John Gallman Lawsuit

ELECTRONICALLY FILED - 2021 Feb 24 8:41 AM - HORRY - COMMON PLEAS - CASE#2021CP2601096
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

) FIFTEENTH JUDICIAL CIRCUIT
COUNTY OF HORRY )
C/A:
John Gallman, )
)
Plaintiff, )
)
Vs. ) SUMMONS
) (JURY TRIAL DEMANDED)
Luke Rankin, Julie Emerson, Laginappe )
Communications Group, LLC, Christian )
Boschult, Waccamaw Publishers, Inc., the )
South Carolina Industry Project, the )
American Industry Project, Tyler Servant, )
Jamie Huval, David Satterfield, Ace Tomato )
Enterprises, Inc., Robert Cahaly a.k.a. )
Campaign Services, LLC, Spring Strategies, )
LLC, Raegan Quinn Smith, and Rebecca )
Quinn Mustian, )
)
Defendants, )
____________________________________)
YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action,
a copy of which is herewith served upon you, and to serve a copy of your Answer to the said
Complaint on the Plaintiff’s attorney, Tucker S. Player, at the Player Law Firm, LLC, 1415
Broad River Road, Columbia, South Carolina 29210, within thirty (30) days after the service
hereof, exclusive of the date of such service and if you fail to answer the Complaint within the
time aforesaid, the Plaintiffs in this action will apply to the Court for the relief demanded in the
Complaint. Dated at Columbia, South Carolina on the 24thnd day of February, 2021
THE PLAYER LAW FIRM, LLC

s/Tucker S. Player, Esq.
SC Bar No. 16217
1415 Broad River Road
Columbia, SC 29210
(803) 772-8008
Attorney for the Plaintiff
Columbia, South Carolina
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) FIFTEENTH JUDICIAL CIRCUIT
COUNTY OF HORRY )
C/A:
John Gallman, )
)
Plaintiff, )
)
Vs. ) COMPLAINT
) (JURY TRIAL DEMANDED)
Luke Rankin, Julie Emerson, Laginappe )
Communications Group, LLC, Christian )
Boschult, Waccamaw Publishers, Inc., the )
South Carolina Industry Project, the )
American Industry Project, Tyler Servant, )
Jamie Huval, David Satterfield, Ace Tomato )
Enterprises, Inc., Robert Cahaly a.k.a. )
Campaign Services, LLC, Spring Strategies, )
LLC, Raegan Quinn Smith, and Rebecca )
Quinn Mustian, )
)
Defendants, )
____________________________________)
COMES NOW, Plaintiff John Gallman, by and through his undersigned attorney, and
submits the following Complaint and alleges as follows:
PARTIES AND JURISDICTION
1. Plaintiff is a citizen and resident of Horry County.
2. Defendant Luke Rankin is a citizen and resident of Horry County.
3. American Industry Project is a Political Action Committee with an office in Alexandria,
Virginia. According to the IRS 990 report for American Industry Project, there are three
directors: Tyler Servant (President) based in Horry County South Carolina; Jamie Huval
of Louisiana, and David Satterfield (treasurer) of Alexandria, Virginia. (Exhibit 1).

4. The South Carolina Industry Project is part of the American Industry Project. The same
three directors control both the American Industry Project and the South Carolina
Industry Project.
5. Defendant Tyler Servant is a citizen and resident of Horry County and is the President of
American Industry Project and the South Carolina Industry Project.
6. Upon information and belief, David Satterfield is a resident of the State of Virginia and is
the treasurer of the American Industry Project and the South Carolina Industry Project.
7. Upon information and belief, Jamie Huval is a resident of the State of Louisiana and is a
director of the American Industry Project and the South Carolina Industry Project.
8. Defendant Julie Laginappe is a citizen and resident of the State of Louisiana. She is a
director of Laginappe Communications Group.
9. Laginappe Communications Group, LLC is a Louisiana limited liability company based
in Baton Rouge, LA. Defendant Julie Emerson is the founding member of the LLC.
10. Waccamaw Publishers, Inc. is a South Carolina corporation based in Horry County,
South Carolina. It publishes the Horry Independent Newspaper and operated the
MyHorryNews Website. It is responsible for the acts of Defendant Boschult under the
theory of respondeat superior and common law agency.
11. Christian Boschult is a Horry County Citizen and employee of Waccamaw Publishers,
Inc.
12. Campaign Services, LLC is a dissolved Georgia limited liability company based in
Atlanta, Georgia operated by Defendant Robert Cahaly.
13. Robert Cahaly is a citizen and resident of Atlanta, Georgia.

