2018-01-10 Barley House Memorandum in Support of Contempt

Case: 1:17-cv-02521-DAP Doc #: 25 Filed: 01/10/18 1 of 9.
PageID #: 250
IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF OHIO
EASTERN DIVISION
W.6 Restaurant Group Ltd., d/b/a The Barley ) CASE NO. 1:17-cv-02521
House of Cleveland, et al. )
) JUDGE DAN A. POLSTER
Plaintiffs, )
)
-vs- ) PLAINTIFFS’ BENCH BRIEF IN
) SUPPORT OF SANCTIONS FOR
Richard Bengtson, et al. ) VIOLATION OF PARTIAL
) SETTLEMENT AGREEMENT
Defendants. )
I. Introduction.
Proving why the Temporary Restraining Order obtained by Plaintiffs, W.6 Restaurant
Group Ltd., d/b/a The Barley House of Cleveland (“Barley House”) and Richie Madison
(“Madison”) was absolutely necessary in the first place, it took less than one (1) week for the
self-described “Internet Gangster” FaZe Banks (aka Defendant Richard Bengtson) to rally his
mob on December 19 and incite a new wave of dangerous threats of violence against Plaintiffs,
their employees and their patrons. These threats now include bomb threats. See examples of
threats Plaintiffs have received in Exhibit “A” attached hereto and incorporated by reference.
The police have been informed of the bomb threats. In order to protect the safety and well-being
of its employees, Plaintiff W.6 Restaurant Group Ltd. was forced to close the Barley House on
December 19, just hours after Defendant Bengtson released his inciting video.
Defendant Bengtson’s incitement of his social media mob and the rabid social media
followers of he and Defendant Alissa Violet Butler must stop. Having so blatantly and carelessly
violated the Confidential Partial Settlement Agreement (which is subject to Court enforcement
Case: 1:17-cv-02521-DAP Doc #: 25 Filed: 01/10/18 2 of 9. PageID #: 251
and was negotiated with the assistance of the Court), Defendant Bengtson, Defendant Butler and
their handlers/employer clearly do not appreciate – or worse, do not care – how easily Defendant
Bengtson’s words and videos incite his social media followers.
The video posted by Defendant Bengtson in no way complies with the “letter and spirit”
of the Confidential Partial Settlement Agreement. See Bengtson’s Br. in Response to Order
Setting Contempt Hearing (Doc. 24) at 2, 8. To say so is absurd. Defendant Bengtson must be
held to account for his intentional and/or reckless actions and show cause as to why this Court
should not sanction him and hold him in contempt of court. Plain and simple, nothing short of
sanctions and being held in contempt will restrain Defendant Bengtson and protect the safety of
Plaintiffs and the employees and patrons of the Barley House.
II. Facts.
On December 13, 2017, the Parties, with the Court’s assistance, entered into a
Confidential Partial Settlement Agreement (“Settlement Agreement”) resolving the Defendants’
challenges to the Temporary Restraining Order and the Plaintiffs’ pending Motion for
Preliminary Injunction. The Parties agreed to keep the contents of the Settlement Agreement
confidential.
The purpose of the Settlement Agreement was to remove the First Amendment
implications from this matter, and provide a specific framework for the Parties as to their
statements going forward and the effect of those statements. Within a week, Defendant
Bengtson posted a professionally produced video on behalf of himself and Defendant Butler, the
vast majority of which was admittedly already “in the can” before the Parties even contemplated
the Settlement Agreement. Rather than editing the video to comply with the Settlement
Agreement or create a new compliant video altogether, Defendant Bengtson disregarded the
2
negotiated terms and the judicial process, and posted the video in such a way to incite his and
Defendant Butler’s followers.
Defendant Bengtson’s violations of the parties’ Settlement Agreement are numerous and
self-evident in his video (which is 24 minutes and 33 seconds in length). Plaintiffs have outlined
some of the most egregious litany of violations in Exhibit “B” attached hereto.
III. Law and Analysis.
“A federal court has the inherent power to enforce compliance with its lawful orders.” In
re: Northern Ohio Maritime Asbestos Litigation v. United Fruit Co., No. 1:10-CV-00001, 2016
WL 4533012 at *1 (N.D. Ohio 2010). In Section 8 of the Settlement Agreement, the Parties
expressly agreed that this Court retain jurisdiction to enforce the terms and conditions of the
Agreement. “The purpose of a contempt proceeding is to ‘enforce the message that
court orders and judgments are to be taken seriously.’” Adcor Indus., Inc. v. Bevcorp, LLC, 411
F.Supp.2d 778, 793 (N.D. Ohio 2005), aff'd, 252 Fed. App’x 55 (6th Cir. 2007) (quoting
Electrical Workers Pension Trust Fund v. Gary's Elec. Serv. Co., 340 F.3d 373, 385 (6th
Cir.2003) and NLRB v. Cincinnati Bronze, Inc., 829 F.2d 585, 588 (6th Cir.1987)). Further
quoting Gary’s Elec. Serv. Co.:
When a court seeks to enforce its order or supervise its judgment, one weapon in
its arsenal is contempt of court. See NLRB v. Cincinnati Bronze, Inc., 829 F.2d
585, 588 (6th Cir.1987). Recognizing that the power “to punish for contempts”
