Rebecca Brannon Answer & Counterclaim

STATE OF MINNESOTA DISTRICT COURT
COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT

Case Type: Civil - Other
William T. Grant, Court File No. 27-CV-21-10948
Plaintiff/Counterclaim Defendant,
v. COUNTERCLAIM AND ANSWER

OF DEFENDANT/COUNTER-
Rebecca Brannon, PLAINTIFF REBECCA BRANNON
Defendant/Counterclaim Plaintiff, JURY TRIAL DEMANDED

and
Justin Perpich,
Defendant.
COUNTERCLAIM OF DEFENDANT/COUNTERCLAIM PLAINTIFF REBECCA

BRANNON
Counterclaim Plaintiff Rebecca Brannon (“Brannon”), for her Counterclaim against
William T. Grant (“Grant”), states and alleges as follows:
NATURE OF THE ACTION
1. This action concerns Grant’s efforts to silence Brannon, a courageous independent
journalist who doggedly has reported on matters of substantial public interest concerning
widespread harassment and toxic work environment within the Republican Party of Minnesota
(“MN GOP”) under the leadership of former Chairwoman Jennifer Carnahan (“Carnahan”).
2. Much of the harassment disclosed by Brannon targeted young female MN GOP
staffers who were afraid to speak up for fear of their careers being destroyed and were further
coerced into silence by Carnahan and her operatives through widespread intimidating demands to
enter into non-disparagement agreements (“NDAs”).

3. One individual who played a prominent role in creating the toxic culture and
maintaining the silence of its victims through his actions as a MN GOP political operative and
Carnahan lieutenant is Grant.
4. Brannon’s investigative reporting also disclosed the substantial ties between the MN
GOP and one of its largest financiers (and friend of both Grant’s and Carnahan’s), Anton “Tony”
Lazzaro (“Lazzaro”), who recently was indicted on federal sex-trafficking charges.
5. Grant has become a limited-purpose public figure as it relates to this controversy both
voluntarily, by commenting on it, and because he has gained public prominence as a self-
described aspiring “top political consultant” (Complaint at ¶ 11). Through his work as campaign
manager for multiple Republican political candidates and his employment and consulting work
for MN GOP, Grant has courted publicity through television, radio, print and digital media
appearances to establish his public prominence as a strategist and thought leader within MN
GOP.
6. In spite of his status as a public figure in MN GOP politics, Grant commenced a
defamation lawsuit against Brannon for her investigative reports on MN GOP politics, as well as
against DFL political activist Justin Perpich (“Perpich”) who merely retweeted and commented
on three of Brannon’s Twitter posts.
7. In his Complaint, Grant conspicuously omits any allegations of Brannon’s actual
malice, as he is required to do as a limited-purpose public figure pursuant to New York Times v.
Sullivan, 376 U.S. 254 (1964) and its progeny.
8. Grant’s lawsuit is a thinly veiled attempt to further his intimidation tactics to silence
Brannon and her sources from disclosing truthful information about the harassment and toxic
work environment at MN GOP under Carnahan and Grant.
2
9. Accordingly, Brannon asserts this counterclaim for a declaratory judgment pursuant to
the Minnesota Declaratory Judgment Act, Minn. Stat. § 555.01, et. seq., to vindicate her rights
with respect to her continued reporting about this matter of public concern.
PARTIES
10. Brannon is an individual who resides in Hennepin County, Minnesota.
11. Grant is an individual who, on information and belief, resides in Ramsey County,
Minnesota.
JURISDICTION AND VENUE
12. This Court has jurisdiction over this matter under Minn. Stat. § 484.01, subd. 1(1),
because this is a civil action arising in this District, and under Minn. Stat. § 555.01, because it is
vested with the authority to construe legal rights in this District.
13. Venue is proper in this Court under Minn. Stat. § 542.09 because one of the
Defendants is a resident of this District and the cause of action, or part of it, arose in this District.
FACTS
A. Brannon’s Journalism Career
14. Brannon graduated from Minnetonka High School in 2009 and attended Indiana
University and Ball State University from 2009 through 2013 to study communications.
15. In 2013, Brannon moved back to Minnesota and applied for and was hired in the
news room at KMSP-TV (Fox 9 News). Brannon subsequently was promoted to Assistant
Newscast Director at KMSP-TV.
16. In late 2016, Brannon left KMSP-TV and became an activist within Minnesota
Republican politics, working first for the Freedom Club, a Minnesota non-profit organized to
educate the public on conservative principles, and then on a succession of political campaigns on
3
behalf of MN GOP candidates during the 2018 election cycle for Attorney General, Governor
and Secretary of State. Brannon worked for these campaigns directly and has never served as a
staff member or employee of MN GOP.
17. Brannon has never worked with or against Grant on any political campaign.
18. After the 2018 election, Brannon grew disenchanted with the direction and operations
of MN GOP, and she terminated her activities as a MN GOP activist.
19. In early 2019, Brannon launched an independent photojournalism business engaged
in writing and producing news stories and multi-media projects for corporations, political
candidates and news organizations on an independent pay-per-project or hourly fee basis.
20. In the summer of 2020, one of Brannon’s photojournalism projects was reporting on
the violence occurring in Minneapolis in the aftermath of the murder of George Floyd. Brannon
produced multiple video reports documenting the violence and rioting in downtown and south
Minneapolis, and submitted several of these segments to Alpha News, a conservative Minnesota-
based news organization, which were subsequently published. Brannon never was employed by
Alpha News; instead, she worked solely as an independent journalist who was paid for each of
her stories that were accepted for publication by Alpha News and other news outlets.
21. Brannon has created and maintains an active social media presence related to her
reporting and photojournalism business, primarily using her Twitter account @RebsBrannon.
Brannon’s Twitter account is solely maintained by her and has over 15,000 followers. As is
customary for popular Twitter accounts, Brannon’s tweets are commented on and linked to by a
multitude and wide variety of people and organizations; however, her Twitter account is
unaffiliated with any organization or any other person.
B. Brannon’s Discovery of the Harassment and Toxic Work Environment at MN GOP

