UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY NORTHERN DIVISION AT COVINGTON
SARAH JONES, a/k/a/ JANE DOE, Plaintiff, v. DIRTY WORLD ENTERTAINMENT RECORDINGS LLC,
., Defendants. Case No. 2:09-cv-00219-WOB Judge William O. Bertelsman
AFFIDAVIT OF NIK LAMAS-RICHIE IN SUPPORT OF DEFENDANTS’ RENEWED MOTION FOR SUMMARY JUDGMENT
I, NIK LAMAS-RICHIE, declare as follows: My name is NIK LAMAS-RICHIE. I am a resident of the State of California, am over the age of 18 years, and if called to testify in court I could and would truthfully testify to the following information based upon my own personal knowledge. 1.
I am currently employed as the manager of Defendant DIRTY WORLD, LLC (“Dirty World”) which owns and operates the website www.TheDirty.com. 2.
I am aware that on January 10, 2012, the Court in this matter issued an order finding that I was not entitled to immunity under the Communications Decency Act because, among other things, “The principal content of ‘the dirty.com’ web site is not only offensive but tortious.” To my knowledge, this conclusion is untrue and is without any basis in fact. 3.
As of March 7, 2013, www.TheDirty.com contains a total of 121,863 separate posts in more than 900 separate categories. In addition, the site also contains a total of 3,182,200 comments about posts.
Case: 2:09-cv-00219-WOB-CJS Doc #: 177-1 Filed: 03/07/13 Page: 1 of 94 - Page ID#: 2696