UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION
AT DETROIT

George Webb Sweigert, : CASE

:
Plaintiffs, : NO.
:
v. : JUDGE
:
CABLE NEWS NETWORK, INC., : PLAINTIFF’S COMPLAINT
: WITH
Defendant. : JURY DEMAND
:
:
:
:
:

NOW COMES George Webb Sweigert (“George Webb Sweigert”),and by and

through his own pro see counsel, and states his Complaint for Defamation against

Cable News Network, Inc. (“CNN”) as follows:

INTRODUCTION

1. In 1980, Ted Turner defied skeptics and successfully founded CNN, the

first 24-hour cable and satellite news channel.

2. For several years thereafter, CNN branded itself worldwide as “the

most trusted name in news.”

3. CNN is now owned by Turner Broadcasting System, Inc., an American

media conglomerate that is a division of Warner Media, LLC.

4. Warner Media, LLC is an American multinational mass media and

entertainment conglomerate owned by AT&T, Inc. and headquartered in New

 York City.

5. AT&T, Inc. is an American multinational conglomerate holding

company headquartered in Dallas, Texas.

6. According to its 2018 Form 10-K filing and Annual Report, AT&T, Inc.’s

2018 operating revenue was $170.756 Billion and its net income was $19.953 Billion.

7. According to Time Warner Inc. n/k/a Warner Media, LLC’s 2017 Form

10- K filing, CNN reached 91.4 million domestic households and more than 350

million households outside of the United States as of December 31, 2017.

8. In 2017, suffering from a public perception that it had deteriorated

from being recognized as a source of hard news to being considered a mere

echo chamber for manipulated and politicized commentary and “fake news,”

CNN launched a new branding campaign, “Facts First,” which is pinned to the

top of its Twitter social media page.

9. From at least as early as the November 2016 election of Donald J.

Trump as the 45th President of the United States, CNN has maintained a well-

known and easily documented biased agenda against President Trump and

established a history of impugning individuals perceived to be supporters of the

President.

10. Prior to January 2018, President Trump publicly and repeatedly

branded CNN as the poster child of “fake news.”

11. Between June 17th, 2017 and October 29th, 2019 at the time of this

writing, CNN brought down the full force of its corporate power, influence, and

wealth on George Webb Sweigert by falsely attacking, vilifying, and bullying

him despite the fact that he was simply a citizen journalist reporting on stories

of worldwide interest and importance.

12. Contrary to its “Facts First” public relations ploy, CNN ignored the facts

and put its anti-Trump agenda first in waging a three and a half year campaign

of false, vicious attacks against George Webb Sweigert, a self financed, citizen

journalist who had only contributed to the Presidential campaigns of Bernie

Sanders in 2016.

13. CNN’s vicious attack on George Webb Sweigert included at least three

(3) defamatory television broadcasts and forty two (42) months of continuous

posting defamatory online articles falsely accusing George Webb Sweigert of

being in a plot to create alarm in the Port of Charleston when he in fact was in

Ohio covering a story of missing uranium and an eight way murder of every

member of a uranium trucking company.

14. More specifically, CNN falsely asserted that George Webb Sweigert

engaged in a deliberate attempt to create a news hoax in the Port of Charleston

when in fact George Webb Sweigert had discounted these initial reports, and

clearly contradicted them by saying any likely attack by the Pakistani terrorist

Daewoo Ibrahim would occur at his main drug port, the US Naval Base in

Norfolk, Virginia, not at the Port of Charleston.

15. Despite numerous attempts by George Webb Sweigert to CNN to

correct the record, CNN has ignored these requests for forty two (42) months.

16. The CNN accusations are totally and unequivocally false and CNN

would have known them to be untrue had it undertaken any reasonable efforts
to verify their accuracy before publication of its false and defamatory

accusations.

17. CNN continued the attacks on Citizen Journalist, George Webb

Sweigert, in June of 2020, making outlandish and false claims that somehow

wished harm on the subjects of one of his news reports.

18. CNN ignored death threats provided by George Webb Sweigert to CNN

Reporter, Donie O’Sullivan, clearly showing a Navy veteran from the US Naval

Base in Norfolk, Virginia had threatened to “Waco” and “Jonestown” George

Webb Sweigert’s family.

19. CNN and Reporter Donie O’Sullivan also ignored text messages from

Ken Hale, a Navy Veteran and former official with the US State Department,

threatening he was “five minutes away” multiple times on a Saturday evening

from the home of George Webb Sweigert’s home in Maryland at that time.

