Dr Christopher Amann v. CM Punk & Colt Cabana
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8/19/2019 Dr Christopher Amann v. CM Punk & Colt Cabana
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IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS
COUNTY DEPARTMENT LAW DIVISION
CHRISTOPHER M. AMANN,
Plaintiff,
v.
PHILLIP JACK BROOKS a/k/a CM Punk ;
and SCOTT COLTON a/k/a Colt Cabana ,
Defendants.
)
)
) Case No.
)
)
)
)
)
)
)
COMPLAINT
, '
/ , r
'
c
Plaintiff, Christopher M. Amann, by his attorneys, Deutsch, Levy Engel, Chartered, as
his Complaint against Defendants, Phillip Jack Brooks a/k/a
CM
Punk and Scott Colton a/k/a
Colt Cabana, alleges as follows:
COMMON ALLEGATIONS
1.
Plaintiff, Christopher M. Amann ( Amann ) is a resident ofWill County, Illinois.
Amann is a licensed medical doctor of good standing in the State of Illinois. Amann concentrates
his medical practice in the areas
of
sports medicine and orthopedics. From 2010 through the
present time, Amann has practiced medicine as the Senior Ringside Physician for World
Wrestling Entertainment, Inc. ( WWE ), and in this capacity has provided and continues to
provide medical care and treatment to professional athletes affiliated with WWE.
2. Defendant, Phillip Jack Brooks ( Brooks ) is a Cook County resident, who, at
times relevant to this Complaint, worked as a professional wrestler with WWE as CM Punk.
3.
Defendant, Scott Colton ( Colton ) is a professional wrestler formerly affiliated
with WWE, whose affiliation was terminated by WWE in 2009. In addition to working as a
professional wrestler as Colt Cabana, Colton hosts and distributes a weekly podcast entitled
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[
The rt of Wrestling in which, among other things, he interviews professional wrestlers. The
rt of Wrestling is published world-wide by Colton, including through a link on his website
(accessible through the URLs www.welovecolt.com and www.coltcabana.com) and through
iTur1es. Colton also publishes his The rt of Wrestling podcasts via streaming services at
http://soundcloud.com/coltcabana and on YouTube. On information and belief, Colton resides in
Cook County, Illinois.
4.
On or about November 26, 2014, Colton first published The rt of Wrestling,
episode No. 226, featuring his interview with Brooks ( the Podcast ). (A transcript
of
the
Podcast is attached as Exhibit A). Since November 26, 2014, the Podcast has been available
on
the internet for streaming and download through the date
of
this Complaint's filing. On
information and belief, as of this Complaint's filing, the Podcast has been streamed in excess of
1,000,000 times on Y ouTube and more than 10,000 times on SoundCloud. com in addition to
downloads through iTunes and streaming through other websites.
5. In the Podcast, Brooks repeatedly and falsely impugned the integrity of Amann as
a medical doctor, stating in substance that: (i) Amann misdiagnosed a growth on Brooks' back as
a harmless fatty deposit ; (ii) Amann willfully disregarded Brooks' repeated requests over time
that Amann excise the growth; and (iii) due to Amann s professional negligence and failure to
adequately treat Brooks, the lump grew to the size of a baseball, was purple, and morphed into a
life-threatening, full-blown MRSA staph infection. Brooks also stated that despite his
complaints to Amann of pain and discomfort from the growing baseball-sized purple lump,
Amann continued to allow Brooks to wrestle and refused to excise the growth. In addition,
Brooks stated in substance that Amann lacked professional competence to properly treat a
concussion, prescribed antibiotics for a concussion (Transcript p. 80), and subjected Brooks to
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unnecessary tests when it was pretty goddamn obvious Brooks had a concussion. (Transcript
pp. 39-40). Brooks further stated that when he told Amann, in the midst
of
his Royal Rumble
match, that he had a concussion after being struck by an opponent, Amann asked Brooks what he
should do, to which Brooks started laughing and I was just like, 'Doctor, you are the most
worthless piece
of
shit
I've
ever
met. '
(Transcript pp. 84-85). In the course
of
the Podcast,
Colton affirmed Brooks ' statements and assisted Brooks in depicting Amann as a doctor who
negligently did not excise the alleged growth because he was lazy, to the point where the
growth became so large and dangerous, it had teeth. Colton urged listeners to hear the
struggle and hear the heartache in Brook's statements in which he was telling ''the whole
story so listeners would understand what [Brooks] was going through and why the decisions
were made. (Transcript pp. 4-5, 7).
