Devin Nunes Lawsuit Against CNN

Case 3:19-cv-00889 Document 1 Filed 12/03/19 Page 1 of 47 PageID# 1
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA
Richmond Division
DEVIN G. NUNES )
)
Plaintiff, )
)
v. ) Case No.
)
) TRIAL BY JURY
CABLE NEWS NETWORK, INC. ) IS DEMANDED
)
Defendants. )
)
COMPLAINT
Plaintiff, Devin G. Nunes, by counsel, files the following Complaint against
defendant, Cable News Network, Inc. (“CNN”).
Plaintiff seeks (a) compensatory damages and punitive damages in an amount not
less than $435,350,000, (b) prejudgment interest on the principal sum awarded by the
Jury from November 22, 2019 to the date of Judgment at the rate of six percent (6%) per
year pursuant to § 8.01-382 of the Virginia Code (1950), as amended (the “Code”), and
(c) court costs – arising out of CNN’s defamation and common law conspiracy.
I. INTRODUCTION
1. CNN is the mother of fake news. It is the least trusted name. CNN is
eroding the fabric of America, proselytizing, sowing distrust and disharmony. It must be
held accountable.
2. On November 22, 2019, CNN published a demonstrably false hit piece
about Plaintiff. CNN intentionally falsified the following facts:
1
CNN THE TRUTH

(Fake News)
Devin Nunes was in Devin Nunes did not go to Vienna

Vienna last year or anywhere else in Austria in 2018
Between November 30, 2018 and December 3, 2018,

Devin Nunes visited Benghazi, Libya on official business
of the House Intelligence Committee to discuss
security issues with General Khalifa Haftar
Devin Nunes also traveled to Malta, where he met with

