No.

07-16-00320-CV

Seventh Court of Appeals
at Amarillo
Timothy Castleman and
Castleman Consulting, LLC,
Appellants,
v.
Internet Money Limited and
Kevin O’Connor,
Appellees.

On Appeal from the 237th District Court
of Lubbock County
Trial Court No. 2016-519,740
Castleman’s Opening Brief

Leif A. Olson
State Bar No. 24032801
leif@olsonappeals.com
The Olson Firm, PLLC
PMB 188
4830 Wilson Road, Suite 300
Humble, Texas 77396
(281) 849-8382

Oral argument requested

Counsel for
Appellant Vision 20/20

Identity of Parties and Counsel
Defendants-appellants
Timothy Castleman
Leif A. Olson
Castleman Consulting, LLC
State Bar No. 24032801
leif@olsonappeals.com
The Olson Firm, PLLC
PMB 188
4830 Wilson Road, Suite 300
Humble, Texas 77396
(281) 849-8382
Counsel on appeal
Jared B. Hall
State Bar No. 24055615
JHallAttorney@gmail.com
P.O. Box 6982
Lubbock, Texas 79493
(206) 853-7182
Counsel in trial court
Plaintiffs-appellees
Timothy Castleman
Internet Money Limited

J. Paul Manning
State Bar No. 24002521
jpmanning@lubbocklawfirm.com
Anna McKim
State Bar No. 24033381
amckim@lubbocklawfirm.com
Field, Manning, Stone,
Hawthorne & Aycock, P.C.
2112 Indiana Avenue
Lubbock, Texas 79410
(806) 792-0810

1

Table of Contents
Identity of Parties and Counsel ........................................................... 1
Table of Contents ............................................................................... 2
Index of Authorities ............................................................................ 4
Statement of the Case ......................................................................... 7
Glossary .............................................................................................. 7
Statement on Oral Argument .............................................................. 8
Issue Presented ................................................................................... 9
Facts ................................................................................................. 10
A. Castleman gives O’Connor instructions on ordering
products. ................................................................................. 10
B. O’Connor doesn’t follow the instructions—and can’t admit
it. ........................................................................................... 14
C. Castleman reviews O’Connor’s work. .................................... 16
D. O’Connor sues........................................................................20
Summary of Argument...................................................................... 22
Standards .......................................................................................... 23
1. Proceedings under the Act. ................................................ 23
2. Defamation requires a falsehood. ....................................... 25
3. Truth is a defense. ............................................................. 25
Argument: O’Connor didn’t meet his burden to furnish prima facie
evidence of defamation because Castleman’s statements are protected speech.
The trial court erred in denying the motion to dismiss. ............................ 26
A. This case is based on Castleman’s exercise of his freedom to
speak. ...................................................................................... 26
B. O’Connor’s attempt to establish a prima facie case failed. ...... 27

2

1. There is no evidence that the factual statements were
false. .................................................................................. 27
2. Opinions can’t be false. ...................................................... 29
C. Castleman’s statements were true. ......................................... 33
D. The commercial-speech exception in the Act doesn’t
swallow the rule that Castleman’s speech protected. .............. 35
E. Both defendants moved to dismiss—which O’Connor’s
response to the motion recognized. ......................................... 37
F. Castleman has proved his legal fees as a matter of law. ............ 39
Conclusion and Prayer ...................................................................... 39
Certificate of Compliance .................................................................40
Certificate of Service.........................................................................40

3

Index of Authorities
Cases
Arant v. Jaffe
436 S.W.2d 169 (Tex. Civ. App. – Dallas 1968, no writ) ............... 33
Backes v. Misko
486 S.W.3d 7 (Tex. App. – Dallas 2015, pet. denied) ................... 36
Beaver County, Okla., Bd. of Commrs. v. Amarillo Hospital Dist.
835 S.W.2d 115 (Tex. App. – Amarillo 1992, no writ)................... 39
Bentley v. Bunton
94 S.W.3d 561 (Tex. 2002) .................................................... 25, 30
Billington v. Houston Fire & Cas. Ins. Co.
226 S.W.2d 494 (Tex. Civ. App. – Fort Worth 1950, no writ) ...... 33
Farah v. Esquire Magazine
736 F.3d 528 (D.C. Cir. 2013) ...................................................... 32
Franklin v. Dynamic Details, Inc.
10 Cal. Rptr. 3d 429 (Cal. App. 2004) .......................................... 33
Greenbelt Cooperative Publishing Assn. v. Bresler
398 U.S. 6 (1970) ......................................................................... 33
Gustafson v. City of Austin
110 S.W.3d 652 (Tex. App. – Austin 2003, pet. denied) ...............26
Hancock v. Variyam
400 S.W.3d 59 (Tex. 2013) .......................................................... 25
Hicks v. Group & Pension Administrators, Inc.
473 S.W.3d 518 (Tex. App. – Corpus Christi 2015, no pet.) ... 36, 37
Hogan v. Winder
762 F.3d 1096 (10th Cir. 2014) ..................................................... 33
Kachina Pipeline Co. v. Lillis
471 S.W.3d 445 (Tex. 2015) ........................................................ 28

4

Kinney v. BCG Attorney Search, Inc.
No. 03-12-00579-CV, 2014 WL 1432012 (Tex. App. – Austin April
11, 2014, pet. denied) ................................................................... 36
Lamons Gasket Co. v. Flexitallic L.P.
9 F. Supp. 3d 709 (S.D. Tex. 2014) .............................................. 36
Masson v. New Yorker Magazine
501 U.S. 496 (1991) ...................................................................... 35
McIlvain v. Jacobs
794 S.W.2d 14 (Tex. 1990) ..................................................... 26, 35
Milkovich v. Lorain Journal Co.
497 U.S. 1 (1990).......................................................................... 25
Miller Weisbrod, L.L.P. v. Llamas-Soforo
No. 08-12-00278-CV, __ S.W.3d __, 2014 WL 6679122 (Tex.
App. – El Paso Nov. 25, 2014, no pet.) ......................................... 36
Moore v. Waldrop
166 S.W.3d 380 (Tex. App. – Waco 2005, no pet.)....................... 33
NCDR, L.L.C. v. Mauze & Bagby, P.L.L.C.
745 F.3d 742 (5th Cir. 2014) ......................................................... 36
Neely v. Wilson
418 S.W.3d 52 (Tex. 2013) ............................................... 25, 29, 35
New Times, Inc. v. Isaacks
146 S.W.3d 144 (Tex. 2004)................................................... 25, 30
Newspaper Holdings, Inc. v. Crazy Hotel Assisted Living, Ltd.
416 S.W.3d 71 (Tex. App. – Houston [1st Dist.] 2013, pet. denied)
..................................................................................................... 36
Old Dominion Branch No. 496, Natl. Assn. of Letter Carriers v. Austin
418 U.S. 264 (1974)................................................................ 30, 31
Ragsdale v. Progressive Voters League
801 S.W.2d 880 (Tex. 1990) ........................................................ 34
5

Rehak Creative Servs., Inc. v. Witt
404 S.W.3d 716 (Tex. App. – Houston [14th Dist.] 2013, pet.
denied)........................................................................................ 24
Schimmel v. McGregor
438 S.W.3d 847 (Tex. App. – Houston [1st Dist.] 2014, pet.
denied)......................................................................................... 36
Whisenhunt v. Lippincott
474 S.W.3d 30 (Tex. App. – Texarkana 2015, no pet.) ................. 36
Wood v. Del Giorno
974 So. 2d 95 (La. App. 2007) ...................................................... 33
Statutes
Tex. Civ. Prac. & Rem. Code § 27.001 ............................ 26, 36
Tex. Civ. Prac. & Rem. Code § 27.002................................. 24
Tex. Civ. Prac. & Rem. Code § 27.005 ................................. 24
Tex. Civ. Prac. & Rem. Code § 27.009 ................................. 24
Tex. Civ. Prac. & Rem. Code § 27.010 .................................. 35
Tex. Civ. Prac. & Rem. Code § 27.011 .................................. 23
Rules
Tex. R. Civ. P. 91......................................................................... 38

6

Nature of the case

Statement of the Case
Texas Citizens Participation Act motion to dismiss defamation claims

Trial court

237th District Court
Judge Les Hatch

Trial court
proceedings

O’Connor sued Castleman for defamation for
statements Castleman had made on his podcast
and in a blog post. CR __. Castleman moved under the Texas Citizens Participation Act to dismiss the claims because the statements were an
exercise of the right to free speech. CR __.

Trial court
disposition

The trial court denied the motion. CR __. After
the deadline to do so, it issued findings of fact
and conclusions of law identifying six statements that were susceptible of a defamatory
meaning. Appx. 4.

Castleman

Glossary
Appellants Timothy Castleman
and Castleman Consulting, LLC

CR

Clerk’s record

O’Connor

Appellees Kevin O’Connor and
Internet Money Limited

1SCR

First supplemental clerk’s record

2SCR

Second supplemental clerk’s
record

7

Statement on Oral Argument
Castleman requests oral argument. This would allow the Court to
address particular concerns it may have about the statements at issue
and the context in which they were made. It would also allow the Court
a full opportunity to consider the substance of the statute at issue, which
it has done in only one case.

8

Issue Presented
A customer posted online about his experience with a
service provider. The post described their interactions
and the provider’s breach of their contract, opined on
the provider’s performance, and suggested that others
avoid the provider. The provider asserts that the post
was defamatory because he read the parties’ contract
differently.
Did the trial court err in denying the customer’s motion
to dismiss under the Texas Citizens Participation Act?

9

Facts
A. Castleman gives O’Connor instructions on ordering products.
Castleman hired O’Connor and his company to work as a virtual assistant. CR _. Among O’Connor’s duties were placing orders with suppliers for delivery of products that customers had ordered from Castleman’s website. Id. Castleman sold some products in different lot
sizes than the sizes in which products were supplied. Id.. That is, Castleman might have sold widgets in lots of 10, but the widgets came from
the supplier in lots of 5. Id.
Castleman furnished O’Connor with instructions for how orders
were to be placed. Appx. 1. The instructions included an example that
demonstrated how multiple-unit products were to be ordered. The first
three steps in the instructions were to log in to Aliexpress, the orderfulfillment website; sort the orders to find the unfulfilled ones; and click
on an unfulfilled order to open it. Appx. 1 at CR _. The next step was
to “look at the order, paying special attention to the amount of each
item.” Appx. 1 at CR _. It was accompanied by this illustration, in
which the example customer ordered two of each item:

10

Appx. 1 at CR _.
The very next instruction and illustration described what to do when
Castleman and the supplier had different lot sizes:
Now go to the Products In Store Spreadsheet and find
the first product on the spreadsheet. Pay special attention to the rows “Variation” and “Volume.” The volume of the Kawaii Sticker Tabs means that if someone
ordered 1 of the item in the store, then we would order
2 in Aliexpress. If someone orders 2 in the store then we
order 4 on Aliexpress. The Variation tells you which
item on the Aliexpress listing to order.

