E-FILED; Montgomery Circuit Court

Docket: 5/3/2022 9:56 AM; Submission: 5/3/2022 9:56 AM

CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

JOHN PAUL MAC ISAAC

1805 Delaware Ave.
Wilmington, DE 19806,

Plaintiff,

V. Case No.

ADAM BENNETT SCHIFF

8204 Windsor View Terrace
Potomac, Maryland 20854,

and

CABLE NEWS NETWORK, INC.

Corporation Trust Company
Corporation Trust Center
.1209 Orange Street
Wilmington, DE 19801

and

THE DAILY BEAST COMPANY LLC

Corporation Trust Company
Corporation Trust Center
1209 Orange Street
Wilmington, DE 19801

and

POLITICO LLC
Corporate Service Company
251 Little Falls Drive
Wilmington, DE 19808,

Defendants.
/

COMPLAINT

COMES NOW, PLAINTIFF JOHN PAUL MAC ISAAC (hereinafter, "Plaintiff"), by

and through undersigned counsel hereby sues Defendants and alleges as follows:
 A. PARTIES, JURISDICTION & VENUE

1. This is an action for defamation, defamation per Se, aiding and abetting

defamation, and civil conspiracy to commit defamation and requests damages in excess of

seventy-five thousand and 00/100 dollars ($75,000.00).

2. Plaintiff John Paul Mac Isaac ("Plaintiff') is an individual over the age of 18 who

is suijuris and resides in Wilmington, Delaware.

3. Defendant Adam Bennett Schiff ("SCHIFF"), being sued in his individual

capacity, is an individual over the age of 18 who is suijuris and resides part-time and, upon

information and belief, as a result of his residency, has substantial contacts in Montgomery

County, Maryland. SCHIFF is the United States Representative for the 28th District of California

and was, at the time of the actions giving rise to this Complaint, the Chairman of the House of

Representatives Permanent Select Committee on Intelligence.

4. Defendant Cable News Network, Inc. ("CNN") is a Delaware corporation that

provides televised and internet-based news and commentary to cable television subscribers and

the general public.

5. Defendant The Daily Beast Company LLC ("DAILY BEAST") is a Delaware

limited liability company that provides written tabloid-style news and commentary services to

the general public.

6. Defendant Politico LLC ("POLITICO") is a Delaware limited liability company

that purportedly provides news and information services at the intersection of politics and policy

to the general public.

7. Personal jurisdiction over SCHIFF is proper pursuant Md. Cts. & Jud. Proc. §6-

102(a) and 6-103(b).

 8. Personal jurisdiction over all other Defendants is proper pursuant to Md. Cts. &

Jud. Proc. §6-103(b).

9. Venue is proper in this county pursuant to Md. Cts. & Jud. Proc. §6-201(b) as

SCHIFF resides in, owns real property in, and maintains substantial ties to Montgomery County.

B. FACTS APPLICABLE TO ALL COUNTS

10. Plaintiff incorporates by reference all allegations contained in Paragraphs 1 - 9.

11. Plaintiff is a private citizen who currently resides in Wilmington, Delaware.

12. Plaintiff owned a small business named The Mac Shop, Inc. (the "Mac Shop")

which was a Delaware corporation.

13. Plaintiff was in the business of repairing Mac computers.

14. Plaintiff derived all of his income from the Mac Shop.

15. Plaintiff was a trusted and respected part of the community in Wilmington,

Delaware.

16. Plaintiff had a loyal customer-base who would refer others to his shop to fix their

Macs.

17. On or about April 12, 2019, Mr. Hunter Biden ("BIDEN") was referred to

Plaintiff's shop to fix some damaged Macs.

18. On April 12, 2019, BIDEN asked to recover information from the damaged Mac

computers. Copy of Repair Authorization attached as EXHIBIT A.

19. On or about April 13, 2019, at Plaintiff's request, BIDEN returned to the Mac

Shop with a Western Digital external hard drive to which Plaintiff could transfer the recovered

data.
 20. Later that same day, on or about April 13, 2019, Plaintiff completed the recovery

and called BIDEN to notify him of such and to request that he retrieve his recovered data.

21. On or about April 17, 2019, Plaintiff sent an electronic invoice to BIDEN in the

amount of $85.00.

041I71 Hunter Siden The Mac Shop Inv — $85.00

22. Plaintiff reached out to BIDEN at least one more time thereafter to request that he

pay his invoice and retrieve his recovered data.

23. BIDEN never returned to the Mac Shop to retrieve his recovered data nor did he

pay his invoice.

24. Pursuant to the terms of the Repair Authorization signed by BIDEN, "[e]quipment

left with the Mac Shop after 90 days of notification of completed service will be treated as

abandoned and you agree to hold the Mac Shop harmless for any damage or loss of property."

25. Starting in late July 2019 to October 14, 2020, Plaintiff had multiple interactions

with the Federal Bureau of Investigation (the "FBI"), U.S. Congressional staff members, and Mr.

