35. DefendantkneworshouldhaveknownthattheheadlineoftheJuly2,2010postwasfalse, especially since the post itself contained no information regarding an investigation of Lost Society by the Dallas Sheriff’s Department and no such investigation is occurring or hasoccurred.36 On September 11, 2010, Defendant committed libel and published disparaging anddefamatory words that were untrue about Plaintiffs on a public Internet site,
, owned and maintained by Defendant.37. TheSeptember11,2010postreads,"LostSociety’sRosalesbackinpokeyforskippinga hearing."38. Defendant'sstatementsof“Rosalesskippedahearingbeforeajudge
..Notonlydidhe skip it, but even his attorneys skipped the hearing” and “ Rosales and his attorney reportedlytoldthejudgetheywouldtrytomakeittocourtinafewdays,youknowhe’skindabusy renovating the club without any permits
” are false and Defendant knew or shouldhave known there was no basis for this statement.40. The October 30, 2010 post reads, "
One dead, one hurt in Lowest Greenvilleshooting
"41. Defendant's statements of “This is the second shooting in less than six months onLowestGreenville.ApatronofLostSocietywasshotandkilledontheChar-BarparkinglotinearlyJune2010..
”arefalseandDefendantkneworshouldhaveknowntherewasnobasisfor this statement.43. The October 30, 2010 post reads, "
"44. Defendant's statements of “There's no word on when his former partner and BFF,Fernando Rosales, will be back in detention, but the wheels of justice they do grind slowly. We are patient.
” are false and Defendantkneworshouldhaveknowntherewasnobasisfor this statement.46. TheDecember04,2010postreads,"