Filing # 114543575 E-Filed 10/06/2020 06:25:36 PM IN THE CIRCUIT COURT OF THE LIT JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO. MONARCH AIR GROUP. LLC, and JACOB GITMAN Plaintitis, GRANT STERN Defendant. COMPLAL ND DEMAND FOR JURY TRIAL, Plaintiffs MONARCH AIR GROUP, LLC and JACOB GITMAN sue Defendant GRANT STERN and allege INTRODUCTION 1. This is an action to recover damages in excess of $5,000,000 for the reputational damage suffered by Jacob Gitman [“Gitman”], a self-made entrepreneur, and a private aviation provider, Monarch Air Group, LLC [*Monarch Ait], due to the publication of an article by a so-called “investigative journalist” based on innuendo and false information. 2. The article falsely clsims that Gitman and Monarch Air have been found by a federal judge to be part of the “Russian Mafia,” even though neither he nor Monarch Air has ever been coavieted, let alone charged with, a crime. It also claims without a shred of evidence that Gitman and Monarch Air have “infiltrated” the Department of Justice.3. The publication of these baseless and unsubstantiated allegations, none of winich he even attempted to speak with Gitman or Monarch about, has caused the Plaintiffs irreparable reputational and economic harm, which is the basis for this action. Jurisdiction, Venue, and Pa 4, Plaintiff MONARCH AIR GROUP, LLC (“Monarch Ait”) is a Florida corporetion with its principal place of business in Fort Landerdale, Florida 3. Plaintiff JACOB GITMAN (“Gitman’) is 2 citizen of Florida and otherwise sui juris. 6, Defendant GRANT STERN (“Stem”) isa citizen of Florida and otherwise sui juris. 7. Venue is proper in Miami-Dade County pursuant to §§ 47.011 and 47.051 because the tortious conduct alleged accrued in Miami-Dade County and the parties reside in Miami- Dade County 8. All conditions precedent to the institution of this action have been satisfied or otherwise excused, including the service of statutory notice on Stem pursuant to Fla.Siat, § 770.01 9, Atall times relevant to this action, Gitman was ¢ minority shareholder of Monarch Air. 10. Atall times relevant to this action, Stern was the editor and publisher of zn online website titled “The Stem Fact 11. “The Stern Facts” is accessible worldwide, According to its website, “The Stern Facts” isa publisher of “investigative news journalism” and “fact based political reports.” 12. Stern reviews, edits, approves, and assists in the creation of the articles published on “The Stern Facts,” including the article that is the subject of this lawsuit. Many of the stories published on “The Stern Facts” are also authored by Stern. Stem, in his capacity 1s editor and publisher of “The Stern Facts,” also pays and collaborates with other self styled “investigative journalists,” including Patrick Simpson, the author ofthe article13 14. 15, that is the subject of this lawsuit. Simpson is also listed on the website as a co-editor of “The Stern Facts,” along with Stern, Upon information and belief, Stern also assists with and/or contributes to the investigations that give cise to the articles that appear on the website, including the article that is the subject of this lawsuit General Allegations On March 14, 2019, Stern, in his capacity es the editor and publisher of “The Stem Fects,” published an article on “The Stem Facts” titled “Under Trump, Witness Protection has been infiltrated by the Russian Mafie” (“March 14 Article"). A copy of the article is attached hereto as Exhibit A. ‘The March 14 Article contained numerous false and defamatory statements about ‘Monarch Air and Gitman, most of which are defamatory per se. Most notably, the anicie falsely and sensationally accused Gitman and Monarch Air of being “Russian Mobsters,” even though they have never been charged with a single erime and there is no evidence that they committed one. The article further falsely asserts that “judges in multiple states” have stated that Monarch Airis “allegedly a Russian Mob front,” even though no judge has ever made sucha finding, let alone made such a statement. In addition, the article claims thet Gitman and Monare Airave “infiltrated” the Department of Justice, falsely implying that they obtained access to the witness protection program, In fact, Monarch Air morely performed a contract which they obtained through competitive bidding to provide air transportation services for the Department of Justice no different than any airline.18, 19, ‘The March 14 Article also states that Monarch Air abtained its contract with the federal government under the Trump administration, falsely implying that Monarch Airhad a connection with Donald Trump. In fact, Monarch Air was approved as a vendor by the federal government to perform air charter services work for any federal agency though the General Services Administration, including the Department of Justice, three years before President Trump was ever elected to the presidenes In addition to these outrageous