Gavin de Becker & Associates brought this suit against the authors and publishers of a book called Among the Mansions of Eden. After several motions in Court and several depositions, the matter was amicably resolved.
JOHN H. LAVELY, JR. (BAR NO. 53954) PAUL N. SORRELL (BAR NO. 126356) LAVELY & SINGER PROFESSIONAL CORPORATION 2049 Century Park East, Suite 2400 Los Angeles, California 90067-2906 Telephone: (310) 556-3501 Facsimile: (310) 556-3615 Attorneys for Plaintiffs GAVIN DE BECKER & ASSOCIATES, GAVIN DE BECKER, MICHAEL LAFEVER, ROBERT MARTIN, JEFF MARQUART, JOSH DESSALINES, ELLEN PRYSTAJKO, GEOFF TOWLE, DAVID FALCONER SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
I. THE ISSUE AT HAND 1. Defendants David Weddle and Howard Libes wrote a book entitled Among the Mansions of Eden , hereinafter referred to as "the Book." Defendant William Morrow & Company published, marketed and distributed the Book, and continues to support its distribution and marketing today. As set forth in further detail below, Plaintiffs contend that the Book contains numerous false and defamatory statements. 2. Plaintiff Gavin de Becker is widely regarded as a leading expert in the prediction and management of violence. He is a #1 National Bestselling author whose books on violence and safety are published in fourteen languages. He is a three-time Presidential Appointee, a Senior Fellow at UCLA's School of Public Policy & Social Research, and an advisor to the Central Intelligence Agency, the U.S. Supreme Court, and the United States Supreme Court, among many others. Plaintiff Gavin de Becker & Associates (formerly Gavin de Becker, Inc.) is Mr. de Becker's 100-member consulting and service firm, the most respected and best-known in the field, with a history of 30 years and a long-earned reputation for quality and integrity. Plaintiffs LaFever, Martin, Marquart, Prystajko, Dessalines, Towle, and Falconer are Principals in the firm. 3. Plaintiffs advise and serve at-risk individuals, advise Government agencies, and advise the general public through books and other media. Their reputation for integrity, quality, and honor is a key asset, and damage to that reputation was foreseeable, and as Plaintiffs are informed and believe and thereon allege, intended by the authors. 4. Chapter 7 in Among the Mansions of Eden contains a lengthy discussion of Mr. de Becker's career (see Exhibit "A" hereto). The brief chapter contains at least thirty factual errors, false and damaging assertions, hurtful implications, erroneous conclusions, and direct statements that constitute, among other things, libel and trade libel. The authors had at their immediate disposal and even amidst their research material, all of the information needed to write an accurate and fair chapter. The authors and publishers had every opportunity to check the accuracy of their assertions, either directly with Mr. de Becker or Robert Martin, the Vice-President of Gavin de Becker & Associates -- yet they did not do so. The Book was undertaken without even the basic research of a full periodical literature review, or the basic practice of adequate fact checking. 5. Defendants instead chose to support their outrageous and libelous statements through almost sole reliance upon people seeking to compete with Gavin de Becker & Associates, some of whom had past relationships with Plaintiffs that would suggest to any capable author that their input would not be reliable. Additional investigation and inquiry is clearly in order when relying upon competitive firms and aspiring competitors for information about a leading firm. 6. The extensive passages regarding Mr. de Becker constitute the most objectionable form of journalism masquerading as credible information, clearly calculated to place Plaintiffs in a false, damaging and unfavorable light -- all of which constitutes trade libel and defamation, resulting in foreseeable harm to Mr. de Becker, to his business, and to each of his 100 associates. 7. The Plaintiffs in this case provide services and consultation to many of the Nation's most at-risk citizens and officials. Plaintiff Gavin de Becker provides guidance on avoiding violence to millions of people through his books and other media. The selection of a service for protecting at-risk persons can be a life and death matter, and there is a widely held standard of care and caution to be applied to published reports that might influence such decisions. For example, a government agency mandated to conduct such reviews (e.g., the Food & Drug Administration, the Consumer Products Safety Commission) does not tell key consumers that a life-saving product or service is defective unless knowledgeable, qualified, unbiased experts reach that conclusion after an extensive inquiry. But the authors and publishers of Among the Mansions of Eden applied no care whatsoever in telling readers (predictably including at-risk persons) that Plaintiffs are unethical, charge "exorbitant" prices, are inexperienced, have no professional qualifications, disparage their competitors, and care only about money. All of this is stated editorially, as fact, without balancing information or reasons that the reader could assess. 8. Defendant William Morrow & Company received notice of the misrepresentations, inaccuracies, libelous statements, damaging assertions, and refused to take effective steps that might correct the errors or help reduce the obvious harms already suffered and foreseeably to be suffered in the future. 9. The Plaintiffs are informed and believe and thereon allege that, due to Mr. de Becker's decision not to participate in an interview for the Book, an interview Defendants very much wanted and considered "essential," Defendants retaliated through intentionally depicting Plaintiffs in a false and outrageous light. Their publication of false and unfavorable claims and implications would foreseeably damage any firm's reputation and competitive advantage. Plaintiffs are informed and believe and thereupon allege that the evidence will support Plaintiffs' claim of malice against Defendants. 10. Through its false, unfair, and unfavorable assertions, conclusions, and implications, Defendants' biased, inaccurate, and misleading Book has already caused irreparable harm to Plaintiffs. By the refusal to correct the many damaging and misleading errors, and by the continued wide dissemination of the Book, Defendants have increased the harm caused by the Book, and extended the period of harm. This action for trade libel, defamation and unfair business practices seeks damages in an amount to be determined. II. THE PARTIES TO THIS DISPUTE 1. Plaintiff Gavin de Becker & Associates is, and at all times mentioned herein was, a corporation organized under the laws of the State of California with its principal place of business in the County of Los Angeles. 2. Plaintiff Gavin de Becker is, and at all times mentioned herein was, a resident of the County of Los Angeles. 3. Plaintiff Michael Lafever is, and at all times mentioned herein was, a resident of the County of Los Angeles. 4. Plaintiff Robert Martin is, and at all times mentioned herein was, a resident of the County of Los Angeles. 5. Plaintiff Jeff Marquart, is, and at all times mentioned herein was, a resident of the County of Los Angeles. 6. Plaintiff Josh Dessalines, is, and at all times mentioned herein was, a resident of the County of Los Angeles. 7. Plaintiff Ellen Prystajko, is, and at all times mentioned herein was, a resident of the County of Los Angeles. 8. Plaintiff Geoff Towle is, and at all times mentioned herein was, a resident of the County of Los Angeles. 9. Plaintiff David Falconer is, and at all times mentioned herein was, a resident of the County of Los Angeles. 10. Plaintiffs are informed and believe and thereon allege that Defendant William Morrow & Company is, and all times mentioned herein was, a corporation organized under the laws of the State of New York conducting business in, among other places, the County of Los Angeles. 11. Plaintiffs are informed and believe and thereon allege that Defendant David Weddle ("Weddle") is an individual who, at all relevant times herein, conducted business in the County of Los Angeles. 12. Plaintiffs are informed and believe and thereon allege that Defendant Howard Libes ("Libes") is an individual who, at all relevant times herein, conducted business in the County of Los Angeles. III. THE FACTUAL BACKGROUND OF THE CASE 1. Plaintiff Gavin de Becker & Associates is a consulting company that is engaged in advising media figures, public figures, government agencies, universities, corporations, and other organizations on matters of violence prediction, prevention, and management. Its founder, Gavin de Becker, a three-time Presidential appointee, is a well-known expert in the field of evaluating and managing situations that might escalate to violence. He is the author of three best-selling books on the topic, and is a Senior Fellow at UCLA's School of Public Policy and Social Research. He has served two terms on the National Institute of Justice Advisory Board and one term on the Governor's Advisory Board at the California Department of Mental Health. Mr. de Becker designed an evaluation system called MOSAIC, currently used by the United States Supreme Court for screening threats to the Justices, by the United States Marshals Service for threats to federal judges, by state police agencies in eleven states, and by the Central Intelligence Agency, among others. Mr. de Becker has served as Co-chair of the Domestic Violence Council Advisory Board. He funds the L.A. County Domestic Violence Hotline. A long-established advocate for and supporter of domestic violence victims, Mr. de Becker received the Sojourn Battered Women's Services Humanitarian Award in 1997, and he is recipient of the 1999 NOVA award from the National Association of Victim's Assistance. His MOSAIC system was selected by the National Victims Center as one of the ten "most promising new technologies for victims." 2. Weddle is the author of two books, If They Move, Kill 'Em , and the book central to this lawsuit, Among the Mansions of Eden . 3. Libes is the former personal manager of a music group called Cherry Poppin' Daddies . He served as a researcher, interviewer, and writer on the Book. 4. Defendant William Morrow & Company published the book, and continues to support its distribution marketing. 5. In September of 2000, Plaintiff de Becker received a mailing, and subsequent emails from Defendant Libes, who claimed to be authoring of the Book. Defendant Libes asked for an interview. In his reply, Mr. de Becker declined to schedule an interview and noted pursuant to his usual policy: "I say No to all interviews these days (occasional exception: Oprah or 60 Minutes), so email's all I've got, and even that's tough." 6. Defendant Libes again wrote to encourage an interview. Though still declining, Mr. de Becker suggested to the author that another person (Robert Martin) would be an "appropriate interview." 7. Defendant Libes wrote again indicating he would interview Mr. Martin. He never did. 8. In his several communications, Defendant Libes stressed the importance of Mr. de Becker's interview, even characterizing it as "essential":
10. Plaintiffs are informed and believe and thereupon allege that the Defendants were angry about being turned down by an interview subject they had energetically pursued and clearly felt was important to their Book - and they retaliated by presenting Mr. de Becker and his firm in the most unfavorable possible light. They invented and presented defamatory characterizations and falsehoods, withheld favorable information, and used every means available to damage Mr. de Becker and his firm. 11. After Mr. de Becker's reply (above), neither Mr. de Becker nor Mr. Martin ever again heard from Defendants Libes, Weddle, or William Morrow & Company to confirm the accuracy of statements and allegations in the Book. 12. The finished Book was published and widely distributed in March of 2003. Plaintiffs are informed and believe and thereon allege that its highest sales occur in Southern California, the precise area from which the majority of Plaintiffs' business derives. IV.
