Chris DeRose, Clerk of Court

Granted with Modifications *** Electronically Filed ***

***See eSignature page*** L. Brown, Deputy
8/28/2018 8:00:00 AM
Filing ID 9644559

1 Lance R. Broberg (SBN 024103)

2
SEVENTH FLOOR CAMELBACK ESPLANADE II
3 2525 EAST CAMELBACK ROAD
PHOENIX, ARIZONA 85016-4237
4 TELEPHONE: 602.255.6000
FACSIMILE: 602.255.0103
5 EMAIL: lrb@tblaw.com

Kenton J. Hutcherson (PHV)

6
HUTCHERSON LAW PLLC
7 3131 McKINNEY AVENUE, SUITE 600
DALLAS, TEXAS 75204
TELEPHONE: 214.443.4200
8 EMAIL: kjh@hutchersonlaw.com

9 Attorneys for Plaintiff

10

11 IN THE SUPERIOR COURT OF THE STATE OF ARIZONA

12 IN AND FOR THE COUNTY OF MARICOPA
13 JUSTIN PAPERNY, Case No. CV2017-010047
14
Plaintiff, FINAL DEFAULT JUDGMENT
15
vs.
16 Assigned to the Hon. Margaret Mahoney
17 CHRISTOPHER MARK LAND,
Default Judgment Proceedings Assigned to
18 Defendant. Commissioner David Garbarino
19

20 ON THIS DAY, On August 9, 2018, the Court held a default judgment hearing
21 and the Court considered Plaintiff JUSTIN PAPERNY’S (“Paperny” or “Plaintiff”)
22 Motion for the Entry of a Default Judgment under Ariz. R. Civ. P. 55(b)(2). Having
23 reviewed the pleadings of record related to Plaintiff’s requested relief for Default
24 Judgment and issuance of a Permanent Injunction, as well as the evidence and testimony
25 presented at hearing, the Court finds that:
26 1. Defendant CHRISTOPHER MARK LAND (“Land” or “Defendant”) was
27 served with process and failed to answer Plaintiff’s Complaint within the period
28 prescribed by law;
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 1 2. The default of Defendant was effective March 2730, 2018;
2 3. Defendant is neither an infant nor incompetent;
3 4. The allegations raised in Plaintiff’s Complaint arise out of defamatory
4 statements Defendant made on the Internet;
5 5. The statements Defendant made on the Internet as identified herein are not
6 entitled to First Amendment protection and are unlawful;
7 6. The allegations in Plaintiff’s Complaint appear to be just and true;
8 7. Plaintiff has presented evidence of the amount of his claims;
9 8. Plaintiff is entitled to affirmative relief against Defendant as specified
10 below;
11 9. There is no just reason for delay of entry of judgment.
12 Based upon the above findings, and for good cause shown, IT IS HEREBY
13 ORDERED, ADJUDGED, AND DECREED:
14 1. No further matters remain pending and default judgment is entered under
15 Ariz. R. Civ. P. 54(c) in favor of Plaintiff Paperny against Defendant Land.
16 2. Judgment is entered in favor of Plaintiff against Defendant for actual
17 damages in the amount of $223,070.00 $109,500.00, punitive damages in the amount of
18 $10,000.00, and $1,276.69 for costs as reflected in Plaintiff’s Statement of Costs.
19 Defendant shall pay and deliver said sum instanter to Plaintiff.
20 3. Plaintiff shall have and recover Judgment against Defendant post-judgment
21 interest on all monies awarded herein at the rate of 6.0% per annum (pursuant to A.R.S. §
22 44-1201(B)), with simple interest, on all unpaid amounts from the date of judgment until
23 paid in full.
24 4. Plaintiff’s Application for Permanent Injunction is hereby granted. The
25 Court finds that there is good cause for the entry of this Permanent Injunction. The Court
26 has considered other possible remedies and finds that enjoining Defendant’s acts is the
27 least restrictive means for guarding against Plaintiff’s imminent, irreparable injuries.
28 Based upon the above findings, and for good cause shown, IT IS THEREFORE
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 1 FURTHER ORDERED, ADJUDGED, AND DECREED that Christopher Mark Land,
2 defendant in this cause, including his agents, servants, employees, independent
3 contractors, attorneys, representatives, and those persons or entities in active concert or
4 participation with him be (collectively, the “Restrained Parties”) and hereby are, forthwith
5 from the date of entry of this order:
6 a. Mandated to immediately take all action, including but not limited to
7 requesting removal from the Internet search engines including Google, Yahoo!, and Bing
8 to remove all defamatory, disparaging, libelous, and false statements about Plaintiff that
9 Defendant posted on the Internet, including, but not limited to, the statements Defendant
10 made at the following URLs:
11 i. http://www.ripoffreport.com/reports/whitecollaradvicecom/intern
12 et/whitecollaradvicecom-justin-paperny-etikallc-michael-santos-
13 justin-paperny-is-a-thie-1368250;
14 ii. http://m.ripoffreport.com/reports/whitecollaradvicecom/internet/
15 whitecollaradvicecom-justin-paperny-etikallc-michael-santos-
16 justin-paperny-is-a-thie-1368250;
17 iii. https://www.facebook.com/pg/justinpaperny/reviews/?ref=page_
18 internal; and
19 iv. https://m.facebook.com/pg/justinpaperny/reviews/?mt_nav=1.
20 b. Mandated, as it is foreseeable that the aforementioned URLs and the
21 statements contained thereon will be copied or referenced on additional webpages in the
22 future, including but not limited to index, directory, and search results pages, that
23 Defendant take all actions, including requesting removal from the Internet search engines
24 including Google, Yahoo!, and Bing to remove all such webpages from the Internet.
25 THE COURT REQUESTS Google, Yahoo!, and Bing to remove all webpages
26 and URLs about Plaintiff identified herein from their respective search indexes.
27 All other relief not expressly granted in either this Final Default Judgment or the
28 Permanent Injunction in this case, is hereby denied.
9599479$$$cv2017-010047 3
Final Default Judgment
 1 ///
2 There is no just reason for delay and the Clerk of the Court is directed to enter
3 judgment against Defendant Land under Ariz. R. Civ. P. 54(c).
4 This is a final judgment as to all claims and parties entered pursuant to Rule
5 54(c) of the Arizona Rules of Civil Procedure as no further matters remain pending
6 before the Court.
7 This is a Final Order.
8 Dated: _______________, 2018.
9

10
The Honorable David Garbarino
11 Maricopa County Superior Court Commissioner
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eSignature Page 1 of 1
Filing ID: 9644559 Case Number: CV2017-010047
Original Filing ID: 9599479
_______________________________________________________________________________
Granted with Modifications

/S/ David Garbarino Date: 8/24/2018

_____________________________
Judicial Officer of Superior Court
 ENDORSEMENT PAGE
CASE NUMBER: CV2017-010047 SIGNATURE DATE: 8/24/2018
E-FILING ID #: 9644559 FILED DATE: 8/28/2018 8:00:00 AM

LANCE R BROBERG

CHRISTOPHER MARK LAND

NO ADDRESS ON RECORD

JOHN DOES
NO ADDRESS ON RECORD