Logosm.gif (1927 bytes)
navlinks.gif (4688 bytes)
Hruler04.gif (5511 bytes)

Back to Dorothy Brizill main page, Guam SLAPP suit

Complaint for Defamation. . . .
Guam Greyhound, Inc. and John Baldwin v. Dorothy Brizill
August 4, 2006




Dorothy Brizill
Bonnie Cain
Jim Dougherty
Gary Imhoff
Phil Mendelson
Mark David Richards
Sandra Seegars


DCWatch Archives
Council Period 12
Council Period 13
Council Period 14

Election 1998
Election 2000
Election 2002

Election 2004
Election 2006

Government and People
Anacostia Waterfront Corporation
Boards and Com
Campaign Finance
Chief Financial Officer
Chief Management Officer
City Council
Control Board
Corporation Counsel
DC Agenda
Elections and Ethics
Fire Department
FOI Officers
Inspector General
Housing and Community Dev.
Human Services
Mayor's Office
Mental Health
Motor Vehicles
Neighborhood Action
National Capital Revitalization Corp.
Planning and Econ. Dev.
Planning, Office of
Police Department
Property Management
Public Advocate
Public Libraries
Public Schools
Public Service Commission
Public Works
Regional Mobility Panel
Sports and Entertainment Com.
Taxi Commission
Telephone Directory
University of DC
Water and Sewer Administration
Youth Rehabilitation Services
Zoning Commission

Issues in DC Politics

Budget issues
DC Flag
DC General, PBC
Gun issues
Health issues
Housing initiatives
Mayor’s mansion
Public Benefit Corporation
Regional Mobility
Reservation 13
Tax Rev Comm
Term limits repeal
Voting rights, statehood
Williams’s Fundraising Scandals


Appleseed Center
Cardozo Shaw Neigh.Assoc.
Committee of 100
Fed of Citizens Assocs
League of Women Voters
Parents United
Shaw Coalition



What Is DCWatch?

themail archives

Orlean Pacific Plaza, Suite 201 
865 South Marine Corps Drive 
Tamuning Guam 96913
Telephone No.: (671) 646-1272 
Facsimile No.: (671) 646-2203

Attorneys for Plaintiffs


CIVIL CASE NO. CV 0960-06 




YOU ARE HEREBY SUMMONED and REQUIRED to serve upon the Law Offices of Richard A. Pipes, Plaintiffs attorney, whose address is 865 S. Marine Drive, Suite 201, Tamuning, Guam 96913, an Answer to the Complaint which is herewith served upon you within twenty (20) days after service upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the Complaint

Dated:   AUG 04 2006

RICHARD MARTINEZ, Clerk of Court Superior Court of Guam
By: Ryan T. Balajadia, Deputy Clerk

Orlean Pacific Plaza, Suite 201 865 South Marine Corps Drive 
Tamuning, Guam 96913 
Telephone No.: (671) 646-1222 
Facsimile No.: (671) 646-2203

Attorneys for Plaintiffs



CIVIL, CASE NO. CV 0960-06


Plaintiffs Guam Greyhound, Inc. and John Baldwin (collectively "Plaintiffs" upon information and belief file this action against Defendant Dorothy Brizill (`Brizill') and would respectfully show as follows:


In an ethical society, the "ends" do not "justify the means," but that is exactly the strategy being employed by anti-slot machine zealots who clearly believe that they, not Guam voters, should decide whether there should be slot machines ("slots") at the Guam Greyhound racetrack. The "means" they are using includes providing the media with a steady stream of inflammatory lies. These lies are designed to so tarnish Guam Greyhound owner John Baldwin's reputation that people will vote against slots because they have been convinced that Mr. Baldwin is not a good person. This is unfair to Mr. Baldwin, to Guam Greyhound, Inc. and all of its employees, customers and vendors (who very desperately need the economic boost that would be provided by slots), and the voters of Guam who are being misled by Brizill.


A. Plaintiffs.

1. Guam Greyhound, Inc. is a corporation organized and existing under the laws of Guam. Guam Greyhound, Inc. is owned by the GG Acquisitions II, LLC. Guam Greyhound is the only pari-mutuel racing facility (dog racing) on Guam.

2. John Baldwin is an individual who resides in St. Croix, U.S. Virgin Islands. Baldwin owns 99% of GG Acquisitions U, LLC, and is the President of Guam Greyhound, Inc. Baldwin also has a home in Guam and spends a considerable amount of time here. 

B. Defendants

3. Brizill is an individual residing in Washington, D.C., and may be served with process at 1327 Girard Street, NW, Washington, D.C. 20009.

4. Plaintiffs are unaware of the true names, capacities, or basis for liability of Defendants Does 1 through 20, inclusive, and therefore sue said Defendants by their fictitious names. Plaintiffs will amend this Complaint to allege their true names, capacities, or basis for liability when the same have been ascertained. Plaintiffs are informed and believe and on that basis allege that Defendants Does 1 through 20, inclusive, and each of them, are in some manner liable to Plaintiffs.