Robert Costello, Esquire ("COSTELLO"), attorney for Rudolph Giuliani, Esquire

("GIULIANI").

26. On or about December 9, 2019, the FBI served a federal grand jury subpoena on

Plaintiff requiring he turn over the laptop and hard drive, which Plaintiff did on that day. Copy of

subpoena attached as EXHIBIT B.

27. In August 2020, Plaintiff connected with COSTELLO to whom he provided a

copy of the recovered data.

 28. Plaintiff specifically asked COSTELLO to not identify him to GIULIANI or

anyone else when discussing the recovered data as Plaintiff desired to remain anonymous.

29. Upon information and belief, COSTELLO followed Plaintiff's wishes.

30. After August 26, 2020, but prior to October 14, 2020, upon information and

belief, GIULIANI provided information from the recovered data to the New York Post

newspaper ("NY POST").

31. On October 13, 2020, Plaintiff received a call from Mr. George Mesires,'

identifying himself as BIDEN's attorney, asking if Plaintiff still had possession of his client's

laptop and following up thereafter with an email to the Plaintiff.

32. On October.14, 2020, at approximately 5:00 AM, the NY POST published an

exposé about the contents of BIDEN's recovered data. Shortly thereafter, the NY POST

"updated" the online version of the exposé.

33. As a direct result of the NY POST exposé, public emotions were heightened and

many in the general public, the media, and the government began to either defend or attempt to

refute the exposé. The NY POST exposé fueled a rise in anger and hatred between the different

political movements. The Plaintiff quickly became the target of accusations by those who sought

to cast doubt on the findings in the laptop and the laptop itself.

34. Plaintiff was not involved in the disclosure of the recovered data to the NY POST,

did not promote the disclosure in any way, nor did the Plaintiff authorize the disclosure.

35. While Plaintiff verified how he came into possession of the recovered data to the

NY POST, Plaintiff was unaware of the details of the NY POST exposé, when the NY POST

George Mesires is a partner in the Chicago office of Faegre Drinker Biddle & Reath LU'.
exposé was going to be published, and Plaintiff explicitly told the NY POST that he did not want

to be identified.

36. Plaintiff did not authorize the disclosure of his identity by GIULIANI,

COSTELLO, or the NY POST, did not authorize the disclosure of the information, nor was he

involved in any determinations or strategy regarding the disclosure of the information.

37. Plaintiff was not explicitly identified in the NY POST exposé but was, instead,

referred to as the Delaware computer repair shop "store's owner."

38. NY POST, as part of its original publication of the exposé and without the

consent of Plaintiff, published a photo of the Repair Authorization without blurring the business

name thereby notifying the public and the media where BIDEN had dropped off his laptop.

39. Also on October 14, 2020, subsequent to the NY POST's disclosure of the

Plaintiff's identity, other media outlets, including writers from the DAILY BEAST purportedly

investigating the NY POST exposé, interviewed and wrote a damaging article about the Plaintiff.

Copy of Daily Beast article about Plaintiff attached as EXHIBIT C.2

40. In an attempt to clarify the inaccuracies about the Plaintiff published in the article

by the Daily Beast, Plaintiff's counsel wrote a statement and approached media outlets with that

statement. The Wall Street Journal did not return communications from Plaintiff's counsel and

the Washington Post responded that they do not think the statement "would be a good fit" for the

news organization. Copy of clarifying statement by Plaintiff's counsel attached as EXHIBIT D

and email from Washington Post attached as EXHIBIT E.

2 The DAILY BEAST article was the result of Plaintiff being accosted by a group of journalists asking him questions
about his involvement in the NY POST exposé. Plaintiff, concerned about his and his family's wellbeing, attempted to
respond in ways that would protect them but, not having ever been the subject of media inquiry, his responses come
across as confused and contradictory. In fact, his seemingly confused and contradictory statements were made as a result
of his inexperience with the media and his lifelong status as a private figure.
 41. On or about October 19, 2020, a "Public Statement on the Hunter Biden Emails,"

signed by more than 50 former intelligence officials was released statingthat the information

contained in the NY POST expose has "all the classic earmarks of a Russian information

operation," but that they "do not know if the emails. are genuine or not and that [they] do not
..

have evidence of Russian involvement..." Public §tatement attached as EXHIBIT F.

42. Upon information and belief, the Public Statement was issued to influence

American voters to vote for then-candidate, now President, Joseph R. Biden and offered no

actual evidence of the claims that Russia was involved in the release of the information from

Hunter Biden's laptop. /

43. Plaintiff is not a Russian agent nor is he a participant in a Russian disinformation

campaign.

44. On or about October 30, 2020, Plaintiffs clarifying statement was published by

justhenews.com for all to read.3

C. COUNT I: DEFAMATION AND DEFAMATION PER SE

ADAM BENNITT SCHIFF, INDIVIDUALLY

45. Plaintiff incorporates by reference all allegations contained in Paragraphs 1 - 44.

46. SCHIFF, individually, was actively involved in fundraising for the 2020

Presidential campaign of Joseph R. Biden, Jr. Articles outlining Defendant's fundraising efforts

attached as EXHIBIT G.

