ECF 29 Redacted

UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF VIRGINIA

Charlottesville Division
_______________________________________
)
BRENNAN M. GILMORE, )
)
Plaintiff ) Case No. 3:18-cv-00017-GEC
)
v. )
)
ALEXANDER (“ALEX”) E. JONES; )
INFOWARS, LLC, a Texas Limited Liability ) JURY TRIAL DEMANDED
Company; FREE SPEECH SYSTEMS, LLC, a )
Texas Limited Liability Company; LEE )
STRANAHAN; LEE ANN MCADOO A/K/A )
LEE ANN FLEISSNER; )
SCOTT CREIGHTON; JAMES (“JIM”) )
HOFT; ALLEN B. WEST; DERRICK )
WILBURN; MICHELE HICKFORD; )
and WORDS-N-IDEAS, LLC, )
)
Defendants. )
__________________________________________)
AMENDED COMPLAINT
NOW COMES Plaintiff Brennan Gilmore, by and through undersigned counsel, and
alleges upon knowledge and belief as follows:
I. INTRODUCTION
Brennan Gilmore works to provide jobs and training in rural areas, participates in local
politics, and plays music around the Commonwealth of Virginia. As a Foreign Service Officer,
Mr. Gilmore has devoted his career to promoting United States interests and to protecting
American citizens through diplomatic efforts abroad. On August 12, 2017, Mr. Gilmore witnessed
firsthand James Alex Fields Jr., a neo-Nazi, deliberately drive his Dodge Challenger into a crowd
of peaceful protesters, killing Heather Heyer and injuring many others. Mr. Gilmore, who had been
Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 1 of 99 Pageid#: 406

filming the protesters as they moved up the street, happened to catch Fields’ attack on video. Mr.
Gilmore posted the video on Twitter, where it attracted the attention of the press. After discussing
what he had witnessed that day with a number of reporters, Mr. Gilmore soon became the target
of right-wing conspiracy theories. Supporters of the alt-right and the “Unite the Right” rally,
including the Defendants, created a new identity for Mr. Gilmore—the organizer and orchestrator
of Fields’ attack and a traitor to the United States. Defendants’ lies about Mr. Gilmore quickly
mobilized their armies of followers to launch a campaign of harassment and threats against Mr.
Gilmore that continue to this day.
Supporters of the “Unite the Right” rally, including Defendants, faced a crisis of legitimacy
when a fellow supporter murdered Heather Heyer in cold blood. Defendants needed a scapegoat
to create distance between the ideology they promote and Heyer’s murder. Given Mr. Gilmore’s
connections to Democratic politicians and the State Department, Defendants thought they had their
scapegoat in Mr. Gilmore, and attacked his presentation of the sequence of events based on his
political leanings. But Defendants did more than just twist the publicly available information about
Mr. Gilmore; Defendants created a new identity for Mr. Gilmore out of whole cloth. All Mr.
Gilmore had done was share the truth about the tragic and traumatic act he regrettably witnessed.
For a man who has devoted his life to serving his local community, the Commonwealth, the United
States, and the global community, Defendants’ absurdly false portrayal of him, and the harassment
that followed, was devastating.
Defendants thrive by inciting devastating real-world consequences with the lies they
publish as “news.” From “Pizzagate” to the Sandy Hook, Las Vegas, and Parkland shootings,
certain Defendants have subjected innocent people to relentless threats of violence and death,
bullying, and online harassment. Defendants’ use of Mr. Gilmore as a tool for their agenda had

immediate, tangible consequences for Mr. Gilmore and his family. A list of Mr. Gilmore and his
parents’ known addresses was posted online, prompting local law enforcement to patrol his
parents’ home. Mr. Gilmore suffered from an overwhelming volume of hate mail and death threats,
hacking attempts, and even in-person harassment on the streets of Charlottesville.
To this day, Mr. Gilmore suffers the effects of this character assassination: his career as a
diplomat has been compromised, he has lost potential partners and clients in his most recent
business venture, and his social relationships have been irreversibly damaged.
Fact-based journalism is essential to our democracy, because it provides citizens with
objective, reality-based information on issues of public concern. While Defendants masquerade as
fact-based journalists, in reality Defendants spread lies to construct false narratives that terrify a
gullible audience, all in a desperate attempt to generate revenue and momentum for a hateful
agenda. The First Amendment necessarily creates space for democratic debate, but it does not and
cannot protect the spread of deliberate lies driven by hate and designed to incite violence against
private citizens. In this era of ubiquitous smartphones and social media saturation, ordinary citizens
like Mr. Gilmore increasingly find themselves in situations where they capture breaking news and
are compelled out of civic duty to share it. The consequences for fulfilling this civic duty cannot
include becoming the target of premeditated character assassination, based on lies and carried out
by professional conspiracy theorists instrumentalizing their throngs of followers.
Brennan Gilmore told the truth about what he saw in Charlottesville, and he refuses to be
intimidated and silenced by Defendants’ dangerous and defamatory lies.
II. JURISDICTION AND VENUE
1. This action arises under Virginia law because Defendants’ statements were published to
Virginia residents and caused ultimate injury to the Plaintiff in Virginia.

2. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b)(2) because a substantial part
of the events giving rise to the claim occurred in and around Charlottesville, Virginia and
Lexington, Virginia.
3. This Court has subject matter jurisdiction pursuant to Article III of the United States
Constitution and 28 U.S.C. § 1332. The amount in controversy exceeds $75,000 for each
Defendant, exclusive of interests and costs, and there is diversity of citizenship.
4. This Court has personal jurisdiction over Defendants under Virginia’s long-arm statute,
Va. Code § 80.1-328.1(A)(1) and (A)(4), as well as the Due Process Clause of the United
States Constitution. The claims in this Complaint arise from Defendants’ tortious conduct
which caused injury in Virginia, and Defendants’ substantial business activity in Virginia.
Exercising jurisdiction over the Defendants would not offend traditional notions of fair
play and substantial justice because the Defendants deliberately targeted Mr. Gilmore, a
Virginia resident, by making false and defamatory statements about his presence at and
observation of an event that took place in Virginia. The event in which Defendants
implicate Mr. Gilmore occurred in part on the campus of the University of Virginia,
concerned the proposed removal of a Confederate statute in Virginia and the renaming of
a Virginia park, and thus was of particular importance to local Virginians. The injury
resulting from Defendants’ tortious conduct occurred primarily within Virginia.
5. Defendants injured Plaintiff Gilmore in the Commonwealth of Virginia by their conduct
outside the Commonwealth. In doing so, Defendants were aware that Mr. Gilmore was a
resident of Virginia and that the matters discussed in their published content primarily
concerned and were of concern to Virginians. Defendants were aware that the larger
controversy driving the event in which Mr. Gilmore was implicated was a divisive issue of

Virginia history, its Confederate monuments, and thus Defendants’ publications were
intended to target and incite a Virginia audience.
6. Defendants’ statements, published to persons in Virginia, ultimately resulted in injury to
Plaintiff Gilmore in Virginia. Defendants’ false and defamatory statements were directed
at, received, and read by individuals and businesses in Virginia. As a result, Plaintiff
Gilmore has experienced irreversible personal and professional damage in Virginia,
including reputational harm, the loss of business opportunities in Virginia, irreparable
damage to his career as a Foreign Service Officer, and the loss of friendships with
individuals in Virginia. Furthermore, as a result of publication in Virginia, Plaintiff also
suffered threats and harassment directed at him and his family in Virginia so severe that he
sought the protection of local Virginia police.
7. Upon information and belief, all Defendants regularly do and/or solicit significant business
in Virginia, engage in other persistent courses of conduct, or derive substantial revenue
from goods sold to, goods used or consumed, or services rendered in Virginia, such that
they have made minimum contacts with the state and have purposefully availed themselves
of its laws. Upon information and belief, Defendant Stranahan temporarily conducts
business from a shared workspace in Arlington, Virginia.
8. Defendants generate substantial revenue from the Commonwealth of Virginia as a result
of their content-driven business model. Some internet-based media providers, including
Defendants, generate revenue by providing content to their readers in exchange for readers’
attention to advertisements placed throughout their media content. Defendants then receive
payment from the advertiser that corresponds to how many times the ad has been viewed

by Defendants’ readers. Thus, the Defendants are paid each time a reader from Virginia
views their websites or videos.
9. On information and belief, InfoWars attracts approximately twenty million viewers per
month, Hoft’s Gateway Pundit attracts approximately three million viewers per month,
Allen B. West’s website attracts approximately forty-nine thousand viewers per month,
and American Everyman attracts approximately eight thousand viewers per month. Upon
information and belief, a significant portion of viewers of each website are Virginia
residents. For Defendants, this amounts to revenue estimated to be at least several thousand
dollars and up to several million dollars. Thus, upon information and belief, all Defendants
generate substantial revenue as a result of transactions with individuals residing in Virginia.
10. Defendants Infowars, Free Speech Systems, and Words-N-Ideas solicit and transact
business through their online stores, which results in the transmission of currency in
exchange for their goods or services. According to New York Magazine, the “vast majority”
of Defendant InfoWars’ operating revenue comes from the sale of InfoWars-branded
dietary supplements.1 Upon information and belief, Defendant InfoWars sold and delivered
its dietary supplements to persons residing in Virginia and used that revenue to publish
defamatory statements against Mr. Gilmore. Upon information and belief, a substantial
portion of this revenue is the result of transactions with individuals in Virginia.
Furthermore, Defendant Jones’ radio show is aired on the Genesis Communication
Network’s Virginia affiliate stations, which publishes content to Virginians.
11. Defendants Jones, Infowars, McAdoo, Stranahan, and Free Speech Systems have gone
further to purposefully avail themselves of Virginia, where Defendants carried out a plan
1
See Seth Brown, Alex Jones’s Media Empire Is a Machine Built to Sell Snake-Oil Diet Supplements, N.Y.
MAGAZINE (May 4, 2017), http://nymag.com/selectall/2017/05/how-does-alex-jones-make-money.html.
6

to report on and cover prominently the “Unite the Right” rally in Virginia. InfoWars
reporters attended and reported on the “Unite the Right” rally in Charlottesville.2
Defendants Jones, Infowars, McAdoo, Stranahan, and Free Speech Systems produced
multiple segments, articles, and other content about the Virginia event and covered the
event as part of a journalistic endeavor.
12. Therefore, Defendants should have foreseen that they would be forced to answer for their
tortious conduct, and the resulting injuries to Mr. Gilmore, in a Virginia court.
III. PARTIES
13. Plaintiff Brennan Gilmore is domiciled in Albemarle County, Virginia. Mr. Gilmore is
currently on long-term unpaid leave from the United States State Department (“State
Department”), where he is a civil servant employed as a Foreign Service Officer. In 2017,
Mr. Gilmore took leave to pursue other employment and educational opportunities, and to
be closer to family after many years of overseas deployments. He previously served as
chief of staff to Tom Perriello during the latter’s 2017 Virginia gubernatorial campaign.
Mr. Gilmore currently serves as a business consultant for Wize Solutions, LLC, an
information technology company founded in 2017.
14. Defendant Alexander “Alex” E. Jones is domiciled in Austin, Texas, and the owner and
publisher of the national website InfoWars,3 as well as the host of various radio- and web-
based shows linked to InfoWars. Defendant Jones’ website published a video containing
false and defamatory statements about Mr. Gilmore entitled Bombshell Connection
2
See, e.g., Infowars Attacked by Antifa! INFOWARS (Aug. 13, 2017), https://www.infowars.com/infowars-attacked-
by-antifa/.
3
See INFOWARS, https://www.infowars.com (last visited Apr. 23, 2018).
7

Between Charlottesville, Soros, CIA on August 15, 2017,4 and another video entitled
Breaking: State Department/CIA Orchestrated Charlottesville Tragedy on August 21,
2017.5
15. Defendant InfoWars, LLC (“InfoWars”) is a Texas limited liability company that operates
as a national news website. InfoWars published the above-mentioned articles and videos
containing false and defamatory statements about Mr. Gilmore.
16. Defendant Free Speech Systems, LLC (“Free Speech Systems”) is a Texas limited liability
company that operates Infowars.com. According to Free Speech Systems’ Media Kit,
Defendant Jones is the owner of Defendant Free Speech Systems.6 According to the
InfoWars website, where Defendants Jones, McAdoo, and Stranahan’s defamatory
statements were published, “Infowars.com is a Free Speech Systems, LLC website.”7
According to the InfoWars Store, purchases of Defendant InfoWars’ dietary supplements
may result in a billing entry on the purchaser’s credit card as “Free Speech Systems, LLC
or Magnolia Management.”8
17. Defendant Lee Stranahan is domiciled in Dallas, Texas. Defendant Stranahan has a Texas-
issued Driver’s License, and as of April 19, 2018, Defendant Stranahan is actively
registered to vote in Texas. Defendant Stranahan was featured in the video that was posted
by InfoWars on August 15, 2017. In this video, Defendant Stranahan made false and
4
Lee Ann McAdoo, Bombshell Connection Between Charlottesville, Soros, CIA, INFOWARS (Aug. 15, 2017),
https://www.infowars.com/bombshell-connection-between-charlottesville-soros-cia.
5
The Alex Jones Show, Breaking: State Department/CIA Orchestrated Charlottesville Tragedy, INFOWARS (Aug.
21, 2017), https://www.infowars.com/breaking-state-departmentcia-orchestrated-charlottesville-tragedy/. The
accompanying video was shared via Defendant Jones’ YouTube channel the day before, on August 20, 2017.
6
Free Speech Systems, LLC Media Kit, INFOWARS, http://static.infowars.com/ads/mediakit_public.pdf (last visited
Feb. 20, 2018).
7
See, e.g., Contact, INFOWARS, https://www.infowars.com/contact/ (last visited Feb. 20, 2018).
8
The InfoWars Store, ALEX JONES’ INFOWARS STORE, http://infowars-shop.stores.yahoo.net/info.html (last visited
Feb. 20, 2018).
8

defamatory statements about Mr. Gilmore. Defendant Stranahan is a former employee of
the website Breitbart News and a current employee of RT, a Russian state-funded and -
operated television network that was recently forced to register with the Department of
Justice as a foreign agent.9 Defendant Stranahan operates the Citizen Journalism School,10
the corporate structure of which is currently unknown. Defendant Stranahan also operates
the political journalism website The Populist,11 where he solicits donations via a PayPal
account registered to Stranahan Strategies, LLC,12 an inactive Texas limited liability
company. Upon information and belief, Defendant Stranahan is temporarily living and
working in the Washington, D.C. metropolitan area, and conducts business from a shared
workspace in Arlington, Virginia.
18. Defendant Lee Ann McAdoo, also known as Lee Ann Fleissner, (referred to herein as
“McAdoo”) is domiciled in Sarasota, Florida. She is the author of the article containing
false and defamatory statements about Mr. Gilmore that was published by Defendant
InfoWars on August 15, 2017, as well as the interviewer of Defendant Stranahan in the
video that accompanies the article. In the article and the video, Defendant McAdoo makes
false and defamatory statements about Mr. Gilmore. Defendant McAdoo is an independent
contractor and reporter at InfoWars.
19. Defendant Scott Creighton is domiciled in Tampa, Florida, and the owner and author of
the national news website American Everyman.13 Defendant Creighton wrote and
9
Jack Stubbs & Ginger Gibson, Russia’s RT America Registers as ‘Foreign Agent’ in U.S., REUTERS (Nov. 13,
2017), https://www.reuters.com/article/us-russia-usa-media-restrictions-rt/russias-rt-america-registers-as-foreign-
agent-in-u-s-idUSKBN1DD25B.
10
See CITIZEN JOURNALISM SCHOOL, https://citizenjournalismschool.com/ (last visited Jan. 25, 2018).
11
See THE POPULIST, http://populist.tv/ (last visited Feb. 20, 2018).
12
Stranahan Strategies, LLC, PAYPAL, https://www.paypal.me/LeeStranahan (last visited Feb. 20, 2018).
13
See AMERICAN EVERYMAN, https://americaneveryman.com/ (last visited Apr. 14, 2018).
9

published an article containing false and defamatory statements about Mr. Gilmore entitled
Charlottesville Attack, Brennan Gilmore and… the STOP KONY 2012 Pysop? What? on
August 13, 2017.14 That same day, Defendant Creighton published a video containing false
and defamatory statements about Mr. Gilmore on his now-terminated YouTube channel,
entitled Charlottesville Attack: Brennan Gilmore – Witness or Accessory?15 On or about
February 28, 2018, YouTube deleted Creighton’s account American Everyman for
allegedly violating YouTube’s Terms of Service.16
20. Defendant James “Jim” Hoft is domiciled in St. Louis, Missouri, and is the owner and
author of the national news website Gateway Pundit.17 On August 14, 2017, Defendant
Hoft wrote and published an article containing false and defamatory statements about Mr.
Gilmore entitled Random Man at Protests Interviewed by MSNBC, NY Times Is Deep State
Shill Linked to George Soros.18
21. Defendant Allen B. West is domiciled in Dallas, Texas, and owner of the national news
website bearing his own name, Allen B. West.19 Defendant West’s website published an
article containing false and defamatory statements about Mr. Gilmore entitled
BOMBSHELL: New evidence suggests Charlottesville was a complete SET-UP on August
14
Scott Creighton, Charlottesville Attack, Brennan Gilmore and… the STOP KONY 2012 Pysop? What?,
AMERICAN EVERYMAN (Aug. 13, 2017), https://americaneveryman.com/2017/08/13/charlottesville-attack-brennan-
gilmore-and-the-stop-kony-2012-pysop-what.
15
AmericanEveryman, Charlottesville Attack: Brennan Gilmore - Witness or Accessory?, YOUTUBE (Aug. 13,
2017), https://www.youtube.com/watch?v=5_1JSC60gkg. As of February 28, 2018, Defendant Creighton’s
American Everyman YouTube channel has been deleted, and the video is no longer viewable on YouTube. See infra
note 16.
16
See Scott Creighton, My YouTube Account Has Been Terminated...for Exposing Disinformation,
AMERICANEVERYMAN (Feb. 28, 2018), https://americaneveryman.com/2018/02/28/my-youtube-channel-has-been-
terminatedfor-exposing-disinformation/.
17
See GATEWAY PUNDIT, http://www.thegatewaypundit.com (last visited Dec. 11, 2017).
18
Jim Hoft, Random Man at Protests Interviewed By MSNBC, NY Times Is Deep State Shill Linked to George
Soros, GATEWAY PUNDIT, http://www.thegatewaypundit.com/2017/08/random-man-protests-interviewed-msnbc-ny-
times-deep-state-shill-linked-george-soros (last visited Apr. 23, 2018).
19
ALLEN B. WEST, https://www.allenwest.com (last visited Dec. 11, 2017).
10

19, 2017.20 Defendant West previously represented Florida’s 22nd congressional district
in the United States House of Representatives and is a regular contributor on Fox News.
22. Defendant Derrick Wilburn is domiciled in Colorado Springs, Colorado. Defendant
Wilburn is the vice chairman of Colorado’s Republican Party and the author of the article
containing false and defamatory statements about Mr. Gilmore that was published on
Defendant West’s website.
23. Defendant Michele Hickford is domiciled in Deerfield Beach, Florida. Defendant Hickford
is the managing member and registered agent of Defendant Words-N-Ideas, LLC and the
editor-in-chief21 of the Allen B. West website, which published Defendant Wilburn’s false
and defamatory article. According to Defendant Hickford’s personal website, she “served
in Congressman Allen West’s congressional office as Director of Outreach and as Press
Secretary for his 2012 campaign.”22 In an interview with Eric Scheiner of MRCTV,
Defendant West claimed that Defendant Hickford, as president of Words-N-Ideas, owned
the rights to the Allen B. West website at the time Defendant Wilburn’s article was
published and was the person who published Defendant Wilburn’s article on the website.23
24. Defendant Words-N-Ideas, LLC (“Words-N-Ideas”) is an inactive Florida limited liability
company and the purported owner of the Allen B. West website, which published Defendant
Wilburn’s false and defamatory article.
20
Derrick Wilburn, BOMBSHELL: New evidence suggests Charlottesville was a complete SET-UP, ALLEN B. WEST
(Aug. 19, 2017), https://www.allenwest.com/2017/08/19/bombshell-new-evidence-suggests-charlottesville-
complete-set.
21
Mallory Shelbourne, Allen West’s Facebook Page Apologizes for Sharing Anti-Muslim Meme, THEHILL (Dec. 11,
2016), http://thehill.com/blogs/blog-briefing-room/309873-editor-in-chief-of-allen-wests-website-apologizes-for-
anti-muslim.
22
About, MICHELEHICKFORD.COM, http://michelehickford.com/about/ (last visited Apr. 19, 2018).
23
“MRCTV, Allen West is Fighting For His Facebook, YOUTUBE (Mar. 22, 2018),
https://www.youtube.com/watch?time_continue=4&v=kkYGX3DWIII.
11

IV. FACTUAL ALLEGATIONS
A. The “Unite the Right” Rally
25. On August 12, 2017, hundreds of white supremacists and neo-Nazis gathered in
Charlottesville, Virginia for what they labeled the “Unite the Right” rally. The rally was
held in Charlottesville in response to decisions by the Charlottesville City Council to
remove a statute of Confederate General Robert E. Lee from a small city park and change
that park’s name from “Lee Park” to “Emancipation Park.”
26. These white supremacists and neo-Nazis organized the rally to further their ideologies of
hatred and to intimidate the residents of Charlottesville. Many marched with swastikas,
chanting the Nazi call, “blood and soil,” in reference to the notion that ethnicity and blood
descent is determinative of entitlement to the land. Some of the rally’s participants carried
firearms, wore body armor, and deliberately positioned themselves to create violent clashes
with counter-protesters.24
27. The counter-protesters came from many backgrounds, united in opposition to white
supremacy. Many were ordinary residents of Charlottesville and neighboring communities.
Mr. Gilmore was among the peaceful counter-protesters on August 12 in his personal
capacity as a concerned resident, and not in any sort of capacity as an employee or agent
of the United States government.
28. On the morning of August 12, rally participants and counter-protesters met at the site of
the anticipated rally. Pockets of each side engaged in physical altercations; Mr. Gilmore
and the vast majority of counter-protesters remained peaceful. By 11:40 a.m., twenty
24
See David Frum, The Chilling Effects of Openly Displayed Firearms, ATLANTIC (Aug. 16, 2017),
https://www.theatlantic.com/politics/archive/2017/08/open-carry-laws-mean-charlottesville-could-have-been-
graver/537087/.
12

minutes before the “Unite the Right” rally was to begin, the state police declared the
gathering an unlawful assembly and ordered the crowd to disperse.25
B. James Alex Fields Jr.’s Attack
29. At or around 1:42 p.m., following the aborted rally, James Alex Fields Jr. drove his Dodge
Challenger into a crowd of peaceful counter-protesters, killing one, Heather Heyer, and
injuring approximately thirty-six others. Fields is a neo-Nazi sympathizer and has been
charged with multiple felonies related to his deliberate act of terror. 26 Attorney General
Jefferson Sessions stated that this attack by a white supremacist was an act of domestic
terrorism.
30. Mr. Gilmore noticed Fields’ Dodge Challenger driving toward the crowd after he had
already begun recording a gathering of counter-protesters marching up Fourth Street in
Charlottesville. His immediate reaction was to continue to record the event on his
smartphone. In the video, Mr. Gilmore happened to catch the Challenger ramming into the
crowd, and then reversing in flight from the scene.
31. Mr. Gilmore was conflicted about sharing the recording of the attack publicly. He did not
want the attention that sharing the video on social media might bring, and he was
uncomfortable about sharing a recording of what he assumed at the time was a video
capturing multiple deaths. He felt it necessary to share the video on his Twitter account
after hearing from family and friends that media outlets were suggesting the incident was
25
See Doug Stanglin and Gabe Cavallaro, 1 dead, 19 Injured as Car Hits Crowd after a “Unite the Right” Rally in
Charlottesville; Driver in Custody, USA TODAY (Aug. 12, 2017),
https://www.usatoday.com/story/news/2017/08/12/charlottesville-va-braces-alt-right-rally-thousands-robert-e-lee-
statue/561833001/.
26
See Jonah Engel Bromwich and Alan Blinder, What We Know About James Alex Fields, Driver Charged in
Charlottesville Killing, N.Y. TIMES (Aug. 13, 2017), https://www.nytimes.com/2017/08/13/us/james-alex-fields-
charlottesville-driver-.html.
13

something other than a deliberate attack. Mr. Gilmore realized his recording unequivocally
showed that the attack was a deliberate attempt to injure and kill peaceful counter-
protesters—not an accident or act of self-defense. Mr. Gilmore also feared that an already
violent day in Charlottesville could get worse, and he felt it was his duty to help convince
the public to stay off the streets until safety was reestablished.
32. Out of concern for his friends and neighbors, Mr. Gilmore decided to share the video via a
tweet, a short statement posted along with the video to his Twitter account. At the time,
Mr. Gilmore had a few hundred followers, most of whom were also from the
Charlottesville area, or Virginia.
33. Not long after he shared the video on his Twitter account, Mr. Gilmore began to receive
media requests from national, local, and international outlets. He was first contacted by
14

Brian Rosenthal of the New York Times on August 12, 2017 via Twitter. More requests
for interviews followed.
34. Mr. Gilmore spoke with multiple television news networks and other news media to
provide an eyewitness account on August 12 and 13, 2017. Each time he was asked, he
relayed a factual account of what he had witnessed first-hand, hoping that by making
himself available in this way he could convey the seriousness and certainty of what he had
seen.
35. At no time during August 12 and 13, 2017 did Mr. Gilmore solicit requests from media
outlets to appear on their televisions or make statements for print publications. He
consented to appear as a fact witness on various outlets when asked, but he did not reach
out to media outlets on his own initiative, or ask media outlets to share his video or his
statements.
C. Conspiracy Theories About the Attack
36. Within twenty-four hours of uploading his video onto Twitter, the Defendants’ first articles
about Mr. Gilmore appeared online, accusing him of being a CIA or “Deep State”27
operative who helped orchestrate Fields’ attack as a “false flag.” 28 Defendants continued
to direct baseless allegations against him in the days and weeks that followed.
27
“Deep State” is defined by the Oxford Dictionary as “[a] body of people, typically influential members of
government agencies or the military, believed to be involved in the secret manipulation or control of government
policy.” Deep State, OXFORD DICTIONARY, https://en.oxforddictionaries.com/definition/deep_state (last visited Apr.
19, 2018). In the parlance of Defendants and the “Alt-Right,” the “Deep State” is a perceived left-wing, organized
bureaucratic resistance to the Trump Administration.
28
A “False Flag” is defined by the Oxford Dictionary as “[a] political or military act orchestrated in such a way that
it appears to have been carried out by a party that is not in fact responsible.” False Flag, OXFORD DICTIONARY,
https://en.oxforddictionaries.com/definition/false_flag (last visited Apr. 19, 2018).
15

Publication by Scott Creighton
37. In the early hours of August 13, 2017, Defendant Scott Creighton published an article
entitled “Charlottesville Attack, Brennan Gilmore and… the STOP KONY 2012 Pysop?
What?” on his website, AmericanEveryman,29 and shared a link to the article with his 1,139
followers on Twitter.30 See Exhibit A. AmericanEveryman is a national news website that
receives hundreds, if not thousands, of unique visitors each month. Defendant Creighton
subsequently republished the article on at least two other websites.31 See Exhibits B-C.
38. In this article, Defendant Creighton notes Mr. Gilmore’s experience as a Foreign Service
Officer in the Central African Republic and his work as chief of staff to Tom Perriello. On
the basis of these true facts, along with Mr. Gilmore’s statement of belief that the attack
was an act of terrorism, Defendant Creighton falsely states that Mr. Gilmore cannot have
been a mere bystander who happened to record the attack. Instead, Creighton falsely
implies that Mr. Gilmore had foreknowledge of Fields’ plan to plow his car into the
protesters (italics added):
But Brennan wasn’t filming [the protesters] was he? No. But he did film the
Charger heading all the way down the street into the crowd of protesters…
almost as if he knew it would run into them rather than simply brake and sit
and wait like the other cars in front of it. Again, not a smoking gun in and
of itself, but when combined with all the other coincidences surrounding his
video PLUS the fact that he was ready to go with the divide and conquer
establishment version of events for CNN while people were still lying on the
hot pavement, it kind of makes you wonder doesn’t it?
PLUS… Brennan says it is “definitely terrorism”… no doubt about it.

HAS to be “terrorism”, right?
29
See Creighton, Charlottesville Attack, supra note 14.
30
See Scott Creighton (@willyloman1), TWITTER (Aug. 13, 2017 07:22 AM),
https://twitter.com/willyloman1/status/896693520400080897.
31
See, e.g., Scott Creighton, Charlottesville Attack, Brennan Gilmore and… the Stop Kony 2012 PYSOP? What?,
SIGNS OF THE TIMES (Aug. 13, 2017), https://www.sott.net/article/359361-Charlottesville-Brennan-Gilmore-and-the-
STOP-KONY-2012-Psyop; Scott Creighton, Charlottesville Attack, Brennan Gilmore and… the Stop Kony 2012
PYSOP? What?, BEFORE IT’S NEWS (Aug. 13, 2017), http://beforeitsnews.com/opinion-
liberal/2017/08/charlottesville-attack-brennan-gilmore-and-the-stop-kony-2012-pysop-what-2558822.html.
16

Let me take a second to explain something to you. Terrorism is an act of
violence or the THREAT of violence designed to prompt a change in a
country in terms of its economic, political or social structure.
How is ramming a car into a crowd of protesters you don’t like to be

considered an effort by that ONE PERSON to bring about a change in this
country’s social structure? Are we to assume the driver thought that
running over a few counter protesters would make the rest of the country
step back and say “yeah, the Robert E. Lee statue is history, not racism”
and let it stand?
A terrorist blows up an airport because he wants to DISRUPT commerce

and travel. A terrorist runs a campaign like GLADIO because he wants to
prevent a nation from slipping too far to the left. A racist might run over
“goddamned hippies” because he HATES THEM. But that’s NOT
terrorism.
However… if the event, the mass casualty event, was PLANNED to

destabilize the nation, to DIVIDE the “alt-left’ and the “alt-right”… then
THAT IS TERRORISM. [...]
[I]s it possible this man with links to Special Ops and CIA and various other
black ops kinds of actors just HAPPENED to be there at that particular
moment in history? Yeah, I guess that’s possible, if you’re into coincidence
theories I suppose. But I’m not into such things. Clearly the State
Department has a lot of disgruntled former employees who would delight in
destabilizing Trump’s tenure even more than they already have. And
Gilmore . . . seem[s] particularly invested in undermining the “alt-right”
in the lead-up to the next round of elections. Waaaaaay [sic] too much
coincidence for me folks. Waaaaaay [sic] too much.
39. Creighton emphasizes certain words, by capitalizing or lengthening with additional vowels,
to falsely convey to his readers that the circumstances overwhelmingly prove that Mr.
Gilmore’s presence during the attack was not coincidence.
40. By stating that he is not into coincidence theories, Mr. Creighton explicitly disclaims the
conclusion that his statements about Mr. Gilmore are hyperbole or opinion.
41. At another point in the article, Creighton refers to Mr. Gilmore as a “convenient witness,”
using scare quotation marks to convey to readers that Mr. Gilmore was not actually a
17

convenient witness. In fact, this falsely implies his knowledge of and participation in
Fields’ attack. Through this use of ironic emphasis and the word “convenient,” Creighton
makes it clear that he is not merely expressing an opinion, but is asserting as a fact that Mr.
Gilmore’s presence during the car attack was due to his foreknowledge that the attack
would happen, because he was part of a terrorist conspiracy to stage a “mass casualty event
. . . planned to destabilize the nation.” This assertion of fact, including the assertion that he
was “a convenient witness,” is objectively and demonstrably false.
42. Creighton falsely states that Mr. Gilmore is a “former” State Department employee. This
objectively false statement is used to support Creighton’s assertion Mr. Gilmore is among
the “disgruntled former employees who would delight in destabilizing Trump’s tenure even
more than they already have,” and that this is why Mr. Gilmore helped organize and stage
the car attack in Charlottesville.
43. While Creighton discloses some of the facts upon which he bases his false and defamatory
conclusion that Mr. Gilmore had foreknowledge of Fields’ terrorist attack, Creighton’s
assertion reasonably indicates to his readers that Creighton knows of the existence of other
undisclosed defamatory facts that justify his conclusion. For instance, Creighton does not
disclose the underlying facts upon which he bases his assertion that “[c]learly the State
Department has a lot of disgruntled former employees” and the false implication that Mr.
Gilmore is one of them. A reasonable reader would interpret this to mean that Creighton
has personal knowledge of Mr. Gilmore’s employment status or his state of mind, when in
reality Creighton possesses no such knowledge.
44. Creighton knew that his readers would understand the clear meaning of his words, and he
intended that they interpret his statements as assertions of fact. Indeed, the comments left
18

by Creighton’s followers and others who read his article demonstrate that they clearly
understood Creighton to be asserting facts: that Mr. Gilmore in fact lied about what he
witnessed in Charlottesville, and that Mr. Gilmore was actually a party to a criminal
conspiracy to stage Fields’ car attack that killed Heather Heyer and injured many more.
45. One commenter on Creighton’s article stated that “Brennan Gilmore is a C.I.A. officer who
was working under official cover with the U.S. State Dept.” Another commenter stated that
“[Brennan]’s not State, he’s CIA. And he’s not disgruntled, he’s still on the job, as a [sic]
illegal domestic NOC. If you meet the scumbag sometime, ask him about all the airdrops
that Kony’s harem lived on. But anyway, good catch.” Creighton endorsed this reading of
his article and responded under his pseudonym, willyloman, by saying “thank you.” In
another illustrative comment, one of Creighton’s followers on Twitter commends him for
being the “first on the scene” in uncovering this “psyop” (short for “psychological
operation,” a term used to describe covert operations).32 These comments demonstrate that
Creighton’s readers understand him to be making assertions of fact about Mr. Gilmore, and
congratulate him for uncovering the truth about Mr. Gilmore.
46. In a companion video entitled “Charlottesville Attack – Brennan Gilmore: Witness or
Accessory,” (see Exhibit D) uploaded to his YouTube channel with the account name
“AmericanEveryman” that same day, Defendant Creighton repeats and expands upon the
allegations contained in the article he published on his website (italics added):33
CREIGHTON: He just happened to be there, at the specific place, where he

could film the whole thing, from beginning, middle, to end. He just
happened to have his camera running, he just happened for some reason to
record this car driving for five seconds, before it did anything out of the
32
See Joshua Roberts (@Joshua_Roberts_), TWITTER (Aug. 13, 2017 07:43 AM),
https://twitter.com/Joshua_Roberts_/status/896698814865735681.
33
See AmericanEveryman, Charlottesville Attack, supra note 15.
19

ordinary, and just happened to have just the right message, just the right
establishment message for CNN . . .
He has ties to special operations, special forces, CIA, State Department,

Hillary Clinton, and Tom Perriello, who has a long career of doing this kind
of thing. People will call me a conspiracy theorist because what I am
suggesting here is that someone had foreknowledge, that this event was
going to happen . . . This man has every reason to want to see the support,
the base for Donald Trump again mischaracterized as Nazis. He has every
reason to do that . . . .
This guy just happens to be on that fucking corner with his camera rolling,
watching that car drive by for five seconds, and he’s former State
Department, and close to Tom Perriello, who is also former State
Department obviously, he’s got a fucking ax to grind, that’s one hell of a
goddamn coincidence, and you got to be a special kind of stupid to buy that.
47. Similar to the statements made in his written article, Creighton again falsely asserts that
Mr. Gilmore was aware of and part of Fields’ plan to plow his car into the protesters.
Creighton even directly states that he is suggesting that Mr. Gilmore had “foreknowledge[]
that this event was going to happen.” This is a statement of fact that is objectively false.
48. To emphasize that he is asserting a statement of fact about Mr. Gilmore’s role in the
Charlottesville attack, Creighton goes on to say that Mr. Gilmore’s recording of Fields’ car
attack is “one hell of a goddamn coincidence, and you got to be a special kind of stupid to
buy that.” There can be no doubt in the mind of an individual watching the video that
Creighton is stating a fact: that Mr. Gilmore had foreknowledge of Fields’ car attack
because he was involved in its planning and execution. This was clearly the understanding
of Mr. Creighton’s viewers and followers.
49. Again, while Creighton discloses some of the facts upon which he bases his false and
defamatory conclusion that Mr. Gilmore had foreknowledge of Fields’ terrorist attack, the
nature of Creighton’s conclusion reasonably indicates to his viewers that Creighton knows
20

of the existence of other undisclosed defamatory facts that would justify the conclusion he
reaches, such as personal knowledge of Mr. Gilmore’s state of mind.
50. Creighton clearly and directly states that Mr. Gilmore was a party to a planned psy-op that
killed and injured human beings in Charlottesville. This is false, defamatory, and
malicious, and has exposed Mr. Gilmore to hatred and contempt, as demonstrated by the
threats and harassment Mr. Gilmore experienced and continues to experience. These
statements have also deterred friends, acquaintances, and members of the community from
associating with Mr. Gilmore, and have imperiled his ability to continue serving as a State
Department employee, because Mr. Gilmore’s ability to continue to do diplomatic work is
severely hindered by the false claim that he participated in a secret operation to stage
violence and commit murder.
51. At no point prior to or after publishing his article or video did Creighton investigate the
outrageous and improbable factual allegations included in his story. He conducted no
research beyond identifying a few disparate facts from Mr. Gilmore’s biography and
references to similar conspiracies.
52. Creighton did not reach out to Mr. Gilmore to confirm the story’s statements or
conclusions. Nor did Creighton reach out to any of the other individuals or organizations
named in his article for comment or confirmation of even the most basic facts it included.
53. Creighton did not reach out to Mr. Gilmore for comment or to respond to the allegations
included in the article.
54. Creighton did not have the facts alleged independently fact-checked.
55. Creighton never updated or corrected information about Mr. Gilmore after he published
his defamatory article.
21

