Sex Offender Jermaine Carlos Diaz File Defamation Lawsuit

Filing # 91884416 E-Filed 06/28/2019 06:10:47 PM
IN THE CIRCUIT COURT OF THE NINTH

JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
JERMAINE CARLOS DIAZ,
Plaintiff, CASE NO:
v.
RAYON SHERWIN PAYNE

d/b/a FOLKSALERT APP,
Defendant.
_______________________________/
COMPLAINT
Plaintiff, JERMAINE CARLOS DIAZ, by and through the undersigned counsel, hereby
sues Defendant, RAYON SHERWIN PAYNE d/b/a FOLKSALERT APP, and states as follows:
PARTIES, VENUE, AND JURISDICTION
1. This is an action for defamation and for damages in excess of $15,000.00, exclusive
of attorney’s fees.
2. Plaintiff, JERMAINE CARLOS DIAZ, is an individual who at all times material
hereto has and continues to reside in Harris County, Texas.
3. Defendant, RAYON SHERWIN PAYNE, is an individual who at all times material
hereto has and continues to reside in Orange County, Florida at the address of 8815 Conroy
Windermere Rd., Orlando, FL 32835.
4. Venue is proper in Orange County, Florida pursuant to § 47.011, Fla. Stat. because
it is the county where the Defendant resides and it is the county where the cause of action accrued.
5. Jurisdiction of this Court is proper pursuant to § 26.012, Fla. Stat.

GENERAL ALLEGATIONS
6. Plaintiff, JERMAINE CARLOS DIAZ (“DIAZ”), is thirty-six (36) years old and
resides in the Houston, Texas area.
7. In July 1998, when DIAZ was only fourteen (14) years old, he was arrested on
charges of transporting a minor, who was one year older than him (15 years old) in interstate
commerce for purposes of prostitution, and for aiding and abetting.
8. Despite being only fourteen (14) years old when the incident occurred, DIAZ has
spent the past two decades with no further incident as it relates to those charges. DIAZ has never
been designated a dangerous sex offender and DIAZ’s lifetime supervision has been terminated.
9. DIAZ was previously enrolled in the Texas Art Institute and majored in interior
design.
10. Since finishing school DIAZ has dedicated his life to raising his twelve-year-old
son of whom he has full custody.
11. Since 2006, DIAZ has managed music artists through his successful company
Money To Blow Music Group, LLC, and has gained considerable notoriety in doing so.
12. DIAZ maintained an Instagram page, @lacetheblueprint, where he promoted the
music artists he manages and commonly goes by the name of “Lace the Blue Print” or “Young
Lace.” Through Instagram, DIAZ generated income in the amount of $15,000 to $25,000 per
month through appearance booking fees and endorsements.
13. Defendant, RAYON SHERWIN PAYNE (“PAYNE”), works in maintenance at a
Central Florida apartment complex and also operates and maintains the FolksAlert App YouTube
page at https://www.youtube.com/channel/UCcXVxqGH-WkzUPKzihJAjmQ/featured
(“FolksAlert”).
2
PAYNE’S FALSE AND DEFAMATORY STATEMENTS AND HARASSMENT OF DIAZ
14. PAYNE, who commonly goes by the name of “Keko,” has an unhealthy obsession
with DIAZ, despite the two having never met and despite DIAZ wanting absolutely nothing to do
with PAYNE. Utilizing FolksAlert, PAYNE routinely harasses DIAZ with an intent to cause DIAZ
substantial emotional distress by publishing false and defamatory videos about DIAZ to
FolksAlert.
15. In fact, PAYNE’s publication of the numerous false and defamatory videos
concerning DIAZ have achieved their desired result of harassing DIAZ and causing DIAZ severe
emotional distress.
16. For example, through his FolksAlert videos, PAYNE frequently states that DIAZ
is a “dangerous sex offender” and implicates DIAZ as being currently involved in human
trafficking. These statements published by PAYNE are false and defamatory, and were published
by PAYNE with express malice or reckless disregard for the truth.
17. A timeline of PAYNE’s bizarre publication of false and defamatory statements
about DIAZ is as follows.
18. On February 13, 2019, PAYNE published a video to YouTube titled “Dear Young
Lace Lets Do Business” https://www.youtube.com/watch?v=d2MwkJYRwp4. In this video,
PAYNE brags about his harassment of DIAZ and states, in part: “Carlos @YoungLace, I just
deleted your #moneytoblowceo ig page.”
19. On February 16, 2019, PAYNE published a video to FolksAlert’s YouTube channel
titled “Young Lace – The Sex Offender Blue Print” https://www.youtube.com/watch?v=GMjF-
q4KoqA. In this video, PAYNE states that “one can arguably say that [DIAZ] is the most
successful human trafficker in the United States.” This statement is false and defamatory, and was
published with express malice or reckless disregard for the truth.
3
titled “The Blue Print – A Dangerous Sex Offender (Young Lace) – Trailer 1”
https://www.youtube.com/watch?v=lM4bg6fs_eQ&t=27s. In this video, PAYNE implicates
DIAZ as being involved in human trafficking and states that DIAZ is a “dangerous sex offender.”
These statements are false and defamatory, and were published with express malice or reckless
disregard for the truth.
https://www.youtube.com/watch?v=3MO7LA3YSBk. In this video, PAYNE implicates DIAZ as
being involved in human trafficking, states DIAZ is a “dangerous sex offender,” and states and
implies that DIAZ is involved with prostitution. The description of the video states:
This summer Folksalert presents a documentary about a dangerous

