ea Aah Rew 10 i 12 13 14 15 16 17 18 19 20 21 2 2B 4 25 26 27 28 Clerk of the Superior Court + Electronically Filed "** T. Formosa, Deputy 6/22/2023 8:49:19 AM . Filing ID 16177570 Daniel D. Maynard, No. 009211 dmaynard@mmeec.com Douglas C,Frickson, No. 012130 derickson@mmcec.com SIAYNARD CRONIN ERICKSON & CURRAN, P.L.C. 3200 North Central Avenue, Ste. 1800 Phoenix, Arizona 85012 (602) 279-8500 Attorneys for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA STEPHEN RICHER, No, _CV2023-009417_ COMPLAINT Plaintiff, v. KARI LAKE, KARI LAKE FOR ARIZONA, and SAVE ARIZONA FUND, INC., Defendants. Now comes Plaintiff Stephen Richer (“Richer”) for his complaint against Defendants Kari Ann Lake (“Lake”), Kari Lake for Arizona (“Lake Campaign”) and Save Arizona Fund, Inc. (“Lake Fund”), hereby alleges as follows: 1. Defendant Kari Lake lost the November 2022 gubematorial election. Instead of accepting that defeat, Lake—together with her campaign and a fundraising entity she controls—accused Plaintiff Stephen Richer of intentionally sabotaging the election, 2. Defendants knew or recklessly disregarded the falsity of those accusations. Courts at every level of the Arizona judiciary have concluded that Defendants have no evidence to support their wild claims. But Defendants continued to spread these egregious and harmful falsities to further their own agendas—and line their own pockets—at Richer’s expense.3. Asaresult of Defendants’ knowing and malicious falsehoods, Richer and his family have been the target of threats of violence, and even death, and have had their lives tured upside down. 4, Defendants, like all Americans, have a right to free speech, and that freedom extends to expressing views and opinions that others find distasteful or offensive, and to criticizing the government. Defendants have made many statements since the election, including statements about Richer, that are protected by the Arizona and U.S, Constitutions. Richer might vehemently disagree with Defendants regarding many of these statements, but he recognizes their right to express them. 5. But there is no constit tional right to spread intentional or reckless falschoods that cause harm to another person. Richer brings this case to hold Defendants accountable for such falsehoods and to obtain redress for the harm done to him and to his family. PARTIES 6. Plaintiff Stephen Richer is an individual who resides in Maricopa County, Arizona. Richer currently serves as the Recorder of Maricopa County, Arizona, He was elected as a Republican in November 2020 to a four-year term and took office in January 2021. He brings this case in his personal capacity. 7. Defendant Kari Ann Lake (a/k/a Kari Lake Halperin) is an individual who, on information and belief, resides in Maricopa County, Arizona. 8. Defendant Kari Lake for Arizona is an Arizona corporation that served as the campaign organization for Lake’s 2022 campaign for governor of Arizona. OnSeer auewn u 12 13 14 15 16 7 18 19 20 2 2 23 4 28 7 28 information and belief, its principal place of business is in Maricopa County, Arizona, and Lake serves as its Chair, officer, and director. 9. Defendant Save Arizona Fund, Inc. is an Arizona corporation that fundraises to support Lake, On information and belief, its principal place of business is in Maricopa County, Arizona, and Lake selects its leadership. On information and belief, Lake has authority and control over Save Arizona Fund and its fundraising soli and the funds that it raises are collected for Lake’s benefit. SURISDICTION AND VENUE 10. This complaint and action are brought pursuant to Arizona Revised Statutes (ARS.”) Title 12, Chapter 1, Article 2. 11. Jurisdiction in this court is proper pursuant to Article 6, § 14, Arizona Constitution and ARS. § 12-123. 12, Venue in this court is proper pursuant to A.R.S. § 12-401. FACTUAL ALLEGATIONS 13. Since the November 2022 election, Defendants have repeatedly and falsely accused Richer of causing Lake’s electoral defeat, including by claiming that Richer—a registered Republican—sabotaged the election to prevent Republican candidates, including Lake, from winning. 14, In particular, Defendants have repeatedly and falsely claimed—at i “person, rallies and speeches, and on podcasts and social media—that Richer (i) intentionally printed 19-inch images on 20-inch ballots to sabotage the 2022 Arizona general election (the “Ballot Size Sabotage’ ), and (ii) inserted 300,000 “illegal,” “invalid,” “phony,” and/or10 " 13 14 15 16 7 18 19 21 22 23 24 25 26 a7 28 “bogus” early-vote ballots into the Maricopa County vote count (the “Bogus Ballot Injection” 15. Lake's January 29, 2023 “Save Arizona Rally” provides one clear example of Lake falsely and with actual malice accusing Richer of both the Ballot Size Sabotage and the Bogus Ballot Injection. (Numerous additional examples are provided below—see infra §§ 25-102—and in Appendix A.) 16. During that rally, Lake falsely and with actual malice accused Richer of sabotaging the 2022 general election by misprinting Election Day ballots. Lake told the assembled crowd that “Richer and [Maricopa County Supervisor Bill] Gates . .. printed a 19-inch image, the wrong image on the ballot, so that the tabulators would jam all day long. That's exactly what happened. They did not want us to notice this. ‘They didn’t want us to notice it. You know who they want—You know, the only the only person, the only thing they wanted to notice this was the tabulators so that they would jam and spit out ballots, which is exactly what happened all day on Election Day... . And Richer and Gates, let's show those two again, these two men. These two men, we pay their salary, we the people pay their salary, we pay for our elector 17. Lake made that false accusation repeatedly. At the same rally, Lake told the crowd that Richer and Gates “intentionally printed the wrong image on the ballot on Election Day so that those ballots would intentionally be spit out of the tabulators. ... Well these guys are really, really terrible at running elections but I found out they’re really good. at lying.”18, During the rally, Lake also accused Richer of the Bogus Ballot Injection— falsely claiming that he was responsible for injecting 300,000 unlawful early voting ballots into the Maricopa County Election Day vote count. Lake stated: “[W]e know that 300,000 illegal ballots” were counted in the final Election Day tally. 19, Lake made the false and defamatory Ballot Size Sabotage and Bogus Ballot Injection claims while photographs of Richer and Gates were prominently displayed behind her, and she pointed to those photographs repeatedly while speaking. 20. Lake made the false Ballot Size Sabotage and Bogus Ballot Injection accusations against Richer weeks affer the Arizona Superior Court found that Lake had provided nothing more than “speculation” and “conjecture” to support her claims of intentional misconduct and that she had “brought forward no evidence” to contradict testimony that the 2022 election was conducted in accordance with established procedures. For that reason—as well as many others, see infra 103-122—Lake knew that her Ballot Size Sabotage and Bogus Ballot Injection claims were false before the January 29, 2023 rally or, at minimum, she was reckless as to the truth or falsity of those claims, 21. Save Arizona Fund’s branding appeared on screens during the “Save Arizona Rally” and on posters provided to attendees. On information and belief, Save Arizona Fund, in full or in part, sponsored and paid for the “Save Arizona Rally.”10 12 13 4 15 16 7 18 19 20 2 2 2B m4 25 26 27 28 22. The defamatory statements made at the “Save Arizona Rally” were part of an ongoing campaign of defamation against Richer by all three Defendants. For the last six months, Defendants have incessantly leveled the false Ballot Size Sabotage and Bogus Ballot Injection claims against Richer. Defendants made such false statements with actual malice through various mediums and spread those statements to new audiences through the Defendants’ social media accounts. 