USA v. STONE

Filing 32

MOTION for Leave to File Amici Curiae Brief as to ROGER JASON STONE, JR. "Leave to file granted" by Judge Amy B. Jackson on February 12, 2019. (Attachments: # 1 Amici Curiae Brief of Dr. Jerome Corsi, # 2 Exhibit A, # 3 Exhibit B)(zvt)

Case 1:19-cv-00324 Document 1 Filed 02/07/19 Page 1 of 12

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DR. JEROME CORSI, Individually
Denville, NJ, 07834
Plaintiff
V.

Case Number:

ROGER STONE, Individually

COMPLAINT

Defendant.
INTRODUCTION
Plaintiff, DR. JEROME CORSI ("Plaintiff' or "Corsi") hereby files this action against
ROGER STONE ("Defendant Stone") for Defamation, Intentional Infliction of Emotional
Distress and Assault

JURISDICTION AND VENUE
1.

This Court has diversity jurisdiction over this case pursuant to 28 U.S.C. § 1332,

as the parties are completely diverse in citizenship and the amount in controversy exceeds
$75,000.
2.

Venue is proper pursuant to 28 U.S.C. § 1391(b)(2), (3) in that a substantial part

of the events or omissions giving rise to Plaintiff Corsi's claims arose herein.

THE PARTIES
3.

Plaintiff, Dr. Jerome Corsi, is an author and political commentator who publishes

works in this judicial district and nationwide. Plaintiff Corsi is a citizen of New Jersey.
4.

Defendant, Roger Stone, is an individual and a citizen of Florida and a resident of

Fort Lauderdale, Florida. Defendant Stone was recently indicted by Special Counsel Robert
Mueller as part of the alleged "Russian Collusion' investigation. His address is
5.

Defendant Stone was recently indicted by Special Counsel Robert Mueller

("Mueller Indictment") as part of his "Russian Collusion" investigation for the alleged crimes of
perjury, witness tampering and obstruction of justice. The indictment comprises seven different

felony counts. See Exhibit 1 - Mueller Indictment. Importantly, Plaintiff Corsi was not accused

of any wrongdoing or illegality in the Mueller Indictment, in which he named as Person 1, a
material witness to the alleged crimes committed by Stone.
6.

Specifically, the seven count Mueller Indictment against Defendant Stone

involves alleged lying under oath - that is, perjury - witness tampering and obstruction of justice
by threatening to kill a material witness, Randy Credico ("Credico") and his dog if Credico did

not lie to government authorities concerning his involvement with Roger Stone. Credico is

Person 2 in the Mueller Indictment of Defendant Stone. Id. Person 1 in this Mueller Indictment is

Plaintiff Corsi.
7.

Even before Defendant Stone was indicted, he began a public relations campaign

in this district, nationally and internationally to smear, intimidate and threaten Plaintiff Corsi, a
material witness in the "Russian Collusion" investigation. Plaintiff Corsi is listed as Person 1 in

the Mueller Indictment and was not indicted along with Defendant Stone, as he testified

truthfully to the grand jury and in interviews.
8.

9.

To the contrary, Plaintiff Corsi has never defamed or disparaged Defendant Stone.

Defendant Stone knew that he was going to be indicted, and therefore began this

GENERAL ALLEGATIONS

2