Hogan 2

Filing # 40950062 E-Filed 05/02/2016 12:17:59 PM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT

IN AND FOR PINELLAS COUNTY, FLORIDA
TERRY GENE BOLLEA professionally known
as HULK HOGAN,
Plaintiff,
vs.
Case No. __________________
DON BUCHWALD & ASSOCIATES, INC.;

TONY BURTON; MICHAEL CALTA aka
Cowhead; MATTHEW CHRISTIAN LOYD
aka Matt Loyd aka Spice Boy; KEITH M.
DAVIDSON; KEITH M. DAVIDSON &
ASSOCIATES, P.L.C.; COX RADIO, INC.,
TASHA NICOLE CARREGA; LORI
BURBRIDGE and GAWKER MEDIA, LLC,
Defendants.
_______________________________________/
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff, Terry Gene Bollea, professionally known as Hulk Hogan (Plaintiff or
Mr. Bollea), sues Defendants, Don Buchwald & Associates, Inc. and Tony Burton
(collectively, the Buchwald Defendants), Michael Calta aka Cowhead, Matthew Christian
Loyd aka Matt Loyd aka Spice Boy, and Cox Radio, Inc. (collectively, the Cox
Defendants), Keith M. Davidson, Keith M. Davidson & Associates, P.L.C., Tasha Nicole
Carrega and Lori Burbridge (collectively, the Davidson Defendants), and Gawker Media, LLC
(Gawker), (together collectively, Defendants), and alleges as follows:
NATURE OF THIS ACTION
1.
Over the past several years, Mr. Bollea has been repeatedly victimized by the use,
disclosure, dissemination and exploitation of surreptitiously recorded and illegally obtained
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video of Mr. Bollea naked, engaged in sexual activity, and having private conversations in a
private bedroom, without his knowledge or consent.
2.
In October 2012, Mr. Bollea sought the assistance of state and federal law
enforcement to investigate and prosecute those responsible for obtaining, using, disclosing,
disseminating and exploiting the contents of these illegal recordings.
3.
Unfortunately, the United States Government and the State of Florida declined to
prosecute anyone involved in the improper use and disclosure of the contents of the illegal
recordings.
4.
Consequently, Mr. Bollea brings this action to seek redress for the damages and
injuries caused by the use, exploitation and public dissemination of the contents of the illegally
recorded footage, including a willful and malicious conspiracy to extort him, invade his privacy,
profit from his name and likeness and the contents of the illegally recorded footage, and to
destroy Mr. Bollea economically and emotionally, ruin his career and reputation and eradicate
his legacy, including the following:
a.
The Buchwald Defendants, and each of them, individually or in
concert with and/or as an agent for one another, engaged in acts of civil
conspiracy, aiding and abetting civil extortion, violation of Plaintiffs rights of
privacy, public disclosure of private facts, invasion of privacy by intrusion,
intentional infliction of emotional distress, interference with Plaintiffs
contractual and advantageous business relationships, and violation of Floridas
Security of Communications Act;
b.
The Cox Defendants, and each of them, individually or in concert
with and/or as an agent for one another, engaged in acts of civil conspiracy, civil
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extortion, aiding and abetting civil extortion, violation of Plaintiffs rights of

privacy, public disclosure of private facts, invasion of privacy by intrusion,
intentional infliction of emotional distress, interference with Plaintiffs
contractual and advantageous business relationships, and violation of Floridas
Security of Communications Act;
c.
The Davidson Defendants, and each of them, individually or in
concert with and/or as an agent for one another, engaged in acts of civil
conspiracy, civil extortion, aiding and abetting civil extortion, violation of
Plaintiffs rights of privacy, public disclosure of private facts, invasion of privacy
by intrusion, intentional infliction of emotional distress, interference with
Plaintiffs contractual and advantageous business relationships, and violation of
Floridas Security of Communications Act; and
d.
Gawker intentionally interfered with Plaintiffs contractual and
advantageous business relationships, and intentionally inflicted
emotional
distress upon him by leaking a sealed transcript of surreptitiously recorded private

oral communications in a bedroom to the media. (Mr. Bolleas claims against
Gawker are based on events that transpired in the summer of 2015, and therefore
do not overlap with the claims that Plaintiff brought against Gawker in the 2012
action titled Bollea v. Gawker Media, LLC, et al., Case No. 12012447-CI-011 in
this Court (the Prior Action)).
5.
Plaintiff seeks damages against the Buchwald Defendants, Cox Defendants and
Davidson Defendants, jointly and severally, as well as a permanent injunction against said
Defendants.
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6.
Plaintiff seeks damages against Gawker, which are not duplicative of the damages
sought in the Prior Action.

JURISDICTION
7.
This Court has jurisdiction because Plaintiff seeks relief in an amount greater than
$15,000, exclusive of interest, attorneys fees and costs.

8.
As more specifically set forth below, this Court has personal jurisdiction over
Defendants under 48.193, Florida Statutes, because they each personally or through an agent
engaged in one or more of the following acts:
a.
committing tortious acts within the State of Florida;
b.
committing intentional torts expressly aimed at Plaintiff, the
effects of which were suffered in Pinellas County, Florida;

c.
operating, conducting, engaging in, or carrying on a business or
business venture within the State of Florida, or having an office in this State;
d.
engaging in substantial and not isolated activity within the State of
Florida; and/or
e.
engaging in a conspiracy to commit tortious acts against Mr.
Bollea within the State of Florida and/or engaging in overt acts in furtherance of
that conspiracy within the State of Florida.
9.
As more specifically set forth below, sufficient minimum contacts exist between
each Defendant and the State of Florida to satisfy the Due Process under the U.S. Constitution
because Defendants have engaged in substantial and not isolated activity within the State of
Florida, reside or maintain offices in the State of Florida, and/or committed or conspired to
commit intentional torts expressly aimed at Plaintiff, the effects and harms of which were
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calculated to and did cause injury to Plaintiff in the State of Florida; such that Defendants should
have reasonably anticipated being sued by Plaintiff in the State of Florida.
10.
Venue is proper in this Court pursuant to section 47.011, Florida Statutes because,
among other things, the claims at issue accrued within Pinellas County, Florida.
PARTIES
11.
Plaintiff is a resident and citizen of the State of Florida, and resident of Pinellas
County.
12.
At all relevant times, Defendant, Don Buchwald & Associates, Inc. (Buchwald
& Associates), was and is a corporation organized and operating under the laws of the State of
New York, with its principal place of business in the City of New York, County of New York,
State of New York. Buchwald & Associates is a talent agency that represents clients in, among
other areas, the radio broadcasting industry; including clients within the State of Florida.
13.
At all relevant times, Defendant, Tony Burton (Burton), was and is a citizen,
resident and domiciliary of the State of New York, and was and is a talent agent acting within the
course and scope of his employment by Buchwald & Associates. Burtons clients have included,
and currently include, among others, Tampa radio personality, Defendant, Michael Calta aka
Cowhead.
14.
At all relevant times, Defendant, Michael Calta aka Cowhead (Calta), was
and is a citizen, resident and domiciliary of Pasco County, Florida. Calta was and is a radio
personality in the Tampa Bay area, who hosts a radio show on The Bone 102.5 FM. At all
relevant times, Calta was acting within the course and scope of his employment by Defendant,
Cox Radio, Inc.
15.
At all relevant times, Defendant, Matthew Christian Loyd aka Matt Loyd aka
Spice Boy aka Jim Janerro (Loyd), was and is a citizen, resident and domiciliary of
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Hillsborough County, Florida. At certain times relevant hereto, Loyd was a radio personality in
the Tampa Bay area, and was acting within the course and scope of his employment by
Defendant, Cox Radio, Inc.
16.
At all relevant times, Defendant, Cox Radio, Inc. (Cox), was and is a
corporation organized and operating under the laws of the State of Delaware, registered to do
business in the State of Florida, with its principal place of business in the City of Atlanta, State
of Georgia. At all material times, Cox owned and operated several terrestrial radio stations
broadcasting in Pinellas County, Florida, including The Bone 102.5 FM, which operates in and
from offices located in Pinellas County, Florida.
17.
At all relevant times, Defendant, Keith M. Davidson (Davidson), was and is a
citizen, resident and domiciliary of the State of California, and a resident of Los Angeles County,
California. Davidson is an attorney at law, licensed to practice in the State of California, with a
record of discipline by the State Bar of California, and was suspended from practicing law in
California for two years. Davidson was retained to assist the Buchwald Defendants and Cox
Defendants in the extortion of Plaintiff using the illegally obtained surreptitious video footage
within Pinellas County, Florida.
18.
At all relevant times, Defendant, Keith M. Davidson & Associates, P.L.C.
(Davidson & Associates), was and is a professional corporation organized and existing under
the laws of the State of California, with its principal place of business in the State of California,
County of Los Angeles. At all relevant times, Davidson was acting within the course and scope
of his employment by Davidson & Associates.
19.
At all relevant times, Defendant, Tasha Nicole Carrega (Carrega), was the wife
of Defendant, Loyd, and a citizen, resident and domiciliary of Hillsborough County, Florida.
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20.
At all relevant times, Defendant, Lori Burbridge (Burbridge), was a close friend
of Carrega and a citizen, resident and domiciliary of Pasco County, Florida.

