Gersh v. Anglin

Filing 1

COMPLAINT against Andrew Anglin, filed by Tanya Gersh. (Attachments: # 1 Civil Cover Sheet) (KJH)

John Morrison
Robert Farris-Olsen
MORRISON, SHERWOOD,
WILSON, & DEOLA, PLLP
401 N. Last Chance Gulch St.
Helena, MT 59601
ph. [phone]
fax [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff Tanya Gersh

Morris Dees*
J. Richard Cohen*
David C. Dinielli*
SOUTHERN POVERTY LAW CENTER
400 Washington Avenue
Montgomery, AL 36104
ph. [phone]
fax [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff Tanya Gersh
*Applications for Admission
Pro Hac Vice Pending

UNITED STATES DISTRICT COURT
DISTRICT OF MONTANA
MISSOULA DIVISION
TANYA GERSH,
Case No.:
Plaintiff,
vs.
ANDREW ANGLIN, publisher of
the Daily Stormer,

COMPLAINT FOR INVASION OF
PRIVACY, INTENTIONAL
INFLICTION OF EMOTIONAL
DISTRESS, AND VIOLATIONS OF
THE ANTI-INTIMIDATION ACT

Defendant.
JURY DEMAND

I.
1.

Introduction

This case asserts claims for invasion of privacy, intentional infliction

of emotional distress, and violations of Montana’s Anti-Intimidation Act arising

Page 1

out of a coordinated, repulsive, threatening campaign of anti-Semitic harassment
directed at Tanya Gersh, a Jewish real estate agent living in Whitefish, Montana.
2.

This terror campaign, known as a “troll storm,” was launched by

Andrew Anglin, a well-known neo-Nazi operating out of Ohio.
3.

Mr. Anglin publishes the Daily Stormer, a neo-Nazi web site with

hundreds of thousands of visitors each month that takes its name from the
infamous anti-Semitic Nazi paper Der Stürmer. The Daily Stormer has become
notorious for terrorizing individuals through similar campaigns in the past.
4.

Mr. Anglin turned his horde of anti-Semitic fanatics loose on Ms.

Gersh in a series of Daily Stormer articles he started publishing in December 2016.
These articles caused his followers to overwhelm Ms. Gersh with hundreds of
hateful and threatening anti-Semitic phone calls, voicemails, text messages, emails,
letters, social media comments, and false online business reviews.
5.

Mr. Anglin made his initial call to arms in a December 16, 2016

article that urged “Let’s Hit Em Up[.] Are y’all ready for an old fashioned Troll
Storm? Because AYO [hey you] – it’s that time, fam [family].”
6.

To assist his white nationalist “fam,” Mr. Anglin provided phone

numbers, email addresses, and links to social media profiles for Ms. Gersh, her
immediate family members (including her twelve-year-old son), her friends, and
her colleagues. Mr. Anglin also provided his followers with online discussion

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forums where the followers could trade ideas and information for carrying out the
harassment.
7.

“Just make your opinions known. Tell them you are sickened by their

Jew agenda . . .” Mr. Anglin urged in his December 16, 2016 article. “This is very
important. Calling these people up and/or sending them a quick message is very
easy. It is very important that we make them feel the kind of pressure they are
making us feel.”
8.

Mr. Anglin even urged his followers to seek Ms. Gersh out in person:

“And hey – if you’re in the area, maybe you should stop by and tell her in person
what you think of her actions[.]”
9.

Mr. Anglin also posted a Nazi-fied image of Ms. Gersh in the

December 16, 2016 article that comes up as a top online search result for Ms.
Gersh’s name: a snapshot of Ms. Gersh in front of a fireplace, recalling the
crematoria of Nazi Germany, superimposed with a yellow Star of David bearing
the label “Jude,” German for “Jew,” in reference to the stars Jews were required to
wear by the Nazi regime before and during World War II.
10.

Mr. Anglin’s white nationalist fanatics, operating at his urging and

exhortation, answered his call and directed hundreds of anti-Semitic, hateful,
harassing communications—including death threats—to Ms. Gersh, her family
members, her friends, and her colleagues.

Page 3

11.

These communications contained countless slurs and threats designed

to inflict maximum emotional damage on Ms. Gersh. “[O]ven-dodging Christ
killer,” “Worthless fuckin kike,” and “slimy jewess,” appeared among scores of
other repugnant epithets.
12.

This tsunami of threats arrived by email, social media, and voicemail:

“We are going to ruin you, you Kike PoS [piece of shit] . . . You will be driven to
the brink of suicide. & We will be there to take pleasure in your pain & eventual
end.” Unidentified individuals threatened, “This is the goylash. You remember the
last goylash, don’t you Tanya?” and, “Ratfaced criminals who play with fire tend
to get thrown in the oven.”
13.

To maximize the troll storm’s terrorizing effect on Ms. Gersh, Mr.

Anglin and his followers even targeted her twelve-year-old son. Mr. Anglin called
him a “scamming little kike” and a “creepy little faggot” in his December 16, 2016
article. Then Mr. Anglin’s followers, acting at his urging, harassed Ms. Gersh’s
son with comments on his Twitter feed: “ask your mommy why she hates white
people so much and runs an extortion racket.” A Twitter user with the handle
“Kaiser Wilhelm II,” the name of an anti-Semitic German emperor, tagged Ms.
Gersh’s son in a tweet that read, “psst kid, theres a free Xbox One inside this
oven[.]” The tweet included a photograph of an oven.

Page 4

14.

Mr. Anglin and his followers targeted Ms. Gersh’s husband, as well.

Mr. Gersh received many threatening, hateful, and harassing phone calls,
voicemails, false online reviews of his law firm and emails including this one: “Put
your uppity slut wife Tanya back in her cage, you rat-faced kike. Tell your
scamming son [name omitted] to kill himself, too. Day of the rope soon for your
entire family.”
15.

Mr. Anglin justified his call to arms as retribution against Ms. Gersh,

whom he accused of “extorting” a part-time Whitefish resident named Sherry
Spencer. Ms. Spencer is the mother of Richard Spencer, an infamous white
nationalist who gained notoriety when a video emerged of him spouting racist
rhetoric and declaring, “Hail Trump! Hail our people! Hail victory!” at a gathering
of white nationalists giving Nazi salutes in Washington D.C. soon after the
November 2016 presidential election of President Donald Trump.
16.

By way of background, Whitefish residents’ discontent with the

Spencer family had been simmering for years and reached a fever pitch when the
“Hail Trump” video of Richard Spencer went viral.
17.

The video’s viral release prompted discussion among Whitefish

residents, the vast majority of whom flatly reject Richard Spencer’s hateful
ideology. Some members of the community, believing that Ms. Spencer had not
disavowed her son’s racist views and was continuing to provide financial support

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to Mr. Spencer, considered protesting in front of a mixed-use commercial building
Ms. Spencer owns on Lupfer Avenue in downtown Whitefish.
18.

When members of the community approached Ms. Gersh (one of the

few Jewish residents of Whitefish) about the possible protests, she and others
contacted the building’s commercial tenants to warn them that a protest might
occur outside the Lupfer Avenue building.
19.

One of these tenants asked Ms. Gersh to call Ms. Spencer. Ms. Gersh

declined at first, then reluctantly agreed to consider accepting a call from Ms.
Spencer, thinking it unlikely that Ms. Spencer would actually call.
20.

But Ms. Spencer did in fact place a call to Ms. Gersh. Ms. Spencer

asked, “What should I do? What would you do?” and expressed concern over the
turmoil her building had caused in the community.
21.

When Ms. Spencer lamented the trouble her building was causing,

Ms. Gersh wondered aloud why Ms. Spencer was keeping it and said that if she
were in Ms. Spencer’s situation, she would sell the building, make a donation, and
issue a statement disavowing her son’s views.
22.

Ms. Spencer took these ideas and ran with them, imploring Ms. Gersh

to serve as her real estate agent for the sale. Ms. Gersh agreed.

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23.

Over the Thanksgiving holiday, however, Ms. Spencer apparently

began to get cold feet. Ms. Spencer emailed Ms. Gersh asking to proceed with the
sale independently, without assistance from Ms. Gersh.
24.

Ms. Gersh agreed, and forwarded contact information for several

other real estate agents who could help Ms. Spencer sell her building. These emails
were the last communication between Ms. Spencer and Ms. Gersh.
25.

About two weeks later, and without any warning to Ms. Gersh, Ms.