22. In her role as an independent photojournalist, Brannon traveled to Florida for the
4
Conservative Political Action Conference (“CPAC”) held from February 25–28, 2021.
Brannon’s reason for attending CPAC was to report on any protests or other newsworthy events
that might take place at or surrounding the conference.
23. Several MN GOP activists also were in attendance at CPAC 2021 and, upon seeing
Brannon, invited her to join an informal group dinner at a restaurant near the convention center,
an invitation which Brannon accepted. During that dinner, a number of activists discussed
Minnesota politics and the state of the MN GOP under Carnahan’s leadership with Brannon.
24. On the day following the group dinner, one of the MN GOP activists who was present
at the dinner (“Source #1) contacted Brannon and requested to meet separately with her to
discuss in more detail the MN GOP issues that had been discussed in general at the group dinner
the previous night.
25. During that detailed one-on-one discussion the following day, Source #1 reported to
Brannon that Spencer Krier (“Krier”), Operations Manager for MN GOP, in November 2020 had
traveled to Georgia on MN GOP business with a group of young Republican staff members in
order to assist in a vote recount. During Krier’s stay in Georgia, Source #1 reported that Krier
had provided alcohol to a minor female who was working for the Georgia Republican party and
then sexually assaulted her in his hotel room. Source #1 reported that in spite of multiple
individuals coming forward to support the allegations of sexual assault by Krier, no investigation
occurred and Krier remained employed as Operations Manager at MN GOP.
26. During the same discussion, Source #1 reported there had been a significant amount
of money misappropriated by Carnahan from MN GOP for her personal use through the
improper reimbursement of MN GOP expenses and personal travel.
27. During the same discussion, Source #1 reported that many former employees had
5
been coerced by Carnahan and her operatives into signing NDA’s which prevented the former
employees from disparaging Carnahan upon leaving employment at MN GOP.
28. During March 2021, Brannon met on three separate occasions with Source #1,
together with two additional women who are active in MN GOP activities (Sources #2 and #3),
to continue the discussion regarding the MN GOP. During the first of these three group meetings
on March 9, Source #2 recounted that Grant had harassed two young female MN GOP staffers
whom Grant falsely believed had created an off-color Twitter account critical of Carnahan
entitled “Gays 4 Jenny Hagedorn.” According to Source #2, Grant told one of these young
female staffers (who had nothing to do with the Twitter account) that if she did not take down the
account, “I’ll break your legs.” Source #3 corroborated Source #2’s recollection of Grant making
these violent threats to the young female staffer.
29. During the same series of group meetings, Source #2 reported that she personally was
harassed by Carnahan, with Carnahan outing Source #2 as a lesbian to party activists, donors and
other officials in an effort to undermine Source #2’s credibility. Source #2 has recently publicly
identified herself in an article published in Minnesota Reformer entitled “Former MNGOP
Political Director Says Party Chair Outed, Subjected Her to Months of Verbal Abuse” as
Francesca Zeller (“Zeller”). Zeller was hired as Political Director for MN GOP in January 2018
when she was 24 years old.
30. Following Zeller’s public criticism of Carnahan, Lazzaro jumped to Carnahan’s
defense on Facebook by labeling Zeller a “lunatic” and stating that Carnahan “doesn’t deserve
this type of nonsense. She just fights back.”
31. On information and belief, due to Carnahan’s blatant disregard for Source #2’s
privacy and repeated anti-LGBTQ harassment from activists due to Carnahan outing her as a
6
lesbian, Zeller quit her job at MN GOP, moved to Texas and no longer works in politics.
32. During the same series of group meetings, Source #1 referred to Grant as being one of
Carnahan’s “henchmen,” using that specific term. All three of the women in the group meetings
confirmed that Grant often acted as Carnahan’s enforcer in dealing with any criticism that
emanated within or toward MN GOP.
33. Brannon later spoke with Justin Sexton (“Sexton”), who admitted that he was the
person who created the “Gays 4 Jenny Hagedorn” Twitter account. Sexton confirmed that the
young female staffer whom Grant had threatened had no involvement with the Twitter account.
Sexton reported to Brannon that during the time period that the Twitter account was active, Grant
messaged the account on multiple occasions threatening the anonymous owner to the effect of,
“when I find out who you are, you are done in Minnesota forever.” Sexton reported that when he
discovered that Grant was threatening the young female staffer who had nothing to do with the
Twitter account, he took down the account and deleted all of the tweets.
34. On April 6, Brannon spoke by phone with Source #4, who is a former MN GOP
Executive Director who worked directly for Carnahan. Source #4 reported to Brannon that the
working environment at MN GOP is “worse than you think,” and added that, “I did not realize I
was walking into such a corrupt situation.”
