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Author Topic: Natalee Holloway/Stephany Flores Case Discussion #869 3/20/2015 -  (Read 730475 times)
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texasmom
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ARUBA: It's all about Natalee...we won't give up!


« Reply #1700 on: November 17, 2018, 09:26:59 AM »

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I stand with the girl, Natalee Holloway.

"I can look back over the past 10 years and there were no steps wasted, and there are no regrets,'' she said. "I did all I knew to do and I think that gives me greater peace now." "I've lived every parent's worst nightmare and I'm the parent that nobody wants to be," she said.

Beth Holloway, 2015 interview with Greta van Susteren
texasmom
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ARUBA: It's all about Natalee...we won't give up!


« Reply #1701 on: November 17, 2018, 09:56:31 AM »

First 25 of 51 pages of Beth's amended complaint (1 of 2)

IN THE UNITED STATES DISTRICT COURT  FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION 
ELIZABETH ANN HOLLOWAY, 
Plaintiff, 
v. 
OXYGEN MEDIA, LLC, and BRIAN GRADEN MEDIA, LLC,   
Defendants.
) ) ) ) ) ) ) ) ) ) )   
CIVIL ACTION FILE NO.  2:18-CV-00176-KOB   
         Jury Trial Demanded
___________________________________ 
FIRST AMENDED COMPLAINT FOR DAMAGES 
 COMES NOW, Elizabeth Ann Holloway, and files her First Amended Complaint for
Damages against Defendants Oxygen Media, LLC and Brian Graden Media, LLC, showing this
Honorable Court as follows:
INTRODUCTION
1. On May 30, 2005, Natalee Holloway (“Natalee”) disappeared on the last night of
her high school senior class trip to Aruba.  In the thirteen years since Natalee’s disappearance,
Plaintiff Elizabeth Ann Holloway (“Beth”), Natalee’s mother, has desperately and endlessly
sought to find Natalee, alive or dead. 
2. Oxygen Media, LLC and Brian Graden Media, LLC (collectively, “Defendants”)
took advantage of Natalee’s disappearance and Beth’s desperation when, between August 19,
2017, and September 23, 2017, Defendants published for profit a six-part “true crime” and
“unscripted” “documentary” entitled The Disappearance of Natalee Holloway (the “Series”)
wherein Defendants made the knowingly false declarations that they had discovered how Natalee
died, where she was buried, that her body was exhumed five years after her death, and that her
FILED  2018 Jul-31  PM 06:30 U.S. DISTRICT COURT N.D. OF ALABAMA
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 1 of 51

remains were then desecrated.  After this lawsuit was instituted, Defendants have republished for
profit their Series as a marathon to coincide with the anniversary of Natalee’s disappearance, as
well as republished individual episodes, with all of the attendant flaws and with actual malice.
3. Defendants’ purported “true crime documentary” Series and their false claims
regarding the murder of Natalee and disgusting desecration of her remains were based solely on
the word of a self-admitted heroin addict, Mr. John Ludwick, and Defendants admitted in their
Series that they believed that sole source to be a liar.
4. On April 25, 2017, after at least two occasions during which Mr. Ludwick was
unable to lead Defendants to any remains or burial site, Mr. Ludwick returned to Aruba and,
outside of Defendants’ presence, “discovered” four bone fragments in a Ziploc bag on his aunt’s
property that he claimed belonged to Natalee and that he kept as a trophy (the “Bone
Fragments”).   
5. On or around June 14, 2017, Defendants were advised by Aruban authorities that
their expert found that the four Bone Fragments were animal bones, not human bones. 
Ultimately, following suspect DNA analysis addressed below, Defendants claimed that just one
of the four Bone Fragments was human (the “Purported Human Bone Fragment”).
6. On August 10 and August 11, 2017, days prior to the Series premiere,
Defendants’ agents contacted Beth privately and claimed to Beth that they discovered human
remains in a grave site in Aruba that they believed to be Natalee, and that they needed Beth’s
DNA to test against those remains to definitively determine whether the remains belonged to
Natalee.  In doing so, Defendants knowingly and intentionally raised Beth’s hopes for a
resolution to Natalee’s disappearance after all of these years.
7. Neither Defendants nor their agents disclosed to Beth during these conversations
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 2 of 51

that the purported human remains were found by a paid participant in a television show who was
an admitted heroin addict, that Defendants were involved, or even that a television show was
being made or existed and that Beth and Natalee’s DNA would be used on that show for
Defendants’ profit.  Beth did not discover the existence of the Series until Defendants’
promotional tour began in earnest just prior to the Series premiere, and only after she was
(falsely) told that the Series found human remains in a grave site in Aruba following a legitimate
investigation by Natalee’s father and private investigator.
8. According to the sworn statement of a Series participant, Gabriel Madrigal, the
“human remains” Defendants claimed to have found were actually pig bones from the skull of a
wild boar that died in 2013 in Florida (the “Pig Skull”).  To repeat, in a “true crime
documentary” about one of the most famous unsolved mysteries in this country, Defendants
claimed to have discovered human remains and used that as a basis to obtain Beth’s DNA
without disclosing the existence of a television show for profit.  They had pig bones.  Nothing
more.
9. In particular, Mr. Ludwick brought to Mr. Madrigal the Pig Skull and stated that
he broke off the four Bone Fragments from the Pig Skull and planted them in Aruba for the
purposes of Defendants’ Series.  Mr. Madrigal taped this conversation.  The Court and
Defendants may choose to watch a video of this recorded conversation at the following link: 
https://www.youtube.com/watch?v=PK8R0UHqRhI (last visited June 12, 2018).   
10. Beth’s counsel is now in possession of the Pig Skull.  The Bone Fragments, and
most especially the Purported Human Bone Fragment, clearly match the appearance and
dimensions of the Pig Skull, and the Purported Human Bone Fragment appears to have come
from the top of the Pig Skull.  Both contain the same green color caused by fungus growth and
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 3 of 51

the same brown plant growth in certain areas.  The Purported Human Bone Fragment is convex
in the same manner as the top of the Pig Skull, each contain the same striations and cracks, and
the length and size of the Purported Human Bone Fragment closely match the length and size of
this portion of the Pig Skull.
11. Following their private declarations and misrepresentations to Beth causing her to
believe that the Series was legitimate, and as mere examples of Defendants’ reckless and
outrageous claims, Defendants published – and made Beth hear, watch, and read – that:  Natalee
was likely drugged, raped, killed, and her body buried after her legs were “cracked” so she could
fit in a burlap sack that would hold her buried body; that five years later, after being “dug up,”
her remains were “crushed” and “pummeled . . . throughout a few hours” “to the point it was not
recognizable”; her skull was “doused in gasoline in a fire pit” “to burn the hair fibers”; and her
crushed bones were then mixed with a dog’s before being “cremated.”  It was not until the end of
the six-week Series that the suspicious circumstances under which the Bone Fragments were
discovered were revealed.  As a result of Defendants’ prior misrepresentations and because these
gruesome depictions appeared on the self-branded go-to network for true crime documentaries,
Beth believed these descriptions to be true.
12. After Defendants received the Bone Fragments from the Aruban authorities,
where they were told that the Bone Fragments uncovered by this unreliable witness were animal
bones, Defendants provided the Bone Fragments to their DNA analyst, Dr. Jason Kolowski.  Dr.
Kolowski first tested the Bone Fragments for nuclear DNA – the type of DNA that makes
humans human and the type of DNA that would allow for a definitive identification of the person
to whom the remains belonged.  That test came back negative for the presence of human DNA. 
Despite this result, Dr. Kolowski then elected to test the Bone Fragments for “mitochondrial
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 4 of 51

DNA.”  That test, according to Defendants, revealed the presence of human mitochondrial DNA
belonging to a Caucasian individual.
13. However, the mitochondrial DNA test performed by Defendants does not
determine species, it determines only the presence of mitochondrial DNA, which all living beings
possess.  Even if the mitochondrial DNA sequence obtained by Defendants is human specific, it
does not follow that the Bone Fragments or the Purported Human Bone Fragment are, in fact,
human.  Such a finding would mean only that there was human mitochondrial DNA found on the
tested Bone Fragments, a finding that is not at all surprising – and may even be expected – given
that the Bone Fragments were handled and likely contaminated by Mr. Ludwick, a Caucasian
and a heroin addict.  Further, whereas tests for nuclear DNA can genetically identify individuals
and family lineage, mitochondrial DNA tests cannot uniquely identify one person under any
circumstances.  The most that Defendants’ mitochondrial DNA test could have done is exclude
the Bone Fragments as belonging to Natalee or determine that the bones belonged to an
individual with a mitochondrial DNA sequence similar to Natalee’s, a sequence that is
presumably shared very widely amongst humankind.  At best, Defendants could have used the
test to determine that Natalee’s DNA was not excluded by the test.  Accordingly, there was no
reasonable basis to conclude that any of the Bone Fragments – in the face of the Aruban
authorities’ declaration that the bones were animal bones and in light of the likelihood of
contamination – were human, and certainly not that the Bone Fragments belonged to Natalee. 
Defendants could have done a speciation test or submitted the Bone Fragments to an
anthropologist to determine whether they were human; they did not do so despite Mr. Ludwick’s
lack of credibility.
14. It appears to have been Defendants’ conduct that substantially caused Dr.
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Kolowski’s errors:  they did not disclose to Dr. Kolowski how the Bone Fragments were
discovered and the associated and resulting contamination of the Bone Fragments.  In Dr.
Kolowski’s own words to Beth:
I feel that in hindsight, I was kept out of the loop of the origin of the bone samples on purpose.  I was told they were recovered in the course of the investigation and were in the possession of the Aruba authorities, who turned them over to TJ [Ward] and Dave for further analysis.  I was not told that John [Ludwick] and Gabe [Madrigal] recovered the bones by themselves, which is a huge conflict. . . . While the testing and my handling of the bones was done professionally and ethically, I could also be ‘burned’ professionally for having done testing on samples that were known to be compromised . . . 
Dr. Kolowski was told by Defendants that T.J. Ward, the Series’ private investigator, recovered
the Bone Fragments from a pet cemetery; he was not told that a heroin addict handled and found
the Bone Fragments in a Ziploc bag without any independent corroboration.
15. It was only after Beth was told of an allegedly credible find of human remains by
seemingly credible individuals in a private investigation, which remains were being tested by a
seemingly credible DNA expert for private purposes, that Beth was forced to hear and watch the
gruesome depictions of Natalee’s desecration in a so-called documentary.  When Beth heard that
Natalee’s skeleton was exhumed and broken into tiny pieces before being mixed with the
remains of a dog, among the many other descriptors, she was not privy to the litany of reasons
showing Mr. Ludwick to lack all credibility in Defendants’ possession at the time of publication. 
Defendants could have waited a matter of weeks to air their show to first conclusively determine
whether they had found Natalee’s bones – they did not – and thereby spare Beth, but for their
own purposes and designs, Defendants recklessly rushed to publish their farcical Series. 
16. Further, according to a lawsuit filed by the Series’ creator, rather than being an
unscripted and true-crime documentary as Defendants portrayed to Beth and their viewers,
Defendants’ Series was preconceived and written in advance.  The Series was not a real-time or
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 6 of 51

legitimate investigation into new leads, and Defendants’ purported discovery of Natalee’s
remains was not spontaneous.  Instead, the Series was a pre-planned farce, and its publication
was outrageous. 
17. In addition to the publications in the Series, Oxygen Media, LLC made the same
outrageous claims before, during, and after the Series via its website, Oxygen.com.
18. The impact of Defendants’ deceit on Beth was profound.  Through their claims
directly to Beth, through their Series, and through their media publications, Beth truly believed
Defendants had found Natalee but she was forced to wait nearly two months to discover the
truth, and even longer to discover that her suffering was consciously and wrongfully inflicted
and that Defendants’ Series was a hoax.  In Beth’s own words, having to wait without knowing
what would happen next while Defendants repeatedly proclaimed what heinous acts had been
visited upon Natalee and her body “completely and utterly destroyed me.” 
19. Accordingly, this Complaint is brought against Defendants for their publication of
gruesome and consciously false descriptions and images of the manner in which Natalee died
and the desecration of Natalee’s remains, and for their fraudulent involvement of Beth by
obtaining her DNA under false pretenses.  Defendants’ conduct is so extreme and outrageous as
to go beyond all bounds of decency and is not to be tolerated in a civilized society.  Defendants
recklessly disregarded the likelihood that their claims were false, and in doing so, intentionally
caused or recklessly disregarded a probability that they would cause Beth grievous emotional
suffering.
PARTIES, JURISDICTION, AND VENUE
20. Plaintiff Elizabeth Ann Holloway is an individual who resides in Jefferson
County, Alabama. 
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 7 of 51