Spencer published a blog post on the website Medium. Ms. Spencer alleged in her
post that Ms. Gersh had tried to threaten and extort her into agreeing to sell her
building, making a donation, and denouncing her son’s views.
26.

The day after Ms. Spencer’s Medium post, Mr. Anglin began posting

articles on the Daily Stormer parroting Ms. Spencer’s allegations against Ms.
Gersh and calling for a troll storm against her. This first post by Mr. Anglin
immediately triggered the deluge of threatening, hateful, and harassing
communications Ms. Gersh has endured.
27.

Since launching the troll storm, Mr. Anglin has stoked the fire

continuously by publishing new articles on the Daily Stormer about Ms. Gersh or
referencing Whitefish. As of the date of this filing, Mr. Anglin has published thirty
such articles, the majority of which urge his readers to continue their harassment of
Ms. Gersh and her family and associates.

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28.

This ongoing campaign of terror has included threatening and hateful

images of Ms. Gersh, even including this image of her along with her twelve-yearold son and two other members of the Whitefish Jewish community superimposed
on a photograph of the Auschwitz concentration camp:

29.

Ms. Gersh has experienced serious and severe emotional and physical

distress as a result of the harassment, for which she has received medical treatment.
Ms. Gersh has had panic attacks, goes to bed in tears, wakes up crying, startles

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easily, feels anxiety and discomfort in crowded places, has had trouble leaving her
home, and fears answering her phone.
30.

Ms. Gersh’s physical symptoms include weight gain, joint pain, and

hair loss. Overall, she feels like an entirely different person than she did before the
troll storm, as though she has been permanently altered.
II.

Jurisdiction and Venue

31.

This action arises under Montana state law.

32.

This Court has jurisdiction pursuant to Article III of the United States

Constitution and 28 U.S.C. § 1332. The amount in controversy exceeds $75,000,
exclusive of interests and costs, and there is diversity of citizenship.
33.

This Court has personal jurisdiction over Mr. Anglin because he

purposefully directed conduct that resulted in the accrual of a tort action at
residents of Montana, thereby injecting himself into the state’s affairs.
34.

Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b)(2)

because a substantial part of the events giving rise to the claim occurred in
Whitefish, Montana.
35.

Intra-district assignment to the Missoula Division is appropriate

because a substantial part of the events or omissions which give rise to the claim
occurred in Whitefish, Montana.

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III.
36.

Parties

Plaintiff Tanya Gersh is a resident of Whitefish, Montana, and has

lived there for over twenty years.
37.

Ms. Gersh is Jewish and is married to a Jewish man. She and her

husband have raised their two children in the Jewish faith.
38.

Ms. Gersh began selling real estate three years ago, after a long career

as a wedding planner.
39.

Defendant Andrew Anglin is a resident of Ohio.

40.

Mr. Anglin is the founder and editor of a neo-Nazi website called the

Daily Stormer, which appears at www.dailystormer.com.
IV.

Factual Allegations
A. Sherry Spencer

41.

Sherry Spencer is the mother of Richard Spencer, a well-known

anti-Semite, racist, xenophobe, and white nationalist who has been labeled the
leader of the “Alt-Right,” short for Alternative Right.
42.

Ms. Spencer has maintained a personal vacation home in Whitefish,

Montana since 2006 but resides in Dallas, Texas.
B. Richard Spencer
43.

Richard Spencer is president of the National Policy Institute (“NPI”),

a racist, white nationalist think tank associated with the alt-right.

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44.

NPI aims “to elevate the consciousness of whites, ensure our

biological and cultural continuity, and protect our civil rights. . . . [NPI] will study
the consequences of the ongoing influx that non-Western populations pose to our
national identity,” according to its mission statement.
45.

Richard Spencer and NPI rose to national prominence when a video of

Mr. Spencer speaking at a November 19, 2016 white nationalist convening in
Washington, D.C. went viral. In the video, Richard Spencer declares, “Hail Trump!
Hail our people! Hail victory!” as attendees raised their hands in Nazi salutes.
C. The Spencers’ Downtown Whitefish Property
46.

A mixed-use property known as 22 Lupfer stands in downtown

Whitefish.
47.

The Spencers purchased the property on May 1, 2013, under the name

of Roediger Property, Inc., of which Richard Spencer was an owner.
48.

Ms. Spencer claims to have taken Richard Spencer out of the business

entity that held title to the property but has not explained why he was on the title to
the property in the first place or whether he receives income from the rents.
49.

Richard Spencer applied for a building permit for the lot on

September 18, 2014.

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50.

Some residents protested in front of 22 Lupfer around the time of the

building permit application, as the application and Richard Spencer’s racist views
were common knowledge in Whitefish.
D. The Spencers’ Relationship with Whitefish
51.

Several vocal white nationalists who moved from other locations now

live in Whitefish and the surrounding areas, although Whitefish does not itself
have any history of local anti-Semitism.
52.

In response to growing concerns about the possibility of an influx of

white nationalists in the region, and in order to demonstrate its united opposition to
the discriminatory white nationalist message espoused by these vocal few, the
Whitefish community has repeatedly and publicly reinforced its commitment to
treating all residents with dignity and respect.
53.

The Whitefish City Council, for example, approved an anti-hate

resolution in December 2014, declaring “its support of Whitefish community
values that recognize and celebrate the dignity, diversity, and inclusion of all of its
inhabitants and visitors, and protect and safeguard the right and opportunity of all
persons to exercise their civil rights, including the rights of free speech, freedom of
assembly, and freedom from discrimination.”
54.

As the city government was standing up for values of inclusion and

diversity, community organizations began to distance themselves from the

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Spencers. The board of the symphony asked Ms. Spencer to resign and returned
her donation to her. The Wildlife Conservancy rescinded its invitation to her, and
the musical school dissolved its advisory committee in part to end its affiliation
with Ms. Spencer.
E. Protest Rumors
55.

Community discontent with the Spencers grew as Richard Spencer’s

profile expanded to a national stage.
56.

About seventy residents of Whitefish gathered for a meeting during or

around the week of November 13, 2016. Someone in the meeting proposed
boycotting the businesses of Ms. Spencer’s tenants. Although the idea was swiftly
rejected, talk of a boycott or protest nonetheless persisted in the Whitefish
community.
57.

Ms. Gersh heard the rumors of a possible boycott or protest and began

to notice people driving past Ms. Spencer’s building. She even saw three or four
people park, get out of their cars, and photograph the building.
58.

Ms. Gersh grew concerned that a protest would actually take place,

and she tried to warn several of her friends who rented space as commercial
tenants in Ms. Spencer’s building.
59.

At least one tenant had received warnings from a number of

individuals in addition to Ms. Gersh. That tenant called Ms. Gersh asking for

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advice. Later, the tenant called again asking Ms. Gersh to call Ms. Spencer, who
wanted to talk to Ms. Gersh, according to the tenant.
60.

Ms. Gersh initially rejected the idea, then reluctantly agreed to at least

consider accepting a call from Ms. Spencer, thinking it unlikely that Ms. Spencer
actually would call.
F. Ms. Spencer’s Call
61.

A few minutes later, Ms. Spencer did call Ms. Gersh, essentially

asking, “What do I do?” and, “How should I handle this?”
62.

During the call, Ms. Spencer lamented the grief her building had

caused in the community from the very beginning, leading Ms. Gersh to wonder
aloud why Ms. Spencer was keeping the building. Ms. Gersh said that if she were
in Ms. Spencer’s situation, she might sell her building, donate the profits, and
make a public statement.
63.

Ms. Spencer apparently liked these ideas and implored Ms. Gersh to

be the realtor. “Is that something you would help me do?” she asked.
64.

Ms. Spencer gave Ms. Gersh an access code to the building and asked

her to go down to the building in person since Ms. Spencer was still in Texas, so
that Ms. Gersh could look around, decide how to market it, and determine a
proposed list price.

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65.

Ms. Spencer also asked Ms. Gersh for assistance drafting a press

release about the sale and about her rejection of her son’s racist ideology.
66.

Ms. Gersh felt tremendous relief after taking the call from Ms.

Spencer. Ms. Gersh felt that, assuming that all went well, she had been able to help
avert what might have been a difficult and disruptive conflict in her community.
She felt as if she had defused a bomb.
67.

Ms. Gersh called a president of her realty company to ask permission

to charge Ms. Spencer a reduced commission, and the president agreed. Ms. Gersh
made plans to donate her portion of this reduced commission to a community
organization and said as much in an email to Ms. Spencer.
68.

