Chrisley Defamation Case

Case 3:21-cv-00105-TCB Document 1 Filed 07/09/21 Page 1 of 38
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF GEORGIA
NEWNAN DIVISION
AMY DOHERTY-HEINZE, Case No.
Plaintiff,
VERIFIED COMPLAINT FOR
v. DEFAMATION
MICHAEL T. CHRISLEY,
DEMAND FOR JURY TRIAL
Defendant.
COMES NOW Plaintiff AMY DOHERTY-HEINZE (“Plaintiff”), and states
her Verified Complaint for Defamation against Defendant MICHAEL T.
CHRISLEY (“Chrisley”), as follows:
PARTIES
1. Plaintiff Doherty-Heinze is an individual resident of the State of
Georgia, who resides in Coweta County, Georgia.
2. Defendant Chrisley is an individual resident of the State of Tennessee,
who, upon information and belief, resides and can be served at 9273 Exton Lane,
Brentwood, Williamson County, Tennessee, 37027.
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JURISDICTION AND VENUE
3. There exists complete diversity of citizenship between Plaintiff and
Defendant.
4. The amount in controversy exceeds $75,000, exclusive of interest,
costs, and attorneys’ fees.
5. Therefore, this Court has subject matter jurisdiction over this matter
pursuant to 28 U.S.C. § 1332(a)(1).
6. Venue is proper in the United States District Court for the Northern
District of Georgia, Newnan Division, pursuant to 28 U.S.C. §§ 1391(b)-(c)
because Plaintiff Doherty-Heinze resides in this judicial district.
7. This Court has personal jurisdiction over Defendant Chrisley pursuant
to O.C.G.A. § 9-10-91 because he transacts business within the State of Georgia
sufficient to anticipate being haled into court in the State of Georgia.
8. This Court further has personal jurisdiction over Defendant Chrisley
because he has filed a lawsuit in the Northern District of Georgia, Atlanta Division,
relating to the same subject matter as his defamation of Plaintiff Doherty-Heinze.
because his defamation of Plaintiff has been directed specifically toward the State
of Georgia, including false and defamatory accusations used by Defendant in an
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explicit effort to have Plaintiff’s certification by the Georgia Peace Officer
Standards and Training Council (“POST”) revoked.
because his defamation of Plaintiff has been directed specifically toward the State
of Georgia, including innumerable statements against the Georgia Department of
Revenue, the Georgia Attorney General, and the entire Georgia legal system.
11. Sufficient contacts exist with respect to Defendant, his business, and
the claims at issue in this case to satisfy the requirements of due process as to
Defendant.
FACTUAL ALLEGATIONS
12. Defendant Chrisley hosts a podcast and is a social media “personality”
who had approximately 2.3 million followers on Instagram as of March 2020.
13. Plaintiff was previously employed by the Georgia Department of
Revenue (the “GDOR”) as an investigator in the Office of Special Investigations.
14. Beginning in 2017, the GDOR undertook an investigation of
Defendant Chrisley and his wife, Julie Chrisley.
15. Defendant Chrisley then began a social media campaign against the
GDOR and certain of its employees, contending that the investigation was illegal
and improperly motivated.
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16. In October 2019, Defendant Chrisley filed a lawsuit against Joshua
Waites, who was the Director of the GDOR’s Office of Special Investigations at
the time of the investigation into the Chrisleys. See Chrisley v. Waites, Case No.
1:19-cv-04610-LMM, United States District Court for the Northern District of
Georgia (the “Waites Litigation”).
17. Aside from performing one discrete task, Plaintiff was not involved in
the investigation of Defendant Chrisley.
18. Nevertheless, in early 2020, Defendant Chrisley also began attacking
Plaintiff and accusing her of a multitude of crimes and wrongdoing.
19. Defendant Chrisley has not asserted any claims against Plaintiff in the
Waites Litigation or otherwise.
20. All of Defendant Chrisley’s accusations of wrongdoing against
Plaintiff are false.
21. Plaintiff served a retraction demand on Defendant Chrisley on July 2,
2021 (the “Retraction Demand”), a true and correct copy of which is attached
hereto as Exhibit A.
22. In response, Defendant Chrisley failed and refused to retract of any of
his false and defamatory accusations against Plaintiff.
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STATUTE OF LIMITATIONS
23. The false and defamatory accusations made by Defendant that form
the basis of this Complaint occurred between March 9, 2020 and July 7, 2020.
24. On March 14, 2020, the Supreme Court of Georgia issued an Order
declaring a Statewide Judicial Emergency pursuant to O.C.G.A. § 38-3-62. See
https://www.gasupreme.us/court-information/court_corona_info/ (Original Order).
25. Pursuant to the Statewide Judicial Emergency Order and pursuant to
its authority under O.C.G.A. § 38-3-62, the Georgia Supreme Court as of March
14, 2020, declared that it “hereby suspends, tolls, extends, and otherwise grants
relief from any deadlines or other time schedules or filing requirements imposed
by otherwise applicable statutes, rules, regulations, or court orders . . . including
but not limited to any: (1) statute of limitation. . . .”
26. On April 6, 2020, the Georgia Supreme Court issued Guidance on
Tolling Statutes of Limitation Under the Chief Justice’s Order Declaring Statewide
Judicial Emergency, which provides that:
Questions have arisen about how the tolling provision in the Chief
Justice’s Order of March 14, 2020, Declaring Statewide Judicial
Emergency applies to statutes of limitation. Simply put, the tolling
of a statute of limitation suspends the running of the period of
limitation, but it does not reset the period of limitation. If the period
of limitation for a particular cause of action commenced prior to
March 14, 2020 – that is, if the “clock” has started to run before
the entry of the Chief Justice’s order – the running of the period
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of limitations was suspended on March 14, and the running of the