21. Beth is a schoolteacher in Cullman County, Alabama, and a mother of one son.  In
2007, Beth authored a book regarding Natalee’s tragic disappearance, her own suffering, and
how she survived in the immediate aftermath of losing her daughter.  Beth opens her book by
describing herself as follows:
I’m the parent who got the dreaded call.  The parent no one wants to be.  The one whose phone rang out of the blue in the middle of the day, and the voice on the other end said, “Your daughter is missing.”  I’m that desperate mother on TV holding up pictures of her missing child, pleading for help, describing the details surrounding an unthinkable crime.  My daughter is Natalee Holloway.  She disappeared in Aruba on the last night of her senior-high graduation trip in 2005 and hasn’t been seen since.  I never imagined that I would be “that parent,” living an endless nightmare in front of the whole world.  But I was, and I still am, because I will always search for her.  I will forever be Natalee’s mom. 
Beth Holloway, Loving Natalee:  A Mother’s Testament of Hope and Faith XV (1st ed. 2007). 
22. Defendant Oxygen Media, LLC (“Oxygen”), a wholly owned subsidiary of NBC,
is a limited liability company organized and existing under the laws of the State of Delaware
with its principal place of business being located at 30 Rockefeller Plaza, New York, New York
10112.   
23. Oxygen’s slogan is “The New Network for Crime.”  According to NBC
Universal’s website, 
Oxygen Media is a multiplatform crime destination brand for women.  Having announced the full-time shift to crime programming in 2017, Oxygen has become the fastest growing cable entertainment network with popular unscripted original programming that includes the flagship “Snapped” Franchise, “The Disappearance of Natalee Holloway,” “The Jury Speaks,” “Cold Justice,” “Three Days to Live,” and “It Takes A Killer.”  Available in more than 77 million homes, Oxygen is a program service of NBCUniversal Cable Entertainment, a division of NBCUniversal, one of the world’s leading media and entertainment companies in the development, production, and marketing of entertainment, news, and information to a global audience. 
See http://www.nbcuniversal.com/business/oxygen-media (last visited Nov. 29, 2017). 
24. Defendant Brian Graden Media, LLC (“BGM”) is a limited liability company
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 8 of 51

