statements, even after Mr. Sanchez reached out to ensure they were

28
-2-
COMPLAINT
 1 aware of the falsity of their statements. Defendants’ actions substantially tarnished Mr. Sanchez’s

2 reputation, caused him severe emotional distress, and were in clear violation of public policy.

3 THE PARTIES

4 7. Plaintiff Michael Sanchez is an individual. He is the brother of Wendy Lauren

5 Sanchez, an Emmy-Award nominated news anchor and media personality whose production

6 company did work for Mr. Bezos’ company, Blue Origin. Mr. Sanchez has acted as Ms. Sanchez’s

7 manager off and on since her first job as a local news anchor. Through Ms. Sanchez’s relationship

8 with Mr. Bezos, Mr. Sanchez became acquainted with Mr. Bezos and Mr. de Becker, which

9 ultimately led to Mr. Sanchez being defamed for allegedly selling graphic, nude photographs to the

10 press, among other things.

11 8. Defendant Jeffrey Preston Bezos is an individual. In 2017, while married to his then-

12 wife, MacKenzie Tuttle, Mr. Bezos began a relationship with Ms. Sanchez. This relationship was

13 publicly revealed in early January 2019 by The National Enquirer. Mr. Bezos is the CEO and

14 President of Amazon.com, Inc., the founder of Blue Origin, and, through Nash Holdings LLC, has

15 owned The Washington Post since 2013.

16 9. Defendant Gavin de Becker is an individual. He is a security specialist and the

17 chairman of Gavin de Becker and Associates. Upon information and belief, Mr. Bezos has been a

18 client of Mr. de Becker for at least twenty-two years, and, in particular, Mr. Bezos asked Mr. de

19 Becker to uncover The National Enquirer’s source for leaked information relating to Mr. Bezos’

20 extramarital affair with Ms. Sanchez. As Mr. Bezos’s security chief, Mr. de Becker, who publicly

21 touts his company as “secret service for famous people,” is directly responsible for the most high-

22 profile breach in CEO security history, regardless of the source or sources behind the leak of Mr.

23 Bezos’s graphic, nude photographs.

24 10. Mr. Sanchez is informed and believes, and thereupon alleges that, at all times

25 material herein, Mr. de Becker was the agent or employee of, and was working in concert with, Mr.

26 Bezos and was acting within the scope of such agency, employment and concerted activity. Upon
27 information and belief, to the extent acts and omissions were perpetrated by Mr. de Becker, Mr.

28 Bezos further confirmed and ratified said acts and omissions.

-3-
COMPLAINT
 1 11. The true names and capacities of Defendants, whether individual, corporate,

2 associate, or otherwise, sued herein as DOES 1 through 10, inclusive, are currently unknown to

3 Plaintiff, who therefore sues Defendants by such fictitious names. Plaintiff is informed and believes,

4 and based thereon alleges, that each of the Defendants designated herein as DOE is legally

5 responsible in some manner for the unlawful acts referred to herein. Plaintiff will seek leave of

6 court to amend this Complaint to reflect the true names and capacities of the Defendants designated

7 hereinafter as DOES when such identities become known.

8 12. Whenever and wherever reference is made in this Complaint to any act or failure to

9 act by a Defendant or Defendants, such allegations and references shall also be deemed to mean the

10 acts and failures of each Defendant acting individually, jointly and severally.

11 JURISDICTION AND VENUE

12 13. Jurisdiction is proper in this Court because, upon information and belief, Mr. Bezos

13 has a residence in Beverly Hills, California. Upon information and belief, Mr. de Becker resides in

14 Studio City, California. In addition, jurisdiction is proper because Defendants’ defamatory

15 statements were intended to, and did, cause damage to Plaintiff in Los Angeles County, California,

16 where Plaintiff resides.

17 14. Venue is proper in this Court because the acts and omissions giving rise to Mr.