period will resume when the tolling provision of the March 14
declaration has expired or is otherwise terminated. If the event that
triggers the running of a period of limitation occurred on or after
March 14 – that is, if the “clock” had not started to run before a
statewide judicial emergency was declared – the period of
limitation will not begin to run until the tolling provision of the
March 14 declaration has expired or is otherwise terminated. In
either circumstance, whatever time remained in the period of
limitation as of March 14 will still remain when the tolling provision
of the March 14 declaration has expired or is otherwise terminated.
https://www.gasupreme.us/court-information/court_corona_info/ (Guidance for
Tolling Statutes of Limitation (April 6, 2020) (emphasis added)).
27. The Statewide Judicial Emergency Order was extended fifteen (15)
times. See https://www.gasupreme.us/court-information/court_corona_info/.
28. In the Fourth Order Extending Declaration of Statewide Judicial
Emergency dated July 10, 2020, the Supreme Court of Georgia reimposed certain
deadlines on litigants and specifically indicated that “[t]he 122 days between
March 14 and July 14, 2020, or any portion of that period in which a statute of
limitation would have run, shall be excluded from the calculation of that statute of
limitation.” See https://www.gasupreme.us/court-information/court_corona_info/
(Fourth Extension Order at II.A(10)).
29. Subsequent extensions of the Statewide Judicial Emergency Order
included the same language as Section II.A(10) of the Fourth Order Extending
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Declaration of Statewide Judicial Emergency. See
https://www.gasupreme.us/court-information/court_corona_info/.
30. As a result of the Statewide Judicial Emergency declared by the
Supreme Court of Georgia, the statute of limitations for the defamation claims set
forth in this Complaint were tolled.
31. Certain of the false and defamatory statements set forth herein were
made by Defendant Chrisley on March 9, 10, and 11, 2020.
32. As a result of the Statewide Judicial Emergency, the statute of
limitations for the March 2020 defamation claims “was suspended on March 14”
and “the running of the period [] resume[d]” when the Statewide Judicial
Emergency was lifted on July 14, 2020. Thus, the statute of limitations for those
claims expires on July 9, 10, and 11, 2021.
33. Certain of the false and defamatory statements set forth herein were
made by Defendant Chrisley on April 8, May 20 and 28, June 3, and July 6 and 7,
2020.
34. As a result of the Statewide Judicial Emergency, the statute of
limitations for the claims based on defamation in April, May, June, and July 2020
did “not begin to run until the tolling provision of the March 14 declaration []
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expired” on July 14, 2020. Thus, the statute of limitations for those claims expires
on July 14, 2021.
35. As a result of the Statewide Judicial Emergency that suspended the
running of the statute of limitations for 122 days between March 14 and July 14,
2020, all claims asserted in this Complaint are timely.
CAUSES OF ACTION
COUNT ONE:
DEFAMATION BY LIBEL
36. Plaintiff incorporates by reference paragraphs 1 through 35 of this
Complaint as if fully stated herein.
37. On March 9, 2020, Defendant Chrisley published the following post
on his Instagram account that includes false and defamatory accusations against
Plaintiff:
https://www.instagram.com/p/B9h4_WKHsPc/ (last visited July 9, 2021).
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38. Plaintiff’s sister, posting initially as @jamie_thehippie and
subsequently as jamieel_84, quickly responded to Defendant Chrisley’s post to let
him know that his accusations against Plaintiff were false:
This post by Plaintiff’s sister was quickly deleted from Defendant Chrisley’s
Instagram account.
39. Other Disney employees also posted comments that supported the
comment posted by Plaintiff’s sister, but those posts also were quickly deleted
from Defendant Chrisley’s Instagram account.
40. Plaintiff’s sister again responded to Defendant Chrisley’s post
pointing out that his accusations against Plaintiff were false and asking why he had
deleted her initial post:
