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CAUSE NO.

______

DR. RICHARD MALOUF, AND § IN THE DALLAS COUNTY


LEANNE MALOUF §
§
Plaintiff, §
§
V. § COURT AT LAW NO.
§
MARY CANDACE EVANS, LAURA C. §
WILSON, BELO CORPORATION, §
WFAA-TV, INC., AND BYRON HARRIS §
§
Defendants. § OF DALLAS COUNTY, TEXAS

PLAINTIFFS' ORIGINAL PETITION, APPLICATION FOR


TEMPORARY RESTRAINING ORDER, APPLICATION FOR INJUNCTIVE
RELIEF, AND REQUEST FOR DISCLOSURE

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW Dr. Richard Malouf ("Dr. Malouf') and Leanne Malouf ("Mrs.

Malouf')(collectively, "Plaintiffs" or "Maloufs"), Plaintiffs in the above-styled and numbered

cause, by and through their counsel Shamoun & Nonnan, LLP, complaining of Mary Candace

Evans ("Candy"), Lauren Wilson ("Wilson"), Belo Corporation ("Belo"), WFAA-TV, Inc.

("WFAA"), and Byron Harris ("Harris")(collectively, "Defendants"), Defendants in the above-

styled and numbered cause. In support of the foregoing, Plaintiffs would respectfully show the

Court the following:

I.
DISCOVERY

1. Discovery is intended to be conducted pursuant to Level 3 of Rule 190.3 of the

Texas Rules of Civil Procedure.

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II.
PARTIES

2. Plaintiff Dr. Richard Malouf, a natural person, is a private individual within the

meaning of Texas law and is a citizen of the State of Texas, and at all times relevant hereto has

resided in Dallas County, Texas.

3. Plaintiff Leanne Malouf, a natural person, i s a private individual within the

meaning of Texas law and is a citizen of the State of Texas, and at all times relevant hereto has

resided in Dallas County, Texas.

4. Defendant Mary Candace Evans, a natural person, is a private individual within

the meaning of Texas law and is a citizen of the State of Texas, and resides in Dallas County,

Texas. Evans may be served with service of process at her residence located at 1 1407 W. Ricks

Circle, Dallas, Texas 75230 or anywhere she may be found.

5. Defendant Laura C. Wilson, a natural person, is a private individual within the

meaning of Texas law and is a citizen of the State of Texas, and resides in Dallas County, Texas.

Wilson may be served with service of process at her residence located at 10621 Strait Lane,

Dallas, Texas 75229 or wherever she may be found.

6. Defendant Belo Corporation is a Delaware corporation registered to conduct

business under the laws of the State of Texas, with its principal place of business in Dallas

County, Texas. Belo may be served with process by and through its registered agent, Guy H.

Kerr at 400 South Record Street, Dallas, Texas 75202 or wherever he may be found.

7. Defendant WFAA-TV, Inc. is a Delaware corporation registered to conduct

business under the laws of the State of Texas, with its principal place of business in Dallas

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County, Texas. WFAA may be served with process by and through its registered agent, Guy H.

Kerr at 400 South Record Street, Dallas, Texas 75202 or wherever he may be found.

8. Defendant Byron Harris, a natural person, is a citizen of the State of Texas, and

resides in Dallas County, Texas. Upon information and belief Harris may be served with process

at his residence located at 3 70 1 Colgate, Dallas, Texas 75225, or at his place of employment,

WFAA, Belo, or wherever he may be found.

9. Plaintiff believes and hereby alleges that at all times mentioned herein, each of

Harris, Candy, and WFAA were the agents, representatives, employees, officers, or directors of

Belo, and acted within the scope and authority of such agency, employment, or authority and

with the knowledge, consent, approval, or ratification of Belo or other of Defendants. Unless a

particular Defendant is named, whenever this pleading references the acts of any Defendant or

Defendants, such allegations shall be deemed to mean the acts of those Defendants named in the

particular cause of action, and each of them acting individually, jointly and severally.

III.
JURISDICTION AND VENUE

I0. Venue is proper in this County Court at Law, Dallas County, Texas under § I5.0I7

Texas Civil Practices and Remedies Code because all of the parties worked and/or resided in

Dallas County, Texas at the time of the accrual of the cause of action. Venue is also proper in

Dallas County, Texas under Texas Civil Practices & Remedies Code § I5.0I7, because

Defendants committed libel, slander, and invasion of privacy in Dallas County, Texas, and the

choice of venue is at the Plaintiffs election.

II. This Dallas County Comi at Law has jurisdiction over the claims at issue in this

proceeding, as Plaintiff seeks to recover damages within the jurisdictional limits of the Court.

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IV.
PRELIMINARY STATEMENT

12. At all times material to this lawsuit, Dr. Malouf has been a licensed doctor of

dental surgery in the State of Texas. Dr. Malouf and his wife Leanne Malouf have resided at

their home for over four (4) years, located at 1071 1 Strait Lane, Dallas, Texas 75229 (the

"Residence").

13. Defendant Candy is a consumer real estate journalist who prides herself on

intruding into the private affairs of others and publishing those matters on her websites

www.candysdirt.com ("Candy's Dirt"), www.secondshelters.com ("Second Shelters"), or

through other media outlets. 1 Candy is the owner and administrator of Candy's Dirt and Second

Shelters. Candy has a self-confessed obsession with real estate and admits to obtaining her Texas

real estate license to circumvent Texas' non-disclosure legislation.2 Candy is frequently aired

on WFAA broadcasts and referenced on WFAA's website, which contains links to Candy's Dirt

and Second Shelters. WFAA regularly broadcasts or publishes Candy's articles or infonnation.

At all relevant times, Candy was acting in her individual capacity and as an agent, employee, or

authorized representative of WFAA and/or Belo. Further, multiple bloggers and journalists, such

as E1ic Nicholson who publishes articles for the Dallas Observer, utilize Candy's unlawfully

obtained pictures and information to taint Dr. Maloufs character.

14. Defendant Belo Corporation is a diversified media company operating in various

business segments and possessing a variety of partnerships with print media businesses, such as

1 Despite President George W. Bush's attempt to keep the purchase of his Dallas residence a little known secret,
Candace Evans was the first person to broadcast to the world the exact location of President Bush's new home. See
Candy's "newgeography" webpage, wherein she boasts about breaking the story; a true and correct copy of Candy
Evans' "newgeography" webpage is attached hereto as Exhibit "A" and incorporated herein by reference.
2 Ex. "A".

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3
The Dallas Morning News. Belo owns, operates and controls the television station WFAA-TV

Channel 8, an American Broadcasting Company ("ABC") network affiliate, and approximately

nineteen ( 19) other public and cable television stations. Additionally, Belo operates more than

twenty (20) websites, several interactive alliances and a broad range of internet-based products.

Belo, through its television stations (WFAA), websites, and print media engagements is watched

or viewed throughout the Dallas/Fort Worth metroplex and throughout the State of Texas. Belo's

websites are viewed around the world.

15. Defendant WFAA-TV, Inc. is an ABC network affiliated �evision station

serving the Dallas/Fort Worth area. WFAA is Belo's flagship station and the largest ABC

affiliate not owned and operated by the ABC network. WFAA consistently airs news reports in

which Candy reports infom1ation related to real estate. In addition, WFAA owns and maintains a

website (www.wfaa.com) with links, articles and video clips containing false information about

Dr. Malouf and the Residence accessible to any person in the world. The miicles and video clips

on WFAA's website were written by Defendants Candy, Harris, or other agents, representatives,

or employees of WFAA or Belo.

16. Defendant Laura C. Wilson lives next door to the Maloufs at I0621 Strait Lane,

Dallas, Texas 75229. Wilson covets her privacy; however, she has no problem assisting and

encouraging Candy, Harris, and WFAA to invade the privacy of the Maloufs by assisting and

encouraging Candy, Harris, and WFAA' s efforts to obtain 1mages of the Maloufs and their

Residence.

3 Belo co-owned The Dallas Morning News unti\ 20 0 8, when it was spun off to A.H. Belo Corporation.

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BACKGROUND FACTS

A. CANDY'S OBSESSION

17. After weeks upon weeks of stalking the Maloufs' home at 10711 Strait Lane,

Dallas, Texas 75229, Candy's long awaited moment arrived. On Sunday, August 19, 2012,

Candy drove to the Residence with the specific purpose of capturing pictures of the Residence

and the backyard equipment located therein.

18. At no time prior to arriving at the Residence, did Candy telephone, text, email,

Facebook message (as all of the young people like to do), or even ring the Maloufs to obtain

permission to open their gate, enter onto the grounds, or photograph the Maloufs' Residence and

the equipment located in the backyard of the Residence. Despite the ten (10) foot tall p1ivacy

fence (the "Privacy Fence") installed to prevent drivers by from viewing the Maloufs, Candy was

undetelTed and proceeded despite the obvious impediment that screams "DO NOT ENTER" and

"PRIVATE AREA".

19. Its doubtful Candy was trained to trespass onto other people's property at Columbia

University's Graduate School of Journalism; however, Candy stealthily slipped inside the

Residence gate and behind the Privacy Fence. Upon entering the grounds of the Residence,

Candy immediately commenced capturing images of the Maloufs' backyard equipment and the

4
Residence. Unsatisfied with the angle or content of the images taken from just inside the gate of

the Residence, Candy ambled her way across the property and repositioned herself to acquire

more promising photos. After Candy published the photographs taken from inside the Privacy

4 See Candy's August 20, 2012, article titled "Water Park Slides Have Arrived at the MaloL!(Manse on Strait Lane
& World Nmv Knows We are Serious About Medicaid Dental Fraud in Texas" (the "We are Serious Article"),
posted on Candy's Diti; a true and cotTect copy of which is attached hereto as Exhibit "B" and incorporated herein
by reference.

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Fence, Dr. Malouf infon11ed the Dallas Police Department of the criminal trespass and filed a

5
criminal report on August 22, 2012 (the "Police Report").

20. The following day, Candy published an article on Candy's Dirt titled, "Water

Park Slides Have Arrived at the Malouf Manse on Strait Lane & World Now Knows We are

Serious About Medicaid Dental Fraud in Texas". The article's headline needed no interpretation,

as Candy's words were precisely calculated to leave the reader (or world) with the false

impression that Dr. Malouf was a thief, fraudster, and environmentally iiTesponsible.

21. Candy's August 19th trespassing photo adventure was not the first time she had

trespassed onto the Maloufs' property. Approximately two years earlier, the Maloufs and their

invited friends celebrated the private birthday event of their minor daughter in the front yard.

Unbeknownst to Dr. Malouf or Mrs. Malouf, Candy just "happened to be in the neighborhood".

As Candy strolled by the Residence and observed the tented celebration, she was unable to fight

the overwhelming urge to intrude upon the private gathering. Without seeking permission,

Candy entered onto the grounds of the Maloufs' Residence and made her way toward the

celebration.

22. Candy brazenly sauntered up to the tent where the Maloufs' daughter was located

and commenced an impromptu interview. Immediately upon witnessing a stranger (Candy)

under the birthday tent inteiTogating the Maloufs' daughter, a family friend intervened and

politely requested that Candy remove herself from the Residence. After speaking with his

daughter, Dr. Malouf discovered that Candy's intent was to probe into the private affairs of his

family. This initial confrontation would foreshadow the coming twelve months and Candy's

obsession.

5 A true and conect copy of the Police Report is attached hereto as Exhibit "C" and incorporated herein by
reference.

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23. Over the course of the following year, Candy habitually drove by the Residence

seeking information related to the latest goings on inside the Maloufs' gates. This type of

"journalism" more closely resembled the acts of the paparazzi than those of a self-respecting

journalist.

24. One of Candy's most recent reconnaissance missions occurred on Wednesday,

August 26, 2012, with the help of the Maloufs' neighbor, Defendant Wilson. Candy's relentless

pursuit to acquire personal information about Dr. Malouf and his Residence and to then publish

that information with false statements about Dr. Malouf had reached new lows, even for Candy.

25. Upon information and belief, approximately one (1) week after Candy trespassed

upon the Maloufs' Residence to capture photographs for her We are Serious Article, Candy

communicated with Wilson regarding the ongoing construction taking place at the Residence.