Ms. Gersh personally notified some of Ms. Spencer’s tenants about

the potential resolution. Ms. Gersh also shared this information through Facebook
hoping to quell discussions of boycotts or protests.
G. Ms. Spencer’s Change of Heart
69.

Thanksgiving was a couple days later, and Ms. Spencer spent the

holiday in Dallas, Texas, where she lives and has family.
70.

On December 1, 2016, Ms. Spencer emailed Ms. Gersh, expressing

anguish about the decision to sell the building as well as her relationship with her
son: “Richard’s actions and statements are not only upsetting to the public at large,
but privately have been a source of anguish within our family for several years.”

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71.

Ms. Spencer expressed interest in proceeding independently, without

Ms. Gersh serving as the real estate agent.
72.

Ms. Gersh responded later the same day, “Thanks for the honest and

admirable email. I agree not having me list the building is the right decision. The
more I had been thinking about it, the more I had been feeling it wouldn’t be right
given the delicate situation. It was why I invited you to lunch. I had the desire,
mother to mother, to meet in person and offer support in any way I could. I admire
you for the statement you are making. I want you to know how sorry I am for
having to be the one to break the situation to you. I hope you understand that I was
only trying to save you and your tenants from a public protest and humiliation, in
which I was not even involved in. I am grateful it ended peacefully before it began.
Your actions will have more of a positive impact on this community than you can
ever imagine.”
73.

Ms. Gersh included contact information for another realtor with a

potential buyer. Ms. Gersh again forwarded contact information for a realtor with
another potential buyer the next day. This was the last communication between
Ms. Gersh and Ms. Spencer.

Page 16

H. Ms. Spencer’s Accusations
74.

Two weeks of silence later, on December 15, 2016, Ms. Spencer

published a blog post on the website Medium in which she accused Ms. Gersh of
threatening and harassing her into agreeing to sell the Lupfer Avenue property.
75.

On information and belief, the blog post was ghostwritten by Ms.

Spencer’s son, Richard Spencer.
76.

Ms. Spencer claimed in the post that she “had no intention of

selling . . . until [she] started receiving terrible threats in the last couple of weeks.”
77.

Falsely attributing the “threats” to Ms. Gersh, Ms. Spencer began to

spin a twisted tale of the events that took place, writing that Ms. Gersh “relayed to
me that if I did not sell my building, 200 protesters and national media would show
up outside—which would drive down the property value—until I complied. [Ms.
Gersh’s] other conditions included that I make a public denunciation of my son in
a statement written by the Montana Human Rights Network and that I make a
donation to this organization from the sale of the property.”
78.

Although Ms. Spencer had implored Ms. Gersh to act as her realtor,

even offering her the access code to the building, Ms. Spencer now falsely accused
Ms. Gersh of “shamelessly suggest[ing] that she act as my realtor!”
79.

Ms. Spencer falsely accused Ms. Gersh of seeking “financial benefit

from threats of protests and reputation damage.”

Page 17

I. Mr. Anglin’s Involvement
80.

Mr. Anglin posted the first in a series of thirty articles related to Ms.

Gersh on his website, the Daily Stormer, titled, “Jews Targeting Richard Spencer’s
Mother for Harassment and Extortion – TAKE ACTION!” on December 16,
2016—the day after Ms. Spencer’s Medium post.
81.

The article published contact information for Ms. Gersh and members

of her family and exhorted readers to contact and visit them to “[t]ell them you are
sickened by their Jew agenda . . . .”
82.

Mr. Anglin attacked Ms. Gersh, accusing her of engaging in “clear

and obvious extortion. They are saying ‘give us money, or we are going to
continue this campaign of terror against you and your family.’”
83.

Mr. Anglin also accused Ms. Gersh of “trying to silence Richard

Spencer by harassing his mother.”
84.

Mr. Anglin encouraged readers to call Ms. Gersh “and tell her what

you think. And hey – if you’re in the area, maybe you should stop by and tell her in
person what you think of her actions[.]”
85.

Mr. Anglin published Ms. Gersh’s cell phone number and the address

for the office of Ms. Gersh’s husband.
86.

Mr. Anglin encouraged readers to “leave a review of her business on

Google, and perhaps note that it is [a] front for an extortion racket.”

Page 18

87.

Mr. Anglin included an image of Ms. Gersh in front of a fireplace

superimposed with a yellow Star of David bearing the label “Jude,” German for
“Jew,” with a note that she “posts slut pics on the internet.” Ms. Gersh was
particularly disturbed by this picture because it seemed to have been carefully
selected for its imagery—a Jew next to a blazing fire, reminiscent of Holocaust
atrocities.
88.

Mr. Anglin also published the Twitter handle of Ms. Gersh’s twelve-

year-old son and encouraged readers to take to Twitter and “tell them what you
think of his whore mother’s vicious attack on the community of Whitefish.” Mr.
Anglin called Ms. Gersh’s son a “creepy little faggot” and a “scamming little
kike.” Mr. Anglin further accused Ms. Gersh’s son of “pushing advertising scams”
on his Twitter followers.
89.

Mr. Anglin also published Mr. Gersh’s work phone number and work

email, and included a link for readers to submit a Google review of Mr. Gersh’s
law firm. Mr. Anglin further encouraged readers to “give him a call or stop by his
office and let him know what you think of his wife’s behavior, advise him to get a
leash on that hoe.”
90.

The December 16, 2016 article written by Anglin also included three

photos of the Gersh family: one of Ms. Gersh, one of Ms. Gersh’s twelve-year-old
son, and one of the whole Gersh family.

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91.

Mr. Anglin told readers, “Let’s Hit Em Up[.] Are y’all ready for an

old fashioned Troll Storm? Because AYO – it’s that time, fam.” Mr. Anglin told
readers, “[M]ake your opinions known. Tell them you are sickened by their Jew
agenda to attack and harm the mother of someone whom they disagree with.” Mr.
Anglin also wrote, “This is very important. Calling these people up and/or sending
them a quick message is very easy. It is very important that we make them feel the
kind of pressure they are making us feel.” The headline of his article includes the
phrase: “TAKE ACTION!”
92.

Mr. Anglin also attacked local rabbis, as well as local business

owners. He also spewed his hatred toward Jews generally in his December 16,
2016 article, calling them a “vicious, evil race of hate-filled psychopaths.” Mr.
Anglin wrote, “All of these Jew organizations engage in this transparent extortion
racket with impunity.”
J. Opened Floodgates
93.

As soon as Mr. Anglin’s December 16, 2016 article went live, Ms.

Gersh and her family began to receive hundreds of threatening communications,
including phone calls, voicemails, text messages, emails, letters, social media
comments, and malicious Christmas cards. At last count, Ms. Gersh had received
more than 700 instances of harassment against her family as a result of Mr.
Anglin’s troll storm.

Page 20

Harassment Ms. Gersh Received – Emails
94.

Ms. Gersh received emails through her personal email account

including the following messages, among others:
a) “Ratfaced criminals who play with fire tend to get thrown in the
oven.”
b) “Merry Christmas, you Christ-killer”
c) “Worthless fuckin kike. Eat a dick.”
d) “You’re going to jail for extortion you hateful bitch”
e) “It’s time for you to take a one way ticket to tel aviv”
f) “This is the goylash. You remember the last goylash, don’t you
Tanya? Merry Christmas, you Christ killing Jew.”
g) “We are going to ruin you, you Kike PoS. The same way you do
anyone else. You mother-fuckers are going taste your own medicine,
as we harass you & yours in your public & professional lives. You
will loose money. You will be driven to the brink of suicide. & We
will be there to take pleasure in your pain & eventual end. You have
hated us for so long, now you shall feel the sharp prongs of hatred
from us. I look forward to seeing how the glove feels on the other
hand... ??”

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h) “You and your sayanim really fkd up this time....We are going to
have a field day with you scumbags..If I was you I would suck the
barrel of a shotgun or run to that shithole in the desert you fkn animals
stole from the Arabs...We are going to keep track of you for the rest of
your life and alert any and all ppl you come into contact with of how
much of a piece of shit you are...Please do us all a favor and commit
suicide..Again...lol”
i) “please go fucks niggas and leave white people alone; we don’t need
you, we don’t want you. nothing you do is good You don’t get no
juice unless you squeeze Lemon Obrien, the Third.”
j) “You are a disgusting, vile Jew. You filthy & depraved Jews never
learn; it is your peoples’ behavior responsible for our resentment of
you, which pales in comparison to your hatred for us. You are too
hateful & psychotic a people to belong anywhere but among your
wretched selves. America is changing at a viral pace & thousands of
Goys are learning of your true nature by the day. Leave Sherry
Spencer & the rest of us alone. As for anti-Jewish attitudes, deal with
it! You reap what you sow, and we don’t give a fuck about your
feelings. This is OUR country: you’re merely living here (for now).”

