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Former Ring of Honor wrestler Pelle Tsichlis aka Pelle Primeau filed motion seeking a dismissal of the lawsuit brought against him last month by Joseph R. Meehan, known professionally in the world of pro wrestling as Joey Ryan, before the United States District Court, Central District of California.
Meehan' lawsuit is specifically seeking millions of dollars in damages from Tsichlis, who had taken to social media, including Twitter and Twitch in response to the allegations made against Meehan during last summer’s #SpeakingOut movement, calling out wrestling personalities, promotions and members of the media, asking them to “publicly commit” against Meehan and asking promotions to no longer book him as a performer.
Tsichlis is seeking a motion to dismiss with his attorneys arguing that the State of California has no personal jurisdiction over the former ROH talent as he has never been to California, never performed in California and does not and has not ever owned any property in the State of California. It also argues that while Meehan is arguing that he has suffered damages in California, that "the Complaints does not allege that Tsichlis has minimum contacts" in California and "is subject to personal jurisdiction in this Court."
It also argued that while Meehan claimed Tsichlis' online behavior and statements hurt Meehan worldwide, he is requiring Tsichlis to have to travel from Pennsylvania to defend himself in California and that while Meehan's original complaint featured 92 paragraphs of comments made by Tsichlis, none of them alleged he was in the State of California when they were published online, so again, there is no local jurisdiction over Tsichlis - and that Meehan's own lawsuit made numerous references to the virtual, world-wide-web community, which obviously, was well beyond Californnia itself.
In responding, Tsichlis' attorneys argued, "In essence, Meehan’s Complaint sets forth multiple redundant claims, both intentional and negligent, seeking an exorbitant amount of damages for alleged defamatory statements made by Tsichlis throughout the world. Meehan’s Complaint has not set forth sufficient allegations to establish that this Court has personal jurisdiction over Tsichlis. In fact, taking Meehan’s allegations to their illogical conclusion, Meehan could bring suit against Tsichlis anywhere in the world. Perhaps he seeks to establish a new jurisdictional doctrine that confers worldwide personal jurisdiction for dissemination of opinions over the world-wide-web? Fortunately, constitutional restraints prohibit this doctrine."
In requesting the dismissal, Tsichlis is arguing there is no general jurisdiction over him, that specific jurisdiction cannot be exercized and that some of the damages Meehan is claiming "only tangentially relate" to the State of California.
Tsichlis' attorneys argued, "All social media and other internet sites are worldwide. Meehan does not allege that any of the wrestling companies with which he did business are incorporated in the state of California or have systemic contacts with the state of California. Meehan does not identify all the locations of the Bar Wrestling venues that he lost, that is, whether any of them were outside the state of California. His claims of emotional distress have no relationship with California, other than the fact that it is his residence. "
Tsichlis argued that Meehan can easily file a claim and pursue a lawsuit in the State of Pennsylvania, noting the State "has a profound interest in adjudicating conduct that occurs within its borders and ensuring that any attempt to restraint a citizen’s speech is constitutionally permissible and not overbroad. California, of course, has an interest in ensuring that its citizens are compensated if a tortious act is committed, but that compensation can just as easily be awarded by a Pennsylvania Court if it is warranted. Judicial efficiency does not weigh in favor of either party. Meehan has evidence in California and Tsichlis’ evidence would be located in Pennsylvania. As the claims involve statements made over the internet, the number of live witnesses, other than the parties, would be limited and therefore not impose undue burdens on Meehan."
They also pointed out that Meehan has multiple lawsuits over similar claims in the State of California, claiming:
"Clearly, Meehan’s goal in filing multiple separate California lawsuits seeking compensation for the same damages is to be relieved of the burden of seeking his millions of dollars in separate states. Considering the amount of damages claimed and the adverse financial effects on Tsichlis if Meehan were successful, less weight should be given to Meehan’s convenience. Lastly, Pennsylvania is an alternative forum.
Based upon the fact that Tsichlis has not purposely interjected himself into the state of California and the difficulty and expense for Tsichlis in defending himself in California, the exercise of personal jurisdiction over him would be unreasonable. This conclusion is further supported by the ability of Pennsylvania courts to adjudicate this matter in the same manner as a California court. Tsichlis never anticipated being haled into court in California for alleged actions that would have occurred in Pennsylvania."
A hearing has been set for 12/21/2020 at 10:00 AM before the court in response to Tsichlis' motion.
