1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY NORTHERN DIVISION AT COVINGTON SARAH JONES, a/k/a/ JANE DOE, Plaintiff, v. DIRTY WORLD ENTERTAINMENT RECORDINGS LLC dba THEDIRT.COM, HOOMAN KARAMIAN aka NIK RICHIE aka CORBIN GRIMES, DIRTY WORLD, LLC dba THEDIRTY.COM, and DIRTY WORLD ENTERTAINMENT, LLC dba THEDIRTY.COM, Defendants. Case No. 2:09-cv-00219-WOB Judge William O. Bertelsman AFFIDAVIT OF NIK LAMAS-RICHIE IN SUPPORT OF DEFENDANTS DIRTY WORLD, LLC AND NIK RICHIE’S MOTION FOR SUMMARY JUDGMENT I, NIK LAMAS-RICHIE, declare as follows: My name is NIK LAMAS-RICHIE. I am a resident of the State of California, am over the age of 18 years, and if called to testify in court I could and would truthfully testify to the following information based upon my own personal knowledge. 1. I am currently employed as the manager of Defendant DIRTY WORLD, LLC (“Dirty World”) which owns and operates the website www.TheDirty.com . In addition to acting as editor-in-chief of www.TheDirty.com , I am also the founder and creator of a website called www.DirtyScottsdale.com which I started in March 2007. 2. When I first started www.DirtyScottsdale.com , the site was focused almost entirely on Scottsdale, Arizona. Initially, I used the site as a forum to post my thoughts, comments and observations about a variety of topics that I felt were interesting, important, or deserving of criticism such as certain “fake” (a/k/a “dirty”) residents of Scottsdale.
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF KENTUCKY
NORTHERN DIVISION AT COVINGTON SARAH JONES, a/k/a/ JANE DOE, Plaintiff, v. DIRTY WORLD ENTERTAINMENT RECORDINGS LLC dba THEDIRT.COM, HOOMAN KARAMIAN aka NIK RICHIE aka CORBIN GRIMES, DIRTY WORLD, LLC dba THEDIRTY.COM, and DIRTY WORLD ENTERTAINMENT, LLC dba THEDIRTY.COM, Defendants.
Case No. 2:09-cv-00219-WOB Judge William O. Bertelsman AFFIDAVIT OF NIK LAMAS-RICHIE IN SUPPORT OF DEFENDANTS DIRTY WORLD, LLC AND NIK RICHIE’S MOTION FOR SUMMARY JUDGMENT
I, NIK LAMAS-RICHIE, declare as follows:
My name is NIK LAMAS-RICHIE. I am a resident of the State of California, am over the age of
18 years, and if called to testify in court I could and would truthfully testify to the following
information based upon my own personal knowledge.
1. I am currently employed as the manager of Defendant DIRTY WORLD, LLC
(“Dirty World”) which owns and operates the website www.TheDirty.com. In addition to acting
as editor-in-chief of www.TheDirty.com, I am also the founder and creator of a website called
www.DirtyScottsdale.com which I started in March 2007.
2. When I first started www.DirtyScottsdale.com, the site was focused almost
entirely on Scottsdale, Arizona. Initially, I used the site as a forum to post my thoughts,
comments and observations about a variety of topics that I felt were interesting, important, or
deserving of criticism such as certain “fake” (a/k/a “dirty”) residents of Scottsdale.
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3. The typical subject matter for my early posts on www.DirtyScottsdale.com was
anything “dirty” or humorous, such as drunken people making fools of themselves in public; i.e.,
an intoxicated college student urinating on a public sidewalk or someone passed out on a toilet in
a bar.
4. Another favorite subject was the “$30k millionaire”—this is a derogatory term
used to refer to young people (usually males in their early 20s) who live far beyond their
financial means—driving expensive cars they cannot afford and living a lavish lifestyle often
funded by maxed-out credit cards. I focused my criticism on $30k millionaires because I
genuinely believe this overly materialistic lifestyle is socially destructive and morally
unacceptable. For those same reasons, I also frequently posted stories about “beer-bong-