Former RR Board Was Being Sued For Making False And Defamatory Allegations Against Levine

Defendant RR either knew that the above-referenced allegations of sexual assault, rape, and diversion of funds were untrue, or published them with reckless disregard as to whether they were true or false, for the purpose of damaging the reputation of Levine.

It turns out the Refuge Recovery Board was being sued by Noah Levine for making False and defamatory statements against Levine. The statement above is from Levine’s Counterclaim to the RR Lawsuit filed against him. Text of the actual Defamation section of the counterclaims:

“TENTH COUNTERCLAIM (Defamation – Libel Per Se)

142. Counterclaim Plaintiff Levine repeats and realleges every allegation in the foregoing paragraphs as if fully set forth here.

143. RR Executive Director Jean Tuller and RR Chairman Chris Kavanaugh told Levine that they did not believe the allegations of sexual misconduct made against him. But on or about October 31, 2018, Counter Defendant RR posted the above-referenced Jezebel Gawkerblog article on the RR Facebook Page. RR’s post included not a hyperlink to the article, but also the graphic headline that included false allegations and accusations of “rape and assault” against Levine.

144. Further, Counterclaim Defendant RR in its Complaint repeatedly alleges, without any factual basis, and knowing that the opposite is true, that Levine diverted $130,000 scholarship donations from RR for the private use of his company RRH and/or himself. For example, in Paragraph 95 of its complaint, RR alleges “Levine intentionally exerted control over the above referenced [$130,000 in] donations... and thereby converted the same by diverting the donations to Refuge Recovery House for Refuge Recovery House to use for its own benefit and/or for the benefit of Levine as the sole member of Refuge Recovery House and Refuge Recovery Services.”

145. On or about January 29, 2019, RR The Unelected RR Board caused RR to go beyond the mere filing of the Complaint, and instead to also publish the Complaint on its website for the general public to read, and to send a link to that posting to many thousands of members of the Refuge Recovery community and others by email, and also to post the link on the RR Facebook page.

146. Counterclaim Defendant RR either knew that the above-referenced allegations of sexual assault, rape, and diversion of funds were untrue, or published them with reckless disregard as to whether they were true or false, for the purpose of damaging the reputation of Levine. Upon information and belief, Counterclaim Defendant RR conducted no investigation into whether the allegations were true or false.

147. The defamatory statements made by Counterclaim Defendant RR were and are false, were not privileged, and cannot be construed innocently or neutrally. RR made the statements with actual malice.

148. By reason of Counterclaim Defendant’s defamatory conduct, Levine has suffered and continues to suffer significant damages, in that the alleged publications have damaged his reputation, and exposed him to hatred, contempt, ridicule, embarrassment and humiliation. In addition, it has caused him embarrassment, stress, emotional suffering, mental anguish and emotional distress. Levine is entitled to actual damages in an amount to be determined at trial.

149. Because the Counterclaim Defendant acted with malicious intent to cause harm to Levine, Levine is entitled to exemplary and punitive damages in an amount to be determined at trial.

REQUEST FOR RELIEF

WHEREFORE, Counterclaim Plaintiffs Levine and RRH request that the Court grant them the following relief against Counterclaim Defendant RR:

55. For an order and judgment on the defamation claim, awarding damages against RR, including exemplary and punitive damages, to be determined at trial; “.

Rachael Savage