June 15, 2022

Sent Via Certified Mail and Electronic Mail

David Wheeler
American Muckrakers PAC
P.O. Box 51
Spruce Pine, NC 28777

Mr. Wheeler:

This law firm represents Congresswoman Lauren Boebert related to false and defamatory
statements published by the American Muckrakers PAC, Inc. (“Muckrakers”), an Independent
Expenditure-Only Committee registered with the Federal Election Commission. David Wheeler
serves as the Treasurer of the Committee and Muckrakers activities are funded by publicly
reported individual donor sources. While Muckrakers has marketed itself as a “watchdog group,”
the truth is that Muckrakers is a political committee that exclusively opposes conservative
candidates, is funded by established Democrat donor sources, and is managed by Democrat
political operatives.

On May 19, 2022, Muckrakers’ Treasurer David Wheeler (“Wheeler”) declared in

published statements that “we’re gonna go after Lauren Boebert in Colorado.” Between June 9,
2022, and June 14, 2022, Muckrakers published a series of false and defamatory statements
about Lauren Boebert that included but are not limited to:

• “Lauren Boebert was an unlicensed, paid escort and met clients through
SugarDaddyMeet.com. Text messages show she was bankrupt at the time and looking for
‘side income’ and called her work ‘pay for play.’ She was paid to ‘escort’ wealthy men.”
Falsely claiming the Congresswoman worked as a prostitute is a disgusting and sexist
statement that, as you know, has zero basis in fact. Further, she has never filed for
bankruptcy.
• “According to our investigation, Boebert was hired by a wealthy male client in Aspen,
Colorado who was a Koch family member.” This statement is a total fabrication with no
semblance of truth that defames more than one party. The Congresswoman has never
had any form of a relationship with anyone from the Koch family.
• Muckrakers published damaging photographs claiming them to be Congresswoman
Boebert. As has been reported by multiple media sources, even a simple web search
would reveal that these were not photos of Lauren Boebert. One media source made this
fact clear: “As a matter of fact, one of the pictures of Boebert displayed as the supposed
proof that she once worked as a sugar baby escort is not the lawmaker. A picture used by
 Notice of Claims: Muckrakers/Wheeler
Page 2

American Muckraker in their dishonest smear campaign against Boebert is actually

Melissa Carone.”1
• “Boebert Had Two Abortions - One At Planned Parenthood…Boebert had an abortion at
a clinic in Grand Junction, Colorado, sometime in 2004 or 2005 when she was
approximately eighteen years old. Then, Boebert, twenty-three at the time had an
abortion in 2009 at the Planned Parenthood Clinic in Glenwood Springs, Colorado, ‘due
to her work with a sugardaddymeet.com client.’” This is another patently false statement
and it is unbelievable that any group would recklessly push on a woman. To be clear,
Rep. Boebert was pregnant with her first son in 2004 and 2005 and he was born in 2005,
she was pregnant with her third son in 2008 and 2009 and he was born in 2009, and she
has never had an abortion.
• Publishing a false text message claiming “she was stripping at the time also.” This
statement is patently false and the Congresswoman has never been a stripper.
• Publishing a false text message regarding Congresswoman Boebert and her husband and
claiming: “They had a meth drug problem at the time.” This statement is also patently
false.
• “Boebert uses donor money to pay taxes and restaurant rent.” Both statements are false.
These same false claims were dismissed by the Federal Election Commission in a
publicly reported document.
• “Jayson Boebert has a ‘consulting; contract for an oil and gas company for $460,000 a
year but has zero consulting experience.” This statement is false.
• “Drunk Lauren…Boebert nearly killed her sister-in-law during a drunk driving
accident…Lauren Boebert was driving an off road 4x4 vehicle while under the influence
of alcohol…Boebert had been drinking alcohol either prior or during the
incident…Anyone that drives drunk with their child in the vehicle and nearly kills a
passenger due to their drunken negligence is not fit to hold public office.” This statement
is false and we have evidence that this statement was published after your own “source”
informed you by text message that this story was “Totally made up.” Further,
Congresswoman Boebert doesn’t drink alcohol and no alcohol was involved in the actual
vehicle accident.
• “Boebert…actively works to cover up the accident two weeks before the primary
election, including paying her sister-in-law off to remain silent.” Both statements are
categorically false. The Congresswoman did not cover up an accident and the accident
didn’t occur during a political campaign- the actual accident happened seven months
before the Congresswoman even filed for office.
• “Boebert bails out of vehicle leaving son and dog behind before crash.” This statement is
false. Congresswoman Boebert was actually ejected from the vehicle during the accident.

1
Big League Politics, 06/14/2022, https://bigleaguepolitics.com/exclusive-american-muckraker-
pac-uses-fake-picture-to-smear-lauren-boebert-as-prostitute/.
 Notice of Claims: Muckrakers/Wheeler
Page 3

• “Sister-in-law flown to hospital with life threatening injuries. This statement is false. No
one was flown to a hospital as a result of this accident.
We have irrefutable evidence that each one of these statements is patently false. You knew
this though. Muckrakers published these outlandish statements knowing they were fabricated
but you likely operated under the inaccurate assumption that publishing false statements against
a public figure would not create legal liability. This will be a costly miscalculation for
Muckrakers, Wheeler and Muckrakers’ donors.

Proving a defamation claim against a public figure does in fact fall under a heightened
standard of proof - it not only requires proof that the statement was false but requires evidence
that the defendant knew or should have known the statement to be false. What is legally, and
financially, disastrous for Muckrakers is the fact that we also have evidence, including internal
Muckrakers’ text and email communications, that demonstrates Muckrakers did in fact publish
statements knowing those statements to be false. Further, numerous statements and images were
published by Muckrakers that, with even a 5-minute web search, Muckrakers knew would be
false. Muckrakers’ sloppy, reckless, and wildly irresponsible actions have created substantial
legal liability for Muckrakers, David Wheeler in his personal capacity, and each donor to the
organization who chose to fund the effort knowing it would result in defamation.

In addition to the civil defamation claims that will be filed, Muckrakers’ actions are
criminally liable. Colorado statute expressly prohibits the circulation of "knowingly or
recklessly" false information meant to influence an election. In addition, Wheeler also sent letters
to the State of Utah and State of Colorado requesting an investigation. Wheeler’s letters contain
multiple knowingly false statements. Utah and Colorado each classify the filing of false reports
as criminal conduct. Muckraker’s illegal conduct has created substantial criminal liability for the
organization as well as individuals personally engaged in circulating false statements.

If either Muckrakers, or David Wheeler in his personal capacity, are represented by legal
counsel please provide me with the name(s) of counsel so that impending communications and
service of process related to this legal matter are properly directed to counsel.

Sincerely,

Jonathan Anderson