IN THE COUNTY COURT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION Reber richee (Sloan caseno.1b-CA - 2944 Aka Peter Shatner num/Z Plaintiff(s) a William Shatner Defendant(s) SUMMONS THE STATE OF FLORIDA: TO EACH SHERIFF OF THE STATE: YOU ARE COMMANDED to serve this summons and a copy of the complaint or petition in this ray ‘on the Defendant(s) whose name and addyess is: Each Defendant is required to serve written defenses to the complaint or petition on Plaintiff's attorney, whose name and address is: within 20 days after service of this summons on that defendant, exclusive of the day or service, and to file the original of the defenses with the clerk of this court either before service on Plaintiff's attomey or immediately thereafter. Ifa Defendant fails to do so, 2 default will be entered against that defendant for the relief demanded in the complaint or petition. ee MAR 25 2016 PAT FRANK PAT FRANK As Clerk of the Court As Clack ofthe Cou {7 4 og Civil Division By in Y f 800 E. Twiggs Street Room 101 ‘As Deputy Clerk. ie Z P.O. Box 1110, Tampa, Florida 33601 "eS ‘$2 If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance, Please contact the ADA Coordinator, Hillsborough County Courthouse, 800 E. Twiggs St., Room 604, Tampa, Florida 33602, (813) 272-7040, at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. ©OCV:261 (052015)PETER MICHAEL SLOAN AKA PETER SHATNER IN THE CIRCUIT COURT OF THE THIRNTEENTH CIRCUIT HILLBOROUGH COUNTY PETER MICHAEL SLOAN caseno: L(0-CADSUY JAKA PETER SHATNER, DSI le Plaintif, LIBEL; DEFAMATION; TORTIOUS INTERFERENCE; SLANDER vs. WILLIAM SHATNER; | CHERRY HEPBURN; RECEIVED PUTAM & HEPBURN; a MAR 25 2016 PAUL CAMUSO, IK OF CIRCUIT Ct THE SHATNER PROJECT; IMBDPRO; WITTER: | AMAZON.COM; ET AL Defendant's Now comes the Plaintiff, Peter Michael Sloan AKA Peter Shatner and states the following: In November of 1984, Peter Michael Sloan met with William Shatner on the set of T.J. Hooker in Burbank California for the purpose of discussing The Plaintiff's patemity. The Defendant admitted the he was the Plaintiffs father and invited him to the set the following week. The Plaintif spent the day with Wiliam LIBEL; DEFAMATION; TORTIOUS INTERFERENCE; SLANDER - 14 25 Shatner again who introduced him to the crew. Upon the Plaintiffs return to his residence in New Jersey, The Plaintif called Willam Shatner at his home in California utiizing the number supplied fo him by the Defendant. The Defendant became agitated and hung-up the phone. Several days later, @ person by the name of David Brody called the Plain at his office and stated that he apologized for Mr. Shatner’s behavior on the phone, days before, but that he (The Defendant William Shatner) wanted to reach-out to the Defendant to say the ‘he feels for you,” but that The Defendant “can't respond.” Further, Mr. Brody explained that The Defendant's ‘lack of acknowledgement” stemmed from the fact that The Plain (at that time) was an adult and that if The Plaintif were a “minor* or if Mr. Shatner had a “patemel instinct,” things might be different. Mr. Brody continued on behalf of The Defendant and stated that, Mr. Shatner is “‘otally denying paternity at this point,” and Mr. Brody said, "Don't go public" with this or it “could be horrendous for" The Plaintiff Jand the Defendant, William Shatner. The Plaintiff suggested a DNA test but was rebuffed. On or about January 9, 2009, The Plaintiff Peter Michael Sloan, registered the web domain hi www pet e1.com for the purpose of creating a nom de plume (pen name) to author his book ‘The Search,” about The Defendant's search for his natural parents. In 2011, The Plaintiff began a radio show under the stage name of ‘Peter Shatner” on CBS Radio 1010AM. On October 11, 2011 an article appeared in the Sarasota Herald Tribune about the Plaintitf Peter Shatner| (Peter Sloan) regarding his affiiation with Savtira Corporation. The Plaintiff was contacted by Eric Hyman| Jof Loeb & Loeb. During several discussions with Mr. Hyman The Plaintiff requested that Mr. Hyman ask the Defendant, Wiliam Shatner to take a DNA test LIBEL; DEFAMATION; TORTIOUS INTERFERENCE; SLANDER - 21 |]On November 7, 2011, The Plaintiff received a letter from The Defendant Wiliam Shatner’s attorney Eric Hyman, from the firm Loeb & Loeb in Los Angeles. Mr. Hyman wrote the letter below to The Plaintiff, 3 || emaited to: and addressed to: 5 || Peter Shatner 10 || which stated: 12. || "Dear Peter: 13 ||/ had another conversation with Bil, who confirmed to me once again that he fs not your father. Thero 14 || have been many people over the years who have claimed to be his children or other relatives. He Is 15 || incredibly busy, eighty year-old man, and is not interested in spending time discussing this issue with you’ 16 |Jor any such individuals. 