18 Sanchez’s claims arose in Los Angeles, California, and at least one Defendant resides in Los

19 Angeles County, California. Cal. Code Civ. Pro. § 395(a).

20 FACTS COMMON TO ALL CLAIMS

21 Mr. Sanchez, Acting in His Capacity as Manager, Signs a Confidential Contract with AMI to

22 Get Ahead of the Story Regarding Ms. Sanchez’s Extramarital Affair with Mr. Bezos

23 15. Mr. Sanchez has been Ms. Sanchez’s manager and most trusted confidante for most

24 of her professional career. For example, pursuant to an agreement dated January 2010, Mr. Sanchez

25 was engaged as Ms. Sanchez’s sole and exclusive personal manager, representative and advisor in

26 all matters involving the entertainment industry. Within the scope of this agreement, Mr. Sanchez
27 was charged with facilitating the growth of Ms. Sanchez’s career, which would include all

28 circumstances with the potential to affect that career, positively or negatively. Mr. Sanchez also
-4-
COMPLAINT
 1 repeatedly demonstrated his primary motive in his actions was protecting his sister and client. For

2 example, he used his experience and relationships to kill true and false stories about Ms. Sanchez’s

3 business and personal affairs -- some of which had the potential to destroy Ms. Sanchez’s career and

4 all of which have remained private to this day.

5 16. Upon information and belief, Mr. Bezos and Ms. Sanchez’s extramarital relationship

6 began when Ms. Sanchez’s production company began working for Mr. Bezos’ company, Blue

7 Origin, in 2017. Ms. Sanchez and Mr. Bezos were guided in their decision to keep their relationship

8 hidden by a psychic in New Mexico, and Mr. Sanchez, as Ms. Sanchez’s brother and manager and

9 Mr. Bezos’s friend, was committed to fulfilling their wishes. As such, from the time that the

10 extramarital relationship commenced to the time it was publicly revealed, Mr. Sanchez was

11 instrumental in covering up first, the existence, and second, the timing of the affair. This included

12 developing and publicizing false narratives (e.g., “they met while working on a documentary” and

13 “both families dealt with this last year,” despite the fact that their spouses had been blindsided by

14 the affair and, as of January 7, 2019, the couple’s children were not aware of the affair). However,

15 pictures of Ms. Sanchez and Mr. Bezos at a July 2018 Blue Origin event, where Ms. Sanchez was

16 standing closer to Mr. Bezos than professionally permissible, eventually surfaced, and news outlets

17 began to ask questions.

18 17. In October 2018, Ms. Sanchez approached Mr. Sanchez about leaking information

19 about her affair with Mr. Bezos to TMZ’s Harvey Levin. Mr. Sanchez advised Ms. Sanchez not to

20 do so until they had informed their respective spouses and children. But, after halting rumors from

21 multiple tabloid reporters, Mr. Sanchez opted to get ahead of the story to limit the backlash against

22 Mr. Bezos and Ms. Sanchez, and to protect Ms. Sanchez’s parents and children, exactly as he has

23 done many times in the past. Mr. Sanchez entered into a confidential deal to cooperate strategically

24 with AMI, the publisher of The National Enquirer, with whom Mr. Sanchez and Ms. Sanchez had

25 cooperated, without money changing hands, for over twenty years. With AMI stating it had multiple

26 sources claiming that Mr. Bezos and Ms. Sanchez were having an affair, Mr. Sanchez agreed to
27 corroborate the existence of the relationship under conditions that would help Mr. Sanchez manage

28 the timing of the story and the way in which the affair was portrayed. This deal included a non-
-5-
COMPLAINT
 1 disclosure agreement, prevented The National Enquirer from publishing any screenshots Mr.

2 Sanchez provided, and gave Mr. Sanchez a significant amount of control over the timing and ability

3 to shape and soften the story during the drafting process. Mr. Sanchez’s motive was to control the

4 timing and narrative of the inevitable scandal coverage in the press, despite false claims of political

5 and financial motives published in outlets such as The Washington Post, Daily Beast, Wall Street

6 Journal and Vanity Fair- claims which were a direct result of the defamatory statements spread by

7 Mr. de Becker at the behest of Mr. Bezos.

9 18. On January 1, 2019, Ms. Sanchez entered into an additional agreement with Mr.

10 Sanchez, whereby she engaged him to provide crisis management, strategic communications, PR

11 and media relations assistance, in anticipation of the upcoming revelations concerning her

12 extramarital relationship with Mr. Bezos. Acting as Ms. Sanchez’s manager, Mr. Sanchez provided

13 Mr. Bezos with talking points for public appearances related to the matter. One such statement was

14 published on January 9, 2019 on Fox.1 Mr. Sanchez also killed and softened devastating “slut

15 shaming” stories about Ms. Sanchez, including one story involving one of Ms. Sanchez’s ex-fiancés

16 Anthony Miller, which was eventually published in The Sun.

17 19. At all times relevant thereto, Mr. Sanchez had been nothing but supportive of his

18 sister and Mr. Bezos, both professionally and personally. Mr. Sanchez’s communications with

19 media outlets during the relevant time was for the benefit of Ms. Sanchez and Mr. Bezos. Both Ms.