47. The laptop held information that could have hurt the political campaign of then-

Presidential candidate, now President, Joseph R. Biden Jr, for whom SCHIFF spent significant

3 https:/

down#article
time campaigning. According to a poll conducted by the Media Research Center, nearly 9.4% of

Biden voters would not have voted for him had they known about the full extent of the scandal.'

Even more Biden voters (45.1%) said they were unaware of the financial scandal enveloping Biden and his son, Hunter (a story
infamously censored by Twitter and Facebook, as well as Ignored by the liberal medIa). According to our poll, full
awareness of the Hunter Biden scandal would have led 9.4% of Biden voters to abandon the Democratic candidate, flipping all
six of the swing states he won to Trump, giving the President 311 electoral votes.

48. Upon information and belief, SCHIFF knowingly fomented further anger and

hatred against the Plaintiff (among others) in his defense of Presidential-candidate, Joseph R.

Biden, Jr., and his attempt to "kill" the story.

49. On or about October 16, 2020, at 6:40 pm EST, SCHIFF was interviewed by

broadcaster, Wolf Blitzer ("BLITZER"), on CNN as part of CNN's show, the Situation Room

with Wolf Blitzer (the "Interview"). The Situation Room with Wolf Blitzer attracts a very large

world-wide audience. Transcript attached as EXHIBIT H.

50. The Interview was conducted live "via Cisco Webex" with BLJTZER in New

York and SCHIFF, seemingly at his home in Potomac, Maryland.

 51. BLITZER's first question to SCHIFF was:

"Does it surprise you at all that this information. that Rudy Giuliani
is peddling very well could be connected to some sort of Russian
Government disinformation campaign?"

52. SCHIFF's response to BLITZER's question was:

"Well we know that this whole smear on Joe Biden comes from the
Kremlin. That's been clear for well over a year now that they've been
pushing this false narrative about the Vice President and his son. And, you
know, the idea that the President, that the White House Counsel, and
others were made aware that Giuliani was being used by Russian
intelligence and using Russian intelligence in the sense of meeting with
an agent of the Kremlin and pushing out this Kremlin false narrative..."
Emphasis added.

53. Defendant continued with:

"But clearly, the origins of this whole smear are from the Kremlin..." Emphasis
added.

54. Later in the interview, BLITZER, in what seems to be an attempt to bolster the

SCHIFF's credentials and the veracity of the SCHIFF's statements, said:

"Have you, as a member of the Gang of Eight, the top leadership in

Congress, the Senate, and the House, and members of the Intelligence
Committee, have you been formally briefed on what the Russians are up to
right now in trying to peddle this kind of information?"

55. SCHIFF's response:

"Well, I was in the Intelligence Committee today to see what the latest
was, and frankly, we haven't gotten much from the intelligence
community very recently, which concerns me. They have at times, some
of the leadership, like Director [of National Intelligence] Ratcliffe, not
been very forthcoming in terms of the intelligence on the Russian threat
and been promoting this false equivalence with other countries.

So, you know, I wish I could tell you more, Wolf. I wish the intelligence
community was able to tell the public more.

But we do know this: the Russians are once again actively involved in
trying to denigrate the Vice President..." Emphasis added.
 56. Director of National Intelligence Ratcliffe, on October 19, 2020, repudiated

SCHIFF's claims during an interview on Fox News Mornings with Maria by stating the

following:

"Let me be clear, the intelligence community doesn't believe [that the

Hunter Biden laptop situation is part of a Russian disinformation
campaign] because there is no intelligence that supports that [assertion]
and we have shared no intelligence with Chairman Schiff or any other
member of Congress that Hunter Biden 's laptop is part of some Russian
disinformation campaign. It's simply not true..." Emphasis added.

57. According to the Director of National Intelligence and upon information and

belief, SCHIFF did not have any evidence and did not receive any report stating that the

information contained in the NY POST exposé was part of a Russian disinformation campaign.

58. The information contained in the NY POST exposé came from BIDEN who

voluntarily left his laptop with the Plaintiff and failed to return to retrieve it.

59. This is not the first time SCHIFF has knowingly made false statements about

Russia's involvement in United States politics. See Wall Street Journal editorial opinion attached

as EXHIBIT I.

60. SCHIFF had not received reports that the Hunter Biden laptop information was

part of a Russian disinformation campaign, therefore, SCHIFF knowingly and intentionally made

the false statements that the information contained in the NY POST exposé, originally obtained

by the Plaintiff, was part of a Russian disinformation campaign.

61. SCHIFF's statements were not made during a Congressional debate or committee

proceeding.

62. SCHIFF was not carrying out any of his enumerated legislative powers at the time

of his interview.
 63. SCHIFF was not carrying out any of his implied powers as a member of

Congress.

64. SCHIFF's job description as a member of Congress does not include knowingly

conveying false information to the public.