21.
At all relevant times, Defendant, Gawker Media, LLC (Gawker), was and is a
limited liability company organized and operating under the laws of the State of Delaware, with
its principal place of business in City of New York, County of New York, State of New York.
22.
At all relevant times, the Buchwald Defendant, Cox Defendants and Davidson
Defndants, and each of them, were and are the agents, licensees, employees, partners, jointventurers, co-conspirators, owners, principals, and employers of one another, and each of them
are, and at all times herein mentioned were, acting within the course and scope of that agency,
license, partnership, employment, conspiracy, ownership, or joint venture. At all relevant times,
the acts and conduct herein alleged of each of said Defendants were known to, authorized by,
and/or ratified by the other said Defendants, and each of them.
FACTS GIVING RISE TO THE CLAIMS
23.
Plaintiff is a former professional wrestler, and is a professional spokesperson,
actor, television personality and product endorser who has enjoyed mainstream popularity as the
character Hulk Hogan.
24.
In or about June-July 2007, Plaintiff, without his knowledge or consent, was
filmed with a hidden camera, naked and engaging in private sexual activity and having private
conversations, in a private bedroom, with Heather Clem (Heather Clem), and having private
conversations, in a private bedroom, with her then-husband Bubba the Love Sponge Clem
(Bubba Clem). Plaintiff understood, believed and expected that his activities in the Clems
private bedroom were private and would not be viewed, heard by other persons nor recorded.
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Had Plaintiff known that his private activities and conversations were being recorded, Plaintiff
would not have engaged in any such activities or conversations.
25.
In or about early 2012, the Cox Defendants illegally obtained a copy of the
surreptitious recordings of Plaintiff, and conspired with one another to use and disclose the
contents of said recordings to harm Plaintiff and obtain an improper economic benefit.
26.
In or about early 2012, the Buchwald Defendants, Cox Defendants and Davidson
Defendants conspired with one another to use and disclose the contents of the illegal recordings
of Plaintiff to cause him harm and obtain an improper economic benefit; and in furtherance
thereof sold information relating to the surreptitious recordings of Plaintiff to media companies
including, among others, TMZ.com and TheDirty.com, which information included still images
and/or portions of the audio and video recordings of Plaintiff. TMZ.com reported on such
information starting on or about March 7, 2012, and TheDirty.com reported on such information
starting on or about April 19, 2012, which reports included still images from the surreptitious
recordings of Plaintiff, as well as information regarding the contents of the audio portions of the
surreptitious recordings.
27.
During 2012, Loyd and Calta communicated repeatedly regarding the formulation
and execution of a plan to release the surreptitious recordings of Plaintiff, including their strategy
for releasing portions of same to media outlets for the purposing of causing substantial economic
harm to Plaintiff, among others; while also furthering their own radio broadcasting careers.
28.
Loyd and Calta were acting within the course and scope of their employment by
Cox when they engaged in acts in furtherance of the scheme and conspiracy to use and disclose
the contents of the surreptitious recordings of Mr. Bollea; and some or all of these acts were
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committed at Coxs offices located in Pinellas County, Florida and/or with the knowledge and
consent of Loyd and Caltas immediate supervisors.
29.
In or about late September 2012, Burton, in his capacity as a talent agent
employed by Buchwald & Associates, and acting on behalf of and in concert with Calta, a client
of Buchwald & Associates, communicated with A.J. Daulerio (Daulerio), who was then the
Editor-in-Chief of Gawker.com, a popular weblog owned by Gawker. In those communications,
Burton stated to Daulerio that a DVD was being sent to Daulerio and Gawker containing a large
portion of the surreptitious recordings of Plaintiff. Within days of these communications, certain
of the Buchwald Defendants, Cox Defendants and/or Davidson Defendants, or someone acting in
concert with them or at their direction, sent to Daulerio and Gawker a DVD containing a little
more than 30 minutes of surreptitious recordings of Plaintiff, including video images of him fully
naked and engaged in consensual sexual activity with Ms. Clem, and also including oral
communications between Plaintiff, Ms. Clem and Mr. Clem (the 30 Minute Video). Burton,
acting on behalf of and in concert with Buchwald Defendants, Cox Defendants and Davidson
Defendants, knew and intended that Daulerio would publicly disclose content from the 30
Minute Video.
30.
Daulerio, edited the surreptitious recordings of Plaintiff contained within the 30
Minute Video into a one-minute and forty-second highlight reel video (the 1:41 Video),
which showed Plaintiff fully naked, receiving oral sex, and engaged in sexual intercourse. The
1:41 Video also included Plaintiffs private oral communications with Ms. Clem. Daulerio and
Gawker included English subtitles to the 1:41 Video, to ensure that viewers understood every
word spoken by Plaintiff and Ms. Clem during the 1:41 of their private encounter. On October 4,
2012, Gawker posted the 1:41 Video to the Internet, along with an incidental, narrative
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description of the contents of the 30 Minute Video, including portions not contained in the 1:41
Video. At least 7 million people watched the 1:41 Video on the Internet. At or around the same
time, Loyd contacted Daulerio using the alias Jim Janerro to discuss additional surreptitious
recordings of Plaintiff.
31.
In October 2012, the Davidson Defendants, acting on behalf of and in concert
with the Cox Defendants (collectively, the Extortionists), contacted counsel for Plaintiff
seeking to extort money from Plaintiff. The Extortionists threatened to release the entirety of the
surreptitious recordings of Plaintiff, if Plaintiff did not agree to make a very large payment in
exchange for all copies of the recordings. Davidson, representing and acting on behalf of and in
concert with the other Extortionists, specifically stated to Plaintiffs counsel that certain of the
surreptitious recordings that were created illegally, and obtained illegally by the Extortionists,
contained insensitive racial remarks which could have the effect of causing great economic harm
to Plaintiff if released publicly. Initially, the Extortionists demanded $1 million.
32.
Davidson, representing and acting on behalf of and in concert with the
Extortionists, also told Plaintiffs counsel that the Extortionists (who acted in agreement with and
the assistance of the Buchwald Defendants), arranged for the 30 Minute Video to be sent to
Gawker as a shot across the bow as part of the scheme to extort money from Plaintiff.
33.
The Extortionists and the Buchwald Defendants agreed and worked in concert
with one another to send the 30 Minute Video to Gawker and Daulerio in furtherance of the
scheme to extort Plaintiff with the surreptitious recordings, promote Loyd and Caltas broadcast
careers (while injuring the career of a competitor), and cause substantial economic harm and
severe emotional distress to Plaintiff through the release to Gawker and Daulerio of the 30
Minute Video.
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34.
Plaintiffs counsel contacted local law enforcement agencies for assistance in
investigating and prosecuting those involved in the recording, use, exploitation and disclosure of
the surreptitious video. However, local law enforcement advised Plaintiffs counsel that the
statute of limitations for any criminal violations under Florida law had expired, because the
recordings were made in 2007.
35.
Plaintiffs counsel then reported the Extortionists threat to the Tampa, Florida
office of the Federal Bureau of Investigation (FBI). The FBI subsequently set up a sting
operation, which occurred on or about December 14, 2012, at a hotel in Clearwater Beach,
Pinellas County, Florida. On that day, the Extortionists followed through on their plan to use the
surreptitious recordings to extort money from Plaintiff. Specifically, the Extortionists turned
over what they represented to Bolleas counsel were all copies of all surreptitious recordings of
Plaintiff in the possession of the Extortionists, in exchange for a check from Plaintiffs counsel in
the amount of $150,000 and a commitment to make subsequent payments of an additional
$150,000, for a total extortion payment of $300,000. Plaintiff and his counsel, David Houston,
appeared at the Clearwater Beach hotel that day and met with Davidson and Burbridge
(representing and acting in concert with the other Extortionists and in furtherance of their
conspiracy) for the execution of a purported settlement agreement and the exchange of the all
copies of the surreptitious recordings (from the Extortionists to Plaintiff) and a $150,000 check
(from Plaintiffs counsel to the Extortionists).
36.
The FBI recorded the activities of the participants (Plaintiff, Houston, Davidson,
Burbridge and a polygraph examiner who was working undercover for the FBI) in a room at the
hotel. The hotel room next door contained several armed FBI agents who recorded the activities
in the adjacent room and prepared to make an arrest of the Extortionists. When Houston handed
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the check to the Davidson and Burbridge (representing the Extortionists), several FBI agents
entered the room with guns drawn, arrested Davidson and Burbridge, and immediately removed
Plaintiff and Houston from the room.
37.
On May 19, 2015, for the sole stated purpose of discovery in the Prior Action to
determine whether Plaintiff knew he was being recorded by Mr. Clem in 2007, Gawker filed a
separate federal lawsuit against the FBI under the Freedom of Information Act (FOIA), to
obtain documents and information relating to the aforementioned FBI investigation and
operation, styled Gawker Media, LLC, et al, v. Federal Bureau of Investigation, U.S. District
Court, Middle District of Florida, Case No. 8:15-cv-01202-SCB-EAJ (the Gawker-FBI
Action). In particular, Gawker sought to obtain other portions of the surreptitiously recorded
video of Plaintiff which were not at issue in nor relevant to the Prior Action.
38.
As the Prior Action and the Gawker-FBI Action progressed, it became clear that
Gawker misrepresented the reason why it was seeking discovery of the FBI extortion
investigation and operation. Gawker, having become aware through discovery in the Prior
Action that other surreptitious recordings seized during the FBI sting operation purportedly
contained racially insensitive statements by Plaintiff, used the Gawker-FBI Action to try to gain
access to video and/or audio footage of Plaintiff making such statements, so Gawker could use
such statements against Plaintiff to destroy him publicly and as leverage to try to force Plaintiff
to settle or drop his claims heading into a jury trial in the Prior Action.
39.
During the Prior Action, Gawker threatened Plaintiff repeatedly with the public
release of a written transcript (prepared by the Extortionists), containing racially insensitive

remarks, derived from the 2007 surreptitious recordings of Plaintiff.
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Plaintiff sought and
obtained a Protective Order in the Prior Action, prohibiting the release of the transcript or its
contents.
40.
In mid-July 2015, following Gawkers repeated threats of releasing the racial
statements during the preceding several months, Gawkers business went into a tailspin over a
controversial story which alleged that an executive at a rival media company arranged a date
with a male porn star and escort. Hundreds of stories were published that were highly critical of
Gawker in connection with its reporting. As a result, several major advertisers stopped their
advertising at Gawker, and others were threatening to do the same. Moreover, several senior
staff at Gawker resigned in connection with the scandal. All such activity (the story, the
backlash, the loss of advertisers and the resignations) happened within the course of only a few
days. Gawker needed an immediate, major public story to be released, to change the public
discourse about Gawker, and deflect attention away from its wrongful business practices.
41.
Gawker found just the solution. Dylan Howard, a senior editor at The National
Enquirer and its sister publication RadarOnline.com (collectively, the Enquirer), who was a
personal friend of Daulerio at the time, gave notice to Plaintiffs counsel on July 23, 2015 that
the Enquirer intended to publish excerpts from the very court-protected, confidential, sealed
transcript that Gawker had been threatening to release publicly for months (but which Gawker
itself could not release because of the Protective Order in the Prior Action prohibiting its public
dissemination).
42.
Shortly after Gawkers CEO, Nick Denton, published an article predicting that
Mr. Bolleas real secret would soon be revealed, at 6:38 a.m. Eastern time on July 24, 2015,
the Enquirer published a story quoting excerpts of the court-protected confidential transcript. In
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its report, the Enquirer confirmed that the excerpts came from the transcript that was filed under
seal in a Florida court.
43.
Only 14 minutes after the Enquirer posted the court-protected confidential
transcript, at 6:52 a.m. Eastern time, Daulerio sent a tweet to Plaintiffs Twitter account stating:
XOXOXO (i.e., hugs and kisses) and attaching a link to the Enquirers post releasing excerpts
of the court-protected confidential transcript. Based upon the timing and content of Daulerios
tweet, Daulerio was aware, in advance, of the Enquirers plans to publish the court-protected
confidential transcript, and the harm that such publication would cause to Plaintiff.
44.
Plaintiff promptly issued a public apology for the offensive language used during
an illegally-recorded private conversation in his then-best friends bedroom in 2007eight years

earlier.
45.
The actions of all of Defendants culminated in the Enquirers publication of the
court-protected confidential transcript, which caused Plaintiff to be immediately terminated by

his employer, World Wrestling Entertainment (WWE). Hundreds of articles were published
by news organizations immediately thereafter, accusing Plaintiff of being a racist.
46.
As a result of the Defendants actions, Plaintiffs highly valuable global brand
(which Plaintiff had developed through personal sacrifice, hard work, talent and an immense
physical toll on his body over the course of more than 35 years) was decimated within days, and
has been permanently damaged if not completely destroyed.
Among other things, all of
Plaintiffs endorsement contracts were terminated shortly after the Enquirers publication of the
court-protected confidential transcript, and his name and likeness were erased from the WWE
website and its Hall of Fame.
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47.
Shortly before his 62nd birthday, because of Defendants use, exploitation and
dissemination of the contents of the illegally-recorded 2007 footage, Plaintiffs income was cut
off, his legacy in entertainment was severely damaged (if not completely destroyed), and his
global brand was forever tarnished.
48.
In the Prior Action, Plaintiffs counsel promptly brought a motion with the court
requesting depositions of Daulerio, Nick Denton (Gawkers CEO) and others, and electronic
discovery, to determine the extent of Gawkers role in connection with the leak of the courtprotected confidential transcripts. Gawker vigorously opposed the motion, but the Court granted
it, and ordered the requested discovery to occur (but with certain limitations imposed by the trial
court sua sponte). Gawker filed an emergency writ petition in the Florida Second District Court
of Appeal (DCA) along with a motion for a stay of the trial courts order pending the DCAs
review. The DCA granted the emergency motion for a stay, but as of the date of this Complaint
has not issued a ruling on the substance of the writ petition.
49.
Gawker participated in, facilitated and/or contributed to the use and public
dissemination of the content of court-protected confidential transcript to the Enquirer, which