U.S. and Maltese officials, including Prime Minister
Joseph Muscat, and participated in a repatriation
ceremony for the remains of an American World War II
Soldier missing in action
Devin Nunes met with Devin Nunes has never met Viktor Shokin
Victor Shokin to
“discuss digging up dirt “This meeting never took place. Viktor Shokin doesn’t
on Joe Biden” know and hasn’t even heard of” Devin Nunes
https://www.washingtonpost.com/politics/top-house-
democrat-says-ethics-probe-of-nunes-is-likely-over-alleged-
meeting-with-ukrainian-about-bidens/2019/11/23/0dde6b22-
0e0a-11ea-97ac-a7ccc8dd1ebc_story.html
“A person close to Shokin also has denied the claim”
https://www.washingtonpost.com/politics/nunes-denies-
allegation-he-met-with-top-ukrainian-prosecutor-about-
bidens/2019/11/24/34644688-0edf-11ea-bf62-
eadd5d11f559_story.html
“Shokin denied that he met with Nunes”
https://www.washingtonpost.com/politics/2019/11/25/devin-
nunes-ukraine-allegations-explained/
Devin Nunes began Devin Nunes did not communicate with Parnas
communicating with in December 2018 around the time of the
Lev Parnas around the “Vienna trip” (a trip that never happened)
time of the Vienna trip
2
3. The “trusted” source of CNN’s fake news story was a man indicted by the
United States Government, charged with multiple Federal crimes – a man who faces
years in a Federal penitentiary – Lev Parnas (“Parnas”):
It was obvious to everyone – including disgraceful CNN – that Parnas was a fraudster
and a hustler. It was obvious that his lies were part of a thinly-veiled attempt to obstruct
justice and to trick either the United States Attorney or House Intelligence Committee
3
Chairman, Adam Schiff (“Schiff”), into offering “immunity” in return for “information”
about Plaintiff – a prominent United States Congressman and Ranking Member of the
House Intelligence Committee. There were obvious reasons to doubt the veracity and
accuracy of the information Parnas provided. MSNBC Justice and Security Analyst,
Matthew Miller, aptly stated:
[https://twitter.com/matthewamiller/status/1198069740733976576].
II. PARTIES
4. Plaintiff, Devin G. Nunes (“Nunes” or “Plaintiff”), is a citizen of
California. Born October 1, 1973, Nunes has served in the United States House of
Representatives since 2003. He currently represents California’s 22nd Congressional
District, which is located in the San Joaquin Valley and includes portions of Tulare and
Fresno Counties. He and his wife have three daughters. He is the author of the
book, Restoring the Republic, which was published in September 2010. Nunes was born
4
in Tulare, California. His family is of Portuguese descent, having emigrated from the
Azores to California. From childhood, he worked on a farm that his family operated in
Tulare County for three generations. Nunes raised cattle as a teenager, used his savings
to begin a harvesting business, and then bought his own farmland with his brother.
Nunes graduated from Tulare Union High School. After associate’s work at College of
the Sequoias, Nunes graduated from Cal Poly San Luis Obispo, where he received a
bachelor’s degree in agricultural business and a master’s degree in agriculture. Nunes
was first elected to public office as one of California’s youngest community college
trustees in state history at the age of 23. As a member of the College of the Sequoias
Board from 1996 to 2002, he was an advocate for distance learning and the expansion of
programs available to high school students. In 2001, he was appointed by President
George W. Bush to serve as California State Director for the United States Department of
Agriculture’s Rural Development section. He left this post to run for California’s 21st
Congressional District and now serves in the 22nd District as a result of redistricting in
2010. Nunes serves as Ranking Member of the House Permanent Select Committee on
Intelligence, having been appointed to the Committee in the 112th Congress and serving
as Committee Chairman during the 114th and 115th Congresses. He was appointed to the
Ways and Means Committee in the 109th Congress and now serves as a Ranking Member
of the Health Subcommittee and a member of the Trade Subcommittee, having served as
Chairman of the Trade Subcommittee in the 113th Congress. Nunes previously served as
a member of the House Budget Committee during the 111th Congress. In the 108th
Congress, his first term in the House of Representatives, he served on the House
Resources Committee, in which he was Chairman of the National Parks Subcommittee,
5
and on the Agriculture and Veterans Affairs Committees. Congressman Nunes has
traveled extensively to war zones to meet with soldiers and examine first-hand their
status. As a member of the House Permanent Select Committee on Intelligence, he
participates in oversight of the U.S. national security apparatus, including the
intelligence-related activities of seventeen agencies, departments, and other elements of
the United States Government, most of which is located in Virginia. Nunes authored the
Hubbard Act of 2008 (H.R. 5825), which was named in honor of the Hubbard brothers of
California – Jared, Nathan, and Jason. Jared and Nathan lost their lives serving in Iraq.
Jason was discharged as a sole survivor, but was denied separation benefits upon leaving
the Army. The Hubbard Act, which was enacted into law, provides sole survivors with
numerous benefits that were already offered to other soldiers honorably discharged. It
relieves sole survivors from repaying any portion of their enlistment bonus; entitles them
to the educational benefits of the Montgomery GI Bill; and allows them to receive
separation pay and transitional healthcare coverage. [https://nunes.house.gov/about/;
https://www.devinnunes.com/bio]. Nunes’ career as a United States Congressman is
distinguished by his honor, dedication and service to his constituents and his country, his
honesty, integrity, ethics, and reputation for truthfulness and veracity.
5. Defendant, CNN, is a Delaware corporation, headquartered in Georgia.
CNN is a division of WarnerMedia. WarnerMedia is an operating segment of AT&T,
Inc. (NYSE:T). CNN is part of WarnerMedia’s “Turner” business unit. The Turner
business unit operates television networks and related properties that offer branded news,
entertainment, sports and kids multiplatform content for consumers around the world. In
the United States, its networks and related businesses and brands include TNT; TBS;
6
Adult Swim; truTV; Turner Classic Movies; Turner Sports; Cartoon Network;
Boomerang; and CNN. Turner’s digital properties include the CNN digital network,
www.cnn.com. According to AT&T, the CNN digital network is “the leading digital
news destination, based on the number of average monthly domestic multi-platform
unique visitors and videostarts for the year ended December 31, 2018.” CNN’s digital
platforms deliver news 24 hours a day, seven days a week, from almost 4,000 journalists
in every corner of the globe. CNN claims that it reaches more individuals on television,
the web and mobile devices than any other cable television news organization in the
United States. In addition to its massive television and digital footprint, CNN employs
multiple social media accounts as a means to publish its statements in Virginia and
worldwide. As of November 22, 2019, @CNN had over 43,500,000 followers on
Twitter; @CNNPolitics had over 2,900,000 followers; @cnni had over 9,200,000
followers; @CNNPhillipines had over 530,000 followers; and @cnnbrk had over
56,000,000 followers. In addition to CNN’s corporate and institutional use of Twitter,
most of CNN’s reporters use Twitter to spread stories to readers, viewers and voters in
Virginia and elsewhere. [See, e.g., @jaketapper (2,200,000 followers)].
6. Vicky Ward (“Ward”) is a senior reporter for CNN, covering “the
intersection of power, money and corruption”. [https://www.cnn.com/profiles/vicky-
ward]. Ward wrote the hit piece at issue in this action, and republished it extensively via
her social media accounts: LinkedIn, Twitter and Facebook. Ward has 3,983 followers
on LinkedIn. [https://www.linkedin.com/in/vickypjward/detail/recent-activity/]. Ward
has 73,300 followers on Twitter. [https://twitter.com/vickypjward?lang=en]. In addition
to Twitter and LinkedIn, Ward uses Facebook to republish her articles. She has 1,044
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Facebook followers. Ward’s Facebook profile is set to “public”, meaning that her posts
are available to all 2.45 BILLION monthly active users of Facebook.
[https://www.facebook.com/VickyPJWard/].
7. Chris Cuomo (“Cuomo”) anchors CNN’s “Cuomo Prime Time”, a 9:00
p.m. nightly news program, where Cuomo “tests power with newsmakers and politicians
from both sides of the aisle, and reports on the latest breaking news from Washington and
around the world”. [https://www.cnn.com/profiles/chris-cuomo-profile]. Between his
two accounts, @ChrisCuomo and @CuomoPrimeTime, Cuomo has over 1,500,000
followers on Twitter. [https://twitter.com/CuomoPrimeTime]. Cuomo is famous for his
brash style, having recently threatened to assault a man who referred to him as “Fredo”.
According to Nielsen, Cuomo Prime Time is CNN’s most-watched program among total
viewers and adults 25-54 with an average of 1,000,000+/- viewers.
[https://www.adweek.com/tvnewser/october-2019-ratings-cnn-posts-significant-year-
over-year-audience-growth-bolstered-by-its-democratic-debate/419277/].
8. At all times relevant to this action, Ward and Cuomo acted as agents of
CNN within the scope of their employment and authority. Ward and Cuomo used CNN’s
networks and properties to disseminate the false and defamatory statements at issue in
this case as part of a scheme to boost CNN’s ratings and further the House Democrats’
impeachment “inquiry”. CNN reviewed, approved and ratified the fake news prior to
