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1 ELECTRONICALLY FILED Benton County Circuit Court Brenda DeShields, Circuit Clerk 2017-Nov-01 16:31:09 04CV C19WD04 : 12 Pages IN THE CIRCUIT COURT OF BENTON COUNTY, ARKANSAS CIVIL DIVISION HENDREN PLASTICS, INC., An Arkansas Corporation PLAINTIFF V. CASE NO.: TIMOTHY STEADMAN Individually DEFENDANT PLAINTIFF'S COMPLAINT COMES NOW Plaintiff, Hendren Plastics, Inc. ("Plaintiff' or "Hendren Plastics"), and for its Complaint against Defendant, Timothy Steadman, ("Defendant" or "Mr. Steadman") does state the following: A. PARTIES AND JURISDICTION 1. Hendren Plastics is an Arkansas corporation with its principal place of business located in Benton County, Arkansas. 2. Based on information and belief. Defendant is a resident of Pulaski County, Arkansas and is a licensed attorney with offices located in Pulaski County, Arkansas. 3. This court has jurisdiction over the persons and subject matter and venue properly lies herein. B. FACTUAL BACKGROUND 4. On October 23,2017, a class action lawsuit was filed by Mark Fochtman and Shane O'Neal (the "Class Representatives"). See Benton County Circuit Court Case No.: 04-CV (the "Lawsuit"). Mr. Steadman was identified as coimsel for the Class Representatives in the Lawsuit. While many of the statements made in the Lawsuit in reference to Plaintiff are false, said statements are privileged because they are part of a judicial proceeding and are not at issue in

2 this Complaint. While the statements made in the Lawsuit are not the subject matter of this action, for the sole purpose of providing background, they will be discussed herein. 5. Hendren Plastics contracted with a drug court rehabilitation facility and agreed to accept residents provided by the facility to work as independent contractors. 6. Hendren Plastics paid the facility for each hour of work performed by the resident. Hendren Plastics paid the facility an amoimt equal to the amount Hendren Plastics was paying its own entry-level employees ($9.25 an hour). 7. Hendren Plastics, Inc., was not a party to any arrangement between the worker and the rehab facility. 8. In the Lawsuit, the Class Representatives allege they were placed with rehabilitation facilities as part of their drug court obligations. These rehab facilities then placed the Class Representatives in gainful employment with Hendren Plastics, Simmons Foods, Inc., and other unnamed employers. The Lawsuit acknowledges that Hendren Plastics paid the rehab facilities for the labor performed by the Class Representatives. See If 40 of Plaintiffs Complaint filed in the Lawsuit. However, the Lawsuit alleges that the rehab facilities did not pay the participants any of the money received by Hendren Plastics. 9. Despite acknowledging that Hendren Plastics paid for the labor received, the Lawsuit alleges Hendren orchestrated "a pervasive scheme of slavery". See 59 of Plaintiffs Complaint filed in the Lawsuit. 10. Because of the salacious allegations of slavery, the Lawsuit generated considerable publicity and news coverage.

3 C. THE DEFENDANT'S NON-PRIVILEGED STATEMENTS 11. As part of the news coverage, on October 31,2017, the local news channel KHBS (40/29) aired a story about the Lawsuit. The news story also ran on KHBS's website. See Exhibit "A" attached hereto and incorporated herein by reference as if set forth in full. 12. The news story was further posted to KHBS's and the reporter's Facebook page where it received negative reactions and was reposted many times. See Exhibits "B" and "C" attached hereto and incorporated herein by reference as if set forth in full. 13. During this news story, KHBS did with the Defendant's authorization, re-broadcast statements made by the Defendant to the KHBS news staff. 14. In referencing the Lawsuit filed against Hendren Plastics and Simmons Food, Inc., Defendant stated: ^^These programs are supposed to help people combat addiction, not turn them into slaves for businesses that are unashamedly for profit" The reporter, Katie Davidson then stated, "Attorneys for the two bringing the suit say it doesn't matter if Simmons Food and Hendren Plastics paid." The story again rebroadcasts the Defendant's statement in which he stated, "Hendren and Simmons Food and the other business that use these men and women are who is profiting from this. They control the employment." 15. Defendant's comments that Hendren Plastics was profiting fi-om slave labor is categorically false. D. COUNT 1 - DEFAMATION 16. Plaintiff restates and reincorporates all allegations of fact contained in all preceding paragraphs. 17. Hendren Plastics is not a public figure, but is rather a private corporation.

