UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

ANTHONY BOBULINSKI,

Plaintiff,

v. Case No.: ________________

DANIEL GOLDMAN, DEMAND FOR A JURY

COMPLAINT

1. Defendant, Daniel Goldman, has repeatedly lied about Plaintiff,

Anthony Bobulinski, saying that Mr. Bobulinski has used a Trump campaign-paid

lawyer to lie since October 2020, spreads Russian disinformation, and is a Trump

campaign plant. Defendant lied solely to serve his political agenda by deliberately

besmirching the character of Mr. Bobulinski and to protect Joseph Biden. Defendant’s

assertions are unequivocally false and defamatory. Mr. Bobulinski demanded a

complete retraction and deletion of his posts made on X (formerly Twitter) on March

26, 2024, which Defendant wholly ignored. Accordingly, Mr. Bobulinski seeks to hold

Defendant accountable for his malicious and knowing lies.

PARTIES AND JURISDICTION

2. Plaintiff Anthony Bobulinski is an individual who is not a resident or

citizen of the State of New York or Washington, D.C.

3. Defendant Dan Goldman is an individual who is a resident and citizen

of the State of New York, and is employed in Washington, D.C.

pursuant to 28 U.S.C. § 1332 as there is complete diversity of citizenship, and the

amount in controversy exceeds $75,000.

FACTUAL BACKGROUND

Background of Mr. Bobulinski

5. Mr. Bobulinski is a decorated Navy veteran and successful

businessman.

6. For over six years, Mr. Bobulinski was an officer in the United States

Navy’s elite Naval Nuclear Power Training Command (“NNPTC”) as a decorated

Master Training Specialist Instructor. He later served as the Command’s Chief

Technology Officer where he held a Q security clearance from the Department of

Energy and from the National Security Agency. When he left NNPTC, Mr. Bobulinski

was the top-ranked Direct Input Officer (“DIO”) in the entire Command, as is

documented in his final Navy Fitness Report (“FITREP”).

7. Mr. Bobulinski’s awards and decorations include the Navy/Marine

Corps Commendation Medal, the Navy/Marine Corps Achievement Medal, and the

National Defense Service Medal.

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 8. After his military service, Mr. Bobulinski became involved in business

ventures and eventually met Joseph Biden in May 2017. Hunter Biden subsequently

engaged Mr. Bobulinski as his business partner to serve as the CEO of SinoHawk

Holdings, a company designed to find investments in the United States. Ultimately,

a partnership was formed between the Chinese Communist Party/Chairman Ye

through their surrogate, China Energy Company Limited (“CEFC”), a CCP-linked

Chinese energy conglomerate, and the Biden Family.

9. Leaked emails eventually raised questions about whether Hunter Biden

was profiting off his father’s name when he was Vice President of the United States.

10. The emails showed that Joseph Biden was aware of Hunter’s business

dealings with foreign nations and even personally benefited from them. They

contradicted Joseph Biden’s several prior assertions that he had no awareness of, or

involvement with, his son’s business dealings.

11. An email dated May 13, 2017, discussed remuneration packages

regarding a business deal with a now-bankrupt Chinese company proposing an equity

split of “20” for “H” and “10 held by H for the big guy?”

12. The reference to “the big guy” was used by James Gilliar to refer to

Joseph Biden in emails to maintain confidentiality. Hunter Biden referred to his

father as “my chairman.”

13. Mr. Bobulinski, who considers himself to be a political moderate and

previously donated to members of the Democratic Party, decided to put principles

above political party. He confirmed the veracity of the emails to the United States

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Senate and that Joseph Biden was aware of, and involved with, his son’s business

dealings with foreign nations, and that the Biden family, including Joseph Biden,

accepted money from foreign nations.

14. Indeed, Mr. Bobulinski came forward because of the lies Joseph Biden

was telling, and continues to tell today, about his involvement with, and financial

benefit from, his son’s business dealings.

15. Mr. Bobulinski confirmed that he saw, firsthand, that Hunter Biden

would frequently go to his father for his approval or advice for various business deals.

16. Additionally, during the course of their business relationship, Mr.

Bobulinski grew concerned that Hunter Biden was using the Chinese company as his

“personal piggy bank,” and Mr. Bobulinski needed to take certain steps at the board

level to minimize that risk.

17. On March 20, 2024, Mr. Bobulinski was sworn in to testify before the

United States House of Representatives Committee on Oversight and Accountability

as to the conduct he witnessed by Joseph Biden, Hunter Biden, and Biden Family

business associates. A photograph of that moment is depicted below.

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 Defendant’s History

18. Defendant is a Democratic congressman in the United States House of

Representatives from New York’s 10th congressional district.

19. Defendant comes from one of the wealthiest families in America. He is

the heir to the Levi Strauss & Co. fortune and is currently one of the wealthiest

members of Congress.

20. Elected to office in 2022, Defendant’s campaign raised millions of dollars

and received maximum contributions from multiple billionaires, which Defendant

leveraged to effectively squash his competition.