ERRORS, MISREPRESENTATIONS AND OMISSIONS IN THE BOOK
1. In a passage set by context in the time period of 1989, Defendants' Book states as follows: "[Gavin de Becker] had never been in the CIA or the FBI, never served as a police officer, a county sheriff, or even a meter reader. But he did possess some vital qualities for succeeding in Beverly Hills: an uncanny theatrical instinct and a prodigious ability for self-promotion. In a city full of re-created people who preferred legends to facts under any and all circumstances, these qualities far outweighed such mundane trivialities as experience and professional qualifications." The clear implication is that Mr. de Becker did not have "experience and professional qualifications." For an advisor on life and death matters, this assertion is libelous. 2. These assertions are also totally inaccurate. At the beginning of his career, when Mr. de Becker was 19 years old, it is true he had not been with the CIA, FBI, or a police department, but it is unfair and misleading to tell readers what experience he did not have as a teenager at the start of career, and then imply that fifteen years later, in 1989, he had no "experience or professional qualifications." It is misleading to tell readers what experience he did not have as a teenager, without also noting that by 1989 (the time period established by context) Mr. de Becker had served two terms on the President's Advisory Board at the U.S. Department of Justice, had been appointed by the Governor to the Advisor Board at the California Department of Mental Health, had worked for 5 years on the largest-ever Federal research project studying mentally ill people who attack public figures, had served a senior position on a Congressional Committee, he had been Director of Special Services Group (responsible for the safety and logistics of public figures attending the Presidential Inauguration), had worked at the State Department on the official visits to the U.S. of several foreign heads of state, had worked as an Advisor at the White House, had received his third Presidential Appointment, had written more than 40 articles published in law enforcement and security industry journals, had testified in many criminal cases, and had personally managed the assessment of thousands of cases of unwanted pursuit and stalking. Defendants withheld all this information. 3. Since Defendants specifically note the FBI in making their claim that Mr. de Becker is insufficiently experienced, it would be fair to balance their statement by also telling readers that he has been an advisor sought out by the FBI on several occasions, or that he has taught at the FBI Academy. Defendants withheld this information. 4. Since Defendants specifically note the CIA in making their claim that Mr. de Becker is insufficiently experienced, it would be fair to balance their statement by also telling readers that the CIA is a client of Mr. de Becker's firm, or that Mr. de Becker designed the CIA's MOSAIC threat-assessment system, or that he has taught at the CIA on more than one occasion, or that he has advised the CIA on several matters, or that he has received the Director's Certificate of Appreciation from the CIA. Defendants withheld this information. 5. If you assert that someone is inexperienced and unqualified (at any point in their career), fairness and accuracy dictate that the assertion be balanced by some reference to the experience and qualifications gained during their career. Defendants' approach is like saying a judge never presided over a single case -- while perhaps true his first day on the bench, it is not true after 30 years in the judiciary. 6. Further, the Book's implication that having served in the CIA or FBI, or having been a police officer would constitute relevant "experience and professional qualifications" is inaccurate Mr. de Becker is the leading pioneer in his field, a field that does not receive even 15-minutes of instruction in any police academy. _ Thus, it is misleading and inaccurate to assert that police officers are automatically qualified in the field of threat assessment, while Mr. de Becker is not. _ Mr. de Becker not only pioneered a new area of law enforcement, but he has been the leading teacher in the field, engaged as noted above by both the FBI and CIA to teach its personnel, as well as by the NY Police Department to teach 600 detectives about assessment of domestic violence cases, the U.S. Supreme Court Police to provide training to police officers, the United States Marshals Service, the Los Angeles Police Department, the United States Secret Service, and many, many others. _ That Mr. de Becker is widely regarded as a pioneer in his field was clearly known to Defendants, as Defendant Libes states it outright in an email he sent to Mr. de Becker (and later shared with his co-author, Defendant Weddle): "As a pioneer and leader in the Threat Management field, you could explain the history and place of Threat Management in regards to celebrity-status and you can help my readers attain a greater understanding of the security needs of a unique community like Beverly Hills." Since Defendants themselves felt Mr. de Becker to be a "pioneer and leader in the threat assessment field," it is outrageous they withheld that and any other favorable facts from their readers. 7. After Defendants presented their editorial assertion that Mr. de Becker is inexperienced and unqualified, they next suggested that others widely agree with their view: "Before long others began to see that hey, there's a shitload of money to be made here! If some little Beverly Hills brat with no law enforcement experience can cash in on this stalking bonanza, why not me?" 8. Having told readers that Mr. de Becker lacks experience and professional qualifications, Defendants step even father outside of acceptable reporting with their most outrageous and damaging allegation, presented as editorial fact: that Mr. de Becker, as a matter of routine practice and solely for his own financial gain, intentionally places his clients at increased risk of injury or death. 9. In the following passage, Defendants publicly state that when his clients are pursued by "psychotic" individuals, Mr. de Becker will, without a case-by-case assessment: a. Automatically and routinely advise against seeking a restraining order; b. Automatically and routinely advise clients not to inform the police; c. Intentionally keep police uninformed to preclude the possibility that they would resolve the danger swiftly; d. Compel clients to engage expensive services that they might well conclude were not in their own best interests; e. Keep the police away, since the police would question his judgment. f. Do all of this for the sole purpose of increasing his wealth. EXCERPT: (1) "And once he controlled the mail, de Becker controlled the clients. (2) He advised them not to file restraining orders against psychotic fans, or to inform the police that they were being harassed. (3) The police are hamstrung by civil rights laws, Gavin argued. (4) Restraining orders have no teeth and might provoke a violent response from a psychopath. (5) A more prudent course of action was to let Gavin put a surveillance team on a potential troublemaker and discreetly monitor his activities. (6) If a stalker actually tried to make a move, de Becker's operatives would swiftly move in to intercept him. (7) Of course this approach had other benefits. (8) By keeping law enforcement officials out of the loop, Gavin precluded the possibility that they might bring the case to a swift conclusion or question de Becker's judgment when he decided to put a fan under costly twenty-four-hour surveillance. " 10. Sentence #1 of the passage above is untrue. 11. Sentence #2 is untrue (" He advised them not to file restraining orders against psychotic fans, or to inform the police that they were being harassed "). Mr. de Becker did not routinely advise against filing restraining orders. He recommended and sought restraining orders when, on the basis of assessment and experience, he felt they would enhance a client's safety. The net result was that Mr. de Becker has sought more restraining orders than anyone in the field. Mr. de Becker did not advise clients to keep information about criminal behavior from the police. 12. Sentence # 3 is untrue (" The police are hamstrung by civil rights laws, Gavin argued "). Though Mr. de Becker has written and spoken extensively on the precise topic of restraining orders, he has never made the argument that "The police are hamstrung by civil rights laws." He has never said the words "The police are hamstrung by civil rights laws." (In any event, every law-abiding citizen is obliged to act in accordance with civil rights laws.) Mr. de Becker's detailed and fully explained views on this critically important topic have been read and heard by millions of people, yet Defendants chose to ignore the widely available information. We are aware that the authors had all of the material needed to report accurately and fairly on Mr. de Becker's views -- yet they chose instead to characterize Mr. de Becker and his firm as having the worst possible motives and the most destructive possible attitude toward the people Plaintiffs are duty-bound to protect. 13. Sentence #4 is untrue (" Restraining orders have no teeth and might provoke a violent response from a psychopath "). Mr. de Becker does not make the argument that restraining orders "have no teeth." The second half of the sentence contains some truth in that Mr. de Becker (along with every reputable expert in his field and related fields) does believe that in some cases, restraining orders can provoke a violent reaction. Accordingly, he advocates careful assessments to determine in each situation if a restraining order will serve safety or undermine safety. 14. Sentences #5 and # 6 are untrue (" A more prudent course of action was to let Gavin put a surveillance team on a potential troublemaker and discreetly monitor his activities. If a stalker actually tried to make a move, de Becker's operatives would swiftly move in to intercept him "). Gavin de Becker & Associates virtually never recommends a case management plan that could be described as putting "a surveillance team on a potential troublemaker." Such a plan might be suggested in perhaps one case out of thousands; perhaps three or four cases in decades -- and even in those rare instances, surveillance would be brief and not for the purposes alleged by Defendants. " If a stalker actually tried to make a move, de Becker's operatives would swiftly move in to intercept him. " Tried to make what kind of "move"? How and with what legal or logistical means would "de Becker's operatives" supposedly intercept such people? Defendants don't bother to answer these questions for their readers because they have no basis upon which to elaborate. 15. Sentence # 7 is untrue (" Of course, this approach had other benefits "). This was not Mr. de Becker's approach. 16. Sentence # 8 is untrue (" By keeping law enforcement officials out of the loop, Gavin precluded the possibility that they might bring the case to a swift conclusion or question de Becker's judgment when he decided to put a fan under costly twenty-four-hour surveillance "). The allegation here is that Mr. de Becker intentionally sought to keep police "out of the loop" specifically to prevent cases from being swiftly resolved! Thus, Defendants allege that Mr. de Becker violated contractual and fiduciary duties by keeping his clients and their families at extraordinary risk of injury or death for his own commercial gain. 17. Defendants allege that Mr. de Becker routinely kept police away because they might question his judgment as he kept "fans" under "costly twenty-four-hour surveillance." It is difficult to even draw an analogy as outrageous or damaging as this. It is tantamount to accusing a doctor of delaying a patient's recovery from a potentially fatal disease just so he can charge more money. The truth is that Mr. de Becker's firm virtually never recommends surveillances, costly or otherwise, for managing the types of situation described, and the truth is that Mr. de Becker's firm routinely and most often recommends against surveillance. 