6
In the Podcast, Brooks and Colton made and published the following statements
with regard to Amann's purported misdiagnosis, failure to adequately treat Brooks, and lack
of
competence and ability as a medical doctor who placed his employer's business interests above
his patient's medical needs:
Brooks: The big thing that led to my decision [to leave WWE] was my health.
1
(Transcript p. 19).
...so Doc was leaning on me going Do you want me to-- do you
have a concussion or can you go to Europe, kind
of
thing. And I
was just like you fuckin' --you pigs,
I'll
go to Europe, whatever.
After the European tour, the whole European tour
I'm
dry heaving
after every match .. .l'm on all fours after every match and I'm
either puking for real or
I'm
just dry heaving because I don't
having anything in my stomach. I have no appetite. I
don't
know
I. In the Podcast, Amann is initially identified as Doc. Reasonable listeners would identify Doc as Dr. Amann
because in the Podcast Brooks specifically names Dr. Amann (Transcript p. 45) and Amann was the Doc (doctor)
on duty at the Royal Rumble referred to by Brooks in the Podcast.
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what is up and what is down. I can't sleep, I
can t
fuckin' train.
(Transcript pp. 73-74).
Doc-- Doc is giving
me--
Doc's like, Oh you're sick, here's a
Z-
Pak. They Z-Pakked me to death, so much that in December I shit
my pants on a Smack Down because that's what antibiotics do to
you, right?
(Transcript p. 74).
Somewhere along the way I get this fucking lump on my fuckin'
back. This is where it gets good. So I go to Doc and I go fucking
look at this, this wasn 't here last week, what is that? Oh it looks
like
a-- a --
a-- what did he call it, not a hematoma, a fatty, I don't
know, he said it was like a fatty deposit. He asked me if it hurt, I
said no, I said, but it wasn't there last week, and
it s
been a long
tradition in the WWE locker rooms, when somebody has
something like that Doc cuts it out, everybody watches it, people
film it, it s the weirdest fuckin' thing.
Colton: Yeah.
(Transcript pp. 78-79).
Brooks: So they- they tell me no, we're not going to do anything
about it because it s just- it s just like a fatty deposit, whatever,
it 's like a calcium deposit, whatever, so I fuckin', I let it go, fine.
It
gets bigger. A couple months later,
I m
like, This things got
fuckin' bigger.
Does it hurt?
No.
Well, then, let' s just leave it.
Let me ask you something, Doc, are you just -- is that like your
medical opinion or are you just a lazy piece of shit and
don t
want
to fuckin' do it, because
I ve
seen you cut a million of these things
out of somebody.
Well, you got to wrestle tonight, and blah, blah, blah, and it
might need like a stitch. I m like, So fucking what? You've put
14 staples in my forehead and then
I ve
had to go out that same
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night and wrestle again. What is preventing you from -- from -
from helping me?''
Well, it s-- it' s, blah, blah, blah.
Colton: Did you have like a theory or --
Brooks: Did I have a theory?
Colton: Yeah.
Brooks: No, I was just like what the fuck is this, it wasn't here
yesterday, get rid
of
it.
Colton: No, a theory on why he s not cutting.
Brooks: Nah, he s lazy.
Colton: Just lazy.
Brooks:
He s
lazy.
Colton: Crazy.
Brooks: I mean, and that's the thing, guys, I really feel like fuckin'
shit, I have broken ribs and I have a fuckin' concussion and they're
like, Here's a Z-Pak, Phil, and
I m
like fuck, okay, I take the Z
Pak, I can t sleep, here 's another Z-Pak, I take the Z-Pak, I shit my
pants in the ring.
I m
like what the fuck, you know, and then after
all that they gave me an even stronger antibiotic, and
I m
like all
right,
I ll
take this, maybe it'll make me feel better. t made me feel
worse. I had fuckin' goddamn diarrhea for like three weeks.
(Transcript pp. 79-80).
