EFiled: Jul 23 2025 08:30AM ERIOR Transaction ID 76706191 Case No. N25C-07-194 CLS IN THE SUPERIOR COURT OF THE STATE OF DELAWARE EMMANUEL MACRON and BRIGITTE MACRON, Plaintiffs, JURY TRIAL DEMANDED CANDACE OWENS, CANDACE OWENS LLC, and GEORGETOM, INC. Defendants. 1. In March 2024, Candace Owens, a right-wing podcaster, told the world she "would stake [her] entire professional reputation on the fact that Brigitte Macron [the First Lady of France] is in fact a man." Since then, Owens has used this false statement to promote her independent platform, gain notoriety, and make money. Owens disregarded all credible evidence disproving her claim in favor of platforming known conspiracy theorists and proven defamers. And rather than engage with President and Mrs. Macron's attempts to set the record straight, Owens mocked them and used them as additional fodder for her frenzied fan base. 2. Owens did not stop there. Retaliating against the Macrons for the "audacity" of sending her a retraction demand, Owens helmed an eight-part podcast series entitled "Becoming Brigitte" (the "Series") and accompanying X posts. Throughout the Series, Owens and her entities, Candace Owens LLC and George Tom, Inc., endorsed, repeated, and published a series of verifiably false and devastating lies about the Macrons, on which this complaint is based. These outlandish, defamatory, and far-fetched fictions included that Mrs. Macron was born a man, stole another person's identity, and transitioned to become Brigitte; Mrs. Macron and President Macron are blood relatives committing incest; President Macron was chosen to be the President of France as part of the CIA-operated MKUltra program or a similar mind-control program; and Mrs. Macron and President Macron are committing forgery, fraud, and abuses of power to conceal these secrets. 3. These claims are demonstrably false, and Owens knew they were false when she published them. Yet, she published them anyway. And the reason is clear: it is not the pursuit of truth, but the pursuit of fame. After being fired from The Daily Wire, Owens used these demonstrably false claims to promote her independent podcast, Candace. Owens' fan base has grown to 6.9 million followers on X and 4.47 million subscribers on YouTube. The most popular podcasts in the world have discussed her “investigation” into the Macrons' history. She launched a revamped website, CandaceOwens.com, fueled by her desire to make these specific false claims about the Macrons, without adhering to content moderation policies. 4. This is nothing new for Owens. She has built a brand on provocation, not truth. Owens labels herself as an independent "investigative journalist" while routinely peddling misinformation under the guise of legitimate reporting. She has promoted a range of conspiracy theories, including anti-vaccine falsehoods, long- debunked antisemitic tropes such as blood libel, and Holocaust distortion—going so far as to dismiss the atrocities of Josef Mengele's medical experiments as mere “propaganda.” Her content is not intended to inform but to inflame and attract attention through sensationalism and conspiracy theories. 5. Owens published the Series and related X posts with reckless disregard for the truth. Owens was repeatedly presented with credible, verifiable evidence disproving her claims-including documentation, public records, and direct outreach from the Macrons. Instead of correcting the record, she doubled down. At the time, Mrs. Macron had won French defamation claims against others who pushed these same baseless theories, underscoring both their falsity and defamatory sting. Owens knew this. Yet Owens, fully aware of the truth, has not only declined to retract her statements but has actively expanded on them. 6. These lies have caused tremendous damage to the Macrons. Defendants have subjected the Macrons to a campaign of global humiliation, turning their lives into fodder for profit-driven lies. Owens has dissected their appearance, their marriage, their friends, their family, and their personal history—twisting it all into a grotesque narrative designed to inflame and degrade. The result is relentless bullying on a worldwide scale. Every time the Macrons leave their home, they do so knowing that countless people have heard, and many believe, these vile fabrications. It is invasive, dehumanizing, and deeply unjust. Faced with this relentless and unjustified smear campaign, the Macrons are left with no choice but to seek relief through this Court to set the record straight, prevent further harm, and hold Defendants accountable for their conduct. PARTIES AND RELEVANT NONPARTIES 8. Plaintiff Emmanuel Macron is a French citizen. President Macron has been the President of France since 2017. Prior to being elected, President Macron served as Minister of Economics, Industry, and Digital Affairs and Deputy Secretary-General to the President. President Macron married Brigitte Macron in Plaintiff Brigitte Macron is a French citizen, the spouse of the current President of France, and a woman. She was born Brigitte Trogneux in Amiens, France, on April 13, 1953. She is the youngest of six children. She gave birth to three children from her first marriage to André-Louis Auzière. Mrs. Macron is a former teacher. In 2007, she married Emmanuel Macron. 10. Defendant Candace Owens is a citizen of the United States and resident and domiciliary of the state of Tennessee. Through her marriage to George Thomas Stahel Farmer, a British citizen, Owens also holds British citizenship. Owens is considered a political commentator and is a self-described conservative. Owens hosts a podcast called Candace, which is published on Owens' X account by Candace Owens LLC, on CandaceOwens.com by GeorgeTom, Inc., and across various other platforms. Owens is a member and the sole manager of Defendant Candace Owens LLC. Owens maintains control of Defendant GeorgeTom, Inc. Defendant Candace Owens LLC is a limited liability company organized under the laws of the State of Delaware with its headquarters in Nashville, Tennessee. Candace Owens is the sole manager of Candace Owens LLC. The company manages Owens' Facebook and X accounts, and Owens oversees and directs all content published on her social media accounts. She disseminated her false and defamatory statements through Candace Owens LLC. Candace Owens LLC is a pass-through entity named after Owens, which is solely controlled and managed by her. It is the legal entity through which Owens operates and manages her social media accounts. Owens has primary control over the management of Candace Owens LLC. 12. Defendant GeorgeTom, Inc. is a registered for-profit corporation organized under the laws of the State of Delaware, with its headquarters in Nashville, Tennessee. Owens made false and defamatory statements on her podcast, Candace, and published them on her website, CandaceOwens.com, which is operated by GeorgeTom, Inc. Owens oversees and directs all content that GeorgeTom, Inc. publishes on CandaceOwens.com. Owens is a member or manager of GeorgeTom, Inc., and she has primary control over the management of GeorgeTom, Inc. 13. Nonparty Jean-Michel Trogneux is the older brother of Brigitte Macron. Jean-Michel was born in Amiens, France, on February 11, 1945, and he still lives there today. 14. Nonparty Xavier Poussard is an investigative journalist and editor of La Lettre de Xavier Poussard. He was a part owner of Faits et Documents, a confidential newsletter that published false and defamatory claims regarding Plaintiffs similar to those stated by Defendants. Owens claims the writings by Xavier Poussard inspired her false and defamatory claims. Poussard is Owens' primary source. 15. Nonparty Natacha Rey is an investigative journalist who has also spread the same false and defamatory claims about the Macrons. Rey originated the claims in France. As a result, Mrs. Macron prosecuted a libel case in France against both Natacha Rey and Amandine Roy. Rey is a key source for Owens and Poussard. 