publication.
9. Edward Brian MacMahon, Jr. (“MacMahon”), an attorney from
Middleburg, Virginia, and Joseph Bondy (“Bondy”), represent Parnas in connection with
a Federal criminal indictment returned against Parnas on October 9, 2019, charging
8
Parnas with the Federal crimes (felony) of conspiracy to defraud the United States in
violation of Title 18 U.S.C. § 371, making false statements to the Federal Election
Commission (“FEC”) in violation of Title 18 U.S.C. § 1001, and falsification of records
in a Federal investigation in violation of Title 18 U.S.C. § 1519.
10. Viktor Mykolayovych Shokin (“Shokin”) is a former Prosecutor General
of Ukraine.
11. Joseph R. Biden, Jr. is the former Vice-President of the United States.
While visiting Kiev in December 2015, Biden threatened Ukrainian President Petro
Poroshenko that, if he did not fire Shokin, the U.S. would hold back its $1 billion in loan
guarantees. In January 2018, Biden specifically recalled the threat: “I looked at them and
said, 'I’m leaving in six hours. If the prosecutor is not fired, you’re not getting the
money.’ Well, son-of-a-b*tch. He got fired. And, they put in place someone who was
solid”. [https://www.nytimes.com/2019/05/01/us/politics/biden-son-ukraine.html;
https://www.realclearpolitics.com/video/2019/09/27/flashback_2018_joe_biden_brags_at
_cfr_meeting_about_withholding_aid_to_ukraine_to_force_firing_of_prosecutor.html;
https://thefederalist.com/2019/09/24/watch-joe-biden-brag-about-bribing-ukraine-to-fire-
the-prosecutor-investigating-his-sons-company/]. Shokin was dismissed by the
Ukrainian Parliament in late March 2016.
12. Dmitry Firtash (“Firtash”) is a Ukrainian oligarch, who lives in Vienna,
Austria. In 2013, Firtash was indicted by the United States on multiple counts of
racketeering, money laundering, conspiracy, and aiding and abetting. USA v. Firtash,
Case 1:13-cv-515 (N.D. Ill.) (pending). On March 12, 2014, Firtash was arrested in
Vienna by Austrian law enforcement on request of the United States. He was released on
9
bond several days later, but barred from leaving Austria. The United States thereafter
submitted a request to the Republic of Austria to extradite Firtash. A Vienna Court
ordered Firtash to be extradited to the United States. Firtash submitted a writ to the
Austria Supreme Court requesting a retrial. The Austrian Supreme Court has not yet
ruled on Firtash’s writ.
III. JURISDICTION AND VENUE
13. The United States District Court for the Eastern District of Virginia has
subject matter jurisdiction over this action pursuant to Title 28 U.S.C. § 1332 (Diversity)
and § 1367 (Supplemental Jurisdiction). The parties are citizens of different States and
the amount in controversy exceeds the sum or value of $75,000, exclusive of interest,
costs and fees.
14. CNN is subject to personal jurisdiction in Virginia pursuant to Virginia’s
long-arm statute, § 8.01-328.1(A)(1), (A)(3) and (A)(4) of the Code, as well as the Due
Process Clause of the United States Constitution. CNN is subject to general personal
jurisdiction and specific personal jurisdiction. CNN engages in continuous and
systematic business in Virginia. It committed multiple intentional torts and acts of
defamation in whole or part in Virginia, causing Plaintiff substantial injury in Virginia.
CNN has minimum contacts with Virginia such that the exercise of personal jurisdiction
over it comports with traditional notions of fair play and substantial justice and is
consistent with the Due Process Clause of the United States Constitution.
15. Venue is proper in the Richmond Division of the United States District
Court for the Eastern District of Virginia pursuant to Title 18 U.S.C. § 1391(b)(1).
10
IV. STATEMENT OF FACTS
16. On August 12, 2019, after speaking ex parte with a Democratic staff
member of the House Intelligence Committee, an anonymous “whistleblower” filed a
complaint with Michael Atkinson, the Inspector General of the Intelligence Community
(“Atkinson”). The anonymous complaint, based entirely on hearsay, states in part:
17. On September 24, 2019, the United States House of Representatives
announced an impeachment “inquiry” into U.S. President Donald Trump.
18. Between October 3, 2019 and October 31, 2019, Schiff conducted
secretive interviews in connection with the Democrats’ impeachment inquiry. On
October 31, 2019, a divided House of Representatives approved guidelines that cleared
the way for nationally televised hearings in mid-November.
19. On October 10, 2019, Parnas was arrested at Dulles International Airport
on charges that he schemed to funnel foreign money to U.S. politicians while trying to
influence U.S.-Ukraine relations. At the time of his arrest, he had a one-way ticket on a
flight out of the country. [https://www.washingtonpost.com/politics/two-business-
associates-of-trumps-personal-lawyer-giuliani-have-been-arrested-and-are-in-
custody/2019/10/10/9f9c101a-eb63-11e9-9306-47cb0324fd44_story.html]. As a result of
his arrest, Parnas’ position as a reliable source of information was compromised.
20. On October 23, 2019, Parnas was released from custody on a $1,000,000
secured bond. The Court required Parnas to surrender his passport; restricted his travel to
11
Virginia and D.C. to meet with lawyers; placed him on home detention with G.P.S.
monitoring; and imposed multiple other restrictions on Parnas. The Court’s complete
lack of trust and confidence in Parnas, as evidenced by the bail disposition, was a matter
of public record known to CNN. [https://www.cnn.com/politics/live-news/impeachment-
inquiry-10-10-2019/h_10c49544ade8af0943742f340e377f13].
21. Not long after his release from custody, Parnas began to concoct a plan to
obstruct the impeachment inquiry and, ultimately, to obtain favorable treatment,
concessions and/or immunity from criminal prosecution.
22. With full knowledge of press accounts of the impeachment inquiry, Parnas
started to manufacture stories that he believed would assist him in obtaining a deal with
the United States Attorney and/or Schiff. Parnas claimed that not long before Ukrainian
President Zelensky was inaugurated on May 20, 2019, he (Parnas) journeyed to Kiev to
deliver a warning to the country’s new leadership. Parnas stated that he told a
representative of the incoming Ukraine government that it had to announce an
investigation into President Trump’s political rival, Joe Biden, and his son, or else Vice
President Mike Pence would not attend the swearing-in of the new president, and the
United States would freeze aid.
23. The problem with Parnas’ story, as was reported by the New York Times
on November 10, 2019, is that the story is knowingly false. Parnas’ business partner (and
co-Defendant in the pending criminal prosecution), Igor Fruman (“Fruman”), publicly
confirmed to the New York Times that “Mr. Parnas’s claim was false; the men never
raised the issues of aid or the vice president’s attendance at the inauguration”.
[https://www.nytimes.com/2019/11/10/nyregion/trump-ukraine-parnas-fruman.html].
12
24. Parnas also lied about his connections with President Trump. Parnas told
Ward that when he attended a White House Hanukkah party with Rudolph Giuliani
(“Giuliani”) in December 2018, they huddled with the President privately. Parnas stated
that President Trump gave him instructions for a secret “James Bond mission” to find
material on Joe Biden. [https://www.cnn.com/2019/11/15/politics/parnas-trump-special-
mission-ukraine/index.html]. In truth, Parnas and Fruman, posed for a one-minute photo
with the President, and walked away.
“‘He [Parnas] has said a few things lately that are completely untrue and provably
untrue,’ Mr. Giuliani said. “I don’t know what he’s doing. He claims we had a
meeting with the president at the Hanukkah party, in December 2018. Someone
should remind Lev that there were five witnesses including his good friend, Igor
Fruman, who all say categorically untrue. Provably by records. He’s trying to
make himself very important … We never had that meeting with the president.
He just made it up … What he said was, we had a long private meeting in which
the president instructed him to do things. False. Untrue … His lawyer [Bondy]
makes these comments that are not only untrue, they are provably untrue … He’s
getting very poor counsel.”
[https://www.washingtontimes.com/news/2019/nov/26/fbi-file-lev-parnas-rolex-watches-
5000-trump-memen/].
25. In addition to CNN’s actual knowledge (a) that Parnas had lied to the FEC
(resulting in the Federal indictment and pending charges) and (b) that after his arrest,
Parnas began circulating false and fantastical stories about a “warning” to Ukraine’s new
leadership and a “James Bond mission” – stories that were demonstrably false – CNN
also knew from its review of “court filings” that a judgment had been entered by the
United States District Court for the Eastern District of New York against Parnas in 2016,
and that the judgment creditor had commenced proceedings in Florida in 2019 to collect
the judgment. [https://www.cnn.com/2019/10/29/politics/lev-parnas-republican-rudy-
giuliani/index.html]. CNN knew from the court filings that the claim against Parnas
13
resulted from his “deliberate, coercive and well-orchestrated scheme to steal $350,000
from Plaintiff by fraudulently inducing Plaintiff to enter into the Loan” [See, e.g., Case
2:11-cv-05537-ADS-ARL (E.D.N.Y) (Document 1)].
26. CNN also knew from prior reporting that Parnas was a “hustler”, and not
in the “good way”. On October 23, 2019, CNN published a story, written by Ward, that
highlighted the fact that Parnas’ “business and networking activities over the past year
had raised red flags with several prominent businessmen and their attorneys”. Ward
noted many examples of Parnas’ shady dealings:
“Bruce Marks, an attorney in Philadelphia who represents prominent Eastern