56. All of these failures demonstrate that Creighton deliberately distorted the facts and their
context, and departed from even the most basic journalistic standards of accuracy for
factual reporting.
57. Mr. Creighton harbored animosity and ill will toward “psy-ops,”34 and those who
participate in “psy-ops.” Creighton has a long history of accusing individuals and
government entities of staging controversial and newsworthy events, including
“Pizzagate,” the Charleston shooting, and the refugee crisis in Syria, all to hide or distract
the American public from more scandalous conduct, or to push “globalist” agendas.35
Thus, where Defendant Creighton falsely identified Mr. Gilmore as being a member of a
“psy-op” in his previous employment and in Charlottesville, he intended to injure Mr.
Gilmore and his reputation.
58. Creighton would not admit that the Charlottesville attack was the act of a white
supremacist. Instead, Creighton utilized a preconceived and well-worn narrative that the
attack was a “psy-op” staged by individuals and government entities.
34
In a previous article, Creighton himself has provided the following definition of “psy-op,” as taken from the
Department of Defense Dictionary of Military and Associated Terms:
“Planned operations to convey selected information and indicators to foreign audiences to influence their emotions,
motives, objective reasoning, and ultimately the behavior of foreign governments, organizations, groups, and
individuals. The purpose of psychological operations is to induce or reinforce foreign attitudes and behavior
favorable to the originator’s objectives.” Scott Creighton, UCF Psyop: SSgt Arabo Babakhani – “Campus Hero”
or…, AMERICAN EVERYMAN (Mar. 20, 2013),
https://americaneveryman.com/2013/03/20/ucf-psyop-ssgt-arabo-babakhani-campus-hero-or/.
35
Scott Creighton, Phony Pizzagate Disinfo Distraction Ends As You Might Expect: With a Crisis Actor and an
Assault on the 1st and 2nd Amendments, AMERICAN EVERYMAN (Dec. 5, 2016),
https://americaneveryman.com/2016/12/05/phony-pizzagate-disinfo-distraction-ends-as-you-might-expect-with-a-
crisis-actor-and-an-assault-on-the-1st-and-2nd-amendments/; Scott Creighton, Understanding the Regugee “Crisis”
of 2015… (or… Enter the “Refugee Truther”), AMERICAN EVERYMAN (Sept. 16, 2015),
https://americaneveryman.com/2015/09/16/understanding-the-refugee-crisis-of-2015-or-enter-the-refugee-
truther/#more-35477; Scott Creighton, The Ridiculous Propaganda Photos of Sheep Dipped Dylan Storm Roof,
AMERICAN EVERYMAN (June 21, 2015), https://americaneveryman.com/2015/06/21/the-ridiculous-propaganda-
photos-of-sheep-dipped-dylann-storm-roof/#more-34713.
22

59. Defendant Creighton’s prior articles and videos make clear that he conceived a storyline
about the events in Charlottesville in advance of any investigation (or lack thereof) and
then consciously set out to make his false statements about Mr. Gilmore conform to his
preconceived narrative. For example, Creighton had previously posted an article and
accompanying video describing the counter-protesters in Charlottesville as “the Soros-
backed36 side of this destabilization event.”37 In addition, he has published statements after
recent national tragedies implying that the United States government staged the Sandy
Hook school massacre and used the Sutherland Springs shooter as a “patsy,” both to bolster
support for gun control. Thus, by stating that Mr. Gilmore had advanced knowledge of the
attack in Charlottesville and delivered a “pre-approved establishment message,”
Defendant Creighton made Mr. Gilmore a central actor in the narrative he had already
crafted: that the violence in Charlottesville was a CIA and State Department “psy-op,”
funded by George Soros, designed to sow distrust and unrest, and ultimately to undermine
the nation and overthrow the Trump Administration.
60. Creighton ran this story despite entertaining serious doubts about the veracity of his claims,
which he demonstrated, at minimum, by directly disavowing the simplest (and the factually
accurate) explanation: that Mr. Gilmore’s witnessing of Fields’ attack was a tragic and
traumatizing coincidence, and that Mr. Gilmore’s employment with the State Department
had absolutely nothing to do with his presence in Charlottesville that day. By twisting true
facts about Mr. Gilmore’s employment history with false assertions to fit a preconceived
36
This philanthropic billionaire has long the subject of right-wing conspiracy theorists. Most recently, he’s been
accused of funding the white-nationalist rally in Charlottesville, the Black Lives Matter and Antifa movements,
Colin Kaepernick’s NFL protest, and even the Women’s March in Washington, D.C.
37
Scott Creighton, Car Plows into Demonstrators at Unite the Right Debstabalization Rally in Charlottesville,
AMERICAN EVERYMAN (Aug. 12, 2017), https://americaneveryman.com/2017/08/12/car-plows-into-demonstrators-
at-unite-the-right-destabilization-rally-in-charlottesville-va-videos/.
23

narrative and ill will toward alleged “psy-ops,” Creighton knowingly or recklessly
disregarded that his statements and their implications were false.
61. Before it was removed from YouTube’s website, Defendant Creighton’s YouTube channel
had over 2,000 subscribers. As of January 2018, Defendant Creighton’s video about Mr.
Gilmore had been watched nearly 19,000 times.
Publication by James Hoft
62. The next morning, on August 14, 2017, Defendant James Hoft published “Random Man at
Protests Interviewed by MSNBC, NY Times Is Deep State Shill Linked to George Soros”
on his website Gateway Pundit.38 See Exhibit E. The Gateway Pundit website is viewed
approximately three million times nationwide every month and considers itself to be the
“voice of Middle America.” Lucian B. Wintrich, the Washington, D.C. correspondent for
Gateway Pundit, was granted temporary press credentials by the Trump administration and
38
See Jim Hoft, Random Man at Protests, supra note 18.
24

was thus able to attend White House press briefings and ask questions of the press
secretary.39
63. In this article, Defendant Hoft asserts unequivocally in the article’s title, lede, and the body
of the article that Mr. Gilmore is “a deep state shill” who is part of the State Department’s
attempt to cover up its involvement in instigating the attack in Charlottesville. Hoft,
republishing screenshots from the Reddit subgroup “The Donald” to bolster his claims,
wrote:
The random Charlottesville observer who was interviewed by MSNBC and

liberal outlets turns out to be a deep state shill with links to George Soros.
It looks like the State Department was involved in Charlottesville rioting
and is trying to cover it up. But after Deep State got caught they are trying
to erase this guy from their records.
The State Department is very familiar with Brennan Gilmore. He was

involved in the Kony 2012 operation. The State Department later removed
any reference of Brennan. Why would the State Department react in such
a way? Why would the State Department scrub that? . . . This weekend
Brennan Gilmore happened to be in Charlottesville with the rioters. The
media knows exactly who he is yet played it off like a casual observer. This
39
Michael M. Grynbaum, White House Grants Press Credentials to a Pro-Trump Blog, N.Y. Times (Feb. 13, 2017),
https://www.nytimes.com/2017/02/13/business/the-gateway-pundit-trump.html.
25

is how the Deep State is working with the liberal media to shape narrative
and fool the American people.
64. Hoft’s statement that Mr. Gilmore “is a deep state shill” is a direct false assertion that Mr.
Gilmore is an accomplice to a con or fraud perpetrated by the government.40 The accusation
that Mr. Gilmore participated in a government-orchestrated scam in Charlottesville is an
assertion of fact that is objectively and verifiably false.
65. Hoft states and republishes statements from a disreputable Reddit thread that falsely assert
that Mr. Gilmore and/or the State Department removed references to Mr. Gilmore’s State
Department work in an attempt to cover up their alleged involvement in the Charlottesville
rioting. This is false: Mr. Gilmore’s information regarding his previous post as Deputy
Chief of Mission at the U.S. Embassy in the Central African Republic was removed when
the Embassy rebuilt its website to reflect current staff information, after Mr. Gilmore left
the Embassy. It was not removed in an attempt to cover up Mr. Gilmore’s presence in
Charlottesville, and certainly not to cover up an alleged role orchestrating the rioting and
violence there.
66. Hoft also implies that the New York Times removed a reference to Mr. Gilmore from their
article to hide Mr. Gilmore’s relationship to the State Department, at the request of Mr.
Gilmore and/or the State Department. This is false: Mr. Gilmore did not, and to his
knowledge, the State Department did not, request the removal of the reference to Mr.
Gilmore and his employment history. Rather, as is common practice, the article in question
reflected a breaking news story published on the Times’ website that was revised and
40
A shill is defined by the Oxford Dictionary as “An accomplice of a confidence trickster or swindler who poses as
a genuine customer to entice or encourage others.” Shill, OXFORD DICTIONARY,
https://en.oxforddictionaries.com/definition/shill (last visited Apr. 20, 2018).
26

updated as the story developed. Mr. Gilmore’s quote and information was removed as
more pertinent information became available.41
67. Through statements such as “[t]he media knows exactly who he is yet played it off like a
casual observer,” and “it looks like the State Department was involved in Charlottesville
and is trying to cover it up,” and by describing Mr. Gilmore’s presence at and later
description of the events in Charlottesville as proving how “the Deep State is working with
the liberal media to shape narrative and fool the American people,” Hoft implies a number
of assertions of fact that are provably false: 1) that the State Department organized the
Charlottesville rioting and/or attack; 2) that Mr. Gilmore participated in the State
Department’s planning of the Charlottesville riots and/or attack; 3) that the State
Department conspired to conceal these facts by removing information about Mr. Gilmore
from a number of internet sources; 4) that media outlets were involved in the conspiracy
because they knew Mr. Gilmore was a State Department employee; 5) that the media
characterized Mr. Gilmore as a casual observer because they were working in concert with
Mr. Gilmore, the State Department, and other government agencies to cover up their
involvement in the conspiracy; and 6) that all of these conspirators worked together to
deceive the public about what happened in Charlottesville that day.
68. Hoft knew that his readers would understand the clear meaning of his words and intended
that they would interpret his statements as assertions of fact.
69. Indeed, Hoft’s readers clearly viewed the statements in Hoft’s article as assertions of fact
that were the result of diligent investigative journalism, as demonstrated by the comments
41
Sheryl Gay Stolberg and Brian M. Rosenthal, Man Charged after White Nationalist Rally in Charlottesville Ends
in Deadly Violence, N.Y. TIMES (Aug. 12, 2017), https://www.nytimes.com/2017/08/12/us/charlottesville-protest-
white-nationalist.html.
27

left on the article. After Hoft shared a link to the article with his 83,000 followers on
Twitter,42 his followers quickly re-posted and shared the article over one hundred times,
and they responded with comments on Twitter such as “Instigated by the Left—as has been
happening for years now!”43 Readers also commented on the article’s page on the Gateway
Pundit website, saying: “There you go. I'll bet there were plenty of deep state ‘plants’ on
hand to spur the events;” “This a good piece of investigation. The encouraging thing is that
truth can still be found. The discouraging thing is that the evil corrupt actions go so deep;”
“That ‘random man’ better watch his back because he’s become ‘inconvenient’ to those he
was working for! They might want to erase more than his history.”
70. By both stating and insinuating that Mr. Gilmore was an accomplice to a government plot
to stage a violent riot and/or attack that killed and injured individuals in Charlottesville,
and cover it up, Hoft falsely brands Mr. Gilmore as a criminal, a fraud, and an accessory
to murder.
71. Such statements and implications are malicious, and have exposed Mr. Gilmore to hatred
and contempt, as demonstrated by the threats and harassment Mr. Gilmore experienced and
continues to experience. These implications have also deterred friends, acquaintances, and
members of the community from associating with Mr. Gilmore and have imperiled his
ability to continue serving as a State Department employee, because Mr. Gilmore’s ability
to continue to do diplomatic work is severely hindered by the false claim that he
participated in a secret operation to stage riots and a violent attack and commit murder.
72. At no point prior to or after publishing his article did Hoft investigate the outrageous,
42
Jim Hoft (@gatewaypundit), TWITTER (Aug. 14, 2017 10:10 AM),
https://twitter.com/gatewaypundit/status/897098093795135488.
43
Stu Cvrk (@STUinSD), TWITTER (Aug. 14, 2017 04:39 PM),
https://twitter.com/STUinSD/status/897195912342130688.
28

improbable, and false factual allegations included in his story.
73. Defendant Hoft did not reach out to Mr. Gilmore for comment or to respond to the
allegations included in the article.
74. Defendant Hoft did not identify any reputable human sources in his article with actual
knowledge of the events described, and Hoft had reason to doubt the veracity of the
anonymous, disreputable Reddit forum he cites. Nor did Hoft have the facts alleged
independently fact-checked.
75. Defendant Hoft never updated or corrected information about Mr. Gilmore after he
published the defamatory article.
76. Defendant Hoft did not reach out to Mr. Gilmore to confirm the statements or conclusions
in his article prior to publication. Nor did Hoft reach out to any of the other individuals or
organizations named in his article to confirm the accuracy of his statements and claims.
77. Instead, Defendant Hoft relied entirely on screenshots from an anonymous, disreputable
Reddit post as his “research.”
78. All of these failures clearly demonstrate that Hoft deliberately distorted the facts and their
context and departed from even the most basic journalistic standards of accuracy and fact-
checking for factual reporting.
79. Defendant Hoft harbored animosity and ill will toward the so-called “Deep State,” a
perceived left-wing, organized bureaucratic resistance to the Trump Administration.
Because Hoft identified Mr. Gilmore as being a member of the “Deep State,” he intended
to injure Mr. Gilmore and his reputation. Defendant Hoft has previously authored articles
and published videos similarly claiming that the “Deep State” is attempting to plan a coup
29

to oust President Trump.44 He has published claims that State Department employees have
“worked together to overthrow other governments” and thus “it was inevitable they would
use the gun on [the U.S. government].”45 These statements are clearly intended for his
audience to make the inference that Mr. Gilmore was one of these State Department
employees allegedly attempting to plan such a coup. While Hoft attributed the car attack
to “white supremacist James Alex Fields,” Hoft sought to deflect blame away from the alt-
right by utilizing a preconceived and well-worn narrative that the “Deep State” was behind
the attack. Hoft then consciously set out to make his false statements about Mr. Gilmore
conform to that narrative.
80. After the attack in Charlottesville, Defendant Hoft used the factually inaccurate
screenshots from Reddit to invent a nefarious role and identity for Mr. Gilmore in order to
promote this preconceived narrative: that the violence in Charlottesville was a creation of
the “Deep State,” that Mr. Gilmore was a central accomplice to that effort, and that the
media was working with the “Deep State” to cover up their role in Charlottesville and
deceive the American public.
81. Defendant Hoft did this despite entertaining the serious doubts about the veracity of his
claims that would naturally arise from relying on screenshots posted to an anonymous,
disreputable forum such as Reddit for the factual basis of his article.
82. Defendant Hoft ran this story despite entertaining serious doubts about the veracity of his
claims, which he demonstrated, at minimum, by directly disavowing the simplest (and the
44
Jim Hoft, BOOM! Democrat Dennis Kucinich: “Deep State Trying to Take Down a President - It is a Threat to
Our Republic,” GATEWAY PUNDIT (May 17, 2017), http://www.thegatewaypundit.com/2017/05/boom-democrat-
dennis-kucinich-deep-state-trying-take-president-threat-republic-video/; Jim Hoft, Presidential Historian: Deep
State Attempting Coup D’etat of U.S. President, GATEWAY PUNDIT (June 15, 2017),
http://www.thegatewaypundit.com/2017/06/presidential-historian-deep-state-attempting-coup-detat-us-
administration-video/.
45
Id.
30

factually accurate) explanation: that Mr. Gilmore’s witnessing of Fields’ attack was a tragic
and traumatic coincidence and that Mr. Gilmore’s employment with the State Department
had absolutely nothing to do with his presence in Charlottesville that day. By twisting true
facts about Brennan’s employment history with false allegations to fit his preconceived
narrative and ill will toward the “Deep State,” Defendant Hoft knowingly and recklessly
disregarded that his statements and their implications were false.
Publications by InfoWars
83. On August 15, 2017, Defendant InfoWars, a website owned and operated by Defendant
Jones, published an article authored by Defendant Lee Ann McAdoo and an accompanying
video, both entitled “Bombshell Connection Between Charlottesville, Soros, CIA.”46 See
Exhibit F. The title of the article and video asserts that the violence in Charlottesville was
connected to Soros and the CIA. McAdoo writes:
As demonstrated this weekend, a civil war is brewing in this country, laying

the foundation for a violent coup to take out Trump.
Soros-funded NGO’s have been able to achieve regime change in other

countries by quite literally teaming up with Neo-nazis and “moderate”
terrorists.
Now, investigative reporter Lee Stranahan reveals the same players

involved in the Ukraine overthrow are working behind the scenes to oust
President Trump.
Because the video goes on to describe Mr. Gilmore and his alleged connection to Ukraine
and Soros, the factual allegation that he is one of the “same players [. . .] working behind
the scenes to oust President Trump.” This is false. In the first seconds of the video interview
with Defendant Stranahan, Defendant McAdoo reiterates that there is a “Deep State coup
underway to oust Trump.” She then goes on to introduce Stranahan, telling viewers that
46
Lee Ann McAdoo, Bombshell Connection, supra note 4.
31

“everyone needs to be following Lee on Twitter. . . he can’t even wait to post his articles
the next day: he wants to give it to you live via Periscope [a live video streaming service]
so you can get the real news before everyone else,” and that Stranahan is “saving journalism
over at CitizenJournalismSchool.com.” McAdoo’s statements convey to viewers that
Stranahan is not merely providing opinion or commentary, but truthful, “real news” based
on facts and research, the content of which she endorses.
84. After McAdoo’s introduction, Defendant Stranahan discusses his background and interest
in groups like Occupy, Black Lives Matter, and the Anti-Fascists (“Antifa”), all of which
are “Soros-funded . . . everyone who watches InfoWars knows and understands that.”
Stranahan then goes on to allege that the United States government, under the Obama
Administration and Hillary Clinton State Department, and the CIA “sponsored a coup” in
Ukraine that was “funded by Soros.” On the screen, Stranahan and McAdoo show a Google
Image search for Svoboda, an “Ukrainian neo-Nazi party,” conducting tiki-torch marches
“exactly like we saw in Charlottesville.” After a discussion about Ukraine, the ideology of
white supremacists, and Obama/Clinton/Soros, Stranahan talks about the importance of
insurrectionist movements having “martyrs” and suggests that Heather Heyer may have
been a “martyr” created by “Soros-funded NGO’s” to orchestrate a “regime change” in the
United States:
STRANAHAN: So it’s come out that Brennan Gilmore was working with
the U.S. - the guy who happened to catch that shot [of Fields’ car attack] -
with the U.S. State Department. He also worked for a Democratic
Representative, but let me point out something else…
While Stranahan discusses Mr. Gilmore, scenes of violent riots and people in riot gear from
Oliver Stone’s “Ukraine on Fire” film plays on the screen. Stranahan and McAdoo
deliberately collocate this visual with Stranahan’s narration to falsely imply Mr. Gilmore
32

is part of what Stranahan claimed was a Soros-funded and United States government-
sponsored coup beginning in Ukraine and further carried out in Charlottesville.47
STRANAHAN: If you go to Brennan Gilmore’s page, his Twitter page,

you’ll see he has a picture of the young woman who was murdered, and you
know what is says? “Martyr.” . . . Literally it says “martyr.” You can’t be
more explicit than this. So here’s what I’m saying. I’m not a conspiracy
theorist, I’m a fact-based journalist. The facts are enough. However, the
Democrats have investigated Trump for a lot less. For a lot less. They have
called for investigations, and secret meetings, they have convened the FBI.
When you have this many things going on, I think someone really needs to
investigate. Again, I don’t like to jump to conclusions, I’d like to ask some
questions about who this kid was, where he came from, what do we know,
get it all out in the open, but I’ll also point out that we can’t count on the
media to do this.
By stating that Mr. Gilmore should be investigated by the FBI, Defendant Stranahan falsely
implies that Mr. Gilmore’s identity, origin, and presence in Charlottesville is related to his
association with a Soros-funded coup effort. The nature of Defendant Stranahan’s
implication reasonably indicates to his audience that he knows of the existence of
additional undisclosed defamatory facts that justify his false conclusions about Mr.
Gilmore and his association with Soros-funded coup efforts.
[MCADOO scrolls through Gilmore’s Twitter page]
STRANAHAN: Yeah, if you scroll…keep scrolling…this is the guy,

Brennan Gilmore, and if you scroll down, keep going, it’s not too far, you’ll
see the photo of the young woman…this is abs [sic]…when I saw this, uh,
I was shocked…[MCADOO continues to scroll through Gilmore’s Twitter
47
This collocation of two unrelated things or concepts in order to imply the existence of a nonexistent relationship
(or as a critic described it, to “connect unconnected dots”) is a method frequently used by Defendant Stranahan in
his journalism and taught by Defendant Stranahan at his Citizen Journalism School. Defendant Stranahan’s interest
in this method was inspired in part by the documentary film “Koyaanisqatsi,” which would compare time-lapsed
images of two unconnected things in a way that required the audience to make the connection between them.
Defendant Stranahan has described this method as allowing the audience to “fill in” the meaning and relationship
between two collocated images “that’s not there.” Kobi Libii, A Crash Course in Breitbart’s Conspiracy
Journalism, Pt. 2, THE OPPOSITION WITH JORDAN KLEPPER, http://www.cc.com/video-clips/d4aufk/the-opposition-
with-jordan-klepper-a-crash-course-in-breitbart-s-conspiracy-journalism--pt--2 (last visited Apr. 20, 2018).
Defendants Stranahan and McAdoo deliberately play images of Ukrainian riots while discussing Mr. Gilmore to
convey to the audience a factual connection between Mr. Gilmore and what Stranahan claimed were United States-
sponsored and Soros-funded riots designed to achieve a coup.
33

feed] by the way, his bio, if you look at this guy’s bio, it says he’s with the
State Department, and the fact that he called her a ‘martyr’. . . I
[STRANAHAN looks knowingly at the camera, eyebrows raised, arm
raised, MCADOO nods comprehendingly, laughs] don’t know, but this is
clearly, the way she’s being used is she’s a martyr to the cause.
Stranahan and McAdoo’s body language falsely convey to the audience that Mr. Gilmore’s
tribute to a woman who died in the traumatizing attack that he and other bystanders
witnessed indicates that he was actually a knowing participant in a Soros-sponsored
conspiracy to stage violence and create a martyr—Heather Heyer—for their cause.
STRANAHAN: And let me point out what’s happening. They, uh, they win
no matter what they do. Are they trying to get a coup? I think clearly they
are. But if they can’t get a coup, they’ll settle for impeachment. And if they
can’t get impeachment, they’ll settle for smearing Trump and his supporters
so much that they’ll be able to elect another elitists. Does that make sense?
MCADOO: Absolutely.
85. The statements and visuals used by Stranahan and McAdoo throughout the video and in
the accompanying article imply an assertion of fact: that Mr. Gilmore’s coincidental
presence at and recording of Fields’ car attack was not coincidental, but was due to his
knowing participation in Soros- and government-staged violence in Charlottesville
designed to force a coup to oust President Trump. Defendants clearly intended their
audience to make this inference. These are assertions of fact that are objectively and
provably false. With his recording of Mr. Fields’ attack, Mr. Gilmore was not “trying to
get a coup”; he was not involved with an effort designed to lead to President Trump’s
impeachment; he was not trying to “smear Trump and his supporters” or “elect other
elitists.”
86. Taking the context of Defendant McAdoo’s article and video as a whole, they clearly assert
the factual conclusion, based on McAdoo and Stranahan’s investigative journalism, that
34

Mr. Gilmore was directly involved in a latent civil war by participating in “Soros-funded”
events to lay “the foundation for a violent coup to take out Trump” and “achieve regime
change.” These assertions are false.
87. The video, bearing the same title as the InfoWars article, is hosted on The Alex Jones
Channel, a YouTube channel owned by Defendants Jones and InfoWars. The channel has
over 2 million subscribers. The video had been watched more than 312,000 times as of
January 2018.48 The description of the video reads:
As evidenced this weekend, a civil war is brewing in this country, laying

the foundation for a violent coup to take out Trump. Soros-funded NGO’s
have been able to achieve regime change in other countries by quite literally
teaming up with Neo-nazis and “moderate” terrorists. Now, investigative
reporter Lee Stranahan reveals the same players involved in the Ukraine
overthrow are working behind the scenes to oust President Trump.
88. Defendant Jones shared a link to the InfoWars article and video defaming Mr. Gilmore
48
See The Alex Jones Channel, Bombshell Connection Between Charlottesville, Soros, CIA, YOUTUBE (Aug. 15,
2017), https://www.youtube.com/watch?v=L58T2dl997A.
35

with his 737,000 followers on Twitter.49
89. Defendants Jones, InfoWars, Stranahan, and McAdoo knew that their readers and viewers
would understand the clear factual meaning of their words and body language. Indeed, as
Defendant Stranahan says in the video, “everyone who watches InfoWars knows and
understands” the factual conclusions he implies.
90. Defendants Jones and Stranahan both hold themselves out to the public as fact-based
journalists. Defendant Jones describes himself on his Twitter profile as “Fighting for
Freedom & Liberty on the Frontlines of Truth Journalism.”50 Defendant InfoWars
describes itself as “The Frontline of Journalism;” indeed, the content on Defendant
InfoWars’ website is listed as “news” or “breaking news.” Defendant Stranahan states
unwaveringly in the above-referenced video, when talking about Mr. Gilmore, that he is a
“fact-based journalist,” and is represented as an “investigative reporter” in the YouTube
video’s description. Defendant McAdoo likewise represents that she is conducting an
interview of “investigative reporter” Stranahan who provides viewers with “real news.”
These representations all support the article and video’s general tenor as factual.
91. Defendant Jones’ followers, understanding Stranahan and McAdoo’s statements about the
Charlottesville attack and implications about Mr. Gilmore’s involvement to be assertions
of fact, quickly responded with comments such as “This was coordinated. Not
spontaneous”51 and “Obama Clinton coupd’tat in full bloom. We see Comey, lynch,
49
Alex Jones (@RealAlexJones), TWITTER (Aug. 15, 2017 11:10 PM),
https://twitter.com/realalexjones/status/897656664379322369.
50
Alex Jones (@RealAlexJones), Twitter,
https://twitter.com/RealAlexJones?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5Eauthor (last visited
Apr. 12, 2018).
51
Catherine (@RealAliCat), TWITTER (Aug. 16, 2017 05:29 PM),
https://twitter.com/RealAliCat/status/897933461012574209.
36

clapper, Brennan, Clintons, FBI, secret service, dnc, democrats in mix.”52
92. By insinuating that Mr. Gilmore knowingly participated in a Soros- and government-
staged violent riot and attack, Defendants Stranahan, McAdoo, Jones, InfoWars, and Free
Speech Systems falsely imply that Mr. Gilmore is a criminal conspirator and a party to
treason and murder. Such implications are false, defamatory, and malicious, and have
exposed Mr. Gilmore to hatred and contempt, as demonstrated by the threats and
harassment Mr. Gilmore experienced and continues to experience. These implications have
also deterred friends, acquaintances, and members of the community from associating with
Mr. Gilmore, and have imperiled his ability to continue serving as a State Department
employee, because Mr. Gilmore’s ability to continue to do diplomatic work is severely
hindered by the false claim that he participated in a secret operation to stage a violent attack
and even commit murder.
93. At no point prior to or after publishing the article and video did Defendants Stranahan,
McAdoo, Jones, or anyone from InfoWars or Free Speech Systems investigate the
outrageous, improbable, and false factual allegations and factual conclusions included
therein. They conducted no research of Mr. Gilmore beyond identifying a few, readily
available disparate facts from his biography.
94. At no point did Defendants Stranahan, McAdoo, Jones, or anyone from InfoWars or Free
Speech Systems reach out to Mr. Gilmore to confirm the statements or conclusions about
Mr. Gilmore. Nor did these Defendants reach out to any of the other individuals or
organizations named in the article and video for comment or confirmation of even the most
basic facts they allege. This failure to verify and investigate Defendants’ statements about
52
Eugene Schreiber (@geno5491), TWITTER (Aug. 16, 2017 9:08AM),
https://twitter.com/geno5491/status/897852665085935617.
37

Mr. Gilmore is particularly egregious, as Stranahan himself asserts that “we can’t count on
the media” to question Mr. Gilmore’s presence in Charlottesville, all while Defendants
themselves failed to confirm their statements or conclusions prior to publishing them to the
public.
95. Defendants Stranahan, McAdoo, Jones, or anyone from InfoWars or Free Speech Systems
did not identify any human sources in the article or video for their information regarding
Mr. Gilmore other than from Mr. Gilmore’s Twitter page or media appearances, nor did
they update or correct any information about Mr. Gilmore after they published the
defamatory article and video. They did not have the facts alleged independently fact-
checked.
96. All of these failures demonstrate that Defendants Stranahan, McAdoo, and Jones
deliberately distorted the facts and their context and clearly departed from even the most
basic journalistic standards for factual reporting.
97. Defendants Stranahan, McAdoo, and Jones harbored animosity and ill will toward Soros-
funded regime changers and associated entities and individuals, including the so-called
“Deep State,”53 a perceived left-wing, organized bureaucratic resistance to the Trump
Administration, and to which they believe the State Department, the Democratic Party, and
George Soros are linked.54 Defendants also harbored animosity and ill will toward George
53
See, e.g., Aidan Quigley, Deep State is ‘Going to Kill the President,’ Alex Jones Claims, NEWSWEEK (Aug. 4,
2017), http://www.newsweek.com/alex-jones-says-deep-state-going-kill-president-646802;
Loulla-Mae Eleftheriou-Smith, Alex Jones Defends His Claim Donald Trump Could Be Assassinated by the ‘Deep
State,’ INDEPENDENT (Aug. 8, 2017), https://www.independent.co.uk/news/world/americas/alex-jones-donald-
trump-assassination-deep-state-infowars-us-president-a7882461.html; Lee Stranahan, JFK, the Deep State, and the
Covert History of the CIA, PSCP https://www.pscp.tv/w/1ZkJzdpAOkqKv; Alex Jones Show, Black Ops
Commander Reveals Deep State Secrets, INFOWARS (Feb. 22, 2017), https://www.infowars.com/black-ops-
commander-reveals-deep-state-secrets/.
54
Michael Hoult, Jones - Vegas Shooter Brainwashed by Obama’s Reptillians Funded by George Soros, BUSINESS
STANDARD NEWS, (Oct. 2, 2017), https://bizstandardnews.com/2017/10/02/jones-vegas-shooter-brainwashed-
obamas-reptilians-funded-george-soros/.
38

Soros and associated entities and individuals.55 Where Defendants identified Mr. Gilmore
as associated with George Soros and the “Deep State” and alleged that Mr. Gilmore was
involved in acts in Charlottesville directed toward regime change in the U.S., they harbored
ill will toward him, and intended to injure Mr. Gilmore and his reputation.
98. Defendants Stranahan, McAdoo, and Jones would not admit that the Charlottesville attack
was the act of a white supremacist. Instead, they utilized the preconceived and well-worn
narrative that George Soros, the State Department, and the Democratic Party were behind
the attack, in advance of any investigation (or lack thereof), and then consciously set up to
make their statements about Mr. Gilmore conform to this narrative. In addition to their
persistent animus toward George Soros, the “Deep State,” the State Department, and the
Democratic Party, Defendants Jones, InfoWars, and Free Speech Systems have also
published numerous similar articles and videos claiming that previous national tragedies
were “false flags” and “inside jobs” created by the government to push a leftist agenda.56
Defendant Stranahan has similarly published statements that the Charlottesville tragedy
55
Michael Hayden, Alex Jones Spins Antisemitic Conspiracy that George Soros Created Sexual Misconduct
Allegations to Hurt Trump, NEWSWEEK, (Dec. 12, 2017), http://www.newsweek.com/alex-jones-antisemitic-
conspiracy-george-soros-trump-sexual-misconduct-745886; The Alex Jones Channel, Obama/Soros Behind Black
Lives Matter Massacre of Police, YOUTUBE (July 8, 2016),
https://www.youtube.com/watch?v=pMUiViz757o; Lee Stranahan (@Stranahan), TWITTER (May 1, 2017 06:49
AM), https://twitter.com/stranahan/status/859042209471107076; Ben Collins and Jordan Resnick, George Soros
Took Control of 183 Groups and 12 People So Far this Year, According to Alex Jones and InfoWars, DAILY BEAST
(Apr. 6, 2017), https://www.thedailybeast.com/george-soros-took-control-of-183-groups-and-12-people-so-far-this-
year-according-to-alex-jones-and-infowars; Trump Ally Alex Jones: Head of Jewish Mafia is Alex Jones, MEDIA
MATTERS FOR AMERICA (Mar. 29, 2017), https://www.mediamatters.org/video/2017/03/29/trump-ally-alex-jones-
head-jewish-mafia-george-soros/215864.
56
See e.g. David Gilmour, Alex Jones Pushes Another Baseless, Grossly Inaccurate School Shooting Conspiracy,
THE DAILY DOT (Feb. 19, 2018), https://www.dailydot.com/layer8/alex-jones-pushes-another-school-shooting-
conspiracy/; Michael Grynbaum, Las Vegas Massacre Gives InfoWars More Conspiracy Fodder, N.Y. TIMES (Oct.
9, 2017), https://www.nytimes.com/2017/10/09/business/media/las-vegas-massacre-infowars-conspiracy.html; Alex
Jones Show, Flashback: Alex Jones Said 9/11 Inside Job On the Day it Happened, INFOWARS (Sept. 11, 2001),
https://www.infowars.com/flashback-alex-jones-said-911-inside-job-on-the-day-it-happened/.
39

was a part of a coordinated plan by the CIA and the left to undermine the Trump
administration through violent protests.57
99. Defendants Jones, InfoWars, Free Speech Systems, Stranahan, and McAdoo fit Mr.
Gilmore into this preexisting narrative. They used select facts from Mr. Gilmore’s
professional history to identify him as a State Department conspirator who organized the
Charlottesville riots and attack, and exploited Heather Heyer’s death as part of a coup effort
designed and funded by George Soros to destabilize the Trump administration. In short,
they cast Mr. Gilmore a central role in the narrative they have worked tirelessly to craft,
and they shoehorned that narrative to fit the events of the Charlottesville riots and attack.
100. Defendants did this despite entertaining serious doubts about the veracity of their claims,
which they demonstrated, at minimum, by directly disavowing the simplest (and the
factually accurate) explanation: that Mr. Gilmore’s witnessing of Fields’ attack was a
tragic and traumatizing coincidence, and that Mr. Gilmore’s employment with the State
Department had absolutely nothing to do with his presence in Charlottesville that day.
By twisting true facts about Mr. Gilmore’s employment history to fit their preconceived
narrative and ill will toward George Soros, the State Department, the “Deep State,” and
the Democratic Party, Defendants Stranahan, McAdoo, and Jones knowingly or
recklessly disregarded that their statements and their implications were false.
101. Defendants Jones and InfoWars continued to spread falsehoods about the Charlottesville
protest and attack in the days that followed. On August 14, 2017, Defendant Jones
published a post entitled George Soros Needs to be Charged and Arrested for Sedition and
Causing Charlottesville on his InfoWars website; in the accompanying video, he alleges
57
See Lee Stranahan (@Stranahan), TWITTER (Aug. 13, 2017 08:02 PM),
https://twitter.com/stranahan/status/896929944294510592?lang=en.
40