sex offender Jermaine Carlos Diaz aka Young Lace and one of his
many prostitutes Angelica DiDisiena. (emphasis supplied).
22. These statements are false and defamatory, and were published with express malice
or reckless disregard for the truth.
tilted “Young Lace – The Bold Sex Offender Pimp”
https://www.youtube.com/watch?v=e_LBLHMwifU. In this video, PAYNE states that DIAZ is a
pimp and implicates DIAZ in prostitution. This statement is false and defamatory, and was
published with express malice or reckless disregard for the truth.
titled “The Blue Print – A Dangerous Sex Offender (Young Lace) - Trailer 3”
https://www.youtube.com/watch?v=4DHUjkcfXy8&t=33s. In this video, PAYNE states that
DIAZ is a dangerous sex offender and implies that DIAZ is a human trafficker, states that DIAZ
4
is a sex trafficker, or involved with human trafficking, implies that DIAZ is involved in
prostitution, and states that DIAZ has eight females working for him. These statements are false
and defamatory, and were published with express malice or reckless disregard for the truth.
https://www.youtube.com/watch?v=rGeDG-hEVPc. In this video, PAYNE states that DIAZ is a
dangerous sex offender. This statement is false and defamatory, and was published with express
malice or reckless disregard for the truth.
26. On March 4, 2019, PAYNE published a video to FolksAlert’s YouTube channel
titled “The Blue Print – A Dangerous Sex Offender (Young Lace) Trailer 6”
https://www.youtube.com/watch?v=cqfX9027gjQ. In this video, PAYNE implies that DIAZ is
involved with human trafficking and sex trafficking and states that DIAZ is a dangerous sex
offender. This statement is false and defamatory, and was published with express malice or
reckless disregard for the truth. Further, the video depicts a picture of a battered woman and falsely
implies that DIAZ beat the woman and otherwise harms women.
https://www.youtube.com/watch?v=X5-m6DzQjcs. In this video, PAYNE implies that that DIAZ
is a sex trafficker, states that DIAZ has eight prostitutes, and that DIAZ is a pimp. These statements
are false and defamatory, and were published with express malice or reckless disregard for the
truth.
28. Also on March 17, 2019, PAYNE published a video to FolksAlert’s YouTube
channel titled “EP 51: BOLD PIMPING – A Houston Sex Trafficking Operation”
https://www.youtube.com/watch?v=DxAyQgX_R6Y. In this video, PAYNE implies that DIAZ is
5
a sex trafficker, and is involved with sex trafficking and prostitution. This statement is false and
defamatory, and was published with express malice or reckless disregard for the truth.
titled “CLASSIC PIMPING: Johnny Cash and Young Lace (2012)”
https://www.youtube.com/watch?v=Qf8zIxwwdIA. In this video, PAYNE implies that DIAZ is a
pimp and involved with prostitution. This statement is false and defamatory, and was published
with express malice or reckless disregard for the truth.
https://www.youtube.com/watch?v=ZTKnqZIG1Wg. In this video, PAYNE states that DIAZ “is
known on social media and around the United States in human trafficking circles as Young Lace
the Pimp.” The video otherwise implies that DIAZ is a sex trafficker or is involved in sex
trafficking. These statements are false and defamatory and were published with express malice or
reckless disregard for the truth.
31. On April 6, 2019, PAYNE published a video to FolksAlert’s YouTube channel
titled “A Trusted Face Young Lace” https://www.youtube.com/watch?v=DpFyBYPqSDo. The
video implies that DIAZ is a pimp and involved with prostitution. This statement is false and
32. On April 16, 2019, PAYNE published a video to the FolksAlert’s YouTube channel
titled “Using Algorithm To Stop Sex Offender Jermaine Carlos Diaz”
https://www.youtube.com/watch?v=0OLEbi2goQA. In this video, PAYNE implies that DIAZ is
dangerous and needs to be stopped from committing crimes. This statement is false and
6
33. On May 6, 2019, PAYNE published a video to FolksAlert’s YouTube channel titled
“The Blue Print – A Dangerous Sex Offender (Young Lace) Trailer 10”
https://www.youtube.com/watch?v=XxRW0KDHJtY. In this video, PAYNE implies that DIAZ
committed the crime of auto theft. This statement is false and defamatory, and was published with
express malice or reckless disregard for the truth.
34. On May 25, 2019, PAYNE published a video to FolksAlert’s YouTube channel
titled “The Young Lace Documentary Coming Summer 2019”
https://www.youtube.com/watch?v=1jkbi7-dl4w. The video threatens and harasses DIAZ with the
release of a false and defamatory “documentary” about DIAZ.
35. On June 14, 2019, PAYNE again threatened and harassed DIAZ by publishing a
video to FolksAlert’s YouTube channel titled “On 6/17/19 I will have a release date for this Young
Lace documentary” https://www.youtube.com/watch?v=N-uWvaOm5uc. The video is a clear
threat from PAYNE to DIAZ that PAYNE still intends to release a so called documentary,
containing false and defamatory statements about DIAZ.
36. Again, on June 15, 2019, PAYNE published another video to the FolksAlert’s
YouTube channel titled “Intro: The Blue Print – A Dangerous Sex Offender (Young Lace)”
https://www.youtube.com/watch?v=GEefId4-nag wherein PAYNE is threatening DIAZ with the
release of the so called documentary about DIAZ.
37. Then, on June 20, 2019, PAYNE published another video to the FolksAlert’s
YouTube channel titled “Registered Sex Offender Carlos Diaz Gets Clowned”
https://www.youtube.com/watch?v=Ph3jSvc6Ji0. In this video, PAYNE again harasses DIAZ and
brags about PAYNE’s efforts to delete DIAZ’s and his company’s Instagram pages.
38. PAYNE has also disseminated the aforementioned false and defamatory statements
concerning DIAZ to Twitter and Instagram.
7
39. The foregoing statements of fact published by PAYNE about DIAZ charged that
DIAZ committed an infamous crime and subjected DIAZ to hatred, distrust, ridicule, contempt, or
disgrace.
40. PAYNE’s false and defamatory statements concerning DIAZ directly and
proximately, and in natural and continuous sequence caused, and continue to cause harm and
damage to DIAZ, including, without limitation, injury and harm to DIAZ’s reputation, and have
caused DIAZ to suffer shame, humiliation, mental anguish and suffering, and hurt feelings
experienced in the past and to be experienced in the future such that, but for the publication of the
false and defamatory statements, the damage to DIAZ would not have occurred.
41. As a result of PAYNE’s publication of false and defamatory statements concerning
DIAZ, DIAZ has also suffered economic damages which are not yet quantified and are ongoing.
42. PAYNE has repeatedly threatened to release a so-called documentary about DIAZ
containing blatant false and defamatory statements about DIAZ.
43. PAYNE’s false and defamatory publications serve no legitimate purposes.
ILLEGAL PHONE CALL RECORDINGS
44. On November 18, 2018, PAYNE illegally recorded a phone call he had with DIAZ
without DIAZ’s consent or knowledge, in violation of § 943.03, Fla. Stat.
https://www.youtube.com/watch?v=o6aa33BfWbs.
45. On or about February 16, 2019, PAYNE illegally recorded a phone call he had with
DIAZ, without DIAZ’s consent or knowledge, in violation of § 934.03, Fla. Stat.
https://www.youtube.com/watch?v=sDThsZ-XvY8.
46. On April 16, 2019, PAYNE illegally recorded a phone call he had with DIAZ
without DIAZ’s consent or knowledge, and in violation of § 943.03, Fla. Stat.
https://www.youtube.com/watch?v=0OLEbi2goQA.
8
47. The aforementioned recordings occurred when DIAZ had a reasonable expectation
of privacy.
PAYNE’S INTENTIONAL AND DELIBERATE TORTIOUS INTERFERENCE
48. PAYNE’s harassment has not stopped with DIAZ. PAYNE has even called DIAZ’s
son’s school and harassed DIAZ’s mother.
49. In 2019, PAYNE took action to cause DIAZ’s personal Instagram page,
@lacetheblueprint, DIAZ’s business Instagram page, @moneytoblowmusicgroup, and DIAZ”s
business YouTube channel, “moneytoblowmusicgroup,” to be deleted or otherwise removed from
Instagram and YouTube. PAYNE took such actions without justification and with an intent to
damage DIAZ.
50. All conditions precedent to the maintenance of this action have been satisfied,
waived or occurred.
51. Plaintiff, DIAZ, has retained the undersigned counsel and has agreed to pay the
undersigned a reasonable fee for services rendered.
COUNT I- SLANDER
52. This is an action for slander against PAYNE.
53. Plaintiff, DIAZ, realleges and incorporates the allegations set forth in paragraphs 1
through 51 as though fully restated herein.
54. Defendant, PAYNE, made false and defamatory statements concerning DIAZ.
55. Said false and defamatory statements were published to third parties.
56. Plaintiff, DIAZ, has suffered damages as a result of the Defendant, PAYNE’s,
publication of the false and defamatory statements.
9
WHEREFORE, Plaintiff, JERMAINE CARLOS DIAZ, respectfully requests this Court
enter judgment in Plaintiff’s favor and against Defendant for all damages, award costs, and grant
such further relief this Court deems just and proper.
COUNT II - LIBEL
57. This is an action for libel against PAYNE.
59. Defendant, PAYNE, made false and defamatory statements concerning DIAZ by
publishing certain written statements to YouTube, Instagram, and Twitter.
61. Plaintiff, DIAZ, has suffered damages as a result of Defendant, PAYNE’s,
COUNT III – SLANDER PER SE
62. This is an action for slander per se against PAYNE.
64. Defendant, PAYNE, made false and defamatory statements concerning DIAZ,
which charged that Plaintiff, DIAZ, committed an infamous crime and subjected DIAZ to hatred,
distrust, ridicule, contempt, or disgrace.
10
COUNT IV – LIBEL PER SE
67. This is an action for libel per se against PAYNE.
69. Defendant, PAYNE, made written false and defamatory statements concerning
DIAZ, which charged that Plaintiff, DIAZ, committed an infamous crime and subjected DIAZ to
hatred, distrust, ridicule, contempt, or disgrace.
COUNT V – DEFAMATION BY IMPLICATION
72. This is an action for defamation by implication against PAYNE.
74. Defendant, PAYNE, made certain statements which either
11
a) Juxtaposed a series of facts so as to imply a defamatory connection between them;
or
b) Created a defamatory implication by omitting certain facts.
COUNT VI – INTERCEPTION OF COMMUNICATIONS IN VIOLATION OF