23. Defendants persisted in making those false accusations, with actual malice, even after they were repeatedly debunked, including by the Arizona courts and independent investigators: a. OnDecember 24, 2022, the Superior Court of Arizona found “nothing to substantiate [Lake’s] claim of intentional misconduct.” b. On February 16, 2023, the Arizona Court of Appeals concluded that the Superior Court’s no-intentional-misconduct finding was supported by “ample evidence,” and that Lake’s contrary claims were, “quite simply, sheer speculation;” On March 22, 2023, the Arizona Supreme Court denied Lake’s petition for review related to the Ballot Size Sabotage and Bogus Ballot Injection claims, concluding that the lower courts “aptly resolved these issues, . . . which were the subject of evidentiary proceedings in the trial court, and [Lake's] challenges on these grounds are insufficient to warrant the requested relief under Arizona or federal law.”On April 10, 2023, former Arizona Chief Justice Ruth V. McGregor issued the findings of a months-long investigation into the Ballot Size Sabotage claims, which concluded—consistent with the Arizona Superior Court’s factual findings—that the Blection Day issues most likely resulted from tech cal problems, not intentional misconduct. 24. Defendants’ false accusations made with actual malice against Richer conceming the Ballot Size Sabotage and Bogus Ballot Injection claims are summarized below and are set forth in more detail in the attached Appendix A. 25. Lake's January 29 Tweet. On January 29, 2023, Lake’s Twitter account, @KariLake, Tweeted an embedded video clip of the “Save Arizona Rally” and again stated the false Ballot Size Sabotage claim: “@Stephen_ Richer, & @billgatesaz, and their crew printed a 19-in image, the wrong image on the ballots, so that the tabulators would jam all day long. That’s exactly what happened.” @ Stephen_Richer is Richer’s personal Twitter account. 26. _Lake’s personal Twitter account is @KariLake, and Lake has approximately 1.3 million Twitter followers. 27. On information and belief, Lake has authority and control over the posts to her Twitter account, 28. As of June 16, 2023, the Tweet had been viewed more than 427,600 times and retweeted more than 3,600 times. 29. Lake’s January 29 Truth. On January 29, 2023, the @KariLake Truth Social account posted an embedded video clip of the “Save Arizona Rally” and again statedthe false Ballot Size Sabotage claim: “Stephen Richer, & Bill Gates, and their crew printed a 19-in image, the wrong image on the ballots, so that the tabulators would jam all day Jong. That's exactly what happened.” 30. Asof June 16, 2023, that post has been ReTruthed over 1,700 times and liked over 5,330 times. 31. Lake’s personal Truth Social account is @KariLake. She has approximately 655,000 followers on Truth Social. 32. On information and belief, Lake has authority and control over the posts to her Truth Social account, 33. Lake’s January 29 Gettr. On January 29, 2023, the @KariLake Gettr account posted an embedded video clip of the “Save Arizona Rally” and again stated the false Ballot Size Sabotage claim: “Stephen Richer, & Bill Gates, and their crew printed a 19-in image, the wrong image on the ballots, so that the tabulators would jam all day long. ‘That's exactly what happened.” 34. As of June 17, 2023, that post has been reposted 681 times and liked 1,300 times. 35, Lake's personal Gettr account is @KariLake. She has approximately 135,800 Gettr followers. 36. On information and belief, Lake has authority and control over the posts to her Gettr account. 37. Lake Campaign’s January 29 Tweet. On January 29, @KariLakeWarRoom Tweeted a photo of Richer and Gates and stated: “@Stephen Richer & @billgatesaz,10 u 12 13 4 15 16 7 18 19 20 2 22 23 24 25 26 27 28 These two clowns sabotaged election day. They knew 75% of @KariLake’s voters would show up on game day, so they programmed the machines to print 19 in images on 20 in ballots. If they had an ounce of integrity they would have resigned long ago.” 38. The official campaign Twitter account for Lake Campaign is @KariLakeWarRoom, The account has approximately 401,000 followers. 39. On information and belief, Lake and Lake Campaign have authority and control over the posts to Lake Campaign’s Twitter account. 40. As of June 16, 2023, the Tweet had been viewed more than 36,000 times and retweeted nearly 1,100 times. 41. Lake’s January 30 Rally Post to Rumble. On or about January 30, 2023, Lake’s Rumble account posted video of the full “Save Arizona Rally,” which includes both the false Ballot Size Sabotage and Bogus Ballot Injection claims. As of June 16, 2023, the Rumble post had been viewed more than 2,300 times. 42. Lake’s personal Rumble account is KariLake, which has approximately 57,500 followers. On information and belief, Lake has authority and control over the posts to her Rumble account. 43. Lake's January 30 Press Conference, On January 30, 2023, Lake held a press conference and falsely stated that “Richer and Gates intentionally printed the wrong image on the ballot when they knew 75% of the people showing up were Kari Lake voters, were Republican voters. They sabotaged Election Day. They printed the wrong image on the ballot knowing that that would jam the tabulator and it would spit the ballot out uncounted.”ul 13 4 15 16 7 18 19 20 21 2 23 24 25 26 27 28 44. Lake’s January 30 Press Conference Post to Rumble. On January 30, 2023, Lake’s Rumble account posted a video of the press conference she held the same day. That video included Lake’s false Ballot Size Sabotage claim, As of June 16, 2023, the Rumble video had been viewed more than 31,700 times. 45. Lake’s January 30 Press Conference Tweet. On January 30, 2023, @KariLake also Tweeted a link to Lake’s defamatory Rumble post containing a video clip of the press conference she held the same day, which included the false Ballot Size Sabotage claim. The Tweet encouraged readers to “WATCH: Kari Lake Holds Press Conference for 1/4 MILLION Ballot Rejections,” and the link preview for the Rumble post asked them to “Help us in our legal battle to Save Arizona: savearizonafund.com.” As of June 16, 2023, the Tweet had been viewed more than 233,100 times and retweeted nearly 2,000 times. 46. Lake’s January 30 Press Conference Truth. On January 30, 2023, the @KariLake Truth Social account posted an embedded video clip of the press conference she held the same day, which included the false Ballot Size Sabotage claim. The post above the embedded video clip encouraged readers to “WATCH: Kari Lake Holds Press Conference For 1/4 MILLION Ballot Rejections.” 47. AsofJune 17, 2023, that post has been ReTruthed over 1,010 times and liked over 3,220 times, 48. Lake’s January 30 Press Conference Gettr. On January 30, 2023, the @KariLake Gettr account posted a link to the defamatory Rumble post containing a video of the press conference she held the same day, wl included the false Ballot Size 10"Sewer) Sabotage claim. The post encouraged readers to “WATCH: Kari Lake Holds Press Conference For 1/4 MILLION Ballot Rejections.” 49. As of June 17, 2023, that post has been reposted 167 times and liked 444 times, 50. Save Arizona Fund’s January 30 Ballot Size Sabotage Rally Post. On January 30, 2023, the @savearizonafund YouTube account posted an excerpt of the video of Lake's January 29, 2023 rally entitled “Save Arizona Rally (1/29/2023): Printed Wrong Image on Ballots.” That video contains the false Ballot Size Sabotage claim. As of June 16, 2023, the YouTube video has been viewed at least 46 times. 51. Oninformation and belief, Save Arizona Fund posts videos to YouTube from the @savearizonafund account, and Lake and Save Arizona Fund have authority and control over the @savearizonafund account. 52. Save Arizona Fund’s January 30 Bogus Ballot Injection Rally Post. On January 30, 2023, the @savearizonafund YouTube account posted an excerpt of the video of Lake’s January 29, 2023 rally entitled “Save Arizona Rally (1/29/2023): Chain Of Custody.” That video contains the false Bogus Ballot Injection claim. As of June 16,2023, the YouTube video has been viewed at least 19 times, 53. Lake Campaign’s January 31 Tweet On January 31, 2023, Lake Campaign’s official Twitter account @KariLakeWarRoom posted a Tweet accusing Richer of “intentionally print{ing] the wrong image on the ballot on election day so that those ballots would intentionally be spit out of the tabulators, and then, they lied and said the problem was fixed early in the day.” “lle24 25 26 27 28 54. As of June 16, 2023, this Tweet had been viewed more than 12,300 times and retweeted more than 300 times. 55. Lake’s February 8 Podcast. On February 8, 2023, Lake appeared on the “YOUR WELCOME” with Michael Malice podcast. 