18 || Allof your actions (including the use of my client's valuable name and likeness without his approval) are 19 || at your own risk: 21 |] Very truly yours, 23 || Erik Hyman 24 || Partner" LIBEL; DEFAMATION; TORTIOUS INTERFERENCE; SLANDER -The Plaintif registered a script entitled: “T.C. Therapeutic Community” with The Writer's Guild of | [America by the stage name, “Peter Shatner.” From 2011 through 2015 the Plaintiff spent time developing a production of his script through IMDBpro a division of Amazon.com, CAUSES OF ACTION 11) On May 9, 2018, an ancl was published n Tho Tampa Tribune which desorbed The Plintis ‘story. Contained within the article was @ quote from The Defendant's publicist, Cherry Hepbum, Principal rom the frm Hepburn & Sih, [a EE hich is quoted in that article as follows: “Me Shatner has 3 lovely daughters but NO son,” Shatne's publicist Chery Hepbum tod the Tabune| ete ere ae ee eer a ae ome eras 57 for yours > ~ See more at: htip://unvw.tho.comfifestyle/kirks-kin-tamp: man-says-hes-willarn 20150509/itsthash TBTGGABF dput 2.) On or about May of 2015, The Defendant, William Shatner’s Social Media Director, and part of “The Shatner Project” The Defendant, Paul Camuso posted malicious, libelous and slanderous statements about the Plaintiff on Facebook and Twitter here Is an example of one of the multiple atlacks on The Plaintiff by Mr. Camuso who is an agent of The Defendant William Shatner: “There was a long and involved discussion about Peter's claim on The Official Willam Shatner. com group. Paul Camuso’s comment: | removed the Peter Sloan (aka Shatner) thread. He is NOT Mr. Shatner's son, LIBEL; DEFAMATION; TORTIOUS INTERFERENCE; SLANDER - 4Here's what | know: The only photos he has are from a convention (where he and his daughter paid to get a photograph with Bil) And then last year he and his daughter encountered Bill backstage at an event in FL and got photo his story: “The Search" is ful of holes. Everyone else who "helped! this guy discover he was Bil's “son" is deceased. Even his story has changed. Originally he said he contacted Bills manager who invited him down to the Td Hooker set in Long Beach. Then Bills manager said that never happened so that part ofthe story changed. Now he met met Bil at the Burbank Studios. The Burbank Studios are new- mayo 5 years old: TU Hooker was filmed at the WB (in Burbank) So this guy doesnt even know whore he met Bil ‘So you are going to meet your long lost cad, don't you take a camera? Where are those photos? They dont exist because the story is made up. his daughter Ann (one of his 6 kids) tried to bully Bil on Twitter last year; Bill blocked her so sho had hor fiends start harassing Bil. IMDB even removed his biography because it was ridiculous Original: his-/ob archive ora... wa.imdb.com/name/nm3421029/ Current: hitp:/hunun.imdl,com/name/nm3421029/ Even on his IMDB profile he has this picture ofa billboard for his radio show: its a fake imago. Compare itt this image: hitips:/3. qoocleusorsontont com. /90ff8d92-d908-Acc0-béto Its @ mock up you use to be able fo do on the CBS Outdoors Advertising website. Its alla big con game for fame so that’s why we dont bother with Mr. Sloan.” 3.) Twitter shut-down the Peter Shatner twitter account permanently claiming: /LIBEL; DEFAMATION: TORTIOUS INTERFERENCE; SLANDER - §“Hello, Ithas come to our attention that your Twitter account is in violation of the Twitter Rules, specifically the policy on Impersonation: hilo//support.twitter.com/entries/18366-impersonation-pollcy. Impersonation is pretending to be another entity in order to deceive, and is strictly prohibited. This account has been suspended and will not be restored. Thanks, Twitter” 4) In July of 201, The Plaintiff's IMDEpro account was shut down, after which the Plaintiff posted the following message to IMDB Pro: | pay for IMDbpro and yet someone at IMDbpro erased my project T.C. Therapeutic Community off the site after 6 months of work and 6,000 submissions, the dashboard still exists but the project has been erased. This is a viable project and IMDBpro advertises this service. Also IMDBpro has removed my biography. 