So I mean, everything fuckin' comes to a head and
I m
still
motivated. It's Royal Rumble season and I know Batista's coming
back and I know the Main Event [ofWrestleMania] is Batista
versus Randy Orton, but
I m
still,
I m
still that kid that was in the
car with you driving to fuckin' Pittsburgh and Philly and IWA and
I m
like
I m
going to change their minds,
I m
going
to-- I m
going
to have this awesome Royal Rumble and they're going to be like
goddamn, all right, Punk needs to be in the Main Event, he hasn't
been in the Main Event. You know, I remember watching Foley's
DVD and they interview Vince and Vince was like I thought it was
a shame that he didn't have his Wrestle Mania moment before he
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retired, so I coaxed him out of retirement and put him in the Main
Event, and so I saw that and
I'm like well, motherfucker, I'm still
here,
I'm
not retired yet. Well, my hard work's going to shine
through and I'm going to wow them with my fuckin , my fancy pro
wrestling skills and they'll realize that Randy Orton versus Batista
would be a big awesome stinker
of
a fucking match for a Main
Event of Wrestle Mania XXX and I -- I wrestle -- that day I
showed Doc that thing on my back, which was now purple and the
size
of
a fuckin' baseball.
Colton: t had teeth.
Brooks: And he went, Does it hurt, and I went, Yeah, actually,
it hurts like a motherfucker, and like the waistband of my tights
was like right on it, so like I was aware
of
it constantly and it was
so big that I felt like
ifl
bumped on it it would bust like, you know,
I
can't
pop it,
it's
not like a fuckin' zit
of
anything, and
he's
like
Well,
I'd
cut it out now, but you know, you got wrestle in the
Rumble,
I'd
probably want to put you on some antibiotics before I
put, and I went Motherfucker, I've been on antibiotics since
November, what are you doing? Just cut it, cut it right now. He
won't
do it. He just wouldn't do it. I didn't get it.
So I got to do this shit, I've got to wrestle in the Rumble, I'm
number one and I'm getting thrown out right at the end ..
(Transcript pp. 8 - 82).
So I flat back and I'm just fuckin' rocked, I'm out of it.
Colton: Number 12, 13?
Brooks:
So
I roll under the fuckin' corner and I motion to Doc and
I go, I have a concussion, and he was like, What do you want
me to do? And I jus t started laughing and I was like, Doctor, you
are one ofthe most worthless piece of shit I've ever met. --
Colton: Well, hold on.
Brooks:
-- in
my entire life.
Colton: I agree, but I don't agree.
Brooks: Right.
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Colton: But what does he do?
Brooks: This is -- this is miserable fucking Phil Brooks you're
talking about.
Colton: Okay.
Brooks: So he goes, Do you want me to tell somebody? I go,
No,
I'm
just going to sit here for a minute,
I'm
going to collect my
wits and then
I'll
go do my shit. Next thing I know one
of
the refs
is like, Kane's out here, he's going to pull you out early, and my
knee-jerk reaction from 15 plus years ofbeing a pro wrestler was
fuck you,
I'm
finishing this match. IfKane touches me
I'm
going
to fuckin' quit, you know, so then poor Glen's out there, he's like
shirtless wearing like business slacks.
Colton: Corporate -
Brooks: And he's crouching down and the camera's trying not to
shoot him and it was like chaos, but then eventually we did the
angle, he choke slammed me through the fuckin' thing and I
walked in back and Doc was there and he was like, Are you okay
and I was like, Cut this fuckin' thing out of me right now, like,
whatever the fuck it is, cut it out of me, like I -- I feel like fuckin'
shit, I've had a fever for weeks,
I'm
fuckin' green when I look at
myself on television, and he
won't
do it because now he's like,
Oh, it's the concussion, it's this,
it's
that, blah blah blah.
(Transcript pp. 86-87).
Brooks: And then they're like,
We
need you to sign this Visa for
this country because we're going
on
this tour, and I was like,
Right now, me, right now, in Cleveland, Ohio take fucking care of
me right fucking now.
Don't
worry about where
I'm
supposed to
be tomorrow, don't worry about what segment
I'm
supposed to be,
fucking fix me. My fuckin' rib's broken, my knee is fucking tom
up, I
am
fucking sick, fucking help me, and they were like, No,
you have to sign this, you have to piss in this, you have to fucking
go take this concussion test.
(Transcript pp. 88-89).
Colton: And I think that's the line, fucking help me.