65. Upon information and belief, SCHIFF's statements were made from his home in

Potomac, Maryland after normal working hours.

66. SCHIFF had significant involvement in the Presidential campaign of Joseph R.

Biden, Jr which included hosting fundraisers for the candidate and speaking on the candidate's

behalf.

67. SCHIFF's false statements were, in fact, campaign speech and not speech

associated with his Congressional duties, which would not involve lying to the American public

about something so sensational.

68. SCHIFF knowingly conveyed false information with the intent to promote the

election of Joseph R. Biden, the candidate most vulnerable because of the NY POST exposé.

69. Plaintiff was the individual who obtained the information from BIDEN that was

eventually published by the NY POST, his identity had been revealed by the NY POST prior to

SCHIFF's interview, and Plaintiff's name was, at that time, and remains synonymous with

Hunter Biden's laptop.

70. SCHIFF's actions and campaign statements had the specific intent to

communicate to the world that the information presented in the NY POST exposé was part of a

Russian disinformation campaign.

 71. SCHIFF's actions and campaign statements had the specific intent to

communicate to the world that the Plaintiff is a Russian agent and/or a participant in a Russian

disinformation campaign.

72. The SCHIFF, through-his conduct of knowingly conveying false campaign

statements to a world-wide audience, was encouraging listeners to take action against those who

released this information, which specifically included the Plaintiff.

73. Plaintiff, as a direct result of SCHIFF s campaign statements, has lost his good
'

reputation in the community, is now widely considered either a Russian agent or a participant in

a Russian disinformation campaign as shown by the attached Yelp Reviews and personal

emails/threats received. Yelp reviews attached as EXHIBIT J and personal threats attached as

EXHIBIT K.

74. Further evidence of the harm suffered by Plaintiff as a direct result of SCHIFF's

false campaign statements is that the Plaintiff lost his loyal client-base and, as a result, had to

close his business.

75. SCHIFF made the false and defamatory campaign statements to the Situation

Room's worldwide audience without privilege to do so.

76. SCHIFF's false and defamatory campaign statements accuses the Plaintiff of

committing an infamous crime, i.e., treason by working with the Russians to commit a crime

against the United States of America by attempting to undermine American democracy and the

2020'Presidential election.

77. As a direct and proximate result of the false and defamatory campaign statements

made by SCHIFF, Plaintiff has suffered, and continues to suffer, substantial damages, including

having to close his business.

 78. SCHIFF s false and defamatory campaign statements are of the kind that would
'

tend to, and in fact did, prejudice the Plaintiff in the eyes of a substantial and respectable portion

of the community at large.

79. SCHIFF acted with actual malice toward the Plaintiff in that he acted with

knowledge that his statements were false or, at the very least, he acted with reckless disregard to

the harm his knowingly defamatory false campaign statements would have on the Plaintiff, both

personally and as a small business owner.

80. SCHIFF's false and defamatory campaign statements have subjected and continue

to subject the Plaintiff to distrust, scorn, ridicule, hatred, and contempt. As such, the defamatory

statements constitute defamation per Se.

81. Alternatively, SCHIFF knew or should have known the significant impact his

defamatory false campaign statements would have on the Plaintiff who was the source of the

information.

82. At the very least, SCHIFF was grossly negligent in making his defamatory false

statements about the Plaintiff.

Prayer for Relief

WHEREFORE, the Plaintiff JOHN PAUL MAC ISAAC prays for judgment against the

Defendant ADAM BENNETT SCHIFF as follows:

(a) Awarding Plaintiff all compensatory damages in excess of $75,000 as a result of

SCHIFF's wrongdoing in an amount to be determined at trial;

(b) Awarding Plaintiff punitive damages as a result of SCHIFF's wrongdoing in an

amount to be determined at trial;

(c) Awarding Plaintiff pre- and post-judgment interest;

 (d) Awarding Plaintiff all attorneys' fees and costs associated with litigating this

case;

(e) Requiring all Defendants to make a public retraction of all false statements and to

issue a public apology to Plaintiff; and

(f) Such further relief as this Court deems just and proper.

D. COUNT 2: DEFAMATION AND DEFAMATION PER SE

CNN

83. Plaintiff incorporates by reference all allegations contained in Paragraphs 1 - 82.

84. On or about October 16, 2020, at 6:40 pm EST, CNN televised the Interview

between SCHIFF and BLITZER.

85. During the Interview, SCHIFF made false and defamatory campaign statements

indicating that he had confirmed that the source of the information from the laptop was Russia.

86. Plaintiff was the known source of the information from the laptop, not Russia.

87. CNN knew Plaintiff was the source of the information as it had published an

article referencing an interview with Plaintiff on October 14, 2020. In that article, it said:
That shop employee has been Identified as John Paul Mac Isaac. He spoke to CNN on Thursday In Wilmington. Mac Isaac said that in April 2019 someone claiming to be
Hunter Biden brought in a damaged laptop computer to retrieve the data on it. This required him to manually transfer the computers data to a separate hard drive, Mac Isaac
said. wliith Is flow he came to see What some of the files contained.

