Filed 18-Cl-01925 10/24/2018 John C. Middleton, KentBiOGrGatIGENAL DOCUMENT 12/30/2019 04:50:54 PM 96340 COMMONWEALTH OF KENTUCKY KENTON CIRCUIT COURT CASE NO: RENAISSANCE COVINGTON PLAINTIFF 2 W PIKE STREET COVINGTON KY 41011 VS. RICHARD HINES DEFENDANT 3200 N PALM AIRE DR UNIT 906 POMPANO BEACH 33069 Electronically Filed VERFIED COMPLAINT FOR DEFAMATION, INVASION OF PRIVACY, AND INJUNCTIVE RELIEF Plaintiff Renaissance Covington (“RCOV") brings this action against Defendant Richard Hines (“Defendant”) for Defamation, Invasion of Privacy, and Injunctive Relief. PB ju tion, and Venue 1. RCOV is a registered Kentucky Non Profit Corporation with its Prineipal Office address located at 2 W Pike Street, Covington, KY 41011. 2. Katie Meyer (“Katie”) is a resident of the Commonwealth of Kentucky and Executive Director of RCOV with her service of process address at 2 W Pike Street, Covington, KY 41011. 3. Defendant is a resident of Kentucky, Georgia, and Florida as evidenced by his biography posted on his newspaper's website. Attached as Exhibit 1. 4, Defendant operates a business consisting of various social media networks and a website, ‘www.tiewsnky.com that he calls the “Northern Kentucky News Network" that claims to cover and report relevant news and facts in Northem Kentucky, including Covington, See Exhibit 1. 5. Defendant's “Northem Kentucky News Network” consists of a website, www hewsnky.com, and various Facebook News Sites including, but not limited to, Boone County News, Campbell County News, Covington News, Grant County News, Kenton County News, Latonia News, Northen Kentucky Life, Old NKY Photos, Cincinnati News, and NKY Directory. See Exhibit 1. 6. According to Defendant, “Norther Kentucky News” is the “region’s most read and most populgr news source with over 113,000* followers/readers.” See Exhibit 1. 7. Pursuant to KRS 452.460(1), Venue and Jurisdiction of this Action in Kenton County Circuit Court is proper, hecause the articles were published to a material number of Filed 18-C1-01925 10/24/2018 John €. Middleton, Kenton Circult ClerkFiled 18-C1-01925 10/24/2018 John C. Middleton, KentBIorGRIGENAL DOCUMENT 12130/2019 04:50:54 PM 96340 22. In fact, his contributor, Charlene Dietz, is further helping in the malicious attack by failing to report the facts as they occurred when she was given RCOV’s financial documents. 23. In response to Defendant's repeated, malicious, and damaging comments, RCOV found it necessary to make a public statement. See Exhibit 7. 24. In response to RCOV’s public statement, Defendant said the following: “Renaissance Covington is wrong. The post, which is still online, asked ifthe group was having some problems, never said it was. We have asked for bank statements and its accounts payable as of Saturday, September 22nd, the day of the post. Itis yet to comply. ‘As a mostly financed organization by the City of Covington, there should be more transparency by Renaissance Covington. ‘The NKY News Network has 131,000+ readers across it’s various Northern Kentucky pages, which makes the network highly popular, with nearly total market coverage, NKY News will continue to ask for the financials and will use all legal means necessary to get those reports from a public entity. This should not be a battle.” See Exhibit 8, 25, Defendant cannot even tell the truth about his own posting. As stated above and as evidenced in Exhibit 1, Defendant stated RCOV was one of two organization filing for bankruptcy and that RCOV “has run out of money and is considering its options.” See Exhibit 1. 26. Additionally, Defendant did ask for financial documents and RCOV provided those documents to Defendant. 27. On September 28, 2018, Defendant once again attacked RCOY, stating the organization canceled an event because it was poorly promoted and claimed it was because RCOV did not reach out to his “Northem Kentucky News Network” for assistance in promotion. ‘These statements are false, and are just a way for Defendant to maliciously attack RCOV while promoting his business. Exhibit 9 28. As shown in all Exhibits referenced above, Defendant has a history of reporting information against RCOV and Katie that is false, misleading, malicious, and damaging. Defendant's sole purpose for his posts is to damage the reputation of RCOV and Katie. 