16. Nonparty Amandine Roy is a self-proclaimed "spiritual medium" who interviewed Rey in 2021 for a since-deleted YouTube video. In 2021, in a four-hour interview, Roy and Rey broadcast false and defamatory claims regarding Mrs. Macron, which prompted her libel claim in France. Roy is a leading source for Owens and Poussard. JURISDICTION This court has subject-matter jurisdiction over this civil action, and the in this Court under Delaware law.¹ 18. This Court has personal jurisdiction over Defendant Candace Owens under Delaware law and the Due Process Clause of the United States Constitution, because she manages an LLC formed under Delaware law and the claims relate to the business of the limited liability company.² Defendant Owens is the manager of Candace Owens LLC and directs, controls, or participates materially in the management of Candace Owens LLC. This Court also has personal jurisdiction over Defendant Owens under Delaware law and the Due Process Clause of the United States Constitution because Plaintiffs' claims against her arise from her and her Delaware entities' actions in causing tortious injury to Plaintiffs by an act or omission outside of Delaware as they regularly do or solicit business, engage in persistent courses of conduct, and derive substantial revenue from services or things used or consumed in the State (including subscriptions and related products and services). Moreover, exercising jurisdiction over Defendant Owens would not offend traditional notions of fair play and substantial justice because she could 1 See Del. Const. art. IV, §§ 1, 7; 10 Del. C. §§ 541-42. 26 Del. C. § 18-109. 3 10 Del. C. § 3104(c)(4). have and should have―reasonably foreseen being haled into court in the State of Delaware, where she formed, managed, and controlled entities she used to commit tortious conduct and where her entities regularly transacts business, to account for her tortious conduct against Plaintiffs. 19. This Court has general personal jurisdiction over Defendant Candace Owens LLC under Delaware law and the Due Process Clause of the United States Constitution because it is formed under Delaware law. Exercising jurisdiction over Defendant Candace Owens LLC would not offend traditional notions of fair play and substantial justice because it could have and should have reasonably foreseen being haled into court in the State of Delaware, where it is formed and where it transacts business, to account for its tortious conduct against Plaintiffs. This Court has general personal jurisdiction over Defendant George Tom, Inc. under Delaware law and the Due Process Clause of the United States Constitution because it is incorporated in Delaware. Exercising jurisdiction over Defendant GeorgeTom, Inc. would not offend traditional notions of fair play and substantial justice because it could have and should have―reasonably foreseen being haled into court in the State of Delaware, where it is formed and where it transacts business, to account for its tortious conduct against Plaintiffs. FACTUAL ALLEGATIONS President Macron rose to power in France, embodying a modern, dynamic image of leadership that resonates with many citizens. President Macron was born on December 21, 1977, in Amiens, France, to Françoise Noguès, a physician, and Jean-Michel Macron, a neurologist. From an early age, he demonstrated intellectual curiosity and emotional sensitivity, nurtured in large part by his close bond with his maternal grandmother, "Manette,” a schoolteacher who introduced him to literature and progressive political ideals. President Macron attended La Providence, a Jesuit high school in Amiens, where he first met Brigitte Macron, a French and drama teacher. At the time, Mrs. Macron was an accomplished educator and mother of three. Their early interactions were centered around academic mentorship and a shared passion for literature and theater. On April 13, 1953, in Amiens, France, Mrs. Macron was born Brigitte Trogneux—a woman. She was the youngest of six children in a prominent chocolate-making family in Amiens. An image of her birth announcement and family photo featuring Mrs. Macron as a child is below. CARNET MONDAIN Anne-Marie, Jean-Claude. Mary- vonne, Monique et Jean-Michel TROGNEUX ont la grande joie de vous annoncer la naissance de leur petite sœur Brigitte. Amiens, 1, rue Delambre. Mrs. Macron married her first husband, André-Louis Auzière, in 1974 when she was 21. They had three children: Laurence, Sébastien, and Tiphaine. A photo from Mrs. Macron's and Mr. Auzière's wedding is below. Mrs. Macron began her career teaching in Paris and Strasbourg before joining La Providence in the early 1990s. There, she taught French and directed the school's theater workshop. 26. Through the school's theater program, President Macron and Mrs. Macron formed a deeper intellectual connection. During a school production of Jacques and His Master, President Macron played the lead role under Mrs. Macron's direction. He later undertook an ambitious rewrite of another play, The Art of Comedy, to create roles for more students. Mrs. Macron agreed to guide him, and the two began meeting regularly to collaborate on the project. At all times, the teacher-student relationship between Mrs. Macron and President Macron remained within the bounds of the law. But, when President Macron's parents became aware of his strong feelings for his teacher, they decided to transfer him to Lycée Henri-IV in Paris. Mrs. Macron encouraged him to leave and was confident he would fall in love with a peer. Yet, before his departure, he told her, "Whatever you do, I will marry you." 28. President Macron completed his studies at Lycée Henri-IV and went on to earn a degree in philosophy from Paris Nanterre University, followed by a master's degree in public affairs from Sciences Po. He then attended the prestigious École Nationale d'Administration (“ENA”), which trains France's top civil servants. After graduating, he began his career as a finance inspector at the French Ministry of Economy and Finance. Over the years, President Macron and Mrs. Macron kept in touch, and their love deepened. In 2006, Mrs. Macron divorced her first husband, and in 2007, she married President Macron. Their relationship has remained strong and supportive, marked by a deep intellectual partnership. 30. In 2008, President Macron joined Rothschild & Cie Banque as an investment banker, where he achieved notable success. His public service career resumed in 2012, when he joined President François Hollande's administration as Deputy Chief of Staff and Economic Advisor. In 2014, he was appointed Minister of the Economy, where he implemented key economic reforms, later known as the "Macron Law." 31. As Hollande's popularity declined amid economic difficulties and rising nationalism, President Macron began distinguishing his platform from that of the sitting administration. He recognized the need for a new centrist movement to address the challenges of the moment. In 2016, he founded the political movement En Marche! ("Forward!"), which he described as a “democratic revolution.” Later that year, he resigned from his ministerial post and declared his candidacy for president. His campaign emphasized pro-European, centrist policies and quickly gained national momentum. Mrs. Macron joined her husband on the campaign trail, acting as a central figure and key advisor to his campaign. Following the first round of elections in April 2017, President Macron publicly credited Mrs. Macron for his success, saying: "Without her, I wouldn't be me." He went on to win the presidency in May 33. Upon assuming office, President Macron formally established an official, unpaid role for the First Lady. In this capacity, Mrs. Macron represents France in diplomatic settings, supports charitable causes, and engages in initiatives related to education, health, disability, and child protection. Her responsibilities are supported by an advisory cabinet and two presidential aides. Mrs. Macron is a strong, independent woman who has consistently forged her own path. Throughout her life, she has refused to be confined by societal expectations or limited by traditional roles. As First Lady of France, she has made deliberate, thoughtful choices rooted in conviction and purpose. Far from merely supporting her husband from the sidelines, Mrs. Macron has been an active and engaged partner-respected for her intellect, influence, and refusal to simply do as she is told. Her life and work embody a commitment to education, civic engagement, and personal agency. Brigitte Macron is the target of a vicious conspiracy crafted by those threatened by her influence. Around March 2021, Natacha Rey-who describes herself as an independent journalist-published on her now-deleted Facebook profile false and defamatory claims alleging that Mrs. Macron is a transgender woman perpetrating identity theft. These baseless allegations initially failed to attract significant public attention. But that changed when Rey began working with Xavier Poussard. 