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https://www.instagram.com/p/B9h4_WKHsPc/ (Comments) (last visited July 9,
2021).
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41. Despite being provided almost immediately with information that his
accusations against Plaintiff were wrong, Defendant Chrisley published false and
defamatory accusations in the comments to his March 9 post in response to
questions from his readers, and he advised his readers that he had undisclosed
evidence to support his accusations:
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These false and defamatory comments by Defendant Chrisley to his March 9 post,
which are true and correct screenshots, were also quickly deleted.
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42. On March 10 and 11, Defendant Chrisley continued to publish false
and defamatory accusations against Plaintiff in the comments to his March 9 post,
including falsely contending that he had undisclosed “receipts” to support his
accusations against Plaintiff that would soon be disclosed (but never were because
they do not exist):
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https://www.instagram.com/p/B9h4_WKHsPc/ (Comments) (last visited July 9,
2021).
43. As was reasonably foreseeable and to be expected, including because
of the media coverage surrounding Defendant Chrisley and the prominence of his
platform, Defendant Chrisley’s false and defamatory accusations against Plaintiff
relating to her vacation were republished by the media, for example, in the March
10, 2020, article titled “Todd Chrisley Slams Georgia Dept Of Revenue – Alleges
Disney Vacation At Taxpayers’ Expense,” available at
https://www.tvshowsace.com/2020/03/10/todd-chrisley-slams-georgia-dept-of-
revenue-alleges-disney-vacation-at-taxpayers-expense/ (last visited July 2, 2021).
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44. On May 28, 2020, Defendant Chrisley published the following post on
his Instagram account, which includes false and defamatory accusations against
Plaintiff:
https://www.instagram.com/p/CAv5Zq2nERi/ (last visited July 9, 2021).
45. On July 6, 2020, Defendant Chrisley published the following post on
his Facebook account that includes false and defamatory accusations against
Plaintiff as well as including her photograph:
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https://www.facebook.com/permalink.php?story_fbid=2921608827948420&id=51
3409295435064 (last visited July 9, 2021).
46. In a comment to his July 6, 2020 Facebook post in the screenshot
above, Defendant Chrisley published the following false and defamatory
statements about Plaintiff, indicating that he had undisclosed “proof” to support his
accusations against Plaintiff and that this “proof” would be disclosed in a
forthcoming lawsuit against Plaintiff – which lawsuit was never filed:
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47. On July 7, 2020, Defendant Chrisley published the following post on
his Facebook account, which includes false and defamatory accusations against
Plaintiff as well as posting another photograph of Plaintiff:
https://www.facebook.com/permalink.php?story_fbid=2924179607691342&id=51
3409295435064 (last visited July 9, 2021).
48. Defendant Chrisley also published the following undated post on his
tubefollow.com account, which includes false and defamatory accusations against
Plaintiff:
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This post apparently has been removed from the internet as of the date of filing this
Complaint but was available as of July 2, 2021 (the date of the above screenshot)
at https://i1.wp.com/cdn-
9.tubefollow.com/photos/l/2348028692109556619/toddchrisley-folks-please-take-
the-time-to-contact-ga-post-peace-officers-2348028692109556619.jpg&dl=1.
49. The posts included in the screenshots above are examples of some of
the social media posts in which Defendant Chrisley published false and defamatory
accusations against Plaintiff.
50. Throughout his social media posts on Instagram, Facebook, and other
sites, Defendant Chrisley has published the following written false and defamatory
statements and gists about Plaintiff (collectively, the “Libelous Statements”):
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a) “Amy Doherty-Heinze . . . putting those taxpayer dollars at work