Upon learning of significant construction progress at the Residence, Candy could not repress her

compulsion to invade the Maloufs' privacy.

26. After Wilson informed Candy of the construction progress, Candy jumped into

her Lexus SUV and headed towards Strait Lane. Candy drove by the Residence on her way to

Wilson's home, which was conveniently adjacent to the Maloufs' Residence. Candy was unable

to examine the new construction progress from Strait Lane because the Privacy Fence impeded

her view within. Candy pulled into Wilson's driveway and entered the Wilson's home located

next door to the Residence. Determined to inspect the backyard of the Residence and undaunted

by the Police Report or Privacy Fence, Candy and Wilson devised a plan to breach the Maloufs'

privacy once again.

27. With Wilson's assistance and encouragement, Candy took the audacious steps of

crawling onto the roof of the Wilson home. Atop the Wilson roof, Candy commenced her

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photographic assault, seizing images of the Residence backyard, likely for use in an upcoming

publication on Candy's Dirt, or in conjunction with a WFAA and Harris television broadcast.

28. Candy's continuous trespasses onto the Residence and invasions into the private

affairs of the Maloufs are fueled by Wilson, Harris, and WFAA. As part of a WFAA July 12,

2012, television broadcast, Harris, Candy, and WFAA crews loitered in front of the Residence

for hours, capturing images of the Residence and hounding Residence staff and constmction

workers in an attempt to gain information pertaining to the private affairs, seclusion, and solitude

of the Maloufs. In the WFAA July 12, 2012, television broadcast, Harris and Candy, acting in

each person's individual capacity and as an agent, authorized representative, or employee of

WFAA and/or Belo, made multiple inaccurate statements regarding modifications, floor plans,

and details of the Residence.

29. Additionally, based on infonnation and belief, Candy elicited assistance and

infonnation from the Maloufs' fanner house manager David Kinney (the "Insider") in an effmi

to obtain private images of the Maloufs fi·om within their home. Upon infonnation and belief,

Candy approached the Insider with a contemptible proposition. Candy's outrageous proposition

involved planting a wireless camera inside Mrs. Maloufs closet. Using the Insider, Candy

would be able to obtain intimate images of the otherwise unsuspecting Maloufs. Moreover, the

Insider would be able to and did provide Candy with p1ivate details related to the Maloufs and

their Residence. Upon infonnation and belief, Candy passed the leaked information about the

Maloufs to Harris and WFAA for use in future television broadcasts.

30. Candy has also unsuccessfully attempted to bribe the Maloufs' civil engineer in

exchange for information related to the Residence and the Maloufs' private and personal affairs.

Upon her bribe of the Maloufs' civil engineer rejecting Candy's bribe, Candy's relentless pursuit

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continued. As a result of the Maloufs civil engineer refusing to provide Candy with private

information related to the Maloufs and their Residence, Candy approached sub-contractors and

individual construction with similar bribes. Candy's prying attempts to elicit private information

and obtain images of the Maloufs and their Residence has been highly offensive to the Maloufs,

as it would be with any reasonable person.

31. Candy's We are Serious Article and her accompanying photos, have since been

commented on by multiple individuals, evidencing the false impression inferred from the We are

Serious Article. Fmiher, other online blogs and journalists have cited to and referenced the We

are Serious Article in their own publications. Writer and online blogger Eric Nicholson did just

that in an miicle he published for The Dallas Observer.6 Additionally, Robert Wilonsky of The

Dallas Morning News published another related article on August 23, 2012, found on his blog

(http://thescoopblog.dallasnews.com).

32. Through her repeated presence on or around the Residence, articles, photos, blog

entries, radio broadcasts, and comments via Candy's Dirt, Second Shelters, and other media

outlets, Candy has engaged in a deliberate pattern of invasion of privacy, trespass, libel, and

defamation per se. Candy has purposefully disseminated significant false information about Dr.

Malouf and the Residence. Candy's paparazzi-like conduct related to the Residence of the

Maloufs seems to serve no other purpose than to invade the privacy, solitude, and seclusion of

the Malouf family. Candy's obsessive behavior is exemplified by the ten (10) or more articles,

radio broadcasts, and television appearances she or other individuals have published in the span

of fifty (50) days.

6 A tme and correct copy of Eric Nicholson's Dallas Observer online article is attached hereto as Exhibit "D" and
incorporated herein by reference.

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33. Further, the published images of the Residence and other substantive content

found on Candy's Dirt and Second Shelters have generated safety concerns for the Malouf

family, and caused injury to the Maloufs. Accordingly, the Maloufs seek nominal damages and

injunctive relief directed at preventing further harassment, invasion of privacy, and defamatory

remarks.

B. BYRONHARRIS' AND WFAA 's FALSE STATEMENTS

34. Candy's obsession and Harris/WFAA's simultaneous focus on Dr. Malouf and his

Residence is not coincidental. Over the course of the last year Candy, Harris, and WFAA have

shined a relentless spotlight upon the seclusion, solitude and private affairs of the Maloufs.

During the last twelve (12) months, Candy, Harris, WFAA, and Belo (including affiliates and

content partners of WFAA/Belo) have published over forty (40) articles, blog entries, radio

broadcasts and television broadcasts disseminating images and erroneous information about Dr.

Malouf and the Residence. Despite Harris, WFAA, and Candy's incessant and blinding spotlight

on the Maloufs, Dr. Malouf and Mrs. Malouf have attempted to maintain their privacy by shying

away from any and all publicity, media, or public issues.

35. In the Spring of 2011, Byron Hanis began investigating alleged Medicaid Fraud

in Texas. HarTis' investigation led to a litany of television broadcasts, a large portion of which

mentioned or referenced Dr. Malouf. As Han·is and WFAA followed up their initial broadcasts,

the scope and content of later television broadcasts eventually centered on Dr. Malouf and his

Residence. These narrowly tailored broadcasts and miicles intruded upon the Maloufs' privacy

by revealing infonnation related to their private affairs. The sharply focused broadcasts and

articles also published multiple false statements related to the Maloufs and the Residence.

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36. Based on Harris' reports, Brett Shipp an employee of WFAA aired a television

report on June 26, 2012, publishing the following misleading remarks:

Shipp: ". . . [Dr. Malouf] has yet to comment on the allegations but filed for
bankruptcy and is in the process o( divesting his once impressive
empire."7

Shipp and WFAA's defamatory statements falsely represent to the public that Dr. Malouf

personally filed for bankruptcy and is in the midst of financial ruin. Dr. Malouf has never

personally filed for bankruptcy or been found guilty of fraud. Shipp and WFAA's false

statements that Dr. Malouf filed for bankruptcy and is in the process of dismantling his personal

estate suggest that Dr. Malouf is guilty of fraud and is therefore being financially stripped or

penalized. Such implications are simply not true.

37. One (1) and a half months prior to the aforementioned story, Harris aired a news

report containing false comments clearly meant to mislead the public regarding Dr. Malouf.

During the report, Harris and \VFAA flashed photos and video of Dr. Malouf and personal motor

vehicles driven by him and his wife. The news story served two purposes: (1) to generate

contempt and hatred for Dr. Malouf, and (2) to invade the Maloufs' privacy. That television story

was broadcasted on May 5, 2012, wherein Harris reported the following:

"[Dr. Maloufs] chain of dental clinics is bankrupt, but yet his $20 million
house is growing . . . Richard Maloufs $11 million dollar mansion is a
symbol of the wealth he built under Medicaid." 8

38. In Harris and WFAA's most recent television broadcast, which aired on October

8, 2012, WFAA and Harris published video of the modified Residence, its concealed backyard

7 A true and correct transcript of the June 26, 2012, WFAA news report is attached hereto as Exhibit "E" and
incorporated herein by reference.
8 A true and correct transcript of the May 5, 2012, WFAA news report is attached hereto as Exhibit "F" and
incorporated herein by reference.

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and Dr. Malouf. As part of their efforts to acquire personal information related to the Maloufs

and the Residence, Harris, WFAA crews, and Candy lingered outside the Maloufs' Residence

waiting for the Maloufs, Resident staff members, or construction workers to exit the property.9

Once outside the Privacy Fence of the Residence, any person that may possess information about

the Maloufs or Residence would be punished by an impromptu interrogation.

39. In addition, Harris, Candy, and WFAA crews spied on the Maloufs by peering

into the Residence backyard, with the help of high-powered lenses and the Maloufs' neighbor,

Defendant Wilson. Without the assistance of Wilson, who invited WFAA, Harris, and Candy to

obtain video footage of the secluded backyard of the Residence, Harris, WFAA, and Candy

would have been unable to intrude into the seclusion and solitude of the Maloufs or publish

video footage of the purposely obscured Residence backyard. Due to the hidden nature of the

Residence backyard, WFAA has gone to the extreme lengths of utilizing its helicopter to capture

aerial video images of the backyard. Despite the Maloufs' Residence obviously lacking any

newsworthy character, WFAA utilized its helicopter and staff to invade the Maloufs' private

retreat.

40. Harris and WFAA published the following false statements during the WFAA

October 8, 2012, television broadcast and accompanying online article authored by HmTis on

WFAA's website, which is titled "Water Park Takes Shape in Backyard of Dentist Who Owes

Millions" (emphasis added):

TV Broadcast: "[The pool area] will use six and half million gallons of
water. So much that it has its own well."

9 The October 8, 2012, WF AA and Harris broadcast can be viewed at www.wfaa.com/news/investigates/Water­


Park-Nears-Completion-While-Bills-Go-Unpaid-17318788l.html.

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Online A1iicle: "Malouf owes an Atlanta-based banking finn $3.2
million for services rendered but not paid for,
according to findings by a federal court last year." 10

Harris's assertion that the Maloufs' backyard pool area will use 6.5 million gallons of water is

completely false and based on pure conjecture. At no time during the television broadcast and

nowhere in the online article does either Harris or WFAA provide any information from which to

base this obscene number. Harris and WFAA misleadingly direct the public to the image of a

single small water well captured by telephoto lens while hovering above the Residence in

WFAA' s helicopter. It is more likely that Harris and WFAA obtained this false and speculative

number from Candy and her August 21, 2012 Second Shelter's blog entry/article, wherein she

eiToneously states, "[i]ts only 6.5 million gallons of water, and Texas sure has plenty of
.
. ll
that ... nght?"

41. Fmiher, Harris and WFAA's statement that Dr. Malouf, individually, owes an

Atlanta-based banking finn $3.2 million dollars is a flat out lie. Contrary to false the

representation by Harris and WFAA, the Atlanta-based banking finn possesses a judgment

against the separate legal entity All Smiles Dental Centers, Inc., not Dr. Malouf. Also, the title of

the article and television broadcast is untruthful, as HaiTis and WFAA are unable to support their

factual claim that Dr. Malouf owes millions of dollars because he fails to pay his bills.

42. Hanis and WFAA's tireless harassment of the Maloufs seems to know no

boundaries. On Friday, October 12, 2012, Harris and WFAA crews stormed a Dallas County

District Courtroom with the purpose of capturing Dr. Malouf and Mrs. Malouf's image on

camera. Despite HaiTis and WFAA crews sprinting down hallways and attempting to track Dr.

10
A true and correct copy of the WFAA and Han·is October 8, 2012, online article "Water Park Takes Shape in
Backyard ofDentist Who Owes Millions", is attached hereto as Exhibit "G" and incorporated herein by reference.
11
A true and correct copy of the Second Shelter's blog entry/article, dated August 21, 2012, is attached hereto as
Exhibit "H" and incorporated herein by reference.

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Malouf and his wife around the Dallas County courthouse, Harris and WFAA's paparazzi-like

actions yielded no usable footage. Harris and WFAA's interruption of a confidential, sensitive

and private civil hearing pertaining to the Maloufs' son was admittedly of no public concern or

newsworthy. Despite the private nature of the civil hearing, Harris confronted the Maloufs'

counsel and became agitated and hostile when he realized his attempts to capture the images of

the Maloufs had failed. Harris and WFAA's disregard for the sensitive nature of the civil

hearing which dealt with the Maloufs' son exemplifies the purposeful pattern of harassment and

invasion of privacy by Harris and WFAA.