36. In May 2021, Poussard began publishing a multi-issue series entitled "The Mystery of Brigitte Macron.” That series recycled and expanded on numerous falsehoods, including the defamatory insinuations regarding Mrs. Macron's alleged biological sex—allegations later amplified and expanded on by Owens. 37. In September 2021, Rey collaborated with Poussard to co-author a publication in Faits et Documents, a fringe magazine reportedly influential within far-right circles in France. Faits et Documents was founded in 1996 by Emmanuel Ratier, a known figure of the French far-right. 38. On December 10, 2021, Rey appeared on the YouTube channel of Amadine Roy, a self-described spiritual medium. Roy conducted a four-hour interview with Rey, during which Rey reiterated the defamatory claims that Mrs. Macron was, in fact, born as a male named Jean-Michel Trogneux (which is the actual name of Mrs. Macron's brother) who stole the identity of Brigitte Trogneux. They also claimed that Mrs. Macron's first husband never existed and that she did not carry her three children. The video quickly went viral, amassing more than 450,000 views before it was removed by YouTube. In December 2021, the hashtag “#JeanMichelTrogneux" began trending on X, with users pointing to the fact that there are few public photos of At the time of the posts, X was known as “Twitter." Mrs. Macron from her youth and that she often “hides her neck" as "proof" she is transgender. From that point forward, the false narrative was amplified by prominent far-right influencers in France. In September 2024, a French court held that Rey and Roy defamed Mrs. Macron for spreading false rumors that Mrs. Macron was born Jean-Michel Trogneux and later stole the identity of Brigitte Trogneux. The defamation suit confirmed that Rey's and Roy's claims that all documents related to Mrs. Macron's birth, marriage, divorce, and childbearing were forged to conceal her actual sex were false. Jean-Michel participated in the trial. Rey and Roy were fined €500 and ordered to pay €8,000 to Mrs. Macron and €5,000 to her brother in civil damages. 41. After multiple victories against Rey and Roy at home in France, the Macrons thought these false claims had been put to bed. But, as discussed below, Owens turned this flame into a fire. Owens is a far-right conspiracy theorist who thrives on making outrageous claims, prioritizing shock value and follower growth over truth or responsible discourse. Owens did not always espouse extreme right-wing ideals. She was born in White Plains, New York, and raised in Stamford, Connecticut. Owens graduated 5 An interim appellate court overturned the judgment on July 10, 2025, and the case is now on appeal to France's highest court, the Court of Cassation. Importantly, the appellate court did not overturn the judgment on the basis that the statements were true, but on other grounds. Mrs. Macron firmly believes that all the statements included in that proceeding are false and defamatory, and that the highest court will uphold her claims. from Stamford High School in 2007 and attended the University of Rhode Island before leaving due to financial issues. 43. Following her departure from university, Owens completed an internship at Vogue magazine and was later hired as an administrative assistant at a private equity firm in New York. In 2015, she left the financial sector to start a marketing agency called Degree180. Degree180's website featured a blog that gained notoriety for publishing progressive, anti-conservative, and anti-Trump content-the exact opposite of her current views. 44. That all changed in 2016 when Owens launched SocialAutopsy.com, a website that aimed to expose individuals responsible for online harassment by publishing their identities. The project was widely condemned across the political spectrum, with both conservative and progressive voices expressing concerns over privacy and potential misuse. In retaliation, critics shared Owens' personal information online. Owens attributed the widespread criticism and retaliation efforts to two progressives who had attempted to convince Owens to abandon the project. While Owens was being criticized by those who purportedly shared her beliefs, she received support from prominent figures associated with the far-right. Owens publicly stated that this was the catalyst for her ideological shift, remarking, “I became conservative overnight." In late 2016, she began expressing support for Donald Trump's presidential run. By 2017, Owens had completely flipped political sides, aggressively ramping up her online criticism of liberal ideology and policies through her YouTube channel. She further amplified her voice and newfound point of view to young conservatives through her role as Communications Director of Turning Point USA, a nonprofit organization that advocates for conservative ideals on high school and college campuses nationwide. 46. In 2019, Owens founded the Blexit movement, which encourages Black Americans to leave the Democratic Party. That same year, she launched The Candace Owens Show, a podcast on YouTube, where she interviewed conservative figures. In August 2019, she married George Farmer, a British citizen and the son of Lord Michael Farmer, a former treasurer of the Conservative Party. When the couple met in December 2018, George Farmer was chairman of Turning Point UK and later became CEO of Parler, a far-right social media platform. 47. As her visibility grew, Owens also became involved in French far-right politics. She was invited to be the headline speaker at the Convention de la Droite in Paris in September 2019. The Convention was organized by associates of Marion Maréchal, the niece of Marine Le Pen, President Macron's political adversary. During her speech, Owens criticized President Macron, calling him a “weak” leader. Shortly after the event, Owens tagged Maréchal in a comment to an X post showing a video of the two speaking: “In the near future, there will be a deeper alliance between France and the United States. ... Thank you, @MarionMarechal for widening my understanding of the challenges faced by France today." Maréchal replied favorably, thanking Owens for her courage. Owens' criticism of President Macron continued and increased after the 2022 Russian invasion of Ukraine. Over the years, Owens' network has included prominent conservative figures known for extreme or conspiratorial rhetoric, such as Charlie Kirk, Alex Jones, Nigel Farage, and even Kanye West. During Paris Fashion Week in the Fall of 2022, Owens appeared with West wearing controversial “White Lives Matter” t- shirts a slogan condemned by civil rights groups as a white supremacist response to the Black Lives Matter movement. West posted a photo of him and Owens wearing the shirts with the caption, “Everyone knows that Black Lives Matter was a scam. Now it's over, you're welcome." Around this time, West announced plans to buy Parler, Farmer's company. The deal collapsed shortly after Adidas ended its contract with West for making antisemitic comments. 