Europeans, told CNN in recent days there was a Russian proverb that applied to
Fruman and Parnas. ‘Don't go in the forest if you’re afraid of wolves,’ Marks
said. ‘And these guys, they just weren’t wolves, I mean they were radioactive
wolves.’
…
South Florida attorney Robert Stok told CNN in an interview that Parnas and
Fruman came to a wealthy client of his seeking money, claiming they were so
short on cash they couldn’t even pay for Parnas’ newborn son’s bris. Stok said
the men asked Felix Vulis, a Russian-American natural resources magnate, if he
could kick in some money for the event. They had also promised to open doors
for Vulis through their connections to Giuliani and others … When they were
slow to repay, Vulis sued. Vulis told their since-indicted associate David Correia
over text message he had been ripped off, and that he planned to tell Giuliani,
Ayers and others that Parnas and Fruman would face a lawsuit”.
[https://www.cnn.com/2019/10/23/politics/parnas-fruman-hustle-profit-access-
giuliani/index.html].
27. From all the evidence in its possession, CNN was well-aware that Parnas
was a renowned liar, a fraudster, a hustler, an opportunist with delusions of grandeur, a
man in financial in extremis laboring under the weight of a $500,000 civil judgment, and
an indicted criminal defendant with a clear motive to lie. CNN and Ward knew that
Parnas was not just a wolf in sheep’s clothing, he was a “radioactive” wolf.
14
28. Prior to November 22, 2019, CNN knew that Parnas and his attorneys or
other political operatives were shopping a story to the press that made claims about the
Plaintiff, implicating him in efforts to get “dirt” on Joe Biden and his son, Hunter Biden.
CNN knew that no other news outlet would touch the salacious story because none of the
“facts” provided could be verified.
29. In spite of its actual knowledge of Parnas’ pattern of fraud and false
statements and in spite of serious doubts as to Parnas’ veracity and the truth and accuracy
of his statements,1 CNN published Parnas’ statements as if they were true. Although
other media outlets immediately recognized Parnas’ serious credibility issues [see, e.g.,
https://www.msn.com/en-us/news/politics/giuliani-associate-lev-parnas-claims-to-have-
hard-evidence-of-wrongdoing-for-trump-impeachment-inquiry/ar-BBXbRYu (Parnas is
1
The CNN Article, in pertinent part, is based entirely on hearsay statements
provided to CNN by Parnas’ attorney, Bondy. Nowhere in the Article does CNN actually
state that Ward ever spoke with Parnas directly. The necessary inferences to be drawn
from CNN’s publication of Bondy’s statements are: (1) prior to publication, CNN
confirmed that Bondy was fully authorized to speak for his client, (2) prior to publication,
CNN confirmed that Bondy accurately conveyed in haec verba Parnas’ statements, (3)
the statements are Parnas’ statements conveyed through his agent, Bondy, and (4) Parnas
has first-hand knowledge of the truth of the statements conveyed through Bondy. An
agent (here, Bondy) may take actions that are binding on the principal (Parnas) in only a
limited number of ways. First, the agent may act with “actual authority” – that is, where
“the agent reasonably believes, in accordance with the principal’s manifestations to the
agent, that the principal wishes the agent so to act,” Restatement (Third) of Agency §
2.01 (Am. Law Inst. 2005), which may be actual or implied, see id. § 2.02. Second, the
agent may act with “apparent authority,” which binds a principal to a third party “when a
third party reasonably believes the actor has authority to act on behalf of the principal and
that belief is traceable to the principal’s manifestations.” Id. § 2.03. Third, an action
taken by a putative agent without actual or apparent authority may nonetheless be binding
on the principal if the principal subsequently ratifies the action, see id. § 4.01, which
“retroactively creates the effects of actual authority,” id. § 4.02(1). In this case,
publication of the CNN Article and the content of the Article itself establishes Bondy
acted with Parnas’ actual or apparent authority. It is also reasonable to infer that prior to
publication, CNN confirmed with Bondy that Parnas was aware Bondy was speaking
with CNN and that Parnas ratified Bondy’s actions.
15
“a dubious character who could make a problematic witness”)], CNN ignored known
“red flags” and proceeded to publish the fake news sponsored by a “radioactive” wolf in
sheep’s clothing.
30. On November 22, 2019, CNN published the following article on its digital
network written by Ward:
[https://www.cnn.com/2019/11/22/politics/nunes-vienna-trip-ukrainian-prosecutor-
biden/index.html (the “CNN Article”)].
31. The CNN Article contains numerous egregiously false and defamatory
statements, including:
16
a. Plaintiff had “meetings … in Vienna last year with a former
Ukrainian prosecutor to discuss digging up dirt on Joe Biden”. This statement is
demonstrably false. Plaintiff was not in Vienna in 2018. Between November 30, 2018
and December 3, 2018, when CNN claims Plaintiff was in “Vienna”, Plaintiff was
actually in Libya and Malta. While in Libya, the delegation traveled to Benghazi on a
fact-finding mission in which they met with General Haftar to discuss security issues
both inside Libya and in the wider region. During the meeting in Libya, Plaintiff was
photographed with General Haftar:
A planned stop in Tripoli for talks with officials there was cancelled due to security
concerns. During the same trip, Plaintiff met with Prime Minister Joseph Muscat of
17
Malta to discuss security and intelligence issues related to Malta, the European Union,
and Libya. While in Malta, Plaintiff was photographed with Prime Minister Muscat:
And, significantly, Plaintiff participated in a repatriation ceremony for a fallen World
War II Army Air Corps service member, whose remains were handed over for return to
the United States for DNA testing, to alert family members, and for proper burial. The
repatriation ceremony in Malta for the World War II Soldier was photographed, see, e.g.:
18
At no time during his visits to Libya or Malta did Plaintiff or his staff ever meet any
Ukrainians or have any discussions with anyone about the Bidens. Parnas, or those
behind his fake news operation, chose “Vienna” for one reason: that is where Firtash
lives.2 In a November 1, 2019 article published by CNN, Parnas claimed to have a strong
connection to Firtash. [https://www.cnn.com/2019/11/01/politics/parnas-firtash-giuliani-
ties/index.html]. By placing Plaintiff in the same city as Firtash, Parnas would be able to
fabricate more fake news, including that Plaintiff was working with the indicted oligarch
Firtash on some nefarious plot.
2
When the story was first shopped to media outlets, the story was that
Plaintiff was meeting with Firtash in Vienna. After Parnas was indicted and charged by
the United States Government, the story changed and Plaintiff was meeting with Shokin.
19
b. “Nunes met with Shokin in Vienna last December”. This
statement is demonstrably false. Plaintiff was not in Vienna in December 2018. Further,
he has never met Shokin; never spoken to Shokin; and never communicated with Shokin.
Parnas fabricated the story after reviewing congressional records that show Plaintiff and
members of his staff traveled to “Europe” between November 30 and December 3, 2018.
[http://clerk.house.gov/foreign/reports/2019q1mar04.pdf]. Despite multiple immediate
public denials by Shokin and his associates of CNN’s false claim, CNN refuses to retract
and apologize for its fake news.
c. “[Parnas] and Nunes began communicating around the time of
the Vienna trip”. This statement is demonstrably false. Plaintiff and Parnas could not
have communicated around the time of the “Vienna trip” because, in fact, there was no
Vienna trip. Further, there were no communications whatsoever between Plaintiff and
Parnas at or around the time identified for the fictitious Vienna trip, November 30, 2018
– December 3, 2018. CNN could never have verified this fake news because, in truth, it
is unverifiable.
d. “Parnas … worked to put Nunes in touch with Ukrainians who
could help Nunes dig up dirt on Biden and Democrats in Ukraine”. This statement is
demonstrably false. Plaintiff never worked with Parnas, other Ukrainians, or anyone else
to dig up dirt on Biden or other Democrats in Ukraine.
e. “Parnas helped arrange meetings and calls in Europe for
Nunes last year”. This statement is demonstrably false without a scintilla of evidence to
support it.
20
f. “Nunes worked to push similar allegations of Democratic
corruption. Nunes had told Shokin of the urgent need to launch investigations
into Burisma, Joe and Hunter Biden, and any purported Ukrainian interference in
the 2016 election”. This statement is a total fabrication. CNN simply chose to publish
the false statements of a source (Parnas) who had no first-hand knowledge of
conversations between Plaintiff and Shokin because no conversations ever took place.
CNN disregarded “red flags” and accepted the word of known liar, a con man and
hustler, who CNN knew had every reason to lie.
g. “Nunes planned the trip to Vienna after Republicans lost
control of the House in the mid-term elections on Nov. 6, 2018. Mr. Parnas learned
through Nunes' investigator, Derek Harvey, that the Congressman had sequenced
this trip to occur after the mid-term elections yet before Congress' return to session,
so that Nunes would not have to disclose the trip details to his Democrat colleagues
in Congress”. These non-sensical statements are patently false and unverifiable. They
were simply made up by Parnas, acting in concert with CNN. CNN published the false
statements as fact with reckless disregard for the truth, without any verification, contrary
to every standard of journalistic ethics and integrity.
h. “[F]ollowing a brief in-person meeting in late 2018, Parnas and
Nunes had at least two more phone conversations, and … Nunes instructed Parnas
to work with Harvey on the Ukraine matters … [S]hortly after the Vienna trip,
[Parnas] and Harvey met at the Trump International Hotel in Washington, where
they discussed claims about the Bidens as well as allegations of Ukrainian election
interference … Following this, … Nunes told Parnas that he was conducting his own
21
investigation into the Bidens and asked Parnas for help validating information he’d
gathered from conversations with various current and former Ukrainian officials,
including Shokin. Parnas said that Nunes told him he’d been partly working off
of information from the journalist John Solomon, who had written a number of
articles on the Biden conspiracy theory for the Hill”. These statements are patently
false and unverifiable. Plaintiff has never met Parnas. It is Plaintiff’s standard operating
procedure to refer matters to his staff. The statements attributed to Plaintiff are false.
Parnas fabricated these communications, and CNN published the false facts, again,
without any effort to verify.
32. On November 22, 2019 at 9:00 p.m., at the same time CNN published the
CNN Article on its digital network, Ward appeared on Cuomo’s television program
“Cuomo Prime Time”. During the broadcast, Cuomo and Ward vouched for the story as
if it were fact, doubled-down, and published further defamatory statements about
Plaintiff, including:
“CUOMO: All right, so next big question. How do we know that