88. De,spite the fact that CNN knew Plaintiff was the source of the information, it

broadcast the Interview SCHIFF during which Plaintiff was defamed.

89. CNN boasts a viewership of over 700,000 viewers each week.6

https://Iit.e.cnn.com/en/ardcle/h 7e5fcdffc7051ba1d73b135ee1615b3b
6

primetime-viewers/504622/
 Week ofMarch 28,2022 cable news ratings, Monday-Sunday (Nielsen live-
same-day data):

PRIME Fox News MSNEC CNN

.Total Viewers: 2,529,000 1,129,000 731,000

• A25-54: 380,000 129,000 182,000

90. CNN broadcast the Interview without privilege to do so to its over 700,000

viewers.

91. The statements broadcast on CNN are of the kind that would tend to, and in fact

did, prejudice the Plaintiff in the eyes of a substantial and respectable portion of the community

at large.

92. CNN knew the story behind the Hunter Biden laptop having spoken with Plaintiff

and written about the Plaintiff two days prior.

93. As CNN knew the story behind the Hunger Biden laptop but broadcast the

Interview anyway, CNN acted with actual malice toward the Plaintiff.

94. Alternatively, CNN broadcast the false statements about Plaintiff with reckless

disregard for the harm the false statements would cause to the Plaintiff.

95. CNN knowingly broadcast the falsehoods to third parties - its over 700,000

viewers.

96. CNN knew or should have known such false statement would likely result in

material and substantial injury to Plaintiff, as the statement accuses the Plaintiff of knowingly

participating in a Russian scheme to disrupt the presidential elections in the United States of

America.
 97. CNN's broadcast of the false statements have subjected and continue to subject

the Plaintiff to distrust, scorn, ridicule, hatred, and contempt. As such, the defamatory statements

constitute defamation per Se.

98. CNN's broadcast of the false statement accuses the Plaintiff of committing an

infamous crime, i.e., treason by working with the Russians to commit a crime against the United

States of America by attempting to undermine American democracy and the 2020 Presidential

election.

99. As a direct and proximate result of the defamatory statements broadcast by CNN,

Plaintiff has suffered, and continues to suffer, substantial damages, including having to close his

business.

100. Upon information and belief, CNN executives told employees not to cover the

Hunter Biden story.'

101. Instead, CNN continually broadcast the false and defamatory story about the

laptop being part of a Russian disinformation campaign designed to influence the 2020 United

States Presidential elections.

102. It is clear by its broadcasts, CNN intended to harm the Plaintiff and the other

parties associated with the release of information from the laptop by broadcasting the false and

defamatory statements.

103. CNN acted with actual malice toward the Plaintiff in that it acted with knowledge

that the statements were false or, at the very least, acted with reckless disregard to the harm the

knowingly defamatory false campaign statements would have on the Plaintiff, both personally

and as a small business owner.

https:IInypost.com12020112/02/cnn-caught-burying-the-posts-hunter-biden-exposedevine/
 104. CNN had actual knowledge of the falsity of the claims and understood the high

probability that injury or damage would result to Plaintiff and; despite such knowledge,

broadcast the false and defamatory statement and has issued no apology to the Plaintiff such as

would repair that damage.

105. In the alternative, CNN's actions, as described above, were so reckless or wanting

in care that they constituted a conscious disregard or indifference to the rights of Plaintiff.

Prayer for Relief

WHEREFORE, the Plaintiff JOHN PAUL MAC ISAAC prays for judgment against the

Defendant CABLE NEWS NETWORK, INC. as follows:

(a) Awarding Plaintiff all compensatory damages in excess of $75,000 as a result of

CNN's wrongdoing in an amount to be determined at trial;

(b) Awarding Plaintiff punitive damages as a result of CNN's wrongdoing in an

amount to be determined at trial;

(c) Awarding Plaintiff pre- and post-judgment interest;

(d) Awarding Plaintiff all attorneys' fees and costs associated with litigating this

case;

(e) Requiring all Defendants to make a public retraction of all false statements and to

issue a public apology to Plaintiff; and

(f) Such further relief as this Court deems just and proper.

E. COUNT 3: DEFAMATION AND DEFAMATION PER SE

THE DAILY BEAST

106. Plaintiff incorporates by reference all allegations contained in Paragraphs I - 44.

107. DAILY BEAST's first story about Plaintiff on October 14, 2020, sought to

prejudice the Plaintiff in the eyes of the national community resulting from a hostile interview
between DAILY BEAST "reporters" and Plaintiff. See EXHIBIT C. At the time, Plaintiff had

never given an interview and was unsure how to answer questions without divulging information

about his father, who helped him and whom he wanted to protect.8 DAILY BEAST used his

inexperience and nervousness against him by pressing him with leading questions.