resulted in the loss of Plaintiffs employment and income, and severe damages to his personal
and professional reputation, and valuable worldwide brand.
50.
For purposes of context, Gawkers strategy in the Prior Action was to deliberately
and repeatedly file materials with the courts that contained the aforementioned offensive
language, which was repeatedly and correctly held inadmissible and completely irrelevant by the
Court in the Prior Action. Although Gawker ostensibly filed these documents under seal, they
were filed with the knowledge that due to the high level of publicity attendant to the Prior
Action, the media would seek to unseal such materials and obtain the highly sensitive transcript
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and audio of Plaintiff using offensive language. Gawkers plan succeeded, as the news media
eventually obtained an order from the Second DCA releasing the sensitive material that Gawker
had placed in the court file, which emanated from the Defendants tortious conduct directed to
Mr. Bollea.
51.
The jury trial in the Prior Action proceeded from March 7 through 21, 2016, and
the jury rendered a verdict on March 18, and a punitive damages award on March 21.
52.
All conditions precedent to the bringing and maintenance of this action and the
granting of the relief requested have been performed, have occurred, or have been waived.
53.
Many of the facts alleged herein were discovered by Plaintiff through an
investigation that has taken several years, and is still continuing. Many of facts became known
to Plaintiff as a result of an investigation by the Tampa Police Department, as reflected in their
Report dated November 13, 2015 (seven months after the discovery cutoff in the Prior Action), a
copy of which is attached hereto as Exhibit A, the contents of which are incorporated herein by
this reference.
54.
Defendants, in doing the things alleged herein, acted with actual malice and
reckless disregard of Plaintiffs rights. Moreover, although none of the Defendants were acting
in the capacity of a member of the press while engaging in the conduct forming the basis of
this action, the actions of each of the Defendants, alleged herein, still served no legitimate public
interest.
FIRST CAUSE OF ACTION
(Invasion of Privacy and/or Aiding and Abetting Invasion of Privacy
Against the Buchwald Defendants, Cox Defendants and Davidson Defendants)
55.
Plaintiff repeats, re-alleges, adopts and incorporates each and every allegation
contained in Paragraphs 1 through 54, inclusive, as though fully set forth herein.
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56.
The Buchwald Defendants, Cox Defendants and Davidson Defendants, in
engaging in the conduct alleged herein, grossly invaded Plaintiffs protected rights of privacy as
recognized under the United States Constitution, Florida Constitution, and Florida common law.
57.
Among other things, the Buchwald Defendants, Cox Defendants and Davidson
Defendants used, exploited and publicly disclosed intimate details of Plaintiffs private life by
disseminating surreptitious recordings of Plaintiff to media companies including TMZ.com,
TheDirty.com and/or Gawker, and/or aided and abetted in connection with such dissemination
and distribution, for their own economic gain and self interests.
58.
The unauthorized distribution and dissemination of the surreptitious recordings of
Plaintiff was highly offensive and objectionable to Plaintiff and to any reasonable person of
ordinary sensibilities, and was not of legitimate public concern.
59.
The Buchwald Defendants, Cox Defendants and Davidson Defendants knew or
should have known that: (1) the surreptitious recordings of Plaintiff contained private and
confidential information about Plaintiff; (2) Plaintiff had a reasonable expectation of privacy in
being fully naked and engaged in consensual sexual activity, and having private conversations, in
a private bedroom; (3) the recordings were taken without Plaintiffs knowledge or consent; (4)
the surreptitious recordings would reveal private and personal things about Plaintiff which said
Defendants had no right or authorization to use, disseminate, disclose or exploit; (5) the
publication of these private facts about Plaintiff would be offensive and objectionable to a
reasonable person of ordinary sensibilities; and, (6) the publication of these private facts
constitutes a substantial violation of Plaintiffs right of privacy.
60.
The Buchwald Defendants, Cox Defendants and Davidson Defendants had no
reasonable or legitimate purpose for their acts of using, distributing, disseminating, disclosing
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and/or exploiting the surreptitious recordings of Plaintiff and/or aiding and abetting of same.
Plaintiff had a reasonable expectation of privacy when he was fully naked and engaged in private
consensual sexual activity and having private conversations in a private bedroom, and had no
knowledge of, and did not consent to, the recording or public disclosure of any such private
activities.
61.
The intimate details of Plaintiffs private life that were used, distributed,
disseminated, disclosed and/or exploited by the Buchwald Defendants, Cox Defendants and
Davidson Defendants were in fact published by the aforementioned media companies, and would
not have been published but for said Defendants actions of using, distributing, disseminating,
disclosing and/or exploiting such private facts, or said Defendants acts of aiding and abetting
same.
62.
The Buchwald Defendants, Cox Defendants and Davidson Defendants violated
Plaintiffs fundamental privacy rights by the conduct alleged herein, including the intrusion into
Plaintiffs privacy and the outrageous use, distribution, dissemination, disclosure and/or
exploitation of the surreptitious recordings of Plaintiff to media companies and others, and/or
aiding and abetting of same, in an unprivileged manner calculated to financially capitalize
therefrom and/or cause substantial harm to Plaintiff and others, in conscious disregard of
Plaintiffs rights.
63.
The Buchwald Defendants, Cox Defendants and Davidson Defendants acted with
actual malice and reckless disregard of Plaintiffs rights.

64.
As a direct and proximate result of the aforementioned acts by each of the
Buchwald Defendants, Cox Defendants and Davidson Defendants, Plaintiff has suffered
economic and emotional injury, damage, loss and harm, damage to reputation, anxiety,
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embarrassment, humiliation, shame, and severe emotional distress in an amount subject to proof;
which damages are continuing in nature and will be suffered in the future.
65.
Plaintiff also is entitled to preliminary and permanent injunctive relief enjoining
the use, distribution, dissemination and disclosure of the surreptitious recordings of Plaintiff, and
any portions and content thereof; mandating the delivery of all originals, reproductions, copies,
and portions of same and all content derived therefrom to Plaintiff; and transferring to Plaintiff
all right, title and interest in and to all originals, reproductions, copies, and portions of same and
all content derived therefrom.
66.
The aforementioned acts of the Buchwald Defendants, Cox Defendants and
Davidson Defendants were done intentionally or with a conscious and/or reckless disregard of
Plaintiffs rights, and with the intent to vex, injure or annoy, such as to constitute oppression,
fraud or malice.
SECOND CAUSE OF ACTION
(Public Disclosure of Private Facts and/or Aiding and Abetting Public Disclosure of Private
Facts Against the Buchwald Defendants, Cox Defendants and Davidson Defendants)
67.
68.
The Buchwald Defendants, Cox Defendants and Davidson Defendants disclosed
to media companies, and thus the public, private facts concerning Plaintiff contained within the
contents of the surreptitious recordings of Plaintiff which depicted him fully naked, engaged in
private consensual sexual activity in a private bedroom, and engaged in private conversations,
and/or said Defendants aided and abetted in connection with such public disclosure for their own
economic gain and self interests.
{BC00089530:1}
19
69.
being fully naked and engaged in consensual sexual activity, and having private conversations in
a private bedroom; (3) the recordings were taken without Plaintiffs knowledge or consent; (4)
the surreptitious recordings would reveal private and personal things about Plaintiff which said
Defendants had no right or authorization to use, disseminate, disclose or exploit; (5) the
70.
The Buchwald Defendants, Cox Defendants and Davidson Defendants had no
reasonable or legitimate purpose for their acts of using, distributing, disseminating, disclosing
and/or exploiting the surreptitious recordings of Plaintiff and/or aiding and abetting of same.
Plaintiff had a reasonable expectation of privacy when he was fully naked, engaged in private
consensual sexual activity, and having private conversations, in a private bedroom, and had no
knowledge of, and did not consent to, the recording of any such private activities.
71.
The private facts that were used, distributed, disseminated, disclosed and/or
exploited by the Buchwald Defendants, Cox Defendants and Davidson Defendants were in fact
published by the aforementioned media companies, and would not have been published but for
said Defendants actions of using, distributing, disseminating, disclosing and/or exploiting such
private facts, or said Defendants acts of aiding and abetting same.
72.
The actions of the Buchwald Defendants, Cox Defendants and Davidson
Defendants as alleged herein are highly offensive and objectionable to Plaintiff, as well as to any
{BC00089530:1}
20
reasonable person of ordinary sensibilities, and are not of legitimate public concern. Plaintiff did
not consent to nor authorize any use, distribution, dissemination, disclosure or exploitation of the
surreptitious recordings of him, or any portions or content thereof, whatsoever, or of the
publication of same by anyone.
73.
Plaintiffs fundamental privacy rights by the conduct alleged herein, including the intrusion into
Plaintiffs privacy and the outrageous use, distribution, dissemination, disclosure and/or
exploitation of the private facts contained within surreptitious recordings of Plaintiff to media
companies and the public, and/or aiding and abetting of same, in an unprivileged manner
calculated to financially capitalize therefrom and/or cause substantial harm to Plaintiff and
others, in conscious disregard of Plaintiffs rights.
74.
actual malice and reckless disregard for Plaintiffs rights.

75.
embarrassment, humiliation, shame and severe emotional distress in an amount subject to proof;
76.
{BC00089530:1}
21
77.
fraud or malice.
THIRD CAUSE OF ACTION
(Invasion of Privacy by Intrusion Upon Seclusion and/or
Aiding and Abetting Invasion of Privacy by Intrusion Upon Seclusion
78.
79.
The Buchwald Defendants, Cox Defendants and Davidson Defendants, without
Plaintiffs consent and against Plaintiffs will, have grossly invaded Plaintiffs protected rights of
privacy as recognized under the United States Constitution, Florida Constitution, and applicable
common law, by obtaining, using, watching, distributing, disseminating, disclosing and/or
exploiting the surreptitious recordings of Plaintiff which depicted him fully naked, engaged in
private intimate consensual sexual activity, and included his private conversations, in a private
bedroom, and/or aiding and abetting of such activity.
80.
The Buchwald Defendants, Cox Defendants and Davidson Defendants, through
electronic means, enabled the general public to intrude into a place in which Plaintiff had a
reasonable expectation of privacy and watch Plaintiff when he was fully naked, engaged in
private sexual activity, and engaged in private conversations, in a private bedroom, without
Plaintiffs knowledge, authorization or consent.
{BC00089530:1}
22
81.
The activities of the Buchwald Defendants, Cox Defendants and Davidson
Defendants were not carried out for reasonable or legitimate purposes, but rather to reap
financial rewards at the expense of Plaintiff and others and/or to cause substantial harm to
Plaintiff and others.
82.
Plaintiff had a reasonable expectation of privacy in the location in which the
surreptitious recordings were secretly made, and a reasonable expectation he was not being
recorded while engaging in the private activities in which he was engaged; appearing fully
naked, engaged in private consensual sexual activity, and having private conversations, in a
private bedroom. Plaintiff had no knowledge of, and did not consent to, the recording or
disclosure and dissemination of such private activities.
83.
The actions by the Buchwald Defendants, Cox Defendants and Davidson
Defendants are offensive and objectionable to Plaintiff, and would outrage or cause mental
suffering, shame, humiliation or hurt feelings to a person of ordinary sensibilities.
84.
being fully naked and engaged in consensual sexual activity, and having private conversations, in
a private bedroom; (3) the recordings were taken without Plaintiffs knowledge or consent;
(4) the surreptitious recordings would reveal private and personal things about Plaintiff which
said Defendants had no right or authorization to use, disseminate, disclose or exploit; (5) the
{BC00089530:1}
23
85.
Plaintiffs fundamental privacy rights by the conduct alleged herein, including the outrageous
intrusion into Plaintiffs privacy and the use, distribution, dissemination, disclosure and
exploitation of the surreptitious recordings of Plaintiff, in an unprivileged manner, calculated to
financially gain therefrom, at the expense of Plaintiff and others, and/or to cause Plaintiff to
suffer substantial harm therefrom, in conscious disregard of Plaintiffs right of privacy.
86.

87.
embarrassment, humiliation, shame, and severe emotional distress in an amount subject to proof;
88.
89.
fraud or malice.
{BC00089530:1}
24
FOURTH CAUSE OF ACTION

(Intentional Infliction of Emotional Distress
90.
contained in paragraphs 1 through 54, inclusive, as if fully set forth herein.

91.
At all times herein, the Buchwald Defendants, Cox Defendants and Davidson
Defendants acted intentionally, maliciously and without justification in causing the surreptitious
recordings of Plaintiff to be disseminated and disclosed to third parties, and in participating and
aiding a civil extortion scheme when they knew or should have known that Plaintiff would suffer
severe emotional distress as a result.
92.
The conduct by the Buchwald Defendants, Cox Defendants and Davidson
Defendants was intentional and malicious and done for the purpose of causing, or was known by
said defendants to be likely to cause, Plaintiff to suffer humiliation, mental anguish and severe
emotional distress, and was done with the wanton and reckless disregard of the consequences to
Plaintiff.
93.
In doing the acts alleged hereinabove, the Buchwald Defendants, Cox Defendants
and Davidson Defendants acted outrageously and beyond all reasonable bounds of decency, and
intentionally inflicted severe emotional distress upon Plaintiff, to his detriment.
94.

95.
emotional injury, damage, loss, harm, anxiety, embarrassment, humiliation, shame, and severe
{BC00089530:1}
25
emotional distress in an amount subject to proof; which damages are continuing in nature and
will be suffered in the future.
96.
Plaintiff is informed and believes and thereon alleges that the aforementioned acts
of the Buchwald Defendants, Cox Defendants and Davidson Defendants were done intentionally
or with a conscious and/or reckless disregard of Plaintiffs rights, and with the intent to vex,
injure or annoy, such as to constitute oppression, fraud or malice.
97.
Plaintiff expressly disclaims any claims of negligence, including negligent
infliction of emotional distress, against the Buchwald Defendants, Cox Defendants and Davidson
Defendants.
FIFTH CAUSE OF ACTION
(Intentional Interference with Contractual Relations and Advantageous Business
Relationships Against the Buchwald Defendants, Cox Defendants and Davidson Defendants)
98.
contained in Paragraphs 1 through 54, inclusive as though fully set forth herein.
99.
At all times herein, the Buchwald Defendants, Cox Defendants and Davidson
Defendants were aware that Plaintiff had specific employment, endorsement and other contracts,
and said Defendants acted intentionally, maliciously and without justification in their wrongful
acts described herein. The Buchwald Defendants, Cox Defendants and Davidson Defendants
knew or should have known that their actions would cause or were likely to cause substantial
interference with Plaintiffs existing contracts and his advantageous business relationships.
100.
The conduct by the Buchwald Defendants, Cox Defendants and Davidson
Defendants was intentional and malicious and done for the purpose of causing, or was known by
them to be likely to cause, the termination of and substantial interference with Plaintiffs
contracts and his advantageous business relationships.
{BC00089530:1}
26
101.
In doing the acts alleged hereinabove, the Buchwald Defendants, Cox Defendants
and Davidson Defendants acted outrageously and beyond all reasonable bounds of decency.
102.
As a direct and proximate result of the aforementioned wrongful conduct by the
substantial economic injury, loss, damages and harm from the actual interference with Plaintiffs
contracts and advantageous business relationships, in an amount subject to proof; which damages
are continuing in nature and will be suffered in the future.
103.

