Gregory T. Fayard, State Bar No.

212930
1 CARDINALE FAYARD, APLC

2 3800 Watt Ave., Suite 245

Sacramento, CA 95821
3 Tel: (916) 244-9116
Fax: (916) 244-9130
4 greg.fayard@cardinalefayardlaw.com

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Attorneys for Plaintiff SCOTT ALVORD
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA

9 COUNTY OF PLACER
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SCOTT ALVORD, Case No.
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Plaintiff, VERIFIED COMPLAINT FOR:
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1. Defamation
v.
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2. False Light
14 MATTHEW OLIVER; HOUSE OF OLIVER,
INC.; AARON F. PARK, and DOES 1 through 3. Unfair Business Practices
15 100
4. Declaratory Relief
16 Defendants. JURY TRIAL DEMANDED
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18 Plaintiff RAYMOND SCOTT ALVORD (“ALVORD”), hereby alleges as follows:

19 GENERAL ALLEGATIONS
20 A. The Parties
21 1. Plaintiff SCOTT ALVORD is, and at all relevant times was, an individual residing
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in the County of Placer, State of California. He is small business owner, adjunct college faculty
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professor, and council member for the city of Roseville, California. At the time of filing, he was
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also a candidate for Placer County supervisor.
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26 2. Defendant MATTHEW OLIVER (“OLIVER”) is, and at all relevant times, was an

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Attorneys at Law
27 individual residing in the County of Placer, State of California.

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COMPLAINT
 3. Defendant HOUSE OF OLIVER, INC. is a California corporation doing business in
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2 the County of Placer, State of California. It is a wine lounge and restaurant located in Roseville,

3 California. On information and belief, it is owned and operated by officer, director and/or

4 shareholder OLIVER.
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4. On information and belief, Defendant AARON F. PARK (“PARK”) is, and at all
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relevant times, was an individual residing in the County of Placer, State of California and/or the
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County of Washoe, State of Nevada. He publishes RightOnDailyBlog.com which, on information
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and belief, is a business enterprise that generates income from multiple sources for PARK.
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10 5. ALVORD is informed and believes and, based thereon, alleges that each Defendant,

11 including DOES 1 through 100, was and is the agent, servant, employee, partner, joint venturer or
12 other legal connection of each other Defendant, and that each Defendant was acting within the
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course and scope of such agency, employment, partnership or joint venture, and with the consent
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or the ratification of each other in doing the things alleged here.
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B. Factual Background
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17 6. ALVORD lives and works in Roseville, California, where he raised his family of

18 seven over the last 30-plus years. He has 13 grandchildren. He is a small business owner and

19 dedicated community leader currently on Roseville’s city council, having been elected twice to
20 that office. In January 2022, ALVORD announced his candidacy for Placer County Supervisor,
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District 2. The second district includes western Roseville (where ALVORD lives), Lincoln, and
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rural areas up to Sheridan. ALVORD prevailed in the June 7, 2022 primary election and is one of
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two candidates in the November 8, 2022 general election.
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25 7. In so doing, ALVORD overcame a brutal, hateful, lie-filled smear campaign against

26 him by OLIVER, HOUSE OF OLIVER, and PARK, all of whom defamed him, damaged his

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27 reputation, and cast him in an offensive false light to the public, the college community and
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2
COMPLAINT
 students where he teaches part-time, and his small business customers. The defamatory and false
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2 statements tried to characterize ALVORD as something he is not—someone who favors

3 overruling parental freedom of choice as it relates to children and prior COVID restrictions and

4 policy, and as someone who is “bad for Placer County business.” The opposite is true. ALVORD
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supports individual and business choice regarding COVID vaccines. He never supported the
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forced masking of children. He is also a zealous supporter of Placer County businesses—being a
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small business owner himself.
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8. PARK regularly cast false aspersions on ALVORD through his blog, which remain
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10 published. For example, on October 16, 2020, regarding ALVORD’s part-time teaching of various

11 business classes at William Jessup University, PARK said “ALVORD requires the students of his
12 classes to purchase his book as required reading!” This is a flat lie.
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16 9. PARK further stated ALVORD insists his Jessup students refer to him as

17 “professor,” even though his title was in fact “adjunct professor.” This is also a lie. Even the

