Professional Documents
Culture Documents
Defendants. SUMMONS
____________________________________________________X
To the above named Defendant(s)
You are hereby summoned to answer the complaint in this action and to serve a
copy of your answer, or, if the complaint is not served with this summons, to serve a
notice of appearance, on the Plaintiffs' Attorney(s) within 20 days after the service of this
summons, exclusive of the day of service (or within 30 days after the service is complete
if this summons is not personally delivered to you within the State of New York); and in
case of your failure to appear or answer, judgment will be taken against you by default
for the relief demanded in the complaint.
Yours, etc.
Peter J. Gleason, PC
By:________//PJG//__________
Peter J. Gleason
Counsel for Plaintiff
935 South Lake Blvd.
Suite 17
Mahopac, New York 10541
(646) 872-3546
PJGleason@aol.com
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SUPREME COURT STATE OF NEW YORK
COUNTY OF NEW YORK
__________________________________________________X
Plaintiff,
VERIFIED COMPLAINT
-v.- Jury Demand
Defendants.
____________________________________________________X
The Plaintiff R.J. CIPRIANI, by his attorney PETER J. GLEASON, PC, as and for his
INTRODUCTION
founded by Glenn Bunting, based in San Francisco California, which according to their website
2. It is asserted that Glenn Bunting and Bunting Co., and their agents, purposefully
and with full knowledge of there falsity, verbally told a third party that Cipriani had committed
the crime of attempted extortion. This statement was unambiguous and directed to a third party
with the sole purpose to discredit Cipriani and destroy his relationship with said third party, The
New York Post. (Attempted extortion is a crime as defined under New York State Penal Law
155.10)
3. The defamatory statement upon which this suit is predicated was a
conversation Bunting had with Richard Wilner, Business Editor of the NY Post. Wilner was
working on a story that was pitched by Cipriani, regarding Canadian billionaire Daryl Katz and
Katzs self-described cousin Michael Gelmon. The basis of the potential story was wire transfers
to Ciprianis wife totaling $35,000. The two wire transfers were from a penny stock, Banyon
Corporation, whose CEO at relevant time was Michael Gelmon. At relevant time Banyon
concert with one another engaged Bunting and or Bunting Co., to destroy any chance that the NY
Post would run a story on the penny stock wire transfer and its more nefarious related backstory.
silencing the media regarding Katz and or Gelmon, engaged in communications with Richard
Wilner and other agents of the NY Post informing them that Cipriani was engaging in criminal
conduct, to wit, attempting to extort Katz and/or Gelmon. The statement(s) made by Bunting
and or Bunting Co. to the NY Post, irreparably caused substantial damage to Ciprianis
relationship with Wilner and the NY Post and Ciprianis philanthropy. The statement(s) made
by Bunting and or Bunting Co. regarding Ciprianis attempted extortion is undeniably false.
Although a plaintiff may not establish personal jurisdiction over defamation defendants under
302(a)(2) and (3) of the CPLR, "courts will entertain defamation cases against non-domiciliaries
F. Supp. 3d 198, 202 (E.D.N.Y. 2014); see also Best Van Lines, Inc. v. Walker, 490 F.3d 239,
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245-46 (2d Cir. 2007). This specific jurisdiction provision permits a court to exercise jurisdiction
over a non-domiciliary so long as two requirements are met: (1) the defendant "transacts any
business within the state; and (2) the "cause of action aris[es] from" that transaction. CPLR
302(a)(1). Transacting business for the purpose of CPLR 302(a)(1) requires "some act by
which [a] defendant purposefully avails itself of the privilege of conducting activities within the
Forum State, thus invoking the benefits and protections of its laws." Best Van Lines, 490 F.3d at
246 (quoting McKee Elec. Co. v. Rauland-Borg Corp., 229 N.E.2d 604, 607 (N.Y. 1967)).
However, "New York courts construe 'transacts any business within the state' more narrowly in
defamation cases than they do in the context of other sorts of litigation." SPCA of Upstate New
York, Inc. v. Am. Working Collie Ass'n ("SPCA"), 963 N.E.2d 1226, 1230 (N.Y. 2012) (quoting
Best Van Lines, 490 F.3d at 248). Under 302(a)(1) in the defamation context:
[T]he single act of uttering defamation, no matter how loudly, is not a transaction
of business that may provide the foundation for personal jurisdiction. In other words,
when the defamatory publication itself constitutes the alleged transaction of business . . . ,
more than the distribution of a libelous statement must be made within the state to
wit, the following is from the Defendants web site: Heidi Davidson joins G.F. BUNTING+CO
to support the growth of the firms rapidly expanding New York practice. According to related
press coverage of Ms. Davidson she joined Bunting Co. in mid 2015.