14. Spring Strategies, LLC is a South Carolina limited liability company based in Columbia,
South Carolina.
15. Reagan Quinn Smith and Rebecca Quinn Mustian are both citizens and residents of
Lexington County, South Carolina.
16. All Defendants are subject to the jurisdiction of this Court by being citizens and residents
of South Carolina or through intentional tortious actions directed at and committed in
Horry County in 2020. Pursuant to the South Carolina Long Arm Statute, the intentional
commitment of a tort in South Carolina subjects all Defendants to personal jurisdiction in
South Carolina.
17. For purposes of this Complaint, the defendants shall be referenced collectively
throughout this pleading with the following designations: the “Rankin Group” shall
include Defendant Rankin, Defendant Spring Strategies, LLC, Defendant Smith, and
Defendant Mustian; the “Emerson Group” shall include Defendant Emerson, Laginappe
Communications Group, LLC, Ace Tomato Enterprises, Inc. a/k/a Campaign Services,
LLC, and Defendant Cahaly; the “AIP Group” shall include the American Industry
Project, the South Carolina Industry Project, Defendant Servant, Defendant Huval and
Defendant Satterfield; the “Boschult Group” shall include Defendants Boschult and
Waccamaw Publishers, Inc.
18. Jurisdiction and venue are proper before this Court.
FACTUAL BACKGROUND
19. Plaintiff ran for public office against Defendant Rankin in the republican primary in
2020.
20. After the initial primary, Plaintiff was placed in a runoff against Rankin only to be the
republican candidate for Senate District 33 in Horry County South Carolina.
The Dossier
21. On or about June 2, 2020, a dossier purportedly containing documents selected from
Plaintiff’s divorce file [hereinafter the “Dossier”] were distributed to numerous media
organizations across the state. Exhibit 2, “Luke Rankin’s Sealed Divorce File: What’s
Good for the Goose …”, FitsNews, June 16, 2020.
22. Robert Halpin repeatedly published false statements about Plaintiff on Facebook and at
polling stations on the runoff election date.
23. Robert Halpin also shared a screenshot on Facebook that appeared to be a Dropbox with
531 pages of documents from Plaintiffs divorce file. Exhibit 3
24. Robert Halpin is the husband of Luke Rankin’s paralegal, Bonnie Halpin. Exhibit 4.
25. Upon information and belief, this packet of information was paid for by Defendant
Rankin and distributed to numerous media outlets around the State of South Carolina.
26. Within these documents, the confidential mental health records of Plaintiff’s 10 year old
daughter were included.
27. More specifically, the Dossier purported to contain forensic interview notes from the
Children’s Recovery Center in Horry County. Those interview notes were from an
investigation concerning possible abuse by a third-party against the 10 year old daughter
of Plaintiff. These records are statutorily protected and confidential pursuant to S.C. Code
§ 19-11-95, S.C. Code § 44-22-100, and S.C. Code § 62-11-310.
28. The Children’s Recovery Center (CRC) is a nonprofit 501(c)3 organization offering child
advocacy center programs in Horry and Georgetown Counties in South Carolina,