organized and existing under the laws of the State of California with its principal place of
business being located at 6855 Santa Monica Blvd., Suite 406, Los Angeles, California 90038.   
25. There is complete diversity of citizenship between Beth and Defendants and the
amount in controversy exceeds Seventy-Five Thousand Dollars ($75,000.00), exclusive of
interest, costs, and attorneys’ fees.  Therefore, this Court has subject matter jurisdiction pursuant
to 28 U.S.C. § 1332(a).
26. Defendants transact business in the State of Alabama and have committed tortious
acts in the State of Alabama.
27. Defendants published the Series in the State of Alabama.
28. Oxygen published its offending articles in the State of Alabama.
29. Defendants published their offending statements directly to Beth in the State of
Alabama.
30. Defendants sought and obtained Beth’s DNA in the State of Alabama.
31. Defendants directed their conduct at Beth, a citizen of Alabama.
32. Oxygen owns and operates the Oxygen Network and an Internet publication at
Oxygen.com, and its publications are regularly made throughout the State of Alabama.
33. Defendants have intentionally sought and obtained benefits from their tortious
acts in Alabama. 
34. Defendants are subject to the jurisdiction of this Court pursuant to Rule 4.2 of the
Alabama Rules of Civil Procedure.
35. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b), based on the fact
that Defendants are subject to personal jurisdiction in this District and a substantial part of the
events giving rise to this claim occurred in this District.
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 9 of 51
10 
FACTUAL BACKGROUND
Natalee’s Disappearance and Beth’s Search for Her Daughter
36. Natalee was one of approximately 120 students from Mountain Brook High
School who took a senior class graduation trip to the island of Aruba in May 2005.
37. The students began their trip on May 26, 2005, and were scheduled to return
home on May 30, 2005.
38. Natalee was last seen entering a car with Joran van der Sloot, Deepak Kalpoe, and
Satish Kalpoe at approximately 1:30 a.m. on the morning of May 30, 2005.
39. Later that same morning, Natalee failed to meet her classmates for their return
flight to the United States. 
40. Joran van der Sloot, Deepak Kalpoe, and Satish Kalpoe have been repeatedly
arrested and released from prison as suspects in Natalee’s disappearance.
41. In June of 2011, Natalee’s father, Dave Holloway, filed paperwork in Alabama
seeking to have her declared dead.
42. Natalee was declared legally dead in January 2012, but her whereabouts and body
remain unfound.  Thus, whether she is actually dead remains unknown.
43. Beth disagreed with Dave Holloway’s decision to have Natalee declared dead and
has been quoted as saying that she “will always hope and pray for Natalee’s safe return.” 
44. The manner of Natalee’s death, if she is dead, also remains unknown.
45. Natalee’s disappearance was the subject of nearly unprecedented media coverage
with round-the-clock coverage of the investigation by members of both the print and broadcast
media.
46. In the immediate aftermath of Natalee’s disappearance, Beth took all measures
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 10 of 51
11 
available to her to locate her daughter. 
47. Beth worked with a multitude of individuals to find Natalee, including but not
limited to:  American, Aruban, and Netherlands authorities; Queen Beatrix of the Netherlands;
Aruba Prime Minister Nelson Oduber; Aruba Minister of Justice Rudy Croes; Aruba Chief
Prosecutor Karin Janssen; Aruba Minister of Tourism Ruben Trappenberg; Aruba Police Chief
Gerold Dompig; the Royal Netherlands Air Force; Aruba attorneys Vinda de Sousa and Helen
Lejuez; President Bill Clinton; U.S. Secretary of State Condoleezza Rice; U.S. Secretary of
Homeland Security Michael Chertoff;  FBI Agent William Bryan among other agents; FBI Legal
Attache Doug Shipley; DEA Agent Eric Williams among other agents; International Victims’
Assistance representatives Kathleen Hall and Dahlia Williams; American Consulates; the
American Consulate General; Alabama Senator Richard Shelby; Alabama Senator Jeff Sessions;
Alabama Congressman Spencer Bachus; Alabama Governor Bob Riley; GA Governor Sonny
Purdue; Arkansas Governor Mike Huckabee; Alabama Lieutenant Governor Luther Strange;
New York City Attorney John Q. Kelly; Ross Perot; the Florida State University Dive Team;
Texas Equusearch; private investigators; and many other authorities; as well as the media,
celebrities, and countless others in her ongoing efforts to find Natalee.
48. Despite repeated searches of Aruba and its waters, neither Natalee nor her
remains have ever been located. 
49. Beth continues to work to discover her daughter’s fate. 
The Actors in the Series
50. The Series was acted out by a number of paid participants, including, among
others:  Gabriel Madrigal (“Madrigal”), John Ludwick (“Ludwick”); Dave Holloway (“Dave”);
T.J Ward (“Ward”); and Jason Kolowski, Ph.D. (“Kolowski”).
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12 
51. Ludwick is referred to as the “suspect” in the Series.  Ludwick claims, among
other things, to have known Joran van der Sloot, to have exhumed Natalee’s body at van der
Sloot’s bidding, to have “crushed” Natalee’s remains into little pieces, and to have burned her
skull before disposing of her remains.
52. Defendants claim that Ludwick was unaware of their involvement, the Series, and
the investigation into Natalee’s disappearance until after he made his confessions during a
“sting” operation depicted in the Series. 
53. Madrigal is referred to as the “informant” in the Series.  Madrigal is depicted by
Defendants as spurring the “new lead” into Natalee’s disappearance.
54. Dave is depicted in the Series as Natalee’s grieving father.
55. Ward is depicted in the Series as the private investigator leading the investigation
into Natalee’s disappearance.
56. Kolowski is depicted in the Series as a forensic expert. 
The Creation and Marketing of the Series
57. Defendants represented in promotional materials and in the Series itself that the
Series was an “unscripted” “real-time investigation” and “documentary” following “a new lead
that could deliver justice for Natalee once and for all,” including “the specifics of what happened
to her and the remains of her body.” 
58. Contrary to Defendants’ representations, the Series was not an “unscripted”
“documentary” or “real-time investigation.” 
59. Rather, upon information and belief, the Series – and its resolution – was a
scripted, pre-planned farce calculated to give the impression of real-time events.
60. Accordingly, upon information and belief, Defendants knew at the outset that they
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 12 of 51
13 
had not discovered, and would not discover, Natalee’s remains.
61. Beth, distraught by the Series, its claims, and her interactions with Defendants
and their agents, only discovered the true nature of the Series following an investigation by
counsel. 
62. In the matter styled Kramer v. Brian Graden Media, LLC et. al., Case No. 2:17
CV-5990 (C.D. Cal. Aug. 11, 2017) (the “Kramer Matter”), the plaintiff, Edward Kramer, seeks
compensation for services he claims to have rendered to Oxygen and BGM.   
63. In particular, Mr. Kramer asserts in the Kramer Matter that he worked with Ward
to create the Series, and that Kramer authored the Series, its plot, and its resolution more than a
year before its publication.   
64. According to Mr. Kramer, he created the plans, scenarios, and episode guides
used by Defendants to “script” the Series.  Mr. Kramer asserts that the “resolution” of the Series
was pre-conceived, and that he wrote it.  (Kramer Matter, ¶¶ 16-21, 27).
65. Mr. Kramer claims to be responsible for signing Madrigal and Ludwick to non
disclosure agreements and recording his conversations with them, which agreements were signed
by BGM, and for selecting Kolowski as the Series’ forensic scientist.  (Kramer Matter, ¶¶ 15,
19).
66. Madrigal purportedly contacted Dave in September 2015 claiming his roommate,
Ludwick, knew the location of Natalee’s remains.  Madrigal was again purportedly interviewed
by Ward on May 29, 2016. 
67. Accordingly, upon information and belief, these interviews and all events in the
Series took place only after Madrigal and Ludwick had already signed non-disclosure
agreements and otherwise agreed to roles as paid participants in the Series.
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 13 of 51
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Timeline of the Series Versus Real Time
68. A review of the purported “real time” events in the Series and those events that
took place in real life reveals that the Series was, in fact, scripted, that Defendants consciously
delayed the results of their DNA testing, that Defendants knowingly preyed on Beth’s hope for
finding her daughter, and that Defendants consciously misrepresented their “discovery” of
“human” remains to hoodwink Beth into providing her DNA for comparison and publication for
profit.
69. As early as the fall of 2014, Mr. Kramer had already created the Series.  (Kramer
Matter, ¶¶ 8, 11).
70. In June 2015, Ward and Dave “signed a Memorandum and Paid Participant
Agreement” to participate in the Series.  (Kramer Matter, ¶ 14).
71. In September 2015, Madrigal called Dave claiming to have a lead – through
Ludwick – on Natalee’s remains.
72. According to Defendants, this September 2015 call was “unsolicited,” and
therefore a fortuitous break for Defendants’ Series.   
73. Dave states that it was when he received that call from Madrigal that he “picked
up the phone and called” Ward.
74. However, according to Mr. Kramer, he was concurrently preparing “non
disclosure agreements and recordings of conversations” with Madrigal and Ludwick, and Dave
and Ward were already signed up as paid participants.  (Kramer Matter, ¶¶ 14, 15).
75. In May 2016, Ward interviewed Madrigal remotely, and was told much of the
information later published in the Series. 
76. On February 8, 2017, Madrigal was interviewed by Dave in person.  This
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15 
interview was aired in the Series and Defendants conveyed that it was a live and unscripted
interview wherein Dave learns of Madrigal’s purported information for the first time.
77. On February 13, 2017, Defendants staged a “sting” operation in which Madrigal
allegedly took Ludwick to gamble in New Orleans with the intent of getting him to admit on tape
to his participation in the exhumation and desecration of Natalee’s remains.  Ludwick was
purportedly enticed to go because it was an “all expenses paid” vacation.   
78. During this “sting” operation, Defendants claim to have surreptitiously surveilled
Madrigal and Ludwick’s hotel room without Ludwick’s knowledge.  Indeed, Dave himself
claims that Ludwick “does not know that we are involved at this point in time.”
79. By this time, however, Ludwick had already signed a non-disclosure agreement
and had his conversations with Mr. Kramer regarding the case recorded.  (Kramer Matter, ¶ 15).   
80. Accordingly, upon information and belief, Ludwick was a paid participant in the
Series and was aware at all times during the Series that he was being taped for publication.
81. On March 15, 2017, Defendants introduce Dr. Jason Kolowski to the Series. 
Kolowski is a forensic scientist and his “major background is DNA analysis.”  He focuses “on
mitochondrial DNA and the forensic application of mitochondrial analysis.”  See
http://www.oxygen.com/the-disappearance-of-natalee-holloway/blogs/meet-the-forensic
scientist-whos-helping-in-the-search (last visited Nov. 1, 2017).   
82. As of March 15, 2017, Madrigal had allegedly “quit” being Defendants’
informant.
83. On March 16, 2017, Madrigal allegedly agreed to come back on board, to go to
Aruba, and to bring Ludwick with him to lead Defendants to the burial site. 
84. By March 19, 2017, Madrigal and Ludwick – and each of their girlfriends – were
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 15 of 51
16 
already in Aruba. 
85. Defendants continued during this trip to represent that Ludwick was unaware of
their involvement, that their video footage of Ludwick was covert surveillance, and that
Madrigal was still acting as their informant. 
86. On March 19, 2017, Ludwick took Madrigal to identify the grave site where he
allegedly dug up Natalee’s remains (the “first search”).   
87. Ludwick was unable to identify the grave site during the first search.
88. On March 26, 2017, Ward interviewed Ludwick in person.
89. Accordingly, by March 26, 2017, Defendants could no longer claim that Ludwick
was unaware of their involvement.  When and how Ludwick became so aware is not mentioned
in the Series.   
90. On April 6, 2017, Dave and Ward met with Madrigal to “get a plan going on what
we are going to do next,” stating that “John has indicated to Gabriel that he is willing to pinpoint
the exact location and cooperate with the Aruban authorities in showing the exact location and
hopefully solving this case.” 
91. On April 8, 2017, Madrigal and Ludwick re-appeared in Aruba to “pinpoint” the
grave site to Defendants (the “second search”).
92. Ludwick was again unable to identify Natalee’s grave site during the second
search.
93. Ludwick was further unable during the second search to identify the alleged
“cave” near his aunt’s property where he and van der Sloot allegedly burned Natalee’s skull.
94. After the failed second search, Defendants confirmed that “Dave and the team cut
ties with Gabriel and John” because they believed the lead to have been false and unfounded. 
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95. Nonetheless, Defendants then claimed that “[t]wo weeks later, [Dave and Ward]
receive[d] word that Gabriel and John have returned to Aruba on their own.”   
96. Madrigal and Ludwick then return to Aruba with Madrigal filming their trip via
his cell phone.  According to these unverified video clips, Madrigal and Ludwick returned to
Aruba for a third time to “bring Natalee home” and because Ludwick knew where her remains
are because “he kept [them] as a trophy” (the “third search”). 