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Brooks: My-- my -- my lovely wife convinced me to go to her
doctor in Tampa. I went to her doctor in Tampa. I walked in, I've
never met this guy, all right ... so I walked in, I never seen him
before, he's got no idea who I am,
he's
like, Okay, so what's the
problem? And I fucking yanked my shorts down and I show him
this fuckin' thing
on
my back.
Colton: What kind of doc - oh, okay.
Brooks: Yeah, yeah, yeah. And he looks right at it, he doesn 't
touch it, he just looked at it, cocks his head sideways and he goes,
That's a full-blown staph infection.
Colton: Full blown.
Brooks: Yeah, and I looked at him and I laughed, and you were
there when the doctor told me I had a fractured skull, same laugh, I
just went ha
ha
ha ha, like yeah, of course it is, I have a staph
infection because
of
course I do.
Colton: Right.
Brooks: Why not? And I was like, All right, what are you going to
do?'' And he was like, I mean, that's-- he's like that's like
MRSA, he's like, I can tell right now like that's-- the thing's
like purple and green. He's like, I can cut it out and you need to
go to a hospital and get like an antibiotic IV drip. And I was like,
Well,
let's
say we
didn't
have time for that, you know, he
just
loaded me up with antibiotics. He cut the thing, he squeezed it, shit
shot onto the ceiling. I've had tattoos in some of the most painful
places, I've fractured my skull, Ryback has broken my ribs, a kick
on purpose, I've wrestled three weeks after knee surgery, this was
the most painful experience ofmy entire life.
Colton: Wow.
Brooks: And I
don't
know why it hurt so bad.
Colton: Did it get videotaped?
Brooks: No.
Colton: Ooh.
Brooks: But I sweat like I was in the fucking Sahara desert, like I
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was clutching the table and this doc was just squeezing this shit
and he kept squeezing this shit and then he fuckin', he patched it
up, put a Band-Aid on it, and he gave me three months of
antibiotics and I was like great. And so I asked him, I was like
I've been on antibiotics for a long time, like why wouldn't it do
this? He is like Unless you're on specific antibiotics to kill a
MRSA infection, he's like a Z-Pak's not going to do anything.
Colton: And he's like you've been working on this thing?
Brooks: Yeah.
Colton: Did he say it was like possible to?
Brooks: He said how long? And I was like I don 't know, at least
three months. And he was like You should be dead. You could
have died, because you know, look up staph infections, people,
they're nothing to fuck with. So I get that taken care of. All
of
a
sudden, I can sleep. And I slept, for a long fucking time.
(Transcript pp. 97-99).
7. The statements
of
Brooks and Colton concerning Amann are false, both literally
and in their implications. Specifically:
(A) Amann was not requested by Brooks to treat and/or excise a lump, let
alone a purple, baseball-sized lump. Indeed, Brooks never advised Amann of any lump on
his back, let alone sought treatment from Amann for a lump on his back. He also never
showed a lump on his back to Amann for a medical diagnosis or treatment.
B)
Amann did not refuse to treat Brooks for a lump or growth of any kind.
(C)
Amann did not prescribe antibiotics to Brooks for a lump on his back,
broken ribs or a concussion.
(D) Amann, upon preliminary diagnosis of a possible concussion, directed that
Brooks leave the wrestling ring to avoid further injury and followed proper protocol,
including but not limited to attempting to remove him immediately from further contact
activity and requesting further evaluation and treatment ofBrooks in the training room.
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He at no time advised Brooks or suggested to him that the course of treatment for a
concussion, if any, was up to Brooks' discretion.
8.
Brooks and Colton published their statements
of
and concerning Amann with the
foreseeable expectation that they would be repeated by third persons, including through print and
on-line media, given Brooks' celebrity status as CM Punk and Colton's marketing of the
Podcast.
9. As a foreseeable consequence of the publication of the statements in the Podcast
by Brooks and Colton, articles were published in various media, reporting on Brooks' false
statements
of
and concerning Amann, as published by Colton in the Podcast, including but not
limited to:
(A) The Washington Post, on November 28, 2014: But perhaps the most
damning story Punk told about WWE s health and wellness policy was about the time the
company allegedly gave him bad antibiotics, which led to a cyst in his back to become a
life-threatening MRSA staph infection. Deadspin summarizes it pretty well. Starting at
around 1:13:00 in the video, Punk say the WWE's traveling doctor [Dr. Amann]
neglected a growth on his back that eventually became very painful. The doctor, he says,
would only prescribe generic antibiotics that only caused more issues. Near 1 30:00, Punk
says he visited a doctor in Tampa who told him that the cyst was in fact a full-blown
staph infection ... (Exhibit B).