pursuant to S.C. Code § 44-11-100, et seq., § 44-22-11, and §63-11-310. It provides
forensic interviews, medical examinations, and caring advocacy for children suspected of
having suffered abuse.
29. All documents from CRC were confidential and protected from disclosure under S.C.
Code § 19-11-95, S.C. Code § 44-22-100, and S.C. Children’s Code.
30. After receipt of the Dossier, the Boschult Group published an article on June 16, 2020,
seven days before the runoff election.
31. The Boschult Group refused to review the evidence possessed and offered by Plaintiff
that demonstrated that the incomplete and misleading information in the family court
documents was false.
32. The Boschult Group refused to publish or reference the evidence offered by Plaintiff that
demonstrated the allegations of abuse were false.
33. The Boschult Group refused Plaintiff’s invitation to review the entire Family Court file to
obtain the truth of the allegations.
34. The Boschult Group refused a plea from Plaintiff to not drag his 10 year old daughter into
a political mudslinging contest.
35. The news article published by the Boschult group actually states: “Notes from a
Children’s Recovery Center interview show that Gallman’s minor daughter alleged he
had hit mom on more than one occasion, and that he would frequently yell at her.”
Exhibit 5.
36. The Rankin Group directly referenced the Boschult group’s defamatory and illegal article
in its campaign advertisements. Exhibit 6.

37. The Boschult group’s defamatory and illegal article was quoted by the Emerson Group in
the ad purchases made on behalf of the AIP Group in television and printed media. The
mailer accused Plaintiff of being a child kidnapper by prominently displaying the words
“Amber Alert Threat” next to Plaintiff’s name. Exhibit 7.
38. Plaintiff previously sent Defendant Rankin videos of the alleged abuse incidents that
clearly showed he was not the aggressor. Exhibit 8.
39. More importantly, the Orders in the Family Court file repeatedly found no evidence of
spousal and/or child abuse.
40. More specifically, the Order arising from the hearing in which the mental health records
of Plaintiff’s minor child were exposed (illegally) found no evidence of any abuse by
Plaintiff.
41. Despite knowing that the allegations were untrue, Defendants flooded the airwaves, mail
services, and social media sites with direct quotes from Boschult article disclosing the
confidential mental health records of a 10 year old girl.
42. The Director of the Children’s Recovery Center [hereinafter “CRC”], Louise Carson,
learned of the disclosure of a minor’s mental health records and contacted Defendant
Rankin’s office. Ms. Carson informed his office that the new article was disseminating
the confidential mental health records of a minor.
43. Defendant Rankin’s office responded “what would you have us do?”
44. Ms. Carson requested that the advertisements be taken down immediately.
45. Despite the direct request from CRC to stop, Defendants continued to publish television
and social media ads that contained direct references to the illegally disclosed mental
health records of Plaintiff’s 10 year old daughter.

46. The only disclosures made by CRC were via a confidential report provided to MUSC, the
South Carolina Department of Social Services, the Horry County Sheriff, and the Indigo
Law Firm in September 2019.
47. No interview notes were ever produced to anyone outside of the Children’s Recovery
Center. If the Boschult Group actually possessed the notes from the interview, they did
not obtain them lawfully.
48. Plaintiff did not know the contents of CRC’s Report until he was interviewed by
Defendant Boschult in June 2020. At that time, he denied the notes existed and accused
Boschult of lying. Only in September 2020, almost 3 months after the runoff election,
did he learn of the existence of the CRC report and the contents thereof.
“LRLindsayFinal”
49. At 12:25pm on the same day that Boschult Group published its defamatory article based
on the Dossier, the Emerson Group submitted a professionally produced, 30 sec
advertisement entitled “LRLindsayFinal” to be televised on local station WMBF.
Exhibit 9.
50. Upon information and belief, the “LRLindsayFinal” is a specific reference to Defendant
Rankin and, upon information and belief, his wife Lindsay Rankin’s approval of the
advertisement.
51. Upon information and belief, LRLinsdayFinal references the Dossier and quotes the
Boschult Group article that had yet to be published.
52. Pursuant to South Carolina and federal law, political action committees cannot coordinate
with political candidates or publish ads that either support a targeted candidate or attack
the opponent of a targeted candidate.

