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Breaking: IPOB Sues Ivan Sascha Sheehan Over Washington Times Publication

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 Breaking Information: IPOB Sues Ivan Sascha Sheehan Over Washington Instances Publication The management of the Indigenous Individuals of Biafra (IPOB), ha…

Breaking Information: IPOB Sues Ivan Sascha Sheehan Over Washington Instances Publication

The management of the Indigenous Individuals of Biafra (IPOB), has formally sued Professor Ivan Sascha Sheehan, in a District Courtroom of Columbia, United States of America. IPOB, a effectively registered group and a globally acclaimed largest Indigenous mass freedom motion with sturdy presence in over 100 (100) international locations, found a latest Washington Instances Publication as not simply ridiculous however grievously malicious and defamatory.

The Government Director of the Faculty of Public and Worldwide Affairs on the College of Baltimore, United States of America, Professor Ivan Sascha Sheehan, had in a Washington Instances printed article, described the Indigenous Individuals of Biafra (IPOB), as “A Small African Terrorist Group”, which is a openly compromised opinion of hate with completely no iota of reality.

Whereas giving response to this provocative and grossly deceptive publication titled: “USA Ignores Small African Terrorist Group – IPOB, At Its Peril”, IPOB has unambiguously acknowledged that the printed Opinion utterly smacks of defamation in each customary. Professor Ivan Sascha Sheehan accused IPOB of violent crimes together with killing of kids.

The swimsuit was initiated and filed by the Group’s Worldwide Authorized Counsel, Professor Bruce Fein and was obtained by Household Writers Press Worldwide.

The swimsuit doc reads: –

Bruce Fein (D.C. Bar No. 446615)

FEIN & DELVALLE PLLC

Legal professional for Plaintiffs

________________________________________________________________

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

INDIGENOUS PEOPLE OF BIAFRA,

a UK registered Group Curiosity Firm,

160 London Highway Barking IG11 8BB,

London, United Kingdom,

Plaintiff CASE NO:

v.

IVAN SASCHA SHEEHAN,

College of Baltimore, Baltimore,’

Maryland, UNIVERSITY OF BALTIMORE,

1420 N. Charles Avenue, Baltimore, Maryland, and

The Washington Instances LLC, 3600 New York Avenue, NE

Washington, D.C. 20002

Defendant.

___________________________________________________________________

COMPLAINT FOR DEFAMATION

Comes now Plaintiff, Indigenous Individuals of Biafra (IPOB), via its undersigned

legal professional, and recordsdata this Criticism for defamation searching for, amongst different issues, compensatory and

punitive damages. Plaintiff states as follows.

SUBJECT MATTER JURISDICTION

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 1 of 20

1. This Courtroom possesses material jurisdiction over Plaintiff’s claims underneath 28

U.S.C. 1332 as a result of the quantity in controversy exceeds $75,000, IPOB is a citizen of

the UK, and Defendants Sheehan and the College of Baltimore are

residents of Maryland and Defendant The Washington Instances LLC is a citizen of the

District of Columbia.

PERSONAL JURISDICTION

2. This Courtroom possesses private jurisdiction over Defendants underneath the District of

Columbia Lengthy-Arm Statute, D.C. Code part 13-423 (a) (3) by inflicting tortious

damage within the District of Columbia by a defamatory publication within the District of

Columbia.

VENUE

3. Venue is correct on this Courtroom underneath 28 U.S.C. 1391 (b) (2) as a result of the occasions that gave

rise to Plaintiff’s defamation claims occurred within the District of Columbia.

PARTIES

4. Plaintiff, Indigenous Individuals of Biafra (IPOB) is a UK registered Group Curiosity

Firm headquartered in London, United Kingdom. IPOB’s paramount mission is

to safe a sovereignty referendum on Biafra to be organized and performed by the

United Nations by peaceable means. IPOB’s chief is Mazi Nnamdi Kanu. At current,

he’s underneath unlawful detention by the Federal Authorities of Nigeria (FGN). Amongst

different issues, Nnamdi Kanu, a UK citizen, has been counterfactually charged with

treason, i.e., levying conflict in opposition to Nigeria based mostly on historic radio broadcasts from

London which studiously shunned encouraging or inciting violence in favor of

peaceable protests protected by freedom of speech and affiliation.

