



Grogan seeks damages in excess of one million dollars from each of the defendants for defamation. Grogan claims that Joseph Paolella defamed him in a letter to Jack Trimarco:



Quote:

On or about February 12, 2008, PAOLLELA wrote a letter to TRIMARCO that contained the following false, malicious, and libelous statements:



a. "After approximately 6-weeks of training, I gave Mr. Grogan an 'honorary completion' certificate. I had no idea that he wanted to be an examiner and go into the business as an examiner";



b. "I had to let Mr. Grogan go because of his 'unauthorized advances' towards female students"; and



c. "Even though Mr. Grogan has lost his P.I. & P.P.O. license, he is using an associate Lisa Javoric . . . to front for him on her website to do private investigations . . ."



Grogan's complaint against Jack Trimarco is that:



Quote:

On or about March 7, 2008, TRIMARCO telephoned the Tom Leykis Radio Talk Show which airs on 97.1 FM (the "SHOW"). When TRIMARCO telephoned the show as a listener, the appearing guest of Mr. Leykis was Plaintiff. Plaintiff was invited to appear on the radio and perform a polygraph examination on a television producer. During this telephone call on a national broadcast to potentially millions of listeners TRIMARCO made several false, malicious, and slanderous statements about Plaintiff including but not limited to:



a. "John Grogan is a fake";



b. "He is not a polygraph examiner";



c. "He's been convicted of 26 counts of fraud;



d. "He's never graduated from a polygraph school";



e. "You're nothing more than a fraud and you're about to get burned";



f. "I'm going to get you convicted";



g. "I'll bring in my proof to the DA in Ventura County"; and



h. "You perjured yourself."



A podcast of the radio show in question, which has been the topic of



http://podcast.971freefm.com/klsx1/956464.mp3



http://podcast.971freefm.com/klsx1/956500.mp3



With regard to Ralph Hilliard, Grogan alleges:



Quote:





a. "John snares the unsuspecting public into his web of deceipt"; and



b. "[f]raud being perpetrated on the public by John in California and now across the nation."



Furthermore, HILLIARD provides two hyperlinks to the false and defamatory articles on POLYGRAPH PLACE. The above articles and statements on both websites are tremendously damaging to Plaintiff's reputation professionally and personally. Shortly after the SHOW aired, HILLIARD posted an article on POLYGRAPH PLACE entitled: "Issue #142  4/18/2008, John Grogan  Part II  Imposter? YES  Swindler? Definitely  Polygraph Examiner? Not by any Stretch of the Imagination." In that article, HILLIARD republished each of the defamatory statements made by TRIMARCO during the SHOW. In addition, HILLIARD wrote that Plaintiff is a "swindler," "imposter," and has "a history of threats, harassment and violence." Then on [ TruthAboutGrogan.org ], HILLIARD posted the following false, malicious, and libelous statements regarding Plaintiff:a. "John snares the unsuspecting public into his web of deceipt"; andb. "[f]raud being perpetrated on the public by John in California and now across the nation."Furthermore, HILLIARD provides two hyperlinks to the false and defamatory articles on POLYGRAPH PLACE. The above articles and statements on both websites are tremendously damaging to Plaintiff's reputation professionally and personally.



John Grogan's statement of "complaint for damages," including copies of Joseph Paolella's letter to Jack Trimarco and the "Polygraph Examiner" diploma that Paolella bestowed upon Grogan, is available for download here:



https://antipolygraph.org/litigation/grogan/grogan-complaint.pdf



Grogan's "Polygraph Examiner" diploma includes no mention of its being "honorary," as Paolella maintained in his letter to Trimarco. On 30 May 2008, polygrapher John L. Grogan of Woodland Hills, California filed a lawsuit against fellow Los Angeles area polygraphers Joseph Paolella and Jack Trimarco as well as PolygraphPlace.com and TruthAboutGrogan.org proprietor Ralph Hilliard of Canton, Georgia. Twenty "Does" are also included among the defendants.Grogan seeks damages in excess of one million dollars from each of the defendants for defamation. Grogan claims that Joseph Paolella defamed him in a letter to Jack Trimarco:Grogan's complaint against Jack Trimarco is that:A podcast of the radio show in question, which has been the topic of previous discussion on this message board, can be downloaded here:With regard to Ralph Hilliard, Grogan alleges:John Grogan's statement of "complaint for damages," including copies of Joseph Paolella's letter to Jack Trimarco and the "Polygraph Examiner" diploma that Paolella bestowed upon Grogan, is available for download here:Grogan's "Polygraph Examiner" diploma includes no mention of its being "honorary," as Paolella maintained in his letter to Trimarco.