56. During her appearance, Lake made the false Ballot Size Sabotage claim, stating that “they the sabotaged election day” by “print{ing] out intentionally” a “19-inch ballot on a 20-inch ballot” so that “a quarter of a million times” ballots were notread. Lake then suggested that system logs reflected that ballots were rejected “because they intentionally printed the wrong image.” 57. On the podcast, Lake also made the false Bogus Ballot Injection claim, stating that “they really had to pour in a lot of phony ballots to make that happen, And turns out now we know 300,000 with no chain of custody were tossed in and counted.” 58. Lake made clear that she was making these false accusations against Richer. Only seconds after making the false Ballot Size Sabotage claim, Lake stated: “Let me tell you about the people running Maricopa County elections . . . there are two men by the name of Stephen Richer and Bill Gates” who run “shoddy rigged elections.” 59. Lake's February 20 Podcast. On February 20, 2023, Lake appeared on an episode of “TRIGGERED,” a video podcast hosted by Donald Trump Jr. 60. Inthe interview, Lake stated that she was fighting an “intentionally botched” election and repeated the false Ballot Size Sabotage claim: [W]e have the proof and the evidence. . .. This is what's in our case. They printed intentionally the wrong image on the ballot, knowing that 75% of the people showing up on election day were voting for10 u 12 13 “4 15 16 7 18 19 20 2 23 24 25 26 27 28 me. They intentionally print the wrong image on the ballot so it jams the tabulator. 61. Further describing the 2022 general election, Lake also repeated the false Bogus Ballot Injection claim, stating: “they couldn't steal it by just throwing in 300,000 bogus ballots with no chain of custody, which they did. ‘They had to sabotage Election Day.” 62. Moments later, Lake clarified who “they” were: “And so the two guys running Maricopa County, even though they are Republicans, Stephen Richer and Bill Gates are their names.” 63. The podcast interview, titled “It’s Worse Than You Thit : Kari Lake on ‘What Really Happened in Arizona,” has been viewed at least 646,000 times on Rumble as of June 16, 2023. 64. Lake’s February 20 Truth. On February 20, 2023, Lake’s Truth Social account, @KariLake posted an embedded video of Lake’s interview with Donald Trump It. where she repeats the false Ballot Size Sabotage and Bogus Ballot Injection claims. The post stated, in part: “WATCH: @KariLake joins @DonaldTrumplr to discuss what really happened in Arizona,” 65. As of June 16, 2023, that post has been ReTruthed 455 times and liked over 2,000 times. 66. Lake’s February 20 Gettr. On February 20, 2023, the @KariLake Gettr account posted a link to a Rumble post cont ing video of Lake’s interview with Donald ‘Trump Jr. where she repeats the false Ballot Size Sabotage and Bogus Ballot Injection -13-claims, The post stated, in part, “We did a deep dive on what really happened in Arizona .. Tune in, You're not going to want to miss it.” 67. As of June 17, 2023, that post has been reposted 140 times and liked 463 times. 68. Lake’s February 22 Podcast. On February 27, 2023, the “LINDELL. REPORT” podeast posted an interview of Lake by Brannon Howse that had been previously recorded on February 22, 2023. During the interview, Lake made the false Ballot Size Sabotage claim, ating: I mean talk about diabolically genius if you want to mess with Election Day . . . .[T]hey did it in a way that was so subtle that the good people of Arizona who showed up to vote on Election Day they wouldn’t even detect it. They made the image on the ballot just a little bit smaller than normal and when that got fed into the tabulator machine the tabulator read it as a paper jam and that’s why a quarter of a million ballots were spit out. 69. On the podcast, Lake also accused Richer of “sabotaging our election day” by “pumping 300,000 invalid ballots in for the count in Arizona. ...” 70. Like the prior interviews, Lake made clear that her false accusations were targeted at Richer: [H]t’s about all voters being disenfranchised intentionally these monsters who run our election at Maricopa County; two men by the name of Stephen Richer and Bill Gates . . . and they’re in charge of the election. 71. Lake’s March 19 Tweet. On March 19, 2023, Lake’s Twitter account, @KariLake, posted an embedded video of the January 30, 2023 press conference, during which she made the false Ballot Size Sabotage claim. The Tweet stated, in part: “This wasn’t an accident. This was the deliberate disenfranchisement of Arizona voters.” In the -14-clip, Lake falsely stated that “Richer and Gates intentionally printed the wrong image on the ballot when they knew 75% of the people showing up were Kari Lake voters . .. . They printed the wrong image on the ballot knowing that that would jam the tabulator.” 72. Asof June 16, 2023, the Tweet had been viewed more than 2.7 million times and retweeted more than 19,100 times, 73. Lake’s March 19 Truth. On March 19, 2023, Lake’s Truth Social account, @KariLake posted an embedded video of the January 30, 2023 press conference during which she made the false Ballot Size Sabotage claim. ‘The post stated, in part: “This wasn’t an accident. This was the deliberate disenfranchisement of Arizona voters.” In the clip, Lake falsely stated that “Richer and Gates intentionally printed the wrong image on the ballot when they knew 75% of the people showing up were K: i Lake voters .... They printed the wrong image on the ballot knowing that that would jam the tabulator ....” 74, As of June 16, 2023, that post has been ReTruthed over 3,720 times and liked over 9,070 times. 75. Lake’s March 19 Gettr. On March 19, 2023, the @KariLake Gettr account posted an embedded video clip of the January 30, 2023 press conference during which she made the false Ballot Size Sabotage claim. The post stated, in part, “This wasn’t an accident. This was the deliberate disenfranchisement of Arizona voters.” In the Lake falsely stated that “Richer and Gates intentionally printed the wrong image on the ballot when they knew 75% of the people showing up were Kari Lake voters .... They printed the wrong image on the ballot knowing that that would jam the tabulator.” <15-76. As of June 17, 2023, that post has been reposted 1,300 times and liked 2,300 times, 71. Lake's April 10 Speech. On or about April 10, 2023, Lake spoke to the Republican Party of San Diego County, California, and she stated: [T]hey intentionally printed the wrong image on the ballot. . . . Everyone knows this, they intentionally printed the wrong image on the ballot, it jammed the machines. . . . This was a disenfranchisement . . .. It was outrageous. And they thought we were going to crawl away from that stolen election .... We're not quitting. ... $o we decided to sue them. 78. Lake named Richer as a defendant in that lawsuit. In the same San Diego speech, Lake also later confirmed that she was accusing “the Republicans running Maricopa County.” Lake was referring to Richer and Gates, and a reasonable listener 79. Lake's April 17 Tweet. On or around April 17, 2023, Lake’s Twitter account, retweeted a post from January 31, 2023, where she implored readers that “[e]very ‘American should watch this video. SHARE!” ‘The Tweet embedded a video of the January 30, 2023 press conference during which she made the false Ballot Size Sabotage claim. 80. As of June 16, 2023, the Tweet had been viewed more than 737,000 times and retweeted more than 10,800 times. 81. Lake’s April 18 Rumble Post. On April 18, 2023, a video of Lake’s San Diego speech with the false Ballot Size Sabotage claim was posted to her Rumble account. As of June 16, 2023, it had been viewed over 20,200 times. 82. Lake’s Rumble post was accompanied by a link asking visitors to “Join our KariLake.com,” a website sponsored by Save Arizona Fund. ote83, Lake's April 18 Truth. On April 18, 2023, Lake’s Truth Social account @KariLake posted an embedded video of Lake’s San Diego speech with the false Ballot Size Sabotage claim. The post stated, in part: “You can watch the rally here!” 84. As of June 16, 2023, that post has been ReTruthed 927 times and liked over 3,690 times. 85. Lake’s April 18 Gettr. On April 18, 2023, the @KariLake Gettr account posted a link to the Rumble post containing a video of Lake’s San Diego speech with the false Ballot Size Sabotage claim. The post stated, in part: “You can watch the rally here!” 86. As of June 17, 2023, that post has been reposted 121 times and liked 485 times. 