11

Appx. 1 at CR _. As the written instructions specifically noted, the Kawaii Sticker Tabs had a volume of 2, so O’Connor would need to order
two sets of tabs from the supplier for every single set of tabs that a customer ordered from Castleman. Id. No other item in the instructional
spreadsheet had a separate volume value. Id. Only the Kawaii Sticker
Tabs, with their value of 2, had a volume value at all. Id. That is, no
product was to be ordered in anything other than a one-to-one quantity—except for the one product that had a different volume number
listed.
The example continued with how to place the items in the online
shopping cart. Once the last item had been added, Castleman’s instructions told O’Connor to “compare what is in your cart[] with the order
… and double check that you have all the things and they are all entered
correctly.” Appx. 1 at CR _. Castleman used the earlier example order,

12

in which the customer had ordered two of each item, to show how a
properly placed order with the supplier would look:

Appx 1 at CR _. The example customer had ordered two of each item;
O’Connor was supposed to fulfill the example order by ordering two of
every item—except for the Kawaii Sticker Tabs, which Castleman’s
spreadsheet indicated had a volume of 2. Id. For those, O’Connor
would properly fulfill the order by ordering from the supplier two times
what the customer had ordered from Castleman: He would, just as Castleman’s written instructions had stated, fulfill the order properly by
ordering four. Id.
13

Castleman also gave O’Connor an actual spreadsheet of the products he sold. CR _. As in the example spreadsheet, one of the values for
each product was “volume.” Id. The numbers for the actual products
varied depending on the product; most were 1 (or blank), but some were
2 or 3. Id. One of the products was Pretty Pastel Washi Tape. (Washi
tape is made of paper; usually colored or decorated; and usually used in
paper crafts, particularly scrapbooking.) The tape had a value of 1—for
every 10-roll package of tape that a customer ordered from Castleman,
O’Connor was supposed to order a single 10-roll package of the tape
from the supplier:

Id.
B. O’Connor doesn’t follow the instructions—and can’t admit it.
In November 2015, Castleman reviewed his web store’s finances for
the previous month and noticed discrepancies between his expected
and actual profits. CR _. Further inquiry revealed that O’Connor was,
14

as he was later to admit, regularly double-ordering every product that a
customer had purchased. Id. The Washi tape, for instance, was Castleman’s best-selling product. Id. The cost of the tape to Castleman was
$1.75—but every time a customer ordered the tape, Castleman paid
$3.50 to fulfill the order because of O’Connor’s double ordering. CR _.
A full review of every one of the more than 2,488 orders that O’Connor had placed showed errors in slightly more than 80% of them. CR _.
Those errors, small individually, were, in the aggregate, large; the review of O’Connor’s orders showed almost $8,000—$7,897.68—in
over-ordered goods. CR _.
Rather than admit his mistake, O’Connor blamed Castleman for the
error. CR _. He pointed to the example of the Kawaii Sticker Tabs in
the instructions, which said that he was to order twice as many tabs
from the supplier as the customer ordered. CR _. He interpreted this to
mean that every item, not just the ones with a volume number of 2, was
to be double-ordered. CR _. He said nothing about the rest of the example, which showed only the tabs being double-ordered. He also justified himself by pointing to a pair of instant messages that one of his representatives had exchanged with Castleman’s assistant. He asserted
that those messages confirmed that every item was to be double-ordered
from the supplier:

15

if anyone is in there rigth now
taking care of an order for Jamie
Jay, please stop. I’m cancelling her
order

For these 2 products: … let us
know how we can process these
since there are no specific colors
ordered.

sorry, we had one fulfilled for Jamie
before the message

For those two, you actually order on
of each of the listing
1 blue, 1 red, 1 pink, etc. etc.

crud…well…I will see if I can kill
it. Thanks for letting me know.

we’ll not double them?
no, just one of each

CR _, _. In neither conversation did the employee mention a belief that
all products were to be double ordered. Nor did Castleman’s assistant
in either conversation instruct that all products—indeed, any products—should be double ordered.
Further communications with O’Connor resulted only in his declaring that he considered the matter to be closed. CR _.
C. Castleman reviews O’Connor’s work.
Out several thousand dollars with no amicable resolution in sight,
Castleman took to the court of public opinion. He wrote a 33-paragraph
review, “Warning: Stay Away From The Offiline Assistant Company
& Kevin O’Connor.” Appx. 2. He posted the review on his website and
on his Facebook page. Id.; CR _. He also uploaded a video to YouTube
and uploaded a podcast to his website, both of which paraphrased the
written review. CR _.
16

Castleman opened the review by recounting how he had come across
O’Connor’s error and the extent of that error:
On November 18th, 2015 during a routine review of our
books, our accountant noticed a $7,897.68 error caused
by Kevin O’Connor’s Offline Assistant Company.
We hired Kevin and his company to fulfill our physical
product store orders and it turns out that they had been
double ordering and shipping our most popular item to
customers at our expense for no understandable reason.
Once the error was discovered, I immediately had the
last 100 orders they had placed for us reviewed, and
there was an 85% error rate in those orders so we started
to dig deeper.
We pulled our financial records from the store, the supplier, and matched them to our credit card statements
for them to get a full accounting of just how bad it was.
When all was said in done, Kevin’s employees had over
ordered and shipped products to the tune of a
$14,968.45 – almost DOUBLE what the orders should
have cost and costing us $7,897.68 in profit.
Appx. 2 at CR _. He summarized their correspondence about the errors, noting that O’Connor’s position was that he was following the example from Castleman’s instructions. Appx. 2 at CR _.
Castleman described the then-current situation as he saw it:

17

– Kevin’s company over ordered and shipped an additional $7,897.68 worth of products to my customers
which I now have to pay out of my own pocket
– No one from his company (that we hired to manage
this for us) reviewed any of the orders to ensure they
were being done correctly despite his assurances they
do quality control and project management on all jobs.
– There was an 85% error rate by his staff in ordering
products for us
– When presented with facts (credit card statements,
Shopify print outs, and AliExpress orders) Kevin still
refused to accept any responsibility and to this day has
refused to pay me back for his company and employee’s
mistakes.
Appx. 2 at CR _. The next several paragraphs recounted Castleman’s
personal interactions with O’Connor; his earlier promotion of O’Connor’s business; and his telling “several business associates,” who later
signed up with O’Connor themselves, about O’Connor’s services.
Appx. 2 at CR _.
This led Castleman to the reasons for his review:
I’m writing this post to warn others and share my personal experience with Kevin O’Connor and his company.
If you choose to use him after seeing that he doesn’t
stand behind his employees work, has zero quality control or checks to ensure work is being done correctly,
18

and no matter how much proof you have of their mistakes, he will never admit when his team has made a
mistake or compensate you in any fashion for those mistakes – go ahead.
If you want to host a webinar, podcast, or invite him to
speak on stage after reading this, that’s your choice and
speaks more to your core values than mine.
I just refuse to have people who have helped him in the
past have their name associated with him or his company without knowing the facts about what he did to our
[e-commerce] business and his unwillingness to stand
behind his word and his employees mistakes.
Appx. 2 at CR _.
The review Castleman posted on Facebook garnered 99 likes and
more than two dozen comments. CR _. The same day that he posted
his review, he also posted a link to the review on his podcast’s Facebook
page. CR _. That post garnered at least 21 more likes and several more
comments. Id.
A little more than a week later, Castleman posted to his podcast’s
Facebook page a link to a domain-name seller showing that O’Connor
had purchased several new domain names. Appx. 3. (One can infer
from the comments to that post that O’Connor was buying several different top-level domains—the codes like .net, .org, .info, and the like—
so that no one could put up a critical website using his own company’s

19

trade name, TheOfflineAssistant.com.) That evening, someone commented on that link, “This is the same guy that practically stole from
you right? The fulfillment guy?” Appx. 3 at CR _. Castleman responded, “Yep same guy.” Id.
D. O’Connor sues.
O’Connor doubled down on his blame shifting after Castleman sent
a demand letter for reimbursement of the over-ordered amounts. CR _.
In his counter-demand letter, he claimed that Castleman had “specifically and unambiguously directed” him to “double all orders.” CR _.
When Castleman refused to take down his reviews, O’Connor sued for
defamation. CR _.
O’Connor put forth a panoply of statements he claimed were defamatory. CR _. The trial court’s findings of fact narrowed these to just six:
• That “there was an 85% error rate” in the orders O’Connor
fulfilled;
• That “[n]o one from [O’Connor’s] company reviewed any of
the orders to ensure they were being done correctly;”
• That O’Connor employed “zero quality control or checks to
ensure work is being done correctly;”
• That O’Connor was “unwilling[] to stand behind his word;”
• Replying “Yep same guy” when asked whether O’Connor
“practically stole” from him; and

20

• That O’Connor is “someone that doesn’t stand behind [his]
work, [his] team does not quality checks or assurances, and if
there’s ever a problem, [he’s] not going to fix it for you, especially when it comes to financial.”
Appx. 5 at 2SCR 5.
O’Connor introduced no evidence that the statements were false
other than his argument that he was following Castleman’s instructions. CR _. No affidavit swore that Castleman or his agent had told
him to double-order every item. No affidavit described any quality-control or review processes. No evidence contradicted the calculated error
rates. No argument posited, or evidence supported, that Castleman was
faking his displeasure with O’Connor’s work. O’Connor’s sole argument was that his interpretation of the instructions was right—and that
the two IM exchanges with Castleman’s confirmed this—so Castleman’s statements that O’Connor had violated the instructions were
necessarily false. CR _.
O’Connor put forth two legal challenges to the motion. He asserted
that it was untimely, but the trial court had granted Castleman relief
from a technical failure and deemed the motion timely. CR _. And he
asserted that the commercial-speech exception to the Act applied because Castleman was in the business of selling goods. CR _.
The trial court denied the motion to dismiss. Appx. 4. It issued findings of fact and conclusions of law that Castleman hadn’t shown that
the suit concerned his right to free speech; that there was a prima-facie
21

case that the six statements were false and susceptible of defamatory
meaning; that Castleman hadn’t proven that the statements were true;
and that the commercial-speech exception to the Act applied. Appx. 5
at 2SCL 4–7.
Castleman now appeals. Appx. 6.

Summary of Argument
The trial court erred in denying the motion to dismiss. O’Connor’s
lawsuit is based on Castleman’s exercise of his freedom to speak, so
Castleman is entitled to dismissal unless O’Connor could produce evidence to support each element of his claim for defamation. He couldn’t.
His sole argument was that Castleman’s statements are defamatory because he did what he was instructed to do. But the evidence is conclusive that he didn’t—the instructions are unambiguous and, in fact, directly contradict what O’Connor claims they said. Because he has no
evidence that he complied with the instructions, he has no evidence that
Castleman’s statements that he didn’t comply with the instructions are
false. Further, most of Castleman’s statements are protected opinion
that can’t constitute defamation; and all of the statements that can be
construed as facts are, as a matter of law, true or substantially true.
O’Connor’s legal and procedural arguments fail, too. The commercial-speech exemption doesn’t apply her to allow his lawsuit because

22

Castleman’s statements weren’t intended to try to win customers for
himself. His argument that Castleman Consulting wasn’t a party to the
motion to dismiss is wrong, too. He didn’t except in the trial court that
the movants’ identities were unclear, so he can’t complain about it
now—particularly because there is nothing in the record showing that
such a complaint was ever considered and all of the evidence that is in
the record supports the opposite conclusion.
Finally, Castleman established his legal fees—an award of which is
mandatory when a party prevails on a motion to dismiss under the
Act—as a matter of law.
The Court should reverse the trial court’s judgment, render judgment that O’Connor’s suit is dismissed, render judgment that Castleman recover his attorneys’ fees, and sever that judgment from the
rest of the case and remand for a determination of the sanction to be
imposed upon O’Connor.
Standards
1. Proceedings under the Act.
This appeal arises under the Texas Citizens Participation Act, which
the Court is to “construe … liberally to effectuate its purpose and intent fully.” Tex. Civ. Prac. & Rem. Code § 27.011(b). That purpose is to “encourage and safeguard” each person’s Constitutional
right to “speak freely … to the maximum extent permitted by law and,
23

at the same time, protect the rights of a person to file meritorious lawsuits for demonstrable injury.” Id. at § 27.002. Under the Act, Castleman is entitled to dismissal if he, as the movant, establishes by a preponderance of the evidence that O’Connor sued him because he exercised one of his protected rights. Id. at § 27.005(b). O’Connor, as the
claimant avoids dismissal only if he brings forth clear and specific evidence of a prima facie case on each essential element of his claim. Id. at
§ 27.005(c). Whether he has done so is a question of law. Rehak Creative
Servs., Inc. v. Witt, 4040 S.W.3d 716, 726–727 (Tex. App. – Houston
[14th Dist.] 2013, pet. denied). Even then, Castleman is still entitled to
dismissal if he establishes by a preponderance of the evidence “each
essential element” of a defense. Tex. Civ. Prac. & Rem. Code
§ 27.005(d).
The Act makes two awards mandatory if a defendant prevails on a
motion to dismiss. First, the defendant must be awarded court costs,
legal fees, and other expenses incurred in defending against the suit.
Tex. Civ. Prac. & Rem. Code § 27.009(a)(1). Second, the court
must impose a sanction upon the plaintiff sufficient to deter it from
bringing similar suits in the future. Id. at § 27.009(a)(2).

