Preview
All Law Division initial Case Management Dates will be heard via12-Person
ZOOM. Jury
For more information and Zoom Meeting IDs go to https://www.cookcountycourt.org/HOME/Zoom-Links/Agg4906_SelectTab/12
Remote Court date: 8/31/2023 10:00 AM
FILED
6/23/2023 11:57 PM
IN THE CIRCUIT COURT OF COOK COUNTY IRIS Y. MARTINEZ
CIRCUIT CLERK
COUNTY DEPARTMENT, LAW DIVISION COOK COUNTY, IL
FILED DATE: 6/23/2023 11:57 PM 2023L006423
2023L006423
RICK BUTLER, an individual, CHERYL Calendar, B
BUTLER, an individual, and GLV, INC., an 23278137
Illinois Corporation,
Plaintiffs,
v. No.
EDELSON PC, an Illinois Professional
Corporation, and LAURA MULLEN, JURY TRIAL DEMANDED
an individual,
Defendants.
COMPLAINT
Plaintiffs, RICK BUTLER (“Rick”), CHERYL BUTLER (“Cheryl”), and GLV, INC.
(“GLV”), an Illinois Corporation, by and through their counsel Danielle D’Ambrose of D’Ambrose
P.C., for their complaint against Defendants, EDELSON PC, an Illinois Professional Corporation,
and LAURA MULLEN (“Mullen”), allege as follows:
INTRODUCTION
1. This is an action alleging Malicious Prosecution and Abuse of Process arising from
a sham class action lawsuit filed by Defendant Edelson PC on behalf of Defendant Laura Mullen.
The class action lawsuit was part of a deceitful, calculated plan to cut the Butlers off from their
supporters, punish GLV customers for their association with the Butlers, and destroy the Butlers’
business. To carry out their plan, Mullen and her attorneys filed the lawsuit with knowledge that
the core allegations of the class action complaint were false, and they used improper and devious
litigation tactics to inflict further harm on Rick Butler, Cheryl Butler, and GLV, Inc.
2. By the time the court granted summary judgment in favor of the Butlers and GLV,
the case had already served its purpose for Edelson PC and Mullen. Edelson PC knew that a court
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filing that began with nearly 50 pages of scandalous and sexually explicit allegations would all but
guarantee a high-publicity case, and Laura Mullen benefitted by furthering the goal of removing
FILED DATE: 6/23/2023 11:57 PM 2023L006423
the Butlers from volleyball and inflicting irreparable harm on their business and reputations.
Mullen improperly brought her claims as a class action lawsuit to maximize publicity and force
the Butlers to incur substantial legal fees they would not have incurred otherwise. Then, Mullen
and her attorneys at Edelson PC engaged in vexatious and unreasonable litigation tactics
throughout this litigation, and their plan worked. The Butlers and GLV suffered permanent harm
as a direct result of the Defendants’ misconduct.
PARTIES
3. Plaintiff GLV, Inc., d/b/a Sports Performance Volleyball Club and Great Lakes
Center, is a corporation organized and existing under the laws of the State of Illinois with its
principal place of business located at 579 North Oakhurst Drive, Aurora, Illinois, 60502.
4. Plaintiff Rick Butler is a natural person and a citizen of the State of Oregon and a
resident of Crook County.
5. Plaintiff Cheryl Butler is a natural person and a citizen of the State of Oregon and
a resident of Crook County.
6. Edelson PC is a professional corporation organized and existing under the laws of
the State of Illinois. Edelson PC operates as a law firm, with its principal place of business located
at 350 N LaSalle Dr, Chicago, Illinois 60654. Edelson PC does business in this County and across
the State of Illinois. In February of 2018, Edelson PC filed a class action lawsuit in the Northern
District of Illinois against Rick Butler, Cheryl Butler, and GLV, Inc. on behalf of Laura Mullen,
the lead plaintiff in the case.
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7. Laura Mullen is a natural person and a citizen of the State of Illinois and a resident
of Kane County. Mullen’s two daughters played in various GLV volleyball programs between
FILED DATE: 6/23/2023 11:57 PM 2023L006423
2011-2017, including GLV camps, GLV clinics, and the Sports Performance Program.
8. Laura Mullen was lead plaintiff in a class action lawsuit filed against Rick Butler,
Cheryl Butler, and GLV, Inc. Mullen’s claims were fully adjudicated on summary judgment in
favor of Rick Butler, Cheryl Butler, and GLV, Inc. Judgment was awarded against Mullen and in
favor of Rick Butler, Cheryl Butler, and GLV, Inc. on September 21, 2020. Mullen appealed the
decision, and the Seventh Circuit Court of Appeals affirmed on June 23, 2022.
JURISDICTION AND VENUE
9. This court has jurisdiction of this controversy because it is among citizens of the
State of Illinois. Venue is proper in Cook County pursuant to 735 ILCS 5/2-101 because the
principal place of business of Defendant Edelson PC is in Cook County and because the transaction
or some part thereof out of which this cause of action arises occurred in Cook County.
ALLEGATIONS OF FACT
10. In the early 1980s, Rick Butler formed the Sports Performance Volleyball program,
which quickly grew to become one of the most successful youth sports programs in the nation. In
1994, Rick Butler was accused of having “inappropriate sexual relationships” with players he
coached in the 1980s.
11. The players, according to their own statements, were above the legal age of consent,
and no law or rule prohibited such relationships at the time.
12. Yet, Rick’s former business partner, Kay Rogness, was leading efforts to have Rick
banned from coaching for life. Rogness claimed to have witnessed “child abuse” and “pedophilia”
within the Sports Performance program in the 1980s when she ran the program with Rick, and she
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wrote to USA Volleyball and the Illinois Department of Children and Family Services demanding
that Rick be prohibited from coaching junior athletes forever. All of the alleged misconduct Kay
FILED DATE: 6/23/2023 11:57 PM 2023L006423
claims to have witnessed stems from her involvement in the program during the 1980s. It was not
until 1994, shortly after Rick made his final buy-out payment to her, that Kay first came forward
seeking a lifetime coaching ban be imposed on Rick Butler.
13. When the accusations were made in 1994, Rick and Cheryl Butler were in the
process of adopting their son, and the adoption court ordered an investigation into the claims. A
court-appointed investigator concluded that the allegations from the 1980s concerned individuals
who were above the legal age of consent at the time, and that Rick Butler “did not break any
criminal laws then or now.”