43 . Harris, WFAA, Belo, and Candy have continuously led a campaign intensely

focused on penetrating the Maloufs' privacy, seclusion, and solitude. Harassment and ostracism

aside, Dr. Malouf has been and continues to be the target of libel and slander purposed on

ruining his reputation. Accordingly, the Maloufs seek nominal damages and injunctive relief

directed at prohibiting Defendants from trespassing, invading the privacy of the Maloufs, and

assisting, encouraging, or pmiicipating in such tortuous conduct.

V. CAUSES OF ACTION
COUNT ONE: TRESPASS TO REAL PROPERTY

44. Plaintiffs re-allege and incorporate the facts and allegations set forth above in

Paragraphs 1 43 , as if they were fully set forth at length herein.

45. Plaintiffs have continually owned the real property located at 10711 Strait Lane,

Dallas, Texas 75229, at all relevant times and have a lawful right to exclude persons from

entering onto such real property.

46. Without Plaintiffs' consent, Candy has repeatedly, physically, and intentionally,

entered onto the surface of Plaintiffs' Residence with the purpose of capturing images of

Plaintiffs' Residence or interrogating employees, family members, or guests of Plaintiffs. As

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described above, Candy unlawfully entered onto the grounds of the Residence without Plaintiffs'

consent and on one occasion confronted the Maloufs' daughter and on a second occasion took

pictures of the Residence from inside the Privacy Fence.

47. Further, upon information and belief, Candy solicited the Insider to carry out the

unlawful act of planting a wireless camera inside the Maloufs' home for the purpose of:

(1) acquiring private and intimate information or images of the Maloufs, (2) leaking said intimate

information/images to Harris and WFAA, and (3) utilizing the information/images to ostracize

the Maloufs.

48. WFAA and Belo encouraged, advised or adopted Candy's acts of physical and

non-physical trespass upon Plaintiffs' Residence, from which Harris, WFAA, and Belo sought to

benefit. WFAA and Hanis interviewed and published video and photographs obtained through

Candy's unlawful trespass upon Plaintiffs' Residence.

49. The multiple acts of trespass by Defendants Candy, WFAA, and Belo constitute

harassment and caused Plaintiffs injury. Future trespasses by Defendants Candy, WFAA and/or

Belo will cause Plaintiffs future injury. As a result of Defendants Candy, WFAA and Belo's

wrongful acts, Plaintiffs have suffered and will continue to suffer injury. Accordingly, Plaintiffs

request the recovery of the costs and expenses to counteract Defendants' unlawful acts, nominal

damages, injunctive relief because a remedy of damages is inadequate due to the multiplicity of

actions necessary to obtain redress, and costs of court.

COUNT TWO: INVASION OF PRIVACY

50. Plaintiffs re-allege and incorporate the facts and allegations set forth above in

Paragraphs 1 - 49, as if they were fully set forth at length herein.

PLAINTIFFS' ORIGINAL PETITION, APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AND REQUEST FOR DISCLOSURE PAGE 16 OF 27
51. Defendants Candy, Wilson, Harris, WFAA, and Belo have repeatedly invaded

Plaintiffs' privacy by intruding on Plaintiffs' solitude, seclusion, and private affairs. Without

Plaintiffs' consent, Candy physically invaded a private celebratory event at the Residence and

subsequently pursued a personal interaction with Plaintiffs' minor daughter during said event.

Additionally, Candy trespassed on August 1 9, 20 1 2, with the intent to acquire photographs.

Candy obtained photographs of the Residence and posted them on Candy's Dirt and Second

Shelters. At no time did Candy obtain the consent of Plaintiffs to enter the Residence physically

or otherwise. Further, Candy allowed others to utilize those unlawfully obtained images.

52. Defendants committed nonphysical invasions by eavesdropping, loitering, and

spying on Plaintiffs' Residence. Based upon information and belief, Candy aided and abetted by

Wilson, and encouraged and advised by WFAA and Belo, climbed atop Wilson's roof to capture

images of the Residence backyard. Additionally, on or around October 2, 20 1 2, Wilson invited

WFAA, Han-is, and Candy to her home, which resulted in WFAA, Han-is, and Candy capturing

detailed pictures of the Maloufs' Residence. Without Wilson's assistance, WFAA and Harris

would not have been able to obtain the video footage of the Maloufs' concealed pool area.

53. Upon infonnation and belief, Candy petitioned the Insider to can-y out the

unlawful act of installing a wireless camera within the Maloufs' closet. Such a flagrant act of

invading the Maloufs' sanctity is shocking and deplorable. As described supra, Candy, Han-is,

and WFAA have committed vast amounts of time and resources into the endeavor of harassing

and intruding upon the Maloufs' privacy, solitude, and seclusion.

54. Plaintiffs' Residence includes a ten ( 1 0) foot tall privacy fence erected along the

outside boundaries of the propetiy. Plaintiffs believed the construction of the Privacy Fence

would afford them a reasonable amount of privacy. Despite Plaintiffs' erection of the Privacy

PLAINTIFFS' ORIGINAL PETITJON, APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AND REQUEST FOR DISCLOSURE PAGE 1 7 0F27
Fence (expanding their expectation of privacy), Defendants' relentless intrusions cannot be

stopped. WFAA, Harris, Candy, and Wilson have schemed to circumvent Plaintiffs' expectation

of privacy and now Plaintiffs are powerless to prevent WFAA, Harris, and Candy from utilizing

helicopters and telephoto lenses in Defendants' campaign against Dr. Malouf.

55. Moreover, Candy, Harris, Belo, WFAA and their respective media content

partners have subsequently published information obtained from Candy's intrusions via Candy's

Di1i, Second Shelters, WFAA's television broadcasts, articles found on www.wfaa.com, and

Dallas Morning News blogs. The constant harassment, stalking, intrusions and subsequent

publications by Candy, Harris, Belo, and WFAA of Plaintiffs and their Residence would be

highly objectionable or offensive to any reasonable person.

56. Plaintiffs, much like any other reasonable person, are outraged by Defendants'

extraordinary efforts of:

(A) Trespassing to confront Plaintiffs minor daughter;

(B) Climbing atop Wilson's roof to obtain photographs of the Residence;

(C) Utilizing WFAA's helicopter and telephoto lenses;

(D) Upon infom1ation and belief Candy's deplorable proposition of the Insider, civil
engineer and other sub-contractors; and

(E) Harassing Interruption of the confidential civil proceedings on October 12, 2012.

Further, the publication of images and photos at the Residence generate safety concerns for

Plaintiffs.

57. As a result of Defendants' wrongful acts, Plaintiffs have suffered and will

continue to suffer injury. Specifically, Plaintiffs have suffered injury as a result of Candy, Harris,

and WFAA's incessant invasions into the seclusion and solitude of Plaintiffs, without their

consent. Accordingly, Plaintiffs request the recovery of nominal damages, injunctive relief

PLAINTIFFS' ORIGINAL PETITION , APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AND REQUEST FOR DISCLOSURE PAGE180F27
directed at prohibiting Defendants from invading the privacy of the Maloufs, the costs and

expenses to counteract Defendants' unlawful acts and publications, and costs of court.

COUNT THREE: DEFAMATION, LIBEL, AND SLANDER

58. Plaintiff Dr. Malouf re-alleges and incorporates the facts and allegations set forth

above in Paragraphs 1 -57, as if they were fully set forth at length herein.

59. On or about August 20, 2012, Candy published the We are Serious Article

containing information which is defamatory per se of and about Dr. Malouf in that the gist of the

publication, when taken as a whole and as would have been perceived by a reasonable reader,

stated:

(A) Dr. Malouf is a criminal; and

(B) Dr. Malouf is environmentally irresponsible.

2
The foregoing statements are/were false. 1

60. On or about October 2, 2012, Candy posted an article on Candy's Dirt, which was

defamatory per se of and about Dr. Malouf (the "Water Games Article"). The first sentence of

the Water Games Article reads, "Byron Harris at WFAA-TV is the guy who busted Richard

Malouf." The essence of this publication, when taken as a whole and as would have been

perceived by a reasonable reader, stated:

(A) Dr. Malouf is criminal; and

(B) Dr. Malouf is environmentally i1Tesponsible.

The foregoing statement is/was false. 13

12 A true and correct copy of the publication is attached to this petition as Exhibit "B".

13 A true and correct copy of the Water Games Article is attached to this petition as Exhibit "I", and incorporated
herein by reference.

PLAINTIFFS' ORIGINAL PETITION, APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AND REQUEST FOR DISCLOSURE PAGE 19 OF 27
61. On or about October 8, 2012, Defendants Harris, Belo and WFAA aired a

television broadcast and published an accompanying online article which were defamatory of

and about Dr. Malouf (the "October 8, 2012 Publications"), in that the meaning of the

publications, when taken as a whole and as would have been perceived by a reasonable

listener/viewer, stated:

(A) Dr. Malouf owes millions of dollars and refuses to pay his bills; and

(D) Dr. Malouf is environmentally irresponsible.

The foregoing statements are/were false. 14

62. On or about June 26, 2012, Defendants Belo, and WFAA disseminated a

television broadcast which was defamatory per se of and about Dr. Malouf (the "June 26, 2012

Broadcast"), in that the gist of the publication, when taken as a whole and as would have been

perceived by a reasonable listener/viewer, stated:

(A) Dr. Malouf committed a clime;

(B) Dr. Malouf, personally, filed for bankruptcy; and

(C) Dr. Malouf had his property shipped from him.

The foregoing statements are/were false. 15

63. On or about May 5, 2012, Defendants Harris, Belo, and WFAA disseminated a

television broadcast which was defamatory per se of and about Dr. Malouf (the "May 5, 2012

Broadcast"), in that the essence of the publication, when taken as a whole and as would have

been perceived by a reasonable listener/viewer, stated:

(A) Dr. Malouf is guilty of a crime; and

(B) Dr. Malouf is the symbol of Medicaid fraud.

14 A true and conect transcript of the October 8, 2012 Broadcast, and a true and conect copy of the October 8, 2012
accompanying article are attached to this petition as Exhibit "F" and incorporated herein by reference.
15 See Exhibit "E".

PLAINTIFFS' ORIGINAL PETITION , APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AND REQUEST FOR DISCLOSURE PAGE 20 OF 27
16
The foregoing statements are/were false.

64. The "gist" of Defendants Candy, Harris, WFAA, and Belo's publications,

including, but not limited to the We are Serious Article, Water Games Article, October 8, 2012

Publications, June 26, 2012 Broadcast, and May 5, 2012 Broadcast was calculated and designed

by Defendants to leave the listener, viewer, or reader with an entirely false and untrue impression

that Dr. Malouf is guilty of a crime, Dr. Malouf is environmentally irresponsible, Dr. Malouf

filed for bankruptcy, Dr. Malouf has been stripped of his property, and Dr. Malouf refuses to pay

millions of dollars in bills. These untrue statements of and about Dr. Malouf have defamed him

in, thus causing him injury, embarrassment, humiliation and other compensable damages. The

reasonable interpretations as a reasonable listener, viewer, or reader would have, on the whole,

from Defendants' false, scandalous, and defamatory statements from the We are Serious Article,

Water Games Article, October 8, 2012 Publications, June 26, 2012 Broadcast, and May 5, 2012

Broadcast, include, but are not limited to those set forth above.

65. The false information published by Defendants Belo, WFAA, Harris and Candy

as alleged in this Petition is defamatory, in that, as reasonably understood, the inf01mation

tended to harm the character and reputation of Dr. Malouf, so as to lower him in the opinion and

estimation of the community and in his profession and to deter other persons from associating or

dealing with him.

66. Defendants published the false statements to countless individuals, knowing the

statements were false, acting with reckless disregard for whether the statements were true,

intending to leave a false impression, acting with ill will, or intending to hann Dr. Malouf, his

reputation and good will. Accordingly, Defendants Candy, Harris, WFAA, and Belo's acts were

committed with actual malice.