18 president of the university, John Jackson, rebutted PARK’s October 16, 2020 blog and its false
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statements:
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10. On March 13, 2022, OLIVER in HOUSE OF OLIVER posted a video on the
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internet that stated ALVORD was a “bold faced liar,” a “snake in the grass,” a “wolf in sheep’s
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26 clothing,” and “not pro small business.” He also said: “One guy has actually sent his little minions

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27 out there to shut restaurants down to report them to the Alcohol Beverage Control, to the Health
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28 Department, to CalOSHA. One person had his minions do that. Scott Alvord.”
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COMPLAINT
 1

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11 11. ALVORD is not a “bold faced liar,” is not a “snake in the grass,” is not a “wolf in
12 sheep’s clothing,” and is pro small business. ALVORD did not send anyone—minions or others—

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to report OLIVER or HOUSE OF OLIVER to any government agency at any time.
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12. On March 22, 2022, OLIVER and HOUSE OF OLIVER posted another video on
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Facebook about ALVORD, depicted below:
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COMPLAINT
 13. In this video, OLIVER and HOUSE OF OLIVER stated ALVORD is a fraud and
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2 bad for business. He also said: “By the way, there was only one city council member who was

3 trying to help get me arrested by the Governor during the shutdown and that person was Scott

4 Alvord.” OLIVER further said: “He [ALVORD] tried to assist in my arrest from the governor.”

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ALVORD is not a fraud and he supports business, being a small business owner active for years in
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Placer County’s small business community. Further, ALVORD did not try to help, or assist, in
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getting OLIVER arrested by the governor.
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14. On March 23, 2022, PARK posted a doctored and incomplete video on YouTube
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10 stating ALVORD “Force Vaccines” and “Forced Mask for Kids” and that he was “Bad for Kids,

11 Bad for Families, Bad for Business.”

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5
COMPLAINT
 15. ALVORD supports individual and business choice regarding COVID vaccines. He
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2 never supported the forced masking of children. As a city council member, he has no jurisdiction

3 over COVID policies in schools. The city council abstained entirely from COVID policies,

4 including whether children and students should be forced to take vaccines or wear masks. In fact,

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the city council’s position was to seek local control of COVID policy. ALVORD also is good for
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kids, good for families, and definitely good for business.
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16. On March 21, 2022, PARK posted on his blog, which OLIVER also posted on May
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15, 2022, the following graphic:
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23 17. PARK stated on his blog that he did not create this graphic, but “wish[ed he] had.”

24 The graphic has had widespread dissemination, resulting in some potential constituents calling him

25 a “fraud” to his face.

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COMPLAINT
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7
COMPLAINT
 18. On May 15, 2022, HOUSE OF OLIVER also published the following, including the
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2 statements that ALVORD is for “forced vaccines on our kids,” and “forced masks” is “anti small

3 business” and “is a fraud.”

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12 19. The “Liar & Fraud” graphic presents no examples of ALVORD lying or making any
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misrepresentations. The statements in the graphic that ALVORD is pro big government who
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refused to stand for families, and has hurt small businesses, ignores the facts that he has owned
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several small businesses and is not in favor of the state or federal government over-regulating
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17 business owners. Additionally, ALVORD stood for families after the COVID pandemic began

18 through a Community Volunteer Force, where he supported families with free computers, food,

19 hard-to-find toilet paper, sanitizing wipes, diapers, gift cards, and shopping services. ALVORD
20 was also voted “Favorite Local Hero” in 2020 and 2021. Further, ALVORD also promoted small
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business through his nine years as president of the Downtown Roseville Merchants and by
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organizing the Placer Valley Business Summit in 2022. In 2022, he was recognized by the
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Roseville Chamber of Commerce for bringing in the most new members. Additionally, when the
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25 pandemic started, ALVORD helped get outdoor seating platforms for restaurants in Placer County

26 and supported a $1 million grant to help small businesses. ALVORD also runs a weekly business

Cardinale Fayard, APLC

27 mastermind group for Christian small business owners.
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8
COMPLAINT
 20. Regarding the statements in the graphic, “wear your damn mask” and “stop whining
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2 when our businesses get shut down,” what is omitted is these statements came from ALVORD’s

3 Facebook post on November 16, 2020, before vaccines, and when local small businesses were

4 particularly suffering. The only way businesses were going to legally re-open was to lower
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infection rates by getting out of the purple zone. To increase the chances of lower infection rates
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so that small businesses in Placer County could re-open, ALVORD favored wearing masks in
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large indoor gatherings. The concern that infection rates would rise, which would keep small
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businesses closed, outweighed his personal annoyance and inconvenience of wearing masks inside
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10 for large gatherings. To that end, ALVORD always wanted small businesses to stay open after the