should not be used lightly, the Supreme Court has stated that this power “is a
necessary and integral part of the independence of the judiciary, and is absolutely
essential to the performance of the duties imposed on them by law. Without it
they are mere boards of arbitration, whose judgments and decrees would be only
advisory.” Gompers v. Buck's Stove & Range Co., 221 U.S. 418, 450, 31 S.Ct.
492, 55 L.Ed. 797 (1911). Contempt proceedings enforce the message that
court orders and judgments are to be complied with in a prompt
manner. Cincinnati Bronze, 829 F.2d at 590.
Bevcorp, 411 F.Supp.2d at 793 (quoting Gary’s Elec. Serv. Co. at 378-79).
3
“The decision whether to hold a person in contempt is within the trial court's sound
discretion.” Id. (quoting Gary’s Elec. Serv. Co. at 378 and citing (citing Peppers v. Barry, 873
F.2d 967, 968 (6th Cir.1989)). A district court’s decision will only be reversed if the court
“relied upon clearly erroneous findings of fact, improperly applied the governing law, or used an
erroneous legal standard.” Gary’s Elec. Serv. Co. at 378; Gascho v. Glob. Fitness Holdings,
LLC, 875 F.3d 795, 800 (6th Cir.2017).
“The court's discretion includes the power to frame a sanction to fit the
violation.” Bevcorp, 411 F.Supp.2d at 793 (citation omitted). “With respect to civil contempt
proceedings, judicial sanctions . . . may, in a proper case, be employed for either or both of two
purposes; to coerce the defendant into compliance with the court's order, and to compensate the
complainant for losses sustained.” Id. at 794 (quoting Gary’s Elec. Serv. Co. at 378) (internal
citation and alteration removed).
“A complaining party in a civil contempt case must prove by clear and convincing
evidence that the alleged contemnor violated ‘a definite and specific order of the court requiring
him to perform or refrain from performing a particular act or acts with knowledge of the court's
order.’” Id. (quoting Cincinnati Bronze, 829 F.2d at 590) (emphasis in original). When
evaluating the actions of a defendant, the Court may “also consider whether the defendant ‘took
all reasonable steps within [his] power to comply with the court's order.’” Gary’s Elec. Serv. Co.
at 379 (quoting Peppers, 873 F.2d at 969).
In this case, Defendant Bengtson materially breached and violated Section 2 of the
Settlement Agreement. Section 2 provided specific instructions that, with respect to the
Disputed Events of the underlying incident, Defendant Bengtson was specifically limited to
discuss six (6) subject matters. He was given limited leeway in which he could address those
4
specific six (6) subject matters in that he could use his own words. However, the use of his own
words was further limited by the requirement for him to affirmatively take all reasonable steps to
ensure that the video will not incite any hostile or violent reactions toward the Barley House or
its affiliated entities, Richie Madison, or any employees or known patrons of the Barley House or
its affiliated entities. Settlement Agreement at §2.
Defendant Bengtson did not limit the video to the specific six (6) subject matters of the
Disputed Events. Defendant Bengtson did not take all reasonable steps within his power to
ensure the video would not incite any hostile or violent reactions. Defendant Bengtson, on
behalf of himself and Defendant Butler, materially breached and flagrantly exploited the
Settlement Agreement as a vehicle for him to disseminate the video he originally made and
desired to post on or around December 1, 2017 before the TRO was entered against him. Indeed,
the title of the video itself – “I was not allowed to upload this video” – brazenly and
unashamedly reflects Defendant Bengtson’s knowledge that the video does not comport with the
terms and conditions of the Settlement Agreement.
In direct violation of the Settlement Agreement, Defendant Bengtson intentionally and
recklessly littered the video with allegations of wrongdoing on the part of Plaintiffs in order to
incite his followers. For example, he discusses the supposed “lack of help or protection from
Barley at all,” and how Barley House staff supposedly “did nothing throughout the night to help
us. They were mocking us on the way out. They were telling us ‘Get the fuck out of here, we
don’t give a fuck who you are.’ All this crazy shit. We didn’t blast this place for no reason.
Obviously something happened, obviously we felt wronged . . . . I get embarrassed, thrown out,
dragged out by my neck, her family is all there. It was embarrassing for me, I was mad. Alissa
5
got hurt in all of this. And all this has everything to do with Barley.” See video at 10:55 –
11:42.1
Defendant Bengtson’s incitement of violence and harassment did not stop there. As
some of the examples of the more egregious violations of the express terms of the Settlement
Agreement (including his promise to take all reasonable steps to not incite any hostile or violent
reactions to the Barley House), Defendant Bengtson:
 incredibly provides his commentary wherein he “break[s] down what

