I DC -J CTN JUDG Marc J. Raiidazcza, NV Bar it 12265 Ronald D. Green, NV Bar 7360 J, Malcolm De\/oy, NV Bar #1 l950 Randazza Legal Group 6525 W. Warm Springs Rd., Ste. 100 Las Vegas, NV 891 18 888~667--1 113 305--437~7662 (fax) ge'i.l ran 212221 .con.: Attorneys for Plaintiff, James CLARK COUNTY, NEVADA JAMES Case No.: A~l2--667l 56--C Plaintiffi Dept. No; XXIV JUDGMENT vs. I--IUNTER MOORE, Defendant. Plaintiff brought a Complaint for defamation and false light against Defendant Hunter Moore. Among other things, Moore falsely accused Plaintiff of serious crimes and offenses that are defamatory per .99, including pedophilia and possession of child pornography. Moore was properly served with process in this case. Moore publicly acknowledged this service through his Twitter account, as noted in the exhibits to Plaintiff's Application for Default Judgment. Despite being properly served, Moore. declined to defend this case, and default was entered against him on October 24, 2012. McGibney clearly and convincingly proved that Moore's statements were false, injurious, and defamatory, and filed his Application for Default Judgment on December 3, 2012. The Court scheduled an evidentiary hearing on McGibney's Application for Default Judgment on February 27, 2013. At this hearing, the Court considered evidence in the form of sworn affidavits from Plaintiff, Professor Colleen Connolly~Ahern University, and Steven Rohr, the principal of Lexicon Public Relation. of States in Los Angeles, California, and copies of Moore's own stateinents, as well as evidence of the reach of Moore's false claims. Both expert witnesses were cornrnunications professionals, with Ms. Connolly-Aliern focusing on the academic scholarship of communication and Mr. Rohr addressing the practical harm Defendant Moore's false statements caused M.cGibney. Mr. Rohr, being duly sworn, offered expert testimony upon questioning from both Plain.tiff's counsel and the Court supporting claim that he has been damaged in the amount of Steven Rohr offered oral. testimony at the February 27, 2013 hearing to expand upon the issues addressed within his oral report. Specifically, Mr. Rohr testified that Mr. McGibney's reputation would suffer at least. $250,000 in damage as a result of Moore's false and defamatory statements and how widely they were broadcast. Particularly, Rohr testifie-d that his estimate of the life--long damage to Plaintiff' personal and professional relationship was at least $1,000,000. Plaintiff, however, stated that he requested judgment of $250,000 as a conservative estimate of his reputational and personal injuries from Moore's conduct. Although it is difficult to pinpoint the precise amount of damages Plaintiff suffered, Plaintiffs affidavit, the affidavits of his experts, and the oral testimony of Steven Rohr are sufficient to support a judgment of $250,000 in Plaintiffs favor against Defendant Hunter Moore. Defendanfs default was previously entered for his failure to answer or otherwise defend Plaintiffs claims aft.er being regularly served with the Surnmons and Complaint, and it appearing that Defendant is not in the military service of the United States and is not an infant or incompetent person, Plaintiff applied for and is granted default judgment. Plaintiff previously requested $11,581 in attorney's fees on November 29, 2012. Since then, Plaintiff has incurred an additional $8,003.00 in reasonable attorneys' fees. Based upon Plaintiff"'s submissions to the Court, and good cause appearing therefor, IT IS ORDIEIRIED that judgment is entered in Plaintiffs favor against Defendant Hunter Moore in the amount. of: . The principal sum of $250,000 in damages; Judgment U1 :0 lntencst on the principal amount at the legal rate of 3.25% per month from the date ()ftl1iS Judgment until paid in full; Costs of t11e suit in the amount DJ 4. $11,581.00 in 21tt01f11eys' fees as of the date of Plaintiffs application for default judgmentfor default Judgment. in a.t'tor11eys' fees incurred following, the filing of P1aintiff"s .. day 2013. Submigted By: .x J. I{a11d2ffiza RANDAZZA LEGAL GROUP 6525 W. Warm Sp1'ings Road, Suite 100 Las Vegas, NV 891 18 A Plain! 3 .lLIdg1m-3111