Meehan, in his lawsuit, alleged that statements made against him by Tsichlis have cost him monthly losses of of $500 per month from Cameo video messages, $1,000 per month in merchandising revenue, $1,000 per month plus additional tips and "subscription shares" from his Twitch account, losses of $1,500 a month from his Bar Wrestling promotion no longer receiving streaming and distribution earnings, $2,000 in losses per month from Bar Wrestling events, $3,000 per month in loss of revenue from his Patreon account, and losses of $8,000-$10,000 per month in lost wrestling bookings. He also cited losing three Bar Wrestling venues, including The Bootleg Theatre in Los Angeles, American Legion Hall in Baldwin Park, CA and Glass House in Pomona, CA. Ryan also alleged that he has lost substantial social media followers and is no longer on pace to add 1,000 new followers per month, as he had prior to the allegations being made public.
The lawsuit alleged that Tsichlis, since June 2020, has made 26 statements that fall under libel, present Meehan under a false light, intentionally interfere with Meehan's finances, negligently interfered with Meehan's finances and intentionally inflicted emotional distress, among other allegations. Meehan alleged that Tsichlis committed these actions because Meehan slept with Tsichlis’ “partner” when Meehan was not aware of their relationship.
Tsichlis’ first comment about Meehan, in June, according to the lawsuit, reads, “You actively pursued my fiance and were instrumental in helping ruin my life. You are the lowest form of human scum on the face of the earth. You’re going to burn. Your time is up. And you [expletive deleted] deserve it. Twitter.com/JoeyRyanOnline…”
In the lawsuit, Meehan responded, “Defendant’s First Statement was published at the beginning of the #SpeakingOut movement. Defendant’s Frist [sic] Statement was not intended by Defendant to “speakout” about a sexual assault but so that could be part of, and be a participant in, a movement that was gaining traction in the professional wrestling community. Defendant intended on being included in the class of victims that encompassed the #speakingout movement, albeit Defendant’s intentions were misplaced. The #SpeakingOut movement did not include persons whose partners committed infidelities with unknowing participants in infidelity. Defendant’s First Statement was made to cast Plaintiff in a false light, for example, that Plaintiff was a “homewrecker” of some sort. Although the incident of his partner cheating on Defendant eight years prior to Defendant’s statements herein described and Plaintiff did have a sexual encounter with the woman Defendant refers to in Defendant’s First Statement, Plaintiff did not “pursue” the woman and moreover had no idea that the woman was in any way engaged or was in a committed relationship with Defendant, or any other person.”
Meehan also alleges that Tsichlis published a false story about him on Twitter. The lawsuit allegation reads:
On or about June 20, 2020, Defendant used his Twitter account with the handle “primeau31” to make the statement, “o.k. I have something new to share. If you know me I grew up in Philly, [sic] have a lot of friends there. This is [sic] account from a friend of mine whom [sic] has zero relation to the wrestling industry that looked at my Twitter tonight 2015 #SpeakingOut #JosephRyanMeehan #JoeyRyan” and then attached what appears to be a series of text messages between Defendant and a purported unidentified woman. The unidentified woman described a sexual encounter with Plaintiff wherein Plaintiff made sexual advances without the consent of the unidentified woman. The attached text messages from the unidentified woman states, “I met up with him on a tinder date!!!” Defendant texted, “…what. Joey Ryan??”. The unidentified woman texted, “Like when I first got my apartment and he kept trying to come to my house and I had him kicked out of a bar because he kept touching my legs and trying to go up my skirt! …I’m SO glad I got him kicked out. It sounded so familiar like I know this person. Yup. [Expletive deleted] Tinder. 2014? 2015? Maybe. He said he was traveling and I was like okay whatever, let’s go out for drinks and if [sic] course, sweeney’s cause it was close and if I need someone kicked out they’re gone and flagged. …That’s terrifying. He was pushy af [as [expletive deleted] and kept touching me and making me feel so weird.”
In response, Meehan’s filing stated, “Defendant’s Second Statement was false in that Plaintiff never went on a date through Tinder (dating application) in Philadelphia at bar called Sweeny’s in 2014 or 2015. Plaintiff has never used or been a member of the application Tinder. Defendant fabricated the messages with the unidentified woman in order to be a part of the #SpeakingOut movement, inter alia, in order to stay connected to the professional wrestling community.”
Meehan’s lawsuit also alleged that Tsichlis published his statements, knowing others would republish them due to the momentum of the #SpeakingOut Movement, that Tsichlis “used his Twitter account with the handle “primeau31” to -
*Make the statement in an attachment showing a photo of a sign stating “I’m with a rapist” next to a drawing of a hand/finger directing the reader to another screenshot of a post made” by Meehan.