14. USA Volleyball (“USAV”) also investigated the accusations in 1995 and
determined that, while the relationships were legal under the laws at the time, it would ban Rick
for five years as punishment for causing the organization “public embarrassment” and “ridicule.”
By 1995, Rick was already well-known as a successful coach within the volleyball community, so
the allegations against him received substantial publicity. The ban prohibited Rick from coaching
junior girls’ teams at USAV-sponsored events only. USAV explained that the ban did not apply to
events held in GLV’s facility, the Great Lakes Center, or events sponsored by other organizations,
such as the AAU. In 2000, USA Volleyball reinstated Rick Butler’s membership.
15. Rick continued to grow the Sports Performance program with his wife, Cheryl
Butler, and their business, GLV, was recognized as one of the top junior volleyball programs in the
country. In 2015, ESPN described Rick Butler as the most powerful coach in the sport of junior
volleyball.
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16. After the allegations were first made in the mid-1990s, they continued to be
discussed in the volleyball community.
FILED DATE: 6/23/2023 11:57 PM 2023L006423
17. Rogness and the three former players from the 1980s turned to the media and
continued to push for bans on Rick’s ability to coach. In addition, certain competitors attempted to
use the accusations to promote their own business and disparage Sports Performance. Since the
1980s, there have been no accusations of misconduct made against Rick Butler. Therefore, the
efforts to disparage the Butlers with accusations from the 1980s had little impact on the Butlers
and GLV.
18. Then, in approximately 2017, Rick’s accusers retained attorney Jay Edelson and his
law firm, Edelson PC, to further their goal of removing Butler from the sport.
19. Edelson PC and the accusers recognized that the prior attacks on the Butlers were
unsuccessful, and that families involved in the Sports Performance program were among Rick’s
strongest supporters. Sports Performance families trusted their own personal experience with the
Butlers over the decades-old accusations in the media and have continued to send their children to
the club year after year.
20. Edelson PC realized that as long as families were sending their children to the club,
GLV and the Butlers would likely remain in business. Therefore, the firm sought to create a lawsuit
which targeted those relationships, and all of GLV’s business relationships, to force the Butlers
and GLV out of business.
21. Edelson PC orchestrated the duplicitous litigation in conjunction with the alleged
victims to advance their goals of removing the Butlers from the sport of volleyball. In the news,
attorney Jay Edelson claims to have “started investigating for the litigation well before USA
Volleyball banned Butler for life in December” of 2017. In January of 2018, one of Rick’s accusers
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posted on Volleytalk that the alleged “victims of Butler just acquired representation from a very
caring and very powerful lawyer” who “has some good angles for us to reach our goals.” That
FILED DATE: 6/23/2023 11:57 PM 2023L006423
lawyer was Jay Edelson.
22. In January of 2018, the nation was captivated by the sentencing of Dr. Larry Nassar,
the disgraced former USA Gymnastics and Michigan State University doctor who sexually abused
young athletes in his care. In February of 2018, the Defendants exploited that publicity with a
bogus class action lawsuit where Edelson PC and Mullen would declare that Rick Butler “raped
children” he coached in his volleyball program. The lawsuit even alleged that Rick had some sort
of “special relationship” Michigan State University, where Nassar was formerly employed.
23. The class action complaint was used to manipulate public perception of the
accusations against Rick Butler, and the complaint was intentionally drafted to mirror the
allegations made against Nassar and create the illusion that the Butlers were being sued by victims
of sexual abuse. Shortly before her lawsuit was filed, Mullen was posting on Volleytalk about the
“recent turn of events and the current climate regarding [sex] crimes” and she was urging others
to take action against the Butlers.
24. For the class action lawsuit, Edelson PC manufactured a theory that the Butlers and
GLV fraudulently concealed from their customers the highly publicized allegations made against
Rick from the 1980s.
25. Because members of the Sports Performance program continued to support the
Butlers despite the public allegations from the 1980s, the class action lawsuit was crafted to
interfere with those parents’ decisions. The lawsuit sought to void all GLV contracts, it asked the
court to prohibit the Butlers from having any involvement in coaching youth athletes, and it tried
to bar parents from making their own decisions about who could coach their children. This lawsuit
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was part of a deceitful, calculated plan to isolate the Butlers from their supporters, punish their
customers for supporting the program, and destroy GLV’s business.
FILED DATE: 6/23/2023 11:57 PM 2023L006423
26. The class action lawsuit required a former customer of GLV to act as the class
representative for all GLV customers. The lawsuit centered on two broad assertions: that parents
join GLV programs without knowledge of the allegations of abuse from the 1980s and that, had
they known of those claims, they would not have allowed their children to participate “in any GLV
associated volleyball programs.” Without these assertions, the fraud claims fall apart.
27. Edelson and the accusers searched for a former Sports Performance parent who
would be willing to act as the class representative in the case. Eventually, they found Laura Mullen
after she posted a comment about Rick Butler in an anonymous online volleyball forum called
Volleytalk.
28. Throughout the class action litigation, Laura Mullen and her attorneys at Edelson
PC knowingly advanced false claims to evade dismissal, to increase the Butlers’ costs of litigation,
and to generate publicity harmful to the Butlers and GLV. To illustrate just a few of many instances:
a. The first paragraph of the class action complaint alleged that Rick Butler sexually
abused athletes “for over three decades.” Mullen later admitted that she does not
know of any allegations of sexual abuse made against Butler since the 1980s.
b. The lawsuit also claimed that Butler sexually abused “no fewer than six underage
teenage girls, and likely many more.” Mullen later admitted that she did not know
of six accusers, and she had no factual basis for her claim that there were “likely
many more.”
c. Mullen falsely claimed in her complaint that she did not see any information about
the accusations until June of 2017. When the Butlers filed a motion for summary
judgment with an abundance of evidence showing that Mullen lied, she suddenly
changed her argument and claimed, for the first time, that “everyone knew” about
the allegations.
29. The complaint falsely asserted that the DCFS “found conclusive and credible
evidence” supporting these stories. The complaint even contained excerpts from the DCFS
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documents in violation of the confidentiality protections of the Abused and Neglected Child
Reporting Act.
FILED DATE: 6/23/2023 11:57 PM 2023L006423
30. One primary purpose of the complaint was to generate negative publicity that could
be used to pressure organizations to cut ties with the Butlers. Laura Mullen and Edelson PC
claimed that they worked together to “conduct a months’ long pre-suit investigation” prior to filing
the class action complaint. Edelson PC assumed responsibility for alleging nearly 50 pages of facts
which were not within Mullen’s personal knowledge.