Barley did wrong” and “the past of Barley, just to support my claims that
this isn’t a perfect establishment, going on to state that “Barley is not right
in this, and I’m going to go into where they went wrong,” inciting his
CloutGang by stating “You guys are probably asking yourself, ‘Well, if
this guy hit Alissa and he doesn’t work for Barley, then what is the
problem? What did they do wrong?’ They did plenty wrong” (3:56 –
4:02; 4:55 – 5:08); and
 specifically identifies Plaintiff Madison by name in a text message

screenshot and details that “my beef with Barley is with what happened in
the basement with [the bouncer] where he grabbed me by my neck,
dragged me up the stairs for no other reason than me waiting in a restricted
area . . . . As I said in my last video, I was allowed to be down there, he
shouldn’t have done this, he mishandled the situation 100%,” he “was
wrong, Barley was wrong. Barley staff, they were wrong, period” (5:09 –
5:51).
The incitement does not just come in verbal form. The video also contains images
designed to incite that cannot be encompassed in a written transcript of the video. See Written
Video Transcript filed as Exhibit 3 to Bengtson’s Br. in Response to Order Setting Contempt
Hearing (Doc. 24-3). For example, when describing Barley House’s response to the altercation
between the Defendants and other Barley House patrons, the video includes on-screen text
suggesting Barley House security pushed Ms. Butler while ignoring the other patrons and on-
1
A copy of the video was available at https://www.youtube.com/watch?v=kr7oKWISbHw&t=1293s and
https://m.youtube.com/watch?feature=youtu.be&v=kr7oKWISbHw until approximately 11:00 am eastern on
December 21, 2017. Up until that point, while the video appeared to be hidden from public view, at least some
people still were able to access and comment on the video. See Exhibit “C” at p.3 attached hereto (“I can't believe
they made him delete this but somehow I'm still watching it???”).
6
screen images of the dictionary definition of “favoritism”. See Video at 13:50-14:12; Video Tr.
at 23:23 – 24:11. The video also inserts internet memes as a way to incite followers. See “Hold
My Beer” Meme inserted at Video at 14:27 – 14:36; Video Tr. at 24:21 – 24:24.
These statements and portions of the video can only be interpreted as a deliberate attempt
by Defendants to incite hostile and violent reactions toward the Barley House, Richie Madison,
and any employees and known patrons of the Barley House. In no way does this comply with
the “letter and spirit” of the Settlement Agreement. See Bengtson’s Br. in Response to Order
Setting Contempt Hearing (Doc. 24) at 2, 8. Defendants must be sanctioned.
IV. Proposed Sanctions.
Defendants must be instructed to remove any and all references to Barley House, its
affiliated entities, its employees (including Plaintiff Madison), and any known patrons from their
social media and must specifically disallow the republishing of the same.
Defendants must compensate Plaintiffs for the damages incurred as a result of the breach
and disregard of the Settlement Agreement, including costs, fees, and attorneys’ fees. Plaintiffs
respectfully request a bifurcated process wherein the Court first issues the sanctions against
Defendants, and then sets the matter for hearing or briefing on damages.
Finally, Plaintiffs respectfully request a significant monetary sanction be issued against
Defendants, which then ostensibly would be passed through to their promoters, handlers, and/or
employers. In less than 12 hours since being rolled out, the video amassed in excess of
1,000,000 views and countless comments. As Defendant Bengtson openly proclaimed, “I’ve
never gotten this many views ever” and it is “December right now” – which “means the CPM is
blasted way up.” The term CPM is a marketing term used to denote the price an advertiser pays
7
for one thousand views of clicks of an advertisement.2 Together with the links in comments to
other websites posted by Defendant Bengtson himself (ostensibly as another revenue stream
designed to maximize his earnings from this video), it stands to reason that the “Internet
Gangster” profited quite handsomely at the expense of the safety and well-being of Plaintiffs and
their employees. To compensate Plaintiffs for their tangible and intangible loss as a result of
this video, in addition to the monetary expenses they have sustained in seeking this relief and lost
revenue suffered by shutting down Barley House, Defendant Bengtson should be required to
disgorge all monies and revenue made in connection with the subject video unless he can show
cause to the contrary.
V. Conclusion.
For each and every reason discussed herein, in order to minimize the irreparable damage
suffered by Plaintiffs as a result of Defendant Bengtson’s latest and most damaging video,
Plaintiffs respectfully request that Defendant Bengtson be appropriately sanctioned for his
conduct and breach of the Settlement Agreement.
Respectfully submitted,
/s/ Christopher B. Congeni