11 pandemic began. He did not want the pandemic to “kill more businesses,” and advocated for
12 slowing the spread through the wearing of masks inside where large gatherings congregated in the
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fall of 2020. Here is the full post from November 16, 2020, which OLIVER and PARK omitted
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when they published the “Liar & Fraud” graphic. PARK has since cited ALVORD’s November
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16, 2020 post on September 14, 2022 to label ALVORD as someone who “looks like” a fraud.
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9
COMPLAINT
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10
COMPLAINT
 21. ALVORD objected to the “Liar & Fraud” graphic, labeling it libelous and
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2 slanderous:

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22. PARK has also published that ALVORD is a “communist” or has “communist
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roots” and/or is “socialist.” But ALVORD is neither communist nor socialist. He is a capitalistic
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business entrepreneur who has run his own small businesses for decades. PARK also referred to
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17 ALVORD as “All-Fraud,” a play on “Alvord.” PARK, OLIVER and HOUSE OF OLIVER have

18 accused ALVORD of reporting or having his “minions” report OLIVER’s businesses to

19 CalOSHA, the Department of Health, and/or the alcohol control board. That is a lie. ALVORD did
20 no such thing. Nor did he have any “minions” report OLIVER or HOUSE OF OLIVER to any
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governmental body.
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FIRST CAUSE OF ACTION
23

24 Defamation Against OLIVER, HOUSE OF OLIVER, PARK and DOES 1-100

25 23. ALVORD repeats and re-alleges paragraphs 1 through 22 as though fully set forth

26 herein.
27
Cardinale Fayard, APLC
Attorneys at Law 24. By publishing and re-publishing the “Liar & Fraud” graphic on various social
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11
COMPLAINT
 media, the internet, and/or blogs, OLIVER, HOUSE OF OLIVER and PARK made the following
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2 statements concerning ALVORD:

3 a) “Scott Alvord Forced Masks for Children.”

4 b) “Scott Alvord Forced Vaccine For Schools.”

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25. HOUSE OF OLIVER publishing on social media and the internet the following
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statements: “He [ALVORD] is for forced vaccines on our kids.”
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26. PARK published a doctored and incomplete YouTube video of a protest of
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ALVORD which included the statement that ALVORD supports: “Forced Mask for Kids” and
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10 “Force Vaccines.”

11 27. These statements are false. OLIVER, HOUSE OF OLIVER, and PARK intended to
12 make these statements and in making them, they knew or should have known that ALVORD, as a
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Roseville city councilmember, local businessman, adjunct professor, and candidate for County
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Supervisor had no jurisdiction over COVID policies in schools. The city council abstained entirely
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from COVID policies, including whether children and students, or anyone, should be forced to
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17 take vaccines or wear masks.

18 28. These statements are defamatory because they carry the meaning that ALVORD, as

19 a city council member, sought to force children to wear masks and sought to force COVID
20 vaccines for students in schools. ALVORD never sought to force children to wear masks. The
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Roseville City Council, of which ALVORD was a member, did not seek to force children to wear
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masks. Likewise, ALVORD does not support forcing students to get vaccines and never sought to
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force vaccines on anyone, which he has publicly stated.
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25 29. The false statements set forth above have been understood to those who saw or

26 heard them to mean that ALVORD, as a city council member, advocated for or sought to force

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27 children to wear masks or advocated for or sought to force COVID vaccines for students in
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12
COMPLAINT
 schools. The opposite is true. He is for individual and business freedom with regard to masks and
1

2 vaccines.

3 30. These false statements set forth above were and are defamatory because they tend to

4 injure ALVORD in his profession, trade and business by imputing to him a position he does not
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hold: that he sought or advocated forced masking of children and forced vaccines of students, or
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anyone for that matter.
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31. These words published by OLIVER, HOUSE OF OLIVER, and PARK were stated
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not as a matter of opinion, but as a matter of fact, and therefore were not protected or privileged in
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10 any way.