21. Defendant is also a lawyer, having graduated from law school in 2005.

22. Prior to running for Congress, Defendant served as lead counsel for the

House impeachment managers during the Senate trial of President Trump, in which

he was ultimately acquitted.

23. Defendant serves on the United States House of Representatives

Committee on Oversight and Accountability. Mr. Bobulinski had been interviewed by

the Committee prior to publicly testifying before the Committee on March 20, 2024.

Mr. Bobulinski agreed to do so, in part, to accommodate Mr. Hunter Biden’s prior

dramatic demands to testify before the Committee publicly as well as to answer any

and all questions about the truth of the corruption within the Biden Family. The

Committee then scheduled a public hearing. Notwithstanding, Hunter Biden failed

to appear. His empty chair is shown in the above photograph.

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 Defendant’s Lies

24. On March 21, 2024, shortly after Mr. Bobulinski’s most recent

appearance before the United States House of Representatives Committee on

Oversight and Accountability, Defendant posted on X, “Tony Bobulinski has used a

Trump campaign-paid lawyer to make false allegations since October 2020.”

25. Defendant also wrote on March 21, 2024, that Mr. Bobulinski’s

testimony was “Russian disinformation.”

26. On February 14, 2024, Defendant directed a post to Oversight

Chairman, James Comer, while discussing Mr. Bobulinski, writing, “You brought in

a Trump campaign plant to peddle your same lies.”

27. Each of the statements is unequivocally false.

28. It is a matter of fact that since 2020, when Mr. Bobulinski first started

speaking publicly against the Biden Family’s corruption, he has spent over $500,000

of his own money on legal fees. Neither President Trump, nor any Trump affiliated

entities, have ever paid for Mr. Bobulinski’s legal fees. Rather, he did because of his

strong sense of civic duty.

29. Further, Mr. Bobulinski is not affiliated with the Trump campaign in

any way. He has never lied to Congress, or anyone else, from the inception of when

he first started speaking publicly in 2020 about Biden Family improprieties with the

Chinese Communist Party and affiliated organizations. Mr. Bobulinski’s testimony,

despite Defendant’s delusional assertion, is not “Russian disinformation,”—the ever-

present garbage so often used by Democrats invariably reflecting their lack of any

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substantive support based in reality. Rather, Mr. Bobulinski is a patriotic American.

He is neither a Republican, nor a Trump campaign plant and is most definitely not

working with the Russians to spread disinformation and lie to the American people.

30. Defendant deliberately and maliciously made these statements, outside

the scope of his employment, in an attempt to discredit Mr. Bobulinski’s testimony

and to besmirch Mr. Bobulinski’s character. It was a mistake for Defendant to believe

he was cloaked with immunity for his defamatory statements.

31. Defendant made these statements impromptu on X, outside of Congress,

and used none of Congress’ resources. He did so not to inform the public with facts,

but rather, for the unforeseeable act to attack Mr. Bobulinski with lies to try and

repair the image of Joseph Biden in the wake of evidence of corruption presented

against the Biden Family. Defendant’s conduct was solely to achieve his personal

vendetta against Mr. Bobulinski for speaking out against the Biden family.

Defendant’s post of February 14, 2024, was even made outside of work hours, made

at 8:03 AM.

32. By letter dated March 26, 2024, attached as Exhibit A, counsel for Mr.

Bobulinski demanded that Defendant retract and delete his defamatory comments.

33. Defendant neither responded to, nor complied with, Mr. Bobulinski’s

demand.

34. Defendant was aware at the time he made these false statements that

they would inflame a segment of the country against Mr. Bobulinski and would falsely

cause persons to disbelieve Mr. Bobulinski’s sworn testimony.

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 35. As a member of the Committee on Oversight and Accountability,

Defendant was acutely aware that Mr. Bobulinski has not accepted money from

President Trump, or any persons or entities affiliated with President Trump, to pay

his legal bills. Defendant was further aware Plaintiff has not told any lies, is not a

Trump campaign plant, and is certainly not spreading Russian disinformation.

Notwithstanding, Defendant has been working in tag-team fashion with fellow

Oversight Committee member, Rep. Jamie Raskin, in a social media blitz of

defamatory posts deliberately and maliciously besmirching the character of Mr.

Bobulinski. Rep. Raskin will soon also enjoy the suffix, “Defendant” in litigation Mr.

Bobulinski will file against him if he also fails to retract and delete his posts.

36. Defendant made these lies against Mr. Bobulinski to defame and

discredit his character and punish anyone who dared speak up against the Biden

Family for its many improprieties with the Chinese Communist Party and affiliated

organizations.

CAUSES OF ACTION
COUNT I
(Defamation and Defamation Per Se)

37. Plaintiff incorporates by reference the above paragraphs as though set

forth fully herein.

38. Defendant has repeatedly defamed Mr. Bobulinski on X, outside the

scope of his employment, by claiming that, Mr. Bobulinski uses a Trump campaign-

paid lawyer to lie and make false allegations, that he has lied about the Bidens since

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October 2020, that his sworn testimony is Russian disinformation, and that he is a

Trump campaign plant.