and incendiary claims, none of which he attempted to verify with Gitman or Monarch, the March 14 Article contained the following false and defamatory statements: a, Mr. Gitman and Monareh Air ate part of the “Russian Matia”; b. “[UJudges in multiple states” have found that Monarch Air is a “front” for the Russian mob; c. The witness protection program has been “infiltrated” by Monarch Air, ‘Why would the Trump Administrations [sic] Department of Justice allow @ company that operates as a front for the Russian mab anywhere near the sacred halls of Witness Protection, not once, but twice? What was going on in June 2017 and January 2018 that warranted these contracts?”; “The only reason these people have not ended up in prison is that is seems like law enforcement is too busy to communicate crimes across stats Lines.”; f Monarch Air has “ties” with members of the “Russian Mafia” who used Monarch Air “to funnel money and drugs on behalf of the Russian Matia.”; g. “Sources have placed Michael Cohen in the same world as Jacob Gitman on multiple occasions as well, There are pretty significant indirect ties between the‘two, but no smoking gun as of yet, These aforementioned crimes mentioned above would send anyone to joil.”; h, “Michael Kocharoy is yet another tie from Gitman to Trump. He is an owner of two Trump Tower Panama Properties, and is also a registered agent for one of Jacob Gitman’s companies. Kocherov's business partner Alexandre Ventura ‘Nogueira was the primary broker for the Panama Project and is now a convicted felon.”; i, “Along came the Gitman Family, Jacob Gitman, though a Brazilian Investment Company ‘Prudent Investimentes’ purchased 200 million in the fake debt portfolios, while allowing Hylan to continue managing the portfolio.”; J. “These aforementioned crimes mentioned above [sic] would send anyone to jail Certainly, the Fake Debt scheme harmed more people then Hollywood Celebrities wasting money to get their kids into reputable colleges, but this happened because authorities across the country fail to share notes and lack the manpower to do the rescarch needed to find the crimes.”; and k. “The very fact that Monarch Air was able to sign two major Witness Security contracts with the DOJ while being tied to the Russian Mob is a story that should have been told months ago. My only hope is that somebody important in the ‘Mueller investigation reads this article and acts appropriately.” 20, Stern also authored and/or co-authored the article's headline, Under Trump, Witness Protection has been infiltrated by the Russian Mafia,” which was also false and defamatory.CLAIMS OF MONARCH AIR COUNT I - DEFAMATION PER SE Plaintiffs reallege and incorporate by reference the allegations in paragraphs 1 - 20, and all subparts, 21. On or about March 14, 2019, Stem posted, 2s Editor, the March 14 Article which contained mumerans statements that were false and defamatory and/or defamatory per se, as more fully described in paragraphs 15-20, ineluding all subparts. 22, The aforementioned false and defamatory statements were of and concerning Monarch Air and published to third parties. 23. The false and defamatory statements were defamatory per se because they charged Monarch Air committed a crime and/or tended to subject Monarch Air to hatred, distrust, ridicule, contempt, or disgrace, and/or tended to injure Monarch Air in its profession. 24, Stem published the March 14 Article and the statements contained therein knowing they were false or with reckless disregard for their truth. 25. Asa direct and proximate cause of the aforementioned defamatory statements, Monarch ‘Air has suffered and will continue to suffer damage to its reputation, as well as loss of income, diminution in value of its shares, loss of goodwill, and other economic losses. WHEREFORE, Plaintiff MONARCH AIR GROUP, LLC demands judgment in its favor, including compensatory damages, costs, interest, and other relief this Court deems just and proper. Monarch Air reserves its right to amend its complaint to seek punitive damages upon the making of an evidentiary proffer.CLAIMS OF JACOB GITMAN COUNT II - DEFAMATION PER SE Plaintiffs reallege and incorporate by reference the allegations in paragraphs 1 ~20, and all subparts 26. On or about March 14, 2019, Stem posted, as Editor, the March 14 Article which contained numerous statements that were false and defamatory and/or defamstory per se, as more fully described in paragraphs 15-20, including subparts. 27. The aforementioned false and defamatory statements were of and concerning Gitman and published to third parties. 28, The false and defamatory statements were defamatory per se because they charged Gitman committed a crime and/or, tended to subject Gitman to hatred, distrust, ridicule, contempt, or disgrace, and/or tended to injure Gitman in his profession. 