18. Defendants had in hand, and even cite in their list of source material, specific published materials that contain accurate discussions of these issues, yet they used source material which was fair to Plaintiffs to invent something damaging to Plaintiffs. The source material they twisted to produce the paragraph cited above included an article in the New Yorker Magazine. The article would give any author plenty of reasons to carefully consider information from some named competitors who could predictably be motivated by greed and malice. In citing by name two of the exact same sources Defendants ultimately relied upon, the article states outright that one of them "clashed with de Becker." This New Yorker article that Defendants had in hand states outright that this source, at the time a police detective, "intends to retire from the LAPD and join [another source Defendants relied upon] in forming a private threat-management business - a direct competitor to de Becker " 19. It is telling to consider the assertions in Defendants' source material that they chose to withhold from their readers, such as "[de Becker] remains the country's leading expert on the stalking of public figures." 20. Beyond alleging that Mr. de Becker recklessly put his clients and their families at extended risk of injury and death, Defendants allege that this was the regular practice of his firm. Through extensive narrative presented as fact, Defendants allege that the dangerous practices were calculated over years of canny development to enrich Plaintiffs at the expense and risk of their clients. 21. Because the allegations above are so defamatory and so destructive to reputation, and because the allegations likely originated or were supported by aspiring competitors and others unfamiliar with the actual facts of Plaintiff's services, and because of the obvious possibility that such sources are biased, any acceptable journalistic standard would call for the most careful investigation. Instead, Plaintiffs are informed and believe and thereon allege that Defendants did no investigation, did not meet their duty to consider the credibility of their sources, withheld from their readers and publishers extensive evidence contrary to their malicious inventions, and produced a profoundly damaging eight-sentence paragraph in which eight of the sentences are untrue. 22. Having alleged that Mr. de Becker is inexperienced and unqualified, that he places clients at risk for his own financial gain, and that police would (if he allowed them) question his judgment, Defendants next tell readers that "His prices are exorbitant." The Book offers no supporting information from which a reader could draw his own conclusions. Unbiased authors might express an opinion and provide supporting reasons, but Defendants state it editorially, as fact: "De Becker charged customers anywhere from $225,000 to $475,000 a year for twenty-four-hour protection. His prices were exorbitant " 23. The description of services tied by Defendants to this wide range of costs is inaccurate, incomplete, and misleading. 24. There has never been a billing structure in the history of Gavin de Becker & Associates with a range along the lines asserted by Defendants ($225,000 to $475,000), as all clients who receive protective security services are billed an amount per man-hour, and the amount does not differ client-to-client by more than 50%, as asserted. 25. Most importantly, the fees are not, and never were "exorbitant." Exorbitant means overpriced, inflated, exceeding all bounds of custom and fairness. Defendants have asserted that Gavin de Becker & Associates charges its clients unfairly, without integrity, and beyond the bounds of custom. Any prospective client reading it would predictably seek services elsewhere, and any current client reading it would have their confidence in the firm shaken. Given the degree of trust and confidence clients and prospective clients must invest in a firm they rely upon for safety and well-being, Defendants' inaccurate assertion stated as fact is trade libel. 26. The Defendants make these allegations without knowing, investigating, or learning the costs associated with providing Gavin de Becker & Associates' service, the customary costs for the type of service, or the charges of competitive services. For example, there are 168 man-hours in a week; with training, briefings, management, and supervision, the actual number of man-hours needed each week to meet a client's needs is 190. Multiply that by 52 weeks and one has almost ten thousand man-hours a year. Divide $225,000 by 10,000 man-hours, and you have a service that costs $22.50 per hour. In other words, Gavin de Becker & Associates charged less per hour in 1989 (the period established by context in the passage) than clients were charged by Gavin de Becker & Associates' primary competitors - including at least one competitor interviewed for the Book. In fact, Gavin de Becker & Associates has always been less expensive for these services than its primary competitors. 27. In order to comment fairly on a company's costs, one must assess the firm's costs for recruitment, background screening, training, licensing, insurance, benefits, holidays, State-mandated qualifications, and all of the many expenses associated with providing a quality service. By every reasonable measure, $22.50 per man-hour was not exorbitant in 1989, and most significantly, it was the lowest price available in Southern California for this level of service. 28. Defendants' own Book contains the clearest evidence that Gavin de Becker & Associates' prices are, in fact, lower than its competitors. Just 4 pages from the appearance of the false statement "his prices were exorbitant" is this passage: "Vance charges the Saudis six-two, seventy-five dollars an hour per body guard. Normally, the going rate is fifty to sixty dollars an hour." Gavin de Becker & Associates' current prices are substantially less than what Defendants themselves identify as the normal "going rate." 29. When Defendants assert that Plaintiffs charged customers as much as $475,000 a year, they do not share that clients paying $475,000 were getting an entirely different set of services. Their assertion is the same as saying that customers in a store are charged $20 for apples -- without disclosing the number of apples purchased. We located the precise source material Defendants twisted to make these allegations about costs, and what they chose to omit is telling. Compare Defendant's blunt description ("$225,000 to $475,000 a year for 24-hour protection") with the original source material from the Los Angeles Times: Top of the line clients pay $475,000 for his services, which in addition to threat analysis pays for around-the-clock protection with trimmings including an armored car and escorts for tours. "A very common figure is $225,000," he said. "That gets you 24-hour coverage." 30. Defendants chose to quote the higher number and yet omit the extensive services provided under that higher number. Readers are left to assume that in 1989, some clients paid $475,000 for 24-hour protection. Readers are not told that a client paying a higher amount is doing so because the client has requested assignment of an armored car, for example. Gavin de Becker & Associates is the only private firm offering customized armored cars for transporting high-risk public figures. An armored car is a tremendously expensive piece of equipment, one that requires a driver, of course, and thus another one or two full-time employees assigned to the client. Readers are not told that an amount such as $475,000 included threat assessment services. With some clients, this might be a labor-intensive service involving assessments, arrests, jailhouse interviews with pursuers, negotiation with mental hospitals, appearances in court, liaison with police departments, complex investigations, and functions that might take the assignment of several full-time professionals. But the most glaring omission in their characterization of services costing $475,000 per year are these three words: "Escorts for tours." This means full-time, multi-man protective traveling teams in addition to the regular security team a client might have had at his or her home. An example of a client spending $475,000 is someone on an international public appearance tour, visiting perhaps fifty countries, and having a security team comprised of five men. When all is said and done, such a client might have as many as ten people assigned - and the client might be paying around $18 per man-hour for these extensive services. If accurately presented and considered, the charges would not appear "exorbitant" to any reader, but Defendants withheld the information they had in hand in order to support the blunt, editorial statement: "His prices were exorbitant." 31. Not only did Defendants provide no favorable or complete information to balance their many damaging allegations, but they then used their own unsubstantiated figures and false allegations to present a derogatory means of explaining away Mr. de Becker's actual reputation as the leader in his field: " in a city that equates price with quality this only served to prove that de Becker was the best in the business." 32. After stating as editorial fact that "His prices were exorbitant," Defendants go on to claim: "some law enforcement veterans would say [de Becker's prices were] ridiculously exorbitant." 33. Would say, or did say? Defendants are alleging that more than one law enforcement veteran said de Becker's prices are "ridiculously exorbitant," or they are alleging that more than one law enforcement veteran would say such prices are "ridiculously exorbitant." In either instance, they do not name the persons they supposedly relied upon to assert this libelous statement. 34. Even if one or more law enforcement veterans did say this, Defendants do not tell readers that a "law enforcement veteran" is not in a position to know about financial details of security services, de Becker's actual rates and fees, fair business practices, what competitors were charging in 1989, what constitutes fair prices, or what the customary prices for similar services are. One could quote "law enforcement veterans" as saying that a firm's prices for jet fuel are exorbitant, but there is no expectation that those making the observation understand the jet fuel business. Yet, the authors hold out unnamed "law enforcement veterans" as qualified sources to disparage Plaintiffs' integrity. 35. In the section of the Book that provides readers with the sources Defendants claim they relied upon, there is only one "law enforcement veteran" named. Plaintiffs expect discovery and investigation to confirm that Defendants relied upon one or more aspiring competitors of questionable knowledge and objectivity to bolster Defendants' own editorial bias and malice. 36. In making an assertion this damaging, accepted journalistic and publishing standards clearly call for Defendants to thoroughly investigate a source's claim to confirm the facts, and to weigh the credibility of all sources. They did not, the result being irreparable damage to Plaintiffs. 37. In actual fact, fees for these services by Gavin de Becker & Associates have been consistently and at all times through the firm's history lower than its competitors' fees for similar services. This is because much of Gavin de Becker's earnings are derived (and have been for as long as the firm has existed) from his consulting services. The protective security division operated at significantly lower profit margins than any of the firm's competitors. Further, since Gavin de Becker & Associates is the most successful firm offering these services, clients have benefitted from lower rates made possible by economy of scale. Even were the figures accurate, and even were Gavin de Becker & Associates' prices higher than others (neither hypothetical is true), that still would not justify a claim that prices were "exorbitant" unless one considered the nature and quality of the service as it compared to the custom. 38. Defendants have widely disseminated within Plaintiffs' home community the false assertion that prices of "$225,000 to $475,000 a year" were in effect in 1989. They were not. Defendants have thus invented false and inaccurate prices, and then called those prices "exorbitant." 39. Defendants developed yet another way to damage Plaintiffs by misusing a sentence from de Becker's response to Defendant Libes' first email, in which Defendant Libes requested an interview. Mr. de Becker replied: "I say No to all interviews these days (occasional exception: Oprah or 60 Minutes), so email's all I've got, and even that's tough. Also, I don't have much interest in being in something with a bunch of so-called 'experts' without knowing who. In other words, I don't want by association to lend credibility to frauds or wannabes." 