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k) “Gersh, you slimy jewess, do you honestly believe you can force a
woman to sell her property for ‘the lowest commission you can
manage’ by threatening to call in your local kike ‘tolerance’ groups?
In the age of social media? You'd better lawyer up, kike – we’re going
to have your real-estate license over this.”
l) “The days of Jews pushing goyim around appear to be drawing to a
close. I saw the mendacious articles in the lugenpresse today. Oh
come now, surely you Jews can hit harder than that! Merry Christmas,
Christ killer.”
95.

Ms. Gersh received emails through work email accounts as well,

including the following:
a) “Death to Tanya. Death to Tanya. Death to Tanya. Death to Tanya.
Death to Tanya. Death to Tanya. Death to Tanya. Death to Tanya.
Death to Tanya. Death to Tanya. Death to Tanya. Death to Tanya.
Death to Tanya. Death to Tanya. Death to Tanya. Death to Tanya.
Death to Tanya. Death to Tanya. Death to Tanya. Death to Tanya.
Death to Tanya. Death to Tanya. Death to Tanya. Death to Tanya.
Death to Tanya. Death to Tanya. Death to Tanya. Death to Tanya.
Death to Tanya. Death to Tanya. Death to Tanya. Death to Tanya.
Death to Tanya.” This message came from “Satan Your King,”

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reachable by email to “[e-mail]” and phone to “666-6666666.”
b) “You have no idea what you are doing, six million are only the
beginning” This message came from a user with the name “Fuck You
Kike” and the email address “[e-mail].”
c) “We see that nest of dirty kikes over at purewest and Christie’s...We
know your a bunch of sayanim freaks... Make Aliyah you fkn
Bolshevik pcs of shit.. We’re coming!”
d) “FUCK YOU”
e) “Do you think Tanya Gersh and that disgusting pack of Talmudic
freaks who work at PureWest Real Estate are going to get away with
terrorizing Americans?...We shall see what will become of
"PureWest" Real Estate in the coming years.”
f) “Tanya Gersh is an extortionist that should have her real estate license
stripped from her. Disgusting anti american thug. Extorting property
and money from Sherry Spencer. Disgusting”
g) “Tanya Gersh is a disgusting thug that extorts money from people
because of their politcal beliefs. What an un american whore.”

Page 24

96.

Some messages that Ms. Gersh received through her work email

account as a result of Mr. Anglin’s troll storm were copied to her colleagues and
were calculated to cause her to be fired:
a) “I’m very concerned that your company is employing Tanya Gersh
who has launched an illegal, bullying, economic and business attack
against Sherry Spencer in Whitefish, MT. I hope your company will
let Mrs. Gersh go so that she cannot use your business to further
harass innocent people.”
b) “You should fire and disavow Tanya Gersh for her unprofessional,
illegal, and anti-white conduct. Do the rest of your agents engage in
extortion and intimidation as well?”
c) “I’m just writing to let you know I will never do business with your
company and I will also tell everyone I know not to do business with
you until such time as you fire your employee, Tanya Girsh a vile
woman who has taken part in an extortion and harassment campaign
against a resident of Whitefish. Get rid of her or get boycotted.”
d) “Tanya Gersh is extorting a local resident, you are employing
someone engaging in extortion and harassment, is this really the kind
of image you want to portray to the world? Better get rid of her before
this becomes national news and you are implicated.”

Page 25

e) “I notice you are using a realtor who is trying to have my mother
murdered, financially, and by giving her location to a wide public
venue, so the same people behind Black Lives Matter can hunt her
down and kill her like they do police. Please inquire diligently as to
why Ms. Gersh feels she is so omnipotent that she can bully my
mother into selling a property using threats of gangs of violent
protestors to ‘lower her property values? Six million thanks for your
cooperation.” This message was sent by someone claiming to be
Richard Spencer.
Harassment Ms. Gersh Received – Phone Calls
97.

Ms. Gersh answered her phone several times after Mr. Anglin’s initial

article and was subjected to vile threats before she realized what was happening.
She stopped answering her phone altogether unless caller ID showed it to be a
caller she knew and still does not answer unknown calls.
98.

One caller said, “You should have died in the Holocaust with the rest

of your people.”
99.

The calls that most disturbed Ms. Gersh consisted only of the sound of

guns being fired.

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Harassment Ms. Gersh Received – Voicemails
100. Voicemails that Ms. Gersh received included the following
statements:
a) “You filthy piece of trash. You are threatening an old lady. You
worthless piece of shit. I hope you die, you worthless cunt. You stupid
ugly bitch.”
b) “Fuck off Jew.”
c) “Fuck you, you stupid Jew.”
d) “Give me a fucking [unintelligible] ho. You keep talking all that shit.
You think I’m gonna hang up now? You got my dick hard bitch.
[unintelligible] what the fuck you want to do with this shit? Give me
your fucking address. [unintelligible] leave me [unintelligible] right
now. I got your fucking name ho. [unintelligible]”
e) “Oh sorry, I think I have the wrong number, I was looking for the
crematorium.”
f) “You are surprisingly easy to find on the internet. And in real life.”
g) “Why don’t you filthy fucking kikes leave Richard Spencer’s mother
alone. FUCKING KIKES!”
h) “Really disgusted with your pro-Jewish sentiment. Oh my god, how
could you fucking out of the case for your own race, you disgusting

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fucking piece of shit. Oh wait it’s ok when you advocate for Jewish
interests right? Isn’t that the right one? [unintelligible] Fuck off.”
i) “Hello this is Chris. Um I wanted to talk to you about a medium sized
resort town. It’s in Montana. Go kill yourself you fucking Jewish kike.
Alright. Thank you.”
j) “When are you going to move your kike ass to Tel Aviv and start
managing brothels there?”
k) “You fucking filthy kike whore. Don’t you for a second…this is
Trump’s America now.”
l) “Oh hi there Tanya. I wanted to let you know that I find what you did
to Sherry Spencer to be vile and disgusting, you rank bitch. You
fucking people, to say that you engage in this kind of blackmail
against this sweet woman who had nothing to do with the politics of
Richard Spencer you vile cunt, so burn in hell Sherry. Or Tanya.
Tanya Gersh. Yeah. You are a disgusting vile human being. Let that
be known. Thank you.”
m) “You are a horrible nasty human being. I don’t know how you sleep at
night. I hope you get call after call after call that tells you how terrible
of a person you are.”

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n) “Listen here you fucking Jew. You had better back off and leave
Richard Spencer’s mom alone you dirty scumbag. You fucking Jew.
You had better back off of Richard Spencer’s mom. Everybody is
watching you.”
o) “You are a slimy extortionist. Give up what you’re doing. It’s wrong.”
p) “You’re a disgusting person. And you’ll burn in hell after you die.
And you’ll die alone. Fuck you.”
Harassment Ms. Gersh Received – Text Messages
101. Ms. Gersh received text messages that included the following
statements:
a) “What a horrible person you are. A money-grubbing kike whore
extortionist”
b) “Hi Tanya, hundreds of people are reporting you to the Board of
Realtors and other legal agencies due to your illegal extortion
activities. Good luck!”
Harassment Ms. Gersh Received – Letters and Postcards
102. Ms. Gersh also received several harassing letters and postcards.
103. One letter, postmarked December 24, 2016, contained the following
message: “Ms. Gersh: STOP BEING AN ANTI-FREE SPEECH, ANTIAMERICAN (rather, UN-American!) Bolshevik Jew(!) and please APOLOGIZE

Page 29

PUBLICLY like a decent citizen to Sherry Spencer for being a poor real estate
agent.”
104. Another postcard included, “[T]he Jewish Left can burn in hell (that
includes you, lady).”
105. Ms. Gersh also received packets of tourist information for different
states (Kansas, Arkansas, and Nebraska), all addressed to “Tanya Shalom
Gershberg” at Ms. Gersh’s home address, presumably as a result of Mr. Anglin’s
troll storm.
Harassment Ms. Gersh Received – Christmas Cards
106. Ms. Gersh received several malicious Christmas cards.
107. One card, postmarked December 24, 2016, bore the message, “A
happy Christmas to you and to those you love.” The word Christmas was
underlined twice in red ink and accompanied by an explanatory note with more
underlining: “because America is a Christian nation! SORRY! YOU HAVE
ISRAEL.” The sender also hand-wrote, “Dear Tanya, I realize that as a Jew your
ancestors have zero traditions of free speech beyond the shtetl, but Americans
(whose great-great-grandparents weren’t Bolshevik Communists) would greatly
appreciate if you STOPPED persecuting freedom-loving, Christian Americans,
STOP BEING A JEWISH BOLSHEVIK. We know what you’re doing.”

