Case 1:19-cv-00618-UNA Document 1 Filed 04/02/19 Page 1 of 25 PagelD #: 1
IN THE UNITED STATES DISTRICT COURT 1 9 - 6 i 8 FOR THE DISTRICT OF DELAWARE
LAURA WILLIS LUHN, An individual Los Angeles, CA
Plaintiff, CIVIL ACTION COMPLAINT v. FOR VIOLATIONS OF THE SHOWTIME NETWORKS, INC., A Delaware LANHAM ACT AND OTHER Corporation CAUSES OF ACTION Registered Agent Listed As: Corporation Service Company JURY TRIAL DEMANDED 251 Little Falls Drive Wilmington, DE 19808
and
BLUMHOUSE PRODUCTIONS, LLC, A Delaware Limited Liability Company Listed As: Registered Agent - Corporation Service Company 251 Little Falls Drive • Wilmington, DE 19808
- and ro GABRIEL SHERMAN, An individual 3537 78th St. #41 Jackson Heights, NY 11372
Defendants.
VERIFIED COMPLAINT FOR VIOLATIONS OF THE LANHAM ACT AND OTHER CAUSES OF ACTION
I. INTRODUCTION
Plaintiff Laura Willis Luhn, former Senior Director of Corporate and Special Events, former Director of Booking and Associate Producer for Fox News, ("Plaintiffor "Plaintiff
Luhn"), by counsel, sues Defendants Showtime Networks, Inc. ("Showtimc"), Blurnhouse
Productions, LLC dba Blumhouse Television (Blumhouse"), and Gabriel Sherman ("Sherman') acting at all material times in concert, jointly and severally, in this civil action for violations of the Lanham Act, 15 U.S.C. §§ 1051 et seq., negligence, and unjust enrichment as a result of
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damages, and Defendants, each and every one of them, causing actual damages, compensatory and an of continuing giving rise to punitive, treble darnages and award attorneys fees, including and livelihood. As aggravated harm to Plaintiff s professional, business and personal reputation grounds therefore, Plaintiff alleges as follows:
II. JURISDICTION AND VENUE
15 U.S.C. 1051 et seq., 1. This is an action for violations of the Lanham Act, §§ negligence and unjust enrichment.
over Plaintiff s claims to 28 2. This Court has subject matter jurisdiction pursuant
a arises under the federal Lanham U.S.C. § 1331 (federal question) in that this is dispute that
matter pursuant to 28 Act, 15 U.S.C. §§ 1051 et seq. The Court also has subject jurisdiction
s claims. U.S.C. § 1367 (supplemental jurisdiction) for Plaintiff additional Showtime because Showtime 3. This Court has personal jurisdiction over Defendant
the laws of Delaware and therefore is subject to this Court's is a corporation organized under
and a of the allegd personal jurisdiction because it resides in this judicial district large portion
acts arose in this district.
Showtime because it has 4. This Court also has personal jurisdiction over Defendant
but not maintained continuous and systematic contacts with the State of Delaware, including
to other marketing, limited to, purposefully availing itself this forum by, among things, making,
or others to offer to sell, or sell products shipping, using, offering to sell or selling, causing use, from such activities. and services in the State of Delaware, and deriving substantial revenue
Blumhouse because 5. This Court has personal jurisdiction over Defendant
under the laws of Delaware and therefore is Blumhouse is a limited liability company organized
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and a because it resides in this judicial district large subject to this Court's personal jurisdiction in this district. portion of the acts alleged herein arose because it over Defendant Blumhouse 6. This Court also has personal jurisdiction but not contacts with the State of Delaware, including has maintained continuous and systematic
to this forum by, arnong other things, making, marketing, limited to, purposefully availing itself others to use, offer to sell, or sell products shipping, using, offering to sell or selling, or causing from such activities. and substantial revenue and services in the State of Delaware, deriving he has over Defendant Sherman because 7. This Court has personal jurisdiction but not with the State of Delaware, including maintained continuous and systematic contacts other himself to this forum by, arnong things, making, limited to, purposefully availing to use, offer to sell, or or or causing others marketing, shipping, using, offering to sell selling, his New York Times Bestselling in the State of Delaware, including sell products and services such activities. and substantial revenue from Book "The Loudest Voice in the Room", deriving and 28 district to 28 U.S.C. § 1391(b)(3) 8. Venue is proper in this judicial pursuant with to the Court's personal jurisdiction U.S.C. § 1391(c)(2) because Defendants are subject
respect to this action.
III. PARTIES State of natural who is a citizen of the 9. Plaintiff Luhn is an individual, person
Plaintiff is not a public figure. California, County of Los Angeles. and satellite television network corporation 10. Defendant Showtirne is a cable has of Delaware. Defendant Showtime purposefully incorporated under the laws of the State
availed itself to this Court.