35. By April 7, Brannon had incorporated the information she learned from the above-
mentioned sources, along with information she obtained from other sources, into a lengthy
investigative report detailing the toxic culture within MN GOP, the widespread demand for
NDA’s to silence victims, Krier’s alleged sexual assault in Georgia, and the financial
irregularities within MN GOP. Brannon intended to submit her investigative report to Alpha
News to be published.
7
36. In anticipation of the publication of her investigative report, Brannon emailed MN
GOP’s publicly-listed general email account to inquire for a comment. Later that day, Grant, on
behalf of MN GOP, called Brannon to respond to her inquiry.
37. Brannon then emailed Grant 13 questions for comment by MN GOP and/or Carnahan
related to the investigative report. In lieu of responding to any of the 13 questions, Grant replied
by requesting that a three paragraph statement written by Carnahan be included in the article.
The requested statement touted Carnahan’s success with MN GOP and characterized the
allegations as, “desperate attacks from my opponent’s failing campaign,” referring to her recent
re-election as Chair of MN GOP without addressing any of the specific allegations.
38. Grant also called Brannon to discuss the proposed article. In one telephone
conversation, Grant called the harassment reports, “crazy-assed statements,” adding “there’s a lot
of problems [at MN GOP] and I’m not here to defend everything,” but “we do not have any HR
complaints.”
39. In a telephone conversation with Brannon on September 9, Source #4 confirmed that
Grant had worked to kill Brannon’s story before it could be published at Alpha News. Source #4
stated to Brannon, “the fact that he’s denying that he tried to kill the story, I don’t know what
planet he lives on.” Source #4 added, “the thought that [Grant] didn’t try to stop the story – are
you delusional?”
40. Brannon also spoke with another young female former MN GOP staffer (Source #5)
who confirmed that Grant pressured her to sign an NDA that prevented her from criticizing
Carnahan after Source #5 left her job at MN GOP. Source #5 reported that Grant had accosted
her in person at the offices of MN GOP by handing her an NDA to sign, saying, “if you don’t
sign this, we’ll ruin your f’n career.”
8
41. Brannon also spoke with another young female former MN GOP staffer (Source #6)
who reported that Carnahan had personally threatened to destroy her future career when the
staffer left her job at MN GOP. Source #6 stated that Carnahan told her that if she shared any
damaging information about MN GOP with anyone, she’d “never be able to work in Minnesota
politics anymore.”
42. Brannon also spoke multiple times with Kayla Khang (“Khang”), another young
female former MN GOP staffer. Khang’s experience within the MN GOP recently has been
reported in an investigative article published in Salon entitled, “How the Minnesota GOP
Imploded: From a Toxic Workplace to a Full-Blown Sex Trafficking Scandal.”
43. As stated by Khang to Brannon, in response to an unrelated party’s tweet that
connected Carnahan in an unflattering manner with “daddy Daudt” (a reference to Minnesota
House Republican Minority Leader Kurt Daudt), Khang’s boyfriend had impulsively responded
on Twitter with a simple “like.” Khang reported to Brannon that shortly thereafter, as Khang was
riding in her boyfriend’s car, Grant called her boyfriend and threatened to break his legs if he
didn’t ‘unlike’ the tweet.
44. Khang also reported to Brannon that she overheard Grant telling people within MN
GOP offices that, “I could have them killed,” and, “I have hit men on deck” in response to public
criticism of Carnahan and MN GOP.
45. On his Twitter profile page, Grant states that his motto is, “Either Caesar or Nothing.”
46. Grant states on his Twitter account that he his ties to mafia culture:
9
47. Upon information and belief, Grant’s favorite fictional television character is Tony
Soprano, as played by the late actor James Gandolfini:
48. Khang reported to Brannon that Khang and her boyfriend attended a debate viewing
party at Grant’s luxury high-rise luxury condo overlooking the river in downtown St. Paul.
According to Khang, during the party Grant showed his guests “an astonishingly large amount of
cash” by “waving it around,” and that Grant was “always open with flashing his money.”
10
49. Khang also reported to Brannon that Grant frequently showed off his Acura NSX
automobile, a car that retails for over $150,000.
50. On information and belief, Grant is 27 years old, graduated from Hamline University
in 2017 with a B.A. degree in History, American Government and Politics, and, since graduation,
has been employed only in political staff positions.
51. After multiple revisions to Brannon’s article, Alpha News ultimately declined to
publish the article, citing to Brannon the length of the article and the detailed nature of the inside
politics contained therein that made it difficult for Alpha News’ audience to follow, as well as
the risk of a lawsuit for publishing a controversial investigative report on MN GOP.
52. Following Alpha News’ decision not to publish her investigative report, Brannon put
the draft article aside and moved on to other projects for the sake of both her mental health and
her business.
C. Brannon’s Twitter Reporting Following Lazzaro’s Sex Trafficking Indictment