97. During the third search, Madrigal and Ludwick purport to go to Ludwick’s aunt’s
house.   
98. Within seconds, Ludwick takes Madrigal directly to the foot of a wall enclosing
his aunt’s property.   
99. By this time, it had been approximately seven years since Ludwick allegedly
exhumed and desecrated Natalee’s remains.
100. Madrigal films while Ludwick purports to uncover a Ziploc bag from just beneath
the ground surface containing the four Bone Fragments.
101. The Ziploc bag, supposedly buried for seven years, appears fairly new, clean, and
in good condition.
102. On April 25, 2017, Dave received a text message from Madrigal containing a
photograph of the Bone Fragments and stating “Hey Dave just in case you think I’m lying I got
evidence[.]  That what this sick f*** gave me as he uncovered it[.]” 
103. Madrigal and Ludwick further claim that the remainder of Natalee’s remains were
buried at a pet cemetery. 
104. Although the date is not given, Madrigal documents via his cell phone Ludwick’s
attempt to identify the grave site with the rest of Natalee’s remains at the pet cemetery (the
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“fourth search”).
105. Ludwick was unable to identify the grave site during the fourth search.
106. Defendants delayed traveling to Aruba to obtain the Bone Fragments from
Aruban authorities for a period of seven weeks.
107. On June 14, 2017, Dave and Ward met with Aruban authorities to obtain the Bone
Fragments. 
108. Although Defendants obtained the Bone Fragments on June 14, 2017, Defendants
did not deliver the bone fragments to their already-retained forensic expert, Kolowski, until July
6, 2017. 
109. The Series, however, states that “[up]on their arrival into the U.S., the bones were
handed off to forensic expert Dr. Jason Kolowski to conduct testing.”
110. Kolowski delivered the bone fragments to a third-party lab (the “Laboratory”) on
the same day, July 6, 2017.
111. On August 10, 2017, prior to the next scene in the Series, Dave contacted Beth
and advised that he and Ward may have discovered Natalee’s “remains.”
112. During this call, Dave advised Beth that “remains” were discovered in Aruba, and
that DNA analysis has shown that the remains are “human female remains” from a “single
individual” of “Caucasian Eastern European origin.”  Dave further advised that the remains are
at least ten years old – the general timeframe that Natalee disappeared. 
113. Accordingly, no later than August 10, 2017, Defendants had informed Dave that
the Bone Fragments were human.
114. During this call and a subsequent text message of the same date, Dave asked Beth
for a DNA sample.
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115. On the same date, August 10, 2017, Kolowski telephoned Beth to confirm the
discovery and analysis of the remains.
116. During this call, Kolowski advised that there would be no gray area – the results
of Beth’s DNA compared to the human remains would either be a match or a full exclusion. 
Kolowski further stated that the analysis would be complete within 30 days.
117. On August 11, 2017, Kolowski contacted Beth via text and overnighted a DNA
kit to Beth.
118. Neither Dave nor Kolowski disclosed Defendants’ involvement to Beth.
119. Kolowski initially instructed the Laboratory on July 6, 2017, to process all four
Bone Fragments together into one extract, rather than examine each of the four Bone Fragments
individually.
120. Later, on August 11, 2017, Kolowski delivered to the Laboratory the remaining
portions of the four Bone Fragments for individual testing. 
121. On August 12, 2017, Beth received, completed, and returned the DNA kit to
Kolowski. 
122. The next event depicted in the Series was a meeting between Dave, Ward, and
Kolowski on August 17, 2017, at least one week after Dave was already informed of Kolowski’s
findings.
123. Defendants convey in their Series that this is the first time that they and their paid
participants, Dave and Ward, learn the results of the DNA testing. 
124. It is during this August 17, 2017, meeting that Defendants convey to their viewers
that:  (1) some or all of the Bone Fragments are human; (2) the Bone Fragments belong to a
Caucasian of European descent; and (3) that Beth’s DNA is needed to definitively determine
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whether the Bone Fragments belong to Natalee.
125. However, as set forth above, Kolowski had already conveyed the results of this
initial DNA testing to Defendants and Dave at least a week prior to the August 17, 2017,
meeting.   
126. Accordingly, the August 17, 2017, meeting in the Series was not an unscripted
documentary as conveyed by Defendants.
127. In keeping with Mr. Kramer’s allegations in the Kramer Matter, Defendants
staged this scene to appear as though it occurred in real-time when, in fact, it was preconceived.
128. Beth was unaware that the purported “remains” were merely four Bone Fragments
found in a Ziploc bag by Madrigal and Ludwick until she watched the Series itself.
129. Then, in its last episode, the Series shows a meeting between Kolowski, Ward,
and Dave on September 11, 2017, wherein Kolowski conveyed additional results of the DNA
testing.
130. During this scene, Kolowski and Defendants convey that they were expecting one
of three possible outcomes:  a match, inconclusiveness, or a full exclusion. 
131. Defendants further conveyed that “we are not seeing a match, but [Kolowski is]
not prepared to call this a full exclusion yet” because they only had access to the DNA profile
obtained from the combined sample of all four Bone Fragments rather than each of the four Bone
Fragments being tested individually. 
132. Defendants, through Kolowski, convey that the testing is “comfortably”
inconclusive. 
133. This was the sixth and final episode of the Series and aired September 23, 2017. 
134. Defendants concluded their Series without divulging the results of the DNA
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testing.
135. Defendants received a written report from the Laboratory on September 22, 2017,
stating, among other things, that the results for the Purported Human Bone Fragment were “not
reportable.”
136. Accordingly, Defendants knew prior to the publication of their last episode that
they could not match the Bone Fragments to Natalee.
137. In fact, Defendants knew all along that they could not match the Bone Fragments
to Natalee as soon as they received confirmation that the Bone Fragments did not contain human
nuclear DNA, and thus that they had to rely on mitochondrial DNA.
138. Accordingly, Defendants received no new information from which they could
have determined that the Bone Fragments did or did not belong to Natalee after they aired their
final episode claiming that the testing was “inconclusive.”
139. Nonetheless, rather than stating that the results were “inconclusive” as was aired
to the world and to Beth specifically, Kolowski’s final report, issued September 30, 2017, stated
that the fact that the combined bone DNA sequence did not match Beth’s was “the first proof of
an exclusion.”
140. Kolowski’s final report further stated that the fact that the remaining three Bone
Fragments were determined not to be human “is the second and final proof of exclusion.”   
141. Further, the Laboratory reports relied upon by Kolowski and Defendants also
stated that the sample was suitable for exclusion purposes only. 
142. Accordingly, Defendants and Kolowski knew that they would not be able to
compare the Bone Fragments to Beth’s DNA to obtain a match, i.e., determine that they had
found Natalee’s remains, because the mitochondrial DNA was not of sufficient quality according
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to the Laboratory.
143. In truth, despite their representations to Beth, in the Series, and in the media,
Defendants never had a DNA sample from which they could determine whether the Bone
Fragments were Natalee’s remains.  As set forth above, mitochondrial DNA cannot provide a
genetic match to a particular person.
144. In truth, despite their representations to Beth, in the Series, and in the media,
Defendants knew prior to concluding their Series that the Bone Fragments did not belong to
Natalee. 
145. In truth, despite their representations to Beth, in the Series, and in the media,
Defendants knew prior to filming their Series that they would not find Natalee because the Series
was pre-conceived and was not a real-time investigation discovering new facts.
146. Defendants had the results necessary to confirm that the Bone Fragments did not
belong to Natalee no later than September 11, 2017, but chose to publish to the world and to
Beth that the results remained “inconclusive.”
147. Defendants did not disclose the results of the DNA testing until October 2, 2017,
via their website, Oxygen.com.
148. On October 2, 2017, Defendants admitted that they did not discover Natalee’s
remains.
149. Defendants attempted to delay their receipt of the Laboratory’s findings – that
they had not discovered Natalee’s remains – so that they could continue to hype their Series as
having discovered Natalee’s remains, and to maximize their ratings and profits. 
Publication of the Articles
150. Between August 16, 2017, and September 21, 2017, Oxygen further published via
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their website Oxygen.com seven absurd, grotesque, and knowingly false articles regarding the
manner of Natalee’s death and the desecration of her remains.
CAUSES OF ACTION
COUNT ONE:  FRAUDULENT MISREPRESENTATION AND SUPPRESSION 
151. Beth reasserts and incorporates by reference paragraphs 2-19, 36-49, and 68-145
of this Complaint as if fully restated herein.
152. Defendants obtained Beth’s DNA through her reliance on their fraudulent
misrepresentations and suppressions made with an intent to deceive.
153. Defendants lured Beth in with false, omitted, and misrepresented information, and
later used Beth’s DNA on their Series without her permission (or seeking her permission).
154. Defendants claimed to have found “human female remains” when, in fact, the
remains they had in their possession were pig bones.
155. As set forth in paragraph 14, Defendants also misled their own retained DNA
consultant, Kolowski, as to the origin of the Bone Fragments, who Defendants “kept out of the
loop of the origin of the bone samples on purpose.”
156. August 10, 2017, was the first time Beth was told by anyone that Dave and Ward
were pursuing this lead into Natalee’s disappearance.
157. On August 10, 2017, Dave contacted Beth by telephone to advise Beth that he and
Ward had discovered “human female remains” in Aruba. 
158. On August 10, 2017, Dave contacted Beth to ask that she provide a DNA sample
for forensic analysis to determine if the human female remains he and Ward discovered were, in
fact, Natalee’s remains. 
159. Upon information and belief, Dave contacted Beth on August 10, 2017, at the
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direction of Defendants and in furtherance of their business. 
160. Defendants did not disclose to Beth prior to her delivery of her DNA that her
DNA results would be broadcast to the world for Defendants’ benefit. 
161. Defendants knew that to continue their Series – which was set to air less than ten
days after they sought Beth’s DNA – they needed Beth’s DNA to give the appearance of
determining whether the Bone Fragments were Natalee’s. 
162. On August 10, 2017, to induce Beth into providing her DNA, Defendants, by and
through their agent Dave, misrepresented to Beth material facts regarding the origins and
circumstances of their purported discovery of Natalee’s remains. 
163. Defendants knew, or should have known, that by making such misrepresentations,
they would raise Beth’s hopes and prayers for the return of her daughter and closure to this
tragedy.  Indeed, Defendants forced Beth to wait through six episodes of the most heinous
descriptions of what happened to her daughter, and let Beth suffer through it. 
164. Defendants knew, or should have known, that they would destroy those hopes and
prayers because they knew they could not return Natalee or her remains.
165. On August 10, 2017, to induce Beth into providing her DNA, Defendants, by and
through their agent Dave, misrepresented to Beth that they may have discovered Natalee’s
remains.   
166. As set forth herein, Defendants knew that they had not discovered Natalee’s
remains prior to contacting Beth. 
167. On August 10, 2017, to induce Beth into providing her DNA, Defendants, by and
through their agent Dave, misrepresented to Beth that the discovery of the remains was a
spontaneous, rather than pre-planned, event.
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168. As set forth herein, Defendants’ Series and its resolution was scripted. 
169. On August 10, 2017, to induce Beth into providing her DNA, Defendants, by and
through their agent Dave, misrepresented to Beth that the remains they discovered were “female”
remains. 
170. Defendants knew that the DNA testing they had conducted could not determine
gender.
171. On August 10, 2017, to induce Beth into providing her DNA, Defendants, by and
through their agents Dave and Kolowski, misrepresented to Beth that the DNA sample in their
possession could be matched to Beth.
172. As set forth herein, and upon information and belief, Defendants knew that their
DNA samples were “below the limit of detection” and ultimately could be used “for exclusion
purposes only.” 
173. As set forth herein, the mitochondrial DNA test employed by Defendants is
incapable of “matching” the Bone Fragments to Natalee even if they had pristine,
uncontaminated bone fragments.
174. On August 10, 2017, to induce Beth into providing her DNA, Defendants, by and
through their agent Dave, misrepresented to Beth that the remains were discovered in a “grave
site” near Ludwick’s relative’s home. 
175. As Defendants knew, the Bone Fragments were not discovered in a “grave site.” 
Instead, just four Bone Fragments were discovered in a small hole in the ground at the foot of a
fence in a plastic Ziploc bag. 
176. Defendants, including through their agents Dave and Kolowski, consciously
failed to disclose to Beth that the persons who “discovered” the Bone Fragments were paid for

