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IN THE CIRCUIT COURT OF THE 17

TH
JUDICIAL CIRUIT
IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO.: ___________________

PRAKAZREL MICHEL P/K/A
PRAS MICHEL,

Plaintiff,

vs.

NYP HOLDINGS, INC., d/b/a NEW YORK
POST, ISABEL VINCENT AND
MELISSA KLEIN,

Defendants.

/

COMPLAINT

Plaintiff, PRAKAZREL MICHEL P/K/A PRAS MICHEL (Pras or Plaintiff),
sues Defendants, NYP HOLDINGS, INC., d/b/a NEW YORK POST (New York Post),
Isabel Vincent (Vincent) and MELISSA KLEIN (Klein) (collectively referred to as
Defendants) for false, inflammatory and libelous assertions concerning Pras
involvement with a failed 9/11 benefit concert. Specifically, Defendants falsely claimed
that Pras owned the Hope for Them foundation (the Foundation), which allegedly
bounced a check to the venue hosting a charity event, falsely claimed that MTV
sponsored the event and failed to register the charity with state officials. Pras has never
owned nor been an owner, director or officer of the Foundation and has been damaged
millions of dollars based on the reckless reporting conducted by the Defendants.
PARTIES
Filing # 19131674 Electronically Filed 10/08/2014 10:11:34 AM
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1. Plaintiff, Pras, is an individual who resides in Broward County, Florida.
Pras is a two-time Grammy winning artist, a founding member of the famous music
group, the Fugees, and is an acclaimed philanthropist who has devoted much of his life to
assisting those in need in Haiti and elsewhere around the world.
2. Defendant, New York Post, is one of the most widely circulated
newspapers in the United States and has an expansive presence worldwide, both as a
newspaper and through its digital content that New York Post publishes and disseminates
twenty-four hours a day, seven days a week. New York Post owns and operates Page
Six, a gossip column that commonly takes aim at covering notable celebrities. New
York Post circulates its newspaper in Florida, advertises, promotes and disseminates its
digital content in Florida and otherwise does or solicits business in Florida.
3. At all times material hereto, Defendants Vincent and Klein were reporters
for New York Post who, while acting within the scope of their employment at New York
Post, contributed to the article, Ex-Fugee rapper bailed on his own 9/11 benefit
concert
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(the Article) at issue in this lawsuit, attached hereto as Exhibit A.
JURISDICTION
4. This court has jurisdiction over this lawsuit, because the amount in
controversy is more than Fifteen Thousand ($15,000.00) Dollars, exclusive of interest
and costs. Pras seeks $30,000,000 for the extreme reputational harm he has suffered as a
result of Defendants reckless acts.
5. Venue and jurisdiction are appropriate in Broward County, Florida
because Pras is and continues to be a resident of Broward County, Florida, and has been
extensively damaged in Broward County, Florida based on Defendants acts of drafting,