16
See Exhibit "F".

PLAINTIFFS' ORIGINAL PETITION , APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AND REQUEST FOR DISCLOSURE PAGE21 OF27
67. The above described statements and additional publications involved a private

matter, a private Plaintiff, and referred to Plaintiff by name. The statements were defamatory

because they unambiguously accused Plaintiff of committing a crime by innuendo or

implication.

68. As a result of the dissemination of the defamatory statements, innuendos, and

implications, Dr. Malouf has suffered nominal damages and seeks recovery of same.

COUNT FOUR: RESPONDENT SUPERIOR

69. Plaintiffs re-allege and incorporate the facts and allegations set forth above in

Paragraphs 1-68, as if they were fully set forth at length herein.

70. Plaintiffs were injured as a result of torts committed by Defendants Candy, Harris,

and WFAA. At all relevant times, Defendants Candy, Harris, and WFAA were the authorized

agents, representatives, and or employees of one another and Belo. The torts were committed

while the tortfeasors were acting within the scope of their agency or representation. Defendants

are vicariously liable for the acts of their agents, representatives, and/or employees.

71. Alternatively, Defendants WFAA and Belo ratified the conduct of Defendants

Candy, Hanis, and WFAA and approved of the tortious conduct by word, act, or conduct after

acquiring full knowledge of the act, and their approval was given with the intention of giving

validity to Defendants' acts.

COUNT SIX: CIVIL CONSPIRACY

72. Plaintiffs re-allege and incorporate the facts and allegations set forth above in

Paragraphs 1-71, as if they were fully set forth at length herein.

73. Defendants Candy, Wilson, Harris, WFAA, and Belo acted in concert and

conspired together to commit the tortious acts desctibed herein. Accordingly, these Defendants

PLAINTIFFS' ORIGINAL PETITION , APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AND REQUEST FOR DISCLOSURE PAGE22 OF27
should be held jointly and severally liable for any damages awarded to Plaintiffs as a result of

this action.

VI.
APPLICATION FOR TEMPORARY RESTRAINING ORDER
AND INJUNCTIVE RELIEF

74. Plaintiffs re-allege and incorporate the facts and allegations set forth above in

Paragraphs 1-73, as if they were fully set forth at length herein.

75. As desclibed supra, Defendant Candy, assisted by Wilson, encouraged and

adopted by Harlis, WFAA, and Belo, continually trespassed upon the Residence without

Plaintiffs' consent or permission. Candy's never-ending attempts to capture images of the

Maloufs, the Residence and backyard continue to be fueled by WFAA, Belo, Hams, Wilson, and

her desire for public attention. In addition, WFAA and Hams have used extreme measures to

capture images of the secluded Residence backyard, such as utilizing helicopters and telephoto

lenses. Defendants' incessant unsolicited invasions into Plaintiffs' Residence, their solitude,

seclusion, and plivate affairs constitute blatant harassment.

76. By way of example only, Candy's intentional acts of trespass related to the

Malouf plivate birthday celebration, the August 19, 2012, incident, and upon information and

belief, Candy's contemptible proposition of the Insider were purposed to (1) obtain plivate and

personal information about Plaintiffs, the Residence and the Malouf family, and (2) harass

Plaintiffs. Plaintiffs filed the Police Report in connection with the August 19, 2012, incident in

an effort to communicate that Defendants' actions were unlawful and should cease; however

Candy, Harlis, and WFAA continue to hound Plaintiffs and their Residence. Defendants

ceaselessly pursue the Maloufs and their property, with the intent to inflinge upon Plaintiffs'

seclusion, solitude, and plivate affairs by snapping pictures and snooping around.

PLAINTIFFS' ORIGINAL PETITION, APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AN[}REQUEST FOR DISCLOSURE PAGE23 OF27
77. As described supra, Defendants Candy, Harris, and WFAA published false

statements to the Dallas/Fort Worth community and across the world in conjunction with

photographs and infonnation acquired through Defendants' meddling actions. Moreover,

Defendants' repeated trespasses, invasions, and harassment have caused Plaintiffs injury.

Defendants' wrongful actions (trespass, invasion of privacy, and defamation) were and continue

to be made with malice and the intent to persecute Dr. Malouf and torment the Malouf family.

78. Plaintiffs have alleged causes of actions against Defendants Mary Candace Evans,

Byron Harris, Laura C. Wilson, WFAA-TV, Inc., and Belo Corporation, as indicated in this

Petition and in the attached Affidavits17, and have demonstrated a probable right of recovery and

likelihood of success on the merits, that Plaintiffs will suffer imminent, irreparable harm without

Court intervention, and that there is no adequate remedy at law.

79. Unless Defendants Mary Candace Evans, Byron Harris, WFAA-TV, Inc., Wilson

and Belo Corporation are restrained and enjoined from undertaking and maintaining the conduct

and activities desc1ibed above, Plaintiffs will continue to suffer irreparable harm, for which

Plaintiffs have no adequate remedy at law. Accordingly, Plaintiffs request that the Court

immediately and temporarily restrain Defendants Mary Candace Evans, Byron Harris, and

WFAA-TV, Inc. and all others acting in concert with them from:

(a) physically invading or entering onto the real property of Dr. Richard Malouf and
Leanne Malouf, located at 10711 Strait Lane, Dallas, Texas 75229;

(b) physically interacting, confronting, touching, or approaching Dr. Richard Malouf,


Leanne Malouf, daughter, guests, employees, or other individuals on the grounds
of the Residence or within fifty (50) feet of the Residence; and

17 See the Affidavit of Dr. Richard Malouf; a true and conect copy of which is attached hereto as Exhibit "K", and
incorporated herein by reference. See also the Affidavit of Leanne Malouf; a true and correct copy of which is
attached hereto as Exhibit "L" and incorporated herein.

PLAINTIFFS' ORIGINAL PETITION , APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AND REQUEST FOR DISCLOSURE PAGE24 OF27
(c) capturing images of the Residence, including the Residence backyard, side yard,
front yard, and from within the Residence, whether digital, video, still, motion,
film or otherwise.

80. In order to preserve the status quo and the rights of the Defendants Candy, Harris,

WFAA and Bela during the pendency of this action, Defendants should be cited to appear and

show cause why they should not be enjoined, during the pendency of this action, from engaging

in any of the conduct described above.

81. At this time, Plaintiffs Dr. Richard Malouf and Leanne Malouf respectfully

request the following relief:

(a) A Temporary Restraining Order be issued, restraining Defendants Mary Candace


Evans, Byron Harris, WFAA-TV, Inc., and Belo Corporation and any and all
others acting in concert with them from engaging in any of the conduct discussed
above;

(b) A Temporary Injunction be issued, after notice to Defendants Mary Candace


Evans, Byron Harris, WFAA-TV, Inc., and Bela Corporation and an evidentiary
hearing, restraining Defendants Mary Candace Evans, Byron Harris, WFAA-TV,
Inc., and Bela Corporation from directly or indirectly engaging in any of the
actions discussed above during the pendency of this case; and

(c) After a final trial of this cause, Defendants Mary Candace Evans, Byron Harris,
WFAA-TV, Inc., and Belo Corporation and any and all others acting in concert
with them be pennanently enjoined from engaging in any of the conduct
desc1ibed above.

VII.
REQUEST FOR DISCLOSURE

82. Pursuant to Rule 194 of the Texas Rules of Civil Procedure, Defendants Mary

Candace Evans, Laura C. Wilson, WFAA-TV, Inc., Byron Hanis, and Belo Corporation are

requested to disclose, within fifty (50) days of service of this request, the information or material

described in Rule 194.2. Copies of documents and other tangible items should be served with the

response pursuant to Rule 194.4 of the Texas Rules of Civil Procedure.

PLAINTIFFS' ORIGINAL PETITION, APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AND REQUEST FOR DISCLOSURE PAGE 25 OF 27
VIII.
PRAYER

WHEREFORE, PREMISES CONSIDERED, Plaintiffs Dr. Richard Malouf and Leanne

Malouf pray that this pleading be received and filed and that Defendants Mary Candace Evans,

Laura Wilson, Byron Hanis, WFAA-TV, Inc., and Belo Corporation be cited to appear and

answer, and that Plaintiffs be awarded the following relief:

(a) A temporary restraining order and the injunctive relief sought herein;

(b) Judgment against Defendants for nominal damages in an amount within the

jurisdictional limits of the Court;

(c) A judgment pennanently enjoining Defendants from engaging in any of the conduct

described herein;

(d) Costs of bringing this action, including all reasonable and necessary attorney's fees,

costs, fees, expenses, and costs of Court; and

(e) For such fmiher reiief, both at law and in equity, to which Plaintiff may show himself

justly entitled.

Respectfully submi.tt��

��
-----�-

By: (/ c:____
C. GREDDYSHAMOUN
State Bar No. 18089650
JOHN DAVID REED
State Bar No. 24075423
SHAMOUN & NORMAN, LLP
1755 Wittington Place, Suite 200, LB 25
Dallas, Texas 75234
Telephone: (214) 987-1745
Facsimile: (214) 521-9033
ATTORNEYS FOR PLAINTIFF

PLAINTIFFS' ORIGINAL PETITION , APPLICATION FOR TEMPORARY


RESTRAINING ORDER, AND REQUEST FOR DISCLOSURE PAGE 26 OF 27
CERTIFICATION

Thi s is to cert i fy that, to Plainti ffs' k nowledge, Defendants Mary Candace Evans, Laura
W i l son, Byro n Harris, WFAA-TV, I nc., and Belo Corporation arc not represented by counsel i n
this matter at the time that Plai nti ffs' Original Petition, Appl i cation for Temporary Restrai n i ng
Order, App l i c ation for I njunctive Rel i e f and Request for D i sclosure was fi l ed with the Court.

JO
��)
�:

VERIFICATION

STATE OF TEXAS §
§
COUNTY OF DALLAS §

B EFORE M E, the undersigned N otary Publ ic, on this day personal ly appeared Dr. Richard
Malouf, who having been by me first duly sworn according to l aw, upon his oath deposed and
stated as fol lows:

My name i s Dr. Richard Malou[ I am over 1 8 y ears of age. I am of sound mind, have
never been convicted o f a felony, and I am ful ly competent to make this Veri fication. The
statements contained in P laintiffs' Original Petition are true and correct to the best o f my
knowledge and belief.

F U RTHER AFFIANT SA YETH NOT,

, [()/,_ (;2
S UU SCRIBED A N D S WORN to before me. the undersigned notary public, on thi
day of October, 20 1 2 .
:�

PLAINTIFFS' O R I G I N A L PE'I n ION , APPLICATION FOR TEMPOR A R Y


RESTRA I N I NG OR DER, A N D REQUEST FOR DISCLOS U R E PAOE 2 7 OF 2 7
II
EX H I B IT A"
- -� � -� � - - · ---� 1 - · � · · o� � o- r � - .;
� · - �---

September 2 7 201 2 L a s t Update 09127120'!2

B!og Con tact Co11\r tbuto1 s About the S1te News from Other S1tes

HOME ECONOMICS POLITICS URBAN ISSUES SMALL CITIES D EMOGRAPHICS SUBURBS CENSUS 2010 2012 BEST CITIES RANKING

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Name:
Candy Evans Enter your email address [ Go! I
Real Estate Editor, AOL's HousingWatch; Founderlblogger, SecondShelters

I am an independent journalist based in Dallas, Texas, obsessed with Real Estate,


which is why I cover it for AOL's Housing Watch, one of the most comprehensive IJ
consumer real estate sites on the web. For ten years, I covered real estate and
design for D Magazine, a regional print publication in Dallas, and developed the NewGeography.com is a joint
city's first real estate blog in 2007: "'""·. D a l la s D i rt.com. I broke countless stories for the award­ venture of . J oel Kot k i n and Praxis
winning blog, and though he tried to keep his post-White House home a secret, I was the first to Stralcg\· Group
report where President George W. Bush bought in Dallas. In October, 2010, D Magazine shut
down the blog and I founded SecondShelters.com, a niche blog devoted to second and multiple FEATU RED CONTENT
home ownership, whether vacation or investment.