at the expense of the Georgia Taxpayers [sic].”
b) “Corrupt ass sister.”
c) “Did your sister Amy Fail [sic] multiple polygraph test [sic]?”
d) “How did Amy get her position with the DOR today when so
many other candidates exceeded her lack of qualifications?”
e) “Your sister has her job because of her relationship with Josh
Waites.”
f) “Did your sister use DOR employees to move her on taxpayer

time?”
g) “Why does your sister have a brand new Kia? At taxpayer

expense?”
h) “What participation did Amy have with misappropriation of fund

while Josh was there?
i) “[Y]ou keep drinking that lieade [sic] Amy is serving . . . .”
j) “[D]id your sister commit a felony and disclose tax information

to you about me?”
k) “She was trained by Josh so I can understand how Amy would

think that she could get away with This [sic].”
l) “it wasn’t their paychecks paying for it, it was taxpayer dollars
from a slush fund. . . .”
m) Asserting that Ms. Doherty-Heinze was “vacationing at the tax

payers’ expense”
n) “I have the records to prove it. . . .”
o) “the forfeiture fund paid their way and they are suppose [sic] to
be in Training, not out partying. . . .”
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p) “ask your sister why she had employees Brian Crisp, Martice
(state employees) help her move to her new home in Marietta
while on the taxpayers dime?’”
q) “why don’t you ask Andy about the failed polygraphs”
r) “Ask about picking out her own car that Josh bought through the
slush fund”
s) “the Georgia Dept of Revenue and their employees that have

committed multiple felonies : . . . 5) Amy Doherty Heinz [sic]”
t) “ask for a full investigation of this woman ‘Amy Doherty

Heinze’ . . . she can go to any other state job and do the same
criminal acts over and over again . . . get rid of any police officer
that has abused their power and badge for their own ego or to line
their pockets”
u) “Amy Doherty Heinz [sic] (3rd photo) who has committed crimes
against our family . . . she’s allowed to now go to another state
agency and commit the same crimes there that she committed at
the DOR. . . .”
v) “These police officers like Amy Doherty Heinz [sic] . . . have

committed crimes and should be punished for them like anyone
else who breaches their oath, and it’s my goal to make this
happen and shed light on those that refuse to do it.”
w) “you have these ass clowns who use their badge to lie, cheat,
steal, and bully people and it’s all because they want power over
the people. . . .”
x) “the OSI division that started this witch hunt against our family
and led by law enforce ER [sic] officers . . . Amy Doherty Heinz
[sic] has been stripped down. . . .”
y) “Email- [XXXXX]@gapost.org if you would like to file a