49. In 2021, Owens joined The Daily Wire, where she hosted her talk show, Candace Owens, until her departure in 2024. Owens left The Daily Wire in March 2024 following public clashes with co-founder Ben Shapiro over her increasingly antisemitic rhetoric. In the wake of the October 7 Hamas attacks on Israel, Owens voiced strong pro-Palestinian and anti-Israel sentiments. Her commentary escalated from political criticism to overt antisemitic conspiracy theories. On her talk show, Owens alleged that secret Jewish "gangs" commit "horrific things" in Hollywood, and on social media, she repeated the long-debunked “blood libel” myth that Jewish people drink the blood of Christian children. These comments justifiably received widespread condemnation. Following her departure from The Daily Wire, Owens did not slow down in fact, she seized the opportunity to become even more extreme. In June 2024, she independently relaunched her talk show under the name Candace on YouTube. In September, she posted an interview with Kanye West, during which both claimed that Jewish people control the media. YouTube removed the video and suspended and demonetized her channel for violating hate speech policies. Despite this, Owens persisted in promoting conspiracy theories, including calling Nazi medical experimentation on Jewish people during the Holocaust “bizarre propaganda." These actions led the Australian government to deny her a visa in 2025, citing a risk that her presence could "incite discord" and concluding that "Australia's national interest is best served when Candace Owens is somewhere 51. Despite the inflammatory and demonstrably false nature of many of her public statements, Owens' audience has continued to grow. As of July 2025, Owens has over 4.47 million subscribers on YouTube, and her videos have garnered millions of views. She has 6.9 million followers on X. Owens repeats the outlandish claim that Brigitte Macron was born a man on The Daily Wire precisely because she knew its shock value would boost her visibility. In March 2024, just prior to her departure from The Daily Wire, Owens began promoting the false claim that Mrs. Macron was born a man. On March 11, 2024, Owens published an episode of her The Daily Wire podcast Candace Owens titled "INSANE. This Is The BIGGEST Political Scandal In Human History," which reported on the Brigitte Macron conspiracy theory that was making its way through the courts in France. Owens was the first to bring this theory to the U.S. media and to a global audience. That same day, Defendants announced the video in an X post, repeating that it is “the biggest scandal that has ever happened in politics in human history": Candace Owens ✔ @RealCandaceO Stop everything and watch this! Not a joke or an exaggeration to say that barring political assassinations, this is likely the biggest scandal that has ever happened in politics in human history. #JeanMichelTrogneux youtu.be/v81g1tldi4c?si... 4:10 PM - Mar 11, 2024 2.2M Views Post your reply Candace Owens @RealCandaceO - Mar 11 I looked into this expecting it to be an insane conspiracy theory and it is anything but. It took 3 years of research for the journalists to unpack this series. It would take 3 seconds for Macron to dispel these rumors and yet they seem unable to. The implications are WILD. 53. Owens claimed she learned about this theory from a 2021 debunking story published by Daily Mail. Owens falsely claimed the article was recent, despite it being published more than three years ago, likely to make it appear that she just happened upon this story rather than searching for a salacious conspiracy to increase viewership. Shockingly, Owens claimed "there was no debunking whatsoever." 54. But that is false. The article included multiple photos of Mrs. Macron as a child and informed that separate journalists met both Mrs. Macron's brother, Jean-Michel, and Mrs. Macron's late ex-husband, André-Louis Auzière. Owens omitted these facts. The next day, Owens followed up with another defamatory X post, stating that she "would stake [her] entire professional reputation on the fact that Brigitte Macron is in fact a man." 6 Paul Bracchi and Peter Allen, The proof France's First Lady WASN'T born a man: The true story of Brigitte Macron's controversial background is revealed as wicked slur is spread by the French far-Right to damage the election hopes of her husband, Daily Mail (Dec. 31, 2021, at 18:08 EDT), https://www.dailymail.co.uk/news/article-10359625/The-proof-Frances-Lady-WASNT-born- Candace Owens @RealCandaceO This episode is blowing up so I just want to say-After looking into this, I would stake my entire professional reputation on the fact that Brigitte Macron is in fact a man. Any journalist or publication that is trying to dismiss this plausibility is immediately identifiable as establishment. I have never seen anything like this in my life. The implications here are terrifying. I do not intend to let up on this story and I am calling on other journalists to look into this explosive story and report accordingly. Watch here: youtu.be/v81g1tldi4c?si... #Jean Michel Trogneux Last edited 11:08 AM - Mar 12, 2024 -7.5M Views On March 13, 2024, Owens released another episode of Candace Owens titled "Media Meltdown! France's First Lady Exposed,” repeating and expanding on her false claims. From the start, Owens could not keep her story straight. For example, on Owens' March 21, 2024, appearance on the nationally syndicated radio show, The Breakfast Club radio show, she said that the Macrons “tried to sell to the press a fake photo which got debunked. It was actually Jean-Michel's daughter.” She has never repeated this claim because it is demonstrably false. 58. After Owens was dismissed from The Daily Wire on March 22, 2024, the outlet did the right thing and immediately removed Owens' March 11 and 13. Video posted by The Breakfast Club (@BreakfastClubPower1051FM), YouTube, Candace Owens On Black America, Congressional Puppets, Donald Trump, Kanye West, T.I. + More (Mar. 21, 2024), https://www.youtube.com/watch?v=goIrzPIh8yA. episodes, but each remains available online on other platforms. Fired from The Daily Wire and faced with clear evidence debunking her claim, Owens continues to push the conspiracy-now from her own podcast. Despite the extensive and publicly available evidence confirming the truth about the Macrons' identities and history, Owens persisted in spreading her false and defamatory allegations. Even after her termination from The Daily Wire- reportedly due, in part, to her repeated dissemination of baseless conspiracy theories Owens showed no sign of retracting or tempering her allegations. She continued promoting her preconceived narrative, undeterred by professional consequences or contradictory facts. Defendants launched Owens' independent podcast, titled Candace, on June 10, 2024. Knowing her false claims about the Macrons had caught fire in March, Owens seized the moment, recycling them starting the very day she premiered Candace—Defendants took to X, declaring Mrs. Macron was a man. Fueled by sensational claims, the show quickly gained attention, earning the second spot on Edison Research's list of top new podcasts for 2024. Candace Owens @RealCandaceO Vince Langman @LangmanVince Jun 9 Seriously, WTF is Emmanuel Macron married to? 9:39 AM Jun 10, 2024 -8.2M Views 61. On June 12, 2024, Owens appeared on Piers Morgan Uncensored to push more false and defamatory claims about the Macrons-claims even Piers Morgan, known for his provocative style, dismissed as absurd. Owens doubled down the next day by republishing clips from the interview, repeating her false allegations on the June 13 episode of Candace.³ 62. Recognizing that her false claims about the Macrons were drawing Video posted by Candace Owens (@RealCandaceO), YouTube, SMACKDOWN! Piers Morgan Tried Candace Ep. 4 (Jun. 13, 2024), https://www.youtube.com/watch?v=yXyVzAn_EMo. significant attention, Owens escalated further. On June 17, 2024, Defendants released an episode titled, “So...Is Brigitte Macron A Man?" to repeat the discredited allegations from Owens' March episodes that had since been deleted by The Daily Wire. Seeking to drive traffic to her new venture and expand her claims, Owens opened by warning that the Macrons were "going to come for [her] life." She then repeated the categorically false claim that the Macrons had deployed the secret service to intimidate and detain journalists to hide the truth of Mrs. Macron's transition and identity theft. Finally, she linked these allegations to a broader, equally baseless conspiracy theory: that the world is being run by a gang of Satanic pedophiles masquerading as Jewish people. 