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company incorporated is a film and television production 11. Defendant Blumhouse availed itself to Defendant Blumhouse has purposefully under the laws of the State of Delaware. this Court. of who is a citizen of the State is an natural person 12. Defendant Sherman individual, himself to this Court. has availed New York. Defendant Sherman purposefully
IV. STANDING she has been directly and to this action because 13. Plaintiff Luhn has standing bring herein. Her injuries are the unlawful conduct complained actually affected and victimized by and one of them, jointly of Defendants, each and every proximately related to the misconduct severally.
V. FACTS and Defendant Sherman, acting and Defendant Blumhouse 14. Defendant Showtime and will be airing an eight-episode are currently filming in concert, jointly and severally, Channel (Fox Officer (CEO") of Fox News miniseries about the former Chief Operating who was accused of Network ("FBN"), Roger Ailes ("Ailes"), News") and CEO Fox Business in in 2016 and other before resigning disgrace decades of sexual harassment and illegalities
dying a year later. of the eight-episode miniseries. 15. Plaintiff Luhn is an integral part the Fox News Channel. of the staff which launched 16. Plaintiff was a part original D.C. headquarters in the summer of 1988 at the Washington, 17. Plaintiff met Ailes
on the staff at the campaign. campaign while she was of the George H.W. Bush presidential News on August 12, 15 for Fox beginning 18. Plaintiff spent ahnost years working Snow, Plaintiff was part of the staffer for Fox News Sunday with Tony 1996 as a Guest Relations
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in the Bureau. News Channel and was based Washington original staff that launched the Fox and was part of the Special to Associate Producer/Guest Producer Later, Plaintiff was promoted former Bill the Kenneth Starr investigation and president Report with Brit Hume staff during for the Fox Plaintiff later became the Director of Booking Clinton irnpeachment proceedings. New York In staff in both Washington, D.C. and City. News Channel that included managing and Events. This new to Senior Director of Corporate Special 2007, Plaintiff was promoted the on the VIP launch event for to New York City working position required commuting weekly held in Executive Chairman of News Corp, Rupert Murdoch, Fox Business Network hosted by
of Art in New York City. October at the Metropolitan Museum Abuse by Roger Ailes and Fox News Facts Pertaining to Sexual and Psychological at Ailes demanded, Plaintiff s time on staff Fox News, 19. During the entirety of forced sexual favors from her, making impossible, coerced, extorted, blackmailed and that demands and using abusive rnind control techniques frightening, dangerous and unrealistic at the Central Ailes had that he conducted training he referred to as her "training." bragged in line and to him." He this was his to keep "Plaintiff loyal Intelligence Agency (CIA") and way she needed her he felt her slipping up and that would periodically call her in Washington telling
more "training." she was to tell Ailes reinforced to Plaintiff that 20. The immensely powerful always and which is why his abusive and tactics demands, no one about what she considered threatening Ailes retribution during her tenure with Fox News. she remained very fearful of Ailespromised orders. The "orders" and that she was expected to follow told her to think of it as the military life. Ailes Plaintiff of the Plaintiff s work life and personal required were implied in every aspect "useful." heard or seen that he would find "to report ie anything she had
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and act like Doris Day. to follow orders like G.I. Jane" 21. Plaintiff was told to wear for Ailes, to black garters and stockings 22. Plaintiff was forced purchase in the middle of the day and He her to leave her job which he called her "uniform." required This was her to wear the "uniform." particularly meet him in various hotel rooms requiring for a show and had to Plaintiff, as she was booking guests painful, humiliating, and embarrassing reminded Plaintiff, "I the producers she felt ill. Ailes constantly to excuse herself, falsely telling
own you." her she needed to in June of 2004, Ailes told 23. When Plaintiff received a promotion Ailes told While in his office at Fox News Headquarters (HQ"), "thank him" as a quidpro quo. thank him for on her "uniform" and Hotel in Times Square, put Plaintiff to go to the Doubletree to and oral sex in order Plaintiff to meet him at the hotel perform the promotion. Ailes forced was explained to Plaintiff. As the promotion thank him for the promotion, continuing manipulate DC Bureau Chief. Ailes to Kim Hume, the Washington to Plaintiff, she would no longer report Shine. That actually — to Bill to New York specifically told her that she would be reporting the Fox News ("HQ"), on the second floor of Headquarters included anyone from management Laterza and others. Kevin Irene Briganti, Judy usually Suzanne Scott, but also Magee, circle came with the email from anyone in Ailesinner 24. A telephone call or orders" no matter the Ailes implying "following understanding that it was what wanted, to orders. This created understood that you were never question consequence. It was absolutely role as while try to function in her new of rnistrust toward Plaintiff, especially an atrnosphere in the D.C. Bureau. in a hostile environment Washington Manager ofBooking, operating Plaintiff to make her Fox Travel Ailes required 25. Instead of using the Department, where most not at the Muse Hotel, Ailes was adamant that Plaintiff stay own hotel arrangements.