40. Even though Mr. de Becker made this statement without reference to any specific persons (as he didn't even know who would be appearing in the Book), Defendants name six specific people and three competitive firms, followed by: "De Becker haughtily denounces all these Johnny-come-latelies as 'frauds or wannabes' pretenders to his throne as security guru to the stars." 41. The direct editorial assertion that Mr. de Becker denounced specific people and firms is not only untrue, but is foreseeably damaging to relationships, some of which are important to the day-to-day work of professionals at Gavin de Becker & Associates, and important to the safety of its clients. 42. Defendants list John Lane, Michael Zona, Park Dietz, Dennis Bridwell, Dan Palmer, and the firms Omega Group, Threat Assessment Group, and Galahad Protective Services, followed by the false assertion that "De Becker haughtily denounces all these Johnny-come-latelies as 'frauds or wannabes." In at least one instance, the assertion interferes with contractual obligations, and in all instances, the false assertion implies that Mr. de Becker made disparaging comments about specific competitors, which he did not. The allegation, if true, would possibly constitute a violation of the California Business & Professions Code. The reader is left to assume that Mr. de Becker made such statements. 43. Some readers of Among the Mansions of Eden will conclude that it is a sleazy tabloid-style book, the type of book Mr. de Becker would (and did) decline to be interviewed for. Unfortunately, Defendants add to the many damaging assertions and implications in the Book the implication that Mr. de Becker participated in their project. Defendants provide readers with a list of their sources, a list that includes: "Howard Libes's correspondence with Gavin de Becker." 44. This reference appears twice in the Book, leading readers to assume that Mr. de Becker added something of substance, when in fact, the actual substance of the "correspondence" with Defendant Libes was that Mr. de Becker would not participate in an interview. Responding to each of the three e-mails in which Defendant Libes requested an interview, Mr. de Becker declined, provided his reasons for declining, and wished the author luck. The assertion that some substantive "correspondence" occurred is misleading, is damaging to the Plaintiffs, and would lead most readers to conclude that the claims in the Book regarding Mr. de Becker are accurate (since he himself was a "source"). 45. Defendants provide a list of people they assert are clients of Mr. de Becker. Though the authors had knowledge of many other clients, their list does not include any of the Federal Government agencies, states, or universities that Gavin de Becker & Associates also advises. Even the limited list they do provide to readers raises a question: Would all of these people, with all of the due diligence they and their representatives undertake, have engaged a person with no "experience" or "professional qualifications" to handle critical life-safety services? Knowing Mr. de Becker's reputation is unsullied, and yet needing to support their outrageous allegations and assertions, Defendants offer readers an answer to the obvious question. They tell their readers, that though unqualified, Mr. de Becker "did possess some vital qualities for succeeding in Beverly Hills: an uncanny theatrical instinct and a prodigious ability for self-promotion. In a city full of re-created people who preferred legends to facts under any and all circumstances, these qualities far outweighed such mundane trivialities as experience and professional qualifications. " 46. Had Defendants offered an accurate sampling of Plaintiff's clients, readers would not have believed that the Nation's twenty-five major universities, or agencies such as the U.S. Supreme Court, U.S. Marshals Service, United States Capitol Police, and the CIA would all have failed to do careful investigation and due diligence prior to engaging Mr. de Becker for advice, development of threat assessment systems, teaching, and other services. The US Attorney General, for example, would not have selected Mr. de Becker to develop threat assessment systems on the basis of his "uncanny theatrical instinct." But Defendants withheld true and complete facts in order to damage Plaintiffs' reputation, and to be certain readers not have the opportunity to reach fairer conclusions. 47. Readers are asked to believe that Plaintiffs' clients did no effective due diligence and were swayed entirely by an "uncanny theatrical instinct." This claim in the Book would be difficult to believe in another context, but by page 208, where the false assertions begin, readers have been provided a steady diet of the central theme of the Book: That Beverly Hills is populated by gullible, stupid, unconscious, people who care only about appearances, theatrics, and "dog-and-pony shows." Nowhere in the Book is anyone portrayed as having a legitimate interest in the safety and well being of their families, for example. V.
CALCULATED ASPERSIONS REGARDING PLAINTIFFS'
MOTIVES AND CHARACTER
1. The Book contains one central theme when it comes to
Plaintiffs: that the motive of Gavin de Becker throughout his career is
solely a commercial one. The issue of Mr. de Becker's commercial
interest is raised at least twelve separate times in the Book, always
expressed in the most pejorative way (" boarded an express train to fat
city;" "entrepreneur like de Becker;" "monopolize;" " whole new
revenue stream for de Becker;" "costly;" "thousands of billing hours
for de Becker;" "his prices were exorbitant;" "little Beverly Hills
brat with no law enforcement experience;" "ridiculously exorbitant;"
"a beautiful maneuver;" " de Becker's ambitions;" "lengthy and
expensive;" "all of his marketing savvy;" "Celebrities forked over ").2. This central theme, presented in a highly pejorative, defamatory, and misleading fashion, is that de Becker is motivated solely by a profit motive without regard to the public interest or the welfare of his clients. In view of the true facts known to the authors and knowable to the publishers -- facts that were not disclosed -- this presentation is false, misleading, and defamatory. 3. For example, the book states editorially: "The star of a hit television series received as many as 20,000 letters a week, which translated into thousands of billing hours for de Becker. Celebrities forked over anywhere from $30,000 to six figures a year for Gavin's mail-reading service." In actual fact, Gavin de Becker & Associates has never offered a "mail-reading service" as described in this passage. Far different from charging clients to read "20,000 letters a week," the firm has assessed just the minuscule minority of letters that were considered by clients to be threatening or otherwise alarming, never amounting to "thousands of billing hours" for any client. 4. Further, for much of the last 30 years, there were no extra charges whatsoever for assessment services. For many years, screening and assessment of threatening and alarming material was automatically provided at no additional charge to clients who received protective security services. The screening benefitted de Becker's security personnel by making them more aware of persons who might show up in a client's environment. After years of not charging anything for the service, even when billing for these services did begin, no client ever paid six figures a year -- nor is any so paying currently. In other words, the entire premise that Mr. de Becker had developed some scheme for a "new revenue stream" that would be an "express train to fat city" is false and misleading. 5. It is trade libel to state editorially that Gavin de Becker & Associates charged individual clients "thousands of billing hours" for a "mail-reading service." Prospective clients of Gavin de Becker & Associates reading this passage would predictably seek services elsewhere, particularly since no favorable information is provided to balance all the defamatory statements, assertions, and implications. Current clients would predictably have their confidence in the firm shaken. 6. Not only did Defendants provide no favorable information to balance their many damaging allegations, but they invented a derogatory way to explain away Mr. de Becker's actual reputation as the leader in his field: "in a city that equates price with quality this only served to prove that de Becker was the best in the business." 7. Though the authors put great effort into characterizing Mr. de Becker and his associates as motivated solely by commercial interests, they elect not to share with readers facts known to them, such as: Mr. de Becker used proceeds from his first book to personally fund development of a threat assessment system for victims of domestic violence; the entire proceeds from sales of his current book go to charity; Mr. de Becker personally funded the LA County Domestic Violence Hotline for many years; he founded and supported two charities; the firm currently provides charitable funding for the Domestic Violence Hotline; the firm provides extensive pro-bono services every year, and has for more than a decade. 8. Continuing in their campaign to damage Plaintiffs commercially, the Defendants imply that Gavin de Becker & Associates is now suffering from business losses, and is overly concerned about competition - a claim far that is from true. 9. Immediately after a misleading juxtaposition and inaccurate statement ("De Becker haughtily denounces all these Johnny-come-latelies as 'frauds or wannabes,' pretenders to his throne as security guru to the stars"), Defendants add: "But there's an undercurrent of stridency in his words; the first beads of cold sweat are forming, for his business has suddenly gotten a lot more competitive." 10. There was no "undercurrent of stridency" to Mr. de Becker's words, which were written about nobody in particular, since he didn't know at that point who was being interviewed for the Book. There were no "beads of sweat" forming, and the authors never saw Mr. de Becker personally in any event. Nor is it true that "his business has suddenly gotten a lot more competitive." 11. After all of the other false and disparaging assertions, the Defendants inaccurately tell readers (predictably including clients and prospective clients) that the business of Gavin de Becker & Associates is suffering due to new and effective competition. In fact, Gavin de Becker & Associates has grown every year for decades - and the past three years, the growth has been larger than at any time in the firm's 30-year history. Though the Defendants would lead readers to believe that Plaintiffs are concerned about increased "competition," the truth is that Gavin de Becker & Associates has never paid the slightest attention to aspiring or actual competitors - except in those few instances when aspiring competitors have acted illegally, stolen proprietary information, or stolen intellectual properties. 12. Though competition has not been an important issue to Plaintiffs, Defendants have now provided a tool that unfairly gives competitive advantage to others, in that firms can and will share this book with prospective clients, thus furthering the damage to Plaintiffs. Other firms mentioned in the Book are presented as basically neutral, while a competitor providing the Book to any prospective client would discourage the client from pursuing services with Gavin de Becker & Associates, a firm that the Book states overcharges its clients, has exorbitant prices, cares only about money, has no integrity, is founded and led by someone without qualifications or professional credentials, and disparages its competitors. Then, after Defendants began to disseminate the Book, they refused to take simple steps to avert or minimize the harm caused by their defamatory statements. Among other things, they refused to provide sales information to allow Plaintiffs to better assess ways of mitigating damages, refused to provide a letter stating merely that the accuracy of the information set forth in the Book regarding Plaintiffs was being evaluated, and refused to notify book sellers (particularly in Plaintiffs' local community) that the accuracy of Chapter 7 of the Book had been called into question and was being evaluated. VI.