(B) On November 27, 2014, the internet publication, 411mania.com
reported on the Podcast as follows: Punk went
off on a WWE doctor named Chris
Amann
...
Punk says he found a lump on his back, which Amann said was just a fat
deposit. Punk asked Amann to cut it out several times but Amann refused. The lump got
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bigger and turned purple and painful. Punk told Amann again before the Royal Rumble to
cut it out but Amann refused, saying Punk had to wrestle
....
After Punk left, he went to
another doctor that AJ Lee found for him, and that doctor diagnosed the lump as MRSA
staph infection and immediately drained pus out
of
it. Punk said the doctor was stunned
that he had been wrestling with the infection for months and said Punk 'should be dead.'
Punk blasted WWE for misdiagnosing and ignoring his infection which he worked with
for months." (Exhibit C).
(C) On December 4, 2014, The Washington Post again reported on the
Podcast, stating, "Punk alleged
WWE s
ringside doctor Chris Amann ignored a cyst on
Punk's back that ended up being diagnosed by another doctor as a life-threatening MRSA
infection." (Exhibit D).
(D) On November 27, 2014, the on-line publication "buzzfeed.com" reported
that in the Podcast it was stated that "Punk had been wrestling with an "odd lump in his
lower back that kept increasing in size and pain. WWE doctor Chris Aman [sic] called it
a 'fatty deposit' and issued a Z-Pak (antibiotics). Aman [sic] consistently cleared him for
action despite Punk's complaints that the lump was getting bigger and painful and the
antibiotics weren't effective. Punk eventually confronted the doctor after nothing was
being done to treat the lump and said, Let me ask you, Doc: Is that your medical opinion
or are you just a lazy piece of shit?' Another doctor eventually diagnosed Punk with
MRSA staph infection, to which he said to Punk, You should be dead. You could have
died ' " (Exhibit E).
(E) On November 27, 2014, the on-line publication "mindofcarnage.com"
reported on the Podcast published by Colton as follows: "CM Punk was particularly
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critical
of
WWE doctor Chris Amann in his appearance on the Colt Cabana podcast. In it,
Punk said Amann misdiagnosed and ignored a MERSA [sic] staph infection on his back
for months and that the first doctor Punk went to after leaving WWE was stunned to hear
that Punk wrestled with the infection for months, going as far as to say he could have died
from it. (Exhibit F).
(F) In its November 27, 2014 edition, sportingnews.com reported that in the
Podcast, Punk stated that he noticed a lump in his back in November, 2013 and that
[w]hen he asked Dr. Chris Amann (the official WWE doctor) about it, he said it was just
a 'fatty deposit' but he refused to cut it out despite Punk's request because it wasn't
causing him any pain. Over time, it got bigger and turned purple and was not [sic] causing
him some pain. Earlier in the day before the 2014 Royal Rumble, Punk again asked the
doctor to cut t out who said he couldn't because Punk was wrestling that night and he
had to be on antibiotics for it. This upset Punk even more because he had been on
antibiotics for the past three months to deal with his sickness. The article also included a
link to the Podcast. (Exhibit G).
(G) In its November, 2014 edition, Cool Wrestling News reported that in the
Podcast, Punk was particularly critical of Chris Amann,
WWE s
Senior Ringside
Physician. Punk said that Amann misdiagnosed and ignored a MRSA infection on his
back for months and that the first doctor he went to after leaving WWE was stunned to
hear that he wrestled with it. The doctor said he could have died from it. (Exhibit H).
(H) On November 27, 2014, the on-line publication Wrestling Rumors
reported on the Podcast as follows: Punk worked several months with MRSA, a very
serious staph infection. It s resistant to common antibiotics, so it needs a very specific
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kind
of
medicine to treat and cure
....
According to Punk, Chris Doc Amann (WWE's
primary physician who he refers to by name) avoided the issue and prescribed broad
spectrum antibiotics to tide him over. The gigantic lump which grew on his waistline was
causing him an immense amount of discomfort, yet Amann always found a way to avoid
cutting it out . .It was only when AJ Lee (his future wife) told Punk to visit her doctor in
Tampa Bay that the correct diagnosis was made.