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the Doubletree at Times Square, was to contact directly of the Fox staff stayed. Plaintiff expected ordered that Plaintiff stay at or the Omni Berkshire. Ailes the Renaissance Hotel Times Square caused further "safe" and convenient for him. This hotels that he had concluded were raised concerning her hotel embarrassment and humiliation for Plaintiff with questions arrangements the Doubletree was for him, Plaintiff was 26. However "safe" Ailes had concluded the June 2004 in November 2006, almost 2 'A years after informed by a co-worker, Jama Vitale, New York Michael Dukakis and a producer in the promotion, that Peter Zorich, nephew to Plaintiff and a few minutes later, had seen depart. bureau, had witnessed Ailes leave the hotel Fox News but had run into Cal Thomas, a 27. Plaintiff was unaware of Zorich,
Ailes later told Plaintiff that he had Contributor while departing to take a cab to the airport.
when visited with Cal Thomas in the hotel lobby departing.
Ailes was embroiled in a sexual 28. It is noteworthy that by October 2004, Andrea Mackris against Bill O'Reilly. harassment lawsuit filed by Fox News Channel producer to had terrified Ailes and his inner circle just enough After settling, the Andrea Mackris situation
or future from Plaintiff Luhn. preempt any perceived threat litigation Plaintiff inner circle tactics to "discredit" 29. It was as if the entire Ailes employed
work environment for Plaintiff, whom right after the Mackris fallout. This created an impossible
they had set up to fail. York and Ailes fueled harmful gossip in New 30. This pattern of conduct by of from her co-workers and the management Washington D.C., further alienating Plaintiff Luhn and the and escalated as the years went on, Fox News. Ailesthreatening brazenness arrogance and threatened Plaintiff, reminding her demands became more frightening. Ailes manipulated
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taken of her in a safe-deposit and videos that he had that he kept the compromising photographs to would remain both silent and loyal "insurance so that she box and that they were his policy" and to frorn his predatory threatening no realistic options get away him. Blackmailed, and with her to meet him to when he ordered in with no choice but comply behavior, Plaintiff felt boxed and she were most effective abusive and intense mind control techniques in a hotel room. The friend. Plaintiff was required her that he was her only to trust the man who told had no choice but vulnerable on the Plaintiff s extremely her to Roger Ailes, playing to consistently pledge loyalty position. to also play the role of behavior continued, Ailes continued 31. While this abusive to her off balance. Yet, to Plaintiff and meant keep "mentor" to Plaintiff, which was confusing
no rnatter how to follow his orders, outrageous. she was expected when on 11, 2001 of time after the terror attacks September 32. There was a period was a wanted her to meet. The "friend" he had a "frienr he Ailes told Plaintiff Luhn that asked Hotel in Times Square. Plaintiff was to a suite at the Renaissance woman he had brought and Plaintiff recalls Ailes being threatening with Ailes and his "friend." to perform 3-way sex from the There were remains traumatized to this day experience. forceful. She was telTified and that with his "friend." The last meeting in New York hotel rooms at least three other meetings York in October 2005. Plaintiff Omni Berkshire Hotel in New Plaintiff recalls took place at the felt the trauma and sickness she that She will never forget recalls Ailes with a camera on day. of his often reminded the Plaintiff her with that woman. Ailes when she saw him photograph of the emotionally his collection of compromising photographs "loyalty requirement" and of in there Laurie!" and Ailes screaming to Plaintiff, "get shattered Luhn that he "owned." kept "friend." violently shoving her into his
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extorted and threatened Plaintiff in 33. Ailes photographed, coerced, blackmailed, to both the disseminated false statements and smears Mafioso fashion for twenty years. He Plaintiff. Ailes used character staff of Fox News, defaming management, on-air talent and false statements about s and intentionally gave assassination to damage Plaintiff reputation frorn his two decades long to create confusion and deflect Plaintiff to the media in an effort Plaintiff Luhn, and Ailes monitored, harassed and gaslit sexual harassment and abuse of Plaintiff. mental state causing severe mental her into a deeply depressed along with his aides, drove anguish and emotional distress. of the Vice Presidents of were overseen by one 34. Ailes hired contractors (which brass lock that could be accessed by to install a veiy large unusual Fox News, Warren Vandeveer in s front door at her Westchester apartment a key to Plaintiff a fingerprint and separate 729B. Curious neighbors Cathedral Avenue, NW, Apartment Washington, D.C., located at 4000 locks for obtrusive and unlike the standard building questioned Plaintiff about the lock. It was for the Plaintiff to and humiliating experience the Westchester. It was another embanassing humiliation and trauma. to Plaintiff s continuing pain, endure. Ailes was completely oblivious Plaintiff s apartment for her and protection. However, Ailes told her falsely that it was security
continued to be ransacked regularly. Plaintiff to cut off contact her tenure at Fox News, Ailes told 35. At one point during ordered her D.C. bureau and her personal friends, with both staff in the Fox News Washington, to to New York in order for him in D.C. and move to sell her co-op apartment Washington, of Stockholm This Plaintiff was a classic victim Syndrome. monitor her and control and use her. to suffer as a and one that she has continued Plaintiff s psychiatrist, was part of a diagnosis by
messages from Ailes. result of years of abuse and conflicting
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and demand sex. 36. Ailes would call Plaintiff at her desk in Washington phone
friends" and that he was her 37. Ailes continuously told Plaintiff that she had "no
Plaintiff. "You need to do this for me, only friend in the world. "I'll protect you," Ailes told
continued to threaten Plaintiff by telling her not stay quiet and show your loyalty, Laurie." Ailes
Ailesinner circle at Fox News, which included Judy to trust anyone with the exception of
now the Chief Officer at Laterza, Michael Tammero, Bill Shine, and Suzanne Scott, Operating
Fox News.