FLORIDA SECURITY OF COMMUNICATIONS ACT – FLORIDA STATUTE 934.10
77. This is action for violation of § 934.03, Fla. Stat. against PAYNE brought pursuant
to § 934.10, Fla. Stat.
79. Defendant, PAYNE, intercepted and recorded oral conversations between PAYNE
and DIAZ.
80. Plaintiff, DIAZ, did not consent to and was not aware of any of these interceptions.
81. Plaintiff, did not give his implied consent or authorization, express or implied, to
allow the interception of these oral communications.
82. The interception and recording of oral communications was Defendant, PAYNE’s,
conscious objective.
83. As a direct and proximate result of Defendant, PAYNE’s, actions and conduct,
Plaintiff, DIAZ, has suffered and will continue to suffer damages, including economic damages,
reputation damages, and damage to his current and prospective business relations.
12
WHEREFORE, Plaintiff, JERMAINE DIAZ, respectfully requests this Court enter
judgment in Plaintiff’s favor and against Defendant, for Plaintiff’s actual damages but not less than
liquidated damages computed at the rate of $100 a day for each date of violation, or $1,000.00,
whichever is higher, pursuant to § 934.10(1)(b), Fla. Stat., pre-judgment interest, costs including
reasonable attorney’s fees pursuant to § 934.10(1)(d), Fla. Stat., and grant such further relief this
Court deems just and proper.
COUNT VII – TORTIOUS INTERFERENCE