87. Lake’s April 21 Speech. On April 21, 2023, Lake gave a speech at the True Texas Project Gala, where she stated: “So they sabotaged election day... . [T]hey intentionally printed the wrong image on the ballot, a quarter of a million ballots were spit out, unreadable on election day . . Lake was referring to Richer and Gates, and a reasonable listener would have understood her as referring to them. 88. Lake’s April 30 Twitter Speech. On April 30, 2023, Lake appeared in a Twitter Space hosted by Mario Nawfal, where she accused “the people running Maricopa County who were in charge of our election,” including Richer, of“mess[ing} with the count of more than 2 million” votes. She further stated that Richer and others “mess{ed]” with the election by doing the following: They realize that they couldn’t cheat in some of the other ways that they cheated before so they had to do something as diabolical as intentionally printing the wrong image on the ballot on election day only. They had a 20-inch piece of paper, ballot paper, and they aie10 u 12 13 4 15 16 7 18 19 20 21 22 23 24 25, 26 a7 28 printed a 19-inch ballot rather than the 20-inch image on that ballot and that’s just a slight enough change that the voter would never detect that there was a problem. But you know what did detect a problem? The tabulator machines. ... And that was intentional. » [T]hey knew they couldn’t win . . . and so the only way they win these days is to cheat in elections. 89. As of June 16, 2023, Lake’s appearance on Nawfal’s Twitter Space had 245,000 listeners. The Tweet publicizing the Twitter Space has been viewed 439,700 times and retweeted more than 300 times. 90. Lake's May 4 Rumble Post. On May 4, 2023, a video of Lake’s Texas speech with the false Ballot Size Sabotage claim was posted to her Rumble account. As of June 16, 2023, it has been viewed over 12,300 times. 91. Lake’s Rumble post was accompanied by a link asking visitors to “Join our movement: KariLake.com,” a website sponsored by Save Arizona Fund, 92. Lake's May 4 Truth. On May 4, 2023, Lake's Truth Social account @KariLake posted an embedded video of Lake’s Texas speech with the false Ballot Size Sabotage claim. The post stated, in part: “Watch my speech here!” 93. As of June 16, 2023, that post has been ReTruthed 597 times and liked over 2,440 times. 94, Lake's May 4 Gettr. On May 4, 2023, the @KariLake Gettr account posted a link to the defamatory Rumble post containing a video of Lake’s Texas speech with the false Ballot Size Sabotage claim. The post stated, in part: “Watch my speech here!” 95. As of June 17, 2023, the post has been reposted 72 times and liked 350 times. ate96. Lake's May 16 Twitter Speech. On a May 16, 2023 Twitter Space hosted by Grant Cardone, Lake stated that, in the 2022 general election, “[t]hey intentionally print{ed] the wrong image on the ballots. It’s disgusting what they did to the people.” 97. Lake added one minute later: “they intentionally printed the wrong image on the ballot on Election Day knowing that our voters were showing up on Election Day. They printed a 19-inch image rather than the 20-inch image and that jammed the machines.” 98. Lake then again repeated the claim that “they intentionally printed the wrong, image on the ballot,” and she detailed the purported sabotage. 99. Lake was referring to Richer and Gates, and a reasonable listener would have understood those statements as referring to Richer and Gates. 100. As of June 16, 2023, the Twitter Space had been listened to 4,100 times. The ‘Tweet announcing the Twitter Space had been viewed by more than 86,000 accounts and retweeted 55 times. 101. Lake's May 30 Tweet. On May 30, 2023, Lake’s official Twitter account @KariLake re-published an embedded video of her entire “Save Arizona Rally” from January 29, 2023, repeating the false Ballot Size Sabotage and Bogus Ballot Injection claims. 102. As of June 16, 2023, the Tweet had been viewed more than 75,900 times and retweeted more than 500 times. Defendants’ Defamatory Statements Were Made With Actual Malice 1. Defendants published their statements with knowledge of their falsity or with reckless disregard for the truth -19-103. Defendants’ accusations against Richer are self-evidently false. 104, Ballot Size Sabotage. Defendants? accusations that Richer intentionally set Election Day printers to print a 19-inch ballot image on a 20-inch ballot are false on their face because, under Arizona law, Richer does not have responsibility for Election Day operations, As County Recorder, Richer is responsible for recording public records, maintaining voter files, registering voters, and administ ing the mail voting process in the County. The Maricopa County Board of Supervisors has responsibility for Election Day and “emergency voting”—in-person voting during the weekend before Election Day. 105. Bogus Ballot Injection. Equally fanciful is Defendants’ assertion that Richer “sabotaged” or “stole” the election by unlawfully injecting 300,000 supposedly “illegal” early voting ballots received on Election Day. Lake testified in a declaration submitted in her election contest that the total number of early voting ballots was 298,942. Thus, in claiming that Richer illegally injected approximately 300,000 “illegal,” “invalid,” “phony,” and/or “bogus” early ballots received on Election Day into the final vote count, Lake implied that every early voting ballot that Maricopa County received at voting locations on Election Day 2022 was illegal. 106, Defendants’ accusation that Richer used early voting ballots to “steal” or “sabotage” the election to prevent Lake from winning office is false and illogical. ‘The early vote ballots dropped off on Election Day—the ones the Defendants claim were injected in order to sway the election away from Lake—actually broke in her favor. -20-107. Lake’s election contest—which, on information and belief, the Lake ‘Campaign funded—further confirms that Defendants, at the very least, acted with reckless disregard for the falsity of their accusations. 108, Superior Court Proceedings. The evidence presented during the December 2022 evidentiary hearing in Lake's election contest clearly established the falsity of Defendants’ claims that Richer intentionally sabotaged the 2022 Arizona election by misprinting ballots or injecting 300,000 bogus or unlawful early voting ballots. 109. Maricopa County Election Director Scott Jarrett testified that no 19-inch configuration was programmed into Maricopa’s Election Management System (EMS). 110, Ryan Macias—the former Acting Director of the Voting Systems Testing and Certification Program for the United States Election Assistance Commission—also testified that there was no basis to conclude that there had been intentional sabotage by an lection official, and he rejected the idea that there was any evidence that any printer issues on Election Day were anything other than an accident. 111. Richer testified in that proceeding that he “[aJbsolutely [did] not” do “anything to sabotage the election, the 2022 Election, including some type of activity performed on the printers to make the printers not print correctly.” In his testimony, Richer explained that he is not responsible for Election Day operations, emergency voting, or ballot tabulation: [Richer]: We are not responsible for Election Day operations or emergency voting, which is the weekend before Election Day, or for ballot tabulation. [Lake's Counsel]: All right. And so those responsibilities lie with the Maricopa County Board of Supervisors, correct? ene10 uN 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 [Richer]: That’s correct, and that’s true of all 15 counties. 112, On December 24, 2022, the Superior Court found “nothing to substantiate {Lake’s] claim of intentional misconduct.” ‘The Superior Court explained that Lake had brought forward no witnesses with any personal knowledge of any misconduct and no evidence to support her claim: “Every one of [Lake’s] witnesses—and for that matter, Defendants’ witnesses as well—was asked about any personal knowledge of both intentional misconduct and intentional misconduct directed to impact the 2022 General Election. Every single witness before the Court disclaimed any personal knowledge of such misconduct.” 113. The Superior Court rejected any suggestion by Lake that ballot printing issues caused ballots to be miscounted. It likewise found that Lake had presented “no evidence at Trial” that “voters were tuned away or refused a ballot,” and it found that Lake did not “show by clear and convincing evidence that alleged misconduct surrounding BOD printers influenced the election outcome,” and furthermore that her own expert at trial admitted that any voters whose ballots were affected by printer issues nevertheless had their votes counted. 