29. Stern published the March 14 Article and the statements contained therein knowing they were false or with reckless disregard for their truth 30, Asa direct and proximate cause of the aforementioned defamatory statements, Gitman has suffered and will continue to suffer damage to his personal and professional reputation, emotional distress, loss of income and future loss of earning capacity. WHEREFORE, Plointiff demand judgment in his favor, including compensatory damages, costs, interest and other relief this Court deoms just and proper. Gitman reserves its right to amend its complaint to seck punitive damages upon the making of aa evidentiary proffer. DEMAND FOR JURY TRIAL Plainvifis demand trial by jury on all issues so triable.Respectfully submitted, THE LAW OFFICE OF DAVID H. POLLACK, LLC 2600 S. Douglas Road Ste 1007 Coral Gables, FL 33134 Tel.No: (305) 372-5900 Fax No G05) 372-5904 BY: _/s'David H. Pollack, DAVID H. POLLACK Fla, Bar No. 0955840 MATTHEW STREET Fla. Bar No, 10139451082020 Under Trump, Winess Pretotion has beoninfivatud by tn Fuceian Mafia | by Patek Simpaon_| The lara Faste © Check your US. voter registration status or register to vote here. Under Trump, Witness Protection has been infiltrated by the Russian Mafia Patrick Simpso 4723) Mar 14,2019 -9 min read WO ots Ml UKRAINE 2016 Ler a DIALOGUE AT MANOR COLLEGE ‘Authors Note: Due to an ongoing court casein Broward County Florida, allegations about about Russian-American Businessman Edi Gurlovsky were removed due to the status of the case. In October 2017, Curt Weldon joined the board of advisors for Monarch Air Group, which had just completed its first contract with the Justice Department's Witness hite/inesterfacsscamfunde.umg-winess-protesion-hes-beon inflratad-y the-ressian-maf-Eo42511005 wesonnco0 Under Trump, Wines Foteton has toon nfraod by th Ruesan Ma by Pik Simon |The Stam ecto Security Division. According to US attorney Joshua Naftalis, and judges in multiple states, Monarch Airis allegedly a Russian mob front. Why would the Trump Administrations Department of Justice allow a company that operates asa front for the Russian mob anywhere near the sacred halls of Witness Protection, not once, but twice? What was going on in June 2017 and January 2018 that warranted these contracts? Details Contract on Gov Tribe between ‘The only reason these people have not ended up in prison is that it seems like law enforcement is too busy to communicate crimes across state lines. Curt Weldon is the author of the backchannel Ukrainian Peace Plan that Michael Cohen and Andrey Artemenko worked on and delivered to President Trump's now-convicted National Security Advisor Michael Flynn. Sen. Dianne Feinstein (D-CA) sent inquiry letters to Cohen and Cambridge Analytica requesting correspondence with Weldon at the end of 2017, and some refer to him as, Putin’s first congressman. He is arguably the most significant tie between politicians in the United States and Putin's Government, and given his belief that he was betrayed by his own government, it may not be hard to guess where he stands. hip: /thostomfacts comlunder-tump-winess-rtecin-has-beer inflated by-he-tssan-mate-feo4825110e5 2a0182020 Undor Trump, Wines Frotction has ben inated by the Russian Mafa | by Patrik Simpson |The Stem Facts compa Monarch is significant because of the ties it represents. In USA vs. Alimzon Tokhtakhounoy, Attorney Joshua Naftalis made a matter of fact statement that the defendants were using Monarch to funnel money and drugs on behalf of the Russian Mafia. In this case, he was talking about the defendants Vadim Trincher and Anatoly Golubchik, who were in charge of the huge racketeering ring being run of out Trump Tower. sia10802120 Under Trump, Winass Proteton has toon infrated bythe Ruslan Mafia |by Patick Simoson | The Stem Facts The Trincher family While Trincher and Golubchik were running what Attorney Joshua Naftalis referred to as “ one of the biggest bookmaking operations in the world.” in New York, they were also running Monarch Air, Shuttleliner Cab of Ocala, Suncoast Air Cargo, and Skyway International out of Jacob Gitman’s Kane Concourse Suite Address in Miami. Andrey Artemenko himself runs a defense contracting company, Ancovi International, out of the same Kane Concourse address. One of the Managers of “Ancovi’ is a company named Global Assets LLG — which was founded by Artemenko AND Vadim Netscheret. Netscheret is another tie to Michael Cohen as Cohen had to go to court to discuss why he gave the alleged mobster check for $350,000. Monarch is just one of the hundreds of interconnected companies registered out of the Same suite at the same office building in the Bay Harbor Harbor Islands, connected to one family lead by one Jacob Gitman, Natasha Bertrand reported last year that the Ukrainian Peace Deal was able to happen because Artemenko was introduced to Felix Sater through a mutual friend named Yan Aronov. Yan is a registered agent at one of these many companies. FAKE DEBT PORTFOLIOS AND THE RUSSIAN MOB In 2017, Zeke Faux wrote