to be continued...
Logged

I stand with the girl, Natalee Holloway.

"I can look back over the past 10 years and there were no steps wasted, and there are no regrets,'' she said. "I did all I knew to do and I think that gives me greater peace now." "I've lived every parent's worst nightmare and I'm the parent that nobody wants to be," she said.

Beth Holloway, 2015 interview with Greta van Susteren
texasmom
Monkey Mega Star
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Posts: 32052


ARUBA: It's all about Natalee...we won't give up!


« Reply #1702 on: November 17, 2018, 11:41:15 AM »

Sorry y'all, I've been trapped in update hell!  PDF froze so I didn't have a choice.   

Continued from above and one more to come, Pages 26-46 of Beth's amended complaint:

their participation in the Series.
177. Defendants, including through their agents Dave and Kolowski, consciously
failed to disclose to Beth that the persons who “discovered” the Bone Fragments were unable to
lead Defendants to any remains during the first, second, and fourth searches for her remains. 
178. Defendants, including through their agents Dave and Kolowski, consciously
failed to disclose to Beth that the persons who “discovered” the Bone Fragments did so by
themselves with no third-party corroboration.
179. Defendants, including through their agents Dave and Kolowski, consciously
failed to disclose to Beth that the persons who “discovered” the Bone Fragments found the
remains on their first solo attempt, with minimal effort, hardly buried, in a seemingly fresh
Ziploc bag that would have supposedly had to have been buried for approximately seven years. 
180. Defendants, including through their agents Dave and Kolowski, consciously
failed to disclose to Beth that the persons who “discovered” the Bone Fragments demonstrated a
total lack of credibility.
181. Defendants, including through their agents Dave and Kolowski, consciously
failed to disclose to Beth that Defendants themselves questioned the credibility of the persons
who “discovered” the Bone Fragments because their story changed multiple times.
182. Defendants, including through their agents Dave and Kolowski, consciously
failed to disclose to Beth that Ludwick admitted to being addicted to heroin at the time he claims
to have disposed of Natalee’s remains. 
183. Defendants, including through their agents Dave and Kolowski, did not disclose
to Beth that Defendants, or any major television network, were in any way involved in the
discovery of the remains. 
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184. Rather, Beth understood that Dave and Ward conducted their own independent
investigation, thereby giving Defendants’ “discovery” of human “female” remains an aura of
credibility that would not have been present had Beth known it was a project for profit. 
185. Beth was unaware that the Series or any major television network was filming a
series regarding Natalee until after she provided her DNA to Defendants.
186. Defendants did not disclose to Beth prior to her delivery of her DNA sample that
same would be used in Defendants’ Series.   
187. Defendants made each of the above lies, misrepresentations, and omissions with
the intent to deceive Beth into providing her DNA.   
188. Defendants knew and had special reasons to expect that Beth would be influenced
by their lies, misrepresentations, and omissions, because of Beth’s relationship to Natalee and
her ongoing search to discover what happened to her daughter. 
189. Defendants, through their agent Dave, Beth’s ex-husband, maintained a
confidential relationship with Beth. 
190. Relying on Defendants’ lies, misrepresentations, and omissions, Beth provided
her DNA to Defendants, hoping and believing it would lead to the discovery of her daughter’s
remains.
191. As a direct result of Defendants’ lies, misrepresentations, and omissions, Beth
began to hope and believe that her daughter had been found.
192. Defendants had not found Natalee, and they knew or should have known that they
had not found Natalee, prior to their publications to the contrary directly to Beth.
193. Beth’s provision of her DNA furthered Defendants’ business and Defendants’
Series.
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194. Defendants profited and otherwise derived a benefit from Beth’s provision of her
DNA. 
195. Upon information and belief, Defendants instructed Dave and Kolowski to obtain
Beth’s DNA for the purposes of their Series.
196. All acts and omissions of Dave and Kolowski were undertaken in the normal
course and the furtherance of Defendants’ business.
197. Upon information and belief, Defendants had the right and ability to control the
manner and means of Dave’s and their other paid participants’ investigation into Natalee’s
disappearance and the location of her remains, including by: (1) determining when episodes
could be filmed; (2) determining where and when the paid participants could travel during the
investigation; (3) furnishing the equipment, vehicles, plane tickets, and lodging used by the paid
participants in the investigation; (4) determining what persons would be available to assist in the
investigation; (5) determining the plot of each episode; (6) financing the DNA testing; and (7)
financing the investigation and the Series.
198. Upon information and belief, Defendants had the right and ability to control Dave
and Kolowski through their contractual terms, including by scripting and/or plotting the Series
for Dave and Kolowski to carry out.
199. Upon information and belief, Defendants had the right and ability to control Dave
and Kolowski through their contractual terms, including by requiring that they perform the scope
of work specified in the contracts, and that they do so in furtherance of Defendants’ business. 
200. Upon information and belief, Defendants had the right and ability to control Dave
and Kolowski through their contractual terms, including by requiring confidentiality regarding
the production of the Series and its events.
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201. Upon information and belief, Defendants had the right and ability to control Dave
and Kolowski through their contractual terms, including by withholding payment to Dave and
Kolowski as paid participants.
202. Upon information and belief, Defendants had the right and ability to control Dave
and Kolowski through their contractual terms, including by withholding payments necessary to
finance the Series and its investigation into the discovery of Natalee’s remains.
203. Dave and Kolowski acted within the scope of their authority and for Defendants’
benefit when they contacted Beth on August 10, 2017.
204. Defendants demonstrated their authorization and ratification of Dave’s and
Kolowski’s actions by seeking an interview from Beth after she submitted her DNA under false
pretenses.
205. Defendants demonstrated their authorization and ratification of Dave’s and
Kolowski’s actions by utilizing Beth’s DNA in their Series without seeking or obtaining her
permission. 
206. Defendants demonstrated their authorization and ratification of Dave’s and
Kolowski’s actions by attempting to surreptitiously, without Beth’s authorization, film
Kolowski’s telephone call to Beth revealing results from the DNA testing. 
207. Defendants further demonstrated their authorization and ratification of Dave’s and
Kolowski’s actions by themselves misrepresenting the circumstances of the discovery and chain
of custody of the remains to Kolowski.  In particular, Defendants misinformed Kolowski
regarding the circumstances of the discovery of the Bone Fragments by misrepresenting and
omitting:  (1) that Ludwick and Madrigal discovered the Bone Fragments by themselves; (2) that
Ludwick and Madrigal discovered the Bone Fragments without any of Defendants or their agents
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present; and (3) that the chain of custody had been broken. 
208. Indeed, Defendants actively participated and intended the fraud upon Beth by
lying to Kolowski about the origin of the Bone Fragments.  See ¶¶ 14, 155. 
209. Kolowski’s contract was with Defendant BGM.   
210. Upon information and belief, Kolowski communicated principally with Defendant
BGM regarding how the Bone Fragments were discovered, but Oxygen participated in those
communications as well.
211. Defendants fraudulently misrepresented and suppressed facts with an intent to
deceive, and thereby induced, Beth into providing her DNA to Defendants for their benefit.
212. Defendants knew, should have known, or recklessly disregarded that their
fraudulent misrepresentations would cause Beth severe emotional distress.
213. As a direct and proximate cause of Defendants’ fraudulent misrepresentations to
Beth, Beth has suffered severe emotional distress and corresponding physical distress. 
214. Defendants demonstrated their knowledge when their paid participants uttered,
among other things, the following statements and images indicating their awareness of the effect
Defendants’ actions would have on Beth:
a. “He knows his daughter his dead.  But to hear about what happened to her remains and what they did to her afterwards – no parent should have to hear that.” 
b. “I’m not gonna get my family involved and get their hopes up high and knowing that we’re gonna have to develop this thing for months, and I finally said, T.J, if anyone takes the fall, it’s going to be me.” 
c. “We’ve had so many disappointments throughout the past and you are always thinking ‘is this the great big con?’ . . . My ex-wife, Natalee’s mother, Beth [does not know that we are going to New Orleans to investigate this lead.]  You just can’t put somebody through anticipation, anxiety, I realize now that I should have been a lot more protective of her emotions and all of our families’ emotion throughout this process, and I didn’t want to put her through that.”   
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215. Defendants fraudulently misrepresented the circumstances of their discovery of
the Bone Fragments and obtained Beth’s DNA with the intent to cause, or with reckless
disregard of a substantial probability of causing, Beth to suffer severe emotional distress. 
216. Defendants’ misconduct was willful and demonstrates that entire want of care that
raises a presumption of conscious indifference to consequences. 
COUNT TWO:  TORT OF OUTRAGE 
217. Beth reasserts and incorporates by reference paragraphs 2-19, 36-49, and 57-150
of this Complaint as if fully restated herein.
218. Defendants’ actions in creating and publishing the Series – individually and in
combination – are extreme, outrageous, and are not to be tolerated in a decent and civilized
society.
219. Defendants’ actions in creating and publishing the Series – individually and in
combination – caused Beth severe emotional distress, and Defendants knew or should have
known that Beth would so suffer.
220. Defendants claimed directly to Beth and in their Series that they found human
remains, but they were pig bones from the Pig Skull.
Obtaining Beth’s DNA Under False Pretenses
221. As set forth in Count One, for which paragraphs 152 through 216 are expressly
incorporated herein by reference because they lay the foundation for this particular claim for
emotional distress, Defendants consciously manipulated Beth into providing her DNA by
misrepresenting and omitting facts which, if truthfully disclosed, would have resulted in Beth’s
refusal to provide her DNA. 
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Defendants’ Publications Directly to Beth 
222. Defendants, by and through their agents Dave and Kolowski, made a number of
factual, false, and outrageous statements directly to Beth regarding their purported discovery of
human remains believed to be Natalee.
223. During the August 10, 2017, call, Defendants conveyed, among others, the
following factual, false, and outrageous statements either verbatim or in substance regarding
Natalee’s death and the desecration of her remains: 
a. Human remains were spontaneously discovered in Aruba; 
b. Natalee’s remains may have been spontaneously discovered in a grave site in Aruba; 
c. The spontaneously discovered human remains were “female”; and 
d. That what was discovered were “remains” rather than the Bone Fragments. 
224. The Bone Fragments were pig bones from the Pig Skull, not human – and
certainly not female – remains. 
Defendants’ Publication of the Series 
225. Defendants made an array of factual, false, and outrageous statements during the
course of their six-episode Series regarding the manner in which Natalee allegedly died and the
manner in which her corpse was allegedly desecrated. 
226. Defendants knew at the time they published such statements that they were false
and/or published such statements with reckless disregard for truth or falsity. 
227. During the Series, Defendants made, among others, the following factual, false,
and outrageous statements either verbatim or in substance regarding Natalee’s death and the
desecration of her remains: 
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a. “Natalee started foaming at the mouth ‘cause she was overdosing” after Joran van der Sloot drugged her. 
b. Joran van der Sloot gave Natalee a date rape drug. 
c. Natalee “choked on her own vomit.” 
d. Joran van der Sloot’s father obtained a burlap bag to put Natalee’s dead body in but she would not fit, so van der Sloot “stomp[ed] on her legs, crack[ed] her legs, [and] puts her in the burlap and actually folders her over . . .” 
e. van der Sloot “dismembered” Natalee’s body before burying her initially to fit her in the burlap bag. 
f. van der Sloot buried Natalee in a national park. 
g. Joran van der Sloot told Ludwick that he would pay Ludwick “$1,500 to move the body, I’m gonna write up a little map and tell you where it’s at, so John goes the following night and he said it was only like three feet down, and [Ludwick] finally seen the little head of the burlap, I pulled it out and it had this decaying smell.” 
h. Ludwick puts Natalee’s body in the trunk of the car and “all the bones were just brownish, moldy and there was two inches of just black lard from the body when it decays on the bottom of the burlap, and her hair was there, and all the bones.” 
i. Reenactments of Natalee’s body being dug up in a burlap bag. 
j. “van der Sloot had a connection that his dad had at the morgue, so then John goes ahead and takes it and the body got cremated, everything in there got cremated, so he picks up all the ashes, he goes back to van der Sloot, they go, and it was low tide, and they just spread it.” 
k. “There should be DNA at the grave, at the national forest, and the aunt’s
car.” 
l. “I can take you to where I got the remains, but it’s not really in the national park.  It’s [the burial site] up at the top of a mountain, like not a mountain, a really big hill there that’s almost like a mountain, like houses are going all the way up this steep hill, the road just eventually dead ends, and it’s like a cul-de-sac where you can turn around.  But if you walk pas the cul-de-sac, there’s like a little path that takes you back in the desert where there’s cactuses and brush trees and sh** like that, and the second clearing of Mesquite tress to duck under and then you’re gonna see a freaking opening and then you’re gonna see a bunch of cactuses grouped together.  That’s where the f***ing sh** was hidden.  It’s actually only like a ten minute walk from my aunt’s house.” 
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m. Joran said “I’ll give you a good amount of money if you do something for me.  It was like $1,500.”   
n. Ludwick went and “dug the body up” because he “needed the money.” 
o. The body “stayed in the trunk until the next day.” 
p. Joran van der Sloot’s dad helped Joran dispose of the body. 
q. “Once you dug it [the body] up, if you open the burlap, yeah you’re gonna have a musty odor of death.” 
r. Joran van der Sloot “went to his house and dug the dog up, he took the bones out, put the dog bones on top.” 
s. Ludwick “got it [the body] cremated and then brought it back.” 
t. At the crematory, Ludwick “went in there with $200 cash and said ‘this dog means a lot to me and freaking I don’t want anyone to be the last one to touch it except me.  If I give you $200 can I push it in there myself?’” 
u. “It’s not like we paid to get an urn made.  I mean, they just put [the ashes] in a big plastic bag.”   
v. It was a lot of ashes “because it was combined with the dog.” 
w. “It’s called desecration of human remains.” 
x. “You coulda thrown it [the ashes] in the ocean.  You coulda flushed it down the toilet.  I don’t give a sh**.” 
y. Video of Defendants, Madrigal, and Ludwick repeatedly searching for Natalee’s remains, with a cadaver dog and Aruban authorities. 
z. Although van der Sloot did not expressly state he “roofied” Natalee, he told Ludwick that “the combination of things [drugs] that [Natalee] was on, if they think we had sex and stuff, and they tested her, it could make it look like he tried to rape her.” 
aa. Joran van der Sloot “never said Paulus’s name, but he implied it was his father.” 
bb. Joran said “Paulus came and helped him figure out how to get rid of evidence.” 
cc. Joran said “his dad helped him cover it up . . . his dad got everything disposed of.  That before sunrise, he . . . there’s a cul-de-sac there, that uh, on the top of a
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hill, that it’s desert area, cactuses, and thorn bushes, and nobody goes up there.  The only house in view wouldn’t be able to stumble upon them, but it’s kind of like a mountain of boulders, not a mountain, but probably like 10, about 10-12 feet tall, and shaped kind of like this [motioning] with big boulders.” 
dd. Joran “knew I was heavily hooked on heroin at the time and I didn’t have the resources to keep it up daily.  So he was saying ‘I’ll give you $1,500 for your help.’” 
ee. Ludwick went by himself, without Joran van der Sloot, “under his instruction” to “dig the remains up.” 
ff. Joran van der Sloot went with Ludwick to “dig the remains up.” 
gg. Ludwick and van der Sloot went out to dig up Natalee’s remains “right at sunrise, like barely able to see.” 
hh. “The burlap sack was wrapped in a tarp, so it was kind of keeping stuff from seeping out, basically.” 
ii. The burlap sack had “a very nasty looking like blackish, brown, dried matter.” 
jj. “Originally he [van der Sloot] discussed getting it cremated, but that time it wasn’t legal but apparently some places would do it for pets.” 
kk. “The idea was to crush everything [Natalee’s skeleton] to the point where it was not recognizable as arm bones or skull or anything like that.” 
ll. “The only thing that got burnt was the skull to burn the hair fibers; it was doused in gasoline in a fire pit in a cave.” 
mm. The cave “was about 150 yards right of my aunt’s property.” 
nn. Ludwick and van der Sloot “pummeled [Natalee’s body] throughout a few hours.” 
oo. “We paid a local fisherman to borrow his boat for the night” to dispose of Natalee’s remains.” 
pp. “I feel bad that if I had the opportunity for [Beth and Dave Holloway] to recover the remains that I let that slip through the cracks.  Now they’re never going to be able to bury her.  I was obsessed with my friendship at the time and I was under the influence of heroin.”   
qq. Video of Ludwick and Madrigal allegedly uncovering Natalee’s remains. 
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rr. Video of the Bone Fragments themselves. 
ss. “This is Natalee’s . . . part of her remains.” 
tt. Ludwick and van der Sloot “broke everything [Natalee’s skeleton] up over there [Ludwick’s aunt’s house] and then they both went and they buried your daughter’s bones in the pet cemetery where the rest of her remains are at.” 
uu. “After [Ludwick] and Joran crushed up the bones, they put them in a box along with dog bones, mixed them together, buried them in a pet cemetery, [and] John held back a few pieces as a trophy so to speak.” 
228.  Defendants’ conduct was further outrageous in that they published to Beth and