20 Sanchez and Mr. Bezos understood this and behaved accordingly. Indeed, out of appreciation for

21 Mr. Sanchez’s efforts on their behalf, Ms. Sanchez and Mr. Bezos promised Mr. Sanchez significant

22 film and television production opportunities and other benefits. This included a promise from Ms.

23 Sanchez and Mr. Bezos that Amazon Studios, owned by Mr. Bezos, would produce the American

24 version of Mr. Sanchez’s successful European Soof film franchise, which Ms. Sanchez’s former

25 producing partner, Dan Friedkin, had also committed to producing upon Ms. Sanchez’s request.

26
27
1
28 https://www.foxbusiness.com/business-leaders/amazon-ceo-jeff-bezos-focused-on-all-
aspects-of-company-despite-divorce
-6-
COMPLAINT
 1 Further, Mr. Sanchez was promised a finder’s fee for locating homes for Mr. Bezos and Ms.

2 Sanchez.

3 20. However, once the relationship between Mr. Bezos and Ms. Sanchez was finally

4 publicized, and Mr. Bezos brought Mr. de Becker on board to conduct the investigation, Mr. Bezos

5 and Ms. Sanchez’s behavior towards Mr. Sanchez changed drastically.

6 The Story on the Relationship Between Ms. Sanchez and Mr. Bezos is Published, and Mr.

7 Bezos Has Mr. de Becker Uncover the Source of the Leaked Photographs

8 21. On January 9, 2019, the relationship between Ms. Sanchez and Mr. Bezos was

9 publicized by The National Enquirer2 and Page 6.3 The National Enquirer article included reports

10 about explicit text messages that Ms. Bezos sent to Ms. Sanchez while they both were still married.

11 The fallout was immediate.

12 22. Mr. Bezos had Mr. de Becker investigate the source of the leaked photographs and

13 directed him to “spend whatever is needed to learn who may have been complicit in the scheme,

14 and why they did it.”4 Upon information and belief, Mr. Bezos authorized Mr. de Becker to speak

15 on Mr. Bezos’ behalf in matters relating to the investigation and to hold himself out as such to third

16 parties, including news and media outlets.

17 23. Soon after Mr. de Becker began to investigate the source of the photographs, Mr.

18 Sanchez became aware that Mr. de Becker’s influence on Mr. Bezos was having a negative effect

19 on Mr. Sanchez’s relationship with Ms. Sanchez, as well as Ms. Sanchez’s relationship with Mr.

20 Bezos. Acting as the dutiful brother and manager, Mr. Sanchez subsequently reached out to Ms.

21 Sanchez, Mr. Bezos, and Mr. de Becker, urging them to keep their heads above the fray so that they

22 could all work towards the common goal of ensuring Ms. Sanchez and Mr. Bezos’ relationship was

23 not ruined.

24
2
25 https://www.nationalenquirer.com/videos/jeff-bezos-divorce-lauren-sanchez-cheating-
affair-photos-exclusive/
26 3
https://pagesix.com/2019/01/09/jeff-bezos-has-been-seeing-former-tv-anchor-lauren-
27 sanchez/
4
28 https://www.thedailybeast.com/jeff-bezos-investigation-finds-the-saudis-obtained-his-
private-information?ref=home
-7-
COMPLAINT
 1 24. Unfortunately, less than two weeks after Mr. de Becker began to investigate the

2 source of the photographs, Mr. de Becker latched onto the idea that Mr. Sanchez, in a conspiracy

3 with his conservative friends like Carter Page and Roger Stone, made sense as the culprit and

4 immediately begin disseminating that to various news sources, in blatant disregard of its falsity.

5 Upon information and belief, Mr. Bezos was aware of Mr. de Becker’s actions and statements, and

6 refused to contradict them. Despite his best efforts, Mr. Sanchez was unable to quell the flow of the

7 defamatory claims because Defendants continued to make and feed them.