53. The actions of Defendants qualify as “coordinated communications” under the Federal
Election Commission’s regulations and should have been disclosed to the South Carolina
Ethics Commission.
54. More specifically, Defendant Servant violated South Carolina law by donating money to
another republican candidate in violation of S.C. Code § 8-13-1340, which constitutes a
misdemeanor under South Carolina law.
55. Upon information and belief, the Emerson Group, the AIP Group, and the Rankin Group
were either privy to the Dossier and/or the news article published by the Boschult Group
before June 16, 2020.
“SCIndustry911call”
56. One or more of the defendants created a television ad that purported to be a 911 call
made by the ex-wife of Plaintiff. However, this 911 call was fake, as Plaintiff made the
911 call, not his ex-wife.
57. The fake 911 call was ordered and paid for by Julie Emerson and Laginappe
Communications Group on behalf of the SC Industry Project on June 17, 2020. The
name of the advertisement is “SC Industry 911 Call.” Exhibit 10.
58. In the “SC Industry 911 Call,” a quote from Plaintiff’s ex-wife is read aloud in an
ominous tone while the sound of terrified breathing goes on in the background.
59. SCIndustry911Call also prominently displays the illegally obtained mental health records
of Plaintiff’s minor child across the entire screen. Exhibit 11 – Screen Shot of
SCInductry911Call.
60. Throughout the ad, the breathing intensifies until a voice says “9-1-1, what is your
emergency?” as the words “John Gallman, Unfit to Represent Our Values” is displayed
with “Paid for by South Carolina Industry Project, 1601 Assembly Street, P.O Box 7766,
Columbia, SC 29202 SCIndustryproject.org.”
61. The P.O Box 7766, Columbia, SC is currently registered to Philip Cahaly, the father of
Robert Cahaly. It was previously registered to Defendant Emerson and Robert Cahaly.
62. According to purchase invoices, the Emerson Group purchased advertisement times to
run this video and the LRLindsayFinal video in every available time slot across three
local television stations for the week leading up to the runoff election. The cost was
$77,225.00.
Other Defamatory Acts by Defendants
63. Defendants also published fliers that indicated Plaintiff abused his wife, was an unfit
father, and was mentally unstable. All of these allegations are false and intended to harm
Plaintiffs reputation.
64. On June 21, 2020, the Rankin Group posted an advertisement on Facebook provided a
direct link to the Boschult article.
65. On June 21, 2020, the Rankin Group published a video advertisement that exclaimed
“Suspect Name: John Gallman” and “Say NO! to domestic VIOLENCE” emblazoned
across three pictures of Plaintiffs’ face.
66. On June 20, 2020, the Rankin Group published a video advertisement that exclaimed
“John Gallman: ACCUSED OF: DOMESTIC VIOLENCE – POLICE REPORT”
emblazoned across a picture of Plaintiffs’ face.
67. On June 19, 2020, the Emerson Group, on behalf of the AIP group, published a flyer that
stated “punching, threats, surveillance, broken bones, terrified children. JOHN

