Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 1 of 91 PageID #: 41
Russell Greer
6337 South Highland Dr.
#209
Holladay, Utah 84121
801-895-3501
russmark@gmail.com
Pro Se Litigant
IN THE UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF TENNESSEE, NASHVILLE DIVISION
RUSSELL G. GREER,
Plaintiff
V.
TAYLOR A. SWIFT,
Defendant
MOTION FOR ENTRY OF DEFAULT
FINAL JUDGEMENT
Case No.: 3: 18-cv-003 94
Presiding Judge: Aleta A. Trauger
Magistrate Judge: Alistair Newbern
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Plaintiff, Russell G. Greer, who is representing himself - for now - in this matter, moves
this Court for entry of a default judgment as to defendant Taylor Alison Swift, upon the
Complaint heretofore filed and served upon the defendant, by service upon defendant's law firm,
Venable, LLP, in accordance with the provisions of Rule 55(b )(2), Federal Rules of Civil
Procedure, and in support thereof shows the Court the following.
I. FACTUAL AND PROCEDURAL BACKGROUND
A. Plaintiff's Allegations
Plaintiff filed the Complaint on April 25th, 2018, alleging that Defendant Taylor Swift
failed to use disclaimers that warned that her publicity stunts and statements (made in
commercial and non-commercial contexts) were not meant to be sweeping advances, and that her
stunts did not create subtle invitations or representations for Plaintiff ( or anybody else) to invest
time and money to have similar success, as shown in her publicity stunts and statements. Compl.
,r,r 71-81. Such a duty is warranted, given Swift's public figure status; given that Swift is the
owner of her intellectual property and based upon public policy, which consists of federal laws
and regulations and case law and several well-regarded case studies.
B. Procedural History Related to Defendant's Default
Plaintiffs process server served defendant's law firm, Venable LLP, with the summons
and Complaint on August 7, 2018. See Proof of Service, Doc. 9 (August 14, 2018). Under
Federal Rule of Civil Procedure 12(a)(l)(A)(i), the original deadline for Venable LLP to respond
to the Complaint was August 28, 2018. That date has since passed, with no reply from defendant.
Venable LLP was the correct firm to serve, as they have openly represented Defendant Taylor
Swift in various matters and referred to himself as Taylor Swift's personal attorney. The attorney
who represents Swift is William Briggs. Months before Venable LLP was served, Plaintiff left
voice messages with Briggs, other attorneys at Venable LLP, Swift's direct managers and
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Swift's publicist. Further, Plaintiff emailed said representatives with Waivers of Service. Exhibit
A. No response was ever given to Plaintiff.
II. ARGUMENT
A. Standard for Entering Default Judgment
Under Federal Rule 55(b)(2), this Court may enter a default judgment against a defendant
that has failed to defend. Entry of a default judgment is appropriate if the defendant's liability is
well-pled in the complaint and the defendant has failed to paiticipate in the litigation in good
faith. Eagle Hosp. Physicians v. SRG Consulting, 561 F.3d 1298, 1307 (11th Cir. 2009) (has
been cited in the 6th Circuit, see Bradley J Delp Revocable Trust v. MSJMR 2008
IRREVOCABLE TRUST, No. 16-3321 (6th Cir. 2018).
B. Plaintiff's Well-Pied Allegations Support Entry of a Default Judgment
1. Count I: Failure to Warn
I. Proving Damages
In seeking a default judgment, Plaintiff bears the burden of proving damages. He may do
so through documentary evidence showing the amount and calculation of damages; an
evidentiary hearing is unnecessary, particularly where the evidence before the Court is not
controverted. CompuServe, Inc. v. Patterson, 89 F.3d 1257 (6th Cir. 1996).
II. Duty Established
In order for Plaintiff to show damages, Plaintiff seeks to reiterate the duty of Taylor
Swift, as mentioned in the Complaint, and give a more broader layout of the duty he argues Swift
should have. A duty is comprised of multiple factors. The courts of Tennessee have held, "When
the existence of a particular duty is not a given or when the rules of the established precedents
are not readily applicable, courts will tum to public policy for guidance. Doing so necessarily
favors imposing a duty ofreasonable care where a defendant's conduct poses an unreasonable
and foreseeable risk of harm to persons or property. When conducting this analysis, the courts
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have considered, among other factors: (1) the foreseeable probability of the harm or injury
occuil'ing; (2) the possible magnitude of the potential harm or injury; (3) the importance or social
value of the activity engaged in by the defendant; (4) the usefulness of the conduct to the
defendant; ( 5) the feasibility of alternative conduct that is safer; ( 6) the relative costs and burdens
associated with that safer conduct; (7) the relative usefulness of the safer conduct; and (8) the
relative safety of alternative conduct." Satterfield v. Breeding Insulation Co., 266 S.W.3d 347,
365 (Tenn. 2008). These seven factors can be applied to the cuil'ent case.
Duty also depends, in part, on whether the victim "falls within the.class of people who
were foreseeably at risk of being harmed." Smith v. Hope Vil!., Inc., 481 F. Supp. 2d 172, 193
(D.D.C. 2007); State Dep 't of Corrs. v. Cowles, 151 P.3d 353, 363 (Alaska 2006) (imposing a
duty in a claim by the family of a decedent killed by a parolee, "only where officials know, or
reasonably should know, that a parolee poses a danger to a ... 'victim class"'). Comparatively,
Plaintiff belonged to a class of people directly connected to Swift: her fan base and social media
followers. Swift should have reasonably known that not having any disclaimers in regards to
publicity stunts or statements done commercially (like a music video nail'ation) or noncommercially
(like crashing a wedding) could have harmed fans and followers like Greer who
believed said stunts created representations of having similar success.
III. Public Policy Supports a Duty.
As Satterfield mentioned, public policy is to be looked at to establish a duty. Hanberry v.