George Soros paid the Charlottesville protestors.58 Defendant Jones published several
additional videos in which he characterized the violence in Charlottesville as “staged” and
orchestrated by left-wing political operatives and “cut-outs.”59
102. While Defendant Jones later attempted to retract his claim that “Jewish actors” paid by
George Soros were responsible for the violence, he doubled down on his efforts to harass
and defame Mr. Gilmore in a video entitled Breaking: State Department/CIA Orchestrated
Charlottesville Tragedy, posted on YouTube on August 20, 2017,60 and on Defendant
InfoWars’ website on August 21, 2017.61 See Exhibit G. The title of the video itself is a
provably false factual assertion that the State Department and/or CIA orchestrated Fields’
attack against Heather Heyer and the other protesters.
103. The video’s title (“Breaking”) as well as Defendants Jones’, InfoWars, and Free Speech
Systems’ characterization of their own work as journalism predicated on “truth,” supports
that the general tenor of the video is factual. Jones, InfoWars, and Free Speech Systems’
description of the video on YouTube, stating that “Alex Jones breaks down shocking
revelations into the charlottesville riots. Who was behind this attack and why they did it!!”
also characterizes that their reporting is factual, and conveys to viewers the false and
defamatory assertion that the individuals discussed in the video, including Mr. Gilmore,
58
The Alex Jones Show, George Soros Needs to be Charged and Arrested for Sedition and Causing Charlottesville,
INFOWARS (Aug. 14, 2017), https://www.infowars.com/george-soros-needs-to-be-charged-and-arrested-for-sedition-
and-causing-charlottesville-chaos/.
59
The Alex Jones Show, Breaking: Charlottesville Confirmed Agitprop Staged Event, INFOWARS (Aug. 16, 2017),
https://www.infowars.com/breaking-charlottesville-confirmed-agitprop-staged-event/; The Alex Jones Show, Deep
State Caught Red-Handed Causing Charlottesville Violence, INFOWARS (Aug. 17, 2017),
https://www.infowars.com/deep-state-caught-red-handed-causing-charlottesville-violence/; see also The Alex Jones
Show, Breathtaking: Democrats Accused of Hiring Actors Prior to Charlottesville Rally, INFOWARS (Aug. 17,
2017), https://www.infowars.com/breathtaking-democrats-accused-of-hiring-actors-prior-to-charlottesville-rally/.
60
The Alex Jones Channel, Breaking: State Department/CIA Orchestrated Charlottesville Tragedy, YOUTUBE
(Aug. 20, 2017), https://www.youtube.com/watch?v=52C5-GplKxg&t=3s.
61
The Alex Jones Show, State Department/CIA Orchestrated Charlottesville Tragedy, supra note 5.
41

were “behind this attack.”
104. In the video, Defendant Jones asserts that the statements he made about Mr. Gilmore were
factual and researched:
I knew a lot of it, but I did deep research . . . I did research, and I confirmed
it all. They had known CIA and State Department officials in
Charlottesville, first tweeting, first being on MSNBC, CNN, NBC. The
mayor is involved. Everybody is a cut-out…62
They got State Department and high-level CIA. One guy is paid 320,000 a
year on the payroll of [George] Soros. He doesn’t just get money from
Soros, he personally is paid 320 a year, and then he is there—CIA, State
Department—and he is on the news. And when people pointed out who he
was, they took his name of the State Department website and stuff, but
Google has all the [screen] shots of it. I mean it’s like WOW, WOW—CIA?
Your senior guys? And you’re so stupid on TV, “oh I saw ‘m run over, I
saw the racists, I saw the white supremacists attack, oh I’m the guy being
interviewed first putting out the talking points “this is the downfall of
Trump this is the beginning, it shows that he…” He worked for Podesta
too, John Podesta. I’ll give you his name and stuff, we’re gonna play a video
of him on the news. They had him first on every news cast…” I’m just
witness standing here, huh yeah huh huh”...formerly worked for Obama,
Podesta, Hillary, the CIA...and when we have Pieczenik on and he says
they’re CIA...he has all the connections, he’s gonna say he thinks they are
and here’s the evidence to why he thinks so...he can’t legally tell you, but
there’s a civil war going on in the government so they’re going to tell you
[. . .]
105. After an advertisement for his InfoWars supplements, Jones’ video then cuts to a narration
of the alleged testimony of a Charlottesville police officer who “has come forward to
express his anger at being told to stand down” during the violence in Charlottesville, and
who claims that the violent crashes were “set up to further the agenda of the elites.” After
discussing the duplicitous involvement of Mayor Signer and his ties to Barack Obama and
62
In espionage parlance, a “cut-out” is a mutually-trusted person involved in espionage who acts as an intermediary
or channel of communication between a spymaster and other subagents of a covert operation. Cutouts usually know
only the source and destination of the information to be transmitted, not the identities of other persons involved in
the espionage process. Thus, a captured cutout cannot be used to identify members of an espionage cell. See Cut-
out, WIKIPEDIA, https://en.wikipedia.org/wiki/Cut-out_(espionage) (last visited Apr. 24, 2018); see also Language
of Espionage, SPY MUSEUM, https://www.spymuseum.org/education-programs/news-books-briefings/language-of-
espionage (last visited Apr. 24, 2018).
42

John Podesta, the video goes on to claim that Fields was a “Hillary supporter” who was “in
receipt of funding by George Soros.” After the narrator says, “if you think that’s
outrageous, wait ‘til you hear about the other actors in this enormous set-up event…” The
screen cuts to a picture of Mr. Gilmore and his dog, and continues: “Brennan Gilmore was
on the scene, and the author of the first viral tweet about Charlottesville. He was later
interviewed by MSNBC. He was presented as an accidental witness, but who is he really?”
The screen then cuts to a screenshot of Google results about Mr. Gilmore’s State
Department assignments in Africa, with the narration stating that “Gilmore worked in
Africa as a State Department Foreign Office under Hillary Clinton. The New York Times
mentioned this coincidence and then later deleted it. Brennan Gilmore was also involved
with the Kony hoax in 2012, and he’s currently Chief of Staff for Tom Perriello, who’s
running for governor of Virginia, and received $380,000 from George Soros.” The screen
then cuts to pictures of Brennan Gilmore and George Soros placed side-by-side, so as to
emphasize the relationship between the two men, and the narration continues:
So the first man in the scene whose tweet went viral and who was later
interviewed on mainstream news as a witness just happened to be a State
Department insider with a long history of involvement in psy-ops? If you
think that isn’t fishy, how about this? Since the Charlottesville protest, and
his appearance in the media, his information was suddenly removed from
the State Department websites. The elites know we’re on to them and are
trying to cover their tracks.
43

106. The “high-level CIA” and “State Department guy” that Defendant Jones is referring to is
clearly Mr. Gilmore. Incredibly, Defendant Jones directly asserts that a campaign donation
by George Soros to Tom Perriello’s gubernatorial campaign was in reality a personal
payment to Mr. Gilmore. Such a provably false factual assertion is material and especially
malicious, as it implies that Mr. Gilmore has received money from Mr. Soros and was paid
by Soros to orchestrate the violence in Charlottesville.
107. Furthermore, Mr. Gilmore did not work for the campaigns or individual offices of President
Obama or Secretary Clinton. He did not work for John Podesta. He did not work for the
CIA. These factual allegations are demonstrably false, and especially in the context of Mr.
Jones and InfoWars’ other content, they are defamatory and have inspired hatred and
harassment from Jones’ and InfoWars’ audience.
108. The InfoWars video falsely states that since the Charlottesville protest and Mr. Gilmore’s
appearance on various media outlets, Mr. Gilmore’s information was removed from State
44

Department websites because “the elites know we’re on to them and are trying to cover
their tracks.” In reality, Mr. Gilmore’s information regarding his previous post as Deputy
Chief of Mission at the U.S. Embassy in the Central African Republic was removed when
the Embassy rebuilt its website to reflect current staff information after Mr. Gilmore left
the Embassy in 2013. It was not removed in an attempt to cover up Mr. Gilmore’s presence
in Charlottesville, and certainly not to cover up his alleged role orchestrating the rioting
and violence there.
109. By stating that the violence in Charlottesville was staged by the State Department and CIA,
by falsely stating that Mr. Gilmore is part of the CIA, and by placing pictures of Mr.
Gilmore next to George Soros so as to associate Mr. Gilmore with a man who Jones claims
paid protesters to incite violence in Charlottesville, and who Jones frequently and viciously
attacks, demonizes, and accuses of committing atrocities, Defendant Jones was clearly
stating and implying an assertion of fact: that Mr. Gilmore participated in a State
Department/CIA operation to stage the violence and Fields’ car attack in Charlottesville.
This assertion of fact is false.
110. By calling Mr. Gilmore a “cut-out” in this context, Defendant Jones clearly asserted the
fact that Mr. Gilmore was involved in this treasonous act of espionage and deceit. This
assertion of fact is false.
111. Defendant Jones knew that his viewers and readers would clearly understand the factual
meaning he intended his words to carry (i.e. that Mr. Gilmore was involved in orchestrating
the violence in Charlottesville), and he intended for them to make this inference.
112. By citing the anonymous “testimony” of an alleged Charlottesville police officer,
Defendants Jones, InfoWars, and Free Speech Systems reasonably indicate to the audience
45

that other undisclosed defamatory facts exist that would justify Mr. Jones’ conclusions,
such as this police officer’s firsthand observation of Mr. Gilmore in Charlottesville.
Furthermore, by airing the alleged “testimony” of a police officer, Defendants Jones,
InfoWars, and Free Speech Systems indicate to their audience that this source has been
verified and the veracity of his or her “testimony” independently checked. Neither is true.
Comments on Defendant Jones’ video left by his followers and other viewers, such as
“Brennan’s little jihadi running around playing parts. ISIS, Antifa, and SPLC’s White
Supremacists. All contracted labor for media mind control operations and it’s about time
they got exposed,” clearly demonstrate that his viewers took Jones’ statements as assertions
of facts that Mr. Jones “exposed.”
113. By insinuating that Mr. Gilmore was part of a State Department/CIA operation to stage the
violence and Fields’ car attack in Charlottesville, Defendants Jones, InfoWars, and Free
Speech Systems falsely brand Mr. Gilmore as a party to a criminal conspiracy and murder.
Such implications are malicious, and have exposed Mr. Gilmore to hatred and contempt,
as demonstrated by the threats and harassment Mr. Gilmore experienced and continues to
experience. These implications have also deterred friends, acquaintances, and members of
the community from associating with Mr. Gilmore, and have imperiled his ability to
continue serving as a State Department employee, because Mr. Gilmore’s ability to
continue to do diplomatic work is severely hindered by the false claim that he participated
in a secret operation to stage a violent attack and even commit murder.
114. At no point prior to or after publishing his video did Defendant Jones or anyone at InfoWars
or Free Speech Systems investigate the outrageous, improbable, and false factual
46

allegations included in his video. Defendant Jones conducted no research beyond
identifying a few disparate facts and circumstances from Mr. Gilmore’s biography.
115. Defendant Jones did not reach out to Mr. Gilmore to confirm the content of his statements
or conclusions (nor did anyone at InfoWars or Free Speech Systems). Nor did they reach
out to any of the other individuals or organizations named in his video for comment or
confirmation of the relevant facts.
116. Defendants Jones, InfoWars, and Free Speech Systems did not reach out to Mr. Gilmore
for comment or to respond to the allegations included in the video at any time before or
after the video was published.
117. Neither InfoWars nor Free Speech Systems independently fact-checked any of the
allegations included in the video. Though Defendant Jones stated in his video that he “did
the research, and [] confirmed it all” there is reason to doubt the veracity of the sources he
consulted, and it is dubious what, if anything, the “Google…[screen] shots” revealed.
Defendant Jones never updated or corrected information about Mr. Gilmore after releasing
this defamatory video.
118. All of these failures demonstrate that Defendant Jones, InfoWars, and Free Speech Systems
deliberately distorted the facts and their context, and departed from even the most basic
journalistic standards of accuracy for factual reporting.
119. As detailed elsewhere in this Complaint, Defendant Jones harbored animosity and ill will
toward the so called “Deep State,” Hillary Clinton, and George Soros. Where Defendant
Jones identified Mr. Gilmore as being a member of the “Deep State,” and identified
connections between Mr. Gilmore and Soros and Clinton, Defendant Jones intended to
injure Mr. Gilmore and his reputation.
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120. Defendant Jones would not admit that the Charlottesville attack was the act of a white
supremacist. Instead, Jones utilized this preconceived and well-worn yet false narrative
that the “Deep State” and George Soros were behind the attack and that Mr. Gilmore was
a “high level CIA” and “State Department guy” who was a “cut-out” involved in the attack,
all in advance of any investigation. As detailed elsewhere in this Complaint, Defendants
Jones, InfoWars, and Free Speech Systems have previously published similar statements
claiming that other national tragedies were hoaxes created by the government to push a
leftist agenda.
121. Defendant Jones used select facts and false statements about Mr. Gilmore’s professional
history available on Facebook, Twitter, and other websites, as well as the alleged,
unverified, and false “testimony” of an anonymous Charlottesville police officer they
found on the internet and twisted these elements to fit their preconceived narrative: that
Charlottesville was a Soros-funded false-flag operation, and Mr. Gilmore was a central
party to that operation. In fact, Defendant Jones has doubled down on his false accusations
to fit this narrative by falsely claiming that this lawsuit and Mr. Gilmore’s counsel, the
Georgetown Law Civil Rights Clinic, is also “backed” by George Soros.63
122. Defendant Jones ran this video despite entertaining serious doubts about the veracity of the
claims it included. This was demonstrated, at minimum, by Jones disavowing the simplest
(and factually accurate) explanation: that Mr. Gilmore’s witnessing of Fields’ attack was a
tragic and traumatizing coincidence, and that Mr. Gilmore’s employment history had
nothing to do with his presence in Charlottesville at that time. By twisting true facts about
Brennan’s employment history to fit a preconceived narrative and their ill will toward the
63
Alex Jones (@RealAlexJones), Twitter, (April 10, 2018 09:20 AM),
https://twitter.com/RealAlexJones/status/983741534234439680.
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“Deep State,” Hillary Clinton, and George Soros, Defendants Jones, InfoWars, and Free
Speech Systems knowingly or recklessly disregarded that Jones’ statements and their
implications were false.
123. Defendant Jones’ video had been watched over 34,000 times as of January 2018. Defendant
InfoWars’ website is viewed approximately 40 million times every month, and the site
consistently ranks among the most popular websites in the United States. InfoWars bills
and presents itself as a news media outlet.
124. In addition to soliciting advertisers for its website, InfoWars funds its work by the sale of
various dietary supplements in its online store, which are featured prominently in each
video and on banner ads that appear in each post. Recent estimates of revenue received
from online sales suggest that business is good: Defendant Jones stated in 2013 that the
online store grossed an average of $9 million in sales annually. Estimates in 2017 indicate
that sales could now be as high as $12.5 million annually.64
Publication by Derrick Wilburn, Allen West, Michele Hickford, and Words-N-Ideas, LLC
125. On August 19, 2017, Defendants West, Hickford, Word-N-Ideas, LLC, and Wilburn
published “BOMBSHELL: New Evidence Suggests Charlottesville Was a Complete SET-
UP” on his website.65 See Exhibit H. The title of the article implies that the statements
contained therein are truthful and based on evidence.
126. The article, authored by Defendant Wilburn, cites and republishes the alleged statement
of an anonymous Charlottesville police officer (the same anonymous police statement
containing the same false and defamatory statements published by Defendants Jones,
64
See Brown, supra note 1.
65
Derrick Wilburn, BOMBSHELL, supra note 20.
49

InfoWars, and Free Speech Systems in their video entitled “Breaking: State
Department/CIA Orchestrated Charlottesville Tragedy”):
If you think that is suspicious, wait until you learn about the other actors in
this enormous set-up event. Brennan Gilmore was the first man “on the
scene” and was the author of the first viral tweet about Charlottesville. He
was later interviewed by MSNBC. He was presented as an accidental
witness. But who is he really? Gilmore worked in Africa as a State
Department foreign officer under Hillary Clinton. The New York Times
mentioned this “coincidence” – and then later deleted it. Brennan Gilmore
was also involved with the Kony hoax in 2012, and he is currently Chief of
Staff for Tom Perriello, who is running for Governor of Virginia and
received $380k from George Soros. So the first man on the scene, whose
tweet went viral, and who was later interviewed on mainstream news as a
witness, just happened to be a State Department insider with a long history
of involvement in psy-ops? If you think this isn’t fishy, how about this –
since the Charlottesville protests and his appearance in the media, his
information was suddenly removed from State Department websites.”
As detailed elsewhere in the Complaint, the assertion of fact that Mr. Gilmore’s
“information was suddenly removed from State Department websites” after the
Charlottesville protests is false.
127. Wilburn then adds:
We need to clarify that these are early accounts and as yet unverified, but if
true this is very, very serious stuff. It points directly to the reality of the
“deep state” and more importantly to the lengths that the
Soros/Clinton/Obama one-world government cabal will go in order to
realize their desires for “fundamental transformation.”
128. However, despite harboring doubts about the truth of the articles’ claims, and instead of
verifying that these “early accounts” were in fact true prior to publication, Defendants
Wilburn, West, Hickford, and Words-N-Ideas published the article. Defendants did not
contact Mr. Gilmore, the anonymous Charlottesville police officer who allegedly provided
the quoted statement, or any other individuals or organizations mentioned in the article to
verify or otherwise comment. Instead, Defendants Wilburn, West, Hickford, and Words-
50

N-Ideas departed from even the most basic journalistic standards of research and
verification because they wanted to push their preconceived narrative: the existence of the
“deep state” and “the lengths that the Soros/Clinton/Obama one-world government cabal
will go in order to realize their desires for ‘fundamental transformation.’”
129. Defendants Wilburn, West, Hickford, and Words-N-Ideas’ article directly and falsely
asserts that Mr. Gilmore is an “actor[] in this enormous set-up event.” This statement is
demonstrably false.
130. By further characterizing Mr. Gilmore’s presence during Fields’ attack as “fishy” and
“suspicious,” and by falsely stating that Mr. Gilmore’s information was “suddenly”
removed from State Department websites to cover up Mr. Gilmore’s presence in
Charlottesville, Defendants Wilburn, West, Hickford, and Words-N-Ideas imply a clear
assertion of fact: that Mr. Gilmore participated in a “deep state”-“Soros/one-world
government cabal” conspiracy to stage the violence in Charlottesville. This statement of
fact can be objectively verified as false.
131. By citing the anonymous “testimony” of an alleged Charlottesville police officer,
Defendants West, Wilburn, Hickford, and Words-N-Ideas reasonably indicate to readers
that other undisclosed defamatory facts exist that would justify the conclusion that Mr.
Gilmore was involved in orchestrating the violence in Charlottesville, such as this police
officer’s firsthand observation of Mr. Gilmore in Charlottesville. Furthermore, by
republishing the alleged “testimony” of a police officer, Defendants West, Wilburn,
Hickford, and Words-N-Ideas indicate to their audience that this source has been verified
and the veracity of his or her “testimony” independently checked. Neither is true.
51

132. Defendants Wilburn, West, Hickford, and Words-N-Ideas knew that their readers would
understand the factual meaning that they intended their words to carry, and they intended
for their readers to make such an inference.
133. Indeed, Defendants Wilburn, West, Hickford, and Words-N-Ideas’ statements were
interpreted by readers as clear statements of fact. When Defendant West shared a link to
the article with his 727,000 followers on Twitter,66 those followers responded with
comments such as “[t]he shadow government has a mission to destroy America as we know
it,”67 and “[t]his whole thing stinks to high heaven. A federal investigation is needed, not
some internal self-serving coverup.”68
134. By stating and implying that Mr. Gilmore participated in a “deep state”-Soros conspiracy
to stage the violence in Charlottesville, Defendants Wilburn, West, Hickford, and Words-
N-Ideas falsely brand Mr. Gilmore as a criminal conspirator and a party to murder. Such
implications are false and malicious, and have exposed Mr. Gilmore to hatred and
contempt, as demonstrated by the threats and harassment Mr. Gilmore experienced and
continues to experience. These implications have also deterred friends, acquaintances, and
members of the community from associating with Mr. Gilmore, and have imperiled his
ability to continue serving as a State Department employee, because Mr. Gilmore’s ability
to continue to do diplomatic work is severely hindered by the false claim that he
participated in a secret operation to stage a violent attack and commit murder.
66
Allen West (@AllenWest), TWITTER (Aug. 19, 2017 09:10 AM),
https://twitter.com/AllenWest/status/898895019951575041.
67
James Reddings (@JamesReddings), TWITTER (Aug. 19, 2017 10:07 AM),
https://twitter.com/JamesReddings/status/898909398575263746.
68
Dave Riles (@DRils), TWITTER (Aug. 20, 2017 08:49 PM),
https://twitter.com/DRils/status/899433273515925504.
52

135. At no point prior to or after publishing this article did Defendants Wilburn, West, Hickford,
and Words-N-Ideas or anyone associated with AllenWest.com investigate the outrageous,
improbable, and false factual allegations included in this article. Defendant Wilburn
conducted no research beyond identifying a few disparate facts and circumstances from
Mr. Gilmore’s biography.
136. As admitted in their article, Defendants Wilburn, West, Hickford, and Words-N-Ideas
failed to investigate by reaching out to Mr. Gilmore or other witnesses of the event to
confirm the accuracy of the article’s statements or conclusions (nor did anyone associated
with AllenWest.com). Nor did they reach out to any of the other individuals or
organizations named in his video for comment or confirmation of the relevant facts.
137. Defendants Wilburn, West, Hickford, and Words-N-Ideas did not reach out to Mr. Gilmore
for comment or to respond to the allegations included in the article.
138. Defendant Wilburn did not identify any sources in the article relevant to the accusations
about Mr. Gilmore other than an anonymous police statement, and no one associated with
AllenWest.com independently fact-checked any of the allegations included in the article.
139. Defendants Wilburn, West, Hickford, and Words-N-Ideas never updated or corrected
information about Mr. Gilmore after releasing this defamatory article.
140. All of these failures demonstrate that Wilburn and all Defendants associated with
AllenWest.com deliberately distorted the facts and their context, and departed from even
the most basic journalistic standards of accuracy for factual reporting.
141. Defendant Wilburn harbored animosity and ill will toward the so-called “deep state,” or
“one-world government cabal,” terms used to capture a perceived left-wing, organized
resistance to the Trump Administration as well as a perceived authoritarian regime pursued
53

by wealthy globalist elites. Defendant Wilburn also harbored animosity and ill will toward
George Soros. Because Wilburn identified Mr. Gilmore as being a member of the “deep
state,” and “one-world government cabal,” and identified connections between Mr.
Gilmore and Soros, Wilburn harbored ill will toward Mr. Gilmore and intended to injure
him.
142. Defendant Wilburn would not admit that the Charlottesville attack was the act of a white
supremacist. Instead, Wilburn utilized this preconceived and well-worn narrative that the
“deep state,” “one-world government cabal,” and George Soros were behind the attack.
143. Defendant Wilburn used select facts, misrepresented information about Mr. Gilmore’s
professional history, relied on the alleged, unverified and false “testimony” of an
anonymous Charlottesville police officer he found on the internet, and twisted these
elements to fit his preconceived narrative: that Charlottesville was a Soros-funded false-
flag operation, and Mr. Gilmore was a central party to that operation. By twisting and
misrepresenting information about Mr. Gilmore to fit his preconceived narrative, the
Defendants associated with AllenWest.com knowingly or recklessly disregarded that their
statements and implications were false.
144. Defendant Wilburn and the Defendants associated with AllenWest.com ran this article
despite entertaining serious doubts about the veracity of its claims. This was demonstrated,
at minimum, by Defendant Wilburn noting that the factual claims he makes are
“unverified.” Nevertheless, Wilburn disavowed the simplest (and factually accurate)
explanation: that Mr. Gilmore’s witnessing of Fields’ attack was a tragic and traumatizing
coincidence, and that Mr. Gilmore’s employment history had nothing to do with his
presence in Charlottesville at that time. By twisting true facts about Mr. Gilmore’s
54

employment history to fit a preconceived narrative and their ill will toward the “deep state”
or “one-world government cabal” and George Soros, Defendants Wilburn, West, Hickford,
and Words-N-Ideas knowingly or recklessly disregarded that Wilburn’s statements and
their implications were false.
Cumulative Effect of Defendants’ Publications
145. There can be no doubt that all Defendants collectively reached hundreds of thousands of
viewers and readers with their publications. Their paranoid fantasies have no basis
whatsoever in fact and are demonstrably false: while Mr. Gilmore was and continues to be
a State Department employee (currently on unpaid leave), was stationed in the Central
African Republic, and worked for Tom Perriello’s campaign, he has at no time been
employed by the CIA or any other intelligence agency, nor has he been employed by or
received payment from George Soros directly. He attended the protest against the “Unite
the Right” rally as a private citizen on his personal time because he opposes racism and
bigotry, not in any sort of capacity as a government employee, because he was sent there
by the State Department or George Soros, or because he was participating in any “Deep
State” “psy-op” or any sort of operation to unseat President Trump.
146. In the months leading up to the rally and counter-protest, Mr. Gilmore had been regularly
confronted with hateful right-wing memes on social media platforms that advocated using
a car as a weapon against protestors. The following meme is similar to the types of memes
Mr. Gilmore encountered:69
69
Thomas Clouse, Chelan County Deletes “All Lives Splatter” Post from Emergency Management Facebook Page,
SPOKESMAN-REVIEW (Sept. 11, 2017, 4:35 P.M.), http://www.spokesman.com/stories/2017/sep/11/chelan-county-
deletees-all-lives-splatter-post-fro/#/0.
55

147. When he noticed that a driver of a car was behaving erratically and driving rapidly towards
a group of protesters, Mr. Gilmore was worried that someone might have taken these
perverse suggestions to heart. Tragically, Mr. Gilmore’s fears proved well-founded, as Mr.
Fields—who was driving the car that drew Mr. Gilmore’s attention—killed one protestor,
Heather Heyer, and injured many others.
148. Mr. Gilmore’s concern for the safety of other protesters and his entirely reasonable sense
of civic duty to share with the world what he witnessed in Charlottesville was sufficient to
put him in Defendants’ crosshairs. The Defendants crafted their delusional narrative about
him from the barest outline of Mr. Gilmore’s resume, which he freely shares on social
media. Mr. Gilmore was an attractive target when Defendants were looking for a scapegoat
to blame both sides for the violence that occurred that day.
149. Defendants thrust Mr. Gilmore—an innocent bystander with no desire for public
attention—into the public eye by intentionally publishing baseless allegations about his
professional life and goals. As detailed above, Defendants’ intentional and reckless
disregard for the truth of their allegations about Mr. Gilmore directly and foreseeably
56

caused the harassment and threats to his personal safety that followed, as well as Mr.
Gilmore’s severe emotional distress.
D. Threats and Harassment
150. As soon as the first publications alleging that Mr. Gilmore was a “Deep State operative”
who helped orchestrate the violence in Charlottesville appeared online, Mr. Gilmore
became the subject of a barrage of harassing and threatening messages that made him fear
for his personal safety as well as the safety of his family members. There can be no doubt
that Defendants’ defamatory publications about Mr. Gilmore directly and proximately led
to this harassment. To this day, Mr. Gilmore continues to experience the effects of the
hatred and violence directed at him as a direct and foreseeable result of Defendants’
reckless decisions to publish these baseless allegations about him.
57

151. Defendant Creighton published his article and video about Mr. Gilmore in the early hours
of August 13, 2017. That very same day, anonymous users of the internet forum 8chan
shared Mr. Gilmore’s address of record:
152. The Lexington, Virginia address posted by these users is that of Mr. Gilmore’s parents,
which Mr. Gilmore used during his overseas postings with the Foreign Service. He resided
there periodically during the summer of 2017 while on vacation and in between permanent
residences.
58

153. Hours later, threatening and harassing messages on Twitter directed at Mr. Gilmore started
rolling in. Some of these messages were an explicit and direct response to Defendant
Creighton’s publication:70 Other Twitter users threatening Mr. Gilmore used language that
closely parses the language used in the article published by Defendant Hoft, who referred
to Mr. Gilmore as a “globalist shill,” thereby leaving little doubt about what incited them
to seek out Mr. Gilmore:71
70
HillaryluvsMoloch (@DARKLERCH), TWITTER (Aug. 14, 2017 07:54 AM),
https://twitter.com/DARKLERCH/status/897063978920181764, HillaryluvsMoloch (@DARKLERCH), TWITTER
(Aug. 14, 2017 08:02 AM) https://twitter.com/DARKLERCH/status/897065917485600769.
71
Puffy Biggles (@PuffyBiggles), TWITTER (Aug. 14, 2017 11:30 PM),
https://twitter.com/PuffyBiggles/status/897299446756593665; Red Pill Dispenser (@cheque197), Twitter (Aug. 15,
2017 08:02 AM), https://twitter.com/cheque197/status/897428396036292612.
59

154. In light of the threats and harassment directed at him and the publication of their home
address by posters on 8chan, Mr. Gilmore contacted his parents to ensure that they were
taking appropriate measures to protect themselves. Mr. Gilmore’s parents live within a
short drive of Charlottesville, and Mr. Gilmore was particularly concerned for their safety
given the number of neo-Nazis who had descended on the region for the “Unite the Right”
rally, with demonstrated violent tendencies. Acting on the advice of the FBI, he instructed
his parents to reach out to the local police department, which they did. Alarmed by what
they learned, local law enforcement devised a scheme to detect any unusual car traffic in
the neighborhood. In addition, Mr. Gilmore’s brother-in-law, who is an active-duty service
member, offered to spend the night with Mr. Gilmore’s parents and bring the handgun he
keeps in his home with him for protection.
155. Fearing for his own safety in addition to that of his parents, Mr. Gilmore also contacted the
FBI and the State Department’s Bureau of Diplomatic Security. Mr. Gilmore spent hours
discussing protective measures for himself and his family members with various law
enforcement agencies in the days that followed.
60

156. Egged on by the campaign of vile lies that Defendants waged against him, Twitter and
YouTube users continued to threaten and harass Mr. Gilmore, telling him he is a “George
Soros HACK” and that “word is out on [him],” they “have [his] number,” he is “going
straight to hell” and they hope that his “family feels the violence [he] protect[s]”72, and
implicitly threatening him with violence by referencing the Comet Ping Pong pizzeria
incident73:
72
Several of these users have had their accounts suspended or deleted the tweets, but see john mac (@johnmac125),
TWITTER (Aug. 15, 2017 05:25 PM), https://twitter.com/johnmac125/status/897569974121844736; Navy Brat
(@loryad123), TWITTER (Aug. 20, 2017 07:01 PM), https://twitter.com/loryad123/status/899405952654471170;
Prez Cannady (@prezcannady), TWITTER (Aug. 22, 2017),
https://twitter.com/prezcannady/status/899993600863477760; MeBituman (@MeBituman), Comment, Brennan
Gilmore with MSNBC’s Alex Witt on Charlottesville Terrorist Incident, YOUTUBE (Aug. 13, 2017),
https://www.youtube.com/watch?v=DOcoq9Dsm48.
73
See infra ¶ 165.
61

62

157. There were dozens of attempts to log-in to Mr. Gilmore’s various online accounts,
including email and social media in the days that followed publication of the conspiracy
theories.
158. Mr. Gilmore and his family were not only threatened online. On Monday, August 14,
2017, Mr. Gilmore was physically accosted on the street in Charlottesville by an unknown
person after concluding a brief television interview describing what he witnessed the day
before. The unknown person aggressively questioned Mr. Gilmore about his ties to
Perriello, Charlottesville Mayor Mike Signer, and his work overseas, all details that were
mentioned by Defendants Creighton and Hoft in their articles about Mr. Gilmore.
159. In addition, shortly after the Defendants started their defamatory campaign against him,
Mr. Gilmore received a letter at his parents’ address with a suspicious powdery residue and
a letter explaining why Mr. Gilmore would “burn in hell.” The receipt of this letter led to
an additional visit to the property by local police, and although the powdery residue turned
out to be harmless upon analysis, the letter remains in the possession of the State
Department Diplomatic Security Office.
160. The threats and harassment have continued well past August 2017. On February 14, 2018,
Twitter user “SonofNewo” retweeted a post about an upcoming performance of Mr.
Gilmore’s band, adding the caption “Will Brennan Gilmore play his tunes from the middle
of 4th Street?”74
74
SonofNewO (@SonofNewo), TWITTER (Feb. 14, 2018, 3:32 AM),
https://twitter.com/SonofNewo/status/963737755657400320. The “4th Street” reference alludes to Fourth Street in
Charlottesville, which intersects with Water Street East. Mr. Gilmore’s video of the Charlottesville attack shows
Fields speeding down Fourth Street before ramming into the crowd at the intersection with Water Street.
63

161. Two minutes later, SonofNewo posted, “I dunno, should I go check out this concert? Leave
your thoughts below!”75
162. SonofNewo’s followers encouraged him to attend, with one user, alias “O’Neil,” tweeting
“Go INCOG[nito].”76 As SonofNewo had previously posted videos on his YouTube
channel that appeared to echo Defendants’ lies about Mr. Gilmore, SonofNewo’s tweets
caused Mr. Gilmore to fear for his safety and for the safety of his band mates and concert-
goers. He contacted the concert venue and alerted them to the perceived threats, and the
venue security team in turn contacted the police.
163. After SonofNewo’s tweets and videos, Mr. Gilmore noticed an uptick in online threats and
harassment. For example, in response to a scientific article Mr. Gilmore shared in a public
Facebook post on February 19, 2018, an individual named Henry Fowler (not known to
Mr. Gilmore) left the following post threatening Mr. Gilmore’s life:
75
SonofNewo (@SonofNewo), TWITTER (Feb. 14, 2018, 3:34 AM),
https://twitter.com/SonofNewo/status/963738293392244737.
76
O’Neil (@ONeilBox), TWITTER (Feb. 14, 2018, 10:25AM),
https://twitter.com/ONeilBox/status/963841617089253378.
64

The Rivanna River is a river in Virginia that runs near Mr. Gilmore’s house. The clear
implication and tone of Fowler’s post was to threaten Mr. Gilmore and to make him fear
for his life.
65

E. The Defendants Knew or Should Have Known that the Harassment Would Ensue
164. All Defendants knew or should have known from recent, publicized experiences that their
defamatory publications about Mr. Gilmore would incite harassing and threatening
messages against him in Virginia. Defendants’ audiences routinely answer allegations of
false-flag operations with violence and anger.
165. In the fall of 2016, Defendants Jones and InfoWars amplified a false conspiracy theory
claiming that Comet Ping Pong, a pizzeria based in Washington, D.C., was involved in an
underground child sex ring run by then-presidential candidate Hillary Clinton.77 After
Defendants published these false statements, an InfoWars reader from North Carolina
drove to the pizzeria, entered the restaurant brandishing a rifle, a handgun, and a knife, and
fired his rifle inside the restaurant at least one time before pointing it at an employee. The
threats and online abuse that followed targeted not only the owner and employees of Comet
Ping Pong, but also neighboring businesses that internet users thought were implicated in
the conspiracy.78
166. After InfoWars reporter Owen Shroyer published a podcast tying East Side Pies, a chain of
pizza restaurants in Austin, Texas, to the baseless conspiracy theory, those owners were
also targeted by phone threats, harassment, and vandalism of one of its delivery trucks with
a vulgar epithet.79 The circumstances surrounding these events were widely publicized in
77
See Zack Beauchamp, Alex Jones, Pizzagate booster and America’s most famous conspiracy theorist, explained,
VOX (updated Dec. 17, 2016), https://www.vox.com/policy-and-politics/2016/10/28/13424848/alex-jones-infowars-
prisonplanet.
78
See Tom Kludt, ‘Pizzagate’: Comet Ping Pong not the only D.C. business enduring a nightmare, CNN (Dec. 5,
2016), http://money.cnn.com/2016/12/05/media/pizzagate-threatening-calls-washington-dc-businesses/index.html.
79
See Michael King, Alex Jones Apologizes!: Slander against politicians is one thing; against pizza shop owners,
another, AUSTIN CHRONICLE (Mar. 31, 2017), https://www.austinchronicle.com/news/2017-03-31/alex-jones-
apologizes.
66

national news,80 and Defendant Jones acknowledged and apologized for his role in
promoting the conspiracy theory.81
167. After the tragic December 2012 mass shooting at Sandy Hook Elementary School in
Newtown, Connecticut, Defendants Jones, InfoWars, and Creighton published false
statements claiming that the mass shooting did not actually happen and was a government-
staged “inside job” designed to bolster support for gun control measures. By publishing
and promoting these conspiracy theories, these Defendants incited harassment and threats
by their followers toward the family members of the shooting victims. As a result, a woman
was criminally sentenced for transmitting death threats through interstate communications
toward the father of a 6-year-old child who was murdered in the shooting.82
168. In 2014, a self-proclaimed Sandy Hook “truther” was sentenced for harassing the sister of
a teacher who was killed while hiding her first-grade students in a classroom closet during
the massacre. 83 This harassment and subsequent convictions have been detailed in multiple
national publications.
80
Faiz Siddiqui & Susan Svrluga, N.C Man Told Police He Went to D.C. Pizzeria with Gun to Investigate
Conspiracy Theory, WASH. POST (Dec. 6, 2016), https://www.washingtonpost.com/news/local/wp/2016/12/04/d-c-
police-respond-to-report-of-a-man-with-a-gun-at-comet-ping-pong-restaurant/?utm_term=.b85e5fe4acca; John
Woodrow Cox, ‘We’re Going to Put a Bullet in Your Head’: #PizzaGate Threats Terrorize D.C. Shop Owners,
WASH. POST (Dec. 6, 2016), https://www.washingtonpost.com/local/were-going-to-put-a-bullet-in-your-head-
pizzagate-threats-terrorize-dc-shop-owners/2016/12/05/39469a82-bb2e-11e6-94ac-
3d324840106c_story.html?utm_term=.f81cc533b356; Louisiana Man Pleads Guilty to Threatening Pizzeria, NBC
WASH. (Jan 13, 2017), https://www.nbcwashington.com/news/local/Louisiana-Man-Pleads-Guilty-to-Threatening-
DC-Pizzeria-410617335.html; Matthew Odam, How Austin’s East Side Pies became target of fake #pizzagate, MY
STATESMAN (Dec. 7, 2016), http://www.mystatesman.com/news/crime--law/how-austin-east-side-pies-became-
target-fake-pizzagate/jQJtrr2xVIMNmpWc0IOW5O/.
81
Eli Rosenberg, Alex Jones Apologizes for Promoting Pizzagate Hoax, N.Y. TIMES (Mar. 25, 2017),
https://www.nytimes.com/2017/03/25/business/alex-jones-pizzagate-apology-comet-ping-pong.html.
82
Derek Hawkins, Sandy Hook Hoaxer Gets Prison Time for Threatening 6-year-old Victim’s Father, WASH. POST
(June 8, 2017), https://www.washingtonpost.com/news/morning-mix/wp/2017/06/08/sandy-hook-hoaxer-gets-
prison-time-for-threatening-6-year-old-victims-father/?utm_term=.1da4bac11915.
83
Daniel Tepfer, Sandy Hook ‘Truther’ Gets Suspended Sentence, CT POST (Apr. 18, 2016),
http://www.ctpost.com/policereports/article/Sandy-Hook-truther-gets-suspended-sentence-7255482.php.
67