29, Defendant’s history of malicious attacks against RCOV and Katie in conjunetion with his refusal to investigate the facts, recklessness, and negligence for the truth, makes him liable and responsible to RCOV for any and all damage resulting from his inability to report the truth. 30. Despite RCOV’s request for Defendant to remove the false, misleading, malicious, and damaging posts and post a correction, Defendant has failed to remove the posts and as of the date of this filing the posts remain up. Filed 18-c1-01925 10/24/2018 John C. Middleton, Kenton Circuit ClerkFiled 48-Cl-01925 10/24/2018 John C. Middleton, KentBIOSrQ@IGRNAL DOCUMENT 12/30/2019 04:50:54 PM 96340 45, Therefore, RCOV prays that this Court issue a preliminary and permanent injunction against Defendant prohibiting them from publicizing any articles about RCOV, its Executive Directors, or its Board Members, to any and all News Sites he owns and/or ‘operates, without proof the publication is accurate or without written consent of RCOV. Prayer for Relief Wherefore, RCOV demand judgment against Defendant as follows: A. Asto Count I and Count Il, declare any and all statements above by Defendant to be libel and any related statements, to be false, misleading, defamatory, and an intentionally- made false statement with malice; B. Asto Count I, award RCOV compensatory damages, in an amount in excess of the minimym jurisdictional amount of this Court to be proven at trial or otherwise; C. Asto Count I and Count II, awarding RCOV punitive damages, attomey fees, and costs in amounts in excess of the minimum jurisdictional amount of this Court to be proven at trial or otherwise; D. As to Count II, preliminarily and permanently enjoin and restrain Defendant and his respective agents, contributors, servants, employees, attomeys, and those persons in active concert or participation with them from further publications of False Statements against RCOV, its Executive Director, or any of its Board Members. E. Foratrial by jury. F. For any other such relief RCOV may be entitled. Respectfully Submitied, si Matthew D. Dusing Shannon’. Smith (#95725) Matthew D. Dusing (#96340) Law Offices of Shannon C. Smith 605 Madison Avenue, Suite 2 Covington, KY 41011 859.414.0543 Shannon Smith@scsmithlaw.net Matthew Dusing@scsmithlaw.net Trial Attorneys for Plaintiff Filed 18-Cl-01925 10/24/2018 John C. Middleton, Kenton Circuit Clerkro2kiad Filed 48-Cl01925 10724120 Bout Nother KenlGdhpNowtliNallatern ire ntOKEr ORIGINAL DOCUMENT 42/30/2019 04:51:02 PM NewsNKY.com | Jobs Search | Weather Radar | Traf€Waze | " newsnky.com About Northern Kentucky News Northern Kentucky News was founded in 2009 as a social media page for a neigborhood in the City of Covington in the Northern Kentucky region, across from Cincinnati OH. Since then, it has expanded across NKY to become the region's most read and most popular news source with over 113,000+ followers/readers. With a significant amount of social media followers, it made sense to have an active news sites. Norther Kentucky News is updated on a daily basis, as are its social media pages. Contact us at: COVINGTON KY 41011 513-661-3607 You can also message us at any of the many NKY community Facebook pages. Best email: rhines@usnation.com Those involved are Editor Richard Schuman Hines; contributors Sue Griffith, Charlene Dietz, Tara Talbott and Jerome Hunt. About the Editor Editor (and publisher) Richard Schuman Hines (photo/2015) has been involved in publishing throughout his adult life. After the University of Cincinnati where he studied political science and history, Richard was immediately hited by the Kentucky Post newspaper which years later ceased publication. 