Hearst Corp., 276 Cal. App. 2d 680, 81 Cal. Rptr. 519 (1969) (magazine found liable for using
incoil'ect stamp of approval, based upon public policy considerations). "Public policy ... must be
well defined and dominant, and is to be ascertained by reference to the laws and legal precedents
and not from general considerations of supposed public interests." Muschany v. United States,
324 U.S. 49, 66 (1945). Several laws and precedents help create public policy for this case.
Federal laws and regulations state that celebrity endorsers must use disclaimers with products
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that they advertise and in social media postings related to any paid marketing or products that
they endorse. See In re Cooga Mooga, 92 F.T.C. 310,321 (1978) (Singer Pat Boone was scorned
by the FTC for failing to make a "reasonable inquiry into the truthfulness" of his acne
medication promotion).
Additionally, the Federal Trade Commission frequently warns celebrities of their social
media content and advertising. All 47 Celebrities Who Received Warnings From the Government
About Their Instagrams. Cosmopolitan (2017).
(http:/ /yvw,v .cosmopolitan .com/entertainment/celebs/a9624256/celebri ties-I ist-ftc-warningssponsored-
social- media/). In fact, according to FTC Endorsement Guides, ifthere is a "material
connection" between an "endorser and an advertiser - in other words, a connection that might
affect the weight or credibility that consumers give the endorsement - that connection should be
clearly and conspicuously disclosed, unless it is already clear from the context of the
communication." FTC Staff Reminds Influencers and Brands to Clearly Disclose Relationship.
FTC.gov. (2017). (
https://www.ftc.gov/nev-,1s-events/press-releases/2017 /04/ftc-staff-remindsinfluencers-
brands-clearly-disclose). The FTC Guides expressly state that use of an individual's
name, signature, likeness, or other identifying personal characteristics, even without
accompanying verbal statements, may cause consumers to believe that the entire message
reflects the "opinions, beliefs, findings, or experience" of the endorser. These guides serve as
great public policy to this case, as it shows influencers are already expected to disclose important
information, to not mislead consumers or fans; those who follow after their words and image. In
the commercial stunts and marketing that Swift did that influenced Greer, Swift had no
disclosures. Her non-commercial publicity stunts lacked disclaimers as well.
Further, precedent, which is apart of public policy, has held that property owners and
owners of products can be held liable for failing to warn of "hidden dangers". Rich v. US, 119 F.
3d 447 (6 th Cir. 1997). Swift's publicity and image is her product and property. Courts have
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described the identity of a celebrity as "the fruit of his labors and a type of property." Uhlaender
v. Henricksen, 316 F. Supp. 1277 (D. Minn. 1970). Swift maintains her image and is allowed to
sue for infringement of her image. In contrast, it should be expected that she is liable for any
hidden dangers with her property, like other property owners. Swift induces fans and followers.
She has an international influence. For the past several years, Swift has used her influence to
donate to hurricane victims, donate to gun control groups and visit the sick and afflicted. Swift
shies away from controversial topics such as politics and religion, in an effort to maintain her
property and image. The hidden danger with her property and representations is the amount of
sway and influence behind them, with no clarifications or disclaimers attached to the marketing
or to her opinions, which can become fact. Given her level of influence, "statements of opinions"
can be seen as "statements of fact". Shirreffs v. Alta Canyada C01p., 8 Cal. App. 2d 742, 48 P.
2d 55, 58 1935). See also, Not Just Words, But Hidden Promise: FTC. Studies Ad's Non-Verbal
Message, L.A. Times (Oct. 16, 1978).
IV. Duty Extends to Third Parties
The 6th Circuit has held that it is not required for a plaintiff to have "a link such as
privity, a bond approaching privity, or a fiduciary relationship with the defendant in order for a
duty ofreasonable care to exist." Molecular Tech. Corp. v. Valentine. 925 F. 2d 910, 916 (6 th
Cir. 1991). Without limiting its holding to a particular group, "the court reiterated the welldeveloped
negligence rule that a defendant owes a duty of care to all those who are foreseeable
as a potential class of injured persons .. . and all those third parties who defendant knows will
rely on the information." Cleveland Indians Baseball v. New Hampshire Ins., 727 F.3d 633 (6th
Cir. 2013). Examples abound of well-cited cases that have been used in the 6th Circuit to
establish a duty to third parties: Glanzer v. Shepard, 233 N. Y 236, 135 N.E. 275 (1922) (a seller
of produce hired the defendant, a public weigher, to certify the weight of beans, which the
plaintiff purchased. The defendant negligently certified the weight, and the purchaser, who was
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harmed as a result, prevailed in a suit against the weigher); Hempstead v. General Fire
Extinguisher Corp., 269 F. Supp. 109 (D. Del. 1967) (a defendant placed its seal of approval on a
fire extinguisher which exploded during use); Hanberry v. Hearst, which was cited in the
Complaint.
V. Defendant Taylor Swift May Be Playing a Character
As a persuasive factor in deciding Duty and Damages, it can easily be argued that
Defendant Taylor Swift is playing a character. Publicity stunts Swift has done may have been
done for show, that she doesn't actually mean anything she says, and thus warrants a disclaimer.
This is readily proven by the bio on Swift's Instagram account, which reads: "The old Taylor
can't come to the phone right now." Exhibit B. Below the statement is a link for tickets to her
concerts, which clearly shows that her profile is a business account. This character argument is a
similar one used as a defense with infamous conspiracy theorist Alex Jones, whose lawyer
argued that Jones was a "performance artist playing a character" and that he didn't mean
controversial statements that he had made. Info Wars' Alex Jones Is a Performance Artist, 'His
Lawyer Says in Divorce Hearing. NBC News. (2017).
(
https://www.google.com/amp/s/www.nbcnews.com/news/amp/ncna747491). If Swift is just
acting and faking with her stunts, she needs to disclaim so. There are no disclaimers with any of
her postings or stunts, etc.
VI. Breach of Duty
With the duty established in the above mentioned points, Swift breached her duty by
failing to use disclaimers. As shown in Exhibit B, there are no disclaimers in any of her posts or
on her profile, as her profile is clearly for marketing her product, which is her music and her
likeness.
