describing events that occurred
twenty-three years before
she held her federal position and, infact, was encouraging people
to discriminate on the basis of race.2.
This action is brought against Andrew Breitbart, author and publisher of the blogpost that contained the defamatory statements; Larry O’Connor, who posted on the internet themisleading edited video segment used in the blog post; and JOHN DOE, an individual whoseidentity has been concealed by the other Defendants and who, according to Defendant Breitbart,was involved in the deceptive editing of the video clip and encouraged its publication with theintent to defame Mrs. Sherrod.3.
Although the defamatory blog post authored by Defendant Breitbart purported toshow “video proof” that Mrs. Sherrod exhibited “racism” in the performance of her USDA jobresponsibilities, the short two-minute thirty-six (2:36) second video clip that Defendantsembedded in the blog post as alleged “proof” of this defamatory accusation was, in truth, anedited excerpt from a much longer speech by Mrs. Sherrod that demonstrated
exactly the opposite
. In sharp contrast to the deliberately false depiction that Defendants presented in thedefamatory blog post, the unabridged speech describes how, in 1986, working for a non-profitgroup that helped poor farmers, Mrs. Sherrod provided concern and service to a white farmerwho, without her help, would almost certainly have lost his farm in rural Georgia.4.
Specifically, Defendants defamed Mrs. Sherrod by editing and publishing anintentionally false and misleading clip of Mrs. Sherrod’s speech
added the followingstatements as a narrative to the clip:
“Mrs. Sherrod admits that in her federally appointed position, overseeingover a billion dollars ... She discriminates against people due to theirrace.”
Mrs. Sherrod’s speech is “video evidence of racism coming from a federalappointee and NAACP award recipient.”