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1 -against- Index No: Date Filed: SUMMONS FOX TELEVISION STATIONS, INC. and JOHN DEUTZMAN, Defendants.... X The basis of venue is the Defendant's, Fox Television Stations, Inc., Principle Place of Business Plaintiff Designates New York County as the Place of Trial Plaintiff resides at 1464 Garfield Road, East Meadow, New York YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer, or, if the complaint is not served with this summons, to serve a notice of appearance, on the Plaintiffs Attorney(s) within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded in the complaint. Dated: +o-' Lake Success, New York June 30,2008 Matthew L. Spindler, Esq., MONSOUR WINN KURLAND & WARNER, LLP Attorneys for Plaintiff 5 Dakota Drive Lake Success, New York (516) Courthouse News Service -.* To: JOHN DEUTZMAN Home Address: 135 W 16th Street, New York, NY \$Business Address: WNYW, 205 East 67th Street, New York, NY Ne TATIONS INC, 1211 Avenue of the Americas, 21St Floor,

2 # -against- Plaintiff, FOX TELEVISION STATIONS, INC. VERIFIED COMPLAINT complaining of the Defendants herein, respectfully shows to thiscourt, and alleges as follows: 1. That at all times hereinafter mentioned Plaintiff GAMAL IBRAHIM is a resident of the County of Nassau, State of New York. 2. That at all times hereinafter mentioned Defendant FOX TELEVISION STATIONS, INC. was and still is a foreign corporation authorized to do business in the State of New York. 3. Upon information and belief, and at all times hereinafter mentioned, the Defendant JOHN DEUTZMAN resides in the State of New York. 4. Upon information and belief, at all times hereinafter mentioned, the Defendant, FOX TELEVISON STATIONS, INC. owns a television station called WNYW on Channel 5 that serves the great New York City Metropolitan Area.

3 c 5. Upon information and belief, and at all times hereinafter mentioned, the Defendant FOX TELEVISION STATIONS, INC. was and still is in the business of preparing, producing, and exhibiting television programs in the nature of news reports. 6. On or about October 2, 2007, and at all times hereinafter mentioned, WNYW broadcasted to the public in the City and State of New York on Channel That at all times hereinafter mentioned, the Defendant FOX TELEVISION STATIONS, INC. controlled the content of broadcasts of WNYW. 8. That at all times hereinafter mentioned, the Defendant, JOHN DEUTZMAN, was an investigate reporter for WNYW. 9. On October 2,2007, the Plaintiff, GAMAL IBRAHIM, was employed by the United Nations in New York, New York. 10. On October 2,2007, the Defendants FOX TELEVISION STATIONS, INC. and JOHN DEUTZMAN, broadcasted a story on Channel 5 concerning the plaintiff, GAMAL IBRAHIM that, upon and information and belief, was heard by many thousands of people within the State of New York. 11. On October 2,2007, the Defendants broadcasted a segment on WNYW accusing the Plaintiff of abusing a dog in his custody as part of his duties at the United Nations in New York, New York. 12. Upon information and belief, the segment was continuously streamed on the myfox.com website up to and including the date of Plaintiff s complaint. 13. The broadcast is available for viewing on The specific link to the video is

4 htttx//w w w.myfoxny. com/mvfox/panes/home/detail; i ses sionid=bf26b B B27 1 SADO573E74DO 1 C473CF5DA?contentId= &version=2&locale=EN -US&lavoutCode=VSTY&DaneId=l.l. l&sflg=l. A Copy of the Broadcast can be sent to Defendants if requested. 14. The Defendants published defamatory statements on their website, concerning the Plaintiff, GAMAL IBRAHIM. 15. The statements published by the Defendants on their website were false, defamatory, malicious, and libelous. 16. The false, defamatory, malicious, and libelous statements published by the Defendants on their website include: 1. With all the heavy security, the United Nations is supposed to be one of the safest places on earth. But in one case it wasn t safe enough for a dog. Fox 5 s John Deutzman has the exclusive story about why the dog had to be taken into custody by the state police. 2. John Deutzman reports on a U.N. security sergeant reassigned from the canine unit and whose dog partner was taken away from him. 17. The Statements made by the Defendants in the broadcast were false, defamatory, malicious, and libelous. 18. The false, defamatory, malicious, and libelous statements made by the Defendants in their October 2,2007 WNYW Broadcast include: John Deutzman: The bond and trust between dog and Canine Officer is considered sacred, but Sergeant Ibrahim might have violated that trust, turned in by his colleagues for possibly mistreating his canine partner named Buddy, a Golden Labrador. Gama1 Ibrahim: That s not true, I don t know where they get this from. About this rumor, that is not true.