A. Commercial Publicity Stunts
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There were no disclaimers in her commercial publicity stunts, like for the promotion
of a movie, which she wrote the theme song for. She does a voiceover in a
promotional for the movie and describes the protagonist's struggles of trying to get
into the entertainment industry "inspiring". This spoken representation done for
commercial marketing, swayed Greer to believe that Swift would be open to his
efforts and story of struggles of living with a disability, trying to get into the
entertainment industry. Her statements made it seem that she was open to all kinds of
inspiring stories. Exhibit C. Similarly, with her music video, "New Romantics",
Swift does a voice over, accompanied with a montage of waving fans, and says, "The
fans are the best part of this tour." Clearly done for promotion of her music and
product, this influenced Greer to believe that she would be welcomed to his efforts
because he was a fan. Exhibit D. Since her statements were made commercially, in
promotion of her movie and music, her statements of opinion became statements of
fact.
B. Non-Commercial Stunts
Swift has done many other publicity stunts, which weren't commercial in nature, but
because they still created powerful representations and because they were posted to
Swift's business profile, they swayed Greer and she breached her duty to have
disclaimers, as they created representations of fact. One stunt was a photo of Swift
who had been invited to a non-famous person's wedding and she accepted. This
created a representation that Swift was open to having fans reach out to her. Exhibit
E. On another occasion, which was carried by the news, Swift paid for her
background dancer's niece's hospital bill. This created a representation that Swift
was a kind, giving person. Exhibit F. On another occasion, Swift accepted prom
invites from high school boys. Swift has had a long, documented history of swaying
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and creating representations without any disclaimers cautioning anybody she may
have swayed. Lack of commercial contexts with these stunts shouldn't matter
because many non-commercial groups and persons have disclaimers with any charity
that they do. For instance, with legal pro bono work, law firms will have criteria
listed as to what they consider. Many charity organizations will have disclaimers
with what they will help out with and what they won't.
Both contexts of commercial and non-commercial stunts show that Swift's words, actions
and likeness have lacked adequate disclaimers to have prevented the harm Plaintiff has suffered.
Swift breached her duty to have disclaimers, given public policy, precedent and the amount of
influence that Swift has.
VII. Swift Should Have Foreseen the Harm
Swift should have easily foreseen that with one hundred and eleven million followers on
her social media, at least one follower would have been swayed by her commercial and noncommercial
stunts and would have suffered harm by reaching out to her and discovering that her
representations (verbal and non-verbal) were not what she intended them to be. Swift should
have foreseen that disclaimers would prevent followers from suffering harm. Even with the chain
reactions that followed, Swift should have foreseen that trolling is real and that there are those
who prey upon others with unique views and said trolls would harass certain people.
One way that Swift could have foreseen harm is how people try "going viral", which
means a person posts a video with the hopes that it gets a lot of views and clicks. Swift has
noticed several people this way. Unfortunately, several people who try going viral, end up
having their plights end up on troll sites; sites where people around the globe make it a sport to
belittle and bully random strangers. Swift apparently advocates against bullying and so she is
aware of trolling. This is what happened with Plaintiff. Swift should have foreseen that by not
utilizing disclaimers, people would try getting her to see their plights and have their stuff end up
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on troll sites. These are all harms that Swift could have easily foreseen. Swift's breach of duties
listed are the proximate cause of Plaintiffs damages.
VIII. Damages
The 6th Circuit has held that a negligent defendant is generally "liable for all injuries
resulting directly from his wrongful act, if the damages were the legal and natural consequences
of his conduct and might have reasonably been anticipated." Cleveland Indians Baseball v. New
Hampshire Ins., 727 F.3d 633 (6th Cir. 2013). Greer now presents all damages resulting from
Swift's breach of duty. Many of the damages shown are lay outs and glances of damages, as that
is what a default is for: is to show basic evidence to support his claims. CompuServe, Inc. v.
Patterson, 89 F.3d 1257 (6th Cir. 1996). If a default judgement is rejected and a trial is instead
warranted, discovery through subpoenas, statements and more pages of damages can show more
in-depth damages.
General Compensatory Damages:
A. Economic Loss
Plaintiff has lost four years of his life being entangled in this mess and the representations
of Taylor Swift. As stated in his Complaint, he relied on Swift's representations starting in 2014.
He dedicated his time, money and fundraising efforts into producing a song ABOUT Taylor
Swift; a gift made in reliance on her previous stunts with the hopes that he would have the same
success that others had. It wasn't his best work, due to hiring fraudulent production companies,
but it still showed genuine effort. Exhibit G, Exhibit Hand Exhibit I. It's apart of having a
disability that motivated Greer to undertake his efforts; of wanting to be accepted and helped by
somebody so he could be so much more than the limitations that he lives with. His invigoration
was sparked by being denied on a reality show and hitting walls with agents in the industry. Put
simply: he saw her help others and saw her make commercialized representations that she would
be open to such an ambition. At the very least, Greer hoped for acknowledgment.
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Greer burned bridges with his college paralegal program director who gave Greer an
ultimatum to choose between flattering a celebrity or being a legal professional. The program
director thinks of Greer as unprofessional now and doesn't help him find jobs, as an alumnus of
the college. Former college legal professors of Greer avoid him. Greer's first professional job,
TraskBritt, fired Greer, in part, because they felt it was unprofessional for him to reach out to
Swift. Charly Doe, office manager of the firm, terminated Greer. EXHIBIT J. Further, no other
entertainment people want to work with Greer, due to these series of events. Agents show
interest in Greer and then they go silent, like they discover this horrible person, when Greer isn't
a bad person. Greer is possibly blacklisted from Hollywood because of this entire incident.
Economic damages also extend to the next point of damages. Economic damages are recoverable
in a negligence third party action, per Circuit case law. Id.
B. Reputational Damages
Greer's largest point of damages is a ruined reputation. Besides being let go from jobs
and ruining his academic connections early on in relying upon Swift's representations, Greer's
efforts began to catch the attention of bullies and cretans, commonly referred to as "internet
trolls", who began to harass Greer through social media, calling him "too ugly to see Taylor".