IMPROPER JOURNALISTIC PRACTICES
1. Defendants did not conduct even the most basic
search for literature, news articles, reports, studies, or other
information that would have informed them adequately to report on
something as serious as services at-risk people seek to protect their
safety. Depositions and investigation will reveal that the authors
calculated to rely upon sources with obvious bias who would support
their intentional creation of an unfavorable treatment of Plaintiffs.
Defendants did not contact the very people in the best position to
accurately inform them on their subject matter. 2. Defendants did not meet a reasonable standard in fact checking. 3. Defendants did not contact Mr. de Becker during their fact checking process (if any), even though they knew at that point that the Book would include highly defamatory and inflammatory allegations. 4. Defendants did not contact any of the other Plaintiffs, all of whom were available to them. 5. Defendants knowingly portrayed Plaintiffs in a false and damaging light. 6. Defendants had in their possession and chose to ignore extensive information favorable to Plaintiffs. 7. Defendants intentionally left information favorable to Plaintiffs out of the passages about Plaintiffs. 8. Defendants sought and accepted information from people who acknowledged they were competitors or aspiring competitors, and Defendants did no investigation whatsoever that would help them assess the truthfulness or objectivity of their sources. For example, Plaintiffs are informed and believe and thereupon allege that two of the sources Defendants relied upon have a history of illegal conduct directed toward Plaintiffs, and have admitted under oath that they breached contracts, violated the law, stole documents, and stole intellectual property. Though other persons in the security industry whom Defendants interviewed are listed by name on Defendants' source list, some sources are intentionally concealed, characterized only as "members of the personal security industry." Depositions and investigation are expected to reveal that Defendants relied upon sources known to be unreliable, and that Defendants took no steps to confirm the truthfulness of statements by any of the sources they used to support the defamatory characterizations they invented. VII.
FACTUAL ERRORS
1. Though not all errors and misrepresentations are of
equal consequence, they are presented here (in the order of appearance
in the Book) to demonstrate Defendants' pattern of inaccuracy, reckless
disregard for the truth, misrepresentation, and malice: × · "Gavin moved into a one-bedroom apartment in South Central Beverly Hills so he could attend Beverly Hills High." Inaccurate . Mr. de Becker did not live in Beverly Hills. Defendants had Gavin's accurate written account: "I grew up on welfare and food stamps, but used an address of a one-room apt in Bev Hills to be able to attend BH High." × · "When he graduated from Beverly High in 1975 " Inaccurate . Mr. de Becker graduated in 1972. × · "Martin's wife, Jeanne " Inaccurate . She is Martin's ex-wife. × · " recommended Gavin for a position as a bodyguard for Elizabeth Taylor and Richard Burton." Inaccurate . Mr. de Becker was never a bodyguard for Elizabeth Taylor or Richard Burton. × · "Taylor began recommending him to friends." Untrue . Mr. de Becker was a full-time employee of Elizabeth Taylor, and she never recommended him to work for anyone else. × · "Park Dietz, who had testified at the trials of John Hinckley and other stalkers " Inaccurate . Firstly, John Hinckley was not tried as a stalker, but for the attempted assassination of President Reagan and others. Secondly, at that time, Park Dietz had not testified at any trials of persons charged with stalking. · "Dietz helped de Becker develop a computer program " Untrue . Dr. Dietz, though he would make a capable and valuable collaborator, was not involved in development of any such program. × · " a computer program that analyzed the language patterns of demented letters " Inaccurate . Mr. de Becker has no computer program that analyzes language patterns. · "The psychological profiling angle created a whole new revenue stream for de Becker." Untrue as to psychological profiling; there was no such service. Untrue as to a new revenue stream. × · "He now insisted that his clients turn all of their fan mail over to him which translated into thousands of billing hours for de Becker." Untrue . Mr. de Becker did not "insist" any such thing, nor did he or his firm ever assess "fan mail," nor did anything along these lines ever translate into "thousands of billing hours." · "Celebrities forked over anywhere from $30,000 to six figures a year for Gavin's mail-reading service." Untrue . There was no "mail-reading" service, and there were no such fees. × · "And once he controlled the mail, de Becker controlled the clients." Untrue . · "He advised them not to file restraining orders against psychotic fans, or to inform the police that they were being harassed." Untrue . × · "The police are hamstrung by civil rights laws, Gavin argued." Untrue . Mr. de Becker has never made any such argument. × · " to let Gavin put a surveillance team on a potential troublemaker " Untrue . Gavin de Becker's firm virtually never recommended any surveillance as a method for managing such matters. By virtually never, this means perhaps one case out of thousands, just a few cases in decades. × · "By keeping law enforcement officials out of the loop " Untrue . Mr. de Becker's firm did not keep law enforcement uninformed of criminal conduct. × · "Gavin precluded the possibility that they might bring the case to a swift conclusion or question de Becker's judgment " Untrue as to Mr. de Becker's motive. Untrue as to the assumption that police would bring a swift conclusion. Untrue as to whether they would "question de Becker's judgment." · " when he decided to put a fan under costly twenty-four-hour surveillance." Untrue . Mr. de Becker's firm virtually never recommended surveillances, costly or otherwise, perhaps one case out of thousands, just a few cases in decades. · "De Becker charged customers anywhere from $225,000 to $475,000 a year for twenty-four-hour protection." Untrue as to amount in 1989; misleading as to range at any time, including the present. × · "His prices were exorbitant " Untrue . × · "Robert Martin, a supervising detective with LAPD " Inaccurate . Captain Robert Martin was not a detective at the time; he was Commanding Officer of Detective Headquarters Division. × · "[In 1989] Martin was keenly aware of the new antistalking bill that had just been passed by the California legislature." Inaccurate . Robert Martin had never heard anything about the antistalking bill, and inaccurate because the antistalking bill wasn't passed until a year later. × · "After Robert Martin departed from the Threat Management Unit, Lieutenant John Lane took over." Inaccurate . Captain Martin was never with the Threat Management Unit, and thus never departed from it. The Threat Management Unit was one of the units that reported to Captain Martin. Captain Martin assigned John Lane to the unit and supervised John Lane's work until Captain Martin retired from Los Angeles Police Department. × · "In 1997 de Becker placed the final capstone on his personal myth by publishing The Gift of Fear " Inaccurate . Mr. de Becker didn't publish the book; he wrote it. It was published by Little Brown & Company, not self-published. Even were one to accept the pejorative characterization "final capstone on his personal myth," it would still be inaccurate , as Mr. de Becker has written two more bestselling books since 1997. × · " The Gift of Fear , a melodramatic chronicle " Inaccurate . Firstly, Mr. de Becker's book is not melodramatic, though he certainly wouldn't object to anyone's opinion. Plaintiffs assert, however, that Defendant Weddle did not read the book he criticizes, and his characterization of the book is in direct conflict with his researcher, who likely did read it, and characterizes the book in an email (09/29/2000): × · "I read the GIFT OF FEAR to gain a greater understanding of problems in today's society that I was going to touch upon in my work. Your book was written with high regard for the reader in thoroughly covering topics with well-founded details and open-minded arguments. That was one of the reasons why I came to you for an interview. I knew from what I read that your contributions to my work would be highly thoughtful and perceptive." × · " chronicle of his career in the personal security industry." Inaccurate . The Gift of Fear is not a chronicle of Mr. de Becker's career in the personal security industry. × · " personal assistant for an A-list movie star, who reports that de Becker attends all of the star's parties and invariably shows up each time with a new starlet on his arm." Untrue . Mr. de Becker does not attend all of anyone's parties, and he has never dated any "starlet," new or otherwise. Plaintiffs believe discovery will reveal that these characterizations are either a) not an accurate report of what the source said; or, b) there was no such source. · × " de Becker failed to anticipate that in pushing for the formation of the Threat Management Unit he was creating a Frankenstein monster." Inaccurate . Mr. de Becker was fully aware that the new unit within LAPD would provide an alternative to his services. He felt formation of the Unit was in the public interest. · "Park Dietz, the forensic psychiatrist who initially served as de Becker's adviser " Inaccurate . While Mr. de Becker respects Dr. Dietz's work, and though they have worked together on several projects, Dr. Dietz never served as an advisor to Mr. de Becker. × · De Becker haughtily denounces all these Johnny-come-latelies as "frauds or wannabes" Untrue . · "But there's an undercurrent of stridency in his words; the first beads of cold sweat are forming" Untrue .