WITH ADVANTAGEOUS BUSINESS RELATIONSHIP
84. This is an action for tortious interference with an advantageous business
relationship against PAYNE.
86. Plaintiff, DIAZ, maintained advantageous business relationships with YouTube
and Instagram.
87. Defendant, PAYNE, had and has knowledge of the advantageous business
relationship.
88. Defendant, PAYNE, intentionally and unjustifiably interfered with the
advantageous business relationship, by taking action to induce YouTube and Instagram to suspend
Plaintiff, DIAZ’s, YouTube and Instagram pages.
89. Plaintiff, DIAZ, has suffered damages as a result of PAYNE’s tortious interference.
WHEREFORE, Plaintiff, JERMAINE DIAZ, respectfully requests this Court enter
judgment in Plaintiff’s favor and against Defendant for all damages, award costs, and grant such
further relief this Court deems just and proper.
13
COUNT VIII – TORTIOUS INTERFERENCE WITH
ADVANTAGEOUS BUSINESS RELATIONSHIP
90. This is an action for tortious interference with an advantageous business
relationship against PAYNE.
through 51 as though fully restated herein
92. Plaintiff, DIAZ, maintained advantageous business relationships with certain
companies and entities which directly generated income each month for DIAZ through YouTube
and Instagram.
93. Defendant, PAYNE, had and has knowledge of these advantageous business
relationships.
94. Defendant, PAYNE, intentionally and unjustifiably interfered with the
advantageous business relationships, by taking action to induce YouTube and Instagram to
suspend Plaintiff, DIAZ’s, YouTube and Instagram pages, and by continuing to make false and
defamatory statements about DIAZ, thereby causing certain companies and entities to discontinue
business with DIAZ.
95. Defendant, PAYNE’s, intentional and unjustified interference with DIAZ’s
advantageous business relationships include, but are not limited to the publication of the
aforementioned YouTube videos, and the following additional videos published to YouTube:
a) http://www.youtube.com/watch?v=5pdaPYgwABU;
b) http://www.youtube.com/watch?v=L6U7TAOJJkU; and
c) http://www.youtube.com/watch?v=n2qEUmEx5Ok.
96. Plaintiff, DIAZ, has suffered damages as a result of PAYNE’s tortious interference,
but such damages are incalculable and therefore, DIAZ has an inadequate remedy at law.
14
WHEREFORE, Plaintiff, JERMAINE DIAZ, respectfully requests this Court enter a
preliminary and permanent injunction in Plaintiff’s favor and against Defendant enjoining
Defendant from making any further false and defamatory statements in furtherance of Defnednat’s
tortious interference and alternatively, a judgment awarding Plaintiff damages, and costs, and grant
COUNT IX – INJUNCTION FOR PROTECTION AGAINST