4 18. Defendant's statements that Hendren Plastics profited from slave labor was an assertion of fact and not a mere opinion. The Defendant's assertions of fact were categorically false. 19. Considering the Lawsuit acknowledges that Hendren Plastics paid the workers' wages. Defendant's false assertion that Hendren Plastics was using slave labor was made with knowledge that such a statement was false. Alternatively, the statements were made with negligence in failing to determine the truth of the statement prior to publishing the statement to a popular television news channel. 20. Defendant's statements have and will continue to negatively affect Plaintiffs business and has injured Plaintiffs reputation. Specifically, Plaintiffs value is in part based on its "good will" which had been damaged by the defamatory statements of Plaintiff. Further, Plaintiffs on-going business requires continually attracting new employees in order to meet its labor demands. Due to the defamatory comments made by Defendant, attracting new employees will be made more difficult. 21. As a result of Defendant's false and defamatory statements. Plaintiff has been damaged in an amoimt to be proven at trial. 22. Defendant's actions demonstrate an intentional course of conduct for the purpose of causing damage to Plaintiff. To wit. Defendant's actions were done with the knowledge that the conduct would naturally and probably damage Plaintiff and continued in such action with malice or reckless disregard of the consequences - from which malice can be inferred. paragraphs. E. COUNT II - PUBLICITY PLACING THE PLAINTIFF IN A FALSE LIGHT 23. Plaintiff restates and reincorporates all allegations of fact contained in all preceding

5 24. Plaintiff sustained damages resulting from the Defendant's publication of statements that placed Plaintiff in a false light. 25. The false light in which Plaintiff was placed would cause a reasonable person to be justified in feeling seriously offended and aggrieved by the publicity. 26. Defendant's public statements that put Plaintiff in a false light were the proximate cause of the damages suffered by Plaintiff. 27. Defendant put Plaintiff in a false light knowing it was false or having a high degree of awareness of its probable falsity. 28. Plaintiff demands trial by jury. F. DAMAGES 29. Plaintiff respectfully requests the following damages to be considered for the purpose of determining the sum of money that will fairly and reasonably compensate it for the damages suffered by the actions of Defendant; a. Damages resulting from Plaintiffs loss of reputation and character in an amount to be proven at trial; and b. Punitive damages in an amount to be proven at trial. WHEREFORE, premises considered, Plaintiff respectfully prays this Court grant Plaintiff the relief requested herein and award Plaintiff any other relief to which it may be entitled. Respectfully submitted. By: Tim Hutchinson ( ) Reece Moore Pendergraft LLP 75 North East Avenue, Ste. 500 P.O. Box 1788

6 Fayetteville, AR (479) Attorneys for Plaintiff

7 VERIFICATION I, Jim Hendren, President of Hendren Plastics, Inc., do hereby state that I have reviewed the foregoing and the statements contained therein are true and correct to the best of my knowledge and belief Dated I, endren STATE OF ARKANSAS COUNTY OF WASHINGTON ) ) ss. ) Personally appeared before me this date, the J day of X^0V/'OTti:>^, 2017, Jim Hendren, to me well known (or sufficiently proven) to be the person whose name is subscribed to the foregoing Complaint and acknowledged tbat he executed the same for purposes expressed therein. KELLI MARIE FOUTS WASHINGTON COUNTY NOTARY PUBLIC -- ARKANSAS My Commission Expires May 7,2022 Commission No fary PUBLIC My commission expires: 7 ^0^^