complaint against . . . Amy Doherty for illegal activities.”
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z) “This police officer helped Joshua Karl Waites and Katie Colvin
Vancil, Scott Santilli and others to try and destroy our family, she
committed crimes and abused the federal GCIC database to help
create a false story about us and all for publicity, well now, she’s
getting the publicity that she wanted.”
aa) The gist that Plaintiff misappropriated taxpayer funds.
bb) The gist that Plaintiff is professionally unqualified.
cc) The gist that Plaintiff obtained her job with the DOR through
nefarious means.
dd) The gist that Plaintiff does not deserve to maintain her Georgia
POST certification as a law enforcement officer.
ee) The gist that Plaintiff is dishonest.
ff) The gist that Plaintiff is professionally corrupt.
gg) The gist that Plaintiff has committed crimes.
51. The Libelous Statements are of and concerning Plaintiff.
52. The Libelous Statements are false.
53. The Libelous Statements are defamatory.
54. Defendant Chrisley published the Libelous Statements negligently and
with actual malice, i.e., knowledge that the Libelous Statements were false or with
reckless disregard for their falsity.
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55. Defendant Chrisley knew that the Libelous Statements were false,
including because he fabricated information to support his false and defamatory
56. Defendant Chrisley knew or should have known that the Libelous
Statements were false, including because publicly available records contradicted
Defendant Chrisley’s false and defamatory accusations about Plaintiff.
57. Defendant Chrisley negligently and recklessly published the Libelous
Statements, including by failing to conduct a reasonable investigation prior to
publication by, without limitation, failing to consider or knowingly disregarding
evidence that was available to him.
Statements, including by relying on unreliable sources.
Statements, including by relying on sources with a known bias against Plaintiff.
60. Defendant Chrisley negligently and recklessly published the
Defamatory Statements by burying his head in the sand, i.e., engaging in a
purposeful avoidance of the truth, by, without limitation, ignoring publicly
available records, failing to contact Plaintiff prior to publication to confirm the
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truth or falsity of the Libelous Statements, and ignoring accurate information
conveyed by Plaintiff’s family member and third parties to Defendant Chrisley.
61. The Libelous Statements constitute defamation per se, for which
compensatory damages are presumed as a matter of law.
62. Plaintiff has suffered actual damages as a direct result of the Libelous
Statements about her, including to her reputation.
63. Plaintiff has suffered actual damages as a direct result of the Libelous
Statements about her, including emotional and mental distress.
64. Plaintiff is entitled to an award of compensatory damages against
Defendant Chrisley in an amount to be proven at trial.
65. Defendant Chrisley published the Libelous Statements with actual
malice and common law malice, thereby entitling Plaintiff to an award of punitive
damages.
66. Defendant Chrisley’s conduct in publishing the Libelous Statements
was outrageous and willful, demonstrating that entire want of care that raises a
conscious indifference to consequences.
67. Plaintiff is entitled to an award of punitive damages against Defendant
Chrisley.
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68. Defendant Chrisley has acted in bad faith, has been stubbornly
litigious, and has caused Plaintiff unnecessary trouble and expense by making and
refusing to retract his Libelous Statements, and Plaintiff is entitled to recovery of
attorneys’ fees pursuant to O.C.G.A. § 13-6-11.
COUNT TWO:
DEFAMATION BY SLANDER
69. Plaintiffs incorporate by reference paragraphs 1 through 35 of this
Complaint as if fully stated herein.
70. Defendant Chrisley has a podcast titled “Chrisley Confessions” which
is publicly available in numerous locations, including Apple Podcasts, Spotify,
iHeartRadio, Audible, PodcastOne, and other popular streaming services.
71. Defendant Chrisley has made numerous false and defamatory
accusations against Plaintiff during his podcasts.
72. During Episode 77 of “Chrisley Confessions,” which was released on
March 11, 2020, Defendant Chrisley made the following verbal false and
defamatory statements and gists about Plaintiff:
a) “Amy, listen, you already know that you’re next, surely you know
that I have the information about your lack of qualifications to be
in the position that you’re in, surely you know that I know how
you got there.”
b) That when Plaintiff was at Disney World, she was “on the
taxpayer’s dime”
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c) Referring his listeners to the false and defamatory accusations in

his March 9 Instagram post and his false and defamatory
subsequent comments on that Post.
d) “When the hell was you at this conference, Amy? What did you
learn in this conference? How many hours were you there?”
e) “If I put it on my social media, you can rest your – you can bet
your ass that I’ve already got the proof, I’ve got the receipts for it,
or I wouldn’t be posting it, because I wouldn’t want to be harming
someone or their character or reputation by saying something that
wasn’t true.”
f) Advising his listeners that he has people providing “tons of

documentation” and that “we already know the answer, you’re the
only one living on the land of denial and thinking that no one’s
going to come for you.”
g) The gist that Plaintiff misappropriated taxpayer funds.
h) The gist that Plaintiff is professionally unqualified.
i) The gist that Plaintiff obtained her job with the DOR through
nefarious means.
j) The gist that Plaintiff is dishonest.
k) The gist that Plaintiff is professionally corrupt.
l) The gist that Plaintiff has committed crimes.
https://www.podcastone.com/episode/77-Pick-that-Phone-Up-Out-of-Respect-
Accountability-Belongs-to-God-and-This-is-Where-You-Are-on-Your-Walk (last
visited July 9, 2021).
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May 20, 2020, Defendant Chrisley made the following verbal false and defamatory
statements and gists about Plaintiff:
a) “You’ve got Amy Doherty who is in control of the evidence room

within the Department of Revenue and yet there’s evidence
missing. There’s items that’s been seized from taxpayers that the
Georgia Department of Revenue cannot account for. Cash, cell
phones, items taken during seizures, things like that.”
b) “Josh Waites wanted her in that position, he wanted her in charge

of the evidence room so he could continue doing his stealing and
the things that he was doing and have her to cover it up.”
c) “It’s obstruction of justice when Amy Doherty destroys documents