108. On October 19, 2020, DAILY BEAST published an article, FBI Examining

Hunter's Laptop as Foreign Op, Contradicting Trump's Intel Czar," in which it referred to the

laptop as "the purloined laptop" ("October 19th Article").9

109. On October 21, 2020, Plaintiff, by and through counsel, issued a cease-and-desist

letter to DAILY BEAST responding to the negative things being said about Plaintiff and warning

to not print any false and defamatory information about the Plaintiff. Copy of cease-and-desist

Letter to DAILY BEAST attached as EXHIBIT L.

110. The October 19th Article was in violation of the cease-and-desist as it described

the laptop as "purloined" (stolen).

111. To date, no retraction has been issued.

112. On December 9, 2020, DAILY BEAST published another article identifying the

Hunter Biden laptop as a stolen laptop ("December 9th Article"): -

7heSW& nfRu&PMdeWs
Cupmn t L ego/ Was Wei vFound
onHk8k1enL*kp
I TjjgU9LE AKEU,TR0URLE 8WKD I

8 This interview would be cited by many in the media, often casting it and the Plaintiff as "bizarre."

trumps-intel-czar
 113. DAILY BEAST knew, or should have known, that the laptop was not stolen as

Plaintiff's clarifying statement had been issued on or about October 30, 2020.

114. On December 14, 2020, after being made aware of the headline, Plaintiff's

counsel sent an email to the General Counsel of DAILY BEAST notifying him of the headline

and its incorrect implication (that the laptop was stolen) and asking him to have the headline

corrected:
PJflI Ic?'lhl Ai€Othedt jyt

ar.
.o.at flat that th? [r ly Baast story, daIs tnmbr hr. 202(1, sr ,ir,ahy rrrtttlad 'TFn hoods ot Hrarthrr dsn a rIOt
wr,r1-ojrrd on ' sort, ri votatiop 0 my r rOar' and draict tIlt', rtht laptop ma not tril,'n the or I- as
pro eritod :0'? firing

F1'rtrik ,'us bar sisi rlsfima lhc.litl, dir coritr5,o to mrli,to pboltlssr( tor drbr'- atrir .spnrtl

115. Soon thereafter, DAILY BEAST corrected the headline:

The Seeds ofNunterilklen'sA ROH t I BYR/ WoesWore

FoundodisLop
mourn.E AHEAD,1RDUBI.E BEHIND

116. However, DAILY BEAST retained the web address associated with the

December 9th Article, failing to correct it:

Co nte°-3d tegal-woes-were-fou rid -on-hs-stoIen-Iaptop

117. To date, the web address has not been corrected.

118. DAILY BEAST article web addresses always contain the entire title of the article.
 119. DAILY BEAST knew, or should have known, that the web address for the article

also contained the false and defamatory headline since its usual practice is to place the entire title

of the article in the web address.

120. In order to pass the December 9th Article to someone, a user must copy and paste

the web address or use another tool to copy the web address into the message.

UrrEt. Legal Wbed Were

Found on His.L
hts://www.t1
tp
bidens-curront

121. The web address clearly shows the false and defamatory statement by the DAILY

BEAST.

122. Plaintiff acquired the laptop directly from BIDEN who then failed to return to

pick it up.

123. Pursuant to the policies of The Mac Shop, any items not picked up within 90 days

becomes the property of The Mac Shop. BIDEN acknowledged and agreed to this policy when

he signed the repair authorization.

124. DAILY BEAST was well aware of how the Plaintiff obtained the laptop.
 125. DAILY BEAST has made multiple false statements about the Plaintiff in both the

October 19th Article and the December 9th Article without privilege to do so.

126. The false and defamatory statements about the Plaintiff by the DAILY BEAST

accused the Plaintiff of committing the crime of theft.

127. The false and defamatory statements made by DAILY BEAST were made

negligently; without reasonable care as to its truth or falsity; with knowledge of its falsity; and/or

with reckless disregard for the truth.

128. DAILY BEAST boasts of more than 1 million readers per day.

Aboutus
Independent. irreverent. Intelligent. The Daily Beast delivers award-winning
original reporting and sharp opinion in the arena of politics, pop-culture and
power. Always skeptical but never cynical, Flie [T)-ulv Bast rea ches more than
im1hou i eader &ky. Tracy Connor is Editor in Chief and Heather Dietrick

is CEO. The Daily Beast is based in New York and is an operating business of
IAC (NASDAQ: LAC).

129. The defamatory statements made by DAILY BEAST were written, without

privilege,and communicated to third parties - DAILY s more than 1 million readers per

day.

130. DAILY BEAST's statements are of the kind that would tend to, and in fact did,

prejudice the Plaintiff in the eyes of a substantial and respectable portion of the community at

large.

131. DAILY BEAST knew the story behind the Hunter Biden laptop having spoken

with Plaintiff and written about the Plaintiff prior to December 9, 2020.
 132. As evidenced in the prejudicial October 14, 2020 article, DAILY BEAST acted

with actual malice toward the Plaintiff in that it acted with knowledge that the statements were

false or, at the very least, acted with reékless disregard to the harm the knowingly defamatory

false campaign statements would have on the Plaintiff, both personally and as a small business

owner.

