‘STEVENS & LEE Geoffrey R, Johnson, Esquire (LD. #36685) 1818 Market Strect, 29" Floor Philadelphia, PA 19103 Attomey for Plaintiff (15) 751-2882 ‘Margo Davidson MARGO L. DAVIDSON : COURT OF COMMON PLEAS 333 Clearbrook Avenue : PHILADELPHIA, PENNSYLVANIA ‘Lansdowne, PA 19050, t Plaintiff, : v. + October Term, 2019 NIKOLAOS HATZIEFSTATHIOU : No. One Liberty Place - 36" Floor t 1650 Market Street Philadelphia, PA 19103 and ORIGINAL MEDIA GROUP CORPORATION: $ va YC NEWS, YC Daily and/or yenews t One Liberty Place ~ 36" Floor 1650 Market Street Philadelphia, PA 19103, Defendants. CIVIL ACTION COMPLAINT “This is en ‘action for defsination against Nikolaos Hitzitstethiou and Original Media Group Corporation va ¥C New, YC Daily andor yesnews, based on aMarch 4, 2019 article written by Hatzifstatiou and published by Original end Hatzefstuthiou in which Defendants fabricated a claim that Plaintiff was under investigation by federal authorities and that her records had been subpoenaed by a federel grand jury. These published defamations are false and 1 , Case ID: 190903291Defendants published them maliciously and with the intent to harm Plant ‘Nikolaos Hatlefstathio, the autho ofthe atil, is no stamgerto fabricating sensations! sews stovies about innocent individuals and groups. In Jily, 2019, he was charged with multiple feony coms arising out of n yonews ale be wrote based on racist eal that purported 0 beftom « Delaware County Courthouse worker. In fact, the emal wasa forgery end ataefsathiou was charged bythe Delaware County District Attamey with matipl ximes, vio snnounced the charges, stating; “Evidence shows that Nikolios Hatiefstathiou will use any smeans to create his false nesintive... Creating on article fll of it, Nikolaos Hatzefstthion tempted to destroy the reputation of hard working people . «2 Nikolaos Hatziefstathiou in his auticle ebout Plaintiff also “use{d] any means to create his false nuratve,” and “attempted to estoy the reputtion of fe hatd working® person — Plaintiff Margo Davidson. Plsintf brings this action seeking dameges forthe malic eotions of Nikolaos Hatziefstathion 1. Plaintiff, Mango Davidson (bereaier “Davidson” i x alt individual and resident of the Commonwealth of Pennsylvania with an address #336 Clearbrook Avenue Lansdowne, PA 19050, Atl times relevant hereto, Davidson tas ‘been a member of the Pennsylvania House of Representatives, 2, Defendant, Nkoleos Htziefiathion (heater “etieitathiov’, i an adult individvel and resident of the state of Pennsylvania with a business wicress at One Liberty Place 36 Floor, 1650 Masket Stoo, Philadelphia, PA 19103. Atal imesrelevant hee, Hlatzefstathou was employed by Original and yosnews as a Pubisher and National News Director. Case ID: 1909032913, Defendant, Original Media Group Corporation (becatfter “Original” t/a YC ‘News and/or YC Daily and/or ye.news, represented itself to be a ao-for-profit comporation with its principal office at One Liberty Place ~ 36" Floor, 1650 Market Street, Philadelphia, PA 19103, tall times relevant hereto, Original also represented itselfto be an American news agency based in Philadelphia that operates as a cooperative with emission isto organize the {information provided to it by people and organizations around the werid, thus making it tniversally accessible and useful to readers, students, professors, researchers and of course the curious general public. 4, Atall times relevant hereto, Original acted by and through its agents and employees including, but not limited to, defendant Hatzeifstathion 5, Atal times relevant hereto, Hatzeifstathiou acted nith the course and scope of bis employment and within the control of her employer Osiginal, JURISDICTION AND VENUE 6, __Jutisdiction over the parties in the courts of the Canmonvtealth of Pennsylvania is proper pursumnt tothe provisions of 42 Pa.C.S. § 5301 et seq, ma 42 Pa.CS. § 3322(0X(1), () and (5), Original cries on a continuous and systematic part of general business within the ‘Commonwealth and it transacts business in the Commonwealth. Defendants have caused harm andtortious injury by their acts in the Commonwealth, to-wit, by publishing and disseminating their defamatory statements in Philadelphia County and elsewhere in Pennsylvania. Further, Defendants have caused harm or tortious injury in this Commonwealth. 