63. Projecting, Owens claimed the Macrons were not behaving in ways one does "when you are telling the truth.” She claimed there are no photos from the first 30 years of Mrs. Macron's life, but contradicted herself just moments later by admitting that photos of a young Mrs. Macron had been released; she just does not believe they are real. 64. The clicks kept coming, so Owens kept going, seizing every opportunity to promote her salacious claims. Defendants released another episode Video posted by Candace Owens (@RealCandaceO), YouTube, So...Is Brigitte Macron A Man?, Candace Ep. 6 (Jun. 17, 2024), https://www.youtube.com/watch?v=mXGUHYVUZZk. mentioning the conspiracy on June 26, 2024.10 On July 1, 2024, Owens repeated her false claims in an episode encouraging viewers to reject scientific findings in favor of following their gut.¹¹ On July 7, 2024, Owens presented these false claims on The Jimmy Dore Show." Jimmy Dore is a stand-up comedian turned political commentator who regularly promotes conspiracy theories. 65. Defendants went so far as to create and sell merchandise to promote these claims. On July 8, 2024, Defendants posted a photo on X of Owens in a t-shirt showcasing a fake Time Magazine "Man of the Year" cover featuring Mrs. Macron. The shirt sold out. Video posted by Candace Owens, (@RealCandaceO), YouTube, Piers Morgan Caught LYING About Brigitte Macron, Candace Ep. 26, 2024), https://www.youtube.com/watch?v=sTXqHi0lOX8. 11 Video posted by Candace Owens, (@RealCandaceO), YouTube, Why I Left This Religion, Candace Ep. 16 (Jul. 1, 2024), https://www.youtube.com/watch?v=8wlq-Q4YgtM&t=1s.. 12 Video posted by The Jimmy Dore Show (@therealjimmydoreshow), YouTube, Candace Owens EXPLOSIVE Take On Macron's Wife Will Blow Your Mind! (Jul. 7, 2024), https://www.youtube.com/watch?v=81ec0BTdAd0. Candace Owens @RealCandaceO I'm calling it now. Time Man of the Year. CLUBCANDACE.COM WHAT'S NEXT 5:21 PM Jul 8, 2024 832K Views 66. Owens went so far as to claim the 2024 Olympic opening ceremony— a tribute to Greek mythology-was designed to "honor Brigitte Macron," because she is transgender. 13 This claim is not only absurd, but self-defeating: Owens also insists Mrs. Macron's biological sex is a "state secret," making such a tribute impossible even by her own logic. 13 Candace: The Olympics Exposed Brigitte Macron, Candace Ep. 34 (Apple Podcasts, Jul. 29, 2024), https://podcasts.apple.com/us/podcast/the-olympics-exposed-brigitte-macron-candace-ep- 34/id1750591415?i=1000663732510. She then escalated her rhetoric, falsely alleging that the Macrons are part of "a very small group of elite oligarchs who routinely practice homosexuality and pedophilia, believe in Baphomet, and worship a transgender deity”14 that controls the world. This is yet another baseless, inherently implausible claim- contradicted by public evidence and common sense. Owens bolstered this claim by reposting on X a takedown of the Opening Ceremony and Mrs. Macron by another provocative figure, Archbishop Viganò, who had just been excommunicated from the Catholic Church. 15 Yet again, searching for the most controversial spin, Owens posted on X that “Brigitte Macron is a transvestite," calling it a "demonic state secret" and falsely claiming that Mrs. Macron is a rapist. Owens used the conspicuous tag "#ChristIsKing" to garner even more attention. Continuing to capitalize on the attention of sensational figures and known liars, Owens published a post by Alex Jones- -a notorious defamer who owes $1.5 billion to the families of the Sandy Hook shooting victims for his malicious 14 Baphomet is a Satanic figure depicted as a “winged hermaphrodite with a torch between his horns and a pentagram on his forehead.” James Morgan, Decoding the symbols on Satan's statute, Aug. 1, 2015, https://www.bbc.com/news/magazine-33682878. https://x.com/RealCandaceO/status/1817912361736392858. (@RealCandaceO), X (Jul. at 09:17 ET), lies and repeated her false allegations. 16 Jones is one of the most unreliable sources imaginable. Owens stated that "Brigitte Macron was born Jean-Michel Trogneux. He lived as a man for about 30 years before 'transitioning' to Brigitte. While he lived as a man he fathered 3 children." Again, Owens tagged “#ChristIsKing." 70. Yet again aligning with the most controversial figures, Defendants brought on Andrew Tate a self-proclaimed misogynist charged with rape and human trafficking. 17 Owens proved that no amount of credible evidence would convince her to abandon her preconceived narrative when she platformed Tate's claim that the French election was rigged like the 2020 U.S. election. 18 Owens went further, claiming the Macrons are "being blackmailed and they are being selected for these positions." She dismissed all critics by saying "the matrix” is targeting her for exposing the supposed homosexuality and pedophilia taking place in the world. On August 30, 2024, Owens interviewed Poussard, the publisher of the defamatory Faits et Documents series on Mrs. Macron. 19 Poussard became Owens' 16 Candace Owens (@RealCandaceO), X (Jul. 29, 2024, at 10:59 https://x.com/RealCandaceO/status/1817937998652023085. 17 Video posted by Candace Owens (@RealCandaceO), YouTube, Andrew Tate x Candace Owens, Candace Ep. 46 (Aug. 15, 2024), https://www.youtube.com/watch?v=iwOXLfVsieA. This fake news has also been debunked. US Dominion, Inc. v. Fox News Network, LLC, No. N21C-03-257 EMD, 2023 WL 2730567, at *21 (Del. Super. Ct. Mar. 31, 2023) (“The evidence developed in this civil proceeding demonstrates that is CRYSTAL clear that none of the Statements relating to Dominion about the 2020 election are true.") (emphasis in original). 19 Candace: EXCLUSIVE: Meet the Journalist Who EXPOSED Brigitte Macron, Candace Ep. 56, (Spotify 2024), (Continued...) primary source quite possibly her only source for her future reporting. In the interview, Owens and Poussard agreed that the Macrons are perpetrating fraud regarding Mrs. Macron's identity and President Macron's political independence and integrity. They further claimed that Mrs. Macron's nephew resembles President Macron and inferred that the Macrons' relationship was incestuous. directly accused Mrs. Macron of abuse of a minor, impersonation, and identity theft. Owens endorsed, adopted, and expanded on these claims, linking them to her broader conspiracy theory involving an extensive network of satanic pedophiles. 72. Every time Owens faced consequences for repeating these outrageous allegations, she refused to take responsibility and instead cast herself as the victim and blamed others. For example, on September 11, 2024, Defendants embedded the August 30 episode in an X post claiming that YouTube removed the video for exposing the media's complicity in covering up pedophilia, when the truth is that Owens did not abide by YouTube's content moderation policies, which are designed to guard against misinformation and hate speech. The Macrons flatly debunk the conspiracy in a retraction demand to Owens-but she mocks their response, ignores the facts, and doubles down with even more reckless claims. The Macrons, through their counsel, sent a detailed retraction demand https://open.spotify.com/episode/5nn9gkM9XQ3W2RfTsoM2Kz?si=dZthIgVGTIqfShzdYw8U letter to Owens via email on December 3, 2024. The December Retraction Demand explained the falsity of Owens' defamatory statements and included an abundance of evidence that Mrs. Macron was born a woman named Brigitte Trogneux; that she was not a blood relative of President Macron; and that the Macrons were not being controlled or blackmailed by any group of people. Owens did not respond to the December 3 email. 