20. CNN and CNN Reporter Donie O’Sullivan also ignored text messages

provided to Donie O’Sullivan sent by Ken Hale threatening to “flamethrower”

the family of George Webb Sweigert.

21. CNN made no acknowledgment of these death threat texts and message
made directly to George Webb Sweigert in its June 2020 reporting about
him.

22. CNN and Reporter Donie O’Sullivan recklessly endangered the life of

George Webb Sweigert and his family by outrageously and falsely twisting the

death threats to him by reporting somehow George Webb Sweigert was wishing

ill on the subjects of his March 2020 reporting.

 23. George Webb Sweigert clearly cast the subject of his March 2020 as

victims of the CoronaVirus while in China for the 2019 NATO Military Games.

24. CNN repeatedly defamed George Webb Sweigert with false claims that

he encouraged bullying of the October 2019 NATO Military Games CoronaVirus

victims in national television broadcasts with anchors Jim Sciutto, Poppy

Harlow, and Brian Seltzer.

25. Contrary to CNN’s repeated false reports, George Webb Sweigert

presented all the CoronaVirus victims from the October 2019 NATO Military

Games as victims including French Gold Medalist Elodie Cloudel and her fiancé

on the Dutch NATO Team. The Italian NATO Team victims were also

accurately presented as victims.

26. CNN rushed to incite a viral social media mob to further its anti-

Trump agenda and increase the billion-dollar bottom lines of its conglomerate

corporate owners by generating eyeballs, clicks, and resulting advertising

revenue from its sensationalized broadcasts and online reporting.

27. According to media reports, CNN’s high primetime viewership of the

reports on George Webb Sweigert as a “harasser”.

28. CNN elevated false, heinous accusations of the alleged “harassment”

conduct of George Webb Sweigert in a national broadcast on October 28th,

2020 from social media to its worldwide news platform without adhering to

well-established journalistic standards and ethics, including its failure to take

the required steps to ensure accuracy, fairness, completeness, fact-checking,

neutrality, and heightened sensitivity when dealing with a minor.

 29. Exposing the shallowness of its “Facts First” public relations branding

ploy, CNN got the “Facts Last” as it repeatedly, recklessly, and willfully violated

basic, fundamental standards of journalistic integrity.

30. CNN’s agenda-driven fiction about George Webb Sweigert about this

March 2020 reporting was not only false and defamatory, it created an

extremely dangerous situation by knowingly triggering the outrage of its

audience and unleashing that outrage on George Webb Sweigert with its

patently false accusations that George Webb Sweigert somehow wished harm on

the subjects of his factual reports.

31. CNN anchors and news personnel openly called for “acts of outrage”

against George Webb Sweigert, furthering the mob frothing to its false

narratives.

32. With its most recent reports in October of 2020, CNN’s wanton

reporting has now move from outrageous misrepresentation and slander to

reckless endangerment for the lives of George Webb Sweigert and his family.

33. Rather than publicly retracting its false, defaming reports about

George Webb Sweigert, CNN willfully chose to amplify this dangerous and

reckless behavior in a worldwide broadcast on October 28th, 2020.

34. George Webb Sweigert was an easy target for CNN to advance its anti-

Trump agenda because he was a Bernie Sanders supporter who had turned to

Trump after his lawsuit against the DNC was mooted by a plea deal of a key

DNC operative.

35. In addition to its substantial broadcast television and online audience,

 CNN republished many of its false and defamatory broadcasts and articles to its

over 41 million Twitter followers.

36. In order to fully compensate George Webb Sweigert for the

reputational harm, emotional distress, and mental anguish caused by CNN’s

false attacks, this action seeks compensatory damages in excess of Fifty Million

Dollars ($55,000,000.00).

37. In order to punish and to deter CNN from ever again engaging in false,

reckless, malicious, and agenda-driven attacks against citizen journalists in

violation of well-

recognized journalistic standards and ethics, this action seeks punitive damages in

excess of One Hundred Million Dollars ($100,000,000.00).

DETAILED FACTUAL BACKGROUND OF

REPORTING BY GEORGE WEBB

SWEIGERT IN PIKETOWN OHIO JUNE 2017

38. George Webb Sweigert met with two independent sources on June

14th, 2020 to confirm and cross-reference a story about missing uranium from

the US Enrichment Uranium Plant in Piketown, Ohio.

39. George Webb Sweigert endeavored to meet with a third independent

source before he was arrested.

