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Chrisley Defamation Case
Chrisley Defamation Case
Plaintiff,
VERIFIED COMPLAINT FOR
v. DEFAMATION
MICHAEL T. CHRISLEY,
DEMAND FOR JURY TRIAL
Defendant.
PARTIES
who, upon information and belief, resides and can be served at 9273 Exton Lane,
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Defendant.
5. Therefore, this Court has subject matter jurisdiction over this matter
6. Venue is proper in the United States District Court for the Northern
because he has filed a lawsuit in the Northern District of Georgia, Atlanta Division,
because his defamation of Plaintiff has been directed specifically toward the State
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10. This Court further has personal jurisdiction over Defendant Chrisley
because his defamation of Plaintiff has been directed specifically toward the State
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
15. Defendant Chrisley then began a social media campaign against the
GDOR and certain of its employees, contending that the investigation was illegal
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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.
17. Aside from performing one discrete task, Plaintiff was not involved in
19. Defendant Chrisley has not asserted any claims against Plaintiff in the
2021 (the “Retraction Demand”), a true and correct copy of which is attached
hereto as Exhibit A.
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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
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
Tolling Statutes of Limitation Under the Chief Justice’s Order Declaring Statewide
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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27. The Statewide Judicial Emergency Order was extended fifteen (15)
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
included the same language as Section II.A(10) of the Fourth Order Extending
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https://www.gasupreme.us/court-information/court_corona_info/.
Supreme Court of Georgia, the statute of limitations for the defamation claims set
31. Certain of the false and defamatory statements set forth herein were
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
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.
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
running of the statute of limitations for 122 days between March 14 and July 14,
CAUSES OF ACTION
COUNT ONE:
DEFAMATION BY LIBEL
on his Instagram account that includes false and defamatory accusations against
Plaintiff:
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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
pointing out that his accusations against Plaintiff were false and asking why he had
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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
questions from his readers, and he advised his readers that he had undisclosed
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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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and defamatory accusations against Plaintiff in the comments to his March 9 post,
accusations against Plaintiff that would soon be disclosed (but never were because
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2021).
of the media coverage surrounding Defendant Chrisley and the prominence of his
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
https://www.tvshowsace.com/2020/03/10/todd-chrisley-slams-georgia-dept-of-
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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:
his Facebook account that includes false and defamatory accusations against
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https://www.facebook.com/permalink.php?story_fbid=2921608827948420&id=51
statements about Plaintiff, indicating that he had undisclosed “proof” to support his
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his Facebook account, which includes false and defamatory accusations against
https://www.facebook.com/permalink.php?story_fbid=2924179607691342&id=51
48. Defendant Chrisley also published the following undated post on his
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
50. Throughout his social media posts on Instagram, Facebook, and other
sites, Defendant Chrisley has published the following written false and defamatory
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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.”
l) “it wasn’t their paychecks paying for it, it was taxpayer dollars
from a slush fund. . . .”
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?’”
r) “Ask about picking out her own car that Josh bought through the
slush fund”
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. . . .”
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. . . .”
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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.”
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.
with actual malice, i.e., knowledge that the Libelous Statements were false or with
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55. Defendant Chrisley knew that the Libelous Statements were false,
56. Defendant Chrisley knew or should have known that the Libelous
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61. The Libelous Statements constitute defamation per se, for which
62. Plaintiff has suffered actual damages as a direct result of the Libelous
63. Plaintiff has suffered actual damages as a direct result of the Libelous
malice and common law malice, thereby entitling Plaintiff to an award of punitive
damages.
was outrageous and willful, demonstrating that entire want of care that raises a
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
COUNT TWO:
DEFAMATION BY SLANDER
March 11, 2020, Defendant Chrisley made the following verbal false and
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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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.”
i) The gist that Plaintiff obtained her job with the DOR through
nefarious means.
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
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May 20, 2020, Defendant Chrisley made the following verbal false and defamatory
https://www.podcastone.com/episode/85-Not-Valid-Expectations-Dictionary-
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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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. . . .”
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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.”
d) “it doesn’t change the criminal conduct that she did while
employed with the Georgia Department of Revenue.”
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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https://www.podcastone.com/episode/92-Do-the-Right-Thing-The-Truth-Comes-
76. Defendant Chrisley has also made false and defamatory statements
and gists identified above from Episodes 77, 85, 87, and 92. For example, in
“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-
77. The false and defamatory accusations and gists set forth above that
were made during numerous episodes of the podcast “Chrisley Confessions” (the
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and with actual malice, i.e., knowledge that the Slanderous Statements were false
81. Defendant Chrisley knew that the Slanderous Statements were false,
82. Defendant Chrisley knew or should have known that the Slanderous
Plaintiff.
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87. The Slanderous Statements constitute defamation per se, for which
malice and common law malice, thereby entitling Plaintiff to an award of punitive
damages.
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outrageous and willful, demonstrating that entire want of care that raises a
Chrisley.
94. Defendant Chrisley has acted in bad faith, has been stubbornly
litigious, and has caused Plaintiff unnecessary trouble and expense by making and
$75,000;
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document and was prepared in Times New Roman 14 point font, as mandated in
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Plaintiff,
v.
DEMAND FOR JURY TRIAL
MICHAEL T. CHRISLEY,
Defendant.
STATE OF GEORGIA
COUNTY OF FULTON
VERIFICATION