169. More recently, Defendants Jones and InfoWars published false claims about the 2017 mass
shooting in Las Vegas that left fifty-nine people dead and hundreds more injured.
Referring to the racist hoax concerning the former president’s birth certificate that he has
helped propagate, Defendant Jones claimed that “Vegas is as phony as a three-dollar bill
or as Obama’s birth certificate.”84 Soon thereafter, survivors of the massacre became
victims of a predictable wave of online threats and harassment. One survivor of a bullet
wound to the head received messages such as “[y]ou are a lying piece of shit and I hope
someone truly shoots you in the head.” Still another survivor was told, “[y]our soul is
disgusting and dark! You will pay for the consequences!”85
170. Further still, following the August 2017 mass shooting at a church Sutherland Springs,
Texas that left twenty-seven people dead, Defendant Jones shared with his followers his
theory that the tragedy was “part of the Antifa revolution against Christians and
conservatives or a Isis op [sic],” and published these false claims on InfoWars.86 Defendant
Creighton also made a series of false claims about the mass shooting, implying that the
United States government used the shooter, Devin Patrick Kelley, as a “patsy” to bolster
support for gun control.87
171. These and other conspiracy theories surrounding the Sutherland Springs attack recently led
the church’s pastor, whose 14-year-old daughter was killed in the shooting, to become the
84
Alex Jones: The Las Vegas Shooting Was as Phony as Obama’s Birth Certificate, MEDIA MATTERS (Nov. 27,
2017), https://www.mediamatters.org/video/2017/11/27/alex-jones-las-vegas-shooting-was-phony-obama-s-birth-
certificate/218648.
85
See Sam Levin, “I Hope Someone Truly Shoots You”: Online Conspiracy Theorists Harass Vegas Victims,
GUARDIAN (Oct. 26, 2017), https://www.theguardian.com/us-news/2017/oct/26/las-vegas-shooting-conspiracy-
theories-social-media.
86
Alex Jones (@RealAlexJones), TWITTER (Nov. 5 2017 03:14 PM),
https://twitter.com/search?q=Was%20this%20part%20of%20the%20Antifa%20revolution%20against%20Christians
%20and%20conservatives%20or%20a%20Isis%20op%3F&src=typd.
87
Scott Creighton, Sutherland Springs Shooting: What We Know So Far, AMERICAN EVERYMAN (Nov. 6, 2017),
https://americaneveryman.com/2017/11/06/sutherland-springs-shooting-what-we-know-so-far/.
68

target of gruesome threats of violence. On March 5, 2018, two individuals showed up to
the church and “continually yelled and screamed and hollered and told [him] he was gonna
hang [him] from a tree, and pee on [him] while [he is] hanging.”88
172. Around April 2017, Defendants Jones and InfoWars made a series of false statements
against Chobani, LLC (“Chobani”). In a video post featuring Defendant McAdoo, among
others, these defendants claimed that the yogurt company’s practice of hiring migrant
workers and refugees brought “migrant rapists” and disease to the areas surrounding its
Idaho factory.89 Defendant Stranahan similarly authored an article for Breitbart News
alleging that Chobani was responsible for local crimes committed by Muslim refugees.90
These false statements harmed both employees and other members of the Idaho community
associated with Chobani. Ultimately, Defendant Jones apologized for and retracted his
inflammatory comments. The circumstances surrounding these events were widely
publicized on national news.91
173. As recently as this month, Defendants Jones, InfoWars, and Hoft have promoted conspiracy
theories about the February 14, 2018 shooting at Marjory Stoneman Douglas High School
in Parkland, Florida, which claimed the lives of 17 students and educators. These
88
Jessica Chasmar, Conspiracy Theorists Arrested Outside Site of 2017 Sutherland Springs Church Shooting,
WASH. TIMES (Mar. 6, 2018), https://www.washingtontimes.com/news/2018/mar/6/conspiracy-theorists-claiming-
sutherland-springs-s/.
89
See John Kell, Chobani Is Suing Infowars Radio Host Alex Jones, FORTUNE (Apr. 24, 2017)
http://fortune.com/2017/04/24/chobani-sues-alex-jones.
90
Lee Stranahan, Turkish Chobani Owner Has Deep Ties to Clinton Global Initiative Campaign, BREITBART (Aug.
25, 2016), http://www.breitbart.com/big-government/2016/08/25/turkish-chobani-owner-has-deep-ties-to-clinton-
global-initiative-and-campaign/.
91
Christine Hauser, Chobani Sues Alex Jones Over Sexual Assault Report, N.Y. TIMES (Apr. 25, 2017),
https://www.nytimes.com/2017/04/25/business/chobani-alex-jones.html; David Montero, Alex Jones Settles
Chobani Lawsuit and Retracts Comments about Refugees in Twin Falls, Idaho, L.A. TIMES (May 17, 2017),
http://www.latimes.com/nation/la-na-chobani-alex-jones-20170517-story.html.
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defendants have endeavored to discredit student survivors who have, in the wake of the
massacre, advocated for action by legislators and politicians to curb gun violence.92
174. Defendants Jones and InfoWars promote violence against their political enemies. On
March 30, 2017, Defendant Jones posted an online clip in which he called a Democratic
congressman a “son of a bitch” and a “goddamn fucker” among other pejoratives and
threatened to “beat” the congressman’s “goddamn ass.” He spent the summer of 2017
regularly telling followers of InfoWars and his radio show that the political left was on the
verge of starting a civil war, and has encouraged violence against “leftists” and Democrats
in response. In a June 23, 2017 broadcast, less than two months before the Charlottesville
rally and attack, Defendant Jones told his followers that “we have to start getting ready for
insurrection and civil war because they’re really pushing it.”93
175. A regular listener or reader of InfoWars would clearly understand that when Alex Jones
identifies an individual such as Mr. Gilmore as linked to George Soros and central to the
orchestration of the Charlottesville attack, that individual should be the object of scorn,
harassment, and even violence. Indeed, this is what Mr. Jones intends to communicate to
his audience.
176. Similarly, Defendant Hoft has an extensive history of inciting harassment by spreading
misinformation through his website Gateway Pundit. To take but one example: on or
around January 11, 2017, Gateway Pundit falsely claimed that an editor for the Washington
92
See, e.g., Dan Lyman, Student Anti-Gun Activist Featured in CBS News Story – Six Months Ago, INFOWARS (Feb.
19, 2018), https://www.infowars.com/student-anti-gun-activist-featured-in-cbs-la-news-story-six-months-ago/; Jim
Hoft (@gatewaypundit), Twitter (Feb. 19, 2018, 2:53 PM),
https://twitter.com/gatewaypundit/status/965720917883146248?ref_src=twsrc%5Etfw&ref_url=https%3A%2F%2F
www.newsmax.com%2Fus%2Fchelsea-clinton-jim-hoft-florida-
shooting%2F2018%2F02%2F20%2Fid%2F844409%2F.
93
Nina Burleigh, Alex Jones and Other Conservatives Call for Civil War Against Liberals, NEWSWEEK (July 21,
2017), http://www.newsweek.com/trump-alex-jones-infowars-violence-639912.
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Post was secretly taking photos of Secretary of State Rex Tillerson’s notes during his
confirmation hearing. The editor has been subjected to intense online harassment as a
result of this publication. She has since chronicled her experiences in an online article for
the paper.94
177. In light of the aforementioned highly publicized events, all Defendants knew or should
have known that their defamatory statements about Mr. Gilmore would incite their reading
and viewing audiences to direct further harm toward Mr. Gilmore in Virginia. The
harassment, threats and intimidation that ensued were entirely foreseeable and caused by
Defendants’ lies about Mr. Gilmore.
F. Defendants’ Defamatory Publications Harmed Mr. Gilmore Personally and

Professionally
178. Before Defendants’ attacks, Mr. Gilmore earned the reputation of being a patriotic and
honorable citizen who had dedicated over 15 years of service to the United States.
However, the publication of false and defamatory information about Mr. Gilmore by
Defendants has caused irreparable damage to this reputation and threatened his physical
and emotional well-being. In short, these lies have deprived him of his livelihood and life’s
passion. Moreover, Defendants’ actions have punished Mr. Gilmore for participating in
one of the essential cornerstones of our democracy: civic engagement.
i. Defendants’ Defamatory Publications Have Threatened Physical Harm to Mr.

Gilmore
179. Fanning the flames of false conspiracies about child sex trafficking at Comet Ping Pong,
“hoaxes” and “crisis actors” in the Sandy Hook, Las Vegas, and Sutherland Springs
94
Doris Truong, Trolls Decided I Was Taking Pictures of Rex Tillerson’s Notes. I Wasn’t Even There, WASH. POST
(Jan. 12, 2017), https://www.washingtonpost.com/posteverything/wp/2017/01/12/trolls-decided-i-was-taking-
pictures-of-rex-tillersons-notes-i-wasnt-even-there/?utm_term=.374baccdf675.
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shootings, and “migrant rapists” working for Chobani all translated to real-world harm.
Likewise, it was foreseeable that publishing lies about Mr. Gilmore would threaten bodily
harm to him and his family. By good fortune and swift precaution to alert the police and
authorities of potential threats against him, Mr. Gilmore was able to avoid actual physical
harm. But it was not for lack of trying: the unknown chemical substance mailed to his home
and the sudden approach of a hostile stranger on the street foreshadow the connection to
some of the deeper threats lurking online, many of which materialize into physical
danger.95 As evidenced by the death threat he received in February, Mr. Gilmore continues
to receive threats of physical harm because of the lies that Defendants spread about him.
This causes Mr. Gilmore to live in constant fear for bodily harm or even death.
ii. Defendants’ Defamatory Publications Have Caused Emotional Harm to Mr.

Gilmore
180. Mr. Gilmore lives in fear for his life because of Defendants’ reckless publications. He has
experienced severe emotional distress as a result of Defendants’ deliberate campaign to
falsely portray him as a “CIA asset” and a “Deep State shill” (among other similar
characterizations) engaged in a criminal conspiracy against the United States. Since these
articles were first published, Mr. Gilmore has had to rely on the assistance of a therapist to
address the substantial emotional stress of coping with the stress caused by Defendants’
false and defamatory statements and the resulting reputational harm, as well as the death
threats and harassment arising out of Defendants’ actions. Mr. Gilmore lives in constant,
ongoing fear of vile online and in-person harassment of himself and his family.
181. As a result of this ongoing distress, Mr. Gilmore has also been diagnosed with Central
95
Adi Robertson, The FBI has Released Its Gamergate Investigation Records, THE VERGE (Jan. 27, 2017),
https://www.theverge.com/2017/1/27/14412594/fbi-gamergate-harassment-threat-investigation-records-release
(detailing threats against those targeted in the Gamergate controversy, including multiple shooting threats).
72

Serous Chorioretinopathy. Central Serous Chorioretinopathy is a disease in which a serous
detachment of the neurosensory retina occurs over an area of leakage from the
choriocapillaris through the retinal pigment epithelium. This disease causes the loss of
vision in Mr. Gilmore’s right eye.
182. Mr. Gilmore suffers from this severe condition as a direct result of the stress he endures
due to Defendants’ false and defamatory publications, their ongoing press offensive against
him, and the threats and harassment those publications have inspired. This physical
condition makes it difficult and sometimes impossible for him to work and conduct
regular, daily activities.
183. Mr. Gilmore also suffers from depression, exacerbated by the stress he’s experienced due
to Defendants’ false and defamatory publications, their ongoing press offensive against
him, as well as from the threats and harassment caused by Defendants’ defamatory
statements. His depressive symptoms, including irritability, difficulty concentrating, and
loss of sleep, have significantly impaired his ability to perform work responsibilities and
attend social events.
184. The presence and content of Defendants’ widely-available articles and videos have not only
jeopardized Mr. Gilmore’s physical and mental health, they have undermined his sense of
safety and well-being. Following Defendants’ publications and their audience’s
foreseeable reaction, Mr. Gilmore keeps alert of those around him when he goes out and
constantly monitors additional threats as they are directed at him or members of his family.
Mr. Gilmore now limits his social engagements or going out in public, as he fears engaging
with people who he does not already know and trust, and engages less on social media.
185. Defendants’ frequent and incendiary publications about Mr. Gilmore have even polluted a
73

simple Google search for his name. As a result, Mr. Gilmore risks losing potential friends
or romantic interests if an acquaintance finds any one of Defendants’ defamatory articles.
At least one potential romantic partner cut off contact with Mr. Gilmore because of
Defendants’ statements.
186. Mr. Gilmore continues to live with the burden of knowing Defendants’ false portrayal of
him masquerades online as truth, and those who come upon it may prejudge him based on
Defendants’ lies. The unpredictability of additional online threats and harassment, threats
of physical harm, the stress and anxiety caused by Mr. Gilmore’s concerns for his family
and the threats and harassment they experienced, and publication of additional false and
defamatory content by Defendants continues to this day, all of which exacerbate and
perpetuate the distress Mr. Gilmore experiences.
iii. Defendants’ Claims Have Done Mr. Gilmore Irreparable Professional Harm
187. As an entrepreneur, Mr. Gilmore must rely on maintaining a spotless reputation of
credibility and integrity to achieve his professional aims. In his current role as a business
consultant for Wize Solutions, a small business venture focused on rural workforce
development, Mr. Gilmore will not be able to continue in his current leadership capacity if
he cannot count on the reputation he has worked so hard to develop. The ready presence
of false information that paints him in such a negative light results in severe skepticism
among those interested in working with the company. Mr. Gilmore has been consistently
questioned by professional contacts about the derogatory information published on
Defendants’ websites, and other potential clients and partners have decided not to pursue
business relationships with Wize after reviewing said information. Thus, Mr. Gilmore may
need to remove himself altogether from the company’s client-facing work out of a duty not
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to harm the fledgling business.
188. Although Mr. Gilmore has dedicated his career to the service of the United States’
diplomatic missions abroad, his illustrious diplomatic career is irreparably damaged
because of Defendants’ reckless acts. When Mr. Gilmore returns to the State Department,
it will be exceedingly difficult for him to serve as a diplomat to another nation, as foreign
officials will certainly research his background and find the shocking and threatening
information published by Defendants, including allegations that he is not actually a
diplomat but a covert CIA agent.
189. Moreover, several high-profile Trump Administration officials and members of Congress
have expressed their sincere belief in the conspiracy theories promoted by Defendants and
suggested that the government needs to be purged of so-called “Deep State” actors.96 At
the heart of Defendants’ lies about Mr. Gilmore is the allegation that he is exactly the type
of “Deep State” actor that should be purged from government. If Mr. Gilmore is able to
return to the State Department, it is likely that government officials who have endorsed
Defendants’ lies will work to harm Mr. Gilmore’s career or oust him from government
service entirely.
190. In the days immediately following the “Unite the Right” rally, dozens of people publicly
called for Attorney General Sessions, President Trump, and Fox News Host Sean Hannity
to open an investigation into Mr. Gilmore’s alleged role in the attack.
191. U.S. Representative Louis Gohmert called for a Department of Justice investigation into
Virginia Governor Terry McAuliffe, Charlottesville Mayor Michael Signer, and rally
organizer Jason Kessler for their alleged roles in the violent clashes that took place at the
96
See infra ¶ 193.
75

rally.97
192. Republican Congressman Paul Gosar recently told Vice News that he believes that George
Soros—who Defendants claim paid Mr. Gilmore to attend the rally—was the behind-the-
scenes organizer of the “Unite the Right” rally.98
193. In December 2017, Republican Congressman Francis Rooney called for a purge of FBI
and Justice Department agents whom he believed were working for the “Deep State.”99
194. In early February of this year, President Trump authorized the release of the so-called
“Nunes Memo,” published by the Republicans on the House Intelligence Committee
alleging that the FBI abused its power in surveilling Donald Trump’s 2016 presidential
campaign.100
195. Conspiracy theorists, including Defendant Jones, have capitalized on this memo to bolster
their theory that there is a “Deep State” conspiracy to undermine President Trump and his
administration.101
196. Former Republican Congressman Jason Chaffetz also believes in the “Deep State,” and
claimed on national television that he “lived through it.”102
97
Alex Swoyer, Texas Lawmaker Calls for DOJ Investigation of Charlottesville Violence, WASH. TIMES (Aug. 20,
2017), https://www.washingtontimes.com/news/2017/aug/20/louie-gohmert-texas-republican-calls-for-doj-inves/.
98
See Elspeth Reeve, Congressman Suggests Charlottesville was George Soros-backed Conspiracy, VICE NEWS
(Oct. 5, 2017), https://news.vice.com/story/paul-glosar-charlottesville-soros.
99
Natasha Bertrand, ‘These People’ are ‘the Deep State’: GOP Congressman Calls for ‘Purge’ of the FBI, BUS.
INSIDER (Dec. 26, 2017, 2:50 PM), http://www.businessinsider.com/francis-rooney-calls-for-fbi-purge-2017-12.
100
Read the Disputed Memo Here, CNN (Feb. 3, 2018, 8:40 AM), https://www.cnn.com/2018/02/02/politics/fbi-
nunes-memo-full/index.html.
101
Adan Salazer, Deep State Death Spiral: Dems in Denial over Damning FISA Memo, INFOWARS (Feb. 2, 2018),
https://www.infowars.com/deep-state-death-spiral-dems-in-denial-over-damning-fisa-memo/; Kit Daniels, Memo
Destroys Fake News Claim Trump Never Spied On, INFOWARS (Feb. 2, 2018), https://www.infowars.com/memo-
discredits-media-who-trashed-trump-over-wiretap-allegations/; Julian Sanchez, How the Nunes Memo Harms
Intelligence Oversight, ATLANTIC (Feb. 6, 2018), https://www.theatlantic.com/politics/archive/2018/02/nunes-
memo-impact/552368/.
102
Joe Concha, Former GOP Rep Jason Chaffetz on Fox: The Deep State ‘is Very Real’, THE HILL (Jan. 3, 2018,
11:58 AM), http://thehill.com/homenews/media/367223-former-gop-rep-jason-chaffetz-on-fox-the-deep-state-is-
very-real.
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197. Indeed, public servants who have been labeled “Deep State” actors have already been
forced out of long careers in government service.103
198. President Trump has expressed his belief in conspiracy theories pushed by InfoWars on
several occasions,104 and allegedly called Jones to thank him for helping him win the 2016
U.S. presidential election.105 Defendant Jones claims to have spoken to President Trump
at least three times in recent months.106 Furthermore, InfoWars was granted temporary
press credentials by the White House last year.107
199. As recently as January of 2018, President Trump has tweeted about his beliefs regarding
the “Deep State”108 and related conspiracy theories about Democratic Party leaders:
Crooked Hillary Clinton’s top aid [sic], Huma Abedin, has been accused of
disregarding basic security protocols. She put Classified Passwords into the
hands of foreign agents. Remember sailors [sic] pictures on submarine?
Jail! Deep State Justice Dept must finally act? Also on Comey & others[.]109
103
Julia Ainsley and Adam Edelman, FBI Director Andrew McCabe Stepping Down, NBC NEWS (Jan. 29, 2018,
2:13 PM), https://www.nbcnews.com/politics/politics-news/fbi-deputy-director-andrew-mccabe-stepping-down-
n842176.
104
William Finnegan, Donald Trump and the “Amazing” Alex Jones, NEW YORKER (Jun. 23, 2016),
https://www.newyorker.com/news/daily-comment/donald-trump-and-the-amazing-alex-jones; Eric Hananoki, A
Guide to Donald Trump’s Relationship with Alex Jones, MEDIA MATTERS (May 3, 2017, 2:37 PM),
https://www.mediamatters.org/research/2017/05/03/guide-donald-trump-s-relationship-alex-jones/21626.
105
See, e.g., Shane Goldmacher, Alex Jones Says Trump Called to Thank Him, POLITICO (Nov. 14, 2016),
https://www.politico.com/story/2016/11/trump-thanked-alex-jones-231329.
106
Adam Raymond, Alex Jones: Trump Has Called Me 3 Times in the Last Few Months, N.Y. MAGAZINE (Jan. 24,
2018, 3:16 PM), http://nymag.com/daily/intelligencer/2018/01/alex-jones-trump-has-called-three-times-in-recent-
months.html.
107
Maxwell Tani, Conspiracy Outlet InfoWars Was Granted Temporary White House Press Credentials, BUS.
INSIDER (May 22, 2017, 3:00 PM), http://www.businessinsider.com/infowars-granted-white-house-press-credentials-
2017-5.
108
Chris Cillizza, Donald Trump’s Assault on Law Enforcement Just Keeps Coming, CNN (Jan. 23, 2018, 2:09 PM),
https://www.cnn.com/2018/01/23/politics/trump-fbi-analysis/index.html; Stephen Collinson and Jeremy Diamond,
Trump Again at War with ‘Deep State’ Justice Department, CNN (Jan. 2, 2018, 3:30 PM),
https://www.cnn.com/2018/01/02/politics/president-donald-trump-deep-state/index.html.
109
Donald J. Trump (@realDonaldTrump), TWITTER (Jan. 2, 2018, 4:48 AM),
https://twitter.com/realDonaldTrump/status/948174033882927104.
77

200. The President’s sons, Donald Trump, Jr. and Eric Trump, have also expressed animosity
toward the so-called “Deep State.”110 On July 7, 2017, Donald Trump, Jr. tweeted: “If there
was ever confirmation that the Deep State is real, illegal, & endangers national security,
it’s this. Their interests above all else[.]”
201. On January 2, 2018, Eric Trump tweeted, “Shocking . . . once again, here are the @Twitter
“suggestions” of who I should follow. #DeepState.”
202. The clear support for Defendants’ conspiracy theories among members of the highest levels
of government, including the President of the United States, leaves no doubt that Mr.
110
Tina Nguyen, Don Jr.: The Deep-State Shadow Conspiracy is Out to Get My Dad, VANITY FAIR (Dec. 20, 2017,
3:01 PM), https://www.vanityfair.com/news/2017/12/donald-trump-jr-deep-state-conspiracy.
78

Gilmore’s career prospects have been seriously injured by the defamatory falsehoods about
him that Defendants published.
203. Mr. Gilmore will not be able to continue engaging in diplomatic relationships on behalf of
the United States when his loyalty to his country has been so profoundly questioned by the
wealth of public information propagated and promoted by Defendants, emboldened by the
support for their theories and validation of their outlets by the current Presidential
Administration.
V. CAUSES OF ACTION
COUNT I: DEFAMATION
(Against All Defendants)
204. Mr. Gilmore re-alleges and incorporates the factual allegations in foregoing paragraphs 1-
203 into Count I as if fully set forth herein.
205. Defendants’ statements described above (collectively, the “defamatory statements”) are
false and defamatory.
206. Collectively, Defendants published to millions of viewers of Twitter, YouTube, and other
platforms directed at and received by Virginia audiences, false statements as discussed
throughout this Complaint. Defendants’ defamatory statements were subsequently and
virally shared and republished on a wide range of websites.
207. Defendants’ false and defamatory statements were intended as assertions of fact and/or are
defamatory by implication, as the Defendants, through the plain and natural meaning of
their statements (and all inferences, implications, and insinuations fairly attributable to
them), intended for their readers and listeners to accept as fact their defamatory assertions
against Mr. Gilmore.
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208. Defendants deliberately imply factual assertions about Mr. Gilmore by pointing out
biographical facts about him (e.g. that he works for the State Department) alongside facts
related to their theories that the Charlottesville attack was staged by the “Deep State” or
George Soros. By alleging these facts in close proximity to one another and against the
backdrop of Defendants’ previously published conspiracy theories about the “Deep State,”
George Soros, and/or “psy-ops,” Defendants deliberately intended for any gaps in factual
assertions made about Mr. Gilmore to be easily filled in by the audience and understood to
be allegations of fact. Indeed, the inferences are so obvious, the dots so easy to connect,
that the only reasonable interpretation of Defendants’ publications is that they are
defamatory assertions of fact.
209. As detailed above, Defendants’ false and defamatory statements concerned Mr. Gilmore
and had him as their primary subject. The Defendants’ defamatory statements were
designed to (1) injure Mr. Gilmore’s reputation, (2) subject Mr. Gilmore to contempt and
disgrace, and (3) incite harassment of and threats directed at Mr. Gilmore.
210. As detailed above, Defendants acted with actual malice. Their false and defamatory
statements about Mr. Gilmore’s background and role in the Charlottesville protest and
attack were made with knowledge of their falsehood or reckless disregard for their truth or
falsity.
211. As detailed above, Defendants failed to investigate the facts they alleged about Mr.
Gilmore in their various publications and severely departed from journalistic standards
despite presenting their publications and videos as fact-based journalism. Defendants
harbored ill will toward Mr. Gilmore.
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212. Moreover, each of Defendants’ previous publications are evidence that they conceived a
storyline in advance of any adequate investigation and then consciously set out to insert
Mr. Gilmore into their preconceived narratives as discussed throughout the Complaint.
213. Together, these facts and circumstances make clear that Defendants subjectively
entertained serious doubts about the truth of their statements about Mr. Gilmore, were
willfully blind to any facts that might have undermined their preconceived narrative, and
deliberately published false facts and stories about Mr. Gilmore.
214. Defendants’ statements are also defamatory per se because they falsely impute to Mr.
Gilmore the commission of a criminal offense involving moral turpitude— broadly, in this
instance, that Mr. Gilmore, as part of some “Deep State” conspiracy, participated in the
orchestration of James Alex Fields, Jr.’s car attack in Charlottesville on August 12, 2017,
which killed one person and injured many others. If true, these allegations would cause Mr.
Gilmore to be indicted and punished. Defendants’ statements also prejudice Mr. Gilmore
in his profession as a Foreign Service Officer at the State Department: by asserting that
Mr. Gilmore planned, orchestrated, or knowingly participated in some sort of operation to
incite violence in Charlottesville, Defendants undermine Mr. Gilmore’s ability to conduct
diplomatic work abroad.
215. Defendants’ false and defamatory statements harmed and continue to harm Mr. Gilmore
both personally and professionally. Defendants are individually liable to Mr. Gilmore for
the personal and professional harm they caused by defaming Mr. Gilmore, each in an
amount greater than $75,000 to be determined at trial.
81

COUNTS II-IV: DEFAMATION FOR STATEMENTS PUBLISHED IN AUGUST
13, 2017 ARTICLE ENTITLED “CHARLOTTESVILLE ATTACK, BRENNAN
GILMORE AND...THE STOP KONY 2012 PYSOP? WHAT?” (EXHIBITS A-C)
(Against Defendant Creighton)
216. Plaintiff re-alleges and incorporates the foregoing factual allegations in paragraphs 1 – 61,
145-203 to Counts II, III, and IV as if fully set forth herein.
217. Defendant Creighton published false and defamatory statements concerning Mr. Gilmore
and had him as their primary subject.
218. Defendant Creighton’s false and defamatory statements were intended as assertions of fact,
and impart what a reasonable reader would believe is factual. Indeed, his website’s
description reads, “Neoliberal News of the Day.”111 As detailed elsewhere in this
Complaint, Defendant Creighton’s audience did believe that his statements were factual.
219. Defendant Creighton republished the same or substantially similar false and defamatory
statements in at least two other forums, “Before It’s News” and “Signs of the Times,”112
on August 13, and therefore Counts III and IV reincorporate and re-allege the same facts
as Count II for each additional publication.
220. Defendant Creighton’s false and defamatory statements were designed to injure Mr.
Gilmore’s reputation, subject Mr. Gilmore to contempt and disgrace, and incite harassment
and threats directed at Mr. Gilmore; indeed, Defendant Creighton’s statements had their
intended effect.
111
American Everyman, https://americaneveryman.com/ (last visited Apr. 24, 2018).
112
See, e.g., Scott Creighton, Charlottesville Attack, Brennan Gilmore and… the Stop Kony 2012 PYSOP? What?,
SIGNS OF THE TIMES (Aug. 13, 2017), https://www.sott.net/article/359361-Charlottesville-Brennan-Gilmore-and-the-
STOP-KONY-2012-Psyop; Scott Creighton, Charlottesville Attack, Brennan Gilmore and… the Stop Kony 2012
PYSOP? What?, BEFORE IT’S NEWS (Aug. 13, 2017), http://beforeitsnews.com/opinion-
liberal/2017/08/charlottesville-attack-brennan-gilmore-and-the-stop-kony-2012-pysop-what-2558822.html.
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221. By publishing such statements, Defendant Creighton did cause harm to Mr. Gilmore, as
detailed in the paragraphs above.
222. Defendant Creighton acted with actual malice. His false and defamatory statements about
Mr. Gilmore’s background and role in the Charlottesville protest and attack were made
with knowledge of their falsehood or reckless disregard for their truth or falsity. As detailed
elsewhere in this Complaint, Defendant Creighton’s failure to investigate, departure from
journalistic standards, ill will toward alleged “psy-ops,” and preconceived storyline about
the violence in Charlottesville in which he inserted Mr. Gilmore all make clear that he
subjectively entertained serious doubts about the truth of his statements, was willfully blind
to any facts that might have undermined his preconceived narrative, and deliberately
published a false story.
223. Defendant Creighton’s statements are also defamatory per se because they falsely impute
to Mr. Gilmore the commission of a criminal offense involving moral turpitude—in this
instance that Mr. Gilmore planned or participated in James Alex Fields, Jr.’s car attack in
Charlottesville on August 12, 2017, which killed one person and injured many others.
Further, Defendant Creighton falsely suggests that Mr. Gilmore is part of a larger plot to
commit treason against the United States by attempting to destabilize and/or delegitimize
the federal government. If true, these allegations would cause Mr. Gilmore to be indicted
and punished. Defendant Creighton’s statements also prejudice Mr. Gilmore in his
profession as a Foreign Service Officer at the U.S. State Department: by asserting that Mr.
Gilmore planned, orchestrated, or knowingly participated in a secret government “psy-op”
in Charlottesville, Defendant Creighton undermines Mr. Gilmore’s ability to conduct
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224. As a direct and proximate result of Defendant Creighton’s false statements, Mr. Gilmore
has suffered presumed damages as well as actual reputational, emotional, and professional
injuries. Defendant Creighton is liable for the harm he caused by defaming Mr. Gilmore in
an amount greater than $75,000 to be determined at trial.
COUNT V: DEFAMATION FOR STATEMENTS PUBLISHED IN AUGUST 13,

2017 VIDEO ENTITLED “CHARLOTTESVILLE ATTACK - BRENNAN
GILMORE: WITNESS OR ACCESSORY” (EXHIBIT D)
(Against Defendant Creighton)
145-203 to Count V as if fully set forth herein.
226. Defendant Creighton published false and defamatory statements concerning Mr. Gilmore
that had him as their primary subject.
227. Defendant Creighton’s false and defamatory statements were intended as assertions of fact,
and impart what a reasonable reader would believe to be factual. As detailed elsewhere in
this Complaint, Defendant Creighton’s audience did indeed believe that his statements
were factual.
228. Defendant Creighton’s false and defamatory statements were designed to injure Mr.
Gilmore’s reputation, subject Mr. Gilmore to contempt and disgrace, and incite harassment
and threats directed at Mr. Gilmore; indeed, Defendant Creighton’s statements had their
intended effect.
229. By publishing such false and defamatory statements, Defendant Creighton did cause harm
to Mr. Gilmore.
230. Defendant Creighton acted with actual malice. His false and defamatory statements about
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elsewhere in this Complaint, Defendant Creighton’s failure to investigate, departure from
journalistic standards, ill will toward alleged “psy-ops” and preconceived storyline about
the violence in Charlottesville into which he inserted Mr. Gilmore all make clear that he
was reckless with respect to the truth of his statements, he subjectively entertained serious
doubts about the truth of his statements, he was willfully blind to any facts that might have
undermined his preconceived narrative, and he deliberately published a false story.
231. Defendant Creighton’s statements are also defamatory per se because they falsely impute
to Mr. Gilmore the commission of some criminal offense involving moral turpitude—in
this instance, that Mr. Gilmore planned or participated in James Alex Fields, Jr.’s car attack
in Charlottesville on August 12, 2017, which killed one person and injured many others.
Further, Defendant Creighton falsely suggests that Mr. Gilmore is part of a larger plot to
commit treason against the United States by attempting to destabilize and/or delegitimize
the federal government. If true, these allegations would cause Mr. Gilmore to be indicted
and punished. Defendant Creighton’s statements also prejudice Mr. Gilmore in his
profession as a Foreign Service Officer at the State Department: by asserting that Mr.
Gilmore planned, orchestrated, or knowingly participated in a secret government “psy-op”
in Charlottesville, Defendant Creighton undermines Mr. Gilmore’s ability to conduct
232. As a direct and proximate result of Defendant Creighton’s false and defamatory statements,
Mr. Gilmore has suffered presumed damages as well as actual reputational, emotional, and
professional injuries, and is liable for the harm he caused by defaming Mr. Gilmore in an
amount greater than $75,000 to be determined at trial.
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COUNT VI: DEFAMATION FOR STATEMENTS PUBLISHED IN AUGUST 14,
2017 ARTICLE ENTITLED “RANDOM MAN AT PROTESTS INTERVIEWED
BY MSNBC, NY TIMES IS DEEP STATE SHILL LINKED TO GEORGE SOROS”
(EXHIBIT E)
(Against Defendant Jim Hoft)
62-82, 145-203 to Count VI as if fully set forth herein.
234. Defendant Hoft published false and defamatory statements concerning Mr. Gilmore that
had him as their primary subject.
235. Defendant Hoft’s false and defamatory statements were intended as assertions of fact, and
impart what a reasonable reader would believe is factual. As detailed elsewhere in the
complaint, Defendant Hoft’s readers did in fact believe his statements to be factual.
236. Defendant Hoft’s statements were designed to injure Mr. Gilmore’s reputation, subject Mr.
Gilmore to contempt and disgrace, and incite harassment and threats directed at Mr.
Gilmore; indeed, Defendant Hoft’s statements had their intended effect.
237. By publishing such false and defamatory statements, Defendant Hoft did cause harm to
Mr. Gilmore.
238. Defendant Hoft acted with actual malice. His false and defamatory statements about Mr.
Gilmore’s background and role in the Charlottesville protest and attack were made with
knowledge of their falsehood or reckless disregard for their truth or falsity. As detailed
elsewhere in this Complaint, Defendant Hoft’s failure to investigate, departure from
journalistic standards, ill will toward the “Deep State,” and preconceived storyline about
the violence in Charlottesville into which he inserted Mr. Gilmore all make clear that he
was reckless with respect to the truth of his statements, subjectively entertained serious
86

doubts about the truth of his statements, was willfully blind to any facts that might have
undermined his preconceived narrative, and deliberately published a false story.
239. Defendant Hoft’s statements are also defamatory per se because they falsely impute to Mr.
Gilmore the commission of some criminal offense involving moral turpitude—in this
instance, that Mr. Gilmore, as part of some “Deep-State” conspiracy, planned or
participated in James Alex Fields, Jr.’s car attack in Charlottesville on August 12, 2017,
Gilmore to be indicted and punished. Defendant Hoft’s statements also prejudice Mr.
Gilmore in his profession as a Foreign Service Officer at the United States State
Department: by asserting that Mr. Gilmore planned, orchestrated, or knowingly
participated in a secret government operation to incite violence in Charlottesville,
Defendant Hoft undermines Mr. Gilmore’s ability to conduct diplomatic work abroad.
240. As a direct and proximate result of Defendant Hoft’s false statements, Mr. Gilmore has
suffered presumed damages as well as actual reputational, emotional, and professional
injuries, and is liable for the harm he caused by defaming Mr. Gilmore in an amount greater
than $75,000 to be determined at trial.
COUNT VII: DEFAMATION FOR STATEMENTS PUBLISHED IN AUGUST 15,

2017 ARTICLE AND VIDEO “BOMBSHELL CONNECTION BETWEEN
CHARLOTTESVILLE, SOROS, CIA” (EXHIBIT F)
(Against Defendants Alex Jones; InfoWars, LLC; Free Speech Systems, LLC; Lee
Stranahan; and Lee Ann McAdoo)
83-100, 145-203 to Count VII as if fully set forth herein.
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242. Defendants Stranahan and McAdoo’s false and defamatory statements, which were
published by Defendants Jones, InfoWars, and/or Free Speech Systems, concerned Mr.
Gilmore and had him as their primary subject.
243. Defendants Jones, InfoWars, Free Speech Systems, Stranahan, and McAdoo’s false and
defamatory statements were intended as assertions of fact, and impart what a reasonable
reader would believe to be factual. And, as detailed elsewhere in this Complaint,
Defendants’ audiences did indeed believe that Defendants’ statements were factual.
244. Defendants Jones, InfoWars, Free Speech Systems, Stranahan, and McAdoo’s statements
were designed to injure Mr. Gilmore’s reputation, subject Mr. Gilmore to contempt and
disgrace, and incite harassment and threats directed at Mr. Gilmore; indeed, Defendants
Jones, InfoWars, Free Speech Systems, Stranahan, and McAdoo’s statements had their
intended effect.
245. By publishing such false and defamatory statements, Defendants Jones, InfoWars, Free
Speech Systems, Stranahan, and McAdoo did cause harm to Mr. Gilmore.
246. Defendants Jones, InfoWars, Free Speech Systems, Stranahan, and McAdoo acted with
actual malice. Their defamatory statements about Mr. Gilmore’s background and role in
the Charlottesville protest and attack were made with knowledge of their falsehood or
reckless disregard for their truth or falsity.
247. As detailed elsewhere in this Complaint, Defendants Jones, InfoWars, Free Speech
Systems, Stranahan, and McAdoo’s failure to investigate, departure from journalistic
standards, ill will toward the “Deep State,” and preconceived storyline about the violence
in Charlottesville into which they inserted Mr. Gilmore all make clear that they were
reckless with respect to the truth of their statements, subjectively entertained serious doubts
88

about the truth of their statements, were willfully blind to any facts that might have
undermined their preconceived narrative, and deliberately published a false story.
are also defamatory per se because they impute to Mr. Gilmore the commission of some
criminal offense involving moral turpitude—in this instance, that Mr. Gilmore planned or
participated in James Alex Fields, Jr.’s car attack in Charlottesville on August 12, 2017,
which killed one person and injured many others, as part of a conspiracy to stage a “coup”
and overthrow a sitting president. If true, these allegations would cause Mr. Gilmore to be
indicted and punished.113
also prejudice Mr. Gilmore in his profession as a Foreign Service Officer at the United
States State Department. By falsely asserting that Mr. Gilmore planned, orchestrated, or
knowingly participated in a secret conspiracy to bring about a coup that would undermine
the Trump Administration, Defendants Jones, InfoWars, Free Speech Systems undermine
Mr. Gilmore’s ability to work at the State Department (an agency of the Executive Branch,
of which President Trump is the Chief Executive) or conduct diplomatic work abroad.
250. At the time the false and defamatory statements were made, Defendant McAdoo was an
employee and/or agent of Defendants Jones, Infowars, and/or Free Speech Systems.
251. Defendant McAdoo was acting within the scope of her employment and/or agency as a
reporter for Defendants Jones, Infowars, and/or Free Speech Systems when she authored
the article, “Bombshell Connection Between Charlottesville, Soros, CIA” and appeared in
the accompanying video by the same name.
113
See 18 U.S.C. § 361.
89