31. Even more, the Defendants made the calculated, intentional decision to file the
complaint on behalf of all GLV customers, knowing that those GLV customers would not support
the class claims, because doing so would directly interfere with the Butlers’ customer relationships.
32. As the class representative, Laura Mullen’s factual claims had to fit the concealment
theory invented by Edelson PC and the accusers. Mullen, therefore, claimed that she sent her
children to GLV “without knowledge” of the abuse claims against Rick, claiming she did not see
any information about the accusations until June of 2017. This was not true.
33. Edelson knew that Mullen was well aware of the allegations prior to 2017, because
she was discussing the allegations on Volleytalk for years while her daughters were playing in
GLV’s programs. Between 2015-2018, Mullen was active in nearly 20 different Volleytalk threads
discussing the allegations of abuse and the various ways in which the Butlers could be attacked,
both professionally and personally. Yet, she continued to send her daughters to GLV programs until
the summer of 2018. Even after Laura Mullen filed the class action lawsuit, she still sent her
daughter to GLV for its 2018 summer league.
34. The class action was used to publicly shame and pressure Sports Performance
customers to cut ties with the Butlers. Just one day after filing her complaint alleging that the
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Butlers fraudulently concealed the claims of abuse, Laura Mullen “liked” a Volleytalk post calling
the allegations “nothing new” to Sports Performance parents and expressing hope that recent
FILED DATE: 6/23/2023 11:57 PM 2023L006423
“attention on them and their decisions” would deter those parents from sending their children to
Sports Performance.
35. Class members made it clear that they did not agree with the claims in Mullen’s
lawsuit. Just four months after the class action lawsuit was filed and publicized by nearly every
major news outlet in the nation, approximately 800 class members trusted GLV to supervise their
daughters during a week-long trip to Florida. The players traveled with one of approximately 40
different Sports Performance teams competing in the AAU Girls’ Junior National Volleyball
Championships. At the time, their parents were undoubtedly aware of the abuse allegations in the
complaint, they made their own determinations as to the materiality and reliability of the claims,
and they chose to continue supporting the Butlers and their program.
36. Mullen’s lies were quickly recognized by class members who had children that
played with Mullen’s daughters. One such parent offered to assist the Butlers in defending the suit,
saying that he was “beyond pissed after reading the crap in this BS lawsuit being filed by
Laura…She was crazy.” Another parent offered to testify against Mullen, saying the Butlers had
“the truth” on their side, and a different parent said, “I know for a fact [Mullen] is lying” in her
complaint Parents on the team that year stated that Rick “bent over backwards” to help Mullen’s
daughter.
37. Throughout the case, Mullen and her attorneys made false and misleading claims
to the court in various filings. For example, in response to a motion to dismiss, Mullen claimed
that GLV “failed to provide [her] with a copy of her contract.” Later in the lawsuit, Mullen
9
produced a copy of her contract and admitted that she received a copy of her contract every year
her daughters were in the Sports Performance program.
FILED DATE: 6/23/2023 11:57 PM 2023L006423
38. One of the most critical falsehoods told by Mullen, however, is that she did not find
out about the claims of abuse until after her daughters left the program. The lawsuit was dependent
on her allegation that she joined Defendants’ program “without knowledge” of the claims of abuse
made against Rick Butler dating back to the 1980s. However, Mullen was posting on Volleytalk
about the allegations for years while she continued to send her daughters to the program. Mullen’s
daughter even emailed Rick about the allegations in 2015, saying that she was sorry about the
negative publicity that was circulating at the time about the allegations. After she sent that email,
Mullen’s daughter returned to the program for another two seasons.
39. The improper conduct of Mullen and her attorneys was not confined to their
baseless complaint. Their continuous misconduct also sought to generate negative publicity for the
Butlers and GLV, to needlessly increase litigation costs, and to interfere with the Butlers’ ability
to defend themselves to their customers and to the public.
40. Throughout the action, Edelson PC and Mullen repeatedly advanced unfounded,
illogical arguments to gain additional publicity, needlessly increase the cost of litigation, and
prejudice the Butlers with baseless allegations.
41. Mullen and her attorneys exploited the judicial process to publicly harass and
humiliate the Butlers in hopes they would be financially destroyed by the lawsuit, regardless of
the outcome. Laura Mullen, using her alias “swimrowvball,” liked several posts on Volleytalk that
demonstrate the deceitful motives and improper purpose behind her lawsuit, such as that:
a. That “the next route is to just empty [Rick’s] backlog, as I said before he has
dealt with the PR scrutiny for decades now but where it will really start to bother
him is when he is losing registrations in his club and camps, partnerships from
satellites and whatever royalties they pay, the schools and third parties that pay
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him to run camps, and the advertisers that may feel being around him and the
club have a particular stank to it.”
FILED DATE: 6/23/2023 11:57 PM 2023L006423
b. “[G]etting all the parents to pull their funding is next to impossible”
c. “When it hurts more than helps to be associated with SPVB…that’s when you’ll
see change.”
42. The class action lawsuit was never about recovering fees. It was never about fraud.
It was always about finding a way to destroy the Butlers’ business; if GLV customers would not
leave the program on their own, the Defendants were going to make them, and Edelson PC
manufactured a cause of action to create a barrier between the Butlers and their customers. From
start to finish, Jay Edelson, along with numerous attorneys at Edelson PC acting under his
direction, orchestrated a fraud on the court.
43. For example, Mullen only survived a motion to dismiss because she made false
allegations and bad faith assertions, which forced the Butlers and GLV to incur substantial legal
fees until those lies ultimately defeated each of Laura Mullen’s claims on summary judgment. In
response to the motion to dismiss, Mullen argued that “[t]he Court should decline to take judicial
notice of the news articles appended to [Defendants’] Motion, as none of the articles are referenced
in the Complaint and they are inconsistent with her claims that she did not see any information
online until June of 2017 due to Defendants’ concealment.”1 (emphasis added). This is not true.
In a brief filed later in the case, Mullen and her attorneys wrote, “Mullen concedes that, between
2015 and 2017, she was generally aware of the allegations regarding sexual abuse by Rick and had
reviewed news articles on the subject.”
1
Furthermore, even if Mullen did learn of the allegations for the first time in June of 2017, her daughter
attended a lesson at GLV on September 3, 2017 and a clinic on September 16, 2017. Therefore, before she
filed the lawsuit, she had allowed her daughter to return to GLV programs at least twice after she “learned
the truth” of the allegations.