114, The Superior Court likewise determined that Lake’s allegation of unlawful ballot insertions was implausible, It noted that the testimony of Lake’s primary trial witness was “of limited use” because “ hile [that witness] has not received the Maricopa County Delivery Receipt forms [which she sought through public records requests}—{the witness] knows that these forms do, in fact, exist.”Seewan eon ul 2 13 14 15 16 7 18 19 20 2 22 24 25 26 7 28 115. Court of Appeals Proceedings. On February 16, 2023, the Arizona Court of ‘Appeals aftirmed the Superior Court’s rejection of Lake’s election challenge. 116, The Court of Appeals held that Lake could not demonstrate that the Superior Court’s rejection of her allegation that Maricopa County officials intentionally printed the wrong image on the ballot was clearly erroneous. To the contrary, the Court of Appeals found that “ample evidence supported the superior court’s conclusion that the printer/tabulator issues resulted from mechanical malfunctions that were ultimately remedied.” It observed that Lake’s suggestion that any printer issues caused disenfranchisement “were baseless,” and that her “only purported evidence . . . was, quite simply, sheer speculation,” and that she presented no evidence showing that any ballots went uncounted, 117. The Court of Appeals likewise affirmed the Superior Court’s findings relating to Lake’s Bogus Ballot Injection claim, noting that even if technical chain-of- custody errors had occurred, they would not render the counted votes “illegal.” 118. Supreme Court Proceedings. On March 22, 2023, the Arizona Supreme Court denied review of, among other things, Lake’s petition for review on issues related to her false Ballot Size Sabotage and Bogus Ballot Injection claims. 119. In relevant part, the Arizona Supreme Court noted: “The Court of Appeals aptly resolved these issues, most of which were the subject of evidentiary proceedings in the trial court, and Petitioner’s challenges on these grounds are insufficient to warrant the requested relief under Arizona or federal law.”W 12 13 4 15 16 7 18 19 20 21 22 4 25 26 27 28 120. McGregor Report. In January 2023, the Maricopa County Attomey’s Office retained former Arizona Supreme Court Chief Justice Ruth V. McGregor “to conduct a focused, fact-specific independent review to determine why printers that performed successfully during the primary election evidenced problems during the general election.” 121, On Api 10, 2023, former Chief Justice McGregor and her team of experts issued a 38-page report, finding no basis for Defendants’ claims that mis-sized ballots were used to intentionally interfere with Election Day voting. This independent investigation found that the issues with the printers on Election Day were most likely the result of printers not being able to reliably print a 20-inch ballot image on 100-pound paper under Election Day conditions. 122, On information and belief, Lake was aware of former Chief Justice McGregor’s Report and its findings as of April 15, 2023, if not earlier. I, Defendants had a financial incentive to defame Richer 123, Defendants have made false statements about Richer to raise money. 124, Many of the alleged defamatory statements were accompanied by URLs that, when visited, solicited donations for Save Arizona Fund. See Appendix A, Ex. at Statement Nos. 2, 6, 8, 25, 30. 125, Moreover, Save Arizona Fund’s webpage presently features a 6-minute video of Lake discussing the 2022 election and accusing Richer of intentionally sabotaging the election, 126. The website asks visitors to “donate to support Kari Lake and Save Arizona,” and seeks donations from $25 to $100,000. -24-10 u R 14 15 16 7 18 19 20 2 2 23 24 25 26 27 28 127. On January 7, 2023, Lake sent an email seeking $10 donations for Save Arizona Fund that repeats the false assertion that the tabulator issues evidenced “intentional sabotage” of the election. 128. The next day, Lake sent a mass email stating, in part: “In a short, two-day trial, my team uncovered a treasure trove of evidence proving that the November election ‘was blatantly influenced and disenfranchised Republican voters to help Katie Hobbs win.” ‘The e-mail then repeatedly asks recipients to donate money, including: “Every dollar you give right now buys my team much-needed time to uncover the truth about our rigged election, Can you spare ANYTHING to help me and my team fight for YOU?” 129, On February 9, 2023, Save Arizona Fund paid for the transmission of an email that included a link to the “Save Arizona Rally,” where defamatory statements about Richer were made, and asked for donations.10 u 12 B 4 15 16 7 18 19 20 21 2 23 25 26 7 28 Help Protect the Integrity of Our Elections! 130. On May 23, 2023, Lake Campaign’s official Twitter Account @KariLakeWarRoom posted a Tweet stating that “Your election officials may betray you,” and included a link to Save Arizona Fund’s website, where visitors are solicited to donate money. 131, On information and belief, between December 5, 2022 and December 24, 2022 alone, Lake raised hundreds of thousands of dollars into the Save Arizona Fund. 132. On information and belief, Lake has used funds raised by Save Arizona Fund to help boost her future political ambitions. 133. For example, Save Arizona Fund has paid for campaign events in Iowa where Lake has met with voters. =26-134, ‘That follows a prior pattem where Lake has told her supporters that fundraising money was needed to contest the election, but then spent the money raised on other items, including more than $35,000 on travel and hotel accommodations. Hl. Defendants’ defamatory falsehoods are part of a pre-existing false narrative of stolen elections to which Defendants are committed 135. Lake has shown herself to be committed to a false narrative concerning stolen elections. She has pressed that false narrative in statements related to at least three elections—the 2020 general election, the 2022 primary election, and the 2022 general election—and has a history of stating falsehoods on social media, in speeches, through court filings, and elsewhere to perpetuate that false narrative. 136. Lake has repeatedly made the false public assertion that former President Donald Trump prevailed in the 2020 presidential election. 137. Lake has falsely claimed that the 2020 election was “undeniably STOLEN, CORRUPT and RIGGED” and that “President Trump was the true winner.” Similarly, Lake has stated that “Governor Ducey . . . shouldn’t have certified the 2020 election” because “[e]very indication showed corruption,” and that, if Lake had been Governor, she would not have certified President Biden’s electoral victory because of unspecified “serious irregularities and problems with the election.” 138. Lake likewise built a false narrative that her electoral results would also be rigged. 139, Before the August 2022 primary election, which Lake ultimately won, was even underway, for example, Lake claimed that she “was already detecting some stealing going on” in the election -27-140, Lake also has brought her pre-existing narrative of stolen elections to judicial proceedings. In an April 2022 lawsuit in federal court, Lake sought, among other things, “a preliminary and permanent injunction prohibiting Defendants from requiring or permitting voters to have votes cast or tabulated using any electronic voting system.” ‘The federal district court sed Lake’s case and granted a motion for sanctions against Lake, the other plaintiff in that case, and their counsel. ‘The dismissal is presently on appeal to the United States Court of Appeals for the Ninth Circuit, and the federal district court has held an evidentiary hearing as to the amount of sanctions. 141. Similarly, after losing her election challenge in Arizona Superior Court in December 2022, Lake continued to perpetuate her narrative of a rigged system with false accusations of government malfeasance. For example, @KariLake posted on Truth Social that “{IJegal experts believe [Maricopa County Superior Court Judge Peter A. Thompson’s} decision was ghostwritten, they suspect top left-wing attorneys like Mare El s emailed him what to say.” IV. Defendants’ personal spite against Richer also evidences actual malice 142. Lake and Lake Campaign have a history of directing personal vitriol and spite at Richer. Those additional statements provide further evidence of Defendants’ actual malice. 