48-cl-01925 10/24/2018 ntp:fwenwnensnky.com/ebout.im! ue NKY communities on Facebook Boone County News 17,080+ Campbell County, News 7,200 Covington News O50" Grant County Buzz 3.20- Kenton County News 1020+ Latonia News e270 Northern Kentucky Life 9.500% Qld NKY Photos a7 Cincinnati News 7580+ NKY Directory 7250" Old Northern Kentucky > 4 18sondebeet 48-C-01925 10/24/20 Nonnem Kena NeudY Klar See nt OCT ORIGHNAL DOCUMENT Atthat time, Hines lived at Ball’s Row on Garrard Street in Aereti2099)08:S 1202120 Covington KY. 96340 Leaving the paper, Richard co-founded a group of weekly newspapers on the west side of Cincinnati called Township Newspapers. Circulation was in the Delhi Township, Green Township and Price Hill communities. Later, he sold his part-ownership and founded a weekly newspaper in downtown Cincinnati called The Downtowner. After several years, Richard sold The Downtowner and launched a publication for highway travellers called Expressway Travel Continuing his career in news, Hines eventually became publisher of the Cobb County Times in Marieta GA. In the late 1990s, Richard became interested in the internet, starting numerous city sites across the country under the umbrella of USNationNet. He considers this his "greatest adventure” but ‘ended the concept after the economic collapse of 2008, choosing to take very early retirement. His entry in social media was, once again, something out of curiousity, Today, Richard operates the NKY News Network on social media. It now has over 113,000+ combined followers. Ithas anews site, newsnky.com . Hines has homes in Fort Thomas, Arabia Moun! Dunedin Florida. Georgia and The NKY News Network began as Russell Street News, an occasional newsletter published "for fun’, when Hines owned a recently-sold home on that Covington KY street. It eventually evolved into what the network is today. NORTHERN KENTUCKY NEWS NETWORK was founded in 2009 as 2 social media page for @ neigherhood in Covington i. ‘Since then, it has expanded across NKY to become the region's most read and most popular news source with aver 100,000+ followers, IMRIING CONTACT: Messape zany of #hraniti dlows Notwork easipbnadiadenny, Kein TAFaHPRRIPR.com Richard itptnewenewtenky.comvabout hint 28sonata 18-C1-01925 —10/24/20A%but Northern Kent Rhy New Nidlaten eden NOrARIGENAL DOCUMENT ‘Schuman Hines, administrator 12/30/2019 04:51:02 PM PRIVACY POLICY | ABOUT US 96340 Filed 18-C1-01925 10/24/2018 John C. Middleton, Kenton Circuit Clerk htpthwwnewsnky.corfabout hil asosibee! 18-C1.01925 10 (2) coving Wee MighWloton, KentBIOFORIGINAL DOCUMENT 12/30/2019 04:51:02 PM {fy Conington News oes40 ‘Two Covington promotional groups may file for bankruptcy: “Ineptly unable” to promote is the cause for expected bankruptcy filings by two Covington promotional groups. It's no secret that crowds have been dwindling at MainStrasse events as the result of inadequate and incompetent marketing by the MainStrasse Village As For example, even though NKY News Network has 131,000* readers, it has never received a single press release from MainSirasse to help spread the word. ciation. “Another promotional organization's fate is less certain, Renaissance Covington, the group put in charge of promoting downtown Covington, has run out of money and is considering its options Like Comment ‘Share & 4 Wite a comment Filed 01925 10/24/2018 John C. Middleton, Kenton Circuit Clerk Intestin facebook comicavinglonnews/posts01567 76590095168 wesonatlbee a-cl-01925 10/24 42/30/2019 04:51:02 PM AIM Latonia News sss40 September 22 Two Covington promotional groups may file for bankruptcy: sineptly unable" to promote is the cause for expected bankruptcy filings by two Covington promotional groups. It's no secret that crowds have been dwindling at MainStrasse events as the result of inadequate and incompetent marketing by the MainStrasse Village Association. For example, even though NKY News Network has 131,000+ readers, it has never received a single press release from MainStrasse to help spread the word ‘Another promotional organization's fate is less certain. Renaissance Covington, the group put in charge of promoting downtown Covington, has run out of money and is considering its options. 2 6 Comments 5 Shares Like Comment Share wb ‘Most Relevant dg Wete 2 comment iT, ) Latonia News “The MainStrasse Board and Membership are proud of the millions of people that attended their festivals, events and visited the MainStrasse area, ‘That quote, of course, is a lie. If milions participated, MSVA would not be bankrupt today. ae Like - Reply » 4 Fited ike “Reply 448.) 