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44. Mullen’s attorneys engaged in a pattern of abusive discovery tactics, demanding
that the Butlers immediately supplement answers, provide documents which were never requested,
FILED DATE: 6/23/2023 11:57 PM 2023L006423
and amend responses with more preferable language or information. Edelson PC would often
reference nonexistent “authority” and threaten the Butlers with a motion for sanctions if they did
not comply with Edelson’s unreasonable demands. Even after the Butlers, attempting to avoid the
waste of time and resources attendant to yet another motion with baseless accusations of
misconduct, provided several versions of the same discovery responses, Edelson PC was never
satisfied. Edelson filed repeated motions and unsolicited “status reports” with the court falsely
accusing the Butlers and their attorney of discovery misconduct and other unsubstantiated claims.
Edelson PC’s deceitful procedure was able to create the perception that the Butlers, GLV, and their
counsel were acting in bad faith.
45. The lawsuit was a sham. Mullen, the accusers, and Edelson PC knew from the
beginning that the Butlers did not conceal the allegations from their customers, because a simple
Google search of Rick’s name shows that the accusations have been highly publicized since 1995.
They knew Laura Mullen has been discussing the allegations on Volleytalk for years while she was
sending her children to GLV’s programs. They knew they would all have to lie to get the case
before a court, and they lied for over two years until the case was finally thrown out. However, by
that point, the lawsuit had already served its purpose.
46. The district court eventually saw through the lies and granted summary judgment
in favor of the Butlers on every cause of action brought by Laura Mullen. The court granted
Edelson PC time to find a new class representative for three of the six causes of action. However,
after nearly two thousand class members were notified of their claims by the court, Edelson PC
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could not identify a single class member who supported the case. As a result, the remaining class
claims were dismissed by the court.
FILED DATE: 6/23/2023 11:57 PM 2023L006423
47. Edelson PC, Mullen, and the accusers were never worried about winning the
lawsuit. The class action lawsuit was a major step in the scheme to destroy the Butlers and destroy
their business. The lawsuit intentionally listed the names of businesses known to associate with
GLV and host GLV events. The Defendants then capitalized on the intense public scrutiny from
the class action lawsuit, and they used the public scrutiny and threat of legal ramifications to force
organizations to cut ties with the Butlers and their business.
48. The complaint sparked national outrage against the Butlers, it advanced the
carefully selected and highly inflammatory false narrative that Rick Butler “raped” the “children”
he coached, and it was a critical component of the plan to destroy the Butlers’ business. Jay Edelson
consistently appeared in the media to discuss the complaint’s allegations and to publicly advocate
for the Butlers to be removed from the sport entirely.
49. Edelson PC planned for the class action complaint to be used to publicly shame the
organizations that did business with GLV and the Butlers. The complaint needlessly listed several
of these organizations, and many were threatened with boycotts, cancelation of their business
contracts, and/or personal harassment as a result.
The Continuous Litigation Misconduct of Edelson PC Attorneys and Laura Mullen
50. Mullen and her attorneys at Edelson PC took steps to vexatiously and unreasonably
increase the cost of attorneys’ fees throughout this litigation. Edelson PC repeatedly violated the
Rules of Professional Responsibility, the firm filed confidential documents in violation of the
Abused and Neglected Child Reporting Act (325 ILCS 5/11 (West 2014)), failed to correct
misstatements and false claims, acting dishonestly to opposing counsel with the intent and purpose
13
of prolonging the frivolous lawsuit, intentionally misleading the court about facts and evidence,
suborning perjury, enticing other participants to participate in the unlawful scheme, and knowingly
FILED DATE: 6/23/2023 11:57 PM 2023L006423
filing a meritless lawsuit for an improper purpose, namely, to harass the Butlers, cause damage to
the Butlers’ business and reputation, and to generate negative publicity about the Butlers and GLV.
51. Furthermore, Mullen improperly brought her claims as a class action lawsuit to
maximize publicity and force the Butlers to incur substantial legal fees they would not have
incurred otherwise. Upon first review of Mullen’s Complaint, the Butlers knew Mullen was lying.
Then, in the following hours and days, they compiled an abundance of evidence that proved she
was lying. However, because the lawsuit was brought as a class action, the Butlers were forced to
deal with the claims of other, unnamed individuals (individuals who, based on Edelson’s inability
to find anyone besides Mullen to carry on the case, did not exist).
52. Edelson PC engaged in an abusive litigation tactic called “litigation by sanction.”
This “sanctions tort” was largely performed through discovery gamesmanship which exploited and
abused judicial procedures to generate sanctions against the Butlers, GLV, and their attorneys.
Edelson PC consistently attempted to stoke the court’s anger at the Butlers and their attorney,
accusing them of intentionally obstructing justice and seeking broad sanctions.
53. Edelson PC repeatedly accused the Butlers and their attorney of providing
misinformation about the lawsuit to putative class members and asked the court to step in and
prohibit the Butlers from talking to their customers about the case. It quickly became clear that
Edelson PC was seeking to prohibit the Butlers from saying anything to defend themselves against
the bogus claims made by Mullen. As a result, the Plaintiffs’ first amendment right to speech was
chilled as a result of Edelson PC’s litigation misconduct.
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54. Edelson PC used this playbook to repeatedly attack the Butlers, GLV, and their
attorney with false, misleading, and baseless accusations. Edelson asked the district court to issue
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rulings which would prohibit the Butlers from defending themselves against the claims made in
the lawsuit and interfere with the Butlers’ ability to communicate with their customers. The
repeated filing of (and threats to file) sanctions motions, along with the increased cost of litigating
those motions, impeded the Butlers’ ability to defend themselves to their customers.
55. Shortly after filing her complaint, which was chockfull of falsehoods, Mullen filed
a motion requesting expedited discovery alleging—with no factual support—that the Butlers and
their attorney were improperly communicating with class members. Mullen and Edelson PC also
advanced unsubstantiated accusations that the Butlers were illegally transferring assets to Brazil
and traveling overseas to set up a new volleyball business. The motion was based on anonymous
information, and it was later uncovered that the sole source of that information was Laura Mullen
herself, who was repeatedly posting these false claims on Volleytalk under her alias.
56. Mullen and Edelson PC supported this motion with a sworn declaration from
attorney Jay Edelson, who claimed to have heard these rumors from unidentified “individuals
following the case” against the Butlers.