74. Owens then repeatedly ignored multiple additional attempts by the Macrons to engage. The Macrons sent a follow-up email on December 18, 2024, which went unanswered. On January 8, 2025, the Macrons contacted Owens' former legal counsel to facilitate communication but received no response. Next, the Macrons attempted to personally serve the December Retraction Demand on January 9, 2025, but were first ignored, then blocked by Owens' counsel—who ultimately agreed to accept service by email. 75. The December Retraction Demand explicitly denied each of Owens' claims and presented evidence that conclusively disproved them. 76. The December Retraction Demand reminded Owens that the very Daily Mail article she cited as support for her conspiracies told readers that the Courrier Picard, a daily newspaper in Amiens, France (Mrs. Macron's hometown), included Mrs. Macron's birth announcement. The birth announcement states that Brigitte Trogneux was born on April 13, 1953, and that her siblings, "Anne-Marie, Jean- Claude, Maryvonne, Monique and Jean-Michel Trogneux, have great joy in announcing the arrival of their little sister, Brigitte."" CARNET MONDAIN Anne-Marie, Jean-Claude. Mary- vonne, Monique et Jean-Michel TROGNEUX ont la grande joie de vous annoncer la naissance de leur petite sœur Brigitte. Amiens, 1, rue Delambre. 77. Defendants knew this information, but Owens omitted it from her Series precisely because it contradicted the preconceived narrative she intended to tell. This omission was deliberate and is evidence of actual malice. 78. The December Retraction Demand reminded Owens that in addition to a first communion photo and family photo, there are additional publicly available photos of Mrs. Macron as a child. In one such photo, Mrs. Macron is playing in a garden as a young girl. This photo was mentioned in the 2021 Daily Mail debunking article and the December Retraction Demand, but Owens never shared it with her viewers because it does not fit her preconceived narrative. 79. The December Retraction Demand reminded Owens that Mrs. Macron's marriage to André-Louis Auzière and his existence were well documented. The most obvious proof of his existence is the three children he fathered with Mrs. Macron, all of whom have acknowledged him as their father and adopted his last name. Initially, Owens falsely stated that there were no publicly available photos of Mr. Auzière. The December Retraction Demand reminded Owens that a publicly available photo exists of Mr. Auzière from his wedding to Mrs. Macron. Since then, Owens has found at least one additional photo through her relationship with Xavier Poussard. 80. To discredit this photo, Owens initially claimed that the subjects are not Mr. Auzière and Mrs. Macron, but Jean-Louis Auzière with his first wife, Susan Spray. The December Retraction Demand reminded Owens that Jean-Louis debunked this claim, stating, "[w]hen André-Louis got married, I was 8 years older and I was working in Germany. There may be a slight family resemblance, but that's not to say that we are the same person. .”20 Indeed, Jean-Louis has testified in French court that the photo is not of him and won a defamation claim against Rey and Roy on that basis. 81. When Owens was confronted with this information, she changed her 20 Julien Lagarde, Trogneux affair: in Normandy, a couple collateral victims of rumors surrounding Brigitte Macron, Le Pays d'Auge, (May 16, 2022, at 19:23 CEST), https://actu.fr/normandie/lisieux_14366/affaire-trogneux-en-normandie-un-couple-victime- collaterale-des-rumeurs-autour-de-brigitte-macron_50917623.html. theory, but rather than accept this photo for what it is (an image of Mrs. Macron from her marriage to Mr. Auzière), Owens concocted a new story. She changed course in the Series to claim that Mr. Auzière is in the photo, but that Mrs. Macron is not. Instead, Owens claimed that it was another woman named Brigitte Trogneux and that Mrs. Macron refused to verify that the image was of her. Another lie. 82. Owens initially told her audience that no journalists could find Mr. Auzière, but this is plainly false. The December Retraction Demand reminded Owens that another Daily Mail debunking article explained that “[r]eporters for several outlets, including the Mail, tracked André-Louis down to Lille several years ago," but he declined to comment.21 That aligns with his family's statements that he was a very private man. The December Retraction Demand stated that Mr. Auzière passed away on December 24, 2019. His and Mrs. Macron's daughter, Tiphaine, spoke about his death afterward and noted that he was buried in “the strictest privacy” and that he was "a nonconformist who valued his anonymity more than anything." Tiphaine ended by stating, “he must be respected.” In her earlier reporting, Owens distorted these words and the family's request for privacy into “a warning, a threat almost, not Guy Adams, Revealed: Truth behind the conspiracy theory Brigitte Macron is really a MAN - as the Mail unmasks the woman being sued over the viral rumour, Daily Mail, (Mar. 22, 2024, at 22:12 https://www.dailymail.co.uk/femail/article-13228445/jolly-clairvoyant-viral- conspiracy-Macron-deny-wife-Brigitte-MAN.html. to look any further." In the Series, after being confronted with proof of Mr. Auzière's existence through his documented death and funeral, she again changed course and distorted the Auzière family's desire for privacy into a plot to coverup wrongdoing. The December Retraction Demand also informed Owens that Jean- Michel Trogneux is alive and well in Amiens. Emmanuelle Anizon, a journalist for L'Orbs magazine, reported having contact with him in Amiens in September 2023. This, too, was included in the Daily Mail's 2024 debunking article. 22 In fact, Ms. Anizon wrote an entire book disproving the disinformation campaign surrounding Mrs. Macron.23 Shockingly, Owens cites Ms. Anizon's book in the Series but fails to tell her viewers it completely disproves her central thesis. The December Retraction Demand provided evidence that Jean-Michel has recently appeared in public. He attended President Macron's investitures in 2017 and 2022, and the December Retraction Demand provided links to publicly available videos from those events. Not only was Jean-Michel present, but also in the same frame as Mrs. Macron-conclusive evidence that debunks Owens' demonstrably false claims: 23 Emmanuelle Anizon, L'affaire Madame: Le jour où la Première dame est devenue un homme: anatomie d'une fake news (2024). 11:35 DI ECT 2017 Investiture²4 11:56 DIRECT 2022 Investiture25 Video posted by BFMTV (@BFMTV), YouTube, Live Passation de pourvoir Macron/Hollande - Edition Spéciale BFMTV (May 14, 2017), https://www.youtube.com/watch?v=9tJPSCnIO_U. 25 Élysée, Cérémonie d'investiture du Président de la République., (YouTube, May 7, 2022) https://www.youtube.com/watch?v=uuaYB8tlaJk. 86. The December Retraction Demand informed Owens that Jean-Michel's defamation claims against Rey and Roy prove his existence and that he is not Mrs. Macron. At Rey and Roy's June 19, 2024 trial, Jean-Michel's attorney presented both Mrs. Macron's and Jean-Michel's electoral cards to the court, demonstrating that they had both voted in the European Elections on June 9, 2024, in different towns. As a result of that trial, Rey and Roy were ordered to pay Jean- Michel €5,000 in civil damages. This information is also publicly available, but Owens has never informed her audience of these facts, which disprove her claim. 