PLAINTIFF
8. Plaintiff, a male citizen of the United States of America over twenty-one (21)
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years of age, resides in Los Angeles County and the State of California. Prior to the ruinous
statement(s) giving rise to this suit, Cipriani was a well-known and respected source for Richard
Wilner of the Business Editor of The New York Post. Cipriani, while embracing the
complexities of the modern world, comes from the simplest of backgrounds. The son of a first
generation Italian American barber Plaintiff grew up on the wrong side of the tracks in
Philadelphia. Plaintiff was reared by his parents while also caring for 4 other children in
cramped quarters above the fathers barbershop. This closeness generated a strong sense of
loyalty and the necessity for honesty. Without these attributes, survival in such close quarters
would have been untenable. Based on this filing, Cipriani not only expects the Defendants to
further attempt to malign his character, he welcomes it. Cipriani is of the opinion that Bunting
enables certain high paying clients to circumvent liability for sexual misconduct. Bunting and
Bunting Cos professional relationship with Florida State University, Baylor University and
Occidental College come to mind. The reprehensible and vile filth that Bunting and Bunting Co.
seeks to cover up through their media strategy is as sick and twisted as communicating to the NY
Post that Cipriani attempted to extort Katz and or Gelmon. Bunting on the Bunting Co. website
shares with the world his passion for his grandchildren: How would he feel if one of his
grandchildren lived the horrors suffered by the victims at Florida State, Baylor University or
Occidental College only to have some media consultant then publically abuse them?
DEFENDANTS
firm advertise itself on the internet as an expert in creating original content and as experts in
strategic communication, and they publicly tout their many friends and former colleagues
who work at the nations leading newspapers, TV networks and online news organizations.
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Buntings reference to creating original content conjures up the term du jour, Fake News.
10. Bunting in a most reckless manner has described his client base as those who have
engage[d] in some kind of misconduct they should have not engaged in. In legal terms this
would be tantamount to making statements against your clients self interest. Bunting, not being
an attorney himself, might self-reflect in hindsight, and recognize that said statement throws his
current and prospective client base under the bus, thus acknowledging his clients culpability.
whitewashing the national epidemic of the sexual abuse of women. Some glaring examples of
storyline of the film, the The Hunting Ground, which depicts the rape epidemic on
college campuses throughout the United States. FSUs segment in the The
Hunting Ground is about Erica Kinsman, who describes being locked in and
pinned to a bathroom floor, having her head slammed against the tile and being
forcefully raped while she is begging the attacker to stop. She went to the
emergency room. She did the rape kit. She later recognized her attacker as Jameis
Winston, at the time Florida State Universitys rising star quarterback, now a
Heisman trophy winner and this years number one pick in the NFL draft. There
was a DNA match. According to the film, Florida State delayed the investigation
In 2013, the LA Times ran a story in 2013 about Occidental College failing to
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report 27 sexual assaults on their campus. Occidental hired G.F. Bunting. Bunting
was able to have the story taken down only to subsequently have Occidental
officials later admit that they had, in fact, failed to report 27 assaults and that they
c. Baylor University retained the services of Bunting Co. to deal with crisis
allegations of rape. There was a related civil action filed on December 8, 2016
circumstances of the withdrawal are unclear which raises the specter that it may
have been quietly settled with a non-disclosure agreement in place. Bunting and
Bunting Co. were not named defendants in the Baylor action and Bunting has
reference, incorporates those sections of the Baylor action that references the
Please find heretofore attached and marked Exhibit A. Here is the caption of the
Baylor action:
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12. Bunting Co. boasts that they have many friends and former colleagues who work
at ... The New York Times, Los Angeles Times, Wall Street Journal, Bloomberg, BusinessWeek,
the Washington Post, Forbes, Fortune, San Jose Mercury News, The Miami Herald, CBS, NBC
and ABC News, The Associated Press, Reuters and The Huffington Post.