Bureau of Fox News in 1996, 38. Ailes had installed Plaintiff in the Washington
Ailes Plaintiff to report telling her that she would be his "eyes and ears in Washington." required
within the staff, and on-air talent of to him any signs of what he called "disloyalty" management,
not fall in line with Ailes' editorial agenda. This Fox News, and that included anyone who did
of their views on later included on-air guests that Ailes deemed unsuitable because particular and at hand or his whim. Ailes was an extremely vindictive policy, whatever may be the topic
him for reason. It was an unwritten policy that mean person towards guests who "displeased" any
her as Director of due to an impending expose by got so out of hand, Plaintiff lost job Booking
not so known as Ailes' Brody Mullins of The Wall Street Journal and what became fondly
at the time. The Wall "blacklisting" of guests appearing on Fox News. It was a huge controversy
was removed from the news division and Street Journal did not run the piece because Plaintiff
to Ailes. was considered no longer "relevant," according Plaintiff that she would need 39. Media Relations Vice President Irena Briganti told
the rumors and the Plaintiff to be removed from the Booking Unit because of gossip surrounding
and Ailes were and Ailes. The Media Relations Department and the very volatile paranoid
Journal from this expose on Fox News making every effort to stop The Wall Street publishing
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and Ailesculture under close "blacklistine because it would no doubt put the entire operation abusive Ailes/Luhn relationship. scrutiny for their disreputable editorial approach and the highly
Bill who removed Plaintiff Here, it was actually Briganti, not her supervisor Shine, effectively her boss in a move to (always) protect from her position as Director of Booking preemptive
no matter the collateral damage, the lies (Ailes) from scrutiny and negative press or exposure,
of a or the lives that were As part larger that were told, the extent of the cover-up, destroyed.
Ailes tasked the Media Relations strategy and reflective of the "culture" of Fox News, This Ailes "cover" and Department with the role of smearing and discrediting Plaintiff. provided
to the media." plausible deniability since he could not be held responsible for "whispers
traumatic as it was 40. The removal of Plaintiff from the news division was severely
her. With his tremendous power and actually a cover-up for Ailes' crimes perpetrated against
and kill the Wall Street Journal piece in an effort to influence, Ailes was able to shift the focus and editorial deflect from his sexual abuse. Ailes had always used Fox News programming
scores with enemies, real or content to impose his own political views and biases; settling
to those views that he deemed perceived. Ailes installed Fox News Contributors agreeable from of the attacks. He "loyal" and paid them handsomely. He skillfully shielded himself many
some of the on-air talent and depended on his inner circle of loyal lieutenants, including He seemed to treat character contributors as layers of protection from negative press.
at and He even assassination like a game, one that he was well-skilled quite enjoyed. employed
his personal attorney, Peter Johnson, Jr. as a Fox News Contributor. of Fox 41. Plaintiff had been referred to as "Roger's spy" since the early days News,
Plaintiff both within the organization and in the greater political and journalistic comrnunity. innuendo that suffered greatly by this designation and the continuing gossip and permanently
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endured recovered — as she has unimaginable darnaged the Plaintiff's reputation — never to be including loss of family relationships. pain and sadness, while at the same time being defamed, and Media Relations Department to 42. Ailes also utilized Fox NewsManagement
to Ailes rnade a management decision destroy monitor, harass, threaten, and gaslight Plaintiff. her as a future in an effort to "discredit" both Plaintiff s confidence and reputation completely
abuse. witness against Ailes' illegal acts and sexual Plaintiff her, "I own you." 43. For twenty years, Ailes threatened by telling her fear Plaintiff had a stalker. Ailes fueled 44. Starting in 2006 and into 2007,
should not in her Washington D.C. co-op apartment and kept her terrified by telling her she stay Hotel in New York under the name Suzanne that she owned. Ailes had her stay at the Warwick where It was a and halTowing experience Scott, who is today the CEO of Fox News. frightening
with even old, personal friends. Ailes required Plaintiff to cut off all communication everyone, He and emails to him for "approval." Ailes forced Plaintiff to provide all incoming outgoing
- the Plaintiff feel the Plaintiff to send. It was classic Ailes making even dictated responses for the stalker on him. Plaintiff was fearful because owned, controlled and completely dependent
on a basis. Ailes told the Plaintiff had been ransacking her Washington D.C. apartment regular
to kill her. that George Soros and Hillary Clinton were trying