57. Edelson PC continued their “litigation by sanction” strategy with another motion
arguing that the Butlers and GLV should be held in contempt of court for providing allegedly
deficient discovery responses. Edelson PC claimed that “[e]ven the most basic and obviously
relevant pieces of information were withheld—e.g., the contract(s)…they entered into with
[Mullen] and are operative here, any marketing materials…issued during the relevant period, and
the like.” Remarkably, Edelson’s argument omitted a crucial piece of information – that they never
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actually requested those contracts and marketing materials be produced. Nevertheless, Edelson PC
Preview
All Law Division initial Case Management Dates will be heard via12-Person ZOOM. Jury For more information and Zoom Meeting IDs go to https://www.cookcountycourt.org/HOME/Zoom-Links/Agg4906_SelectTab/12 Remote Court date: 8/31/2023 10:00 AM FILED 6/23/2023 11:57 PM IN THE CIRCUIT COURT OF COOK COUNTY IRIS Y. MARTINEZ CIRCUIT CLERK COUNTY DEPARTMENT, LAW DIVISION COOK COUNTY, IL FILED DATE: 6/23/2023 11:57 PM 2023L006423 2023L006423 RICK BUTLER, an individual, CHERYL Calendar, B BUTLER, an individual, and GLV, INC., an 23278137 Illinois Corporation, Plaintiffs, v. No. EDELSON PC, an Illinois Professional Corporation, and LAURA MULLEN, JURY TRIAL DEMANDED an individual, Defendants. COMPLAINT Plaintiffs, RICK BUTLER (“Rick”), CHERYL BUTLER (“Cheryl”), and GLV, INC. (“GLV”), an Illinois Corporation, by and through their counsel Danielle D’Ambrose of D’Ambrose P.C., for their complaint against Defendants, EDELSON PC, an Illinois Professional Corporation, and LAURA MULLEN (“Mullen”), allege as follows: INTRODUCTION 1. This is an action alleging Malicious Prosecution and Abuse of Process arising from a sham class action lawsuit filed by Defendant Edelson PC on behalf of Defendant Laura Mullen. The class action lawsuit was part of a deceitful, calculated plan to cut the Butlers off from their supporters, punish GLV customers for their association with the Butlers, and destroy the Butlers’ business. To carry out their plan, Mullen and her attorneys filed the lawsuit with knowledge that the core allegations of the class action complaint were false, and they used improper and devious litigation tactics to inflict further harm on Rick Butler, Cheryl Butler, and GLV, Inc. 2. By the time the court granted summary judgment in favor of the Butlers and GLV, the case had already served its purpose for Edelson PC and Mullen. Edelson PC knew that a court 1 filing that began with nearly 50 pages of scandalous and sexually explicit allegations would all but guarantee a high-publicity case, and Laura Mullen benefitted by furthering the goal of removing FILED DATE: 6/23/2023 11:57 PM 2023L006423 the Butlers from volleyball and inflicting irreparable harm on their business and reputations. Mullen improperly brought her claims as a class action lawsuit to maximize publicity and force the Butlers to incur substantial legal fees they would not have incurred otherwise. Then, Mullen and her attorneys at Edelson PC engaged in vexatious and unreasonable litigation tactics throughout this litigation, and their plan worked. The Butlers and GLV suffered permanent harm as a direct result of the Defendants’ misconduct. PARTIES 3. Plaintiff GLV, Inc., d/b/a Sports Performance Volleyball Club and Great Lakes Center, is a corporation organized and existing under the laws of the State of Illinois with its principal place of business located at 579 North Oakhurst Drive, Aurora, Illinois, 60502. 4. Plaintiff Rick Butler is a natural person and a citizen of the State of Oregon and a resident of Crook County. 5. Plaintiff Cheryl Butler is a natural person and a citizen of the State of Oregon and a resident of Crook County. 6. Edelson PC is a professional corporation organized and existing under the laws of the State of Illinois. Edelson PC operates as a law firm, with its principal place of business located at 350 N LaSalle Dr, Chicago, Illinois 60654. Edelson PC does business in this County and across the State of Illinois. In February of 2018, Edelson PC filed a class action lawsuit in the Northern District of Illinois against Rick Butler, Cheryl Butler, and GLV, Inc. on behalf of Laura Mullen, the lead plaintiff in the case. 2 7. Laura Mullen is a natural person and a citizen of the State of Illinois and a resident of Kane County. Mullen’s two daughters played in various GLV volleyball programs between FILED DATE: 6/23/2023 11:57 PM 2023L006423 2011-2017, including GLV camps, GLV clinics, and the Sports Performance Program. 8. Laura Mullen was lead plaintiff in a class action lawsuit filed against Rick Butler, Cheryl Butler, and GLV, Inc. Mullen’s claims were fully adjudicated on summary judgment in favor of Rick Butler, Cheryl Butler, and GLV, Inc. Judgment was awarded against Mullen and in favor of Rick Butler, Cheryl Butler, and GLV, Inc. on September 21, 2020. Mullen appealed the decision, and the Seventh Circuit Court of Appeals affirmed on June 23, 2022. JURISDICTION AND VENUE 9. This court has jurisdiction of this controversy because it is among citizens of the State of Illinois. Venue is proper in Cook County pursuant to 735 ILCS 5/2-101 because the principal place of business of Defendant Edelson PC is in Cook County and because the transaction or some part thereof out of which this cause of action arises occurred in Cook County. ALLEGATIONS OF FACT 10. In the early 1980s, Rick Butler formed the Sports Performance Volleyball program, which quickly grew to become one of the most successful youth sports programs in the nation. In 1994, Rick Butler was accused of having “inappropriate sexual relationships” with players he coached in the 1980s. 11. The players, according to their own statements, were above the legal age of consent, and no law or rule prohibited such relationships at the time. 12. Yet, Rick’s former business partner, Kay Rogness, was leading efforts to have Rick banned from coaching for life. Rogness claimed to have witnessed “child abuse” and “pedophilia” within the Sports Performance program in the 1980s when she ran the program with Rick, and she 3 wrote to USA Volleyball and the Illinois Department of Children and Family Services demanding that Rick be prohibited from coaching junior athletes forever. All of the alleged misconduct Kay FILED DATE: 6/23/2023 11:57 PM 2023L006423 claims to have witnessed stems from her involvement in the program during the 1980s. It was not until 1994, shortly after Rick made his final buy-out payment to her, that Kay first came forward seeking a lifetime coaching ban be imposed on Rick Butler. 13. When the accusations were made in 1994, Rick and Cheryl Butler were in the process of adopting their son, and the adoption court ordered an investigation into the claims. A court-appointed investigator concluded that the allegations from the 1980s concerned individuals who were above the legal age of consent at the time, and that Rick Butler “did not break any criminal laws then or now.” 14. USA Volleyball (“USAV”) also investigated the accusations in 1995 and determined that, while the relationships were legal under the laws at the time, it would ban Rick for five years as punishment for causing the organization “public embarrassment” and “ridicule.” By 1995, Rick was already well-known as a successful coach within the volleyball community, so the allegations against him received substantial publicity. The ban prohibited Rick from coaching junior girls’ teams at USAV-sponsored events only. USAV explained that the ban did not apply to events held in GLV’s facility, the Great Lakes Center, or events sponsored by other organizations, such as the AAU. In 2000, USA Volleyball reinstated Rick Butler’s membership. 