Wrongfully Accused: Notice of Intent to Sue Letter on Behalf of Jordan Chariton

Dear Mr. Chiakulas,

My firm has been retained by Mr. Jordan Chariton and Miss Chelsea Lyons to explore legal action against you in relation to certain false and defamatory publications in addition to other serious causes of action.


Feel free to explain to me like a small child how it is possible that Chelsea (5'3) held Carly’s (5'7) hands over her head while at the same time performing oral intercourse as has been alleged? This is anatomically impossible unless you also allege that Chelsea is Stretch Armstrong.

Feel free to explain to me how Jordan (5'6) could have concurrently pulled Carly’s (5'7) hands away from her face while also performing oral intercourse as was alleged. This is anatomically impossible unless my client separated his shoulders.

It was alleged in your piece that Carly kicked Mr. Chariton in the face (front side of the head) during the performance of oral intercourse — something that is physically impossible unless Mr. Chariton was performing oral intercourse on her feet.

Then there are the parts in your piece where Miss Hammond describes seeing certain scenes, but in her interview with Tim Black she claims that she had her faced covered throughout the entirety (“There are no images in my mind because I had my hands over my face” was the precise quote).

Also, having interned at a D.A.’s office and with an anti-sexual assault organization, I have done intake with victims. The idea that somebody would have omitted covering their face the entire time but would later allege that several parties were trying to remove her hands from her face is absurd (and as described above, it would have been anatomically impossible).

That new allegation also isn’t something you would have excluded when you were openly talking about fabricating somebody else’s non-sexual harassment claim into something more nefarious telling them it can’t be a “Jordan Chariton is a terrible person story” but had to be a “Jordan Chariton is a sexual predator story.”

In fact, these false claims against my clients have grown to be so absurd that you claimed in the ShadowProof article that there were six — not one, two, three, four or five but six — other accusers but that you did not know their names. You don’t even know who people are, but you know that they are accusers?

Other Gross Inconsistencies Include:

(1) Miss Hammond said only her top was off in your story, but said she got into bed next to Mr. Chariton with both her top and bottoms off in Tim Black interview;

(2) You writing in a Facebook chat: “I really don’t know that we’re going to find anyone else (sad face)” but then claiming in your piece that there were multiple accusers and stating for ShadowProof that there were six (imaginary) accusers — if there’s any confusion, Zee said in the same chat “Carly is the only one.”

(3) You claiming G.P. was an accuser only to later claim that she was a “spy” when we both know she hadn’t met Mr. Chariton in person at the time you were preparing hit jobs against Jordan;

(4) You all seem to leave out that Carly texted Mr. Chariton the next morning, “Thanks for sacrificing sleep to talk to me last night. I really appreciate it.” In the Tim Black video, Miss Hammond claimed that she went to sleep curled in a ball and that they did not talk until the early morning hours.

(5) Carly added in new details in the Tim Black interview using statutory language while looking off screen, squinting her eyes, and changing into a reading tone (not eyes jumping from fear, but a steady 50-second stare off-screen);

(6) After Chelsea and Ty stated that Jordan’s recitation of facts was accurate, the story morphed into Carly accusing Chelsea of “rape” in the ShadowProof article (again, anatomically impossible unless she is Stretch Armstrong) and a tale of being convinced that Ty was going to rape her too (“erection” portion of the video)

(7) Carly said at one point to Tim Black that everything was in her mind consensual until she admitted to her husband she cheated several months later and that her husband convinced her that she didn’t consent. That’s not how this works.


(1) You failed to disclose that you, Zee, and the Facebook group participants planned to start a competitor outlet called “Staunch” (bad name);

(2) You failed to disclose your stated objective in that group of getting Mr. Chariton fired from TYT (itself being tortious interference);

(3) There were two other people in the room saying the same thing — you did not interview or reach out to either one of them and later flipped accusations on them. There were also defamatory statements about Jenn, but you didn’t reach out to her either which effectively waives any defamation defense you could hope for;

(4) You claimed that there were multiple accusers publicly while privately acknowledging that there were no others. “Carly is the only one”;

(5) You talked about adding Jordan Chariton to the “list” of folks such as Weinstein and coached somebody with a non-sexual harassment tale to frame their experience more nefariously so this isn’t a “Jordan Chariton is a terrible person story” but rather a “Jordan Chariton is a sexual predator” story;

(6) You failed to disclose that your group talked about having a backdoor into Mr. Chariton’s personal messages, the password for his accounts being “JewCrew9,” and about one participant talking about taking Jordan’s website “hostage.” Carly herself instructed, “Shut down Jordan’s site until you get what you want”;

(7) Without reaching out to any possible witnesses, you went on to say to H.A. Goodman that “Jordan is guilty of rape” (see 37:47 to 37:49);

(8) Zee herself admitted that Carly knew her allegation is a “lie” (on file);

(9) Using off-record statements as on record and then attacking your own source.


This started with accusations against Jordan but has since grown to include:

(1) A rape allegation against Chelsea

(2) Allegation against Ty

(3) Allegation of assault against Jenn and Theresa for helping a drunk girl stand up

(4) Labeling G.P. a spy after inaccurately labeling her an accuser

(5) Accusations against TATM to the IRS and Michigan A.G.’s office

(6) Reporting one of Jordan’s attorneys (me) to the bar for being mean?

  • This happened an hour after asking me if you were getting sued. Taylor then made a full reference to a mutual associate about the fact that this complaint was being made in retaliation for you guys getting sued. Oops.


If I laid out every cause of action that Mr. Chariton and Miss Lyons have against you and your cadre of joint tortfeasors, it might take days at this point. Let me simplify it for you by just giving you the Amazon link for the Restatement of Torts.


Criminally, I believe each person in your group violated 18 U.S.C. 2511 punishable by up to five years in prison for plotting to (we don’t even need to prove you did it, planning is enough) gain unauthorized access to his pages and web data.


You all need to get attorneys. The civil cases will move forward in the next couple of months and in the interim you are called on to retain all relevant documents and electronically stored information including drafts, notes, and communications (Facebook discussion group) used in preparation of these smears and attacks.

I would also caution — although let me make clear I am not your attorney or giving you legal advice — against destroying the contents of the Facebook discussion group in order to mask or obfuscate your violations of 18 U.S.C. 2511 this itself would be a violation of 18 U.S.C. 1519 punishable by up to 20 years in prison.

On behalf of Mr. Chariton, we intend to join each of you to a lawsuit against the Huffington Post pursuant to New York’s Long-Arm Statute CPLR 302 on the basis of additional tortious conduct here beyond defamation. If we can, that will be in a couple of weeks. If we can’t, we’ll sue you in your home state in a couple months.

On behalf of Miss Lyons, we intend to sue each of you in your home states.

I think this was the part where you thought I was going to negotiate with you and say “if you just retract or apologize then we won’t file claims and press charges.”

No. I will offer you nothing. I do not negotiate with people who operate in bad faith. Jordan and Chelsea expressed that they are only interested in clearing their names from false allegations and do not want vengeance. You want to make an offer, fine.

If it were only my call — there would be no option of an offer at all.


William Moran II

Hawgood, Hawgood & Moran

Disclaimer: Mr. Moran is barred in Maryland and before the US District of Maryland. He will be participating in these matters pro hac vice.

Disclaimer #2: This should not be construed as legal advice. Get an attorney.