11 32. At no relevant time did ALVORD ratify or consent to the dissemination of the
12 statements set forth above. In fact, ALVORD has objected to these statements publicly as being
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defamatory and which should be retracted.
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33. ALVORD is informed and believes and thereon alleges that OLIVER, HOUSE OF
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OLIVER, and PARK’s defamatory statements herein were re-published by others. OLIVER,
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17 HOUSE OF OLIVER, and PARK made the false statements with malice as evidenced by video

18 footage and blog posts indicating they have personal animus toward ALVORD as a person and

19 local elected official, including PARK’s name-calling by insinuating ALVORD is a fraud, with
20 communist roots and a socialist (both are false). OLIVER and HOUSE OF OLIVER’s animus and
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malice is evidenced by the statements that ALVORD is a fraud, a snake in the grass, a wolf in
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sheep’s clothing. These statements occurred after OLIVER sandbagged ALVORD in what was
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supposed to a fair and balanced interview on or about January 26, 2022.
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25 34. As a proximate result of OLIVER, HOUSE OF OLIVER, and PARK’s publication

26 of the false statements set forth above, ALVORD suffered loss of his reputation, shame,

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27 mortification, embarrassment and humiliation, all to his general damages in a sum to be proven at
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13
COMPLAINT
 trial.
1

2 35. As a further result of OLIVER, HOUSE OF OLIVER, and PARK’s publication of

3 the false statements, ALVORD has suffered special damages according to proof in that the

4 defamatory statements suggest that ALVORD is unfit to be a Placer County Supervisor because he
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sought and advocated for forced vaccines for students and forced masks for children—both lies.
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36. As the above-described statements were published with malice and oppression and
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fraud, and based on animus toward ALVORD as a person and local elected official, an award of
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exemplary and punitive damages is necessary and appropriate.
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10 SECOND CAUSE OF ACTION

11 False Light Against OLIVER, HOUSE OF OLIVER, PARK, and DOES 1-100
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37. ALVORD repeats and re-alleges paragraphs 1 through 36 as though fully set forth
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herein.
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38. OLIVER, HOUSE OF OLIVER, and PARK have knowingly and recklessly put
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16 ALVORD in a false light by publishing with reckless disregard to its offensiveness, offensive

17 information about ALVORD that portrays him in a false and misleading light, which a reasonable

18 person would find highly offensive or embarrassing.

19 39. Specifically, OLIVER, HOUSE OF OLIVER and/or PARK have published or
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verbalized that ALVORD attempted to get OLIVER arrested, had “minions” report OLIVER’s
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businesses to government authorities, is a liar, fraud, a snake in the grass, a wolf in sheep’s
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clothing, is communist or socialist, is bad for small business, and was more concerned about
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24 mask-wearing than the impact not wearing masks in 2020 would have on keeping Placer County

25 small businesses open.

26 40. As a direct and proximate cause of the above-described depictions, publications, and
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Attorneys at Law statements, ALVORD has suffered and will suffer embarrassment and humiliation by these false
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COMPLAINT
 light and misleading statements and implications thereof, and fears the false light and misleading
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2 depictions will harm his reputation (both in business and among the William Jessup community

3 and students) and inhibit his livelihood, particularly among those who do not know ALVORD

4 personally or professionally, as his livelihood is derived from his small businesses and part-time
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college teaching that he has spent decades building and growing. As a result of this damage to his
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reputation, ALVORD has suffered and may continue to suffer significant damage to his personal
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reputation in the community and his business and personal relationships have been, and may
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continue to be, adversely affected.
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10 41. All of these above-described damages are in an amount that cannot presently be

11 ascertained but which ALVORD is informed and believes are in excess of the jurisdictional
12 minimum of this Court, according to proof at trial.
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42. OLIVER, HOUSE OF OLIVER, PARK, and each of them, have acted with
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knowledge that the depictions of ALVORD were false and/or with reckless disregard of the
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depictions’ truth or falsity. OLIVER, HOUSE OF OLIVER, and PARK’s conduct was intended
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17 by them to cause injury to ALVORD and was despicable conduct carried on with a willful and

18 conscious disregard of the rights, reputation and safety of ALVORD. As such, ALVORD is

19 entitled to recover punitive and exemplary damages in an amount sufficient to punish OLIVER,
20 HOUSE OF OLIVER and PARK, and deter them from such conduct in the future.
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THIRD CAUSE OF ACTION
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Unfair Business Practices Under Cal. Bus. Prof Code § 17200
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24 Against OLIVER, HOUSE OF OLIVER, PARK, and DOES 1-100

25 43. ALVORD repeats and re-alleges paragraphs 1 through 42 as though fully set forth
26 herein.
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Attorneys at Law 44. The aforementioned acts of OLIVER, HOUSE OF OLIVER and PARK constitute
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COMPLAINT
 unfair, fraudulent and/or illegal business practices through their associated business activities
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2 within the meaning of California's Unfair Competition Law ("UCL"), embodied in section 17200

3 et seq. of the California Business and Professions Code.

