Complaints For Defamation and Commercial Disparagement

j:
nnsylvania
Supr~meC
For Prothonotary Use Only:

Docket No:
s
E
c
T
I
0
N
Commercement of Action:
IE!Copiplaint
D Writ of Summons
Cl Tr,nsfer from Another Jurisdiction
Petition
[J Declaration of Taking
Lead PlJintiffs Name:
Lead Defendant's Name:
CBS PITTSBURGH/KDKA AM
Jesstj:White
i
1:
.4re money damages requested?
IEIYes
D No
Dollar Amount Requested:

(check one)
ls thii a Class Action Suit?
Cl
Yes
IE)No
Is this an MDJ Appeal?
I
I
Nbe
Clwithin arbitration limits

IE)outside arbitration limits
Cl Yes IE)No
of Plaintiff/ Appellant's Attorney:
I:
IE!
Check here if you h_a_v_~_n_o_a_t_t,_ff_n_c_y_(_ar_c_'

~-1-S-~-lf--I-lc-1-}r-c-sc-11-t-.c-d_l_P_n_)_S_c_l
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------
. Naturk of the Case:

l
Place an "X" to the left of the ONE case category that most accurately describes
your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
I!
TORTj((do:7ot include Mass
Tort)
:D Intentional
lD"
; Malicious Prosecution
i[l Motor Vehicle

i[J N~isance
I[] Pfemises Liability
D Pfoduct Liability (does not include
E
m~s tort)
IEI
S1ander/Libel/
Defamation
,
I'
:IE!qrher:
CONTRACT
(do not include Judgments)
D Buyer Plaintiff
D Debt Collection: Credit Card
D Debt Collection: Other
Administrative Agencies
Cl Board of Assessment
CJBoard of Elections
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D Employment Dispute:
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IJ Employment Dispute: Other
CJ;ommerical
Disoaraaemea
T
I
CIVIL APPEALS
Cl Zoning Board
Cl Other:
1:
Cl Other:
MAssJiTORT
:0 T?b~cco
,iaA!sbestos
1CITbxtc Tort - DES
i[] Tbxic Tort - Implant
!DTpxic Waste
;a
1her:
, PROFESSIONAL
LIABLITY
1: :
.
[] Dental
[] Lbgal
:aijedical
)0 lther Professional:
REAL PROPERTY
[j Ejectment
[J
Eminent Domain/Condemnation
[] Ground Rent
CJLandlord/Tenant Dispute
IJ Mortgage Foreclosure: Residential
D Mortgage Foreclosure: Commercial
Cl Partition
Cl Quiet Title
[J Other:
MISCELLANEOUS
[j Common Law/Statutory Arbitration
D Declaratory Judgment
Mandamus
Non-Domestic Relations
Restraining Order
D Quo Warranto
CIReplevin
D Other:
J:
Updated1/112011
IN THE COURT OF COMMON PLEAS OF
WASHINGTON COUNTY, PENNSYLVANIA
I
JES~E WHITE,
Civil Division
Plaintiff,
No.:
vs.
CBS iPlTTSBURGH/KDKA AM,
COMPLAINT IN DEFAMATION AND

COMMERCIAL DISPARAGEMENT
MARTY GRIFFIN,
and
ONALD ROESSLER,
Defendants.
Filed on behalf of Plaintiff by:

Jesse J. White, Esq.
PA I.D. # 91152
Law Office of Jesse White
3350 Millers Run Road
P.O. Box384
Cecil, PA 15321
724-743-4444
IN THE COURT OF COMMONPLEAS OF
WASHINGTONCOUNTY,PENNSYLVANIA
Civil Division
Plaintiff,
vs.
No.:
CBS .PITTSBURGH/KDKA
AM,
COMPLAINTIN DEFAMATIONAND
COMMERCIALDISPARAGEMENT
'
MARTYGRIFFIN,
.
I:
and DONALDROESSLER,
'
Defendants.
NOTICE TO DEFEND
You . ave been sued in court. If you wish to defend against the claims set forth in
the
follor7ing pages, you must take action within twenty (20) days after this complaint
and notice
are served, by entering a written appearance personally or by attorney and filing
in writing
with/:'thecourt your defenses or objections to the claims set forth against you.
You are warned
that ~fyou fail to do so the case may proceed without you and a judgment may be
entered
against you by the court without further notice for any money claimed in the
complaint or for
any bther claim or relief requested by the plaintiff. You may lose money or
property or other
iighjs important to you.
OU SHOULDTAKE THIS PAPER TO YOUR LAWYERAT ONCE. IF YOU DO NOT HAVE

ALl}WYER,GO TO OR TELEPHONETHE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDEYOU WITH INFORMATIONABOUT HIRINGA LAWYER.
IF Ybu CANNOTAFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLETO
PR~IL'!IDE
YOU WITH INFORMATIONABOUT AGENCIESTHAT MAYOFFER LEGAL
SEM,VICESTO ELIGIBLEPERSONS AT A REDUCEDFEE OR NO FEE.
~~R REFERRAL SERVICE
119 ~outh College Street

Wa~hington, PA 15301
l724J225-6710
1
.
SO!ITHWESTERN PA LEGAL AID SOCIETY
10 West Cherry Avenue
Washington, PA 15301
724-225-6710
.
1:
JESS~ :WHITE,
Civil Division
Plaintiff,
No.:
vs.
CBS I ITTSBURGH/KDKAAM,
MARTYGRIFFIN,
/!
~d J;)ONALDROESSLER,
Defendants.
COMPLAINTIN DEFAMATIONAND COMMERCIALDISPARAGEMENT

AN/iNOW comes the Plaintiff, Jesse White, who files this Complaint in Civil Action
against
Defe dants, and in support thereof avers the following:
l.
The Plaintiff, Jesse White, is an adult individual residing at 26 White Lane,

McDonald,
PA 15057.
2.
The Defendant, CBS Pittsburgh/KDKA AM, is Pennsylvania business with a primary

place of business at 651 Holiday Drive, Foster Plaza Building 5, Pittsburgh, PA
15220.
3.
The Defendant, Marty Griffin, is an adult individual who resides in Allegheny

County,
Pennsylvania; his specific home address is unknown. His place of business is 651
Holiday Drive, Foster Plaza Building 5, Pittsburgh, PA 15220.
4.
The Defendant, Donald Roessler, is an adult individual residing at 720 Ridge

Avenue,
:Canonsburg, PA 15317.
5.
From December 1, 2006 - November 30, 2014, Plaintiff was a member of the
Pennsylvania House of Representatives, representing the 46th Legislative District.
6.
Plaintiff was up for re-election in 2014 and faced both a Primary and General
Election
. challenge.
7.
Plaintiff defeated Democrat/Defendant Tom Casciola in the May 20, 2014 Primary
Election by a total of 3,107 to 2,366 votes.
8!
'
9.
Plaintiff lost to Republican Jason Ortitay in the November 4, 2014 General Election
by
. a total of 10,462 to 8,169 votes.
I
: Defendant Marty Griffin is the host of "The Inside Story With Marty Griffin",
which
, airs from 9:00 AM - 12:00 PM daily on Defendant KDKAAM.
10.
According to their website, KDKAAM broadcasts news and talk programming 24

hours a day over a 50,000-watt signal that at night reaches 38 states and several
Canadian provinces. The station is also available via HD Radio and streaming
online.
11.
Beginning on or about May 12, 2014 "The Inside Story With Marty Griffin" began a
segment known as the "ABJ Hour", which aired daily for the week leading up to the
May 20, 2014 Primary Election.
12.
According to host Marty Griffin, "ABJ" stood for "Anybody But Jesse"; by his own
admission, the goal was to disparage White and discourage voters from supporting
him in the upcoming election.
13.
During his discussion of White, Defendant Marty Griffin repeatedly used the term
"illegal" to describe White's activities, specifically White's use of social media.
14. , Griffin punctuated his statements by claiming that everything he was saying
was
"fact", citing reports by KDKA TV reporter Andy Sheehan.
+5.
At no time did Sheehan say White did anything illegal in any of his reports. Marty
Griffin fabricated this conclusion for the sole purpose of disparaging Jesse White.
16.
Defendant Griffin went on at length to discuss Plaintiff on his radio show, calling
him
"borderline psychotic" and other derogatory terms.
17.
On May 12, 2014 at 5:58 PM, Defendant Griffin posted the following on his Facebook
, page (See Exhibit "A", attached):
normal banter ... right now ... hes under investigation by THREE
agencies ... three sir ... including the d.a .... and the house ethics committee ..
18.
This statement is utterly and completely false. Plaintiff was never investigated by
the
.House Ethics Committee and was not under investigation by any District Attorney at
the time the statements were made by Griffin on May 12, 2014.
19.
Plaintiff's conduct had been examined by Washington County District Attorney Gene
Vittone and determined not to be criminal ih any way, as told to Plaintiff
personally in
December 2013, six months before Defendant Griffin broadcast that Plaintiff was
still
"under investigation".
20.
On May 12, 2014 at 5:37 PM, Defendant Griffin posted the following on his Facebook
page (See Exhibit "B", attached):
bruce ... do a little research on Jesse White .... and get back to me. his
"mistakes" ... he attacked and threatened people ... he lied about his
name ... he created fake names ... he lied when asked directly by us. He
demanded SUPER BOWL TICKETS ON A PRIVATEJET ... from Range
Resources. I have the e-mails if ud like. I can spend hours on his lack of
integrity. regarding me ... I aint rich and i aint popular. jesse white is a
horrible leader, sir. he took tens of thousands from the oil and gas folks
and when they quit paying he changed sides. its all there. in terms of
selling my soul. im all about high paying jobs for working folks. thats the
beginning ..middle and end of it for me. enjoy.
21.
, Plaintiff never demanded Super Bowl tickets from Range Resources or anyone else.
This is an utterly false statement.
22.
Plaintiff did not take "tens of thousands of dollars" in campaign contributions

from
"the oil and gas folks". According to http://www.MarcellusMoney.org, Plaintiff
received under $10,000.00 in cumulative campaign contributions during his time in
the legislature from 2006-2014.
23.
There is no indication that Plaintiff ever threatened anybody in any way.
24.
When questioned by Andy Sheehan of KDKATV about the incident in question,