I was born in Chicago, studied journalism at Columbia University's Graduate School of


Journalism (1979, I'm old) and moved to Dallas to work in TV news. I acquired my Texas real
estate license in 2009 to become a better reporter and gain access to the MLS, since Texas is a
non-disclosure state. I love urban development issues want to know everything about Real Estate!
' I
Special areas of interest: H ouse Porn, second homes, real estate finance, and how Gen X and Y
1 The Evolving U rban F o r m !
will buy homes. ()e.veloprrumt Profill!s of i
World Urban Areas I
Blog:
!lttp.!/secondshe/!ers corn
a "- ·'!I
Interests:

Real estate, land use, second home development, real estate investing

http.//www secondshelters com


Census20 1 0
Dallas, texas

V i"" a ll su bjects

LATEST ACTIVITY AT NEWGEOGRAPHY.COM


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11 "
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V V Ul\,..-1 .1 (.ll l\.. t...J llU"-".-:) l .l(.l V \..1 � l l l V \...- U U l l.ll\...- _l_YJ.U.lVU.l _l Y J.UJ..lo.::""'' V J. .l U '-.1 '-l..l '- ..LJU.i.l""' \.A..- ' ' V .l .lU- .l. ., V Y Y ..l. '1o.._.J. .J.V Y Y • • • ..1. ._...0 _ ..t._ 'J ..L. '

! Se;.1rch

Water Park Slides Have Arrived at the Malouf Manse on Strait Lane & World Now
Knows We Are Serious About Medicaid Dental Fraud in Texas
:.w. :2 01 :.:?

"Texas Drills Down on Medicaid Dental Fraud" (sub.


rec.) is the headline in today's Wall Street Journal.
What do they mean by that? Why, maybe a b l ast from
the past biz practices of people like Richard Malouf
who is putting in a WatcrPark that one reader thinks
we ought to christen "Waterl'ik Park" over on Strait
Lane. H is gates were wide open on Sunday as trucks
heaved in the equipment which is now sitting right in
the front yard of what was once 10711 Strait Lane.

That is, as you know, is the Family Sports World.

If any of you were as surprised as I was over this


Medicaid deal I mean, I know what Medicaid
reimburses physicians for medical care and it is barely
enough to cover the exam table paper in the office it
seems as though the problem stemmed from a 2007
civil lawsuit (that really started in 1993) that made the
state increase reimbursement rates for M e dicaid dental
services:

"The suit, a federal class action filed by parents

in 1993 against state officia ls, a lleged Texas

was fa iling in its duty to ensw·e that children on

Medicaid received proper preventa tive care in

dental and other areas. Eligibility fol' Children ·s

Medicaid in Texas is pegged to income. In 2007,

Texas legislators agreed to settle, conceding

that there was a dwindling n umber of doctors

and dentists in the state willing to treat

http://www.candysdirt.com/20 1 2/08/20/water-park-slides-have-arrived-at-the-malouf-man... 9/28/20 1 2


w mer t"arK ;:,uaes t1ave 1-unvea al me lVIaiOUl lVIanse on ;:, trau Lane o.:, vv oriU 1" o w !'...n o w ... r age;; L. 01 '+

DM·hJJ

Tweet 2 Share

Amy Patrick, P.E. oil August �o, 2012 at 6:.-!:J pm

S(lmronc's kiddo pla�-s little league on the same leam as some other kiddo who.'.e dnddr is on Cily Council or is reeeeally high up in the City Engineer's
office . . .

Bless their next-door-neighbor's souls!

Margaret l.VIanser oil Au"ust 20, 2 0 1 2 at 6:51 pm

.J ust - makes - me -- uncomfortable. And I'm a Realtor and all o\·er the American dream. Are these my tax dollars going down the drain'?

http://www. candysdirt.com/2 0 1 2/08/20/water-park -slides-have-arrived-at-the-malouf-man... 9/28/20 1 2


VY i:Her rarK ;:, uues n a v e run v e u aL u1e lVlaiUUI lVtause u 1 1 u Li aH LaHe oc vv uuu 1 � u w .l'..uu w . .. r age; .J u1 -t

Tim Monnich on August 20. 2012 at T06 pm

O.s million gallons of water? Tl1is m a kes l -ance Armstong u:-:ing lf)O.ooo gallons/month in Austin look small.

Karen Eubank on August 2 1 , 2 0 1 2 <It t :os am

Orothodontic Oasis'' Plaque Pia, ground'! This is going to be fun !

Pingback:
A'> lical'd ( )n Jo,/if neon: Tue:.;day. o8 ·21 2012 . , q8.-:- I<U T

critic on August 2 1 , 2 0 1 2 at q::-1�1 a m

The little kiddies better haw their mouth guards in place a s t hey swoosh d<nnl the gowrnment ( me the taxpayer) paid for entertainment !

Crosstown Clay on August 2 1 , 2012 at 12 ::11 pm

An}· child or pan"nt with a legitimate All-Smiles receipt �hould ret'ein" frer admission to Strait Lane·s new \NaterPik Park.

Uppercase Matt on Augmt 2:1. 2 0 1 2 at S:so am

Ul!-oh! T �l'-'SUnH:" you\·t" seen tlw eriminal trespass complaint against �ou (or whoeYer took those pictures) b�· M a louf!

Debbie Hagan on August 2:1. 2 0 1 � at 9:59 am

1 think being listed at m1mber 67 on the Tr>p 100 most Expens i\'e ! tomes in Dallas list in 2009, was just too much for the old boy. I t must ha,·e shook his and
.Stcphy Leanne's enormous egos to their cores.

M aybe he \\"<IS visited b\" soute Boston medium who told him he must "build a home for yourself and for the spirits of the children mu haw
broken" You must newr stop building the house. !f you continue building, \"OU will liw forewL But if vou stop, then ,·ou ,,;11 die," like Sarah
\Vinehestcr.

Uppercase Matt on August 2:l. 2 0 1 2 at 1o:sH am

I !ere's the criminal trespass complaint


http: '\' wv·:.sc rihd.conl .' d( )t' J n:co:�Hn- I\Ialouf-Trc .o.:: p;L''

Pingback:
/)enlist f(iclwrd ;\Jalnl!f. (/(('/1.-;l'd of .\Jedi!'r71d.frnud. docsn 't like it wlt!'l! real c_..;fuf(' NorJIJi'I'S come o n h i:-: proper!!} ! l11c ,<..,'n l(J}J /Ho(7

http://www.candysdirt.com/20 1 2/08/20/water-park-slides-have-arrived-at-the-malouf-man ... 9/28/20 1 2


W ater rarK �uaes 1-tave AHlVea at tne lVla!UUl JVJ all:St: U l l ,:) LJ (:U l Ldllt: (X, VV U l lU l 'I U W 1'>.11U W • • • 1 at, � ..,. V I ..,.

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})irl Fdft,n· C'miil.lf 1--;" r·rm.-:::

steve stringer on August 2;;, 2012 at 2:08 am

'
candy. }'ou are loH·d! just read r. wilonsk-y snippet about water pa rk . rw is cool, you are fantastic and byron harris i s hadass. (w h il e we re at it,
becky oi i,·er is a pit b u l l too! )

TG on Augusl :.n, 2 0 1 :2. at 10:-t:z am

,Just so horridly· honidl�- exressin:-. What a n embarrassment.

Pingback:
:t! n ndl/11 t1fil/ionnire(s!: 7'111' < ?lficiaf l,u...:: f .. f\n;-( ?(Sllml1ler S1rifl1111illg Pool Roundup i ( '1111(1_1(:> ])irf I nullo..:; 1\('o[ /�stote Nell'S ond Hloq hy FOT'Il1C1' /)olfos Dil'(

Edito r ! 'nn rlr; Er·m1.-.:

On t h e M a rket. urban l iYi ng i n Dallas.


Ca l i fo rn i a . Nev\'S East Dallas M ondaY \ t i l ! ' (qrnwr r·d i l 1 > 1 d ( n lfaq1uinc'� O a l h� "> P h·l.
'dl• ' l i l < >1 1 i � • · r presidr,nt ( ;eorp,l' \\·. Bush hnught h i-' Dallas home .
Morn i ng M illionaire T h u rsday Th re� 1n

. nviL,!Jh , � r ii ! \ · l ( k \\il-li·,_
H un d re d . Condo l iYing nat ional news
stories a ffecting second homes
Tuesday Two H u n d red. Beach • · \ r·n h:n •' .1

H omes' cele britv real esta te. •pw·-li· >lJ', \ \ �' ( ! . 1 it "11 h ' 'lll qqr in

Economv. House Camh·. Realtor ! ! d i j.;,· '!'l"n ( • f l h • ' -...iJt>"' 1 >1!\


il"\lll !..: l n '>\'l l _\., 111 h•'i!W.
news e"ni.erg in,� t·ea l estate m arkets ,l ,l

jnurnali"'t !,. , · 1 e n t \ ' ' 1 "<1! i ·<.; l Yt · · ...., · i u t • · l ! • I ·· h'''l' \ \ l l l t ! !) , · •·1 H.'111'.' . 1 n d ) J , , I { b ·r , , ._ T, I
Real Est . ate. Cetehritv Homes Real
\' ;1 I t';�

. · · c.. !\<1;• !j;•;•!l'-f· i l h i :-. llFtP i ! J . i ! ··, \1 ith !·.!Jh\ J !a!Jid,1\ � h 1 ' f d , H ..; r r V•-<1111 ( n =;1 • ! 1 ; <1
estate m a rket news. I)allas real estate .i�Hl t'nali.<.d_
news I,ouhoutin .-..,

.\hout Candy'� ! }irt

http://www .candy sdirt.com/20 1 2/08/20/water-park-slides-have-aJTived-at-the-malouf-man . . . 9/28/20 1 2


EX H I B IT "C"
Dal las Pol ice Department Reports

Offe nse Record for P u b l i c Release


020871 4-Z
I ncide nt #:
UCR CODE: 26 530 AS SIGNAL: 6X Offense Date: 8/22/20 1 2

OlD: MDT TCB : 1 6 :41 :23 TC E : 1 6 : 52: 1 1 DISPATCH E D AT: 1 5 : 59

BEAT: 556 REPORTI N G AREA: 3032 WATC H : 2

COM PLAINANT I N FORMATION

NAM E : MALOUF ,RICHARD BUSI N ESS ADDRES S :


HOME ADDRESS :
1 0 7 1 1 STRAIT
DALLAS TX

RAC E : C S EX : M AGE: 47 DOB:

OFFENSE

O F F E N S E DESCRIPTI O N : CRIMINAL TRESPASS


M/0 : SUSP ENTERED ONTO PROPERTY AT GATED HOME
OFFENSE LOCATION : 1 0 7 1 1 STRAITLN

APT:

PREMISES: 50 1 - HOUSE P ROPERTY ATTAC K CODE : 50 1

I NVESTIGATOR ASS I G N E D :

DATES O F OCCURRENC E : 20 1 2/8/22 1 4: 1 6 • 20 1 2/8/22 1 4: 1 6

STATUS : 0 U C R DISP: P SPECIAL REPORT:

FOLLOW U P : 8 REVIEWED BY: 57 1 22 WEATHER:

S R CODE: 5 INV. DIV. NOTI FI E D :

FAM I LY VIOLEN C E : N GANG ACTIVITY CRIME: N

Crime classifications are based upon preliminary i n formation supplied to the Dallas Police Department by the reporting pa rties
and the preliminary classifications may be changed at a later date based upon additional investigation. Therefore, the D a l l a s
Police Department d o e s not g u a rantee (either expressed o r i m p l ied ) t h e accuracy, completeness, timeliness, o r correct
sequencing of the i n formation contained herein and the i n formation should not be used for comparison purposes over tim e .
T h e Dallas Police Department w i l l n o t be responsible for a n y error or omission, or for the u s e of, o r the results obtained from
the use of this informati o n .

Open Records requests m u s t be m a d e in writing. They m a y b e :

1. H a n d -carried t o t h e Records Sectio n , D a l l a s Police Headquarters, 1400 S. L a m a r St. , D a l l a s , T x . 752 1 5 .