FIRST CAUSE OF ACTION
(For Trade Libel By Plaintiff Gavin de Becker & Associates Against All Defendants)
2. Plaintiffs repeat, reallege and incorporate herein
by reference each and every allegation contained in Paragraphs 1 through
102, inclusive, as though fully set forth herein. 3. During 2003, Defendants willfully, without justification, and without privilege, published and communicated the Book or caused the Book to be published and communicated to numerous third persons, in Los Angeles County and throughout the United States. The Book contains various statements that are false, misleading and disparaging of the Plaintiffs, including, without limitation, the statements set forth in Paragraph 102 above. 4. Each of the aforementioned statements by Defendants in the Book was made of and concerning Gavin de Becker & Associates' goods and services, and was so understood by those who read or were informed of the statements in the Book. 5. Defendants' statements in the Book unlawfully disparaged Plaintiff's reputation and services, in that, among other things: (a) The statements referenced in Paragraph 102 above were false statements. (b) The statements referenced in Paragraph102 above explicitly and implicitly suggest that Gavin de Becker & Associates lack necessary knowledge, experience and credentials to perform their work and engage in unethical and unfair business practices in a manner that is not followed by those in the same industry, for the sole purpose of pecuniary gain to the detriment of the public interest and clients, thereby severely disparaging the public's view of the quality of Plaintiffs' services and the public image associated with Plaintiffs. Contrary to the statements in the Book, the true facts are that Gavin de Becker & Associates has conducted its business with the highest integrity, quality and fairness and fully in accord with its duties to its clients. (c) The statements referenced in Paragraph 102 above inaccurately and in a misleading fashion severely disparage Gavin de Becker & Associates' services and reputation in the public's eye. (d) The statements referenced in Paragraph 102 above are incomplete, incorrect or misleading in view of the context in which the statements are made and in the context of crucial information that is not provided in the Book, thus making false implications concerning Gavin de Becker & Associates as alleged herein. 6. Each of the aforementioned statements by Defendants was false at the time that it was made. 7. Each of the statements by Defendants in the Book set forth above was made and published with actual malice, with knowledge of its falsity or with reckless disregard for its truth or falsity. Defendants' actual malice is evidenced by various facts, including, but not limited to, Defendants' calculated solicitation of negative comments from persons interviewed; Defendants' intentional failure and refusal to contact and/or interview sources provided to Defendants and/or who Defendants otherwise knew to have extensive knowledge and/or experience concerning Plaintiffs; Defendants' failure to check certain facts and implications set forth in the Book, including those set forth above, before publishing and disseminating the Book; Defendants' selective, misleading and out of context use of statements and alleged quotations in order to create false impressions concerning Plaintiffs, and the experience and credibility of people who purportedly commented on Plaintiffs. 8. Plaintiffs are informed and believe, and thereon allege, that as a proximate result of Defendants' publication of the statements in the Book as alleged above, prospective customers have been deterred from seeking Plaintiffs' services, and existing clients may be deterred from continuing their patronage, and from otherwise dealing with Plaintiffs. Plaintiffs have thereby suffered and will continue to suffer general special damages, including loss of business, loss of goodwill and injury to business reputation, in an amount to be proven at the time of trial. Plaintiffs are informed and believe and thereon allege that the aforementioned acts of Defendants, and each of them, were done intentionally and/or with a conscious disregard of Plaintiffs' rights, and with the intent to vex, injure or annoy Plaintiffs such as to constitute oppression, fraud or malice, thus entitling Plaintiffs to exemplary or punitive damages in an amount appropriate to punish or set an example of Defendants, and each of them, and to deter such conduct in the future, which amount will be proven at trial.
SECOND CAUSE OF ACTION
(For Defamation By All Plaintiffs Against All Defendants)
9. Plaintiff repeats, realleges and incorporates herein
by reference each and every allegation contained in Paragraphs 1
through 102 and 104 through 106, inclusive, as though fully set forth
herein. 10. Defendants printed, disseminated, published and circulated, or caused to be printed, disseminated, published and circulated, in California and elsewhere, the Book, which is libelous as to Plaintiffs. 11. The statements in the Book referenced in Paragraph 102 among others, are false and defamatory as to Plaintiffs: 12. The aforementioned portions of the Book, among others, are false and defamatory as to Plaintiffs in that, among other things, they disparage and malign Plaintiffs and their reputations and suggest that Plaintiffs are inexperienced and lacking credential to perform their work; engage in unethical and unfair business practices in a manner that is not followed by those in the same or similar industries; are motivated by pecuniary gain to the detriment of the public interest and their clients; have not conducted themselves with integrity and fairness and in accordance with their duties to clients and the general public; have violated statutory and common law and appropriate business practices; and are not worthy of trust and respect. 13. The Book was intended by Defendants, and each of them, to be read, and the Book was read, by people in the County of Los Angeles, State of California, and throughout the United States. Plaintiff is informed and believes and thereon alleges that Defendants have used the Book to advertise and promote their activities and businesses. If and to the extent that any Defendant used any portion of the Book to advertise or promote his or its activities or businesses, such conduct is also wrongful and actionable. 14. The defamatory statements in the Book were unprivileged and were intended by Defendants to directly injure Plaintiffs with respect to their reputation, character, profession, trade and business, including Plaintiffs' credibility, integrity, and standing in the area of security and domestic violence issues. 15. The defamatory statements in the Book as described above are reasonably susceptible of a defamatory meaning on their face in that the false and defamatory statements have a direct tendency to injure Plaintiffs with respect to their reputation, character, profession and business. 16. The defamatory statements in the Book alleged hereinabove were made and published with actual malice, with knowledge that they were false or with a reckless disregard for the truth or falsity of the statements. 17. Plaintiff is informed and believes, and thereon alleges, that as a direct and proximate result of the printing, dissemination, publication and circulation of the Book, Plaintiffs have suffered and will continue to suffer general damages, including, but not limited to, damages to their reputation and standing in the community, in an amount to be proven at the time of trial. 18. Plaintiffs are informed and believe, and thereon allege, that as a direct and proximate result of the wrongful conduct by Defendants as alleged herein, Plaintiffs have suffered and will continue to suffer special damages, including, but not limited to, damage to Plaintiffs' business, profession, character and property, in an amount to be proven at the time of trial. 19. Plaintiffs are informed and believe and thereon allege that the aforementioned acts of Defendants, and each of them, were done intentionally or with a conscious disregard of Plaintiffs' rights, and with the intent to vex, injure or annoy Plaintiffs such as to constitute oppression, fraud or malice, thus entitling Plaintiff to exemplary or punitive damages in an amount appropriate to punish or set an example of Defendants, and each of them, and to deter such conduct in the future, which amount will be proven at trial. THIRD CAUSE OF ACTION
(For Unfair Business Practices and Other Acts In Violation of § 17200
of the California Business and Professions Code
and for Permanent Injunction - By All Plaintiffs Against All Defendants)
20. Plaintiffs repeat, reallege and incorporate herein by
reference each and every allegation contained in Paragraphs 1 through
102 and 104 through 106, inclusive, as though fully set forth herein.21. Defendants' publishing and disseminating of the defamatory and disparaging statements about Plaintiffs with the intent to deceive the public, current clients, and prospective clients constitutes unfair business practices in violation of § 17200 et seq .of the California Business and Professions Code. 22. Plaintiffs allege on information and belief that as a direct and proximate result of Defendants' unfair business practices and violations of § 17200 et seq . of the California Business and Professions Code, Plaintiffs have suffered and will continue to suffer general damages, including, but not limited to, damages to Plaintiffs' reputation and standing in the community, in an amount to be proven at the time of trial. 23. Plaintiffs are informed and believe and allege thereon that as a direct and proximate result of the unfair business practices of Defendants in violation of § 17200 et seq ., Plaintiffs have suffered and will continue to suffer special damages, including, but not limited to, loss of business, loss of clients, and other losses and damage to Plaintiffs' business, in an amount to be proven at the time of trial. 24. Plaintiffs are informed and believe and allege thereon that the acts of Defendants, and each of them, as alleged hereinabove, were done intentionally or with a conscious or reckless disregard of the truth or falsity of the defamatory statements alleged above, with a conscious disregard of Plaintiffs' rights, and with the intent to vex, injure or annoy Plaintiffs such as to constitute oppression, fraud or malice, thus entitling Plaintiffs to exemplary or punitive damages in an amount appropriate to punish or set an example of Defendants, and each of them, and to deter such conduct in the future, which amount will be proven at trial. 