Nunes met with Shokin?
WARD: So, it gets interesting. So, Shokin tells Lev Parnas … And
what’s interesting is that Nunes comes back and tries to recruit Lev Parnas. He
does recruit Lev Parnas to merge his effort, his and Rudy Giuliani’s
investigations, with his.”
…
CUOMO: Devin Nunes, at the hearing, saying, ‘This is crazy that the
President would want Ukraine to look at the Bidens.’ The prosecutor who was
the one at the center of all the controversy … met with Nunes in Vienna—
WARD: Right.
CUOMO: --last December. So, before all this other stuff that they're
saying was just about one phone call—
22
WARD: Way before.
CUOMO: Months before. Shokin then tells Parnas, the shady guy, at
the center of all this.
WARD: Right.
CUOMO: And then Nunes’ staffer meets with Parnas – Parnas?
WARD: Well so does Nunes. Nunes meets with Parnas. Nunes

speaks to Parnas several—
CUOMO: About dirt on the Bidens?
WARD: [S]everal times. Yes, they’re asked to merge operations,

essentially. So, in other words, you know, this whole impeachment, Chris, is
about a shadow foreign policy.
CUOMO: Right.
WARD: That Devin Nunes appears to have … some involvement

in.
CUOMO: So, he knew it was going on … He knew they were looking

for dirt on the Bidens.
WARD: Right. He is a drama in the – in this play himself. And …

yet, he has not told anyone about this.
…
CUOMO: What is the chance of getting to him [Shokin] on this

because, obviously, he can confirm or deny also.
WARD: Well, you know, I have his phone number. So, I’ve texted
him. I’ve got to him. We’ve reached out to him. He’s not talking.
…
CUOMO: [S]houldn’t he [Plaintiff] have disclosed … that he went

over to … Vienna, Austria, to meet with Shokin?
23
WARD: Well what’s so intriguing, for want of a better word, about

his whole trip was the timing of it. And, in fact, his aide, Derek Harvey told Lev
Parnas that the timing of it was very deliberate. It was done right after the
Republicans lost the House in the midterms, but before the Democrats took over
in January.
CUOMO: Why[?]
WARD: Because once the Democrats took over, he would have had
to … disclose the details of it. So, this is why nobody has known, until now, what
Devin Nunes was doing last December.”
After Ward, Cuomo paraded Katie Hill (“Hill”) before the camera so CNN could get Hill
to publish further defamatory statements about Plaintiff. Hill resigned from Congress in
October 2019 amid allegations of an improper sexual relationship with a staff member
and after shocking pornographic pictures of her appeared on the Internet.
[https://www.dailymail.co.uk/news/article-7609835/Katie-Hill-seen-showing-Nazi-era-
tattoo-smoking-BONG-NAKED.html; https://www.youtube.com/watch?v=D5PD-
pIFeok]. CNN published the following exchange between Cuomo and Hill:
CUOMO: Can you believe this? Help me understand this Vicky