104.
Plaintiff is informed and believes and thereon alleges that the aforementioned acts
of the Buchwald Defendants, Cox Defendants and Davidson Defendants were done intentionally
or with a conscious and/or reckless disregard of Plaintiffs rights, and with the intent to vex,
injure or annoy, such as to constitute oppression, fraud or malice.
105.
interference, against the Buchwald Defendants, Cox Defendants and Davidson Defendants.
SIXTH CAUSE OF ACTION
(Violation of Section 934.10, Florida Statutes and/or
Aiding and Abetting of Violation of Section 934.10, Florida Statutes
106.
contained in Paragraphs 1 through 54, inclusive as though fully set forth herein.
107.
Plaintiff had a reasonable expectation of privacy in engaging in private oral
communications in a private bedroom, and a reasonable expectation that said oral

communications would not be recorded, and did not know about, nor consent to, the recording of
such oral communications.
{BC00089530:1}
27
108.
The Buchwald Defendants, Cox Defendants and Davidson Defendants
intentionally violated Plaintiffs rights under Section 934.10, Florida Statutes, by using,
disseminating, disclosing and/or distributing to third parties the contents of private oral
communications of Plaintiff.
109.
confidential information about Plaintiff; (2) Plaintiff had a reasonable expectation of privacy
while having private conversations, in a private bedroom; (3) the recordings were made without
Plaintiffs knowledge or consent; (4) the surreptitious recordings would reveal private and
personal things about Plaintiff which said Defendants had no or authorization to use,
disseminate, disclose or exploit; (5) the use or disclosure of Plaintiffs oral communications or
the contents thereof would be offensive and objectionable to a reasonable person of ordinary
sensibilities; and, (6) the use and disclosure of Plaintiffs oral communications was unlawful.
110.
The actions of the Buchwald Defendants, Cox Defendants and Davidson
Defendants have not served any legitimate public interest.

111.
actual malice and reckless disregard of Plaintiffs rights, including his right to privacy.
112.
As a direct and proximate result of the aforementioned acts by the Buchwald
Defendants, Cox Defendants and Davidson Defendants, Plaintiff has suffered substantial actual
damages; which are continuing in nature and will be suffered in the future. in an amount subject
to proof.
113.
{BC00089530:1}
28
fraud or malice.
SEVENTH CAUSE OF ACTION
(Civil Conspiracy Against Cox Defendants and Davidson Defendants)
114.
contained in Paragraphs 1 through 113, inclusive, as if fully set forth herein.

115.
The Buchwald Defendants, Cox Defendants and Davidson Defendants entered
into an agreement to commit an unlawful act and/or perform a lawful act by unlawful means.
116.
Defendants, as more specifically set forth above, each performed overt acts in
pursuance of their conspiracy.

117.
As a direct and proximate result of The Buchwald Defendants, Cox Defendants
and Davidson Defendants acts, Plaintiff suffered substantial economic and emotional injury,
damage, loss and harm, anxiety, embarrassment, humiliation, shame, damage to reputation and
severe emotional distress, in an amount subject to proof; which damages are continuing in nature
and will be suffered in the future.
EIGHTH CAUSE OF ACTION
(Intentional Interference with Contractual Relations and Advantageous Business
Relationships Against Gawker)
118.
contained in Paragraphs 4(d), 6, 7 through 21, 23 through 25, 31, 32, 34 through 50, and 52
through 54, inclusive, as though fully set forth herein.
119.
At all relevant times herein, Gawker was aware that Plaintiff had specific
employment, endorsement and other contracts, and advantageous business relationships, and
acted intentionally, maliciously and without justification in causing the contents of a court-
{BC00089530:1}
29
ordered confidential transcript relating to Plaintiff to be disseminated to the media when Gawker
knew or should have known that such actions would cause or were likely to cause substantial
interference with Plaintiffs employment, endorsement and other contracts, and his advantageous
business relationships, of which Gawker had knowledge.
120.
The conduct by Gawker was intentional and malicious and done for the purpose
of causing, or was known by Gawker to be likely to cause, the termination of and substantial
interference with Plaintiffs employment, endorsement and other contracts, and his advantageous
business relationships.
121.
In doing the acts alleged hereinabove, Gawker acted outrageously and beyond all
reasonable bounds of decency.

122.
As a direct and proximate result of the aforementioned wrongful conduct by
Gawker, Plaintiff has suffered substantial economic injury, loss, damages and harm from the
actual interference with Plaintiffs employment, endorsement and other contracts, and
advantageous business relationships in existence in July 2015, in an amount subject to proof.
(Plaintiff does not seek against Gawker Defendants herein any liability or damages that would be
duplicative of the liability determined and damages awarded in the Prior Action.)
123.
Gawker acted with actual malice and reckless disregard of Plaintiffs rights.
124.
The aforementioned acts of Gawker were done intentionally or with a conscious
and/or reckless disregard of Plaintiffs rights, and with the intent to vex, injure or annoy, such as
to constitute oppression, fraud or malice.
125.
interference with contractual relations or advantageous business relationships, against Gawker.
{BC00089530:1}
30
NINTH CAUSE OF ACTION

(Intentional Infliction of Emotional Distress
Against Gawker)
126.
contained in Paragraphs 4(d), 6, 7 through 21, 23 through 25, 31, 32, 24 through 50, and 52
through 54, inclusive, as though fully set forth herein.
127.
At all times herein, Gawker acted intentionally, maliciously and without
justification, in causing the contents court-ordered confidential transcript relating to Plaintiff to

be disseminated to third parties when Gawker knew or should have known that Plaintiff would
suffer severe emotional distress as a result.
128.
The conduct by Gawker was intentional and malicious and done for the purpose
of causing, or was known by Gawker to be likely to cause, Plaintiff to suffer severe emotional
distress, and was done with the wanton and reckless disregard of the consequences to Plaintiff.
129.
In doing the acts alleged hereinabove, Gawker acted outrageously and beyond all
reasonable bounds of decency, and intentionally inflicted severe emotional distress upon
Plaintiff, to his detriment.
130.
Gawker acted with actual malice and reckless disregard of Plaintiffs rights.
131.
As a direct and proximate result of the aforementioned acts by Gawker, Plaintiff
has suffered emotional injury, damage, loss, harm, anxiety, embarrassment, humiliation, shame,
and severe emotional distress in an amount subject to proof; which damages are continuing in
nature and will be suffered in the future. (Plaintiff does not seek against Gawker Defendants
herein any liability or damages that would be duplicative of the liability determined and damages
awarded in the Prior Action.)
{BC00089530:1}
31
132.
The aforementioned acts of Gawker were done intentionally or with a conscious
and/or reckless disregard of Plaintiffs rights, and with the intent to vex, injure or annoy, such as
to constitute oppression, fraud or malice.
133.
infliction of emotional distress, against Gawker.

PRAYER FOR RELIEF
WHEREFORE, Plaintiff, Terry Gene Bollea, prays for judgment against each of the
Defendants as follows:
1.
For an award of general and special damages in an amount in excess of the
minimum jurisdictional limits of this Court in accordance with proof at trial together with
interest thereon at the maximum legal rate;
2.
For costs of suit incurred herein;
3.
For reasonable attorneys fees against only the Buchwald Defendants, Cox
Defendants and Davidson Defendants, pursuant to the Sixth Cause of Action, only;
4.
For preliminary and permanent injunction against only the Buchwald Defendants,
Cox Defendants and Davidson Defendants, including all persons acting under their control,
prohibiting any and all activity that would cause the distributing, disseminating, disclosing,
publishing, displaying, posting for view or access on or through the Internet or any other manner
or media outlet, broadcasting, transferring, licensing, selling, offering to sell or license, or
otherwise using, exploiting or attempting to exploit, the surreptitious recordings of Plaintiff, or
any portions or content thereof or any copies thereof, in any and all formats and media, including
all electronic and physical media;
5.
For an Order and Judgment requiring only the Buchwald Defendants, Cox
Defendants and Davidson Defendants to turn over to Plaintiff all surreptitious recordings of
{BC00089530:1}
32
Plaintiff, or any portions or content thereof or any copies thereof, in any and all formats and
media, including all electronic and physical media; and
6.
For such other and further relief as to this court may deem and proper.
DEMAND FOR JURY TRIAL
Plaintiff, Terry Gene Bollea, hereby demands a trial by jury on all issues so triable.
Respectfully submitted,
Dated: May 2, 2016
/s/ Shane B. Vogt

Kenneth G. Turkel, Esq.
Florida Bar No. 867233
[email protected]
Shane B. Vogt, Esq.
Florida Bar No. 257620
[email protected]
BAJO | CUVA | COHEN | TURKEL
100 N. Tampa Street, Suite 1900
Tampa, Florida 33602
Telephone: (813) 443-2199
Facsimile: (813) 443-2193
Charles J. Harder, Esq.
California Bar No. 184593
(Pro Hac Vice application to be filed)
[email protected]
HARDER MIRELL & ABRAMS LLP
132 S. Rodeo Drive, Suite 301
Beverly Hills, California 90212
Telephone: (424) 203-1600
Facsimile: (424) 203-1601
David R. Houston, Esq.
Nevada Bar No. 2131
(Pro Hac Vice application to be filed)
[email protected]
LAW OFFICES OF DAVID R. HOUSTON
432 Court Street
Reno, Nevada 89501
Telephone: (775) 786-4188
Facsimile: (775) 786-5091
Attorneys for Plaintiff Terry Gene Bollea,
professionally known as Hulk Hogan
{BC00089530:1}
33
Filing # 40950062 E-Filed 05/02/2016 12:17:59 PM
EXHIBIT A
TAMPAPD
GENERAL OFFENSE HARDCOPY
COPY FOR THE GENERAL PUBLIC
GO# 2014-332377 EXCEPTIONALLY
CLEARED
2100-8 EXTORTION
General Offense Information

Operational status: EXCEPTIONALLY CLEARED
Reported on: May-23-2014 (Fri.) 1015
Occurred between: Jan-05-2012 (Thu.) 600 and Mar-01-2012 (Thu.) 1300
Approved on: May-24-2014 (Sat.) by: 31598 - MARTINEAU, LISA M (Retired)
Report submitted by: 42324 - FINE, RALPH
Org unit: Squad 102
Address: 5021 NASSAU ST W
Municipality: TAMPA
District: 1 Beat: A4 Grid: 118
Felony/Misdemeanor: FELONY
Bias: None (no bias)
Special study: Not Applicable
Family violence: NO
Offenses (Completed/Attempted)
Offense: # 1 2100-8 EXTORTION - COMPLETED
Location: Commercial Off Bldg
Offender suspected of using: Not Applicable
Criminal activity: Not Applicable
Weapon type: Threat/Intimidation, Not Applicable
f For: 52253
Printed On: Nov-13-2015 (Fri.)
Page 1 of311
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2100-8 EXTORTION

CLEARED
Related Event(s)
CP
2014-332377
Related Person(s)
1. VICTIM# 1 - CLEM, BUBBA THE LOVE SPONGE
(Case Specific Information)

Sex: MALE
Race: WHITE
Date ofbirth: Apr-23-1966
Address: 5021 W NASSAU ST
Municipality: TAMPA, Florida 33607Phone Numbers
Home: (727) 241-8466
Business: (813) 832-1000
Particulars
Occupation: RADIO HOST
Employer: SELF-EMPLOYED 5021 W NASSAU ST
Citizenship: America, United States of
Marital status: Single
Ethnicity: USA
Language( s) spoken: English
Height: 5'10 Weight: 250 lbs.
Disability: None Known
Build: Large Complexion: MEDIUM
Eye color: HAZEL
Hair color: BROWN
Hair style: Short Length
Master Name Index Reference