CYBERSTALKING PURSUANT TO FLORIDA STATUTE 784.0485
97. This is a petition for an injunction against cyberstalking pursuant to Florida Statute
784.0485 against Payne.
99. Defendant, PAYNE, is a forty-three (43) year old African American male born
November 7, 1975.
100. Defendant, PAYNE’s, height, weight, eye color, and hair color is unknown.
101. Defendant, PAYNE, has cyberstalked Plaintiff, DIAZ, by engaging in a course of
conduct to communicate, or cause to be communicated, words, images, or language by or through
the use of electronic communication by publishing numerous false and defamatory videos directed
to DIAZ as described in paragraphs 14 through 43, and paragraph 95, supra, thereby causing DIAZ
substantial emotional distress and serving no legitimate person.
102. Plaintiff, DIAZ, seeks an injunction against cyberstalking against Defendant,
PAYNE, which immediately restrains Defendant from committing any acts of cyberstalking,
15
I HAVE READ EVERY STATEMENT MADE IN THIS PETITON AND EACH
STATEMENT IS TRUE AND CORRECT. I UNDERSTAND THAT THE STATEMENTS
MADE IN THIS PETITION ARE BEING MADE UNDER THE PENALTY OF PERJURY,
PUNISHABLE AS PROVIDED IN SECTION 837.02, FLORIDA STATUTES.
Jermaine Carlos Diaz
WHEREFORE, Plaintiff, JERMAINE DIAZ, respectfully requests this Court enter an
injunction against Defendant enjoining Defendant from cyberstalking pursuant to Chapter 784,
Florida Statutes, and grant such further relief this Court deems just and proper.
DEMAND FOR JURY TRIAL
Plaintiff, JERMAINE DIAZ, demands a jury trial for all issues so triable herein.
RESERVATION OF RIGHT TO AMEND
Plaintiff reserves his right to amend this Complaint to add claims, including, but not limited
to, claims for punitive damages against Defendant, pursuant to Chapter 768, Florida Statutes.
Respectfully submitted this 28th day of June, 2019.
/s/ Eric P. LaRue II

