record cites

The conversation with his professor allowed Mr. Reddy to realize that his journalistic passion was in the lives of media celebrities and how they got to be so successful.

13

Mr. Reddy writes all about media celebrities, their lives, careers, accomplishments, sensationalism, and scandal.

9

Reliable Media has a website and a Flitter account.

9

Mr. Reddy always hopes that he will have enough information to publish an article after he names a person of the week.

14

Mr. Reddy is unable to ascertain whether the information he receives on a media celebrity is going to be sufficient to create an article until after the information is gathered.

15-16

He gathers this information because RM has had the purpose from the beginning to post information about media celebrities.

17

Mr. Reddy passionately writes about media celebrities because he believes that “the public has a right to know about the people who deliver their news to them.”

13, 17

Akash did not pay Mr. Reddy to nominate Ms. Hammond, but did ask Mr. Reddy to investigate IBC employees, which happened to include Ms. Hammond.

13, 14

Mr. Reddy made the decision to publish the article about Ms. Hammond after he received an abundance of information about her through the RM Flitter DM.

14

Mr. Reddy’s brother Akash Reddy, applied for a street-reporter position at IBC, and the thought occurred to the brothers that they may be able to learn about IBC employees by using RM’s resources.

13

Mr. Reddy has always dreamed of bringing news to the people, so after graduating in May 2024 with a degree in journalism, he launched RM.

8

While in school, Mr. Reddy struggled to find a journalism job in the traditional sense, so his journalism professor introduced him to the idea of creating a media website to make a name for himself.

13

Mr. Reddy is committed to working hard to make it as a reporter.

16

Reddy volunteers at the Brooklyn Gazette on Saturdays proofreading articles, just in hopes of making some contacts there.

8

Mr. Reddy is the owner and sole reporter of RM.

8

RM receives nominations through private Flitter direct message (DM) for a person of the week, which Mr. Reddy then will select.

9

The nominations are sent to RM accompanied by a $50 payment, which Mr. Reddy will only accept if the nomination is selected.

10

Flitter users are then encouraged by Mr. Reddy to send in confidential information through a private DM regarding the person of the week.

9

After an examination of the information gathered, Mr. Reddy discerns whether he has received enough information to write an article.

9

Mr. Reddy thoroughly verifies all the information he receives.

11

Mr. Reddy requires the informant to share their name, and if a phone number is provided, Mr. Reddy personally calls them to discuss the information.

11

Mr. Reddy asks the informant for the information of two additional witnesses that can verify the truthfulness of the information.

11

After receiving the two additional witnesses, Reddy contacts them to verify the information.

11

Mr. Reddy will not publish an article unless he can verify that the information is correct with the two additional witnesses.

11

Mr. Reddy thoughtfully crafts his articles so that they provide new and accurate information to the public while also being “professional in quality and novel in substance.”

11, 15

Outside of the DMs, Mr. Reddy does additional work to create articles for RM.

12

Reddy asks friends, former teachers, relatives, and others, questions pertaining to media celebrities.

12

Mr. Reddy conducts further research into other postings and publications on the internet, in magazines, and in newspapers regarding a media celebrity to verify that his information will be new to the public.

12

Reddy uses his editing skills to combine information from DMs and formats the information into an article worthy of the public.

15

During the week of June 10, 2025, Mr. Reddy through RM named Ms. Hammond the person of the week.

14

Mr. Reddy, and RM, were served with a Subpoena Duces Tecum for Deposition, on November 2, 2024, regarding Ms. Hammond’s lawsuit against IBC.

7

The Subpoena requested that Mr. Reddy bring to the deposition all documents reflecting his confidential sources of information related to Ms. Hammond’s article.

7

During the deposition, Mr. Reddy was continuously asked by Ms. Hammond’s attorney to divulge his confidential sources, to which Mr. Reddy was forced to repeatedly state that he has a reporter’s privilege to that information.

10, 12, 14

Mr. Reddy informed Ms. Hammond’s attorney that while he does have the contact information of the informants, he will not reveal them because of his reporter’s privilege and his promise to his informants that their information will stay confidential.

12

Whenever any individual shares information to any of RM’s accounts, a notice is supplied which guarantees that all submissions are confidential and source information will not be disclosed.

12

Mr. Reddy further reassures his sources through direct communication, that he will keep all confidential information secure.

12

Prior to the use of DMs, Mr. Reddy lacked sufficient information to post about media celebrities.

9

But now, the use of DMs has broadened the horizons of RM’s articles, by allowing Mr. Reddy to receive and compile information easier.

9, 11, 15