Ward reporting. Devin Nunes, I guess, being Chairman, you don’t have to tell
people what you’re going. But putting in the record, ‘I'm going to Vienna with a
couple of staffers,’ and you know you’re investigating all this Ukraine stuff and
you don’t mention that you met with the guy at the center of the whole situation?
… But he had to know that we were going to find out. It’s not like these players
are exactly, you know, lock-lipped, you know, that these guys that we’re dealing
with. And he sat in the hearings, Katie. I don't know how much of them you saw
but … every time they bring up ‘The President wanted Ukraine to get dirt on the
Bidens,’ he was, ‘Oh man, I can't believe!’ And he even said, ‘I can't believe,’
you know, and in some words that you guys would think this was possible when
he knew damn well that he was trying to.
HILL: He was doing it. Yes.
CUOMO: Unless Parnas’ lawyer is lying because Shokin … hasn’t

confirmed it yet. Nunes says he won’t answer any questions.
…
24
HILL: Look, I don’t know if he … thought he would never get

found out. But you know he’s going to deny it until the day he dies … It’s just …
where we’re at, unfortunately, with Republicans right now, is that there’s … zero
shame in lying, just straight-up lying constantly.
[http://transcripts.cnn.com/TRANSCRIPTS/1911/22/CPT.01.html].
33. CNN coordinated publication of the false and defamatory statements about
Plaintiff across each of its platforms. CNN published the CNN Article to multiple new
target audiences, including CNN’s 32,000,000+ Facebook followers and CNN’s
56,000,000+ Twitter followers in Virginia and around the World:
25
26
27
CNN’s goal was to inflict maximum damage to Plaintiff’s reputation Worldwide and to
cause him to be removed from the impeachment inquiry. At the same time CNN tweeted
the CNN Article, Ward, Cuomo, Vaughn Sterling, Jake Tapper, and a host of other CNN
employees republished the CNN Article to their millions of Twitter followers, e.g.:
28
29
30
31
The breadth of CNN’s publication is staggering.
34. The defamation continued on November 23, 2019. Ward tweeted the
following:
32
Ward’s tweet stated or implied that a meeting between Plaintiff and Shokin actually
occurred and that, if the meeting had occurred, there would have been something wrong
with it. In another tweet, Ward also confirmed that the entire CNN Article was based on
information she received from Parnas (through Bondy). Ward falsely implied that there
were “text messages and other such evidence” to back up the fake news about Plaintiff:
33
There is no such evidence.
35. The defamatory gist of the CNN Article was clear to everyone. On
November 22, 2019 and, thereafter, multiple third-parties republished the CNN Article,
e.g.:
34
[https://secure.actblue.com/donate/arb_dd_search_1909_nunes?gclid=EAIaIQobChMIwc
KpvKiV5gIVyODICh1BegNfEAAYASAAEgKHN_D_BwE
(“#DevinNunesGotCaught Devin Nunes met with Ukrainians to get dirt on Joe Biden --
he took part in Donald Trump’s impeachable offense”)].
35
36
COUNT I – DEFAMATION PER SE
36. Plaintiff restates paragraphs 1 through 35 of his Complaint, and
incorporates them herein by reference.
37. CNN, using its vast digital network, television network and resources, and
social media network, made, published and republished numerous false factual statements
of and concerning Plaintiff. These statements are detailed verbatim above. CNN
published the false statements without privilege of any kind.
38. CNN’s false statements constitute defamation per se. The statements
accuse and impute to Plaintiff the commission of felonies and crimes involving moral
turpitude and for which Plaintiff may be punished and imprisoned in a state or federal
institution. The statements impute to Plaintiff an unfitness to perform the duties of an
office or employment for profit, or the want of integrity in the discharge of the duties of
such office or employment, including dishonesty, lack of candor, fraud and concealment,
lack of ethics, self-dealing and conflicts of interest. CNN’s false statements prejudice
Plaintiff in his profession and employment as a United States Congressman.
39. By publishing the CNN Article on the Internet, by talking about Plaintiff
on Cuomo’s show, and by tweeting the CNN Article to the Twitter universe, CNN knew
or should have known that its defamatory statements would be republished over and over
by third-parties to Plaintiff’s detriment. Indeed, there have been millions of
republications to date. Republication by both CNN subscribers and viewers and Twitter
users was the natural and probable consequence of CNN’s actions and was actually
and/or presumptively authorized by CNN. In addition to its original publications online,
on air, and on Twitter, CNN is liable for the republications of the false and defamatory
37
statements by third-parties under the doctrine (the “republication rule”) announced by the
Supreme Court of Virginia in Weaver v. Home Beneficial Co., 199 Va. 196, 200, 98
S.E.2d 687 (1957) (“where the words declared on are slanderous per se their repetition by
others is the natural and probable result of the original slander.”).
40. CNN’s false statements have harmed Plaintiff and his reputation.
41. CNN made the false statements with actual or constructive knowledge that
they were false or with reckless disregard for whether they were false. CNN acted with
actual malice and reckless disregard for the truth for the following reasons:
a. CNN, in fact, entertained serious doubts as to both the veracity of
its source, Parnas, and the truth and accuracy of the statements in the CNN Article. In
spite of these serious doubts, CNN published Parnas’ demonstrably false statements as if
they were true and later directly vouched for the truth of the statements. The three (3)
pillars of Parnas’ story are demonstrably false:
● Devin Nunes was not in Vienna in December 2018;
● Devin Nunes has never met Shokin;
● Devin Nunes never communicated with Parnas in