1am accumulating damages every day as a direct resutt of the actions of IMDBpro and it's parent ‘amazon.com. Peter Shatner LIBEL; DEFAMATION; TORTIOUS INTERFERENCE; SLANDER - 620 2 2 IMDBpro responded: Peter: As per the response you have received earlier, IMDBpro's longstanding policies related to future titles are well documented and can be found here: http/vvwn_imdb.com/help/show leaf?illes please be aware that being a pak nproductios subscriber to IMDbPro.com has no bearing on whether a title will be accepted or kept on the site. The decision is based exclusively on the information/data presented to us and on our ability to verify its accuracy. Titles, particularly those that are submitted as future unreleased projects, are routinely removed when our editors cant verily that they stl fulfll our requirements to be Iisted. Ifyou believe that the tte is eligible to be listed and are able to venty that it meets the eligibility criteria outlined in the above documentation, please foo! free to resubmit i. Resubmiting It along with third-party sources verifying that iis active and that there is @ reasonable expectation that it will be made and released in the near future, is all we need to lst it Likewise, biographical information can be changed or removed if we are unable to verity its accuracy, or we determine that i's inaccurate. Ifyou believe that such removal may have occurred by mistake, you should resubmit the data along with links to source verilying its accuracy, and our editors will me more than happy to review it and revisit it applicable, their decision. Thank you, LIBEL; DEFAMATION; TORTIOUS INTERFERENCE; SLANDER - 7tips //getsatisfaction.com/imab/topics/peter-shatner-imdbpro-erased-my-project-and-my- biography-damages-are-accruing-daily-due-to-imdb-and-ts-parent-company?tople-reply- list%e5Bsettings%5D%5Bfilter_by%5D=star promoted 5) Here is the transcript of the interview with my father, Wiliam Shatner from Thursday January 7, 2016 on 102.5 The Bone Radio with Mike Calta: Calta There is a gontieman down here here who did lke a pay your own way radio show wo is. claiming to be your son, Is that true? Shatner Uknoww... (Laughter from Calta and the stualo) Calta Is he not your son, he kinda looks ike you a litle? (3 second pause) Shatner Woa...everybody looks like me a little. Gata (Laughing) | wish fooked like you a ite. No. Aya aya | don't know ifthore's a. Shatner Na..na..oh no..a he's a..apparently a lovely man whose in need of a father. But ah. he's gotten LIBEL; DEFAMATION: TORTIOUS INTERFERENCE; SLANDER - 8old over the years. I mean, he's in his sities isnt he, something like that? Calta Yes! So he's not your son? I'm glad | dat buy into it Shatner No, 10, no.1 ahh Calta | would assume that a man of your stature probably had, may have a couple of kids ying round that you weren't sure of around the country. ‘Shatner Yeah but they're lying around, they're not a..on the radio station. Calta I.J00k, look if | looked like you, and | was on the radio I'd use that is a gimmick... 'm Shatners kid} you know? Hah..anyway...okay so he's not...o when I see him this guy I should call him out on Bs? ‘Shatner Yeahh...| mean...do..a..wa.. | don't know what he's doing, or why he's doing that. It may be a 1eed on his part but he's been at it for quite a while. Calta No kiddin’ | thought you wore going to go, "Yeah, | did you know a... his mother you know and blah blah blah... | would imagine you..you in your day..um. | would imagine..so now. ‘Shatner That would have to be... that would have to take me back to Canada and me as a kid and a..a you know.a..wa... I dont know what he's doing. Calta /LIBEL; DEFAMATION; TORTIOUS INTERFERENCE; SLANDER - 9"4 25 (Gafah) Shatner Idel.d.eh.1 sympathize with him..inths...vhatever his needs are. Calta Oh..n.oh you're right, that becomes a sad situation now...urm. okay... Shatner That's the way |....um that's the way I'm taking it. DAMAGES INCURRED BY THE PLAINTIFF As a direct result of the Defendant(s) malicious behavior, and malfeasance, The Plaintiff has incurred |damages. 1.) The Plaintiffs loss of the production of the fim: T.C. Therapeutic Community by direct actions of all of the Defendant(s) who sought to destroy the reputation of The Plaintif. 2.) Loss of the ability to eam income from the use of the name Peter Shatner, which has been The Plaintif's “Brand” since 2009. RELEIF SOUGHT BY THE PLAINTIFF 1.) The Plaintiff asks that The Court grant Injunctive relief to demand that the Defendant(s) cease ‘and desist from further claims that the Plaintiff is not the natural child of William Shatner. 2.) The Plaintiff asks that The Court grant Declaratory relief by directing Mr. Shatner to submit to a DNA test with The Plaintiff to confirm paternity. LIBEL; DEFAMATION; TORTIOUS INTERFERENCE; SLANDER - 103.) The Plaintiff asks that The Court grant Compensatory damages in the amount of $30,000,000.00. 4) The Plaintiff asks that The Court grant Punitive damages in the amount of $90,000,000.00. 5) The Plait ff asks that The Court grant $50,000,000.00 for Pain and Sulfering inflicted upon The Plaintitt 6) The Plaintiff asks for reimbursement of funds paid or lost as a result of the actions of the Defendant(s) 7.) Attomeys' fees together with costs of this lawsuit. 8.) The Plaintiff asks The Court for any other type of relief such as The Court deems necessary. 9) The Flaintil Demande «ecg Hire Datod this 25 of March, 2016. Peter Michael Sloan AKA Peter Shatner LIBEL; DEFAMATION; TORTIOUS INTERFERENCE; SLANDER - 11