Online investigator and YouTube personality Spencer Cornelia — known for his investigative video series on the music industry, money in hip-hop and get-rich-quick social influencers — has prevailed in a long-running defamation lawsuit filed by Derek Moneyberg, the online persona of self-proclaimed wealth coach Dale Buczkowski.
Buczkowski operates a number of big-ticket wealth management coaching services, including his “Mastermind Network” — which charges users a $20,000 initiation fee and a $5,000 annual renewal fee — and his “1-ON-1 Training,” which starts at $75,000 per year, according to his attorney Tamara Beatty Peterson.
The defamation suit — filed on June 21, 2021, in U.S. District Court in Nevada — accused Cornelia of making false and defamatory statements against Buczkowski during two interviews with a former friend and associate of Buczkowski named John Mulvehill, whom Buczkowski also sued. During the interviews with Cornelia, Mulvehill questioned Buczkowski’s academic credentials and suggested Buczkowski’s success was due in part to criminal behavior. On a later broadcast, Cornelia openly mused about nominating Buczkowski for his annual “Charlatan of the Year” award.
Over the course of several months in summer 2023, U.S. District Court Judge James C Mahan dismissed the complaints against both Mulvehill and Cornelia. On July 23, Mahan ruled in favor of Mulvehill, finding that Buczkowski lacked jurisdiction to file his lawsuit in Nevada since Buczkowski couldn’t provide any evidence he lived in the state beyond “a handful of pieces of mail.”
Then, in late September, Judge Mahan tossed the defamation charges filed against Cornelia, ruling that Buczkowski was a public figure — a designation that requires a finding that Cornelia acted with actual malice, meaning “a statement is made with falsity or reckless disregard for the truth.”
“Here, all of the allegedly defamatory statements were uttered by Mulvehill, not Cornelia. Cornelia was simply interviewing Mulvehill,” Mahan wrote in his September ruling. “Regardless of this fact, the evidence in the record shows that Cornelia did not act with reckless disregard in conducting his interview with Mulvehill,” noting that “Cornelia published his videos based on reasonable information he received from reliable sources.”
That included a video from a former employee of Buczkowski “who corroborated claims about plaintiffs’ unethical business practices and their using young, unqualified people to write the instructional and promotional material for plaintiffs’ courses,” Mahan wrote. In his deposition, Buczkowski was asked about his claims that he had been interviewed by major magazines and television outlets seeking his financial acuity but was unable to name a publication he hadn’t paid to be featured in.
“Even if Cornelia were mistaken, his conduct is not remotely close to constituting reckless disregard. Thus, defendants did not act with actual malice, and the court grants their motion for summary judgment.”
Buczkowski has already filed an appeal of the ruling, and Cornelia has indicated he too plans to appeal Judge Mahan’s denial of Cornelia’s anti-SLAPP motion — a type of request that asks the court to dismiss a case on grounds that it attacks protected speech. Had Mahan granted the motion, Buczkowski could be found liable for Cornelia’s legal expenses.
“I feel incredibly relieved that the judge granted our motion for summary judgment on all claims. It was the correct ruling and another reminder to angry litigants that the legal system will deter those attempting to engage in lawfare,” Cornelia told Billboard in a statement.
“Because Moneyberg’s only interest is dragging this case as long as possible and attempting to defeat an underfunded litigant by spending his way to victory, he decided to appeal the judge’s ruling,” Cornelia continued. “I am excited for the finality of this case following the appeals process and seeing a judgment against Moneyberg for a significant amount of money. I will be pursuing him for 100% of my attorneys fees when this case is over.”
Billboard reached out to representatives for Buczkowski and did not receive a response.
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