Huon v. Breaking Media et al

Filing 79

RESPONSE by Meanith Huon to MOTION by Defendants John Lerner, Breaking Media, David Lat, Breakingmedia.com, David Minkin, Abovethelaw.com, Elie Mystal to dismiss pursuant to rule 12(b)(6) 35 (Attachments: # 1 Exhibit A)(Huon, Meanith)

24.

Defendants intentionally omitted the following facts:

a.
b.

The complainant that is the subject of all the news articles is the same woman.
The jury was not allowed to consider the consent defense and, thus, the jury found
that no sexual contact took place. The trial judge had barred the consent defense.
c.
The complainant sustained minor injuries from walking or running in a cornfield.
d.
There was no evidence of a Craigslist ad for a job for promotional modeling.
There was no evidence that Mr. Huon represented himself as a talent scout.
e.
The video evidence at trial showed Mr. Huon, dressed in shorts, on a Sunday
afternoon with the complainant, in a bar.
f.
There was no DNA evidence of semen and the complainant never went to the
hospital.
g.
The police never interviewed witnesses at the scene who testified at trial that the
complainant gave different versions of the alleged incident.
h.
The police asked the complainant to call Mr. Huon to arrange a private meeting
and to ask for money.
i.
The complainant had gone drinking with Mr. Huon at several bars for hours.
j.
There was no evidence presented that the complainant jumped out of a moving
car.
k.
There was no evidence of force presented at trial. The police report stated that
complainant alleged that Mr. Huon raised his voice but that Mr. Huon never
threatened the complainant.
l.
The photograph of the complainant showed no injuries (besides from her walking
in a cornfield barefoot) and showed her clothes to be completely intact with no
tears.
25.
Defendants intentionally invented the following fiction or made the following
false statements available worldwide on Internet via the Abovethelaw.com website by:
a.
b.
c.

d.
e.
f.

g.
h.
i.
1

Falsely identifying Mr. Huon as an attorney rapist near you on the day of his
acquittal.
Falsely labeling Mr. Huon as wanton and depraved .
Falsely identifying Mr. Huon as a St. Louis-area lawyer . Mr. Huon’s address
in the news article is in Chicago and he was a financial advisor at the time of the
alleged incident.
Falsely reporting that Mr. Huon came up with an excellent little game to meet
women.
Falsely reporting that Meanith Huon allegedly listed Craigslist ads where he
claimed to be a talent scout for models.
Falsely suggesting that Mr. Huon was targeting “ bubble gum princesses at a BU
party.” The alleged complainant was 26 years old at the time of the alleged
incident.
Falsely reporting that Mr. Huon told lies.
Falsely calling Mr. Huon’s actions as dastardly.
Falsely reporting the complainant as a “victim” of Mr. Huon.

j.
k.
l.
m.
n.
o.
p.
q.
r.
s.
t.
u.

v.
w.

x.
y.
z.
aa.

2

Falsely reporting that the complainant responded to a Craigslist ad posted by
Huon in late June, seeking promotional models.
Falsely reporting that the two agreed to meet at the downtown St Louis bar
Paddy O’s.
Falsely reporting that Mr. Huon told complainant to meet him at certain bars.
Falsely reporting that Mr. Huon told complainant that “other promotional
models left” and that Mr. Huon “ was going to interview her.”
Falsely reporting that if the complainant had Googled Mr. Huon, she would have
found other stories in the Madison County Record and Lawyer Gossip.
Falsely reporting that Mr. Huon was posing as a supervisor for a company that
sets up promotions for alcohol sales at area bars.
Falsely calling Mr. Huon a potential rapist and a depraved dude walking
around that are potential rapist.
Falsely reporting that Mr. Huon asked the complainant if she wanted to go to
Pop’s in Sauget to meet the other models.
Falsely reporting that the complainant said she didn’t have enough gas in her
car, so she went with him.
Falsely reporting that “ This is gonna end badly.”
Falsely reporting that Mr. Huon”fondled the woman, then forced her to
perform oral sex on him.”
Falsely stating that Mr. Huon “force” the complainant to perform oral sex and
that the complainant jumped out of the car for that reason. Defendants write:
“Oh, come on. If somebody was driving and tried to “force” me to perform
oral sex on them, I’d just get out of the stupid car. Which is to say, I’d do
exactly what the victim did in this case.”
Falsely reporting that the photograph of the woman showed bruised knees,
skinned feet and cut toes.
Falsely reporting that the issue of consent was an issue before the jury: “Damn.
If you can’t get a woman to consensually stay in a moving vehicle, can you
really get her to consensually agree to sex (insofar as lying to her about your
job and your intentions to get her into the car counts as consensual in the
first place)? Obviously, Huon sees things differently.”
Falsely reporting that Mr. Huon lied about his intentions or that he tried to get
complainant into the car.
Falsely reporting that complainant hurled herself out of a moving car.
Falsely reporting that Mr. Huon “raped” the complainant: “It seems to me that
there is entirely too much (alleged) raping going on in this country.”
Falsely inventing a fiction that the issue of consent was submitted to the jury.
The issue of consent was never submitted to the jury and, thus, the jury had to
have found no sexual contact. (Emphasis supplied.)