*Warned against users patronizing Meehan’s YouTube page by stating “reminder that Joey Ryan (Joseph Meehan) is an accused serial sexual predator and that watching any of the videos uploaded onto his YouTube channel @BarWrestling playlist is giving him money.,”
*Pushing others to report Meehan’s Bar Wrestling promotion to Twitter and YouTube to “deplatform” Meehan, pushing others via Twitter to help prevent Meehan from earning revenue from his YouTube channel.
*Falsely accused Meehan of molesting women, that Tsichlis implied Meehan was going to sexually assault someone at a ‘Taco Truck’ - a reference to an allegation by a woman that Meehan responded to via YouTube, breaking down their night, which including getting food from a ‘Taco Truck’ - or implied that Meehan and the person Tsichlis was conversing with were going to sexually assault someone together.
*Pushed for others to prevent Meehan from being able to return to professional wrestling via his Twitter comments.
*Pushing other performers to cancel themselves off events if Meehan was booked as a pro wrestler, declaring that if they did not they were “every bit as guilty” - implying Meehan was indeed guilty of the accusations against him.
*Made reference to “evidence of another WWE performer who’s engaged in preying on children online” on Twitter while commenting on Meehan. Meehan responded that Tsichilis, “accused Plaintiff of committing crimes upon “children” and refers to Plaintiff as “another WWE performer”. Plaintiff has never committed the acts that Defendant accused Plaintiff of committing including the accusation related to “preying on children online.” “
*Posted calls to action via Twitter to pro wrestling personalities, pro wrestling promoters and pro wrestling promotions, requesting they pledge “accountability and public commitment” to not allow Meehan to work for them, to “commit publicly and unify” against Meehan and in the case of California’s Pro Wrestling Guerrilla, which Meehan helped found, declare their plans regarding Meehan’s involvement going forward.
*Posted a call to action via Twitter to several pro wrestling production companies, asking them to pledge they would not tape or film any events featuring Meehan performing.
*Stating he was contacting Twitch and Cameo in an attempt to “deplatform” Meehan.
*Published a false statement that Meehan committed rape.
*Made a false statement that Plaintiff forced himself on any person for sexual gratification.”
Meehan’s lawsuit also makes reference to an online video produced by Tsichlis:
“On or about August 7, 2020, Defendant created a thirty-seven-minute video (Defendant’s Video) that was viewed at least 808 times on YouTube by September 18, 2020. The video was posted on YouTube and made available on Twitter. In the video. Defendant sits in front of a backdrop of screenshots of many of the Defamatory Statements above listed.
In Defendant’s Video, Defendant was serious and was without any sense or indication that his statements were meant to be taken as a joke. In fact, Defendant screamed or spoke with a raised voice throughout the Defendant’s Video and was visibly angry.
In Defendant’s Video, Defendant states that Plaintiff does “not [take] no for an answer” in reference to Plaintiff’s sexual encounters with women and that Plaintiff “used power and influence” to assault women.
In Defendant’s Video, Defendant makes it clear that Defendant knows, and has known, that Plaintiff lives in Los Angeles and his lived in Los Angeles in his professional wrestling career when he said, “Especially when he is flying from So Cal. He just wants to do his work. Do his shot and then get back on the plane right back to So Cal” and when he said, “One Joseph Ryan Meehan out of Southern California”
In Defendant’s Video, Defendant made his intent clear about destroying Plaintiff financially, “We are taking ‘Joey Ryan’ away from “Joseph Ryan Meehan” “the very least we can do is make sure that the ‘Joey Ryan’ brand is laid out to rest.” That is to say that Defendant was aware of the high value in the brand of “Joey Ryan” the wrestler and that Defendant intended on ruining the Joey Ryan brand to such a degree that Plaintiff could never again profit, financially or otherwise, from the “Joey Ryan brand”.
In Defendant’s Video, after naming professional wrestlers who were in the past accused of involvement in scandal, Defendant states that those wrestlers “are still here. And are still making money off the business. Not you [referring to Plaintiff]. We’re putting our foot down. We’re not letting you back in the ring. I will remind professional wrestling every single day if I have to. I will get on Twitter. I will get on social media. I will email promotors. I will email bookers. …Your house of cards and your ilk, it’s going to start to fall.…And if I can’t do it myself. If I’m not in locker rooms myself. Then I’m calling on [names of over thirty names of persons and business entities involved in professional wrestling promotions]. …Keep him [referring to Plaintiff] out of wrestling. …Don’t ever let this man have access to money from the professional wrestling business ever again. …Joseph Meehan will never step foot in your rings again.”