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See http://pagesix.com/2014/10/05/ex-fugee-rapper-bailed-on-his-own-911-benefit-concert/
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publishing and disseminating the Article throughout the world, including but not limited
to individuals who have and maintain personal and professional relationships with Pras in
Broward County, Florida. Thus, the cause of action accrued in Broward County, Florida
and Floridas long-arm statute (Fla. Stat. 48.193) applies to the instant case.
6. Pras reputation has been devastatingly harmed in Broward County,
Florida as a result of Defendants defamatory acts. Additionally, Defendants availed
themselves to the jurisdiction of this Court based on their transacting business in Broward
County, Florida. The resulting injury to Pras was initiated in this jurisdiction by an act or
omission of Defendants that had the effect of taking place in Broward County, Florida.
Furthermore, this Court has jurisdiction over New York Post based on the cause of action
arising from Defendants tortious act in this county by an act or omission outside of this
county, and New York Post engages in a persistent course of conduct, or derives
substantial revenue from goods used or consumed or services rendered in Broward
County, Florida.
GENERAL ALLEGATIONS
7. Pras has dedicated much of his life to charity, providing whatever
resources he can to others in need, with a specific focus on philanthropic efforts aimed at
restoring Haiti after the devastating 2010 earthquake and empowering its inhabitants in
any way possible.
8. Thus, it came as a complete shock to Pras when he discovered his name
printed as the first words in the Article that blasphemously claimed he bailed on his own
9/11 benefit concert.
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9. Defendants wrote, published and disseminated the Article without
conducting any due diligence on the matter covered or attempting any real outreach to
uncover if any truth existed relating to the matter that was being asserted therein.
10. Vincent and Klein, the authors of the Article, hold themselves out as
investigative journalists. New York Post has also consistently referenced Vincent and
Klein as investigative journalists in its newspaper and on the Internet.
11. The drafting, publishing and dissemination of the Article was
accomplished with a reckless disregard for the truth. The reckless reporting would be
deemed as such had a high school student drafted the Article. However, the authors are
seasoned, experienced investigative journalists employed by one of the most widely
circulated newspapers in the world. Their actions serve as blatant reckless disregard for
the truth.
12. The opening paragraph of the Article states that the Hope for Them
foundation is Pras foundation. That statement is completely false.
13. But for Defendants making a false connection between the Foundation and
Pras, there would be no article and Pras would not have been harmed. Yet, Defendants
published the Article that recklessly associated Pras and the Foundation, which has
resulted in an exorbitant amount of reputational and emotional harm to Pras, negatively
affecting his business ventures and his well-being.
14. The Article claims that Pras was a no-show as a headliner for a charity
event in Hells Kitchen. That statement is false. Pras never guaranteed a performance at
the event.
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15. The Article claims it was a 9/11 charity event, even mentioning 9/11 in
the title of the Article, in an effort to falsely make an association between the event and
the horrendous terrorist events that took place on September 11, 2001. However, said
event had absolutely nothing to do with the charity event in Hells Kitchen. This goes to
show that New York Post purposefully inserts language in an effort to sensationalize
articles and pump up page views, even if the content is false and serves the effect of
wrongfully harming an individuals reputation and further causing emotional distress.
16. Pras reputation was further tarnished, because the Article states that the
Foundation bounced a check to the venue hosting the charity event, falsely claimed MTV
sponsored the event and failed to register the charity with state officials. These wrongs
were falsely associated with Pras, who had nothing to do with the event and has no
relationship with the Foundation.
17. The Article was published on October 5, 2014 at 3:36 a.m. EDT.
18. On October 3, 2014 at 9:33 p.m. EDT, the Foundations president wrote to
Defendant, Vincent, Pras is a good friend of the organization and supports our cause but
is not a board member. (emphasis added)
19. Vincent and Klein failed to follow up on that statement. They did not ask
any further questions about Pras role (if any) with the Foundation. They made no effort
to determine whether Pras was actually a part of the Foundation after its president
explicitly said he was not a board member. They did not even seek to obtain the
Foundations articles of incorporation, which reveal that Pras is neither an officer nor
director of the Foundation. Yet, in the first paragraph of the Article, Defendants
refer to the Foundation as his own, in reference to Pras.
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20. Since the Article was initially published on October 5, 2014, Pras has
received countless phone calls and other forms of communication from friends, family
and high-profile businesspeople with inquiries relating to the Article and questions
regarding his ability to engage in important transactions worth millions of dollars to Pras
and his colleagues.
21. Pras is currently in the process of attempting to effectuate major
transactions that possess international importance and has been questioned by those
involved in such transactions solely based on the publication and content of the Article.
22. New York Post was the first publication to cover one such potential
transaction, involving the acquisition of the Plaza Hotel, Dream Downtown and Londons
Grosvenor House Hotel
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, attached hereto as ExhibitB.
23. That deal, along with many other transactions involving Pras, are now at
serious risk of falling apart due to the reputational harm that Pras is suffering as a
consequence of the drafting, publication and dissemination of the Article. Millions of
dollars are now on the line due to Defendants highly reckless actions.
24. On October 5, 2014, the undersigned counsel sent a demand letter to
Defendants requiring them to immediately retract the Article and further publish a
retraction letter containing an apology to Pras for recklessly dragging his name in the
mud without conducting any due diligence into the matters discussed in the Article.
25. Despite Pras good faith attempt to resolve this matter without litigation,
Defendants failed to comply with the demands set forth in the demand letter.
26. Pras continues to suffer the extremely harmful effects of Defendants
actions.