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Harassment Ms. Gersh Received – Social Media Comments
108. Ms. Gersh’s personal Twitter account was tagged in tweets:
a) “do you truly think we’ll forget about this? That you’ll get away with
it? We have a good memory for these things”
b) “Hope everybody sends Tanya a nice Christmas Card telling her
where she can take her business….”
c) “You’re un-American, leave.”
d) “I’m super pissed about this. Going after a mans mother is disgusting,
it’s like going after the children.”
e) “not so nice when it’s you being harassed, is it ;)”
f) “why waste time in a court room? There are other ways,” a user
named BaconBooks&Bullets threatened. Perhaps fearing he’d crossed
a line, he later wrote, “I am [not] advocating violence in any way. I
advocate peace. But I am fairly certain she will disappear soon.”
g) “oooooosh looka dat schnozz!!” one user posted, followed by another
tweet: “beady lil eyes too!”
h) “Remember, creature, that you started this. When we come for you,
remember that it is your fault.”
i) “Hickory dickory dock, the kike ran up the clock. The clock struck
three and Internet Nazis trolls gassed the rest of them.” This user

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included an altered image of Ms. Gersh being sprayed with a cloud of
green gas.
j) “Thanks for demonstrating why your race needs to be collectively
ovened.”
k) “Are you going to take yourself out of the equation, @GershTanya?
#JustDoIt!” This user included memes about suicide.
109. Richard Spencer himself tweeted, “Nasty Tanya never lets ethics or
common decency get in the way of a good deal,” and linked to the emails his
mother published on Medium.
110. As a result of Mr. Anglin’s troll storm, Ms. Gersh received harassing
comments on her YouTube page before she deactivated her account, including,
“Tanya Gersh is a filthy jew[.]”
111. As a result of Mr. Anglin’s troll storm, Ms. Gersh received several
hateful messages on Facebook before she deactivated her account.
Harassment Ms. Gersh Received – Other
112. Ms. Gersh also received hateful and harassing comments on her
personal website, tanyagersh.com.
113. Ms. Gersh took down her website and did not save the content in her
distressed state as a result of Mr. Anglin’s troll storm.

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114. Ms. Gersh removed her wedding planner profiles from popular
wedding websites, including theknot.com, as a result of Mr. Anglin’s troll storm.
115. As a result of Mr. Anglin’s troll storm, someone published a
fabrication about Ms. Gersh on a website called shesahomewrecker.com
suggesting that Ms. Gersh lured another woman’s husband to bed.
116. Ms. Gersh also received subscription notices for far-right news media
that individuals had maliciously signed up for using her email address as a result of
Mr. Anglin’s troll storm, as well as password reset requests showing that
individuals were trying to hack into her accounts.
117. Ms. Gersh received hateful comments through her realtor profiles on
the websites realtor.com and zillow.com as a result of Mr. Anglin’s troll storm.
Harassment Husband of Ms. Gersh Received – Emails
118. In his effort to terrorize Ms. Gersh, Mr. Anglin targeted her husband
as well. Mr. Gersh received numerous threatening, hateful, and harassing emails
about her, including the following:
a) “Put your uppity slut wife Tanya back in her cage, you rat-faced kike.
Tell your scamming son [name omitted] to kill himself, too. Day of
the rope soon for your entire family.”

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b) “Kindly sell your practice and give all money to NPI. Then apologize
to White people for Communism, Trotsky, the Holodomor, the word
'racism,' decades of anti-White propaganda, etc.”
c) “Dont harass Richard Spencers Mother...fucking JEWS!”
d) “JUDAH- SO YOUR WIFE HAS A PROBLEM WITH WHAT
RICHARD SPENCER HAS SAID AND GOES AFTER HIS MOM.
WHAT THE FUCK. WHY DIDN'T YOUR WORTHLESS PIECE
OF SHIT WIFE GO AFTER RICHARD SPENCER, THE PERSON,
INSTEAD? FROM WHAT I'VE SEEN WITH ZIONIST JEWS,
THEY DO NOT LIKE FREE SPEECH. IF A WHITE PERSON DID
WHAT YOUR WIFE DID TO A JEW, THEY WOULD BE FIRED
ON THE SPOT AND A BIG ROUND OF APOLOGIES WOULD
ENSUE. BUT WHEN A JEW PICKS ON AN OLD WHITE
WOMAN, THE JEWISH PRESS RALLYS AROUND THE JEW
INSTEAD OF THE WHITE WOMAN. YOUR WIFE IS PROVING
HITLER WAS RIGHT ABOUT THE JEWS.”
e) In an email with the subject “the holocaust is coming” the sender
wrote “go the fuck back to hell where you came from. filthy hooknosed satanists.”
f) “Gersh, your wife’s vaginal discharge reeks. She’s filthy.”

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g) “Your jewish supremacy has no more business in a Christian society.
We are awake -and on to your subversive and tribal nationalism.
Millions have been affected by your sick supremacist race -and we
had enough. The more you lash out with your hate of Christians, the
more you arouse suspicions of your intent. Keep it up and you’ll soon
find no one willing to stop what your bringing on to yourselves.
Christians had enough jewish hate, its time for you to leave.......”
h) “Your treatment of Richard Spencer’s mother is absolutely disgusting.
It just shows you that Jews are sociopaths, trying to ruin someone
financially because they disagree with her sons political views.”
i) “When will your firm be dismissing Judah Gersh for his family’s
involvement in the criminal activity of extorting Whitefish
residents?...We will destroy ALL your reputations for YEARS to
come in a relentless attack on everything you touch...If you’re
smart...Ditch Gersh!”
Harassment Husband of Ms. Gersh Received – Voicemails
119. Voicemails that Mr. Gersh received included the following
statements:
a) “You know, it really irks my feces that shylocks like you think you
can josh our people and, you know, do the damage you’re doing. I

Page 35

don’t appreciate it. I’m sure no one else appreciates it. I mean Jesus
Christ you guys live in Montana. You’re kind of a super minority
there. At least do your best to fit in. It’s not cool. Leave Richard
Spencer’s mama alone. Thank you and have a nice day. And happy
Rosh Hashanah or whatever the fuck you celebrate for your volcano
demon god.”
b) “Judah, yeah, this is a fellow Montanan here. We’re not far away from
you. And I would suggest that you actually hold out the reins on your
wife, Tanya. You and your kike fucking mentality. Seriously bro, like
pull back. You know, go back to Philadelphia. Or better yet, go back
to Israel. You’re gonna go back, bro, go back.”
c) “Hey you ugly fucking kike. We know what you want to do. You
want to kill all the white people. [Unintelligible] fuck him. Kike rat. I
know what your [unintelligible] said you piece of shit. I know you see
us as worthless animal goyim. We want you and your fucking Jew lies
[possibly, lives], you fucking Jew rat. We know all your crimes, all
your crimes. May Hitler guide us.”
d) “Is your wife still persecuting Sherry Spencer? Cuz if it is, well, I’m
fucking…rein that bitch in. Because you’re at…Your fucking

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business is going to go down. So, you know, get the fucking clue. You
fucking Jew motherfucker you.”
e) “Hi Tanya. If you are messing with Richard Spencer’s mom, you
should really stop. Because if you own a business, you don’t want to
start this war with the internet. The internet will win. The internet
stands behind Richard Spencer. So I’m just warning you that
nothing…we’re really gonna like troll your Facebook, your business
and everything. It will be worse than Pizza Comet. So just letting you
know. That whole thing going on with Pizza Comet will go on with
you.” (“Pizza Comet” is a reference to an incident in November 2016
in which a gunman fired shots in a pizza restaurant as a result of his
believing an Internet hoax that had been hyped on various websites,
including Mr. Anglin’s website.)
Harassment Husband of Mr. Gersh Received – Letters
120. Mr. Gersh received numerous letters at his law office as a result of
Mr. Anglin’s troll storm.
121. One of the letters contained just one phrase, written in blue pencil,
“Juden Raus,” meaning, “Jews out.” The phrase was used by Nazis and is the name
of a Nazi board game akin to Monopoly, the object of which was to collect as
many Jews as possible as the player made his way around the board.

