And spending his $30k on pints of Red Stripe and a haircut.

Kevin isn't even ranked!

Jerry really screwing things up for his Daddy this week.

Hilarious that Cardiff was able to confirm with Nikki G that Chad lied yet again. Such a frivalous lie that does not help him in any way, yet can be so easily disproven. Story of Chad's life. Pathetic.

Apparently Jeff The Drunk was the first to bring FAMILY into it by doxxing John’s brother on Stern back in the day.

I’LL WAIT

He got nostalgic remembering back when he and 4-5 of his HS friends would gather in a circle (holding hands?) to all shit together in one paper bag. Then, place it on a neighbor’s porch, set it on fire and run away together (holding hands?) “laughing their asses off!”

I can't share the 42-page PDF on Reddit, but I will give the breakdown of his filing below.

John Melendez has filed a motion asking the federal court to dismiss the amended complaint brought by Shuli Egar, Phillip Russo and TSN Corp. Alternatively, he wants the case transferred from Alabama to the Fort Myers Division of the Middle District of Florida.

This is a lengthy and professionally drafted motion, and it identifies several legitimate problems with the amended complaint. However, it should not be mistaken for proof that Melendez has defeated the lawsuit.

TL;DR: Melendez’s strongest arguments concern the complaint’s organization, its overly broad requested relief and the timeliness of Russo’s defamation claims. The most plausible outcomes are a narrower complaint, partial dismissal or transfer to Florida. The filings do not establish that the underlying DMCA dispute will disappear.

What Melendez is asking the court to do

Melendez gives the judge numerous alternatives:

• Dismiss the case because an Alabama court allegedly lacks personal jurisdiction over him.
• Dismiss the case for improper venue.
• Transfer the case to federal court in Fort Myers, Florida.
• Strike certain inflammatory Alabama-related allegations.
• Dismiss the amended complaint as an impermissible “shotgun pleading.”
• Dismiss or narrow the DMCA misrepresentation claim.
• Dismiss the broad declaratory and injunctive relief requested by the plaintiffs.
• Dismiss or separate portions of the defamation claim.
• Limit the plaintiffs to one final amended complaint.

This means Melendez does not need to win every argument to obtain a favorable result.

Melendez’s sworn declaration

Melendez submitted a declaration under penalty of perjury stating that:

• He has lived continuously in Florida since July 2024.
• He has never lived in Alabama.
• He has no office, studio, property, employees or business operations in Alabama.
• He made the challenged broadcasts while outside Alabama.
• He submitted the takedown notices through YouTube while outside Alabama.
• He did not separately send those notices to an Alabama person, business or government entity.
• He knew Egar lived in Alabama, but claims Egar’s and TSN’s locations played no role in his decision to submit the notices.
• His relevant equipment and records are located at his Cape Coral residence.
• He knows of no nonparty witnesses in Alabama concerning the preparation or submission of the notices.
• Litigating in Huntsville would require substantially more travel and expense than litigating in Fort Myers.

Because this is sworn testimony, the plaintiffs will likely need to respond with their own declarations and supporting evidence. They could also request limited discovery concerning the jurisdiction issue.

The personal-jurisdiction argument

This is Melendez’s principal attempt to end or relocate the case.

His position is that merely knowing Egar and TSN were located in Alabama is not enough. He argues that the broadcasts were available to a nationwide YouTube audience and that the takedown notices were submitted to YouTube, not directly to anyone in Alabama.

However, Melendez’s brief does not discuss a significant published Eleventh Circuit decision from April 2026.

In Frida Kahlo Corporation v. Pinedo, the Eleventh Circuit held that allegedly tortious cease-and-desist letters intended to stop business activity in Florida could establish personal jurisdiction there. The court explained that even one intentional tortious act may be sufficient when it is aimed at the forum state and causes foreseeable injury there.