2
See http://pagesix.com/2014/09/09/pras-michel-joins-2-2-billion-bid-to-buy-the-plaza-hotel/
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27. Thus, Pras is left without any option to seek relief other than to file the
instant Complaint against Defendants seeking monetary damages and any further relief
the Court deems to be fair and just.
FIRST CAUSE OF ACTION: DEFAMATION/LIBEL
28. Pras re-alleges the allegations contained in Paragraphs 1 through 27 as
though fully set forth herein.
29. Defendants made and published statements of fact and/or statements of
mixed opinion and fact (which are made actionable because there are undisclosed sets of
defamatory facts underlying the opinion) in an intentionally false, malicious, or otherwise
defamatory manner (i.e. with reckless disregard for the truth) and distributed same (in the
form of the Article) in Florida and throughout the rest of the world.
30. The statements made by Defendants had, and continue to have, a
defamatory effect, because they have resulted in an adverse effect to the reputation and
standing of Pras, primarily among his surrounding community in Broward County,
Florida and with businesspeople that he has done, is in the process of doing, or plans to
do business with in the future.
31. The statements made by Defendants had, and continue to have, the effect
of impeaching Pras honesty, integrity, virtues, morals and the like. Defendants attacked
Pras charitable efforts, in which Pras takes a great amount of pride, as he has dedicated
much of his life to serving and helping others in need. Pras positive character has
opened doors for him in business and Defendants actions have already caused, and will
continue to cause, harm to Pras reputation, which is of utmost importance in his day-to-
day dealings.
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32. Defendants specifically and unambiguously stated and/or implied that the
Foundation belongs to Pras. That is false.
33. Defendants specifically and unambiguously stated and/or implied that Pras
bounced a check to a venue. That is false.
34. Defendants specifically and unambiguously stated and/or implied that Pras
falsely claimed MTV sponsored a fund-raiser hosted by the Foundation. That is false.
35. Defendants specifically and unambiguously stated and/or implied that Pras
had an obligation to register the charity with state officials. That is false.
36. Defendants specifically and unambiguously stated and/or implied that Pras
had an obligation to perform as a headliner for a 9/11 charity event. That is false.
37. Defendants specifically and unambiguously stated and/or implied that Pras
was associated with an event, and bailed on his own 9/11 benefit concert. That is
false.
38. Defendants made the defamatory statements through the popular Page
Six of New York Post to newspaper subscribers, newspaper purchasers and individuals
accessing the New York Post website and the Article on the Internet. Those individuals
include persons located in Broward County, Florida and throughout the entire world.
Many of those individuals who have read the Article include businesspeople who have
done, or are contemplating doing, business with Pras.
39. Defendants caused the false and defamatory Article to be published with
knowledge of its falsity and/or with reckless disregard for the truth. In the alternative,
Defendants made and published the defamatory statements with negligent disregard for
the truth.
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40. All of the defamatory statements made and published by Defendants
concerning Pras are false.
41. As a direct and proximate cause of Defendants defamatory statements,
Pras has suffered and continues to suffer compensable and pecuniary damages.
Specifically, but without limitation, Pras has experienced and continues to experience
false rumors, damage to reputation, and continual questioning from businesspeople,
including key executives in the music and movie industries who demand more
information about the underlying issue reported by Defendants before they are willing to
proceed with ongoing business negotiations. Pras has incurred and continues to incur
attorneys fees and other costs and expenses suffered and continues to lose otherwise
advantageous relationships with businesspeople based on Defendants defamatory
statements.
42. Pras hereby reserves the right to seek leave to amend this Count to add a
claim for punitive damages pursuant to Fla. Stat. 768.72.
43. Wherefore, Pras asks this Honorable Court to award him damages in the
amount recoverable as a result of the damage to his reputation (which Pras estimates to
be a value of $30,000,000 based on lost business opportunities), costs, attorneys fees,
interest and costs and such other relief the Court deems just and proper.
SECOND CAUSE OF ACTION: DEFAMATION/LIBEL PER SE
44. Pras re-alleges the allegations contained in Paragraphs 1 through 27 as
though fully set forth herein.
45. Defendants made and published statements of fact and/or statements of
mixed opinion and fact (which are made actionable because there are undisclosed sets of
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defamatory facts underlying the opinion) in an intentionally false, malicious, or otherwise
defamatory manner (i.e. with reckless disregard for the truth) and distributed same (in the
form of the Article) in Florida and throughout the rest of the world.
46. The statements made by Defendants had, and continue to have, a
defamatory effect, because they have resulted in an adverse effect to the reputation and
standing of Pras, primarily among his surrounding community in Broward County,
Florida and with businesspeople that he has, is in the process of, or plans to do business
with in the future.
47. The statements made by Defendants had, and continue to have, the effect
of impeaching Pras honesty, integrity, virtues, morals and the like. Defendants attacked
Pras charitable efforts, which Pras takes a great amount of pride in as he has dedicated
much of his life to serving and helping others in need. Pras positive character has
opened doors for him in business and Defendants actions have already caused, and will
continue to cause harm, to Pras reputation, which is of utmost importance in his day-to-
day dealings.
48. Defendants specifically and unambiguously stated and/or implied that the
Foundation belongs to Pras. That is false.
49. Defendants specifically and unambiguously stated and/or implied that Pras
bounced a check to a venue. That is false.
50. Defendants specifically and unambiguously stated and/or implied that Pras
falsely claimed MTV sponsored a fund-raiser hosted by the Foundation. That is false.
51. Defendants specifically and unambiguously stated and/or implied that Pras
had an obligation to register the charity with state officials. That is false.
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52. Defendants specifically and unambiguously stated and/or implied that Pras
had an obligation to perform as a headliner for a 9/11 charity event. That is false.
53. Defendants specifically and unambiguously stated and/or implied that Pras
was associated with an event, and bailed on his own 9/11 benefit concert. That is
false.
54. Defendants made the defamatory statements through the popular Page
Six of New York Post to newspaper subscribers, newspaper purchasers and individuals
accessing the New York Post website and the Article on the Internet. Those individuals
include persons located in Broward County, Florida and throughout the entire world.
Many of those individuals who have read the Article include businesspeople who have or
are contemplating doing business with Pras.
55. Defendants caused the false and defamatory Article to be published with
knowledge of its falsity and/or with reckless disregard for the truth. In the alternative,
Defendants made and published the defamatory statements with negligent disregard for
the truth.
56. All of the defamatory statements made and published by Defendants
concerning Pras are false.
57. The Article was defamatory per se, because it contains allegations
injurious to Pras in his trade and business.
58. The Article specifically and unambiguously stated and/or implied that Pras
does not have the character required to carry out his particular occupation, that of a
celebrity headliner who makes appearances at events in exchange for compensation or
otherwise.
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59. The Article further specifically and unambiguously stated and/or implied
that Pras, who considers his occupation to be philanthropist, does not have the
character to carry out his duties and responsibilities in connection with charitable giving
and enterprise.
60. As a direct and proximate cause of Defendants defamatory statements,
Pras has suffered and continues to suffer compensable and pecuniary damages.
Specifically, but without limitation, Pras has experienced and continues to experience
false rumors, damage to reputation, and continual questioning from businesspeople,
including key executives in the music and movie industries who demand more
information about the underlying issue reported by Defendants. Pras has incurred and
continues to incur attorneys fees and other costs and expenses suffered and continues to
lose otherwise advantageous relationships with businesspeople based on Defendants
defamatory statements.
61. Pras hereby reserves the right to seek leave to amend this Count to add a
claim for punitive damages pursuant to Fla. Stat. 768.72.
62. Wherefore, Pras asks this Honorable Court to award him damages in the
amount recoverable as a result of the damage to his reputation (which Pras estimates to
be a value of $30,000,000 based on lost business opportunities), costs, attorneys fees,
interest and costs and such other relief the Court deems just and proper.
THIRD CAUSE OF ACTION: NEGLIGENT OR INTENTIONAL INFLICTION
OF EMOTIONAL DISTRESS