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 2 of 20

5. Defendant Ivan Sascha Sheehan is the manager director of the Faculty of Public and

Worldwide Affairs on the College of Baltimore. On data and perception,

Defendant Sheehan is an unregistered overseas agent of the Federal Authorities of

Nigeria in violation of the International Brokers Registration Act.

6.Defendant College of Baltimore employs Defendant Sheehan. On data and

perception, Defendant College of Baltimore is an unregistered overseas agent of the

Federal Authorities of Nigeria in violation of the International Brokers Registration Act.

7.Defendant The Washington Instances LLC is a newspaper firm printed in

Washington, D.C. answerable for publishing Defendant Sheehan’s 7 defamatory

falsehoods about Plaintiff IPOB in conspiracy with the FGN as alleged hereafter

STATEMENT OF FACTS

8. On or about Monday, October 4, 2021, Defendant Sheehan printed in The

Washington Instances an “ANALYSIS/OPINION” defamatory article headlined “U/S/ ignores

small African terrorist group IPOB at its peril.”

9. The article contained a number of defamatory falsehoods about Plaintiff IPOB

printed with sick will and with information of their falsity or with reckless disregard of

whether or not they had been true or not.

10. Defamatory falsehood no 1 asserted “An African terrorist group

[IPOB] is suing U.S. Secretary of State Antony Blinken….” IPOB just isn’t a terrorist

group underneath U.S. regulation or any regulation of a overseas nation aside from Nigeria. IPOB’s

designation as terrorist group in Nigeria was made through a judicial edict with no listening to

or due course of. IPOB opposes violence. It helps an impartial Biafran sovereignty by

peaceable means. At current, the Federal Republic of Nigeria is engaged in an ongoing

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 3 of 20

genocide of Biafrans. Terrorist organizations make use of illegal violence in opposition to civilians to

advance political targets. IPOB doesn’t.

11. Defamatory falsehood quantity 2 asserted, in context, that IPOB deserves itemizing as

a overseas terrorist group by the Secretary of State pursuant to part 219 of the

Immigration and Nationality Act: “The violent secessionist group in query—the

Indigenous Individuals of Biafra (IPOB)—is but to be designated as a International Terrorist

Group by the US Division of State.” Amongst different issues, an FTO itemizing requires

proof that the group engages in premeditated politically motivated violence in opposition to

civilians or noncombatants. See 22 U.S.C. 2656f(d)(2); 8 U.S.C. 1182 (a) (3) (B). IPOB

doesn’t interact in politically motivated violence in opposition to civilians or noncombatants or

in any other case and doesn’t qualify for itemizing as an FTO underneath the legal guidelines of the US.

12. Defamatory falsehood quantity 3, in context, asserted that IPOB chief Nnamdi

Kanu helps terrorism: “That [Nnamdi Kanu] feels no have to even disguise his assist

for terrorism is worrisome.” However Nnamdi Kanu opposes terrorism. It’s the Federal

Authorities of Nigeria that every day practices terrorism in opposition to Biafrans.

13. Defamatory falsehood quantity 4, in context, asserted that since December 2020,

IPOB has engaged in violent and escalating assaults on each Nigerian safety personnel and

civilians: “Since then [December 2020] violent IPOB assaults on each safety personnel and

civilians have surged by a terrifying 59%, deaths by 344%.”

14. Actually, IPOB refrains from the usage of power besides in self-defense. IPOB has not

attacked both safety personnel or civilians since December 2020 or in any other case.

15. Defamatory falsehood quantity 5, in context, accused IPOB of killing the Fulani

and inciting homicide of any one who rents or offers lodging to a Fulani:

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 4 of 20

“Via Radio Biafra, IPOB repeatedly calls on its supporters to not solely kill the Fulani, however

to kill ‘any landlord that offers lodging or rents his home or her home to a Fulani

particular person.”