133. DAILY BEAST knowingly communicated the falsehoods to third parties - its

more than 1 million per day readership.

134. DAILY BEAST knew or should have known such false statement would likely

result in material and substantial injury to Plaintiff, as the statement accuses the Plaintiff of

stealing a laptop from the son of the newly elected President of the United States.

135. The DAILY BEAST' s false statements have subjected and continue to subject the

Plaintiff to distrust, scorn, ridicule, hatred, and contempt. As such, the defamatory statements

constitute defamation per Se.

136. DAILY BEAST's false statement does not only accuse the Plaintiff of theft but

also implies that Plaintiff has committed an infamous crime, i.e., crime against the United States

of America by attempting to undermine American democracy and the 2020 Presidential election

through the alleged theft of the laptop.

137. As a direct and proximate result of the defamatory statements made by DAILY

BEAST, Plaintiff has suffered, and continues to suffer, substantial damages, including having to

close his business.

138. Upon information and belief, as evidenced in the prejudicial October 14, 2020

article, DAILY BEAST intended to harm the Plaintiff with the false statements.
 139. DAILY BEAST had actual knowledge of the falsity of the claims' and understood

the high probability that injury or damage would result to Plaintiff and, despite such knowledge,

broadcast the false and defamatory statement and has issued no apology to the Plaintiff such as

would repair that damage.

140. In the alternative, DAILY BEAST's actions, as described above, were so reckless

or wanting in care that they constituted a conscious disregard or indifference to the rights of

Plaintiff.

Prayer for Relief

WHEREFORE, the Plaintiff JOT-IN PAUL MAC ISAAC prays for judgment against the

Defendant THE DAILY BEAST COMPANY, LLC as follows:

(a) Awarding Plaintiff all compensatory damages in excess of $75,000 as a result of

DAILY BEAST's wrongdoing in an amount to be determined at trial;

(b) Awarding Plaintiff punitive damages as a result of DAILY BEAST's wrongdoing

in an amount to be determined at trial;

(c) Awarding Plaintiff pre- and post-judgment interest;

(d) Awarding Plaintiff all attorneys' fees and costs associated with litigating this

case;

(e) Requiring all Defendants to make a public retraction of all false statements and to

issue a public apology to Plaintiff; and

(1) Such further relief as this Court deems just and proper.

F. COUNT 4: DEFAMATION AND DEFAMATION PER SE

POLITICO

141. Plaintiff incorporates by reference all allegations contained in Paragraphs 1 —44.

 142. On October 19, 2020, POLITICO published an article entitled: 10

HATtONAL SECURITY

Hunter Biden story is Russian disinfo, dozens of former Intel officials say
More than 50 former intelligence officials signed a letter castng doubt on the provenance of a New York Post stoxy on the
former vice president'
s son.

143. According to POLITICO in that article:

The letter, signed on Monday, centers around a batch of documents released by

the New York Post last week that purport to tie the Democratic nominee to his
son Hunter's business dealings. Under the banner headline "Biden Secret E-
maib," the Post reported it was given a copy of Hunter Biden's laptop hard
drive by President Donald Trump's personal lawyer Rudy Giuliani, who said he
ioiii a .c si l)elavar who ci

144. POLITICO is referencing the letter signed by more than 50 former senior

intelligence officials stating their belief that the information from the laptop "has all the classic

earmarks of a Russian information operation."

145. The 50 former senior intelligence officials did not state that the Hunter B iden

story IS Russian disinformation that was POLITICO.

-

146. POLITICO knowingly falsely stated as fact that the Hunter Biden story LS
Russian disinformation.

147. The article was written by journalist Natasha Bertrand, who seemingly has a

history of transforming speculation into fact in the stories upon which she reports.'1

148. POLITICO published the article with a false headline stated as fact and is about

the Plaintiff.

10
https://www.po1itico.com/news/2O2O/1O/19/hunterhidenstorynissjan...&sjifo43O276
11

credulity-intotv1ig/
 149. POLITICO published the false factual statement about the Plaintiff without

privilege to do so.

150. The false and defamatory publication about the Plaintiff by POLITICO include,

but are not limited to, allegations that the information published by the NY POST, which

originally came from the Plaintiff, was part of a Russian disinformation campaign, thereby

directly implying that the Plaintiff part of a Russian disinformation campaign and/or, more

specifically, a Russian agent.

151. The defamatory publication was made negligently; without reasonable care as to

its truth or falsity, with knowledge of its falsity, and/or with reckless disregard for the truth.

152. The defamatory publication was published and viewed by POLITICO's readers.

153. POLITICO's publication alleges that Plaintiff committed crimes including (but

not limited to) working with Russians to spread "disinformation" relating to the son of

Democratic Party nominee, now President, Joseph Biden, thereby implying that Plaintiff

committed treason by being part of an attempt to undermine American democracy and the 2020

Presidential election.

154. POLITICO's publication is of the kind that would tend to, and in fact did,

prejudice the Plaintiff in the eyes of a substantial and respectable portion of the community at

large.