53. On August 12, 2021, the U.S. Attorneys’ Office for the District of Minnesota
announced that Lazzaro had been indicted and arrested on federal sex trafficking charges for
allegedly recruiting six minor victims to engage in commercial sex acts.
54. Earlier in 2021, several former MN GOP employees had told Brannon they were
“freaked out” and “weirded out” around Lazzaro because they believed or knew there were
hidden cameras in his downtown Minneapolis condo, including the bathroom, while a MN GOP
event had been held there.
55. Following the disclosure of Lazzaro’s indictment, on August 12 Brannon posted a 12-
part thread on her Twitter account disclosing portions of her previously unpublished
investigative report concerning Carnahan’s misconduct and Lazzaro’s ties with the MN GOP. In
this Twitter thread, Brannon implored the Executive Committee members of the MN GOP to
11
conduct a full financial record audit and to ask for Carnahan’s resignation.
56. Also on August 13, Brannon posted a 31-part thread on her Twitter account detailing
the alleged harassment and sexual assault within the MN GOP that she had sourced in her prior
investigative reporting, including Grant’s threats and participation in the silencing of harassment
victims. A true and correct copy of this Twitter thread as published is attached hereto as Exhibit
1.
57. On the evening of August 13, Joe Dunham (“Dunham”), an attorney with the Taft
Stettinius & Hollister LLP law firm, called Brannon’s personal mobile phone number without
notice. Upon Brannon answering the phone, Dunham immediately stated that he represented
Grant and, without asking Brannon if she were represented by counsel, proceeded to proclaim
that Brannon’s tweets were “false, libelous and defamatory.” Dunham then stated that he
understood Alpha News had refused to publish Brannon’s story because it’s “a load of crap,” and
warned Brannon that if the story was not immediately taken down, “we will be taking
appropriate legal action against you.” In response, Brannon requested that Dunham put his
claims in writing so that she could share it with her lawyer, to which Dunham responded, “I’ll be
sending you a letter.”
58. No letter was ever received by Brannon from Dunham or any other lawyer
representing Grant.
59. Upon information and belief, on August 14, Perpich retweeted three of the individual
tweets from Brannon’s August 13 Twitter thread and added three comments of his own.
60. On information and belief, on August 14, the Executive Committee of MN GOP met
and approved a waiver of all NDA provisions for current and former MN GOP employees so that
they would be allowed to speak freely about the work environment at MN GOP.
12
61. On August 15, Brannon posted a 19-part thread on her Twitter account disclosing that
she had obtained recordings from multiple sources detailing the alleged questionable and
unethical behavior and toxicity of MN GOP under Carnahan. In this thread, Brannon included
details on alleged financial misappropriation by Carnahan which former MN GOP staffers had
previously shared with Brannon.
62. Also on August 15, Brannon posted an 18-part thread on her Twitter account that
included a statement released by the Minnesota College Republicans (“MCR”) confirming that a
young woman within MCR had been sexually harassed by a MN GOP employee and that
Carnahan was made aware of this incident yet failed to take action.
63. On August 18, four former Executive Directors of MN GOP, all of whom worked
directly for Carnahan in rapid succession between 2018 and 2021, released a joint statement
describing “the toxic environment, inappropriate behavior and manipulation that [Carnahan] has
facilitated.” Their joint statement added, “most disturbing of all, we now know by the multitude
of young women coming forward that Carnahan used her power to cover up allegations of sexual
harassment and abuse.”
64. On August 19, Andy Aplikowski (“Aplikowski”), one of the former Executive
Directors who issued the August 18 joint statement, released an additional statement confirming
that, due to the MN GOP Executive Committee’s recent waiver of his NDA, he could now
disclose that “Carnahan uses separation payments as a way of silencing staff as she shows them
his or her way out the door.” In his statement, Aplikowski attached the specific NDA provision
MN GOP forced on terminating employees (RPM = Republican Party of Minnesota):
13
65. On August 17, following the waiver of her NDA by MN GOP, Khang posted on
Facebook her report of Krier’s sexual assault and racial harassment of her while she worked at
MN GOP. Khang stated that on multiple occasions Krier “forced unsolicited hugs while pressing
my breasts against his chest,” and “put his hand on my upper butt/small of my back, and
routinely violated my personal space.” Khang, who is Asian American, also reported that Krier
made comments to her such as, “You look chinky today,” and, “Did you eat your dog yet?”
66. On August 19, Carnahan resigned as Chairwoman of the MN GOP.
67. On September 4, Brannon posted a 28-part thread on her Twitter account that
disclosed the internet video sites using the moniker “Tiny Teens” created by Lazzaro to
distribute his pornography, some of which was filmed in his downtown Minneapolis condo using