GALLMAN is every mother’s nightmare” referencing the Boschult article of June 16,
2020.
68. On June 19, 2020, the Rankin group posted the following in a Facebook message: “John
Gallman’s record can only be found in police reports and court documents all pointing to
a history of John Gallman’s domestic abuse.”
69. On June 13, 2020, the Rankin Group posted the following in a Facebook message: “My
opponent, the unstable John Gallman.”
70. On June 10, 2020, the Rankin Group posted the following in a Facebook message: “Dark
outside money came in at the last minute distorting my record and supporting my
unstable opponent John Gallman.”
The Public Record
71. At the time the mental health records of Plaintiff’s 10 year old daughter were published
in television advertisements, mailers, Facebook posts and other media, the family court
file contained documents related to an emergency hearing in September 2019. That
hearing specifically dealt with the referral to CRC, made by SCDSS and/or therapists at
the Medical University of South Carolina, that resulted in the forensic interview at CRC.
72. Plaintiff’s ex-wife submitted the CRC records as part of the emergency hearing, which
were not provided to Plaintiff or his counsel prior to the hearing. Neither Plaintiff nor his
attorney knew what was in the CRC records until September 2020.
73. The records were never sealed as required under South Carolina law. In addition, failing
to protect the mental health records of Plaintiff’s daughter violated the standing orders in
the family court case, the statutory law of South Carolina as described above, and the
Rule 41.2 of the Rule of Professional Responsibility regarding privacy protection for
filings to protect the personal information of parties in a lawsuit.
74. However, the Order issued by the Family Court as a result of the September hearing, filed
and in the record as of September 23, 2019, specifically stated “The only statement
regarding neglect or abuse was the minor child’s statement about an incident where
Defendant-Father threw her on the bed in an attempt to retrieve her phone as she
describes it to prevent her from contacting her mother. The allegation was investigated
by SCDSS and no findings were issued as to abuse or neglect.” Emphasis added.
75. According to the Final Order issued by the Horry County Family Court
concerning the custody of Plaintiff’s children “(there was) no actual data to
confirm any type of abuse against either parent” and “there was no verifiable
data of domestic abuse by one party against the other, or child abuse” Emphasis
Added.
CAMPIGN FINANCE VIOLATIONS
76. All allegations of fact made previously are repeated as if set forth here verbatim
77. Despite the obvious coordination with a political action committee in violation of the law,
Defendant Rankin never listed any of the $77,225.00 paid to local television stations by
the Emerson Group and the AIP Group on his campaign disclosure forms filed with the
State Ethics Commission.
78. In the television ads that contained the mental health records of Plaintiff’s 10 year old
daughter, the address for the S.C. Industry Project is listed as “P.O. Box 7766, Columbia,
South Carolina.”
79. Despite the obvious coordination with a political action committee in violation of the law,
Defendant Rankin never listed any of the monies paid for the distribution of political
fliers attacking John Gallman paid for by the Emerson Group and the AIP Group on his
campaign disclosure forms filed with the State Ethics Commission.
80. Tyler Servant violated S.C Code § 8-13-1340 by donating funds to the Rankin Campaign
through his control of the American Industry Project and the SC Industry Project.
81. Upon information and belief, Tyler Servant filed numerous false reports with the ethics
commission to obfuscate the connection with the AIP Group and the Emerson Group.
82. Servant made a report on April 15, 2020 that claimed payments to “Campaign Services,
P.O. Box 56271, Atlanta, Georgia 30343” in the amount of $7304.85 as a “constituent
contact.” Servant claimed this was for the 2022 election cycle.
83. Campaign Services was dissolved by the Georgia Secretary of State in 2015. The P.O.
Box referenced by Defendant Servant is now registered to “Ace Tomato Enterprises,
Inc.” which is just another false front for Defendant Robert Cahaly.
84. Robert Cahaly is a citizen and resident of Atlanta, Georgia and is not a constituent of
Tyler Servant or Luke Rankin.
85. Upon information and belief, no advertisements or other campaign promotional materials
for the 2022 election have been created on behalf of Tyler Servant.
86. Upon information and belief, this payment was for campaign advertisements created by
the AIP Group and the Emerson Group for Defendant Rankin.
FOR A FIRST CAUSE OF ACTION