December 2018 at the time of the “Vienna trip” (that
also never happened).
CNN knew Parnas was an unreliable source. CNN failed to reasonably assess the
veracity of its sole source prior to publication. Compare, e.g., Wells v. Liddy, 2002 WL
331123, at * 4-5 (4th Cir. 2002).
b. CNN misrepresented the extent of its investigation and knowledge,
misrepresented that it had verified Parnas’ story, and deliberately minimalized the
38
credibility problems of its source. CNN knew its statements were materially false, and
possessed information that demonstrated the falsity of its statements.
c. CNN conceived the story line in advance of any investigation and
then consciously set out to publish statements that fit the preconceived story.
d. CNN deliberately ignored source material, including Parnas’ phone
records, that would have demonstrated that Parnas’ statements were absolutely false.
e. CNN and its reporters, editors and publishers abandoned all
journalistic standards and integrity, including CNN’s own code of ethics, in writing,
editing and publishing the CNN Article. CNN did not seek the truth or report it. CNN
betrayed the truth for the sake of its political and ideological slant, and institutional bias
against President Trump and Plaintiff. CNN did not confirm facts and verify Parnas’
information before releasing it. The CNN Article was nothing less than opposition
research. CNN rushed to get the story out in order to blunt the disastrous spectacle of the
House Democrats’ impeachment inquiry, and to hurt the leader of the Republican
opposition. CNN misrepresented facts and oversimplified issues in promoting the fake
news story. In spite of multiple reports on November 23, 2019, November 24, 2019 and
November 25, 2019, confirming that Shokin never met with Plaintiff, CNN refused to
update or correct its story. CNN withheld from the public key pieces of information
about Parnas that bore directly upon his veracity, reliability and motivations. CNN
deliberately distorted facts to support its false narrative that Plaintiff concealed from the
House Intelligence Committee a clandestine effort to “dig up dirt on the Bidens”. Rather
than minimize harm, CNN set out to inflict maximum pain and suffering on Plaintiff in
order to support the impeachment effort and to undermine due process and the search for
39
the truth. In promoting fake news about secret meetings in Vienna with a corrupt former
Ukraine prosecutor, CNN pandered to lurid curiosity. CNN never once considered the
long-term implications of the extended reach and permanence of its various online, on
air, and social media publications. CNN abjectly failed to act independently. Rather, it
accepted and published the false statements of an indicted criminal, a known fraudster,
known liar, known hustler, with a motive to lie. Whereas other media outlets refused to
take the bait, CNN eagerly published Parnas’ lies. CNN refuses to be accountable;
refuses to acknowledge its mistakes; refuses to retract; refuses to correct; refuses to
clarify; and refuses to apologize. [https://cnnsoc185.wordpress.com/vision-statement/;
https://www.warnermediagroup.com/company/corporate-responsibility/telling-the-
worlds-stories/journalistic-integrity; https://www.spj.org/ethicscode.asp].
f. CNN intentionally employed a scheme or artifice to defame
Plaintiff with the intent to obstruct, interfere with and impede the impeachment inquiry.
CNN, Ward and Cuomo acted intentionally, purposefully and in concert with Parnas to
accomplish an unlawful purpose through unlawful means, without regard for the
Plaintiff’s rights and interests.
g. CNN chose to manufacture and publish false and scandalous
statements and use insulting words that were unnecessarily strong and that constitute
violent, abusive and hateful language, disproportionate to the occasion, in order to foment
controversy, undermine public confidence in Plaintiff, and hinder him from performing
his duties as Ranking Member of the House Intelligence Committee. The ulterior
purpose of the CNN Article is to advance the impeachment inquiry, to seed doubt in the
minds of Americans, and to influence the outcome of the 2020 election.
40
h. The words chosen by CNN, Ward and Cuomo evince their ill-will,
spite and actual malice.
i. CNN, acting in concert with Parnas, manufactured the claims
about Plaintiff out of whole cloth. CNN did not act in good faith because, in the total
absence of evidence, it could not have had an honest belief in the truth of its statements
about Plaintiff or in the veracity of Parnas.
j. CNN harbors an institutional hatred, extreme bias, spite and ill-will
towards Plaintiff, the GOP and President Trump, going back many years. CNN is
notorious for making false claims about Republicans and publishing fake news that later
has to be retracted. For example, in August 2017, CNN published a story smearing then-
Trump ally, Anthony Scaramucci. CNN stated that Scaramucci was connected to a
Russian investment fund that was supposedly under investigation by the U.S. Senate.
Scaramucci threatened to take immediate legal action. CNN retracted the fake news and
fired three reporters over the incident. [https://www.foxnews.com/politics/cnn-faced-
100m-lawsuit-over-botched-russia-story;
https://www.nytimes.com/2017/09/05/business/media/cnn-retraction-trump-
scaramucci.html (“At CNN, Retracted Story Leaves an Elite Reporting Team
Bruised”)]. In December 2017, CNN was again caught peddling fake news, this time
misrepresenting that Donald Trump. Jr. had advance notice from WikiLeaks of
documents that WikiLeaks planned to release during the 2016 presidential campaign.
[https://www.nytimes.com/2017/12/08/business/media/cnn-correction-donald-trump-
jr.html (“CNN Corrects a Trump Story, Fueling Claims of ‘Fake News’”)]. In July
2018, CNN published a blockbuster fake news story, heavily promoted by Cuomo on his
41
show, that Michael Cohen was prepared to tell Robert Mueller that President Trump
knew in advance about a meeting with Russians at Trump Tower.
[https://www.cnn.com/2018/07/26/politics/michael-cohen-donald-trump-june-2016-
meeting-knowledge/index.html]. In August 2019, CNN’s Brian Stelter allowed a
psychiatrist to falsely claim that President Trump was “as destructive … as Hitler, Stalin
and Mao” and that he “may be responsible for many more million deaths than they were”.
[https://www.cnn.com/videos/tv/2019/08/25/exp-two-psychiatrists-discuss-coverage-of-
trump.cnn]. Between 2017 and the present, CNN has been at the forefront of the
advancement of false narratives about the Trump campaign, Trump associates, collusion
with Russia, and now Ukraine. Plaintiff poses a threat to CNN. Between 2017 and
March 22, 2019, Plaintiff emphatically argued that there was no “collusion” between
Trump associates and Russia to hack the 2016 presidential election, and that CNN and
others were perpetuating a hoax and lying to the American people. Most recently, as
Ranking Member of the House Intelligence Committee, Plaintiff spearheaded Republican
efforts to investigate and defend the truth during the impeachment inquiry. CNN is out to
get the Plaintiff. CNN’s reporting is part of a coordinated opposition research smear
campaign against Plaintiff that has been ongoing since at least 2018. [See
https://dailycaller.com/2019/11/27/fusion-gps-devin-nunes/]. In furtherance of the
operation, CNN defamed Plaintiff in order to drum up negative publicity and
manufacture an “ethical” issue, where none exists. CNN knew that its reporting would
then be used by political operatives to file “ethics” complaints. And, in fact, as a result of
CNN’s publication of the CNN Article, Plaintiff now faces a potential ethics
42
investigation. [https://thehill.com/homenews/house/471994-nunes-faces-potential-ethics-
review-over-alleged-meeting-with-ukrainian].
k. Publication of the CNN Article was an unmitigated act of
retaliation against Plaintiff. Plaintiff stopped talking to CNN in the spring/summer of
2017. He told CNN that he would not talk until CNN retracted its fake news stories.
CNN refused. In 2018, Plaintiff pointed out that CNN was the Democratic Party’s
“leading propaganda” tool. He reiterated that he would not talk to CNN:
43
Plaintiff refuses to speak with CNN, and this angers CNN. That anger manifested itself
in the CNN Article and CNN’s willingness to publish the demonstrably false statements
of Parnas. The CNN Article is an act of retribution against Plaintiff.
l. CNN also initiated the defamation on November 22, 2019 in
retaliation and reprisal for Plaintiff and the Republican’s investigation and defense of
President Trump at the impeachment inquiry. CNN went out of its way to publish and
then republish false statements about Plaintiff that CNN knew were untrue.
m. CNN reiterated, repeated and continued to republish the false
defamatory statements about Plaintiff out of a desire to hurt Plaintiff and to permanently
stigmatize him, even after CNN learned that Parnas had lied.
n. Plaintiff loudly and publicly notified CNN that its false statements
were demonstrably untrue. The Washington Post published three (3) stories in which
Shokin and his associates denied ever meeting Plaintiff. CNN disregarded all these
communications, and continues to stand by its fake news. Daniczek v. Spencer, 2016 WL
153086, at * 12 (E.D. Va. 2016) (“Spencer neglects that malice may be inferred under
aggravating circumstances, including disregard for communications by others and the
appearance of reprisal.”).
42. As a direct result of CNN’s defamation, Plaintiff suffered presumed
damages and actual damages, including, but not limited to, insult, pain, embarrassment,
humiliation, mental suffering, injury to his reputation, special damages, costs, and other
out-of-pocket expenses, in the sum of $435,000,000 or such greater amount as is
determined by the Jury.
44
COUNT II – COMMON LAW CONSPIRACY
43. Plaintiff restates paragraphs 1 through 42 of his Complaint, and
incorporates them herein by reference.
44. Beginning in October 2019 and continuing through the present, CNN
(including agents such as Ward acting within the scope of their employment for CNN),
combined, associated, agreed or acted in concert with Parnas and his attorneys, and, upon
information and belief, an opposition research firm (whose identity is unknown at this
time) for the express purposes of injuring Plaintiff, intentionally and unlawfully impeding
and interfering with his business and employment as a United States Congressman, and
defaming Plaintiff. In furtherance of the conspiracy and preconceived plan, CNN and its
co-conspirators engaged in a joint scheme the unlawful purpose of which was to destroy
Plaintiff’s personal and professional reputations, interfere with Plaintiff’s duties as a
United States Congressman, including the performance of his duties as Ranking Member
of the House Intelligence Committee during the impeachment inquiry, and to further the
goal of the ongoing opposition research smear campaign against Plaintiff.
45. CNN acted intentionally, purposefully, without lawful justification, and
with the express knowledge that it was defaming Plaintiff. As evidenced by its concerted
actions online, on air, and via Twitter, CNN acted with the express and malicious intent
to cause Plaintiff permanent injury.
46. CNN’s actions constitute a conspiracy at common law.
47. As a direct result of CNN’s willful misconduct, Plaintiff suffered actual
damages, including, but not limited to, insult, pain, embarrassment, humiliation, mental
suffering, injury to his reputation, special damages, costs, and other out-of-pocket
45
expenses, in the sum of $435,000,000 or such greater amount as is determined by the
Jury.
Plaintiff alleges the foregoing based upon personal knowledge, public statements
of others, and records in his possession. Plaintiff believes that substantial additional
evidentiary support, which is in the exclusive possession of CNN, Ward, Cuomo, Parnas,
Bondy, MacMahon, and their agents and other third-parties, will exist for the allegations
and claims set forth above after a reasonable opportunity for discovery.
Plaintiff reserves his right to amend this Complaint upon discovery of additional
instances of CNN’s wrongdoing.
CONCLUSION AND REQUEST FOR RELIEF
WHEREFORE, Devin G. Nunes respectfully requests the Court to enter Judgment
against CNN as follows:
A. Compensatory damages in the amount of $435,000,000 or such greater
amount as is determined by the Jury;
B. Punitive damages in the amount of $350,000 or the maximum amount
allowed by law;
C. Prejudgment interest from November 22, 2019 until the date Judgment is
entered at the maximum rate allowed by law;
D. Postjudgment interest at the rate of six percent (6%) per annum until paid;
E. Such other relief as is just and proper.
46
TRIAL BY JURY IS DEMANDED
DATED: December 3, 2019
DEVIN G. NUNES
By: /s/ Steven S. Biss