Christopher B. Congeni (#0078160)
Adam D. Fuller (#0076431)
Chad R. Rothschild (#0088122)
BRENNAN, MANNA & DIAMOND, LLC
75 East Market St.
Akron, Ohio 44308
Telephone: 330.253.5060
Facsimile: 330.253.1977
Email: cbcongeni@bmdllc.com
adfuller@bmdllc.com
crothschild@bmdllc.com
2
https://en.wikipedia.org/wiki/Cost_per_mile.
8
/s/ Jeffrey C. Miller

Jeffrey C. Miller (#0068882)
BRENNAN, MANNA & DIAMOND, LLC
200 Public Square, Suite 3270
Cleveland, Ohio 44114
Telephone: 216.658.2155
Facsimile: 216.658.2156
Email: jcmiller@bmdllc.com
Counsel for Plaintiffs
CERTIFICATE OF SERVICE
I hereby certify that on this 10th day of January 2018, a copy of the foregoing was filed
electronically. Notice of this filing will be sent to all parties by operation of the Court’s
electronic filing system. Parties may access this filing through the Court’s system.
/s/ Christopher B. Congeni

Counsel for Plaintiffs
4810-4782-0122, v. 1
9
Case: 1:17-cv-02521-DAP Doc #: 25-1 Filed: 01/10/18 1 of 5. PageID #: 259
EXHIBIT A
EXHIBIT B
 Deviating from the specifically agreed upon subject matters, Bengtson starts by stating he
“finally get[s] to show you guys this video” (0:01 – 0:03) – specifically referring to a
video he originally made and intended to post on or about December 1, 2017. A video
that counsel for Bengtson denied existed in Chambers when asked whether a rough
version of the video existed.
 Instead of honoring the agreed-upon specific subject matters in Section 2(iv)(a)-(f) and
the promise to take all reasonable steps to not incite any hostile or violent reactions to the
Barley House in Section 2, Bengtson issues a wholly unsanctioned diatribe about how the
original video he wanted to post on or about November 28, 2017:
was intended to defend mine and Alissa’s self from the video that Barley
House released. There is a lot of fucked up shit going on in that video,
and trust me I wanted to show you guys ASAP.
I originally planned on uploading this video at the end of November, I