Name: CLEM, BUBBA THE LOVE SPONGE SPONGE
Sex: MALE
Race: WHITE
Ethnicity: USA
Address: 5021 W NASSAU ST
Municipality: TAMPA, Florida 33607Phone numbers
Home: (727) 241-8466
Business: (813) 832-1000
Alias(es)/AKA
Name:
CLEM, TODD
IFor: 52253
Address:
Sex:
M
DOB:
Apr-23-1966
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Linkage factors
Resident status: City (Tampa)
Statement taken : YES
Age range : 30-49 Years
Access to firearm: NO
Victim of:
2100- 8 EXTORTION- COMPLETED
Victim's Relationship to Offender : Victim Was Employer
Person's role : SUSPECT/OFF #1
Person's name : LOYD, MATTHEW C Feb-07-1979
Victim's Relationship to Offender : Victim Was Stranger
Person's role: SUSPECT/OFF #2
Person's name: DAVIDSON, KEITH M Apr-08-1971
Offender LEOKA details

LEOKA details
Officer's experience (in years) : 0
2. VICTIM # 2 - BOLLEA, TERRY

Sex: MALE
Race: WHITE
Date ofbirth: Aug-11-1953
Address: 1040 EL DORADO AV
Municipality: CLEARWATER BEACH, Florida 33767Phone Numbers
Cellular: (727) 365-7174
Home: (727) 432-1084

Name: BOLLEA, TERRY
Sex: MALE
Race:WIDTE
Date ofbirth: Aug-11-1953
Address: 1040 EL DORADO AV
Municipality: CLEARWATER BEACH, Florida 33767Phone numbers
Home: (727) 432-1084
Cellular: (727) 365-7174
Linkage factors
Victim of:
2100- 8 EXTORTION- COMPLETED
IFor: 52253
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Victim's Relationship to Offender : Victim Was Acquaintance

Person's name: LOYD, MATTHEW C Feb-07-1979
Victim's Relationship to Offender: Victim Was Stranger
Person's name : DAVIDSON, KEITH M Apr-08-1971

LEOKA details
3. SUSPECT/OFF# 1- LOYD, MATTHEW CHRISTIAN

Sex: MALE
Race: WHITE
Date ofbirth: Feb-07-1979
Address: 9601 WOODBAYDR
Municipality: TAMPA, Florida 33626Phone Numbers
Home: (727) 776-1855
Particulars
Occupation: UNK
Employer: UNK
Master N arne Index Reference

Name: LOYD, MATTHEW CHRISTIAN
Sex: MALE
Race: WHITE
Municipality: TAMPA , Florida 33626Phone numbers
Home: (727) 776-1855
Linkage factors
Resident status: City (Tampa)
Access to firearm: NO

LEOKA details
4. SUSPECT/OFF# 2 -DAVIDSON, KEITH M
IFor: 52253
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Sex: MALE
Race: WHITE
Address: 8383 WILSHIRE BLVD Apartment: 510
Municipality: BEVERLY HILLS, California 90211Phone Numbers
Business: (323) 658-5444
Cellular: (310) 936-5361
Particulars
Place ofbirth: Massachusetts
Occupation: ATTORNEY
Employer: SELF
Master Narne Index Reference

Name: DAVIDSON, KEITH M
Sex: MALE
Race: WHITE
Address: 8383 WILSHIRE BLVD Apartment: 510
Municipality: BEVERLY HILLS , California 90211Phone numbers
Business: (323) 658-5444
Cellular: (310) 936-5361
Linkage factors
Resident status : Out of State

LEOKA details
5. INVOLVED# 1- CARREGA, TASHANICOLE

Sex: FEMALE
Race: WHITE
Municipality: TAMPA, Florida 33626Phone numbers
Home: (813) 810-3533
Cellular: (813) 810-3533
Particulars
IFor: 52253
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Height: 5'6
Build: Medium Complexion: MEDIUM
Hair color: BLOND/STRAWBERRY
Linkage factors
Resident status : County (Hillsborough)

LEOKA details
6. INVOLVED# 2- BURBRIDGE, LORI

Master Narne Index Reference
Sex: FEMALE
Race: WHITE
Address: 107 KARDE CIRCLE Apartment: D
Municipality: BRANDON , Florida 33510Phone numbers
Home: (813) 802-4107
Business: (727) 238-4038
Cellular: (813) 475-8038
Linkage factors
Resident status: County (Hillsborough)

LEOKA details
Officer's experience (in years): 0
IFor: 52253
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Related Text Page(s)