They began creating posts on Reddit of Greer through the "Sad Cringe" section. One of the first
posts created of Greer on Reddit was a post saying, "The only thing Russell Greer and Taylor
Swift have in common are that they both play victims." Exhibit K. The defamation only
increased thereafter. Since his efforts caught the attention of trolls, they use any sort of
misstatement Greer makes against him or they fabricate events that never happened or they
exaggerate who Greer is. The trolls began harassing Greer's place of employment, Patent Law
Works, and started emailing lies about Greer. The Human Resources manager wouldn't hand
over evidence for this Motion, but Plaintiff declares under penalty of perjury that one email sent
to the HR manager, as told to Greer by the manager, was an email that had a picture of a phone
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that had pornography on it, which said, "Russell has been looking at porn on his work phone."
The email was a lie because Greer didn't have a work assigned phone. Anonymous people had
set out to destroy Plaintiff Greer. If evidence or testimony is needed in the form of a subpoena, if
this proceeds instead to a trial, it was told to Greer that hundreds of emails were sent to his
former HR manager, with lies about Greer. The manager, Jennifer Nakao, even told Greer that he
"had made some enemies." Greer was bewildered because he hadn't done anything wrong.
Around this time, Taylor Swift's agents were negligent with handling Greer's musical
gift. They believed that Greer was trying to get Swift to have her do a song. They somehow
refused to understand that he was trying to give her a gift - the same kind of gift she had
received in the past. What is important to understand is that this gift wasn't a cover of one of
Swift's songs; it wasn't an instrumental version of her song; it was an original song that was
meant to be a gift that talked about how Taylor's music had helped him. They mentioned
contracts and unsolicited song submission policies and how Swift writes all of her own music,
which is irrelevant and proved negligence because Greer was trying to give a gift, thus none of
that mattered because there's a difference between a gift for her to have and a song for her to do.
At the very least, he wanted his story of trying to overcome his disability passed on. Somehow,
the agents didn't understand this, and for some reason, it brought out trolls who embarked on a
mission to destroy Plaintiff Greer. Exhibit L. It would have killed Greer to know that he gave
his all after relying on Swift's representations and that she never saw it, especially in light of the
harassment. So Greer looked for other ways to get it to Swift: he contacted associates of hers, her
record label and her IP law firm. Nobody seemed to want to help him.
After studying cases on Google Scholar, Greer found a case for "vicarious liability",
which stated that suing under vicarious liability "reflects the likelihood" that an employer will
work a problem out. The Restatement (Third) of Agency 2.04. With Swift's representations, she
portrayed that the likelihood of success of a problem being resolved would be realistic if she saw
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said problem. This was reinforced by Exhibit F: her dancer showed her a problem that he had
and she fixed it. Also, Swift has been the subject ofridiculous lawsuits and she has responded to
several lawsuits. So Greer relied on this and sued her for the conduct of agents, as explained in
the Complaint. When Greer told one of his friends what he was doing, Greer began crying
because he didn't know of any other way that she would see his efforts. Greer filmed two videos
of himself and sent to Swift's agents, explaining the purpose of the lawsuit. The second video
was made to clarify misstatements that he had made in the first video. Also, the lawsuit was
citing a state statute that required registered agents to act in the same competence and manner
that other agents would act because Greer believed that any other agents would have taken the
time to learn that it was a gift Greer was trying to pass along and not a song for her to do. Utah
Code 75-9-l l 4(2)(C). Thus, the lawsuit was not frivolous.
Weeks later, Swift's lawyer in Utah, Greg Skordas, wrote a motion to dismiss and
according to the legal document, Taylor Swift was perturbed by Greer. Greer was crushed. This
is another example of Swift's representations leading Greer on and causing him to engage in
action based on her statements and likeness. Without these representations that Swift has made,
there would have been no "likelihood" of a problem being resolved, thus the lawsuit would have
never been filed; Greer would have never gone to extremes to try fighting for the efforts he
worked on, and Greer would have no reason to have had complaints with the agents. Ironically.
Swift slandered Greer for him relying on her representations. Greer has to take the words in the
motion as true, as the lawyer and other professionals wouldn't have lied about words Swift said.
ExhibitM.
As iterated in the Complaint, that previous lawsuit does not preclude claims here, as
Greer is arguing claims based on Swift, not her agents, which is what the small claims lawsuit
argued. "Collateral estoppel prevents re litigation of factual matters that were fully considered
and decided in a prior proceeding. Thus, collateral estoppel operates to prevent repetitive
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litigation." Tipler v. E. I du Pont de Nemours and Co., 443 F.2d 125, 128 (6th Cir. 1971). No
arguments for "duty to warn", failing to warn or anything based on Swift's conduct were ever
brought forth in the lawsuit. Also, the claim was filed in small claims justice court, not a state or
federal court, so the judgement (which was based mostly on lack of jurisdiction) wouldn't affect
this case even though no similar claims are brought here. " ... Requires a federal court to accord a
state court judgment the same preclusive effect that the judgment would have in a state court."
See Marrese v. American Academy of Orthopaedic Surgeons, 470 U.S. 373,384, 105 S.Ct. 1327,
84 L.Ed.2d 274 (1985). Justice court is different than State court and thus no preclusion applies.
Lastly, rulings are found to be invalid when it is found that judges have a bias. Several
witnesses saw, and are willing to attest to if this current case goes to trial, that Judge Havas of
the small claims court of Salt Lake City was hostile and intolerant to Greer. The judge didn't let
Greer show any evidence. The judge laughed at Greer. The judge rolled his eyes at Greer. The
case was very embarrassing because nobody understood the vicarious arguments even though
Greer presented solid claims of the agents being obtuse with handling the communication. Greer
had evidence of emails telling the agents how he thought it was unfair for her to accept gifts from
random people, but not from him, which proves he was trying to give her a gift and not that a
song for her to do. EXHIBIT Z. The judge wouldn't let Greer show this. The evidence would
have helped show what Greer was trying to do and display the agents' negligence and shown that
Swift was liable for their negligence because she failed to work with them on instructions on
accepting gifts. There seemed to be communication conflicts between the agents and Swift.