252. Defendants Jones, Infowars, and/or Free Speech Systems participated in, produced, and
ratified Defendant McAdoo’s conduct.
253. At the time the defamatory statements were made, Defendant Stranahan was an employee
and/or agent of Defendants Jones, Infowars, and/or Free Speech Systems.
254. Defendant Stranahan was acting within the scope of his employment and/or agency for
Defendants Jones, Infowars, and/or Free Speech Systems when he made defamatory
statements about Mr. Gilmore that appeared in the article, “Bombshell Connection Between
Charlottesville, Soros, CIA” and the accompanying video by the same name.
255. Defendants Jones, Infowars, and/or Free Speech Systems participated in, produced, and
ratified Defendant Stranahan’s conduct.
256. Defendants Jones, Infowars, and/or Free Speech Systems are legally responsible for the
acts of their employees, agents, or servants, pursuant to the doctrine of respondeat superior.
257. As a direct and proximate result of Defendants Jones, InfoWars, Free Speech Systems,
Stranahan, and McAdoo’s false statements, Mr. Gilmore has suffered presumed damages
as well as actual reputational, emotional, and professional injuries, and Defendants Jones,
InfoWars, Free Speech Systems, Stranahan, and McAdoo are jointly and severally liable to
Mr. Gilmore in an amount greater than $75,000 to be determined at trial.
COUNT VIII: DEFAMATION FOR STATEMENTS PUBLISHED IN VIDEO

ENTITLED “BREAKING: STATE DEPARTMENT/CIA ORCHESTRATED
CHARLOTTESVILLE TRAGEDY” (EXHIBIT G)
(Against Defendants Alex Jones; InfoWars, LLC; and Free Speech Systems, LLC)
83-124, 145-203 to Count VIII as if fully set forth herein.
259. Defendants Jones, InfoWars, and Free Speech Systems’ published false and defamatory
statements concerning Mr. Gilmore and had him as their primary subject.
90

260. Defendants Jones, InfoWars, Free Speech Systems’ statements were intended as assertions
of fact, and impart what a reasonable reader would believe is factual. As detailed elsewhere
in this Complaint, Defendants’ audiences did indeed believe that Defendants’ statements
were factual.
261. Defendants Jones, InfoWars, and Free Speech Systems’ false statements were designed to
injure Mr. Gilmore’s reputation, subject Mr. Gilmore to contempt and disgrace, and incite
harassment and threats directed at Mr. Gilmore; indeed, Defendants Jones, InfoWars and
Free Speech Systems’ statements had their intended effect.
262. By publishing such false and defamatory statements, Defendants Jones, InfoWars, and Free
Speech Systems did cause harm to Mr. Gilmore.
263. Defendants Jones, InfoWars, and Free Speech Systems acted with actual malice. Their
false and defamatory statements about Mr. Gilmore’s background and role in the
Charlottesville protest and attack were made with knowledge of their falsehood or reckless
disregard for their truth or falsity. As detailed elsewhere in this Complaint, Defendants
Jones, InfoWars, and Free Speech Systems’ failure to investigate, departure from
journalistic standards, ill will toward the “Deep State,” and preconceived storyline about
the violence in Charlottesville into which they inserted Mr. Gilmore all make clear that
they were reckless with respect to the truth of their statements, subjectively entertained
serious doubts about the truth of their statements, were willfully blind to any facts that
might have undermined their preconceived narrative, and deliberately published a false
story.
264. Defendants Jones, InfoWars, and Free Speech Systems’ statements are also defamatory per
se because they falsely impute to Mr. Gilmore the commission of a criminal offense
91

involving moral turpitude—in this instance that Mr. Gilmore, as a CIA operative, planned
or participated in James Alex Fields, Jr.’s car attack in Charlottesville on August 12, 2017,
Gilmore to be indicted and punished. Defendants Jones, InfoWars, and Free Speech
Systems’ false and defamatory statements also prejudice Mr. Gilmore in his profession as
a Foreign Service Officer at the United States State Department. By asserting that Mr.
Gilmore is a CIA operative who planned, orchestrated, or knowingly participated in a secret
“Deep State” or government operation to carry out a terrorist attack in Charlottesville,
Defendants Jones, InfoWars, and Free Speech Systems undermine Mr. Gilmore’s ability to
conduct diplomatic work both at home and abroad.
265. At the time the defamatory statements were made, Defendant Jones was an employee
and/or agent of Defendants Infowars, and/or Free Speech Systems.
266. Defendant Jones was acting within the scope of his employment and/or agency for
Defendants Infowars, and/or Free Speech Systems when he made defamatory statements
about Mr. Gilmore that appeared in the video, “Breaking: State Department/CIA
Orchestrated Charlottesville Tragedy.”
267. Defendants Infowars, and/or Free Speech Systems participated in, produced, and ratified
Defendant Jones’s conduct.
268. Defendants Infowars, and/or Free Speech Systems are legally responsible for the acts of
their employees, agents, or servants, pursuant to the doctrine of respondeat superior.
269. As a direct and proximate result of Defendants Jones, InfoWars, and Free Speech Systems’
false and defamatory statements, Mr. Gilmore has suffered presumed damages as well as
actual reputational, emotional, and professional injuries, and Defendants Jones, InfoWars,
92

and Free Speech Systems are jointly and severally liable for the harm he caused by
defaming Mr. Gilmore in an amount greater than $75,000 to be determined at trial.
COUNT IX: DEFAMATION FOR STATEMENTS PUBLISHED IN AUGUST 19,

2017 ARTICLE ENTITLED “BOMBSHELL: NEW EVIDENCE SUGGESTS
CHARLOTTESVILLE WAS A COMPLETE SET-UP” (EXHIBIT H)
(Against Defendants Allen B. West, Derrick Wilburn, Michele Hickford, and Words-
N-Ideas, LLC)
125-203 to Count IX as if fully set forth herein.
271. Defendants Wilburn, West, Hickford, and Words-N-Ideas published false and defamatory
statements on Defendant West’s website on August 19, 2017 concerning Mr. Gilmore that
had him as their primary subject.
272. Defendants’ statements were intended as assertions of fact and impart what a reasonable
reader would believe is factual. Indeed, and as detailed elsewhere in the Complaint,
Defendants’ readers did believe Defendants’ statements to be factual.
273. Defendants’ false and defamatory statements were designed to injure Mr. Gilmore’s
reputation, subject Mr. Gilmore to contempt and disgrace, and incite harassment and threats
directed at Mr. Gilmore; indeed, Defendants’ statements had their intended effect.
274. By publishing such false and defamatory statements, Defendants did cause harm to Mr.
Gilmore.
275. Defendants acted with actual malice. Defendants’ false and defamatory statements about
elsewhere in this Complaint, Defendants’ failure to investigate, departure from journalistic
standards, ill will toward the “Deep State,” and preconceived storyline about the violence
93

in Charlottesville into which they inserted Mr. Gilmore all make clear that they were
reckless with respect to the truth of Defendant Wilburn’s statements, subjectively
entertained serious doubts about the truth of their statements, were willfully blind to any
facts that might have undermined his preconceived narrative, and deliberately published a
false story.
276. Defendants’ statements are also defamatory per se because they falsely impute to Mr.
Gilmore the commission of some criminal offense involving moral turpitude—in this
instance, that Mr. Gilmore, as part of some “Deep State” conspiracy, participated in or
planned James Alex Fields, Jr.’s car attack in Charlottesville on August 12, 2017, which
killed one person and injured many others. If true, these allegations would cause Mr.
Gilmore to be indicted and punished.
277. Defendants’ statements are also defamatory per se because they prejudice Mr. Gilmore in
his profession as a Foreign Service Officer at the State Department: by falsely asserting
that Mr. Gilmore planned, orchestrated, or knowingly participated in a secret “Deep State”
conspiracy in Charlottesville, Defendants West, Wilburn, Hickford, and Words-N-Ideas
undermine Mr. Gilmore’s ability to conduct diplomatic work at home and abroad.
278. At the time the false and defamatory statements were made, Defendant Wilburn was an
employee and/or agent of Defendants West, Hickford, and/or Words-N-Ideas.
279. Defendant Wilburn was acting within the scope of his employment and/or agency for
Defendants West, Hickford, and/or Words-N-Ideas when he made defamatory statements
about Mr. Gilmore that appeared in the article, “Bombshell: New Evidence Suggests
Charlottesville Was a Complete Set-Up.”
94

280. Defendants West, Hickford, and/or Words-N-Ideas participated in, produced, and ratified
Defendant Wilburn’s conduct.
281. Defendants West, Hickford, and/or Words-N-Ideas are legally responsible for the acts of
their employees, agents, or servants, pursuant to the doctrine of respondeat superior.
282. As a direct and proximate result of Defendants Wilburn, West, Hickford, and Words-N-
Ideas’ false and defamatory statements, Mr. Gilmore has suffered presumed damages as
well as actual reputational, emotional, and professional injuries, and are jointly and
severally liable for the harm he caused by defaming Mr. Gilmore in an amount greater than
$75,000 to be determined at trial.
COUNT X: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

(Against All Defendants)
283. Mr. Gilmore re-alleges and incorporates the foregoing factual allegations in paragraphs 1
– 203 into Count X as if fully set forth herein.
284. Defendants’ conduct is outrageous and beyond all reasonable bounds of decency, where,
without engaging in the bare minimum of journalistic factual inquiry and verification,
Defendants published to their audiences content portraying Mr. Gilmore as a criminal
accessory to murder, violence, and treason.
285. Defendants’ statements falsely and maliciously assert that Mr. Gilmore is a criminal.
Considering all publicly available information about Mr. Gilmore and all information
resulting from Defendants’ investigation of Mr. Gilmore, of which there is none,
Defendants have no basis for so asserting.
286. Defendants knew or should have known that reading their publications and the reputational
harm that resulted from them would cause Mr. Gilmore severe emotional distress.
95

287. Based on their audiences’ foreseeable reactions, detailed elsewhere in this complaint,
Defendants knew or should have known that their publications about Mr. Gilmore would
cause him to be the subject of harassment and threats and thereby cause severe emotional
distress.
288. Defendants’ decisions to publish baseless false allegations as fact, while reasonably
foreseeing that their actions would cause severe emotional distress, is outrageous and
intolerable.
289. Mr. Gilmore has experienced serious and severe emotional distress as a direct and
proximate result of Defendants’ actions. Defendants’ publication of baseless false
allegations have caused Mr. Gilmore extensive personal suffering in the wake of the slew
of threats and harassment that has been directed at him; depression, anxiety, sleeplessness,
inability to concentrate, irritability. It has also caused irreparable damage to his
professional reputation as a diplomat in the State Department and his ability to conduct
business in his current employment, including loss of income.
290. Mr. Gilmore lives in a state of constant fear and anxiety after reading Defendants’ false
and defamatory statements about him all over the Internet and due to the death threats that
Defendants’ armies of followers have launched at him after taking Defendants’ defamatory
statements as assertions of fact. This high level of stress has manifested itself both
physically and psychologically.
291. Mr. Gilmore has developed a medical condition called Central Serous Chorioretinopathy,
which causes loss of vision in Mr. Gilmore’s right eye. This visual impairment seriously
impedes his ability to conduct business, let alone carry out day-to-day activities.
96

292. Mr. Gilmore also suffers from depression, the symptoms of which have been exacerbated
by the consistently high levels of stress caused the reputational harm caused by Defendants’
false and defamatory statements, as well as by the threats and harassment directed at Mr.
Gilmore, and have impaired his ability to conduct both work and social activities.
293. Defendants are each individually liable to Mr. Gilmore for the emotional distress they
caused in an amount greater than $75,000 to be determined at trial.
VI. PRAYER FOR RELIEF
WHEREFORE, plaintiff Brennan Gilmore prays that this Court enter judgment in his favor
and against all Defendants, and respectfully that this Court grant the following relief:
A. An award of presumed and actual damages to compensate Mr. Gilmore for his
reputational, emotional, and professional injuries, in an amount to be determined at
trial;
B. An award of damages to compensate Mr. Gilmore for his emotional distress, in an
amount to be determined at trial;
C. An award of punitive damages, in an amount to be determined at trial;
D. An award of reasonable attorneys’ fees and costs to the fullest extent permitted by law;
and
E. Such other and further relief as the Court deems just.
Dated: April 24, 2018.
/s/ Andrew Mendrala

Andrew Mendrala, Esq., Virginia Bar No. 82424
Aderson Francois, admitted pro hac vice
CIVIL RIGHTS CLINIC
Georgetown University Law Center
600 New Jersey Avenue, NW
97

Washington, DC 20001
Phone: (202) 662-9065
Email: Andrew.Mendrala@georgetown.edu
Attorney for Plaintiff
98

CERTIFICATE OF SERVICE
I hereby certify that on April 24, 2018, I electronically filed the foregoing with the Clerk
of the Court for the Western District of Virginia via the CM/ECF system. Participants registered
for electronic filing will automatically receive notification of this filing.
I further certify that I mailed via First-Class Mail, postage prepaid, a copy of the
foregoing to the following parties who are not registered for electronic service via the CM/ECF
system:
Scott Creighton, a/k/a/ Raymond Scott Creighton

9214 13th Street N, Apt. A,
Tampa, FL 33612
Allen B. West
9925 Wood Forest Drive
Dallas, TX 75243
Derrick Wilburn
1820 Smoke Ridge Drive
Colorado Springs, CO 08919-3458
Michele Hickford
848 SE 4th Court
Deerfield Beach, FL 33441
Words-N-Ideas, LLC
848 SE 4th Court
Deerfield Beach, FL 33441
s/ Andrew Mendrala
99

EXHIBIT A
Case 3:18-cv-00017-GEC Document 29-1 Filed 04/24/18 Page 1 of 20 Pageid#: 505

3/1/2018 Charlottesville Attack, Brennan Gilmore and… the STOP KONY 2012 Pysop? What? | American Everyman
American Everyman
Charlottesville Attack, Brennan Gilmore and… the STOP KONY 2012

Pysop? What?
Posted on August 13, 2017 by willyloman

by Sco Creighton
UPDATE: Moon of Alabama blog makes some valid comparisons between this event and those that took place in Kiev during our color
revolution (h p://www.moonofalabama.org/2017/08/charlo esville-what-you-wish-upon-others-you-wish-upon-yourself.html)
(of course, those were REAL Nazis throwing fire bombs at the police as opposed to FAKE NAZIS, probably police provocateurs, whom the police didn’t
bother with and were given a stand-down order to stay out of the way till some good violence unfolded)
Go back and look at the video Brennan Gilmore posted of the Charlo esville a ack. Go back and look at it. Something very odd and
OBVIOUS is staring us in the face and all we have to do is step back and take a breath and see what’s right there for us to see.
The numbers from the Charlo esville a ack are in and one individual is dead with another 30 or so injured. Two more deaths are
a ributed to the event in an effort to make it bleed more so to speak, but they were killed when their helicopter crashed. I’m not sure how
they link that to the protests, but, there you go.
I will do some research on the suspect and publish it a li le later but right now I wanted to share with you some things I found out about
Brennan Gilmore, the former State Department employee who just HAPPENED to be at the exact right place at the exact right time already
filming with his camera to capture the entire event from beginning to end.

https://willyloman.wordpress.com/2017/08/13/charlottesville-attack-brennan-gilmore-and-the-stop-kony-2012-pysop-what/ 1/19
And he just HAPPENED to have the pre-approved establishment message canned and ready to go for a CNN interview on the scene.
Funny, his video hadn’t gone viral yet and CNN was already interviewing him? What a coincidence there, huh? Notice he says the
counter-protesters were “peaceful”. I guess that means Soros’ ANTIFA provocateurs had been told to avoid that particular march. Also
notice he equates “alt-right” with “terrorists” and “racists” with ease.
Minor Leaguer
@Minor_Leaguer
Excellent answer, Brennan Gilmore.

3:45 PM - Aug 12, 2017
1,518 838 people are talking about this

Brennan Gilmore’s video is viral now. It’s been hijacked by more YouTubers than you can imagine. It really was perfect. Not only did he
HAPPEN to be at the right place at the right time, but he was ALREADY recording with his camera and it was focused on that car, for
SOME REASON as it drove by the corner at a reasonable rate. Why he would focus on that vehicle right then and there BEFORE IT DID
ANYTHING is a mystery to me. It was traveling down the street at about 25 miles and hour which is not out of place for that road.
Certainly it may be for the situation, but remember, the march was not planned and or sanctioned, so the street was not blocked off, and in
fact, there were two more cars in front of the Dodge Charger that were stuck in the middle of the protest on that same street. Those are the
ones hit from behind by the Charger. But Brennan wasn’t filming them was he? No. But he did film the Charger heading all the way down
the street into the crowd of protesters… almost as if he knew it would run into them rather than simply brake and sit and wait like the
other cars in front of it.
Brennan Gilmore
@brennanmgilmore
Video of car hitting anti-racist protestors. Let there be no

confusion: this was deliberate terrorism. My prayers with
victims. Stay home.
1:13 PM - Aug 12, 2017
100K 91.9K people are talking about this
Again, not a smoking gun in and of itself, but when combined with all the other coincidences surrounding his video PLUS the fact that he
was ready to go with the divide and conquer establishment version of events for CNN while people were still lying on the hot pavement, it
kind of makes you wonder doesn’t it?
PLUS… Brennan says it is “definitely terrorism”… no doubt about it. HAS to be “terrorism”, right?
Let me take a second to explain something to you. Terrorism is an act of violence or the THREAT of violence designed to prompt a change
in a country in terms of it’s economic, political or social structure.
How is ramming a car into a crowd of protesters you don’t like to be considered an effort by that ONE PERSON to bring about a change in
this country’s social structure? Are we to assume the driver thought that running over a few counter protesters would make the rest of the
country step back and say “yeah, the Robert E. Lee statue is history, not racism” and let it stand?
A terrorist blows up an airport because he wants to DISRUPT commerce and travel. A terrorist runs a campaign like GLADIO because he
wants to prevent a nation from slipping too far to the left. A racist might run over “goddamned hippies” because he HATES THEM. But
that’s NOT terrorism.
However… if the event, the mass casualty event, was PLANNED to destabilize the nation, to DIVIDE the “alt-left’ and the “alt-right”…
then THAT IS TERRORISM.
Moving on…
“The violence and hatred in our society is out of control. We like to think that it’s be er than places like Africa and Asia, but it’s not,”
said Mr. Gilmore, who worked in Africa as a U.S. State Department foreign service officer before leaving to manage the campaign of
Tom Perriello for Virginia governor earlier this year. “I’m worried.” New York Times
(h ps://www.nytimes.com/2017/08/12/us/charlo esville-protest-white-nationalist.html)
Given Brennan’s rather suspicious positioning before the fact and his former employer (a State Department that is wholly disgusted with
BOTH Trump and Tillerson for firing a number of 7th floor entrenched State Department career “soft power” activists) I thought I would
look him up and see if I could find some more background on who is really is and what he did for them.
This is what I found:
Brennan M. Gilmore | Embassy of the United States Bangui, CAR

(http://bangui.usembassy.gov/about-us/deputy-chief/deputy-chief-of-mission.html)
bangui.usembassy.gov/about-us/deputy-chief/deputy-chief-of-mission.html
Prior to this, Mr. Gilmore served as the Special Assistant for Lord’s Resistance Army (LRA) Issues in the Bureau of African Affairs,
coordinating the development …
The link is dead. They scrubbed it from the interwebs. But as you can probably imagine, when I saw he was linked somehow to the whole
“STOP KONY 2012” psyop, I was amazed.
Then I found some more (not an easy thing to do mind you):
State/OIG recently posted its inspection report of the US Embassy in Bangui, a 15% danger pay post, as well as a 35% COLA and 35%
hardship differential pay assignment (h p://aoprals.state.gov/Web920/location_action.asp?MenuHide=1&CountryCode=1182). The
inspection took place in Washington, DC, between September 10 and 28, 2012, and in Bangui, the Central African Republic, between
November 5 and 12, 2012.
The diplomatic mission is headed by Ambassador Laurence D. Wohlers (h ps://diplopundit.net/2010/07/05/officially-in-laurence-d-

wohlers-to-bangui/), a career diplomat. The deputy chief of mission (DCM) is Brennan M. Gilmore. The embassy temporarily
suspended operations on December 28, 2012, as a result of the security situation in the country…
The Ambassador arrived in September 2010 and the deputy chief of mission (DCM) in July 2011. They constitute a team that is
particularly strong in outreach and reporting and have successfully weathered a series of management challenges. They are not as
successful when it comes to leadership and morale.
The DCM has broad executive responsibilities. He supervises the reporting agenda assigned to the first-tour
political/economic/consular officer. The officer meets weekly with the DCM and usually the Ambassador as well. The DCM is
responsible primarily for military affairs, which include the U.S. Special Forces deployment to the eastern Central African
Republic and a rotational U.S. Africa Command liaison officer position. Diplopundit archive on Brennan Gilmore
(h ps://diplopundit.net/tag/brennan-m-gilmore/)
The STOP KONY 2012 psyop was all about using the Joseph Kony boogieman to justify le ing Barack Obama send Special Operations
troops into Africa to run around and squash any and all resistance to our new imperialism campaign. It was a fraud. A show. And
Brennan was part of it.
He was also part of the campaign of Tom Perriello’s in Virginia to become the next governor. Perriello also has ties to the new African
imperialism campaign that was waged under the watchful eyes of our first black president. Tom lost the primary two months ago in spite
of the fact that he was backed by every establishment unDemocratic Party leader and even that Khan guy who
(h ps://twi er.com/brennanmgilmore/status/874425567977844737)was rolled out by Hillary Clinton to paint Trump as a racist way back
when.

In July 2015, President Obama appointed Tom Perriello to succeed former US Senator Russell Feingold as Special Envoy to the
Great Lakes Region and the Democratic Republic of Congo. As Special Envoy, Perriello was the US representative to a region
including Democratic Republic of Congo, Burundi, and Rwanda, countries working to overcome a recent legacy of civil war and
genocide.
In December 2016, Perriello indicated that he would run for Governor of Virginia (h ps://en.wikipedia.org/wiki/Governor_of_Virginia)
in the 2017 election (h ps://en.wikipedia.org/wiki/Virginia_gubernatorial_election,_2017) on a platform centered around economic
justice as well as resistance to the Trump Administration (h ps://en.wikipedia.org/wiki/Presidency_of_Donald_Trump).[51]
(h ps://en.wikipedia.org/wiki/Tom_Perriello#cite_note-51)
Perriello is currently CEO of Win Virginia a PAC dedicated to helping Democrats win back the Virginia House of Delegates in
2017.
And there’s one more thing about the man Brennan Gilmore tried to make the next governor of Virginia… he’s a centrist neoliberal linked
to the CIA’s USAID
(h ps://en.wikipedia.org/wiki/Tom_Perriello#Special_Envoy_to_the_Great_Lakes_Region_and_the_Democratic_Republic_of_Congo).

During the 2009 legislative session, Perriello voted for the American Recovery and Reinvestment Act
(h ps://en.wikipedia.org/wiki/American_Recovery_and_Reinvestment_Act_of_2009),[31]
(h ps://en.wikipedia.org/wiki/Tom_Perriello#cite_note-rc46-31) (he voted for TARP) the American Clean Energy and Security Act
(h ps://en.wikipedia.org/wiki/American_Clean_Energy_and_Security_Act),[32]
(h ps://en.wikipedia.org/wiki/Tom_Perriello#cite_note-rc477-32) and the Patient Protection and Affordable Care Act
(h ps://en.wikipedia.org/wiki/Patient_Protection_and_Affordable_Care_Act) in March 2010.[33]

(h ps://en.wikipedia.org/wiki/Tom_Perriello#cite_note-33) During debate over the health care bill in the House, he voted for the
Stupak–Pi s Amendment (h ps://en.wikipedia.org/wiki/Stupak%E2%80%93Pi s_Amendment) to the Affordable Health Care for
America Act (h ps://en.wikipedia.org/wiki/Affordable_Health_Care_for_America_Act), which would have prohibited the use of
federal funds to cover any part of the costs of any health plan that includes coverage of abortion (and he voted for fascist ObamaCare
but didn’t want abortion to be paid for under it)…
Tom Perriello was selected by Secretary of State John Kerry to lead the 2015 Quadrennial Diplomacy & Development Review, a
strategic planning process intended to be conducted every four years for the U.S. Department of State
(h ps://en.wikipedia.org/wiki/U.S._Department_of_State) and the U.S. Agency for International Development
(h ps://en.wikipedia.org/wiki/U.S._Agency_for_International_Development) (USAID)…
He has worked as a consultant to the International Center for Transitional Justice

(h ps://en.wikipedia.org/wiki/International_Center_for_Transitional_Justice) in Kosovo (h ps://en.wikipedia.org/wiki/Kosovo) (2003),
Darfur (h ps://en.wikipedia.org/wiki/Darfur) (2005), and Afghanistan (h ps://en.wikipedia.org/wiki/Afghanistan) (2007) where he
worked on justice-based security strategies.[13] (h ps://en.wikipedia.org/wiki/Tom_Perriello#cite_note-c-ville-13) Perriello has also
been a fellow at The Century Foundation (h ps://en.wikipedia.org/wiki/The_Century_Foundation)
Ah, so Tom worked mopping up resistance in places like Kosovo, Darfur and Afghanistan before becoming such a stalwart “progressive”
huh?
And what’s that about The Century Foundation? Who are they you ask?
The Century Foundation is a progressive think tank (h ps://en.wikipedia.org/wiki/Think_tank) headquartered in New York City
(h ps://en.wikipedia.org/wiki/New_York_City) with an office in Washington, D.C (h ps://en.wikipedia.org/wiki/Washington,_D.C).[1]
(h ps://en.wikipedia.org/wiki/The_Century_Foundation#cite_note-1) It was founded as a nonprofit
(h ps://en.wikipedia.org/wiki/501%28c%29%283%29) public policy research institution on the belief that the prosperity and security of
the United States depends on a mix of effective government, open democracy, and free markets

Ah, the Global Free Market Wars, a.k.a. the Global War on Terrorism a.k.a. Overseas Contingency Operations. And Tom, and apparently
our “convenient witness” Brennan Gilmore, were all over it.
Gilmore has spent a lot of time Tweeting since the event unfolded yesterday. As expected, he is quick to label it terrorism and cast blame
on the “alt-right” which he equates with Nazism (h ps://twi er.com/brennanmgilmore/status/896464509262548992).
It’s important to put into context Brennan Gilmore’s time in CAR when they were fighting “KONY”
They weren’t fighting KONY. He was there in support of the brutal military dictatorship of General François Bozizé
(h ps://en.wikipedia.org/wiki/Fran%C3%A7ois_Boziz%C3%A9) who took over in coup from the elected president of the country, Ange-
Félix Patassé (h ps://en.wikipedia.org/wiki/Ange-F%C3%A9lix_Patass%C3%A9)
Our puppet dictator Bozize was trying to hold onto power in the face of a 2012 uprising from Séléka CPSK-CPJP-UFDR
(h ps://en.wikipedia.org/wiki/S%C3%A9l%C3%A9ka_CPSK-CPJP-UFDR) not “KONY”. But of course, that would have been a harder sell
to the fans of President Peace Prize so “KONY” the boogieman. In the end, Special Operations and all the propaganda we could muster
did li le to stem the tide of CHANGE in CAR and the start of 2013 saw folks like Brennan Gilmore and Bozize flee the country.
Gilmore has said on multiple occasions since the event yesterday that you would think hatred and violence is more widespread in “African
nations” than it is right here in the states, but “you would be wrong” which is quite an amazing statement coming from a man who
resided in a country that routinely killed opposition leaders and who was forced to FLEE THE COUNTRY when the people finally took it
back from us.
All this being said, is it possible this man with links to Special Ops and CIA and various other black ops kinds of actors just HAPPENED to
be there at that particular moment in history?
Yeah, I guess that’s possible, if you’re into coincidence theories I suppose.
But I’m not into such things.
Clearly the State Department has a lot of disgruntled former employees who would delight in destabilizing Trump’s tenure even more
than they already have. And Gilmore, like Tom, seem particularly invested in undermining the “alt-right” in the lead-up to the next round
of elections.
Waaaaaay too much coincidence for me folks. Waaaaaay too much.
Filed under: Charlo esville a ack, Kony 2012, Neoliberalizing Africa, Sco Creighton |
« Charlo esville A ack: A Strategy of Tension (AE video) Charlo esville A ack: Brennan Gilmore – Witness or Accessory? (AE video) »

50 Responses
Anon.X, on August 13, 2017 at 7:44 am said:

Good sleuthing.
Reply
willyloman, on August 13, 2017 at 8:16 am said:

thanks
Reply
adambaumsocal, on August 13, 2017 at 8:16 am said:

It was a Trump opponent driving the car…h p://ukrainecrisisanamericandisaster.blogspot.com/2017/08/charlo esville-murderer-
identified.html
Reply
Suspicious Interview / Charlo esville A ack, Brennan Gilmore – Adam's Dream Studio & News, on August 13, 2017 at 8:18 am said:
[…] via Charlo esville A ack, Brennan Gilmore and… the STOP KONY 2012 Pysop? What? — American Everyman […]
Reply
deinvestiture, on August 13, 2017 at 8:34 am said:

Excellent. Superior work. Thank you
Reply

thank you
Reply
Choppers, on August 13, 2017 at 8:46 am said:

He’s not State, he’s CIA. And he’s not disgruntled, he’s still on the job, as a illegal domestic NOC. If you meet the scumbag sometime,
ask him about all the airdrops that Kony’s harem lived on. But anyway, good catch.
Reply

thank you.
Reply
mercury7, on August 13, 2017 at 8:49 am said:

re the car crash: the really strange part wasn’t that gilmore’s camera followed the car, it was that he chose to pan away from the car
after it crashed into a crowd of people.
also, i couldn’t help but think of recent terror events in europe where a vehicle was used as a weapon. i guess we’re supposed to equate
the threat from trump/alt-right as being as dire as the threat of radical islam?
Reply

i don’t think that car was supposed to come back up the street. they couldn’t foresee cars stopped in the middle of the crowd and
the driver couldn’t see them stopped there due to all the people walking in front of them. When he hit the car, he hit it hard enough
to launch it into the one in front of it, then the driver paniced and hit reverse. I think, if the videographer was part of the operation,
he was as shocked to see the car coming back up the street as the driver was and probably didn’t want to risk recording the driver’s
face had the window been busted.
Reply
mercury7, on August 13, 2017 at 9:32 am said:

the vid cuts away from the car almost as soon as it crashes into the crowd, which i thought was weird; i know if i captured
something like that on camera, i’d keep the camera on the car & probably try to get a closer pic of the car, rather than turn the
camera around to film a handful of people away from the crash.
Reply
Jan10, on August 13, 2017 at 9:14 am said:

Strange that the police helicopter crashed before they had a chance to
shoot at the car as it was backing up the street.
Reply
Norman Pilon, on August 13, 2017 at 9:44 am said:

Fascinating. Excellent work, Sco , as usual.
Reply

thanks
Reply
Anthony Clifton, on August 13, 2017 at 9:55 am said:

them thar Al Quida boys will do almost any sneaky OP to
get the GOYIM to blame the {{{{JEWS}}}
sneaky & cunning is what they are
can I get an AMEN…?
H/T – TEL AVIV SCRIPTWRITERS
Reply
cheyennesage, on August 13, 2017 at 1:42 pm said:

No think tank claiming to believe in a “free market” can call itself progressive. The ‘free’ market doesn’t exist; further, the consequence
of unfe ered trade is a huge outflux of cash from this country and a lot less money flowing into the economy, since it’s offshored or in
some fatcats’ bank accounts. Neoliberalism is just Reaganism hiding in sheep’s clothes.

Reply
Charlo esville false flag hoax?! | Veterans Today, on August 13, 2017 at 6:34 pm said:
[…] Charlo esville A ack, Brennan Gilmore and… the STOP KONY 2012 Pysop? What? […]
Reply
Anonymous, on August 13, 2017 at 9:23 pm said:

All the White Nationalist rally organizers are CIA also, including Richard Spencer and David Duke.
C.I.A. Connections of White Nationalist Leaders and Alternative Media Figures

h ps://imgur.com/a/oiB5I
Reply
willyloman, on August 13, 2017 at 10:02 pm said:

I wouldn’t doubt that for a second
Reply
Digital Empire, on August 14, 2017 at 7:48 am said:

Reblogged this on Digital Empire.
Reply
badbikemechanicx, on August 14, 2017 at 11:42 am said:

Before you guys go crazy making connections. We are talking about Charlo seville, VA. Langley is just a couple of hours away. The
feds love recruiting from UVA. As a person that lives in Northern Virginia it’s not surprising in the least to see a former agent taking
this video. He makes no secret about it in his politico article- infact he makes some interesting comparisons to situation dealt with in
Africa. If anything we owe him a great deal for his ability to stay calm and articulate during a hostile situation. We are are all be er
informed because of it.
Reply
Steph, on August 14, 2017 at 12:29 pm said:

B.B.M. CIA troll pops up to defend fellow agent?

