SUPREME COUF OF QUEENS! NO ypreme court oF QUEENSLAND 27 JAN 2015 REGISTRY: BRISBANE FILED NUMBER: | of 2016 First Plaipit| SBANE CAMPBELL NEWMAN ps 82° AND ‘Second Plaintif JEFFREY SEENEY AND First Defendant: ALAN JONES AND ( Second Defendant: RADIO 4BC BRISBANE PTY LIMITED ACN 009 662 784 TRADING AS RADIO STATION 4BC CLAIM The Plaintiffs claim: 1. General compensatory damages. 2. Aggravated damages. 3. Interest, 4. Costs. ‘The Plaintiffs make this claim in reliance on the facts alleged in the attached Statement of Claim. CLAIM CiarkeKann Filed on behalf of the First and Second Plaintiffs Level 7 Form 2-R.22 300 Queen Stroot BRISBANE 4000 Phone 07 3001 9222 Fax 07 3001 9299 so2e121tTo the Defendant: TAKE NOTICE that you are being sued by the Plaintiffs in the court. If you intend to dispute this Claim or wish to raise any counterclaim against the Plaintiffs, you must within 28 days of the service Uupon you of this claim file a Notice of Intention to Defend in this Registry. if you do not comply with this requirement judgment may be given against you for the relief claimed and costs without further notice to you. The Notice should be in Form 6 to the Uniform Civil Procedure Rules. You must serve a sealed copy of itat the Plaintiffs’ address for service shown in this claim as soon as possible. Address of Registry: QE11 Courts of Law Complex, 415 George Street, Brisbane 4000 lf you assert that this court does not have jurisdiction in this matter or assert any irregularity you ‘must file a Conditional Notice of Intention to Defend in Form 7 under Rule 144, and apply for an order under Rule 16 within 14 days of fling that Notice. If you object that these proceedings have ‘not been commenced in the correct district of the Court, that objection must be included in your Notice of Intention to Defend, ‘The Plaintiffs rely on the cross-vesting laws in respect of each claim. PARTICULARS OF THE PLAINTIFFS: Name: Campbell Newman Residential or business address: 66-68 Bowen Street, Spring Hill 4000 Name: Jeffrey Seeney Residential or business address: 66-68 Bowen Street, Spring Hill 4000 Solicitor's name: ‘Shane Williamson and firm name: ‘ClarkeKann Solicitor's business address: Level 7, 300 Queen Street, Brisbane. Address for service: Level 7, 300 Queen Street, Brisbane. Dx ery ‘Telephone: 3001 9222 eal eden fan aula sonGelaotann.com. au sig Qe Description: Solicitor for the First and Second Plaintiffs Dated: 22 January 2015 201214This application is to be served on: of: of: 33291214 ‘Alan Jones Level 1, Building C, 33-35 Saunders Street, Pyrmont NSW 2009 Radio 48C Brisbane Pty Limited ACN 009 662 784 trading as Radio Station 4BC 1 Darling Island Road, Pyrmont NSW 2008SUPREME COURT OF QUEENSLAND REGISTRY: BRISBANE NUMBER: of 2015, First Plaintif CAMPBELL NEWMAN ‘AND Second Plaintift JEFFREY SEENEY ‘AND First Defendant: ALAN JONES AND ‘Second Defendant: RADIO 4BC BRISBANE PTY LIMITED ACN 009 662 784 TRADING AS RADIO STATION 4BC Filed in the Brisbane Registry on: ‘STATEMENT OF CLAIM This Claim in this proceeding is made in reliance on the following facts: 1. Atall material times the First Plaintiff was the Premier of Queensiand, 2, Atall material times the Second Plaintiff was the Deputy Premier of Queensland. 3, tall material times the Second Defendant was incorporated and capable of being sued in its corporate name and style. 4, The Second Defendant is and was at all material times the licensee of 4BC, a commercial radio station transmitting throughout the State of Queensland. 5. On 19 January 2015 the Defendants published in the State of Queensland, of and concerning the each of the Piaintifs, the matter set forth in Schedule "A" attached hereto (‘the first matter complained of"). ‘STATEMENT OF CLAIM ClarkeKann Filed on behalf of the First and Second Plaintitis, Level 7 Form 16 - RR.22, 146 300 Queen Street BRISBANE 4000 Phone 07 3001 9222 Fax 07 3001 9299 e0st2 320122.4Particulars Of Publication The first matter complained of formed a segment of a morning radio talk-back and current affairs program at about 8am on 19 January 2018 conducted by the First Defendant on radio 4BC on behalf of the Second Defendant. 