he referred to as and forbade 45. Ailes had constantly demanded what "loyalty"
- or — Dr. David Fischer friends family Plaintiff from telling her Washington D.C. psychiatrist abuse. She remained silent for 20 years, about the constant sexual, emotional and psychological
destructive abuse she endured bottled up inside, becoming deeply depressed by keeping the traumatized Plaintiff was completely isolated resulting in humiliation and embaiTassment. The for malicious gossip and rumors, from Fox News staff and remained a prirne target painful
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and to Los Angeles in 2011. Ailes eventually driving her from Washington D.C. moving
— her and on him intentionally keeping exploited the Plaintiff s vulnerable position dependency Mafioso tactics, gaslighting and off balance through his destructive mind control techniques, harassment by his aides, causing severe psychological damage. Plaintiff about aspect of her life. 46. Ailes threatened, harassed and questioned eveiy
her on whom she could "trust," This included probing her personal life and constantly instructing
her to cut off relationships with whom she could have as friends, including forcing existing
that the Plaintiff could not trust anyone. friends and colleagues. Ailes was very insistent for years within Fox News and the community as Therefore, this resulted in complete isolation both from Luhn. This obsession of a obsession with Plaintiff a whole. Roger Ailes was guilty decades-long
and toxic to the Plaintiff. was sadistic and proved dangerous highly
— — at the direction of Ailes ordered 47. In 2011, Bill Shine, Ailesright-hand man
a few — took — in Los This event place Plaintiff to vacate her apartment with zero notice Angeles. 2011 about a one on February 24, Roger days after The New York Times published page stoiy
a involving key Ailes urging Judith Regan to lie to federal investigators regarding cover-up
9/11 terror attacks. figures, such as Bernard Kerik ofthe
to her home in San 48. Shine hired Pinkerton Security and sent Plaintiff family
had to be checked out due to stalkers. Antonio, telling her that the Los Angeles ("LA") apartment her Soros was to kill her, which kept Ailes had continued to tell the Plaintiff that George trying
LA her stay with her parents, terrified because she was being terrorized at the apartment. During based at the University Bill Shine, Ailes' top deputy, sent Plaintiff to a handpicked psychiatrist and her from speaking out of Texas Health Science Center in an effort to manipulate prevent
about the sexual and psychological abuse.
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the General of the 49. While in San Antonio, Plaintiff contacted the office of Attorney
that there were rumors online and United States, Eric Holder, on the telephone. It is noteworthy
which terrified the Plaintiff because she was tied in the press that Roger Ailes was to be indicted,
to a confidential conversation with Holder to him. Plaintiff explained that she would like have
not the call to the Attorney regarding Fox News. Mr. Holder's assistant would put through Assistant U.S. Jim General. Instead, Plaintiff was directed to meet with First Attorney time Blankenship ("Blankenship") in San Antonio. A veiy shaken and frightened Plaintiff spent that she endured at the outlining in graphic detail the years of abuse and psychosexual torture hands of Ailes.
and his were dismissive and 50. Blankenship, a George H.W. Bush appointee, aide,
on the serious claims did not take her seriously or rnake any effort to follow up very regarding Dr. Camis Milam ("Dr. Ailes. The rneeting was cut short when the Shine-picked psychiatrist, office in San Milam"), called her out of the meeting while she was in the U.S. Attorney's
to the Antonio. On the telephone, Dr. Milam threatened to adrnit the Plaintiff hospital psych
ward that veiy night if she did not leave immediately.
a mental 51. In fact, the doctor admitted Plaintiff to the psychiatric ward at hospital
U.S. of Justice. 48 hours later. Dr. Milam scolded the Plaintiff for contacting the Department
were in direct and constant Both Bill Shine and Dianne Brandi, Legal Counsel for Fox News,
her for — to Plaintiff and contact with Dr. Mil= including issuing threats the scolding contacting
a co-worker at Fox News.
as and 52. This was part of Ailesstrategy to paint Plaintiff "crazy, delusional,
his and sexual abuse. paranoid" and to discredit any possible testimony regarding psychological
s father this time As acts of intimidation, Bill Shine also frequently called Plaintiff during asking
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questions about her. Dr. Milam referred 53. When Plaintiff returned to her LA apartment, indirectly
settlement with Fox News. Plaintiff to an attorney in order to negotiate
was in no mental or emotional 54. However, Fox News executives knew that Plaintiff from on medication that prevented her condition to negotiate settlement, as she was serious
of a Plaintiff was traumatized and frightened media having a clear head or thinking logically. spectacle if she filed suit against Fox News.