7. Venues proper in the Court of Common Pleas of Philadelphia County under ‘Pennsylvania Rule of Civil Procedure 1006(e) and Pennsyvanie Rule of Civil Procedure 3 Case ID: 1909032912179(1X(1), @), (3) and (4, inasmuch as (i) Hatzeifstathion and Original regularly conduct business in Philadelphia County, (i) the cause of action arose in Philadelphia County, end (iv) the transaction or occurrence out of which Davidson's cause of ation arises, to wit the defendants publication and dissemination of false and defamatory statements about Davidson to third parties, took place in Philadelphia County. FACTS 8. Onorabout March 4, 2019, Defendants publishedan article on multiple websites, including yesnows, captioned as “State Rep. Margo Davidson sulject of probe, federal grand ‘jury looking at whether cempaign finds were used for personal epemses.” The enicle was vaitten by defendant Hatzeifstathiou and published by Original aed Hatzeifstathion as the lead article on its yoanews website and elsewhere, A copy of the artcsis appended hereto as Exhibit “An 9, Inthe article, Defendants defamed Davidson by string and/or implying that she is under investigation by a federal grand jury that hns subpoenaed bet political campaign's ‘financial records, that subpoenas had been served on members offriends of Margo Davidson and People’s Victory, her political action committees, and that sieis under investigation as part of a joint effort of the FBI, IRS and other agencies. The statemeat, implications and innuendo published as to Ms. Davidson are entirely fase and have caused mibitatial harm to her reputation as well as other damage. 10, Defendants expressly, falsely and maliciously stein the headline to the article: “state Rep. Margo Davidson subject of probe, federal grand jury locking at whether campaign flands were used for personl expenses.” Case ID: 19090329111, The Article goes on to falsely and maliciously state: Delaware County State Representative Margo Davidson isunder investigation by ‘afedetal grand jury that has subpoenaed her political campsign’s financial records to determine if she misspent funds on her personal scpenses, according to souroes familiar with the probe. “There is a grand jury empaneled,” a law enforcement sowee told yo.news. “Rep. Davidson has been under a microscope since the indictment of Philadelphia Disa Auorey Seth Williams and State Representative Vanessa Lowery wn, Suibpoonas wore served as revently as last week to mesubes of Friends of Margo Davidson and People’s Viotory, her political action commitees, seid the source, vyiho desoribed the investigation as part ofa joint effort ofthe FBI, IRS and other agencies. See Exhibit“A.” Count I Defamation Margo Davidson v. All Defendants 12, The averments set forth in paragraphs one through elves, inclusive, are incorporated by reference as though set forth full herein, 13, Defendants published and disseminated false and defuetory statements, assertions, suggestions, innvendoes, and/or implintions as aforni in thei ticle and item of March 4, 2019, which are appended hereto os Exhibit “A.” 14. The above statements, assertions, suggestions, inmendoes and/or impHications maliciously and fisely state, imply and suggest a a fact, direty and by innuendo and inference, individually and colletively, that Davidson () i under investigation by multiple federal agencies, (i) is being Investigated for erminal conduc, and (3)has acted ilegsly, 15, The above statements assertions, suggestions, iments and/or implications are 5 Case ID: 19090329116. Defendants published the above statements, assertons, suggestions, innuendoes and/or implications with knowledge of their fulsty and/or with reHles disrogard oftheir falsity. 17, _ Inpublishing the above statements, assertions, suggestions, innuendoes and/or implications defendants acted in grossly irresponsible manner witwutdue consideration for the standards of information gathering and dissemination ordinarily flowed by responsible parties. 18, The defendants’ aforementioned false and defamatory statements, assertions, siggestons,innnendoes and/or implications are false, defamatory nd Libelous per sein that they attribute unethical, unprofessional, improper, end illegal conductto Berman, 19, ‘The aforementioned defamatory statements by defendants about Davidson were published in Philadelphia County and elsewhere, read by rosidens, citizens and individuals in Philadelphia County and elsewhere, and were understood by saidresidents, citizens and individuals to be defamatory of Davidson. 20, The aforementioned defamatory statements were published by defendants with the intent that they be re-published elsewhere and cause further arm to Davidson, 20. "The above-mentioned false and defamatory statements assertions, suggestions, innuendoes and implications about Davidson have tarnished Davidson’ s reputation in her community, They have exposed Davidson to public contempt and ridicule, They have also falsely asexibed to Davidson improper and illegal conduc, as wel. as unethical behavior, and 9 lack of decercy, integrity and responsibility. As a result ofthe publication of these false and defnmatory statements, Davidson's reputation and good name have been harmed and she has 6 Case ID; 190903291suffered other damage. 