titles such as, “Summer Camp Teen Gets F***ed by Counselor.”
68. On information and belief, Perpich was served with the Complaint on August 26 in
Duluth, Minnesota.
69. On September 8 at 2:54pm, attorney Kathryn Babb of the Taft Stettinius & Hollister
LLP law firm emailed Howard Root, in his role as Brannon’s attorney, attaching the Summons
and Complaint and requesting waiver of service or acceptance of service. The requested waiver
was signed by Brannon later that evening and emailed back to Kathryn Babb the following
morning at 9:06 am.
D. Grant’s Public Relationship with MN GOP, Carnahan, Krier and Lazzaro
14
70. On his Instagram page and Twitter profile (which has almost 15,000 followers), Grant
touts himself as a “GOP Consultant” and “Republican Strategist” who appeared on WCCO-TV’s
Super Tuesday primary coverage:
71. Grant regularly has appeared on radio and audio podcasts, holding himself out to be a
leading political operative on Minnesota Republican issues, including on the popular Justice &
Drew morning show on Twin Cities talk radio station KTLK:
72. On information and belief, from December 2017 through February 2021, Grant was
first an associate and then a senior account executive with RightVoter, LLC, a campaign
consulting firm that provides campaign management services to Republican candidates in
15
Minnesota and throughout the country.
73. On information and belief, during 2020 Grant provided consulting services through
RightVoter, LLC to Lacy Johnson’s unsuccessful campaign for Minnesota’s Fifth Congressional
District. In doing so, Grant worked directly with Lazzaro, who served as Campaign Manager for
the Lacy Johnson campaign.
74. On information and belief, Grant was Campaign Manager for Carnahan’s successful
re-election campaign in 2019 for MN GOP chairperson. Following Carnahan’s re-election, Grant
congratulated her on the victory and commented that he was “proud to have managed” her
campaign:
75. On October 2, 2020, MN GOP issued a press release announcing that Grant had been
retained by MN GOP in a consulting capacity as “one of the most well-respected up and coming
political operatives in our state.”
16
76. On information and belief, during late 2020, Grant served on a de facto basis as the
interim executive director of MN GOP, reporting directly to Carnahan, following the resignation
of MN GOP’s former Executive Director Becky Alery.
77. On information and belief, since February 2021, Grant has been employed as Vice
President of Strategy for Arsenal Media, a public relations and communications firm specializing
in conservative campaigns and causes. Through Arsenal Media, Grant works on a number of
Republican campaigns in Minnesota and elsewhere.
78. On information and belief, in June 2021, Krier was hired by Arsenal Media as Senior
Client Manager, a position that Krier stated would involve working “alongside GOP pros like
@RealBillyGrant”:
79. Grant has publicly acknowledged Krier as “a great friend” on social media posts, as
shown below:
17
80. Krier has publicly acknowledged Grant as “one of his best friends” on social media
posts, as shown below:
18
81. On information and belief, Krier has worked with Grant on the Mark McCloskey
2022 campaign for U.S. Senate in Missouri as shown below:
82. On information and belief, Grant and Krier ran Carnahan’s successful 2021 re-
election campaign for MN GOP chairperson. Following Carnahan’s re-election in 2021, Grant
and Krier were congratulated on Facebook for “an incredible job running” Carnahan’s campaign,
with Carnahan giving the Facebook post a thumbs’ up “like” response:
19
83. Grant and Krier have interacted with Lazzaro on social media, one example of which
is shown below:
20
84. Starting in October 2019, Carnahan and Lazzaro co-hosted a public podcast entitled
#TruthMatters “to talk everything going on with the Republican Party of Minnesota.” Six
episodes of the podcast were produced before it abruptly ended in January 2020. In episode #4,
which was posted on November 3, 2019, Grant was a guest brought on to the podcast to talk
about Minnesota politics.
85. Carnahan introduced Grant on the episode by saying, “Now we’ve got one of our
friends – friends with both of us – um, Billy Grant on the phone,” to which Lazzaro says,
“Awesome.” Carnahan then continues, “Well I’m here with – with Tony – Tony Lazzaro – so
he’s cohosting with me on this podcast. We know we’ve both worked with you.”
86. At the end of the interview, Grant says, “Skol Vikings,” and Lazzaro says, “Yeah,
he’s a huge fan.” The podcast episode summary is shown below:
21
87. Upon information and belief, Grant has attended several social and/or political
functions at Lazzaro’s luxury condo residence in the Ivy Hotel in downtown Minneapolis.
88. On August 14, 2021 (i.e., two days after Lazzaro’s arrest), Grant published a
statement regarding Lazzaro on both his Twitter and Facebook social media accounts, expressing
shock that “someone I thought I knew” was charged with such despicable conduct:
22
89. On August 14, 2021, Grant retweeted statements from two of the Minnesota
campaigns he manages – Doug Wardlow for Attorney General and Tyler Kistner for Congress in
Minnesota’s Second District – distancing those campaigns from Lazzaro:
E. Brannon’s Future Statements Regarding Grant and the MN GOP
90. Brannon wishes to continue to speak regarding these matters of public concern and,
accordingly, seeks a declaratory judgment that the statement attached as Exhibit 2 hereto is not
defamatory.
91. Because Grant has commenced this lawsuit against Brannon, and because Brannon
wishes to continue to speak with respect to this matter of public concern, a present and adverse
interest exists between the parties and a justiciable controversy has arisen from this dispute under
the Minnesota Declaratory Judgment Act, Minn. Stat. §555.01.
COUNT I: DECLARATORY JUDGMENT
92. Brannon realleges each allegation of this Complaint as if fully set forth herein.
93. Grant has inserted himself into the public controversy with respect to the
statements attributed to Brannon.
94. Grant is a limited-purpose public figure with respect to the statements attributed
23
to Brannon.
95. The statements attributed to Brannon as the basis for this Complaint are true or
substantially true.
96. Grant has failed to allege actual malice.
97. The statements attributed to Brannon as the basis for Grant’s Complaint are
privileged because Grant is a limited-purpose public figure.
98. The statements attributed to Brannon as the basis for Grant’s Complaint are
related to a matter of substantial public interest and concern.
99. Brannon acted without malice in all of her conduct relating to the statements
attributed to Brannon as the basis for this Complaint.
100. Brannon did not make any false statements about Grant.
101. Brannon did not make any defamatory statements about Grant.
PRAYER FOR RELIEF
WHEREFORE, there being a present and adverse interest between the parties and a
justiciable controversy arising from this dispute, Brannon requests that the Court grant relief by
declaring the rights of the parties under the Minnesota Declaratory Judgment Act, Minn. Stat. §
555.01, et seq., and Brannon prays for a declaration and judgment against Grant as follows:
1. That Grant is a limited-purpose public figure with respect to the statements attributed
Brannon as the basis for this Complaint;
2. That the statements made by Brannon to date regarding Grant are true or substantially
true;
3. That the statements made by Brannon about Grant are protected as commentary on a
matter of substantial public concern;
24
4. That Brannon has not made any statements about Grant with actual malice;
5. That Brannon has not defamed Grant;
6. That the statements attached hereto as Exhibit 2 are not defamatory to Grant;
7. That Grant has no valid claim against Brannon;
8. That such claims brought by Grant against Brannon shall be dismissed with prejudice;
9. That the Court award Brannon her costs and disbursements; and
10. That the Court grant such other and further relief as it deems fair, equitable, and in the
interests of justice.
ANSWER TO COMPLAINT
Defendant/Counterclaim Plaintiff Rebecca Brannon (“Brannon”), for her Answer to
Plaintiff/Counterclaim Defendant William T. Grant’s (“Grant”) Complaint, denies each and
every allegation, matter or thing set forth in Grant’s Complaint, except as hereinafter specifically
admitted, qualified or otherwise addressed, and further responds as follows:
1. Brannon lacks information sufficient to form a belief as to the allegations of paragraph
1 of the Complaint and therefore denies the same.
3. Brannon admits the allegations in paragraph 3 of the Complaint.
25
10. Brannon lacks information sufficient to form a belief as to the allegations of
paragraph 10 of the Complaint and therefore denies the same.
14. Brannon denies the allegations in paragraph 14 of the Complaint.
15. Brannon admits that, on her Twitter feed, she has stated that she has “stepped away
from the inner circle of activism a few years [sic] to avoid further harassment from Carnahan
myself . . . .” Brannon denies that she has ever been a staff member of the MN GOP. Brannon
denies the remainder of the allegations in paragraph 15 of the Complaint.
16. Brannon admits that she is the sole owner of the Twitter account bearing the handle
@RebsBrannon. Brannon admits that she has “tweeted” over 3,500 tweets and has nearly 16,000
followers. Brannon denies that she holds any title or position with Alpha News. Brannon denies
the remainder of the allegations in paragraph 16 of the Complaint.
17. Brannon admits that she published the excerpts of tweets posted on the
@RebsBrannon Twitter account contained in paragraph 17 of the Complaint, with additional
26
context provided in the full tweets. Brannon denies the remainder of the allegations in paragraph
17 of the Complaint.
18. Brannon admits that portions of the tweets identify Grant. Brannon denies the
remainder of the allegations in paragraph 18 of the Complaint.
19. Paragraph 19 is not directed at Brannon and no response is required. To the extent a
response is required, Brannon lacks information sufficient to form a belief as to the allegations of
24. Brannon denies that she has made false statements about Grant. Brannon lacks
information sufficient to form a belief as to the remaining allegations of paragraph 24 and
therefore denies the same.
27
25. Brannon denies that she has made false statements about Grant. Brannon lacks