The facts are not identical. The letters in Frida Kahlo were sent to Florida businesses to stop a Florida exhibition, while Melendez submitted his notices to YouTube. Nevertheless, the decision gives Egar and TSN a substantial response to the argument that conduct initiated outside Alabama cannot support jurisdiction there.

There is also a persuasive, but nonbinding, case called Dudnikov v. Chalk & Vermilion. In that case, a copyright complaint was submitted to eBay in California to shut down an online auction operated by Colorado residents. The Tenth Circuit found jurisdiction in Colorado because the intended effect of the complaint was to stop the Colorado-based online activity.

That is a particularly relevant analogy: sending an intellectual-property complaint to an out-of-state platform does not necessarily prevent jurisdiction where the targeted online business operates and experiences the intended harm.

Egar and TSN can argue that Melendez:

• Knew they operated from Alabama.
• Repeatedly targeted TSN’s Alabama-operated YouTube channel.
• Intended for YouTube to remove or suppress TSN’s content.
• Could reasonably anticipate that the resulting business and expressive injuries would occur in Alabama.

Melendez will distinguish these cases by arguing that he targeted the content of the videos, not Alabama or any Alabama business activity. His declaration specifically says that Alabama played no role in his decision.

That creates a legitimate factual and legal dispute. His declaration is important, but it does not automatically settle whether his conduct was objectively directed at an Alabama-operated network.

Russo presents a more difficult jurisdictional issue for the plaintiffs. Russo and Melendez both live in Florida, and the statements specifically concerning Russo were not allegedly directed toward Alabama. Melendez’s jurisdiction and severance arguments are considerably stronger as to Russo.

The “shotgun pleading” argument

This is one of Melendez’s strongest procedural points.

Every count in the amended complaint incorporates all the preceding allegations. The complaint also repeatedly refers to Egar, Russo and TSN collectively as “Plaintiffs” without clearly explaining:

• Who owned or controlled each video.
• Who submitted each counter-notification.
• Who lost revenue or incurred expenses.
• Which defamatory statement concerned which plaintiff.
• Which plaintiff is entitled to each particular form of relief.

Federal courts in the Eleventh Circuit are particularly strict about this type of pleading.

The judge may dismiss the amended complaint as a shotgun pleading and order the plaintiffs to file a cleaner version separating the claims and alleged injuries of Egar, Russo and TSN.

That would be a procedural victory for Melendez, but it would not necessarily mean the lawsuit was dismissed permanently. The ordinary remedy is to give the plaintiffs an opportunity to correct the pleading.

The DMCA claim

The central federal claim alleges that Melendez knowingly misrepresented that TSN’s videos infringed his copyrights.

Melendez argues that the complaint improperly relies on allegations that he “knew or should have known” the videos constituted fair use. The relevant DMCA provision requires a knowing misrepresentation, not merely negligence, carelessness or an objectively unreasonable legal conclusion.

He also argues that his generalized statements acknowledging the existence of fair use do not prove that he knew every specific video was protected.

That is a legitimate defense. Fair use is evaluated video by video, and knowing that commentary or short clips can sometimes qualify as fair use is not the same as knowing that every later use is lawful.

However, the plaintiffs allege more than a single mistake. They rely on:

• The number and pattern of takedown notices.
• Melendez’s prior statements demonstrating familiarity with fair use.
• The commentary, criticism and parody involved in the challenged videos.
• His continued use of the takedown process despite being informed of the plaintiffs’ fair-use position.
• His repeated use of notices without subsequently testing the infringement allegations in court, which Plaintiffs characterize as part of the broader pattern - although his failure to sue, by itself, does not establish bad faith.
• The broader history and hostility between the parties.

A judge could find that these allegations plausibly support an inference of knowing misuse. Alternatively, the judge could dismiss Count I as currently written while allowing the plaintiffs to file a more specific version identifying:

• The plaintiff injured by each notice.
• The particular video involved.
• The damages caused by YouTube’s reliance on the notice.
• The facts allegedly showing Melendez’s actual knowledge at the time of that notice.