40. George Webb Sweigert was tracked and his cell phone was repeatedly

pinged by the FBI on the afternoon of June 14th, 2020.

41. George Webb Sweigert had no idea the first informant he met with for

several hours, Marshall Okey Richards, was in fact an FBI Informant. Richards
played a key role in the entrapment of several residents of West Virginia and

Ohio by encouraging them to take bomb making classes in previous years.

42. The second informant George Webb Sweigert met with on June 14th,

2020 reported that the uranium trucking company he was investigating in

Piketon, Ohio (where every member of the company was murdered in a

gruesome eight-way murder), was actually an industrial drug operation run by

the Rhoden Trucking family.

43. CNN never reported a correction to their grossly misleading story that

George Webb Sweigert had somehow been the source of the information

himself, even after FBI Marshall Okey Richards was outed in the media.

44. CNN was informed numerous times in dozens of online broadcasts and

requests to correct their reporting that somehow George Webb Sweigert had

generated the story. The second information source is a former law

enforcement officer who was present as George Webb Sweigert took five calls

from DHS and Port of Charleston officials in trying to understand which DNC

operative had shipped four diplomatic containers to the Port.

45. Despite dozens of requests to correct the record, CNN and Reporter

Donie O’Sullivan callously refused to correct the story that an FBI Informant

was the actually source of the story, and that George Webb Sweigert had been

entrapped.

46. CNN has shown willful disregard for the truth by even the most minimal
journalist standard by allowing this false “Port of Charleston hoax”
narrative to continue.
47. Instead of trying to contain the irreparable harm their grossly
misleading story about the Port of Charleston, CNN and Reporter Donie

O’Sullivan chose to willfully compound the damage by making George Webb

Sweigert the target of yet another CNN attack in June of 2020.

REPORTING GEORGE WEBB SWEIGERT IN March 2020

48. In March of 2020, George Webb Sweigert correctly reported that

Chinese Foreign Minister Spokesman Jian brought CoronaVirus to Wuhan at

the US Military Athletes at the October 2019 NATO Military Games.

49. George Webb Sweigert was not aware of the Harvard CoronaVirus

Study placing the outbreak in Wuhan, China in August of 2019 at the time of

the reporting.

50. George Webb Sweigert received information at a news gathering event

that Ft. Belvoir Community Hospital in Virginia had an outbreak in September

of 2019 and Detrick, Maryland area hospitals and nursing homes had a

CoronaVirus outbreak in August of 2019 near the bioweapons facility in Ft.

Detrick Maryland.

51. George Webb Sweigert had been informed in January of 2019 by a

doctor at the Ft. Belvoir facility that voluntary testing sometimes occurred both

facilities of “mock” or “low intensity” viruses to test treatments and vaccines.

52. At a news gathering event of ten citizen journalists, the number of

athletes that could have been infected at Ft. Belvoir Community Hospital that

also attended the Wuhan NATO Military Games in October 2019 was just one

person, a Dutch National woman cyclist with a background as a driver for the

Supreme NATO Allied Commander.

 53. In a working news gathering event with ten people, the name of the

Dutch NATO driver was put on a whiteboard, and her employment at Ft.

Belvoir Community Hospital was confirmed. George Webb Sweigert only

speculated this Dutch NATO driver was a possible victim at this event, and

unknowingly been “patient zero”. During this time of intense tension between

the United States and China with each side blaming the other for the

CoronaVirus, this effort seemed to be the only logical and helpful discussion

occurring in the News universe to reduce the name calling and assignment of

blame.

54. Instead of lauding this logical epidemiology approach to actually

solving and tracing the CoronaVirus crisis, CNN and Reporter Donie O’Sullivan

chose to jump on the attack of Citizen Journalist, George Webb Sweigert yet

again. Even after evidence was produced that the Dutch courier was indeed

Dutch, had been a driver for the Supreme Allied Commander of NATO, and was

indeed employed at Ft. Belvoir Community Hospital for CNN Reporter Donie

O’Sullivan, instead of responsibly reporting these facts, he and CNN willfully

choose to suppress this information from the American people. To compound

these gross errors of omission, CNN and Reporter Donie O’Sullivan chose to

simply say there was no evidence presented to them.

55. Even after the Chinese Foreign Minister specifically requested the

medical records of the Dutch cyclist with the NATO High Command experience,

CNN and Reporter Donie O’Sullivan continue to push the false narrative their

was not evidence and no attempt at fair and balanced journalist by George
Webb Sweigert, causing yet more irreparable harm and defamation.