their viewers that the Series was an “unscripted,” “true crime” “documentary” of a “real time
investigation.”   
229. In truth, as set forth above, Defendants’ Series was preconceived and scripted.
230. In truth, Defendants’ Series found pig bones from the Pig Skull, not human
remains.
231. Accordingly, Beth was forced to watch a six-part Series, hanging on every word,
believing it to be real, when in fact the Series was a farce. 
232. Defendants’ conduct was further outrageous in that Defendants concluded their
Series without disclosing the results of the DNA testing on the Bone Fragments.
233. Defendants conduct was further outrageous in that Defendants contradicted the
DNA results that they already had in their possession prior to the conclusion of their Series. 
Oxygen’s Publication of the Articles 
234. Between August 16, 2017, and September 21, 2017, Defendants published at least
seven articles containing false and outrageous statements describing the manner of Natalee’s
death and the alleged desecration of her corpse. 
235. After discovering the existence of Defendants’ Series, Beth became extremely
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hopeful of discovering Natalee and began following Oxygen, its Series, and its media
publications closely.
Article 1
236. On August 16, 2017, Oxygen published a false and outrageous article entitled:
NATALEE HOLLOWAY’S DAD REVEALS INVESTIGATORS HAVE UNCOVERED HUMAN REMAINS IN NEW INTERVIEW 
237. A true and correct copy of the August 16, 2017, article published to Oxygen.com
is attached hereto as Exhibit 1 and incorporated herein by reference (“Article 1”).
238. Publication of Article 1 and the following false statements and images contained
therein constituted extreme and outrageous conduct:
a. Article 1 linked to a marketing video for the Series stating, among other things, that “the body was right here” and showing images of a body in a burlap sack being exhumed. 
b. “. . . human remains have been found.”   
c. “The informant’s friend was friends with suspect Joran van der Sloot, and new information led them to a home where human remains were dug up.  The remains were tested, and they tested positive for human remains.  It’s not yet clear who the remains belong to, however.”   
d. “In the new Oxygen crime series, ‘The Disappearance of Natalee Holloway,’ premiering Saturday, August 19 at 7pm ET/PT, viewers will follow Dave and T.J. Ward . . . in the latest and, perhaps, final chapter of the decade-long pursuit to uncover what really happened to Natalee.  The series reveals what could be the most credible lead to date:  a first-hand account from a man who claims to know the whereabouts of his daughter’s remains. 
Article 2
239. On August 21, 2017, Oxygen published a false and outrageous article entitled:
4 CRUCIAL DETAILS TO KNOW ABOUT THE NEW LEAD IN THE NATALEE HOLLOWAY CASE 
240. A true and correct copy of the August 21, 2017, article published to Oxygen.com
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is attached hereto as Exhibit 2 and incorporated herein by reference (“Article 2”).
241. Publication of Article 2 and the following false statements and images contained
therein constituted extreme and outrageous conduct:
a. “Joran van der Sloot allegedly paid him [Ludwick] $1,500 to get rid of the
body.” 
b. “. . . Van der Sloot reached out to the lead, asking him to help get rid of Holloway’s dead body.” 
c. “. . . Joran offered to give him $1,500 to help dig up the body in Aruba’s national forest and dispose of the remains.” 
d. “He believes Natalee overdosed.” 
e. “Gabriel also alleges in the first episode of the docuseries that the new lead revealed how Natalee really died.  According to the new account, Van der Sloot had given her a drink that may have contained drugs before taking her to the beach.  While on the beach, Natalee allegedly began foaming at the mouth and choking on her own vomit.  When she died, Van der Sloot called his dad to ask for help disposing of the body.”   
Article 3
242. On August 24, 2017, Oxygen published a false and outrageous article entitled:
DNA TESTING PROVES BONES FROM NATALEE HOLLOWAY SEARCH ARE FROM A SINGLE HUMAN OF CAUCASION, EUROPEAN DESCENT 
243. A true and correct copy of the August 24, 2017, article published to Oxygen.com
is attached hereto as Exhibit 3 and incorporated herein by reference (“Article 3”).
244. Publication of Article 3 and the following false statements and images contained
therein constituted extreme and outrageous conduct:
a. “Forensic scientist tells Oxygen.com that testing can’t reveal gender, but a conclusive answer is expected sometime in September.” 
b. “At least one of the bone fragments discovered is ‘from a single individual,’ Kolowski, who is pictured below, tells Oxygen.com.  ‘They are human, and they are of Caucasian, European descent.’  Natalee, who was declared legally dead in 2012, was also Caucasian and of European descent.” 
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Article 4
245. On September 2, 2017, Oxygen published a false and outrageous article entitled:
FRIEND OF JORAN VAN DER SLOOT SAYS HE WAS PAID TO DIG UP NATALEE HOLLOWAY’S REMAINS AND CREMATE THEM 
246. A true and correct copy of the September 2, 2017, article published to
Oxygen.com is attached hereto as Exhibit 4 and incorporated herein by reference (“Article 4”).
247. Publication of Article 4 and the following false statements and images contained
therein constituted extreme and outrageous conduct:
a. “No body or remains have ever been found, but a sting operation in Episode 3 of the show reveals shocking footage that could lead to a break in the case.” 
b. “JORAN VAN DER SLOOT’S FRIEND CLAIMS HE WAS PAID $1,500 TO DIG UP NATALIE’S [sic] REMAINS AND CREMATE THEM” 
c. “. . . John Ludwick told [Madrigal] he was paid $1,500 to dig up Natalee’s remains and have them cremated.  ‘I can take you to where I . . . I got the remains,’ says John during the sting operation on episode 3.  John then describes in great detail that Natalee had been buried up a steep hill and past a cul-de-sac near a bunch of cactuses in the desert.  ‘That’s where the f***ing shit was hidden,’ he said.”   
d. “Asked if the body smelled after he dug it up, John answered:  ‘Yeah once you dug it up, if you opened the burlap, you’re going to have the musty odor of death.’  John also claimed Joran put dog bones on top of Natalee’s remains, presumably to throw off future investigations, before John took Natalee’s remains to a crematorium.” 
e. “‘I went in there with $200 cash,’ explained John.  ‘And said, ‘this dog means a lot to me and, freakin’, I don’t want anyone to be the last one to touch it except me.  If I give you $200 can I push it in myself?’” 
f. “Asked if he felt remorse, John answered callously that he did not.  ‘It didn’t happen to my kid,’ said John.  ‘Could have thrown it in the ocean, coulda flushed it down the toilet.  I don’t give a shit.’” 
Article 5
248. On September 8, 2017, Oxygen published a false and outrageous article entitled:
MEET THE FORENSIC SCIENTIST WHO’S HELPING IN THE
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SEARCH FOR NATALEE HOLLOWAY’S REMAINS 
249. A true and correct copy of the September 8, 2017, article published to
Oxygen.com is attached hereto as Exhibit 5 and incorporated herein by reference (“Article 5”).
250. Publication of Article 5 and the following false statements and images contained
therein constituted extreme and outrageous conduct:
a. “Dr. Jason Kolowski explains how he traveled to Aruba to help identify potential burial sites and how he’s testing the DNA of discovered bone fragments for a possible match to Natalee Holloway.” 
b. “The show previously showed footage of John Ludwick, a friends of primary suspect Joran van der Sloot, saying he was paid $1,500 to dig up Natalee Holloway’s remains in 2010 and have them cremated.  In the clip above, from episode 4, which airs Saturday at 7/6c and 9/8c, TJ Ward wants to know whether John’s description of the condition of the remains would be accurate for a body that had allegedly been buried in 2005.” 
c. “According to John, a burlap bag contained blonde hair and there was a musty odor.  When he pulled the bag up there was some dark fluid that settled back into the ground.  ‘Everything that is described as far as the disinterment of the remains in 2010 fits with what we would expect for the normal decomposition of a human body, especially in this type of environment and this type of a locale,’ says Dr. Kolowski.” 
d. “As Oxygen.com recently reported, at least one of the four bone fragments that are ultimately discovered through TJ Ward’s investigation on the show came from a single human of Caucasian, European descent—just like Natalee.” 
Article 6
251. On September 16, 2017, Oxygen published a false and outrageous article entitled:
JORAN VAN DER SLOOT’S FRIEND SAYS THEY BURNED NATALEE HOLLOWAY’S SKULL IN A CAVE 
252. A true and correct copy of the September 16, 2017, article published to
Oxygen.com is attached hereto as Exhibit 6 and incorporated herein by reference (“Article 6”).
253. Publication of Article 6 and the following false statements and images contained
therein constituted extreme and outrageous conduct:
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a. “‘The only thing that got burned was the skull to burn the hair fibers,’ says Joran’s friend.  ‘It was doused in gasoline in a fire pit in a cave.’” 
b. “In episode 5 of ‘The Disappearance of Natalee Holloway,’ John Ludwick, who is a friend of Joran Van der Sloot, claims on video that he and Joran burned Natalee’s skull in a cave in Aruba.”   
c. “In the clip above, John has agreed to talk after an informant working with TJ recorded him saying that Joran Van der Sloot paid him $1,500 to dig up Natalee’s body.”   
d. “Asked where he took the remains, John says Joran had initially discussed having them cremated.  While it was illegal to bring in human remains to be cremated, John says that some morgues in Aruba would cremate pets.” 
e. “‘The idea was to crush everything to the point where it wasn’t recognizable as her bones or skull or anything like that,’ says John, explaining that he and Joran spent hours pummeling the bones.” 
f. “Natalee’s skull was also apparently burned in this process.  ‘The only thing that got burned was the skull to burn the hair fibers,’ says John.  ‘It was doused in gasoline in a fire pit in a cave.’” 
g. “Bone fragments discovered during the new investigation by Dave Holloway and TJ Ward are currently in a lab for DNA testing.  The forensic scientist leading the charge, Dr. Jason Kolowski, told Oxygen.com at least one of the bone fragments is from a single individual.  ‘They are human, and they are of Caucasian, European descent,’ he said.  Natalee, who was declared legally dead in 2012, was also Caucasian and of European descent.” 
Article 7
254. On September 21, 2017, Oxygen published a false and outrageous article entitled:
THE LATEST ON THE NATALEE HOLLOWAY DNA TESTING 
255. A true and correct copy of the September 21, 2017, article published to
Oxygen.com is attached hereto as Exhibit 7 and incorporated herein by reference (“Article 7”).
256. Publication of Article 7 and the following false statements and images contained
therein constituted extreme and outrageous conduct:
a. “These bone fragments were discovered as part of an investigation being chronicled on Oxygen’s ‘The Disappearance of Natalee Holloway.’” 
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b. Images of the alleged bone fragments belonging to Natalee Holloway. 
c. “Pictured are four bone fragments currently being tested for a possible match to Natalee Holloway . . .” 
d. “As Oxygen.com recently reported, at least one of the bone fragments discovered through an investigation chronicled on ‘The Disappearance of Natalee Holloway’ came from a single human of Caucasian, European descent.” 
e. “The bone fragments were recently discovered in Aruba during an 18month investigation conducted by Natalee’s father, Dave Holloway, and his private investigator, TJ Ward.  John Ludwick, a friend of longtime suspect Joran van der Sloot, claimed he was paid $1,500 in 2010 to dig up Natalee Holloway’s remains and have them cremated.  In a disturbing interview with TJ Ward, John claimed that he and Joran pummeled the bones for hours and burned Natalee Holloway’s skull in a cave before he took them to a morgue.” 
f. “‘The idea was to crush everything to the point where it wasn’t recognizable as her bones or skull or anything like that,’ said John, explaining that it was illegal to bring human remains to a crematorium but not those of a pet.  John said that Joran mixed in dog bones with Natalee’s remains.  John then took them to a morgue and paid someone $200 cash to allow him to cremate what he claimed was his beloved pet.  John also told TJ Ward that he and Joran paid a fisherman to borrow his boat and then spread the ashes at sea.” g. “‘Beth’s would be exactly the same as Natalee’s [DNA] or any of Beth’s other children,’ explains Dr. Jason Kolowski.  Final results of the testing should be completed by October 6, at the latest.  If any of the bone fragments turn out to match Beth’s mitochondrial DNA, the 12-year search for Natalee’s remains will be over.” 
257. Articles 1 through 7 are collectively referred to as the “Articles.” 
Falsity
258. Defendants’ publications in their Series and in Oxygen’s Articles (hereinafter,
“Defendants’ Publications”) were false.
259. The statements in Defendants’ Publications are false because they never
recovered human remains and never had a reasonable basis to claim to Beth or in their Series that
they had recovered human remains.  Rather, Defendants recovered pig bones.
260. The statements in Defendants’ Publications are false because Defendants never
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possessed a DNA sample from which they could “match” the Bone Fragments to Natalee. 
Mitochondrial DNA simply cannot do that.  It can exclude or include, but it cannot match.
261. The statements in Defendants’ Publications are false because whether Natalee is
alive or dead is unknown.
262. The statements in Defendants’ Publications are false because if Natalee is dead,
the location of her remains is unknown.
263. The statements in Defendants’ Publications are false because Defendants did not
find Natalee’s remains.
264. The statements in Defendants’ Publications are false because the manner in which
Natalee died, if she died, is unknown.
265. The statements in Defendants’ Publications are false because whether Natalee’s
body, if she died, was cremated, buried, or otherwise disposed of is unknown. 
266. The statements in Defendants’ Publications are false because where Natalee was
buried, if she was buried, is unknown. 
267. The statements in Defendants’ Publications are false because whether Natalee’s
body has ever been exhumed, if she died, is unknown.
268. The statements in Defendants’ Publications are false because whether Natalee’s
corpse, if she died, has ever been desecrated is unknown. 
269. The statements in Defendants’ Publications are false because the Bone Fragments
did not belong to Natalee. 
270. The statements in Defendants’ Publications are false because Defendants could
not prove through DNA analysis whether the Bone Fragments belonged to Natalee, as the DNA
samples obtained from the Bone Fragments were suitable for “exclusion purposes only.” 
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271. The fact that what happened to Natalee remains, to a large extent, unknown, does
not mean that Defendants’ Publications are not false.  Rather, if Defendants’ Publications were
true, what happened to Natalee would no longer be unknown.
272. Moreover, it is known that Defendants did not have in their possession human
remains as they claimed to Beth and in the Series, and there therefore exists a substantial
probability that each of Defendants’ claims is false.  The Series did not find Natalee nor reveal
any new evidence as to what happened to Natalee. 
Actual Malice
273. Defendants’ Publications were made with actual malice in that Defendants
knowingly and recklessly made numerous factual, false, and outrageous statements regarding
their purported discovery of Natalee’s remains, the purported manner in which Natalee died, the
purported resting place from which Natalee was purportedly exhumed, and the purported heinous
means by which Natalee’s corpse was desecrated. 
274. Defendants’ Publications were made with actual knowledge of falsity or with
reckless disregard for truth or falsity. 
275. Defendants knew prior to publishing Defendants’ Publications that their Series
was scripted, that the discovery of the purported remains was preconceived, and that the Series
therefore was not an “unscripted” “true-crime” “documentary.” 
276. Defendants knew or recklessly disregarded prior to publishing Defendants’
Publications that they had not discovered any human remains, much less Natalee’s remains.
277. Defendants were told by Aruban authorities that the Bone Fragments were animal
bones, and yet Defendants declared that the Bone Fragments were human via a test that was
incapable of doing so and with Bone Fragments known have been handled by Ludwick.
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278. Defendants knew or recklessly disregarded prior to publishing Defendants’
Publications that they had not discovered Natalee’s remains. 
279. Defendants knew prior to publishing Defendants’ Publications that Natalee’s
death was not confirmed.
280. Defendants knew prior to publishing Defendants’ Publications that the manner in
which Natalee died, if she is dead, is unknown.
281. Defendants knew prior to publishing Defendants’ Publications that the location of
Natalee’s remains, if she is dead, is unknown. 
282. Defendants knew prior to publishing Defendants’ Publications that the manner in
which Natalee’s body was disposed of, if she is dead, is unknown.
283. In publishing Defendants’ Publications, Defendants knowingly relied upon
sources known to them to be unreliable, lacking credibility, and untrustworthy. 
284. In publishing Defendants’ Publications, Defendants knowingly relied upon
sources known to them to be unreliable, lacking credibility, and untrustworthy without obtaining
any independent verification or corroboration of the statements those sources made.
285. In particular, Defendants relied upon Madrigal and Ludwick as their key sources
for Defendants’ Publications. 
286. Defendants had clear and compelling reasons to doubt the veracity of Madrigal
and Ludwick and the truth or accuracy of their uncorroborated false factual statements regarding
Natalee’s death, her burial, her exhumation, and the desecration of her remains. 
287. Madrigal and Ludwick’s story changed significantly during the course of the
Series.  The changes included, among others:  (1) how Natalee died; (2) who initially disposed of
Natalee’s body; (3) where Natalee’s body was initially buried; (4) who was present when
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Natalee’s body was exhumed; (5) where Natalee’s body was exhumed; and (6) after being
exhumed, whether Natalee was cremated and tossed in the ocean or her remains buried in a pet
cemetery. 
288. Madrigal and Ludwick were unable to identify where Natalee’s remains were
purported buried during the first, second, and fourth searches with Defendants present.
289. Madrigal and Ludwick purported to discover the Bone Fragments easily and by
themselves without any independent corroboration. 
290. Madrigal and Ludwick were highly unlikely to incriminate themselves in criminal
conspiracies amounting to, among other possible charges, desecration of human remains and
accessory to murder after the fact. 
291. Upon information and belief, Ludwick is a known drug user.   
292. Madrigal possessed no independent knowledge of any events described in the
Series; he “knew” only what Ludwick told him.
293. Upon information and belief, Madrigal and Ludwick were paid by Defendants to
make the outrageous claims on which Defendants relied in Defendants’ Publications. 