of as she was and 55. Plaintiff never received proper assistance counsel, pressured
the conflicted attorney who deceived, if not fraudulently induced, into settlement by unethically
— when — who was in concert with Fox News was referred indirectly by Dr. Milam working
action was ever filed, and Plaintiff, in a Plaintiff really needed to file a legal action. No legal
was coerced and fraudulently heavily medicated, hazy, and foggy mental state, pressured,
induced into agreeing to settlement. and 56. The entire "settlemenr process was rushed through slapped together
s all closely together. extremely quickly by Ailes, Dianne Brandi, and Plaintiff attorney, working and life 57. Plaintiff has suffered and continues to suffer serious, debilitating
as a result of Ailessevere threatening trauma, anxiety and other serious health complications
was covered and furthered by his inner circle, psychological torture and mind control. This up
Bill Brian Irena Briganti and Suzanne including but not limited to Judy Laterza, Shine, Lewis, her with Ailes and Fox Scott. Emotionally shattered and deeply depressed by tragic experience
twice suicide and to this day continues News and a with destroyed reputation, Plaintiff attempted
of intermittent and hopelessness. She to be severely damaged with PTSD and bouts anxiety
The and severe damage continues to feel isolated and ostracized by society. long-term impact
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and the and complicity of his caused by Ailesmind control techniques, cover-up still and abovementioned top aides, and the resulting Stockholm Syndrome gripping strangling
able to reach closure this the Plaintiff is incalculable. Plaintiff has never been through ongoing
in loss of income and any chance of a healthy painful process of defamation, a tragedy resulting existence.
a New York law firm hired by 21st 58. After Ailes resigned in 2016, Plaintiff called
him. Century Fox to investigate sexual-harassment allegations against harassed Plaintiff for over two 59. Ailes sexually, psychologically and emotionally decades.
Facts Pertaining to The Loudest Voice in the Room
Blumhouse and Defendant 60. Defendant Showtime, by and through Defendant
The Loudest Voice in the Sherman, acting in concert, jointly and severally, is currently filming Ailes. Room and will soon air the eight-episode rniniseries about Roger
miniseries is based on the 61. Defendant Showtime's and Defendant Blumhouse's
stars Russell Crowe as Ailes, Naomi Watts as book and prior writings of Defendant Sherman and
Ailes of sexual and Gretchen Carlson, the first prominent person to publicly accuse harassrnent,
has cast A-list actress Annabelle Wallis as Plaintiff Luhn.
to be her 62. Defendant Sherrnan coerced and induced Plaintiff interviewed, telling
and that she was in and thus sharnelessly through an intermediaiy, Madelon Highsrnith, "danger"
as so-called When cruelly lured her to be interviewed by Defendant Sherman "protection." Defendant Sherman told Plaintiff expressed hesitation about going forward with the interview, her June 2011 Plaintiff that he had heard from a NewsCorp executive that 15, Separation
to induce her to be Agreernent: "was not worth the paper it was printed on." Defendant Sherman,
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Fox News had interviewed, further stated that he knew of instances where the Agreement by
— in violation of the been broken and that the Plaintiff had been disparaged by Fox News
and Shine. Separation Agreernent and Mutual General Releases signed by Ailes of audio 63. Defendant Sherman recorded the interview with over 11 hours including
Jennifer Stahl of the New accessing the Plaintiff s computer with Defendant Sherman's wife,
interview — which took Yorker, who unexpectedly accompanied Defendant Sherman for the
California. Defendant Sherrnan lies, place at the Plaintiff s residence in Encino, published
He on promoted, marketed and monetized Plaintiff s severe pain, trauma and tragedy. capitalized
and an terrified, confused, and her very vulnerable state of mind, PTSD exploited already
cashed in on Plaintiff s tragic Fox News emotionally shattered woman. Defendant Sherman
so much as a experience and the psychosexual torture she endured by Ailes without courtesy notification regarding the Showtime and Blurnhouse series, damaging Plaintiff s reputation. titled 64. Prior to this, Defendant Sherman published an article on July 29, 2016,
"Foriner Fox News Booker Says She Was Sexually Harassed and 'Psychologically Torturedby
and Roger Ailes for More Than 20 Years", which contains several false, misleading defamatoiy
and false statements be statements and innuendos. When Plaintiff demanded that the misleading
on to retracted and/or corrected, Defendant Sherman ignored her requests and proceeded profit
and life of from his works which used, however inaccurately, the likeness and being story
Plaintiff.