Page 37

Harassment Son of Ms. Gersh Received – Social Media
122. Mr. Anglin presumably knew that there is no surer way to traumatize
a mother than to harass and threaten one of her children, and this is exactly what he
did. He targeted Ms. Gersh’s twelve-year-old child and encouraged his followers to
do so as well, resulting in numerous harassing tweets, including the following:
a) “[A]sk your mommy why she hates white people so much and runs an
extortion racket.”
b) “[Name omitted], I saw ur mom kissing some guy who wasn’t ur dad
inside Casey’s the other day! Ask ur mom about it?”
c) “[Name omitted], your mother is going to get sued and lose
everything. Please put her back in the kitchen where she belongs.”
d) “did your rabbi do this to you?” (The user posted an image of a news
article with the headline “Not Sucking Baby’s Penis After Removing
Foreskin Is Heresy, Haredi Rabbi Says.”)
e) “Keep a leash on yo mama”
f) “psst kid, there’s a free Xbox One inside this oven” The user included
an image of an oven.
g) “Tell your mom to stop with her vicious attacks on Richard Spencer!
WTF is wrong with you freaks?!”

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123. Ms. Gersh’s son received harassing comments on a YouTube video
that he posted as well: “what do you think of your mom harassing Richard
Spencer’s elderly mother and forcing her to sell her business? What does Judah
say, being a lawyer?”
124. The Gershes quickly decided to deactivate their son’s YouTube and
Twitter accounts after realizing he was being targeted as well.
K. Mr. Anglin’s Second Article
125. Mr. Anglin posted another article on December 17, 2016, repeating
the extortion tale about Ms. Gersh and making several demands: “On behalf of
global Nazism, I am hereby demanding that the Jew Tanya Gersh sell her property
in Whitefish and donate the money to [the National Policy Institute, the white
nationalist organization of which Richard Spencer is president], issue an apology
to the community, the white race and goyim everywhere, and immediately move to
Israel.”
126. Mr. Anglin threatened, “So you have to go back, Tanya. You simply
are not welcome in this country. We’ve had enough, Tanya. This is the goylash.
You remember the last goylash, don’t you Tanya?”
127. Mr. Anglin goes on: “Yeah. You’re gonna wanna dip out before this
thing really gets started. Because I’ll tell you want [sic], Tanya. This fire is already
rising.”

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128. Mr. Anglin continues: “There’s only one place this road ends. Keep
Up the Pressure. Keep calling these people. Keep emailing them. Make it known to
them that the jig is officially up. We aren’t playing this game anymore. The entire
list of contact information is in my last post. Go do it.” Mr. Anglin posted a link to
the first article he published about Ms. Gersh on December 16, 2016.
L. Mr. Anglin’s Continued Posts
129. Mr. Anglin has continued to publish articles about or relating to Ms.
Gersh.
December 19, 2016 Article
130. Mr. Anglin repeated his erroneous tale about Ms. Gersh for a third
time and again encouraged his readers to contact Ms. Gersh in a December 19,
2016 article titled, “Lying Jew Media Says Daily Stormer ‘Threatened’ Jewish
Racketeers Extorting the Spencer Family,” writing, “We will keep putting pressure
on these Jews, Tanya Gersh in particular, until they stop harassing the Spencers
and issue an apology for this brutal Jewish racketeering. . . . So please, if you
haven’t contacted these people to let them know what you think of their deranged
actions, do so. The contacts are all in this article.” Mr. Anglin provided a link to
his December 16, 2016 article.
131. Mr. Anglin also promised to provide an “extended contacts list, where
you will be able to tell the business associates of these people what you think of

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their actions, and ask that they cut their business ties with the Jews engaged in this
campaign of harassment and extortion against the Spencers.”
December 21, 2016 Articles
132. Mr. Anglin repeated his extortion tale about Ms. Gersh for a fourth
time in a December 21, 2016 article.
133. Mr. Anglin also advocated confrontation in this article, writing, “As
with all terrorism, whenever you pay the ransom, they keep doing it, the only thing
that will stop this madness is through direct (and fully within the confines of the
law) confrontation.”
134. Mr. Anglin posted additional hateful content designed to stoke his
followers’ bile and emotionally harm Ms. Gersh in a second article published
December 21, 2016.
135. Mr. Anglin wrote in this second article, “I can also photoshop pictures
of your face and that of your scamming spammer rat son onto Nazi propaganda
posters from the 1930s! No one can stop me from doing this, Tanya! It’s in the
Constitution!” and included the following image of Ms. Gersh and her son
superimposed onto a Nazi propaganda poster:

Page 41

136. Mr. Anglin promised to continue attacking Ms. Gersh: “Well,
tomorrow we’re kicking it up a notch – so get ready. I am going to post an entire
list of business . . . ties with these individuals due to their unethical practices of
threats, harassment and extortion of family members of people they disagree with.”
137. Mr. Anglin concluded this second article with “Hail Victory.”

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December 22, 2016 Articles
138. Mr. Anglin exhorted readers to “catchup quickly and join this MEGA
TROLLSTORM” in a December 22, 2016 article.” He then published the contact
information for Ms. Gersh’s employer and others with whom she is associated.
139. Mr. Anglin commanded, “GET TO IT! If you are a true warrior for
the cause, you will make time to contact all of these people. I’m serious. We are all
busy. Trust me, I know about busy. But this is so, so important. We have to stand
up to these people, and we have to force an apology from Tanya Gersh . . . So, if
you don’t have time: make time. Call and email all of these people. Do it right
now.”
140. Apparently believing that a disclaimer would exculpate him, Mr.
Anglin wrote, “AND AS ALWAYS: ABSOLUTELY NO THREATS OF
VIOLENCE, SUGGESTIONS OF VIOLENCE OR ACTS OF VIOLENCE.
DON’T DO IT. IT JUST GIVES THEM POWER. THEY ARE ALREADY
CLAIMING THEY ARE GETTING DEATH THREATS, WHILE THE LOCAL
POLICE AND THE FBI ARE DENYING IT AND THIS MAKES THEM LOOK
STUPID. KEEP EVERYTHING ON THE LEVEL.”
141. The next sentence in the article belies his claim: “For the next phase
of our plan against Jew Gersh and Jew Love Lives Here, we are planning an armed
protest in Whitefish.”

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142. Moreover, Ms. Gersh received a threatening email that very day:
“Leave Whitefish, leave Montana. Change your name, change your occupation.
Don’t let me see your face or we both will suffer as a result. You – immediately,
me when they get me. LEAVE.” This email was signed “AA,” the initials Mr.
Anglin used to sign an editor’s note in a February 3, 2017 Daily Stormer article.
143. After discussing logistics of the armed protest, Mr. Anglin posted an
image of Ms. Gersh, her son, and two other Jewish residents of Whitefish at
Auschwitz concentration camp, similar to the image featured above.
December 23, 2016 Articles
144. Mr. Anglin claimed that Love Lives Here, an anti-hate group in
Whitefish, was “throwing Tanya Gersh under the bus,” in his December 23, 2016
article, “WHITEFISH GAME CHANGER: Love Lives Here Throws Tanya Gersh
Under the Bus!” even though Love Lives Here continuously supported the Gershes
and other victims of Mr. Anglin’s troll storm.
145. Mr. Anglin then encouraged his readers to contact businesses and
organizations associated with Ms. Gersh, writing “Earlier today, I made a huge
post with contact information for business contacts of the racketeers and their
supporters. GO CONTACT THESE PEOPLE NOW! If they don’t answer the
phone, email them or contact them through Twitter . . . .”

Page 44

146. Mr. Anglin again included the altered photograph of Ms. Gersh, her
son, and two other Jewish residents of Whitefish at the Auschwitz concentration
camp, this time with a red filter.
147. Mr. Anglin published two other articles on December 23, 2016 that
referenced Whitefish.
148. In the first, Mr. Anglin attributed a school bus crash in Whitefish to
“Kek,” an alt-right meme.
149. In the second, the article published by Mr. Anglin claimed that “Jews
in Montana, Whitefish [sic] are . . . persecuting anyone who dares to speak out,”
and linked to the December 21, 2016 article featuring an image of Ms. Gersh and
her son superimposed on a Nazi propaganda poster.
December 26, 2016 Article
150. Readers were encouraged to listen to Richard Spencer’s radio
appearance on the David Duke Show in which Spencer speaks about Ms. Gersh in
a December 26, 2016 article published by Mr. Anglin in the Daily Stormer.
151. Richard Spencer said in the interview, “I know bad things about
Tanya Gersh,” and accused her of extorting his mother.
152. Richard Spencer repeated lines from the Medium article almost
verbatim.