Newspapers and news stations around the country and the globe picked up Greer's
lawsuit and purposely smeared Greer. The news purposely omitted the "vicarious liability"
arguments and failed to mention Greer's disability or other motivating factors that would have
not painted Greer into a raving lunatic. But the newspapers were fueled by Swift's slander in the
motion and the hostile tone that the lawyer had. A newspaper in the United Kingdom called
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Greer "entitled". A Utah News station smeared Greer as "frivolous". Exhibit N. The news
refused to correct statements they had published or even refused to reach out to him for
comment, which furthers the smear. They put in false information about Greer, such as he was
suing her to go on a date. Nowhere in the lawsuit was there a mention of a date, However, in the
first video Greer sent, he made a misstatement and said that he worked on the song with the
hopes he could have similar success as other people, such as going on a date. He felt that this
was unclear and so he made a second video which clarified what he meant. The news didn't
mention this and deliberately put that lie in their newspapers, which is defamation. The hostile
news attracted more trolls, who put Greer onto various websites.
One website, Kiwi Farms, is a troll site mocking those they deem to be weird. They refer
to people as "Lolcows". Exhibit 0. Said site has over 100 pages on Russell Greer. The troll sites
made the incident worse than it was. The owner of Kiwi Farms, Joshua Moon, who goes by the
name "NULL" on the website, has refused to comply with requests to remove Greer from the
website. The site has gone from mere defamatory statements to putting Greer's copyrighted
material on that site, publishing Greer's addresses, phone numbers, his family's contact info, his
friends' info. Under the Communications Decency Act, site owners are not liabl~ for third party
conduct, a fact NULL proudly touts. Even if Greer could sue NULL, the site owner doesn't have
the monetary value to compensate for the harms Greer has suffered. This site engages in a
practice of malicious harassment.
Several people have tried coming to Greer's defense on that site, only for them to be
blocked and to have a message sent to them saying, "You're stuck here forever." This site has
had users create fake profiles of Greer and they send him friend requests. Some profiles created
have been: "Shit lips Greer", "Rat Face Russell Greer", another profile had put Greer's face on
the guy grabbing Taylor Swift's butt. Exhibit P. Some of these users have impersonated famous
people and stole personal, intimate photos of Greer, after coaxing Greer into believing he was
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talking to said celebrity. Another person left a voice message on Greer's phone and pretended to
be Swift's record label. One person pretended to be pop star Katy Perry and stole intimate items
of Greer's. They later posted said items on troll platforms. Exhibit Y. Others have hacked
Greer's accounts. Other users created fake profiles of Greer and began impersonating him online.
They created fake emails that purported to belong to him and began harassing places and people
with those fake email accounts. It's a never ending stream of harassment. Greer has contacted the
police and the district attorney of Salt Lake and they never do anything.
As stated in the complaint, from October 2017 to June 2018, Greer has been fired from 5
jobs due to the trolls harassing Greer's employment. Greer tried publishing a book on his actions
to try fighting the slander, but the trolls purposely gave it bad reviews. Because of the bad
reviews, Greer can't market the book. Greer has been robbed of his ability to have the truth told,
which is one reason why this current lawsuit was filed. Exhibit Q. Trolls have in groups
published defamation onto review websites such as a site called, MyLife. 115 random reviews
painted Greer as a horrible person. One random review said, "I wouldn't be Russell's friend."
Another said, "Don't hire Russell Greer." Another review, "Russell is delusional and mentally
ill." These reviews were all left around the same date of 11/20/2017, which shows that it was a
coordinated group effort and not sporadic harassment. Exhibit R.
They have published Greer's number onto phone number review websites and leave bad
reviews on his number. Simply blocking and requesting to delete negative reviews and trolls
doesn't work because he blocks one and 12 new trolls come at him. No high quality jobs want to
hire Greer because of the false reputation he has been given. He has applied to over one thousand
jobs in a year and only 4 have interviewed him. Exhibit S. Greer has been evicted and
essentially homeless because of the slander. Exhibit T. Greer has been unemployed and has had
to collect unemployment checks just to eat. Exhibit U.
16
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 17 of 91 PageID #: 57
Reputational damages are recoverable in a negligence lawsuit. Kennedy v. McKesson,
58NY2d 500,448 NE2d 1332 (1983) (Defendant anesthetic company negligently repaired
machines; Plaintiff accidentally killed a patient with the machine. Plaintiff was able to recover
for reputational damages).
C. Physical Injury
Plaintiff suffers from depression and anxiety. He has suffered with both since his teenage
years. Discovering trolls harassing him and discovering that Swift thought of Greer's efforts as
"troubling" has caused plaintiff to attempt to kill himself. Also, Greer's depression and anxiety
from this incident frequently causes Greer's head to tighten, to which he has to take medicine
for. Because Greer continues to lose employment over this, he can't go to a doctor and get his
head examined to make sure he doesn't have anything else going on. Also, one night as he was
walking home, he had a truck toss a firecracker at him, which caused bums to his legs. Greer has
been a target of harassment. On another time, Greer received a package that had powder in it. He
became ill from the package. It was later deemed to be non-lethal, but it made Plaintiff
lightheaded. His former roommate Paul Lopez witnessed the ordeal, but didn't want to write an
affidavit for fear of trolls coming after him too.
D. Fear of Violent Assault
Greer has had several incidents stemming from this ordeal, which have made him fear for
his life. Several times he has been in the grocery store and has overheard people say, "That's the
guy who sued Taylor Swift" and he is afraid they're going to attack him. Another incident, a
woman actually came up to him and berated him over the lawsuit. Greer has received strange
packages in the mail, as noted above. One package called Greer a "narcissist". EXHIBIT V.
Another time, a group of strangers shouted harassment at Greer as he walked on a sidewalk.
Another time, a lady shouted at him, "I should sue you for being ugly!" With Greer's address on
the troll sites, he is afraid that he is going to be killed. This is a reasonable fear, based on the
17
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 18 of 91 PageID #: 58
2017 New Mexico High School shooter, who was a member of Kiwi Farms. Before the shooter
went on his rampage, he asked NULL when he was going to start shooting people. EXHIBIT
W. Greer is afraid for his family's safety. Whenever Greer eats in public places, he sits facing
windows and exits for fear that he will be attacked from behind. When Greer sleeps, he places a
heavy object in front of his bedroom door, so that it can't be opened because he fears he will be
killed in his sleep. The 6th Circuit allows for one to recover for fear of harm happening, as a
distinct claim from emotional injuries. Sterling v. Velsicol Chem. Corp., 855 F.2d 1188, 1205-07
( 6th Cir. 1988) ( class action for fear of contracting liver and kidney disease and cancer due to
defendant corporation's dumping of hazardous chemicals in water supply).
