Superior Court of California

County of Orange

Case Number : 30-2013-00657459-CU-DF-CJC Copy Request: 966412 Request Type: Case Documents Prepared for: cns
Number of documents: 1 Number of pages: 7

SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE CENTRAL JUSTICE CENTER

ELECTRONICALLY FILED Jun 18 2013

ALAN CARLSON, Clerk of the Court by E. SUTTER

30-2013-00657459-CU-DF-CJC Judge Andrew Banks

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
L AW O FFICE OF K ENT W. E ASTER

FIRST CAUSE OF ACTION (Slander) (Against Defendants Orange County District Attorney, The Irvine Police Department, and DOES 1-10) 1. On June 19, 2012, Plaintiffs were arrested by the Irvine Police Department for

false imprisonment and conspiracy to falsely imprison Jane Doe, a compensated monitor for after-school programs at an Irvine public school. The Orange County District Attorneys Office and the Irvine Police Department both published numerous false statements on June 19, 2012 to media outlets about the Plaintiffs arrests. The following statements attributed to both the Orange County District Attorneys Office and the Irvine Police Department in print, television and online media reports are false as they apply to the Plaintiffs: that a video surveillance camera captured Kent Easter calling Irvine police from a business center in a hotel near his legal office, that Kent and his wife, Jill, were in constant contact via cell phone calls and text messages while Kent drove to and from the volunteer's home and that the alleged victim is a school volunteer. 2. None of the statements about are true. There is no video surveillance of Kent

Easter making a telephone call from the hotel. Also, Kent did not drive to and from the alleged victims home. In addition, he and his wife were not in constant contact, and there were no cell phone calls between the two at the time of the alleged crime and no text messages. Finally, the alleged victim was a monitor for after-school programs compensated by the Irvine Public Schools Foundation and not a volunteer. 3. Defendants published these false and defamatory statements with constitutional

malice in that Defendants knew that the statements were false, or acted with negligent or reckless disregard for the truth of these statements. In addition, the statements of the Orange County District Attorneys Office were in violation of California Rule of Professional Conduct 5-120 prohibiting extrajudicial statements that a reasonable person would expect to be disseminated by means of public communication if the member knows or reasonably should know that it will have a substantial likelihood of materially prejudicing an adjudicative proceeding in the matter
COMPLAINT

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

and presents information the member knows is false, deceptive, or the use of which would violate Business and Professions Code section 6068(d). 4. Plaintiffs are entitled to general damages for their loss of reputation, shame,

mortification, and emotional distress in accordance with proof at trial. 5. Plaintiffs are entitled to special damages for the damage done to their property,

business, trade, profession, or occupation, including amounts of money plaintiff expended as a result of the defendants' defamatory statements and assertions. In particular, these false and defamatory statements will make it very difficult for Plaintiff Kent Easter to obtain future work as a lawyer and for Plaintiff Jill Easter to obtain future work as a writer and an author. 6. As a direct result of defendants' wrongful acts, plaintiffs have suffered emotional

distress and other damage and has suffered an indelible mark on their reputation in an amount to be proven at trial. 7. Defendants acted with reckless, willful or callous disregard for plaintiffs rights

and with malice, fraud or oppression toward plaintiffs, thereby entitling plaintiffs to an award of punitive damages in an amount to be proven at trial. SECOND CAUSE OF ACTION (LIBEL) (Against Defendant Los Angeles Times Media Group and DOES 11-25) 8. Defendant Los Angeles Times Media Group published numerous false statements in print and online about Plaintiffs arrests. In the article titled Irvine Parents Planted Drugs on School Volunteer, Police Say, and dated June 19, 2012, it is written Video surveillance from a hotel near Kent Easter's Newport Beach office showed him allegedly making the initial 911 call. This statement is false. There is no video surveillance of Kent Easter making a telephone call from this hotel. In addition, the alleged call was not made to 911. The article also states that the alleged victim is a school volunteer, which is false. 9. The second article, titled Irvine Couple Charged with Planting Drugs, and dated

June 20, 2012, is almost identical with the article published on June 19, 2012, and contained the same false statements about video surveillance and the alleged victim. Also, Kent did not drive -2COMPLAINT

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

to and from the alleged victims home as stated. In addition, he and his wife were not in constant contact, and there were no cell phone calls between the two at the time of the alleged crime and no text messages. 10. Defendant Los Angeles Times Media Group published these false and defamatory

statements with constitutional malice in that Defendant knew that the statements were false, or acted with negligent or reckless disregard for the truth of these statements. 11. Plaintiffs are entitled to general damages for their loss of reputation, shame,

mortification, and emotional distress in accordance with proof at trial. 12. Plaintiffs are entitled to special damages for the damage done to their property,

business, trade, profession, or occupation, including amounts of money plaintiff expended as a result of the defendants' defamatory statements and assertions. In particular, these false and defamatory statements will make it very difficult for Plaintiff Kent Easter to obtain future work as a lawyer and for Plaintiff Jill Easter to obtain future work as a writer and an author. 13. As a direct result of defendant's wrongful acts, plaintiffs have suffered emotional

distress and other damage and has suffered an indelible mark on their reputation in an amount to be proven at trial. 14. Defendant Los Angeles Times Media Group acted with reckless, willful or callous

disregard for plaintiffs rights and with malice, fraud or oppression toward plaintiffs, thereby entitling plaintiffs to an award of punitive damages in an amount to be proven at trial. THIRD CAUSE OF ACTION (LIBEL) (Against Defendants DOES 26-100) 15. On June 21, 2012, an anonymous posting was published on Amazon.com under a review for the book, Holding House, written under Jill Easters pen name, Ava Bjork, that stated her book had a Totally Misleading Description!!! and that about a couple of sleazy lawyers/parents that try to frame a enemy by planting drugs on that enemy and then, in a totally unbelievable narrative, manage to make every mistake imaginable and of course get CAUGHT by the police!!! I am sorry but no two people could be so stupid as to think that they would get -3COMPLAINT

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

away with their heinous acts. The statements are false because the book does not have a misleading description and has nothing to do with a story about planting drugs on an enemy and the author, Jill Easter is not a sleazy lawyer/parent that made every mistake imaginable. 16. The unknown Defendants published these false and defamatory statements with

constitutional malice in that Defendants knew that the statements were false, or acted with negligent or reckless disregard for the truth of these statements. 18. Plaintiffs are entitled to general damages for their loss of reputation, shame,

mortification, and emotional distress in accordance with proof at trial. 19. Plaintiffs are entitled to special damages for the damage done to their property,

business, trade, profession, or occupation, including amounts of money plaintiff expended as a result of the defendants' defamatory statements and assertions. In particular, these false and defamatory statements will make it very difficult for Plaintiff Kent Easter to obtain future work as a lawyer and for Plaintiff Jill Easter to obtain future work as a writer and an author. 20. As a direct result of defendants' wrongful acts, plaintiffs have suffered emotional

distress and other damage and has suffered an indelible mark on their reputation in an amount to be proven at trial. 21. Defendants acted with reckless, willful or callous disregard for plaintiffs rights

and with malice, fraud or oppression toward plaintiffs, thereby entitling plaintiffs to an award of punitive damages in an amount to be proven at trial.

-4COMPLAINT