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153. The Medium article contains the text, “In other words, I poured my
heart and soul into this project,” and Richard Spencer said, “She poured her heart
and soul into it, as she wrote in a letter that you can read online.”
154. The Medium article also contains the text, “Whatever you think about
my son’s ideas — they are, after all, ideas — in what moral universe is it right for
the ‘sins’ of the son to be visited upon the mother?” Mr. Spencer said, “And,
effectually, the—the sins of the son are being visited upon the mother.”
December 27, 2016 Article
155. Mr. Anglin encouraged readers to listen to a radio interview of
himself on the David Duke Show in a December 27, 2016 article.
156. In the interview, Mr. Anglin recounts the false story about Ms. Gersh
extorting Ms. Spencer for the fifth time.
December 28, 2016 Article
157. Mr. Anglin recounted the false story of Ms. Gersh extorting Ms.
Spencer for a sixth time in a December 28, 2016 article, this time in the context of
deriding elected Montana officials for releasing a statement disavowing antiSemitism.
158. Mr. Anglin likened Ms. Gersh to ISIS and Ms. Spencer to a public
execution victim, writing, “Gersh had provided Spencer with a pre-written
apology/confession, which they asked her to read to the community. This practice

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is also popular among ISIS, which usually requires public execution victims to
read aloud a scripted apology/confession before death.”
January 5, 2017 Article
159. Mr. Anglin updated his followers on his plans for an armed protest in
a January 5, 2017 article.
160. Mr. Anglin published a copy of his permit application for an armed
protest and announced the official title of the event as the “James Earl Ray Day
Extravaganza” in honor of the man convicted of murdering civil rights icon Martin
Luther King, Jr.
161. Mr. Anglin claimed that the march was supposed to end at Ms.
Gersh’s home, “but we decided it would be too cold. We will instead simply march
through the center of town, ending at a Memorial Park where several speakers will
speak.”
162. Mr. Anglin announced that marchers would include white nationalists
from the U.K., Sweden, France, and Greece.
163. Mr. Anglin confirmed that a representative of Hamas would attend
and “give a speech about the international threat of the Jews,” posting a
photograph of heavily armed men in masks:

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164. Mr. Anglin posted a clip of the song “Be Prepared” from the Disney
film The Lion King, and wrote, “And they will rue the day, as they see two hundred
skinhead Alt-Right Nazis marching with a guy from Hamas carrying machine guns
through the center of their town!”
165. Mr. Anglin concluded his article with a photograph of armed Nazis
marching:

Page 48

January 6, 2017 Article
166. The story about Ms. Gersh harassing Ms. Spencer was posted on
Anglin’s Daily Stormer for the seventh time in a January 6, 2017 article
summarizing the Alt-Right’s 2016 activity: “Dec16 – Harassment and extortion of
Richard Spencer’s mother by Jewish activists. Proving that there is always a profit
to be made, Montana realtor (((Tanya Gersh))) had the gall to suggest Richard’s
mother do the following: 1. Denounce her son (as opposed to just disavowing his
beliefs, which she did) 2. Sell the building and make ‘a donation to human rights
efforts’ (after threatening to organize protests outside the property, which would
lower its value).”
167. White nationalists use triple parentheses to signify that a name
belongs to a Jewish person.
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168. The article opened with an image of Donald Trump hugging Pepe the
frog, an alt-right meme:

January 8, 2017 Articles
169. The story about Ms. Gersh was repeated on Anglin’s Daily Stormer
for the eighth time in a January 8, 2017 article, in which the planned actions of the
Jewish Defense League, a radical organization, were attributed to Mr. Anglin’s
own “planned march in Whitefish, Montana to support Spencer after his mother
was illegally harassed by Jewish racketeers.”
170. The article expressed Mr. Anglin’s typical anti-Semitism: “These
Jews can’t even admit that what their people did to Spencer’s mother was wrong.
They are biologically incapable of admitting that their people could ever be at fault

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for something. If these Jews actually do end up visiting Whitefish to stir up
trouble, it will only further highlight the disgusting and degenerate behavior of the
Jew that much more.”
171. Mr. Anglin posted a second article that day denigrating the World
Jewish Congress President Ronald S. Lauder for demanding “that authorities in
Montana immediately put a stop to an armed march being planned by neo-Nazis in
the town of Whitefish on January 15.”
172. Mr. Anglin falsely claimed in this article that Ms. Gersh had “pending
litigation against her for her racketeering activities.”
173. Mr. Anglin wrote that he was in communication “with our anti-Jew
comrades in Hamas, as we prepare to join hands in Whitefish and march against
the Jews, and you just can’t even believe what these poor bastards are dealing with
over there.” Elaborating, Mr. Anglin wrote, “These Jews in Israel are just running
around killing babies left and right! They took their land! Just went ahead and
straight jacked it! Can you believe it??? No wonder they’re so angry!”
174. Mr. Anglin reiterated his interest in the armed protest, sharing a quote
from the Whitefish police chief in a mainstream news article and writing, “Dial
seems like a pretty cool guy, and I don’t think he’s going to block us from keeping
our weapons LOADED.”

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175. Mr. Anglin provided more details about his plans for an armed
protest: “Currently, we have 178 skinheads being bussed in from the Bay Area on
6 large buses. Including international representatives, we will have a total of
around 225 people marching through the city, though only about a third will be
armed with machine guns. Others may carry baseball bats or swords, we haven’t
decided yet.”
176. Mr. Anglin concluded the post with an image of Nazis marching:

January 10, 2017 Articles
177. Mr. Anglin’s followers were directed to listen to another episode of
the David Duke Show featuring Richard Spencer in a January 10, 2017 article on
the Daily Stormer.
178. The section of the interview about Ms. Gersh was highlighted for Mr.
Anglin’s readers: “Richard Spencer also updated listeners on the efforts by Jewish

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extremists to wreck and extort money from his mother’s business in Whitefish,
Montana as a means of silencing Richard’s own voice.”
179. Readers were encouraged to “share [the interview] widely.”
180. In the interview, Richard Spencer repeated the accusations he made
against Ms. Gersh in his December 26, 2016 interview with David Duke: “There
was this nasty woman named Tanya Gersh, who was attempting to force my
mother to sell her property and to profit from it all by being her broker. It was just
a really terrible situation.”
181. David Duke interjected, “Well she’s totally consistent with the
Talmud and the Halacha. That’s for sure.”
182. Richard Spencer said, “I’m afraid I agree with you.”
183. David Duke recounted the extortion narrative Mr. Anglin continues to
promote: “Your mother, who has no political association with you, of course, she
doesn’t agree necessarily – you have made a statement she doesn’t agree with your
politics, was targeted in an attempt to destroy her financially, destroy her business,
and to basically, profit from it by a number of Jewish elements in Montana.”
184. Richard Spencer responded, repeating the extortion narrative yet
again, “I mean, Tanya Gersh, who was the person involved in the shakedown of
my mother, she just expected her to sell her property, denounce me. I would leave
town, and it would just be an easy victory. But the fact is, my mother fought back.