E. Loss of Family Relationship
Greer has a twin sister that he was separated at birth from. Just barely five years ago, he
made contact with his birth family. He was barely building a relationship with them when the
trolls went to the liberty of digging through everything in his personal life and began harassing
his sister with fake email accounts. His sister thought that it was Greer who was harassing her,
when it wasn't. Now his birth family wants nothing to do with him. His birth family is the key to
knowing about his future, such as ifhe will live long in age, if his family has any history of
diseases, etc. They are his only blood relatives and it has been forever ruined because of this
entire ordeal.
F. Emotional Damages
Greer reiterates previously mentioned damages to fit in this claim. Greer has suffered fear
for his life. He has suffered loss of relationship. He has a ruined reputation. He has damages
stemming from knowing that Swift continues to interact with random fans while she shafted him
after relying on her representations. Those interactions are essentially pouring salt into open
wounds. Greer can't sleep at night due to his anxiety. Greer is constantly worried about losing
further employment. These are recoverable damages.
18
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 19 of 91 PageID #: 59
G. Calculation of Damages
Plaintiff estimates his general compensatory damages to be around $22,69,950.00 dollars.
Plaintiff comes to this conclusion by estimating that he will live for another 50 years. As a
paralegal graduate with an Associates Degree and legal work experience, the Natfonal
Association of Legal Assistants and Paralegals estimates that those who hold an associate's
degree in paralegal studies earned an average salary of $53,399 per year. What Can My Salary
Be with a Paralegal Associates Degree. Chron.com. (2018) (
https://work.chron.com/can-salaryparalegal-
associates-degree-25487 .html). If Greer being fired or unable to find a job due to Swift
failing to warn is going to be a consistent pattern, Greer is entitled for lost future wages and
would multiply 50 by $53,399. The total would be $2,669,950. As for reputational damages,
several judgements have found those with reputational damages to be upwards of $20 Million
dollars. How much is a damaged reputation worth? Medical Economics. (2003).
(
http://v-,r,vw.medicaleconomics.com/practice-111anagement/how-much-da111aged-reputationworth).
Greer asks for 20 million dollars for a ruined reputation and mental anguish and fear of
violent assault and loss of family connection. Altogether, Greer seeks compensatory damages of
$22,69,950.00
Also, Greer doesn't sue the people and organizations involved in the chain of events for
damages because Joshua Moon is unemployed and so suing him would essentially be as effective
as n~t suing him. Further, federal law protects Moon as a site owner, although he has done plenty
of harassment himself, such as publishing requests onto his site of Greer wanting stuff removed.
Exhibit Al.
H. Punitive Damages Will Not Be Sought
In federal diversity cases, the legal standard is that the laws of the forum state are to be
followed. The forum state in this case is Tennessee. Tennessee Code 29-39-104 holds that
punitive damages can only be found by a jury if it is determined a defendant acted recklessly.
19
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 20 of 91 PageID #: 60
Greer initially stated in his complaint that he wanted punitive damages to bring the amount to
100 Million. Greer wrote that before he was aware of the statute that has been cited. Therefore,
Greer will not seek punitive damages, as he can't prove recklessness on behalf of Swift. Greer
can only prove negligence, which he has done.
IX. Entry of the Proposed Default Judgment Is in the Public Interest
This circuit has held that in certain civil actions, the public interest should be weighed.
Mason County Medical Ass'n v. Knebel, 563 F.2d 256 (6th Cir. 1977). The relief Greer seeks is
in the public interest. Although the damages he claims are in a private action, the defendant is a
public figure. The action speaks for itself that Swift nor any of her representatives chose to
respond to this lawsuit; that none of them came forward to explain why Swift, an internationally
famous celebrity, shouldn't have to use disclaimers with her publicity stunts, when public policy
and precedent says otherwise. None of them have shown any sympathy towards Greer and the
damages that he has claimed.
The public does have an interest in this. A few months before commencing this action, a
person messaged Greer and told him that she felt empathy for Greer's plight. She told him that
her cousin did something similar as Greer. Her cousin was in a car accident and wanted to meet a
certain celebrity. This person's cousin went to great efforts to have said celebrity see their
efforts. Trolls saw the cousin and put it on websites, mocking the cousin. For a while, the family
was afraid that he would kill himself because the taunting was too much. Exhibit X. It's
apparent: others have suffered similar harms doing similar efforts. In a world that idolizes
celebrities, such disclaimers should be used to avert hidden dangers. See, Leets, L., de Becker,
G. & Giles, H. (1995). Fans: Exploring Expressed Motivations for Contacting CelebrUies.
Journal of Language and Social Psychology, 14 (1-2), 102-123; Social Influence of an
International Celebrity: Responses to the Death of Princess Diana. Oxford Academic Journal of
Communication. (2003).
20
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 21 of 91 PageID #: 61
In matters similar to the one at hand, courts have concluded that "the court's authority to
exercise full equitable powers is especially appropriate in a case like the one at bar." FTC v. Gem
Merchandising Corp., 87 F.3d 466,470 (11th Cir. 1996). A judgement against Swift would be
sweeping. She's considered one of the top artists currently. If she were found to be liable and in
default, the ramifications would be swift in and of itself: other celebrities would change how they
do stunts. See, Any Resemblance to Persons Living or Dead: Film and the Challenge of
Authenticity. Stanford.edu. (2016).
(https ://\veb. stanford.edu/ dept/HPS/H istory Wired/Davis/DavisAuthenticity.html) (talks about
how the "All Persons Fictitious" disclaimer came to be, which was created in response to a libel
lawsuit from 1932. The disclaimer is now used by every major movie company).