Eric P. LaRue II, Esquire
Florida Bar No.: 97995
The LaRue Firm, PLLC
501 S. New York Avenue
Suite 230
Winter Park, FL 32789
Phone: 407-455-4779
[email protected]
[email protected]
Counsel for Plaintiff

16

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Filing # 91884416 E-Filed 06/28/2019 06:10:47 PM

IN THE CIRCUIT COURT OF THE NINTH

JERMAINE CARLOS DIAZ,

Plaintiff, CASE NO:

RAYON SHERWIN PAYNE

PARTIES, VENUE, AND JURISDICTION

2. Plaintiff, JERMAINE CARLOS DIAZ, is an individual who at all times material

hereto has and continues to reside in Harris County, Texas.

3. Defendant, RAYON SHERWIN PAYNE, is an individual who at all times material

Windermere Rd., Orlando, FL 32835.

5. Jurisdiction of this Court is proper pursuant to § 26.012, Fla. Stat.

resides in the Houston, Texas area.

commerce for purposes of prostitution, and for aiding and abetting.

son of whom he has full custody.

12. DIAZ maintained an Instagram page, @lacetheblueprint, where he promoted the

month through appearance booking fees and endorsements.

13. Defendant, RAYON SHERWIN PAYNE (“PAYNE”), works in maintenance at a

by PAYNE with express malice or reckless disregard for the truth.

17. A timeline of PAYNE’s bizarre publication of false and defamatory statements

about DIAZ is as follows.

Lace Lets Do Business” https://www.youtube.com/watch?v=d2MwkJYRwp4. In this video,

deleted your #moneytoblowceo ig page.”

titled “Young Lace – The Sex Offender Blue Print” https://www.youtube.com/watch?v=GMjF-

published with express malice or reckless disregard for the truth.

https://www.youtube.com/watch?v=lM4bg6fs_eQ&t=27s. In this video, PAYNE implicates

disregard for the truth.

https://www.youtube.com/watch?v=3MO7LA3YSBk. In this video, PAYNE implicates DIAZ as

This summer Folksalert presents a documentary about a dangerous

or reckless disregard for the truth.

tilted “Young Lace – The Bold Sex Offender Pimp”

https://www.youtube.com/watch?v=e_LBLHMwifU. In this video, PAYNE states that DIAZ is a

published with express malice or reckless disregard for the truth.

https://www.youtube.com/watch?v=4DHUjkcfXy8&t=33s. In this video, PAYNE states that

https://www.youtube.com/watch?v=rGeDG-hEVPc. In this video, PAYNE states that DIAZ is a

malice or reckless disregard for the truth.

26. On March 4, 2019, PAYNE published a video to FolksAlert’s YouTube channel

https://www.youtube.com/watch?v=cqfX9027gjQ. In this video, PAYNE implies that DIAZ is

https://www.youtube.com/watch?v=X5-m6DzQjcs. In this video, PAYNE implies that that DIAZ

https://www.youtube.com/watch?v=DxAyQgX_R6Y. In this video, PAYNE implies that DIAZ is

titled “CLASSIC PIMPING: Johnny Cash and Young Lace (2012)”

https://www.youtube.com/watch?v=Qf8zIxwwdIA. In this video, PAYNE implies that DIAZ is a

with express malice or reckless disregard for the truth.

https://www.youtube.com/watch?v=ZTKnqZIG1Wg. In this video, PAYNE states that DIAZ “is

reckless disregard for the truth.

31. On April 6, 2019, PAYNE published a video to FolksAlert’s YouTube channel

titled “A Trusted Face Young Lace” https://www.youtube.com/watch?v=DpFyBYPqSDo. The

titled “Using Algorithm To Stop Sex Offender Jermaine Carlos Diaz”

https://www.youtube.com/watch?v=0OLEbi2goQA. In this video, PAYNE implies that DIAZ is

https://www.youtube.com/watch?v=XxRW0KDHJtY. In this video, PAYNE implies that DIAZ

express malice or reckless disregard for the truth.

titled “The Young Lace Documentary Coming Summer 2019”

https://www.youtube.com/watch?v=1jkbi7-dl4w. The video threatens and harasses DIAZ with the

release of a false and defamatory “documentary” about DIAZ.

Lace documentary” https://www.youtube.com/watch?v=N-uWvaOm5uc. The video is a clear

containing false and defamatory statements about DIAZ.

https://www.youtube.com/watch?v=GEefId4-nag wherein PAYNE is threatening DIAZ with the