to be continued
Logged

I stand with the girl, Natalee Holloway.

"I can look back over the past 10 years and there were no steps wasted, and there are no regrets,'' she said. "I did all I knew to do and I think that gives me greater peace now." "I've lived every parent's worst nightmare and I'm the parent that nobody wants to be," she said.

Beth Holloway, 2015 interview with Greta van Susteren
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ARUBA: It's all about Natalee...we won't give up!


« Reply #1703 on: November 17, 2018, 11:45:03 AM »

Remainder of page 46-51 of Beth's amended complaint

294. Defendants, in fact, harbored serious doubts as to the truth of the information they
chose to publish.  Defendants’ own paid participants in the Series repeatedly expressed their
belief that Madrigal and Ludwick were liars.  For instance, Defendants’ cast stated the following
during the Series:
a. Ludwick’s “story changed and that’s concerning.  Why would he lie about all that stuff; I mean why would he fabricate an entire story.”  
b. Madrigal and Ludwick are “bulls*** artist(s)”  
c. “I know John [Ludwick] has lied a number of times.”  
d. “Maybe he [Ludwick] hasn’t taken us to the right place [grave site].”
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e. “Fully expected that John [Ludwick] planted those bones.”  
f. “If he was involved, is this just little bits and pieces of truth, or is it just a complete lie?  That is the big question mark here.”  
g. “I still can’t prove beyond a reasonable doubt that John is lying.”  
295. Defendants’ knew prior to publishing the Articles that Madrigal and Ludwick
were not reliable sources.  
296. Yet, Defendants failed to conduct a reasonable investigation of the false and
outrageous statements made in Defendants’ Publications prior to publishing same.
297. Indeed, Defendants consciously avoided discovery of the truth by intentionally
delaying the DNA results so that Defendants could publish their Series and Articles with
plausible deniability at the time of publication.  
298. Defendants consciously elected to publish Defendants’ Publications prior to
receiving the Laboratory reports so that they could continue to market their Series to the public
(and to Beth) as discovering Natalee.  
299. As set forth herein, the timeline shows that Defendants consciously avoided
discovery of the truth by intentionally delaying the DNA results so that they could claim
plausible deniability at the time of publication.  
300. Ludwick and Madrigal advised Defendants that they discovered the Bone
Fragments on April 25, 2017.
301. Approximately seven weeks later, Dave and Ward obtained the Bone Fragments
from Aruban Authorities on June 14, 2017.
302. Defendants did not provide the Bone Fragments to their already-retained forensic
expert, Kolowski, until July 6, 2017.
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303. The last episode of the Series was aired September 23, 2017.
304. The last scene involving Kolowski in the Series is dated September 11, 2017.
305. In that scene, Kolowski and Defendants published that a match to Natalee’s
remains is possible.  
306. Defendants knew that they could not match, but only exclude, the Bone
Fragments to Natalee with the DNA sample in their possession.
307. In that scene, Kolowski and Defendants publish that the results of the DNA
testing remain “inconclusive.”  
308. In truth, Defendants already knew prior to the conclusion of the Series that the
DNA analysis showed “the first proof of exclusion.”  
Damages
309. Defendants’ misconduct – through obtaining Beth’s DNA, making false
statements directly to Beth, and publishing false statements via the Series and the Articles –
raised Beth’s desperate hopes for the discovery of her daughter.  
310. Defendants’ misconduct truly made Beth believe that she could finally lay
Natalee to rest.  
311. Defendants’ misconduct forced Beth to wait in hope for nearly two months that
Natalee had been found (August 10, 2017 to October 2, 2017).
312. Defendants forced Beth to hear, watch, and read gruesome and false statements
regarding how Natalee died and how her body was thereafter desecrated.
313. Defendants’ misconduct is extreme, outrageous, and goes beyond all possible
bounds of decency.  
314. Defendants’ misconduct cannot be tolerated in a civilized society.  
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 48 of 51
49  
315. Defendants intended to, knew, should have known, or recklessly disregarded that
their conduct would, cause Beth grievous emotional injury.
316. As a direct and proximate result of Defendants’ misconduct, Beth suffered severe
emotional distress and associated physical distress of such intensity that no person could be
expected to endure it.
317. Defendants’ misconduct was willful, reprehensible, and demonstrates that entire
want of care that raises a presumption of conscious indifference to consequences.  
318. In Beth’s own words, Defendants misconduct “completely and utterly destroyed
me.”
WHEREFORE, Plaintiff, Elizabeth Ann Holloway, demands:
(a) A trial by jury;
(b) That judgment be entered against Defendants, jointly and severally where
applicable, for compensatory damages in an amount not less than $20 Million
($20,000,000.00);
(c) That judgment be entered against Defendants, jointly and severally where
applicable, for punitive damages to punish and deter Defendants in an amount not less
than $30 Million ($30,000,000.00);
(d) That judgment be entered against Defendants for attorneys’ fees, costs,
and interest; and
(e) Such other relief as this Court deems equitable, just, and proper.    
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 49 of 51
50  
Respectfully submitted this 31st day of July, 2018.
    L. LIN WOOD, P.C.  
/s/ L. Lin Wood L. Lin Wood (pro hac vice) lwood@linwoodlaw.com GA State Bar No. 774588 Jonathan D. Grunberg (pro hac vice) jgrunberg@linwoodlaw.com GA State Bar No. 869318 G. Taylor Wilson (pro hac vice) GA State Bar No. 460781 twilson@linwoodlaw.com  
1180 West Peachtree Street Suite 2400 Atlanta, Georgia 30309 404-891-1402 404-506-9111 (fax)  
BEASLEY, ALLEN, CROW, METHVIN, PORTIS & MILES, P.C.  
C. Elizabeth Littell Courson Lisa.Courson@beasleyallen.com  
218 Commerce Street Montgomery, Alabama 36104 800-898-2034 334-954-7555 (fax)  
Attorneys for Beth Holloway    
Case 2:18-cv-00176-KOB   Document 23   Filed 07/31/18   Page 50 of 51
  
CERTIFICATE OF SERVICE
This is to certify that I have this day electronically filed the foregoing FIRST
AMENDED COMPLAINT FOR DAMAGES via the CM/ECF system, which will
automatically send e-mail notification to the attorneys of record.        
This 31st day of July, 2018.                               /s/ G. Taylor Wilson               G. Taylor Wilson
« Last Edit: November 17, 2018, 11:46:46 AM by texasmom » Logged

I stand with the girl, Natalee Holloway.

"I can look back over the past 10 years and there were no steps wasted, and there are no regrets,'' she said. "I did all I knew to do and I think that gives me greater peace now." "I've lived every parent's worst nightmare and I'm the parent that nobody wants to be," she said.

Beth Holloway, 2015 interview with Greta van Susteren
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ARUBA: It's all about Natalee...we won't give up!


« Reply #1704 on: November 17, 2018, 12:36:02 PM »

They've been trying to get Beth's case dismissed and if not dismissed, delayed, still trying...  
I'm downloading some of the documents to read when I get a chance this weekend.  

Quote
https://abc3340.com/news/local/mother-of-natalee-holloway-asks-judge-to-reject-oxygens-motion-to-dismiss-lawsuit

Natalee Holloway's mother asks judge to reject Oxygen's motion to dismiss lawsuit
by Stephen GallienTuesday, May 8th 2018

FILE - In this June 8, 2010, file photo, Beth Holloway, mother of Natalee Holloway, speaks during the opening of the Natalee Holloway Resource Center (NHRC) at the National Museum of Crime & Punishment in Washington. Beth Holloway said on NBC's "Today" show Monday, August, 29, 2016, that justice hasn't been served in her daughter's death. (AP Photo/Pablo Martinez Monsivais, File)

The mother of Natalee Holloway wants a federal judge to reject a media company's motion to dismiss her federal lawsuit.

Elizabeth Holloway's response to the dismissal motion by Oxygen Media claims the alleged conduct was fraudulent and outrageous and has no place in a civil society.

Holloway filed a $35 million dollar lawsuit against Oxygen Media over the six part series "The Disappearance of Natalee Holloway."

Her lawsuit claims the series contained gruesome depictions of Natalee's death and that the defendants obtained Elizabeth Holloway's DNA under false pretenses.

Oxygen Media claimed first amendment protection in asking the judge to dismiss the lawsuit.

https://ecf.alnd.uscourts.gov/cgi-bin/DktRpt.pl?73994454682656-L_1_0-1

U.S. District Court
Northern District of Alabama (Southern)
CIVIL DOCKET FOR CASE #: 2:18-cv-00176-KOB

Holloway v. Oxygen Media LLC et al
Assigned to: Chief Judge Karon O Bowdre
Demand: $999,000
Cause: 28:1332 Diversity-Personal Injury   
Date Filed: 02/02/2018
Jury Demand: Plaintiff
Nature of Suit: 360 P.I.: Other
Jurisdiction: Diversity
Plaintiff
Elizabeth Ann Holloway   represented by   C Elizabeth Littell Courson
PO Box 242606
Montgomery, AL 36124
334-649-0076
Email: Lisa.Courson@BeasleyAllen.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

L Linn Wood
L LIN WOOD PC
1180 West Peachtree Street
Suite 2040
Atlanta, GA 30309
404-891-1402
Fax: 404-506-9111
Email: lwood@linwoodlaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

G Taylor Wilson
L. LIN WOOD PC
1180 West Peachtree Street, Suite 2040
Atlanta, GA 30309
678-365-4107
Fax: 404-506-9111
Email: twilson@linwoodlaw.com
PRO HAC VICE
ATTORNEY TO BE NOTICED

Jonathan D Grunberg
L LIN WOOD PC
1180 W Peachtree St. Suite 2400
Atlanta, GA 30309
404-891-1402
Fax: 404-506-9111
Email: jgrunberg@linwoodlaw.com
ATTORNEY TO BE NOTICED

V.
Defendant
Oxygen Media LLC   represented by   John G Thompson , Jr
LIGHTFOOT FRANKLIN & WHITE LLC
400 20th Street North
Birmingham, AL 35203
205-581-0700
Fax: 205-581-0799
Email: jthompson@lightfootlaw.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Cameron Altman Stracher
CAMERON STRACHER
4 N. Pasture Rd.
Westport, CT 06880
203-222-7169
Fax: 646-810-3089
Email: cam@stracherlaw.com
ATTORNEY TO BE NOTICED

Harlan Irby Prater , IV
LIGHTFOOT FRANKLIN & WHITE LLC
400 20th Street North
Birmingham, AL 35203
205-581-0700
Fax: 205-581-0799
Email: hprater@lightfootlaw.com
ATTORNEY TO BE NOTICED

Jeffrey P Doss
LIGHTFOOT FRANKLIN & WHITE LLC
400 20th Street North
Birmingham, AL 35203
205-581-0700
Fax: 205-380-9346
Email: jdoss@lightfootlaw.com
ATTORNEY TO BE NOTICED
Defendant
Brian Graden Media LLC   represented by   John G Thompson , Jr
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Cameron Altman Stracher
(See above for address)
ATTORNEY TO BE NOTICED