143. For example, on November 10, 2022, Lake Campaign’s Twitter account posted a photo of Richer and then-governor-elect Katie Hobbs under the message: “They told us to look for the root causes of @MaricopaVote’s election problems. Found them.” 144, Lake has likened Richer to an arsonist and accused him of perjury:Cea .s 10 a 12 = 14 1s 16 17 18 19 20 21 n 2B m4 P| 26 27 28 ‘Geting tips om Stephen Richer about elections inte is he gesting fee soley tps from an arconct {The anything he should do to reform our eleclonss resign immediatly nd epehogie te everyman, woman & chin Azone for is malls incompatence &pery 2 TUB Unee Aeootmee 145. Lake Campaign’s official Twitter account @KariLakeWarRoom also has implied that Richer should be arrested by the sheriff's office: 146. In the past year alone, Lake’s and Lake Campaign’s Twitter accounts have repeatedly targeted Richer and called him an “incompetent, corrupt fool,” a “corrupt moronf],”and a “reprehensible human being.” 147. Lake and Lake Campaign’s Twitter accounts also retweeted an article from far-right conspiracy theorist Laura Loomer instructing readers how to file bar complaints against Richer (which several people did, and the Arizona bar dismissed them all). -29-Defendants’ Barrage Of Defamatory Statements Has Caused Richer Substantial Injuries 148. While Defendants have raised money and benefited from their defamatory falsehoods regarding Richer, they have caused Richer substantial reputational, financial, physical, emotional, and professional harm. 149, These harms flow in part from the widespread vitriol and threats that are directly traceable to Defendants’ defamatory statements. For instance, on January 29, 2023, Lake posted to social media platform Truth Social a video clip of her “Save Arizona Rally,” during which she made the false Ballot Size Sabotage claim, 150. Replies from Truth Social users included: a, “Why aren’t these mother fuckers in jail?!2!? We've seen this time after time. They did it in 2020!!! And God only knows how many other times!! Tam SO done. I don’t even live in AZ. Take them out. Now” “So lock some asses up already what is the hold up people need to pay with their life it’s that simple set an example” ¢. “If that’s proven then someone needs to be dismembered” 151. On January 30, 2023, Lake posted a link to a video of her January 30 Press Conference to Gettr, during which she made the false Ballot Size Sabotage claim. 152. Replies from Gettr users included: a. “Election [sic] fraud is a form of treason and should dealt with as so” -30-10 u 2} 13 4 16 7 18 19 20 2 2 mw 25 7 28 153. On February 20, 2023, Lake posted a link to a video of her podcast interview with Donald Trump Jr. to Gettr, during which she made the false Ballot Size Sabotage and Bogus Ballot Injection claims. 154, Replies from Gettr users included: a. “TREASON=EXECUTION” 155, On March 19, 2023, Lake posted an embedded video on Truth Social of the January 30, 2023 press conference, during which she made the false Ballot Size Sabotage claim. 156. Replies from Truth Social users included: a, “HANG THESE MOTHER FUCKERS!” b. “They need to pay ! Time ! Or Stretch some Rope from an Oak Tree !!!” ¢. “We should hang anyone who steals an election. ‘That would stop it.” 157. On March 19, 2023, Lake posted an embedded video on Gettr of the January 30, 2023 press conference, during which she made the false Ballot Size Sabotage claim, 158. Replies from Gettr users included: a, “ELECTION TREASON MUST BE EXECUTIONABLE! TIME FOR HEADS TO ROLL...LITERALLY! ENOUGH OF THIS BULL-SH!T-VIC NONSENSE!!!” b. “The only way this changes is by going after the Republicans that are blocking we the people. We need to identify and crucify each one.”10 ul R 13 4 15 16 7 18 19 20 2 2 2B m4 25 26 2 28 159. On May 1, 2023, Lake posted the following message to Truth Social: “Stephen Richer & his fellow obstructionists in Maricopa County think that if they stonewall long enough, we're just going to go away. It’s not going to happen. We The People of Arizona will no longer tolerate having to vote in third-world elections.” 160, Replies from Truth Social users included the following: a, “I think your [sic] gonna need to build a public gallows” b, “Hanging in public would be nice ©.” ¢. “Gitmo for treasonous election thieves that have overthrown our legally elected government.” 161. On June 6, 2023, Lake posted to Twitter the following statement she had made during a television interview the previous day, tagging the Maricopa County Elections Department official Twitter account: Itis going to get very uncomfortable for these folks. I’m sure they’re feeling the drumbeat hearing it loud & I hope to god they wake up in the middie of the night, with the terror of what they did to the people, with guilt & shame, because they really should, 162. When a user posted Lake’s Tweet to the discussion board website Patriots. Win, responses included the following: a, “Fuck shame, when do the hangings start?” b. “How about a few of them wake up with nooses around their necks.” c. “They should wake up in the middle of the night with an 8 inch kitchen knife stuck in their chest.” 163. The U.S. Department of Justice has prosecuted at least one person who credibly threatened Richer’s life.u R 13 14 15 16 7 18 19 20 2 2 23 24 25 26 21 28 164. In light of threats to their physical safety caused by Defendants’ defamatory statements, Richer and his wife spent thousands of dollars of their own money installing additional security features at their home. 165. Both the Maricopa County Sheriff's Office and the Phoenix Police Department do regular patrols of Richer’s and his wife’s home and places of work, 166. Richer and his wife have changed their personal and professional routines, aware that people spurred on by Defendants’ falsehoods about the November 2022 election wish to do them harm. 167. Additional security cannot, however, prevent the torrent of vitriol Richer experiences day in and day out, which comes in the form of emails, direct messages on Twitter, voicemails, and even in-person confrontations. 168, Defendants’ defamatory statements have damaged Richer’s reputation by cutting him off from Republican networks and donors who once supported his career and future ambitions for elected office. 169. Predictably, this decline in his career prospects and constant calls for his resignation, prosecution, and even execution have taken a toll on Richer’s physical and ‘mental health and required him to spend time and money on additional medical treatment and medication. 170. Richer’s injuries are traceable to Defendants’ attacks on Richer. Claim 1: Defamation regarding Ballot Size Sabotage (Against All Defendants) 171. Richer incorporates by reference the allegations of the preceding paragraphs and the Appendix as if fully set forth herein, -33-172, Lake made the following defamatory statements of fact accusing Richer of Ballot Size Sabotage, each of which is reproduced in Appendix A: a, Statement at the January 29 Rally (supra {fj 15-21, Appendix A, No. Ds b, Statement in the January 29 Lake Tweet (supra §§ 25-28, Appendix A,No. 2); ¢. Statement in the January 29 Lake Truth (supra ff 29-32, Appendix A, No. 3). d. Statement in the January 29 Lake Gettr (supra §9] 33-36, Appendix A, No.4). e. Statement in the January 30 Rally Rumble Video (supra {f] 41-42, Appendix A, No. 6); f, Statement in the January 30 Press Conference (supra § 43, Appendix A,No. 7); g. Statement in the January 30 Press Conference Rumble Video (supra 144, Appendix A, No. 8); bh, Statement in the January 30 Press Conference Tweet (supra 45, Appendix A, No. 9); i. Statement in the January 30 Press Conference Truth (supra {| 46-47, Appendix A, No. 10); j. Statement in the January 30 Press Conference Gettr (supra § 48-49, Appendix A, No. 11); aahStatement in the February 8 Podcast (supra 4¥] 55-58, Appendix A, No. 15); Statement in the February 20 Podcast (supra $4 59-63, Appendix A, No. 16); Statement in the February 20 Truth (supra 4 64-65, Appendix A, No. 17); Statement in the February 20 Gettr (supra §¥] 66-67, Appendix A, No. 18); Statement in the February 22 Podeast (supra {f| 68-70, Appendix A, No. 19); Statement in the March 19 Tweet (supra $f 71-72, Appendix A, No. 20); Statement in the March 19 Truth (supra §4] 73-74, Appendix A, No. 21); Statement in the March 19 Gettr (supra | 75-76, Appendix A, No. 22), Statement in the April 10 Speech (supra §{{ 77-78, Appendix A, No. 23); Statement in the April 17 Tweet (supra $f 79-80, Appendix A, No. 24); Statement in the April 18 Rumble Post (supra #§ 81-82, Appendix A, No. 25). 