87. The December Retraction Demand explicitly stated that Mrs. Macron is the biological mother of her three children, proving that she was born as woman and has not engaged in identity theft. In her earlier reporting, Owens claimed that Mrs. Macron fathered her three children with Brigitte Proba-Auzière, whom she falsely claimed was the niece of Jean-Louis Auzière, the uncle of Mrs. Macron's late ex-husband. She accused Jean-Louis of forging the children's birth certificates to hide Mrs. Macron's secret. This is the same Jean-Louis whom she claimed was in the wedding photo of Mrs. Macron and her first husband, and who has successfully sued Rey and Roy for defamation. Owens did not repeat these claims in the Series, but she has never retracted the prior false claims. Further, Owens initially claimed that the photo of Mrs. Macron-in which she is described as a thirty-six-year-old teacher named Brigitte Auizère-is not actually of her, but rather of the fictitious Brigitte Proba-Auzière. In doing so, Owens recklessly disregarded the facts that the photographed woman in this picture (1) had the same name as Mrs. Macron did at the time; (2) had the same occupation that Mrs. Macron had at the age of thirty-six; and (3) bears a striking resemblance to a younger version of Mrs. Macron. Owens later admitted that this was false but she never removed the episodes including this false claim. AUZIERE Brigitte Rue des Coquelicots Professeur de Français When Owens realized her claims about Mrs. Macron's children (i.e., that she fathered her children with the fictitious Brigitte Proba-Auzière) could not possibly be true, she dropped them—offering no alternative explanation, just a gaping hole. She counted on her audience being too captivated or too unquestioning to notice the gap, let alone call her out on it. The reason is clear: Any theory that claims Mrs. Macron is not the mother of her children recklessly disregards the striking resemblance between her and her daughters: 90. The December Retraction Demand reminded Owens that Mrs. Macron, Jean-Michel, and Jean-Louis, along with his wife, Catherine, have sued the originators of this theory, Rey and Roy, for defamation. On September 12, 2024, Rey and Roy were found guilty of defamation and ordered to pay damages to Mrs. Macron and Jean-Michel. Before that, the women were found guilty and fined for lying about Jean-Louis and Catherine. Owens disregarded this credible evidence because it contradicted her preconceived narrative. Owens responds with ridicule and doubles down. 91. On January 10, 2025, Defendants posted on X that the Macrons had sent Owens a legal letter. 26 That post demonstrated Owens' loose relationship with 26 Candace Owens (@RealCandaceO), X (Jan. 10, 2025, at 15:29 ET), https://x.com/RealCandaceO/status/1877814980399030350. the truth. In her X post, Owens claimed that “in mid-November, [she] made contact with a journalist claiming to have a trove of evidence to support the claim that the first lady of France lived as a man named Jean-Michel Trogneux before becoming and transitioning to Brigitte." Owens crafted the post to suggest that she had a new source, but the journalist was actually Poussard, whom she had already met and interviewed. Owens claimed that "just 10 days after [their] initial correspondence," the Macrons sent her a legal letter-proving that Owens saw and ignored the Macrons' initial outreach in early December. Owens claimed the Macrons “demanded [she] not publicize" the letter-in fact, the letter had only a heading stating it was not for publication or attribution, a far cry from the demand she claimed. Most troubling, Owens promised she would publicize the December Retraction Demand, but she never did. And the reason is clear the 33-page December Retraction Demand conclusively debunked Owens' claims and exposed her lies. 92. Owens knows a media firestorm when she sees one. Sensing an opportunity to amplify her claims and attract more attention, she falsely asserted that Tucker Carlson-a high-profile political commentator-was named in the December Retraction Demand. Defendants tagged Carlson on X, banking on the controversy to draw him in and further spread Owens' false narrative. Candace Owens @RealCandaceO Mentioned in this letter are @TuckerCarlson @TateTheTalisman @ArchbpVigano @RealAlexJones Jimmy Dore and many others. AND MR. MACI ARE UPSET. youtube.com I Got A Legal Threat From A Sitting President... | Candace E... Yesterday I received a legal letter from the Macrons. Today, I'll break down what this means and what surprises I have ... 3:32 PM Jan 10, 2025 1.3M Views Once again framing herself as a victim, in Defendants' January 10, 2025 episode of Candace, Owens claimed the Macrons attempted to personally serve her with the December Retraction Demand to “intimidate” and “terrify” her. 27 However, she neglected to tell her viewers that, in fact, the Macrons only resorted to personal service after she ignored multiple emails. Owens claimed the Macrons “strenuously requested” that she not publicize the December Retraction Demand and that the letter said “all over it” that it was not to be shared. Another, at best, gross exaggeration the letter contained only a standard first-page heading: "Confidential - Not For Publication Or Attribution." 94. Owens continued to refuse to meaningfully engage with the December 27 Video posted by Candace Owens (@RealCandaceO), YouTube, I Got A Legal Threat From A Sitting President..., https://www.youtube.com/watch?v=tJtAUKgkqc0. Retraction Demand. Instead, she intentionally led her audience to believe that the Macrons refused to say whether Mrs. Macron was born a woman or address Owens' other claims. But Owens knew that the December Retraction Demand addressed each of her claims and proved them to be false. Owens cherry-picked portions of the December Retraction Demand to read to her audience but did not present the evidence against her claims that it contained-because it contradicted her preconceived narrative. Indeed, Owens told her viewers that she had evidence disproving portions of the December Retraction Demand, but she was "not going to tell you that today." Spoiler: She never presented it. Owens leveraged the December Retraction Demand to generate buzz and build anticipation for her upcoming episodes. Again, Owens implied she had a new source with “a trove of evidence,” but that source was Poussard, whom she had already presented to her audience. She then falsely claimed that the timing of the December Retraction Demand demonstrated “the communications of the journalist are being monitored,” but admitted she had no evidence to support this. 96. Rather than reconsider her false claims, Owens doubled down, blaming the Macrons for her content being removed from YouTube and vowing not to retract what she "deems to be the truth." On January 11, 2025, Defendants posted on X that "all correspondence between our legal teams will be available for the public to read." Owens has not lived up to this promise because she knows the legal correspondence contradicts her false claims. As with her other false allegations, she promised “strong evidence" that the first communion photo was not Mrs. Macron (but never delivered it). She also pretended the Macrons had not definitively denied her claims-ignoring the clear, contradictory evidence they already provided. 98. Defendants continued to mock the Macrons' attempt to correct the record, demonstrating that Owens was not interested in the truth. She would rather make salacious and false claims to boost her revenue. For example, Defendants reposted and expanded on a post from Alexander Dugin (a far-right Russian philosopher and controversial figure) featuring Mrs. Macron as a Neanderthal and wondering if he, too, would be sent a retraction demand: 28 Candace Owens (@RealCandaceO), X (Jan. 11, 2025, at 13:41 https://x.com/RealCandaceO/status/1878150320762548707. Candace Owens @RealCandaceO - Jan 11 Will Emmanuel Macron now send a strongly worded letter to Alexander Dugin? How global is @Emmanuel Macron willing to go? Alexander Dugin @AGDugin Jan 11 We've made some fact-checking and can certified the first appearance of Briditte Macron from Neanderthalian cave in the South of France. He/she doesn't only belong to different gender but to different race than all the rest of the humans. On January 11, 2025, Defendants reposted on X the false assertion that the December Retraction Demand admitted that Mrs. Macron raped President Macron. This was blatantly false, and Owens knew it. The truth was that the December Retraction Demand pointedly denied that the President was statutorily raped. Candace Owens ✔ @RealCandaceO You will note the lawyers intentionally leave out how old Brigitte was. The public was told a lie from the very beginning. They were told Macron was 17 and Brigitte was 34. All of that was a media-curated tale to help bury the obvious perversion. Alex Stein #99 @alexstein99 - Jan 10 The French Government just admitted to @Real CandaceO that President Macron started his relationship with Brigitte when he was 15 years old and somehow that's not rape in France FRENCH GOVERNMENT CONFIRMS PRESIDENT MACRON WAS RAPED 1:21 PM Jan 11, 2025 1.2M Views 0:00/2:27 CC 100. On January 12, 2025, Defendants again reposted another claim that the December Retraction Demand admitted that Mrs. Macron raped President Macron and agreed it "was indeed the most stunning admission from the letter." Owens repeated this claim on Defendants' January 13, 2025 episode. Again, Owens knew these statements were false when she made them, but the truth did not matter when there were followers to be gained. 