6. In its ordinary and natural meaning the first matter complained of conveyed the following imputations, each of which is defamatory of the First Plaintiff @) (b) (oe) (a) The First Plaintiff lied to the First Defendant when he said he would not approve the ‘Acland Stage Three coal mine; ‘The First Plaintif dishonestly approved the Acland Stage Three coal mine because New Hope Coal had given hundreds of thousands of dollars to the Newman government; ‘The First Plaintiff dishonestly approved the Acland Stage Three coal mine because New Hope Coal had donated more than $700,000 to his politcal party; ‘The First Plaintiff prostituted himself because he approved the Acland Stage Three coal mine because New Hope Coal had donated more than $700,000 to his political party; 7. In its ordinary and natural meaning the first matter complained of conveyed the following imputations, each of which is defamatory of the Second Plaintif: (a) (o) © (@) ‘The Second Piaintif ied to the public when he said that the LNP Government would not support the expansion plans for New Acland; The Second Plaintiff dishonestly approved the Acland Stage Three coal mine because New Hope Coal had given hundreds of thousands of dollars to the Newman government; The Second Plaintiff dishonestly approved the Acland Stage Three coal mine because New Hope Coal had donated more than $700,000 to his political party; ‘The Second Plaintiff prostituted himself because he approved the Acland Stage ‘Three coal mine because New Hope Coal had donated more than $700,000 to his * political party; 8 On 20 January 2015 the Defendants published in the State of Queensland, of and concerning the each of the Plaintiffs, the matter set forth in Schedule “B" attached hereto ("the second matter complained of). 9201224Particulars Of Publication ‘The second matter complained of formed a segment of a morning radio talk-back and current affairs program at about 8am on 20 January 2015 conducted by the First Defendant on radio 4C on behalf of the Second Defendant. 9. Inits ordinary and natural meaning the second matter complained of conveyed the following imputations, each of which is defamatory of the First Plaintif: (2) The First Plaintiff lied to the public in a press release sent from his office on 26.2.2012 which said his party the LNP would not approve the Acland Stage Three coal mine proposal which would see the open cut coal mine expand to the very edge of Oakey; ( (b) The First Plaintiff approved the Acland Stage Three coal mine proposal because a bribe of $700,000 was paid to his political party, the LNP; 10. In its ordinary and natural meaning the second matter complained of conveyed the following imputations, each of which is defamatory of the Second Plaintiff: (@) ‘The Second Plaintif lied to the public in a press release sent from the First Plaintif's office on 26.2.2012 in which the Second Plaintiff said his party the LNP would not approve the Acland Stage Three coal mine proposal which would see the open cut ‘coal mine expand to the very edge of Oakey; (b) The Second Plaintiff approved the Acland Stage Three coal mine proposal because a bribe of $700,000 was paid to his political party, the LNP; 11. On 21 January 2015 the Defendants published in the State of Queensland, of and concerning the each of the Plaintfs, the matter set forth in Schedule "C* attached hereto ("the third matter complained of) Particulars Of Publication The third matter complained of formed a segment of a morning radio talk-back and current affairs program at about 8am on 21 January 2018 conducted by the First Defendant on radio 4BC on behalf of the Second Defendant. 12, In its ordinary and natural meaning the third matter complained of conveyed the following Imputations, each of which is defamatory of the First Plaintiff: (@) ‘The First Plaintiff dishonestly approved the Acland Stage Three coal mine because Brickworks had given $385,000, and New Hope Coal had given $700,000, to his political party, the LNP. 3291224