Document: CASE SUMMARY
Author: 42324 - FINE, RALPH
Related date/time: May-23-2014 (Fri.) 1015
The victim reported that personal property taken from him in 2012, without
his knowledge or permission, was tweeted to him in a photo on today's date.
The victim believes the tweeted photo was intended as a personal threat
because the release of its content has the potential to negatively affect
his reputation and his livelihood.
For: 52253
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Document: INITIAL REPORT
I responded to 5021 W. Nassau St. where I met with the victim. The victim
(W/M Clem) provided me with a photocopy of a tweeted message he received to
his BTLS (Bubba The Love Sponge Show) account. The message was provided
via a subject identified through his Twitter account as "Joshisinthecity."
The message stated that a letter and DVD was left on his vehicle because he
has a "Bubba Army" bumper sticker attached to his vehicle. The tweeted
message asked for a contact number and that he was attempting to return the
DVD left in his possession.
The photo of the DVD had the name "Denzel" written on it and W/M Clem
identified "Denzel" as a close personal friend.
W/M Clem also identified the handwriting on the DVD in the photo as his
own.
I collected the photocopies of the tweeted message and took W/M Clem's
statement. I then provided W/M Clem a report number.
As of the completion of this report, there are no other known investigative
leads beyond the twitter account, "Joshisinthecity."
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Document: STATEMENT
W/M Clem was sworn and advised the statement he provided is true and
accurate.
W/M Clem advised that he is the host of a syndicated radio program and is a
known public figure.
W/M Clem advised that during October of 2011, he and his ex-wife began
divorce proceedings. During this time, their relationship was contentious
and he had concerns that personal information could potentially be made
public by his wife that could affect his reputation as a public figure in
the media. The primary focus of his concern involved the existence of
several homemade DVD's depicting consensual sexual contact between his wife
and other subjects of which he was a knowing participant. As a result of
his concern, W/M Clem transferred the DVD's from his horne to his workplace
where he believed they would be more secure.
During the months of December 2011 and January 2012, he and his staff moved
equipment and property from one radio studio to a newer radio studio at his
current location. W/M Clem advised he specifically remembered moving the
DVD's to an upstairs office/storage area in his new studio that was
designated for his own personal items.
In March of 2012, W/M Clem learned that a screen shot of a portion of one
of his personal DVD's had been leaked to the media. This screen shot
depicted a still video image of his then wife and a close personal friend,
professional wrestler and media figure Hulk Hogan, as they were involved in
a consensual sexual encounter. At that time, W/M Clem immediately
responded to the office/storage area and became aware that each of his
DVD's were now missing.
W/M Clem advised that at that time, he did not believe his wife was
involved in releasing the screen shot to the media or was responsible for
their disappearance however, he could not rule out that she had been able
to copy the DVD's prior to his moving them to his workplace. His minimal
suspicions of her were also the result of the contentiousness of their
ongoing divorce at that time.
W/M Clem advised that he had stronger suspicions that a former co-worker
had taken the DVD's from the office/storage area. W/M Clem advised that
IFor: 52253
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Matt Loyd (AKA "Spice Boy") was formerly an employee and an on-air member
of his radio show. During the months of January and February 2012 W/M
Loyd began to lobby with corporate executives to be granted a hosting
position of his own radio program. W/M Clem believes that Loyd wanted to
be considered as an available replacement to host his (The Bubba The Love
Sponge Show) show in the event that he (W/M Clem)
was fired. Shortly
after this in April of 2012, Matt Loyd began to host his own radio program.
1
On today's date, W/M Clem received a tweet via social media to his radio
show's twitter account. The tweet depicted a photo of one of the DVD's
taken from W/M Clem's office/storage area in 2012. W/M Clem recognized the
handwriting on the DVD as his own. W/M Clem related that he knew the DVD
contained footage of a similar nature to other DVD's involving his ex-wife
and was intended for his own personal use.
W/M Clem advised that he believes the tweeted
of his stolen personal
property is intended as a message and a threat to him. The personal
footage depicted on the tweeted DVD has the potential to negatively affect
his reputation and also, potentially, his livelihood were it released
publicly.
W/M Clem related that he believes Matt Loyd had both the means and the
motive to steal his personal DVD's. During his employment on The Bubba The
Love Sponge Show, he had unrestricted access to all areas of the building
including the office/storage area. He also, based upon his knowledge of
Loyd's actions in 2012, believes that Loyd had a desire to take over as a
host of his show. W/M Clem believes that Loyd took the DVD's with the
intent to expose their content to the media and effectively cause his
dismissal as a result of the associated scandal.
W/M Clem also advised that there are an additional 12 employees who work in
his studio and each of them have access to the upstairs office/storage
area. He does not suspect any current or prior employees of the theft of
the DVD's other than Matt Loyd.
W/M Clem related in conclusion that he made a conscious decision to not
report the theft of the DVD's originally in 2012 when he became aware of
their disappearance. His rationale for this was that although Hulk Hogan
had been exposed as a result of the release of the specific DVD involving
him, other involved subjects had not yet been exposed and he hoped by not
reporting the theft, he could protect them from potential scandal that
could result from his offense report.
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Document: INVEST REPORT
Author: 47801 -SCHLEMMER, JOHN
Related date/time: May-27-2014 (Tue.)
On 05/27114 I received this assigned case reference latent investigation. The phone numbers listed
for Clem were longer valid so I left a message with Cox Media Group for him to call me.
On 05/28/14 I received a call from Clem's agent, Tom Bean.
Bean provided me with his phone number and said he would be able to have Clem call me should it
become necessary. I informed Bean that I would like to speak with Clem about responding back to the tweet he
received before I subpoenaed Twitter.
Bean stated he would have Clem call me.
On 05/30/14 I received a call from Clem. I informed him of Twitter's policy to notify the account
holder when a subpoena is issues. Therefore, I would like for him to respond to the tweet. Clem agreed and it was
decided that he would tweet something similar to "hey buddy, thanks for looking out." And then see if there was
a response.
On 06/24114 I attempted to contact Clem and left a message.
On 06/25114 I completed a Subpoena for Records requesting information for the Twitter handle
#Joshisinthecity which was used to send the tweet regarding the DVD. The subpoena was reviewed and approved
by ASA Goldstein.
On 07/08114 I received the subpoena information from Twitter which showed the account was
created on 05117/14 at 2306 hours, using the email address [email protected], from an IP
address of97.76.206.251. A computer check of the IP address used to create the Twitter account came back to
being a Time Warner account.
I prepared a subpoena for records request to Time W amer for account information. The subpoena
was reviewed and approved by ASA Traina
On 07/09114 I contacted Clem and informed him of the email address used to create the Twitter
account. He stated that it did not sound familiar to him.
Clem informed me that he had received a tweets from the subject and would email them to me.
The tweets Clem emailed me were as follows:
Clem: 6/4/14, 10:39 AM "I'm trying to reach out to you"
Josh: 6/4/14, 11:05 PM "Sorry was outta town My girlfriend told me not to give it back
what 2
to you because of all the stuff going on. I like ya and dont know
do".
Clem: 6/6114, 4:08AM "Well i would like to get it back".
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Josh: 7/2114, 7:55AM "Just got back & listening. You fired Shanon? He was my
favorite".
Clem: 7/2/14, 10:25 AM "No I didn't fire him at all. It was his choice to leave".
Clem: 7/2/14, 10:26 AM "U ever going 2 meet me to pick up that DVD".
Clem informed me that there has been no other contact from the subject..
On 07/17/14 I received information from Time Warner that the IP address belonged to Bright house
Networks.
I prepared a subpoena for records to Bright house Networks account holder information regarding
the IP address. The subpoena was reviewed and approved by ASA Goldstein.
On 07/23114 I received the information from Bright house Networks which showed the IP address as
being assigned to Knight Global Entertainment, 18 2nd Street North in St Petersburg, FL. The listed contact on
the account was J C Harkins.
A computer search of the address, 18 2nd Street North in St Pete carne back to Jannus Live where
concerts as well as as Jannus Live TV show featuring Matt "spice boy" Loyd, is filmed.
On 08/20/14 MPO Miller and I responded to Janus Live and met with office manager J C Harkins.
I informed Harkins that I would like to speak with him concerning the IP address in question. Harkins told me
that the IP address is used on the third floor in an area were several of the Jannus Live show workers use. Harkins
informed me that on the night of 05117114 a group called "Soul Circus Cowboys" was performing.
I informed him that I would like to speak with Matt Loyd and his cameraman, Josh Vozda.
Harkins contacted them and they agreed to meet with us in the business's office.
Josh Vozda arrived withing a few minutes. I explained to Vozda that a twitter account had been
created on 05/17114 at 11:06 PM from the business using the handle Joshisinthecity. He denied having any
knowledge of the Twitter account and stated that he hardly ever uses the third floor office. He believes that on the
night of 05/17/14 he left immediately after the show which would have ended at 11:00 PM.
Approximately twenty minutes later Matt Loyd arrived. MPO Miller, J C Harkins, Matt Loyd and I
sat down in their conference room.
I informed Loyd that I was conducting an investigation that involved a Twitter account created on
05/17114 from an IP address at the business and that this Twitter account has been used in possible criminal
activity. Loyd denied knowing anything about it. I informed him that the account was opened using an email
of radiornanflavor [email protected] and that I thought it was him do to him being in radio, radioman, and his
nickname being spice boy, flavor.
Loyd stood up and asked if we could speak in private.
MPO Miller and I followed Loyd into a side office. Once in the office Loyd stated, "ok, I created that
twitter account, where do we go from here?".
I asked Loyd why he would go to the trouble of creating a fictitious email and then using the email
address to create the twitter account. He responded by saying "I didn't want him to know it was me. I wanted him
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to squirm. He is a very bad man and has a lot of connections, even in law enforcement. I have seen him make a
phone call and people get arrested."
I asked Loyd where the DVD was. He stated, "I don't have it. I made the one in the picture from a
blank disc and wrote on it."
I informed Loyd that Clem identified the DVD in the photo as being his, with his handwriting.
Loyd stated "I made the one in the picture. I took a blank disc and wrote on it with a sharpie".
I asked Loyd how he knew Clem was missing a DVD with Denzil on it. He stated, "everyone knew
his cop buddy and ex-wife's sex tape was missing".
I asked Loyd how he came up with the date on the disc. He stated "I just made it up".
I informed Loyd that the date was significant because that is the exact date the stolen DVD was
made.
Loyd then stated "I am just trying to focus on my family and put this all behind me".
Loyd admitted to creating the Twitter account and sending the messages to Clem, along with the
photo of the DVD. Loyd stated that the DVD in the photo was just a blank one he made to look like one of
Clem's missing DVDs.
I informed Loyd that Clem identified, from the tweet photo, the DVD as being his. Loyd denies
taking any of Clem's DVDs and insisted that he made the one in the photo.
Loyd said he did this as a prank because Clem is always talking bad of him in the media and on the
radio.
Loyd swore that the statements he made to us were the truth.
On 12/26/14 I contacted Clem and informed him of the status of his case. I informed him that I
would like to obtain some handwriting samples of his and we agreed to meet on 12/31/14 at 1100 hours, at his
office, 5021 W Nassau Street in Tampa.
On 12/31114 I met Clem at his office and swore him in. Clem informed me that during the course
of his divorce, his ex-wife Heather Clem had made references to the sex tapes she had made with Terry Bollea,
Hogan, and also his childhood friend Denzil Washington, who is a Terre Haute Indiana Police Sergeant.
Clem was concerned that she would release these videos to the public and removed them from his
home. He stored them at his studio, 5025 W
lemon St in Tampa.
In March of2012 his business moved to their current studio at 5021 Nassau Street in Tampa. During
the move he distinctly recalls the Hogan, Denzil and Angie sex DVDs being in a box along with numerous other
DVDs, CDs and headphones. This box was moved into an unoccupied upstairs office. The rest of the upstairs was
unfmished. None of the employees at that time utilized the upstairs.
Clem stated that the Hogan DVD had been in a round DVD case. The type that holds multiple discs.
He stated that the Denzil DVD had been in it's own individual clear plastic case and that the Angie
DVD was in a separate case similar to the Hogan case.
Clem said he realized the DVDs were missing once a video clip from the Hogan recording showed
up on-line. Clem said he went to the box upstairs and noticed the only things missing were the sex tape DVDs.
Clem stated "you can't have one of the discs without the others".
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Clem provided me with (6) discs that he had previously written on with a Sharpie. The handwriting
appears to be the same as the handwriting on the DVD in the photo Loyd tweeted to Clem.
Clem informed me that the FBI had conducted an investigation involving the Bollea DVDs and he
thought that case was over.
Clem desires to prosecute anyone involved in the theft and illegal use of his property.
I contacted the Tampa FBI Field office regarding the Bollea DVD investigation and was told that
Special Agent Shearn was the lead Agent.
I then contacted Agent Shearn who informed me that he had conducted an investigation regarding
the Bollea sex video and the US Attorney's Office declined to file charges. I informed Agent Shearn of my
investigation and the admission from Matt Loyd.
Agent Shearn told me he would have to speak with the Assistant US Attorney to obtain approval
before discussing the case with me.
On 01/15/15 I was contacted by FBI SA Jason Shearn. He informed me that Assistant US Attorney
Sweeney had authorized him to provide me with non-grand jury subpoena information reference the case. SA
Shearn informed me that the FBI obtained the original DVDs during an operation. The operation was the result
of an extortion involving Matt Loyd, attorney Keith Davidson, and Lori Burbridge. During this operation the
original DVDs were delivered by Lori Burbridge, a female associated with Matt Loyd, via an attorney named
Keith Davidson. SA Shearn and I made an appointment for 1120/2015 at 1330 hours to review his case.
I contacted Assistant State Attorney Division Chief Matt Smith to discuss my investigation and
informed him of the FBI's closed case which was related. ASA Smith agreed to accompany me to view the case
at the FBI office.
On 01120/15 ASA Division Chief Matt Smith and I responded to the FBI Pinellas office. SA Shearn
showed us the original DVDs that he was currently holding as evidence. The DVDs were delivered by Lori
Burbridge during a controlled transaction on 12114/2012. The DVDs were in a black and silver hard case. Inside
the case were several DVD sleeves. There were three DVDs total. One was labeled HOGAN 7/13/07, another
was labeled HOOTIE 7/3/07, and the third was labeled HOOTIE with no date.
ASA Smith, SA Shearn and I viewed the DVDs and noted the following;
Disc marked HOGAN 7/13/07 contained Heather Clem and Terry Bollea engaging in sex. Bollea
does not look at the camera. The camera appears to be on a high ledge in the master bedroom behind a plant.
There is no discussion about them being recorded.
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The disc marked HOOTIE 7/3/07 showed the camera to be in the same location as the previously
mentioned disc. Bollea and Heather are standing next to the bed, Heather is topless and facing Bollea as Bubba
walks into view and comments about a scratch she has on her back. Bubba then leaves the room. Bollea and
Heather engage in sex.
The disc marked HOOTIE with no date shows that Bubba walks in after sex between Bollea and
Heather. Bollea, Heather and Bubba have conversation. Bollea leaves. Bubba makes comment about tape being
used for retirement. Bubba says he is going to get the tape and walks out. Tape ends.
I reviewed the case reports and noted that on 10/16/2012 Atty David Houston and his client, Terry
Bollea, meet with the FBI at the Pinellas Office. Houston informed them that he had contacted Clearwater PD
and the St Petersburg PD reference the filming of his client. He was told that the filming was "out of statute" and
was encouraged to contact the FBI.
The FBI then began their investigation which lead to recorded phone conversations, a recorded
operation to purchase the DVDs, and interviews. SA Shearn provided me with copies of the recorded phone calls
and the recordings made during the transaction to obtain the DVDs.
I listened to the recorded phone conversations between Keith Davidson and David Houston which
were provided by the FBI. The following is a summary of each call:
10/22/12 call
KD- We can say they came from the hand ofBubba
KD - You're buying the original or a copy made by Bubba
KD - There's no indication at all that your client knew it was running
KD - Viewed them through a streaming service
KD - He seems like a really nice guy going through a bad part in life
KD - He confides in Clem, talking about deteriorating marriage.
KD- Wants to start negotiating
DH- $1.00
KD - $1 million
KD - reference dollar figure "you know I still need to talk to my people".
10/28/12 call
KD- Client is under the impression that it went from Bubba's hands into his own.
KD - As far as assurances for your client, everything that I said on prior occasion stands. Like
representation and warranties and the agreement.
1112112 call
KD- I have authority, bottom line $400,000
KD- Three separate DVD's
DH- Asks if they would be willing to split them up. Says one is already out there. So only interested
in other two.
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KD- ... there's one that's more inflammatory than the others and then carries the lion share of the
value.
KD - have gone twice at a million and dropped it to $400,000 and have heard nothing in response.
KD - As with any settlement, you're trying to eliminate risk.
DH - TMZ, Gawker, Dirty.com, Hersch at Vivid, Sexlink.com, these are the five entities that claim
to have seen these things or have copies.
KD- Understanding is that the materials in client's possession are the materials which were shared.
KD The materials were streamed to me.
KD- Agrees on $300,000. 50% down at execution, 25% in 9 months, 25% in 16 months from the
date of execution.
KD- Acknowledges he knows Terry holds copyrights to the videos and by Gawker continuing to run
the video violates his copyright.
KD -If fails polygraph. So now you're in a position where you say, ok, are you really going to let my
pissed off client walk out with the tapes, you know what I
mean? It's
so, it really does nothing because the deal has to close.
11127/12 call
They have a discussion of the agreement and the uses of names.
The following is a summary of the 12/14/12 transaction recordings provided to me by the FBI:
12/14/12
11:00 Davidson enters. Introductions are made.
Davidson explains content of DVDs.
11 :08 Davidson agrees that the person they are meeting today is the one who leaked to
Gawker and has possessed the tapes.
11:09 Houston asks which tape has the issues. Davidson says tape 2 talks about his son's
twin girlfriend. Davidson says tape 3 talks about n word,
Brooke
dating black guy, etc.
Davidson says tape 3 around the 49 minute mark.
11:17 Houston asks "Do you know where she got them from Keith". Davidson says
"Yes, she bought the case and does not know where she bought
them
from. Someone who was close to Todd and is no longer close to Todd gave them to her. There was an education
process with my client.
My client gave her the tapes."
"Something you will have to deal with Bubba, we know these things came from
him" (meaning Bubba).
Davidson says you have 2 loose ends, Bubba and this.
11 :21 Davidson says "my client is in no way associated with Heather". Houston says
sounds like a Bubba girlfriend. Davidson says "no, more like a
professional
relationship". Davidson says "I think it is a former employee or something like".