8 Defendants Falsely State Mr. Sanchez is the Source of the Leaked Nude Photographs, and

9 Mr. Sanchez Suffers Extensive Reputational Damage

10 25. At the end of January 2019, the Daily Beast had published an article naming Mr.

11 Sanchez as the supposed source who provided Ms. Sanchez and Mr. Bezos’ graphic, nude

12 photographs according to “Amazon Investigators.” Prior to publication, the Daily Beast named Mr.

13 de Becker as the Amazon investigator source. Despite multiple communications from Mr. Sanchez

14 asserting that he would never do such a thing, and especially not to his own sister, Mr. de Becker

15 continued to make this false and defamatory statement. Upon information and belief, not only was

16 Mr. Bezos aware of the falsity of this statement due to direct communications from Mr. Sanchez,

17 but he himself aggressively promulgated it by reviewing and giving advance approval to an article

18 in The Washington Post that repeated the defamatory statements.

19 26. While Mr. de Becker’s initial asserted theory was that Mr. Sanchez had sold out his

20 sister for $200,000, Mr. de Becker soon realized this theory would not hold up because, among other

21 reasons, it was inconceivable that Mr. Sanchez would ruin his relationship with his sister and her

22 current fiancé, the richest man in the world, for financial gain. Indeed, Mr. Sanchez stood to make

23 tens of millions of dollars by protecting Ms. Sanchez and Mr. Bezos’ secrets, particularly since Mr.

24 Sanchez was already promised the production of his film franchise and a lucrative finder’s fee,

25 among other things. While scrambling to manufacture a replacement motivation for Mr. Sanchez,

26 Mr. de Becker began to weave together a convoluted theory linking Mr. Sanchez to an international
27 conspiracy between the Trump administration and Saudi Arabia to take Mr. Bezos down. The only

28 ties Mr. de Becker could find to support his theory were feeble, at best: Mr. Sanchez had recently
-8-
COMPLAINT
 1 been in Dubai for a half-day layover on an unrelated trip, and he is friendly with two players, Carter

2 Page and Roger Stone, in the political field.

3 27. Over the next month, Mr. Sanchez was forced to endure conversations with a variety

4 of reporters while he attempted to futilely assert his innocence, despite the humiliation involved

5 with being repeatedly tied to possessing and then leaking graphic, nude photographs of his own

6 sister. Unfortunately, while Mr. Sanchez was attempting to use his media connections to staunch

7 the flow of false information, Mr. de Becker was reaching out to his own media connections,

8 attempting to convince the New York Post, The Sun, and others, of the false story contained in Mr.

9 de Becker’s Daily Beast article. For example:

10 (a) On January 31, 2019, a reporter from the HuffPost and New York Magazine

11 reached out to Mr. Sanchez, asking him to “confirm that [he’d] been

12 interviewed by Amazon investigators” in relation to the graphic, nude

13 photographs referenced in the Daily Beast article. Mr. Sanchez had not been

14 interviewed by Amazon investigators, including Mr. de Becker.

15 (b) On February 1, 2019, a reporter from The Sun told Mr. Sanchez that Mr. de

16 Becker told her that Mr. Sanchez was the source of the leaks when she

17 contacted him for comment.

18 (c) On February 8, 2019, a reporter from CBS News contacted Mr. Sanchez to

19 say: “We are reporting that investigators for Bezos are looking at you for

20 leaking the materials on their client.”

21 (d) On February 12, 2019, a reporter with the Los Angeles Times offered Mr.

22 Sanchez a chance to comment on its article stating, in relevant part, “[a]

23 source familiar with the investigation… said that Gavin De Becker’s

24 investigation… determined that... Michael Sanchez was allegedly a source

25 for The National Enquirer and had access to the messages.”

26 (e) On February 14, 2019, a reporter with Mail on Sunday, contacted Mr.
27 Sanchez for his version of the story, stating that “De Becker is certainly

28 throwing everything he can at you.”

-9-
COMPLAINT
 1 (f) On February 27, 2019, a reporter from the DailyMail.com reached out to Mr.

2 Sanchez for comment on “Lauren Sanchez ‘cuts all ties with her brother

3 Michael’”.

4 (g) On March 18, 2019, Alexandra Berzon, a reporter for The Wall Street

5 Journal, contacted Mr. Sanchez to confirm he “provided the sexually explicit

6 pictures” as told to her by Mr. de Becker.