and lies to agencies that she didn’t do certain things that we know
that she did. I mean at the end of the day Amy Doherty-Heinze is
as guilty as Josh Waites has ever been and we’re going to bring all
of that out in court.”
https://www.podcastone.com/episode/85-Not-Valid-Expectations-Dictionary-
Definition-of-Ho-and-Heartache-Down-the-Road- (last visited July 9, 2021).
June 3, 2020, Defendant Chrisley made the following verbal false and defamatory
a) “I get to find out about, you know, Amy Doherty, and this gun
shooting that she was involved in, and how she celebrates the kill
every year.”
b) “Yeah, yeah, that’s what was told us. . . . I’m repeating what I have
been told. I’ll have you the facts next week.”
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c) “But Amy Doherty was involved while in Clayton County in a

shooting that killed a man. And every year it’s called ‘celebrate
the kill.’ Now she, folks, is working for the Department of
Revenue. So this was the story that was brought back to me.”
d) “This individual proceeds to tell me about this celebration of this

kill.”
e) “No one should be celebrating taking another human’s life. But

Amy Doherty-Heinz obviously – and I want to preface, I’m
repeating what I’ve been told, and I don’t like to repeat things that
are going to harm people if there’s no factual basis for them. I’ve
been told that there is factual basis for this, if there’s not then I
apologize, and I will retract it next week, but I’m getting all the
documentation hopefully by Friday, and I’ll fill everyone in on
that.”
f) “But you know when you have somebody like Amy Doherty-
Heinze who is sitting there committing felonies – and these are just
the felonies that we know about – and she’s still allowed to sit in
that position that she’s in right now with access to people’s
backgrounds, their histories, they have prosecuted other people in
the State of Georgia for committing these crimes, yet she is still
sitting on her job.”
g) “Now I’m going to make these things public, and I’m giving them
to the press over the course of the next few weeks so that they can
put all this stuff out there so we can figure out why the Attorney
General Chris Carr has not demanded that charges be brought
against these individuals, Amy Doherty-Hinze. . . .”
m) The gist that Plaintiff is dishonest.
n) The gist that Plaintiff is professionally corrupt.
o) The gist that Plaintiff has committed crimes.
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https://www.podcastone.com/episode/87-Were-Here-for-the-People- (last visited
July 9, 2021).
July 7, 2020, Defendant Chrisley made the following verbal false and defamatory
a) “Amy was let go, and you know, I had been pushing for that for
probably 9 months.”
b) “and she did do wrong. Amy Doherty-Heinze utilized a federal

database, GCIC, to gain information that she would not have had
without pulling it about me, Julie, and Chase. And she did this
knowing that it was wrong and knowing that she should have never
done it.”
c) “she’s applying for positions with other police departments which

will allow her to continue to have her badge, which will allow her
to keep her POST certification and allow her to go and utilize tools
that the law enforcement has at their hands for wrongdoing, which
is what she did with us. Now that’s been proven, folks.”
d) “it doesn’t change the criminal conduct that she did while
employed with the Georgia Department of Revenue.”
e) “Amy Doherty-Heinze was utilizing GCIC on her own. She was

doing it for shits and giggles just cause she’s nosy as hell and
wanted to figure out a different angle on how to take someone
down so that her name could be attached to that story.”
f) “The same thing goes with the shooting that she was involved with
with a young African-American young man who was shot and
killed. And the conversation that was brought back to us was that
she and the other officers involved in that, they celebrate that kill
date. Folks, do you understand how serious that is? But yet we’re
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gonna to allow her to continue with a badge and a gun? Now I,

what I’m repeating – now what I’m stating is something that I was
told by someone that worked with her that literally knew of the
anniversary of the death of this young African-American male. . .”
g) “we have the evidence to prove what I’m saying, or folks I