4 45. OLIVER, HOUSE OF OLIVER and PARK's actions, including defaming ALVORD
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and presenting him in a false light as set forth herein, were unfair in that they harmed ALVORD's
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reputation in the community and may inhibit his livelihood with regard to his small businesses
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where he is unjustifiably the subject of scorn based on false and misleading statements about him
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with regard to child masking and COVID vaccinations and his support of small business in Placer
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10 County.

11 46. OLIVER, HOUSE OF OLIVER and PARK's actions were illegal in that they
12 violated ALVORD's rights under California law to not be defamed and to not be presented in a
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false light and inhibited ALVORD from practicing his business trade and occupation, and/or his
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profession as a Roseville city councilmember.
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47. On information and belief, OLIVER, HOUSE OF OLIVER, and PARK's unfair,
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17 deceptive and fraudulent practices originated from and/or occurred primarily in California.

18 48. Pursuant to California Business and Professions Code section 17203, ALVORD

19 seeks an order of this Court that permanently enjoins OLIVER, HOUSE OF OLIVER and PARK
20 from continuing to engage in the unlawful, unfair, and fraudulent conduct described herein.
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ALVORD seeks an order requiring OLIVER, HOUSE OF OLIVER, and PARK to (1)
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immediately cease the unlawful, unfair, and fraudulent practices stated in this complaint; and (2)
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award ALVORD reasonable costs and attorney fees pursuant to California Code of Civil
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25 Procedure section 1021.5.

26 49. By reason of the alleged acts and conduct of OLIVER, HOUSE OF OLIVER, and

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27 PARK, ALVORD has suffered and will suffer further harm, including a decrease in business
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COMPLAINT
 opportunities through his small businesses, embarrassment and humiliation. ALVORD is fully
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2 entitled to remedies under the UCL, including restitution for lost income.

3 FOURTH CAUSE OF ACTION

4 Declaratory Relief Against OLIVER, HOUSE OF OLIVER, PARK
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and DOES 1-100
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50. ALVORD repeats and re-alleges paragraphs 1 through 49 as though fully set forth
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8 herein.

9 51. ALVORD contends that OLIVER, HOUSE OF OLIVER, and PARK have defamed

10 him, published statements depicting him in a false and misleading light, and committed unfair
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business practices. There is an actual controversy between ALVORD and OLIVER, HOUSE OF
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OLIVER, and PARK concerning whether the defamatory and false light statements may remain
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posted on various social media platforms, and on the internet, and in blogs which are in the public
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square.
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16 52. ALVORD seeks a declaration and injunctive order from the Court that would

17 require OLIVER, HOUSE OF OLIVER and PARK to remove and publicly retract the false and
18 defamatory statements and publications described in this complaint.
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PRAYER FOR RELIEF
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ALVORD prays for judgment against OLIVER, HOUSE OF OLIVER and PARK as
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follows:
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23 1. To remove and publicly retract the false and/or defamatory statements and

24 publications described in this complaint;

25 2. For temporary and permanent injunctive relief;
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3. For general damages according to proof at trial, exceeding the jurisdictional
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minimum of this Court;
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COMPLAINT
 4. For special damages arising from the loss of business or business opportunities,
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2 according to proof at trial;

3 5. For exemplary and punitive damages;

4 6. For attorney fees under Code of Civil Procedure section 1021.5 and costs of suit
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incurred; and
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7. For such other and further relief as the Court deems just and proper.
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Dated: October 11, 2022 CARDINALE FAYARD, APLC
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9
GREGORY T. FAYARD
10 Attorneys for Plaintiff SCOTT ALVORD
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VERIFICATION
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Alvord v. Oliver, et al.
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I, SCOTT ALVORD, declare:
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16 I am the plaintiff in the above-entitled matter. I have read the foregoing complaint and

17 know the contents thereof. The same is true of my own knowledge, except as to those matters
18 which are therein stated on information and belief, and, as to those matter, I believe it to be true.
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Executed on October 11, 2022 at Roseville, California, Placer County, California.
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I declare under penalty of perjury that the foregoing is true and correct.
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23 ________________________________
SCOTT ALVORD
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COMPLAINT