COMPLAINT FOR DEFAMATION AND FALSE LIGHT

This is an action by Mr. Larry Klayman, Esq. for defamation and false light against Mr. Harvey Berkman, Patrick R. Oster and American Lawyer Media, Inc., d/b/a/ The National Law Journal arising from an article that was published in The National Law Journal. Damages exceed the sum of $15,000, exclusive of interest, costs and attorney's fees.

JURISDICTION

1. Jurisdiction of this Court is founded on the District of Columbia Code � 11-921 (1981 ED., 1997 Supp.).

PARTIES

2. Plaintiff Larry Klayman ("Plaintiff") is the founder, Chairman and General Counsel of Judicial Watch, Inc., a public interest law firm based in Washington, DC that is dedicated to furthering honest government and respect for the law and fighting government corruption.

3. Defendant Harvey Berkman ("Berkman") is, on information and belief, a citizen of the District of Columbia, residing at 1436 Corcoran Street, N.W., Washington, DC 20009. Defendant Berkman is a writer for The National Law Journal and the author of two (2) articles concerning Plaintiff.

4. Defendant Patrick Oster ("Oster"), is Editor-in-Chief of The National Law Journal and, on information and belief, resides at 18 Hunter Place, Croton-On-Hudson, New York 10520.

5. Defendant American Lawyer Media, Inc., d/b/a The National Law Journal ("American Lawyer"), is a corporation incorporated under the laws of the State of New York and having its principal place of business at 345 Park Avenue, New York, New York 10010. Defendant American Lawyer publishes The National Law Journal, a weekly newspaper that is widely read by lawyers, judges and other members of the legal profession, as well as by diverse persons throughout the District of Columbia, the United States and the world.

FACTS

6. On information and belief, Defendants Berkman, Oster, and American Lawyer work and/or consult with lawyers, investigators and other agents of the President and Mrs. Clinton, including the law firm of Williams & Connolly, Mr. Terry Lenzner and employees and agents of Investigative Group International, Inc., in order to obtain documents and information, albeit incorrect, for articles about Plaintiff. On information and belief, Defendants have participated and are continuing to participate in unlawful violations of the civil and privacy rights of Plaintiff and others in an attempt to gather such documents and information about Plaintiff.

7. In an article appearing in The National Law Journal on November 8, 1999, Defendants Berkman, Oster, and American Lawyer caused the following false and misleading statements about Plaintiff to be published:

Five years ago, Larry Klayman was an obscure international trade attorney.

. . . .

Along for the ride will be Dolly Kyle Browning (whom Mr. Klayman is representing in a civil suit alleging that Mr. Clinton damaged her ability to publish a fictional account of their supposed 30-year relationship by denying that it ever occurred). . .

. . . .

A willingness to toss iffy claims up against the wall of the courtroom to see what sticks is not a new approach for Mr. Klayman. In November 1994, Mr. Klayman argued an appeal for three overseas branches of the Bank of Credit and Commerce International. BCCI had forfeited assets to the United States pursuant to a plea agreement under the Racketeer Influenced and Corrupt Organizations Act, but federal law allows anyone 'other than the defendant" to file suit for return of property in which the party has a bona fide interest. . . .

. . . .

One of Mr. Klayman's current favorite legal tactics is the corporate derivative suit. His first such action was against State Farm Insurance Co., . . . .The suit against State Farm was brought on behalf of a shareholder in Pennsylvania, the suit against Loral on behalf of a shareholder who is dead. . . .

8. Defendants Berkman, Oster and American Lawyer also caused quotations attributed to Professor Larry Sabato of the University of Virginia and former U.S. District Attorney Joseph DiGenova to be published in the November 8, 1999 article. These quotations were false, misleading, or taken out of context.

9. In second article appearing in The National Law Journal on November 15, 1999, Defendants Berkman, Oster, and the Journal caused the following false and misleading statement about Plaintiff to be published:

Finally, there is no truth to Mr. Klayman's charge that the quotations from Mr. DiGenova or Professor Sabato were either fabricated or used out of context.

10. The publication of these false, misleading, disparaging and defamatory statements were intended to defame, and did defame Mr. Klayman, and was intended to, and did hold Mr. Klayman in a false light.

11. The publication of these false, misleading, disparaging and defamatory statements were intended to, and did cause substantial harm to Mr. Klayman's personal and professional reputation.

12. The publication of these false, misleading, disparaging and defamatory statements also caused Mr. Klayman to suffer loss of reputation, emotional distress, embarrassment and personal humiliation.COUNT I

(Defamation)

13. Plaintiff realleges paragraphs 1 through 12 as if fully set forth herein.

14. Defendants Berkman, Oster, and American Lawyer composed and caused the statements set forth in paragraphs 7, 8 and 9 of this complaint ("the statements") to be published in The National Law Journal.

15. These statements are false, misleading, disparaging and defamatory towards Plaintiff.

16. In composing and causing the statements to be published in The National Law Journal, Defendants Berkman, Oster, and American Lawyer, and those acting in concert with them, acted with malice, had knowledge that the statements contained were false, and/or acted with a reckless disregard for the truth and without reasonable grounds to believe that the statements contained therein were true.

17. As a proximate result, Plaintiff suffered substantial damages, including but not limited to loss of reputation, emotional distress, embarrassment and personal humiliation.

WHEREFORE, Plaintiffs demands judgment against Defendants Berkman, Oster, and American Lawyer for compensatory damages, punitive damages, prejudgment interest, postjudgment interest, costs, attorney's fees and such other relief as the Court deems appropriate.

COUNT II

(Invasion of Privacy - False Light)

18. Plaintiff realleges paragraphs 1 through 17 as if fully set forth herein.

19. The statements also place Plaintiff in a false light that is highly offensive to a reasonable person.

20. In composing the statements and causing them to be published in The National Law Journal, Defendants Berkman, Oster, and American Lawyer, and those acting in concert with them, acted with malice, had knowledge that the statements were false, and/or acted with reckless disregard for the false light in which Plaintiff was being placed.

21. As a proximate result, Plaintiff suffered substantial damages including but not limited to loss of reputation, emotional distress, embarrassment and personal humiliation.

WHEREFORE, Plaintiffs demand judgment against Defendants Berkman, Oster, and American Lawyer for compensatory damages, punitive damages, prejudgment interest, postjudgment interest, costs, attorney's fees and such other relief as the Court deems appropriate.

Plaintiff demands trial by jury on all issues so triable.

________________________________

Paul J. Orfanedes

DC Bar No.: 429716

KLAYMAN & ASSOCIATES, P.C.

501 School Street, SW

Suite 700

Washington, DC 20024

(202) 646-5160

Counsel for Plaintiff