Steven S. Biss (VSB # 32972)
300 West Main Street, Suite 102
Charlottesville, Virginia 22903
Telephone: (804) 501-8272
Facsimile: (202) 318-4098
Email: [email protected]
Counsel for Plaintiff, Devin G. Nunes
47

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Case 3:19-cv-00889 Document 1 Filed 12/03/19 Page 1 of 47 PageID# 1

IN THE UNITED STATES DISTRICT COURT

defendant, Cable News Network, Inc. (“CNN”).

2. On November 22, 2019, CNN published a demonstrably false hit piece

about Plaintiff. CNN intentionally falsified the following facts:

CNN THE TRUTH

Devin Nunes was in Devin Nunes did not go to Vienna

Between November 30, 2018 and December 3, 2018,

Devin Nunes also traveled to Malta, where he met with

“A person close to Shokin also has denied the claim”

“Shokin denied that he met with Nunes”

years in a Federal penitentiary – Lev Parnas (“Parnas”):

Matthew Miller, aptly stated:

4. Plaintiff, Devin G. Nunes (“Nunes” or “Plaintiff”), is a citizen of

Representatives since 2003. He currently represents California’s 22nd Congressional

bachelor’s degree in agricultural business and a master’s degree in agriculture. Nunes

programs available to high school students. In 2001, he was appointed by President

Resources Committee, in which he was Chairman of the National Parks Subcommittee,

status. As a member of the House Permanent Select Committee on Intelligence, he

participates in oversight of the U.S. national security apparatus, including the

intelligence-related activities of seventeen agencies, departments, and other elements of

separation pay and transitional healthcare coverage. [https://nunes.house.gov/about/;

https://www.devinnunes.com/bio]. Nunes’ career as a United States Congressman is

honesty, integrity, ethics, and reputation for truthfulness and veracity.

5. Defendant, CNN, is a Delaware corporation, headquartered in Georgia.

CNN is a division of WarnerMedia. WarnerMedia is an operating segment of AT&T,

news destination, based on the number of average monthly domestic multi-platform

worldwide. As of November 22, 2019, @CNN had over 43,500,000 followers on

56,000,000 followers. In addition to CNN’s corporate and institutional use of Twitter,

Virginia and elsewhere. [See, e.g., @jaketapper (2,200,000 followers)].

6. Vicky Ward (“Ward”) is a senior reporter for CNN, covering “the

intersection of power, money and corruption”. [https://www.cnn.com/profiles/vicky-

on LinkedIn. [https://www.linkedin.com/in/vickypjward/detail/recent-activity/]. Ward

has 73,300 followers on Twitter. [https://twitter.com/vickypjward?lang=en]. In addition

are available to all 2.45 BILLION monthly active users of Facebook.

7. Chris Cuomo (“Cuomo”) anchors CNN’s “Cuomo Prime Time”, a 9:00

around the world”. [https://www.cnn.com/profiles/chris-cuomo-profile]. Between his

two accounts, @ChrisCuomo and @CuomoPrimeTime, Cuomo has over 1,500,000

followers on Twitter. [https://twitter.com/CuomoPrimeTime]. Cuomo is famous for his

viewers and adults 25-54 with an average of 1,000,000+/- viewers.

9. Edward Brian MacMahon, Jr. (“MacMahon”), an attorney from

a Federal criminal indictment returned against Parnas on October 9, 2019, charging

Commission (“FEC”) in violation of Title 18 U.S.C. § 1001, and falsification of records

in a Federal investigation in violation of Title 18 U.S.C. § 1519.

10. Viktor Mykolayovych Shokin (“Shokin”) is a former Prosecutor General

the-prosecutor-investigating-his-sons-company/]. Shokin was dismissed by the

Ukrainian Parliament in late March 2016.

12. Dmitry Firtash (“Firtash”) is a Ukrainian oligarch, who lives in Vienna,

submitted a request to the Republic of Austria to extradite Firtash. A Vienna Court

ruled on Firtash’s writ.

III. JURISDICTION AND VENUE

costs and fees.

14. CNN is subject to personal jurisdiction in Virginia pursuant to Virginia’s

jurisdiction and specific personal jurisdiction. CNN engages in continuous and

systematic business in Virginia. It committed multiple intentional torts and acts of

defamation in whole or part in Virginia, causing Plaintiff substantial injury in Virginia.

IV. STATEMENT OF FACTS

member of the House Intelligence Committee, an anonymous “whistleblower” filed a