16. Actually, IPOB doesn’t name on supporters to kill the Fulani. Neither does IPOB

name on its supporters to kill landlords that hire to the Fulani.

17. Defamatory falsehood quantity 6, in context, accuses IPOB of butchering six

younger Fulani kids with machetes, burning a child alive, and discarding the corpses in

mass graves: “In a single latest [IPOB] assault on a Fulani neighborhood, six younger kids

had been butchered with machetes—one, a child, was burned alive. Their our bodies had been

discarded in mass graves.”

18. Actually, IPOB didn’t kill younger Fulani kids, didn’t burn a child alive, and

didn’t bury the putative corpses in mass graves.

19. Defamatory falsehood quantity 7, in context, accuses IPOB of resorting to threats

and violence to coerce politicians and civilians to give up to its political calls for:

“Whether or not with threats made on Biafra Radio or repeated acts of violence, IPOB coerces

politicians and civilians to acquiesce to its radical political calls for.”

20. Actually, IPOB refrains from threats or violence or coercion in its political actions,

that are peaceable and guarded by the universally protected rights of free speech or

affiliation underneath worldwide regulation.

21. Defamatory falsehoods 1-7 all falsely accuse IPOB of crimes of violence, together with

terrorism, that are per se defamatory.

22. On data and perception, Defendant Sheehan conspired with the Federal

Authorities of Nigeria (FRN) to jot down and publish the 7 defamatory falsehoods in

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 5 of 20

alternate for a financial fee or one thing of fabric worth from the FRN as a

reward.

23. On data and perception, the Defendant College of Baltimore conspired with

Defendant Sheehan and the FRN to have Defendant Sheehan’s 7 defamatory

falsehoods printed referencing his capability as the manager director of the Faculty

of Public and Worldwide Affairs on the College of Baltimore in alternate for

cash or something of worth from the FGN.

24. On data and perception, Defendant The Washington Instances LLC printed

Defendant Sheehan’s 7 defamatory, polemical, and counterfactual falsehoods in

alternate for cash or something of fabric worth from the FGN. The clear

excessive bias in Defendant Sheehan’s article and the clumsy, amateurish fashion are far

under the customary publication requirements of The Washington Instances LLC.

25. Defamatory falsehoods 1-7 all accused Plaintiff IPOB of complicity in crimes of

violence that are defamatory per se.

26. The intent and impact of defamatory falsehoods 1-7 subjected IPOB to skilled

and social ostracism and curtailment of its means to draw members and donations.

COUNT 1-DEFAMATION-DEFENDANT SHEEHAN

27. Plaintiff realleges paragraphs 1-26 as if alleged herein.

28. Defamatory falsehood no 1 was printed by Defendant Sheehan with

information of its falsity or with reckless disregard of whether or not it was true or not, and

with spite or ill-will.

29. Defamatory falsehood no 1 has proximately brought about injury to Plaintiff’s

repute in an quantity to be confirmed at trial.

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 6 of 20

30. Defamatory falsehood no 1 was printed with ill-will or spite by Defendant

Sheehan justifying an award of punitive damages.

COUNT 2-DEFAMATION-DEFENDANT SHEEHAN

31. Plaintiff realleges paragraphs 1-30 as if alleged herein.

32. Defamatory falsehood quantity 2 was printed by Defendant Sheehan with

information of its falsity or with reckless disregard of whether or not it was true or not, and

with spite or ill-will.

33. Defamatory falsehood quantity 2 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

34. Defamatory falsehood quantity 2 was printed with ill-will or spite by Defendant

Sheehan justifying an award of punitive damages.

COUNT 3-DEFAMATION-DEFENDANT SHEEHAN

35. Plaintiff realleges paragraphs 1-34 as if alleged herein.

36. Defamatory falsehood quantity 3 was printed by Defendant Sheehan with

information of its falsity or with reckless disregard of whether or not it was true or not, and

with spite or ill-will.

37. Defamatory falsehood quantity 3 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

38. Defamatory falsehood quantity 3 was printed with ill-will or spite by Defendant

Sheehan justifying an award of punitive damages.

