This is an update to our earlier piece, “Same Court, Same Problem: ZeroDarkTony’s Second Restraining Order Attempt Against Krackhead Kenny.”
The April 17 hearing in D’Amato v. Brooks (26STRO01932) ended today without a ruling. Judge Holly L. Hancock-Goode continued the matter to May 26, 2026, when the pending Motion to Quash and potentially the underlying restraining order petition will be heard. Here is what we know about what happened inside the courtroom — and what the minute order from the hearing reveals about the strategy at play.
What Happened in Court Today
Jared Brooks appeared remotely via LA CourtConnect. Anthony R. D’Amato appeared in person, represented by attorney Dawn Dunbar of the Law Offices of Christopher Chaney.
According to Brooks’s account following the hearing, the photo dispute was front and center. Petitioner’s Exhibit 1 is described in the minute order as “a black and white photo of Respondent in front of an apartment complex.” Brooks reportedly told the court, showing the judge via video, where in his own home the original photograph was actually taken. His position is that the exhibit submitted by D’Amato’s team is a photoshopped composite: his image placed in front of a building he has never been near. By his account, the judge appeared satisfied that the photograph was fabricated or not what the petitioner claimed it to be.
That is significant, because the photo was presumably offered to support D’Amato’s claim in his declaration that Brooks “posted a photo of himself in front of my apartment building in Los Angeles.” If the court found that photo to be manipulated, it removes one of the few pieces of evidence the petition offered for physical presence in California and undercuts D’Amato’s credibility on the facts he swore to under penalty of perjury.
Brooks was more guarded about the second area of my questioning. He indicated that the subject of him “calling in” to something came up, and then declined to say more about the hearing. The minute order obtained from the hearing fills in what that “calling in” refers to.
The Jurisdictional Hook: State Bar Meetings
The minute order lists Petitioner’s Exhibit 2 as “a video recording from a virtual California State Bar meeting purported to be dated February 2025,” accompanied by Exhibit 2A, a written transcript. This appears to be the evidentiary foundation D’Amato’s team is using to argue that Brooks has a meaningful connection to California, and specifically to Los Angeles County, sufficient to give the court jurisdiction over Brooks.
Let that sink in for a moment. The argument, as best as can be reconstructed from the record, is that Jared Brooks phoned into a California State Bar teleconference meeting to make public comment, and that this act of calling into a government meeting constitutes “purposeful availment” of California courts.
Purposeful availment is a legal standard where a defendant has made a deliberate connection to a forum state by choosing to engage with it in a “real way,” such as by living there, doing business, or committing physical acts on its soil. It requires conduct intentionally directed at the state to create a “meaningful connection” that justifies a court exercising authority over an out-of-state resident.
We were not able to locate any February 2025 State Bar meeting minutes reflecting public comment from Brooks or his online alias “Kenny.” What we did find are minutes from two State Bar-affiliated meetings in fall 2024: the Committee of Bar Examiners teleconference on September 30, 2024, and the Legal Services Trust Fund Commission Legal Aid Leaders Fellowship Grants Committee meeting on October 4, 2024. We also obtained both video and video transcripts.
In those meetings, multiple Scientology protesters were signed up for public comment. Brooks, using his alias “Kenny,” called in to both. He used the public comment window to raise concerns about the Church of Scientology, describe alleged swatting and harassment of protesters, and call out Scientology attorney Kendrick Moxon for alleged misconduct. At the September 30 meeting he named “Anthony D’Amato, Jr., ZDT” by his YouTube channel, accusing him of sexually harassing and stalking a minor boy and his mother, referring to a restraining order a 16-year-old boy, also a protester of Scientology, and his family had against D’Amato.
The September 30 meeting minutes, in summarizing Brooks’s comment, note that he “raised alarm about online harassment and stalking linked to Scientology, urging authorities to take action.” The October 4 minutes log the comment simply as “Kenny expressed opposition to the Church of Scientology.”
This is the public record D’Amato’s team appears to rely on, though they now claim it extends into February 2025 based on a meeting we have not been able to verify.
Why This Jurisdictional Theory Is Legally Fragile
The attempt to use public comment at a state government teleconference as a jurisdictional contact faces some pretty strong legal headwinds, and Brooks’s Motion to Quash is well-positioned to challenge it on multiple fronts.
The “absolute privilege” problem. It is a bedrock principle of California law, affirmed in cases going back decades, that statements made during legislative or quasi-legislative proceedings are absolutely privileged. This protection is not qualified. It does not depend on whether the statements were accurate, tactful, or even germane to the agenda. The policy rationale is explicit: people must be able to speak “fully and fearlessly” at government meetings without the threat of civil litigation hanging over them. If Brooks’s public comments at those meetings are absolutely privileged, they cannot legally form the basis of a harassment claim under CCP § 527.6 — and by extension, they arguably cannot serve as the basis for establishing jurisdiction either.