This CIA orchestrated Exercise, now going on Tour.
The ranks of Police/Internment Camp Interns,
the Badges StandDown…Shows that Rulers preparing a JadeHelm
For Real. Civil disturbance Provoked. Martial Law Rule.
It’s all so obvious, It Screams Out!
Reply
Z, on August 14, 2017 at 1:02 pm said:

Did you see that someone is driving the wrecked vehicle through the streets of Charlo esville ?……dragging the bumper and with a
crashed wind shield ???
You would think that the cops would have put it on a flat bed tow truck to examine it for fingerprints and other evidence in a vehicular
homicide investigation.
Something very strange going on here.
h ps://www.aol.com/article/news/2017/08/14/charlo esville-suspect-james-alex-fields-jr-denied-bail-in-first-court-
appearance/23077134/
Reply
Joseph, on August 14, 2017 at 1:16 pm said:

When my shrink said there are no coincidences I thought she was ba y, but the more I focused on “coincidental” occurances it became
clear that she is right. There are no coincidences. Every thing that happens is explainable. The next time you have a; “well, what a
coincident” moment, try looking back at, the “coincident”, and what just happened, disect the moments, question the elements
involved. You will also come to the same conclusion. There are no coincidents. Except the Big Bang.
I thank the author for doing the work necessary to the forming an opinion based on logical assesment of some hard to find information.
Good work.
Reply
Charlo esville Witness Brennan Gilmore | Slaves Of Corruption, on August 14, 2017 at 1:32 pm said:
[…] And he just HAPPENED to have the pre-approved establishment message […]

Reply
Anon, on August 14, 2017 at 1:36 pm said:

no one died at Sandy Hook either
Alex Jones is a gatekeeper/controlled oppo
Megyn Kelly is a miserable deceptive kunt
Reply
donkeyshowup, on August 14, 2017 at 10:07 pm said:

XCELLENT work WillyLoman. I have followed you since the Aurora psyops where you came up with (from my rapidly ageing brains
memory) the discarded gas mask lying on the ground in the back of the theatre. I came across a 4 second video on Live leak & I too
thought it strange that the cameraman panned away after watching the car driving sedately it seemed down the street. It doesn’t show
any other cars I might go look on (((You Tube))). Over here in New Zealand the latest story is that he hit his mother & that when he was
on a school trip to Dachau he’d said “this is where the magic happened” .
Check this guys twi er feed out – appears to be saying someone else driving car ??? h ps://twi er.com/Ariosopher Wouldn’t be the
47th time some patsy has been told “you’re it sunshine – don’t you remember doing that??”
Again top notch research
Reply
GZ, on August 16, 2017 at 2:47 pm said:

How come his airbag didn’t deploy?
Reply
willyloman, on August 16, 2017 at 2:52 pm said:

someone disabled them (that model has air-curtains over the side windows as well, right?) prior to the event so when he hit
people they wouldn’t deploy making it impossible for him to see and steer. that’s my guess anyway
Reply
donkeyshowup, on August 15, 2017 at 1:36 am said:

Ah interestinger & interestinger . . . . . . . I’ve just looked on you tube & the—- first thing I noticed was that my browser extension
/download bu on is no longer working. And I seem to have gone from You Tube .com to You Tube .com. NZ.
It would appear from the videos I watched that the shot of the car driving relatively sedately before the “mayhem” has been placed
into the “presentations” later on, so that one can’t actually work out the sequence of events. There were obviously multiple camera-
people & a guy from Twi er (linked to above) has what may well be pertinent to understanding WTF happened. Someone else did a
Twi er search on the hash-tag # False Flag . . . .(where I picked up Ariosopher from) – there’s are certainly shit loads of people calling
“bullshit” on the MSM version of events !!
We watch with interest.
Cheers
Chris in Christchurch
Reply
Repost by Permission: Russia Reports CIA “Genocide Expert” Orchestrated Charlo esville Mob Violence, on August 15, 2017 at
10:15 am said:
[…] roles” in creating this media spectacle, this report says, third up was Brennan Gilmore—who “magically and mystically” was able
to appear at the height of this created mob violence with a …—with Brennan Gilmore, afterwards, being prominently interviewed by
not only CNN, but every […]
Reply
Dialectics, Charlo esville and Uniting Solutions | Drive Time with Varshney and Davis 2 – Joseph Davis | Freedom Advocate in
Memphis, TN, on August 15, 2017 at 12:30 pm said:
[…] A ack, Brennan Gilmore and… the STOP KONY 2012 Pysop? What? h ps://willyloman.wordpress.com/2017/08/13/charlo esville-
a ack-brennan-gilmore-and-the-stop-kony… Sco Creighton’s “Charlo esville” […]
Reply
Janet, on August 15, 2017 at 1:58 pm said:

Members of The Century Foundation were involved in JournoList too.
3 are listed in the KNOWN members – h p://thevailspot.blogspot.com/2011/01/journolist-membership.html
Reply

Russia Reports CIA "Genocide Expert" Orchestrated Charlo esville Mob Violence | The Impious Digest, on August 15, 2017 at 3:08
pm said:
[…] roles” in creating this media spectacle, this report says, third up was Brennan Gilmore—who “magically and mystically” was able
to appear at the height of this created mob violence with a …—with Brennan Gilmore, afterwards, being prominently interviewed by
not only CNN, but every […]
Reply
Steph, on August 15, 2017 at 9:23 pm said:

O. B. V. I. O. U. S. l. i e !
Virginia cia pentagon MilitryP’Lice E X E R C I S E .

Testing sheeple. are u ready to cook?
These Pentagon Bankster Corporate /robot monster mass murderers are on automatic holocaust apocalypse FinalSolution.
amurdika. Yer doom.
Reply
GZ, on August 16, 2017 at 2:49 pm said:

How come his airbag didn’t deploy?
Reply
dsmclellan, on August 16, 2017 at 4:42 pm said:

Brennan GIlmore is a racist himself
Reply
Rusia demuestra que el atropello de Charlo esville fue orquestado por el agente de la CIA Brennan Gilmore – Alerta Digital, on
August 17, 2017 at 6:42 am said:
[…] La jugada se completa con la aparición de Gilmore, armado con su videocámara, para grabar la estampida del coche que mató a la
manifestante, dando acto seguido las consabidas entrevistas a la CNN, como estaba previsto en el guión previamente escrito. […]
Reply
CHARLOTTESVILLE AND THE MARCH OF THE DEVIL, AMERICAN PSYOPS | In Search of Black Assassins, on August 17,
2017 at 11:37 am said:
[…] [9] h ps://willyloman.wordpress.com/2017/08/13/charlo esville-a ack-brennan-gilmore-and-the-stop-kony… […]
Reply
Daily Reading #197 | thinkpatriot, on August 17, 2017 at 7:30 pm said:
[…] h ps://willyloman.wordpress.com/2017/08/13/charlo esville-a ack-brennan-gilmore-and-the-stop-kony… […]
Reply
dotherigh hing4, on August 18, 2017 at 8:41 am said:

Amazing amount of investigative reporting. Continuing to peel back the layer. The LEFT is so craven they will stop at nothing to regain
control.
Reply
The Charlo esville Conspiracy and the Anti-American, Anti-White, Subversive, Hate Promoting Mainstream Media – THE
GOVERNMENT RAG BLOG, on August 20, 2017 at 10:20 pm said:
[…] One of the first commentators and State actors on the scene in Charlo esville was Brennan Gilmore, a former State Department
Employee with history of entanglements in psychological operations and hoaxes to achieve agenda. Gilmore was assigned to the
Central African Republic (CAR), as part of the US Embassy Staff. While in CAR, Gilmore was involved with a Psy-op, which became
known as the Kony 2012 campaign. This deception involved trying to create the need to involve US troops in the deteriorating political
situation (for the US Government) in CAR, which threatened the US Embassy and the political regime of the current puppet US
Dictator. […]
Reply
On Charlo esville | Ronald Thomas West, on August 21, 2017 at 2:59 am said:
[…] police state tactics and solutions, White identity groups will discover they had been used and discarded like the ignorant stooges
they […]
Reply
Elly, on August 21, 2017 at 6:35 pm said:

I got the same sense of bs from the Berkeley rally, too, except that was on the other side.
Reply
mercury7, on August 21, 2017 at 7:53 pm said:

i don’t exactly remember, but weren’t those campus cops told to stand down, too?
Reply
The Charlo esville Conspiracy and the Anti-American, Anti-White, Subversive, Hate Promoting Mainstream Media| Jack Mullen
– aladdinsmiraclelamp, on August 22, 2017 at 4:00 am said:
[…] One of the first commentators and State actors on the scene in Charlo esville was Brennan Gilmore, a former State Department
Employee with history of entanglements in psychological operations and hoaxes to achieve agenda. Gilmore was assigned to the
Central African Republic (CAR), as part of the US Embassy Staff. While in CAR, Gilmore was involved with a Psy-op, which became
known as the Kony 2012 campaign. This deception involved trying to create the need to involve US troops in the deteriorating political
situation (for the US Government) in CAR, which threatened the US Embassy and the political regime of the current puppet US
Dictator. […]
Reply
European “False Flag” Expert focuses on Charlo esville Fiasco | SOTN: Alternative News & Commentary, on September 4, 2017 at
6:57 pm said:
[…] and Hillary Clinton, who pardoned 60,000 felons to ensure the state went for her. A key witness, Brennan Gilmore, worked as a US
State Department Service Officer (CIA) in Africa and is the Chief of… candidate for governor, to whom George Soros has contributed
more than $250,000. Soros appears to […]
Reply
European “False Flag” Expert focuses on Charlo esville Fiasco | Cosmic Convergence: 2012 and Beyond, on September 4, 2017 at
6:59 pm said:
[…] and Hillary Clinton, who pardoned 60,000 felons to ensure the state went for her. A key witness, Brennan Gilmore, worked as a US
State Department Service Officer (CIA) in Africa and is the Chief of… candidate for governor, to whom George Soros has contributed
more than $250,000. Soros appears to […]
Reply
Anonymous, on September 15, 2017 at 3:59 am said:

Brennan Gilmore is a C.I.A. officer who was working under official cover with the U.S. State Dept.
Richard Spencer, one of the white supremacist organizers of the Charlo esville rally, also has C.I.A. connections through his employer
William Regnery II.
Reply
Media Elevates War Mongers, Tortures to Denounce Hate?! What?, on October 13, 2017 at 10:50 pm said:
[…] the links to history and former involvement with Lord’s Army Issues at the State Department: Charlo esville A ack, Brennan
Gilmore and… the STOP KONY 2012 Pysop? What? On what Kony was ACTUALLY ABOUT: […]
Reply
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by Scott Creighton I Can’t Title This Post Because it Will Be
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Go back and look at the video Brennan Gilmore posted of the Charlottesville attack. Go back and look at it. Attack
Something very odd and OBVIOUS is staring us in the face and all we have to do is step back and take a breath and Trump's Marines Anthraxed! Tom Heneghan
see what’s right there for us to see. 100-Year-Old Way to Filter Rainwater in a
Barrel
The numbers from the Charlottesville attack are in and one individual is dead with another 30 or so injured. Two Black Eyed Kids They're Just Kids, Right?....
Wrong! What Are They? (Video)
more deaths are attributed to the event in an effort to make it bleed more so to speak, but they were killed when
New Q Anon Report Plus the Latest on the
their helicopter crashed. I’m not sure how they link that to the protests, but, there you go. Alarming Purge: Truthful Free Speech Is Being
Terminated at an Incurable Rate (Video)
I will do some research on the suspect and publish it a little later but right now I wanted to share with you some
Why Glenn Beck Is the Most Dangerous Man in
things I found out about Brennan Gilmore, the former State Department employee who just HAPPENED to be at the America
exact right place at the exact right time already filming with his camera to capture the entire event from beginning Trump, Q Anon, The Illuminati, 4chan, Pepe,
to end. Kek, Meme Magick and Sigils ... This Is Strange
Stuff!
And he just HAPPENED to have the pre-approved establishment message canned and ready to go for a CNN interview Bombshell Confirmed: Broward Co Deputies
'Ordered' to Stand Down…Then All Radio
on the scene. Funny, his video hadn’t gone viral yet and CNN was already interviewing him? What a coincidence
http://beforeitsnews.com/opinion-liberal/2017/08/charlottesville-attack-brennan-gilmore-and-the-stop-kony-2012-pysop-what-2558822.html 1/8
there, huh? Notice he says the counter-protesters were “peaceful”. I guess that means Soros’ ANTIFA provocateurs Communications were Cut Off While the
Shooting Continued +Videos
had been told to avoid that particular march. Also notice he equates “alt-right” with “terrorists” and “racists” with
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Excellent answer, Brennan Gilmore. pic.twitter.com/n8iuLYRK74
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— Minor Leaguer (@Minor_Leaguer) August 12, 2017
Watch Him Transform Before Their
Brennan Gilmore’s video is viral now. It’s been hijacked by more YouTubers than you can imagine. It really was Very Eyes
perfect. Not only did he HAPPEN to be at the right place at the right time, but he was ALREADY recording with his Her Moments
camera and it was focused on that car, for SOME REASON as it drove by the corner at a reasonable rate. Why he Avoid Terrible Email Sign-Offs With
would focus on that vehicle right then and there BEFORE IT DID ANYTHING is a mystery to me. It was traveling down This New Extension
the street at about 25 miles and hour which is not out of place for that road. Certainly it may be for the situation, Grammarly
but remember, the march was not planned and or sanctioned, so the street was not blocked off, and in fact, there
were two more cars in front of the Dodge Charger that were stuck in the middle of the protest on that same street.
This adorable puppy with his mom will
Those are the ones hit from behind by the Charger. But Brennan wasn’t filming them was he? No. But he did film the
make your day
Charger heading all the way down the street into the crowd of protesters… almost as if he knew it would run into
Topix
them rather than simply brake and sit and wait like the other cars in front of it.
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victims. Stay home. pic.twitter.com/MUOZs71Pf4 You Would Expect, Or Even Close
NinjaJournalist
— Brennan Gilmore (@brennanmgilmore) August 12, 2017
Again, not a smoking gun in and of itself, but when combined with all the other coincidences surrounding his video This Travel Card Has No Annual Fee
PLUS the fact that he was ready to go with the divide and conquer establishment version of events for CNN while And $200 For Travel
people were still lying on the hot pavement, it kind of makes you wonder doesn’t it? Wise Bread
PLUS… Brennan says it is “definitely terrorism”… no doubt about it. HAS to be “terrorism”, right?
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Let me take a second to explain something to you. Terrorism is an act of violence or the THREAT of violence At Risk?
designed to prompt a change in a country in terms of it’s economic, political or social structure. Gundry MD
How is ramming a car into a crowd of protesters you don’t like to be considered an effort by that ONE PERSON to by Taboola
bring about a change in this country’s social structure? Are we to assume the driver thought that running over a few
counter protesters would make the rest of the country step back and say “yeah, the Robert E. Lee statue is history,
not racism” and let it stand? Are We Losing America To Endless Immigration?
A terrorist blows up an airport because he wants to DISRUPT commerce and travel. A terrorist runs a campaign like Signs In The Heavens - A Biblical Blue Moon?
GLADIO because he wants to prevent a nation from slipping too far to the left. A racist might run over “goddamned Why US GDP Hasn’t Really Increased Since 2000
hippies” because he HATES THEM. But that’s NOT terrorism. Services and features of Admiral Markets
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However… if the event, the mass casualty event, was PLANNED to destabilize the nation, to DIVIDE the “alt-left’
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and the “alt-right”… then THAT IS TERRORISM. Stonington, Illinois, to Washington, D.C.
(Video)
Moving on…
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“The violence and hatred in our society is out of control. We like to think that it’s better than places like Africa and
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Asia, but it’s not,” said Mr. Gilmore, who worked in Africa as a U.S. State Department foreign service officer
Advanced Ancient Technology That Surpasses
before leaving to manage the campaign of Tom Perriello for Virginia governor earlier this year. “I’m worried.” New Any That We Know Of (Video)
York Times Thousands of Americans Jailed in Private
Prisons for Small Debts
Given Brennan’s rather suspicious positioning before the fact and his former employer (a State Department that is
wholly disgusted with BOTH Trump and Tillerson for firing a number of 7th floor entrenched State Department
career “soft power” activists) I thought I would look him up and see if I could find some more background on who is FEATURED
really is and what he did for them. Thousands of Americans Jailed in Private…
What Happened When I Tried to Access I…
Web Bot: Clif High: Crypto Blood 2018 St…
Brennan M. Gilmore | Embassy of the United States Bangui, CAR Q Anon: Obama Russian Ties? Payback f…
Deep State Making Final Move on Americ…
bangui.usembassy.gov/about-us/deputy-chief/deputy-chief-of-mission.html
How Money Changes the Way You Think an…
Prior to this, Mr. Gilmore served as the Special Assistant for Lord’s Resistance Army (LRA) Issues in the Bureau Alex Jones - Full Show - Wednesday (2-2…
of African Affairs, coordinating the development … CRISPR - Wait Until You Find Out What it…
I Can’t Title This Post Because it Will Be …
The link is dead. They scrubbed it from the interwebs. But as you can probably imagine, when I saw he was linked
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somehow to the whole “STOP KONY 2012” psyop, I was amazed.
Then I found some more (not an easy thing to do mind you): TOP GLOBAL
‘The Time for Reconciliation Is Over’: South …
State/OIG recently posted its inspection report of the US Embassy in Bangui, a 15% danger pay post, as well as a 35%
Preston James and Mike Harris, Veterans To…
COLA and 35% hardship differential pay assignment. The inspection took place in Washington, DC, between
Why Turkey Wants to Invade the Greek Isla…
September 10 and 28, 2012, and in Bangui, the Central African Republic, between November 5 and 12, 2012.
Putin Claims Russia Is Testing a New Range…
The diplomatic mission is headed by Ambassador Laurence D. Wohlers, a career diplomat. The deputy chief of Google and Facebook: Supping With the Devil …
mission (DCM) is Brennan M. Gilmore. The embassy temporarily suspended operations on December 28, 2012, as a What Happened When I Tried to Access I…
result of the security situation in the country…
Operation Hogg Wash: The Back Story Just …
The Ambassador arrived in September 2010 and the deputy chief of mission (DCM) in July 2011. They constitute a Benjamin Fulford: February 26, 2018 - Th…
team that is particularly strong in outreach and reporting and have successfully weathered a series of management Syria conflict: Syrian women told no sex no aid
challenges. They are not as successful when it comes to leadership and morale. Red alert: Met issues highest weather warni…
The DCM has broad executive responsibilities. He supervises the reporting agenda assigned to the first-tour
TOP ALTERNATIVE
political/economic/consular officer. The officer meets weekly with the DCM and usually the Ambassador as well.
Advanced Ancient Technology That Surp…
The DCM is responsible primarily for military affairs, which include the U.S. Special Forces deployment to the Are Liberal Values to Blame for Mass Killings?
eastern Central African Republic and a rotational U.S. Africa Command liaison officer position. Diplopundit archive Why US GDP Hasn’t Really Increased Since…
on Brennan Gilmore Kyle Kulinski Sees the Bigger Threat Behind…
Preston James and Mike Harris, Veterans To…
The STOP KONY 2012 psyop was all about using the Joseph Kony boogieman to justify letting Barack Obama send
Special Operations troops into Africa to run around and squash any and all resistance to our new imperialism Photos Show Venezuelan Zoo Animals St…
campaign. It was a fraud. A show. And Brennan was part of it. Scientists Warn of the Potential for an ET…
Google and Facebook: Supping With the Devil …
He was also part of the campaign of Tom Perriello’s in Virginia to become the next governor. Perriello also has ties
ZetaTalk Newsletter as of March 4, 2018
to the new African imperialism campaign that was waged under the watchful eyes of our first black president. Tom
Biblical Blue Full Moon Tonight - 2 Full O…
lost the primary two months ago in spite of the fact that he was backed by every establishment unDemocratic Party
leader and even that Khan guy who was rolled out by Hillary Clinton to paint Trump as a racist way back when.
In July 2015, President Obama appointed Tom Perriello to succeed former US Senator Russell Feingold as
Special Envoy to the Great Lakes Region and the Democratic Republic of Congo. As Special Envoy, Perriello was
the US representative to a region including Democratic Republic of Congo, Burundi, and Rwanda, countries working
to overcome a recent legacy of civil war and genocide.
In December 2016, Perriello indicated that he would run for Governor of Virginia in the 2017 election on a platform
centered around economic justice as well as resistance to the Trump Administration.[51]
Perriello is currently CEO of Win Virginia a PAC dedicated to helping Democrats win back the Virginia House of
Delegates in 2017.
And there’s one more thing about the man Brennan Gilmore tried to make the next governor of Virginia… he’s a
centrist neoliberal linked to the CIA’s USAID.
During the 2009 legislative session, Perriello voted for the American Recovery and Reinvestment Act,[31] (he voted
for TARP) the American Clean Energy and Security Act,[32] and the Patient Protection and Affordable Care Act in
March 2010.[33] During debate over the health care bill in the House, he voted for the Stupak–Pitts Amendment to
the Affordable Health Care for America Act, which would have prohibited the use of federal funds to cover any part
of the costs of any health plan that includes coverage of abortion (and he voted for fascist ObamaCare but didn’t
want abortion to be paid for under it)…
Tom Perriello was selected by Secretary of State John Kerry to lead the 2015 Quadrennial Diplomacy &
Development Review, a strategic planning process intended to be conducted every four years for the U.S.
Department of State and the U.S. Agency for International Development (USAID)…
He has worked as a consultant to the International Center for Transitional Justice in Kosovo (2003), Darfur (2005),
and Afghanistan (2007) where he worked on justice-based security strategies.[13] Perriello has also been a fellow at
The Century Foundation
Ah, so Tom worked mopping up resistance in places like Kosovo, Darfur and Afghanistan before becoming such a
stalwart “progressive” huh?

And what’s that about The Century Foundation? Who are they you ask?
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Total 6 comments
Man
OMG congrats on making the first post that Charlottesville protest is a fake plot!
Terrorism is to incite terror. You can do that without the Bombs. That is also what the KKK is doing perfectly. And
they are a domestic terror group.
Seriously, if you have a group consisting of the KKK, NEo-Nazi’s and white supremacist supporting the Robert
Edward Lee Sculpture because it is part of Confederate Culture, you really need to think really hard why these
groups are defending it.
Seriously, If i was a Alt-righter and you Have the KKK, Neo-Nazi’s and white supremacists defending you. I would
really think hard what my political ideology is about. Because if you don’t support these groups. You should speak
out or you are with them.
Similar to those Muslims who don’t condemn Islamic terrorists.
AUG 13, 2017, 9:07 AM Reply -5
Rockledge
Bullshit.
AUG 13, 2017, 3:53 PM Reply 1
drew
No one pays any attention to you Man because you’re extremely one-sided in your argument. You must
be getting paid for your efforts and don’t want to jeopardize your next pay increase.
AUG 13, 2017, 8:34 PM Reply 1
Man
If you have a grain of decency you should be doing that as well.
The American Vanguard has a Nazi reference as their website Link. Blood and soil was used
as a slogan in Nazi germany.
You don’t need to get paid to understand this common sense
AUG 13, 2017, 11:29 PM Reply -1

Rockledge
When hate-mongering crybaby racists like Sharpton and Jesse whatshisname have their public whine events, you
don’t see white people interfering.
I am not for white supremacists ( although it isn’t hard to see that given the condition our society has become
pretty much is a recruitment commercial for them) but I am also not for limiting constitutional rights, and the klan
and supremacists have just as much right to peaceful assembly and to celebrate AMERICAN culture as the
brainwashed herd that hate this country and are trying to take it over.
It appears to me that what has really happened is a group of law abiding citizens got together to enjoy their
constitutional right of assembly and were harassed by those who hate AMERICA and want us to keep just being
america, the has been nation.
I am thinking a LOT of AMERICANS are sick and tired of all the crybaby dependent mentality bullshit
and likely see through the medias corrupt misrepresentation of reality.
AUG 13, 2017, 3:46 PM Reply 1
Man
it is not american culture when you have people openly chanting racist slogans and doing nazi
references on the street
This is like syaing that ISIS should be allowed to do an assembly and shout allah ackbar on the street.
it is crazy
AUG 13, 2017, 11:32 PM Reply -1
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EXHIBIT C


3/1/2018 Charlottesville, Brennan Gilmore, and the STOP KONY 2012 Psyop -- Society's Child -- Sott.net
Charlottesville, Brennan Gilmore, and the STOP KONY

2012 Psyop
Scott Creighton
American Everyman
Sun, 13 Aug 2017 17:26 UTC
© Getty
Go back and look at the video Brennan Gilmore posted of the Charlottesville attack. Go back
and look at it. Something very odd and OBVIOUS is staring us in the face and all we have to
do is step back and take a breath and see what's right there for us to see.
The numbers from the Charlottesville attack are in and one individual is dead with another 30
or so injured. Two more deaths are attributed to the event in an effort to make it bleed more so
to speak, but they were killed when their helicopter crashed. I'm not sure how they link that to
the protests, but, there you go.
I will do some research on the suspect and publish it a little later but right now I wanted to
share with you some things I found out about Brennan Gilmore, the former State Department
employee who just HAPPENED to be at the exact right place at the exact right time
already filming with his camera to capture the entire event from beginning to end.

https://www.sott.net/article/359361-Charlottesville-Brennan-Gilmore-and-the-STOP-KONY-2012-Psyop 1/6
And he just HAPPENED to have the pre-approved establishment message canned and
ready to go for a CNN interview on the scene. Funny, his video hadn't gone viral yet and
CNN was already interviewing him? What a coincidence there, huh? Notice he says the
counter-protesters were "peaceful". I guess that means Soros' ANTIFA provocateurs
had been told to avoid that particular march. Also notice he equates "alt-right" with
"terrorists" and "racists" with ease.
Brennan Gilmore's video is viral now. It's been hijacked by more YouTubers than you can
imagine. It really was perfect. Not only did he HAPPEN to be at the right place at the right time,
but he was ALREADY recording with his camera and it was focused on that car, for SOME
REASON as it drove by the corner at a reasonable rate. Why he would focus on that vehicle
right then and there BEFORE IT DID ANYTHING is a mystery to me. It was traveling down the
street at about 25 miles and hour which is not out of place for that road. Certainly it may be for
the situation, but remember, the march was not planned and or sanctioned, so the street was
not blocked off, and in fact, there were two more cars in front of the Dodge Charger that were
stuck in the middle of the protest on that same street. Those are the ones hit from behind by
the Charger. But Brennan wasn't filming them was he? No. But he did film the Charger heading
all the way down the street into the crowd of protesters... almost as if he knew it would run into
them rather than simply brake and sit and wait like the other cars in front of it.
Again, not a smoking gun in and of itself, but when combined with all the other
coincidences surrounding his video PLUS the fact that he was ready to go with the
divide and conquer establishment version of events for CNN while people were still
lying on the hot pavement, it kind of makes you wonder doesn't it?
PLUS... Brennan says it is "definitely terrorism"... no doubt about it. HAS to be "terrorism",
right?
Let me take a second to explain something to you. Terrorism is an act of violence or the
THREAT of violence designed to prompt a change in a country in terms of it's economic,
political or social structure.
How is ramming a car into a crowd of protesters you don't like to be considered an effort by
that ONE PERSON to bring about a change in this country's social structure? Are we to
assume the driver thought that running over a few counter protesters would make the rest of
the country step back and say "yeah, the Robert E. Lee statue is history, not racism" and let it
stand?
A terrorist blows up an airport because he wants to DISRUPT commerce and travel. A terrorist
runs a campaign like GLADIO because he wants to prevent a nation from slipping too far to the
left. A racist might run over "goddamned hippies" because he HATES THEM. But that's NOT
terrorism.
However... if the event, the mass casualty event, was PLANNED to destabilize the nation,
to DIVIDE the "alt-left' and the "alt-right"... then THAT IS TERRORISM.
Moving on...
"The violence and hatred in our society is out of control. We like to think that it's better
than places like Africa and Asia, but it's not," said Mr. Gilmore, who worked in Africa
as a U.S. State Department foreign service officer before leaving to manage the
campaign of Tom Perriello for Virginia governor earlier this year. "I'm worried." New
York Times
Given Brennan's rather suspicious positioning before the fact and his former employer (a State
Department that is wholly disgusted with BOTH Trump and Tillerson for firing a number of 7th
floor entrenched State Department career "soft power" activists) I thought I would look him up
and see if I could find some more background on who is really is and what he did for them.
Brennan M. Gilmore | Embassy of the United States Bangui, CAR
Prior to this, Mr. Gilmore served as the Special Assistant for Lord's Resistance
Army (LRA) Issues in the Bureau of African Affairs, coordinating the development
...

The link is dead. They scrubbed it from the interwebs. But as you can probably imagine, when I
saw he was linked somehow to the whole "STOP KONY 2012" psyop, I was amazed.
Then I found some more (not an easy thing to do mind you):
State/OIG recently posted its inspection report of the US Embassy in Bangui, a 15%
danger pay post, as well as a 35% COLA and 35% hardship differential pay
assignment. The inspection took place in Washington, DC, between September 10 and
28, 2012, and in Bangui, the Central African Republic, between November 5 and 12,
2012.
The diplomatic mission is headed by Ambassador Laurence D. Wohlers, a career

diplomat. The deputy chief of mission (DCM) is Brennan M. Gilmore. The embassy
temporarily suspended operations on December 28, 2012, as a result of the security
situation in the country...
The Ambassador arrived in September 2010 and the deputy chief of mission (DCM) in
July 2011. They constitute a team that is particularly strong in outreach and reporting
and have successfully weathered a series of management challenges. They are not as
successful when it comes to leadership and morale.
The DCM has broad executive responsibilities. He supervises the reporting agenda
assigned to the first-tour political/economic/consular officer. The officer meets weekly
with the DCM and usually the Ambassador as well. The DCM is responsible primarily
for military affairs, which include the U.S. Special Forces deployment to the eastern
Central African Republic and a rotational U.S. Africa Command liaison officer position.
Diplopundit archive on Brennan Gilmore
The STOP KONY 2012 psyop was all about using the Joseph Kony boogieman to justify
letting Barack Obama send Special Operations troops into Africa to run around and
squash any and all resistance to our new imperialism campaign. It was a fraud. A show.
And Brennan was part of it.
He was also part of the campaign of Tom Perriello's in Virginia to become the next governor.
Perriello also has ties to the new African imperialism campaign that was waged under the
watchful eyes of our first black president. Tom lost the primary two months ago in spite of the
fact that he was backed by every establishment unDemocratic Party leader and even that Khan
guy who was rolled out by Hillary Clinton to paint Trump as a racist way back when.
In July 2015, President Obama appointed Tom Perriello to succeed former US Senator
Russell Feingold as Special Envoy to the Great Lakes Region and the Democratic
Republic of Congo. As Special Envoy, Perriello was the US representative to a region
including Democratic Republic of Congo, Burundi, and Rwanda, countries working to
overcome a recent legacy of civil war and genocide.
In December 2016, Perriello indicated that he would run for Governor of Virginia in the
2017 election on a platform centered around economic justice as well as resistance to
the Trump Administration.[51]

Perriello is currently CEO of Win Virginia a PAC dedicated to helping Democrats win
back the Virginia House of Delegates in 2017.
And there's one more thing about the man Brennan Gilmore tried to make the next
governor of Virginia... he's a centrist neoliberal linked to the CIA's USAID.
During the 2009 legislative session, Perriello voted for the American Recovery and
Reinvestment Act,[31] (he voted for TARP) the American Clean Energy and Security
Act,[32] and the Patient Protection and Affordable Care Act in March 2010.[33] During
debate over the health care bill in the House, he voted for the Stupak-Pitts Amendment
to the Affordable Health Care for America Act, which would have prohibited the use of
federal funds to cover any part of the costs of any health plan that includes coverage
of abortion (and he voted for fascist ObamaCare but didn't want abortion to be paid for
under it)...
Tom Perriello was selected by Secretary of State John Kerry to lead the 2015
Quadrennial Diplomacy & Development Review, a strategic planning process
intended to be conducted every four years for the U.S. Department of State and
the U.S. Agency for International Development (USAID)...
He has worked as a consultant to the International Center for Transitional Justice in

Kosovo (2003), Darfur (2005), and Afghanistan (2007) where he worked on justice-
based security strategies.[13] Perriello has also been a fellow at The Century
Foundation
Ah, so Tom worked mopping up resistance in places like Kosovo, Darfur and Afghanistan
before becoming such a stalwart "progressive" huh?
And what's that about The Century Foundation? Who are they you ask?
The Century Foundation is a progressive think tank headquartered in New York City
with an office in Washington, D.C.[1] It was founded as a nonprofitpublic policy
research institution on the belief that the prosperity and security of the United States
depends on a mix of effective government, open democracy, and free markets
Ah, the Global Free Market Wars, a.k.a. the Global War on Terrorism a.k.a. Overseas
Contingency Operations. And Tom, and apparently our "convenient witness" Brennan
Gilmore, were all over it.
Gilmore has spent a lot of time Tweeting since the event unfolded yesterday. As expected, he
is quick to label it terrorism and cast blame on the "alt-right" which he equates with Nazism.
It's important to put into context Brennan Gilmore's time in CAR when they were fighting
"KONY"
They weren't fighting KONY. He was there in support of the brutal military dictatorship of
General François Bozizé who took over in coup from the elected president of the
country, Ange-Félix Patassé
Our puppet dictator Bozize was trying to hold onto power in the face of a 2012 uprising from
Séléka CPSK-CPJP-UFDR not "KONY". But of course, that would have been a harder sell to
the fans of President Peace Prize so "KONY" the boogieman. In the end, Special Operations
and all the propaganda we could muster did little to stem the tide of CHANGE in CAR and the
start of 2013 saw folks like Brennan Gilmore and Bozize flee the country.
Gilmore has said on multiple occasions since the event yesterday that you would think hatred
and violence is more widespread in "African nations" than it is right here in the states, but "you
would be wrong" which is quite an amazing statement coming from a man who resided in a
country that routinely killed opposition leaders and who was forced to FLEE THE COUNTRY
when the people finally took it back from us.
All this being said, is it possible this man with links to Special Ops and CIA and various
other black ops kinds of actors just HAPPENED to be there at that particular moment in
history?
Yeah, I guess that's possible, if you're into coincidence theories I suppose.
But I'm not into such things.
Clearly the State Department has a lot of disgruntled former employees who would delight in
destabilizing Trump's tenure even more than they already have. And Gilmore, like Tom, seem
particularly invested in undermining the "alt-right" in the lead-up to the next round of elections.
Waaaaaay too much coincidence for me folks. Waaaaaay too much.
UPDATE: Moon of Alabama blog makes some valid comparisons between this event and
those that took place in Kiev during our color revolution
(of course, those were REAL Nazis throwing fire bombs at the police as opposed to FAKE
NAZIS, probably police provocateurs, whom the police didn't bother with and were given a
stand-down order to stay out of the way till some good violence unfolded)
Like
See Also:
In 2017, the US government 'lost' $2.2 million every minute
How British media coverage of Syria is a total hoax
Mohammad Tamimi on his detention: 'They beat me into confessing'

EXHIBIT D


3/9/2018 YouTube
SIGN IN
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longer available
because the
YouTube account
associated with
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EXHIBIT E


3/9/2018 Random Man at Protests Interviewed By MSNBC, NY Times Is Deep State Shill Linked to George Soros
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August 14, 2017 by Jim Hoft 149 4.6K Share 211 Tweet Email
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The random Charlottesville observer who was

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It looks like the State Department was involved in
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Brennan Gilmore tweeted out a video of the horrific car attack on
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The New York Times later removed the quote.
The State Department is very familiar with Brennan Gilmore. He was

involved in the Kony 2012 operation.
Sean Hannity
Suffers Massive
Scare At Home -
Police Make Arrest
thepoliticalinsider.com
The State Department later removed any reference of Brennan.

Why would the State Department react in such a way? Martin Shkreli Cries
Why would the State Department scrub that? In Court As He's
Sentenced To 7
Brennan Gilmore was also Chief of Staff for liberal Rep. Tom Years
Perrielo. time.com
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This weekend Brennan Gilmore happened to be in Charlottesville

with the rioters. The media knows exactly who he is yet played it off View My
like a casual observer. Stats
This is how the Deep State is working with the liberal

media to shape narrative and fool the American
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USMCDanang1966 • 7 months ago ⚑ −

Truthfully, I am at a loss for words, this morning, after reading
this article! There is a "bipartisan call" for Capitol Hill hearings
on what happened in Charlottlesville, VA. Why bother? The
cover up will be massive, and we all know that the white
supremacists will get all of the blame. Antifa, BLM, The State
Department, etc. will not even be a footnote. Good Lord, our
President is surrounded by traitors. Our country is in deep
trouble, and now it's palpable!
97 △ ▽ • Reply • Share ›
John Locke > USMCDanang1966 • 7 months ago ⚑ −

We have been in deep trouble for a very long time. It is
just blatantly obvious now. We have many
representatives that need replacing.
nuthinmuffin > John Locke • 7 months ago − ⚑

the deep state russia fraud is winding
down...trying to whip up another frenzy for the far
left to focus on.
bonnieblue2A > nuthinmuffin − ⚑

• 7 months ago
Shiny things and squirrels....distract and
divide so we cannot concentrate on the
criminal elements within our government
bureaucracies.
Brian Niziol > bonnieblue2A − ⚑

• 7 months ago
Well Bonnieblue2A you have risen above
the rest and hit the nail squarely on the
head.
2△ ▽ • Reply • Share ›
Bobo Bob > bonnieblue2A − ⚑

• 7 months ago
Pizzagate?
fiatmasochist > nuthinmuffin − ⚑

• 7 months ago
They say 'mayhem' till 2020 to escalate till
Case 3:18-cv-00017-GEC thiDocument
t b29-5
k i Filed
t i 04/24/18
thi kPage
d 10 of 17 Pageid#: 552
this country breaks into pieces....think and
act accordingly...what kind of country will
our grandchildren inherit?
Wanda > nuthinmuffin • 7 months ago − ⚑

Rush said the same thing today...
This comment was deleted.

−
Tom Johnson > Guest • 7 months ago ⚑ −

Our country is in trouble and all you can
do is make a business advertisement?
Shame on you!
bc1659 > Tom Johnson • 7 months ago ⚑ −

Yes, go elsewhere with your wealth drivel.
Maybe target BLM people.
They seem to have few good paying jobs
and a lot of time on their hands.
The Trumpet > John Locke • 7 months ago ⚑ −

The advent of Trump has made it very clear what
is going on. The globalist traitors are trying to
reassert themselves. The worst part is that the
GOP is infiltrated by the Globalist RINOs
Tom Johnson > The Trumpet − ⚑

• 7 months ago
McCain, McConnell, Boehner are just as
bad as Obama, Reid, Pelosi, Clinton,
The_Idiot_John_Kerry.
bc1659 > John Locke • 7 months ago − ⚑

On both sides of the aisle.
JVC > John Locke • 7 months ago − ⚑

We have many representatives that need
replacing.
I would think about 90% of them at the least.