39. Defendant’s assertions are categorically false.

40. Defendant published the defamatory statements on X, knowing that

they were false or with reckless disregard for the truth. Given Defendant’s

employment, and position with the Democratic party, he knew Mr. Bobulinski was

telling the truth and knew Mr. Bobulinski was doing so for the benefit of the

American people. Defendant deliberately acted with reckless disregard for those

truths.

41. The defamatory statements constitute defamation per se because by

claiming that Mr. Bobulinski lied and made false allegations, Defendant accused Mr.

Bobulinski of committing perjury and violating 18 U.S.C. § 1001, for lying to

Congress. Further, by claiming that Mr. Bobulinski is spreading Russian

disinformation, and is a Trump campaign plant, while using a Trump campaign-paid

lawyer, Defendant sought to destroy Mr. Bobulinski’s credibility, and it subjected him

to hatred, distrust, ridicule, contempt, and/or disgrace by a certain segment of

America and the world which lives in an alternate reality. The statement inherently

causes people to view Mr. Bobulinski as untrustworthy by negatively implying that

his testimony is bought and paid for without the assistance of any extrinsic evidence.

42. The defamatory statements have directly and proximately caused Mr.

Bobulinski to suffer significant damages, including damage to his reputation,

humiliation, embarrassment, and mental anguish, as well as to his business

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ventures, and profession. These damages were foreseeable, are long-lasting, and

ongoing, and will be suffered in the future.

43. Defendant published the defamatory statements knowingly,

intentionally, willfully, wantonly, and maliciously, with intent to harm Mr.

Bobulinski, or in blatant disregard for the substantial likelihood of causing him harm

and were part of a well-established malicious pattern by Defendant, thereby entitling

Plaintiff to an award of punitive damages.

44. As a direct and proximate result of the misconduct of Defendant, Mr.

Bobulinski is entitled to compensatory, special, and punitive damages, in the sum of

$10,000,000.00, or such greater amount as is determined by the jury.

COUNT II
(Defamation by Implication)

45. Plaintiff incorporates by reference the above paragraphs as though set

forth fully herein.

46. On March 21, 2024, Defendant wrote, “Tony Bobulinski has used a

Trump campaign-paid lawyer to make false allegations since October 2020.”

47. In doing so, Defendant intentionally omitted important context that

neither President Trump, nor any entities affiliated with President Trump, are

paying for Mr. Bobulinski’s legal fees at all, and certainly not to lie.

48. Indeed, Defendant intentionally omitted this context in an attempt to

discredit Mr. Bobulinski by nonsensically trying to tie together a true fact that a PAC

has paid his lawyer’s firm, Elections LLC, in the past for work completely unrelated

to his lawyer’s representation of Mr. Bobulinski, in an attempt to imply defamatory

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innuendo and an understanding that President Trump is paying for Mr. Bobulinski’s

testimony before congress. In so doing, Defendant’s defamation by implication sought

to discredit Mr. Bobulinski.

49. Defendant’s omission of this context left a reasonable viewer with the

impression that President Trump or his campaign is paying for Mr. Bobulinski’s legal

fees, and ultimately, his testimony.

50. Defendant intentionally created this inference to salvage his political

party to the detriment of Mr. Bobulinski and his pursuit to expose the truth of the

Biden Family corruption.

51. The inference made is defamatory as it leads to hatred, distrust, ridicule,

contempt, and/or disgrace for Mr. Bobulinski. Indeed, it caused not only a large

segment of the nation which despises all things Trump regardless of reality, but also

rational and reasonable viewers, not to trust or find credibility with Plaintiffs.

52. Defendant made the statement with malice. He intended and endorsed

the inference because he wanted to continue to discredit Mr. Bobulinski in order to

serve Defendant’s personal political agenda.

53. As a direct and proximate result of the misconduct of Defendant, Mr.

Bobulinski is entitled to compensatory, special, and punitive damages, in the sum of

$10,000,000.00 or such greater amount as is determined by the jury

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Anthony Bobulinski respectfully requests this Court

to enter a judgment in his favor and grant relief against Defendant as follows:

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 a. An award of compensatory, special, and punitive damages of twenty

million dollars ($20,000,000.00);

b. An award of Plaintiff’s costs associated with this action, including but

not limited to their reasonable attorneys’ fees and expenses; and

c. Such other and further relief as the Court deems just and appropriate

to protect Plaintiff’s rights and interests.

DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury on all issues so triable.

Dated: April 5, 2024 ANTHONY BOBULINSKI

Respectfully submitted,

/s/
Jesse R. Binnall (Bar VA022)
John C. Sullivan (pro hac vice)
Jared J. Roberts (pro hac vice)
BINNALL LAW GROUP, PLLC
717 King Street, Suite 200
Alexandria, Virginia 22314
Phone: (703) 888-1943
Fax: (703) 888-1930
Email: [email protected]
[email protected]
[email protected]

Counsel for Plaintiff

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