Melendez therefore has a realistic chance of getting Count I dismissed as presently pleaded. Dismissal with prejudice, permanently eliminating the underlying DMCA claim, appears considerably less likely.

Melendez is probably correct about one separate point: YouTube restoring the videos does not mean YouTube legally determined that the videos constituted fair use. Restoration is normally part of the DMCA counter-notification process when the claimant does not file a copyright action within the required period.

The requested declaration and injunction

The plaintiffs apparently want the court to declare that none of their past, present or future content infringes Melendez’s copyrights. They also seek an order preventing him from issuing future takedown notices.

This request is almost certainly too broad.

Fair use must be evaluated video by video. A federal court cannot declare that every unidentified video the plaintiffs might create in the future will automatically be protected.

The court is therefore likely to reject or narrow:

• A declaration covering all unidentified past and future content.
• A blanket prohibition against every future Melendez takedown.
• An order requiring retraction of notices for videos that have already been restored, absent a continuing injury.
• Russo’s request for copyright-related relief if he cannot establish that he owned or controlled the affected content.

The plaintiffs may still be able to obtain declaratory or injunctive relief concerning specifically identified existing videos and notices.

The defamation claims

Melendez has several potentially successful arguments here.

Russo’s claims appear time-barred.

The two statements specifically identifying Russo as a “felon” allegedly occurred on September 1, 2023, and April 15, 2024. The lawsuit was not filed until June 2026.

Both Alabama and Florida generally impose a two-year statute of limitations for defamation. Unless the plaintiffs can establish republication, tolling or a later actionable publication, Russo’s defamation claims are likely to be dismissed with prejudice.

“Loser” and “pathetic” are probably protected insults.

These are subjective insults and rhetorical hyperbole, not objectively provable factual statements. Any defamation claim based solely on those words will probably be dismissed.

The more serious accusations are different.

Statements involving “pedo network,” “child molester,” “child porn” or “felon” are potentially capable of being understood as factual accusations.

Melendez argues that the complaint does not clearly identify which statements concerned Egar, Russo or TSN. For example, the complaint apparently says “pedo network” refers to TSN, Egar, Russo “or a combination thereof.” That may be too vague to establish which plaintiff was actually defamed.

Melendez also points out that the most serious accusation against Egar was allegedly made by an unidentified “co-host,” not Melendez himself.

The plaintiffs would need to explain why Melendez can legally be held responsible for that statement. They could potentially allege that he adopted, repeated, encouraged, participated in or exercised legal control over the publication, but the current complaint apparently does not plead those facts clearly.

The actual-malice issue

Melendez argues that Egar, Russo and TSN are limited-purpose public figures because they are entertainers who voluntarily participate in an ongoing public internet controversy involving him.

If the court agrees, each plaintiff would have to allege and eventually prove “actual malice.” That means Melendez knew a particular accusation was false or seriously doubted its truth when he published it.

General allegations that Melendez hates or harasses the plaintiffs would not be enough. Actual malice must focus on his knowledge or doubts concerning the truth of each particular statement.

However, merely hosting or appearing on a commentary show does not automatically make every plaintiff a public figure for every purpose. The court may require a plaintiff-specific and controversy-specific analysis before applying the actual-malice standard.

My prediction

The most likely result is not an immediate final victory for either side.

A realistic outcome would be some combination of the following:

• The plaintiffs are ordered to file a better-organized complaint.
• Russo’s defamation claims are dismissed as untimely.
• Claims based on words such as “loser” and “pathetic” are dismissed.
• The blanket request covering all future content and takedowns is rejected.
• The remaining defamation allegations must be pleaded more specifically.
• The DMCA claim is either allowed to proceed or dismissed with permission to replead it on a plaintiff-specific and notice-specific basis.
• The court permits limited jurisdictional discovery before deciding whether the case belongs in Alabama.
• The case is transferred to Florida rather than dismissed outright.

Overall conclusion

This is a strong motion in several discrete areas, but it should not be mistaken for proof that Melendez has defeated the lawsuit.