5 c John Deutzman: Oh it s more than the rumor what we are about to tell you, has been confirmed by a spokesperson inside the United Nations, sources in the United Nations, and a Spokesperson from the State Police, the agency that loaned the dog Buddy to the UN. John Deutzman: Everyone agrees the problem wasn t with Buddy the dog, The problem apparently was with Buddy s human partner Sergeant Ibrahim. Recently, one of his fellow officers observed the Sergeant raising his hand in a threatening manner to the dog and the dog cowering down, a sign of possible abuse. This set off such a bad vibe within the UN that they started an investigation, What they found was bad enough for the State Police to take custody of Buddy and the UN to take Sergeant Ibrahim off canine duties. According to State Police, a veterinarian who examined Buddy concluded that Buddy had injuries consistent with trauma. Now they didn t find enough solid evidence to prove that the Sergeant beat his canine dog, but what they found was enough to have him transferred out of the canine unit and for the State police to take the dog back. John Deutzman: We had a problem matching what the sergeant said against reality. The reality is that Buddy was taken into custody by State police. John Deutzman: Oh no he s not according to the Spokesman from the United Nations; he s been transferred out and does not work with dogs. The state police tell us, Buddy is completely healed and doing fine with his new Canine officer and is working in the Albany area. Buddy s ex partner Sergeant Ibrahim is still working too. Not with dogs however, but still a security officer at the United Nations. Now despite this incident, the State Police tell us they have a great relationship with the UN and will continue to provide them with dogs. I m John Deutzman, Fox 5 News. 19. The statements broadcasted and published by the Defendants were intended to and were understood by the viewing and listening public to charge that the Plaintiff abused a dog in his custody while Plaintiff was employed by the United Nations in New York, New York.

6 20. The statements broadcasted and published by the Defendants and the innuendos necessarily implicit therein were false and defamatory. 21. The statements broadcasted and published by the Defendants consisted of statements accusing him of abusing his dog while working for the Canine Unit at the United Nations, thus are defamatory per se because they constitute imputation of a trait that is inconsistent with Plaintiffs trade, occupation, or business, 22. The statements broadcasted and published by the Defendants are defamatory per se because they accused Plaintiff of committing the New York State crime of Overdriving, Torturing, and Injuring animals; Failure to Provide Proper Sustenance under McKinney s Agriculture and Markets Law Upon information and belief, at the time of the aforesaid broadcast, the Defendants were actuated by actual malice in that Defendants knew that the segment and matters contained therein concerning the Plaintiff so broadcasted, were false or untrue, or were broadcasted with reckless and wanton disregard of whether they were false or untrue. 24. Upon information and belief, in broadcasting and publishing the defamatory matter cited above, the Defendants acted in a grossly irresponsible manner, without due consideration for the standards of information gathering and dissemination ordinarily followed by responsible parties. 25. The statements broadcasted by the Defendant in the news segment on October 2,2007 and published on their website about the Plaintiff, GAMAL

7 c IBRAHIM, were defamatory because they had a tendency to expose the Plaintiff to public hatred, contempt, ridicule and disgrace. 26. As a result of the publication, broadcast, and the acts of the Defendants in connection therewith, the Plaintiff has been held up to public contempt, ridicule, disgrace, and prejudice; has suffered great mental pain and anguish; and has been irreparably injured in his good name, business reputation, and social standing, and has lost the esteem and respect of his friends, acquaintances, business associates, and of the pubic generally. 27. By reason of the foregoing, Plaintiff has been greatly injured and damaged, and is entitled to compensatory and punitive damages, inter alia for emotional distress and loss of reputation. WHEREFORE, Plaintiff demands judgment against the Defendants on this Complaint in sums that exceed the monetary jurisdiction of all of the lower courts of the City and State of New York together with interest, costs and disbursements as might be allowed by law. Dated: Lake Success, New York June 30,2008 Yours etc., MONSOUR, WINN, KURLAND & WARNER LLP. Attorneys for Plaintiff 5 Dakota Drive Lake Success, New York Tel.: (516) h4- * $r - " r. L - A* -. + MATTHEW L. SPINDLER, ESQ.

8 INDIVIDUAL VERIFICATION STATE OF NEW YORK ) COUNTY OF NASSAU ) SA.: ) GAMAL IBRAHIM, being duly sworn deposes and states: I ~-&&ktiff h-kwithbx action& - kwe-~-$eregeing - - SUMMONS AND COMPLAINT and know the contents thereof and that the same is true to my own knowledge except as to the matters therein stated to be alleged upon information and belief and as to those matters I believe them to be true. Sworn to before me this 2 day of July, NOTARY e- PUBLIC

9 ~~ SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK Index No.: GAMAL IBRAHIM -against- Plaintiff, FOX TELEVISION STATIONS INC., and JOHN DEUTZMAN Defendants. SUMMONS & COMPLAINT MONSOUR, WINN, KURLAND & WARNER, LLP. Attorneys for Plaintiff 5 Dakota Drive Lake Success, New York (516) Signature pursuant to Rule 130- I. I (a) f w.,c r& Matthew L. Spindler, Esq.