an explosive Pulitzer Prize worthy article for Bloomberg about atopic I had no idea existed; Phantom Debt Portfolios. As the story goes, scammers bought a whole load of personal information on the internet and packaged the information as loans that needed to be collected on. These portfolios get sold over and over and over again to hide the lizbility. hepssthestemfacts.comfundersrunp-winess-srotection-tas-beer-inilvetedby he usson-mala-Bo4825H1 035, 4n2soreaozo Under Tramp Wiese Proton hat bean fated byte Rein Ma | by Pack Simpeon| The Sem Fost However, they didn’t count on the tenacity of a small town guy named Andrew. After one of the debt collectors threatened to rape his wife in a debt collection call, he transformed into what can only be described as the modern-day equivalent of the Marvel Anti-Hiero, the Punisher. They threatened his family so he vowed never to stop searching. He kept moving up the chain, taking down the payday loan industry, bit by bit when he found the supposed ring leader — Joel Tucker (and his brother Scott.) ‘Very interesting connections existed from the outset of my reporting about the Joel ‘Tucker case. For instance, Pay Day Loan Financier Del Kimball had to declare bankruptcy because Joel Tucker and his allies worked with Russian Payday loan magnate and son of the oligarch Igor Provkin to extort Kimball out of millions of dollars. In the Bankruptcy filings themselves, Kimball revealed that his business partner in Russia — Notorious Russian criminal Oleg Boyko was harassing him for payment of the monies Tucker stole and that he felt afraid for his life. Interestingly enough, Boyko was using Roman Abramovich as his intermediary. Boiko owned a condo in Trump tower from 1994 until he sold it to Gitman’s business partner and convicted criminal Vadim Trincher in 2009. Finally, in December 2016, the FTC sued Tucker for selling phantom debt. According to the regulator, everything had happened pretty much as Therrien imagined: Tucker had invented more than 7.7 million fake debts and sold them to a series of middlemen for $4.2 million. This September, a judge ruled for the agency, ordering Tucker to pay back that money on top of the $30 million he already owed. Scott was convicted on 14 charges and sent to Prison. Six months after Bloomberg Article published the story, Joel was indicted on 15 counts and is due to in court later this year. nips thoserfacs com/undertnimp-winees-pcestion has-been infirated-by te-rsslan-nafefS4005t10a5 2.‘ove2020 Under rump, Wines Protdtion has beoninfitated by the Russian Mal | by Patek Simpson | The Som Facto Andrew, like Frank Castle, had finally caught his man. Orhad he? This is where it gets truly fascinating On 8/27/18, the Attorney General of the State of New York filed a lawsuit against Hylan Asset Management and other related companies concerning the Phantom Debts. | i 1 ‘The Web connecting Gitman and his associates to the Fake Debt Portfolios and Private Airlines Andrew Shaevel, a well-respected businessman from Buffalo was one of the principles involved in the Phantom Debt scheme. He ultimately claimed he was unaware of the fake debts being sold by his company, but email evidence showed that he was aware of it and did not stop buying up the fake debts. ntge/theeterfacis com/indartnmp-winess-postonhes-baensnfiratad-by-the-rssian-mafe-f604825110n5 en‘1082020 Under Temp, Winass Protection has bear infirlad bythe Russian Mafia by Patek Simpson | Tha Som Facts allowing Hylan to continue managing the portfolio. Bizapedia lists Prudent as being registered in 2014, by Jacob Gitman, LGN International, and Roman Faizulin. Despite being registered by Gitman, Prudent was being run in public by Dennis Klemming. He has no connection to the company on any registrations forms that I've seen, According to Open Corporates, the directors of Prudent area Brazillian man, Edson Luis Paulino, and what appears to be a “KSB International.” KSB International is a Maltese company, formed six months before Prudent invested in the fake debt portfolios. in April 2016, KSB itself entered into an agreement to purchase part of the Phantom debt portfolios from Hylan. Roman Faizulin was the point of contact. LGN International, a registered agent for Prudent Investmentos, filed a lawsuit on behalf of KSB International, in 2017. The Lawsuit alleges that KSB International and Mordechey Shahak along with other Russian Businessmen allegedly reached an agreement to form KSB Holdings and work together to collect on the 60 million of phantom debts KSB had purchased from Hylan. The Assets for KSB Holdings were transferred to a new company, MBG Financial, run by one of the Defendents in September 2016. This includes the aforementioned fake debts. This Racketeering Case is still active in Broward County hipesthestemtacts.comlundorsrum-viness-protaction-tas-deor-inreted by ho-usslan-tia- 6804802511005, ane‘012020 Under Trunp, Winess Protection hes been infratad