Davidson says "I can't disclose everything or they are going to walk".
11 :24 Houston asks why does Bubba give it to a former employee when he feels its
valuable enough to retire on.
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Davidson asks Houston if they can speak in private and they enter bathroom.
Davidson says came from a former employee of Bubba who hates Bubba. He says
"I don't know if they were stolen and quite frankly I don't
want to
know if they were stolen".
11 :3 7 Davidson leaves to get LB.
11:42 LB and Davidson enter room.
12:00 Houston, Davidson and Bollea leave room and go to hotel restaurant.
Davidson says he does not know any of these people. It's his understanding that
Bubba has a unique personality he can be a vindictive person.
Davidson says he heard Bubba and Heather met Petraeus at a swingers party and
it is rumored they have video.
13 :05 Davidson gives his word he will aggressively work to have Gawker take it off the
site.
13:06 Davidson offers to show tapes for authenticity. Hogan does not want to watch
them. Houston says to have them view beginning then fast forward
to
end.
13:55 Houston, Bollea and Davidson are viewing tapes.
13:58 Davidson said Mr. X was shown tapes is how he knew they were there.
Heather refuses to sign off her rights to the videos according to Houston.
Davidson says it is his understanding that Heather has no involvement.
14:02 Discussion about why Heather refuses to sign a walk away agreement.
Hogan asks for verification these tapes were stolen
Davidson says I can't say that but a reasonable person would believe that.
14:06 Davidson says ifGawker will not take it down he will prepare a declaration that
he represents the possessor of the tapes who stole them.
Houston says Gawker indicates that JW Moreno gave them the footage of Hogan.
14:10:33 tape ends
Session#2
14:10:34 tape begins with the sound of them walking.
14:12:33 back in the room with LB and polygraph operator Orr.
14:19 signing agreement and accepting DVDs.
14:21 Houston explains to Davidson error in his office making the check $150,000.
They change agreement to reflect that.
14:26:03 FBI enter. Sounds like Houston and Hogan walked out.
14:27:02 tape ends.
I reviewed the FBI reports and noted that on 12114/12 Lori Burbridge, in a post Miranda interview
with the FBI, stated that she was instructed by Atty Keith Davidson and Matt Loyd to say she and "Mr. X" (Matt
Loyd) were the ones who leaked the Hogan clip to Gawker in order to complete negotiations with Bollea and his
attorney.
Burbridge says Loyd leaked the stills to THE DIRTY.COM which did not create enough buzz in the
media.
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Loyd, who possessed the tapes, contacted TMZ who in tum put him in touch with Atty Keith
Davidson.
Around this time a clip was leaked to Gawker. Carrega (Loyd's wife) contacted Burbridge and
explained that Loyd had the Bollea sex tapes and was actively trying to sell them. Burbridge was asked to
become involved in exchange for $10,000.00 compensation.
Burbridge states that on Veteran's Day 2012 (November 11) she went to Loyd and Carrega's house
for a conference call with Atty Davidson. Loyd and Carrega had Burbridge view all three videos. While viewing
the videos Burbridge and Carrega took handwritten notes.
Burbridge states that on 12/11/2012 Loyd and Carrega came to her work, Bank of America, to
review the Settlement Statement.
Burbridge says that on 12113/2014 Loyd, Carrega, Davidson and her go to dinner at Ceviche's in St
Petersburg prior to the settlement meeting. She questions the legality of what they are doing and Atty Davidson
brags about handling several similar cases.
Burbridge said that in preparation for the 12/14/2012 settlement meeting Loyd gave her $200 to
rent a car in case someone followed her after the meeting.
Burbridge was
instructed to return the car to the airport and not at the location she rented it from. Carrega was to pick her up at
the airport.
Burbridge said she was to receive $5000 as partial payment for her involvement which she was to
pay towards her repossessed car. The remaining $5000 was to come from Loyd.
Burbridge stated that Loyd leaked the clip to TMZ and was paid $8500. To remain anonymous Loyd
had Burbridge sign the tax form for the money and was told that Loyd and Carrega would help her with the taxes
on the income.
Burbridge said she received a TMZ check, via Fed-Ex, that she deposited into her bank account. She
then got an $8000 cashier's check made out to Matt Loyd.
Burbridge said she received a total of $500 for assisting Loyd with the TMZ transaction.
Burbridge stated that "Janerro" was the name Loyd used when dealing with Gawker.
Burbridge states Loyd and Carrega used multiple fake email accounts, potentially Gmail, to converse
and deal with media sites regarding these tapes. Once used, they would shut them down to avoid being traced.
Burbridge states Bubba Clem has nothing to do with the leaks or sale of the tapes. She said Loyd is
afraid of Bubba and is afraid of him finding out he was selling the tapes.
On 12117112 Burbridge was called by the FBI. She informed them that she rented the car for the
transaction with her debit card at the Enterprise Car Rental near Webb Road and Hillsborough A venue. She says
she was reimbursed by Loyd.
Burbridge informed the FBI that Loyd and Carrega deposited the cashier's check into their son,
Jayden Carrega's, account.
She stated that she has not had contact with either Loyd or Carrega.
On 12/20112 Burbridge calls the FBI and informs them she found her hand written notes from
the Veteran's Day meeting with Loyd and Carrega. She says she had watched the videos on Loyd's MacBook
computer.
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On 01122115 I contacted Denzil Lewis, who had been recorded having sex with Heather Clem
which was documented on the DVD marked Denzil. Lewis informed me that he had been visiting the Clem's
between 2/15/08 and 2/18/08. Bubba and Heather agreed to him having sex with Heather and he knew it would
be recorded.
On 01/22/15 I called Burbridge who agreed to meet with me at her residence. TPD MPO D. Miller
and I met with Burbridge at 1825 hours. I informed Burbridge that I would like to talk with her concerning the
transaction she had participated in regarding some DVDs. She said she thought that was over. I informed her that
I was working a case where another one of the originally stolen DVDs had surfaced. She was concerned that she
needed to get something in writing to protect herself from being prosecuted. She said she should have done that
earlier when dealing with the FBI. Burbridge has two children, one 10 years old and one 4 years old. The younger
one kept interrupting our attempts at talking and it was agreed that we would meet the following Tuesday when
she is off work and her kids are in school.
On 01/23/15 I provided Burbridge an Investigative Witness Subpoena issued by ASA Division Chief
M. Smith. Burbridge accepted the subpoena and agreed to meet as requested.
On 01126/15 I was informed ASA Smith that Burbridge had sought council and the interview would
be postponed.
On 02/03/15 at 0900 hours Lori Burbridge, her attorney David Weisbrod, ASA M. Smith and I met
at the State Attorney's office for the purpose of conducting an interview of Lori Burbridge. A court reporter was
also present and recorded the interview. The following is a summary of the interview:
Burbridge stated that Tasha Carrega, Matthew Loyd's wife, and her have been friends for years.
Regarding the transaction from 12114112, Tasha called her and told her they had the tapes with Hogan to sell.
They had already obtained Davidson as their counsel for the exchange. She believed that Davidson was referred
to them by someone from TMZ. Tasha asked her to be the person trying to sell the tapes. Burbridge said she
went to Tasha and Matt's house and watched the DVDs so she would have historical info to be able to present
herself as the seller. She remembers watching the videos on Matt's MacBook laptop. She said there were (3)
videos and thinks they were in folders on the laptop. She said the only time she actually saw the discs was the day
everything happened, when she met Hulk and his attorney. She said that while they are watching the videos Matt
is the one pulling up the videos to view. Matt had told her she would get $5000.00 for her part. Burbridge said
they were watching the DVDs in preparation to speak with attorney Davidson. Burbridge said a speaker phone
call with Davidson was then made, Tasha and Matt were present. Burbridge remembers Davidson stating that she
needed to say, and he included in the contract, that she was the one who sold the video to Gawker. If they didn't
the whole deal possibly would not go through. Burbridge said it was pretty clear that Davidson knew they hadn't
leaked it to Gawker. They discussed how Matt obtained the tapes and he came up with a story about purchasing
them at a Bubba yard sale. Davidson did not like that story and suggested they instead bought a laptop with them
on it. Matt had explained to her that there were copies going the station and that is how she thought he obtained
them. Burbridge said that once the contract was written Matt brought it to her work for her to sign. At that time
she was working at the Bank of America on Hillsborough Ave in Tampa. Burbridge said she was not involved
in the actual TMZ deal. She said that was all Matt. Tasha had called her and asked her to receive the money
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since they were trying to keep a distance from their names. Burbridge recalls the TMZ check as being $10000.00
written in her name. The check came to her in Brandon by FedEx. She cashed it and gave Matt a cashier's check.
Matt paid her $500.00 for her part. She said the purpose of leaking the clip to TMZ was to build up interest. She
believes Matt became involved with Davidson through TMZ. Davidson told them if they did not claim to be the
ones to release it to Gawker the deal they were working on would not go through. Burbridge recalls meeting
with Davidson, Matt, and Tasha the day before the transaction at the Ceviche restaurant in St Petersburg. During
this meeting Davidson said he had brokered other sex tapes with celebrities that could have put them in a bad
light, such as Kanye West. Lori said the day of the transaction she met with Davidson at the Sand pearl Resort
in Clearwater. Davidson told her that the cat was out of the bag and that they knew she was not Mr. X but they
would say she represents someone who they are going to call Mr. X.
Burbridge stated that she spoke with Matt Loyd prior to this interview. She told him that I had
mentioned the DVD he tweeted to Bubba. Burbridge said Matt told her he was trying to make Bubba sweat. He
told her he worked for Bubba for years and he can forge his handwriting. He told her he posted it on Twitter.
At 1400 hours a telephone conference call was conducted at the State Attorney's office with David
Houston, the attorney for Terry Bollea. Houston stated that Davidson clearly indicated the tapes were stolen. He
said Gawker was aware of Matt Loyd's activities. Houston informed us that there was a civil trial against Gawker
set for 7/6/15. Houston agreed to contact Bollea so he could be interviewed.
On 02/04/2015 ASA Division Chief Matt Smith and I responded to 5021 W Nassau Street to meet
with Bubba Clem. ASA Smith contacted Clem's attorney, Diaco, who agreed to the interview. We met in Clem's
personal office with the door closed. Clem was introduced to ASA Matt Smith. Clem was informed that there
were some additional questions regarding this case. Clem was asked about a "Bubba Yard Sale". Clem said that
he has had four previous "Bubba Yard Sales" during which he sells different items from the show and donates the
money for charity. Clem said he has heard allegations that the leaked videos were purchased at one of these yard
sales which he says is not true.
Clem was asked if he has had any involvement with Tony Burton of the Buchwald Group. Clem
stated that he never has, but he knows that Burton is Mike Calta's agent. He also said that Howard Stem had been
represented by the Buchwald Group.
I asked Clem why the sex tapes were such a big topic of his divorce mediation with Heather. Clem
said he had a pre-nuptial agreement with Heather which did not leave her with very much.
Clem was asked ifBollea knew he was being recorded in the sex tapes. Clem said "no, he did not
know he was being recorded".
Clem said the recordings that he knew of involving his ex-wife Heather and others were; Hogan,
Denzil, a black guy from Miami, and a girl named Angie. Clem said when he received the DVDs from Heather
he did not look in the bag and take an inventory. He said he just put the bag in his desk drawer.
Clem confmned that his employee "twenty five cent" is Broderick E. Epps. Clem said that Matt
Loyd and Epps used to be very close friends. Clem does not believe that Epps had anything to do with the sex
tapes being stolen or exposed.
I asked Clem if he had shown the sex tapes to anyone and he said no.
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I also asked Clem if Loyd or Calta had sex with Heather. He said no.
On 02/06115 I met with Broderick Epps, also known as "twenty five cent", at the studio on Nassau
Street in Tampa. Epps was sworn in and stated the following: He currently works on Bubba's radio show as an
on air personality. He had previously worked on the Bubba show from 2005 until September of2012 when he
quit due to a conflict between him and Bubba. Epps said he and Mat Loyd, also known as "spice boy", worked
together on the Bubba show until Loyd got his own show. He said Loyd was always looking for "dirt" on Bubba
to use on his show. Epps said he had never seen sex videos with Bubba's wife and does not remember Bubba ever
saying he had them prior to them being exposed.
I subpoenaed the phone records for Matt Loyd's known phones which showed that from 3/7112 to
10/16/12 he had 38 calls with Mike Walters from TMZ.
I made several attempts to contact Mike Walters of TMZ, which were unsuccessful.
I subpoenaed and obtained phone records from both Matt Loyd's and Keith Davidson's phones. The
records show they made 35 calls to each other between 10110/12 and 12114112, the day of the FBI operation. The
records show they had no contact after then.
Burbridge's and Carrega's phone records were also subpoenaed. The records confirmed that phone
calls referenced in interviews were made.
On 0/12/15 I met with Agent Shearn who released the following items of evidence to me:
-(1) Silver box containing (3) DVDs
-(1) Check made to Keith Davidson from David Houston for $150,000
-Settlement Agreement signed on 12114112
On 03112/15 I delivered the silver box containing the (3) DVDs to TPD print examiner Thomas
Gonzalez for processing. Two of the DVDs had print evidence positive for ridge and were submitted through
AFIS receiving negative results.
On 04/01115 Heather Cole, Bubba Clem's ex-wife, was interviewed at her attorney's office. ASA
Matt Smith and a court reporter were also present. Cole was sworn in and stated the following: She stated that she
works in public access TV and that is how she met Bubba. Cole said they dated off and on for about (4) years and
were married in January of2007. She said they were married for 56 months. Cole stated that the sex she had with
others during her marriage to Bubba was consensual. She stated that Bubba insisted on it being videoed. I asked
Cole if Bollea knew he was being recorded and she said no. I told Cole that the in the videos it appears as though
she is positioning Bollea for the camera. She said she did that because that is what Bubba wanted. Cole said
Bubba could be very controlling. Cole said she remembers Bubba coming to the house after they had separated
and requesting the DVDs sometime around the end of2011.
On 04/16/15 I called Mike Calta and left a phone message. My message was returned on 04/21115
by Calta's attorney, Dominic Fariello. We made arraignments for Calta and me to meet the following morning at
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Fariello's office in Tampa. I received a call, later that same day, from Fariello who said Calta would not agree to
meet.
On 05/12/15 Tasha Carrega, Matt Loyd's wife, was interviewed at the Hillsborough County State
Attorney's office. Her attorney was present along with ASA Matt Smith and a court reporter.
The following is a summary of her interview: Carrega stated that she was married to Matt Loyd
on 6/22113. She said she has been "best friends" with Lori Burbridge since High School. When asked how she
became involved with the Bollea sex tapes she stated that Loyd and she were at a Bubba yard sale in 20 I 0 or
2011 where they purchased a Rocky DVD movie box set. Approximately (2) weeks after the purchase they went
to play the Rocky movies and discovered the sex tapes inside. She recalls there being 4 to 6 DVDs. Carrega
stated that she did not recall much about the tapes. I asked her if she recalled viewing the videos and taking
notes. She said she did not recall. I showed her a copy of her handwritten notes depicting the content of each
video. She then acknowledged it was her handwriting but did not recall why she wrote them. She did not recall
conversations, phone calls or meetings regarding this case. Carrega stated that she was at the West Shore mall in
Tampa with Loyd during the 12/14112 transaction. She said Loyd received a text message from Davidson saying
"raided, need legal representation".
On 06/16/15 Detective Kirlangitis and I met with Terry Bollea at his residence. I informed Bollea of
my current investigation and informed him that the DVDs involving him and Cole had been stolen at the same
time as the one tweeted to Clem by Loyd. Bollea was asked if he desired to proceed with prosecution for the
Extortion. He said he was interested but would need to confer with his attorney.
On 07/16/15 Detective Kirlangitis and I met with Patrick Fowler, aka Tuddle, in the TPD CIB
conference room. Fowler swore to tell the truth and stated the following. Fowler currently works for Clem on
the radio show. He remembered that sometime in 2012 Loyd and Calta were watching something on a desktop
computer at Cox media group's office in St Petersburg. He said they were laughing and making voices to try and
sound like "Hogan". Fowler said he went over to see what they were watching and it was a video of "Hogan" and
Bubba's then wife having sex. He stated that he only watched for a few seconds but he remembers the computer
monitor as having a smaller window where the video was being played and the desktop screen background with
icons behind it. He did not see any disc and did not know if what he was watching was the clip from Gawker or
from some other source. Fowler said in his opinion anyone with !-movie on an Apple device could have created
the clip he saw on Gawker.
During the video of the FBI operation on 12114/12, Lori Burbridge acknowledged viewing all (5)
videos involving Clem's wife which would have included the "Denzil" video. This statement, along with the
statement of Carrega confirms that Loyd had been in possession of the DVDs stolen from Clem.
Matt Loyd's phone records confirm calls to the media outlets attorney David Houston say he was
contacted by.
Matt Loyd's phone records show he initially contacted attorney Keith Davidson and call blocked his
number.
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Ceviche and Sand Pearl were subpoenaed and provided transaction records confirming Davidson
was at both the 12/13/12 Ceviche meeting and that he stayed at the Sand Pearl resort.
Enterprise car rental was subpoenaed and provided the rental agreement for the vehicle Lori
Burbridge used during the Sand Pearl meeting.
Conclusion: Matthew Loyd stole several sex tape DVDs from Bubba Clem's office building. He then
shopped clips of the Hogan DVDs to build interest, selling to TMZ, and concealing his identity by having Lori
Burbridge accept payment for him.
Mathew Loyd then contacts attorney Keith Davidson from California to engage in the extortion of
Terry Bollea. At the time of this contact and throughout the negotiations Davidson is suspended from practicing
law by the California Bar.
Davidson translates the necessity for Bollea to purchase these videos to Bollea's Attorney Houston
via FBI recorded phone conversations. Davidson's only option to keep from exposing the multiple videos and the
damaging content is to obtain payment which starts out at $1 Million. Davidson also acknowledges that his client
obtained them from his former employer without that former employers knowledge. Davidson assisted Loyd in
coming up with a more suitable story as to how the videos were obtained. He also instructed Loyd they would
have to admit to the Gawker leak or the deal may not go through.
On 10/08/15 ASA Matt Smith and I met with State Attorney Mark Ober, Chief Assistant State
Attorney Mike Sinacore, Felony Bureau Chief Chris Moody, and Chief of Investigations Mark Cox. The
case was presented to them and they are determining prosecution for Conspiracy to Extort and Dealing in
stolen property. It was determined that the Statewide Prosecutors Office would review the case to determine
jurisdiction.
On 11110/15 I met with Statewide Prosecutors Nick Cox and Mike Williams this case was presented
to them for consideration of prosecution. Statewide Prosecutor Cox stated that he would speak with his superiors
and get back.
On 11113/15 I was informed that the Hillsborough County State Attorney's Office as well as the
Office of the Statewide Prosecutor declined to prosecute or file charges in this case.
Therefore this case is EXCEPTIONALLY cleared.
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Document: IDENT REPORT
Author: 45100- GONZALEZ, THOMAS G
Subject: FINGERPRINT PROCESS
Related date/time: Mar-12-2015 (Thu.) 1141
Report Number: 14-3 323 37