63. Pras re-alleges the allegations contained in Paragraphs 1 through 27 as
though fully set forth herein.
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64. Defendants knew or should have known that their egregious conduct in
drafting, publishing and disseminating the defamatory Article (including its title and body
content) would cause Pras emotional distress.
65. Defendants acts in drafting, publishing and disseminating the Article
without conducting a real investigation or any due diligence was extreme and outrageous,
especially for a publication the size of New York Post and journalists held out to the
public as investigative journalists, beyond all possible bounds of decency.
66. Defendants extreme and outrageous conduct intentionally, recklessly or
negligently caused Pras emotional distress and should be subject to liability for such
emotional distress.
67. Defendants conduct in drafting, publishing and disseminating the Article
is sufficiently outrageous and intolerable as to support an award to Pras for punitive
damages.
68. Defendants conduct was atrocious and utterly intolerable, as it falsely
associated Pras, who dedicates his life to charitable efforts, with the failure of an event
that was purported to benefit Haiti and benefit those somehow related to the tragic
terrorist events that took place on 9/11.
69. As a result, Pras has suffered and continues to suffer harm, including but
not limited to physical injuries, severe emotional distress, embarrassment and
humiliation, the nature of which no reasonable person should be expected to be able to
endure. Pras is thus entitled to recover damages under this cause of action.
DEMAND FOR JURY
Plaintiff, Pras Michel, hereby requests trial by jury on all counts so triable.
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October 8, 2014 Respectfully submitted.
HEITNER LEGAL, P.L.L.C
Attorney for Plaintiff
185 SW 7th Street, Suite 2311
Miami, Florida 33130
Phone: 954-558-6999
Fax: 954-927-3333


By:
DARREN A. HEITNER
Florida Bar No.: 85956
Darren@heitnerlegal.com