information sufficient to form a belief as to the remaining allegations of paragraph 25 and
therefore denies the same.
27. Brannon admits that on Twitter a person wrote those words in response to one of
Perpich’s tweets. Brannon lacks information sufficient to form a belief as to the remainder of the
allegations of paragraph 27 of the Complaint and therefore denies the same.
28
35. Brannon denies having made false and defamatory accusations against Grant.
Brannon lacks information sufficient to form a belief as to the remainder of the allegations of
36. Brannon denies the allegations contained in paragraph 36.
ANSWER TO COUNT I: DEFAMATION
39. Brannon repeats and incorporates by reference her Counterclaim and her responses to
paragraphs 1 through 38 to the Complaint as though fully set forth herein.
40. To the extent Paragraph 40 of the Complaint is not directed at Brannon, no response
is required. Brannon denies the allegations contained in paragraph 40 of the Complaint.
ANSWER TO COUNT II: DEFAMATION PER SE
29
ANSWER TO COUNT III: TORTIOUS INTERFERENCE
ANSWER TO COUNT IV: INJUNCTIVE RELIEF
30
60. Brannon hereby demands a trial by jury on all counts so triable.
AFFIRMATIVE DEFENSES
61. Brannon expressly and specifically reserves the right to amend this Answer to add,
delete or modify affirmative defenses based on legal theories, facts and circumstances which
may or will be developed and to allege any other affirmative defenses contained in Rule 8.03 of
the Minnesota Rules of Civil Procedure as necessary as discovery proceeds in this matter. The
affirmative defenses are alleged herein in an abundance of caution to preserve defenses; Brannon
affirmatively states that she maintains that the majority of the affirmative defenses alleged below
comprise elements of claims upon which Grant, and not Brannon, bears the burden of proof.
FIRST AFFIRMATIVE DEFENSE
Grant’s Complaint fails to state a claim upon which relief may be granted, and to which
judgment on the pleadings should be granted.
SECOND AFFIRMATIVE DEFENSE
The statements attributed to Brannon as the basis for this Complaint are true or
substantially true and Grant cannot carry his burden of proving that the statements are false.
31
THIRD AFFIRMATIVE DEFENSE
Grant’s claims are barred by his failure to allege and prove malice, including actual
malice.
FOURTH AFFIRMATIVE DEFENSE
At all times relevant to the Complaint, grant was a limited-purpose public figure and the
statements attributed to Brannon were accordingly privileged. Thus, Grant’s claims are barred by
his failure to allege and prove malice, including actual malice.
FIFTH AFFIRMATIVE DEFENSE
The statements attributed to Brannon as the basis for this Complaint related to a matter of
substantial public interest and concern.
SIXTH AFFIRMATIVE DEFENSE
Brannon acted without malice, in both the Constitutional sense and the common law
sense, in all of her conduct relating to the statements attributed to Brannon as the basis for this
Complaint.
SEVENTH AFFIRMATIVE DEFENSE
Brannon acted without the requisite scienter, in both the Constitutional sense and the
common law sense, in all of her conduct relating to the statements attributed to Brannon as the
basis for this Complaint.
EIGHTH AFFIRMATIVE DEFENSE
Brannon acted without fault as required by the United States Constitution in all of her
conduct relating to the statements attributed to Brannon as the basis for this Complaint.
32
NINTH AFFIRMATIVE DEFENSE
Grant’s claims are barred, in whole or in part, by the First and Fourteenth Amendments to
the United States Constitution and applicable law.
TENTH AFFIRMATIVE DEFENSE
Grant’s claims are barred, in whole or in part, by the Minnesota Constitution and
applicable law.
ELEVENTH AFFIRMATIVE DEFENSE
The statements attributed to Brannon as the basis for this Complaint are statements of
opinion, not fact, and are therefore not actionable.
TWELVTH AFFIRMATIVE DEFENSE
Grant has not sustained any actual injury by reason of the statements attributed to
Brannon as the basis for this Complaint.
THIRTEENTH AFFIRMATIVE DEFENSE
Brannon’s conduct was not the proximate cause of any injury to Grant.
FOURTEENTH AFFIRMATIVE DEFENSE
Grant’s alleged damages, if any, are the result of his own conduct or the conduct of others
beyond Brannon’s control and for whom Brannon is not legally responsible.
FIFTEENTH AFFIRMATIVE DEFENSE
Grant’s claims are barred in whole or in part because he failed to allege special damages
with specificity as required by Minn. R. Civ. P. 9.07.
33
SIXTEENTH AFFIRMATIVE DEFENSE
Grant’s claims are barred because the statements allegedly made by Brannon were made
without malicious intent, on proper occasion, with a proper motive, and based upon reasonable
grounds and/or probable cause.
SEVENTEENTH AFFIRMATIVE DEFENSE
Grant has failed to mitigate his damages as required by law.
EIGHTEENTH AFFIRMATIVE DEFENSE
Grant’s claims are barred, in whole or in part, by the equitable doctrines of, inter alia,
unclean hands, waiver, laches, estoppel and assumption of risk.
WHEREFORE, Brannon requests that the Court enter judgment in her favor and against
Grant, award Brannon her costs, and grant to Brannon such other and further relief as the Court
may deem just.
Date: October 4, 2021 By: /s/ Howard Root