Defamation
87. All allegations of fact made previously are repeated as if set forth here verbatim.
88. Defendants knowingly, or with reckless disregard for the truth, published false statements
asserting Plaintiff was mentally unstable and that he physically abused his wife.
Defendants provided those statements to third parties by and through local news media
and social media wherein any user can access and view.
89. The written allegations about Plaintiff were defamatory and published with actual malice,
to wit: (a) the statements were disseminated despite Defendants knowing they were
false; (b) the statements contained illegally disclosed mental health records of Plaintiff’s
10 year old daughter; (c) and the advertisements published by the Emerson Group and
the AIP Group were all specific attacks on Defendant Rankin’s opponent in violation of
South Carolina and federal election/ethics laws.
90. The allegations by Defendants were false and made with the expectation and intention by
Defendants that such allegations would harm Plaintiff’s reputation and deter third persons
from associating or dealing with the Plaintiff.
91. As a result of Defendant’s defamation, Plaintiff has been specially harmed and damages
have been incurred, including but not limited to, actual and future damage to reputation.
In addition, Plaintiff lost substantial business and clients as a direct result of false and
defamatory statements published by Defendants.
92. Plaintiff is entitled to recover consequential, nominal, actual, and special damages, costs,
and punitive damages as a direct result of Defendants’ defamation.
FOR A SECOND CAUSE OF ACTION

Intentional Infliction of Emotional Distress
94. Defendants intentionally and/or recklessly inflicted severe emotional distress, or was
certain, or substantially certain, that such distress would result from their conduct.
95. Defendants’ conduct was so extreme and outrageous so as to exceed all possible bounds
of decency and must be regarded as atrocious, and utterly intolerable in a civilized
community.
96. Defendants’ actions caused Plaintiff severe emotional distress.
97. Plaintiff’s emotional distress was severe such that no reasonable man could be expected
to endure it, to wit: Plaintiff was forced to seek therapy for the mental stress and anguish
caused by the intentional destruction of his reputation, loss of business and income
caused by the attacks on him.
and punitive damages as a result of Defendants’ intentional infliction of emotional
distress.
FOR A THIRD CAUSE OF ACTION

Invasion of Privacy (Wrongful Publication of Private Affairs)
100. Defendants intentionally disclosed facts in which there was no legitimate public interest
with actual malice an intent to harm Plaintiff.
101. The private facts, specifically the mental health records of a 10 year old daughter of
Plaintiff, were publicized to hundreds of thousands of people in District 33 over the
course of 2 weeks in June 2020. At the time of this Complaint, a google search of
Plaintiff results in articles that refer to him as a domestic abuser.
102. The disclosure of the mental health records of his 10 year old daughter was highly
offensive and caused serious mental injury to Plaintiff as it pitted his own child against
him in a public forum on an issue that was heard and decided as unfounded by the
presiding judge in family court.

and punitive damages as a result of Defendants’ invasion of privacy.
FOR A THIRD CAUSE OF ACTION

Invasion of Privacy (Wrongful intrusion into private affairs)
105. Defendant intentionally, substantially and unreasonably intruded into issues that were
private and of a nature that a normal person would expect to be free from exposure to the
public.
106. The CRC records are protected by statute and deemed confidential under South Carolina
law.
107. The publication and publicity of the mental health records of Plaintiff’s 10 year old
daughter, which were not deemed credible or probative by the presiding court, was
outrageous and showed shocking disregard for the rights of Plaintiff and resulted in
serious mental injury and humiliation.
and punitive damages as a result of Defendants’ invasion of privacy.
FOR A FIFTH CAUSE OF ACTION

Civil Conspiracy
110. Defendants all conspired to violate mental health privacy laws and campaign finance
laws in an effort to personally injure Plaintiff, destroy his campaign, and pitted his 10
year old daughter against him in a political campaign.

111. Defendants committed overt acts in furtherance of the conspiracy by creating and
publishing false advertisements that used illegally obtained mental health records of a 10
year old girl in violation of South Carolina campaign finance laws.
112. As a direct and proximate result of Defendants actions, Plaintiff suffered special
damages, to wit: Plaintiff suffered (1) irreparable damage to his relationship with his
daughter and (2) severe emotional distress due to the alienation between himself and his
daughter caused by the dissemination and misrepresentation of his divorce records to the
public.
and punitive damages from Defendants upon a finding of civil conspiracy.
WHEREFORE, having fully set forth his Complaint against Defendant, Plaintiff prays for the
following relief: That a jury be impaneled to decide all disputed issues of fact and that Plaintiff
be awarded a judgment against Defendants in such amounts and upon such terms as will fully
and fairly compensate Plaintiff for his nominal, actual, general, special and consequential
damages as will be proven during the trial of this action; That Plaintiff be awarded punitive
damages against Defendants as found appropriate by the Court and trier of fact; and for such
other and further relief as this Court deems just and proper.
Respectfully Submitted
s/Tucker S. Player, Esq.