8 Suit says rehab programs used patients for free labor Page 1 of 3 EXHIBIT A f N oweast Watch on Demand GAME OF THE WfctK "ra :%f! i-««a -..,'V. - '. ' m,... 'H' = SHOW TRANSCRIPT Suit says rehab programs used patients for free labor Updated: 6:51 PM CDT Oct 31,2017 Katie Davidson f if ^ l.u.'ltimedia Jcotnalist Adam Roberts, DMM f SF H Digitoi Media Man.-tget BENTONVILLE, Ark. Two men filed a lawsuit in Benton County, saying couit-ordered drug and alcohol recovery programs used them as free labor for local businesses. Exh. A /1/2017

9 Suit says rehab programs used patients for free labor "They =yj>ucipated receiving treatment for an addiction to help better their lives than they were before," said Jerry Garner, an a^grnfey for the plaintles^mtmstead they get to these facilities and essentially it's a labor camp." shares Guaranteed Recovery, D.AWM ;n;-vrmtnr<.rmik> The two programs are the Drug and Alcohol Recovery Program (OARP) and Christian Alcoholics and Addicts in Recovery (CAAIR). Those programs sent men to work for Hendren Plastics and Simmons Foods. Hendren Plastics is owned by State Sen. Jim Hendren of Sulphur Springs. Hendred told 40/29 his company has already canceled its contract with the court-ordered program. "Several years ago, we were approached by the folks at DARP who asked if we would be willing to participate in a drug court program to allow kids alternative sentencing," Hendren said, "instead of going to jail they would have an opportunity to work and learn some skills and hopefully have a job when they finished the program." Hendren told 40/29 his company paid DARP $9.25 an hour for the labor its men performed. But the lawsuit says DARP kept the money. "These programs are supposed to help people combat addiction, not turn them into slaves for businesses that are unashamedly for profit," Steadman told 40/29. Hendren told 40/29 he signed onto the program because he wanted to help people. "It's very disheartening, and it's disheartening to think about the kids now that are going to have to sit back in jail because of these types of lawsuits," he said. Simmons Foods released a statement to 40/29 News; The claims by former CAAIR participants of their experiences are inconsistent with Simmons' operational policies and core values. There is another side of this story that has not been told about the hundreds of CAAIR participants who successfully completed CAAIR's program and decided to continue to work at Simmons' facilities. Simmons is proud of the nearly 30 current employees who graduated from the CAAIR program, including some who are pursuing advanced college degrees and developing their careers. Exh. A-2 http;//' 11/1/2017

10 Suit says rehab programs used patients for free labor Page 3 of 3 Whjle cannot comment on the specifics of any pending litigation related to this matter, we want to assure our custon^^rs, and c^iottltos that we are prepared to use every resource at our disposal to vigorously defend the company. shares employees, f ^ October 12,2017 Alternative Investments: Not Just for Billionaires C2 Sponsored Content 5 By Wells Fargo KHBS/KHOG FORT SMITH-FAYETTEVILLE f y G* CS Contact Us News Team Apps & Social Alerts Careers Internships Advertise RSS EEO Reports Captioning Contacts Public Inspection File Hearst Television participates in various affiliate marketing programs, which means we may get paid commissions on purchases made through our links to retailer sites. 2017, Arkansas Hearst Television Inc. on behalf of KHBS-TV.Privacy Policy Interest-Based Ads Terms of Use Site Map Exh. A /1/2017