2. Faxed to 2 14-6 7 1 -4636
3. E-mailed to openrecordu n it @ d p d . c i . d a l las.tx.us
4. Mai led b y US Postage to Dallas Police Open Records, 1400 S . Lamar St., Dallas, Tx. 75215.

02087 14-Z Page 1 of 2 on 8/23/2012 9 : 46 : 1 1 AM


Dal las Pol ice Department Reports

Offe nse Record for P u b l i c Release


020871 4-Z
I ncident #:
UCR CODE: 26 530 AS SIGNAL: 6X Offe nse Date: 8/22/20 12

OFFICER I NFORMATION

REPO RTI N G OFFICER: 7 1 2 7

O T H E R O F FICER:

NARRATIVE

ON LISTED DATE S N D TI M E, SUSP ENTERED PRIVATE PROPERTY T H ROUGH A CON STRUCTIO N


GATE . S U S P TOOK PICTU RES OF PRO PERTY A N D POSTED TH E M TO H E RW E BSITE CALLED
CA N DYS D I RT . COM . S U S P DID N OT HAVE P E R M I SSION TO BE ON PROPERTY A N D LEFT B E FO R E
R O S ARRIVAL. N FI

Crime classifications are based u po n preliminary information supplied to the Dallas Police Department by the reporting parties
and the prel i m i n a ry classifications may b e changed a t a later date based upon additional i n vestigation. Therefore, the D a l l a s
Police Department d o e s not g u a rantee (either expressed or i m p l ied ) t h e accuracy, completeness, timeliness, or correct
sequencing of the i n formation contained herein a n d the i n formation should not be used for compa rison purposes over tim e .
The Dallas Police Department w i l l n o t b e responsible for a n y error o r omission, or for the u s e of, o r the results obtained from
the use of this informati o n .

O p e n Records requests must be made i n writing . They m a y b e :

1. H a n d -carried t o the Records Sectio n , Dallas Police Headqua rters, 1400 S. L a m a r St. , Dallas, Tx. 752 1 5 .
2. Faxed to 2 14-67 1 -4636
3. E-mailed to openrecordunit@ d pd .ci. dallas.tx.us
4. Mailed b y US Postage to - Dallas Police Open Records, 1400 S . Lamar St. , Dallas, Tx. 75215.

02087 14-Z Page 2 of 2 on 8/23/2012 9 : 46 : 1 1 AM


11 11
EX H I B IT D
.I. � V .l .l'-".l """ .l. T . l U .l \J \.1...1 ' L.l l V .l....' '-' .l . l L .l J L .1. Ji. V V U J V """ V ..l .l. T ..l .l.l.l.lV.l..loJ J.J..l. .l T -LV """.l. V'-"J.""" -L .l. '-" U""" ' .l. oJ ..._, U J. l """.l.l.lf:, "-" -L .1..1 Y \.4.'-'-' • � • ..&. ""'b'-' .1. '-".1. '-"

Richard Malouf, the Dentist Accused of


Millions in Medicaid Fraud, is Building a
Private Water Park
By Eric Nicholson
Published Fri. , Jul. 13 2 0 12 at 11:31 AM

For the past year, WFAA has been digging into Richard
Malouf and All Smiles Dental and Orthodontics, the chain
of pediatric clinics he owns (used to own, actually) with his
wife. What the station found was what appeared to be a
massive case of Medicaid fraud in which he bilked the state
for unnecessary procedures.

In March, he settled with the feds to the tune of $1.2


million, only to be hit with another lawsuit, this one filed by
the state, three months later.

You might be wondering what Malouf has done with all the candy Evans

money. I mean besides spending it on the $ 1:1 million


Preston Hollow estate and the private jets. Just ponder it for
a second. What would a middle-aged dentist accused of massive Medicaid fraud want most in the
world?

A water park, of course.

Real-estate blogger Candy Evans knows these things. She reported on it yesterdav on her blog and has
the architectural drawings filed with the citv to prove it:

In 20 11, they bought 10674 Strait Lane, the house next door, as I've told you. He debated
what to do with it, as any investor would. Should he remodel and flip it, after all, they got a
great price. Sell it to a home builder? Ultimately, he decided to keep the home and connect
the two properties, by building a bridge crossover between the two homes which you can
see from the street, with a drivewayjport-cochere beneath it.

Eureka ! 10674 Strait Lane would be his family's own personal sports world. Just walk there
over the driveway.

It'll have a sports complex complete with a basketball gym, bowling alley and rock-climbing wall, deep
pool, lazy river, and 35-foot high water slides. Being built by the guys who did H urricane Harbor. It's
under construction right now. Owen Wilson was none too happy with the noise when he was crashing
with his parents a few months back, Candy tells us.

http ://blogs.dal l asobserver.com/unfairpark/2012/07/dentist_still_accused_of_milli. php?pri . . . 9/28/2012


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All for the greater good, though, right? Surely he will give open access to all the impoverished children
on whose bfte.ks teeth he paid for the extravagance. H ave a shuttle that carries them straight from the
clinics. Not mentioned in the plans, but why else would one want a private water park?

Showing 36 comments

Gat2keeponmovin 2 months ago

Think you can make it through writing an article without profanity or <del> tags?</del>

guest 2 mon t h s a�o i n ITP i l l " < ; a l :c>kcct H H l ll H l l i n

Dude - you are a complete loser. Why don't you troll some other blog since you obviously don't have a job o r anything worthwhile
to do.

quellepotat 2 months ago

Still want to expand Medicaid'?

Fraud happens to both public and private insurers. Medicaid provides healthcare more efficiently than private insurance,
Including fraud. Someone has to steal in order to get rich off Medicaid, in contrast to all the execs who've gotten rich off private
insurance.

"Medicaid provides healthcare more efficiently than private insurance" Actually Texas Medicaid has tradtionally been a
poorly run program allowing massive fraud by orthodontists because the state Medicaid administration bureacrats allowed
ALL orthodontic charges to be re-imbursed FOR YEARS without ANY scrutiny and evidentally without "noticing" the
escalating outflow of tax payer funds for shoddy orthodonture exceeded total costs in Georgia and California combined. FYI,
the state now outsources administration of many Medicaid funds to third party private insurers who are remarkably more
efficient and capable .. The NYT has an article yesterday which reveals those pushing hardest for expansion of Medicaid are
private hospitals, including NFPs (whose 1% CEOs make up to $smillion/year here-TH R). Hospitals pushed for the ACA
realizing their gravy-train was about to be de-railed in 2014-decreased Ins and Medicare re-imbursements like other
physician providers are stuck with since 1992- but could make it up with enhanced Medicaid enrollment. Those NFP
hospital system CEOs could continue to make millions and YOU can pick up the tab.(sucker)

scottindallas 2 months ilJ?.O i n rL·ph lo quc· l lep• ' ''"' '

and, all that fraud, cost a fraction of what the LI BOR scandal cost the taxpayers of this country.

Remind us what percent of the G DP is represented by the healthcare industry.

http://blogs.dall asobserver.com/unfairpark/20 1 2/07/dentist_still_accused_o(_milli. php?pri . . . 9/28/20 1 2


nearly 20%. Now here's the kicker. Medicare and Medicaid are less than 1/2 of medical payments.
Consider that private insurance doesn't do ANITHING--compared to the burden that medicare carries,
where the vast majority of our healthcare cost accrue. That's the real scandal.

� ·� Mavdog 2 months ago

Just a perfect illustration why the Obama proposal on ending the tax reductions for the wealthy are justified.

Think moving the tax rate to 39% from the current 36% would have a negative affect on this guy?

ObscJ•vist 2 months ago i n reply lo :'- l aH!""

Hell yes it would have a negative effect! He might have to reduce the height of his private water slides, which would reduce the
velocity of the" trickle down".

The government can waste it a Jot more efficiently that the private sector.

The irony of using a guy accused of stealing tax dollars to justify increasing the tax dollars he stole from is lost on you right?

no, but the irony of you posting a remark that in effect says that anyone who abuses the system for financial gain deserves
to get a reduced tax liability on that income sure is fun.

bwahahahaha

Gat2keeponnunin 2 m o nt h s t�go in rvpl\ tu \ l < l nlog

You are impressive at missing the point.

!� M avdog 2 months ago i 1 1 rvph ln ( : a l :! kt·\ !". l l l l i i O\ il)

apparently your "point" is that M alouf is "accused of stealing tax dollars", which BTW isn't accurate, and that my
pointing out that this doctor has is benefitting from a lowered tax levy on his amassed wealth
of supposed illgotten "tax dollars" is somehow irony.

as he didn't "steal" any money, the irony just doesn't exist.

http://blogs.dallasobserver.corn/unfairpark/20 1 2/07/dentist_still_accused_of_milli. php?pri... 9/28/20 1 2


however, you defending the current structure when confronted by the excess of this person, likely under the guise
of "fairness", is terribly ironic

What Malouf did was manipulate the system to bill the state for excessive amounts of orthodonic work that many
say wasn't needed. Of course, M alouf has settled those claims with no guilty verdict and therefore no crime, and
certainly no "stealing [of] tax dollars" exists.

M alouf is just a symbol of how inequitable the tax system has become under its current structure, where he can
amass the wealth to build a private water park off the back of public dentistry, or the hedge fund and venture
capital investor who isn't taxed at the same rates as us common people because they have "carried i nterest" rather
than having just everyday income. which in reality it is, just everyday income.

So let's hear it: is increasing the effective tax rate on a person such as Malouf the proposed 3% unfair and
inequitable? should the income from "carried interest" be taxed any different than standard income? well?

Gat2kceponruovin <! months ago in replY t" :'l l a nl<.!J!.

Higher taxes = more money to be ripped off.

Why does the federal government DESERVE more money?

seriously, THAT''S your response?

simple is as simple does.

You Sir are obviously correct.. .lets cut off ALL federal subsidies that could be abused. You know like
Transportation , Unemployment ,Medicare,Medicaid,Agricultural,Education...... .

Another not so sharp Obama voter

cngntofo <! months ugo i n rcph lo ( �;i l co kcqH • I I i l l " ' 111

He swings . . . . .h e misses

The government is a crime victim here - don't you think it should just shoot the perp?

http://blogs.dallasobserver.com/unfairpark/20 1 2/07/dentist_still_accused_of_milli. php?pri. .. 9/28/20 1 2


I 'm not defending him.

I also have no problem "blaming the victim" and the Obama voters that enable it.

But if it was a defense contractor and some republicans

higher tax rates shows up as slightly higher revenue. Even under Ike's 94% tax rate, the effective rate
was only 22%

qucllcpotat 2 months a�o in rvpl\ l u � l m doL;

FYI providing and charging for unnecessary and excessive medical services to Medicaid and M edicare
patients is fraud and punishable by the (federal) DOJ.

GusMitclu�m 2 months a�o Ll!__L<J.ill_!.,L�fu£

Manipulate the system, I did that when I was six, I manipulated the checkout line at Kmart and somehow
had extra HotWheels

TexOHara 2 months a?,o in rc:ply l ( ) il ! uYch '"

Define "wealthy."

Gat2kct.� pomnovin 2 months ago i l LU;J.liLI • �_JQ:t} I J; t r;I

"Everyone who makes more money than I do"

wow, that's a lot. from what you've posted my guess is about 98% of all Americans make more than you do.

pretty subjective, I'd place it at the top 2-3% of incomes.

THar 2 months ago iJJ_[Q,J-Lt.<>�\.!<�\ dn·•

http://blogs.dallasobserver.corn/unfairpark/20 1 2/07/dentist_still_accused_of_rnilli. php?pri ... 9/28/20 1 2


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,
u1v LI' V I I U .:t t .r�V\,.;UV\,.;U v.1 1 Y ..L I I I I V I10 111 1 V � V U IV U 1 U ..L 1 uuu
,
�� .LJ U U UJIIO u ..L 1 1 v at""' · · · ..L uo "" v v ..L v

stupid comment.

primi_timpano 2 months ago

Why do all these multimillionaire con men stick around to get caught, as opposed to changing their name and moving to Argentina?

gladnotsad 2 mo nths ago in rc·piY l11 pri m i LilllJ><lil"

Good question. Often socio-paths operate as though they want to get caught.