5. Jurisdiction is vested in this Court pursuant to pursuant to Sections 3105 and 4101, of Title 7 of the Guam Code Annotated.

6. This Court has personal jurisdiction over Brizill because her tortious actions were directed toward, and caused injury in, Guam. This Court also has jurisdiction over Brizill as she has purposefully availed herself of such jurisdiction by, among other things, appearing on a Guam radio program on August 2, 2006, and making false and defamatory statements and otherwise tortiously injuring each of the Plaintiffs.


A. Guam Greyhound's Fight For Survival.

7. Guam Greyhound is the only pari-mutuel racing facility on the island of Guam. It conducts eight or nine greyhound races five days a week year-round, with customers wagering on the dog races. The track is a venerable institution; it has been operating continuously on Guam since about 1974. In its heyday, typical crowds at the races numbered in the thousands and it had hundreds of employees. These days, employees number under 100, and the crowds are much thinner -- under 200 a night -- and the sport of champions and the breeding of strong and graceful greyhounds are at risk of being lost.

8. Plaintiffs have filed and collected over 14,000 signatures in support of a ballot initiative (the "Initiative") to legalize slot machines at Guam Greyhound. To place the Initiative on the November 7, 2006 general election ballot, Plaintiffs needed to gather only 4,959 signatures of registered Guam voters in support of the Initiative.

9. As of August ,2, 2006, the Guam Election Commission was predicting that there would be ample valid signatures to put the measure on the ballot. Indeed, so strong was public support for slots at the track that slots supporters collected the necessary signatures easily in only a little over two weeks.

10. As a result, it appears likely that the Initiative will be included on the November, 2006, general ballot. If there are slots at the track, the stands. will be filled again and hundreds of local jobs will be created. These are the very sort of facts that Brizill, Jacqueline A. Marati ("Marati') and other anti-gambling zealots want to cover up under a blanket of lies. B. Defendant Smears Plaintiffs In An Effort To Derail The Initiative Process.

11. On July 31, 2006, Matati and Lina'la Sin Casino ("LSC") issued a press release ("Defamatory Release) filled with false and defamatory statements about Mr. Baldwin. Marati and LSC made these false and defamatory statements initially with reckless disregard for whether or not they were untrue and then republished them with full knowledge that they were untrue.

12. Brizill provided Marati and LSC with some of the defamatory material and then appeared on a Guam radio program on August 2, 2006, and repeated many of the same false and defamatory statements contained in the Defamatory Release. These false and defamatory statements are the worst type of defamation because they not only harmed the business reputation of Mr. Baldwin and by extension his business, Guam Greyhound, but also falsely accused Baldwin of criminal misconduct.

13. Brizill's false and defamatory statements contained in the Defamatory Release and an August 2, 2006 radio program included the following.

  • John Baldwin was Involved in a signature buying scheme to get a Video Lottery Terminal Initiative in Washington, D.C"
  • John Baldwin was "part of group fined $622,820 in DC signature buying scheme for slot legalization."
  • John Baldwin "was denied or failed to obtain gambling licenses in five states, due to financial irregularities."
  • John Baldwin was a "partner in a company that in the late 1990s owned gambling halls in South Carolina that failed to pay taxes and broke state gaining rules."

These allegations are completely false and extremely damaging. Among other things, Mr. Baldwin was not involved in the DC Slots project - and Brizill has no basis for believing he was - so why is she saying these things?

14. Well, as one Guam news commentator stated publicly, these allegations seem geared to bring people to the conclusion that they should vote against the slots initiative because Guam Greyhound's owner is untrustworthy. This is a calculated strategy by gambling opponents to avoid a discussion of the benefit of slots at the track by poisoning people's opinion of a relative newcomer to Guam, John Baldwin.

15. Shortly after Marati released the Defamatory Release, Plaintiffs sent a letter to members of the Guam press indicating the false and defamatory nature of the various allegations contained in Marati's press release and to inform members of the Guam press that they should desist from publishing them lest they too be guilty of defaming Plaintiffs. Unfortunately, on August 1 and 2,2006, both the Marianas Variety and the Pacific Daily News, along with various radio and TV stations, published the defamatory statements.

16. On August 2, 2006, Brizill not only repeated the above allegations over the airwaves, but also falsely claimed that federal law precluded Guam from enacting slots legislation and failed to disclose that her efforts to make this same argument in the District of Columbia had been rejected by the courts.

17. Brizill also claimed she knew that Baldwin bad been denied a license in five or mote jurisdictions or "had been run out of them" and that Baldwin controlled the people who committed election law violations in the District of Columbia and therefore was responsible for them. All of this was knowingly untrue.

18. Brizill apparently believes the people of Guam are just too uneducated and uncivilized to make these important decisions for themselves, and that she instead should force the correct decision, as she sees it, upon them. Not content with bullying District of Columbia residents, Brizill now reaches out to Guam to impose her views on its citizens.