11 EXHIBIT B fl f Wnte a commeni TV Channel Shane Lllsenl>ee Praying tor all the victims and their families Like Reply '6 'ifs Community see All Invite your friends to like this Page 40/29 News ~ Fort Smith & Fayetteville, Arkansas o CO;4G;?9nev/s Home Posts Photos 40/29 News - Fort Smith & Fayetteville, Arkansas L.'Mi. i! 40/29 Katie Davidson - post './lire» «40/29 Katie Davidson i4 Like Page FREE LABOR: A new lawsuit claims court-ordered rehabilitation programs placed people convicted of crimes In Jobs at Simmons and Hendren Plastics and made them work for tree irhjivijuetlv entj am briuu <>( All uih4f«eimiurlv «MuAtnl ik people like this.=v\ people follow this XI Caitlin Noblitt and 280 other friends like this O Typically replies instantly Send Message 4029tv.com 6 TV Channel See All Videos CAAIR. ISC, MMMONS f<s) >S. INC, r»arr, INC., HI shkrs n ahtic^ ivc. Pages Hked by this Page At)out Events McLarty Daniel & The Ma... Community Best Seat in The House CLAM ACnOS COMTIJUKT LtMnooccnm I Tlite ii «(Um wthbi (c* vkrutun* tfv ArkamM CmetiluUnn'e pnthilmina on tm vrall m k* unpikl ntimmtim wtgt and ovwiunr urblpf rtv KliiiJB»um VVAgr Ait Ik-ierikUits CAAIR. If* ('CAAIR*) aral UAKP. I.V Suit says rehab programs used patients for free labor 40/29 Allison Wise O fir Like 40/29 Joshua Cole O Like Create a Page Two men filed a lavr/suit in Benton County, saying court-ordered drug and alcohol recovery programs used them as free labor for local businesses. The Arkansas CW Like ^ Like Comment ^ Share OW^17 vvnte a comitk-'i* Top Comments O g) 0 Enqhsh (US) Espanol Portugues (Brasll) ^ Fran^ais (France) Deutsch _ Pnvacv Terms Advertising Ad Choices J>- Cookies More' Facebook 2017 Sheila Moyers I hope these guys go through with this. One of those employers built a dorm for them to house more guys. There is a sehous lack of treatment facilities and lots of addicts but the focus has to be on sobriety and not making a profit off of someone's pain and suffering Like Reply O Marlis Ketrow The former head of Simmons HR Department "developed" this "rehab" solution after being unable to fill Jotjs for the company and help addicts. NPR did a story on Uiis a couple of weeks ago Including an interview with her. Like Reply ^ 1 v/ nif. View 5 more comments

12 EXHIBIT C Journalist "i Community See All Al Invite your friends to like this Page i people like this 40/29 Katie Posts ^ 2,931 people follow this 11 Joe Warren and 3 other friends like this Home Posts Photos Community Videos o 40/29 Katie Davidson - -ri FREE 1_A80R: A new lawsuit claims court-ordered rehabilitation programs placed people convicted of crimes in jobs at Simmons and Hendren Plastics and made them work for free. ind!vidu4lly ott behalf of 4II olhcr*»im>brly iluiled PI-AINTIITS O Typically replies within minutes Send Message ^ a Journalist See All About Create a Page CAAIK. INC. FOODS, IKC.. DAttP. INC., Ill NDKLN PLAMICS, INC jnd loiindoi St-.IU DKIItNDANTS People Also Like 40/29 Allison WiseO Joumalist Like CLASS ACTION COMITAINT I.I.VtlU>f>tXlMM 1 Thi«I* rt ituv. a<uon lt»r viouitofte Ktl ihe Arluinu» CmvtlUiUon'* prohtwhon on»bvcr>. aa well 4* Un unfwul mttutnum wafge and twrtlnw under Ihc ArWnivsjis Minimum VVagr Act IX-lffvl.ints CAAIK. Iw. fcaair') Dik) OARP. Itx Suit saj^ rehab programs used patients for free labor Two men filed a (awsuit m Benton County, saying court-ordered drug and alcohol recovery programs used them as free labor for local businesses. 4029T>.' COM 40/29 News - Fort S... O TV Channel 40/29 Brendan Johnson JoumalisI Pages liked by this Page lir Like il Like [ ) Like Comment ^ Share 2 40/29 Allison Wise O il Like 14 Shares Write a canmera-. ' English (US) Espanol Portuguds (BrasH) (al Franqals (France) Deutsch Pnvacy Terms Advertising Ad Choices Cor^isa More -

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