13. Upon information and belief, Bunting and Bunting Co. uses their many friends
in the media to assist those who engage in some kind of misconduct they should have not
14. Furthermore, Bunting boasts on his company website, every one of our senior
executives served as respected members of the Fourth Estate. This is disturbing on many
levels. The implications are clear based on the historical analysis of what the meaning and
implications are regarding the Fourth Estate. In 1580 Montaigne proposed that governments
should hold in check a fourth estate of lawyers selling justice to the rich and denying it to
rightful litigants who do not bribe their way to a verdict. The modern day metamorphosis of the
Fourth Estate has evolved into the medias ability to silence the truth for the highest bidder.
15. Bunting and or Bunting Co. may have fallen prey to their own self-proclaimed
success in covering up sexual assault and or misconduct as evidenced by Buntings own words in
16. In the video, Bunting smugly professes that he gets the call after the house is
fully engulfed in flames, this after the potential client has engage[d] in some kind of
misconduct they should have not engaged in. Buntings self-indictment of his (Buntings)
client base brings into question not only Buntings business acumen but the veracity of any
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denials Bunting may proffer on behalf of his clients to his or his companys many friends and
former colleagues who work at the nations leading newspapers, TV networks and online news
organizations.
17. Upon information and belief Bunting and Bunting Co. have lulled themselves into
the false belief that he and/or his company are impervious to any legal or moral accountability.
18. A very wise man once said, When you have your hand in the mouth of the tiger,
you pull it out very slowly. In applying this to the instant matter, Bunting through sheer
arrogance may have met his Waterloo in the form of a kid from the wrong side of the tracks in
Philadelphia.
19. While Bunting and Bunting Co. acknowledge their extensive transactional
business connections to New York, they should have done some homework. The New York
press corp., particularly the NY Post, does not look favorably upon those who lie to them or
embolden sexual predators. By way of example, the eventual downfall of one of New Yorks
most powerful men, Sheldon Silver, can be directly linked to the NY Posts exposing Silvers
cover-up of the sexual assaults of his (Silvers) Chief of Staff, Michael Boxley.
PROCEDURAL REQUIREMENTS
21. Plaintiff by dint of a letter to GF Bunting, dated January 16, 2017, requested that
Bunting retract the defamatory statement he (Bunting) made to the NY Post. To date, Bunting
BACKGROUND
22. The backstory to Buntings zealous yet inappropriate invocation is, upon
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information and belief, related to Buntings representation of Canadian billionaire Daryl Katz
(Katz).
23. By any standard, Katz is not a handsome man. What he lacks in physical
presence, he tries to overcompensate with his bankroll. Upon information and belief, one way in
which Katz encounters beautiful women is through a magazine called Viva Glam.
24. Upon information and belief, Viva Glam is a front for Katz to procure beautiful
women for his own personal pleasure. One such photo shoot, in Hawaii, included Plaintiffs
wife where Katz assisted by Gelmon inappropriately pursued Plaintiffs wife that resulted in an
alienation of affection, claim by Plaintiff and a Criminal Complaint filed by Plaintiffs wife.
25. Hawaii recognizes the tort of alienation of affection, and both Katz and Gelmon
lawyers memorialized, from their perspective, in writing and upon information and belief
27. Plaintiffs wife is no stranger to being pursued by rich powerful men, and with the
exception of Katz/Gelmon, it was always done with a certain je ne sais quoi. Some of Plaintiffs
wifes suitors included Leonardo DiCaprio. Axl Rose, John Stamos, and Jim Carrey. All of
28. The totality of Katz/Gelmons inappropriate behavior can be found in the criminal
complaint that Plaintiffs wife filed with the Culver City Police Department # 16-27085 on July
10, 2016, which was forwarded to Chief Harry Kubojiri of the Hawaii Police Department, that is
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FACTUAL ALLEGATIONS
30. On or about July 11, 2016, Defendants Bunting and or Bunting Co. told Richard
Wilner of the NY Post that Plaintiff was involved in an extortion plot against Katz and/or
Gelmon.
31. Defendants, Bunting and or Bunting Co. knew, or at a minimum, should have
known that the statements regarding Plaintiff that they told to Richard Wilner were false.
34. Plaintiffs claim exceeds the jurisdictional limit of the Court below.
JURY DEMAND
Plaintiff hereby demands a trial by jury on all issues of fact and damages stated
herein.
Yours, etc.
Peter J. Gleason, PC
By:________//PJG//___________
Peter J. Gleason
Counsel for Plaintiff
935 S. Lake Blvd.
Suite 17
Mahopac, New York 10541
(646) 872-3546
PJGleason@aol.com
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