15. Rick continued to grow the Sports Performance program with his wife, Cheryl Butler, and their business, GLV, was recognized as one of the top junior volleyball programs in the country. In 2015, ESPN described Rick Butler as the most powerful coach in the sport of junior volleyball. 4 16. After the allegations were first made in the mid-1990s, they continued to be discussed in the volleyball community. FILED DATE: 6/23/2023 11:57 PM 2023L006423 17. Rogness and the three former players from the 1980s turned to the media and continued to push for bans on Rick’s ability to coach. In addition, certain competitors attempted to use the accusations to promote their own business and disparage Sports Performance. Since the 1980s, there have been no accusations of misconduct made against Rick Butler. Therefore, the efforts to disparage the Butlers with accusations from the 1980s had little impact on the Butlers and GLV. 18. Then, in approximately 2017, Rick’s accusers retained attorney Jay Edelson and his law firm, Edelson PC, to further their goal of removing Butler from the sport. 19. Edelson PC and the accusers recognized that the prior attacks on the Butlers were unsuccessful, and that families involved in the Sports Performance program were among Rick’s strongest supporters. Sports Performance families trusted their own personal experience with the Butlers over the decades-old accusations in the media and have continued to send their children to the club year after year. 20. Edelson PC realized that as long as families were sending their children to the club, GLV and the Butlers would likely remain in business. Therefore, the firm sought to create a lawsuit which targeted those relationships, and all of GLV’s business relationships, to force the Butlers and GLV out of business. 21. Edelson PC orchestrated the duplicitous litigation in conjunction with the alleged victims to advance their goals of removing the Butlers from the sport of volleyball. In the news, attorney Jay Edelson claims to have “started investigating for the litigation well before USA Volleyball banned Butler for life in December” of 2017. In January of 2018, one of Rick’s accusers 5 posted on Volleytalk that the alleged “victims of Butler just acquired representation from a very caring and very powerful lawyer” who “has some good angles for us to reach our goals.” That FILED DATE: 6/23/2023 11:57 PM 2023L006423 lawyer was Jay Edelson. 22. In January of 2018, the nation was captivated by the sentencing of Dr. Larry Nassar, the disgraced former USA Gymnastics and Michigan State University doctor who sexually abused young athletes in his care. In February of 2018, the Defendants exploited that publicity with a bogus class action lawsuit where Edelson PC and Mullen would declare that Rick Butler “raped children” he coached in his volleyball program. The lawsuit even alleged that Rick had some sort of “special relationship” Michigan State University, where Nassar was formerly employed. 23. The class action complaint was used to manipulate public perception of the accusations against Rick Butler, and the complaint was intentionally drafted to mirror the allegations made against Nassar and create the illusion that the Butlers were being sued by victims of sexual abuse. Shortly before her lawsuit was filed, Mullen was posting on Volleytalk about the “recent turn of events and the current climate regarding [sex] crimes” and she was urging others to take action against the Butlers. 24. For the class action lawsuit, Edelson PC manufactured a theory that the Butlers and GLV fraudulently concealed from their customers the highly publicized allegations made against Rick from the 1980s. 25. Because members of the Sports Performance program continued to support the Butlers despite the public allegations from the 1980s, the class action lawsuit was crafted to interfere with those parents’ decisions. The lawsuit sought to void all GLV contracts, it asked the court to prohibit the Butlers from having any involvement in coaching youth athletes, and it tried to bar parents from making their own decisions about who could coach their children. This lawsuit 6 was part of a deceitful, calculated plan to isolate the Butlers from their supporters, punish their customers for supporting the program, and destroy GLV’s business. FILED DATE: 6/23/2023 11:57 PM 2023L006423 26. The class action lawsuit required a former customer of GLV to act as the class representative for all GLV customers. The lawsuit centered on two broad assertions: that parents join GLV programs without knowledge of the allegations of abuse from the 1980s and that, had they known of those claims, they would not have allowed their children to participate “in any GLV associated volleyball programs.” Without these assertions, the fraud claims fall apart. 27. Edelson and the accusers searched for a former Sports Performance parent who would be willing to act as the class representative in the case. Eventually, they found Laura Mullen after she posted a comment about Rick Butler in an anonymous online volleyball forum called Volleytalk. 28. Throughout the class action litigation, Laura Mullen and her attorneys at Edelson PC knowingly advanced false claims to evade dismissal, to increase the Butlers’ costs of litigation, and to generate publicity harmful to the Butlers and GLV. To illustrate just a few of many instances: a. The first paragraph of the class action complaint alleged that Rick Butler sexually abused athletes “for over three decades.” Mullen later admitted that she does not know of any allegations of sexual abuse made against Butler since the 1980s. b. The lawsuit also claimed that Butler sexually abused “no fewer than six underage teenage girls, and likely many more.” Mullen later admitted that she did not know of six accusers, and she had no factual basis for her claim that there were “likely many more.” c. Mullen falsely claimed in her complaint that she did not see any information about the accusations until June of 2017. When the Butlers filed a motion for summary judgment with an abundance of evidence showing that Mullen lied, she suddenly changed her argument and claimed, for the first time, that “everyone knew” about the allegations. 29. The complaint falsely asserted that the DCFS “found conclusive and credible evidence” supporting these stories. The complaint even contained excerpts from the DCFS 7 documents in violation of the confidentiality protections of the Abused and Neglected Child Reporting Act. FILED DATE: 6/23/2023 11:57 PM 2023L006423 30. One primary purpose of the complaint was to generate negative publicity that could be used to pressure organizations to cut ties with the Butlers. Laura Mullen and Edelson PC claimed that they worked together to “conduct a months’ long pre-suit investigation” prior to filing the class action complaint. Edelson PC assumed responsibility for alleging nearly 50 pages of facts which were not within Mullen’s personal knowledge. 31. Even more, the Defendants made the calculated, intentional decision to file the complaint on behalf of all GLV customers, knowing that those GLV customers would not support the class claims, because doing so would directly interfere with the Butlers’ customer relationships. 