The “purposeful availment” problem. Under the Due Process Clause and California’s long-arm statute, a non-resident can only be brought into a California court if they have purposefully availed themselves of the privilege of conducting activities in California. Calling into a state government teleconference from Louisiana, which is accessible by telephone or internet from anywhere in the country, is a shaky foundation for personal jurisdiction. Courts have been skeptical of treating digital or telephonic contact as creating the kind of deliberate, substantial ties to a forum that jurisdiction requires. The prior restraining order case, 25CHRO01789, was dismissed in October 2025 by Commissioner Caitlin Crary Taylor on exactly this basis.
The Anti-SLAPP dimension. Under California’s Anti-SLAPP statute (CCP § 425.16), a defendant can move for early dismissal of any claim that “arises from” protected activity — which expressly includes oral statements made before a legislative or executive body. If D’Amato’s case for jurisdiction is premised on Brooks’s participation in those State Bar meetings, Brooks may have grounds to argue this is a strategic lawsuit designed to punish and chill constitutionally protected speech and petitioning activity. The statute’s “loser pays” provision, which awards attorney’s fees if the motion succeeds, is a meaningful deterrent for this kind of litigation. As a pro per, self-represented respondent, whether Brooks pursues this route could depend on whether he can retain counsel. Perhaps D’Amato and his lawyers are banking on the fact that Brooks does not have an attorney pushing back on the protected speech angle.
What Could Brooks Do Before May 26?
This is not legal advice. We are journalists, not attorneys, and anyone in Brooks’s position should consult a licensed lawyer. But we can talk about what the procedural landscape looks like, because it’s directly relevant to understanding what happens next in this case.
Brooks already has a Motion to Quash on file, scheduled to be heard May 26. That motion argues lack of jurisdiction and procedural defects in the petition. Based on what emerged today, specifically, that the petitioner’s jurisdictional evidence consists of a State Bar meeting video, there are several ways a respondent in his position might choose to strengthen the record before that hearing.
Supplemental Declaration or Brief. Brooks can file a supplemental declaration or a brief in support of his existing motion. Now that the specific exhibit has been identified in the minute order, and once he receives the exhibit, he can address it directly: what those State Bar meetings were, what was said, and why telephonic participation in a government public comment session from Louisiana cannot constitute the kind of purposeful availment that gives a California court jurisdiction over him. He can attach the publicly available meeting minutes as supporting exhibits. A court can also take judicial notice of official government records, which is a formal procedural mechanism for getting those documents into evidence.
An Anti-SLAPP Motion? This could be a more aggressive option and with the most complexity. An Anti-SLAPP motion under CCP § 425.16 is a separate filing from the Motion to Quash. In California, it generally must be filed within 60 days of service of the complaint, though courts have discretion to allow late filings. Brooks was served in early April 2026, so he is still be within that window. The argument would be that the petition “arises from” Brooks’s protected activity, his public comment at government meetings, and that D’Amato cannot demonstrate a probability of prevailing because (a) those statements are absolutely privileged, and (b) the court lacks jurisdiction over Brooks in the first place. If the motion succeeds, D’Amato would be required to pay Brooks’s attorney’s fees. The practical catch: Anti-SLAPP motions are procedurally complex, and filing one pro per carries real risk of technical error. Exploring this move and whether it is a legitimate strategic option would require and attorney.
What Probably Won’t Help. Filing new accusations about D’Amato’s conduct, relitigating grievances outside the scope of the jurisdictional question, or making statements in public that could be submitted as additional evidence against him. The strongest position Brooks can be in on May 26 is a narrow, well-documented argument that the court simply does not have the power to hear this case — not a broader counter-narrative about who did what to whom online.
The May 26 Hearing
The May 26 hearing will address both the Motion to Quash and, potentially, the restraining order itself, if the court first determines that it has jurisdiction over Brooks.
Petitioner’s counsel will need to produce the February 2025 State Bar meeting video identified as Exhibit 2 and make it available in advance of the hearing, in accordance with the court’s order governing the exchange of electronic evidence.
In the meantime, the case remains open. The central question the court will confront on May 26 is jurisdictional, and it is not settled. Does a Louisiana resident’s voluntary participation in a California government teleconference, a meeting open to the public from anywhere, create the kind of meaningful connection to the state that justifies bringing him before its courts? If the answer is yes, the implications would extend well beyond this case.
We intend to continue following the record as filings become available, but that work depends on support. If you find this work useful, your support helps make this kind of reporting possible.
Hero Not Zero covers predatory behavior, online community conflict, and the legal context around it. The documents referenced here are drawn from the public docket in D’Amato v. Brooks, 26STRO01932, Superior Court of California, County of Los Angeles.