COUNT 4-DEFAMATION-DEFENDANT SHEEHAN

39. Plaintiff realleges paragraphs 1-38 as if alleged herein.

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 7 of 20

40. Defamatory falsehood quantity 4 was printed by Defendant Sheehan with

information of its falsity or with reckless disregard of whether or not it was true or not, and

with spite or ill-will.

41. Defamatory falsehood quantity 4 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

42. Defamatory falsehood quantity 4 was printed with ill-will or spite by Defendant

Sheehan justifying an award of punitive damages.

COUNT 5-DEFAMATION-DEFENDANT SHEEHAN

43. Plaintiff realleges paragraphs 1-42 as if alleged herein.

44. Defamatory falsehood quantity 5 was printed by Defendant Sheehan with

information of its falsity or with reckless disregard of whether or not it was true or not, and

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with spite or ill-will.

45. Defamatory falsehood quantity 5 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

46. Defamatory falsehood quantity 5 was printed with ill-will or spite by Defendant

Sheehan justifying an award of punitive damages.

COUNT 6-DEFAMATION-DEFENDANT SHEEHAN

47. Plaintiff realleges paragraphs 1-46 as if alleged herein.

48. Defamatory falsehood quantity 6 was printed by Defendant Sheehan with

information of its falsity or with reckless disregard of whether or not it was true or not, and

with spite or ill-will.

49. Defamatory falsehood quantity 6 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 8 of 20

50. Defamatory falsehood quantity 6 was printed with ill-will or spite by Defendant

Sheehan justifying an award of punitive damages.

COUNT 7-DEFAMATION-DEFENDANT SHEEHAN

51. Plaintiff realleges paragraphs 1-50 as if alleged herein.

52. Defamatory falsehood quantity 7 was printed by Defendant Sheehan with

information of its falsity or with reckless disregard of whether or not it was true or not, and

with spite or ill-will.

53. Defamatory falsehood quantity 7 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

54. Defamatory falsehood quantity 7 was printed with ill-will or spite by Defendant

Sheehan justifying an award of punitive damages.

COUNT 8-DEFAMATION-DEFENDANT THE WASHINGTON TIMES

55. Plaintiff realleges paragraphs 1-54 as if alleged herein.

56. Defamatory falsehood no 1 was printed by Defendant The Washington Instances

with information of its falsity or with reckless disregard of whether or not it was true or not,

and with spite or ill-will.

57. Defamatory falsehood no 1 has proximately brought about injury to Plaintiff’s

repute in an quantity to be confirmed at trial.

58. Defamatory falsehood no 1 was printed with ill-will or spite by Defendant

The Washington Instances justifying an award of punitive damages.

COUNT 9-DEFAMATION-DEFENDANT THE WASHINGTON TIMES

59. Plaintiff realleges paragraphs 1-58 as if alleged herein.

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 9 of 20

60. Defamatory falsehood quantity 2 was printed by Defendant The Washington Instances

with information of its falsity or with reckless disregard of whether or not it was true or not,

and with spite or ill-will.

61. Defamatory falsehood quantity 2 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

62. Defamatory falsehood quantity 2 was printed with ill-will or spite by Defendant

The Washington Instances justifying an award of punitive damages.

COUNT 10-DEFAMATION-DEFENDANT THE WASHINGTON TIMES

63. Plaintiff realleges paragraphs 1-62 as if alleged herein.

64. Defamatory falsehood quantity 3 was printed by Defendant The Washington Instances

LLC with information of its falsity or with reckless disregard of whether or not it was true or

not, and with spite or ill-will.

65. Defamatory falsehood quantity 3 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

66. Defamatory falsehood quantity 3 was printed with ill-will or spite by Defendant

The Washington Instances LLC justifying an award of punitive damages.

COUNT 11-DEFAMATION-DEFENDANT THE WASHINGTON TIMES

67. Plaintiff realleges paragraphs 1-66 as if alleged herein.

68. Defamatory falsehood quantity 4 was printed by Defendant The Washington Instances

LLC with information of its falsity or with reckless disregard of whether or not it was true or

not, and with spite or ill-will.