21. The false and defamatory statements, assertions, sigzestions, innuendoes and implications published by defendants about Davidson were published reckless disregard for the injury Which said statements, assertions, suggestions, innuendoes anc implications would inflict ‘on the good name and reputation of Davidson. 22, Davidson is entitled to recover such damages as will compensate her forthe injury to her reputetion as well as the embarrassment, humilitioned exnotional distress resuiting ftom the defendants’ false and defamatory sintements, aseations, suggestions, innuendoes and implications. WHEREFORE, plaintiff, Margo Davidson, demands judgrest in her favor and ageinst defendants, Nikolios Hatzeifstathiou and Original Media Group Corporetion, jointly and severally, and requests an award of compensatory damages in exiessof the jurisdictional amount of Fity Thousand Dollars ($50,000.00), plus interest and costs, es wall es an award of punitive damages in an amount to be determined by a jury. STEVENS & LEE By: RJ 1818 Market Floor Philadelphia, PA 19103 (215) 751-2882 [email protected] Date: Leptemlen 25; 2el4 Case ID: 190903291‘VERIFICATION {Margo Davidson, have read the foregoing Civil Action Complaint, hereby state that the ‘acts set forth are true and correct to the best of my knowledge, information and belief. 1 ‘understand that the statements herein are made subject to the penilies of 18 Pa.CS, § 4904 (lating to unswora filsfication to authorities) Date: September? 2019 Case ID: 190903291EXHIBIT AState Rep. Margo Davidson subject of probe, federal grand jury looking at whether campaign funds were used for personal expenses By YE = Hach .a9 Pra ie Hage Davieo ameain Delaware County State Representative Margo Davidson is under Investigation by a federat grand jury that has subpoenaed her poltcal campaign's finandlal nedris to determine if she rmisspent funds on personal expenses, according to sources fami with the probe. ‘There is a grand jury Impaneled;” a law enforcement source tld nes. Rep. Davidson thas beet under 8 miéroscape since the Indictment af Philadelphia Dstset Attorney Seth Witeme and State Representative Vanessa Lowery Brown.” subpoenas were served as recently ag last week te members of Frends of Margo Davidson ‘and People's Vctory, her political action committees, sald the soune, who describes the Investigation as a Jolt effort ofthe FBI, IRS, and other agencies, Davidson, vino declined to comment on her financial reports, Is pad a salary of $64,012 year. ‘According to the well-placed source, @ grand Jury was Impaneled z leest one month 890, noting that the investigation is “ell overdue" and that new Information caught the eye of prosecutors after the indictment of former Philadelphia State Repnsertative Vanessa Lowery Brown. Case ID; 190903291The government offered Margo Davidson the opportunity to commizcrimes;" the source cose to the probe told yesnews. "Day after day, week after week, month after manth and year efter year. It should have been stopped. It could have been sopped. Tt was ignored.” Davidson, @ Democrat serving her fourth term in office with her ith approeching, di not personally respond Monday to voice mall and emall requests for earment. However, Davidson staff member at her Harrisburg ofice declined to respond when asked several times if she received the subpoenas. “t don't have time for this ~ stop caling cur office” the woman seil."J'm not answering your ‘questions, J don’t give mecia soundbites.” 1n 2018, Davidson announced her re-election campaign and a separate td for congress, 'A shott breakdown of cempalgn finance reports obtained and reviewed by ye.news, indicate that Davidson used her cempelgn accounts to fund her personal style, going as fer as fraudulently expensing dver $1,000 for gas at a Waive that doesrtsell gasoline. “The finance reports also detail tips that she took to North Cars, Vigra, and several ‘other states, Including a trip for her and her husband, Rabert Davison, fr thelr wedding ‘anniversary, The Davideons traveled to Virginia end splurged on chness ar thelr weekend getaway. ‘tes absolutely unheard of for a campolgn to spend nearly $70,0:0.00 n one month on 8 race that she Is unopposed In and vil win given the ratio of Reputtcars vs, Demoxrdts, former investigator forthe Federal Election Committee tld ye.ners.