think November 28th, a day, only a day after they posted their video.
Unfortunately, I was not allowed to do so, legally not allowed to do so.
To give you guys a little timeline on what exactly happened, Barley House
uploaded their video in response to the whole situation. I found a lot of
problems in this video, so obviously I planned on responding to this video.
However, I could not because Barley House successfully filed a TRO
against myself and Alissa which prevented us from speaking on the
matter. We were not allowed legally to defend ourselves; we were not
allowed to respond about the night at all. This was a problem, a HUGE
problem because Barley House got a lot of things wrong and they were not
as perfect as they claim to be this night.
In the meantime, while Alissa and I are unable to speak, they put out ads
on YouTube sharing this video, spreading it as far across the Internet as
they could. Again, with mine and Alissa’s inability to defend ourselves or
speak at all about it.
It took so long for this video to come out because the legal process is very
slow. Alissa and I had to fly to Cleveland, we had to pay a lot of money
for flights and lawyers and hotels and all that shit, just so you guys could
see this video, we did it just so you guys could see this video. I was
allowed to post other videos, don’t get me wrong, I could have went on
with my life and pretended like nothing happened but that was a huge
problem for me; that’s just not who I am. More often than not YouTubers
will go about their life, pretend like nothing happened if shit gets too hot.
I could not do that, I could not have anyone thinking that this side of the
story was the only side of the story. I had to share this with you guys, I’m
more excited than anything to just be able to show you guys this. It took
so much time; more work and effort and time and money went into this
video than anything by far on my channel and Alissa’s channel. This was
so hard to get out to you guys.
Washington Post did a pretty interesting article on the matter, and before I
had even seen this, that is exactly how I felt about the matter. They talk
about how my freedom of speech is potentially being violated in all this.
That is exactly how I felt. I had to sit by the sidelines and have a whole
bunch of people think that this happened like the way they said it did when
it didn’t at all happen like that. I was patient, I respected the legal process,
and we finally got it reversed.
But without further ado, enjoy the fucking video [aka the original response
video]”.
(0:32 – 2:37)
Barley House in Section 2, Bengtson specifically implicates Barley House by stating
“everyone involved in the incident between me, Alissa and the Barley House made
mistakes throughout the night, we all could have handled it better,” referencing his prior
video from November 29, 2017 and further claiming that the Disputed Events “didn’t
happen for no reason, obviously something happened” (2:40 – 3:06).
Barley House in Section 2, Bengtson continues to smear Barley House and incite a
response by arguing that Barley House “released their video, it got posted to Reddit, and
a wave of Reddit users came and just started blasting my video, started blasting me on
Twitter and stuff” (3:07 – 3:24).
 Instead of honoring the specifically limited subject matter and talking point in Section
2(iv)(d) and simply stating that Alissa’s mother did not apologize, Bengtson took it
several steps further by claiming Alissa’s mother was “just as mad, if not the most mad
about the situation” (3:47 – 3:50).
Barley House in Section 2, Bengtson incredibly provides his commentary wherein he
“break[s] down what Barley did wrong” and “the past of Barley, just to support my
claims that this isn’t a perfect establishment, going on to state that “Barley is not right in
this, and I’m going to go into where they went wrong,” inciting his CloutGang by stating
“You guys are probably asking yourself, ‘Well, if this guy hit Alissa and he doesn’t work
2
for Barley, then what is the problem? What did they do wrong?’ They did plenty wrong
(3:56 – 4:02; 4:55 – 5:08).
2(iv)(a) that “he did not start any physical altercation,” and the promise to take all
reasonable steps to not incite any hostile or violent reactions to the Barley House and
Plaintiff Richie Madison in Section 2, he instead specifically identifies Madison by name
in a text message screenshot and details that “my beef with Barley is with what happened
in the basement with [the bouncer] where he grabbed me by my neck, dragged me up the
stairs for no other reason than me waiting in a restricted area . . . . As I said in my last
video, I was allowed to be down there, he shouldn’t have done this, he mishandled the
situation 100%,” he “was wrong, Barley was wrong. Barley staff, they were wrong,
period” (5:09 – 5:51).
2(iv)(a) that “he did not start any physical altercation,” and the promise to take all
reasonable steps to not incite any hostile or violent reactions to the Barley House in
Section 2, he goes on to provide a detailed breakdown of, and his response to, security
footage and “poke holes in [Plaintiffs’] story”, in the process again specifically
identifying Madison by name in a text message screenshot (5:52 – 9:20). Bengtson later
continues to provide a detailed breakdown of, and his response to, security footage
almost entirely outside the scope of the agreed-to talking points (11:42 – 17:44), broadly
claiming without limitation or regard for the Settlement Agreement that “this video, this
footage, this narrative, the narrative – its complete bullshit” (17:44 – 17:48).
3
 Disregarding the specifically limited subject matter in Section 2(iv)(a)-(f), Bengtson