wouldn’t come on this podcast and say it if we didn’t have the
documents and the testimony to back it up. So everything that I
say on this podcast, I say it because the proof has been provided to
me and to my counsel to show that what I’m going to say is
factual.”
https://www.podcastone.com/episode/92-Do-the-Right-Thing-The-Truth-Comes-
Out-and-God-is-Good (last visited July 9, 2021).
76. Defendant Chrisley has also made false and defamatory statements
during other episodes of “Chrisley Confessions” asserting the same accusations
and gists identified above from Episodes 77, 85, 87, and 92. For example, in
Episode 79 released on April 8, 2020, Defendant Chrisley referred to Plaintiff as a
“cohort” of Joshua Waites who was “in collusion” in wrongdoing on behalf of the
GDOR. https://www.podcastone.com/episode/79-Fighting-the-Rona-Separate-
Bathrooms-and-Doing-Our-Child-an-Injustice (last visited July 9, 2021).
77. The false and defamatory accusations and gists set forth above that
were made during numerous episodes of the podcast “Chrisley Confessions” (the
“Slanderous Statements”) are of and concerning Plaintiff.
78. The Slanderous Statements are false.
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79. The Slanderous Statements are defamatory.
80. Defendant Chrisley published the Slanderous Statements negligently
and with actual malice, i.e., knowledge that the Slanderous Statements were false
or with reckless disregard for their falsity.
81. Defendant Chrisley knew that the Slanderous Statements were false,
including because he fabricated information to support his false and defamatory
82. Defendant Chrisley knew or should have known that the Slanderous
Statements were false, including because publicly available records contradicted
Defendant Chrisley’s false and defamatory accusations about Plaintiff.
Slanderous Statements, including by failing to conduct a reasonable investigation
prior to publication by, without limitation, failing to consider or knowingly
disregarding evidence that was available to him.
Slanderous Statements, including by relying on unreliable sources.
Slanderous Statements, including by relying on sources with a known bias against
Plaintiff.
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Slanderous Statements by burying his head in the sand, i.e., engaging in a
purposeful avoidance of the truth, by, without limitation, ignoring publicly
available records, failing to contact Plaintiff prior to publication to confirm the
truth or falsity of the Slanderous Statements, and ignoring accurate information
conveyed by Plaintiff’s family member and third parties to Defendant Chrisley.
87. The Slanderous Statements constitute defamation per se, for which
compensatory damages are presumed as a matter of law.
88. Plaintiff has suffered actual damages as a direct result of the
Slanderous Statements about her, including to her reputation.
89. Plaintiff has suffered actual damages as a direct result of the
Slanderous Statements about her, including emotional and mental distress.
90. Plaintiff is entitled to an award of compensatory damages against
Defendant Chrisley in an amount to be proven at trial.
91. Defendant Chrisley published the Slanderous Statements with actual
malice and common law malice, thereby entitling Plaintiff to an award of punitive
damages.
-32-
92. Defendant’s conduct in publishing the Slanderous Statements was
outrageous and willful, demonstrating that entire want of care that raises a
conscious indifference to consequences.
93. Plaintiff is entitled to an award of punitive damages against Defendant
Chrisley.
94. Defendant Chrisley has acted in bad faith, has been stubbornly
litigious, and has caused Plaintiff unnecessary trouble and expense by making and
refusing to retract his Slanderous Statements, and Plaintiff is entitled to recovery of
attorneys’ fees pursuant to O.C.G.A. § 13-6-11.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that the Court grant Plaintiff
the following relief against Defendant Chrisley:
A. Compensatory damages in an amount to be proven at trial in excess of
$75,000;
B. An award of attorneys’ fees and costs pursuant to O.C.G.A. § 13-6-11,
in an amount to be proven at trial;
C. An award of punitive damages in an amount to be proven at trial; and
D. Such other relief as the Court deems just and proper.
-33-
Dated: July 9, 2021 By: /s/ Nicole Jennings Wade
Nicole Jennings Wade

State Bar No. 390922
[email protected]
Jonathan D. Grunberg
[email protected]
G. Taylor Wilson
[email protected]
WADE, GRUNBERG & WILSON, LLC
600 Peachtree Street N.E.
Suite 3900
Atlanta, GA 30308
Telephone: (404) 600-1153
Facsimile: (404) 969-4333
Attorneys for Plaintiff
-34-
Plaintiffs demand a trial by jury on all counts so triable.
Dated: July 9, 2021 By: /s/ Nicole Jennings Wade

[email protected]
Jonathan D. Grunberg
[email protected]
G. Taylor Wilson
[email protected]
WADE, GRUNBERG & WILSON, LLC
600 Peachtree Street N.E.
Suite 3900
Atlanta, GA 30308
Telephone: (404) 600-1153
Facsimile: (404) 969-4333
Attorneys for Plaintiff
-35-
CERTIFICATION UNDER L.R. 7.1D.
Pursuant to Northern District of Georgia Civil Local Rule 7.1D, the
undersigned counsel certifies that this VERIFIED COMPLAINT is a computer
document and was prepared in Times New Roman 14 point font, as mandated in
Local Rule 5.1C.
This 9th day of July, 2021.

