STATE OF MINNESOTA

COUNTY OF DAK.OT A
New School Communications, Inc., a
Minesota Cororation,
Blois Olson,
Plaintifs,
vs.
Michael B. Brodkorb and
www .minnesotademocratsexposed.com
Defendants.
DISTRICT COURT
FIST JUDICIAL DISTRICT
Case Type: Other Civil
Court File No.

COMPLAINT
Plaintifs New School Comunications, Inc, a Minnesota corporaton and Blois Olson
(together: "Plaintifs,
,
), for their complaints against Michael B. Brodkorb and
ww.mi esotademocratsexposed.com (together: "Defendants"), the Defendants herein,
state and allege as follows:
PARTIES A JURISDICTION
1. New School Communications, Inc. ("New School") is a corporation
organized under the laws of the State of Minnesota, with a registered address at 2124
Uruversity Avenue, St. Paul, Minnesota.
2. Blois R. Olson ("Olson") is a citizen of the state of Minnesota, residing at
2124 University Avenue, St. Paul, Minesot.
3. Olson is the President and Founder of New School.
4. Upon information and belief Michael B. Brodkorb ("Brodkorb") is a
citizen of the state of Minnesota residing at 4136 Countryvicw Drive, Eagan, Minnesota
,
55123.
5. w.minnesotademocratsexposed.com ("MDE") is a politicaJ activist
web site, which upon infrmation and belief is operated by Brodkorb. A tue and corect
printout ofME's home page on December 29, 2005 is attached hereto a Exhibit A.
6. This Cour has jurisdiction over this matter, where the defendant resides in
Dakota County and te damages alleged a in excess of f thousand dollars
($50,000.00).
FACTUAL ALLEGATIONS RELEVANT TO ALL CLAIMS
7. On or about December 28, 2005, Defndants published on the DME
website statements claiming:
a. That Plaintifs had been critical of the political campaign of Coleen
Rowley;
b. That Defendants has a "source,, in "contact" with the Rowley
campaign;
c. That New School, by and through Olson and New School
employee Hubert H. Humphrey T ("Humphrey"), solicited work
fom the Rowley campaign;
d. That New School's bid was rejected;
e. That Plaintifs only became critical of the Rowley campaign aer
the Rowley campaig declined to hire New School.
8. New School is a public relations agency working for a vaiet of frms in
the maket place, is such industies a Healt Care, Real Estate, Technology or Legal
A airs A te and correct print-out of New School's web site's "about us" page is
attached hereto as Exhibit B.
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9. New School does not perform political campaign and at no time did New
School ever submit a proposal to do work for the Rowley campaign.
I 0. On or about December 29, 2005, Plaitifs informed Defendants that New
School does not perform politcal campaign work. Exhibit A at p. 3.
11. Defndants have persisted in making, and a of the day of this complaint
continue to make. the claims detailed i paragaph 7.
12. Defendants seek to derive a monetary beneft from their political activism
by seeking donation to a so-called "legal defense fd." A true and correct printout of
te relevant page on DM's web site on December 29, 2005 is attached hereto as Exhibit
C.
COUNT I DEFAMATION
13. Plaintifs reallege all of the allegations set forth i the fregoing
paragraphs and incorporates them herein by reference.
14. Defndants made statement about Defndants that are provably false,
including:
a. That New School, by and through Olson and Humphrey, solicited
work fom the Rowley campaign;
b. That New School's bi d wa reected;
c. That Plaintifs only became critical of the Rowley campaign afer
the Rowley campaign declined to hire new school.
15. Upon information and belief, Defendants' "source" has no knowledge
about Plaintifs, Plaintifs' business or Plaintifs solicitations for public relation work,
and the "source" may, i fct, be a fabrication.
3
16. Upon infonnaton and belief, Defendants knew or should have known that
their "source" bas no knowledge about Plaintifs, Plaintiffs' business or Plaintifs
solicitations for public relation work.
17. Defendants knew that the "source's" information was false, or acted with
reekess disregad to whether the information was true or false.
18. Defendants communicated those statements to nuerous third parties by
publishing them on the ME website.
19. Damages are presumed from Defendants' malicious false statements.
20. Damages are presued because Plaintifs published false stalernents
injuring Plaintifs in their business or profession.
21. The fregoing constitutes Defamation P. er se.
22. By reason of the foregoing, Plaintif has sufered daages in a amount of
in excess of fify thousand dollars ($50,000.00).
COUT n IJCTI RLmF
23. Plaintifs reallege all of the alegations set fr m the fregoing
paragaphs and incorporates them herein by refrence.
24. Defendants' defamatory statements a continuing in nature, and wl
continue uless properly enjoinedW
25. Plaintifs are theatened wt irreparable harm by the continuing malicious
statements, which jure Plaintifs in teir business ad profession.
26. Daages are not an adequate remedy because the unlawful conduct by
Defendants is continuing and damages contnue to accrue. In addition, damages ae
4
difcult to ascertain, and only an end to Defendants' defamatory statements can alleviate
ongoing harm.
27. Plaintfs ae likely to succeed on the merits because
a. Defendants made false statements;
b. Defendants published false statements;
c. Defendants' false statements injured Plaintifs i their business and
profession;
d. Defendants' false statements are malicious.
28. The fregoing satisfes the conditions necessary to support the grant of
injunctive relief.
WRFOR, Plaintif requests the following relief fom the Coun:
1. A judgment for Plaintifs against Defendants in an amount in excess of fify
thousand dollars ($50,000.00).
2. A order requiring the immediate removal of all defamatory statements fom
Defendants' website.
3. An order enjoining Defendants fom making any further defamatory statements
about Plaintifs.
4. An order granting Plaintifs costs, disbursements, and reasonable attoreys' fees.
S. A order granting Plaintifs such other and further relief as the Cou deems just
and equitable.
[ECUTED ON THE N PAGE]
s
Date: December 29, 2005.
401912.2
Steven H. on (260769)
Jea B. Rot (0348181)
1700 U.S. Ba Pla South
220 South Si Street
l55402-511
ATTORNEYS FOR PLAINTIFFS
6
ACKNOWLEDGMENT
(hcundcrsgnedhcrcby acknowlcdcstha|approprato sanc|onsmay ocimposed
aanst thc partics and/orthcr a|tomcys pursuant\oMinncsota Stat

tc 549 .211 f|hc

Courtdctcnnncs|hatthrcIaims, dctcnscs orothcrIcaI contcp|ionscontaincd hcrcinarc
prcscnlcd !cr an mproper piaose, unwarrantcd oycxis|

nIaw,hivoIously prcscntcd,
withou| cvidcn|ary support, not rcason

oIy oascd upon knowIg c, inmrmation and

_____
o
_______
onaoIc

401912.2
7
StevenH. Si!|on(260769)
Jea B. Roth (0348181)