32. As the class representative, Laura Mullen’s factual claims had to fit the concealment theory invented by Edelson PC and the accusers. Mullen, therefore, claimed that she sent her children to GLV “without knowledge” of the abuse claims against Rick, claiming she did not see any information about the accusations until June of 2017. This was not true. 33. Edelson knew that Mullen was well aware of the allegations prior to 2017, because she was discussing the allegations on Volleytalk for years while her daughters were playing in GLV’s programs. Between 2015-2018, Mullen was active in nearly 20 different Volleytalk threads discussing the allegations of abuse and the various ways in which the Butlers could be attacked, both professionally and personally. Yet, she continued to send her daughters to GLV programs until the summer of 2018. Even after Laura Mullen filed the class action lawsuit, she still sent her daughter to GLV for its 2018 summer league. 34. The class action was used to publicly shame and pressure Sports Performance customers to cut ties with the Butlers. Just one day after filing her complaint alleging that the 8 Butlers fraudulently concealed the claims of abuse, Laura Mullen “liked” a Volleytalk post calling the allegations “nothing new” to Sports Performance parents and expressing hope that recent FILED DATE: 6/23/2023 11:57 PM 2023L006423 “attention on them and their decisions” would deter those parents from sending their children to Sports Performance. 35. Class members made it clear that they did not agree with the claims in Mullen’s lawsuit. Just four months after the class action lawsuit was filed and publicized by nearly every major news outlet in the nation, approximately 800 class members trusted GLV to supervise their daughters during a week-long trip to Florida. The players traveled with one of approximately 40 different Sports Performance teams competing in the AAU Girls’ Junior National Volleyball Championships. At the time, their parents were undoubtedly aware of the abuse allegations in the complaint, they made their own determinations as to the materiality and reliability of the claims, and they chose to continue supporting the Butlers and their program. 36. Mullen’s lies were quickly recognized by class members who had children that played with Mullen’s daughters. One such parent offered to assist the Butlers in defending the suit, saying that he was “beyond pissed after reading the crap in this BS lawsuit being filed by Laura…She was crazy.” Another parent offered to testify against Mullen, saying the Butlers had “the truth” on their side, and a different parent said, “I know for a fact [Mullen] is lying” in her complaint Parents on the team that year stated that Rick “bent over backwards” to help Mullen’s daughter. 37. Throughout the case, Mullen and her attorneys made false and misleading claims to the court in various filings. For example, in response to a motion to dismiss, Mullen claimed that GLV “failed to provide [her] with a copy of her contract.” Later in the lawsuit, Mullen 9 produced a copy of her contract and admitted that she received a copy of her contract every year her daughters were in the Sports Performance program. FILED DATE: 6/23/2023 11:57 PM 2023L006423 38. One of the most critical falsehoods told by Mullen, however, is that she did not find out about the claims of abuse until after her daughters left the program. The lawsuit was dependent on her allegation that she joined Defendants’ program “without knowledge” of the claims of abuse made against Rick Butler dating back to the 1980s. However, Mullen was posting on Volleytalk about the allegations for years while she continued to send her daughters to the program. Mullen’s daughter even emailed Rick about the allegations in 2015, saying that she was sorry about the negative publicity that was circulating at the time about the allegations. After she sent that email, Mullen’s daughter returned to the program for another two seasons. 39. The improper conduct of Mullen and her attorneys was not confined to their baseless complaint. Their continuous misconduct also sought to generate negative publicity for the Butlers and GLV, to needlessly increase litigation costs, and to interfere with the Butlers’ ability to defend themselves to their customers and to the public. 40. Throughout the action, Edelson PC and Mullen repeatedly advanced unfounded, illogical arguments to gain additional publicity, needlessly increase the cost of litigation, and prejudice the Butlers with baseless allegations. 41. Mullen and her attorneys exploited the judicial process to publicly harass and humiliate the Butlers in hopes they would be financially destroyed by the lawsuit, regardless of the outcome. Laura Mullen, using her alias “swimrowvball,” liked several posts on Volleytalk that demonstrate the deceitful motives and improper purpose behind her lawsuit, such as that: a. That “the next route is to just empty [Rick’s] backlog, as I said before he has dealt with the PR scrutiny for decades now but where it will really start to bother him is when he is losing registrations in his club and camps, partnerships from satellites and whatever royalties they pay, the schools and third parties that pay 10 him to run camps, and the advertisers that may feel being around him and the club have a particular stank to it.” FILED DATE: 6/23/2023 11:57 PM 2023L006423 b. “[G]etting all the parents to pull their funding is next to impossible” c. “When it hurts more than helps to be associated with SPVB…that’s when you’ll see change.” 42. The class action lawsuit was never about recovering fees. It was never about fraud. It was always about finding a way to destroy the Butlers’ business; if GLV customers would not leave the program on their own, the Defendants were going to make them, and Edelson PC manufactured a cause of action to create a barrier between the Butlers and their customers. From start to finish, Jay Edelson, along with numerous attorneys at Edelson PC acting under his direction, orchestrated a fraud on the court. 43. For example, Mullen only survived a motion to dismiss because she made false allegations and bad faith assertions, which forced the Butlers and GLV to incur substantial legal fees until those lies ultimately defeated each of Laura Mullen’s claims on summary judgment. In response to the motion to dismiss, Mullen argued that “[t]he Court should decline to take judicial notice of the news articles appended to [Defendants’] Motion, as none of the articles are referenced in the Complaint and they are inconsistent with her claims that she did not see any information online until June of 2017 due to Defendants’ concealment.”1 (emphasis added). This is not true. In a brief filed later in the case, Mullen and her attorneys wrote, “Mullen concedes that, between 2015 and 2017, she was generally aware of the allegations regarding sexual abuse by Rick and had reviewed news articles on the subject.” 1 Furthermore, even if Mullen did learn of the allegations for the first time in June of 2017, her daughter attended a lesson at GLV on September 3, 2017 and a clinic on September 16, 2017. Therefore, before she filed the lawsuit, she had allowed her daughter to return to GLV programs at least twice after she “learned the truth” of the allegations. 11 44. Mullen’s attorneys engaged in a pattern of abusive discovery tactics, demanding that the Butlers immediately supplement answers, provide documents which were never requested, FILED DATE: 6/23/2023 11:57 PM 2023L006423 and amend responses with more preferable language or information. Edelson PC would often reference nonexistent “authority” and threaten the Butlers with a motion for sanctions if they did not comply with Edelson’s unreasonable demands. Even after the Butlers, attempting to avoid the waste of time and resources attendant to yet another motion with baseless accusations of misconduct, provided several versions of the same discovery responses, Edelson PC was never satisfied. Edelson filed repeated motions and unsolicited “status reports” with the court falsely accusing the Butlers and their attorney of discovery misconduct and other unsubstantiated claims. Edelson PC’s deceitful procedure was able to create the perception that the Butlers, GLV, and their counsel were acting in bad faith. 