SIME Fels av boy atening 4 Users tal game whist key Probing
‘iter Reuly and salt embers fom speaking with hin; and baning hin fon sing
‘Amps erounds—vhich include the gravesites his mother ad athe,
% The University aso moved quickly odestoy Mr. Faves reputation inte
Lew commnty on mieoe. On August 26,200 nbs Mole and pubic
‘maicaed Community Servic exe, hie hounds of gre des ad cyan
$e worry let cece t Grats, tg tha Mr. Fale had egped in
“tnobedie
shaver “in secret” that was “shameful” and a “sin.* Liberty then repeated
‘iil statements in a press leas and is fel maga,
{Upon that pois, Grands were it thie, vigorously denied by Mr
Falwell ut Litery gre thos san ar eh and righteousness. With the ence of even
‘heals iene, Livery wuld have qty cn that Crs cages re
{se Intend, Liter gave rans es nar of tah by immediatly feng Me Fabets
‘eslration an publicly defaning him.
‘Tiber’ ations are ntti tthe teachings of Chis. Liberys conduct hat
‘eosesd Mr. Fall's standing among Livery fc, stems, and alumni, the sder
‘reneece communiy, and beynd, Libey’scondut has ls damaged Liberty sl; and the
‘rangclical comunity, by playing right into the hands of sinister operatives with wher
‘mete ibeny hus rected Mr. Faves atemps ofeach an amicable eatin, cng
Mr Falwell bring this action to restore hie repttion
THE PARTIES
12. PlainitfJery Falwell, Je. 8 9 citizen and resident of Virginia,
He curently
‘sides in Bedford County, Virginia. Mr, Favell as «Js Doctorate fom the University ef‘Virginie and nas practi Inner for many years Mr, Fle bepan working Liberty
the
‘Universi in 1986 as General Counsel, posto hate eld util May 2007, Flow
eth of Dr. Falwell in May 207, Me. Fal serve ste President nd Chancellor of Libty
Univer this August 25, 220 resignation,
11, Defendant Lider Univers is Ving nono corporation eden in
Lynchburg, Vinin with its principal office located at 1971 University Blvd, Lyvehburg
Virgin 24515
URISDICTION AND VENUE
14, This Cou has jrsicon over this mater persue 19 Va. Code §§17.-
513,8912261. Defeednt is organized asa noesoc corporation under the las of the
‘Comimonweath o Vrgini nd hast principale in the Contmcnweath of Virgii.
1S. enue proper isin his Cau unde Wa, Code Aan. 801-257 and 801-262
‘eeu it frum convenient the pasties and witness, where nce canbe adinstered
without prejaice er deny. Livery Univesiy’s prinpal ofc is lsted in Lnchbure,
Vii,
16. Furthemore, the Bnployment Agreement entered ino berween Mi. Flvel and
Livery, wish provides he bss fo aes neo th ans ia his tio, specifies tat any
legal ction or proceeding ring ou of or elaing tthe Employment Agreement sabe fled
and ajudcted only na sate or fderal court siting in Lynchburg, Virginian
FACTUAL UND
‘A: The Fal Ful and he Founding of ier erty
17. erm on June 1,196 in Lynch, Vieni, Mr, Falwell comes for svi
Virginian rots. is late father, De. Falwell is among he most respected Headers inthe‘vengelcl Christan communi, described ty The Economist as “quinessetlly American
‘ype: apoorman who won fim ad fate by preaching the Wor”
18, In 1952, De, Falwell decided to diate his te to Chit anc preaching
tt x church in a
Cusniy. Aer graduating college, he ume home oC yachbg o