IN the UNITED STATES DISTRICT COURT for the DISTRICT of COLUMBIA US DOMINION, INC., DOMINION VOTING SYSTEMS, INC., and DOMINION
Case 1:21-cv-02130-CJN Document 1 Filed 08/10/21 Page 1 of 213 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) US DOMINION, INC., DOMINION ) VOTING SYSTEMS, INC., and ) DOMINION VOTING SYSTEMS ) CORPORATION ) c/o Cogency Global ) 1025 Vermont Ave, NW, Ste. 1130 ) Washington, DC 20005, ) ) Plaintiffs, ) ) v. ) Case No. ) HERRING NETWORKS, INC., d/b/a ) ONE AMERICA NEWS NETWORK ) 101 Constitution Ave., NW ) Washington, DC 20001, ) ) CHARLES HERRING ) 17353 Circa Oriente ) Rancho Santa Fe, California 92067, ) ) ROBERT HERRING, SR. ) 4289 Rancho Las Brisas Trail ) San Diego, California 92130, ) ) CHANEL RION ) 3211 Cherry Hill Lane, NW ) Washington, DC 20007, ) ) and ) ) CHRISTINA BOBB ) 565 Pennsylvania Ave., NW ) Apt. 803 ) Washington, DC 20001, ) ) Defendants. ) ) Case 1:21-cv-02130-CJN Document 1 Filed 08/10/21 Page 2 of 213 COMPLAINT AND DEMAND FOR JURY TRIAL April 18, 2021: “‘The majority of people [at OAN] did not believe the voter fraud claims being run on the air.’ . Mr. Golingan, the producer, said some OAN employees had hoped Dominion would sue the channel. ‘A lot of people said, “This is insane, and maybe if they sue us, we’ll stop putting stories like this out,”’ he said.” Former OAN Producer Marty Golingan, quoted in the New York times, and fired by OAN the day after the statements were published 1. On the actual facts, the November 2020 election was a huge success for Dominion. In jurisdiction after jurisdiction, in 28 states, in the midst of a highly disruptive pandemic, Dominion’s voting machines facilitated efficient and reliable voting with accurate tallying of votes.
[Show full text]