Former Trump 2016 campaign adviser Carter Page is suing the Democratic National Committee (DNC) for a whole host of claims. Page’s 49-page response to the DNC’s motion to dismiss those claims contains several notable items. Let’s take a look at some of the more interesting aspects, angles and legal theories contained therein.

1. Page accuses the DNC of civil rights violations.

Throughout the pro se filing (i.e., he’s representing himself) Page accuses the DNC and other defendants of having injured him through various civil rights violations. The issue here is that none of these alleged “civil rights” violations are ever named. Early on, Page makes reference to “extreme civil rights abuses and other associated damages caused by the Defendants.” In fact, the phrase “extreme civil rights abuses” is repeated in two separate headers. At another point, Page accuses his opponents of engaging in “associated unconstitutional civil rights abuses” and injustices from “a legal and civil rights perspective.”

Under U.S. law, “civil rights” are typically regarded as a series of discrete and enumerated rights held by anyone under the jurisdiction of the United States–and these rights entail certain corresponding obligations. Page’s filing invokes the phrase repeatedly, but fails to reference any of the statutes or frameworks that actually pertain to the U.S. legal system’s understanding of civil rights.

2. Page accuses the DNC of engaging in “domestic terrorism” against him.

This one should be allowed to speak for itself:

Based on the defamatory information distributed and paid for by the Defendants, the [U.S. Government] waged an unprecedented, targeted, state-sponsored surveillance operation against Dr. Page. Given subsequent death threats and the intent of the Defendants, the outcome of the libel committed against Dr. Page clearly displays the requisite elements of the statutory definition of domestic terrorism: “activities that involve acts dangerous to human life that are a violation of the criminal laws of the United States or of any State” and“appear to be intended…to intimidate or coerce a civilian population… to influence the policy of a government by intimidation or coercion; or… to affect the conduct of a government by…assassination… and… occur primarily within the territorial jurisdiction of the United States.”

3. Page says the Steele Dossier qualifies as a “racketeering enterprise.”

In service of a Racketeer Influenced and Corrupt Organizations Act (RICO) complaint–yes, a RICO complaint–Page describes the construction of the infamously salacious Steele Dossier as part of a racketeering enterprise. This enterprise, Page alleges, made false declarations in front of a court, engaged in domestic terrorism, threatened to injure reputations across state lines, obstructed criminal investigations, worked to influence an officer and generally engaged in frauds and swindles.

“The Defendants’ Dodgy Dossier operation constituted a Racketeering Enterprise, formed in approximately April 2016 with the hiring of its opposition research team,” the filing reads. “As the U.S. Congress has helped to expose,the Defendants’ enterprise had the required longevity [to satisfy RICO requirements.] The Defendants also had an unlawful common purpose and their conduct in support of that common purpose was unlawful.”

4. Page insists that he’s not a public figure.

At the heart of the matter, despite the RICO and domestic terrorism claims, Page’s lawsuit is an action for defamation due to the perceived injustices resulting from the Steele Dossier. In an attempt to bat away those claims, the DNC-and-attorney-defendants have raised Page’s status as a public figure. Under longstanding defamation case law, it is exceedingly difficult for public figures to win defamation lawsuits. So, Page is effectively arguing that the defendants are the ones who turned him into a public figure–against his will.

“Dr. Page’s Wikipedia presence began within hours of the Dodgy Dossier-based 2016 Yahoo Article,” the filing notes. “Dr. Page never sought attention and instead tried to limit his media presence to the greatest extent possible throughout his life except in instances when malicious allegations required comment to prevent severe damage to himself and his company until the defamatory reports of September 23, 2016sourced to the Defendants’ servants made the continuation of the peaceful and safe life he once enjoyed impossible. In response to the terrorist and other threats that the Defendants verifiably played a key role in helping to inspire against the Plaintiff, Dr. Page has since been forced to incessantly conduct crisis communications. He also never met Mr. Trump.”

5. The filing contains some cautionary tales for pro se litigants.



Carter Page has submitted this filing all by his lonesome–or, at least, without help from a named attorney. This is generally advised against in high-profile cases, especially those in federal court. While Page makes clear that he is currently studying the law, his inexperience shines through in ways large and small. References to legal standards are occasionally clumsy, rendered fancifully and off-base–or, as noted above, simply missing altogether–and Page repeats the same typo some 80-plus times.

There’s also several instances of languages atypical of federal court filings.

The Page filing makes the following broadside generalization: “During the months before the 2016 Presidential election, the Defendants committed torts previously unseen in the history of the United States and without precedent in the annals of American law.”

There’s also this:

The Defendants unluckily gambled in 2016 with high hopes that some of the defamatory dirt spread with their defamatory Dodgy Dossier deck might fertilize. Now, the [motion to dismiss] doubles down on their imprudent bets.

[image via Drew Angerer/Getty Images]

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