35+y. Statement in the April 18 Truth (supra $f 83-84, Appendix A, No. 26). w. Statement in the April 18 Gettr (supra $¥ 85-86, Appendix A, No. 27). x. Statement in the April 21 Speech (supra 4 87, Appendix A, No. 28); y. Statement in the April 30 Twitter Speech (supra f| 88-89, Appendix A, No. 29); z, Statement in the May 4 Rumble Post (supra ff 90-91, Appendix A, No. 30); aa, Statement in the May 4 Truth (supra fj 92-93, Appendix A, No. 31); bb. Statement in the May 4 Gettr (supra $¥ 94-95, Appendix A, No. 32). ce. Statement in the May 16 Twitter Speech (supra $f 96-100, Appendix A,No. 33); dd. Statement in the May 30 Tweet (supra §§ 101-02, Appendix A, No. 34). 173. Lake's statements about Richer were false. 174, Lake made those false and defamatory statements to one or more third person(s) with the knowledge and intent that her statements would be released to the public. 175. Lake's false and defamatory statements accused Richer of, among other things, intentionally sabotaging the 2022 election by intentionally having ballot-on- demand printers print the wrong sized ballot. 176. Lake’s false and defamatory statements damaged Richer, the nature, magnitude, and extent of which will be addressed in discovery and at trial. =36-10 ul 2 13 4 15 16 Ww 18 19 20 21 2 2B 24 25 26 27 28 177. Lake’s false and defamatory statements constituted defamation per se by injuring Richer in his profession, trade, or business and by accusing him of criminal offenses and acts of moral turpitude. 178, Lake published those defamatory statements with actual malice, namely with knowledge of the statements’ falsity and/or with reckless disregard of whether the statements were false or not, as demonstrated by, among other things: a. The publication of the accusation after ithad been disproven in Lake’s election challenge, of which she had knowledge, and in other unbiased and reputable sources, including the McGregor report and public reporting; b. _ Lake’s financial incentive to defame Richer; c. _Lake’s attachment to a preconceived narrative; and/or 4. Lake’s pre-existing personal spite towards Richer. 179. Lake Campaign and Save Arizona Fund are vicariously liable for Lake’s defamatory statements because: a, Lake is an employee, officer, or agent of Lake Campaign and Save Arizona Fund, and b. Lake made the defamatory statements reproduced in Appendix A within the scope of her employment or while acting on behalf of or to benefit Lake Campaign and/or Save Arizona Fund. -37-Claim 2: Defamation regarding Ballot Size Sabotage (Against Lake Campaign) 180. Richer incorporates by reference the allegations of the preceding paragraphs and the Appendix as if fully set forth herein. 181. Lake Campaign made the following defamatory statements of fact accusing Richer of Ballot Size Sabotage, each of which is also reproduced in Appendix A: a. Statement in the January 29 @KariLakeWarRoom Tweet (supra 4937-40, Appendix A, No. 5); b. Statement in the January 31 @KariLakeWarRoom Tweet (supra 1153-54, Appendix A, No. 14); 182. Lake Campaign’s statements were false. 183. Lake Campaign made those false and defamatory statements to one or more third person(s) with the knowledge and intent that its statements would be released to the public, 184, Lake Campaign’s false and defamatory statements accused Richer of, among other things, intentionally sabotaging the 2022 election by intentionally having ballot-on- demand printers print the wrong sized ballot. 185. Lake Campaign’s false and defamatory statements damaged Richer, the nature, magnitude, and extent of which will be addressed in discovery and at trial. 186. Lake Campaign’s false and defamatory statements constituted defamation per se by injuring Richer in his profession, trade, or business and by accusing him of criminal offenses and acts of moral turpitude. =38-187. Lake Campaign published those defamatory statements with actual m: namely with knowledge of the statements” falsity and/or with reckless disregard of whether the statements were false or not, as demonstrated by, among other things: a. The publication of the accusation after it had been di roven in Lake’s election challenge, of which Lake Campaign had knowledge, and in other unbiased and reputable sources; b. Lake Campaign’s financial incentive to defame Richer; c. Lake Campaign’s attachment to a preconceived narrative; and/or 4. Lake Campaign’s pre-existing spite towards Richer im 3: Defamation regarding Ballot Size otage (Against Save Arizona Fund) 188. Richer incorporates by reference the allegations of the preceding paragraphs and the Appendix as if fully set forth herein. 189. Save Arizona Fund made the following defamatory statement of fact accusing Richer of Ballot Size Sabotage, which is also reproduced in Appendix A: a, Statement in the January 30 “Save Arizona Rally (1/29/2023): Printed Wrong Image on Ballots” YouTube video (supra 50-51, Appendix A,No. 12); 190. Save Arizona Fund’s statement about Richer was false. 191. Save Arizona Fund made that false and defamatory statement to one or more third person(s) with the knowledge and intent that its statements would be released to the public. -39-192. Save Arizona Fund’s false and defamatory statement accused Richer of, among other things, intentionally sabotaging the 2022 election by intentionally having ballot-on-demand printers print the wrong sized ballot. 193. Save Arizona Fund’s false and defamatory statement damaged Richer, the nature, magnitude, and extent of which will be addressed in discovery and at trial, 194. Save Arizona Fund’s false and defamatory statement constituted defamation per se by injuring Richer in his profession, trade, or business and by accusing him of criminal offenses and acts of moral turpitude. 195. Save Arizona Fund published that defamatory statement with actual malice, namely with knowledge of the statement’s falsity and/or with reckless disregard of whether the statement was false or not, as demonstrated by, among other things: a. The publication of the accusation after it had been disproven in Lake’s election challenge, of which Save Arizona Fund had knowledge, and in other unbiased and reputable source: including public reporting; b. Save Arizona Fund’s financial incentive to defame Richer; and/or c. Save Arizona Funds attachment to a preconceived narrative. ing Bogus Ballot Injection (Against All Defendants) 196, Richer incorporates by reference the allegations of the preceding paragraphs and the Appendix as if fully set forth herein. 197. Lake made the following defamatory statements of fact accusing Richer of Bogus Ballot Injection, each of wl is also reproduced in Appendix A: -40-im 2 13 14 15 16 7 18 19 20 au 22 24 28 26 7 28 198. 199, Statement at the January 29 Rally (supra §9 15-21, Appendix A, No. Ds Statement in the January 30 Rumble Video (supra §€ 41-42, Appendix A,No. 6); Statement in the February 8 Podcast (supra 49] 55-58, Appendix A, No. 15); Statement in the February 20 Podcast (supra $f] 59-63, Appendix A, No. 16); Statement in the February 20 Truth (supra 4 64-65, Appendix A, No. 1); Statement in the February 20 Gettr (supra $f 66-67, Appendix A, No. 18); Statement in the February 22 Podeast (supra 68-70, Appendix A, No. 19); Statement in the May 30 Tweet (supra §{ 101-02, Appendix A, No. 34), Lake’s statements about Richer were false. Lake made those false and defamatory statements to a third person with the knowledge and intent that her statements would be released to the public. 200. Lake’s false and defamatory statements accused Richer of, among other things, intentionally sabotaging the 2022 election by injecting 300,000 illegal ballots into the final vote tally for Maricopa County, Arizona, -41-201. Lake’s false and defamatory statements damaged Richer, the nature, magnitude, and extent of which will be addressed in discovery and at trial. 