If
he had waited any lcnger, there is a
very good chance that it could have killed him
....
Whether
it s
negligence or sheer
laziness, not treating Punk's symptoms with the utmost
of care is unacceptable no matter
which way you look at it
....
All
AJ s
doctor had to do was stare at the lump to tell how
serious the matter was. That's scary. (Exhibit 1 .
COUNT DEFAMATION
PER
SE AGAINST BROOKS AND COLTON
10. Amann restates and incorporates paragraphs 1-9
of
the Common Allegations,
including each of their respective subparts, as though they were fully stated in Count I
11. The statements
of
Brooks and Colton, and published by Colton, are false and
defamatory p r
s
in that they impute a lack of integrity in the performance
of
Amann's
professional duties as a medical doctor and/or an inability or lack
of
competence to perform his
professional duties as a medical doctor.
12.
Further, Colton affirmed and amplified Brooks' false and disparaging comments
and that Amann did not remove the lump because he was lazy, thus allowing the growth to
grow to the size of a baseball, turn purple and blue and was so apparent and obviously dangerous
that it had teeth. Colton further assured listeners that Brooks was disclosing all that
he s
wanted to get off his chest and now he has the opportunity to do it in a safe place with his friend
in his own house on a podcast that he trusts has no ulterior motives or anything .. . Hopefully you
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guys give it a real in depth listen, you hear it, you hear the story, you hear the struggle, you hear
the heartache. There's so much to it. (Transcript
p.
4). Colton also told listeners that Brooks was
telling the whole story without charge to get as many ears as possible to hear this to
understand what this man was going through and why the decisions were made. (Transcript pp.
4-5, 7). Through his participation in Brooks' false statements, Colton affirmed the statements and
communicated to listeners that the statements in the Podcast were truthful and substantive.
13.
Defendants knowingly fabricated the false and disparaging statements o and
concerning Amann.
14.
Brooks and Colton published the statements with negligence, in that they knew or
should have known that the disparaging statements
o
and concerning Dr. Amann were false
and/or failed to investigate the veracity o those statements.
15.
In the alternative, Brooks and Colton published the statements with knowledge
that they were false and/or with reckless disregard as to the truth o the statements.
16.
As a consequence o Defendants' defamatory publication, Amann suffered injury
to his reputation as a medical doctor.
WHEREFORE, Plaintiff Christopher M. Amann respectfully requests that this Court
enter judgment in his favor and against Defendants Phillip Jack Brooks and Scott Colton, award
him compensatory damages in an amount in excess
o
$1,000,000, punitive damages in an
amount to be determine at trial, and such other relief that this Court deems just and appropriate.
COUNT F LSE LIGHT INV SION OF PRIV CY
G INST BROOKS ND COLTON
17. Amann restates and incorporates paragraphs 1-9 o the Common Allegations,
including each o their respective subparts, as though they were fully stated in Count II.
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18. Defendants publicized the statements contained in the Podcast by marketing the
Podcast, offering it and making it available for streaming and/or downloading and disseminating
the Podcast to the public at large throughout the world.
19. The false statements and implications concerning Amann in the Podcast are highly
offensive in that they accuse Amann
o
a gross lack
o
integrity as a medical doctor, an inability
to perform his professional duties as a medical doctor, and in placing the financial interest
o
his
employer above life-threatening health conditions
o
his patients.
20. The publication
o
such falsehoods by Defendants was willful and wanton, and
was calculated to cause and did cause damage to Amann, causing Amann to suffer injury to his
reputation as a medical doctor.
21. Brooks and Colton published the statements with knowledge that they were false
and/or with reckless disregard as to the truth
o
the statements. Defendants knowingly fabricated
the disparaging statements o and concerning Dr. Amann.
WHEREFORE, Plaintiff Christopher M. Amann respectfully requests that this Court
enter judgment in his favor and against Defendants Phillip Jack Brooks and Scott Colton, award
him compensatory damages in an amount in excess
o 1,000,000, punitive damages in an
amount to be determine at trial, and such other rel ief that this Court deems
just
and appropriate.
Respectfully submitted,
Phillip J Zisook CHRISTOPHER M. AMANN
Brian D. Saucier
Deutsch, Levy Engel, Chartered
225 West Washington Street
Suite 1700
Chicago, Illinois 60606
T: (312) 346-1460
F: (312) 346-1859
Atty No. 90235
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