“This:s a textbook case ‘of public corruption.” “The most recent campaign report for Friends of targo Davidson, fed in December to detail finances from November 27, 2018 to December 34, 2016, showedthat she started the ‘month with $34,156.93, raised $63,275.00, and spent $67,738.25, lenving $29,693.68 In the bank as of Dec. 31. Davidson held her frst congressional campetan perty on March 17, 2018 and spent over {$6,000 that weekend from her re-election campaign ta ft the bl for her congressional run kickoff party, according to documents, bisturbingly, Davidson pal attorney Kevin O’Nell, 2 criminal defese attorney who represented her after she repeatedly crashed a taxpayer-funded vehicle without a valid drive's license béfore fleeing the scene. O'Nell Is also the attore) of record who represents tio of her three incarcerated children. He recelved $1,000.00 fron Davidson's campaign shortly after her crash spree. Kevin O'Nell did not respond to repeated requests for comment. ‘Davidson pald Vincent Curtis of Newtown Square, Pe.'$500 for iranct consuling® Fees. ‘Curtis, who was unnlling to comment cn the consultation fee, cies the IRS nearly $20,000 ‘im unpaid federal taxes, according to reports. Case ID: 190903291‘Campaign finance reports also Indicate that the state representatie’ husband, Robert Davidson, was pald over $3,750 to “canvas neighborhoods" duringand efter the election. “Jennifer Heath, @ campaign staff member for Davidson was paid $3,000.00 for “election day ‘operations on May 15, 2018 and 2,250.00 on November 6, 2018. Heath, whe hes @ lengthy criminal background Including charges of harassment, dlszeely conduc, simple ‘assault, coruption of minors, Indecent assault, and other crimes rfesed to comment on the payment. “The campalgh expense reports expose that Davidson spent campy fancs to cover her cost to-and from Harrisburg for over two-years, spending over $5,000 2018 alone to foot the bil for her Hardsburg travel, accomadation and meals. (On March 16, May 25, and November 11, 2018, Davidson's campeon tance report Indicates that she spent $967.21 at three “fundraising planning events” at the Harrisburg ton Hotel ‘Arepresentative for Hilton Hotels told ye.news thet there *were no fondralsing planning ‘events that took place on those dates.” Nonetheless, Davidson wes n Harrisburg on those three occasions to attend voting sesslons, according to records fren he House oF Representatives. ‘hen the House isin gession, all members are given a per dlem p use towards travel, Including hotel." A spokesperson for the Pennsylvania Departmentof State told ycsnews, noting that each representative racelves a $157/day per diem forirevel, “Though spending funds for her to travel to and from Harrisburg tevote may appear normal, Davidson could face serlous legal penalties for funneling thousands of dollars from her ‘campaign to foot the bil for her regular Job. “The documents reveal that she was reimbursed for traveling to and from Harrisburg on each date thatthe house was in session, but the tzxpayerfunds she recived for her rembursemient were revet returned to the campaign account, Davidson pald 25-year-old Desmond Dozier aver $2,000 for *suppart” during her re-election. Dozler refused to commnent on the services he provided Davidson n exchenge for the ‘peyments he received from her coripsion. (on March 14, 2018, Davidson spent $686.80 on dinner at Mangle Qui a lavish Harrisburg ‘Europeen restaurant located across the street from the Copitol. Davidson wrote te meal off ‘8 “campaign fundralsing evant” However, records indicate that Davidson ws In Harrisburg on that day to vote on legislation, not to host an evert. ‘on March 1, 2018, Davidson pal Bernard Lopez 42,000.00 for hsrale asa Yeampalgn operative” Lopez ho was arrested and convicted ot diving unde the Infrecejost srths prior tothe payment refused to comment on the payment andservices provided.‘Davidson's former chief-of-staff Carolyn Collins and her husband vata Collins were pald '$2,650.00 as “volunteer coordinators” Colins came under fire lastyeer after Davidson was accused of forging campaign signatures, The court rulad that out ¢ &5¢ signatures on her nomination petitions that were notarized by Cols, 361 were frauticst and stricken from her pettion, Cerolyn and Kelth Collins dé not respond to requestster comment, Davidson also expensed gasoline at the Wave located on 202 Stati head on dezens of occesions, however, that speciic Wawa does not sell gasotine. nto ate Aap. Hoge Deer (0m expense esa cing gs cases Wor a eal ‘enamvercoene) When asked ebout the subpoenas, Investigation, and Rep. Davidsn's fiance reports, Pennsylvania Attorney General Josh Shapiro sal, "no comment.” ttarete (Hiresiea ss [Smee | Case ID: 190903291