Harlan Irby Prater , IV
(See above for address)
ATTORNEY TO BE NOTICED

Jeffrey P Doss
(See above for address)
ATTORNEY TO BE NOTICED

Date Filed   #   Docket Text
02/02/2018   1    COMPLAINT against Brian Graden Media LLC, Oxygen Media LLC, filed by Elizabeth Ann Holloway. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7)(SAC ) (Entered: 02/02/2018)
02/05/2018       Filing Fee: Filing fee $ 400, rALND receipt#: B4601086509/ eceipt_number 1126-3020482. related document 1 COMPLAINT against Brian Graden Media LLC, Oxygen Media LLC, filed by Elizabeth Ann Holloway. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7)(SAC ). (Littell Courson, C) Modified on 2/6/2018 (SAC, ). (Entered: 02/05/2018)
02/09/2018   2    Summons Issued as to Brian Graden Media LLC & Oxygen Media LLC; placed in SASE (FedEx) to Plintiff's attorney. (SAC ) (Entered: 02/09/2018)
02/12/2018   3    MOTION for Leave to Appear Pro Hac Vice of G. Taylor Wilson by Elizabeth Ann Holloway. (Wilson, G) (Entered: 02/12/2018)
02/12/2018   4    MOTION for Leave to Appear Pro Hac Vice of Jonathan D. Grunberg by Elizabeth Ann Holloway. (Grunberg, Jonathan) (Entered: 02/12/2018)
02/12/2018       PHV Fee paid: $ 50, ALND receipt#: B4601086756/ receipt number 1126-3025892. (Wilson, G) Modified on 2/13/2018 (SAC, ). (Entered: 02/12/2018)
02/12/2018       PHV Fee paid: $ 50, ALND Receipt#: B4601086757/ receipt number 1126-3025895. (Grunberg, Jonathan) Modified on 2/13/2018 (SAC, ). (Entered: 02/12/2018)
02/12/2018   5    MOTION for Leave to Appear Pro Hac Vice of L. Lin Wood by Elizabeth Ann Holloway. (Wood, L) (Entered: 02/12/2018)
02/12/2018       PHV Fee paid: $ 50, ALND receipt#: B4601086758/ receipt number 1126-3025900. (Wood, L) Modified on 2/13/2018 (SAC, ). (Entered: 02/12/2018)
02/13/2018   6    TEXT ORDER granting 3 Motion to Admit G. Taylor Wilson Pro Hac Vice. The court advises counsel that it may require at least one attorney for each party to be physically present at every hearing and status conference. Signed by Chief Judge Karon O Bowdre on 2/13/18. (MMW) (Entered: 02/13/2018)
02/13/2018   7    TEXT ORDER granting 4 Motion to Admit Jonathan D. Grunberg Pro Hac Vice. The court advises counsel that it may require at least one attorney for each party to be physically present at every hearing and status conference. Signed by Chief Judge Karon O Bowdre on 2/13/18. (MMW) (Entered: 02/13/2018)
02/13/2018   8    ORDER granting 5 Motion to Admit L. Lin Wood Pro Hac Vice. The court advises counsel that it may require at least one attorney for each party to be physically present at every hearing and status conference. Signed by Chief Judge Karon O Bowdre on 2/13/18. (MMW) (Entered: 02/13/2018)
02/20/2018   9    NOTICE of Appearance by John G Thompson, Jr on behalf of Brian Graden Media LLC, Oxygen Media LLC (Thompson, John) (Entered: 02/20/2018)
02/20/2018   10    REQUEST FOR WAIVER of Service sent to Oxygen Media, LLC on 02/12/2018 by Oxygen Media LLC. Waiver of Service due by 4/13/2018. (Thompson, John) (Entered: 02/20/2018)
02/20/2018   11    REQUEST FOR WAIVER of Service sent to Brian Graden Media, LLC on 02/12/2018 by Brian Graden Media LLC. Waiver of Service due by 4/13/2018. (Thompson, John) (Entered: 02/20/2018)
02/20/2018   12    NOTICE of Appearance by Harlan Irby Prater, IV on behalf of Brian Graden Media LLC, Oxygen Media LLC (Prater, Harlan) (Entered: 02/20/2018)
02/20/2018   13    NOTICE of Appearance by Jeffrey P Doss on behalf of Brian Graden Media LLC, Oxygen Media LLC (Doss, Jeffrey) (Entered: 02/20/2018)
04/13/2018   14    MOTION to Dismiss by Brian Graden Media LLC, Oxygen Media LLC. (Attachments: # 1 Exhibit A)(Prater, Harlan) (Entered: 04/13/2018)
04/16/2018   15    ORDER SETTING BRIEFING SCHEDULE re 14 Defendant's Motion to Dismiss- Plaintiff's response to the motion to dismiss will be due on or before May 7, 2018. Any reply brief, if necessary, will be due on or before May 21, 2018. Signed by Chief Judge Karon O Bowdre on 4/16/18. (SAC ) (Entered: 04/16/2018)
04/16/2018   16    Corporate Disclosure Statement by Brian Graden Media LLC, Oxygen Media LLC. filed by Brian Graden Media LLC, Oxygen Media LLC (Doss, Jeffrey) (Entered: 04/16/2018)
05/07/2018   17    *CERTIFICATE OF INTERESTED PARTIES* Corporate Disclosure Statement by Elizabeth Ann Holloway. filed by Elizabeth Ann Holloway (Wilson, G) Modified on 5/8/2018 (SAC ). (Entered: 05/07/2018)
05/07/2018   18    RESPONSE in Opposition re 14 MOTION to Dismiss filed by Elizabeth Ann Holloway. (Wilson, G) (Entered: 05/07/2018)
05/21/2018   19    REPLY to Response to Motion re 14 MOTION to Dismiss filed by Brian Graden Media LLC, Oxygen Media LLC. (Prater, Harlan) (Entered: 05/21/2018)
05/24/2018   20    MOTION for Leave to Appear Pro Hac Vice by Brian Graden Media LLC, Oxygen Media LLC. (Attachments: # 1 Exhibit A - Certificate of Good Standing)(Stracher, Cameron) (Entered: 05/24/2018)
05/24/2018       PHV Fee paid: $ 50, ALND Receipt#: B4601089236/ receipt number 1126-3094811. (Stracher, Cameron) Modified on 5/25/2018 (SAC ). (Entered: 05/24/2018)
05/25/2018   21    TEXT ORDER granting 20 Motion to Admit Cameron Stracher Pro Hac Vice. The court advises counsel that it may require at least one attorney for each party to be physically present at every hearing and status conference. Signed by Chief Judge Karon O Bowdre on 5/25/2018. (JWD) (Entered: 05/25/2018)
07/31/2018   22    NOTICE by Elizabeth Ann Holloway of Filing First Amended Complaint for Damages (Wilson, G) (Entered: 07/31/2018)
07/31/2018   23    AMENDED COMPLAINT for Damages against All Defendants, filed by Elizabeth Ann Holloway. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7)(Wilson, G) (Entered: 07/31/2018)
08/06/2018   24    MOTION for Extension of Time to Answer or Otherwise Respond to the First Amended Complaint by Brian Graden Media LLC, Oxygen Media LLC. (Prater, Harlan) (Entered: 08/06/2018)
08/07/2018   25    TEXT ORDER: The court GRANTS Defendants' "Unopposed Motion For Extension Of Time To Respond To First Amended Complaint." (Doc. 24). Defendants shall file their responsive pleading on or before August 30, 2018. Defendants' motion to dismiss (doc. 14) is MOOT. Signed by Chief Judge Karon O Bowdre on 8/7/2018. (JWD) (Entered: 08/07/2018)
08/30/2018   26    MOTION to Dismiss by Brian Graden Media LLC, Oxygen Media LLC. (Prater, Harlan) (Entered: 08/30/2018)
09/20/2018   27    RESPONSE in Opposition re 26 MOTION to Dismiss filed by Elizabeth Ann Holloway. (Wilson, G) (Entered: 09/20/2018)
09/26/2018   28    Joint MOTION to Stay (Discovery Deadlines) by Brian Graden Media LLC, Oxygen Media LLC. (Prater, Harlan) (Entered: 09/26/2018)
09/26/2018   29    ORDER DENYING 28 Joint MOTION to Stay Discovery Deadlines. Signed by Chief Judge Karon O Bowdre on 9/26/2018. (JLC) (Entered: 09/26/2018)
09/26/2018   30    TEXT ORDER. The court has received Plaintiff's response to the motion to dismiss (doc. 26), filed on September 20, 2018. (Doc. 27). Any reply brief, if necessary, will be due on or before October 4, 2018. Signed by Chief Judge Karon O Bowdre on 9/26/2018. (MCP) (Entered: 09/26/2018)
10/04/2018   31    REPLY to Response to Motion re 26 MOTION to Dismiss filed by Brian Graden Media LLC, Oxygen Media LLC. (Prater, Harlan) (Entered: 10/04/2018)

Keep fighting, Beth!  Standing with you!  
« Last Edit: November 17, 2018, 12:37:50 PM by texasmom » Logged

I stand with the girl, Natalee Holloway.

"I can look back over the past 10 years and there were no steps wasted, and there are no regrets,'' she said. "I did all I knew to do and I think that gives me greater peace now." "I've lived every parent's worst nightmare and I'm the parent that nobody wants to be," she said.

Beth Holloway, 2015 interview with Greta van Susteren
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« Reply #1705 on: November 18, 2018, 07:20:29 AM »

Thanks for posting TM!  I'm with Beth as well!   
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ARUBA: It's all about Natalee...we won't give up!


« Reply #1706 on: November 18, 2018, 05:34:51 PM »

Thanks for posting TM!  I'm with Beth as well!   

You're welcome, Klaas!     
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I stand with the girl, Natalee Holloway.

"I can look back over the past 10 years and there were no steps wasted, and there are no regrets,'' she said. "I did all I knew to do and I think that gives me greater peace now." "I've lived every parent's worst nightmare and I'm the parent that nobody wants to be," she said.

Beth Holloway, 2015 interview with Greta van Susteren
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« Reply #1707 on: November 20, 2018, 05:02:25 PM »

Thank you Texasmom for posting that. Unbelievable what Beth has to go through.
We stand with Beth.

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ARUBA: It's all about Natalee...we won't give up!


« Reply #1708 on: December 06, 2018, 08:45:56 PM »

Thank you Texasmom for posting that. Unbelievable what Beth has to go through.
We stand with Beth.


You're welcome, Kermit!  Absolutely standing with Beth, every step of the way.   
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I stand with the girl, Natalee Holloway.

"I can look back over the past 10 years and there were no steps wasted, and there are no regrets,'' she said. "I did all I knew to do and I think that gives me greater peace now." "I've lived every parent's worst nightmare and I'm the parent that nobody wants to be," she said.

Beth Holloway, 2015 interview with Greta van Susteren
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ARUBA: It's all about Natalee...we won't give up!


« Reply #1709 on: December 06, 2018, 08:50:22 PM »

Photobucket finally reduced my bail!   Monkey Devil!

So glad I can post some precious pictures of Natalee again!   
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I stand with the girl, Natalee Holloway.

"I can look back over the past 10 years and there were no steps wasted, and there are no regrets,'' she said. "I did all I knew to do and I think that gives me greater peace now." "I've lived every parent's worst nightmare and I'm the parent that nobody wants to be," she said.

Beth Holloway, 2015 interview with Greta van Susteren
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ARUBA: It's all about Natalee...we won't give up!


« Reply #1710 on: December 06, 2018, 08:53:35 PM »

 


Justice for Natalee!

 
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I stand with the girl, Natalee Holloway.

"I can look back over the past 10 years and there were no steps wasted, and there are no regrets,'' she said. "I did all I knew to do and I think that gives me greater peace now." "I've lived every parent's worst nightmare and I'm the parent that nobody wants to be," she said.

Beth Holloway, 2015 interview with Greta van Susteren
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« Reply #1711 on: December 07, 2018, 01:28:10 PM »

Aruba and Van Der Sloots

Scared Monkeys DO NOT forget


 
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"A small body of determined spirits fired by an unquenchable faith in their mission can alter the course of history."

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« Reply #1712 on: December 07, 2018, 01:29:12 PM »

Hey, Aruba! Where is Urine Van Der Sloot?

Hint: It has bars....
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"A small body of determined spirits fired by an unquenchable faith in their mission can alter the course of history."

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« Reply #1713 on: December 07, 2018, 01:31:42 PM »

I stand with Beth

I stand with the TRUTH

 an angelic monkey



P.S. Persistence...We HAVE NOT forgotten

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"A small body of determined spirits fired by an unquenchable faith in their mission can alter the course of history."

MOHANDAS GANDHI
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