54. After dozens of outreaches to the subjects of the story, many of the

outreaches broadcast around the world, the subjects of the story remained only

in close consult with CNN and Reporter Donie O’Sullivan.

55. Given CNN’s prior misrepresentations and denials of responsibility for

correction for the previous 42 month, a reasonable person would expect some

modicum of journalistic inquiry to avoid their egregious earlier, uncorrected

errors. But the exact opposite behavior was demonstrated by CNN and

Reporter Donie O’Sullivan in June 2020 with an irresponsible amplification of

previous false narratives about George Webb Sweigert.

56. CNN not only unleashed a mob a revenge minded internet trolls to

descend on George Webb Sweigert’s YouTube Channel, but they actively

lobbied the removal of his channel to deprive him any means of rebuttal against

the CNN Media Giant.

57. YouTube responded to CNN pressure by destroying four years of

journalistic work that included tens of thousands of source citations that would

fill seven Gutenberg Bibles at last count.

58. Instead of taking a sober assessment of the irreparable damage they

had done to George Webb Sweigert’s career and life’s work, CNN and Reporter

Donie O’Sullivan actively conspired with internet trolls to intensify the damage

caused.

59. CNN and Reporter Donie O’Sullivan continues this character

assisination scheme up to one week before the US Presidential Election
with yet another false and misleading attack on George Webb Sweigert
 on October 28th, 2020.

60. CNN and Reporter Donie O’Sullivan continue to promote their

misrepresentations and defamations of George Webb Sweigert to the very

minute of this writing, and CNN and Reporter Donie O’Sullivan show now signs

of abating their actions.

61. At all times, George acted respectfully, responsibly, appropriately, and

in a manner consistent with the values instilled upon him by his family and his

faith.

THE CNN COVERAGE

62. The CNN attacks on citizen journalism can be understood if one looks

at the money mad history of CNN and their continual choice over targeting

innocents to dogwhistle their base of rabid followers in deference to journalistic

integrity. When view through the lens of false narratives leading to rapacious

profits, their contemptible behavior is at least understandable.

63. Given this egregious behavior by CNN, a reasonable person might

expect CNN and Reporter Donie O’Sullivan would be rushing to issue a

retraction or a statement of contrition regarding its wanton targeting of a

citizen journalist who was just trying to tell the truth. But, what my not

surprise the Court by this point in the Complaint, CNN nor Donie O’Sullivan

have never to the date of the filing of this Complaint issued a formal retraction,

correction or an apology to George Webb Sweigert.

PARTIES, JURISDICTION, AND VENUE

64. George Webb Sweigert now resides in Monroe County, Michigan.

 65. George Webb Sweigert has been a self finance journalist for the last

four years, and before that he was a network analyst.

66. CNN is a foreign corporation existing under the laws of the State of

Delaware with its principal place of business being located at One CNN Center,

Atlanta, Georgia 30303. CNN may be served by delivery of a copy of the

summons and complaint to its duly-appointed registered agent, the

Corporation Trust Company, Corporation Trust Center, 1209 Orange Street,

Wilmington, Delaware 19801.

67. There exists complete diversity of citizenship between Plaintiffs and

CNN.

68. The amount in controversy greatly exceeds Seventy-Five Thousand

Dollars ($75,000.00), exclusive of interests, costs, and attorneys’ fees, as

required to sustain subject-matter jurisdiction in this Court.

69. This Court has subject-matter jurisdiction over this matter pursuant to
28

U.S.C. § 1332(a).

70. CNN is the nation’s first cable news network and remains a fixture of
cable

news – both nationally and internationally.

 129. CNN transacts business in the State of Michigan, including through the

distribution of its content through cable television and the Internet, and CNN

committed the tortious acts identified herein in the State of Michigan.

130. CNN published the broadcasts and online articles identified herein in

the State of Michigan.

131. CNN has intentionally sought and obtained benefits from their tortious

acts in the State of Michigan.

132. CNN directed its conduct at George Webb Sweigert, a citizen of

Michigan.

133. George suffered substantial reputational and emotional harm in this

District.

134. There is a reasonable and direct nexus between CNN’s tortious conduct
in

Michigan and the harm suffered by George Webb Sweigert in Michigan and beyond.

135. CNN is subject to the jurisdiction of this Court.

136. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)

because the CNN is subject to personal jurisdiction in this District and/or a

substantial part of the events giving rise to this claim occurred in this District,

including publication and injury.