24

2. Defamation requires a falsehood.
Defamation first requires a false statement of fact. Bentley v. Bunton,
94 S.W.3d 561, 580 (Tex. 2002). A statement is a fact if it can be objectively verified. Milkovich v. Lorain Journal Co., 497 U.S. 1, 19–22
(1990); Neely v. Wilson, 418 S.W.3d 52, 62 (Tex. 2013). Whether a statement is an assertion of fact or an assertion of opinion depends on the
entire context surrounding the statement; unless a reasonable reader
could believe that a statement was both false and factual, it is protected.
Bentley, 94 S.W.3d at 580–81; New Times, Inc. v. Isaacks, 146 S.W.3d
144, 154 (Tex. 2004); Hancock v. Variyam, 400 S.W.3d 59, 66 (Tex.
2013). Hyperbole—exaggeration for effect—doesn’t qualify as a false
fact. Bentley, 94 S.W.3d at 578; Milkovich, 497 U.S. at 20; see also New
Times, 146 S.W.3d at 167. The objective-verification and reasonablereader analyses are both questions of law. Bentley, 94 S.W.3d at 580–81.
3. Truth is a defense.
A statement isn’t defamatory if it’s true. See Neely, 418 S.W.3d at
57. In defamation cases, “true” is a term of art. A statement is true for
defamation purposes if it is “substantially true,” that is, if the gist of
the complete statement is correct. If the gist and “sting” of the statement—that is, the hit to the plaintiff’s reputation—aren’t substantially
worse than the “sting” of the literal truth, then the statement is substantially true and not actionable. McIlvain v. Jacobs, 794 S.W.2d 14, 15–

25

16 (Tex. 1990). This test applies to private-figure plaintiffs like O’Connor. Gustafson v. City of Austin, 110 S.W.3d 652, 656 (Tex. App. – Austin 2003, pet. denied) (applying test to private figure).
Argument:
O’Connor didn’t meet his burden to furnish prima facie
evidence of defamation because Castleman’s statements are
protected speech. The trial court erred in denying the motion to
dismiss.
A. This case is based on Castleman’s exercise of his freedom to
speak.
There is no question that O’Connor sued Castleman because Castleman exercised his right to speak. See Tex. Civ. Prac. & Rem.
Code § 27.001(1), (3). The pleadings and evidence are conclusive.
O’Connor cannot be suing for defamation unless Castleman said something; the only question is whether Castleman’s speech was “on a matter of public concern.” The Act defines “public concern” to include
“an issue related to … a good, product, or service in the marketplace.”
Tex. Civ. Prac. & Rem. Code § 27.001(7)(E). Castleman’s
statements were about the services that he received from O’Connor,
which O’Connor was continuing to offer in the marketplace. Castleman
noted in his review that he was posting the review specifically because
O’Connor continued to offer those services in the marketplace—and
others had hired O’Connor because of him. Appx. 2 at CR _. Indeed,

26

O’Connor’s entire complaint is that Castleman’s statements about his
business reduced the amount of business he was doing. CR _.
The evidence and pleadings are conclusive: This case is based on
Castleman’s right to free speech.
B. O’Connor’s attempt to establish a prima facie case failed.
O’Connor tripped over the first hurdle he had to overcome to avoid
dismissal: He needed to introduce clear and specific evidence showing
a prima facie case of each element of his claim, but he failed. He offered
no evidence that Castleman’s statements were false. In some cases he
couldn’t have, because Castleman stated not facts, but opinions. Castleman was entitled to dismissal.
1. There is no evidence that the factual statements were false.
a. The instructions are unambiguous, and they unambiguously contradict O’Connor.
The sole basis on which O’Connor claims falsehood is that he was
actually instructed to double-order every item. CR _. But there is no
evidence that he did so. The instructions from Castleman say nothing
about double-ordering every item. On the contrary: They go to great
lengths to demonstrate the difference between items that should be
double ordered and those that should not. Appx. 1 at CR _.The example
that runs through the instructions posits an order for two units apiece
of Kawaii Sticker Tabs, listed with a volume of 2, and three other items.

27

Appx. 1 at CR _. One step in the instructions is to compare the customer’s order with the order to the supplier to make sure that the correct quantities are entered. That step shows O’Connor ordering two
units of everything—except for the Sticker Tabs, of which he is ordering four. Appx. 1 at CR _.
O’Connor offered no evidence that he was told to disregard the instructions or to vary from the example. He in fact claims that the instructions were explicit that he double order everything—the same instructions that include an example order showing some items being
double ordered and some items ordered normally. CR _. His only other
proffer is two instant-message exchanges. CR _. But those are no evidence, either. One message concerns the way that orders for a particular
product are to be filled; the other concerns an attempt to cancel a customer’s order. CR _, _. Neither mentions double ordering, much less
that O’Connor is supposed to double everything.
The instructions were unambiguous and can be construed as a matter of law. See Kachina Pipeline Co. v. Lillis, 471 S.W.3d 445, 449–450
(Tex. 2015). Even if they were ambiguous, there is no plausible argument that they say what O’Connor claims—the instructions themselves go to great length to contradict it. They cannot support O’Connor’s claim that Castleman’s statements about O’Connor’s performance were false.

28

b. O’Connor introduced no evidence of falsity.
O’Connor introduced no evidence that Castleman’s statements are
false. Assuming that they are statements of fact, there must be evidence
that they are untrue for O’Connor to establish a prima facie case of defamation. There is none.
There was no testimony, pleading, or other evidence describing any
quality-control or review processes. There was no evidence to contradict Castleman’s initial calculation of an 85% error rate. There was no
evidence or argument that Castleman was faking his displeasure with
O’Connor’s work. And there is no evidence that O’Connor fixed the
problem he caused Castleman—unsurprising, given that O’Connor’s
position is that he did everything right.
O’Connor needed only to show a prima facie case of falsity. He
chose to show nothing.
2. Opinions can’t be false.
a. Pure opinions.
Several of Castleman’s statements can’t be defamatory because they
can’t be false because they’re opinions. Statements that O’Connor
isn’t willing to stand behind his word or to fix problems are pure opinion. See Neely, 418 S.W.3d at 62. Assuming first of all that we could
come to an objective definition of “word” in this context—a formal
promise? a written agreement? any oral statement of intent? an oral

29

acknowledgement of someone else’s interpretation of his obligations?—there is no objective, verifiable test for when O’Connor has
stood behind it. See Appx. 2 at CR _. Does he stand behind his word
when he does whatever the client requests? Does he do so when he performs what he believes his obligations to be under an agreement? Does
he do so by performing even when agreements (or understandings) are
oral rather than written? And in the same vein, how would he fix problems? See Appx. 2 at CR _. What constitutes a problem for him versus
a problem for his client? Is he supposed to fix the latter even if it’s not
covered by a contract? Is he supposed to “fix” a problem to the extent
that a reasonable person would think a breach of contract cured, or does
he “fix” a problem by ensuring that his client, even if unreasonable, is
happy?
The only thing that is sure from the statement is that Castleman is
unhappy with O’Connor’s work. And “I’m unhappy with your work”
is a pure expression of opinion.
b. Contextual opinions.
Castleman’s statements must be analyzed through the eyes of a typical reader of his blog or Facebook feed or listener to his podcast. New
Times, 146 S.W.3d at 160–161; Old Dominion Branch No. 496, Natl.
Assn. of Letter Carriers v. Austin, 418 U.S. 264, 284–286 (1974). Cf.
Bentley, 94 S.W.3d at 584–585. In context, that analysis shows that some

30

of the statements that O’Connor derides as false facts are, in fact, opinions.
In the context of his review, as read by a regular visitor to his blog or
Facebook page, Castleman’s statements that O’Connor performed no
quality control and reviewed none of the orders are expressions of frustration. The statements come in the middle of a 33-paragraph review
that spent the last several paragraphs describing the errors committed
in ordering; the work needed to uncover and quantify those errors; the
communications to attempt to cure those errors; and the refusal to reimburse for the cost the errors imposed. Appx. 2 at CR _.They demonstrate his dissatisfaction with a contractor who erred in 80% of the tasks
that were assigned to him. No reasonable reader of Castleman’s entire
review—a person who sought out Castleman’s blog, YouTube channel,
podcast, or Facebook page—would conclude that these statements
were anything other than “rhetorical hyperbole, a lusty and imaginative
expression of the contempt felt by” Castleman toward someone who
hadn’t performed as he had promised. Letter Carriers, 418 U.S. at 286.
In the same vein, Castleman’s statement, “Yup same guy,” when
asked whether O’Connor was the same person who had “practically
stole[n]” from him is simply hyperbole. Appx. 3 at CR _. The statement
was posted as a response to a Facebook comment, but that simply looks
at the statement in isolation. It is that whole context, which includes

31

“the immediate context of the disputed statements,…the type of publication, the genre of writing, and the publication’s history,” that determines how the statement “would be understood by the readers to whom
it was addressed” and thus whether it could be defamatory. Farah v.
Esquire Magazine, 736 F.3d 528, 535 (D.C. Cir. 2013) (internal citations
and quotations omitted).
Looking at the full context here, Castleman’s “Yup same guy” must
be read through the eyes of a person who had gone to the Facebook page
for Castleman’s podcast; read the link (about O’Connor’s buying up of
domain names) that accompanied the post; and understood from the
link, the earlier comments, and Castleman’s review—without which
neither the link nor the comments can be understood—that the comment referred to O’Connor. And no reasonable reader armed with that
knowledge would believe that Castleman was either accusing O’Connor
of thievery or agreeing with such an accusation. It would be clear to that
reader that the comment was referring to the several thousands of dollars that O’Connor had cost Castleman and hadn’t reimbursed to him.
And this would have been the case even if Castleman had simply
come out and stated, “O’Connor practically stole from me.” There is
no innuendo or suggestion of actual criminality; in context, it’s clear
that Castleman would be referring to the money that O’Connor cost
him. Directed verdicts on similar statements have been upheld: “The
words ‘liar’ and ‘crook’ were abusive and opprobrious, but they did not
32

impute the commission of a crime….” Billington v. Houston Fire & Cas.
Ins. Co., 226 S.W.2d 494, 497 (Tex. Civ. App. – Fort Worth 1950, no
writ); see also Moore v. Waldrop, 166 S.W.3d 380, 386 (Tex. App. – Waco
2005, no pet.); Arant v. Jaffe, 436 S.W.2d 169, 176–177 (Tex. Civ. App.
– Dallas 1968, no writ). Indeed, direct statements accusing people of
much worse have been found to be protected opinion as a matter of law.
See, e.g., Greenbelt Coop. Publg. Assn. v. Bresler, 398 U.S. 6, 13–14 (1970)
(plaintiff committed “blackmail”); Hogan v. Winder, 762 F.3d 1096,
1109–1110 (10th Cir. 2014) (plaintiff’s actions “go by the names of
‘blackmail’ and ‘extortion’”); Wood v. Del Giorno, 974 So. 2d 95, 97
(La. App. 2007) (plaintiff was “complete fraud” and “out-and-out lying”); Franklin v. Dynamic Details, Inc., 10 Cal. Rptr. 3d 429, 437 (Cal.
App. 2004) (plaintiff “stole copyrighted materials” and “plagiarized
… data”).
C. Castleman’s statements were true.
Even if O’Connor had cleared his hurdle, his case would still have
to be dismissed because Castleman has established as a matter of law
that the factual statements are true.
The pleadings and the evidence—all of the relevant evidence, given
that O’Connor introduced none—support the finding that Castleman’s
statements, to the extent they are factual, are true. Castleman testified
in his affidavit to the same thing he wrote in his review: His review of a