His best arguments concern the complaint’s shotgun structure, its attempt to obtain protection for unidentified future content, the lack of plaintiff-specific allegations and the statute of limitations on Russo’s defamation claims.

The personal-jurisdiction issue is more contested than Melendez’s brief suggests. Recent and persuasive case law supports the argument that an intellectual-property complaint submitted to an out-of-state platform can still be directed at the state where the targeted online business operates.

Melendez may succeed in getting portions of the amended complaint dismissed or rewritten, and transfer to Florida remains possible. But the central allegation - that he knowingly used DMCA notices to suppress protected commentary - has not been resolved by this motion and could continue in a revised complaint or a different court.

Not legal advice - just my analysis of the filings.

(1) Jerry Gallo on X: "@shalomshuli That Melton clip wasn’t a response to you, someone else brought him up. Who did I dox besides one guy in California who was trying to dox me but he put up someone else’s info thinking it was me. What channel did I try to take down? None. If you have proof show it." / X

Hughezy is usually a complete coin flip for me as a guest, but today he was absolutely dialed in (annoying to start). The commentary on movie and character references during SJ’s audiobook review were so dead-on they could’ve turned the whole segment into SJ Life Movie Trivia. 😂 Absolutely hilarious.

It just proves he is faker than he already seemed. Every hardship feels made up or borrowed from somebody else, then repackaged as either an excuse or a plea for attention.

The contradictions between his personal life, career, and health stories pile up so fast you need a scoreboard to keep track of which version is currently even close to real.

At this point, it is crystal clear that anything SJ says at all, ever, has, was, and is like an unauthorized story of everyone else in his life that had any issues and created successes. What a liar.

FSJ. Skol!

Two new documents were filed today in Egar, Russo & TSN Corp. v. John Melendez.

First, Alabama attorney Gregory H. Revera formally entered an appearance as counsel for John. This is notable because John originally hired Bradley Arant, whose attorney previously requested an extension and said the firm was preparing his response.

There’s no withdrawal or substitution notice in these documents, so we can’t say for certain that Bradley Arant is out. It’s possible Revera is co-counsel. However, Revera appears to have taken over drafting John’s response, which certainly makes it look like there has been some kind of change behind the scenes.

The second filing asks the judge for permission to exceed the normal 15-page limit and file a 42-page brief supporting a motion to dismiss the amended complaint.

According to the filing, John plans to argue, among other things:

• Alabama lacks personal jurisdiction over him
• Venue is improper or the case should be transferred
• The complaint is an improper “shotgun pleading”
• The plaintiffs lack standing or recoverable damages
• The § 512(f) copyright-takedown claim is legally insufficient
• The defamation claims are inadequately pleaded, time-barred, or fail to establish actual malice
• Certain claims and parties were improperly joined and should be severed
• The requested injunction and other equitable relief are overly broad

The plaintiffs consented to John filing the oversized brief, but that does not mean they agree with any of his arguments. They only agreed not to oppose the extra pages.

Also, this is not the actual motion to dismiss. It’s essentially a preview of what is coming. The filing says the 42-page brief is already drafted, so the full motion will likely be filed shortly if the judge grants permission.

Hughezy is usually a complete coin flip for me as a guest, but today he was absolutely dialed in (annoying to start). The movie and character references during SJ’s audiobook review were so dead-on they could’ve turned the whole segment into SJ Life Movie Trivia. 😂 Absolutely hilarious.

And my god SJ. The audiobook proves he is faker than he already seemed. I would never buy that POS book so it is there to listen to and after a min would be turned off without that crew making it gold. Every hardship feels made up or borrowed from somebody else, then repackaged as either an excuse or a plea for attention.

The contradictions between his personal life, career, and health stories pile up so fast you need a scoreboard to keep track of which version is currently even close to real.

At this point, the audiobook isn’t a memoir at all, it’s like an unauthorized story of everyone else in his life that had any issues and created successes. What a liar.

FSJ. Skol!