Plaintiff stated that he had no comment. Declining to comment is not the same thing
as lying.
25.
The company mentioned by Defendant Griffin, Range Resources, is a natural gas

drilling company that is a substantial advertiser of Defendant CBS Pittsburgh.
26.
On October 24, 2013, Defendant Griffin broadcast his show from the headquarters of
Range Resources in Cecil Township, Washington County. (See Exhibit "C", attached.)
27.
Defendant Donald Roessler posted relevant portions of The Inside Story with Marty
Griffin broadcasted on May 13, 14 and 15, 2014 on his YouTube page at
http://www.youtube.com/user/bugabool9621.
COUNT I - DEFAM.ATION
28.
Paragraphs 1-27 are incorporated by reference as though fully set forth herein.
29.
,Implying criminality as set forth in Paragraph 13 is defamation per se under

Pennsylvania law.
30.
Defendant Marty Griffin's published statements were defamation per se and had the
effect of harming the reputation of Plaintiff as to lower him in the estimation of
the
community or to deter third persons from.associating or dealing with him.
31.
Defendant Marty Griffin's published statements had the impact of ascribing to

Plaintiff
conduct, character, or a condition that would adversely affect his fitness for the
proper
conduct of his proper business, trade or profession, and are therefore defamatory
under Pennsylvania law.
32.
Defendant Marty Griffin's published statements alleging Plaintiff was under

investigation by three agencies including two district attorneys and the House
Ethics
Committee were defamatory in that Defendant, as a professional news reporter, knew
or should have known said statements were untrue.
33.
These statements were made by Defendant Marty Griffin via social media and
therefore visible worldwide.
3'4.
Plaintiff suffered special harm in the form of lost business in his law practice,
including clients who disengaged Plaintiff as a result of Defendants' statements.
3,5.
Plaintiff also lost salary and benefits he would have been entitled to as a member
of
the Pennsylvania House of Representatives had he been re-elected.
Plaintiff was also required to spend additional political funds to counteract the
, defamatory message being used against him.
36.
37.
Plaintiff suffered impairment of reputation and standing in the community, personal

humiliation, and mental anguish and suffering as a result of Defendants' published
statements and is entitled to damages.
38.
Defendant Marty Griffin's conduct was outrageous because of his personal motive
and/or their reckless indifference to the rights of others.
~9.
Defendant Marty Griffin's conduct was malicious, reckless, willful, and oppressive
towards Plaintiff.
40.
By republishing the defamatory content published by Defendants Marty Griffin and

CBS Pittsburgh/KDKA on his YouTube account, Defendant Donald Roessler is liable
,for the defamatory content of knowingly false statements regarding the false
implication of criminality against Plaintiff.
41.
.Plaintiff is entitled to punitive damages.

WHEREFORE, the Plaintiff demands judgment against the Defendants in an amount in
exce~s of fifty thousand dollars ($50,000), exclusive of interest and costs.
COUNTII - COMMERCIAL
DISPARAGEMENT
42.
43.
Plaintiff runs his own law practice, currently located at 3350 Millers Run Road,
Suite
102, Cecil, PA 15321.
44.
Plaintiff has operated this business since February 1, 2004.
45.
The business is a sole proprietorship belonging solely to Plaintiff.

46.
Defendant Marty Griffin's statement published on or about May 12 - May 20, 2014
implied criminal conduct towards Plaintiff that never occurred, which is defamation
: per se under Pennsylvania law.
47.
!
Defendant Donald Roessler's republication was with actual malice towards Plaintiff,
and therefore was defamatory.
48.
A lawyer's reputation in the community is essential to cultivating client

relationships.
49.
A public official's reputation in the community is essential to cultivating public

trust.
50.
A false implication of criminality is damaging to that reputation.
51.
Defendants intended the publication of their statements to cause financial loss, or

they
should have reasonably recognized the publication would result in financial loss.
52.
Plaintiff did in fact suffer a financial loss as a result of Defendants'

statements.
53.
Defendants knew or should have known that his statements were false and in reckless
disregard of their truth or falsity.
WHEREFORE,
the Plaintiff demands judgment against the Defendant in an amount in excess
of fi~ thousand dollars ($50,000), exclusive of interest and costs.
ti
:
VERIFICATION
1:
!,;Jete
White, hereby state that the facts above set forth are true and correct (or are
~e ac
nd correct to the best of my knowledge, information and belief) and tbat I expect
to be :able to prove the same at a hearing held in this matter. I understand that
the
state! ents herein are made subject to the penalties of 18 Pa.C.S. 4904 (relating
to
unsJom falsification to authorities).
L/-p/Datei
/5
MartJ
Griffinnormalbanter...right now...hes under investigationby THREE
~,Cies ...three sir..Jootudlngthe d.a....and the houseethics committee..
MaVJi
12 at 5 :58pm Like s:'J1
Mart,
Griffin im okay myman.u seema tad angry.enjoy
Ma 12 at6:03pm ~Like .61
Ma Griffin bruoemdo
a tittle researchon JesseWhite....and get backto ine.

his ffmfstakerf~,.he attacked and threatend people...he lied about his name,~.he
crera
I: . fake names...he lied when asked directty by US~he demandedSUPER
BO
TICKETS ON A PRIVATEJET...from Range Resources.I have 1hee-mails If
ud n e. f can spend hours on his lack of intergrity.regarding me ...i a.intrtch and
i runt
pop
jessewhite is a horrible leadersir. he took tens of thosaundsrromthe oil
and ' folks and when they quit payinghe changed sides. its authere. in termsof
selU :s my soul. im atl about high payingjobs for workingfolks. thats the
begt;ning..middleand end of it for me. enJoy.
Mayii2 at 5:37pm Like
'
'
'
'-,
If
13
\
''\
Suprehie~o
For ProthonotaryUseOnly:
Docket No:
Wt4SHt
o20/S -;2/:?7
County
;,., Jormarian calle~ted on this form
i! used solely .fi>rlc-o_i.::w:.:t

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f.ln~o~r
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supplement or replace the filzng and service of pleadmgs or other papers as

required by law or rules of court.
Co~men~ment of Action:
~ Co~plaint
Cl ~ri~ o~Summons
[J Transfer from Another Junsd1ct1on
.
II
Leaa Platiffs
Jesse
T
l
Cl Petition
CJDeclarationof Taking
1,
LeadDefendant'sName:
Name:
Observer Publishing Company
hite
Afe mfney damages requested?
ii Yes
D No

(check one)
ls this/!a Class Action Suit?
ClYes
tBJNo
ls this an MDJ Appeal?
'
1:
0
N
'
I
.. Nature
of the Case:
/!
'
No
here if you have no attorney tare a Self-Represented [Pro Sci Litigant)
your
PRIMARY CASE. lfyou are making more than one type of claim, check the one that
TORT /(do
not include Mass Tort)
[] In!entional
0 Mj~licious~osecution
CJ~tor Vehicle
D N'isance
.
O P~emisesLiability
[] Plduct Liability (does not include
Cl Yes ii
Nr
of Plaffitifl1Appdlant'sAtt=ey,
1
1!J Check
Clwithin arbitration limits

l!loutside arbitration limits
m. ss tort)
ifBJ
slander/Libel/ Defamation
olher:
c :m
~ommerical Disoaraoemea
CONTRACT (do not include Judgments)

[] Buyer Plaintiff
[] Debt Collection:Credit Card
D Debt Collection:Other
[] EmploymentDispute:
Discrimination
[J EmploymentDispute: Other
CIVIL APPEALS
AdministrativeAgencies
D Board of Assessment
Cl Board of Elections
StatutoryAppeal: Other
Cl Zoning Board
O Other:
Ir
'
I
0
N
B .
MASSiTORT
i[]
pjsbestos
:
I,
CJ~pbacco
,[] ~oxicTort-DES
j Cl
~xic Tort - Implant
D Joxic Waste
. [] .ther:
,
I:
I
I
. PROij;ESSIONAL LIABLITY
Il)ental
,tl llegal
*edical
, 0 ther Professional:
Cl Other:
REAL PROPERTY
[] Ejectment
[] Eminent Domain/Condemnation
O Ground Rent
D Landlord/TenantDispute
[] MortgageForeclosure:Residential
[] MortgageForeclosure:Commercial
D Partition
[] Quiet Title
Cl Other:
MISCELLANEOUS
D CommonLaw/StatutoryArbitration
O DeclaratoryJudgment
Mandamus
Non-DomesticRelations
RestrainingOrder
CJQuo Warranto
DReplevin
[] Other:
Ii
~,-,-~~~~~~~~
Updated 1/112011
Civil Division
Plaintiff,
vs.
No.:
OBSERVERPUBLISHINGCOMPANY,
TH~S
CASCIOLA,
DARfENE BARNI,
JUDr BOWSER,
JAN~CE
GIBBS,
.I,
1:
"COtJCERNEDCITIZENS OF THE
45thDISTRICT"
'
'
Defendants.