65. Defendants Showtime, Blumhouse and Sherman use Plaintiff s identity, name,
s to market, sell, likeness, persona, privacy rights and otherwise (Plaintiff Rights") advertise,
and commercial services. and promote and sell Defendants' rniniseries, commercial products,
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and use 66. In addition to using Plaintiff s Rights, Defendants, on information belief,
innuendos and Defendant Sheiman's false, misleading and defamatory statements and present
Sherman claimed that Plaintiff them as facts in their miniseries. In particular, Defendant falsely
as well as that she had a Luhn sent Ailes women to his office "after hours" falsely representing history of mental illness, among other perversions ofthe truth.
claimed that Plaintiff fired a 67. As just one example, Defendant Sherman falsely
cause. The article was neither fact- staffer, when in reality Human Resources fired that staffer for checked as promised nor corrected.
to of to use 68. At no thne did Plaintiff ever give permission Defendants, any them,
and sell Defendants' Plaintiff s Rights or otherwise to associate with, advertise, market, promote
she Defendant Sheiman miniseries, commercial products, or for any other purpose. Nor did give
a and of her life in particular the right to use her likeness and being to produce manuscript script
The miniseries story to sell to the other Defendants to line his own pockets. eight-episode
to the prominently features this life story and a prominent A-list actress has been cast play prominent role and part of Plaintiff Luhn. commercial 69. Plaintiff has not received any compensation for such unauthorized
to market and sell Defendants' use of Plaintiff s Rights and otherwise advertise, promote,
miniseries, products, and services.
70. Plaintiff is infoimed and believes that Defendants intentionally, purposefully,
market and sell recklessly, and/or negligently used Plaintiff s Rights to advertise, promote
Defendant's miniseries, products and services.
71. Defendants have, without any right, title or authorization, misappropriated
and financial reward. Plaintiff s Rights for their own commercial purposes resulting
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to resolve the serious matters set 72. Plaintiff and her undersigned counsel have tried
one of have refused, forth in this Verified Complaint but Defendants, each and every them,
the entertainment obviously believing that their self-styled powerful standing in Hollywood, would dissuade Plaintiff from filing industry and elsewhere and far superior financial positions Trernaine brushed Plaintiff this lawsuit. As a result, Defendantslaw firm, Davis Wright initially
from Plaintiff Luhn's and aside, to allow their clients to continue to exploit and profit tragic in their works by and abusive past with Ailes and Fox News, which is prominently portrayed through A-list actress Annabelle Wallis, who was cast to play Plaintiff.
CAUSES OF ACTION
COUNT ONE Federal Unfair Competition Lanham Act §' 43(a), 15 U.S.C. § 1125(a)(1)(A) (Against All Defendants)
of the 73. Plaintiff repeats, re-alleges, adopts and incorporates all previous allegations
as if set forth of the entirety of this Verified Complaint, with the same force and effect, fully
herein again at length.
not limited to its 74. Defendants' distribution of the miniseries, including but
use Plaintiff s promotions, advertisements, sales and commercial activities, all of which Rights,
as to the source or affiliation of Defendants' is likely to cause confusion, rnistake or deception
goods and services and otherwise related to her life story. that Plaintiff 75. Defendants' unauthorized use of Plaintiff s Rights falsely indicates
or by, or Luhn or her agents are connected with, sponsored, endorsed, authorized, approved
affiliated with Defendants, or that Defendants are connected with, sponsored, endorsed,
Plaintiff s authorized, or approved by, or affiliated with Rights.
19 Case 1:19-cv-00618-UNA Document 1 Filed 04/02/19 Page 20 of 25 PagelD #: 20
their 76. Defendants unauthorized use of Plaintiffs Rights in connection with
has miniseries allows Defendants to receive the benefit of Plaintiff s goodwill, which she
Fox News Channel established at great labor and expense professionally as one of the original
to of staffers, and her public appearances, and further allows Defendants gain acceptance
but on the hard work and of Plaintiff s Rights based not on the miniseries, reputation, goodwill
Plaintiff.
77. Defendants have unfairly profited from their false and/or misleading representations.
78. Plaintiff has been damaged by Defendantsfalse and/or misleading representations.
79. Defendants' acts are wilful and Plaintiff is entitled to treble damages.
80. The unlawful acts of Defendants complained herein constitute unfair competition in violation of Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a)(1)(A).
COUNT TWO Federal False Designation of Origin Lanham Act § 43(a), 15 U.S.C. § 1125(a)(1)(B) (Against All Defendants)
81. Plaintiff repeats, re-alleges, adopts and incorporates all of the previous allegations
as set forth of the entirety of this Verified Complaint, with the same force and effect, if fully
herein again at length.
82. Defendants' distribution of the miniseries, including but not limited to its
promotions, advertisements, sales and commercial activities, all of which use Plaintiff s Rights,
misrepresents the nature, characteristics, qualities, and/or geographic origin of Plaintiff s Rights,
including her goods, services, and/or commercial and other activities.
20 Case 1:19-cv-00618-UNA Document 1 Filed 04/02/19 Page 21 of 25 PagelD #: 21
83. Defendantsunauthorized use of Plaintiff s Rights and nature, characteristics, qualities and/or geographic origin in connection with their miniseries allows Defendants to
and receive the benefit of Plaintiff s goodwill, which she has established at great labor expense
and further allows Defendants professionally as one of the original Fox News Channel staffers,
hard to gain acceptance of Plaintiff s Rights based not on the miniseries, but on the reputation, work and goodwill of Plaintiff.
