US DOMINION, INC., DOMINION VOTING SYSTEMS, INC., and DOMINION VOTING SYSTEMS CORPORATION
c/o Cogency Global
1025 Vermont Ave, NW, Ste. 1130
Washington, DC 20005,

Plaintiffs,

v.

MY PILLOW, INC. and MICHAEL J. LINDELL
343 E 82nd Str #102
Chaska, MN 55318,

Defendants.

COMPLAINT AND DEMAND FOR JURY TRIAL

1. After hitting the jackpot with Donald Trump’s endorsement for MyPillow and after a million-dollar bet on Fox News ads had paid out handsome returns, Michael Lindell exploited another chance to boost sales: marketing MyPillow to people who would tune in and attend rallies to hear Lindell tell the “Big Lie” that Dominion had stolen the 2020 election. As when MyPillow previously faced legal action for deceptive marketing campaigns, Lindell knew there was no real “evidence” supporting his claims. And he is well aware of the independent audits and paper ballot recounts conclusively disproving the Big Lie. But Lindell—a talented salesman and former
professional card counter—sells the lie to this day because the lie sells pillows. MyPillow’s defamatory marketing campaign—with promo codes like “FightforTrump,” “45,” “Proof,” and “QAnon”—has increased MyPillow sales by 30-40% and continues duping people into redirecting their election-lie outrage into pillow purchases.

2. Bipartisan election officials, judges, 59 election security experts, Attorney General Bill Barr, Trump appointee Chris Krebs, Georgia’s Republican Governor Brian Kemp, Georgia’s Republican Secretary of State Brad Raffensperger, Colorado’s former Republican Secretary of State Wayne Williams, and others have rebutted Lindell’s false claims about Dominion.

3. Most importantly though, paper ballots are the hard evidence conclusively disproving Lindell’s claims. If the vote tallies in Dominion machines had been manipulated, the machine tallies would not match the number of votes on the paper ballots. In fact, they do match, as independent audits and hand recounts have repeatedly proven. The contrary “evidence” put forward by Lindell’s allies—including Sidney Powell, L. Lin Wood, and others—was deliberately misrepresented, manufactured, cherry-picked, and sourced from con artists and conspiracy theorists who were judicially determined to be “wholly unreliable.” Lindell knows all of this because Dominion wrote to him multiple times, put him on formal written notice of the facts, and told him that Dominion employees were receiving death threats because of the lies.

4. Instead of retracting his lies, Lindell—a multimillionaire with a nearly unlimited ability to broadcast his preferred messages on conservative media—whined that he was being “censored” and “attacked” and produced a “docu-movie” featuring shady characters and fake documents sourced from dark corners of the internet.

5. Through discovery, Dominion will prove that there is no real evidence supporting the Big Lie. Dominion brings this action to vindicate the company’s rights, to recover damages, to seek a narrowly tailored injunction, to stand up for itself and its employees, and to stop Lindell and MyPillow from further profiting at Dominion’s expense.

KINGSTON, N.Y. — Just 48 hours after Ulster County Executive Pat Ryan unveiled plans to launch a Universal Basic Income pilot program in the county, more than 1,500 people had applied to participate.

Through the program, 100 eligible Ulster County households will receive a guaranteed $500 monthly income from May 1, 2021, to April 30, 2022, for a total of $6,000 per recipient.

The outpouring of applications, he said, speaks to the dire financial straits that many community members find themselves and the need for government leaders to find new and innovative ways to address the needs of their communities.

"It's a sad validation of how much need there is right now," Ryan said during an interview Thursday, Feb. 18, a day after announcing plans for the program during his State of the County address.

Social contact with loved ones will take precedence over the reopening of shops and hospitality when Boris Johnson sets out his roadmap for lifting restrictions in England on Monday, with school sports and family picnics offered as a trade-off for a longer closure of retail and restaurants.

Johnson will order the reopening of all schools on 8 March and pledge that two families or a group of six friends will be allowed to meet outdoors three weeks later, the Guardian understands.

He will set out a four-stage lockdown plan for the easing of the restrictions that touch almost every corner of daily life, with several weeks between each phase of reopening.

The roadmap will include:
- Rules relaxed on 8 March to permit two friends to meet for coffee outdoors.
- School sports and activity clubs to resume outside when schools reopen.
- Six friends – or two households – can meet outside from Easter.
- Sports such as tennis and basketball will resume from 29 March.

(CNN)With the US approaching 500,000 Covid-19 deaths, President Joe Biden will mark the grim milestone Monday with a candle lighting ceremony and a moment of silence, the White House said Sunday.

The event, which is set for 6:15 p.m. ET at the White House, will also feature first lady Jill Biden, Vice President Kamala Harris and second gentleman Doug Emhoff. Biden will deliver remarks on the lives lost ahead of the ceremony.

The ceremony underscores the empathetic message Biden has sought to bring to the US coronavirus response since taking office last month -- a departure from his predecessor. On Friday, White House press secretary Jen Psaki said the administration was working on plans so the President could use his "own voice and platform to take a moment to remember the people whose lives have been lost, the families who are still suffering."

One day before taking office, Biden, Harris and their spouses held a somber ceremony at the Lincoln Memorial to commemorate the 400,000 lives lost to Covid-19 in the US at the time.

Sen. Susan Collins (R-Maine) will not vote to confirm President Biden's nominee to lead the Office of Management and Budget, Neera Tanden, according to a statement first obtained by Politico.

Why it matters: The moderate Republican was viewed as a possible savior to Tanden's nomination, after Sen. Joe Manchin (D-W.Va.) became the first Democratic senator to oppose one of Biden's nominees last week.

Tanden has faced scrutiny for her social media activity during the Trump presidency, during which she frequently attacked Republicans.

Tanden, who once called Collins "the worst" on Twitter, apologized for her tweets during her confirmation hearings.

In his first post-presidential appearance, Donald Trump plans to send the message next weekend that he is Republicans' "presumptive 2024 nominee" with a vise grip on the party's base, top Trump allies tell Axios.

What to watch: A longtime adviser called Trump's speech a "show of force," and said the message will be: "I may not have Twitter or the Oval Office, but I'm still in charge." Payback is his chief obsession.

Axios has learned that Trump advisers will meet with him at Mar-a-Lago this week to plan his next political moves, and to set up the machinery for kingmaking in the 2022 midterms.

Trump is expected to stoke primary challenges for some of those who have crossed him, and shower money and endorsements on the Trumpiest candidates.