On May 11, 2020, Glen Allen, responding to the SPLC’s brief in opposition to his opening brief, filed his reply brief in further support of his appeal. In his reply brief, Allen castigated the SPLC Defendants for improperly citing matters outside the appellate record in their opposition brief by seeking to introduce newspaper articles and articles written by the SPLC as though factual. Allen also excoriated the SPLC Defendants for repeatedly contradicting themselves, e.g., claiming their Hate Map is a reliable source of information about “hate groups” while simultaneously claiming that the Hate Map is not factual but mere “hyperbole and rhetoric.”
In addition, Allen argued that:
- the SPLC Defendants in their opposition brief never properly came to terms with Allen’s allegations that the SPLC unlawfully acquired the information it used to orchestrate Allen’s dismissal from the City of Baltimore
- the defendants avoided – because they had no credible rejoinder to – Allen’s argument that the District Court misinterpreted the basic elements of Allen’s tortious interference with contract and negligent supervision claims
- the defendants’ own statements, and the SPLC’s status as a 501c3 nonprofit, show that their defamatory accusations against Allen were not mere hyperbole and rhetoric
- Allen’s RICO claims were properly pled.