33

sample of O’Connor’s orders showed an 85% error rate, and a full review showed an error rate of approximately 80%. CR _. Castleman said
that there was no quality control or review; O’Connor got only 20% of
the orders right and described no reviews or procedures. CR _. Castleman said that O’Connor didn’t stand behind his word; O’Connor
wouldn’t reimburse the extra costs that he imposed. CR _.
There is no evidence to contradict any of this. There are no pleadings that can be read to contest it. O’Connor’s only argument is that he
read the instructions right. CR _. He didn’t. Argument § B.1.a. There
is no evidence—much less legally sufficient evidence—of falsity. All of
the evidence supports the finding that Castleman’s statements are true.
And all of that evidence is clear, positive, direct, and free from anything
that would tend to cast suspicion on its truth. Ragsdale v. Progressive Voters League, 801 S.W.2d 880, 882 (Tex. 1990). The truth of the statements is thus established as a matter of law. Id.
And even if O’Connor had shown a smidgen of quality control or
order review, so what? Quality control measures that result in an 80%
error rate might as well be no measures at all; whatever review was being employed didn’t catch that O’Connor’s interpretation of the instructions directly contradicted the example given in the instructions.
The “sting” of the truth—O’Connor employed quality-control
measures that resulted in a 20% success rate; O’Connor’s review of the
orders didn’t catch that he was directly contradicting the instructions
34

he was given—is no worse than what Castleman said. McIlvain, 794
S.W.2d at 15–16. Defamation law polices outright falsehoods; the
cranny between Castleman’s statements and the Platonic truth doesn’t
have to be calibrated to the same tolerances as the gaps between heatshield tiles on a space shuttle. See Neely, 418 S.W.3d at 76, citing Masson
v. New Yorker Magazine, 501 U.S. 496, 516 (1991). The gist of the statements doesn’t misrepresent O’Connor’s performance; the sting of the
statements is no worse than if Castleman had told the truth about whatever procedures O’Connor might claim he used. The statements are
thus substantially true and not defamatory.
D. The commercial-speech exception in the Act doesn’t swallow
the rule that Castleman’s speech protected.
The commercial-speech exception to the Act prevents a defendant
whose primary business is “selling … goods or services” from moving
to dismiss based on statements arising from “the sale or lease of goods
[or] services … in which the intended audience is an actual or potential
buyer or customer.” Tex. Civ. Prac. & Rem. Code § 27.010(b).
Castleman’s primary business is selling goods and services; his statements were made to potential customers of O’Connor’s services; thus,
the argument goes, the Act doesn’t protect Castleman’s review of
O’Connor’s bad performance.
Nonsense. The commercial-speech exception denies the Act’s protection to misstatements about the products or services of a company
35

or its competitors in an attempt to win business for the speaker. Newspaper Holdings, Inc. v. Crazy Hotel Assisted Living, Ltd., 416 S.W.3d 71,
88–89 (Tex. App. – Houston [1st Dist.] 2013, pet. denied). This is both
the logical reading of the statute and the necessary one. Were O’Connor right, the commercial-speech exception would swallow the Act’s
application to speech about services offered in the marketplace. Tex.
Civ. Prac. & Rem. Code § 27.001(7)(E); Newspaper Holdings, 416
S.W.3d at 89. A private school whose principal wrote a negative review
of a lazy janitorial contractor would be excluded from the Act’s protection simply because both entities sell “services.”
It is no surprise that every appellate court in Texas that has considered O’Connor’s argument has rejected it. 1 Indeed, the First Court of
Appeals has refused to apply the commercial-speech exception in an

1

Newspaper Holdings, 416 S.W.3d at 88–89; Whisenhunt v. Lippincott, 474 S.W.3d
30, 42–43 (Tex. App. – Texarkana 2015, no pet.); Backes v. Misko, 486 S.W.3d
7, 21 (Tex. App. – Dallas 2015, pet. denied); Hicks v. Group & Pension Adminrs.,
Inc., 473 S.W.3d 518, 531 (Tex. App. – Corpus Christi 2015, no pet.); Schimmel
v. McGregor, 438 S.W.3d 847, 857–58 (Tex. App. – Houston [1st Dist.] 2014,
pet. denied); Kinney v. BCG Atty. Search, Inc., No. 03-12-00579-CV, 2014 WL
1432012, *6–7 (Tex. App. – Austin April 11, 2014, pet. denied). Cf. NCDR,
L.L.C. v. Mauze & Bagby, P.L.L.C., 745 F.3d 742, 753–755 (5th Cir. 2014) (applying exemption because advertisements were targeted at speaker’s potential
customers); Miller Weisbrod, L.L.P. v. Llamas-Soforo, No. 08-12-00278-CV, __
S.W.3d __, 2014 WL 6679122 (Tex. App. – El Paso Nov. 25, 2014, no pet.)
(same); Lamons Gasket Co. v. Flexitallic L.P., 9 F. Supp. 3d 709, 711–712 (S.D.
Tex. 2014) (same).

36

analogous case. In Hicks v. Group & Pension Administrators, the plaintiffs
alleged that a lawyer’s statements to the City of Galveston caused the
city to back out of its contracts with them. 438 S.W.3d at 857. The Court
refused to apply the exception because while the lawyer was in the business of selling legal services, he didn’t make the statements to try to get
the city to hire him. Id. at 857–858. The lawyer made the statements in
the course of representing clients of his own; the city wasn’t a “‘potential buyer or customer’” of his services. Id. at 858. Similarly, O’Connor’s claim is that Castleman’s statements cost him business—and, as
with the statements in Hicks, Castleman wasn’t making the statements
to an audience of potential customers in an effort to win their business.
It was O’Connor’s burden to show that Castleman’s statements
were made to win business for Castleman himself. He introduced no
evidence to meet that burden. The commercial speech exception does
not apply.
E. Both defendants moved to dismiss—which O’Connor’s
response to the motion recognized.
The trial court found that Castleman Consulting hadn’t moved to
dismiss the case. That finding is supported by no evidence, is directly
contradicted by the motion itself, and was preemptively repudiated by
O’Connor himself.

37

The motion to dismiss stated in its introduction and its prayer that
the trial court should dismiss not the claims against Tim Castleman individually, but the suit in its entirety. CR _, _. The first paragraph in
the “Facts” section states that the term “Castleman” includes both
Tim Castleman and Castleman Consulting, just as it noted that
“O’Connor” included Kevin O’Connor and his company. CR _.
O’Connor himself construed the motion as being made by both defendants: He describes the motion as containing claims by “Defendants”
about “their” statements, of which “Defendants” list only some, and
he accuses “Defendants” of ignoring both some statements and his accusation that “Defendants’ … goal” was to injure him. CR _. And in
closing, O’Connor asked the trial court to deny “Defendants’ Motion
to Dismiss[.]” CR _.
If O’Connor was confused about the provenance of the motion he
should have excepted to it. Tex. R. Civ. P. 91. He wasn’t confused
over it, so he didn’t. All of the evidence, including the motion itself and
O’Connor’s reaction to it, indicates that the motion was brought on behalf of Tim Castleman and Castleman Consulting—and that O’Connor
knew it. The conclusion that only Tim Castleman brought the motion
is supported by no evidence; all of the evidence supports the conclusion
that both defendants brought the motion.

38

F. Castleman has proved his legal fees as a matter of law.
As with Castleman’s evidence of truth, his evidence of legal fees establishes his entitlement to those fees as a matter of law. Though he had
the ability to do so, O’Connor declined to challenge the affidavits attesting to the amount, reasonableness, and necessity of Castleman’s
fees. CR _. That evidence was “uncontradicted, unimpeached, internally consistent, and readily subject to disproof.” Beaver Cnty., Okla.,
Bd. of Commrs. v. Amarillo Hosp. Dist., 835 S.W.2d 115, 128 (Tex. App.
– Amarillo 1992, no writ). Nor are their circumstances suggesting that
the fees are “incredible or unreasonable.” Id. The Court should adjudge that Castleman recover from O’Connor $10,371.40 in trial-court
fees and $10,000 in appellate-court expenses.
Conclusion and Prayer
The Appellants pray that the Court reverse the trial court’s judgment, render judgment dismissing O’Connor’s suit, render judgment
for the Appellants for $20,371.40 in legal costs, and sever and remand
the issue of the amount of mandatory sanctions for consideration by the
trial court.
Respectfully submitted,
The Olson Firm, PLLC
/s/ Leif A. Olson
Leif A. Olson
State Bar No. 24032801
leif@olsonappeals.com
39

PMB 188
4830 Wilson Road, Suite 300
Humble, Texas 77396
Counsel for appellants

Certificate of Compliance
I certify that this Castleman’s Opening Brief was prepared with Microsoft Word 2013, and that, according to that program’s word-count
function, the sections covered by Texas Rule of Appellate Procedure
9.4(i)(1) contain 6,286 words.
/s/ Leif A. Olson
Certificate of Service
I certify that on October 11, 2016, in accordance with Texas Rule of
Appellate Procedure 9.5(b), I served a copy of this Castleman’s Opening
Brief and its Appendix by e-filing upon:
J. Paul Manning
jpmanning@lubbocklawfirm.com
Anna McKim
amckim@lubbocklawfirm.com
Field, Manning, Stone,
Hawthorne & Aycock, P.C.
2112 Indiana Avenue
Lubbock, Texas 79410
(806) 792-0810
Counsel for appellees
/s/ Leif A. Olson

40

No. 07-16-00320-CV

Seventh Court of Appeals
at Amarillo
Timothy Castleman and
Castleman Consulting, LLC,
Appellants,
v.
Internet Money Limited and
Kevin O’Connor,
Appellees.

On Appeal from the 237th District Court
of Lubbock County
Trial Court No. 2016-519,740
Castleman’s Appendix

Oral argument requested

Leif A. Olson
State Bar No. 24032801
leif@olsonappeals.com
The Olson Firm, PLLC
PMB 188
4830 Wilson Road, Suite 300
Humble, Texas 77396
(281) 849-8382
Counsel for Appellants

Appendix Contents
Tab

Contents

1

Ordering instructions

2

Castleman’s review

3

Facebook post

4

Order denying motion to dismiss

5

Findings of fact and conclusions of law

6

Notice of appeal

7

Texas Citizens Participation Act

Tab 1:
Ordering instructions

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Exhibit B - Page 7

Payment

�---------------;
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Une Lee

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113 Pickering dr.

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number field. In Shopify it shows the state abbreviation but
AliExpress re quires the full state name, you can find that by looking
for the abbreviations here http://www.stateabbreviations.us/

Exhibit B - Page 8

� O�CJf'IS ! #1012

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Exhibit B - Page 9

Payment

1. Please fill in your shipping address. Don't forget to save!

Contact l\iame:

Country/Region:

Street Address�

Clty;

Srate/Provlnce/Region:

Zip/Postal Code:

Karen P Stephens
United States
3947 Highway H

Salem
Missouri
65560

lei:
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Mobile:

573-L53-4222

·

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1

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Exhibit B - Page 10

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Exhibit B - Page 11

Card Expiration Date Verification

In order to ensure your account security, you will need to provide some information before continuing.
Please enter your card expiration date.

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.

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Exhibit B - Page 12

·--- ---- ------------------

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Exhibit B - Page 13

Tab 2:
Castleman’s review

Warning: Stay Away From The Offline Assistant Company & Kevin O’Connor |

THE LIFE AND TIMES OF TIM CASTLEMAN

DECEMBER 4, 2015

Warning: Stay Away From The Ofine
Assisant Company & Kevin O’Connor

On November 18th, 2015 during a routine review of our books, our accountant noticed a
$7,897.68 error caused by Kevin O’Connor’s Offline Assistant Company.

We hired Kevin and his company to fulfill our physical product store orders and it turns out that
they had been double ordering and shipping our most popular item to customers at our
expense for no understandable reason.

Once the error was discovered, I immediately had the last 100 orders they had placed for us
reviewed, and there was an 85% error rate in those orders so we started to dig deeper.

I immediately let Kevin know about this issue personally and told him I would get him a full
report by the following Monday (this was Friday).