155. POLITICO knowingly published the falsehoods as facts to third parties.

156. POLITICO knew or should have known such false statements in the publication

would likely result in material and substantial injury to Plaintiff, as the statements call into

question Plaintiff's loyalty to the United States. Additionally, the published statements have

subjected and continue to subject the Plaintiff to distrust, scorn, ridicule, hatred, and contempt.
 157. POLITICO's publication of false statements impute that Plaintiff has committed

an infamous crime, i.e., treason and/or other crimes against the United States of America by

attempting to undermine American democracy and the 2020 Presidential election.

158. As a direct and proximate result of the defamatory statements published by

POLITICO, Plaintiff has suffered, and continues to suffer, substantial damages, including the

loss of his business.

159. Upon information and belief, and based on the prejudicial October 10 article,

POLITICO intended to harm the Plaintiff (among others) through the publication of the false

statements.

160. POLITICO had actual knowledge of the falsity of the claims and understood the

high probability that injury or damage would result to Plaintiff and, despite such knowledge,

broadcast the false and defamatory statement and has issued no apology to the Plaintiff such as

would repair that damage.

161. In the alternative, POLITICO's actions, as described above, were so reckless or

wanting in care that they constituted a conscious disregard or indifference to the rights 'of

Plaintiff.

Prayer for Relief

WHEREFORE, the Plaintiff JOHN PAUL MAC ISAAC prays for judgment against the

Defendant POLITICO as follows:

(a) Awarding Plaintiff all compensatory damages in excess of $75,000 as a result of

POLITICO's wrongdoing in an amount to be determined at trial;

(b) Awarding Plaintiff punitive damages as a result of POLITICO's wrongdoing in an

amount to be determined at trial;

 (c) Awarding Plaintiff pre- and post-judgment interest;

(d) Awarding Plaintiff all attorneys' fees and costs associated with litigating this

case;

(e) Requiring all Defendants to make a public retraction of all false statements and to

issue a public apology to Plaintiff; and

(f) Such further relief as this Court deems just and proper.

G. COUNT 6: CIVIL CONSPIRACY TO COMMIT DEFAMATION

ALL DEFENDANTS

162. Plaintiff incorporates by reference all allegations contained in Paragraphs 1 - 161.

163. The Defendants all expressed support for then-Presidential candidate, Joseph R.

Biden in the 2020 U.S. Presidential election.

164. The - Defendants all expressed vehement opposition to President Donald J. Trump

in the 2020 U.S. Presidential election.

165. The information contained in the NY POST expose would have hurt the

candidacy of Joseph R. Biden and, potentially, prevent his election.

166. The Defendants all knew that the information contained in the NY POST expose

would hurt the candidacy of Joseph R. Biden and, potentially,. prevent his election.

167. Voters who voted for Joseph R. Biden have indicatd that, if they had known

more about the Hunter Bideñ laptop, they likely would not have voted for Joseph R. Biden.

168. The Defendants would do everything within their power to prevent the re-election

of President Donald J. Trump, including defaming Plaintiff and others.

169. SCHIFF is a powerful member of Congress.

170. Defendants, CNN, DAILY BEAST, and POLITICO are powerful media outlets

who have loyal readers/viewers all over the world.

 171. The Defendants all openly participated in the efforts to kill the Hunter Biden

laptop story including painting those involved (including the Plaintiff) as willing participants in a

Russian disinformation scheme.

172. The Defendants all openly participated in the efforts to falsely communicate to the

general public that the Hunter Biden laptop story is Russian disinformation and that those

involved (including the Plaintiff) are working with the Russians to influence the U.S.

Presidential elections.

173. In doing so, the Defendants have unlawfully defamed the Plaintiff on numerous

occasions.

174. As a result, Plaintiff has suffered significant damages including the loss of income

from having to close his business.

Prayer for Relief

WHEREFORE, the Plaintiff JOHN PAUL MAC ISAAC prays for judgment against the

Defendants as follows:

(g) Awarding Plaintiff all compensatory damages including consequential and

incidental damages as a result of Defendants' wrongdoing in an amount to be determined at

Trial;

(h) Awarding Plaintiff punitive damages as a result of Defendants' wrongdoing in an

amount to be determined at Trial;

(i) Awarding Plaintiff pre- and post-judgment interest;

(j) Awarding Plaintiff all attorneys' fees and costs associated with litigating this

case;
 (k) Requiring all Defendants to make a public retraction of all false statements and to

issue a public apology to Plaintiff; and

(1) Such further relief as this Court deems just and proper.

DEMAND FOR JURY TRIAL

Plaintiff requests a trial by jury on all issues raised herein.

Date: May 3, 2022 Respectfully submitted,

Brian R. Della Rocca, Esquire

Bar ID: 21781
Compass Law Partners
51 Monroe Street, Suite 408
Rockville, Maryland 20850
Ph: (240)560-3030
Fax: (301) 740-2297
bde1laroccaccompass-law.com

Attorneys for Plaintiff