GusM i tchctn 2 months ago i n rl�Jlil l < 1 pri l l l i t i n JP<I I i < l

Because America i s a great place to be, especially when you are loaded

Larry 2 months ago

Belo goes after this water park, but has no problem touting the city's failed whitewater and the doomed Trinity tollway.... Partisan
swine.

cuomei635 2 months ago

linrurl.com /nilnzc

http://blogs.dallasobserver.com/unfairpark/20 1 2/07/dentist_still_accused_of_milli. php?pri... 9/28/20 1 2


11 11
EX H I B IT E
Transcript of WFAA June 26, 2012 Broadcast

J u n e 26, 2012 at 12:38 p.m.

http://www/wfaa. com/news/investigates/Attoreny-General-files-lawsuits-related-to-WFAA-dental­

i nvestigations-160402665.html

TEXAS ATTOR N EY G E N ERAL F I LES SUIT AGAINST DR. R. MALOU F - ALL S M I LES D E NTAL

W FAA - Byron H a rris rep o rts on c h a rges filed by Texas AG aga i n st a m ajor fra u d ster in Texas
o rthodo ntic.

Cash for crooked teeth . Texas tax payers have paid o ut m i l l i o ns of d o l l a rs. Now the Texas Atto r n ey
G e n e ra l wa nts 30 m i l l i o n of it back from a D a l l a s dentist. The state is s u i ng the dentist for fra u d . All of
it after a n ews aid i nvestigation . C h a n n e l 8's B rett S h i p p has the follow up tonight.

Brett Shipp: Byron H a rris' year long i nvestigation i nto q uestion a ble Med i ca id d e ntal payme nts h a s
exposed o n e o f l a rgest d e nta l o v e r b i l l i ng sca n d a ls i n the nations. O n e of the central fig u re s i n t h e
i nvestigation, D a l l a s d e n tist Richard M a l ouf, whose b i l l i ng successes afforded h i m t h i s m u lti m i l l i o n
m a nsion, corpo rate jets, a n d n u m e ro us l ux u ry ve h icles. N o w Atto rney G en e r a l G reg Abbott, a nd h i s
Civil Medicaid Fra u d Division have ta ken notice. T h e AG h a s filed two civil lawsu its accusing M a l o uf a nd
his p a rtners of vio lating State Med i ca id Laws. The court fil i ngs layout the a l leged sch e m e . D e n t a l c l i n ics
a l legedly i m p ro pe rly recruiting welfa re fam i lies, p e rform i ng need less o rthodo ntic work on the c h i ld re n ,
t h e n b i l l i n g the state fo r m il l i o n s of t a x payer d o l l a rs . H a rris' i nvestigation revea led Texas paid m o re i n
Medicaid o rthodontic c l a i m s t h e n the oth e r forty- n i n e states com bi n e d . T h i s past A p r i l a Congress i o n a l
Com m ittee t o o k note a n d a k e y wh istle blower, D a l las O rthodo ntist, C h ristine E l l i s testified a b o u t h e r
contin u i ng frustrations.

Christine Ellis: " I was contacted by both Texas OIG a nd the Atto rney G e neral with i n a bo u t a w e e ks
p e riod after o n e of Byron H a rris' sto ries ra n ."

Man questioning Ms E l l i s : " H a s the office of I ns pecto r G e ne r a l at the D e p a rt m e n t of Hea lth a n d

H u m a n Services ta l k to you?"

Christine Ellis: "The F e d e ra l?"

Man questioning Ms Ellis: "Yes."

Christine Ellis: " N o ."

B rett Shipp: I n addition to the Congressio n a l H e a ring seve r a l key M edicare regu lators i n the state
h ave a n nou nced resignations or been reassigned. In M a rch Dr. M a l o uf agreed to pay 1.2 m i l l i o n d o l l a rs
to Federal a n d State reg u l ators i n a sett l e m e nt over q u e sti o n a b l e b i l li n g . H e h a s yet to com me n t o n the
a l legations but filed for B a n k r u ptcy and i s i n the process of divesting his o nce i m p ressive e m p i re a nd

the Attorney Ge n e r a l spokesma n said today t h e i r i nvestigation is o ngoing. B rett S h i p p for Cha n n e l 8
N ews.
EX H I B IT " F"
ALL SMILES DENTAL CENTER FILES FOR
BANKRUPTCY FOLLOWING INVESTIGATION
h ttp://www wfaa com/news/investigates/A I I Smi les F i les for Bankruptcy
. .
- - - - --
1 50243 685 html
.

May 5, 20 1 2

GLORIA CAMPOS (W FAA/NEWS 8): A mansion paid for in pmi by chlldren's


braces, now this was taken last year, but now as a result of a News 8 i nvestigation. The
owner's chain of dental clinics is bankrupt but yet his $20 million house is growing and
today it has literally doubled in size. News 8 ' s Byron Hmris has an update tonight.

BYRON HARRIS (WFAAINEWS 8): Frenos Gratis Con Medicaid reads braces with
Medicaid even today All Smiles advetiises free braces with Medicaid even though the
state of Texas was never supposed to routinely provide them and this All Smiles clinic in
Oak Cliff remains open but for the last several months the All Smiles empire has been
declining fi·om dozens of clinics to fi·om when our investigation began to a handful today.
This high volume clinic on Garland Road has closed. I n Chapter l l All Smiles lists $ 50-
I 00 million in liabilities and $ 1 - 1 0 million in assets. At one point, All Smiles b illed as
much for Medicaid braces as the entire State of Illinois. Its leader, the flamboyant dentist
Richard Malouf, he had two corporate jets, a Bentley, a Porsche, and a chateau in Dallas '
toniest neighborhood. Richard Maloufs $ 1 1 million mansion is a symbol of the wealth
he built under Medicaid, its untouchable in this bankruptcy and its getting even bigger.
On his sprawling Strait Lane propetiy, Malouf is expanding his chateau. Construction
crews appear to be doubling the size of the original. Malouf still owns 28% of All Smiles.
Most are owned by Valor Equity of Chicago. In March, Malouf agreed to pay the federal
government $ 1 .2 million to settle a case for the alleged fi·audulent billing of Medicaid for
over tour years. He admitted no wrong doing. Although he is listed as a creditor in the
All Smiles bankruptcy, Malouf ' s empire appears intact. He can smile at life. Byron
Harris, Channel 8 News.
11 11
EX H I B IT G
Transcript of WFAA October 8, 2012 Broadcast

October 8, 2012 at 10:30 p . m .

http://www.wfaa.com/news/investigates/Water-Park-Nears-Com pletion-While-B i l l s-Go-U n paid-

173187881.html

Water Park Takes Shape in Backyard of Dentist Who Owes M illions

WFAA: When you t h i n k wate rsl ides you p ro b a b ly think H u rrica n e H a rb o r o r Hawaiian Falls n ot the

l u x u ry h ouse of a N o rth Texas d e ntist u nd e r investigation for fra u d . This p rivate water park belo ngs to
Texas most fa m o us d e ntist Dr. Richard M a lo u f a nd to n ight our o ngoing n ews aid i nvestigation reve a l s
h i s estate continues to grow. A s his d o e s h i s b i l l i n g p robe.

Byron Harris: The t h ree sto ry water p a rk i s nearing co m pletion even t h ough its owner Dr. R i c h a rd
M a louf is being sued for fra u d by the atto rney general. All s m i les d e nt a l ce nters the co m pa ny h e
fo unded a nd stil l owns p a rt o f d ecla red b a nk ru ptcy e a r l i e r this yea r. But t hat's o n ly p a rt o f the fin a ncial
backgro u nd b e h i n d Richard M a l o uf. N ews C h a n n e l 8 investigates.

Byron Harris: Forget Disney La nd this is De nta l Land b u i lt by a dentist who m a d e a fortu n e from the
Med ica id d ental p rogram i n one of Dal las' poshes! n eigh borhoods with water slides a n d a l a zy river. It
will use six a nd a h a lf m i l l i o n g a l l o n s of wate r so m uch it has its own we l l . It p e a ks t h rough the t re e s
into neighbors' ya rds. The latest ed ifice i n the e m p i re of M ed icaid de ntist Dr. Richard M a l o uf. T h a t' s
h i m i n the B entley e m e rging from b e h i n d h i s i ro n gates. W h e n h e spots us ta king h i s pictu re h e c a l l s
D a l l a s police, wit h i n seco nds the p o l ice a rrive t e l l i ng us we a re just fi n e w h e re w e a re .

Candy: O h they a re s p raying water a t us.

Byron H arris: The n his gard en e r sta rts trying to s pray us with a h ose from a cross the street.

Candy: Ta l k about wasting water !

Byron Harris: Despite h i s fo rtress o f assets, M a louf won't ta l k to u s . Si nce last yea r h e h a s d o ubled
the size of his French chateau o n Stra it La n e . The new o n e acco rd ing to reco rds filed with the city has a
bowling a l ley a n d a gym n a s i u m ; he has a m il li o n d o l l a rs worth of p r o p e rty at the ra nch n e a r Poss u m
Kingdom La ke. A secon d h o m e l a rg e r t h a n most people's first h o m e . A n d t h ree lots worth t h re e
h u n d red fifty thousand d o l la rs, p r o p e rty records show. But despite M a l o uf's roster o f p hysica l
possessio ns, news aides learned he h a s a history of being sued for not paying h i s b i l l s .

Byron Harris: I n Atla nta a co u rt order says All S m i l e s D e n t a l Cente rs o w e s a n i nvestment ba n ke r more
t h a n 3 . 2 m i l l i o n d o l l a rs from w h e n M a lo uf was CEO. In D a l l a s records show he had a federal tax l i e n of
m o re than two h u n d red twe nty five thousand d o l l a rs agai nst him in 2006 which h e u ltimate ly p a i d . And
i n Dallas Co unty reco rd s show co nstructio n fi rms have filed six o utsta n d i ng l i e n s agai nst his chate a u for
m o re t h a n o n e h u nd red twelve thousand d o l l a rs ove r the past thre e yea rs. Severa l entities have t h e i r
eyes o n M a l o uf, first, B a n kr u ptcy Cou rt M a lo uf sti l l o w n s p a rt of All D enta l S m i le s De nta l Centers w h ich
decla red ba n k r u ptcy e a rl i e r t h i s year. Second, the Texas Atto rney G en e r a l is suing M a louf fo r M e d icaid
fra u d .

Lady speaking: . . . . The flagra ncy of t h e fra ud that I fou n d . . . .

A w histle blower says 90% of the c l a i m s All S m i l e s filed u n d e r the Med i ca i d O rthodontic P rogra m w e re
fra u d u l ent, M a lo u f d e nies the c h a rges. But a l l smiles billed the state more that 5.5 m il l i o n d o l l a rs for
com posite fil l i ngs in kid's teeth u nd e r M e d icaid last yea r. And M a l ouf's n e ighbors a re watc h i n g h i m .

Byron asking Candy: Does the water park necessa rily e n h a nce the value of the p ro p e rty.

Candy: This water p a rk? Absol utely not. The neigh bors a re very d istressed, beca use they d o n't w a n t to
look at wet a nd w i l d . Even though you have got these two a nd th ree acre p r o p e rties you ca n s t i l l see
this thing.

Byron: The workers we have ta l ked to say they a re sti l l getting paid. M a l o uf is m a naging this

constructi o n h imse lf. Stil l a s the ba n k r u ptcy a nd fra ud cases work t h e i r way through the cou rts, t h e
d o o rs m a y n o t h ave closed o n the stage o f denta l work.

Byron H arris C ha n ne l 8 News.


EX H I B IT "H"
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Second heltersBiog
""""'""' ecouse you con never hove loo many homes '"-""

Sliders of Blue: Would You Put a Private Water Park in Your Backyard?

Is this the private D allas water park that braces built?