45. The lawsuit was a sham. Mullen, the accusers, and Edelson PC knew from the beginning that the Butlers did not conceal the allegations from their customers, because a simple Google search of Rick’s name shows that the accusations have been highly publicized since 1995. They knew Laura Mullen has been discussing the allegations on Volleytalk for years while she was sending her children to GLV’s programs. They knew they would all have to lie to get the case before a court, and they lied for over two years until the case was finally thrown out. However, by that point, the lawsuit had already served its purpose. 46. The district court eventually saw through the lies and granted summary judgment in favor of the Butlers on every cause of action brought by Laura Mullen. The court granted Edelson PC time to find a new class representative for three of the six causes of action. However, after nearly two thousand class members were notified of their claims by the court, Edelson PC 12 could not identify a single class member who supported the case. As a result, the remaining class claims were dismissed by the court. FILED DATE: 6/23/2023 11:57 PM 2023L006423 47. Edelson PC, Mullen, and the accusers were never worried about winning the lawsuit. The class action lawsuit was a major step in the scheme to destroy the Butlers and destroy their business. The lawsuit intentionally listed the names of businesses known to associate with GLV and host GLV events. The Defendants then capitalized on the intense public scrutiny from the class action lawsuit, and they used the public scrutiny and threat of legal ramifications to force organizations to cut ties with the Butlers and their business. 48. The complaint sparked national outrage against the Butlers, it advanced the carefully selected and highly inflammatory false narrative that Rick Butler “raped” the “children” he coached, and it was a critical component of the plan to destroy the Butlers’ business. Jay Edelson consistently appeared in the media to discuss the complaint’s allegations and to publicly advocate for the Butlers to be removed from the sport entirely. 49. Edelson PC planned for the class action complaint to be used to publicly shame the organizations that did business with GLV and the Butlers. The complaint needlessly listed several of these organizations, and many were threatened with boycotts, cancelation of their business contracts, and/or personal harassment as a result. The Continuous Litigation Misconduct of Edelson PC Attorneys and Laura Mullen 50. Mullen and her attorneys at Edelson PC took steps to vexatiously and unreasonably increase the cost of attorneys’ fees throughout this litigation. Edelson PC repeatedly violated the Rules of Professional Responsibility, the firm filed confidential documents in violation of the Abused and Neglected Child Reporting Act (325 ILCS 5/11 (West 2014)), failed to correct misstatements and false claims, acting dishonestly to opposing counsel with the intent and purpose 13 of prolonging the frivolous lawsuit, intentionally misleading the court about facts and evidence, suborning perjury, enticing other participants to participate in the unlawful scheme, and knowingly FILED DATE: 6/23/2023 11:57 PM 2023L006423 filing a meritless lawsuit for an improper purpose, namely, to harass the Butlers, cause damage to the Butlers’ business and reputation, and to generate negative publicity about the Butlers and GLV. 51. Furthermore, Mullen improperly brought her claims as a class action lawsuit to maximize publicity and force the Butlers to incur substantial legal fees they would not have incurred otherwise. Upon first review of Mullen’s Complaint, the Butlers knew Mullen was lying. Then, in the following hours and days, they compiled an abundance of evidence that proved she was lying. However, because the lawsuit was brought as a class action, the Butlers were forced to deal with the claims of other, unnamed individuals (individuals who, based on Edelson’s inability to find anyone besides Mullen to carry on the case, did not exist). 52. Edelson PC engaged in an abusive litigation tactic called “litigation by sanction.” This “sanctions tort” was largely performed through discovery gamesmanship which exploited and abused judicial procedures to generate sanctions against the Butlers, GLV, and their attorneys. Edelson PC consistently attempted to stoke the court’s anger at the Butlers and their attorney, accusing them of intentionally obstructing justice and seeking broad sanctions. 53. Edelson PC repeatedly accused the Butlers and their attorney of providing misinformation about the lawsuit to putative class members and asked the court to step in and prohibit the Butlers from talking to their customers about the case. It quickly became clear that Edelson PC was seeking to prohibit the Butlers from saying anything to defend themselves against the bogus claims made by Mullen. As a result, the Plaintiffs’ first amendment right to speech was chilled as a result of Edelson PC’s litigation misconduct. 14 54. Edelson PC used this playbook to repeatedly attack the Butlers, GLV, and their attorney with false, misleading, and baseless accusations. Edelson asked the district court to issue FILED DATE: 6/23/2023 11:57 PM 2023L006423 rulings which would prohibit the Butlers from defending themselves against the claims made in the lawsuit and interfere with the Butlers’ ability to communicate with their customers. The repeated filing of (and threats to file) sanctions motions, along with the increased cost of litigating those motions, impeded the Butlers’ ability to defend themselves to their customers. 55. Shortly after filing her complaint, which was chockfull of falsehoods, Mullen filed a motion requesting expedited discovery alleging—with no factual support—that the Butlers and their attorney were improperly communicating with class members. Mullen and Edelson PC also advanced unsubstantiated accusations that the Butlers were illegally transferring assets to Brazil and traveling overseas to set up a new volleyball business. The motion was based on anonymous information, and it was later uncovered that the sole source of that information was Laura Mullen herself, who was repeatedly posting these false claims on Volleytalk under her alias. 56. Mullen and Edelson PC supported this motion with a sworn declaration from attorney Jay Edelson, who claimed to have heard these rumors from unidentified “individuals following the case” against the Butlers. 57. Edelson PC continued their “litigation by sanction” strategy with another motion arguing that the Butlers and GLV should be held in contempt of court for providing allegedly deficient discovery responses. Edelson PC claimed that “[e]ven the most basic and obviously relevant pieces of information were withheld—e.g., the contract(s)…they entered into with [Mullen] and are operative here, any marketing materials…issued during the relevant period, and the like.” Remarkably, Edelson’s argument omitted a crucial piece of information – that they never 15 actually requested those contracts and marketing materials be produced. Nevertheless, Edelson PC