Might be time to consider a mass citizen's arrest
of the entire congress--make that the entire
government.
fiatmasochist > JVC • 7 months ago ⚑ −

or just ignore them.....how do the citizens
just 'suspend' congress? without pay or
benefits? till each one makes their
agenda/loyalties clear?
△ ▽ • Reply • Share ›
The Punisher > fiatmasochist − ⚑

• 7 months ago
"How do the citizens just 'suspend'
congress?"
It's called stop paying your taxes. If you

stop feeding the beast then the beast
starves. It's quite simple really, but it takes
many people acting in concert to
accomplish.
So they must divide based on class, race,

religion, whatever while all the while
keeping the dogma alive that the beast is
necessary for life and liberty, when in fact
it is the sole enemy of such.
End this nonsense by peacefully resisting

by not paying your taxes and supporting
any and all peaceful secession options.
Tokaise Blessed Patriot > USMCDanang1966 − ⚑

• 7 months ago

Joatmoaf > Tokaise Blessed Patriot − ⚑

• 7 months ago
Truth.
freeinaz > USMCDanang1966 • 7 months ago − ⚑

But no call for hearings on the ANTIFA/BLM riots in
Seattle & Dallas last night? Isn't it strange and
coincidental how anti-White Nationalists
marches/demonstrations broke out so fast after & during
Charlottesville. It sure looks like this whole thing was
Soros pre-planned commie anti-American staged event
because that Russian thing just isn't panning out
curmudgeon VN Veteran > USMCDanang1966 − ⚑

• 7 months ago
Unlawful acts and democRATick politicians. A marriage
made in Hell.
Infowarrior C > USMCDanang1966 • 7 months ago − ⚑

My USMC Brother, you have it figured out. This is a
shuffle the blame game. Blame it on the nationalist to
discourage them from gathering and prevent the
nationalist from organizing.. Civil War is upon us...
Remember Ours is not to question why ours is but to do

or die....SEMPER F1
Tom Johnson > USMCDanang1966 • 7 months ago − ⚑

I was USMC DaNang, An Hoa 1968-9.
In Viet Nam, we were allowed to shoot back at the
communists.
In America, the communists (Obama, Sanders, Clinton)
are winning.
Trump is our only chance.
If Trump is taken out, we might end up with a shooting
Case 3:18-cv-00017-GEC
i il H Document
t 29-5 Filed 04/24/18 Page 13 of 17 Pageid#: 555
civil war. Hope not.
Infowarrior C > Tom Johnson • 7 months ago ⚑ −

Tom just remember what Charlie taught us and
apply it when SHTF. They dont want us Vets
armed they dont want us vets training civilians.
Thats why the VA has been mandated to screw
us over we are now a liability to the powers that
be who spent millions of tax payer dollars to train
us for their own greedy purposes. Now we are the
ones who they are most afraid of. We were better
trained than the kids these days and we possess
the knowledge of tactics and equipment needed
for any counter offensive. When it goes south we
as former MARINES are the last line of defense.
SEMPER F1!!!!! FU(K the APPLE SAVE THE
CORP....
Ploni > USMCDanang1966 • 7 months ago − ⚑

Relax, USMCD.
No need to get riled up.
The Leftists are playing right into our hands by wasting

their time and George Soros's money.
President Trump's supporters are still with him, even

more now than during the campaign.
They see what he's up against, what he's fighting.
Plus they're already benefiting from the president's

policies and actions.
Only the smallest number of Americans who are

influenced by the Left's dirty tricks have jumped ship.
Ha! The professional troublemakers think they're actually

accomplishing something!
Tom Johnson > Ploni • 7 months ago − ⚑

I hope you are right.
Trouble is, Soros has lots of money and has/will
make lots of trouble.
We needDocument
Case 3:18-cv-00017-GEC to be fixing 29-5
the economy for the folks
Filed 04/24/18 at 14 of 17 Pageid#: 556
Page
We need to be fixing the economy for the folks at
the bottom: infrastructure JOBS.
The folks at the economic bottom are hurting real-
time, and need to get jobs NOW.
If Trump can get the folks at the economic bottom
working again SOON,
then Trump will be a real hero to the folks. The
folks need HELP.
fiatmasochist > Tom Johnson − ⚑

• 7 months ago
Question: if this is all a set up by Soros,
how is this not seditious activity?
Ploni > fiatmasochist • 7 months ago ⚑ −

Because he's got friends in the highest
places.
doctorbri43 > Tom Johnson − ⚑

• 7 months ago
Do you see any bills or policies flowing
from the White House or Congress that
has any potential for job creation? Nada.
None. Nothing. Trump is a conman
supreme and the McConnells and Ryans
and the rest of Republican clowns can't
get anything done. The Corporatist
Democrats are also vile with the likes of
Schumer and Pelosi and Hoyer and
Himes representing the Deep State. The
ruling elites are warring with each other
and will do anything to trick others into a
great series of divides to divert attention
from their constant sucking wealth out of
the rest of us.
Fast Shot > USMCDanang1966 • 7 months ago − ⚑

I don't see much change, with couched phrases of 'right
to feel safe' to walk your dog or kids to go outside and
play.
Work people into frenzy of outrage that Trump and
Hannity were spied on, but convince folks to welcome
their own Safe City virtual panopticon and force them to
Case 3:18-cv-00017-GEC f th i Document
j il ll i 29-5 th Filedf 04/24/18
j b ti Page 15 of 17 Pageid#: 557
pay for their own jail cells in the name of job creation.
FreddyB > USMCDanang1966 • 7 months ago − ⚑

It is unfortunate that it is taking so long for people to,
forgive the term, wake up. This has been slowly brewing
for a very very long time.
All I hope is that you guys realize that while all this inner
turmoil is going on your government is doing it's best to
start a major war. Americans are the only ones that can
stop the use of your military in the escalation of all these
conflicts going on.
edb > USMCDanang1966 • 7 months ago − ⚑

#pAntiFake
TS > USMCDanang1966 • 7 months ago ⚑ −

Why would the state department just so happen to have
one of their lefties there ready to film the incident?
sophisticatedlydumb > USMCDanang1966 − ⚑

• 7 months ago
It shouldn't surprise you!!9/11 was committed by these
same groups!
doctorbri43 > sophisticatedlydumb • 7 months ago− ⚑

Which groups? The CIA and their pawns on
behalf of the Deep State? Mossad? The Saudis?
Sounds right to me and the truth will ultimately
out as the 9/11 Commission was a despicable
sham. Three powerfully strong buildings
collapsing into their own footprints without any
pushback from underlying steel and concrete
structures? Impossible according the Laws of
Physics.
CJDAUB > USMCDanang1966 • 7 months ago ⚑ −

www.republicoftheunitedstat... to be involved and know
what to do.

>
bob e > CJDAUB • 7 months ago − ⚑
great website .. thanks
John Locke • 7 months ago − ⚑

I wonder if there was collusion between the government and
groups like ANTIFA and BLM? Perhaps the DOJ could get some
answers.
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EXHIBIT F


3/10/2018 Bombshell Connection Between Charlottesville, Soros, CIA » Alex Jones' Infowars: There's a war on for your mind!
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https://www.infowars.com/bombshell-connection-between-charlottesville-soros-cia/#disqus_thread 1/16
BOMBSHELL CONNECTION BETWEEN CHARLOTTESVILLE, SOROS, CIA

Nazi collaborator Soros funding division in America just like Ukraine
Bombshell Connection Between Charlottesville, Soros, CIA
Alex Jones: I'm Going To Expose George Soros

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−
ylcalif > gnostictheosophy • 7 months ago − ⚑

Good info. Merkel received the Kalergi Award in 2010.
Kalergi Plan to flood Europe with non-Europeans to create a mixed race that is easily
controllable by elites. Rothschilds funded the Kalergi Plan about 100 years ago and the
EU was planned just as the North American Union is planned.
10 △ ▽ • Share ›
Kevin Flynn > gnostictheosophy • 7 months ago ⚑ −

And if that isn't enough: Soros donated $33 million dollars to help local activists ferment
racial division in Ferguson, Missouri, an action that transformed “a one day criminal event
into a 24-hour -a- day national cause celebre. Soro's Open Society Foundation recently
gave $10 million to “confront hate” in the U.S. plus another $500 million for “migrants,
refugees and host communities.” More hate and division is the goal.
Soros believes the United States should become subservient to global rules, including the
false global warming/carbon paradigm. He has also invested in Monsanto and a lab in
Sierra Leone that created a CDC patented Ebola strain. Humanevents.com readers call
the billionaire Soros ““the single most destructive leftist demagogue in the country.”
12 △ ▽ • Share ›

−
All-American > Guest • 7 months ago ⚑ −

Too easy, he should be fed face first through a wood chipper with the video
sent to Obama saying, YOU'RE NEXT!
2△ ▽ • Share ›
reticle > Kevin Flynn • 7 months ago − ⚑

*Foment*.
And Ferguson had it coming.

2 △ ▽ • Share ›
ReadWryt • 7 months ago − ⚑

Wait...BRENNAN GILMORE?? You mean the Brennan Gilmore who grew up in Virginia and
graduated from UVA? Brennan Gilmore who still lives in Charlottesville, THAT Brennan Gilmore??
What the heck would HE be doing in Charlottesville covering political strife near the UVA campus,
that's just CRAZY! I can see why you assumed it was more than a coincidence...
2△ ▽ • Share ›
Xaviersp > ReadWryt • 6 months ago − ⚑

haha, well said. The amount of delusion on this website is unprecedented.
△ ▽ • Share ›
Nikolaos Skordilis • 7 months ago ⚑ −

Did I just hit the "Jack Pot" of conspiracy theory lunacy? It appears that I did. Bring on the attacks
crazies..
△ ▽ • Share ›
Dan Griffin • 7 months ago − ⚑

The level of stupid on this website is off the charts!
4△ ▽ • Share ›
Xaviersp > Dan Griffin • 6 months ago ⚑ −

Well, that is why no sane person takes Infowars seriously. The problem, they hold sway
over very influenced brains, who then may do something stupid based on their delusions.
Where are reason and rationality when you need them...
△ ▽ • Share ›
James West > Dan Griffin • 7 months ago − ⚑

Way, way beyond stupid! Paranoid, delusional, mad-as-a-hatter material.
4△ ▽ • Share ›
Jeffrey Gee • 7 months ago ⚑ −

Some of us were paying respects to the statue of all of our history. I was there... Add to history put
a black confederate statue nearby??? Add to, don't delete history in your own demi-god image!
"YOU MANIACS, YOU BLEW IT ALL UP... DAMN YOU.... GOD, DAMN YOU ALL TO HELL...."
Charton Heston
△ ▽ • Share ›
freenewlife8 . • 7 months ago ⚑ −

Good 'ol WND has just found and reported on the link between the organizer and known Soros
groups. His name is Jason Kessler, and he is from inside Occupy, a lover of every sick thing
liberal, who claims to have "changed his opinion" recently. It's also clear he worked with ACLU, a
known liberal cog in the machine. Here's the great WND expose': http://www.wnd.com/2017/08/...
△ ▽ • Share ›
Karl Kühlschrank > freenewlife8 . • 4 months ago − ⚑

Jason Kesser is doing such a good job as a plant, he can't even show his face in
Charlottesville without a security detail. There is also the likelihood he will sue the city.
Pretty good at deep cover huh? Dumfuk.
△ ▽ • Share ›
Steve White • 7 months ago − ⚑

Wow, I can't believe people believe this garbage.
5△ ▽ • Share ›
Jay • 7 months ago − ⚑

Just looked up Lee Stranahan on youtube and what do I find...
! This account has been terminated for violating YouTube's Community Guidelines. These dirty
bastards have to be stopped somehow. Youtube, Facebook, Google Censoring and Hiding the
Truth by blocking or Terminating the ones who Know.
3△ ▽ • Share ›
JUNIOR • 7 months ago ⚑ −

NWO in full swing. The problem is you have at least 60% of the country watching this unfold that
is not going to remain idle much longer. Less than 1% that believe rioting and looting is
acceptable and 30% that will just remain neutral. What I'm curious to is this. Have the Soros
Puppets actually done the MATH? The second some soccer mom is on her way home with her
kids and some protestor road blockade ends up hurting them freeway bowling will become a sport
. And the other 30% that was neutral will now become the Hunters. Trump isn't going to invoke
martial law, he is going to let this problem sort itself out and I guarantee the people that voted for
this countries future will come out on top.
3△ ▽ • Share ›
Kurt King • 7 months ago − ⚑

The Charlottesville terrorist attack car, 2010 Dodge Challenger, license in the photos is Ohio
GVF1111. The car registered with that # is to James Alex Fields, Jr, 20, and it had a sun/moon
roof, but the attack car did not. And Fields was not driving it. The driver as seen through the
windshield looks like James G Field, 32, US infantry Veteran. In the crash at least the driver's
airbag should have deployed, but it didn't. Therefore, that car had to have been specially prepared
for Veteran Field, with a fake license plate for kid Fields.
Then the cops allowed Vet. Field to slip away – because he was working for the deep state, and
they blamed and arrested kid Fields - a perfect lone-wolf patsy. See 82 221 129
208/baaaasepaagec9.html
3△ ▽ • Share ›
Karl Kühlschrank > Kurt King • 4 months ago ⚑ −

You didn't see the video of Field' car being struck with a club and people trying to surround
it? Heather Heyer died of a heart attack or more specifically, suicide by fork and newports.
△ ▽ • Share ›
tim necciai > Kurt King • 6 months ago − ⚑

Holy shit. This level of stupid is actually kind of impressive.
△ ▽ • Share ›
Lickyalips • 7 months ago − ⚑

Why hasn't Trump issued an arrest warrant for Soros?
5△ ▽ • Share ›
Rick Brohmer > Lickyalips • 7 months ago ⚑ −

Where is Soros hiding out now days? he seem to be on the move a lot more of recently
△ ▽ • Share ›
All American Chutzpah > Lickyalips • 7 months ago − ⚑

Jewish privilege? .
△ ▽ • Share ›
Founding Fathers 1776 • 7 months ago ⚑ −

Only thing worse than Soros himself are the MILLIONS of useful idiots falling for that disgusting
pig's BS
2△ ▽ • Share ›
Betty > Founding Fathers 1776 • 7 months ago ⚑ −

Those useful idiots if successful in over throwing America's govt., would later be eliminated
with deadly force as that is what communist do. The communist destroy their tools who are
violent and out of control as they have no trust of them. Wish they'd wake up as they are
Americans , and we could unite against a totalitarian NWO govt. Remember God chose
you from the beginning to live this remarkable time for His honor and glory forever. I pray
God protects us all.
2△ ▽ • Share ›
AdirondackChairman > Founding Fathers 1776 • 7 months ago − ⚑

Soros is the opportunist. The cultural division is the opportunity. He made his billion by
betting against currencies and then destabilizing the country government. "If I don't do it,
you know somebody else will." https://www.youtube.com/wat...
1△ ▽ • Share ›
landy fincannon • 7 months ago − ⚑

What about this?
https://www.thenewamerican....
1△ ▽ • Share ›
Ken Martin • 7 months ago − ⚑

F**king reptile.
△ ▽ • Share ›
Smarterthanyou • 7 months ago ⚑ −

What a load of nonsense. Face it, you infowarriors and white supremacists are the ones pushing
for a civil war.
2△ ▽ • Share ›
Karl Kühlschrank > Smarterthanyou • 4 months ago ⚑ −

White Nationalist or White Identitarian please. I don't have to look down on other to love
my race, you're just anti-white.
△ ▽ • Share ›
All American Chutzpah > Smarterthanyou • 7 months ago − ⚑

Rules for Radicals. Saul Alinsky.
1△ ▽ • Share ›
Real Anti-Racist Action • 7 months ago − ⚑

Nazi collaborator Soros?
Well first off "Nazi" is short for Ashkenazi-Jew. And yes Soros is an Ashkenazi-Jew. And I am an
anti-Ashkenazi.
Second, the nationalist who liberated much of Europe were awakened patriots like the Minute
Men who fought against Ashkenazi-dominating over them.
1△ ▽ • Share ›
Occams Razor • 7 months ago ⚑ −

“Political leaders in capitalist countries who cheer the collapse of socialism in other countries
continue to favor socialist solutions in their own. They know the words, but they have not learned
the tune.” Milton Friedman
△ ▽ • Share ›
aname123 • 7 months ago ⚑ −

We don't have a democratically elected gov't. The candidates, including Trump, are selected in
advance by donors and lobbies or participation in occult elitist societies.
https://thezog.info/who-con...
△ ▽ • Share ›
Lakshmima • 7 months ago − ⚑

Put some sugar in your popcorn and watch the show.
△ ▽ • Share ›
Lakshmima • 7 months ago ⚑ −

Divide and Conquer. Goal = Martial Law. The group is Occupy Wallstreet going by another name.
Funded by DNC, Soros, Hillary, Rinos, and 0bammy Pac. Don't fall for it. Paid agitators on
standby for city to city staged violent events, to cause violence for a paycheck. Free bussing, food
and shelter. $3500 paycheck per event. Black suits provided free of charge. Free dope and
booze. Classes provided for each event. Paid training. Democratic Governor and Mayors as well
as the leftie news are compliant and involved ahead of time. Leftie cops put on schedule and told
to stand down. Hire a punk today.

You fall for it=You lose.
△ ▽ • Share ›
tim necciai > Lakshmima • 6 months ago − ⚑

I assume this is all well sourced of course.
△ ▽ • Share ›
freenewlife8 . > Lakshmima • 7 months ago ⚑ −

Yep, and turns out it was a known Occupy guy who organized this one, too. Jason Kessler.
WND did an expose' on his links to Occupy today. Here it is:
http://www.wnd.com/2017/08/...
△ ▽ • Share ›
Mark Tipton • 7 months ago ⚑ −

Maybe we could arrange a family reunion ... Clinton could go visit Putin again, with all the little red
buttons and yellow cake she and Soros can carry?
1△ ▽ • Share ›
Brian Christopher • 7 months ago ⚑ −

There is literally no reason to "speak out against Neo nazi white supremacists" since they are not
the ones causing problems in USA.....Antifa is
4△ ▽ • Share ›
tim necciai > Brian Christopher • 6 months ago ⚑ −

While antifa are certainly scumbags, a neo Nazi did just run his car into a crowd. And there
was that train stabbing. Let me guess - Soros funded false flags?
△ ▽ • Share ›
Brian Christopher > tim necciai • 5 months ago ⚑ −

The Neo Nazi ran his car into a mob of STATE SPONSORED TERRORISTS that
exist on behalf of the State to intimidate political dissidents. This was the exact
same situation in Germany before Hitler was elected. Read
As for the train stabbing....that guy was a crazy Bernie Sanders Supporter ....but if
the two men had not attacked him first they would not have gotten stabbed.
I dont get in fights because I am not looking for fights. But I will certainly defend
myself if necessary
△ ▽ • Share ›
Mark Tipton > Brian Christopher • 7 months ago ⚑ −

Just do not ask me to agree with them ... but yeah, I would fight to defend their right to free
speech and to peaceably demonstrate the same as I would for Antifa ...
1△ ▽ • Share ›

Alex you are stuck in the boomer mindset a little bit...we don't want diversity anymore...we dont
want to bullied by Jews anymore ....we dont care if you call us Nazis
1△ ▽ • Share ›
aname123 > Brian Christopher • 7 months ago − ⚑

I said nothing
△ ▽ • Share ›
ethernet ethernet • 7 months ago ⚑ −

With Jason Kessler and Mayor Michael Singer having “played their roles” in creating this media
spectacle, this report says, third up was Brennan Gilmore—who “magically and mystically” was
able to appear at the height of this created mob violence with a video camera in hand to record a
pro-fascist supporter ramming his car into a crowd of communists agitators—with Brennan
Gilmore, afterwards, being prominently interviewed by not only CNN, but every other anti-Trump
“fake news” media outlet in America too—and whose statements were, obviously, pre-planned.
2△ ▽ • Share ›
tim necciai > ethernet ethernet • 6 months ago ⚑ −

Yeah, just unbelievable that in a world where everyone has a camera in their pocket that
someone would film this. Magical indeed.
△ ▽ • Share ›
Xaviersp > ethernet ethernet • 6 months ago − ⚑

Oh my, the delusions...the guy is FROM Charlottesville, he is a progressive who would
naturally protest against neo-nazis, everyone on that day was filming, and you question
why he would be there "magically and mystically" filming? Delusions know no bounds on
this website...
△ ▽ • Share ›
freenewlife8 . > ethernet ethernet • 7 months ago − ⚑

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EXHIBIT G

3/10/2018 Breaking: State Department/CIA Orchestrated Charlottesville Tragedy » Alex Jones' Infowars: There's a war on for your mind!
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https://www.infowars.com/breaking-state-departmentcia-orchestrated-charlottesville-tragedy/ 1/35
BREAKING: STATE DEPARTMENT/CIA ORCHESTRATED CHARLOTTESVILLE TRAGEDY

The deep state is working overtime trying to divide America
Breaking: State Department/CIA Orchestrated Charlottesville Tragedy
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463 Comments Infowars 1 Login
Sort by Newest
VAHAWK • 7 months ago − ⚑
All BS all the time
△ ▽ • Share ›
Demos Last • 7 months ago − ⚑

Jews
△ ▽ • Share ›
spartan111 • 7 months ago − ⚑

Ever since the Democratic's (40 year) Dream to allow millions and millions of poor and
uneducated illegals from Latin America into the US to get Hillary elected and then give those
illegals amnesty to vote for them (to replace their aging and incarcerated Black voting block) went
up in smoke with President Trump's election, the Democrats now realize that they have to double
down on the Black voters to have any chance of winning. This is why Charlottsville was a set up
by the governor of Virginia to "gin" up the black vote for the 2017 Governor's race in Virginia this
year. It is so obvious. I hope the Republican wins there.
2△ ▽ • Share ›
Paulo Sérgio > spartan111 • 7 months ago − ⚑

You rigth and this problem is happing not only in the US but in all stabilized nations
inclusive in Brazil. In fact anybody here bear this anymore only the zumbis lefts in the
universities. The truth is that Trump is the last frontier against the Global communist. Every
good person needs to support him.
△ ▽ • Share ›
NancyDrew • 7 months ago ⚑ −

At least Trump can put out a public warning to us the targets at these staged but violent protests.
To steer clear. Millie Weaver sounded real afraid while reporting this "set up" she suddenly was up
against while trapped during her Charlottesville live report. What this woman says in the following
youtube is critical. If you watch/listen to nothing else, listen to her! https://www.youtube.com/wat...
1△ ▽ • Share ›
Alabama Mothman • 7 months ago ⚑ −

If Trump doesnt take action now, he will be the president that surrenders to a communist coup.
He needs to take to the air and declare these people terrorist. NOW.
2△ ▽ • Share ›
Publius Maximus > Alabama Mothman • 7 months ago − ⚑

He cannot take unilateral action, there is a reason we have 3 co-equal branches of
government. He needs Congressional support; right now, he does not have it (ironic in that
his party controls Congress, except when they don't).
△ ▽ • Share ›
Steve smith • 7 months ago ⚑ −

https://newspunch.com/hunga...
Soros has been exposed.....and yet nothing happens to him. He has been exposed as the money
man who has tried to undermine countries around the world, including the USA, for his own profit.
He is a citizen of the US and so why is it that he has not been arrested? Israel wants him, Russia
wants him and even Hungary wants him to stand trial for his criminal activities.
We know about the Clinton Foundation....why is it that Hillary, Bill and Chelsea have not been
arrested for their criminal activities?
I am sure the the Justice Department knows about all this criminality. It is time to do something
about it. Our country is being undermined by these treasonous scum and something needs to be
done Document 29-7 Filed 04/24/18 Page 5 of 36 Pageid#: 581
soon before it is too late
done soon before it is too late.
2△ ▽ • Share ›
Demos Last > Steve smith • 7 months ago − ⚑

Soros wants to kill you all. Exterminate you. By proxy. Like Jews always have.
△ ▽ • Share ›
neil sutherland • 7 months ago − ⚑

First, the five key actors in this staged event are George soros/Shultz, Hillary rodham/Clinton,
barak/barry plants. The leader of the fake right group, the leader of the fake left group [both
demographics are victims of elite pedophile, neither ‘supreme’ nor lives matter], the mayor and
governor who ordered police to foment violence, the driver of the ‘death’ ‘terrorist’ car, and the
innocent bystander who happened to be walking by to film and upload and be first interviewed,
are all George soros/Shultz, Hillary rodham/Clinton, barak/barry plants .
Second, this false flag, fake news, is not an isolated event meant to attack trump. One of the key
elements of propaganda, is repetition. The theme of this particular treasonous action, has three
aims: to scare americans, to divide americans, and to make americans ashamed of their
clown/joker com-‘patriots’.
1△ ▽ • Share ›
Seeker333 • 7 months ago − ⚑

If this is true, line them up in front of the firing squad. Disgusting POS.
1△ ▽ • Share ›
Ed • 7 months ago − ⚑
They infiltrated the occupy Wall Street movement also.
2△ ▽ • Share ›
sunnyd55 • 7 months ago ⚑ −

All of this crap comes to light after the election? Doesn't that seem strange to anyone else? What
are the powers that rule trying to protect or hide?
1△ ▽ • Share ›
renton willoughby • 7 months ago ⚑ −

Dismantle the CIA they have orchestrated the 911 False Flag attacks, the Gulf of Tonkin Incident,
and many other FALSE FLAGS.... they are EVIL! DRAIN THE SEWER!
5△ ▽ • Share ›
aj1575 > renton willoughby • 7 months ago ⚑ −

Just pause for a moment, and think. If the CIA did do all that, and has the power to do so,
don't you think that they also would have the power to have a prevented a Trump
presidency. Or even more simple, don't you think that they would shut down InfoWars, or
that Alex Jones would suddenly get a deadly disease because he spreads all those
"secrets" and hidden "agendas"? (Like in russia, where people who try to fight the "deep
state" or "hidden state" suddenly disappear, die, or get killed...
△ ▽ • Share › Document 29-7 Filed 04/24/18 Page 6 of 36 Pageid#: 582
PA George > aj1575 • 7 months ago − ⚑

That's taking it a bit to far,,,,no one expected that the people would vote Trump
in..As for the rest,,Plenty of people have "suddenly died" here in the USA,,,they got
the Hillary treatment. Now you have to know that the so called deep state members
include many traitor democrats and the Clintons are the very face of the deep state
in action.
△ ▽ • Share ›
aj1575 > PA George • 6 months ago ⚑ −

Oh well, I thought Obama was running the deep state after Trump took over
from him. But you sure got reliable sources that prove that it is run by the
Clintons.
(Actually the deep state is run by big money, rich people and companies are
paying the people who make laws (senate congress). Without big money,
nobody gets elected, and once elected, they pay it back with laws that help
the rich and the companies, and not people like you and me.)
△ ▽ • Share ›
Steve smith > aj1575 • 7 months ago − ⚑

Could it be that aj1575 is a CIA plant that tries to undermine the credibility of
anyone who speaks out?
It could be......
△ ▽ • Share ›
aj1575 > Steve smith • 7 months ago − ⚑

you are right, I'm an Agent. But we don't need to undermine InfoWars
credibility; InfoWars is actually one of our assets too. It helps to drive our
very hidden agenda much further....
No, just get real. Do you really think Alex Jones would still make TV-Shows,
if the conspirycy theories he spreads (basically, they are fantasy stories),
where true? If you believe Seth Rich got killed for handing over Clinton E-
Mails, what do you believe they would do to Alex Jones?
△ ▽ • Share ›
Steve smith > aj1575 • 7 months ago ⚑ −

Seth Rich died because HE was the leak. The demonic rats are as corrupt
as the GOP....Gay Old Pedophiles. The political system in this country is
controlled. Trump was the first president in a long time to go against the
system as it is......and that is why he is being attacked by the
ENEMEDIA....they are owned by the globalist bankers that want to run the
world.
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aj1575
Case 3:18-cv-00017-GEC > Steve smith
Document 29-7• 6 months
Filedago − ⚑
04/24/18 Page 7 of 36 Pageid#: 583
j g ⚑
Gay and Pedophiles like Milo you mean...
Yeah, Trump is running agains the system, but he has no alternate plan; the
plan is simply to be against.
But basically he is unfit for the job, there is not much he gets done.
If you like to change something, go after your congressman, they are the
real problem.
△ ▽ • Share ›

https://www.youtube.com/wat...
Just for YOU!!!!!!!!!!!!!!!!
Trump has gotten more done that is GOOD for the country than Obama,
Bush and Clinton ever did. As a matter of fact, those three presidents will go
down in history as the WORST presidents for freedom and liberty.
Of course you will not understand this.....it is too logical and you have
Trumo derangement syndrome brought on by watching the corporate owned
ENEMEDIA which is in a panic because most of the owners and many of
the ENEMEDIA itself are involved in pedophilia and so they are stuffing your
empty head with made up nonsense.
The country was started by less than 3% who were willing. The country will
be saved by the millions who voted for PRESIDENT DONALD J. TRUMP.
△ ▽ • Share ›
aj1575 > Steve smith • 6 months ago ⚑ −

Then please tell me the biggest achievements of Trump as the president.
What did he do so far?
△ ▽ • Share ›

He got rid of TPP.....He is getting us out of NAFTA......He is cutting
regulations so that business can thrive......He is showing the ENEMEDIA for
the Anti American communist sympathizers that they are.......He has given a
whole lot of people hope that the USA will not become part of the plans for
globalization. He through his justice department is going after the
pedophiles. His justice department is going after criminal politicians like
Debbie Wasserman Schultz....Hillary and Bill Clinton......Barack
Obama......and many more...He has accomplished more positive things in
his first 8 months than Obama was able to bring about failure in his first 8
months. We as the USA were able to just barely survive Obama......Trump is
making progress in getting rid of Obamaism.
He is doing what I and many millions more voted for him to do........He is
goingDocument
to build the29-7
wall Filed
He is04/24/18 PageHER
going to LOCK 8 of 36
UP Pageid#: 584
He is in the
going to build the wall.....He is going to LOCK HER UP......He is in the
process of MAKING AMERICA GREAT AGAIN......
But I guess you are not for any of that.........so sad that you are so negative.
△ ▽ • Share ›

Sorry for the late answer,
TPP is a two sided sword, the upside may be some benefits for Jobs at
home, on the downside, it gives China to opportunity to strengthen its
position on the pacific rim. The country with the better economic
relationships, also influences the politics (and this could be China now).
Nothing happened to NAFTA so far, so can not book for Trump. Cutting
regulations has also two sides, it makes it easier to do business, but it
makes it also easier for them to damage the enviornment, and the health of
its workers.
The wall is still in doubt (and I personally think, not much will be built in the
next 4 years. He is definitly not going to look Hillary up (and neither
Obama).
We can have a talk in two years again, and see what happened (tax reform,
Obama care repeal, infrastructure bill...)
△ ▽ • Share ›

TPP is a one way highway. It made the US a poor competitor and shackled
us with all kinds of nonsense.
It is not up to Trump to lock up these criminals....it will be up to Jeff

Sessions and the congress. Jeff Sessions already has the support of the
demonicrats since Trump made it seem that he wanted him gone. Now that
Sessions has demonicrat support thanks to Trump attacks......Sessions will
go after them.....he has to as there will be a civil war if he does not.
△ ▽ • Share ›

Dream on, Session will never jail Hillary or Obama up.
As for TPP, as I said, it is two sided. I'm not sure if it would have been such
a bad deal for the USA, maybe some renegotiation would have been
neccesary. But now, the US leaves those countries to China, who is more
than happy to widen their sphere of influence.
Steven Bannon is right to fear a future where China dictates the rules, like
the USA did for the the last 20-30 years, but cancelling TPP just gave a
boost to China.
△ ▽ • Share ›

Never? You did say never didn't you? If there is one thing I have learned in
life and
Case 3:18-cv-00017-GEC that is never
Document 29-7to Filed
say never
04/24/18 Page 9 of 36 Pageid#: 585
life and that is never to say never.
President Trump is way different from any other president in history.....He

actually is doing what he said he would do.
To save the country and his presidency.....President Trump will do what is

needed......and that includes putting those two in prison.
△ ▽ • Share ›

Are you so sure about that, that you are willing to make a bet?
How much money is it worth to you?
And btw, america did not only survive Obama, he was also responsible for
one of the longest job growth streaks in US history.
△ ▽ • Share ›

I don't need to bet........it will happen. How do I know? Because the wheels
are already turning.........and I don't want to take advantage of you for being
ignorant of certain things........have a nice life......what is left of it.
△ ▽ • Share ›

Money is not a problem for me. What if it does not happen until reelction is
up; will you still cheer for Trump (even if he breaks his promises?)
△ ▽ • Share ›

What if my aunt had balls? Would she be then my uncle?
What if we would have won the lottery? Would we care about any of this?
What if...what if....what if....
△ ▽ • Share ›
Alan Gross • 7 months ago ⚑ −

How many people are in The State Department and C.I.A. and How many people are in the rest
of The United States?
△ ▽ • Share ›
Tony Gersh • 7 months ago ⚑ −

This information is the sort of news Daily Stormer was reporting on two weeks ago before being
taking off the internet. This is why we need free speech. Hopefully this does not become another
nothing burger.
1△ ▽ • Share ›
White Phosphorus • 7 months ago − ⚑

The mayor of Charlottesville is a Jew.
Charlottesville Police Come Forward: We Were Told to “STAND DOWN” to Ignite Race War
(Video)
“We wanted to do our job and keep the peace. But these mother******s in charge really want to
destroy America.”
http://countercurrentnews.i...
4△ ▽ • Share ›
Olavo de Carvalho • 7 months ago − ⚑

Think for just one minute. Which conservative Christian or pro-Trump leader
would be interested in giving his movement the looks and the aestethics
of a nazi rally, virtually expelling from its ranks all non-white
supporters? Inversely, which leftist leader would be interested in
portraying all conservatives as nazis? The first principle of criminal
investigation is "Cui bono" (google for a translation).
9△ ▽ • Share ›

The real truth is that anti white Infowars Jew Steve Pieczenik claims "his group" shut down the
upcoming Richard Spencer speaking engagement in Florida. Steve also backed the Jewish group
in Montana that tried to run an extortion scheme against Richard's mom trying to force her
through intimidation to sell her property because of her sons political views. Steve also claims he
worked with the FBI/SPLC to go after white people who organize politically for their own interests.
Steve Pieczenik is a Jew who worked under Kissinger running Psychological Warfare campaigns.
△ ▽ • Share ›
Disqus-helpsGOVTbreaklaws&kill • 7 months ago − ⚑

gruber...
the Obamacare architect
has been awarded a get-out-of-jail-free-card
for stealing money and lying to America.
.
2△ ▽ • Share ›
aname123 • 7 months ago − ⚑

The cointelpro cat covered this days ago
△ ▽ • Share ›
No Warning Shots • 7 months ago − ⚑

Soros, Hitlery, and Obama committing insurrection.Indict these pigs NOW!
2△ ▽ • Share ›
Case 3:18-cv-00017-GEC Document

Tom > No Warning Shots • 7 months29-7
ago − ⚑
Filed 04/24/18 Page 11 of 36 Pageid#: 587
Tom > No Warning Shots 7 months ago ⚑
You know ur a bonafide brainwashed infotard when you bring up and start saying Soros,
Hilliary and Obama names in your message posts.
1△ ▽ • Share ›
Susan Johnston > Tom • 7 months ago ⚑ −

You know you are brainwashed by corporate media when you criticize a person for
saying Soros, Obama and Clinton in a comment on an article about Soros, Obama
and Clinton...
2△ ▽ • Share ›
Founding Fathers 1776 > Tom • 7 months ago − ⚑

You know you're a useless idiot when you defend Soros
4△ ▽ • Share ›
renton willoughby > Founding Fathers 1776 • 7 months ago ⚑ −

The only news I want to hear about Obama, Hillary , Podesta, Soros etc. is
that their funerals will be a private affair!
3△ ▽ • Share ›
Lee • 7 months ago − ⚑

you guys are so stupid. Get a grip, get help
2△ ▽ • Share ›
Tom > Lee • 7 months ago − ⚑

You can't fix stupid infotards, if they are stupid today, then they're still gonna be stupid
tomorrow too, why even suggest to them getting help, real infotards are beyond help.
1△ ▽ • Share ›
the postman > Tom • 7 months ago − ⚑

So where do you get your news?
1△ ▽ • Share ›
the postman > Lee • 7 months ago − ⚑

How so?
△ ▽ • Share ›
The Force • 7 months ago − ⚑

Brennan's liitle jihadi running around playing parts.
ISIS, Antifa and SPLC's White Supremacists. All contracted labor for media mind control
operations and it's about time they got exposed.
Only sane liberal is an ex-liberal.

1△ ▽ • Share ›
Caius Keys • 7 months ago − ⚑

Charlottesville teaches me one important lesson --
Democrats are even worse than I thought,
And I already thought they were the devil...

6△ ▽ • Share ›
Cindy Bruce • 7 months ago ⚑ −

Isn't it interesting how Sessions faked being above reproach by recusing himself from the Russia /
Trump conspiracy theory.
But when Trumped publicly expressed his displeasure with and humiliated Sessions, Sessions
said he would continue working for the president rather than recuse himself. Why? Because
Sessions knows if Trump fired him the backlash may be severely damaging and perhaps even
unrecoverable for Trump.
Sessions has to be a mouse and a turncoat and bought and paid for deep state operative. He has
to be.
Sessions recused himself when he shouldn't have becuase it benefited the deep state (and hurt
Trump) and he didn't recuse himself when he should have because once again it benefited the
deep state (and hurt Trump).
It doesn't get any plainer than that. Fire his wrinkly ass and prosectute him.
1△ ▽ • Share ›
AlphaLady777 • 7 months ago − ⚑

Everyone is being played for fools - while the rich laugh all the way to their billion dollar bank
accounts. Watch Noam Chomsky's documentary: https://www.youtube.com/wat...
1△ ▽ • Share ›
aname123 > AlphaLady777 • 7 months ago − ⚑

Noam Chomsky is a 911 denier. He's irrelevant
1△ ▽ • Share ›
ah.... • 7 months ago − ⚑

Kessler, agent provocateur !
3△ ▽ • Share ›
Diane Hinkle • 7 months ago − ⚑

In the time of chimpanzees, I was a monkey.
1△ ▽ • Share ›
Mark Tipton > Diane Hinkle • 7 months ago − ⚑

The one that is not Glenn!
△ ▽ • Share ›

.
.
soros rent a riot - rent a mob ads
running in Craigslist
indicate this is a pre planned staged crisis-actor false flag Hegelian dialectic event.
.
.
5△ ▽ • Share ›
Timman • 7 months ago ⚑ −

I had some suspicions raised when I read that the ACLU was the law firm for the protest
organisers. There were 3 groups that filed for right to protest in the city on the same day, all
asking for basically the same area of the city. The federal judge said they were to be kept 2 miles
apart. Now we hear they all possibly came to the same area in the city.
2△ ▽ • Share ›
the postman • 7 months ago − ⚑

EVERYONE NEEDS TO SEE THIS!
As told by a woman who was there on the scene in Charlottesville ...
PEOPLE FROM BOTH SIDES OF CHARLOTTESVILLE RIOT ARRIVED IN THE SAME

CHARTER BUS CONVOY!!!
Re-posting this from 3 hours ago. Thanks Texxtyn!
https://www.facebook.com/mr...
5△ ▽ • Share ›
The Force • 7 months ago − ⚑

Vote out as many Democrats as possible.
3△ ▽ • Share ›
Malsikcuf • 7 months ago − ⚑

OK, so when are we gonna start seeing some justice for these POS traitors?
△ ▽ • Share ›
Milly Vanilly • 7 months ago − ⚑

Soros is a CIA ASSet....He's been using their tactics over in Europe for quite a while.
The CIA is ONE tentacle that Keeps the Military Industrial Complex FLOODED with ILLEGAL
money through ILLEGAL wars & by PROTECTING ALL the TRUE criminals ( Soros, Obama,
Clintons, FBI Muppets Mueller & Comey ETC.) They CONTROL/Direct ALL the Alphabet
Agencies as well as laundering their drug money through the Deep State & Rothschilds Banks.
If President Trump is not Compromised/coerced in SOME Way, he must BEAT these Psychopaths
Head to Head and ELIMINATE them COMPLETELY but he is surrounded by them.
4△ ▽ • Share ›
Mark Tipton > Milly Vanilly • 7 months ago ⚑ −

It would be unwise to discount the role that the Bush family has played in this mess either.
Papa Bush was in charge of the CIA for a time, and actually increased the flow of drugs,
arms and ill-gotten gains into the US through little airports in Arkansas ... thus the
Bush/Clinton connection.
Think Iran Contra.

