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Joseph R. Meehan, professionally known in pro wrestling circles as Joey Ryan, filed a second lawsuit against women who came out against him during the #SpeakingOut movement on 9/24. The second suit, filed before the City of Los Angeles' Central Judicial District names one woman (PWInsider will use "Cali" to refer to her as she is a resident of California) as well as ten additional Janes Does to be named. It appears the Does have been added so Ryan has the ability to add them to this lawsuit if he opts to do so
The 38-page lawsuit features a lot of background material on Ryan, his career and social media that is identical to the other lawsuit filed on 9/24 before specifically noting that Cali took to Twitter to make accusations about Ryan's alleged sexually abusive nature towards her and referring to Ryan's other alleged victims, all of which the lawsuit describes as a six different "defamatory statements" about Ryan.
The lawsuit also alleges the sixth statement was specifically "intended to prevent Plaintiff from earning any income through wrestling and destroy the credibility of his denial in Plaintiff’s video, i.e., that Plaintiff did in fact assault Defendant. [Name redacted by PWInsider] Sixth Statement was intended by Defendant to reach out to any of Defendant’s Instagram followers and those interested in Plaintiff’s services that he was offering through, YouTube, Patreon and Cameo, etc., to not use those services."
The lawsuit alleges that "Cali" used Twitter to defame Ryan by publishing "the defamatory statements described above and incorporated by reference herein, which included, that (1) Plaintiff assaulted defendant; (2) Plaintiff committed a sexual battery on defendant; (3) Plaintiff committed (1) and (2) in a manner that would be considered a felony;(4) defendant engaged in sexual acts with Plaintiff without Defendant’s consent; and/or (5) defendant was forced by Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of fear, threat and intimidation."
The lawsuit also alleged:
On information and belief, defendant did use other social media websites to write, and thereby publish, the defamatory statements described above and incorporated by reference herein.
Prior to publishing the defamatory statements, defendant was fully aware that Twitter and the other social media websites used to publish defendant’s defamatory statements described above and incorporated by reference herein had members and subscribers located worldwide and were connected to the professional wrestling industry, because defendant was a user, subscriber and account holder of Twitter and had Twitter handles and thus understood how Twitter and social media websites worked.
Prior to publishing the defamatory statements, defendant was fully aware that Twitter had a membership of approximately in excess of three hundred million persons and that by publishing the defamatory statements, the defamatory statements would be read by hundreds to thousands of Twitter’s membership, because defendant was a user, subscriber and account holder of Twitter and had Twitter handles and thus understood how Twitter and social media websites worked.
Prior to publishing the defamatory statements, defendant was fully aware that publishing the defamatory statements described above and incorporated by reference herein would reach the eyes and ears of at least hundreds to thousands of persons, and that after defendant did publish the defamatory statements described above and incorporated by reference herein that the published defamatory statements did reach the eyes and ears of at least hundreds to thousands of persons, because defendant was a user, subscriber and account holder of Twitter and had Twitter handles and thus understood how Twitter and social media websites worked.
Defendant published the defamatory statements described above and incorporated by reference herein fully aware that Plaintiff lived in Los Angeles, California and that Plaintiff was a professional wrestler and promotor (sic) in the state of California. Defendant was fully aware that Plaintiff was a principal of Bar Wrestling and that Bar Wrestling promoted wrestling matches in bars in Los Angeles, California.
Defendant was fully aware that Defendant’s defamatory statements described above and incorporated by reference herein would cause a negative effect on Plaintiff as a professional wrestler and wrestling promotor, i.e., defendant intended that the defamatory statements would prevent Plaintiff from practicing as a professional wrestler and further wrestling promotions. In addition, defendant was fully aware that because of the defamatory statements, Plaintiff’s reputation would be damaged in the community in California and the virtual community located in the worldwide-web that were related to Plaintiff’s as a professional wrestler and wrestling promotor.
It was, is, and has always been, untrue, and false, that (1) Plaintiff assaulted defendant; (2) Plaintiff committed a sexual battery on defendant; (3) Plaintiff committed (1) and (2) in a manner that would be considered a felony;(4) defendant engaged in sexual acts with Plaintiff without Defendant’s consent; and/or (5) defendant was forced by Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of fear, threat and intimidation.
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. Defendant responded by repeating more statements that (1) Plaintiff assaulted defendant; (2) Plaintiff committed a sexual battery on defendant; (3) Plaintiff committed (1) and (2) in a manner that would be considered a felony;(4) defendant engaged in sexual acts with Plaintiff without Defendant’s consent; and/or (5) defendant was forced by Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of fear, threat and intimidation.
Prior to publishing the defamatory statements, defendant knew and otherwise were fully aware that the defamatory statements were not true.
Prior to publishing the defamatory statements, defendant 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.
Prior to publishing the defamatory statements, defendant failed to use reasonable care to determine the truth or falsity in the defamatory statements by not conducting reasonable diligence, inquiry and investigation as to whether or not the defamatory statements were true or false.
The hundreds to thousands of person who did read defendant’s defamatory statements on Twitter and other social media websites understood the defamatory statements to be of and concerning Plaintiff and were understood by the hundreds to thousands of persons to mean that (1) Plaintiff assaulted defendant; (2) Plaintiff committed a sexual battery on defendant; (3) Plaintiff committed (1) and (2) in a manner that would be considered a felony;(4) defendant engaged in sexual acts with Plaintiff without Defendant’s consent; and/or (5) defendant was forced by Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of fear, threat and intimidation.
Because of the facts and circumstances that were known to the hundreds to thousands of readers of the defamatory statements, including that Plaintiff was a professional wrestler and wrestling promotor in California, (1)The defamatory statements tended to injure Plaintiff as a professional wrestler and wrestling promotor, and otherwise injure Plaintiff whether or not as a professional wrestler and wrestling promotor; (2)The defamatory statements exposed Plaintiff to hatred, contempt, ridicule, and shame by (1) persons residing in California; (2) persons involved and interested in professional wrestling and wrestling promotions; and (4) those persons using the world-wide-web interested in Plaintiff, professional wrestling and wrestling promotions; and (3)The defamatory statements discouraged others from associating or dealing with Plaintiff.
Ryan has requested damages for negligent infliction of emotional distress, for libel against him and for compensatory damages against each defendant, including:an amount in excess of $25,000.00 for economic damages, $25,000 for non-economic damages, for an order retracting and correcting the defamatory statements, for equitable relief based on principles that are fair and just."
Ryan is also requesting the court rules for "an injunction ordering to retract the defamatory statements and to take the defamatory statements down from the websites in which the statements were made and published; specifically defendant should retract and take down any, and all, defamatory statements made and published by defendant that (1) Plaintiff assaulted defendant; (2) Plaintiff committed a sexual battery on defendant; (3) Plaintiff committed (1) and (2) in a manner that would be considered a felony;(4) defendant engaged in sexual acts with Plaintiff without Defendant’s consent; and/or (5) defendant was forced by Plaintiff to engage in sexual acts with Plaintiff, forced meaning the use of fear, threat and intimidation; and any iteration of such statements."
In this lawsuit as well, Ryan has also requested a jury trial.
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