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She wrote about what happened. She actually released the e-mails online. That was
a huge thing.”
185. Mr. Anglin updated his followers on the armed protest in another
article published January 10, 2017.
186. In this post, Mr. Anglin revealed that the city government of
Whitefish denied his permit application for the armed protest: “The local
government of Whitefish, Montana, where we have been planning to have an
armed Neo-Nazi march against local Jewish terrorists, have attempted to cockblock
us by denying our permit based on some alleged technicality.”
187. Mr. Anglin indicated that he would probably postpone the march and
concluded this post with “Hail Victory.”
January 11, 2017 Article
188. Mr. Anglin confirmed that he would postpone the armed protest in a
January 11, 2017 article, but promised more guns at the rescheduled event: “[W]e
will need to postpone the planned march. We will of course be
rescheduling . . . and the march will be bigger and have more guns and special
guests than we originally planned.”
January 18, 2017 Article
189. Mr. Anglin repeated the extortion narrative about Ms. Gersh for the
ninth time when he published a January 11, 2017 article on the Daily Stormer

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reporting that a group of anti-fascist protesters in Whitefish “came out to defend
real estate speculator (((Tanya Gersh))), who sought to use Richard Spencer’s
status to mobilize Whitefish Jewry into intimidating his mother into selling her
property to Gersh and leaving the town.”
190. The article contained a link to Mr. Anglin’s December 16, 2017
article containing Ms. Gersh’s contact information.
January 19, 2017 Articles
191. Mr. Anglin published an article titled “Whitefish: Christ-Killing Kikes
Trying to Have Daily Stormer Classified as a Terrorist Group…!” on January 19,
2017.
192. Mr. Anglin began his article, “The nerve of these Jews. Shaking my
damn head. It never ceases to amaze.”
193. Mr. Anglin repeated the extortion narrative about Ms. Gersh for the
tenth time in his January 19, 2017 article, writing, “It was the Jew Tanya Gersh
who threatened Richard Spencer’s mother. It was the Jewish community of
Montana . . . which backed up Gersh in her campaign of extortion. We simply
responded. And yet, somehow, we are the bad guys. And the Jews are the victims.”
194. Mr. Anglin characterized the Holocaust as a hoax and attempted to
draw a connection to Whitefish: “This is just like another Holocaust, a hoax

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created to defame good and well-meaning people who are trying to protect
themselves and their kinfolk from the international Jewish terror network.”
195. Mr. Anglin denigrated all Jewish people: “The Jews are a vicious,
diseased race of evil monsters, and it is they who deserve to be banned as a
terrorist group. Their entire existence, going back all through their recorded
history, has been a series of terrorist incidents.”
196. Mr. Anglin posted a threatening image in this article:

197. Mr. Anglin concluded this article with the statement, “Hitler was
right,” and “Hail Victory.”
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198. Mr. Anglin referenced Whitefish in another January 19, 2017 article,
“The Daily Stormer was attempting peaceful assembly in Whitefish, Montana
when we were shut down by kikes. These people are terrorists. At least most of
them are. Paid rioters, Jews and other psychopaths.”
199. Mr. Anglin posted a third article on January 19, 2017 denigrating Ms.
Gersh. Having received word that Jewish leaders from the U.S. and Canada met
with the Governor of Montana to thank him for speaking out against antiSemitism, the article suggested that “procurers of hate and baby-fellatio are flying
in from all over the place to Whitefish, Montana – not for any just or noble cause,
but to provide cover for a member of the Kosher Nostra, Tanya Gersh, who was
trying to extort the mother of Richard Spencer (who doesn’t even say much about
Jews to begin with).”
200.

“The problem is that these Jews are fighting against an earthquake

that no amount of criminal activity or lying can contain,” the article bragged. “It’s
the zeitgeist, and no Tay-Sachsoid can will himself over this emerging historic
spirit. Their tricks aren’t working anymore.”
February 3, 2017 Article
201. Mr. Anglin mentioned Whitefish in an editor’s note attached to an
article he published on the Daily Stormer on February 3, 2017 opposing the

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ACLU: “When the publisher of this website emailed the ACLU about our
proposed march on Whitefish, they never replied.”
202. Mr. Anglin signed the editor’s note with “AA,” his initials.
203. Ms. Gersh received harassing communications signed with the initials
“AA.”
M. Effects on Ms. Gersh
204. Ms. Gersh has experienced serious and severe emotional and physical
distress as a result of Mr. Anglin’s troll storm and related activities. Since the troll
storm, she feels like a completely a different person than she was before. Ms.
Gersh has experienced panic attacks, goes to bed in tears nearly every night, wakes
up crying nearly every morning, startles easily, feels anxiety and discomfort in
crowded places, has had trouble leaving her home, and fears answering her phone.
205. Ms. Gersh’s physical appearance has changed as a result of the
harassment from Mr. Anglin’s troll storm and related activities. She has rapidly
gained weight and started losing her hair.
206. Ms. Gersh has sought and received medical care to relieve the
symptoms of her distress. Her primary care physician has, for the first time,
prescribed antidepressants, valium, and acupuncture. She has also started to going
to trauma therapy twice a week.

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207. Ms. Gersh has been unable to pursue her passions and hobbies. Before
the attack, she went ice skating three times a week, worked out almost daily, and
went skiing on weekends. Since the attack, physical pain in her shoulders and hips
stemming from the extreme distress she has experienced has prevented her from
doing any of these things. Ms. Gersh has developed bursitis from carrying herself
differently—she has begun compulsively rounding her shoulders in a subconscious
effort to defend herself from attack.
V.

COUNT ONE
Invasion of Privacy

208. Ms. Gersh incorporates into Count One the allegations of the
foregoing paragraphs.
209. Mr. Anglin’s conduct as described above and the conduct of his
followers who acted at his urging amounts to a course of hounding Ms. Gersh.
210. The conduct of Mr. Anglin and his followers who acted at his urging
has become a substantial burden to Ms. Gersh’s existence.
211. Mr. Anglin’s conduct was wrongful.
212. Mr. Anglin knew that his followers’ conduct constituted a breach of
duty and, in fact, it was his intended result.
213. Mr. Anglin acted in an extreme and outrageous manner by calling for
a troll storm against Ms. Gersh.

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214. Mr. Anglin gave his followers substantial assistance in harassing Ms.
Gersh by continually posting stories about, and posting contact information for,
Ms. Gersh, her family members, and her colleagues.
215. Mr. Anglin gave his followers instruction and encouragement to
harass Ms. Gersh by exhorting them to contact Ms. Gersh and by repeating false
stories about Ms. Gersh and Jews generally to stoke his followers’ emotions.
216. Mr. Anglin’s conduct was a substantial factor in bringing about the
harm that Ms. Gersh experienced.
217. Mr. Anglin is liable to Ms. Gersh for an invasion of Ms. Gersh’s
privacy in an amount greater than $75,000 to be determined at trial.
VI.

COUNT TWO

Intentional Infliction of Emotional Distress
218. Ms. Gersh incorporates into Count Two the allegations of the
foregoing paragraphs.
219. Mr. Anglin’s conduct was designed to inflict maximum emotional
distress on Ms. Gersh.
220. Mr. Anglin knew that serious and severe emotional distress to Ms.
Gersh was certain or substantially certain to result from his conduct.
221. Mr. Anglin could reasonably foresee the consequences of his conduct
and actually intended such consequences to occur.

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222. Mr. Anglin’s conduct was extreme and outrageous and went beyond
all possible bounds of decency.
223. Ms. Gersh has experienced serious and severe emotional distress as a
direct and proximate result of Mr. Anglin’s conduct.
224. Mr. Anglin is liable to Ms. Gersh for the emotional distress he caused
in an amount greater than $75,000 to be determined at trial.
VII.

COUNT THREE

Montana Anti-Intimidation Act
225. Plaintiff incorporates into Count Three the allegations of the
foregoing paragraphs.
226. Ms. Gersh was attempting to exercise her legally protected rights,
including her free speech rights.
227. Ms. Gersh was injured, harassed, and aggrieved by the troll storm Mr.
Anglin orchestrated against her.
228. Many of the harassing communications constituted threats or
intimidation giving rise to a civil cause of action pursuant to Mont. Code Ann. §
27-1-1503(2).
229. Mr. Anglin is liable to Ms. Gersh for violating the Montana AntiIntimidation Act in an amount greater than $75,000 to be determined at trial.

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VIII.

COUNT FOUR
Malice

230. Ms. Gersh incorporates into Count Four the allegations of the
foregoing paragraphs.
231. Mr. Anglin’s conduct constitutes actual malice within the meaning of
Mont. Code Ann. § 27-1-221 entitling Ms. Gersh to punitive damages.
232. Punitive damages should be assessed against Mr. Anglin in order to
punish and deter such intentional and malicious conduct.
IX.

CLAIM FOR RELIEF

For the foregoing reasons, Plaintiff respectfully requests that the Court grant
the following relief:
A. General damages;
B. Special damages;
C. Compensatory damages;
D. Consequential damages;
E. Nominal damages; and
F. Punitive damages, all in amounts to be determined at trial; and
G. Attorney fees, costs, and disbursements, to the extent permitted by law;
and
H. Such other and further relief as the Court deems just.
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X.

JURY DEMAND

233. Plaintiff hereby demands a trial by jury on all issues triable by a jury.

Respectfully submitted,
/s/ John Morrison
Attorney for Plaintiff Tanya Gersh
on behalf of all Attorneys for Plaintiff

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