7 28. Despite Mr. Sanchez’s best efforts, the majority of the reporters who reached out to

8 him ended up publishing a version of the false Daily Beast story promulgated by the Defendants,

9 some even incorrectly quoting Mr. Sanchez in contravention of Mr. Sanchez’s stance on the subject.

10 One such version was published by The Washington Post, which Mr. Bezos owns. Upon

11 information and belief, Mr. Bezos (along with Mr. de Becker) read and approved The Washington

12 Post article before it was published, despite Mr. Bezos’ equally false public assertions that he has

13 no involvement in the content of any of The Washington Post’s articles.

14 29. Indeed, upon information and belief, the Defendants directed Sarah Ellison, a

15 reporter for The Washington Post, to include statements in the article that were known to be false in

16 order to further smear Mr. Sanchez. For example, Ms. Ellison was aware that The Washington Post

17 allegation that Mr. Sanchez had leaked the confidential information of his then-client, Scottie Nell-

18 Hughes, was false because she knew that Irene Briganti, Fox’s head of public relations, had been

19 behind the leak. This defamatory statement destroyed Mr. Sanchez’s relationship with Ms. Hughes,

20 hurting his reputation in the industry and causing him significant economic harm.

21 30. Indeed, many of the various news connections Mr. Sanchez works with to do his job

22 and earn his living have been reticent to engage with him for his other clients since the allegations

23 that he leaked the graphic, nude photographs broke. All of these actions, including Mr. de Becker’s

24 promulgation of the false information and Mr. Bezos’ refusal to contradict that false information,

25 caused Mr. Sanchez’s reputation to suffer damage on a national scale, as well as causing him to

26 suffer emotional distress. As specific examples:

27

28
- 10 -
COMPLAINT
 1 (a) On February 1, 2019, despite assuring Ms. Sanchez that he was perfectly

2 capable of continuing his job as her manager and representative, Mr. Sanchez

3 was replaced as Ms. Sanchez’s media representative by Judy Smith.

4 (b) On March 20, 2019, Mr. Sanchez was publicly humiliated in a restaurant

5 when Dyan Traynor, a producing partner with whom Mr. Sanchez and his

6 business partner were on the verge of signing a major deal, announced, for

7 the entire restaurant to hear, “you sold out your sister for $200,000 and no

8 one in Hollywood will work with you.” After this, Ms. Traynor reached out

9 to Mr. Sanchez’s business partner behind Mr. Sanchez’s back and offered to

10 help with his career so long as he shunned Mr. Sanchez.

11 (c) On September 20, 2019, Page Six published a 1988 photo of Ms. Sanchez in

12 a bikini, for which it was alleged that Mr. Sanchez had stolen the photo and

13 then sold it, adding fuel to Defendants’ false and defamatory statements.

14 (d) On or about November 1, 2019, a New York Post reporter called Mr. Sanchez

15 to inform him that Mr. de Becker was "freaking out" about whether or not he

16 had testified before a grand jury. The reporter agreed with Mr. Sanchez that

17 “it was strange” Mr. de Becker was still calling reporters to attack Mr.

18 Sanchez.

19 (e) On or about November 2, 2019, Mr. Sanchez received a call from his mother,

20 angry for “leaking stories about Mark Bezos' extramarital affair.”

21 31. These are just a few examples of many that demonstrate the extent Mr. Sanchez has

22 been shut out of his own family, as well as business opportunities, as a result of the Defendants’

23 actions and omissions. To this day, Mr. Sanchez is estranged from his family as a result of the

24 Defendants’ illegal acts.

25 FIRST CAUSE OF ACTION

26 (Defamation, Against All Defendants)

27 32. Mr. Sanchez realleges and incorporates herein by reference the allegations contained

28 in the preceding paragraphs.

- 11 -
COMPLAINT
 1 33. Defendants repeatedly made false and defamatory statements concerning Mr.

2 Sanchez, and still continue to do so. These false and defamatory statements include, without

3 limitation, that (i) Mr. Sanchez leaked graphic, nude photographs of Mr. Bezos; (ii) Mr. Sanchez

4 was part of a conservative-Saudi conspiracy to take down Mr. Bezos; (iii) Mr. Sanchez stole, then

5 sold photographs of Ms. Sanchez; and (iv) Mr. Sanchez shopped around the story of Mark Bezos’

6 extramarital affair to multiple media outlets.