PA I.D. # 91152
P.O. Box384
Cecil, PA 15321
724-743-4444
I!
JESSE
WHITE,
:
I
Civil Division
Plaintiff,
No.:
vs.
OBSERVER PUBLISHING COMPANY,
TH~
CASCIOLA,
DARLENE BARNI,
Ii
JUDr BOWSER,
JANICE GIBBS,
:
I!
i'CO~CERNED CITIZENS OF THE

45th DISTRICT" t
Defendants.
:
NOTICE TO DEFEND
ou ave been sued in court. If you wish to defend against the claims set forth
in the
.;,
folloynng pages, you must take action within twenty (20) days after this complaint
and notice
are s;erved, by entering a written appearance personally or by attorney and filing
in writing
withlthe court your defenses or objections to the claims set forth against you. You
are warned
that you fail to do so the case may proceed without you and a judgment may be
entered
i:}gaihstyou by the court without further notice for any money claimed in the
complaint or for
any bther claim or relief requested by the plaintiff. You may lose money or
property or other
rights important to you.
it
I:
YOlf SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LJl.WYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
~A, PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YEU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
l'Rq~E
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SEjlCES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER
REFERRAL SERVICE
I
119 South College Street
Wa~hington, PA 15301
724-~25-6710
SOUTHWESTERN PA LEGAL AID SOCIETY

724-225-6710
'
1:
JESSE WHITE,
Civil Division
Plaintiff,
No.:
vs.
OBSlRVER PUBLISHINGCOMPANY,
9!MAS CASCIOLA,
DARlENE BARNI,
:
Ii
JUDr BOWSER,
JANICE GIBBS,
.
!
:
Ii..
"CO~CERNED CITIZENS OF THE

46th DISTRICT"
'
,
'
Defendants.
COMPLAINT IN DEFAMATION AND COMMERCIAL DISPARAGEMENT

AN~ NOW comes the Plaintiff, Jesse White, who files this Complaint in Civil Action
against
Defe,:dants, arid in support thereof avers the following:

l.
The Plaintiff, Jesse White, is an adult individual residing at 26 White Lane,

McDonald,
PA 15057.
2.
The Defendant, Observer Publishing Company, is Pennsylvania corporation with a

primary place of business at 122 S. Main Street, Washington, PA 15301.
3.
The Defendant, Thomas Casciola, is an adult individual residing at 17 Ridgewood

Drive, McDonald, PA 15057.
ii.
The Defendant, "Concerned Citizens of the 46th District" is an unincorporated

organization believed to be headquartered at 1943 Route 980, Canonsburg PA 15317.
5.
The Defendant, Darlene Barni, is an adult individual residing at 1943 Route 980,
Canonsburg PA 15317.
6:.
The Defendant, Judy Bowser, is an adult individual residing at 804 Redwood Road,
McDonald PA 15057.
7:.
The Defendant, Janice Gibbs, is an adult individual residing at 293 Profio Road,
McDonald PA 15057.
8.
Pennsylvania House of Representatives, representing the 46th Legislative District.
9.
Plaintiff was up for re-election in 2014 and faced both a Primary and General
Election
challenge.
10.
Plaintiff defeated Democrat/Defendant Tom Casciola in the May 20, 2014 Primary
Election by a total of 3,107 to 2,366 votes.
11.
Plaintiff lost to Republican Jason Ortitay in the November 4, 2014 General Election
by
a total of 10,462 to 8,169 votes.
i2.
On April 29, 2011, the Washington Observer-Reporter, a newspaper published by

Defendant the Observer Publishing Company printed a story about a civil trial in
which Plaintiff Jesse White was the Defendant.
13. i The headline in the April 29, 2011 Observer-Reporter read: "Lawmaker Guilty
of
Defaming Area Dem". The headline appeared on Page Al of the newspaper as a lead
. story. See Exhibit "A", attached.
i4.
The headline was also published on the Observer-Reporter website,

http://www.observer-reporter.com, making it available worldwide.
15.
Because the proceeding was a civil trial, not a criminal trial, there is no way
White
could have been found "guilty" of anything.

16.
The jury in the aforementioned defamation trial found no damages against the
plaintiff, Ray Bish, which means by definition there was no defamation because
damages are an essential element to the cause of action.
17.
The headline was used in a piece of campaign literature paid for and authorized by
Thomas Casciola's campaign. This literature was sent by mail to voters throughout
the 46th Legislative District.
18.
The story was republished via photocopying in May 2014 by Thomas Casciola and the
"Concerned Citizens of the 46th District" and distributed door-to-door throughout
the
45th Legislative District, which includes approximately 65,000 residents.
19.
Plaintiff personally found the photocopied article, printed on florescent paper, at

numerous homes as he was canvassing neighborhoods to speak to voters.
20. : The Observer-Reporter article was also discussed on "The Inside Story With
Marty
Griffin" on KDKARadio 1020 AM during the "ABJ Hour", which aired daily for the
week leading up to the May 20, 2014 Primary Election. According to host Marty
Griffin, "ABJ" stood for "Anybody But Jesse"; by their own admission, the goal was
to
disparage White and discourage voters from supporting him in the upcoming election.
21.
According to an article in the Pittsburgh Post-Gazette dated May 3, 2014, attached

as
Exhibit "B", the "Concerned Citizens of the 45th District" are led by three
individuals:
Darlene Bami, Judy Bowser and Janice Gibbs.
22.
The "Concerned Citizens of the 46th District" also operate a website dedicated to
attacking Plaintiff (http://www.concernedcitizens46thdistrict.com).
23.
All of the posts on both the Facebook page and the website are anonymous; in fact,
individual members of the "Concerned Citizens" would often communicate
individually with the organization via Facebook to presumably create the impression
that they were not affiliated with the organization or its content.
24.
The Defendant "Concerned Citizens of the 46th District" and its members were
actively
campaigning on behalf of Defendant Thomas Casciola in the 2014 Primary Election.
COUNTI - DEFAMATION
25.
26.
Implying criminality as set forth in Paragraph 13 is defamation per se under

Pennsylvania law.
27.
Defendant Observer Publishing Company's published statements were defamation per

se and had the effect of harming the reputation of Plaintiff as to lower him in the
estimation of the community or to deter third persons from associating or dealing
with
him.
28. , Defendant Observer Publishing Company's published statements had the impact
of
, . ascribing to Plaintiff conduct, character, or a condition that would adversely
affect his
, fitness for the proper conduct of his proper business, trade or profession, and
are
therefore defamatory under Pennsylvania law.
29.
Defendant Observer Publishing Company's published statements alleging Plaintiff

' was "guilty" of a non-criminal offense were defamatory in that Defendant, as a
professional news organization, knew orshould have known was untrue.
30.
These statements were made by Defendant Merl Williams via social media and
therefore visible worldwide.
31.
including clients who disengaged Plaintiff as a result of Defendants' statements.
132. : Plaintiff also lost salary and benefits he would have been entitled to as a
member of
the Pennsylvania House of Representatives had he been re-elected.

33.
34,
Plaintiff was also required to spend additional political funds to counteract the
defamatory message being used against him.

humiliation, and mental anguish and suffering as a result of Defendant Observer
, Publishing Company's published statements and is entitled to damages.
35.
Defendants' (Casciola, Barni, Bowser, Gibbs and The Concerned Citizens of the 46th
District) conduct was outrageous because of their personal motive and/or their
reckless indifference to the rights of others.
~6.
Defendants' (Casciola, Barni, Bowser, Gibbs and The Concerned Citizens of the 46th
District) conduct was malicious, reckless, willful, and oppressive towards
Plaintiff.
37.
By republishing the defamatory content published by the Observer-Reporter,

Defendants Casciola, Barni, Bowser, Gibbs and The Concerned Citizens of the 46th
District are liable for the defamatory content of knowingly false statements
regarding
the false implication of criminality against Plaintiff.
38.
The republication of the defamatory content by Defendants Casciola, Barni, Bowser,

Gibbs and The Concerned Citizens of the 46th District reset the one-year statute of
limitations for defamation in Pennsylvania, so this action is timely under
Pennsylvania
law.
Plaintiff is entitled to punitive damages.

exce~s of fifty thousand dollars ($50,000), exclusive of interest and costs.
COUNT II - COMMERCIALDISPARAGEMENT
40.
41.
Plaintiff runs his own law practice, currently located at 3350 Millers Run Road,
Suite
102, Cecil, PA 15321.
42.

43.
The business is a sole proprietorship belonging solely to Plaintiff.
44.
Defendant Observer-Reporter's statement published on April 29, 2011 implied

criminal
conduct towards Plaintiff that never occurred, which is defamation per se under
Pennsylvania law.
45.
Defendants' Casciola, Barni, Bowser, Gibbs and The Concerned Citizens of the 46th
District republication was with actual malice towards Plaintiff, and therefore were
defamatory.
46.

relationships.
47.
48.
Defendants intended the publication of their statements to cause financial loss, or

they
should have reasonably recognized the publication would result in financial loss.
49.

statements.
50.
disregard of their truth or falsity.
WHB~EFORE,the Plaintiff demands judgment against the Defendant in an amount in

excess
qf fifbythousand dollars ($50,000), exclusive of interest and costs.
Respectfully Submitted,
VERIFICATION
I
I, Je~se White, hereby state that the facts above set forth are true and correct
(or are
true bd correct to the best of my knowledge, information and belief) and that I
expect
to bJ able to prove the same at a hearing held in this matter. I understand that
the
statJments herein are made subject to the penalties of 18 Pa.C.S. 4904 (relating
to
unsJom falsification to authorities).
SERVING
f,UJ..l
GREENE
COU
1:
OURi20~RD
,n1U
WASHINGTON&
YEAR, WASHINGTON,
PA
attome
of
;_
lknetiamanfaces 42 countsoffo~gery,1j
def~
DISTRICT.
areaDem
J:
BYKATHIE
O.WARCO,Staff writer
lcwarco@observer-reporter.com
J\To
~es
Jury:
againstWhitefor
Interfl,f!t post
on commttteeman
1log
1taff
writer
BYLINDAMETz,
I
lmetz@observer-reportp:com
j! A
jury of
pight women
and four men
trhursday
found
that state Rep.
se White, Decil, defamed
~ d invadedthe
privacy of a
White
~ob i nson
Township man
in statements aiid pictures that
Whitepostefi
on Internetblog.
After nearly three hours of deliberatia
:..L. retmned with
.
OS, the
.. JutY
their verdict,e;f5n e four-day
trial before:W on County
Judge Kath~rine[B.Emery. And
while the verdict found against
White,thejliry
not award any
(:lamagesin the case.
Democratic Committeeman
Raymond Bish, J!63, filed suit
against Whitein qonnectionwith
t}lelegislator's blpg posting Oct.
27,2008.
i
*8
difl
.-~
A disbanedCanonsburgattorney was arrested Thursday

morning,accused of forgingthe
signature of four judges andtwo
attorneysin WashingtonCounty
and stealing more than $250,000
from two clients.
James A. Marchewka, 42, of
290Pine Ridge Drive, Venetia,
was arraigned before District
Judge EthanWard on 42 counts
of forgery, 10 felony counts of
tamperingwith public recordsor
identification,20 misdemeanor
counts of the same charge, 11
countsof theft,10 counts oftheft
by deception and 11 counts of
failure to make required deposition of funds received.
State police said the investiga-,
tionby thestate police organized
crime task force began after
Charles and Trudy Gratz, of
South Strabane Township, met
with repieSentati:ves
of the Wash-:
ington and AlleghenyCountydis-
trict attorneys.
The Gratzes had hired
Marchewkato represent them in
severalcasesbeforelearning
that
he had been . disbarred.
Marchewka,whohad law offices
in Canonsburg,was
disbarredby
consentApril 26,2010,according
to the state SupremeCourt disciplinary boardwebsite.
..
.
JIM MCNUTT
I 0BSERVERREPO
The couple believed they had PennsylvaniaState PoliceTiooperErik Graham,eads a
handcuffi
unresolved lawsuits pending. JamesMewka out of
Dis1rictJudgeEthanWard'sofficeinBuffa
~he~ka
~- ~y
ml~ .Townshipifter MarchewkawasarraignedThursday.
'
post-:azette.
,._,.,...,Pf&.
:
Inc1:1rif~nt h?pe~ to overcome scandal in 46th