CAUSE OF ACTION FOR DEFAMATION

137. George reasserts and incorporates by reference paragraphs 1 through

136 of this Complaint as if fully restated herein.

138. CNN published to third parties without privilege no less than three (3)

false and defamatory television broadcasts, three (3) false and defamatory
 Internet articles, and three (3) false and defamatory tweets of and concerning

George Webb Sweigert.

139. As late as October 28th, 2020, CNN and Reporter Donie O’Sullivan

posted on its Twitter page and published to approximately 41 million followers

false and defamatory gists of their previous defamations of George Webb

Sweigert.

140. These tweets are collectively referred to herein as the “Tweets.”

141. The Tweets, Broadcasts, and Articles are collectively referred to herein as

the “False and Defamatory Accusations.”As the natural and foreseeable consequence
of its actions, CNN knew and intended that its False and Defamatory Accusations
would be republished by others, including media outlets and others on social media.

George IS A CITIZEN JOURNALIST

142. George Webb Sweigert has a right to Freedom of Speech and Freedom

of the Press guaranteed by the Constitution.

143. George Webb Sweigert has always made a practice of fast and very

public retractions if every pointed to be in error of a story.

144. George Webb Sweigert does not take money for large corporate
advertisers looking for journalists who will look the other way to their
transgressions.

145. George Webb Sweigert does not promulgate conspiracy theories like
Donald Trump being the agent of Russia as CNN and Reporter Donie
O’Sullivan have done like clockwork that last four years.
146. George Webb Sweigert has a reasonable expectation to be protected by the
rights guaranteed by the US Constitution and relevant State Law.
 CNN PUBLISHED NEGLIGENTLY AND
MALICIOUSLY

CNN published its False and Defamatory

Accusations negligently and with actual knowledge
of falsity or a reckless disregard for the truth.

147. As one of the world’s leading news outlets, CNN knew but ignored the

importance of verifying damaging and, in this case, incendiary accusations

against a citizen journalist prior to publication.

148. Instead, CNN recklessly rushed to publish its False and Defamatory

Accusations in order to advance its own political agenda against President

Trump.

149. In doing so, CNN lifted the incident from social media and placed it in

the mainstream media, giving its False and Defamatory Accusations credibility

and permanence.

150. CNN negligently published its False and Defamatory Accusations by

departing from the reasonable standard of care employed by journalists,

including those standards articulated by the Society of Professional Journalists’

Code of Ethics.

151. CNN’s collective conduct demonstrates a purposeful avoidance of the

truth and the publication of the False and Defamatory Accusations with actual

knowledge of falsity following its review of the complete video evidence and

George’ statement no later than January 20.

152. CNN negligently and recklessly published its False and Defamatory

Accusations by failing to conduct a reasonable investigation prior to

publication.
 153. CNN’s duty to investigate is heightened where, as here, where the June

2020 and October 2020 CNN Reporting compounded the injury.

154. CNN negligently and recklessly published its False and Defamatory

Accusations by relying on unreliable and biased sources with questionable

credibility.

155. CNN negligently and recklessly published its False and Defamatory

Accusations by failing to conduct a reasonable investigation, including by

relying on unreliable sources for its publications.

156. Indeed, CNN conducted no interviews of George Webb Sweigert’s

sources.

157. CNN consciously elected to ignore this contrary information in favor of

its pre-conceived false narrative against President Trump and his supporters.

158. CNN negligently and recklessly failed to consult publicly available

information demonstrating its False and Defamatory Accusations to be false,

including, without limitation, other video evidence available online

demonstrating the steadfast journalistic discipline of George Webb Sweigert.

159. In fact, upon information and belief, prior to publishing any of its False

and Defamatory Accusations, CNN knew that its defamations were the result of

FBI Informants planting false information with George Webb Sweigert. But

CNN wholly omitted and otherwise contradicted this information.

160. CNN continued to publish its False and Defamatory Accusations with

actual knowledge of falsity, having reviewed video evidence and statements of

George Webb Sweigert contradicting its False and Defamatory Accusations.

 161. CNN negligently and recklessly failed to seek information from other

obvious sources who were present at the January 18 incident and would have

demonstrated its False and Defamatory Accusations to be false, including

George Webb Sweigert, and upon information and belief, his wealth of video

documentation proving his journalistic integrity.