101. Owens' response to the December Retraction Demand was picked up by other media outlets, who understood from Owens that the Macrons had not provided any denials or evidence against her false claims, including that the Macrons were lying about Mrs. Macron's biological sex, just as Owens intended. 29 Those same outlets described Owens as doubling down on all her claims. 102. Defendants prioritized profit over truth and used the December Retraction Demand as fuel for even more content. On January 13, 2025, Defendants posted on X that Owens was sharing her legal response to the Macrons- she had not yet sent to them.30 In Defendants' January 13, 2025 episode, Owens promised to upload her entire response to her Locals page yet again, she did not follow through.31 Brigitte Macron was born a man: Candace Owens spreads crazy conspiracy theory about Emanuel India (Jan. https://timesofindia.indiatimes.com/world/europe/brigitte-macron-was-born-a-man-candace- owens-spreads-crazy-conspiracy-theory-about-emanuel-macrons- wife/articleshowprint/117208515.cms; French President Emmanuel Macron Says His Wife Does Not 'Owe' Candace Owens 'Proof' She Is and 'Always Has Been a Woman' in Stern Legal Letter, OK! Magazine, (Jan. 10, 2025, at 18:33 ET), https://okmagazine.com/p/emmanuel-macron-legal- letter-wife-doesnt-owe-candace-owens-proof-woman/; Jenel Treza Albuquerque, Candace Owens says Emmanuel Macron sent her a legal letter after she met a journalist who claimed Brigitte Macron was "born a man", Soap Central, (Jan. 12, 2025, 18:54 ET), https://www.soapcentral.com/entertainment/news-candace-owens-says-emmanuel-macron-sent- legal-letter-met-journalist-claimed-brigitte-macron-born-man; Candace Owens responds to Emmanuel Macron's legal threat after claiming his wife is transgender, The Express Tribune, (Jan. 11, 2025), https://tribune.com.pk/story/2521484/candace-owens-responds-to-emmanuel- macrons-legal-threat-after-claiming-his-wife-is-transgender; President Emmanuel Macron and Wife Brigitte Send Candace Owens Legal Threat Over 'Gender' Report as Far-Right Pundit Laughs it Off - You're Not Above Critique', Radar, (Jan. 10, 2025, at 19:30 ET), https://radaronline.com/p/candace-owens-emmanuel-macron-brigitte-macron-transgender- allegations-letter-legal/. Candace Owens (@RealCandaceO), X (Jan. https://x.com/RealCandaceO/status/1878900942986432750. 2025, at 15:24 ET), 31 Video posted by Candace Owens (@RealCandaceO), YouTube, I Respond To Mr. And Mr. Macron, Candace Ep. 131 (Jan. 13, 2025), https://www.youtube.com/live/mQoVHeeynNA. 103. At that point, Owens decided to escalate her claims further. In that same episode, Owens falsely implied that the Macrons were responsible for the death of a journalist investigating them. Owens claimed that the Macrons have a “dark side” and “one by one, these independent journalists and researchers begin to suffer." Noting that "this is a true story," Owens told her audience about Isabella Ferreira, who was investigating the Macrons' relationship and "landed upon something bigger" and "two weeks later, this Isabella Ferreira is found dead.” The authorities ruled Ferreira's death a suicide, but Owens claimed that was “almost impossible." The intended, unavoidable, and false implication is that Ferreira was killed for investigating the Macrons. 104. Owens repeated that the December Retraction Demand did not "deny that Brigitte is trans” or “explicitly state that Brigitte Macron was born a biological woman." This is false. The December Retraction Demand explicitly stated that the Macrons were not concealing Mrs. Macron's biological sex and that she was born Brigitte Trogneux, a woman. 105. Owens told the Macrons to "bring this lawsuit." She continued, “[d]on't even waste your money on getting a courier to file. I'll file it for you . . . I'll run down to the courthouse and file the lawsuit for you.” Owens claimed, “I might even cover your legal expenses." Owens displayed her ill will toward the Macrons, stating, "I am disgusted by your relationship. You make me sick, Brigitte." 106. On January 16, 2025-several days after publicly referencing its contents Owens finally sent a response to the December Retraction Demand to the Macrons' counsel. Rather than retract her demonstrably false statements, Owens defiantly reaffirmed them. She provided no evidence or justification to support her defamatory claims. Instead, she attempted to trivialize the matter by insisting that the Macrons reframe their denials as responses to 21 questions-an apparent effort to convert her baseless "investigation” into a publicity stunt. Owens then misled her audience by claiming that, because she had posed these questions, the Macrons could never prove actual malice. 32 She failed to disclose, however, that the Macrons had already addressed the substance of her questions within the December Retraction Owens releases an eight-part series pushing the conspiracy, packed with false and defamatory claims she knows are blatantly false. 107. On January 31, 2025, Defendants premiered the Series. The Series began with an introductory episode, followed by six chapters, and concluded with an epilogue. Throughout the Series, Owens made the false and defamatory allegations that Mrs. Macron, born a man, stole another person's identity to become Brigitte; Mrs. Macron and President Macron are blood-relatives involved in incest; Video posted by Candace Owens (@RealCandaceO), YouTube, OH SNAP! Justin Baldoni Is Now Suing Blake Lively and Ryan Reynolds PERSONALLY, Candace Ep. 134 (Jan. 16, 2025), https://www.youtube.com/watch?v=gTiobOd9MAM. President Macron was chosen to be the President of France as part of MKUltra or a similar mind control program; and Mrs. Macron and President Macron are committing forgery, fraud, and abuses of power to cover up these “facts." These claims are demonstrably false, and Owens knew it when she published them. An Introduction January 31, 2025 108. The first installment, titled "An Introduction," premiered on January 31, 2025.33 Defendants announced the introductory episode on X.34 The episode can be found on CandaceOwens.com, YouTube, Spotify, Audible, iHeartRadio, Apple Podcasts, and Amazon Music. A transcript is available on YouTube, Spotify, Apple Podcasts, and PodScribe. 33 Video posted by Candace Owens (@RealCandace), Becoming Brigitte: An Introduction, https://www.youtube.com/watch?v=FDOnxpViQxY&list=PLPW2eH9z9CUvJ0liv9AQqq2RVA WFFfNZR&index=8. 34 Candace Owens (@RealCandaceO), X (Jan. https://x.com/RealCandaceO/status/1885330518352318558. 2025, at 09:13 ET), Candace Owens @RealCandaceO - Jan 31 Despite all of the censorship and prosecution in France we are already trending. Because today is #BecomingBrigitte Day. The French citizens have been gaslit for years by their media. That ends today. Jean-Marie Le Pen OMING GITTE IGATIVE SERIES DACE OWENS 3 Sport Tedes Brest Tendance de la catégorie france Candace Owens @RealCandaceO La Trinité-sur-Mer CandaceOwens See you at 4pm ET as we begin to awaken the world to the sadistic world of Brigitte and her groomed pet, @Emmanuel Macron plus the power structures that protect them both. 9:13 AM Jan 31, 2025 930.9K Views 109. Just before the premiere of the Introduction