25. Plaintiffs also seek a permanent injunction against any further violation of § 17200 et seq . of the California Business & Professions Code, including, but not limited to a preliminary injunction and permanent injunction preventing Defendants or any of them from publishing or disseminating false, defamatory or disparaging statements about Plaintiffs or their services, which statements are determined to be unprotected by the First Amendment to the U.S. Constitution. WHEREFORE , Plaintiffs pray for judgment against Defendants, and each of them, as follows: ON THE FIRST CAUSE OF ACTION: 1. For general and special damages against Defendants and each of them, according to proof at the time of trial; 2. For exemplary and punitive damages against each of the Defendants in an amount sufficient to punish and deter Defendants, and each of them; 3. For costs of suit herein; 4. For interest at the maximum legal rate; 5. For such other relief as the Court deems just and proper. ON THE SECOND CAUSE OF ACTION: 6. For general and special damages against Defendants and each of them, according to proof at the time of trial; 7. For exemplary and punitive damages against each of the Defendants in an amount sufficient to punish and deter Defendants, and each of them; 8. For costs of suit herein; 9. For interest at the maximum legal rate; 10. For such other relief as the Court deems just and proper. ON THE THIRD CAUSE OF ACTION: 11. For general and special damages against Defendants and each of them, according to proof at the time of trial; 12. For exemplary and punitive damages against each of the Defendants in an amount sufficient to punish and deter Defendants, and each of them; 13. For a preliminary injunction and a permanent injunction against any further violation of § 17200 et seq .of the California Business & Professions Code, including, but not limited to, a permanent injunction preventing Defendants or any of them from publishing or disseminating false, defamatory or disparaging statements about Plaintiffs, which statements are determined to be unprotected by the First Amendment to the U.S. Constitution. 14. For costs of suit herein; 15. For interest at the maximum legal rate; ON ALL CAUSES OF ACTION: 16. For such other relief as the Court deems just and proper. DATE: July __, 2003 LAVELY & SINGER PROFESSIONAL CORPORATION JOHN H. LAVELY PAUL N. SORRELL By:_________________________________ PAUL N. SORRELL Attorneys for Plaintiffs EXHIBIT "A"
CHAPTER 7 of Among the Mansions of Eden (pages 208-214)
"Security Chic"
Rebecca Schaeffer's murder sent a fresh shock wave through
Beverly Hills. The entertainment industry's top personal managers
quickly organized a conference to address the stalking "epidemic." At
that meeting all eyes turned to one man, an individual who had
established himself as show business's foremost authority on celebrity
security: Gavin de Becker, CEO of Gavin de Becker, Inc., security broker
to the stars. De Becker was in one sense an unlikely security maestro. He had never been in the CIA or the FBI, never served as a police officer, a county sheriff, or even a meter reader. But he did possess some vital qualities for succeeding in Beverly Hills: an uncanny theatrical instinct and a prodigious ability for self-promotion. In a city full of re-created people who preferred legends to facts under any and all circumstances, these qualities far outweighed such mundane trivialities as experience and professional qualifications. Gavin de Becker's rise from obscurity to High Priest of Celebrity Security was almost as inspiring as Hershel Geguzin's journey from Lithuanian peasant to Russian prince. The product of a broken home that was rife with domestic violence, de Becker in his own words "grew up on welfare and food stamps." When he reached his teens, Gavin moved into a one-bedroom apartment in South Central Beverly Hills so he could attend Beverly Hills High. He struck up a friendship with Dean Martin's daughter, and when he graduated from Beverly High in 1975, Martin's wife, Jeanne, recommended Gavin for a position as a bodyguard for Elizabeth Taylor and Richard Burton. To the nineteen-year old de Becker, it was a job that, he later admitted, "I was in no way qualified for." But "I had moxie and some ability." He possessed a natural charisma and air of authority that was quite unusual for a man not yet twenty years old. Taylor took a liking to him and began recommending him to friends. Over the next decade his client list rapidly expanded to include Cher, Robert Redford, Dolly Parton, Jane Fonda, Joan Rivers, Victoria Principal, Brooke Shields, Olivia Newton-John, Tina Turner, Bill Cosby, and John Travolta. By 1989 Gavin had more than a hundred celebrity accounts. As his client list expanded, so did de Becker's ambitions. He took note of the growing number of demented fan letters that his customers received, and decided to keep files on the individual letter writers. By the time of Rebecca Schaeffer's murder he had more than 200,000 letters and had kept track of the writers who became violent, and those who made threats but never took action. De Becker then joined forces with a forensic psychiatrist, Park Dietz, who had testified at the trials of John Hinckley and other stalkers. It was a mutually advantageous alliance: De Becker gave Dietz an unprecedented mother lode of research data, and Dietz helped de Becker develop a computer program that analyzed the language patterns of demented letters to determine which fans were harmless and which were likely to pose a physical threat to a celebrity. The psychological profiling angle created a whole new revenue stream for de Becker. He now insisted that his clients turn all of their fan mail over to him so he could identify potential stalkers and neutralize them before they showed up at a celebrity's doorstep with a .357 Magnum. The star of a hit television series received as many as 20,000 letters a week, which translated into thousands of billing hours for de Becker. Celebrities forked over anywhere from $30,000 to six figures a year for Gavin's mail-reading service. And once he controlled the mail, de Becker controlled the clients. He advised them not to file restraining orders against psychotic fans, or to inform the police that they were being harassed. The police are hamstrung by civil rights laws, Gavin argued. Restraining orders have no teeth and might provoke a violent response from a psychopath. A more prudent course of action was to let Gavin put a surveillance team on a potential troublemaker and discreetly monitor his activities. If a stalker actually tried to make a move, de Becker's operatives would swiftly move in to intercept him. Of course this approach had other benefits. By keeping law enforcement officials out of the loop, Gavin precluded the possibility that they might bring the case to a swift conclusion or question de Becker's judgment when he decided to put a fan under costly twenty-four-hour surveillance. Identify two or three potentially dangerous stalkers per client and you've boarded an express train to fat city. De Becker charged customers anywhere from $225,000 to $475,000 a year for twenty-four-hour protection. His prices were exorbitant - some law enforcement veterans would say ridiculously exorbitant - but in a city that equates price with quality this only served to prove that de Becker was the best in the business. So when he spoke for more than two hours at the emergency summit of entertainment managers in the summer of 1989, the showbiz high rollers did not fidget or complain but sat in rapt attention as Gavin assailed the police for treating stalking victims with indifference and hostility. What was needed, de Becker argued, was an elite corps of stalking specialists within the LAPD to deal with the crisis. Also in the audience that afternoon was Robert Martin, a supervising detective with LAPD. Martin was keenly aware of the new antistalking bill that had just been passed by the California legislature, which made it a crime to willfully or maliciously follow, harass, or instill fear in a person. Rebecca Schaeffer's murder had put LAPD under tremendous pressure to take some kind of action, and Martin thought de Becker had just spelled out what that action should be. So Martin established the LAPD's Threat Management Unit (TMA) to deal with stalking cases, and enlisted de Becker as a special consultant. It was a beautiful maneuver that further solidified Gavin's position as the world's leading expert on stalking. After Martin retired from LAPD he went to work as vice president for Gavin de Becker, Inc. In 1997 de Becker placed the final capstone on his personal myth by publishing The Gift of Fear , a melodramatic chronicle of his career in the personal security industry that became a bestseller. In it he portrayed himself as part spymaster, part psychoanalyst extraordinaire engaged in high-stakes chess games with evil genius stalkers who were out to rob the world of his glamorous clients. The book was plastered with endorsements from celebrities - Theresa Saldana, Victoria Principal, David Mamet, Janet Reno - and in the acknowledgments Gavin expressed gratitude for the encouragement and support he received from his "extraordinary friends" Joan Rivers, Brooke Shields, Jennifer Grey, Michael J. Fox, Tom Hanks, Jeff Goldblum, Laura Dern, Garry Shandling, Oprah Winfrey, Robert Redford, Tina Turner, Michael Eisner, and on and on. Gavin de Becker, refugee from a broken home in Baja Beverly Hills, had made it to the other side of the rainbow. He joined the beautiful people in their walled-in paradise by helping them to keep others out. "He's more than an employee, he's a member of the family," says the personal assistant for an A-list movie star, who reports that de Becker attends all of the star's parties and invariably shows up each time with a new starlet on his arm. "He's quite the ladies' man. He's even dated some major stars, like Geena Davis and Alanis Morrissette." But for all of his marketing savvy, de Becker failed to anticipate that in throwing the spotlight on himself and pushing for the formation of the Threat Management Unit he was creating a Frankenstein monster. Before long others began to see that hey, there's a shitload of money to be made here! If some little Beverly Hills brat with no law enforcement experience can cash in on this stalking bonanza, why not me? Like the sorcerer's apprentice, Gavin unwittingly created a legion of de Becker clones who stampeded into the marketplace. After Robert Martin departed from the Threat Management Unit, Lieutenant John Lane took over. During the seven years that Lane ran the TMU he worked a number of celebrity cases and hooked up with a forensic psychiatrist of his own, Michael Zona, who served as an adviser and reserve officer in the LAPD. In 1997 Lane and Zona retired from the force to set up their own private security company, the Omega Group, which followed the de Becker template by offering mail-reading services, psychological profiling, and intensive 24/7 security and surveillance teams. Park Dietz, the forensic psychiatrist who initially served as de Becker's