We pulled our financial records from the store, the supplier, and matched them to our credit
card statements for them to get a full accounting of just how bad it was.

Exhibit E - Page 1
http://www.timothycastleman.com/warning-stay-away-from-the-offline-assistant-company-kevin-oconnor/[5/6/2016 8:22:59 PM]

Warning: Stay Away From The Offline Assistant Company & Kevin O’Connor |

When all was said in done, Kevin’s employees had over ordered and shipped products to the
tune of a $14,968.45 – almost DOUBLE what the orders should have cost and costing us
$7,897.68 in profit.

Armed with this information I sent everything to Kevin and asked him to review everything and
if the numbers were correct explain why none of the orders were checked by his project
manager (as promised when we signed up) or anyone else on is staff for accuracy, how his
employees could see us losing money on ever order and not say anything, and why they
hadn’t followed the spreadsheet directions we gave them.

When he finally responded 3 days later, he blamed us for not catching the error and cited a
training example order we included in the training materials (of a totally different product than
the one they misordered above) as a reason why they had doubled ordered everything.

Except they hadn’t double ordered every item.

His team managed to order the correct quantities of other items we sold in different amounts
(1, 2, 4 etc) with no problem.

When confronted with this, he went radio silent and refused to respond to any more of my
emails.

It was only after I demanded repayment for the $7,897.68 error that he finally responded, and
only to tell me that he considered the matter closed on his part and that he and his employees
had done nothing wrong and that he wouldn’t be paying for his employee’s mistake.

So here’s where we stand

– Kevin’s company over ordered and shipped an additional $7,897.68 worth of products to my
customers which I now have to pay out of my own pocket

– No one from his company (that we hired to manage this for us) reviewed any of the orders to

Exhibit E - Page 2
http://www.timothycastleman.com/warning-stay-away-from-the-offline-assistant-company-kevin-oconnor/[5/6/2016 8:22:59 PM]

Warning: Stay Away From The Offline Assistant Company & Kevin O’Connor |

ensure they were being done correctly despite his assurances they do quality control and
project management on all jobs.

– There was an 85% error rate by his staff in ordering products for us

– When presented with facts (credit card statements, Shopify print outs, and AliExpress
orders) Kevin still refused to accept any responsibility and to this day has refused to pay me
back for his company and employee’s mistakes.

The money part stings, but here’s the worst part.

I first met Kevin when I and several others (Brad Gosse, Ron Douglas, E. Brian Rose, Ben
Littlefield, Ben Adkins, Colin Theriot, Mark Helton, Brian Anderson, Ryan McKinney) were his
mentor at the Marketers Mansion.

We all spent time with him trying to help him grow his business.

I personally promoted Kevin not only to my list via a webinar, but also through my podcast
(free of charge), and told several business associates about him (who ended up signing up
with him – right Los).

Just last month I dropped everything when he came into town and showed him around
Lubbock and offered to help him even more with his company.

And this is how he repaid me and everyone else who helped him for doing so.

No apology, no acceptance of the facts, and most of all not a single offer to help us or
compensate us these errors.

I gotta assume that whole personal responsibility thing Garret White preaches didn’t sink in
with Kevin.

Exhibit E - Page 3
http://www.timothycastleman.com/warning-stay-away-from-the-offline-assistant-company-kevin-oconnor/[5/6/2016 8:22:59 PM]

Warning: Stay Away From The Offline Assistant Company & Kevin O’Connor |

Now don’t worry about me. We’ll be seeing Kevin in court and we’ll get every cent (plus some)
back from him.

I’m writing this post to warn others and share my personal experience with Kevin O’Connor
and his company.

If you choose to use him after seeing that he doesn’t stand behind his employees work, has
zero quality control or checks to ensure work is being done correctly, and no matter how
much proof you have of their mistakes, he will never admit when his team has made a
mistake or compensate you in any fashion for those mistakes – go ahead.

If you want to host a webinar, podcast, or invite him to speak on stage after reading this, that’s
your choice and speaks more to your core values than mine.

I just refuse to have people who have helped him in the past have their name associated with
him or his company without knowing the facts about what he did to our eCom business and
his unwillingness to stand behind his word and his employees mistakes.

I’m just thankful that we have the cash reserves to not only absorb this temporary loss and but
also pursue every legal recourse against him.

In closing I’ll share with you one last thought. Sometimes in life things like this happen. People
disappoint you, friendships end, and true colors are revealed. While you can’t control when or
why that stuff happens, you can control your response to those situations.

I tried to resolve this in private, I gave Kevin every opportunity to make this right. It was only
after he refused to do so, and I saw how huge of a disaster this could be for people who don’t
have the same resources I do, that I knew I had to go public with this issue.

Share the joy

Exhibit E - Page 4
http://www.timothycastleman.com/warning-stay-away-from-the-offline-assistant-company-kevin-oconnor/[5/6/2016 8:22:59 PM]

Warning: Stay Away From The Offline Assistant Company & Kevin O’Connor |

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Exhibit E - Page 5
http://www.timothycastleman.com/warning-stay-away-from-the-offline-assistant-company-kevin-oconnor/[5/6/2016 8:22:59 PM]

Tab 3:
Facebook post

Discussion

Members

Events

Photos

Files

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Tab 4:
Order denying motion

Filed 8/11/2016 8:10:38 AM
Barbara Sucsy
District Clerk
Lubbock County, Texas

CAUSE NO. 2016-519,740
INTERNET MONEY LIMITED d1b/a
THE OFFLINE ASSISTANT AND
KEVIN O'CONNOR, INDTVTDUALLY,
Plaintiffs,
v.

!i

§

!i

§

TIMOTHY CASTLEMAN AND
CASTLEMAN CONSULTING, LLC,
Defendants.

IN THE 237TH DISTRICT COURT

OF

!i

§

!i

LUBBOCK COUNTY, TEXAS

ORDER GRANTING DEFENDANTS' MOTION FOR RELIEF FROM
TECHNICAL FAILURE AND FOR EXTENSION OF TIME AND DENYING
DEFENDANTS' l

Related Interests

IOTION To DISMISS

The Court, having considered the Defendants' Motion for Relief from Technical Failure
and for Extension of Time, Defendants' Motion to Dismiss, as well as Plaintifts' Opposition to
Motion to Dismiss and Request for Attorney's Fees, t ogether with supporting evidence and the
arguments made by counsel together with legal authority submitted by counsel, the Cou rt is of
the opinion that the Motion for Relief from Technical Failure and for Extension of Time is
granted and that the Defendants' Motion to Dismiss be denied.

Further, the Court is of the

opinion that the Motion to Dismiss was not frivolous or solely intended to delay and therefore
denies Plaintifts' attorney's fees.
IT lS THEREFORE, ORDERED, ADJUDGED AND DECREED that the Defendants'
Motion for Relief from Technical Failure and for Extension of Time be and the same is hereby
GRANTED.

Order Granting and Denying Motions

Page 1

IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the Defendants'
Motion to Dismiss be and the same is hereby DENIED.

It is further ordered that the Plaintitls'

Request for Attorneys' Fees is DENIED.
All costs of court are taxed against the party incuning same.

All relief not expressly

granted herein is hereby denied.
SIGNED this

10th

day of

August

,

,

_

2016.

JUDGE PRESIDING

Order Granting and Denying Motions

Page 2

Tab 5:
Findings of fact and conclusions of law

Filed 10/4/2016 2:33:54 PM
Barbara Sucsy
District Clerk
Lubbock County, Texas

cf

CAUSE NO. 2016-519,740
INTERNET MONEY LIMITED d/b/a
THE OFFLINE ASSISTANT AND
KEVIN O'CONNOR, INDIVIDUALLY,
Plaintiffs,

v.
TIMOTHY C~a..STLEM~a~ .AND
CASTLEMAN CONSULTING, LLC,
Defendants.

§
§
§
§
§
§
§
§
§
§

IN THE 237TH DISTRICT COURT

OF

LUBBOCK COUNTY, TEXAS

FINDINGS OF FACT AND CONCLUSIONS OF LAW IN RELATION TO DENIAL OF
MOTION TO DISMISS OF DEFENDANT, TIMOTHY CASTLEMAN

The above-captioned motion to dismiss came on before the Court's motion
docket on July 1, 2016. All parties were represented by counsel at the hearing. After
considering the motion to dismiss filed by Defendant Timothy Castleman, the
response, the evidence, the argument and briefs from counsel as well as Defendants'
Motion for Relief from Technical Failure and for Extension of Time, the Court, in
response to a request from Defendant, Castleman, makes the following findings of
fact and conclusions of law. Any finding of fact mislabeled as a conclusion of law
shall be deemed a finding of fact. Any conclusion of law mislabeled as a finding of
fact shall be deemed a conclusion of law.
FINDINGS OF FACT
1.
Defendant, Timothy Castleman, was served with process of Plaintiffs'
original petition on larch 7, 2016. Defendant Castleman filed a late motion to
dismiss under the Texas Citizens Participation Act on May 7, 2016. Defendant
Castleman also filed a Motion for Relief from Technical Failure, or, in the
Alternative, for Extension of Time in order to allow his motion to be timely.

2.
Defendant, Castleman Consulting, LLC, was served with process of
Plaintiffs' original petition on March 9, 2016. Defendant Castleman Consulting,
LLC did not f:tle a motion to dismiss under the Texas Citizens Participation Act nor
did Defendant Castleman Consulting, LLC, file a Motion for Relief from Technical
Failure, or, in the Alternative, for Extension of Time.
3.
Plaintiffs' First . A~ended
.
Petition asserts causes of action for slander
and libel associated with Defendants' Facebook, Twitter, blog, Warrior Forum,
Google Reviews, and podcasts alleging Plaintiffs' failed promises, placement of
liPage Findings of Fact and Conclusions of Law

4

orders with an 80% to 85% error rate, Plaintiffs' inability or unwillingness to follow
instructions, Plaintiffs' stealing from Defendants, and Plaintiffs' terrible services.
4.
The matter was originally set within 60 days of the motion but was
delayed by a request for discovery.
5.
The matter was set for hearing on July 1, 2016, within 90 days after
the service of the motion.
6.
The court considered the pleadings and supporting and opposing
affidavits stating the facts on which the liability and defenses are based. Tex. Civ.
Prac. & Rem. Code § 27.006.
7.
Defendant did not show by a preponderance of the evidence that the
legal action was based on, related to, or was in response to Defendant's exercise of
the right of free speech, the right to petition, or of the right of association.
8.
Plaintiffs provided clear and specific evidence of a prima facie case for
each element of their claims, including the facts of when, where, and what was said,
the defamatory nature of the statements, and how they damaged Plaintiffs.
9.

Defendant failed to show a valid defense to Plaintiffs' claims.

10.

Defendant failed to show truth of at least the following statements:
a. "there was an 85% error rate" in the orders placed.
b. "No one from his company reviewed any of the orders to ensure they
were being done correctly."
c. "zero quality control or checks to ensure work
correctly"

IS

being done

d. "unwillingness to stand behind his word"
e. confirming that Plaintiffs "practically stole" from Defendants

f. Plaintiff was "someone that doesn't stand behind their work, their
team does not quality checks or assurances, and if there's ever a
problem, they're not going to fix it for you, especially when it comes to
financial"
11.
The statements at issue arose out of the sale of goods, and the intended
audience is actual or potential buyers or customers.
21Page Findings of Fact and Conclusions of Law

5

12.
Defendants' statements were made with either the knowledge of their
falsity or, at the very least, with reckless disregard as to their truth or falsity.
Defendants admitted their intent to harm Plaintiffs and acknowledged
13.
the damage their statements were causing Plaintiffs.
The Court does not find the Motion to Dismiss to be frivolous or solely
14.
intended to delay.

CONCLUSIONS OF LAW
1.
Defendant Castleman's motion to dismiss was untimely, but the
Motion for Relief from Technical Failure and for Extension of Time is properly
granted within the discretion of the court.
2.
The motion to dismiss under the Texas Citizens Participation Act is
deemed timely filed. Tex. Civ. Prac. & Rem. Code§ 27.003.
3.
Defendant Castleman Consulting, LLC did not file a motion to dismiss
under the Texas Citizens Participation Act. Tex. Civ. Prac. & Rem. Code§ 27.003.
4.
27.004.