Leg1slat1veD1str1ct
'
May 3, 201411!:33 PM
By JanicJ Crompton I Pittsburgh Post-Gazette

Though i~is Jound zero for Marcellus Shale gas development in the area and home to
several local
drilling giantt the 46th Legislative District in Washington and Allegheny counties
features a primary
election that issurprisingly skimpy on issues involving shale gas drilling.
.
1,
Instead, the Jee for state representative there seems to have boiled down to one
thing: Can a techsavvy incmlient overcome his past foibles and thin-skinned
reputation to hold on to his seat?
.
I:
State Rep. Jte
White, a Democrat and lawyer from Cecil, hopes so.
"I take tuii1r~pousibility for the way I conducted myself. It's not something I'm
particularly proud of.
It's somethinig I think about every single day," he said of a scandal last year
that made national
headlines w~en it was revealed that Mr. White used pseudonyms and even impersonated
his enemies
on Internet Jostings, especially those on social media sites like Facebook.
As he goes d(])or-to-door introducing himself to voters in his redrawn district,
Mr. White, 35, said he's
;ort
hearing $UpP,l for his tough stance against the Marcellus Shale drilling industry
despite his
peccadilloes.
He is bei)lg eiallenged by Cecil supervisor Thomas Casciola in the Democratic

primacy May 20 and
the winner ot that race will face Republican Jason Ortitay, a 30-year-old small-
business owner from
South Fayet, in the Nov. 4 general election.
"I h.ear, 'Yeaf, you scre~ed up. That was rea~y stupi~. But, we get that you are
the guy ~ut here that's
asking the t9ugh questions. You put yourself 1n the hne of fire when you could have
easily stuck your
head in the iand, "' he said. "Al:the end, that's what I think matters to people."
'i
But that isn what matters to all of the voters.
\ \ 13,,
Arecent Jlg
of the Concerned Citizens of the 46th District looked more like a game of bridge
than
a political(ac~bn committee. At its helm are three white-haired ladies from Cecil
-- 65-year-old
grandmother ranice Gibbs is the youngest of the crew -- who were meeting to discuss
ways to unseat
.
Mr. White or protect themselves from his wrath if he's re-elected.
"I voted f9r ht twice," said Mrs. Gibbs, whom Mr. White pretended to be by using
her name to
register on sef e~al Internet sites, ~ll~ng her "dumber than a box of rocks," and
an "uneducated
yinzer" for her viewson gas well dnllmg.
Mrs. Gibbs sdid she is a proponent of safe drilling, though she has no lease for
her 10-acre property.
She said she tas astonished by Mr. White's actions last year and frustrated that no
legal action was
taken againstlfhim by lawmakers or prosecutors. .
The citizen's group has a handful of members, including Judy Bowser and Darlene
Barni, who
protested agdinst Mr. White outside his Harrisburg office last year, urging him to
resign.
s1gnatur~s to convmce Mr. Wlute to resign. They got nearly 300 supporters.
Group memHers said they are concerned about what will happen if Mr. White wins re-
election. They
are planning /to mount a campaign to inform voters, especially those in new parts
of the district, which
includes Bridgeville and the surrounding area.
"Turnout is Lportant,"
. I
Mrs. Gibbs said. "People in the new area have no idea what he's like."
When the flab over the fake online personas blew up last year, Mrs. Gibbs said Mr.
White left a note
on her door Jsking for a private meeting to discuss issues between them, but she
feared meeting with
I
.
him alon. 1:
lsagree
with Rep. White, you become a target," she said. 'You may as well wear a bullseye
''When you
on your bac~."
Those sep.tilljlentshave been echoed by others, who say that Mr. White goes beyond
passionate in his
views and ca't tolerate disagreement or criticism.
1;
''You ha\fe t work with yo~r :ell~w representativ~s, your fellow se~ators. If I'm
on the losing end of a
4-1 vote,.I mGve on. The op1mon 1sthat Jesse cant. Ifhe loses that issue, he has to
go after those four
until they're p.estroyed," said Mr. Casciola, 59, a homebuilder.
Mr. Casci?la ~as been a supervisor for 22 years and said he's never seen a state
representative who is
unable to worl-<with even members of his own party due to constant conflicts.
The bipartisam. group of officials who control where the local share of slots
gaming revenue from the
Meadows(Ra9 etrack & Casino is to be used are "loathe to support anything that
Jesse puts his name
1
on," Mr. Casciola said.

State Sen; Tim Solobay, D-Canonsburg, one of those who was impersonated last year
online by Mr.
White, has ptously
said he won't support the incumbent
Mr. White said his conflicts with Mr. Solobay revolve around a difference of
opinion regarding gas
well drill~g ~ said he frequently works with U.S. Rep.Tim Murphy, R-Upper St Clair,
who he said
sent a staff mimber to a recent forum on drug abuse sponsored by Mr. White.
Susan Mosycpuk, Mr. Murphy's chief of staff, confirmed that the office sent a staff
member to the
event due to t)ie congressman's interest in prescription drug and heroin abuse, but
had no comment
'
1
,I
about the Derocratic pnmary.

Mr. Whit makes no apologies for his nature and said he thinks his role as a
"watchdog" for the
drilling induJtry has made him a target.
"So man)( of Ly colleagues have ignored these issues because they don't want to
take on the drilling
industry and iin this district, you can't do that," he said.
In the di~trict, known for its rich natural gas deposits and heated debates over
how best to safely
access that rJsource -- even President Barack Obama describes natural gas as "the
'bridge fuel' that
1
can power o '.reconomy" -- the candidates differ somewhat on impact fees and
whether drillers should
be charged a ,severance tax.
Mr. Whi~e ,d Mr. Casciola supported a challenge to Act 13, the state's 2012
sweeping law governing
Marcellus S~ale development and impact fees. In his role as Cecil supervisor, Mr.
Casciola was among
a small grou~ of municipal leaders who successfully challenged the zoning
provisions in the law, while
Mr. Whiie sJpported the challenge in several key ways.
With stafewipde zoning provisions struck down as unconstitutional by state Supreme
Court in
December, l\fr. Casciola said he's largely satisfied that drilling companies are
paying their fair share,
though h,e wrldn 't oppose a slightly higher impact fee, so long as it wouldn't put
jobs at risk.
It's an inipo~t
I
distinction for Mr. White, who supports a "reasonable" severance tax in addition to
'
/l
. '
ee.
t he current' impact
"
14k
at all the money we're leaving on the table ...when we have critical funding issues
... I
"When yo
think in this d;ayand age, how can we not have a severance tax?" Mr. White said.
"We're the only state
that doesn't h~ve one. The impact fee works out to the functional equivalent of a 1
percent tax rate."
Before the dells of Act 13 were ironed out, Mr. While said he was "personally
lobbied" by drilling
industry exechtives who were hoping at the time for a 7 percent tax.
.'Idon't buy
e we're-going-to-kill-the-goose-that-laid-the-golden-egg argument, especially in

Southwe~teri Pennsylvania I've seen the infrastructure around here on a daily basis
and it's not going
anywher~. Atjyone who says anything different is uninformed or disingenuous."
r
Mr. Casdola said he isn't courting the industry for campaign funds and a spokesman
for Range
Resources -- fue major drilling company in the district -- has said the company
won't get involved in
the race.;
"I'm not foot
for their support," Mr. Casciola said.
Mr. White says he isn't opposed to drilling and doesn't favor a moratorium, but his
well-publicized
comments Iatt year have fairly or unfairly drawn him as the anti-drilling
candidate.
Jt
bills itself as "the Energy capital of the East," that was named among the top tier
in job
In an are~
1
growth in th] : nation, such a position can be a tough sell.
"Shale has b )come its own political party," Mr. White observed. "You're either on
their team or you
aren't." :
Janice Crobptqn:jcrompton@post-gazette.com.
or 412-263-1159.
Sup.
e C.
,o
. rJem.
tCour
!
1'
For ProthonotaryUse Only:
FilED
'
r.
.
.
Docket No:
'
<..,VisH 1Jb....
'
County
APff22 ttJ15
~JS ~o2/8
J
Th~9ltf
he i+Ormotion col/ec1ed o~ 1hisform i~ used solely ji,r court odmioistrolion

purpom.
t;/Molf1A.RY
supple,mentor replace theft/mg and service of pleadings or other papers as reqwred
by law or rules of court.
.. Corilme~~e~ent of Action:
s...JEIComplaint
Cl Petition
Writ of Summons
D Declaration of Taking
D Trarisfer from Another Jurisdiction
E' .. .
.c
..
.T
Lead Defendant'sName:
Charles E. Kurowski
Lead Plairtiffs Name:

Jesse ~effrey White
I
I.. Are m!ney damages requested? l?!1

Yes
D No
0
N

(check one)
IEINo
Is this an MDJ Appeal?
bthisl!aiC/assActionSuit?
DYes
[]within arbitration limits

IEJoutside arbitration limits
Cl Yes
JE1No
NTJ e of Plaintiff/Appellant's Attorney:----------------------------
IEI
Ch,~ck l'rnrcif you haw 1w attorncy {arc a Sdf-Rcprcscntcd [Pro Sci Litigant)
.._~~-.-~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~--'
NaturJi of the Case:
your
1:
'
.TORT
I' not include Mass Tort)