Meehan’s lawsuit responded to the video, noting, “Defendant uses the word “accountable” to mean that Plaintiff assaulted women and committed sexual crimes against women, especially in the face of Defendant’s other statements published prior to Defendant’s Twenty-Fourth Statement and on the same day when Defendant published Defendant’s Video. Defendant implied that Plaintiff was going to pay for his sexual crimes against women because Defendant was intending on being the person that prevents Plaintiff from ever again engaging in professional wrestling.”
In the lawsuit, Meehan argues that Tsichlis was fully aware how Twitter and other social media websites worked, that his statements could be read and republished by others, that the allegations "would reach the eyes and ears of at least hundreds to thousands of persons", was fully aware that the defamatory statements "would cause a negative effect" on Meehan as a professional wrestler and promoter, that Meehan's reputation would be damaged in the "community of California and the virtual community located in the world-wide-web that were related to" Meehan's career.
Meehan’s lawsuit stated, “It was, is, and has always been, untrue, and false, that (1) Plaintiff assaulted women; (2) Plaintiff committed a sexual battery on women; (3) Plaintiff committed (1) and (2) in a manner that would be considered a felony;(4) women engaged in sexual acts with Plaintiff without the consent of those women; and/or (5) women were forced by Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of fear, threat and intimidation.”
Meehan’s filing also states, “Defendant’s defamatory statements were not privileged and Plaintiff did not consent to the publication of the defamatory statements. Plaintiff, in fact, implored defendant to stop the publication of the defamatory statements” but that Tsichlis “responded by repeating more statements that (1) Plaintiff assaulted women; (2) Plaintiff committed a sexual battery on women; (3) Plaintiff committed (1) and (2) in a manner that would be considered a felony;(4) women engaged in sexual acts with Plaintiff without the consent of those women; and/or (5) women were forced by Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of fear, threat and intimidation.” - and that Tsichlis knew these statements were untrue, “acted in reckless disregard for the truth in the defamatory statements by not conducting any diligence, inquiry and investigation as to whether or not the defamatory statements were true or false” and failed to use “reasonable care” to determine the truth before publishing.
Meehan is seeking economic damages of $200,000 per claim (eight claims total) or the amount lost as a result of Tsichlis' conduct "multiplied by the months from June 21, 2020 to the date of the award of damages", be awarded $5 million in non-economic damages, award Meehan “his costs, investigatory fees and expenses to the fullest extent provided by law”, “award punitive and exemplary damages against defendant and in favor of Plaintiff in the sum of $10,000,000.00 by reason of defendants’, and each of them, malice, hatred, ill-will, despicable and intentional acts” as well as “such additional and further relief as the Court deems just and proper.”
Meehan is also asking for a permanent injunction restraining Tsichlis from "making and publishing the defamatory statements or any iteration of the defamatory statements as set forth above and herein, Ordering defendant to retract the defamatory statements as set forth above and herein” and “ Ordering defendants to direct any, and all, websites that defendants posted the defamatory statements as set forth above and herein, to delete the defamatory statements, Award Plaintiff his actual damages; 5. Award Plaintiff his costs, investigatory fees and expenses to the fullest extent provided by law, Award punitive and exemplary damages against defendants and in favor of Plaintiff in the sum of $10,000,000.00 by reason of defendants’, and each of them, malice, hatred, ill-will, despicable and intentional acts, Awarding Plaintiff such additional and further relief as the Court deems just and proper.”
Meehan also requested “that this this court declare as false statements that 1) Plaintiff assaulted women; (2) Plaintiff committed a sexual battery on women; (3) Plaintiff committed (1) and (2) in a manner that would be considered a felony;(4) women engaged in sexual acts with Plaintiff without the consent of those women; and/or (5) women were forced by Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of fear, threat and intimidation, including Defendant’s false statement that Plaintiff had, and used, business power in professional wrestling.”
Meehan has requested a jury trial.
Meehan was the subject of numerous accusations during the #SpeakingOut movement on Twitter over the summer. Meehan’s work as a professional wrestler and independent wrestling promoter halted when the allegations first came to light. Meehan did answer some of the claims in a now-deleted YouTube video, a video which is referenced in this lawsuit. He is not known to have, as of this writing, been criminally charged in relation to any of the accusations.
Tsichlis wrestled from 2005 to 2019 for Ring of Honor as well as a number of independent promotions in the Northeast.
Meehan filed six other lawsuits over the last several weeks, all denying any claims of sexual assault against him and alleging that the women who made the claims used social media postings to defame him, hurting his ability to make money as a professional wrestler through his performances, merchandise, Patreon account, the loss of his Bar Wrestling independent wrestling promotion, his Twitch channel and Cameo video messaging. In many of those lawsuits, he is seeking sizable monetary damages.
Meehan is also pursuing a breach of contract lawsuit against Impact Wrestling parent company Anthem Wrestling.
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