8△ ▽ • Share ›
Milly Vanilly > Mark Tipton • 7 months ago ⚑ −

Agreed...the Bush Crime Family IS also a big piece for helping to organize a LOT
of what is taking place currently but they escaped a lot of the scrutiny. They (and
their partners) got away with TRILLIONS in Stolen, laundered, drug and FALSE
Insurance claim money. All the False flags & MSM have drawn attention away from
them but believe me, it is NOT forgotten.
1△ ▽ • Share ›
Oscar Madison > Mark Tipton • 7 months ago ⚑ −

Jimmy Carter fired pappy and over 800 "rouge agents" the plotted and got revenge
on a decent man. That cabal has not relinquished power. Prescot was hitlers
Banker, brown bros harroman, Hamburg American lines. Paperclip, operation
gehlen....on and on. Redschield faction agin a Rockefeller type cabal. 7 billion
useless eaters in the middle.
Do they need us to sustain their empires?
Do we need them for our existence?
Day will come when you will have a choice.
Logos or satan
2△ ▽ • Share ›
Surfer Joe • 7 months ago − ⚑

Talk about need to expedite the cleaning or draining of the swamp--Tillerson/Sessions and the
Prez need to get out the Clorox and go to work NOW---
△ ▽ • Share ›
Larry Underwood • 7 months ago ⚑ −

Control freaks have to control everything including every protest that might turn the tide against
their agenda. Unite the Right is an empowerment message (even the Left has used it). They can't
have an empowered opposition. They are here to destroy and delegitimize. So they hijacked it,
refused to call it by its name in the media, and instead called them all nazis which is a
psychological trigger word to instantly make you repulsed (simple Pavlov's dog conditioning) and
destroy all credibility that "Unite the Right" innately has, controlled the rally at the top with their
own people, and at that point they can get away with anything. They profit immensely from this.
Unless we become as control freak as they are, they will continue to do this until Trump is out of
office and they have political control once more.
△ ▽ • Share ›

soros Craigslist ads for rioters and protests against trump .
2△ ▽ • Share ›

obama's insider computer programmer was guccifer 2.0 ( RUSSIA Did IT
patsy) manufactured by DNC to draw attention away from seth rich murder
COVER UP
△ ▽ • Share ›

pelosi gives out record number of Obamacare tax avoidance waivers
to California constituents who own night clubs and restaurants and buy
wines from her vineyards.
2△ ▽ • Share ›
BibiRibozo • 7 months ago ⚑ −

I thought it was Obama and Soros running things out of a bath house? So good, you finally got it
right, so what is Trump doing about it?
△ ▽ • Share ›
Texxtyn • 7 months ago − ⚑

coup in progress. Panetta and Privately controlled Military. Bush Obama Clinton Group
△ ▽ • Share ›

the unsustainable cost of deep state taxpayer funded govt employee labor union no-bid
contractors
http://articles.latimes.com...
△ ▽ • Share ›
Reckonings • 7 months ago ⚑ −

Yep, I'm a deep state spook and all my friends Ive known for years that were there with me were
spooks... It was all staged. I'm actually friends with antifa and black lives matter. We were using
fake blood and stuff. We are good huh? You frigging idiots.
△ ▽ • Share ›

silent owner...senator hagel owns diebold dnc voting machines ..
Case △ 3:18-cv-00017-GEC
▽ • Share › Document 29-7 Filed 04/24/18 Page 16 of 36 Pageid#: 592
△ ▽ • Share ›
Queen Latifah > Disqus-helpsGOVTbreaklaws&kill • 7 months ago ⚑ −

even the New York Times suspected Hagel of rigging voting machines to help Bush, back
before Hagel befriended Obama. Then Hagel switched sides. We actually had 4 rigged
elections, courtesy of Hagel, 2 Bush & 2 Obama elections. They thought they rigged
Hillary's election too, but to their surprise learned they hadn't rigged it quite enough. After
they stole 3 million plus votes, it never occurred to them, Hillary could still lose. Hagel
rigged his own original election to the Senate, then began rigging other elections.
△ ▽ • Share ›
Disqus-helpsGOVTbreaklaws&kill > Queen Latifah • 7 months ago − ⚑

The Best Democracy Money Can Buy - A Greg Palast film
△ ▽ • Share ›
inabunker • 7 months ago − ⚑

The minute I found out Kessler "organized" the Unite the Right, it was fishy. Here we have
Kessler, an occupy wall street and Obama supporter, organizing something so 180 to that mind
set? Then we have a democratic mayor and democratic governor, McAuliffe, ordering a stand
down of the police? McCauliffe was head of the DNC and is corrupt as the day is long:
http://www.cnn.com/2016/05/....
http://dailycaller.com/2016...
3△ ▽ • Share ›
Jennifer Anzalone • 7 months ago − ⚑

TAKE A GOOD LOOK AT THE CAR.
△ ▽ • Share ›
the postman > Jennifer Anzalone • 7 months ago + ⚑

Charlottesville Ambushed by people that got off bus from both sides
bOTH SIDES IN CHARLOTTESVILLE ARRIVE IN SAME BUS CONVOY
LIVE CHAT WITH MY FRIEND IN CHARLOTTESVILLE, VA
iMPORTANT INTERVIEW DON'T MISS. DISREGARD SLOW START.

3△ ▽ • Share ›
the postman > Texxtyn • 7 months ago ⚑ −

Thank you for posting. I just watched it. All I can say is WOW and you absolutely ROCK!
1 △ ▽ • Share ›

00000 BOTH SIDES IN CHARLOTTESVILLE ARRIVE IN SAME BUS CONVOY 0000
LIVE CHAT WITH MY FRIEND IN CHARLOTTESVILLE, VA
iMPORTANT INTERVIEW DON'T MISS. DISREGARD SLOW START.

3△ ▽ • Share ›
@DrChzBrgr • 7 months ago − ⚑

Yep I truly believe Charlottesville was staged.
Some of it was real some of it was fake, which is why you can't prove it.
I've questioned a couple AltRight "leaders" about it on twitter via DM and they block me.
1△ ▽ • Share ›
Koroviev,Behemoth&Woland LLP • 7 months ago − ⚑

That's every bit as disingenuous as the support the Clintons got from from the Entertainment
Industry,
When Bubba & the Sea Hag went to the White House they sent two of their Arkansas "friends" to
set up a blackmail operation in the guise of a Hollywood Production Company, just like they did
when they got their hands on the "dirty dossiers" about the freaks on Capitol Hill.
Bubba's been blackmailing people since the day he caught his bother Roger, whacking off.
2△ ▽ • Share ›
Waspinator Prime • 7 months ago − ⚑

Of course it was a CIA op.
Another National Enquirer inspired article courtesy of Info/Jones.

lmfao
△ ▽ • Share ›
powerxq • 7 months ago − ⚑

How many Nazis and White Supremacists do you know that go around the country dragging
identical Tiki Torches along with them, just on the off-chance there will be a convenient
demonstration for them to attend.
Other than in the Ukraine.

5△ ▽ • Share ›
Koroviev,Behemoth&Woland LLP > powerxq • 7 months ago ⚑ −

In six and a half decades, I never seen or met a genuine Nazi or a Klansmen. Of course,
I've had a lifetime of Hollywood indoctrination trying to convince me that all poor Christian
whites are idiots who have sex with their sisters.
Antifa and BLM are the end result of decades of propaganda puked up by Christian hating
Hollywood writers, and the idiot teachers who've been trained in the Bill Ayers model of
anarchy.
3△ ▽ • Share ›
Tommy James > powerxq • 7 months ago ⚑ −

Walmart is having a summer-end sale on Tiki torches right now. A secret signal meant to
trigger the alt-right revolution?
2△ ▽ • Share ›
BunnyRabbit • 7 months ago − ⚑

That's a bunch of Chobani
△ ▽ • Share ›
RT • 7 months ago − ⚑
Would it be considered too radical to suggest that these people in charge of the "deep state"
connected to the Charlottesville tragedy be put in jail?
8△ ▽ • Share ›
vincent > RT • 7 months ago − ⚑

no. not radical. but lets give few some sentences to give a message
time for local people to set local charges, and then make it national
time to set the standard

1△ ▽ • Share ›
shagstar > RT • 7 months ago − ⚑

those asshole deep state scumbags, own the jails for now!
2△ ▽ • Share ›
Glen > RT • 7 months ago − ⚑

yeah, way too radical. thats hate speech.
1△ ▽ • Share ›
RT > Glen • 7 months ago − ⚑

Why would it be considered "hate speech"?
△ ▽ • Share ›
Glen > RT • 7 months ago − ⚑

probably to shut down websites and jail people they dont agree with.
1△ ▽ • Share ›
Nunya Beezwax • 7 months ago − ⚑

Can you post flow charts or timelines with links to each person/event as a kind of footnote? It
makes it easier to show people. There's so much happening at once, and I can't have an hour
long debate with every leftist I talk to.
1△ ▽ • Share ›
This comment was deleted. +

the soros Craigslist ads .recruiting rent a mob paid rioters
rioters funded by covert planned parenthood & HUD tax dollar money is 1 indicator the whole
crisis was staged
△ ▽ • Share ›
Disqus-helpsGOVTbreaklaws&kill • 7 months ago ⚑ −

CIA Document #1035-960
immediately shout conspiracy theory ..to silence anyone who questions an official story told by
govt.
2△ ▽ • Share ›
the postman > Disqus-helpsGOVTbreaklaws&kill • 7 months ago − ⚑

It's my understanding that the CIA actually coined the term "conspiracy theory".
△ ▽ • Share ›
Disqus-helpsGOVTbreaklaws&kill > the postman • 7 months ago − ⚑

yes.... it is their CIA document # 1035-960
△ ▽ • Share ›
NeoclassicalShredder • 7 months ago − ⚑

Its becoming more evident by the day that whole thing was staged. The most disturbing part
though is how the objective was achieved by the Soros/Deep State Clan. All Conservatives are
now branded racists, Antifa is stronger now in the court of public opinion, the MSM was able to
brand President Trump a racist, our historic statues across this Nation are falling like Domino's,
the average Joe along with the masses bought into this crap, and the Deep State now has their
finger on that button...Anytime they want to push it from here out, they will have maximum
impact....and they know it..
2△ ▽ • Share ›
@DrChzBrgr > NeoclassicalShredder • 7 months ago − ⚑

Keep spreading comments like this. Keep waking people up.
△ ▽ • Share ›
Disqus-helpsGOVTbreaklaws&kill • 7 months ago ⚑ −

legalized corruption..,
taxpayer funded unaccountable govt employee labor unions working against America to protect
Hilary Clinton .
Case
△ 3:18-cv-00017-GEC
▽ • Share › Document 29-7 Filed 04/24/18 Page 20 of 36 Pageid#: 596
△ ▽ • Share ›
Diane Hinkle • 7 months ago − ⚑

Why do you ignorant people buy into this? We all know who's responsible. White supremacist
groups and their leader in the white house. He is the one dividing America. And he actually thinks
he can win re election. He won't even last a full term
1△ ▽ • Share ›
Guy W Jordan > Diane Hinkle • 7 months ago ⚑ −

Let's see, Trump got an award from Jesse Jackson for hiring minorities. Trump spent the
majority of his life as a liberal Democrat, and, frankly, I don't think he changed anymore
than the guy who organized the UnitetheRight rally in Charlottesville who was also a liberal
Democrat until--I guess--he was knocked off his horse by lightning on his way to
Damascus on election night 2016.
Come on, you know Trump isn't a racist or a white supremacist. Russia just didn't work.
Why don't you wait until he trips over a conflict of interest with his businesses, or someone
finds one of those old DECLINED PROSECUTION investigations of him that MUST exist
somewhere in the bowels of the FBI's white collar section, the statute of limitations hasn't
run out, and they make something of it. That would be at least Constitutional. Let's not go
as far as martial law, please, and we don't need your spy agency and Establishment
generals pulling any 1963 style coups.
△ ▽ • Share ›
Diane Hinkle > Guy W Jordan • 7 months ago − ⚑

Kiss my hoo-haw, Boris!!
△ ▽ • Share ›
Guy W Jordan > Diane Hinkle • 7 months ago − ⚑

Oh, you have no answer for that one. Okay. I understand.
△ ▽ • Share ›
BB > Diane Hinkle • 7 months ago − ⚑

Russia! Russia! Russia!
△ ▽ • Share ›
AllRoadsLead2Rome > Diane Hinkle • 7 months ago − ⚑

This was going on in Obama's administration as well, you are just to biased to see it.
△ ▽ • Share ›
gazoo3 > Diane Hinkle • 7 months ago + ⚑
the postman > Diane Hinkle • 7 months ago ⚑ −

In the ignorance competition (where most ignorant wins), the right can't hold a candle to
the left. (edit: in other words, the left is dumb as sh_t)
△ ▽ • Share ›
Diane Hinkle > the postman • 7 months ago + ⚑
Mitchell > Diane Hinkle • 7 months ago − ⚑

You're just stupid if you believe that.
1△ ▽ • Share ›
Diane Hinkle > Mitchell • 7 months ago − ⚑

Your avatar is a symbol of terrorism!!
1△ ▽ • Share ›
Mitchell > Diane Hinkle • 7 months ago ⚑ −

I'm not the one going around attacking people, smashing windows of stores,
vocally attacking and threatening the law trying to keep the peace.
1△ ▽ • Share ›
Slimon3.0 > Mitchell • 7 months ago − ⚑

No, you're right. People like you are going around killing people. Big
difference.
△ ▽ • Share ›
Mitchell > Slimon3.0 • 6 months ago − ⚑

I've not killed anyone, unlike the ones killing cops and such. THAT'S the
difference.
1△ ▽ • Share ›
Diane Hinkle > Mitchell • 7 months ago − ⚑

Eat my bowel movement, you terrorist.
△ ▽ • Share ›
Mitchell > Diane Hinkle • 6 months ago − ⚑

Have a nice day you pink-o commie.
△ ▽ • Share ›
NeoclassicalShredder > Diane Hinkle • 7 months ago − ⚑

You are one gullible phuk....Wake up
△ ▽ • Share ›
gazoo3 > Diane Hinkle • 7 months ago ⚑ −

Charlottesville Is a completely fake hoax in which nobody died. You should stop believing
th MSM T i Document
't i t 29-7 Filed 04/24/18 Page 22 of 36 Pageid#: 598
the MSM. Trump isn't a racist.
1△ ▽ • Share ›
the postman > gazoo3 • 7 months ago ⚑ −

I'm willing to bet that someone died but I'm certainly not willing to bet that the driver
was representative of even 1% of people on the right and the video seems to
confirm that he was a plant by the left.
△ ▽ • Share ›
gazoo3 > the postman • 7 months ago ⚑ −

The driver was not the guy who was arrested. Everything about the victims
is fake and fishy. YouTube: "Charlottesville Hoax". These a video of
someone shputing "cut"like a movie director. The footage of the day's
events is littered with Freemasonic symbols and code numbers. Not the
least of which were the license plate of the Dodge and the supposed driver's
mother's car.
△ ▽ • Share ›
Diane Hinkle > gazoo3 • 7 months ago + ⚑
Diane Hinkle > gazoo3 • 7 months ago + ⚑
AllRoadsLead2Rome • 7 months ago ⚑ −

The 65th Bilderberg Meeting, held
earlier this month, from 1-4 June at Marriott Hotel in Chantilly,
Virgina, was noteworthy on a number of counts, starting with the
presence of four members of the Trump Administration at a gathering
where it was widely assumed that both the policy direction and
legitimacy of Trump’s presidency would have been hotly contested. This
represented a deviation from the poor attendance by senior US officials
at Bilderberg during Obama’s second term – during the previous four Bilderberg meetings the
Obama Administration sent just one official in 2015. For a number of alternative news outlets,
particularly Alex Jones’ Infowars,
the presence of the four Trump Administration officials presented a
unique ideological challenge given their previous incantations against
Bilderberg as a hot-bed of intrigue by the elitist supporters of
globalism, and their strong support of Trump, whom they had exalted as
the globalist giant-slayer. The Infowars solution to this dilemma was to hold a poorly attended pro-
Trump rally outside the Marriott.
While the overall turnout from the anti-Bilderberg protestors at Chantilly was, as Intellihub noted
“substantially lower than in 2012 when the Bilderbergers last met at the very same hotel”, the
alternative media and key activists were still well represented. In addition to the Infowars crew of
David Knight and Owen Shroyer (incredibly, despite the convenience of the US location, Alex
Jones
Case failed to turn up with
3:18-cv-00017-GEC his bullhorn)
Document 29-7there was04/24/18
Filed Luke Rudkowski
Page 23fromofWe
36 Are Change599
Pageid#: Dan
Jones failed to turn up with his bullhorn) there was Luke Rudkowski from We Are Change, Dan
Dicks from Press For Truth, Jeff Berwick from The Dollar Vigilante, Mark Anderson of the
American Free Press, Loose Change producer Jason Bermas (who got into an argument with
Jack Posobiec over Trump’s relationship with Bilderberg), Leigh Stewy from Independent Citizen
News, Conspiracy Cabbie TV, Lulz Machine, and Chris Dorsey the self-styled “commander” of the
Virginia Militia.
△ ▽ • Share ›
AllRoadsLead2Rome > AllRoadsLead2Rome • 7 months ago − ⚑

http://www.conspiracyarchiv...
△ ▽ • Share ›

.
mask wearing taxpayer funded USA govt employee labor union rioters...
.
△ ▽ • Share ›
edward_lobb • 7 months ago ⚑ −

Some kind of Doppler radar jamming is aimed at your live b'casts, Alex. Your's is the only audio
on a wide audience spectrum that is hard to listen to. I have a good audio system. It's set up to go
gravely - or is it your mike? I've produced audio - it's definitely coming from external sources.
△ ▽ • Share ›
Grayson2401 • 7 months ago ⚑ −

I will save myself the time by not watching the video and assume it has no evidence to back this
claim.
△ ▽ • Share ›
Dave • 7 months ago − ⚑

If Trump doesn't indict Hillary, the WTF!!!! NOBODY SHOULD OBEY THE LAW!!! F*CK IT
3△ ▽ • Share ›
Publius Maximus > Dave • 7 months ago − ⚑

Trump cannot indict anyone; he is not a prosecutor....all he can do is call for an
investigation, and hope Congress complies...
△ ▽ • Share ›
Dave > Publius Maximus • 7 months ago − ⚑

EXCUUUUSSEEE ME...WOW, LIGHTEN UP DUDE, SMOKE A JOINT
△ ▽ • Share ›
Publius Maximus > Dave • 7 months ago − ⚑

Uhhhh...right....perhaps you should first, stop yelling (lighten up), and
second, try not to post something inane and expect no one to reply....
△ Document
Case 3:18-cv-00017-GEC ▽ • Share ›29-7 Filed 04/24/18 Page 24 of 36 Pageid#: 600
Dave > Publius Maximus • 7 months ago − ⚑

HEY I GOT 2 UP-VOTES FOR THAT COMMENT - SO F*CK YOU
△ ▽ • Share ›
Tommy James > Dave • 7 months ago − ⚑

Bill and Hillary are the god parents of Trump's kids -- no way does the Big D indict the
those two hillbilly slobs.
△ ▽ • Share ›
Dave > Tommy James • 7 months ago ⚑ −

THEY ARE GIVING HILLARY A PLEA BARGAIN AND IF SHE DOESN'T ACCEPT
THEN IT'S OPEN SEASON ON THE QUEEN OF CORRUPTION
△ ▽ • Share ›
Like White > Dave • 7 months ago − ⚑

The same should be said due to the government being at war against God, against
freedom of assembly, the government is against free speech, the government is against
the right to pursue happiness, pro abortion, pro LGBT, EPA, imminent domain, voting laws,
etc. The judges are like enforcers for the mafia. The judges are criminals
1△ ▽ • Share ›
Drink-More-Die-Young > Dave • 7 months ago − ⚑

Go start a Petition on Sessions to do is JOB and carry out Trump's agenda that is on
Sessions sleeve.
1△ ▽ • Share ›
Kirschwasser • 7 months ago − ⚑
"The deep state is working overtime trying to divide America"
Roman Empire:
"The Romans also used the classic tactic of ‘divide and rule’. As long as the tribes were
divided, the Roman army was the strongest force in Britain.
And while they were fighting each other, the tribes were unlikely to team up and fight the
Romans."
2△ ▽ • Share ›
AllRoadsLead2Rome > Kirschwasser • 7 months ago − ⚑

Good post. Can you guess with those same tactics whos in control today?
△ ▽ • Share ›
Dave • 7 months ago ⚑ −

I WANT TO SEE HILLARY IN AN ORANGE PANT SUIT WITH SHACKLES!!!!!!!!!!!! WHEN!!!!!!!!!1
△ ▽ • Share ›
Missy > Dave • 7 months ago ⚑ −

"She went through a lot and suffered greatly in many different ways.”
"It’s just not something that I feel very strongly about.”
Doesn't sound like the Great Pumpkin wants anything to do with locking her up. Just one
of the many useless chants you lemmings believed.
△ ▽ • Share ›
Libs sux > Missy • 7 months ago − ⚑

Troll alert . Or dumbass Alert either one
△ ▽ • Share ›
Drink-More-Die-Young > Libs sux • 7 months ago − ⚑

Trolls are generally smarter than this dumb ass Missy Dave
1△ ▽ • Share ›
Missy > Libs sux • 7 months ago − ⚑

Quoting Trump makes me a troll?
△ ▽ • Share ›
Jrobby > Missy • 7 months ago − ⚑

Jerko Fucko
Why post where you are hated? Because you are getting paid to.
1△ ▽ • Share ›
Dave > Missy • 7 months ago − ⚑

Well she is organizing a resistance FORCE with SOROS and Trump better do
something about it. Hillary is FIGHTING BACK NOW. SHE NEEDS TO BE
PROSECUTED and FAST.
What about THIS pussy PLEA bargin she was given
1△ ▽ • Share ›
Missy > Dave • 7 months ago − ⚑

Trump is NEVER going to prosecute Hilary. He never intended to it just
sounded good at the rallies.
LOCK HER UP!!
BUILD THE WALL!!
...
Sound familiar?
△ ▽ • Share ›
Dave > Missy • 7 months ago − ⚑

The wall is getting built.
Hillary will go down one way or another.
2△ ▽ • Share ›
Tommy James > Dave • 7 months ago − ⚑

Ha ha - you said she'd go down. Huma?
△ ▽ • Share ›
Dave > Tommy James • 7 months ago − ⚑

Yeah, maybe just Huma, that's why she got the job
△ ▽ • Share ›
Missy > Dave • 7 months ago − ⚑

Lol 😂
△ ▽ • Share ›
Drink-More-Die-Young > Missy • 7 months ago ⚑ −

Trump not the AG, don't you think you should be breathing down Sessions
neck!
△ ▽ • Share ›
Missy > Drink-More-Die-Young • 7 months ago ⚑ −

He said himself he is not interested in prosecuting Hilary. You've been had.
△ ▽ • Share ›
Drink-More-Die-Young > Missy • 7 months ago ⚑ −

Too bad you weren't one of Hillary's rape victims like Cathy O'Brien, you be
singing a different tune. Now you can Go F. Off
1△ ▽ • Share ›
Missy > Drink-More-Die-Young • 7 months ago − ⚑

Are you denying that he said that he didn't want to prosecute Hilary?
△ ▽ • Share ›
Drink-More-Die-Young > Missy • 7 months ago − ⚑

Here you think Trump really meant that.
△ ▽ • Share ›
Missy > Drink-More-Die-Young • 7 months ago ⚑ −

So just to be clear, we are not supposed to believe the words coming from
the president of the USA's own mouth? Really? That's the argument you're
going
Case 3:18-cv-00017-GEC with? Sad.29-7 Filed 04/24/18 Page 27 of 36 Pageid#: 603
Document
go g t Sad
△ ▽ • Share ›
largejack > Missy • 7 months ago − ⚑

Not as much as those who disagreed or tried to expose her suffered.
1△ ▽ • Share ›
largejack > Dave • 7 months ago − ⚑

Ughhh! What a revolting thought? You clearly have no taste?? lol
△ ▽ • Share ›
John Henke > Dave • 7 months ago − ⚑

Trump needs to get a real AG if that's going to happen.
2△ ▽ • Share ›
Drink-More-Die-Young > John Henke • 7 months ago ⚑ −

I think Trump should of picked a young ATTY with a high IQ that had balls of steel,
not afraid of death threats from the Deep State to been his AG.
Sessions showing his yellow streak.

1△ ▽ • Share ›
Jrobby • 7 months ago ⚑ −

The Deep state is in it's death throws, but have yet to completely realize it. They think they will
live.
△ ▽ • Share ›
John Henke • 7 months ago ⚑ −

Trump better get to draining that swamp he's always talking about. Of course the whole thing was
orchestrated, all except the crazy guy in the car. I think that took them all by surprise.
1△ ▽ • Share ›
Drink-More-Die-Young > John Henke • 7 months ago − ⚑

Trump having to wait for Sessions to find his Balls.
2△ ▽ • Share ›
John Henke > Drink-More-Die-Young • 7 months ago ⚑ −

He better get rid of that little punk. I worked in prisons for 25 years and Sessions
has cho-mo written all over him. He want's to destroy the lives of people who may
have a hemp plant growing in their back yard but he will not go after the pedophile
rings because he is a member.
△ ▽ • Share ›
Drink-More-Die-Young > John Henke • 7 months ago − ⚑

You have your INFO wrong, Sessions is going after the pedophile rings,
don't you keep up with the news.
It's Sessions that is not going after the Deep State Criminals and getting
them off Trump's back.
He can't get rid of Sessions. Trump would have to appoint someone else,
then the Senate approval board would keep Trump in check with no AG.
△ ▽ • Share ›
PeaceTrain • 7 months ago − ⚑

Finally we are getting to the deep middle of the swamp, the CIA and Hillary's State Dept.
1△ ▽ • Share ›
Sam Iam • 7 months ago − ⚑

The FBI runs the white supremacists. The CIA runs Antifa (95-percent white, communists).
Strange that the CIA would try to destroy their own country. Then, you have McCain, Romney,
Rubio volunteering to lead Antifa.
2△ ▽ • Share ›
AllRoadsLead2Rome > Sam Iam • 7 months ago − ⚑

The CIA stands for Catholics In Action
△ ▽ • Share ›
John Henke > Sam Iam • 7 months ago − ⚑

The CIA has no country.
2△ ▽ • Share ›
aname123 > John Henke • 7 months ago − ⚑

correct Thats why JFK had to die because he wanted to disband them.
△ ▽ • Share ›

−
MilesMonroe > Guest • 7 months ago ⚑ −

Rather, you would have us believe you, a faceless commenter, are the voice of reason and
reality. Rrrrriiiiiiggggghhhhhhttttt, (lumberg intonation)
△ ▽ • Share ›
Stan Durinski • 7 months ago − ⚑

Government is violence. The Republic is dead and has been for decades. What we are
witnessing now is the lead up to a very violent end to our civilization (A Major Paradigm shift is
about to take place). All because people got lazy and let their so called 'Elected Leaders' who are
supposed to have represent them, burn it all down.
1△ ▽ • Share ›
Roadrunner0 • 7 months ago − ⚑

I think that car was being driven remotely as you can see there are 2 cameras mounted on the
dash in black boxes..
1△ ▽ • Share ›
Duncan Idaho ghola • 7 months ago − ⚑

Anyone sign up for this? Craigslist ad offers to pay actors to be Trump supporters in Phoenix -
preferably minority.http://www.azcentral.com/story/new...
△ ▽ • Share ›
Roadrunner0 > Duncan Idaho ghola • 7 months ago − ⚑

That is what we call disinformation so as to cover their real recruiting being exposed..
1△ ▽ • Share ›
Duncan Idaho ghola > Roadrunner0 • 7 months ago − ⚑

why would the same not be true for the left?
△ ▽ • Share ›
Duncan Idaho ghola • 7 months ago ⚑ −

sorry alex. you are slow to this. Like the prez's response. Too little, too late. Stop your BS - you
ARE MSM.
△ ▽ • Share ›
karl > Duncan Idaho ghola • 7 months ago − ⚑

Did you hear what he said before he posted????
△ ▽ • Share ›
Duncan Idaho ghola > karl • 7 months ago − ⚑

try that again. Alex? who? I can't stand alex's voice - I try to avoid it.
△ ▽ • Share ›
Roadrunner0 > Duncan Idaho ghola • 7 months ago − ⚑

It is never to late for the truth unless you are on the gallows with the rope around your
neck..
△ ▽ • Share ›
Duncan Idaho ghola > Roadrunner0 • 7 months ago − ⚑

cool non violent right person.
△ ▽ • Share ›
Dr. D > Duncan Idaho ghola • 7 months ago − ⚑

And you are just slow aren't you private account troll? I'm surprised you didn't up vote
yourself also! HAHAHAAA!
1△ ▽ • Share ›
Duncan Idaho
Case 3:18-cv-00017-GEC ghola > Dr.29-7
Document D • 7 months
Filed ago − ⚑
04/24/18 Page 30 of 36 Pageid#: 606
u ca da o g o a o t s ago ⚑
Troll assumption = ignorance.
△ ▽ • Share ›
Dr. D > Duncan Idaho ghola • 7 months ago − ⚑

No, I'm right.
△ ▽ • Share ›
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EXHIBIT H


3/1/2018 BOMBSHELL: New evidence suggests Charlottesville was a complete SET-UP - Allen B. West - AllenBWest.com
BOMBSHELL: New evidence suggests Charlottesville was a complete SET-UP

By Derrick Wilburn - August 19, 2017
FACEBOOK TWITTER Subscribe
At least one law enforcement officer in Charlottesville, VA has come forward to clear his conscience and reveal the truth — or
at least his version of it — that what went down in the city was not only condoned by city governance but was intentional,
orchestrated and may have been as long ago as May.
The as-yet unidentified police officer has said that the Charlottesville P.D. were specifically instructed to bring the radical left
and right wing groups together to instigate violence and then to told to “stand down” once violence ensued in a deliberate
effort to ignite a race riot. Hear his words:
The story is being told on YourNewsWire.com and other sources:

https://www.allenwest.com/2017/08/19/bombshell-new-evidence-suggests-charlottesville-complete-set/ 1/7
This revelation is huge and if true may implicate Mayor Signer and possibly other city officials in the death of a citizen.
“Fox News reporter Doug McKelway was on the scene in Charlottesville and he backs up the police officer’s claims.
Here’s McKelway’s initial report upon landing on the ground in Charlottesville. Remember this is long before these new
revelations when neither he nor anyone had the slightest idea some dirty tricks may be afoot. To cut directly to the chase fast
forward to the 2:40 mark of this 3:51 long video and listen to what the reporter says:
Now why would the cops, sworn servants of the

populace be just standing around while citizens are bleeding right in front of them? Could it be because they were given
specific orders to render no assistance in an effort to let tensions fester?
Breaking911 tweeted video of James Fields, Jr., driver of the car in the deadly attack, as he fled the scene. People are now
noticing how at no point was the car that plowed into the crowd of protesters pursued by police – there is not a police car in
sight leading into the area or in pursuit as he drives away! How does that happen?
In the 38-second video below cops are plainly visible as Fields drives his battered Chrysler away from the carnage. Officers can
clearly be seen looking directly at the suspect and his torn up car yet they casually observe the man who’d just mowed down
dozens of people. They allow him to motor on by as if on a Sunday drive. They make NO effort to stop the car which is a mere
yard or two away with its torn up windshield and front end traveling at a very low rate of speed leaving a trail of smoke:

Breaking911
@Breaking911
NEW VIDEO: Car That Plowed Into Charlottesville Crowd Spotted

Leaving the Scene
1:00 PM - Aug 14, 2017
631 1,207 people are talking about this
Does this seem like a normal reaction by law enforcement in such a situation? The depth of this conspiracy runs deeper:
“[Mayor]

We need to clarify that these are early accounts and as yet unverified, but if true this is very, very serious stuff. It points
directly to the reality of the “deep state” and more importantly to the lengths that the Soros/Clinton/Obama one-world
government cabal will go in order to realize their desires for ‘fundamental transformation.’
Folks this is much, much more serious than white supremacists versus Antifa fighting in the streets.
[NOTE: This article was written by Derrick Wilburn, Founder and Chairman of the Rocky Mountain Black Conservatives, and a
speaker, author, columnist and analyst for multiple print and broadcast media outlets. Follow him on Facebook and at
RMBlackConservatives.com.]
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UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF VIRGINIA

alleges upon knowledge and belief as follows:

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 1 of 99 Pageid#: 406

Gilmore that continue to this day.

that followed, was devastating.

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 2 of 99 Pageid#: 407

hacking attempts, and even in-person harassment on the streets of Charlottesville.

Fact-based journalism is essential to our democracy, because it provides citizens with

objective, reality-based information on issues of public concern. While Defendants masquerade as

by professional conspiracy theorists instrumentalizing their throngs of followers.

intimidated and silenced by Defendants’ dangerous and defamatory lies.

II. JURISDICTION AND VENUE

Virginia residents and caused ultimate injury to the Plaintiff in Virginia.

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 3 of 99 Pageid#: 408

Defendant, exclusive of interests and costs, and there is diversity of citizenship.

resulting from Defendants’ tortious conduct occurred primarily within Virginia.

5. Defendants injured Plaintiff Gilmore in the Commonwealth of Virginia by their conduct

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 4 of 99 Pageid#: 409

intended to target and incite a Virginia audience.

6. Defendants’ statements, published to persons in Virginia, ultimately resulted in injury to

Gilmore has experienced irreversible personal and professional damage in Virginia,

including reputational harm, the loss of business opportunities in Virginia, irreparable

individuals in Virginia. Furthermore, as a result of publication in Virginia, Plaintiff also

sought the protection of local Virginia police.

in Virginia, engage in other persistent courses of conduct, or derive substantial revenue

business from a shared workspace in Arlington, Virginia.

8. Defendants generate substantial revenue from the Commonwealth of Virginia as a result

of their content-driven business model. Some internet-based media providers, including

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 5 of 99 Pageid#: 410

views their websites or videos.

generate substantial revenue as a result of transactions with individuals residing in Virginia.

of Defendant InfoWars’ operating revenue comes from the sale of InfoWars-branded

portion of this revenue is the result of transactions with individuals in Virginia.

Furthermore, Defendant Jones’ radio show is aired on the Genesis Communication

Network’s Virginia affiliate stations, which publishes content to Virginians.

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 6 of 99 Pageid#: 411

event as part of a journalistic endeavor.

Department”), where he is a civil servant employed as a Foreign Service Officer. In 2017,

be closer to family after many years of overseas deployments. He previously served as

information technology company founded in 2017.

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 7 of 99 Pageid#: 412

Breaking: State Department/CIA Orchestrated Charlottesville Tragedy on August 21,

containing false and defamatory statements about Mr. Gilmore.

InfoWars website, where Defendants Jones, McAdoo, and Stranahan’s defamatory

statements were published, “Infowars.com is a Free Speech Systems, LLC website.”7

According to the InfoWars Store, purchases of Defendant InfoWars’ dietary supplements

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 8 of 99 Pageid#: 413

account registered to Stranahan Strategies, LLC,12 an inactive Texas limited liability

workspace in Arlington, Virginia.

contractor and reporter at InfoWars.

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 9 of 99 Pageid#: 414

entitled Charlottesville Attack: Brennan Gilmore – Witness or Accessory?15 On or about

allegedly violating YouTube’s Terms of Service.16

Shill Linked to George Soros.18

BOMBSHELL: New evidence suggests Charlottesville was a complete SET-UP on August

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 10 of 99 Pageid#: 415

22. Defendant Derrick Wilburn is domiciled in Colorado Springs, Colorado. Defendant

Defendant West’s website.

in Congressman Allen West’s congressional office as Director of Outreach and as Press

Defendant West claimed that Defendant Hickford, as president of Words-N-Ideas, owned

24. Defendant Words-N-Ideas, LLC (“Words-N-Ideas”) is an inactive Florida limited liability

Wilburn’s false and defamatory article.

Case 3:18-cv-00017-GEC Document 29 Filed 04/24/18 Page 11 of 99 Pageid#: 416