19. In any event, the truth is fairly boring, but very important:

  • Mr. Baldwin was not "behind" the DC Slot Initiative and not involved with the DC Slots signature gathering campaign, much less "in control" of it.
  • Mr. Baldwin has never been denied a gaming license.
  • Neither Mr. Baldwin nor any of his companies have been found to have "broken gaming laws."

20. In addition to having the facts wrong about Mr. Baldwin, Brizill has the facts wrong about the DC Slots Campaign:

  • There was no finding or even an allegation of "signature buying" - a crime in the District of Columbia -- in connection with the DC Slot Initiative.
  • None of the financial backers of the DC Slot Initiative was fined. Not one cent. Newspapers that reported otherwise retracted their false stories and issued corrections.
  • None of the financial backers of the DC Slot Initiatlve was charged with, much less found guilty of, violations of election law. Newspapers that reported otherwise withdrew and corrected those stories.
  • The Board of Ethics and Elections identified evidence of only one forged signature out of over 56,000 signatures collected for the 2004 DC Slot Initiative campaign. Signatures were unconstitutionally disregarded by the DC Board of Elections because of the actions of a small number of bad signature gatherers who were subcontractors of the company hired to manage the signature drive. That company was not involved in the Guam effort.

21. In short, Brizill has chosen to smear and defame in the hopes of shifting attention from the real issue: letting voters decide whether to approve a limited expansion of gambling in Guam, slots at a racetrack that already allows wagering. As a result, Brizill has perverted the initiative process and the will of the people, and caused significant damage to John Baldwin and Guam Greyhound, Inc.


Count I: Defamation (For all Plaintiffs).

22. Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 21 as if fully set forth herein.

23. Through the Defamatory Release, the subsequent articles and radio and television interviews (collectively, the 'Defamatory Statements') Brizill made false statements about Plaintiffs. These Defamatory Statements were made with knowledge that they were false.

24. The Defamatory Statements were neither privileged not protected.

25. Because Brizill published or caused to be published statements maligning Baldwin's and Guam Greyhound's character and accusing Baldwin of violating the law, the Defamatory Statements are defamatory per se as a matter of law, thereby entitling Plaintiffs to recover presumed damages.

26. Brizill published or caused to be published the Defamatory Statements with actual malice, that is, with knowledge that the statements were false, or with reckless disregard as to the truth or falsity of the statements.

27. Brizill's conduct was so malicious and egregious as to warrant punitive damages. Brizill's actions were particularly reckless and malicious because she was on notice that the statements were false. Brizill published and republished these statements despite such notice.

28. As a direct and proximate result of Brizill's intentional defamation, Plaintiffs have suffered, continue to suffer, and will continue to suffer loss of income, damage to their personal and professional reputations, mental anguish and humiliation, and damage to their business.

Count II: Tortious Interference With Prospective Business Advantage (For Guam Greyhound).

29. Plaintiff Guam Greyhound, Inc. repeats and realleges the allegations contained in paragraphs I through 28 as if fully set forth herein.

30. Plaintiffs' Initiative to introduce slot machines at Guam Greyhound represents a valid prospective business advantage or expectancy for Guam Greyhound, Inc. that is sufficiently definite, specific and capable of acceptance, in that there is a reasonable probability of it maturing into a future economic benefit to Guam Greyhound, Inc.

31. Brizill was fully. aware of this prospective business advantage or expectancy.

32. Through her Defamatory Statements, Brizill undertook, with purposeful intent, a campaign to interfere with that business advantage or expectancy.

33. Brizill's actions have legally caused and resulted in interference with, and impairment of, that business advantage or expectancy.

34. As a result of Brizill's actions, Guam Greyhound, Inc. has suffered actual damages.

Count III: False Light Invasion of Privacy (for all Plaintiffs).

35. Plaintiffs repeat and reallege the allegations contained in paragraphs I through 34 as if fully set forth herein.

36. Brizill gave publicity to matters concerning Plaintiffs that placed Plaintiffs before the public in a false light

37. The false light in which Brizill placed Plaintiffs would be highly offensive to a reasonable person.

38. Brizill had knowledge o f or acted with reckless disregard as to, the falsity of the publicized matter and the false light in which Plaintiffs would be placed.

39. Plaintiffs have suffered damages as a result of Brizill's actions.


For all the foregoing reasons, Plaintiffs respectfully request that Brizill be cited to appear and answer, and that this Court enter a judgment in Plaintiffs' favor and against Brizill providing for the following relief:

A. Compensatory Damages;

B. Punitive Damages;

C. Pre-judgment interest to the extent permitted by law,

D. Costs of this action;

E. Reasonable attorney's fees; and

F. Such other relief as the Court may deem just and appropriate.

Dated this 4th day of August, 2006.

Attorneys for Plaintiffs

By: Richard A. Pipes

Back to top of page

Send mail with questions or comments to webmaster@dcwatch.com
Web site copyright ©DCWatch (ISSN 1546-4296)