The hearing was timely pursuant to Tex. Civ. Prac. & Rem. Code §

5.
Defendants' acts fall within an exception to the Citizens Participation
Act. Tex. Civ. Prac. & Rem. Code§ 27.101(b).
6.
In the alternative, Defendant failed to show by a preponderance of the
evidence that the legal action is based on, relates to, or is in response to the party's
exercise of the right of free speech, the right to petition, or the right of association.
7.
Plaintiffs established by clear and specific evidence a prima facie case
for each essential element of the claims in question.
8.
Defendant failed to establish by a preponderance of the evidence each
essential element of a valid defense to Plaintiffs' claims.
9.
In determining whether a legal action should be dismissed under this
chapter and at the request of Defendant Castleman, pursuant to Section 27.003,
this Court finds that Plaintiffs' legal actions were not brought to deter or prevent
the Defendants from exercising constitutionai rights and were not brought for an

3IPage Findings of Fact and Conclusions of Law

6

improper purpose, including to h arass or to cause unnecessary delay or to increase
the cost of litigation. Tex. Civ. Prac. & Rem. Code§ 27.007.
10.

Plaintiffs' objections at the hearing on July 1, 2016 are overruled.

11.

Defenda nt Castleman's Motion to Dismiss is denied.

12.

The Motion to Dismiss was not frivolous or solely intended to delay.

13.

No attorneys' fe es were awarded.

14.

All costs incurred shall be borne by the party incurring same.

:m
SIGNED this ---+~

____

day of October, 2016.£

/~

JUDGE PRESIDING

41 Page

Findin gs of Fact and Conclu s i on s of L aw

7

Tab 6:
Notice of appeal

Filed 8/22/2016 8:03:26 PM
Barbara Sucsy
District Clerk
Lubbock County, Texas

Case 2016-519,740
Internet Money Limited and
Kevin O’Connor,
Plaintiffs,
v.
Timothy Castleman and
Castleman Consulting LLC,
Defendants.

cf

237th District Court
Lubbock County

Defendants’ Notice of Appeal
The defendants’ Motion to Dismiss Under the Texas Citizens Participation Act was denied by operation of law on August 1, 2016. The Court
memorialized that dismissal in an order signed on August 10. Defendants
Timothy Castleman and Castleman Consulting, LLC, appeal that order to
the Seventh Court of Appeals. This is an accelerated appeal.
Respectfully submitted,
The Law Office of Jared
B. Hall, PLLC
Jared B. Hall
State Bar No. 24055615
JHallAttorney@gmail.com
P.O. Box 6982
Lubbock, Texas 79493
(806) 853-7182
The Olson Firm, PLLC
/s/ Leif A. Olson
Leif A. Olson
State Bar No. 24032801
leif@olsonappeals.com
PMB 188
4830 Wilson Road, Suite 300
Humble, Texas 77396
(281) 849-8382
Counsel for Defendants
Certificate of Service
I certify that on August 19, 2016, I served a copy of this notice of appeal
upon J. Paul Manning, counsel for the plaintiffs, by electronic filing.
/s/ Leif A. Olson

Tab 7:
Texas Citizens Participation Act

Chapter 27. Actions involving the exercise of certain
constitutional rights
Sec. 27.001. Definitions. In this chapter:
(1) “Communication” includes the making or submitting of a
statement or document in any form or medium, including oral,
visual, written, audiovisual, or electronic.
(2) “Exercise of the right of association” means a communication
between individuals who join together to collectively express,
promote, pursue, or defend common interests.
(3) “Exercise of the right of free speech” means a communication
made in connection with a matter of public concern.
(4) “Exercise of the right to petition” means any of the following:
(A) a communication in or pertaining to:
(i) a judicial proceeding;
(ii) an official proceeding, other than a judicial proceeding,
to administer the law;
(iii) an executive or other proceeding before a department of
the state or federal government or a subdivision of the
state or federal government;
(iv) a legislative proceeding, including a proceeding of a
legislative committee;
(v) a proceeding before an entity that requires by rule that
public notice be given before proceedings of that entity;
(vi) a proceeding in or before a managing board of an
educational or eleemosynary institution supported
directly or indirectly from public revenue;
(vii) a proceeding of the governing body of any political
subdivision of this state;

(viii) a report of or debate and statements made in a
proceeding described by Subparagraph (iii), (iv), (v), (vi),
or (vii); or
(ix) a public meeting dealing with a public purpose,
including statements and discussions at the meeting or
other matters of public concern occurring at the meeting;
(B) a communication in connection with an issue under
consideration or review by a legislative, executive, judicial, or
other governmental body or in another governmental or
official proceeding;
(C) a communication that is reasonably likely to encourage
consideration or review of an issue by a legislative, executive,
judicial, or other governmental body or in another
governmental or official proceeding;
(D) a communication reasonably likely to enlist public
participation in an effort to effect consideration of an issue
by a legislative, executive, judicial, or other governmental
body or in another governmental or official proceeding; and
(E) any other communication that falls within the protection of
the right to petition government under the Constitution of
the United States or the constitution of this state.
(5) “Governmental proceeding” means a proceeding, other than a
judicial proceeding, by an officer, official, or body of this state or
a political subdivision of this state, including a board or
commission, or by an officer, official, or body of the federal
government.
(6) “Legal action” means a lawsuit, cause of action, petition,
complaint, cross-claim, or counterclaim or any other judicial
pleading or filing that requests legal or equitable relief.
(7) “Matter of public concern” includes an issue related to:

(i) health or safety;
(ii) environmental, economic, or community well-being;
(iii) the government;
(iv) a public official or public figure; or
(v) a good, product, or service in the marketplace.
(8) “Official proceeding” means any type of administrative,
executive, legislative, or judicial proceeding that may be
conducted before a public servant.
(9) “Public servant” means a person elected, selected, appointed,
employed, or otherwise designated as one of the following, even
if the person has not yet qualified for office or assumed the
person’s duties:
(A) an officer, employee, or agent of government;
(B) a juror;
(C) an arbitrator, referee, or other person who is authorized by
law or private written agreement to hear or determine a
cause or controversy;
(D) an attorney or notary public when participating in the
performance of a governmental function; or
(E) a person who is performing a governmental function under a
claim of right but is not legally qualified to do so.
Sec. 27.002. Purpose. The purpose of this chapter is to encourage
and safeguard the constitutional rights of persons to petition, speak
freely, associate freely, and otherwise participate in government to the
maximum extent permitted by law and, at the same time, protect the
rights of a person to file meritorious lawsuits for demonstrable injury.

Sec. 27.003. Motion to dismiss.
(a) If a legal action is based on, relates to, or is in response to a party’s
exercise of the right of free speech, right to petition, or right of
association, that party may file a motion to dismiss the legal action.
(b) A motion to dismiss a legal action under this section must be filed
not later than the 60th day after the date of service of the legal
action. The court may extend the time to file a motion under this
section on a showing of good cause.
(c) Except as provided by Section 27.006(b), on the filing of a motion
under this section, all discovery in the legal action is suspended
until the court has ruled on the motion to dismiss.
Sec. 27.004. Hearing.
(a) A hearing on a motion under Section 27.003 must be set not later
than the 60th day after the date of service of the motion unless the
docket conditions of the court require a later hearing, upon a
showing of good cause, or by agreement of the parties, but in no
event shall the hearing occur more than 90 days after service of the
motion under Section 27.003, except as provided by Subsection (c).
(b) In the event that the court cannot hold a hearing in the time
required by Subsection (a), the court may take judicial notice that
the court’s docket conditions required a hearing at a later date, but
in no event shall the hearing occur more than 90 days after service
of the motion under Section 27.003, except as provided by
Subsection (c).
(c) If the court allows discovery under Section 27.006(b), the court
may extend the hearing date to allow discovery under that
subsection, but in no event shall the hearing occur more than 120
days after the service of the motion under Section 27.003.

Sec. 27.005. Ruling.
(a) The court must rule on a motion under Section 27.003 not later
than the 30th day following the date of the hearing on the motion.
(b) Except as provided by Subsection (c), on the motion of a party
under Section 27.003, a court shall dismiss a legal action against
the moving party if the moving party shows by a preponderance of
the evidence that the legal action is based on, relates to, or is in
response to the party’s exercise of:
(1) the right of free speech;
(2) the right to petition; or
(3) the right of association.
(c) The court may not dismiss a legal action under this section if the
party bringing the legal action establishes by clear and specific
evidence a prima facie case for each essential element of the claim
in question.
(d) Notwithstanding the provisions of Subsection (c), the court shall
dismiss a legal action against the moving party if the moving party
establishes by a preponderance of the evidence each essential
element of a valid defense to the nonmovant’s claim.
Sec. 27.006. Evidence.
(a) In determining whether a legal action should be dismissed under
this chapter, the court shall consider the pleadings and supporting
and opposing affidavits stating the facts on which the liability or
defense is based.
(b) On a motion by a party or on the court’s own motion and on a
showing of good cause, the court may allow specified and limited
discovery relevant to the motion.

Sec. 27.007. Additional findings.
(a) At the request of a party making a motion under Section 27.003,
the court shall issue findings regarding whether the legal action was
brought to deter or prevent the moving party from exercising
constitutional rights and is brought for an improper purpose,
including to harass or to cause unnecessary delay or to increase the
cost of litigation.
(b) The court must issue findings under Subsection (a) not later than
the 30th day after the date a request under that subsection is made.
Sec. 27.008. Appeal.
(a) If a court does not rule on a motion to dismiss under Section
27.003 in the time prescribed by Section 27.005, the motion is
considered to have been denied by operation of law and the moving
party may appeal.
(b) An appellate court shall expedite an appeal or other writ, whether
interlocutory or not, from a trial court order on a motion to dismiss
a legal action under Section 27.003 or from a trial court’s failure to
rule on that motion in the time prescribed by Section 27.005.
(c) Repealed by Acts 2013, 83rd Leg., R.S., Ch. 1042, Sec. 5, eff. June
14, 2013.
Sec. 27.009. Damages and costs.
(a) If the court orders dismissal of a legal action under this chapter, the
court shall award to the moving party:
(1) court costs, reasonable attorney’s fees, and other expenses
incurred in defending against the legal action as justice and
equity may require; and
(2) sanctions against the party who brought the legal action as the
court determines sufficient to deter the party who brought the
legal action from bringing similar actions described in this
chapter.

(b) If the court finds that a motion to dismiss filed under this chapter is
frivolous or solely intended to delay, the court may award court
costs and reasonable attorney’s fees to the responding party.
Sec. 27.010. Exemptions.
(a) This chapter does not apply to an enforcement action that is
brought in the name of this state or a political subdivision of this
state by the attorney general, a district attorney, a criminal district
attorney, or a county attorney.
(b) This chapter does not apply to a legal action brought against a
person primarily engaged in the business of selling or leasing goods
or services, if the statement or conduct arises out of the sale or
lease of goods, services, or an insurance product, insurance
services, or a commercial transaction in which the intended
audience is an actual or potential buyer or customer.
(c) This chapter does not apply to a legal action seeking recovery for
bodily injury, wrongful death, or survival or to statements made
regarding that legal action.
(d) This chapter does not apply to a legal action brought under the
Insurance Code or arising out of an insurance contract.
Sec. 27.011. Construction.
(a) This chapter does not abrogate or lessen any other defense,
remedy, immunity, or privilege available under other constitutional,
statutory, case, or common law or rule provisions.
(b) This chapter shall be construed liberally to effectuate its purpose
and intent fully.

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Exhibit B - Page 13

Tab 2:
Castleman’s review

Warning: Stay Away From The Offline Assistant Company & Kevin O’Connor |

THE LIFE AND TIMES OF TIM CASTLEMAN

DECEMBER 4, 2015

Warning: Stay Away From The Ofine
Assisant Company & Kevin O’Connor

On November 18th, 2015 during a routine review of our books, our accountant noticed a
$7,897.68 error caused by Kevin O’Connor’s Offline Assistant Company.