/s/ Nicole Jennings Wade
-36-
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF GEORGIA
NEWNAN DIVISION
AMY DOHERTY-HEINZE, Case No.
Plaintiff,
v.
MICHAEL T. CHRISLEY,
Defendant.
STATE OF GEORGIA
COUNTY OF FULTON
VERIFICATION
I, Amy Doherty-Heinze, Plaintiff in the above-styled matter, hereby certify
under penalty of perjury, before the undersigned officer authorized to administer
oaths, that the information contained in the foregoing VERIFIED COMPLAINT is
true and correct to the best of my knowledge, information, and belief.
[signature page follows]


Chrisley Defamation Case

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Chrisley Defamation Case

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Case 3:21-cv-00105-TCB Document 1 Filed 07/09/21 Page 1 of 38

UNITED STATES DISTRICT COURT

AMY DOHERTY-HEINZE, Case No.

COMES NOW Plaintiff AMY DOHERTY-HEINZE (“Plaintiff”), and states

her Verified Complaint for Defamation against Defendant MICHAEL T.

CHRISLEY (“Chrisley”), as follows:

1. Plaintiff Doherty-Heinze is an individual resident of the State of

Georgia, who resides in Coweta County, Georgia.

2. Defendant Chrisley is an individual resident of the State of Tennessee,

Brentwood, Williamson County, Tennessee, 37027.

JURISDICTION AND VENUE

3. There exists complete diversity of citizenship between Plaintiff and

4. The amount in controversy exceeds $75,000, exclusive of interest,

costs, and attorneys’ fees.

pursuant to 28 U.S.C. § 1332(a)(1).

District of Georgia, Newnan Division, pursuant to 28 U.S.C. §§ 1391(b)-(c)

because Plaintiff Doherty-Heinze resides in this judicial district.

7. This Court has personal jurisdiction over Defendant Chrisley pursuant

to O.C.G.A. § 9-10-91 because he transacts business within the State of Georgia

sufficient to anticipate being haled into court in the State of Georgia.

8. This Court further has personal jurisdiction over Defendant Chrisley

relating to the same subject matter as his defamation of Plaintiff Doherty-Heinze.

9. This Court further has personal jurisdiction over Defendant Chrisley

of Georgia, including false and defamatory accusations used by Defendant in an

explicit effort to have Plaintiff’s certification by the Georgia Peace Officer

Standards and Training Council (“POST”) revoked.

of Georgia, including innumerable statements against the Georgia Department of

12. Defendant Chrisley hosts a podcast and is a social media “personality”

who had approximately 2.3 million followers on Instagram as of March 2020.

13. Plaintiff was previously employed by the Georgia Department of

Revenue (the “GDOR”) as an investigator in the Office of Special Investigations.

14. Beginning in 2017, the GDOR undertook an investigation of

Defendant Chrisley and his wife, Julie Chrisley.

and improperly motivated.

16. In October 2019, Defendant Chrisley filed a lawsuit against Joshua

1:19-cv-04610-LMM, United States District Court for the Northern District of

Georgia (the “Waites Litigation”).

the investigation of Defendant Chrisley.

18. Nevertheless, in early 2020, Defendant Chrisley also began attacking

Plaintiff and accusing her of a multitude of crimes and wrongdoing.

Waites Litigation or otherwise.

20. All of Defendant Chrisley’s accusations of wrongdoing against

Plaintiff are false.

21. Plaintiff served a retraction demand on Defendant Chrisley on July 2,

22. In response, Defendant Chrisley failed and refused to retract of any of

his false and defamatory accusations against Plaintiff.

declaring a Statewide Judicial Emergency pursuant to O.C.G.A. § 38-3-62. See

https://www.gasupreme.us/court-information/court_corona_info/ (Original Order).

25. Pursuant to the Statewide Judicial Emergency Order and pursuant to

by otherwise applicable statutes, rules, regulations, or court orders . . . including

but not limited to any: (1) statute of limitation. . . .”

26. On April 6, 2020, the Georgia Supreme Court issued Guidance on

Judicial Emergency, which provides that:

of limitations was suspended on March 14, and the running of the

https://www.gasupreme.us/court-information/court_corona_info/ (Guidance for

Tolling Statutes of Limitation (April 6, 2020) (emphasis added)).

times. See https://www.gasupreme.us/court-information/court_corona_info/.

28. In the Fourth Order Extending Declaration of Statewide Judicial

limitation.” See https://www.gasupreme.us/court-information/court_corona_info/

(Fourth Extension Order at II.A(10)).

29. Subsequent extensions of the Statewide Judicial Emergency Order

Declaration of Statewide Judicial Emergency. See

30. As a result of the Statewide Judicial Emergency declared by the