(do
... DI n1*:ntiona
I,
1
[J M!licious Prosecution
I'
t] Motor
Vehicle
...
l'"'l'NI,,
LJ
U1sance
CONTRACT (do not include Judgments)

[J Buyer Plaintiff
IJ Debt Collection: Credit Card

IJ Debt Collection: Other
CJPr?duct Liability (does not include

mass tort)
(EJSlfuider/Libel/ Defamation
a oter:
Cl Board of Assessment
Cl Board of Elections
CJPr~mises Liability
s
E
c
CIVIL APPEALS
[j Employment Dispute:
Discrimination
Cl Employment Dispute: Other
Cl Zoning Board
Cl Other:
IJ Other:
0.
....MA.SS ~ORT
CJAsbestos
I
Cl T~bacco
D T~xic Tort- DES
ClToxic Tort - Implant
Cl TticWaste
O OI:er:
B.
t] Ejectment
IJ Eminent Domain/Condemnation
[j Ground Rent
jl
IJ Landlord/Tenant Dispute
IJ Mortgage Foreclosure: Res1dent1al
:.' PROFESSIONAL LIABLITY

>
REAL PROPERTY
.
I'
Cl
Dental
[J L6gal
.a ~~dical
Cl Other Professional:
[] Mortgage Foreclosure: Commercial

[l Partition
IJ Quiet Title
[j Other:
MISCELLANEOUS
Cl Common Law/Statutory Arbitration