And would you even consider putting in a water park in
a private home? Tc:-,:a" D r i l b ll! !W l l 1m l\ kd i ('a i d [k n t a l

Fr:llld . . (sub. rec.) i s a headline i n today's Wall Street

Journal. What do they mean by that? Possibly the

business practices of people like R i \' h md l\1 a l n u f 1\' h n i s


tn l t t i n .�� i n a \Y<i k r Pa r L t h ai l l llt ' reader t h i 1 1 k s \l l' n u g h l

t o t 'l l l i;;lt• J J '"\\' ; 1 1L ' r P i k F':1 r k '" ( J\ l'l' 1 1 1 1 St ra i t La 1 w . His

gates were wide open on Sunday as trucks h eaved in the

equipment which is now �;itting right in the front yard

of what was once 10711 Strait Lane.

1 of 3 1 01 1 /20 1 2 2:25 PM
� u uers U l D I U e : VVUUIU I U U r u L a r i i VaLt: vv a Lt.:I r a i K Ill I UUl Udf..... l\. JcllU . . . u up . ! ! W W W . ;:")�\.,V1lU3li\.,H\_, I 3 . \..-V l l lf .£..V l .£../ V U/ .:.. l / J l l 'U- "-" .l .;r v i U"-"- P '-' " - ....J I 1 Y U.'-'-' n...

is, as you know, is the Family Sports World.

any of you were a.'l surprised a.'l I was over this Medicaid deal - I mean, I know what Medicaid reimburses physicians for
'""ou''""-" care and it is barely enough to cover the exam table paper in the office - it seems as though the problem stemmed

a 2007 civil lawsuit (that really started in 1993) that made the state inct"ease reimbursement rates for Medicaid dental

"The suit, a federal class action filed by parents in 1 993 against state officials, alleged Texas was failing in its

duty to ensure that children on Medicaid received proper preventa tive care in dental and other areas.

Eligibilih.J for Children's Medicaid in Texas is pegged to income. In 2007, Texas legislators agreed to settle,

conceding tha t there was a dwindling number of doctors and dentists in the state willing to treat Medicaid

patients and agreeing to increase Medicaid-reimbursement ra tes. A 2012 report by the House Com mittee on

Oversight and Govemment Reform offered case stltdies in various states of supposed Medicaid abuse; it

cited dental services in Te.xas as a particular problem area. By 2010, according to the report, Texas'

Medicaid program was spending more on braces than the other 49 state Medicaid programs

spent combined on such orthotics. "

il : d U\ I f i l l H : > l ' l i ' , l< ' i l< l !' l i '( i , : t nd I wonder why the ws.J doesn't mention his report. It has also, like always,

in the loss of services for kiddos who really need it: All Smiles Dental Professionals P.C., has shuttered 13

2 of 3 1 0/ 1 /20 1 2 2:25 PM
lorihodontic offices in the Dallas area because of the investigation, leaving an estimated 12,000 Medicaid-eligible patients
I . I1out care .
lWit
tl
jBut hey, \\ : l l l'r- Pi k Pa r k � � ( ' " I I! Look at those slides just waiting to be installed! I t :--. 1 ( ' "' m i l l i " n .� < il i o n ,; of \\ all'!.
l
j: t n d T c ·\ : ! ' ' ll l ' l ' h : J :, p k ! i !l " f t l w t 1 i � i l t"

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I
I ���1and
j Super


L()('ation,
Grent
Open
House
Candy in
Not .Just
A Se<'ond
Homt":
Hunter


Lot�ation, Dallas: Mahan
Location Don't Be and
Koi Btide
About Building
These 19,000
H om
es Squa re
Ff'et in
Dallas

Seco n d h on'!fe�! �p1d t a xes, Secon d Since its launch in October, 2010, SecondShelters.com has established itself as the
!l o m e c ka l s . .N c·\\ Yo r k Ci tY, U rb a n
, center of the second, vacation and investment home real estate universe offering readers
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sevo nd li o m es, ,\ s k Cl ! ! d v:secoml
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deals, new developments, the where it's not, and of

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course the latest gossip. We do it all from our base in Dallas/Fort Worth, where everyone
likes to get out of Dodge come August. Unlike 99% of the sites out there,
s t o r i es a ffccli llg .'-i ccond l wnws, SecondShelters' content is created by an award-winning national jountalist who isn't
EconomY, C d i for u i a, ! I ou:--. e Cmch-, trying to sell you a home; a journalist who went to real estate school to sleep with the

·tH1(h·.:.;; L) i r t . co n t , c i ncr�i t 1 g real c\Stat e enemy; a journalist who visits and reviews each property, eyes t.ite neighborhood and
kicks the tires hard in her Louboutilts. Make no mistake: Candy Evans !<'II> i t l i ke' il i,
n l a rk(:ts, Real Est a te, B'c;H:h ! l ome.:: ,
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1
11 11
EX H I B IT
w aLer parK LaKes snape Hl oa\:Kyaru u1 ut:Hll:SL w 1 1u u w e;; s uuutuH:s 1 w taa.�,.;uut uauas - r vl l . . . 1 a�co 1 v 1 £..

DALLAS/ FORT WORTH I W FAA-TV

Water park ta kes shape i n backya rd of dentist


wh o owes m i l l ions

by BYRON HAR R I S

WFAA

Posted on October 8, 20 1 2 at 1 0 03 P M

Updated Tuesday, Oct 9 at 6 1 7 PM

NEWS 8 INVESTIGATES

DALLAS - There's a different kind of skyscraper going up in one of Dallas' most


exclusive neighborhoods on Strait Lane. M avericks superstar Dirk Nowitzki, former
Rangers ovvner Tom Hicks and even Mayor Mike Rawlings live close by.

This "skyscraper" is really a three-story water slide and lazy river in the backyard of
Texas' most famous dentist.

http://www.wfaa.com/news/investigates/Water-Park-Nears-Completion-While-Bills-Go-... 1 0/ 1 2/20 1 2
w ater parK LaKt:S suapt: HI ua�.;Ky dl u v 1 ucu u :, L w uv v w c:, uutuvu;:, 1 vv 1 aa ... vu1 LJa11a;:, - � vH. . . � ub'"' ... vL ...

Dr. Richard Malouf made millions from putting braces on children under
Medicaid.

In a whistleblower lawsuit, the Texas attorney general says much of Dr. Maloufs
work was fraudulent. All Smiles Dental Clinics - which Malouf founded and still
owns part of - filed for bankruptcy earlier this year.

Work on the water park and an addition to Maloufs huge chateau on Strait Lane
continues.

A turquoise pigtail of a water slide curls over the backyard and peeks through
neighbors' trees. A five-foot wide, concrete-lined Lazy River water feature is taking
shape below.

But a News 8 investigation fi nds the Bentley-driving Malouf has a history of being
sued for failing to pay his bills.

Malouf owes an Atlanta-based banking firm $3.2 million for services rendered but
not paid for, according to findings by a federal court last year.

Dallas County records show Malouf owed the I nternal Revenue Service $ 226,0 0 0
for income taxes through the mid 2000s. H e paid the tax bills shortly before h e sold
most of All Smiles to an equity firm.

But Malouf has not yet paid half a dozen firms that have worked on his mansion .
There are liens for more than $ 112,000 on his property over the past three years.

M aloufs attorneys have not responded to our attempts to contact him.

Because homesteads are shielded from seizure i n Texas, wealthy homeowners often
put as much money into their homes as possible in the face of legal action like
Malouf faces.

But Dallas real estate agent Candy Evans said the water park may not
enhance the value of Maloufs property.

"Even a swimming pool now is looked at as something that will lose value. It's like a
car," Evans said. "It's going to be a huge negative for the prope1ty. The neighbors
are distressed because they don't want to look at Wet 'n Wild."

Email bharris@wfaa.com

http://www.wfaa.com/news/investigates/Water-Park-Nears-Completion-While-Bills-Go-... 1 0/ 1 2/20 1 2
11 11
EX H I B IT J
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l__iiiE construction and beyond. " - . ··- ���


O£SIGltrt. IUtLDIT AEMODB..rt
�'"""'�

Richard Malouf Really Likes Water Games, Turns Hoses On Us On Strait Lane
E\;,ns on fktolwr 2. 2012

Byron Harris at WFAA-TV is the guy who


busted Richard Malouf He's got some more
info coming down the pike, and we are both
watching progress on what I have christened
"Water Pic Park", the massiw backyard priYate
water park project Malouf is building over at
10711 Strait Lane. So Friday we met in front of
the house to check progress and talk about how
the neighbors feel. ( Hint: they are not happy.)
You may recall , Malouf called the cops on me
and accused me of trespassing on his property
on August 22. I did not; was not even near
Strait Lane and can prove it. Wel l , he wasted
no time in calling the cops Friday on Byron
Harris and his camera crew - this before I got
there. Malouf drove out in his Bentley. Cops
came, said WFAA doing nothing wrong. Cops left . I arrive for the interview. You can't see much now from the front, the big
3-story tall tubes are now in the back. Oh but you can see plenty from the neighbor's yard, hint hint. We are busy talking
when we notice water being sprayed OVER the fence. From a hose - don't worry, the cameras caught the whole thing. They
told us (from behind the fence) they were watering the trees, but most of it was directed our way. It was so hot Friday, that
l i ttle shower felt good!

Can 't wait for the story to nm . See, Malouf really is trying to create Wet N Wild over there on Strait Lane even in the
streets.

Meantime, wanted you to see the new "No Trespassing" signs he has put out. They mean business, too, as I'm told orders
have been given to shut the gates immediately after they are opened. Operation protect Water Pic Park!

J ' I Ji�·· 1 ',' .1 · s


ii 1 t 'r'h,hrity f ! nnw�. cPI<>hrit�· rt';-11 e-o; l a l e . J);J}];Jo; n•cll l'.'- l ll\(· !W\\·s. Heal E�lnt('. I.Zt>;Jl e tat(' market new" . 1 1 1 d l .lQ�ed Bentley Cops. B�Ton I I a rri:.;_ � lalouL
Eidw 1 d \!a lout" l h'S. Siiait Lane \\T.\XIY permalink

http://www.candysdirt.com/20 1 2/1 0/02/richard-malouf-really-likes-water-games-tums-ho... 1 0/1 2/20 1 2


KH.:naru JVI aiU U l Keau y L I Ke::; vv ater va1ue:s, 1 ur u::; nu::;c:::; vu u ::; vu ..J ll i:U l L aue: 1 \...- a11uy ::; . . . r a�;; c: "- u .t J

10 Responses to Richard MaloufReally Likes Water Games, Turns Hoses On Us On Strait Lane

Mike on October 2, 2012 at 10:26 am

What kind of clown is this guv'l

Joanna England on October 2, 2 0 1 2 at 1 o::J8 a m

�praying a hose OH.'r a frnre? That's .iust tasteless.

Scott on October 2, 2 0 1 2 at 1 2 : 10 pm

F1ida!·'? Sounds like a ,·iolation of Dallas \Yatering restrictions to me.

Chuck Fleischer on October 2. 2 0 1 2 at 1 2::31 pm

You .iust got splasl1ed by a douche bag. Troubl e m a ker. ' ;)

Joe on October 2. 2 0 1 2 at 4:5-1 pm

You'd probabh haYe gotten a much lwtter response if Hm'd brought a ,·an ful l 2-yr-old Medicaid recipients for their appointment to get braces on
their baby teeth.

Red on October 2. 2012 at il::Jo pm

Sounds l i k e \'l>n're a nosy jealous bitch as well as ,Joe and Churk and Scott and ,Joanna and Mike, all pathetic jealous srabs. R}Ton Hanis "busted"
Dr. M a l ouf, ll\ron didn't bust anyone. llr. Malouf issued the State of Texas an inYoice and the,· paid it, case closed. Cet a l i fe �·ou pitiful wanna­
lw.

Lindy on October :J. 2 0 1 2 at 2 : 0 1 pm

Gee dnps RPd haw a had toothache" Perhaps he should spc a dentist.

Candy Evans on < ktnber :J. 2 0 1 2 at 1 2 : 20 am

Red · i f only he hadn't gotten m�: hair t vct.

http://www.candysdiii.com/20 1 21 1 0/02/richard-malouf-really-likes-water-games-tums-ho... 1 01 1 2/20 1 2


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