925 10/24/2018 John ¢. idleton, Kenton Circuit Clerk hitpssivww facebook comatonianews/posts/1630825487022007 42 eyed Neg. Bideloton, Kent OArERIGENAL DOCUMENTsored 48-C1-01925 10/24/2018 gy tated @NEG- Bédlleton, KentBHCKErEMRIGENAL DOCUMENT @ 42/30/2019 04:51:02 PM Kenny Smith Very well said. Pretty much sums it up. ae Like «Reply 4a @ ‘Taylor Alejandro CM I wonder if crowds have dwindle due to lack of parking during construction Luke = Reply @ 2 sre trina Na es Wott anne an vie Re Filed 18-cl01925 10/24/2018 John C. Middleton, Kenton Gircuit Clerk tps sw facebook conviatonianaws/posts/1630825437022997 22.sod 18-C1-01925 10/24 nod hnGabligitleton, KentBIOTGRIGNAL DOCUMENT 12/30/2019 04:51:02 PM Northern Kentucky Life 96340 Le Page September 22 Two Covington promotional groups may file for bankruptcy: “Ineplly unable" to promote is the cause for expected bankruptcy filings by two Covington promotional groups. It's no secret that crowds have been dwindling at MainStrasse events as the result of inadequate and incompetent marketing by the MainStrasse Village Association. For example, even though NKY News Network has 131,000+ readers, it has never received a single press release from MainStrasse to help spread the word, ‘Another promotional organization's fate is less certain. Renaissance Covington, the group put in charge of promoting downtown Covington, has run out of money and is considering its options. " +4 Comments 2 Shares Like Share Filed 18 on, Kenton Circuit Clerk tps sw Sacebook.comgroupsinkyifepermalink!242280020123943/ wsondlee 10/24/2018 (2 norinomn WAALS NdMAHaHaN, Koni BLOT ORIGINAL DOCUMENT 12/30/2019 04:51:02 PM {[7q, Northern Kentucky News 96340 Sep ‘Two Covington promotional groups may file for bankruptcy: “Inepily unable" to promote is the eause for expected bankruptcy filings by two Covington promotional groups, Its no secret that crowds have been dwindling at MainStrasse events as the result of inadequate and incompetent marketing by the MainStrasse Village Association, For example, even though NKY News Network has 131,000+ readers, it has never received a single press release from ‘MainStrasse to help spread the word. Another promotional organizations fate is less certain, Renaissance Covington, the group putin charge of promoting downtown Covington, has run out of money and is considering its options. 1 Comment Like Share on Oldest ap Northern Kentucky News “The MainStrasse Board and Membership are proud ofthe millions of people that attended their festivals, events and visited the MainStrasse area.” That quote, of course, isa lie, If millions participated, MSVA would not be bankrupt today, Like « Reply -4w: Eeited David Alexander Northern Kentucky News Or maybe there's more than we're secing... Mismanaged money? 1 Like» Reply =v QS woes comment Filed 48-c1-01925 10/24/2018 John C. Middleton, Kenton Circuit Clerk ites facebook.corvnkynews! wuJOCUMENT Pm September 23, 2018 Covington News Via Email rhines@usv c Via Facebook Messenger Covington News RE: Cease and Desist, Defamation, and Demand for Correction CEASE AND DESIST Dear Mr. Hines: Jam writing on behalf of my client, Renaissance Covington (“RCOV"). This letter serves 2s formal notice and demand for correction under KRS 411.051! to immediately remove all anguage from any of your websites, Facebook pages (Covington News, Latonia News, NKY News, Old NKY News, Kenton County News ete.), Twitter accounts, or any other medium (Richard Hines et. al”) suggesting Renaissance Covington has run out of money, is filing for bankruptcy, or has any financial difficulties and immediately print a correction in compliance with the statute, One example of the false financial statement is attached hereto as Exhibit A, printed September 22, 2018 at 6:40PM and in pertinent part reads, “Two Covington promotional groups may file for bankruptcy"; “Ineptly unable” to promote is the cause for expected bankruptcy filings” ; “Renaissance Covington, the group promoting downtown Covington, has run out of money and is considering its options.” TKRS 411.051 @) specifies what constitutes a sufficient demand for correction which is one ofthe prerequisites to "A "sufficient demand for correction” is « demand the filing for pumitive damages. Specifically, the statute provid for correction which i in writing: which is signed by the plaintiff or his duly-authorized attomey or agent, which specifies the statement or statements claimed to be false and defamatory, states wherein they are false, and seis forth the facts; and which is delivered to the defendant prior to the commencement of the action.