202. Lake’s false and defamatory statements constituted defamation per se by injuring Richer in his profession, trade, or business and by accusing him of criminal offenses and acts of moral turpitude, 203. Lake published those defamatory statements with actual malice, namely with knowledge of the statements’ falsity and/or with reckless disregard of whether the statements were false or not, as demonstrated by, among other things: a. Thepublication of the accusation after ithad been disproven in Lake’s election challenge, of which she had knowledge, and in other unbiased and reputable sources, including public reporting; b. Lake's financial incentive to defame Richer; c. _ Lake’s attachment to a preconceived narrative; and/or 4. Lake’s pre-existing personal spite towards Richer. 204. Lake Campaign and Save Arizona Fund are vicariously liable for Lake’s defamatory statements because: a, Lake is an employee, officer, or agent of Lake Campaign and Save Arizona Fund, and Lake made the defamatory statements reproduced in Appendix A within the scope of her employment or while acting on behalf of or to benefit Lake Campaign and/or Save Arizona Fund. -42-wk wn 10 12 13 14 15 16 7 18 19 20 21 22 m4 25 26 ry Claim 5: Defamation regarding Bogus Ballot Injection (Against Save Arizona Fund) 205. Richer incorporates by reference the allegations of the preceding paragraphs and the Appendix as if fully set forth herein, 206. Save Arizona Fund made the following defamatory statement of fact accusing Richer of Bogus Ballot Injection, which is also reproduced in Appendix A: a, Statement in the January 30 “Save Arizona Rally (1/29/2023): Chain of Custody” YouTube video (supra 52, Appendix A, No. 13); 207. Save Arizona Fund’s statement about Richer was false. 208. Save Arizona Fund made that false and defamatory statement to one or more third person(s) with the knowledge and intent that its statements would be released to the public. 209. Save Arizona Fund’s false and defamatory statement accused Richer of, among other things, intentionally sabotaging the 2022 election by injecting 300,000 illegal ballots into the final vote tally for Maricopa County, Arizona, 210. Save Arizona Fund’s false and defamatory statement damaged Richer, the nature, magnitude, and extent of which will be addressed in discovery and at trial. 211. Save Arizona Fund’s false and defamatory statement constituted defamation per se by injuring Richer in his profession, trade, or business and by accusing him of criminal offenses and acts of moral turpitude. 212. Save Arizona Fund published that defamatory statement with actual malice, namely with knowledge of the statement’s falsity and/or with reckless disregard of whether the statement was false or not, as demonstrated by, among other things: -43-a, The publication of the accusation after ithad been disproven in Lake’s election challenge, of which Save Arizona Fund had knowledge, and in other unbiased and reputable sources, including public reporting: b, Save Arizona Fund’s financial incentive to defame Richer; and/or €. Save Arizona Fund’s attachment to a preconceived narrative. PRAYER FOR RELIEF Richer prays for relief as follows: A. Nominal damags B. Compensatory damages, including general, actual, pecuniary, consequential, and special damages, in an amount to be determined at trial; Punitive damages; D. Reasonable and necessary attorneys’ fees; E. Reasonable and necessary costs of suit; Prejudgment and post-judgment interest at the highest lawful rates; G. Declaratory relief stating that the defamatory statements authored, published, and otherwise made by the defendants identified within this complaint, individually and collectively, were and are false; H. _Injunctive relief enjoining Defendants to remove the false and defamatory portions of the statements about Richer from any website and/or social media accounts under their control or under the control of parties in pri ity with Defendants; and I. Such other and further relief as this Court deems just and appropriate. -44-Jury Demand Richer demands a jury trial of all issues so triable. DATED this 22nd day of June, 2023. MAYNARD CRONIN ERICKSON & CURRAN, P.L.C. By: _/s/Daniel D. Maynard Daniel D. Maynard Douglas C. Erickson 3200 N. Central Avenue, Ste. 1800 Phoenix, Arizona 85012 Brandon L. Amold (pro hae vice forthcoming) Lauren Cassady Andrews (pro hac vice forthcoming) Chloe C. Bootstaylor (pro hac vice forthcoming) KRAMER LEVIN NAFTALIS & FRANKEL LLP 2000 K Street NW, 4th Floor Washington, DC 20006 Tel: (202) 775-4500 bamold@kramerlevin.com Tandrews(alermerlevin.com cbootstaylor@kramerlevin.com David M. Alexander (pro hac vice forthcoming) KRAMER LEVIN NAFTALIS & FRANKEL LLP 1177 Avenue of the Americas New York, NY 10036 Tel: (212) 715-9100 dalexander@kramerlevin.com Anne Harden Tindall (pro hae vice forthcoming) ‘Cameron O. Kistler (pro hae vice forthcoming) PROTECT DEMOCRACY PROJECT 2020 Pennsylvania Avenue NW, #163 Washington, DC 20006 Tel: (202) 579-4582 anne.tindall@protectdemocracy.or; cameron. kistler@protectdemocracy.org, Benjamin Berwick (pro hac vice forthcoming) PROTECT DEMOCRACY PROJECT 15 Main Sireet, Suite 312 Watertown, MA 02472 Tel: (202) $79-4582 -45-wk we 10 12 13 4 15 16 7 18 19 20 21 23 24 25 26 28 ben.berwick@protectdemocracy.org Jared Davidson (pro hac vice forthcoming) PROTECT DEMOCRACY PROJECT 3014 Dauphine Street, Suite J New Orleans, LA 70117 Tel: (202) 579-4582 jared.davidson@)protectdemocracy.org Laurence M. Schwartztol (pro hae vice forthcoming) DEMOCRACY AND RULE OF LAW CLINIC Harvard Law School 1525 Massachusetts Avenue Cambridge, MA 02138 Tel: (617) 998-1877 Ischwartztol@law.harvard.edu 6.aoRUaTU} pINOM SIo|TE4 980) two roj]eq 2tp wo afew Suosm ue Jo4ory puy “wede J0A0 pue s9A0 sno yds 08 Ady ‘mo yds x08 sro “Keq won?2Iq Yo Sep He pouaddey reyss Ajioexe s1 yorym ‘ioqqeq Ino (uo ayp Kuo yp “mou no, pap Sau, pauadey eH, “Buo| Kop ye we pmo sxoVeInger ou 0 ojleg ou uo aBeus Suoum ayn ‘aBeUUL You ue patutsd mara statp pur Saye) pue J3YR “pur sagprt ng 064 YOU v UO aR ‘ie wuozssy -0@ ¥ one 1 posodkns oom sous oH SNL, | enes—Wooeds | ezrecrt| 1 siuouisieis evopppy | _vonsefarsiomrestsnog 2x swswayeAS aBeoqes as ona a1 swuswiayes| _woyeonana | ayea| “ON y xIGNadav“(nd 076 ‘€202 ‘67 ‘Ues) [eS “Na 61:6 “€z07 “62 “UeL) >I (oye TEND) 241 WEN ¢ TUE) ET WEN svoyeynges aun veyp 05 “ojfeq a UO ‘eum Buon a ‘oBeU YOUIR6 | paruad 219 sotp pe ‘sayep pure ‘oy yep ose ano uy poxoxd _pouodday oy po0x9 pease peppeqt a spa potod De THAD = 190 suet uv ‘zesoyeaiq@) 7 “soyory_weydars@, 390KL Jo dio o2pua. pappaquua um api pas v parsod ccrald cuoysafuy sjoneg snSog ax suamayeis aBejoqus 97 o1rea 24 sIuOMIIIENS wopeanand awa oe€ TSO Na 1-01 “$20 “67 Wer) sOMEALL “{HOYsE MOE TOAD) eUOZLAY 40} OCT ED ‘BION LA SOA MOS INAH SAN “Wd O76 “EO ‘67 Ue) MAD {OAETHEAD) aT WEN ¢ coe Huo] pouBisou avy pjnom oxy AysBayur go 20uno ue pey Aoup Jf “shojfeq Ut gz Uo SafeUT UT {61 tuud on sauryaeu axp pauourefoxd Kou os ‘kop ‘ured uo dn moys pino% si2I04 8,246 TED) Jo wooys sa1ep pu 4st wou Kany, op uoR29[9 paBeoges sUaop> | eye TOO yor 30 oroud papnyour s29MA1 ‘om asou ‘esensuG® wsoyory waydass®.,| — —soum| exioz| (6si0-sz:0) 2" wel pinom aug yoxp 0s suonejnges aun Sw STH “(90°0-00:0) «01rea Are sont on panes ftp Hunn ‘4p vo oBeun Suowss axp poyud éetonuDyut uozuy au, °° 3 sono oF sm ‘yp wip 2869 0 w panoud'™, :oapi, | 2888 9 ayy "> Bu} Kop yo wel pINos 40 dio copia suoygnge ayn ep OS Yo} 319 UO _cpoueddey yeys Sp9ex9 8.704), Buo} Sep] pappoquie oun Buns a¢p “aBeUU YU 61 re wet pjnom sxorenge ay req 05 “sojeq amp wo | —_-ue parsod - panutd soso sop pus ‘sane pur aBour Buon ayy ‘aFeun wi-g1 e parwud walosap | aye THAD 497 “PU JOULE O9PLA ue ‘soreg st “ow Uat dans, 804 9 =mep| ewer | syuawayeys jeuomrppy | _wonsaluy sionvs sndog 94 syuaWa,EIS aBejoqus o715 youteg ax syuowayeis | _wopeanang| _aeq| “ON, STATION TTT SAY (CoO “Oe “wer a|quimy py BUORLY aaDs 5, YT LH YIM ET WEN (acer) “By0Ws ‘ys wos 2307] puryag wa919s to paseydtp sux Sovep TE pu apt aydays Jo oy :09pt, cezrorly) :ye10} yeu o4p ut parunoo azoM ‘Sporsno ps PUEIsapUun ,uop Oya NOK Jo soy 403 “Apoisn Jo ureup pyre] S014 000'00¢ "Tip soxoud xpoqumy we usp ‘samo|gopstya ano wou uous USiS-ZEizs) « BUyAL we pood seas a, camp ‘mo pumgy Ting suonsafe Ferns ye ofgusoy iypau ‘Sear are s&n asamp faq °° Suoreinger ‘9p Jo 3no yds og Ayfeuonuaruy pynow sio|feq ‘Azojes story Sed am ‘wou om ‘sau, "UoUl OM 2594) “UIVBe OMY OSH MOUS 5.19] ‘sap pur sayory puy “°° -Aeq{ uons9fg uo Aep Ire pauaddey yey Spioexe st yoru? aud pue wef pynor Koup yeu 0s storelnger amp sean stip 2onou ot paruens dau Bump Auo amp ‘uossod yuo omy Squo arp “moury nox-gu oxy OU MOU, nO, "If eonow oF sn EA ,upIp AOU, “SINR 2on0u ‘oy sn juss ou pyp ays, “pausddey yey peo “eto eq eipau oyu! 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