bythe Russian Maa | by Patrick Simeson| Th Stor Facts Disbarred former lawyer Jon Purzihansky was his Partner in the venture. In 2006, Purzihansky, himself a Russian born American Citizen was found guilty of helping a Russian mobster obtain a VISA on false pretenses. Hylan was accused of purchasing the Phantom Debt Portfolios through a Chicago area intermediary, Stark Law. Attorney Dennis Vacco is the lawyer Purzihansky and Shaevel hired to defend them. He is the former New York Attorney General, serving while Giuliani was Mayor of New York City. ‘Vacco is well known in New York circles for becoming the lobbyist for Waste Management months after settling an anti-Trust lawsuit against them. Michael Caputo also hired Vacco as his attorney in the “Trump Russia” scandal Along came the Gitman Family. Jacob Gitman, through a Brazilian Investment Company “Prudent Investimentos” purchased 200 million in the fake debt portfolios, while npethestorfacs com/under-tump-winess-potestonhes-baen nfirateby-to-rusian-nafe (60482511005 me.0182020 Under Tromp, Winess Protection has baeninitratad by the 3p Mafa | by tick Simpson | Th Stom Facts Living in a world where two debt collectors can sue each other over debts that don’t even exist is mind-boggling when you stop and think about it. Kocharov Partner Alexander Nogueira with the Trump family, Michael Kocharov is yet another tie from Gitman to ‘Trump. He is an owner of two Trump ‘Tower Panama Properties, and also a registered agent for one of Jacob Gitman's companies. Kocharov’s business partner Alexandre Ventura Nogueira was the primary broker for the Panama Project and is now a convicted felon. "SIPHONING OFF MILLIONS OF DOLLARS FOR PERSONAL PROJECTS” hitpavthosterfactsconundar-tum-winess-retection-has-toorinfltaiod by the-tssan-aia-Eo4825!1005, one.Under Trump, Winess Protexton has beeninftrates by te Russian Mata | by Pick Simpson |The Stem Facts Jacob and his son David are embroiled in a contract dispute being played out in the Miami County court system. The Plaintiffs allege that the Gitman’s siphoned 11 million dollars off of the contract they signed in 2012 for personal use through one of his companies, Basta Holdings (now known as Blackpoll Fleet International.) Aside from this, the former Basta CFO, Andrew Logullo had his FINRA membership suspended due to corruption. This case connects a lot of dots the federal government should have connected long ago. Jacob, David, and the Gitman family businesses have attempted to turn the case into one that blames another party. They started the case by convincing everyone around them that Boruch Freedman was the real decision maker and that they were unaware of the. situation and just following directions. Evidence Freedman’s lawyers collected throughout the case revealed that Freedman supposedly wasn'tan officer in the company involved, nor did he fill out any of the bank paperwork. The Plaintiffs were able to convince the court to request his arrest with false information, but he had already fled the country due to receiving threats from the plaintiffs. During the case, it was revealed that the Plaintiffs “ER. Troika” are actually the mobsters known as the Khazakh trio. The Trio — Patokh Chodiey, Alijan Ibragimov and Alexander Machkevich — built their fortunes in the mining, oil and gas industry. ‘They've partnered with the Bayrock Group on developing Trump SoHo in the past and share extensive ties to Felix Sater. ips testerfacts com/undoctump nese protectin has toon infeed by the-tsan mae Eo4825H1005 sonsorez020 Under Tanp, WinessPetecon hes bon nfl by he Ruslan Ma | by Patek Smpson| Tho Stom Fast While this court case was ongoing, two of Jacobs children (Larry and David) were being served eviction notices for breaching their rental contracts. Interestingly enough, at least one of the brothers used their mother, Alisa, as a real estate agent. Alisa works for Sib Realty, the real estate agency that almost exclusively deals with Trump properties in Florida Sources have placed Michael Cohen in the same world as Jacob Gitman on multiple occasions as well. There are pretty significant indirect ties between the two, but no smoking gua as of yet. ‘These aforementioned crimes mentioned above would send anyone to jail. Certainly, the Fake Debt scheme harmed more people than Hollywood Gelebrities wasting money to get their kids into reputable colleges, but this happened because authorities across the country fail to share notes and lack the manpower to do the research needed to find the crimes. The very fact that Monarch Air was able to sign two major Witness Security contracts with the DOJ while being tied to the Russian Mob is a story that should have been told months ago. My only hope is that somebody important in the Mueller investigation reads this article and acts appropriately. ‘Thanks to Grant Stem, htpathasterfacts omJundar-tump-winess-otesion-hes-boorinfiraled-y-te-rusian-mafe-fed62511085, mre