[] Declaratory Judgment
Mandamus
Non-Domestic Relations
RestrainingOrder
[] Quo Warranto
Cl Replevin
Cl Other:
. -1~,
::
1
.
~~~~~~~~
Updated 1/1/2011
JESSE fWHITE,
Civil Division
Plaintiff,
vs.
No.:
CHARLES E. KUROWSKI,
Defendant.
COMPLAINT

PA I.D. # 91152
...

P.O. Box 384
Cecil, PA 15321
724-743-4444
JESSE :WHITE,
Civil Division
Plaintiff,
No.:
vs.
CHAR ES E. KUROWSKI,
Defendant.
NOTICE TO DEFEND
YOUhrve been sued in court. If you Wish to defend against the claims set forth in
the
follo1ng pages, you must take action within twenty (20) days after this complaint
and notice
aiie served, by entering a written appearance personally or by attorney and filing
in writing
Vlri.th
the court your defenses or objections to the claims set forth against you. You are
warned
14at it/iyou fail to do so the case may proceed without you and a judgment may be
entered
against you by the court without further notice for any money claimed in the
complaint or for
any o~er claim or relief requested by the plaintiff. You may lose money or property
or other
righ,i important to you.
YOU ~HOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAfiYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF Ydu CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
~ROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
'
I'
SER,ICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWVER REFERRAL SERVICE
119 S,outhCollege Street
'{Vas*ngton, PA 15301
724-225-6710

724-225-6710
IN THE COURTOF COMMONPLEASOF
JESSEfWHITE,
Civil Division
Plaintiff,
vs.
No.:
CHAR,'ES E. KUROWSKI,
Defendant.
COMPLAINT
ANDNOWcomes the Plaintiff, Jesse White, who files this Complaint in Civil Action
against
Defen1ant, Charles E. Kurowski, and in support thereof avers the following:
1.
' The Plaintiff, Jesse White, is an adult individual residing at 26 White Lane,
McDonald,
. PA 15057.
2:
The Defendant, Charles E. Kurowski, Esq., is a practicing attorney with an address

of
30 South Main Street, Suite 102, Washington, PA 15057.
On February 5, 2015, Defendant filed a Complaint against Plaintiff in the
Washington
County Court of Common Pleas at case number 2015-631.
, The Complaint was filed on behalf of Defendant's client, Sharlene Watazychyn.
I
The Complaint contained allegations of identity theft, invasion of privacy and

slander
of credit.
6..
Within moments of the filing of the Complaint, numerous media outlets were alerted
of
the filing and presumably were given copies of the Complaint by Defendant or
someone on his behalf.
7.
The story was picked up by several of those media outlets, including KDKA-TV,The
Washington Observer-Reporter, the Pittsburgh Post-Gazette, the Pittsburgh
TribuneReview, the Almanac, and WJPA Radio.
8.
Defendant issued statements on the record in numerous cases in reference to the

Complaint.
9.
.:Defendant's client, Sharlene Watazychyn, had previously referred the matter to

the
!Pennsylvania State Police with the stated goal of having criminal charges filed
against
;Plaintiff.
10.
Plaintiff spoke with Trooper Brown of the Waynesburg Barracks of the Pennsylvania
State Police on several occasions in January 2015 and provided written
documentation that severely impacted the credibility of the allegations made by
Defendant's client.
.On January 25, 2015, Trooper Brown informed Plaintiff that the documentation
submitted was sufficient, there was no evidence of criminality, and the case was
considered closed with no further action to be taken.
1i.
Trooper Brown also told Plaintiff that he had communicated the same to Defendant's
client, who was irate because there would be no criminal action.
12.
'
13.
i
14.
15.
Defendant's client left three (3) separate voicemail messages for Plaintiff on
January
25-26, 2015 acknowledging her conversations with Trooper Brown and his position
that the case was closed.
: Defendant filed the aforementioned Civil Complaint on February 5, 2015.

, :In his numerous interviews with the media, Defendant made inferences and direct
statements to imply that the conduct of the Plaintiff may have been criminal in
nature,
, despite clear evidence to the contrary given to his client.
!
16.
11.
In the Pittsburgh Tribune-Review on February 7, 2015, Defendant told a reporter

that
his client "told state police about the matter". Defendant is quoted as saying, "My
understanding is they are looking into it." See Exhibit "A".
: This statement by Defendant, which implies criminal conduct on the part of the
Plaintiff, is completely false.
1:a. Defendant either knew or should have known that his statement was false,
because
his client had known there was no criminal investigation pending for nearly two
; weeks.
19.
Defendant is quoted on KDKAtelevision on February 5, 2015, as claiming Plaintiff's

actions were "fraud", which is both a criminal and civil offense. Defendant makes
no
effort whatsoever to clarify that the alleged actions were civil and not criminal
in
nature.
40.
,Plaintiff requested a clarification from Defendant to the media on the specific

issue of
implied criminality, which was flatly refused by Defendant.
21.
Although Plaintiff had previously served as a member of the Pennsylvania House of

Representatives from 2006-2014, he held no elected or appointed public office at
the
time the statements were made by Defendant and therefore was not a public figure.
,
COUNTI - DEFAMATION
22.
~~ragraphs 1-21 are incorporated by reference as though fully set forth herein.
23.
~efendant's communications to the media intended to hann the reputation of

Plaintiff
as to lower him in the estimation of the community or to deter third persons from
~ssociating or dealing with him, and are therefore defamatory under Pennsylvania
law.
24,:
IJl)efendant'scommunications to the media intended to ascribe to Plaintiff conduct,

~haracter, or a condition that would adversely affect his fitness for the proper
conduct
bt
his proper business, trade or profession, and are therefore defamatory under
II
Pennsylvania law.
25.:
Oefendant's overall comments to the media were defamatory in that they implied
~riminal conduct on behalf of Plaintiff that Defendant knew or should have known
was
I!
1:
iUiltrue.
I
pefendant's specific comment to the Pittsburgh Tribune-Review that the PA State

Police "are looking into it" is defamation per se, as the comment clearly intends
to
;imply criminality where Defendant knew or should have known none existed.
26;
!These statements were made by Defendant to the media and published to potentially
hundreds of thousands of readers and viewers in the Greater Pittsburgh area. The
!story was also picked up by the Associated Press and therefore visible worldwide.
1
28.
:A reasonably prudent person would understand Defendant's statements to be

i defamatory and directed specifically at the Plaintiff.
29.
!
30.
; Defendant's statements were malicious in nature.
31.
32.
Defendant's statements were negligent in nature.
including clients who disengaged Plaintiff as a result of Defendant's statements.
humiliation, and mental anguish and suffering as a result of Defendant's statements
and is entitled to damages.
Defendant's conduct was outrageous because of his personal motive and/or his
reckless indifference to the rights of others .
34.
.Defendant's conduct was malicious, reckless, willful, and oppressive towards

Plaintiff.
35.
Plaintiff is entitled to punitive damages.
W.:
H~.'.BREFORE,
of fiftythousand dollars ($50,000), exclusive of interest and costs.
COUNTII - COMMERCIAL
DISPARAGEMENT
36.
raragraphs 1-35 are incorporated by reference as though fully set forth herein.
37.
Plaintiff
runs his own law practice, currently located at 3350 Millers Run Road, Suite
I
i02, Cecil, PA 15321.
'
38.:
39.
Lhe business is a sole proprietorship belonging solely to Plaintiff.
40J
pefendant's statements implying criminality of Plaintiff were false.
4L

relationships.
42;
I!
'Defendant intended the publication of his statements to cause financial loss, or

he
ishould have reasonably recognized the publication would result in financial loss.
'
44.
45.
Plaintiff did in fact suffer a financial loss as a result of Defendant's

statements.
Defendant knew or should have known that his statements were false and in reckless
: disregard of their truth or falsity.
WHB,EPORB, the Plaintiff demands judgment against the Defendant in an amount in

excess
of~
thousand dollars ($50,000), exclusive of interest and costs.
ResP.ectfully Submitted,
VERIFICATION
I, Jesse/White, hereby state that the facts above set forth are true and correct
(or are
true an& correct to the best of my knowledge, information and belief) and that I
expect
to be J1e to prove the same at a hearing held in this matter. I understand that the
statemtits
herein are made subject to the penalties of 18 Pa.C.S. 4904 (relating to
unswo& falsification to authorities).

I
i-~:l-/)
Da;te
,..
'
R_etumto Slot-
print_Thispage_
ii
Larger text"
Smaller text
Formet: state Rep. White stole identity, charged $28K in

her ~a.\ne, mother says in lawsuit
By Jason
catd.
Saturday, F~b. 7,lf

2015, 12:01 a.m.
Having bOme~!ear-constantattacks and criticismas a

lawmaker)for :.
er state Rep. Jesse White has another feud to
deal with ,- ofthe family variety.
White's mothe~. Sharlene Watazychyn, 57, of Waynesburg filed
a 33-pag~ co~plaint this week in Washington County courts
that accmJes h~r son of identity theft and making more than
$28,000 in un~llthorized charges on an account in her name.
"I don't know Jho this kid is since he's been elected,"
Watazychyn sJip Friday. "When the facts come out, it will come
out how much ~~is boy lies."
White, 36, a Cecil Democrat, returned Friday to Western
Pennsylvania ftQm South Carolina. White, an attorney, said he
has not s~en t~e lawsuit but insisted the allegations are not true
and they stem 1~omhis mother's history of substance abuse and
mental illness. !
'This lawsuit is !frivolous. The whole thing is just absurd," White
said. "I wm hanttle it quickly and effectively."
Former state Rep. Jesse White
LIVE
Watazychyn dclnied having any addiction or mental health

issues.
!;,
I
"Absolutely not l" she said. "He's grasping at straws to make me

look irrational." i
Watazychyn's attorney, Charles Kurowski, said his client discovered the account in
July when trying to refinance
said that beside.s the civil suit, Watazychyn told state police about the matter.
her mortg~ge.
~f3
"My unders~nd,itg is they are looking into it,"Kurowski said.

State police coilild not be reached.
In the laws'uit fil~d Thursday, Kurowski stated that White .opened a revolving Citi
Bank account in Watazychyn's
name and had b~en using it without her authority.
It has an o~tst+~ing balance of $27,816.55, statements show. The account's credit
limit is $29,100.
Among the,,cha~ges on the account are payments to the Washington County Bar
Association, White's law office
and the Pittsburi~h Penguins for season tickets. Other payments include travel and
other expenses related to
White's 2012 w~dding in Las Vegas.
Watazychyn acused her son of signing her name on three checks cashed on the
account for $11,000.
White maintain~ that he has long been authorized to use the Citi Bank account,
which he said his mother opened
for him to use ~hn he started his professional career. He said his mother is aware
of this and that he has voice
mail messages ahd other evidence.
"I can prov~ thiJ so easily," White said.
In his Faceboo~i statement, White said he and his wife, Eileen, expressed concerns
to his mother last summer
after the bir:thofj(their son because they were not comfortable with her driving
the baby while using or under the
influence of illega'I drugs. That conversation did not go well, White said.
"It is unfortunat~. but not at all shocking," he wrote. "This.suit is another

example of my mother's refusal to
address an :und~f"lyingproblem."
: . I,.
White contends ti:he lawsuit was filed soon after he made it known that he might
run for a vacant district judge
:
i
\IA,.
.
i
seat.
\l
In.November,'(111,ite
lost a re-electionbid for the 46th District House seat he held since 2006. White
was
was discoveredin 2013 that he used online alter egos to attack his critics on the
Internet.
criticized\o/henllit
Kurowskisaid fhe lawsuit has nothingto do with politics.
"He actuallythjrks he could be elected? I can't believe it. This guy is
something,"he said. "I don't have any
politics agains~!him- other than how could you do this to your own mother?"
Jason Cato
is aI writer for Trib TotalMedia. Reach him at 412-320-7936or jcato@tribweb.com.
,
Copyright'2015-Trib
Total Media
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Com~encef.ent of Action:.
.
IB] Complamt
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D Petition
[] Wnt of Summons
DI'transfbr from Another Jurisdiction

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Cl Declaration of Taking
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Lead Plaintiffs Name:

Jesse W*ite
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Lead Defendant's Name:
T.
T Are mon~y damages requested? IBlYes
Merl Williams
DINo

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IE!No
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Dlwithin arbitration limits
IE!outside arbitration limits

[J Yes
tB] No
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'
Name of Plaintiff/ Appellant's Attorney:

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IE! Check here if you have ,w attorney (arc a Se!f:.}h!prcscnted [Pm Sc! Litigant)
Nature of the Case:

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CONTRACT
(do not include Judgments)

DIBuyer Plaintiff
DIDebt Collection: Credit Card
DIDebt Collection: Other
CIVIL APPEALS
DIBoard of Assessment
DIBoard of Elections
Cl Employment Dispute:
Discrimination
DIEmployment Dispute: Other
DIZoning Board
DIOther:
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REAL PROPERTY
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DIGround Rent
Cl Landlord/Tenant Dispute
DIMortgage Foreclosure: Residential
Cl Mortgage Foreclosure: Commercial
DIPartition
DIQuietTitle
DIOther:
MISCELLANEOUS
DICommon Law/Statutory Arbitration

DIDeclaratory Judgment
DIMandamus
[] Non-Domestic Relations
Restraining Order
DIQuo Warranto
DIReplevin
Clother:
Updated 1/1/2011
Civil Division
Plaintiff,
vs.
No.:
MERL 'fILLIAMS,
DARLENE BARNI,
JUDY ~OWSER,
JANICE GIBBS,
"C0NC/ERNED CITIZENS OF THE
46th DI :TRICT",
Defendants.


Jesse J. White, Esq .
PA I.D. # 91152

P.O. Box 384
Cecil, PA 15321
724-743-4444
JEasE
j:
HITE,
Civil Division
Plaintiff,
vs.
No.:
MERL lfILLIAMS,
DARLENE BARNI,
JUDY ~OWSER,
JANICE GIBBS,
"CC>NC~RNED CITIZENS OF THE
46~ DI~TRICT",
Defendants.
COMPLAINT IN DEFAMATION
AND COMMERICAL DISPARAGEMENT
NOTICE TO DEFEND
You haye been sued in court. If you wish to defend against the claims set forth in
the
follbwiJg pages, you must take action within twenty (20) days after this complaint
and notice
are; senl'ed, by entering a written appearance personally or by attorney and filing
in writing
with th~ court your defenses or objections to the claims set forth against you. You
are warned
that if Yilbu fail to do so the case may proceed without you and a judgment may be
entered
aga.'in:~..:you by the court without further notice for any money claimed in the
complaint or for
any o ....
_1~r claim or relief requested by the plaintiff. You may lose money or property or
other
1
rig;ts irportant to you.
1
YOU SJiOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A I;,A~YER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CA!NPROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
'
1:
IF YOl.f CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO

PR,OVI~
.
E YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVIrES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER
REFERRAL SERVICE
1,
11~ Softh College Street
Washh~gton, PA 15301
724-22~-6710

724-225-6710
JESSE '.WHITE,
Civil Division
Plaintiff,
No.:
vs.
MERL fl'ILLIAMS,
DARLENE
BARNI,
:
I!
JUDY BOWSER,
JANIC~ GIBBS,
"C'ONaERNED CITIZENS OF THE
46th DISTRICT"
i
,
COMPLAINT IN DEFAMATION
AND COMMERICAL DISPARAGEMENT
Defendants.
COMPLAINT IN DEFAMATION AND COMMERCIAL DISPARAGEMENT
I
A~D
~:owcomes the Plaintiff, Jesse
White, who files this Complaint in Civil Action against
Defend:ants, and in support thereof avers the following:

1. .
IThe Plaintiff, Jesse White, is an adult individual residing at 26 White Lane,

McDonald,
PA 15057.
2.:
:The Defendant, Merl Williams, is an adult individual residing at 267 4 Reissing

Road,
McDonald PA 15057.
3 ..
The Defendant, "Concerned Citizens of the 46th District" is an unincorporated

:organization believed to be headquartered at 1943 Route 980, Canonsburg PA 15317.
4.:
iThe Defendant, Darlene Barni, is an adult individual residing at 1943 Route 980,
'canonsburg PA 15317.
5.:
:The Defendant, Judy Bowser, is an adult individual residing at 804 Redwood Road,
(McDonald PA 15057.
6.:
!The Defendant, Janice Gibbs, is an adult individual residing at 293 Profio Road,
:McDonald PA 15057.
7.
House of Representatives, representing the 46th Legislative District.
IPennsylvania
~laintiff was up for re-election in 2014 and faced both a Primary and General
Election
dhallenge.
8.
1:
9.
1aintiff defeated Democrat Tom Casciola in the May 20, 2014 Primary Election by a
total of 3,107 to 2,366 votes.
10.
flaintiff lost to Republican Jason Ortitay in the November 4, 2014 General Election
by
a total of 10,462 to 8,169 votes.
1
1:
July 2013, Plaintiff attended a three-week course at the John F. Kennedy School of
@overnment at Harvard University for Executives in State and Local Government.
11.:
I!
12.
Plaintiff paid the tuition for this course, which was approximately $11,000.00, via
a
!tudent loan. No taxpayer dollars were used to pay for said tuition.
13.
or about July 29, 2014, Defendant Merl Williams posted on the social media
internet site Facebook regarding Plaintiff's attendance at the Kennedy School. The
felevant portion of his post, attached as Exhibit "A", says:
bn
I
I called out to that class he took for 3 weeks, yes tax payers payed for it, it
was like $11,000. I was told it was a high end CEO and Corporate leaders
class to under stand and how to deal with stressful situations. So I asked
"So this is like an Anger Management Class" I was told "Yes, a very
expensive one"
14.
fhe posting was made on the Facebook page "Concerned Citizens of the 46thDistrict",
rLnanonymous page devoted almost exclusively to criticizing Jesse White.
(https://www.facebook.com/www.concernedcitizens46thdistrict)
15.:
~ccording to an article in the Pittsburgh Post-Gazette dated May 3, 2014, attached
as
Exhibit "B", the "Concerned Citizens of the 46thDistrict" are led by three
individuals:
barlene Barni, Judy Bowser and Janice Gibbs.
16.
,The "Concerned Citizens of the 46th District" also operate a website dedicated to
,attacking Plaintiff (http://www.concemedcitizens46thdistrict.com).
17~
All of the posts on both the Facebook page and the website are anonymous; in fact,
individual members of the "Concerned Citizens" would often communicate
individually with the organization via Facebook to presumably create the impression
:that they were not affiliated with the organization or its content.
1
18;
!on April 27, 2014, Defendant Merl Williams posted on the Concerned Citizens 46th
!District Facebook page about an incident that had occurred at a community event.
:(See Exhibit "C", attached.)
19.
:Not only is the April 27, 2014 statement by Defendant Merl Williams utterly false,
the
:"Concerned Citizens 46thDistrict" responded by stating "You are absolutely right,
Merle. I was there also. Here he goes again with poor me, pooooor meee. He is so
full
iof it." (See Exhibit "C", attached.)
20.:
pn or about July 20, 2014, Defendant Merl Williams posted the following on his
Facebook page (See Exhibit "D", attached):
When we went to Harrisburg, myself and a friend went to his office. We
went in and ask to speak to Jesse White. His reception person told us he
would get him. He got up went in to get Jesse came back out and said
Jesse was not in. Jesse White was in. He was actually hiding behind a
book shelf. Then when he opened the tundra door and seen the the people
who he used their name, he slammed the door shut and ran away. His own
peers were laughing at him in the halls!
2V
o such incident, nor anything remotely resembling it, ever occurred.
22.
Ji1here
was no bookcase in Plaintiff's office at the State Capitol (212 lrvis Office
!Building)that Plaintiff could have possibly hid behind.
23.
bn or about May 17, 2014, Defendant Merl Williams posted the following to the
oncerned Citizens 46th District Facebook page (See Exhibit "E", attached):
.. .People outside our district that are now in his don't know about his
Bullying that goes beyond the internet. His behavior in public is
outrageous. Giving people the middle finger. There are police reports on
that.
24;
The incidents described in Paragraph 23 never occurred.
25,
rBystating "There are police reports on that", Defendant Williams is directly

implying
!criminal conduct on the part of Plaintiff.
26;
)Plaintiffhas never been questioned about, charged or cited with anything remotely
!similarto the incident described in Paragraph 23, and to the best of his knowledge
and
ibeliefno police report exists.
COUNTI - DEFAMATION
27;
28:
)Defendant Merl Williams' statements made via social media intended to harm the
'reputation of Plaintiff as to lower him in the estimation of the community or to
deter
;third persons from associating or dealing with him, and are therefore defamatory
)under Pennsylvania law.
29.
;Defendant Merl Williams' statements made via social media intended to ascribe to
iPlaintiff conduct, character, or a condition that would adversely affect his
fitness for
,the proper conduct of his proper business, trade or profession, and are therefore
defamatory under Pennsylvania law.
'!Defendant Merl Williams' statements made via social media were defamatory in that
Defendant knew or should have known was untrue.
30.
These statements were made by Defendant Merl Williams via social media and
:therefore visible worldwide.
31.
'
A reasonably prudent person would understand Defendant Merl Williams' statements

;to be defamatory and directed specifically at the Plaintiff.
32.
33.'
pefendant Merl Williams' statements were negligent in nature.
34:
:Defendant Merl Williams' statements were malicious in nature.

'
35.
:including clients who disengaged Plaintiff as a result of Defendants' statements.
36;
:Plaintiff also lost salary and benefits he would have been entitled to as a member
of
(the Pennsylvania House of Representatives had he been re-elected.
37.

humiliation, and mental anguish and suffering as a result of Defendants' statements
:and is entitled to damages.
38.
Defendants' conduct was outrageous because of their personal motive and/or their
reckless indifference to the rights of others.
39!
Defendants' conduct was malicious, reckless, willful, and oppressive towards

Plaintiff.
40J
!Asproof of malice on the part of Defendant Merl Williams, on or about May 21,
2014,
Williams posted the following on Facebook (See Exhibit .._,,, attached):
Sorry Tom Casciola did not win his election to knock Jesse White off the
ballot. Although, on the other hand, we get to watch State Rep. Jesse White
get his face dragged through the mud from the Republican Party.
41.
: y publishing and responding to Defendant Merl Williams' defamatory comments,

befendant "Concerned Citizens of the 46th District" (and by extension self-
identified
proup members Darlene Bami, Judy Bowser and Janice Gibbs) are liable for the
refamatory content of knowingly false statements posted on their Facebook page.
42.,
rmplying criminality as set forth in Paragraph 23 is defamation per se.
43.;
rlaintiff is entitled to punitive damages.

exdess bf fifty thousand dollars ($50,000), exclusive of interest and costs.
COUNT II - COMMERCIALDISPARAGEMENT
44.
'
aragraphs 1-43 are incorporated by reference as though fully set forth herein.
1t
45.,
flaintiff runs his own law practice, currently located at 3350 Millers Run Road,
Suite
02, Cecil, PA 15321.
46.i
f
1:
47.;
48.i
49.
50.
he business is a sole proprietorship belonging solely to Plaintiff.
Defendants' statements published on Facebook were knowingly false and published

lwithactual malice towards Plaintiff, and therefore were defamatory.
lawyer's reputation in the community is essential to cultivating client

relationships.
1,
false implication of criminality is damaging to that reputation.
51.
befendants intended the publication of their statements to cause financial loss, or

they
,should have reasonably recognized the publication would result in financial loss.
52.

statements.
53.
;disregard of their truth or falsity.
WHERJ3FORE,
of fifty ~housand dollars ($50,000), exclusive of interest and costs.
VERIFICATION
I, Jesse:White, hereby state that the facts above set forth are true and correct
(or are
tru~ anb correct to the best of my knowledge, information and belief) and that I
expect
to be
af1eto prove the same at a hearing held in this matter. I understand
that the
statements herein are made subject to the penalties of 18 Pa.C.S. 4904 (relating
to
unswo& falsification to authorities).
C/-;H-/>
I
'
Date
'
:
Merl dHams I called out to that class he took for 3 weeks, yes tax payers payed
for;it, ~ was like around $11,000. I was told it was a high end CEO and Corporate .
leadets class to under stand and how to deal with stressful situations. So I asked
11
Sb trlis is like an Anger ManagementClass" I was told "Yes,a very expensive one11
So mt theory is and some others in his position that the democraticparty sent him
to there classes at your expensefor the bad behavior he had done with his online
p~rsopa's. Even though he did this, he never mentionedan apology on TV, Radio
orin ~ublic. Each month on the first Monday,he has every opportu.nity to apologize
to thelwomen he made victims by using their identity.Jesse they are there each
I
meeti g, I have seen you there but never once have the balls to walk up and
apolobize like a real man.
Like [Reply 161 12
'
,,
A
Incum~ent hopes to overcome scandal in 46th
Legisla~iveDistrict
:3r
May 3, 2014 11
PM
By Janice Qrofpton I Pittsburgh Post-Gazette
Though it is gr+nd zero for Marcellus Shale gas development in the area and home to
several local
drilling giants, tjhe 46th Legislative District in Washington and Allegheny
counties features a primary
election that is Jurprisingly skimpy on issues involving shale gas drilling.
Instea~ th ra+ for state rep~esentati:,"e there see:"s t~ have boiled ~own to one
thing:. Can a techsavvy lllCUf\lber overcome h1s past fmb]es and tlnn-skmned
reputat10n to hold OU to h1s seat?
State Rep. Jesse White, a Democrat and lawyer from Cecil, hopes so.
"I take full =p~nsibility for the way I conducted myself. It's not something I'm
particularly proud of.
It's something] think about every single day," he said of a scandal last year that