69. Defamatory falsehood quantity 4 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 10 of 20

70. Defamatory falsehood quantity 4 was printed with ill-will or spite by Defendant

The Washington Instances LLC justifying an award of punitive damages.

COUNT 12-DEFAMATION-DEFENDANT THE WASHINGTON TIMES

71. Plaintiff realleges paragraphs 1-70 as if alleged herein.

72. Defamatory falsehood quantity 5 was printed by Defendant The Washington Instances

LLC with information of its falsity or with reckless disregard of whether or not it was true or

not, and with spite or ill-will.

73. Defamatory falsehood quantity 5 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

74. Defamatory falsehood quantity 5 was printed with ill-will or spite by Defendant

The Washington Instances LLC justifying an award of punitive damages.

COUNT 13-DEFAMATION-DEFENDANT THE WASHINGTON TIMES

75. Plaintiff realleges paragraphs 1-74 as if alleged herein.

76. Defamatory falsehood quantity 6 was printed by Defendant The Washington Instances

LLC with information of its falsity or with reckless disregard of whether or not it was true or

not, and with spite or ill-will.

77. Defamatory falsehood quantity 6 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

78. Defamatory falsehood quantity 6 was printed with ill-will or spite by Defendant

The Washington Instances LLC justifying an award of punitive damages.

COUNT 14-DEFAMATION-DEFENDANT THE WASHINGTON TIMES

79. Plaintiff realleges paragraphs 1-78 as if alleged herein.

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 11 of 20

80. Defamatory falsehood quantity 7 was printed by Defendant The Washington Instances

LLC with information of its falsity or with reckless disregard of whether or not it was true or

not, and with spite or ill-will.

81. Defamatory falsehood quantity 7 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

82. Defamatory falsehood quantity 7 was printed with ill-will or spite by Defendant

The Washington Instances LLC justifying an award of punitive damages.

COUNT 15-DEFAMATION-DEFENDANT UNIVERSITY OF BALTIMORE

83. Plaintiff realleges paragraphs 1-82 as if alleged herein.

84. Defamatory falsehood no 1 was printed in conspiracy between by Defendant

Sheehan and Defendant College of Baltimore with information by each of its falsity

or with reckless disregard of whether or not it was true or not, and with spite or ill-will.

85. Defamatory falsehood no 1 has proximately brought about injury to Plaintiff’s

repute in an quantity to be confirmed at trial.

86. Defamatory falsehood no 1 was printed with ill-will or spite in conspiracy

between Defendant Sheehan and Defendant College of Baltimore justifying an

award of punitive damages in opposition to Defendant College of Baltimore.

COUNT 16-DEFAMATION-DEFENDANT UNIVERSITY OF BALTIMORE

87. Plaintiff realleges paragraphs 1-86as if alleged herein.

88. Defamatory falsehood quantity 2 was printed by Defendant Sheehan in conspiracy

with Defendant College of Baltimore with each having information of its falsity or

with reckless disregard of whether or not it was true or not, and with spite or ill-will.

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 12 of 20

89. Defamatory falsehood quantity 2 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

90. Defamatory falsehood quantity 2 was printed with ill-will or spite in conspiracy

between the College of Baltimore and Defendant Sheehan justifying an award of

punitive damages in opposition to the College of Baltimore.

COUNT 17-DEFAMATION-DEFENDANT UNIVERSITY OF BALTIMORE

91. Plaintiff realleges paragraphs 1-90 as if alleged herein.

92. Defamatory falsehood quantity 3 was printed by Defendant Sheehan in conspiracy

with Defendant College of Baltimore with information by each of its falsity or with

reckless disregard of whether or not it was true or not, and with spite or ill-will.

93. Defamatory falsehood quantity 3 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

94. Defamatory falsehood quantity 3 was printed with ill-will or spite in conspiracy

between Defendant College of Baltimore and Defendant Sheehan justifying an

award of punitive damages in opposition to Defendant College of Baltimore.