Requested By: Det J Schlemmer
Details:
Items were submitted for processing in this case. The results are as follows:
*Item
Development Media
DVD-R "Hootie 7/3/07"
Black Powder
*Processing Results
Postive for ridge detail
DVD-R "Hogan 7113/07"
Black Powder
Postive for ridge detail
DVD-R
Black Powder
Negative for ridge detail
Sleeves of DVD case
Black Powder
Negative for ridge detail
Latents Collected/Developed BY:
LFS T Gonzalez
Date processed: 03-12-15
Lifts were released to Det J Schlemmer for case file.
Author: Latent Fingerprint Specialist

Thomas Gonzalez
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Document: IDENT REPORT
Author: 45100- GONZALEZ, THOMAS G
Subject: FINGERPRINT AFIS/CAFIS SEARCH
Related date/time: Mar-17-2015 (Tue.) 1446
Report Number: 14-332337

Requested By: Det J Schlemmer
Details:
Initial analysis of this case determined that there are latents of Comparison Value. Print(s) were searched in
AFIS with the following results.
*Location of latent
*Comparison Results
*Subject Identified
DVD-R "Bootie 7/3/07"
AFIS and CAFIS Search Negative
DVD-R "Hogan 7113/07"
AFIS Search Negative
Latents Collected/Developed BY:
LFS T Gonzalez
Date processed: 03-12-15
Lifts were released to Det J Schlemmer for case file.
Author: Latent Fingerprint Specialist

Thomas Gonzalez
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Follow Up Report# 1
Follow Up Report# 1
Assignment Information
Assigned to: 47801 - SCHLEMMER, JOHN Rank: Detective
Capacity: Investigate/Case Manager Org unit: CIB
Assigned on: May-27-2014 (Tue.) 1253 by: 43915- KENNEDY, PATRICK
Report due on: Jun-30-2015 (Tue.)
Submission Information
Submitted on: Nov-13-2015 (Fri.) 1212
Approved on: Nov-13-2015 (Fri.) by: 35865- VICTOR, MICHAEL R
Follow Up Conclusion
Follow Up concluded: YES
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Clearance Information
Agency: TPD
Cleared status: Exceptionally Cleared -Prosecution Declined
Cleared on: Nov-13-2015 (Fri.)
Cleared by Officer 1: 47801- SCHLEMMER, JOHN
Org Unit: SQ531 - CIB
Approved by: 35865- VICTOR, MICHAEL R
Org Unit: SQ531 - CIB
Complainant/Victim notified: NO
Notified by: 47801 - SCHLEMMER, JOHN
Notified on: Nov-13-2015 (Fri.)
How notified: Telephone
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Related Property Report(s)

Report Information
Property Report#: 1490031
Property case status: STOLEN
Submitted on: May-23-2014 (Fri.) by: FINE, RALPH
Authority for disposal: SCHLEMMER, JOHN Org unit: CIB
Related:
Offense: GO 2014- 332377
Related items: 0
Flags= d (disposed) x (x-reference) n (entered on NCIC) *e (evidence)
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Related Property Report(s)

Report Information
Property Report#: 1556111
Property case status: EVIDENCE/HELD
Submitted on: Nov-13-2014 (Thu.) by: SCHLEMMER, JOHN
Related:
Offense: GO 2014- 332377
General remarks: LOYD,MATHEW 020779
Related items: 4
Articles - Evidence
Status: EVIDENCE/HELD
Tag#: 1556111- 1
Article: RCDISC- RADIO, TV, ENTERTAINMENT DEVICES
Serial# 1: UNKNOWN
OAN:
Value: $0.00
Color:
Description: GREY BOX CONTAINING 3 DVD'S
Recovered date:Recovered value: $0.00
Flags: *e
Current Location: IM WE WALL
Articles - Evidence
Tag#: 1556111- 2
Article: 77Serial # 1: NONE
OAN:
Value: $0.00
Color:
Description: SETTLEMENT AGREEMENT AND MUTUAL RELEASE
Flags: *e
Articles - Evidence
Tag#: 1556111-3
Article: 77Serial # 1: UNKNOWN
OAN:
Value: $0.00
Color:
Description: ORIG CHECK USED DURING FBI TRANS SEALED IN ORIG P ACKG BY FBI
Flags: *e
Articles - Evidence
Tag#: 1556111- 4
Article: RCDISC- RADIO, TV, ENTERTAINMENT DEVICES
Serial# 1: UNKNOWN
OAN:
Value: $0.00
Color:
Description: 8 CD'S OF RECORDINGS OF PHONE CALLS & TRANS DURING FBI INV
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Recovered date:Flags: *e
2100-8 EXTORTION
Recovered value: $0.00
Flags= d (disposed) x (x-reference) n (entered on NCIC) *e (evidence)
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*** END OF HARDCOPY ***
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Filing # 40950062 E-Filed 05/02/2016 12:17:59 PM

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT

Case No. __________________

DON BUCHWALD & ASSOCIATES, INC.;

disclosure, dissemination and exploitation of surreptitiously recorded and illegally obtained

The Buchwald Defendants, and each of them, individually or in

The Cox Defendants, and each of them, individually or in concert

extortion, aiding and abetting civil extortion, violation of Plaintiffs rights of

The Davidson Defendants, and each of them, individually or in

Gawker intentionally interfered with Plaintiffs contractual and

advantageous business relationships, and intentionally inflicted

distress upon him by leaking a sealed transcript of surreptitiously recorded private

sought in the Prior Action.

$15,000, exclusive of interest, attorneys fees and costs.

committing tortious acts within the State of Florida;

committing intentional torts expressly aimed at Plaintiff, the

effects of which were suffered in Pinellas County, Florida;

operating, conducting, engaging in, or carrying on a business or

engaging in substantial and not isolated activity within the State of

engaging in a conspiracy to commit tortious acts against Mr.

At all relevant times, Defendant, Keith M. Davidson (Davidson), was and is a

At all relevant times, Defendant, Keith M. Davidson & Associates, P.L.C.

of Carrega and a citizen, resident and domiciliary of Pasco County, Florida.

Plaintiff is a former professional wrestler, and is a professional spokesperson,

In or about June-July 2007, Plaintiff, without his knowledge or consent, was

In or about late September 2012, Burton, in his capacity as a talent agent

Daulerio, edited the surreptitious recordings of Plaintiff contained within the 30

In October 2012, the Davidson Defendants, acting on behalf of and in concert

Davidson, representing and acting on behalf of and in concert with the

Plaintiffs counsel contacted local law enforcement agencies for assistance in

release of a written transcript (prepared by the Extortionists), containing racially insensitive

Plaintiff sought and

In mid-July 2015, following Gawkers repeated threats of releasing the racial

Only 14 minutes after the Enquirer posted the court-protected confidential

an illegally-recorded private conversation in his then-best friends bedroom in 2007eight years

The actions of all of Defendants culminated in the Enquirers publication of the

court-protected confidential transcript, which caused Plaintiff to be immediately terminated by

As a result of the Defendants actions, Plaintiffs highly valuable global brand

Among other things, all of

dissemination of the content of court-protected confidential transcript to the Enquirer, which

Many of the facts alleged herein were discovered by Plaintiff through an

The Buchwald Defendants, Cox Defendants and Davidson Defendants, in

The unauthorized distribution and dissemination of the surreptitious recordings of

The Buchwald Defendants, Cox Defendants and Davidson Defendants knew or

The Buchwald Defendants, Cox Defendants and Davidson Defendants had no

The Buchwald Defendants, Cox Defendants and Davidson Defendants violated

actual malice and reckless disregard of Plaintiffs rights.

As a direct and proximate result of the aforementioned acts by each of the

Plaintiff also is entitled to preliminary and permanent injunctive relief enjoining

The aforementioned acts of the Buchwald Defendants, Cox Defendants and

The Buchwald Defendants, Cox Defendants and Davidson Defendants disclosed

The Buchwald Defendants, Cox Defendants and Davidson Defendants knew or

The Buchwald Defendants, Cox Defendants and Davidson Defendants had no

The actions of the Buchwald Defendants, Cox Defendants and Davidson

The Buchwald Defendants, Cox Defendants and Davidson Defendants violated

actual malice and reckless disregard for Plaintiffs rights.

As a direct and proximate result of the aforementioned acts by each of the

Plaintiff also is entitled to preliminary and permanent injunctive relief enjoining