84. Defendants have unfairly profited from their false and/or misleading representations.
85. Plaintiff has been damaged by Defendants' false and/or misleading representations.
86. Defendants' acts are willful and Plaintiff is entitled to treble damages.
87. The unlawful acts of Defendants complained herein constitute a false designation of origin, in violation of Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a)(1)(B).
COUNT THREE Negligence (Against All Defendants)
88. Plaintiff repeats, re-alleges, adopts and incorporates all of the previous allegations of the entirety of this Verified Complaint, with the same force and effect, as if fully set forth herein again at length.
89. At all times, and pursuant to applicable law, Defendants owed a duty to Plaintiff not to use Plaintiff s Rights in advertisements or otherwise to associate with, advertise, promote, market or sell Defendants' products and services.
21 Case 1:19-cv-00618-UNA Document 1 Filed 04/02/19 Page 22 of 25 PagelD #: 22
90. Defendants breached that duty by using Plaintiff s Rights in the advertisements and otherwise to associate with, advertise, promote, market or sell Defendantsproducts and services.
91. As an actual and proximate result of the aforesaid wrongful acts of Defendants,
Plaintiff has been damaged in an amount that is not yet fully ascertainable, but which exceeds the jurisdictional minimum of this Court.
92. As an actual and proximate result of the aforesaid wrongful acts of Defendants,
Plaintiff has suffered severe emotional distress and harrn in an amount to be determined at trial by a juiy.
93. As an actual and proximate result of the aforesaid wrongful acts of Defendants,
Plaintiff has suffered severe harm to her reputation in an amount to be determined at trial by a jury.
94. As an actual and proximate result of the aforesaid wrongful acts of Defendants,
Defendants have received and will receive large profits from and attributable to the unauthorized use, which Plaintiff is entitled to recover.
95. Plaintiff also seeks preliminaiy and permanent injunctions to prohibit Defendants for any further commercial use of Plaintiff s Rights.
COUNT THREE Unjust Enrichment (Against All Defendants)
96. Plaintiff repeats, re-alleges, adopts and incorporates all of the previous allegations of the entirety of this Verified Complaint, with the same force and effect, as if fully set forth herein again at length.
22 Case 1:19-cv-00618-UNA Document 1 Filed 04/02/19 Page 23 of 25 PagelD #: 23
97. By their wrongful acts and omissions, each and eveiy Defendant was unjustly enriched at the expense of and to the rnaterial detriment of Plaintiff Luhn.
98. Defendants were unjustly enriched as a result of the compensation and financial and other benefits they received while unjustly enriching themselves to the detriment of Plaintiff
99. Defendantsactions have caused, and will continue to cause, irreparable harrn to
Plaintiff, and will continue to so harm Plaintiff unless preliminarily and permanently enjoined.
100. Furthermore, Defendants are realizing profit and will continue to realize profits from its unlawful actions. Defendants' unlawful actions are causing and will cause Plaintiff monetary damage in amounts to be determined at trial.
101. Plaintiff seeks restitution frorn Defendants, each and eveiy one of them, and seeks an order disgorging all profits, benefits, and other compensation obtained from their wrongful conduct.
VII. PRAYER FOR RELIEF
(a) For general (non-economic), special (econornic), actual and compensatory damages in
excess of $250,000,000 USD;
(b) for additional consequential damages in a sum reasonable to a jury;
(c) for punitive darnages in excess of $500,000,000 USD to punish and irnpress upon
Defendants the seriousness of their conduct and to deter similar conduct in the future;
(d) for Defendants to immediately produce to Plaintiff Luhn the script and any already produced video and audio for the eight-part miniseries and for preliminary and permanent
injunctive relief to air this eight-part miniseries and to use Plaintiff s likeness, being and life
stoiy in any way without it being accurate and non-defamatoiy, as well as her being fairly
compensated for its use;
(e) for attorneys' fees, expenses and costs of this action, and;
23 Case 1:19-cv-00618-UNA Document 1 Filed 04/02/19 Page 24 of 25 PagelD #: 24
(f) for such further relief as this Court deems necessary, just and proper.
DEMAND FOR JURY TRIAL
Plaintiff Luhn demands a trial by jury on all counts as to all issues so triable.
24 Case 1:19-cv-00618-UNA Document 1 Filed 04/02/19 Page 25 of 25 PagelD #: 25
SIGNATURE AND VERIFICATION
in I, Laura Luhn, hereby swear under oath and penalty of perjury that the facts contained
belief. this Complaint are true and correct to the best of my personal knowledge and
Dated: April 1, 2019 Respectfully Submitted,
A AAA- ( k f'LOX—1R-1 Plaintiff Pro Se
OfCounsel Larry Klayman, Esq. KLAYMAN LAW GROUP, P.A. 2020 Pennsylvania Ave. NW # 800 Washington, D.C. 20006 Tel: (310) 595-0800 Email: leklayrnan(c-L)gmail.com Case 1:19-cv-00618-UNA Document 1-1 Filed 04/02/19 Page 1 of 1 PagelD #: 26
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