Plaintiff would be prejudiced if a default judgment were not entered because, without a
final judgment, there would be nothing preventing future harm that could befall others who rely
on Swift's actions. In addition, without a judgment for monetary relief, Plaintiff would be
unable to confidentially move on with his life, based on how ruined and fractured it currently is.
A judgement would save Plaintiff the costs of litigation, as it's apparent Swift and her attorney
do not care about the case. Finally, the failure to award default judgment here would create a
perverse incentive for future defendants in similar actions, by rewarding Defendant's failure to
answer or defend this action. These considerations weigh heavily in favor of entering the Default
Judgment here.
X. CONCLUSION
For these reasons, Plaintiff respectfully requests that the Court. enters the proposed
Default Judgment against Defendant Swift.
Respectfully submitted,
21
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 22 of 91 PageID #: 62
DATED: September 6th, 2018
Respectfully submitted,
By:
Russell Greer
Pro Se Litigant
/rgreer/
CERTIFICATE OF SERVICE:
I certify that on September 6th, 2018, a true and correct copy of PLAINTIFF'S MOTION FOR
ENTRY OF DEFAULT FINAL JUDGEMENT was emailed to the following:
William Briggs, counsel for defendant, at:
wjbriggs@Venable.com
A copy will also be physically mailed to his office addresses:
William Briggs
Venable LLP
2049 Century Park E
#2300
Los Angeles, CA 90067
22
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EXHIBIT A
23
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 24 of 91 PageID #: 64
••• Verizon LTE 7:26 AM
Request to waive service
I
Mr. Briggs,
Please find attached my document to waive
service of summons to save me cost
expense. Since you are her attorney, and are
thus a representative that can get this to her,
you accepting service will suffice. Please
sign the VVaiver and scan back to me.
Thank you.
Russell Greer
pdf
I ( .
24
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EXHIBITB
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 28 of 91 PageID #: 68
Taylor Swift - On Tour
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 30 of 91 PageID #: 70
One Chance -- EXCLUSIVE First Look with
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FREE - On the App Store
'All of us are praying for you':
.
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Taylor Sffift donates $50,000 to
her backup dancer's baby nephe"\V
who is battling cancer
By Iona Kirby For Dailymail.com
18:46 EDT 30 Sep 2015, updated 14:09 EDT 01 Oct 2015
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37
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11 kickstarter.com
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 40 of 91 PageID #: 80
EXHIBIT I
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• goog1e.com . v
reddit
r/niceguys
If there's any resemblance between him an
Taylor Swift, is that they both play the victim
all the time. This girl's crime? Unfriend him
on FB.
45
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 46 of 91 PageID #: 86
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You're a fat sack of shit.
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 48 of 91 PageID #: 88
Warning if you don't 'date' Russell Greer he will
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Do You Believe In Life
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•i; J(H,u Verizon ..,. 12:51 PM
6 Messages
Don't Have the Godly Loki L ...
Jay Schaudies
To: Cc:
Dear Mr Greer,
After you had sent some additional
correspondence about your music, I
called this morning to speak to you .. I got
your voice mail and left a message
explaining some of the legal reasons why
neither we nor Taylor can receive, open or
forward any unsolicited material.
I truly do wish you the best in your
efforts. I hope you and your songs find
the right audience.
Sincerely,
Jay
Jay Schaudies
Sent from my iPhone
S, • P M c) r f·" f r • , , , ; , • .' ·., · r 1. i , 1 1 1" · •
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 51 of 91 PageID #: 91
( Voicemail
Jay Schaudies
Taylor Swift Agent
September 13, 2016 at 9:47:34 AM
From: En1ail My
Edit
ff'-.?rstanding In Vesterday·s
Em i,. I Am Trying to For\Nard A Fan
Made Song To Taylor That Cost Me
$400.00 To Produce. Please
Forvvard To Her. I Am Not Trying To
Pitch A Song. If the song is not
forwarded, it vvill have been a vvaste
of time and money
I only want her
to smile
I don•t know hovv else to
give to her so that•s vvhy I contact
you two.
Dear Jay and Robert:
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 52 of 91 PageID #: 92
Jay Schaudies
To:
Dear Sir,
Taylor writes all of her own music
and none of us can or will accept
unsolicited works. This will not be
forwarded or ·opened.
I wish you well in your endeavors
Jay Schaudies
Sent from my iPhone
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52
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0-..::>0 F'llVI
_. dailymail.co.uk X
MailOnline
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Utah nian sues Taylor smft after
her agents 'stone"W"all' his efforts to
niake niusic mth her
By Kaileen Gaul For Mailonline
05:18 EDT 08 Dec 2016, updated 13:48 EDT 08 Dec 2016
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 57 of 91 PageID #: 97
Cl Files ••• ? 6:36 AM
Iii dailymail.co.uk
MailOnline
X View
FREE - On the App Store
I
Russell Greer from Salt Lake City blames Swift's
agents for not forwarding his music to her.
He believes he is
attention.
tied to the singer's
Mr Greer was allegedly told multiple times th"
Shake It Off songstress had a 'no unsolicited
ml ADVERTISEMENT )n policy.
Aj
ar
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57
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58
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•• II Verizon ? 6:54 PM
matthewhopkinsnews.com
@ f * 55%C7• +
the past two years have been campaigning to shut
down Kiwi Farrns, a site run by Joshua Conn Moon -
formerly of Pensacola, Florida.
F A R. M S
Ki\tVi Farms
Gossip and exploitation of the mentally
handicapped for amusement purposes.
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 60 of 91 PageID #: 100
••••o Verizon 3G 3:14 PM
(801) 512-2052
Russel you piece of shit.
All your information
including phone, home
address, work address,
etc. Will be published to
the trolls unless you
unblock me.
It is Zig.
Sorenson was very
helpful in providing me
everything I need to
know.
Why you deactivate
your Facebook Russell?
54%1 I•
60
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61
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September 24, 2017
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 68 of 91 PageID #: 108
Cl Mail • 11 9:18 AM
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Anonymous
Columbus, OH
Mylife
Searched for you on
09/03/2078
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 69 of 91 PageID #: 109
Russell, Your Reputation Score is
69
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 70 of 91 PageID #: 110
EXHIBITS
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 71 of 91 PageID #: 111
My Jobs
Next Steps 1
Saved 1
Applied 111
. Interviewing
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 72 of 91 PageID #: 112
EXHIBITT
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 73 of 91 PageID #: 113
NOTICE TO TERMINAT8t.