accuses the Barley House of having additional security footage, demands the release of
the footage and accuses Barley House of lying. (7:48-8:48).
 Disregarding the specifically limited subject matter in Section 2(iv)(a)-(f), Bengtson tries
to provide context for his statement in a prior video that he “did not have an aggressive
bone in my body,” again trying to provide a response to the Barley House video on an
issue well outside the scope of the Settlement Agreement (10:01 – 10:54).
 Disregarding the specifically limited subject matter in Section 2(iv)(a)-(f) and in violation
of the promise to take all reasonable steps to not incite any hostile or violent reactions to
the Barley House in Section 2, Bengtson discusses the supposed “lack of help or
protection from Barley at all,” and how they supposedly “did nothing throughout the
night to help us. They were mocking us on the way out. They were telling us ‘Get the
fuck out of here, we don’t give a fuck who you are.’ All this crazy shit. We didn’t blast
this place for no reason. Obviously something happened, obviously we felt wronged . . . .
I get embarrassed, thrown out, dragged out by my neck, her family is all there. It was
embarrassing for me, I was mad. Alissa got hurt in all of this. And all this has
everything to do with Barley. * * * Barley is not perfect (10:55 – 11:42).
the Barley House in Section 2,, Bengtson accuses Barley House of “chang[ing] these
minor little to make me look even worse than I am” (13:39 – 13:43).
the Barley House in Section 2, Bengtson accuses “Barley security [of] grab[bing] Alissa
and . . . pushing her this way” and accusing Barley House of favoritism and treating the
Defendants unfairly (13:43 – 14:42).
4
of the provision that “Defendants shall take all reasonable steps to ensure that the above-
described video will not incite any hostile or violent reactions toward . . . known patrons
of the Barley House or its affiliated entities,” Bengtson discusses in great detail the “guy
[and his girlfriend] who hit Alissa” – both of whom are, in fact, known by the Defendants
to be patrons of Barley House (18:00 – 19:06).
the Barley House in Section 2, Bengtson transitions into about two (2) minutes of “last
words” during which he claims that “Barley did shit wrong” (19:10 – 19:11), that he feels
he “is a victim of [Barley’s alleged] misinterpretation of the night” (19:12 – 19:20), and
that the guy and his girlfriend who hit Alissa (i.e. known patrons of Barley House) “are
not victims” (19:20 – 19:22), among other topics designed to incite hostile and violent
reactions in violation of the Settlement Agreement.
the Barley House in Section 2, Bengtson thanks his fans on behalf of himself and Alissa,
claiming “we see all the tweets, we see all the comments, we see all the love, I see all the
likes. I love you guys so much, like you guys mean the world to me, you’re part of our
family” (20:58 to 21:24). It is important to remember that at this time, on or about
December 1, 2017, the “tweets” and “comments” were largely death threats and threats of
violence.
4825-3260-3994, v. 1
5
EXHIBIT C
I was not allowed to upload this video... - YouTube Page 1 of 3
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this breaks my heart fuck barley house ily Banks and Alissa I MADE A SONG..
1 FaZe Banks
2,486,123 views
Angry Chick 3 hours ago

Why is it age-restricted ???
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Lucas Renneflott 3 hours ago

watching when deleted lol
IlianaBlue 3 hours ago

ohmygod These bitches fooled us..i didn't even notice the points you made in this video
in their response vid. Fuck Barley House. #JusticeForBanks
1
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d0wnshift 4 hours ago

Unlisted gang
1
Dave Smith 4 hours ago

Fuck them banks don't waste your time with them hopefully barley place burns down
Crystal
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RiceGum 4 hours ago

I can't believe they made him delete this but somehow I'm still watching it???
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2018-01-10 Barley House Memorandum in Support of Contempt

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2018-01-10 Barley House Memorandum in Support of Contempt

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Case: 1:17-cv-02521-DAP Doc #: 25 Filed: 01/10/18 1 of 9.

IN THE UNITED STATES DISTRICT COURT

Bengtson’s words and videos incite his social media followers.

Plaintiffs and the employees and patrons of the Barley House.

Confidential Partial Settlement Agreement (“Settlement Agreement”) resolving the Defendants’

Defendant Butler’s followers.

III. Law and Analysis.

Agreement. “The purpose of a contempt proceeding is to ‘enforce the message that

quoting Gary’s Elec. Serv. Co.:

LLC, 875 F.3d 795, 800 (6th Cir.2017).

citation and alteration removed).

at 379 (quoting Peppers, 873 F.2d at 969).

its affiliated entities. Settlement Agreement at §2.

terms and conditions of the Settlement Agreement.

In direct violation of the Settlement Agreement, Defendant Bengtson intentionally and

reactions to the Barley House), Defendant Bengtson:

 incredibly provides his commentary wherein he “break[s] down what

 specifically identifies Plaintiff Madison by name in a text message

Setting Contempt Hearing (Doc. 24) at 2, 8. Defendants must be sanctioned.

IV. Proposed Sanctions.

Finally, Plaintiffs respectfully request a significant monetary sanction be issued against

cause to the contrary.

conduct and breach of the Settlement Agreement.

/s/ Christopher B. Congeni

/s/ Jeffrey C. Miller

Counsel for Plaintiffs

/s/ Christopher B. Congeni

I originally planned on uploading this video at the end of November, I

 Disregarding the specifically limited subject matter in Section 2(iv)(a)-(f), Bengtson

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