We hired Kevin and his company to fulfill our physical product store orders and it turns out that
they had been double ordering and shipping our most popular item to customers at our
expense for no understandable reason.

Once the error was discovered, I immediately had the last 100 orders they had placed for us
reviewed, and there was an 85% error rate in those orders so we started to dig deeper.

I immediately let Kevin know about this issue personally and told him I would get him a full
report by the following Monday (this was Friday).

We pulled our financial records from the store, the supplier, and matched them to our credit
card statements for them to get a full accounting of just how bad it was.

Exhibit E - Page 1
http://www.timothycastleman.com/warning-stay-away-from-the-offline-assistant-company-kevin-oconnor/[5/6/2016 8:22:59 PM]

Warning: Stay Away From The Offline Assistant Company & Kevin O’Connor |

When all was said in done, Kevin’s employees had over ordered and shipped products to the
tune of a $14,968.45 – almost DOUBLE what the orders should have cost and costing us
$7,897.68 in profit.

Armed with this information I sent everything to Kevin and asked him to review everything and
if the numbers were correct explain why none of the orders were checked by his project
manager (as promised when we signed up) or anyone else on is staff for accuracy, how his
employees could see us losing money on ever order and not say anything, and why they
hadn’t followed the spreadsheet directions we gave them.

When he finally responded 3 days later, he blamed us for not catching the error and cited a
training example order we included in the training materials (of a totally different product than
the one they misordered above) as a reason why they had doubled ordered everything.

Except they hadn’t double ordered every item.

His team managed to order the correct quantities of other items we sold in different amounts
(1, 2, 4 etc) with no problem.

When confronted with this, he went radio silent and refused to respond to any more of my
emails.

It was only after I demanded repayment for the $7,897.68 error that he finally responded, and
only to tell me that he considered the matter closed on his part and that he and his employees
had done nothing wrong and that he wouldn’t be paying for his employee’s mistake.

So here’s where we stand

– Kevin’s company over ordered and shipped an additional $7,897.68 worth of products to my
customers which I now have to pay out of my own pocket

– No one from his company (that we hired to manage this for us) reviewed any of the orders to

Exhibit E - Page 2
http://www.timothycastleman.com/warning-stay-away-from-the-offline-assistant-company-kevin-oconnor/[5/6/2016 8:22:59 PM]

Warning: Stay Away From The Offline Assistant Company & Kevin O’Connor |

ensure they were being done correctly despite his assurances they do quality control and
project management on all jobs.

– There was an 85% error rate by his staff in ordering products for us

– When presented with facts (credit card statements, Shopify print outs, and AliExpress
orders) Kevin still refused to accept any responsibility and to this day has refused to pay me
back for his company and employee’s mistakes.

The money part stings, but here’s the worst part.

I first met Kevin when I and several others (Brad Gosse, Ron Douglas, E. Brian Rose, Ben
Littlefield, Ben Adkins, Colin Theriot, Mark Helton, Brian Anderson, Ryan McKinney) were his
mentor at the Marketers Mansion.

We all spent time with him trying to help him grow his business.

I personally promoted Kevin not only to my list via a webinar, but also through my podcast
(free of charge), and told several business associates about him (who ended up signing up
with him – right Los).

Just last month I dropped everything when he came into town and showed him around
Lubbock and offered to help him even more with his company.

And this is how he repaid me and everyone else who helped him for doing so.

No apology, no acceptance of the facts, and most of all not a single offer to help us or
compensate us these errors.

I gotta assume that whole personal responsibility thing Garret White preaches didn’t sink in
with Kevin.

Exhibit E - Page 3
http://www.timothycastleman.com/warning-stay-away-from-the-offline-assistant-company-kevin-oconnor/[5/6/2016 8:22:59 PM]

Warning: Stay Away From The Offline Assistant Company & Kevin O’Connor |

Now don’t worry about me. We’ll be seeing Kevin in court and we’ll get every cent (plus some)
back from him.

I’m writing this post to warn others and share my personal experience with Kevin O’Connor
and his company.

If you choose to use him after seeing that he doesn’t stand behind his employees work, has
zero quality control or checks to ensure work is being done correctly, and no matter how
much proof you have of their mistakes, he will never admit when his team has made a
mistake or compensate you in any fashion for those mistakes – go ahead.

If you want to host a webinar, podcast, or invite him to speak on stage after reading this, that’s
your choice and speaks more to your core values than mine.

I just refuse to have people who have helped him in the past have their name associated with
him or his company without knowing the facts about what he did to our eCom business and
his unwillingness to stand behind his word and his employees mistakes.

I’m just thankful that we have the cash reserves to not only absorb this temporary loss and but
also pursue every legal recourse against him.

In closing I’ll share with you one last thought. Sometimes in life things like this happen. People
disappoint you, friendships end, and true colors are revealed. While you can’t control when or
why that stuff happens, you can control your response to those situations.

I tried to resolve this in private, I gave Kevin every opportunity to make this right. It was only
after he refused to do so, and I saw how huge of a disaster this could be for people who don’t
have the same resources I do, that I knew I had to go public with this issue.

Share the joy

Exhibit E - Page 4
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Warning: Stay Away From The Offline Assistant Company & Kevin O’Connor |

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Exhibit E - Page 5
http://www.timothycastleman.com/warning-stay-away-from-the-offline-assistant-company-kevin-oconnor/[5/6/2016 8:22:59 PM]

Tab 3:
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Tab 4:
Order denying motion

Filed 8/11/2016 8:10:38 AM
Barbara Sucsy
District Clerk
Lubbock County, Texas

CAUSE NO. 2016-519,740
INTERNET MONEY LIMITED d1b/a
THE OFFLINE ASSISTANT AND
KEVIN O'CONNOR, INDTVTDUALLY,
Plaintiffs,
v.

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TIMOTHY CASTLEMAN AND
CASTLEMAN CONSULTING, LLC,
Defendants.

IN THE 237TH DISTRICT COURT

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LUBBOCK COUNTY, TEXAS

ORDER GRANTING DEFENDANTS' MOTION FOR RELIEF FROM
TECHNICAL FAILURE AND FOR EXTENSION OF TIME AND DENYING
DEFENDANTS' 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IOTION To DISMISS

The Court, having considered the Defendants' Motion for Relief from Technical Failure
and for Extension of Time, Defendants' Motion to Dismiss, as well as Plaintifts' Opposition to
Motion to Dismiss and Request for Attorney's Fees, t ogether with supporting evidence and the
arguments made by counsel together with legal authority submitted by counsel, the Cou rt is of
the opinion that the Motion for Relief from Technical Failure and for Extension of Time is
granted and that the Defendants' Motion to Dismiss be denied.

Further, the Court is of the

opinion that the Motion to Dismiss was not frivolous or solely intended to delay and therefore
denies Plaintifts' attorney's fees.
IT lS THEREFORE, ORDERED, ADJUDGED AND DECREED that the Defendants'
Motion for Relief from Technical Failure and for Extension of Time be and the same is hereby
GRANTED.

Order Granting and Denying Motions

Page 1

IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the Defendants'
Motion to Dismiss be and the same is hereby DENIED.

It is further ordered that the Plaintitls'

Request for Attorneys' Fees is DENIED.
All costs of court are taxed against the party incuning same.

All relief not expressly

granted herein is hereby denied.
SIGNED this

10th

day of

August

,

,

_

2016.

JUDGE PRESIDING

Order Granting and Denying Motions

Page 2

Tab 5:
Findings of fact and conclusions of law

Filed 10/4/2016 2:33:54 PM
Barbara Sucsy
District Clerk
Lubbock County, Texas

cf

CAUSE NO. 2016-519,740
INTERNET MONEY LIMITED d/b/a
THE OFFLINE ASSISTANT AND
KEVIN O'CONNOR, INDIVIDUALLY,
Plaintiffs,

v.
TIMOTHY C~a..STLEM~a~ .AND
CASTLEMAN CONSULTING, LLC,
Defendants.

§
§
§
§
§
§
§
§
§
§

IN THE 237TH DISTRICT COURT

OF

LUBBOCK COUNTY, TEXAS

FINDINGS OF FACT AND CONCLUSIONS OF LAW IN RELATION TO DENIAL OF
MOTION TO DISMISS OF DEFENDANT, TIMOTHY CASTLEMAN

The above-captioned motion to dismiss came on before the Court's motion
docket on July 1, 2016. All parties were represented by counsel at the hearing. After
considering the motion to dismiss filed by Defendant Timothy Castleman, the
response, the evidence, the argument and briefs from counsel as well as Defendants'
Motion for Relief from Technical Failure and for Extension of Time, the Court, in
response to a request from Defendant, Castleman, makes the following findings of
fact and conclusions of law. Any finding of fact mislabeled as a conclusion of law
shall be deemed a finding of fact. Any conclusion of law mislabeled as a finding of
fact shall be deemed a conclusion of law.
FINDINGS OF FACT
1.
Defendant, Timothy Castleman, was served with process of Plaintiffs'
original petition on larch 7, 2016. Defendant Castleman filed a late motion to
dismiss under the Texas Citizens Participation Act on May 7, 2016. Defendant
Castleman also filed a Motion for Relief from Technical Failure, or, in the
Alternative, for Extension of Time in order to allow his motion to be timely.

2.
Defendant, Castleman Consulting, LLC, was served with process of
Plaintiffs' original petition on March 9, 2016. Defendant Castleman Consulting,
LLC did not f:tle a motion to dismiss under the Texas Citizens Participation Act nor
did Defendant Castleman Consulting, LLC, file a Motion for Relief from Technical
Failure, or, in the Alternative, for Extension of Time.
3.
Plaintiffs' First . A~ended
.
Petition asserts causes of action for slander
and libel associated with Defendants' Facebook, Twitter, blog, Warrior Forum,
Google Reviews, and podcasts alleging Plaintiffs' failed promises, placement of
liPage Findings of Fact and Conclusions of Law

4

orders with an 80% to 85% error rate, Plaintiffs' inability or unwillingness to follow
instructions, Plaintiffs' stealing from Defendants, and Plaintiffs' terrible services.
4.
The matter was originally set within 60 days of the motion but was
delayed by a request for discovery.
5.
The matter was set for hearing on July 1, 2016, within 90 days after
the service of the motion.
6.
The court considered the pleadings and supporting and opposing
affidavits stating the facts on which the liability and defenses are based. Tex. Civ.
Prac. & Rem. Code § 27.006.
7.
Defendant did not show by a preponderance of the evidence that the
legal action was based on, related to, or was in response to Defendant's exercise of
the right of free speech, the right to petition, or of the right of association.
8.
Plaintiffs provided clear and specific evidence of a prima facie case for
each element of their claims, including the facts of when, where, and what was said,
the defamatory nature of the statements, and how they damaged Plaintiffs.
9.

Defendant failed to show a valid defense to Plaintiffs' claims.

10.

Defendant failed to show truth of at least the following statements:
a. "there was an 85% error rate" in the orders placed.
b. "No one from his company reviewed any of the orders to ensure they
were being done correctly."
c. "zero quality control or checks to ensure work
correctly"

IS

being done

d. "unwillingness to stand behind his word"
e. confirming that Plaintiffs "practically stole" from Defendants

f. Plaintiff was "someone that doesn't stand behind their work, their
team does not quality checks or assurances, and if there's ever a
problem, they're not going to fix it for you, especially when it comes to
financial"
11.
The statements at issue arose out of the sale of goods, and the intended
audience is actual or potential buyers or customers.
21Page Findings of Fact and Conclusions of Law

5

12.
Defendants' statements were made with either the knowledge of their
falsity or, at the very least, with reckless disregard as to their truth or falsity.
Defendants admitted their intent to harm Plaintiffs and acknowledged
13.
the damage their statements were causing Plaintiffs.
The Court does not find the Motion to Dismiss to be frivolous or solely
14.
intended to delay.