Howard Root (#0169523)
North Star Legal Foundation, P.C.

25 Fairhope Avenue
Tonka Bay, MN 55331
Phone: 612-327-7976
roothoward@gmail.com
and
Michele R. Wallace (#262304)

Michele R. Wallace, PA
2585 Hamline Ave. N, #A
Roseville, MN 55113
(612) 281-8804
mrwmnlaw@gmail.com
Attorneys for Defendant/Counterclaim Plaintiff

Rebecca Brannon
34
ACKNOWLEDGEMENT
The undersigned hereby acknowledges that, pursuant to Minn. Stat. §549.211, subd. 2,
costs, disbursements, and reasonable attorney and witness fees may be awarded to the opposing
party or parties in this litigation if the Court should find that the undersigned acted in bad faith,
asserted a claim or defense that is frivolous and that is costly to the other party, asserted an
unfounded position solely to delay the ordinary course of the proceedings or to harass, or
committed a fraud upon the Court.
Date: October 4, 2021 By: /s/ Howard Root

Howard Root (#0169523)
North Star Legal Foundation, P.C.

25 Fairhope Avenue
Tonka Bay, MN 55331
Phone: 612-327-7976
roothoward@gmail.com
and
Michele R. Wallace (#262304)

Michele R. Wallace, PA
2585 Hamline Ave. N, #A
Roseville, MN 55113
(612) 281-8804
mrwmnlaw@gmail.com
35
EXHIBIT 1
36
37
38
39
40
41
42
43
EXHIBIT 2
44
Statement of Rebecca Brannon
Billy Grant and Jennifer Carnahan worked closely together on many matters at MN GOP over the
years, including Grant managing Carnahan’s campaign for reelection as Chairwoman in 2019. By working
closely with Carnahan, Grant not only knew that she ruled MN GOP with abusive rants and widespread
harassment; he furthered that toxic culture by making threats and intimidating victims into silence.
Grant acted as Carnahan’s enforcer by threatening several employees into signing non-
disparagement agreements (NDA’s) as they left employment at MN GOP. These NDA’s prevented former
employees from making any comments that would be critical or tend to injure the reputation of
Carnahan. To coerce these primarily young women into signing an NDA, Grant threatened to damage
their future careers and used his physically imposing size to scare the employees with mafia-style
threats.
These NDA’s were used to silence victims of sexual harassment and sexual assault, and thereby
conceal the abuse of young women employees of MN GOP. Spencer Krier is one of Grant’s close friends,
and Krier has worked with Grant on campaigns and other political activity. Krier has been credibly
accused of sexual assault and racial harassment by at least one young female employee of MN GOP, but
no action was ever taken against Krier. Grant helped perpetrate the silence of Krier’s victim through his
enforcement of NDA’s and his own threats to the victim’s career.
Grant also was friends with Tony Lazzaro. They worked together on Lacy Johnson’s campaign for
Congress in 2020, with Lazzaro being the Campaign Manager and Grant being a campaign consultant
and strategist. They discussed Vikings football and other social topics openly on Facebook and Twitter.
And on a podcast that Grant appeared on, Carnahan publicly stated the three of them (that is, Carnahan,
Lazarro, and Grant) were “friends.”
It is reprehensible that Grant engaged in mafia-style tactics to enforce silence at MN GOP

concerning widespread harassment and sexual assaults. It also is reprehensible that Grant kept company
with abusers and refused to speak up for victims. Billy Grant hasn’t been defamed because of my
tweets: instead, he is suffering consequences because of his own misconduct.
45

Rebecca Brannon Answer &amp; Counterclaim

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Rebecca Brannon Answer &amp; Counterclaim

Uploaded by

Copyright:

Available Formats

STATE OF MINNESOTA DISTRICT COURT

COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT

William T. Grant, Court File No. 27-CV-21-10948

v. COUNTERCLAIM AND ANSWER

Defendant/Counterclaim Plaintiff, JURY TRIAL DEMANDED

COUNTERCLAIM OF DEFENDANT/COUNTERCLAIM PLAINTIFF REBECCA

William T. Grant (“Grant”), states and alleges as follows:

NATURE OF THE ACTION

1. This action concerns Grant’s efforts to silence Brannon, a courageous independent

2. Much of the harassment disclosed by Brannon targeted young female MN GOP

enter into non-disparagement agreements (“NDAs”).

Carnahan lieutenant is Grant.

Lazzaro (“Lazzaro”), who recently was indicted on federal sex-trafficking charges.

6. In spite of his status as a public figure in MN GOP politics, Grant commenced a

on three of Brannon’s Twitter posts.

7. In his Complaint, Grant conspicuously omits any allegations of Brannon’s actual

malice, as he is required to do as a limited-purpose public figure pursuant to New York Times v.

Sullivan, 376 U.S. 254 (1964) and its progeny.

work environment at MN GOP under Carnahan and Grant.

10. Brannon is an individual who resides in Hennepin County, Minnesota.

JURISDICTION AND VENUE

vested with the authority to construe legal rights in this District.

A. Brannon’s Journalism Career

Newscast Director at KMSP-TV.

staff member or employee of MN GOP.

of MN GOP, and she terminated her activities as a MN GOP activist.

19. In early 2019, Brannon launched an independent photojournalism business engaged

candidates and news organizations on an independent pay-per-project or hourly fee basis.

unaffiliated with any organization or any other person.

B. Brannon’s Discovery of the Harassment and Toxic Work Environment at MN GOP

that might take place at or surrounding the conference.

the previous night.

occurred and Krier remained employed as Operations Manager at MN GOP.

improper reimbursement of MN GOP expenses and personal travel.

employees from disparaging Carnahan upon leaving employment at MN GOP.

these violent threats to the young female staffer.

identified herself in an article published in Minnesota Reformer entitled “Former MNGOP

when she was 24 years old.

30. Following Zeller’s public criticism of Carnahan, Lazzaro jumped to Carnahan’s

this type of nonsense. She just fights back.”

emanated within or toward MN GOP.

was walking into such a corrupt situation.”

behalf of MN GOP, called Brannon to respond to her inquiry.

re-election as Chair of MN GOP without addressing any of the specific allegations.

39. In a telephone conversation with Brannon on September 9, Source #4 confirmed that

sign this, we’ll ruin your f’n career.”

Imploded: From a Toxic Workplace to a Full-Blown Sex Trafficking Scandal.”

43. As stated by Khang to Brannon, in response to an unrelated party’s tweet that

connected Carnahan in an unflattering manner with “daddy Daudt” (a reference to Minnesota

didn’t ‘unlike’ the tweet.

criticism of Carnahan and MN GOP.

Soprano, as played by the late actor James Gandolfini:

automobile, a car that retails for over $150,000.

has been employed only in political staff positions.

the risk of a lawsuit for publishing a controversial investigative report on MN GOP.

C. Brannon’s Twitter Reporting Following Lazzaro’s Sex Trafficking Indictment

allegedly recruiting six minor victims to engage in commercial sex acts.

event had been held there.

sending you a letter.”

previously shared with Brannon.

harassment and abuse.”

MN GOP forced on terminating employees (RPM = Republican Party of Minnesota):

66. On August 19, Carnahan resigned as Chairwoman of the MN GOP.

titles such as, “Summer Camp Teen Gets F***ed by Counselor.”

Rebecca Brannon Answer & Counterclaim

Rebecca Brannon Answer & Counterclaim