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1 18. On information and belief, the Fact Sheet led third parties to believe that Lim <br /> 2 Ranch was operating in violation of environmental laws and that the RWQCB was investigating <br /> 3 Lima Ranch for violating environmental laws. <br /> 4 19. Plaintiffs are informed and believe and thereon allege that Coldani directed <br /> 5 DeArth and Genesis to publish and distribute the Fact Sheet. In fact, Coldani has admitted t <br /> 6 third parties that he is responsible for publishing and distributing the Fact Sheet. <br /> 7 20. The Fact Sheet contains several false and/or inaccurate allegations on the face o <br /> 8 the document including the following statements. <br /> 9 a. "local groundwater has been contaminated with nitrates as the result o <br /> 10 improper and unlawful dairy operations at the Lima Ranch Dairy.' <br /> 11 (Emphasis added). <br /> 12 b. "the primary source of this nitrate is the dairy cow manure, urine, and other <br /> 13 wastes stored in the waste lagoons and ditches at Lima Ranch and applied t <br /> 14 croplands at Lima Ranch." <br /> 15 c. "groundwater analysis shows that the primary sources of that nitrat <br /> 16 contamination are the Lima Ranch's manure water holding ponds an <br /> 17 lagoons, the ditches through which manure water is moved, and th <br /> 18 application of manure water to Lima Ranch's croplands." <br /> 19 21. The statements published in the Fact Sheet are not only defamatory on their face, <br /> 20 but are also defamatory by the implications and innuendoes they make. The statement that"local <br /> 21 groundwater has been contaminated with nitrates as the result of improper and unlawful dai <br /> 22 operations at the Lima Ranch Dairy" is both defamatory on its face and by its implication as i <br /> 23 falsely alleges that Lima Ranch operates in an unlawful manner. (Emphasis added). <br /> 24 22. The statements that "the primary source of this nitrate is the dairy cow manure <br /> 25 urine, and other wastes stored in the waste lagoons and ditches at Lima Ranch and applied t <br /> 26 croplands at Lima Ranch" and that "groundwater analysis shows that the primary sources of tha <br /> 27 nitrate contamination are the Lima Ranch's manure water holding ponds and lagoons, the ditches <br /> C <br /> 28 through which manure water is moved, and the application of manure water to Lima Ranch' <br /> HERUM\,CRAUREE <br /> q <br /> COMPLAINT FOR TEMPORARY RESTRAINING ORDER,PRELIMINARY AND PERMANENT <br /> INJUNCTION,LIBEL PER SE,AND LIBEL PER QUOD <br />