CONCLUSIONS OF LAW
1.
Defendant Castleman's motion to dismiss was untimely, but the
Motion for Relief from Technical Failure and for Extension of Time is properly
granted within the discretion of the court.
2.
The motion to dismiss under the Texas Citizens Participation Act is
deemed timely filed. Tex. Civ. Prac. & Rem. Code§ 27.003.
3.
Defendant Castleman Consulting, LLC did not file a motion to dismiss
under the Texas Citizens Participation Act. Tex. Civ. Prac. & Rem. Code§ 27.003.
4.
27.004.

The hearing was timely pursuant to Tex. Civ. Prac. & Rem. Code §

5.
Defendants' acts fall within an exception to the Citizens Participation
Act. Tex. Civ. Prac. & Rem. Code§ 27.101(b).
6.
In the alternative, Defendant failed to show by a preponderance of the
evidence that the legal action is based on, relates to, or is in response to the party's
exercise of the right of free speech, the right to petition, or the right of association.
7.
Plaintiffs established by clear and specific evidence a prima facie case
for each essential element of the claims in question.
8.
Defendant failed to establish by a preponderance of the evidence each
essential element of a valid defense to Plaintiffs' claims.
9.
In determining whether a legal action should be dismissed under this
chapter and at the request of Defendant Castleman, pursuant to Section 27.003,
this Court finds that Plaintiffs' legal actions were not brought to deter or prevent
the Defendants from exercising constitutionai rights and were not brought for an

3IPage Findings of Fact and Conclusions of Law

6

improper purpose, including to h arass or to cause unnecessary delay or to increase
the cost of litigation. Tex. Civ. Prac. & Rem. Code§ 27.007.
10.

Plaintiffs' objections at the hearing on July 1, 2016 are overruled.

11.

Defenda nt Castleman's Motion to Dismiss is denied.

12.

The Motion to Dismiss was not frivolous or solely intended to delay.

13.

No attorneys' fe es were awarded.

14.

All costs incurred shall be borne by the party incurring same.

:m
SIGNED this ---+~

____

day of October, 2016.£

/~

JUDGE PRESIDING

41 Page

Findin gs of Fact and Conclu s i on s of L aw

7

Tab 6:
Notice of appeal

Filed 8/22/2016 8:03:26 PM
Barbara Sucsy
District Clerk
Lubbock County, Texas

Case 2016-519,740
Internet Money Limited and
Kevin O’Connor,
Plaintiffs,
v.
Timothy Castleman and
Castleman Consulting LLC,
Defendants.

cf

237th District Court
Lubbock County

Defendants’ Notice of Appeal
The defendants’ Motion to Dismiss Under the Texas Citizens Participation Act was denied by operation of law on August 1, 2016. The Court
memorialized that dismissal in an order signed on August 10. Defendants
Timothy Castleman and Castleman Consulting, LLC, appeal that order to
the Seventh Court of Appeals. This is an accelerated appeal.
Respectfully submitted,
The Law Office of Jared
B. Hall, PLLC
Jared B. Hall
State Bar No. 24055615
JHallAttorney@gmail.com
P.O. Box 6982
Lubbock, Texas 79493
(806) 853-7182
The Olson Firm, PLLC
/s/ Leif A. Olson
Leif A. Olson
State Bar No. 24032801
leif@olsonappeals.com
PMB 188
4830 Wilson Road, Suite 300
Humble, Texas 77396
(281) 849-8382
Counsel for Defendants
Certificate of Service
I certify that on August 19, 2016, I served a copy of this notice of appeal
upon J. Paul Manning, counsel for the plaintiffs, by electronic filing.
/s/ Leif A. Olson

Tab 7:
Texas Citizens Participation Act

Chapter 27. Actions involving the exercise of certain
constitutional rights
Sec. 27.001. Definitions. In this chapter:
(1) “Communication” includes the making or submitting of a
statement or document in any form or medium, including oral,
visual, written, audiovisual, or electronic.
(2) “Exercise of the right of association” means a communication
between individuals who join together to collectively express,
promote, pursue, or defend common interests.
(3) “Exercise of the right of free speech” means a communication
made in connection with a matter of public concern.
(4) “Exercise of the right to petition” means any of the following:
(A) a communication in or pertaining to:
(i) a judicial proceeding;
(ii) an official proceeding, other than a judicial proceeding,
to administer the law;
(iii) an executive or other proceeding before a department of
the state or federal government or a subdivision of the
state or federal government;
(iv) a legislative proceeding, including a proceeding of a
legislative committee;
(v) a proceeding before an entity that requires by rule that
public notice be given before proceedings of that entity;
(vi) a proceeding in or before a managing board of an
educational or eleemosynary institution supported
directly or indirectly from public revenue;
(vii) a proceeding of the governing body of any political
subdivision of this state;

(viii) a report of or debate and statements made in a
proceeding described by Subparagraph (iii), (iv), (v), (vi),
or (vii); or
(ix) a public meeting dealing with a public purpose,
including statements and discussions at the meeting or
other matters of public concern occurring at the meeting;
(B) a communication in connection with an issue under
consideration or review by a legislative, executive, judicial, or
other governmental body or in another governmental or
official proceeding;
(C) a communication that is reasonably likely to encourage
consideration or review of an issue by a legislative, executive,
judicial, or other governmental body or in another
governmental or official proceeding;
(D) a communication reasonably likely to enlist public
participation in an effort to effect consideration of an issue
by a legislative, executive, judicial, or other governmental
body or in another governmental or official proceeding; and
(E) any other communication that falls within the protection of
the right to petition government under the Constitution of
the United States or the constitution of this state.
(5) “Governmental proceeding” means a proceeding, other than a
judicial proceeding, by an officer, official, or body of this state or
a political subdivision of this state, including a board or
commission, or by an officer, official, or body of the federal
government.
(6) “Legal action” means a lawsuit, cause of action, petition,
complaint, cross-claim, or counterclaim or any other judicial
pleading or filing that requests legal or equitable relief.
(7) “Matter of public concern” includes an issue related to:

(i) health or safety;
(ii) environmental, economic, or community well-being;
(iii) the government;
(iv) a public official or public figure; or
(v) a good, product, or service in the marketplace.
(8) “Official proceeding” means any type of administrative,
executive, legislative, or judicial proceeding that may be
conducted before a public servant.
(9) “Public servant” means a person elected, selected, appointed,
employed, or otherwise designated as one of the following, even
if the person has not yet qualified for office or assumed the
person’s duties:
(A) an officer, employee, or agent of government;
(B) a juror;
(C) an arbitrator, referee, or other person who is authorized by
law or private written agreement to hear or determine a
cause or controversy;
(D) an attorney or notary public when participating in the
performance of a governmental function; or
(E) a person who is performing a governmental function under a
claim of right but is not legally qualified to do so.
Sec. 27.002. Purpose. The purpose of this chapter is to encourage
and safeguard the constitutional rights of persons to petition, speak
freely, associate freely, and otherwise participate in government to the
maximum extent permitted by law and, at the same time, protect the
rights of a person to file meritorious lawsuits for demonstrable injury.

Sec. 27.003. Motion to dismiss.
(a) If a legal action is based on, relates to, or is in response to a party’s
exercise of the right of free speech, right to petition, or right of
association, that party may file a motion to dismiss the legal action.
(b) A motion to dismiss a legal action under this section must be filed
not later than the 60th day after the date of service of the legal
action. The court may extend the time to file a motion under this
section on a showing of good cause.
(c) Except as provided by Section 27.006(b), on the filing of a motion
under this section, all discovery in the legal action is suspended
until the court has ruled on the motion to dismiss.
Sec. 27.004. Hearing.
(a) A hearing on a motion under Section 27.003 must be set not later
than the 60th day after the date of service of the motion unless the
docket conditions of the court require a later hearing, upon a
showing of good cause, or by agreement of the parties, but in no
event shall the hearing occur more than 90 days after service of the
motion under Section 27.003, except as provided by Subsection (c).
(b) In the event that the court cannot hold a hearing in the time
required by Subsection (a), the court may take judicial notice that
the court’s docket conditions required a hearing at a later date, but
in no event shall the hearing occur more than 90 days after service
of the motion under Section 27.003, except as provided by
Subsection (c).
(c) If the court allows discovery under Section 27.006(b), the court
may extend the hearing date to allow discovery under that
subsection, but in no event shall the hearing occur more than 120
days after the service of the motion under Section 27.003.

Sec. 27.005. Ruling.
(a) The court must rule on a motion under Section 27.003 not later
than the 30th day following the date of the hearing on the motion.
(b) Except as provided by Subsection (c), on the motion of a party
under Section 27.003, a court shall dismiss a legal action against
the moving party if the moving party shows by a preponderance of
the evidence that the legal action is based on, relates to, or is in
response to the party’s exercise of:
(1) the right of free speech;
(2) the right to petition; or
(3) the right of association.
(c) The court may not dismiss a legal action under this section if the
party bringing the legal action establishes by clear and specific
evidence a prima facie case for each essential element of the claim
in question.
(d) Notwithstanding the provisions of Subsection (c), the court shall
dismiss a legal action against the moving party if the moving party
establishes by a preponderance of the evidence each essential
element of a valid defense to the nonmovant’s claim.
Sec. 27.006. Evidence.
(a) In determining whether a legal action should be dismissed under
this chapter, the court shall consider the pleadings and supporting
and opposing affidavits stating the facts on which the liability or
defense is based.
(b) On a motion by a party or on the court’s own motion and on a
showing of good cause, the court may allow specified and limited
discovery relevant to the motion.

Sec. 27.007. Additional findings.
(a) At the request of a party making a motion under Section 27.003,
the court shall issue findings regarding whether the legal action was
brought to deter or prevent the moving party from exercising
constitutional rights and is brought for an improper purpose,
including to harass or to cause unnecessary delay or to increase the
cost of litigation.
(b) The court must issue findings under Subsection (a) not later than
the 30th day after the date a request under that subsection is made.
Sec. 27.008. Appeal.
(a) If a court does not rule on a motion to dismiss under Section
27.003 in the time prescribed by Section 27.005, the motion is
considered to have been denied by operation of law and the moving
party may appeal.
(b) An appellate court shall expedite an appeal or other writ, whether
interlocutory or not, from a trial court order on a motion to dismiss
a legal action under Section 27.003 or from a trial court’s failure to
rule on that motion in the time prescribed by Section 27.005.
(c) Repealed by Acts 2013, 83rd Leg., R.S., Ch. 1042, Sec. 5, eff. June
14, 2013.
Sec. 27.009. Damages and costs.
(a) If the court orders dismissal of a legal action under this chapter, the
court shall award to the moving party:
(1) court costs, reasonable attorney’s fees, and other expenses
incurred in defending against the legal action as justice and
equity may require; and
(2) sanctions against the party who brought the legal action as the
court determines sufficient to deter the party who brought the
legal action from bringing similar actions described in this
chapter.

(b) If the court finds that a motion to dismiss filed under this chapter is
frivolous or solely intended to delay, the court may award court
costs and reasonable attorney’s fees to the responding party.
Sec. 27.010. Exemptions.
(a) This chapter does not apply to an enforcement action that is
brought in the name of this state or a political subdivision of this
state by the attorney general, a district attorney, a criminal district
attorney, or a county attorney.
(b) This chapter does not apply to a legal action brought against a
person primarily engaged in the business of selling or leasing goods
or services, if the statement or conduct arises out of the sale or
lease of goods, services, or an insurance product, insurance
services, or a commercial transaction in which the intended
audience is an actual or potential buyer or customer.
(c) This chapter does not apply to a legal action seeking recovery for
bodily injury, wrongful death, or survival or to statements made
regarding that legal action.
(d) This chapter does not apply to a legal action brought under the
Insurance Code or arising out of an insurance contract.
Sec. 27.011. Construction.
(a) This chapter does not abrogate or lessen any other defense,
remedy, immunity, or privilege available under other constitutional,
statutory, case, or common law or rule provisions.
(b) This chapter shall be construed liberally to effectuate its purpose
and intent fully.

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