COUNT 18-DEFAMATION-DEFENDANT UNIVERSITY OF BALTIMORE

95. Plaintiff realleges paragraphs 1-94 as if alleged herein.

96. Defamatory falsehood quantity 4 was printed by Defendant Sheehan in conspiracy

with Defendant College of Baltimore with information by each of its falsity or with

reckless disregard of whether or not it was true or not, and with spite or ill-will.

97. Defamatory falsehood quantity 4 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 13 of 20

98. Defamatory falsehood quantity 4 was printed with ill-will or spite in conspiracy

between Defendant College of Baltimore and Defendant Sheehan justifying an

award of punitive damages in opposition to Defendant College of Baltimore.

COUNT 19-DEFAMATION-DEFENDANT UNIVERSITY OF BALTIMORE

99. Plaintiff realleges paragraphs 1-98 as if alleged herein.

100. Defamatory falsehood quantity 5 was printed by Defendant Sheehan in

conspiracy with Defendant College of Baltimore with information by each of its

falsity or with reckless disregard of whether or not it was true or not, and with spite or illwill.

101. Defamatory falsehood quantity 5 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

102. Defamatory falsehood quantity 5 was printed with ill-will or spite in conspiracy

between Defendant College of Baltimore and Defendant Sheehan justifying an

award of punitive damages in opposition to Defendant College of Baltimore.

COUNT 20-DEFAMATION-DEFENDANT UNIVERSITY OF BALTIMORE

103. Plaintiff realleges paragraphs 1-102 as if alleged herein.

104. Defamatory falsehood quantity 6 was printed by Defendant Sheehan in

conspiracy between Defendant College of Baltimore with information by each of its

falsity or with reckless disregard of whether or not it was true or not, and with spite or illwill.

105. Defamatory falsehood quantity 6 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 14 of 20

106. Defamatory falsehood quantity 6 was printed with ill-will or spite in conspiracy

between Defendant College of Baltimore and Defendant Sheehan justifying an

award of punitive damages in opposition to the College of Baltimore.

COUNT 21-DEFAMATION-DEFENDANT UNIVERSITY OF BALTIMORE

107. Plaintiff realleges paragraphs 1-106 as if alleged herein.

108. Defamatory falsehood quantity 7 was printed by Defendant Sheehan in

conspiracy with Defendant College of Baltimore with information by each of its

falsity or with reckless disregard of whether or not it was true or not, and with spite or illwill.

109. Defamatory falsehood quantity 7 has proximately brought about injury Plaintiff’s

repute in an quantity to be confirmed at trial.

110. Defamatory falsehood quantity 7 was printed with ill-will or spite in conspiracy

between Defendant College of Baltimore and Defendant Sheehan justifying an

award of punitive damages in opposition to the Defendant College of Baltimore.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff calls for judgment in opposition to Defendants, collectively and severally

as follows:

a) For basic damages as to Counts 1-21 of not lower than TWO MILLION

DOLLARS as to every rely or such different quantity to be proved at trial;

b) For particular damages as to Counts 1-21 of not lower than ONE MILLION FIVE

DOLLARS as to every rely or such different quantity to be proved at trial;

Case 1:21-cv-02743 Doc 1 Filed 10/17/21 Web page 15 of 20

c) For punitive damages in opposition to every Defendant as to Counts 1-21, respectively, in

an quantity to be confirmed at trial, however not lower than ten occasions the quantity of basic and

particular damages as to every rely, to punish and penalize Defendants and to discourage

repetition.

d) For an injunction requiring Defendants to take away all statements adjudicated

defamatory on this case from any and all web sites or different digital, social media, or

arduous copy platforms of their management;

e) For an injunction requiring Defendants to publish a retraction of the statements

discovered defamatory together with a retraction printed in The Washington Instances;

f) For attorneys’ charges and prices incurred by Plaintiffs on this motion; and,

g) For such different and additional aid because the Courtroom deems simply and correct.

JURY DEMAND

Plaintiffs demand a jury trial of all points so triable on this trigger pursuant to Rule 38

of the Federal Guidelines of Civil Process.

Date: October 17, 2021

Respectfully submitted,

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