adviser, also started a company of his own - Threat Assessment Group - which advises corporations on how to deal with stalking problems in the workplace. Dietz trademarked the term "Threat Assessment" in an attempt to preserve his identity as one of the pioneers in the field. And two of de Becker's security men, Dennis Bridwell and Dan Palmer, defected to start another knockoff, Galahad Protective Services. Galahad added a brilliant touch of theater by placing their HQ in a nondescript building with blacked-out windows and a sign for a fictitious business on the front door - a James Bondian ploy that provokes laughter from veteran private detectives and police officers, but plays like gangbusters with the customers. De Becker haughtily denounces all these Johnny-come-latelies as "frauds or wannabes," pretenders to his throne as security guru to the stars. But there's an undercurrent of stridency in his words; the first beads of cold sweat are forming, for his business has suddenly gotten a lot more competitive. Some of his rivals specialize in undercutting him. Instead of performing a lengthy and expensive background investigation and psychological profile of a stalker, followed up by even more costly surveillance work, one private detective prefers a more confrontational and cost-effective approach. "I had a client who was a television executive. An ex-boyfriend who she hadn't heard from in a year and a half started calling her and getting real weird - sent her some very strange Halloween cards and stuff. So one night he called her at home, and as soon as she hung up she paged me. So I called him up right away. I said, 'Hey listen, you don't know me. Let me tell you my background and how this is gonna work if you call her again. I'm coming down to where you work and I'm gonna tell your boss that I want to talk to you and I'm gonna give your boss my business card, which says private investigator on it, and then I'm gonna come in and talk to you. After I talk to you then I'm gonna start watching everything you do, and if you call her again, I'm going to start keeping track. I'm going to go to the police and we're going to file a civil suit and we're gonna do this and we're gonna do that and at some point in time it's all going to become public record and then I'm going to tell your boss and he's gonna fire you because you're a fucking psycho. So you know what? Don't fucking call again.' He never called her again. End of case." But the discount operators are the least of de Becker's worries. With celebrity security now generating more than $100 million in revenue each year, this market niche has now become attractive to the big boys. Kroll International, the Microsoft of the private security industry, has thrown its hat into the ring. Kroll's core business is corporate security, but recently it's begun to recruit officers from the TMU. Industry insiders see this as a clear signal of Kroll's intention to invade the celebrity market. The harsh reality is that the days when a single entrepreneur like de Becker could monopolize celebrity security are over. In the new Darwinian environment, independent operators who carve out even more specialized niches have the best chance of surviving. Some have already done it. Basil Stevens, CEO of Close Range International, provides security to rock and pop stars like Madonna, Celine Dion, Michael Jackson, the Rolling Stones, and Run-D.M.C. As a Secret Service agent during the Ford administration, Chuck Vance had to stick close to President Gerald Ford's daughter, Susan. So close that he ended up marrying her. Vance retired from the Service in 1979 and opened his own security firm, Vance International. Drawing upon his father-in-law's copious connections, Vance specialized in providing security for visiting foreign dignitaries, especially filthy rich Saudi Arabians. * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * EXHIBIT "B" SOURCES OF CHAPTER 7 "SECURITY CHIC" Sources for the passage on the booming security business in Beverly Hills include David Weddle's and Howard Libes's observations; Howard Libes's interviews with Dr. Michael Zona, John Lane, Michael Eubanks, Heidi Prince, general manager of the Counter Spy Shop; David Weddle's interviews with members of the personal security industry, Beverly Hills residents, and personal assistants to feature-film stars; Howard Libes's correspondence with Gavin de Becker; The Gift of Fear by Gavin de Becker; promotional material provided by the Omega Group and the Officers Group; promotional materials provided by the Counter Spy Shop; "Ill Be Watching You" by Lisa Leff, Los Angeles, March 2000; "The Follower" by Bill Hewitt, People, February 28, 2000; "Wilson Signs Tough Anti-Stalking Bill" by Lisa Fernandez, Los Angeles Times, August 6, 1997; "New D.A. Unit to Stake Out Stalking Cases" by Jose Cardenas, Los Angeles Times, July 23, 1997; "Stalking in L.A." by Jeffrey Toobin, The New Yorker, February 24 & March 3, 1997; "When the Law Can't Protect" by Miles Corwin, Los Angeles Times, May 8, 1993; "Inside Celebrity Obsessions" by Scott Hays, Los Angeles Times, October 17, 1990. The source for current crime statistics in Beverly Hills is Beverly Hills Economic Profile - 2001-2000, published by the Beverly Hills Chamber of Commerce. Sources for the overview of the stalking phenomenon include Howard Libes's interviews with Dr. Michael Zona, John Lane, Michael Eubanks; David Weddle's interviews with members of the personal security industry; Obsessed: The Stalking of Theresa Saldana by Ronald M.D. Markman and Ron Labrecque; "Kidman Wins Restraining Order," Los Angeles Times, May 31, 2001; "Long Strange Trip," Los Angeles Times, May 29, 2001; "She's Not Interested," Los Angeles Times, May 11, 2001; "Stun Gun Justice," Los Angeles Times, April 20, 2001; "Quick Takes," Los Angeles Times, March 29, 2001; "Actor Spade Attacked by Intruder in Beverly Hills Home," Los Angeles Times, November 30, 2000; "Key Advice on Stalkers; Don't Underestimate Their Tenacity" by Gina Piccalo, Los Angeles Times, October 15, 2000; "The Follower," by Bill Hewitt, People, February 28, 2000; "Wilson Signs Tough Anti-Stalking Bill" by Lisa Fernandez, Los Angeles Times, August 6, 1997; "New D.A. Unit to Stake out Stalking Cases" by Jose Cardenas, Los Angeles Times, July 23, 1007; "Stalking in L.A." by Jeffrey Toobin, The New Yorker, February 24 & March 3, 1997; "Madonna Bodyguard Describes Intrusion" by Andrea Ford, Los Angeles Times, January 5, 1996; "When the Law Can't Protect" by Miles Corwin, Los Angeles Times, May 8, 1993; "In the Mind of a Stalker" by Mike Tharp, U.S. News & World Report, February 17, 1992; "Inside Celebrity Obsessions" Scott Hays, Los Angeles Times, October 17, 1990. The source for the passage on the murder of Ned Doheny is Dark Side of Fortune: Triumph and Scandal in the Life of Oil Tycoon Edward L. Doheny by Margaret Leslie Lewis. The sources for the description of Buster Keaton's encounter with a stalker include Keaton by Rudi Blesh and Keaton-The Man Who Wouldn't Lie Down by Tom Dardis. The source for the passage on Joan Berry and Charlie Chaplin is Chaplin: His Life and Art by David Robinson. The source for the passage on Lana Turner is Lana by Lana Turner. Sources for the passage on Charles Manson include Helter Skelter by Vincent Bugliosi and Curt Gentry, "The Long Chilling Shadow of Manson" by Richard C. Paddock, Los Angeles Times, August 6, 1994. Sources for the widening gap between America's rich and poor include "A Nation Divided" by Mortimer B. Zuckerman, U.S. News & World Report, October 18, 1999; David Green, U.S. News & World Report, July 26, 1999. Sources for the passage on the development of the stalking phenomenon include Howard Libes's interviews with Dr. Michael Zona, John Lane, Michael Eubanks; David Weddle's interviews with members of the personal security industry; Obsessed: The Stalking of Theresa Saldana by Ronald M.D. Markman and Ron Labrecque; "KidmanWins Restraining Order," Los Angeles Times, May 31, 2001; "Long Strange Trip," Los Angeles Times, May 29, 2001; "Quick Takes," Los Angeles Times, March 29, 2001; "City of Angels" by Ann O'Neill, Los Angeles Times, May 15, 2001; "She's Not Interested," Los Angeles Times, May 11, 2001; "Stun Gun Justice," Los Angeles Times, April 20, 2001; "Actor Spade Attacked by Intruder in Beverly Hills Home," Los Angeles Times, November 30, 2000; "Key Advice on Stalkers: Don't Underestimate Their Tenacity" by Gina Piccalo, Los Angeles Times, October 15, 2000; "I'll Be Watching You," by Lisa Leff, Los Angeles, March 2000; "The Follower" by Bill Hewitt, People, February 28, 2000; "Wilson Signs Tough Anti-Stalking Bill" by Lisa Fernandez, Los Angeles Times, August 6, 1997; "New D.A. Unit to Stake Out Stalking Cases" by Jose Vardenas, Los Angeles Times, July 23, 1997; "Stalking in L.A." by Jeffrey Toobin, The New Yorker, February 24 & March 3, 1997; "Madonna Bodyguard Describes Intrusion" by Andrea Ford, Los Angeles Times, January 5, 1996; "When the Law Can't Protect" by Miles Corwin, Los Angeles Times, May 8, 1993; "In the Mind of a Stalker" by Mike Tharp, U.S. News & World Report, February 17, 1992; "Inside Celebrity Obsessions" by Scott Hays, Los Angeles Times, October 17, 1990. Sources for the development of Gavin de Becker's career and the growth of the stalking industry in Los Angeles include David Weddle's observations and interviews with members of the personal security industry, Beverly Hills residents and personal assistants to feature-film stars; Howard Libes's interviews with Dr. Michael Zona, John Lane, Michael Eubanks, Heidi Prince, general manager of the Counter Spy Shop, and correspondence with Gavin de Becker; The Gift of Fear by Gavin de Becker; promotional materials provided by the Omega Group and the Officers Group, promotional materials provided by the Counter Spy Shop; "I'll Be Watching You" by Lisa Leff, Los Angeles, March 2000; "The Follower" by Bill Hewitt, People, February 28, 2000; "Wilson Signs Tough Anti-Stalking Bill" by Lisa Fernandez, Los Angeles Times, August 6, 1997; "New D.A. Unit to Stake Out Stalking Cases" by Jose Cardenas, Los Angeles Times, July 23, 1997; "Stalking in L.A." by Jeffrey Toobin, The New Yorker, February 24 & March 3, 1997; "Mister Know-It-All" by Steve Daly, Entertainment Weekly, August 23, 1996; "When the Law Can't Protect" by Miles Corwin, Los Angeles Times, May 8, 1993; "Inside Celebrity Obsessions" by Scott Hays, Los Angeles Times, October 17, 1990; "High-Tech Methods - He Stars as Protector of Celebrities" by Beverly Beyette, Los Angeles Times, March 10, 1989. Sources for the description of "The Dynamics of Stalking" seminar include Howard Libes's observations and promotional materials provided by California K-9 Academy and Picore & Associates. |
Thursday, March 20, 2014
The curse of faked fear- Kroll, Debecker and the cops who love them
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