162. CNN negligently and recklessly published its False and Defamatory

Accusations despite internal inconsistencies in despite uncovering information

which corroborated George Webb Sweigert’s reporting.

163. CNN negligently and recklessly published its False and Defamatory

Accusations in derogation of accepted principles of journalistic ethics, including

by failing to use heightened sensitivity when dealing withcitnizen journalists.

164. CNN negligently and recklessly published its False and Defamatory

Accusations in derogation of accepted principles of journalistic ethics, including

by failing to verify each before publication.

165. CNN negligently and recklessly published its False and Defamatory

Accusations in derogation of accepted principles of journalistic ethics, including

by failing to avoid stereotyping.

166. CNN negligently and recklessly published its False and Defamatory

Accusations in derogation of accepted principles of journalistic ethics, including

by failing to examine the way in which its own biases and agenda shaped its

false reporting.

167. CNN negligently and recklessly published its False and Defamatory

Accusations in derogation of accepted principles of journalistic ethics, including

by failing to treat George Webb Sweigert as a human being deserving of respect.

168. CNN negligently and recklessly published its False and Defamatory

Accusations in derogation of accepted principles of journalistic ethics, including

by wrongfully placing the anti-Trump agenda over the harm its False and

Defamatory Accusations caused irreparable harm to George Webb Sweigert.

169. Upon information and belief, at the time of its initial reporting of and

concerning George, CNN did not know George’ age and did not make any

reasonable attempt to ascertain it despite the general knowledge that George

Webb Sweigert was being misled by FBI Informants.

170. CNN’s actual malice is further evidenced by its failure to retract is False

and Defamatory Accusations.

171. CNN published its False and Defamatory Accusations with common

law malice, including because it intended to harm George Webb Sweigert

because his was a disaffected support of the Democratic Party and consciously

ignored the threats of harm that it knew would inevitably ensue, in favor of its

political agenda.

172. CNN published its False and Defamatory Accusations with common

law malice, demonstrated by its failure to retract its False and Defamatory

Accusations despite the harm and danger it knew would be inflicted upon

George Webb Sweigert.

173. CNN published its False and Defamatory Accusations with common

law malice, including because it callously ignored the consequences of its

actions upon a citizen journalist.

 174. CNN’s common law malice is further evidenced by its failure to
reprimand Reporter Donie O’Sullivan for his cyber-assault of George on
Twitter.

DAMAGES

175. The publication of the False and Defamatory Accusations directly and

proximately caused substantial and permanent damage to George Webb

Sweigert.

176. The False and Defamatory Accusations were republished by third-

parties and members of the mainstream and social media mob, which was

reasonably foreseeable.

177. The False and Defamatory Accusations against George Webb Sweigert

are defamatory per se, as they are libelous on their face without resort to

additional facts, and as clearly demonstrated here, George Webb Sweigert was

subjected to public hatred, contempt, scorn, obloquy, and shame.

178. As a direct and proximate result of the False and Defamatory

Accusations, George Webb Sweigert suffered permanent harm to his

reputation.
 291. As a direct and proximate result of the False and Defamatory

Accusations George Webb Sweigert suffered severe emotional and mental

distress.

292. As a direct and proximate result of the False and Defamatory

Accusations George Webb Sweigert is forced to live his life in a constant state

of concern over his safety and the safety of his family.

293. CNN published its False and Defamatory Accusations with actual

malice and common law malice, thereby entitling George Webb Sweigert to an

award of punitive damages.

294. CNN’s conduct was outrageous and willful, demonstrating that entire

want of care that raises a conscious indifference to consequences.

295. George Webb Sweigert is entitled to an award of punitive damages to

punish CNN and to deter it from repeating such egregiously unlawful

misconduct in the future.

WHEREFORE, George Webb Sweigert respectfully prays:

(a) That judgment be entered against CNN for substantial compensatory

damages in an amount not less than Fifty Million Dollars ($50,000,000.00);

(b) That judgment be entered against CNN for punitive damages in an

amount not less than One Hundred Million Dollars ($100,000,000.00);

(c) That George recover his reasonable attorneys’ fees and expenses from
CNN;
(d) That all costs of this action be taxed to CNN; and
(e) That the Court grant all such other and further relief that the Court
deems just and proper, including equitable relief.
 Respectfully submitted this 30th day of October, 2020.

George Webb Sweigert

George Webb Sweigert (pro se)

[email protected]

1671 W. Stearns Road, Suite E

Temperance, MI 48182
Tel: 503-919-0748