SC Bar 16217
Player Law Firm, LLC
PO Box 21005
Columbia, SC 29221
803-772-8008 (phone)
803-772-8037 (fax)
Tucker@playerlawfirm.com
Attorney for Plaintiffs
This 23rd day of February, 2021

John Gallman Lawsuit

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ELECTRONICALLY FILED - 2021 Feb 24 8:41 AM - HORRY - COMMON PLEAS - CASE#2021CP2601096

STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

THE PLAYER LAW FIRM, LLC

submits the following Complaint and alleges as follows:

PARTIES AND JURISDICTION

1. Plaintiff is a citizen and resident of Horry County.

2. Defendant Luke Rankin is a citizen and resident of Horry County.

3. American Industry Project is a Political Action Committee with an office in Alexandria,

of Louisiana, and David Satterfield (treasurer) of Alexandria, Virginia. (Exhibit 1).

American Industry Project and the South Carolina Industry Project.

director of Laginappe Communications Group.

9. Laginappe Communications Group, LLC is a Louisiana limited liability company based

theory of respondeat superior and common law agency.

Atlanta, Georgia operated by Defendant Robert Cahaly.

13. Robert Cahaly is a citizen and resident of Atlanta, Georgia.

Lexington County, South Carolina.

of South Carolina or through intentional tortious actions directed at and committed in

commitment of a tort in South Carolina subjects all Defendants to personal jurisdiction in

Waccamaw Publishers, Inc.

18. Jurisdiction and venue are proper before this Court.

republican candidate for Senate District 33 in Horry County South Carolina.

Good for the Goose …”, FitsNews, June 16, 2020.

polling stations on the runoff election date.

531 pages of documents from Plaintiffs divorce file. Exhibit 3

daughter were included.

§ 19-11-95, S.C. Code § 44-22-100, and S.C. Code § 62-11-310.

advocacy center programs in Horry and Georgetown Counties in South Carolina,

having suffered abuse.

Code § 19-11-95, S.C. Code § 44-22-100, and S.C. Children’s Code.

seven days before the runoff election.

documents was false.

demonstrated the allegations of abuse were false.

obtain the truth of the allegations.

a political mudslinging contest.

in its campaign advertisements. Exhibit 6.

“Amber Alert Threat” next to Plaintiff’s name. Exhibit 7.

clearly showed he was not the aggressor. Exhibit 8.

spousal and/or child abuse.

confidential mental health records of a 10 year old girl.

the confidential mental health records of a minor.

health records of Plaintiff’s 10 year old daughter.

Law Firm in September 2019.

not obtain them lawfully.

on the Dossier, the Emerson Group submitted a professionally produced, 30 sec

advertisement entitled “LRLindsayFinal” to be televised on local station WMBF.

Boschult Group article that had yet to be published.

the opponent of a targeted candidate.

another republican candidate in violation of S.C. Code § 8-13-1340, which constitutes a

misdemeanor under South Carolina law.

before June 16, 2020.

911 call, not his ex-wife.

name of the advertisement is “SC Industry 911 Call.” Exhibit 10.

Columbia, SC 29202 SCIndustryproject.org.”

Other Defamatory Acts by Defendants

direct link to the Boschult article.

across three pictures of Plaintiffs’ face.

“John Gallman: ACCUSED OF: DOMESTIC VIOLENCE – POLICE REPORT”

emblazoned across a picture of Plaintiffs’ face.

stated “punching, threats, surveillance, broken bones, terrified children. JOHN

a history of John Gallman’s domestic abuse.”

opponent, the unstable John Gallman.”

unstable opponent John Gallman.”

The Public Record