made national
headlines wheJ it was revealed that Mr. White used pseudonyms and even impersonated
his enemies
on Internet:pos~ngs, especially those on social media sites like Facebook.
As he goes dooLo-door
introducing himself to voters in his redrawn district, Mr. White, 35, said he's
hearing suppotl for his tough stance against the Marcellus Shale drilling industry
despite his
peccadilloes.
He is beingichalllenged by Cecil supervisor Thomas Casciola in the Democratic

primary May 20 and
the winner bf iat race will face Republican Jason Ortitay, a 30-year-old small-
business owner from
South Fayette, 1n the Nov. 4 general election.
"I hear, 'Yeah, you screwed up. That was really stupid. But, we get that you are
the guy out here that's
asking the tough questions. You put yourself in the line of fire when you could
have easily stuck your
head in the: sar,"' he said. "At the end, that's what I think matters to people."
.
But that isn't Wrlhatmatters to all of the voter~;
f:/
A recent mefitint of the Concerned Citizens of the 46th Districtlooked more like a
game of bridge than
'
a political actio
committee. At its helm are three white-haired ladies from Cecil -- 65-year-old
I,
,
grandmoth~t J bice Gibbs is the youngest of the crew -- who were meeting to discuss
ways to unseat
Mr. White pr, tect themselves from his wrath if he's re-elected.
'
or
"I voted for himftwice," said Mrs. Gibbs, whom Mr. White pretended to be by using
her name to
register on several Internet sites, calling her "dumber than a box of rocks," and
an "uneducated
1
yinzer" for her m[ews on gas well drilling.

:
Mrs. Gibbs $aid Ishe is a proponent of safe drilling, thongh she has no lease for
her 10-acre property.
She said she wa: astonished by Mr. White's actions last year and frustrated that no
legal action was
taken against h~m by lawmakers or prosecutors.
I
The citizen'$ gr up has a handful of members, including Judy Bowser and Darlene
Barni, who
protested aiain'. t Mr. White outside his Harrisburg office last year, urging him
to resign.
The group confi;onted the incumbent again in September, during a local fall
festival where they sought
signatures to cdnvince Mr. White to resign. They got nearly 300 supporters.
Group membert' said they are concerned about what will happen if Mr. White wins re-
election. They
are planning to :mount a campaign to inform voters, especially those in new parts
of the district, which
includes Bridge, lle and the surrounding area.
"Turnout islimlrtant,"
Mrs. Gibbs said. "People in the new area have no idea what he's like."
When the tlap ~ver the fake online personas blew up last year, Mrs. Gibbs said Mr.
White left a note
on her door: as~ing for a private meeting to discuss issues between them, but she
feared meeting with
him alone .
"When you disagree with Rep. White, you become a target," she said. ''You may as
well wear a bullseye
on your back. "Ji
Those sen~e ;ts have been echoed by others, who say that Mr. White goes beyond
passionate in his
views and Jan'~ltolerate disagreement or criticism.
"You have to wprk with your fellow representatives, your fellow senators. If I'm on
the losing end of a
4-1 vote, I mov on. The opinion is that Jesse can't. Ifhe loses that issue, he has
to go after those four
until they're deroyed," said Mr. Casciola, 59, a homebuilder.
i
I
Mr. Casciola ha~ ~een a supervisor for 2_2years and said he's never seen a _state
representative who is
unable to work With even members of his own party due to constant conflicts.
The bipartisan ~roup of officials who control where the local share of slots gaming
revenue from the
Meadows Raceqack & Casino is to be used are "loathe to support anything that Jesse
puts his name
on," Mr. Ca8cio1r said.
State Sen. Tim ~olobay, D-Canonsburg, one of those who was impersonated last year
online by Mr.
I
White, has ~iously
said he won't support the incumbent
Mr. White said his conflicts with Mr. Solobay revolve around a difference of
opinion regarding gas
I,
well drilling and said he frequently works with U.S. Rep.Tim Murphy, R-Upper St.
Clair, who he said
sent a staff :i;neI!:
her to a recent forum on drug abuse sponsored by Mr. White.
I
Susan Mosi-;ch ] , Mr. Murphy's chief of staff, confirmed that the office sent a
staff member to the
event due to thJ congressman's interest in prescription drug and heroin abuse, but
had no comment
. Ii
ab out th e D em1cratic primary.
mak
Mr. White
i s no apologies for his nature and said he thinks his role as a "watchdog" for the
drilling industrlr has made him a target.
industry and inithis district, you can't do that," he said.

i
In the district, :nown for its rich natural gas deposits and heated debates over
how best to safely
access that res9urce -- even President Barack Obama describes natural gas as "the
'bridge fuel' that
can power our rconomy" -- the candidates differ somewhat on impact fees and whether
drillers should
a seh
: erance tax.
be charged
'
'
'
:
Mr. White and r. Casciola supported a challenge to Act 13, the state's 2012
sweeping law governing
Marcellus Sha!: development and impact fees. In his role as Cecil supervisor, Mr.
Casciola was among
1:
a small grou
p 0 1,,fmunicipal leaders who succe.ssfully challenged the zoning provisions in the
law, while
Mr. White sup ,orted the challenge in several key ways.
'
'
1
I
With statevyiodlezoning provisions struck down as unconstitutional by state Supreme

Court in
December, iMr./)casciolasaid he's largely satisfied that drilling companies are
paying their fair share,
thongh he woidn't oppose a slightly higher impact fee, so long as it wouldn't put
jobs at risk.
It's an importrt
distinction for Mr. White, who supports a "reasonable" severance tax in addition to
I
j:
!
'
.:
the current wpact fee.

I
''When you look:at all the money we're leaving on the table ...when we have
critical funding issues ... I
think in this: da~ and age, how can we not have a severance tax?" Mr. White said.
"We're the only state
one. The impact fee works out to the functional equivalent of a 1 percent tax
rate."
that doesn'that
Before the d;etaifs of Act 13 were ironed out, Mr. White said he was "personally
lobbied" by drilling
industry executives who were hoping at the time for a 7 percent tax.
"I don't buythe we're-going-to-kill-the-goose-that-laid-the-golden-egg
argument, especially in
Southwestern Prnnsylvania. I've seen the infrastructure around here on a daily
basis and it's not going
anywhere. Any1ne who says anything different is uninformed or disingenuous."
Mr. Casciola saj~ he isn't courting the industry for campaign funds and a
spokes1nan for Range
Resources -L thJ major drilling company in the district -- has said the company
won't get involved in
the race.
"I'm not looking for their support," Mr. Casciola said.
1:
Mr. White says ~e isn't opposed to drilling and doesn't favor a moratorium, but his
well-publicized
comments last year have fairly or unfairly drawn him as the anti-drilling
candidate.
1:
Inan area that bills itself as "the Energy capital of the East," that was named
among the top tier in job
growth in tlie nltion, such a position can be a tough sell.

"Shale has becoLe its own political party," Mr. White observed. ''You're either on
their team or you
aren't."
Janice Crompton: crompton@post-gazette.com.or 412-263-1159.
Merl Williams
District
> Concerned
Citizens 46th
April 27 i!J
a:':C~
ooo
fk
Jrtuna!e
Incidenton the campaign
trail; stoppedat
Just had a,.:unf
the MuseIt~lian!;clubfor some spaghettiand tripe but we never
got to sit ddwn6ecause Ced! SupervisorElizabethCowden,

wearinga ~tto~ for my opponent,made a vulgarremarkto me
and Eileen.
Here is Jesse White again, telling lies. I was there he

walked ln, got his food and left. NO ONE even spoke to
him. He is at his old tactics of picking on the same
people who have supported him in the past but won't
do so now. He is trying to drum up "sympathy Votes"
again.
Uke Comnwnt Sharr;;
11.:'.:l
3 people like this.
Top Comments
! 2 shares
:~<inoerri~(t;itiz~!)S46ffil~l&jrfof
You are
Instead of enga,ing her and her group, whichindudedmy

opponentTom ciola,formeropponentPaulWalshand a bunch
of supportersin icampaignt-shirts,we choseto takethe highroad
and got ou1:
foo!: to go. I guessyou reallyare definedby the
companyyou k ;ep.
1
:
absolutely right Merle.I was there also. Here he

goes again with poor me, pooooor meee. He is so
full of it
Llke Reply '63, April 27 at
Edited
Merl Williams All the same people were at
Bridgeville and I don't see him posting about us
there? All though 1can say he rolled his eyes at
me when I said hello.
,, c
l'
T
Merl , iHiams When we went to HarrisburgJmyself and a friend went to his
office.iWewent in and ask to speak to Jesse White. His receptionperson told us he
wquld :gethim. He got up went in to get Jesse came back out and said Jesse was
not in.iJesse White was in. He was actually hiding behind a book shelf. Then when
he:op ned the tundra door and seen the the peoplewho he used their name, he
sl~m redthe door shut and ran away. His own peers were laughing at him in the
halls! :
9:50am
\.\ D
,r
'
Meri Williams Those cards do not say anything about him. I
hav : everyone. I also have every one of Jesse White1s cards.

1
11
Ca 't be buUied,can1t be bought*1 People outside our district that
a~e . owin his don't knowabout his Bullying that goes beyond the
i~ie inet His behavior in public is outrageous. Giving people the
~id le finger. There are poHcereports on that He slandered false
ace :sations about me all over his Facebook page, then blocks
me $0I can not defend myself. He literally runs away from his
cbn '.tituents on many accusationswhen they approach him at
pub ,icfunctions. Really,he runs to his car and leavest With au the
c~ :eraphones out there, rm sure a video of it wm pop up
sprtjetime. Plus, he has been bought, his ass is chapped cause
Ra . e is not paying his way anymore.....*. Correction on my
1
sparing in the original post, I meant to say "flier" not flyer.

L~k i Reply rlj 2
1 at :14pm
\I[''
lr1
Wiiiiams
:orry Tom caseiola did not win his election to knock Jesse
.; hite off the ballot Althought on the other hand, we get to
: atch State Rep. Jes,seWhite get his face dragged through the
ud from 1heRepublican Party. @
!
Ii
r,n">,i,w,an,
11

Complaints For Defamation and Commercial Disparagement

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Complaints For Defamation and Commercial Disparagement

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j:

For Prothonotary Use Only:

Lead PlJintiffs Name:

Lead Defendant's Name:

.4re money damages requested?

Dollar Amount Requested:

ls thii a Class Action Suit?

Clwithin arbitration limits

of Plaintiff/ Appellant's Attorney:

Check here if you h_a_v_~_n_o_a_t_t,_ff_n_c_y_(_ar_c_'

. Naturk of the Case:

TORTj((do:7ot include Mass

i[l Motor Vehicle

D Pfoduct Liability (does not include

(do not include Judgments)

D Debt Collection: Credit Card

D Debt Collection: Other

IJ Employment Dispute: Other

i[] Tbxic Tort - Implant

COMPLAINT IN DEFAMATION AND

Filed on behalf of Plaintiff by:

OU SHOULDTAKE THIS PAPER TO YOUR LAWYERAT ONCE. IF YOU DO NOT HAVE

~~R REFERRAL SERVICE

119 ~outh College Street

COMPLAINTIN DEFAMATIONAND COMMERCIALDISPARAGEMENT

The Plaintiff, Jesse White, is an adult individual residing at 26 White Lane,

The Defendant, CBS Pittsburgh/KDKA AM, is Pennsylvania business with a primary

The Defendant, Marty Griffin, is an adult individual who resides in Allegheny

The Defendant, Donald Roessler, is an adult individual residing at 720 Ridge

According to their website, KDKAAM broadcasts news and talk programming 24

Plaintiff did not take "tens of thousands of dollars" in campaign contributions

There is no indication that Plaintiff ever threatened anybody in any way.

When questioned by Andy Sheehan of KDKATV about the incident in question,

The company mentioned by Defendant Griffin, Range Resources, is a natural gas

,Implying criminality as set forth in Paragraph 13 is defamation per se under

Defendant Marty Griffin's published statements had the impact of ascribing to

Defendant Marty Griffin's published statements alleging Plaintiff was under

Plaintiff suffered impairment of reputation and standing in the community, personal

By republishing the defamatory content published by Defendants Marty Griffin and

.Plaintiff is entitled to punitive damages.

Plaintiff has operated this business since February 1, 2004.

The business is a sole proprietorship belonging solely to Plaintiff.

A lawyer's reputation in the community is essential to cultivating client

A public official's reputation in the community is essential to cultivating public

A false implication of criminality is damaging to that reputation.

Defendants intended the publication of their statements to cause financial loss, or

Plaintiff did in fact suffer a financial loss as a result of Defendants'

a tittle researchon JesseWhite....and get backto ine.

;,., Jormarian calle~ted on this form

i! used solely .fi>rlc-o_i.::w:.:t

supplement or replace the filzng and service of pleadmgs or other papers as

Observer Publishing Company

Afe mfney damages requested?

Dollar Amount Requested:

ls this/!a Class Action Suit?

ls this an MDJ Appeal?

here if you have no attorney tare a Self-Represented [Pro Sci Litigant)

Clwithin arbitration limits

CONTRACT (do not include Judgments)

Filed on behalf of Plaintiff by:

i'CO~CERNED CITIZENS OF THE

SOUTHWESTERN PA LEGAL AID SOCIETY

"CO~CERNED CITIZENS OF THE