7 34. These false and defamatory statements were made to persons other than Mr. Sanchez,

8 including several major news and media outlets. The people who heard the statements reasonably

9 understood that the statements were about Mr. Sanchez.

10 35. Defendants knew that the statements were false or failed to use reasonable care to

11 determine the truth or falsity of the statements.

12 36. The publication of the false and defamatory statements was not privileged.

13 37. The statements tended to injure Mr. Sanchez in his occupation, and Mr. Sanchez in

14 fact suffered harm to his property, business, profession and occupation as a consequence of

15 Defendants’ misconduct.

16 38. Defendants’ actions described herein were done with a conscious disregard for the

17 rights of Mr. Sanchez and with the intent to vex, injure and annoy Mr. Sanchez such as to constitute

18 oppression, fraud or malice under California Civil Code section 3294. As such, Mr. Sanchez is

19 entitled to punitive damages in an amount appropriate to punish and make an example of

20 Defendants.

21 SECOND CAUSE OF ACTION

22 (Intentional Infliction of Emotional Distress, Against All Defendants)

23 39. Mr. Sanchez realleges and incorporates herein by reference the allegations contained

24 in the preceding paragraphs.

25 40. The deliberate conduct described above, including scapegoating Mr. Sanchez and

26 alienating him from his family and professional colleagues, is extreme and outrageous, exceeding
27 the bounds tolerated in a civilized society.

28
- 12 -
COMPLAINT
 1 41. Among other consequences, Defendants’ illegal acts subjected Mr. Sanchez to an

2 FBI raid at his house in full view of his neighbors, to backlash from business associates, friends and

3 family who believed the lies spread by Defendants, and to humiliation and harassment when he was

4 forced to publicly defend himself against the onslaught of allegations. Defendants further

5 humiliated Mr. Sanchez and caused him distress by repeatedly spreading the accusation that he was

6 the source of the private photographs as well as news of Mark Bezos’ affair. Defendants’ conduct,

7 including Defendants’ refusal to cease or correct the defamatory statements, was outrageous and

8 intended to cause Mr. Sanchez emotional distress. Defendants acted with blatant disregard of Mr.

9 Sanchez’s rights and deliberately engaged in outrageous and severe conduct intended to cause Mr.

10 Sanchez emotional distress.

11 42. Defendants knew and should have known that their conduct would cause Mr.

12 Sanchez to suffer emotional distress, as well as negatively impact his career, reputation, and future

13 job opportunities. As a proximate result of the acts of Defendants, and each of them, Mr. Sanchez

14 suffered economic damages, including lost wages, and other compensatory damages in an amount

15 to be determined at trial. As a further proximate result of the acts of Defendants, and each of them,

16 as alleged above, Mr. Sanchez has suffered severe emotional and mental distress in an amount to be

17 determined at trial.

18 43. Defendants’ actions described herein were done with a conscious disregard for the

19 rights of Mr. Sanchez and with the intent to vex, injure, and annoy Mr. Sanchez such as to constitute

20 oppression, fraud or malice under California Civil Code section 3294. As such, Mr. Sanchez is

21 entitled to punitive damages in an amount appropriate to punish and make an example of

22 Defendants.

23 / / /

24 / / /

25 / / /

26 / / /
27

28
- 13 -
COMPLAINT
 1 PRAYER FOR RELIEF

2 WHEREFORE, Mr. Sanchez prays for judgment as follows:

3 (a) For general, compensatory, reputation and special damages, including for lost clients

4 and business opportunities and lost potential clients and business opportunities;

5 (b) For Court orders mandating Defendants to issue corrective statements to the

6 defamatory statements;

7 (c) For prejudgment interest at the maximum legal rate;

8 (d) For an award of attorneys’ fees, costs and expenses incurred herein;

9 (e) For punitive damages in an amount appropriate to punish and make an example of

10 Defendants for their conduct; and

11 (f) For such other and further relief as the Court deems just and proper.

12

13

14 DATED: January 31, 2020 LTL ATTORNEYS LLP

15

16
By
17 Enoch H. Liang
Caleb H. Liang
18 Attorneys for Plaintiff Michael Sanchez
19

20

21

22

23

24

25

26
27

28
- 14 -
COMPLAINT