()etober 31 2011
Tenant{s):
Russell Greer
3306 East Del Verde Ave
Salt Lake City, Utali 84109
TO TENANT(S) AND ALL OTH'ERS IN POSSESSI0.11 Qtr:
3306 East Del Verde A
Salt Lake Chy. Utah .
PLEASE TAKE NOTICE that your month-to-month~
herein described premises is hereby 1erminated as of
this NOTICE upon you. YOO ARE; HEREBY rcqu
Hirshberg on or before the date ofNOVEMBE
October 31, 2017. Failure to do so will result In
an Unlawful Detainer lawsutt .p.lnst you lo
nus JS INTENDED AS A llff.~ (30) DAY
TENANCY. THIS NOtlCBlSlNACCO
80:!(b)(i). . ...
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EXHIBITU
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•1 Verizon ~ 9:29 AM
11 jobs.utah.gov
Current Claim for
RUSSELL G GREER
Type: Unemployment Insurance
Status:
Eligible
Weekly Benefit Amount
$264.00
Last Deposit Date
Begin Date
Feb 25, 2018
Maximum Benefit Amount
$6,864.00
Last Weekly Claim Filed
Mar 24, 2018
EndDate
Feb 23, 2019
Remaining Balance
$6,713.00
Work Search Requirement
4 weekly
*Your claim will stop at the end of the
benefit year. Any remaining balance
cannot be carried over to a new claim.
Claims
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 76 of 91 PageID #: 116
EXHIBITV
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EXHIBITW
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 79 of 91 PageID #: 119
• venzon -~-
would clearly have cast suspicion on n1e - until Moon
was goaded into adrnitting in a post on Kiwi FanT1s that
he sent it (article with links and evidence). After this
ad n1 ission th re were no n,ore threats to public
buildings. Until the real n1urders on 7th December.
Atchison and Moon were acquainted and chillingly 3
days before going on his rampage, Atct,ison posted on
Kiwi Farn1s under his usernarne, "FuckYou" asking how
long before Moon would do so (archive).
It is in,potiant to understand that Kiwi Farms' owner has
called for th extern,ination of Jews and Muslims, and
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 80 of 91 PageID #: 120
• Verizon ~ 6:54 PM
iii lolcow.wiki
Born
Died
William Atchison
March 17, 1996 (disputable, dox suggests
March 17th 1996!11, forum account
suggests 1993[21)
New Mexico
December 11, 2017 (age 21-24)
New Mexico
Cause of Suicide after murdering two students
death
William Emsgtret Atchison was a user i:§1 of
Kiwi Farms who garnered infamy and mockery
in the community for his involvement in the
A-,.+"",-.. LJi,....h C,-..h.-...,....1 .-.h.,.....-..+j.,...,.... r'\.,... ,--1,....,... _ _..,.L-.,,......,.
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 81 of 91 PageID #: 121
Verizon? 6:53 PM @ f * 54% f
i kiwifarms.net
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EXHIBITX
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 83 of 91 PageID #: 123
I just wanted to say I saw your
story and I found it super
upsetting. My cousin back
home was paralyzed in a car
accident when he was young
and has a similar story to
yours. He put a ton of effort
into creating a song + video,
and the video centered on his
struggle a·s a disabled person.
He sent the song/video out to
a few celebrities and some
people on Reddit's cringe
subreddit found it. They
harassed him in droves and
he ended up deleting it all and
we were scared he was going
to kill himself for a while ... this
was a few years back but I
just wanted to let you know
that you'll be ok and lots of
people go thru the same
thing! He even found a
support group for people who
83
0
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 84 of 91 PageID #: 124
Exhibit Y
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 85 of 91 PageID #: 125
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 86 of 91 PageID #: 126
Exhibit Z
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 87 of 91 PageID #: 127
• 11 Verizon ~ 10:38 PM @ -f * 15%
5 Messages
Don't Have the Godly Loki Looks, Bu ...
\.,Ill l::>l~I Ill I~ en ll It:: UU\.,I\, ll It:: "' 11~1 ll VVI IU
has fought so valiantly to get here at this
point of his journey is still waiting for his
hero's reward.
~at may seem as me being stubborn or
level headed (which I'm totally not. I'm
actually quite content and happy right
now and grateful you took time out of
your busy day to call me), is actually me
just wanting to be treated equally. I'm a
paralegal. I think through problems and I
analyze. I started on this quest to impress
her and write music for her ·after seeing
her accept prom dates; wedding invites;
going to charities; visiting kids in
hospitals. While all of that was sweet of
Taylor to do, none of it benefited her in
return. And then I saw her do
collaborations with other artists so thus a
confusing rule is created: her contract
won't allow her to accept material to be
pitched to her, but the contract allows her
to work with others. or to do music for
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 88 of 91 PageID #: 128
Exhibit Al
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 89 of 91 PageID #: 129
• Verizon
~s: Josh
! owner
1[1 ][2]
~alled Kiwi
:fefame
~bsite
~y exist
York
cializes in
.
91ng
1e way'(4 1.
which
and in
als. At
~ family
I •
I r I •
11:52 PM
kiwifarmswiki.com
Joshua Conner Moon
Born 1 9/12/1 992
Residence a, E
Florida
Nationality United States
Other names Josh Moon, Null, lchverbot,
lbanx (pseudonyms)
Citizenship United States
Occupation Unemployed
Organization None
Known for Dismissal from 8Chan due to
misconduct and poor
performance, administrator of
Kiwi Farms
Salary
Spouse(s)
Parent(s)
I
None, living off his mother
Candice Lynn Potter and his
savings
None
Candice Lynn Potter (mother)
+
Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 90 of 91 PageID #: 130
,Ill Verizon ? 2:59 PM @ --1 * 55% +
i kiwifarms.net
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Case 3:18-cv-00394 Document 10 Filed 09/14/18 Page 91 of 91 PageID #: 131
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