parker-v-goldhagen-edpa-15-cv-3304
parker-v-goldhagen-edpa-15-cv-3304
parker-v-goldhagen-edpa-15-cv-3304
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&<br />
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k'<br />
} W ffifi ; IN THE UNITED STATES C'URT<br />
ro*rnn EASTERN DISTRTcT oF pEr{NSyvLANTA<br />
GORDON ROY PARr(ER'<br />
alWa"Piay Gordon,"<br />
4247 Locust Street, #119<br />
Philadelphia, PA 19104<br />
(267)298-t2s7<br />
SnodgrassPublish@aol. com,<br />
Plaintiff, caseNo: I5 <strong>3304</strong><br />
v.<br />
JACQUELINE FAYE GOLDHAGEN,<br />
a[Wa"hcqui Holland"<br />
10524 West Pico Boulevard,#216<br />
Los Angeles, CA 90064,<br />
Complaint for Declaratory Relief,<br />
Fraudulent Misrepresentation,<br />
Breach of Contract, and<br />
Defamation<br />
Defendant<br />
COMPLAINT FOR DECLARATORY RELIEF"<br />
FRAUDULENT MISREPRESENTATION"<br />
BREACH OF' CONTRACT, AND DEFAMATION<br />
Plaintiff Gordon Roy Parker ("Plaintiff'), in the above-styled action, based upon<br />
information and belief, sets forth and avers the following:<br />
THE PARTIES<br />
1. Plaintiff Gordon Roy Parker, alWa "Ray Gordon," is an adult male domiciled and<br />
residing in the Commonwealth of Pennsylvania, who may be served at the address listed for him<br />
in the caption. Plaintiff is the owner and operator of Snodgrass Publishing Group, a<br />
Pennsylvania Sole Proprietor and Internet media company, whose primary website is<br />
toosmarltofail.com.
2. Defendant Jacqueline Faye Goldhagen, aNa Jacqui Holland ("Defendant"), is an<br />
adult female domiciled and residing in Los Angeles, California. She is a "rising star" actress<br />
known for cutting-edge and extremely sexy PG-13 work (e.g., Bikini Avengers, Hollywood Sex<br />
ll/ars, Lde As A Hot Loser, etc.), and a hypnotist/life coach, who may be served at the address<br />
listed for her in the caption. Her current website is http://www.newagehypnotist.com.<br />
NATURE OF ACTION<br />
3. Many years ago, this court branded Plaintiff a serial litigant, though he would assert<br />
that time has validated his arguments. With two cataracts, Stage III COPD, two gallstones, high<br />
blood-sugar, and numerous other medical concerns, Plaintiff has far better things to do than to<br />
"throw down" in Federal court. Nevertheless, lb-case exists solely because Defendant<br />
threatened to sue Plaintiff over a negative Yelp! review, using her attorney to amplifu the threat.<br />
Plaintiffs review of the underlying facts, and subsequent events, have given rise to this action.<br />
4. This action stems from the breach of a contract, atlveat of litigation by Defendant<br />
over Plaintiffs negative review of her practice, and alleged defamation of Plaintiff by Defendant<br />
in response to said negative review. All attempts at mitigation and settlement have failed.<br />
STATEMENT OF JURISDICTION AND VENUE<br />
5. Personal jurisdiction in Pennsylvania is conferred by Defendant's threat to sue<br />
Plaintiff as the defamation suit would have to occur in this jurisdiction.<br />
6. Subject-mafter jurisdiction is conferred by diversity jurisdiction and the amount in<br />
controversy, both in the Complaint and in the threatened defamation claim.<br />
7. Supplemental jurisdiction is conferred over all other claims.<br />
8. Venue is proper because Plaintiff resides within the Eastem District Of Pennsylvania.<br />
2
BACKGROUND<br />
9. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire<br />
contents of all previous paragraphs, and all exhibits to this Complaint.<br />
"Bg!4g@i"<br />
10. On June 4,20<strong>15</strong>, after viewing an impressive (and very sexy) display of hypnotic<br />
talent from Defendant, in a "past-life regression" video on YouTube, Plaintiff began exploring<br />
the possibility of hiring Defendant to make for him a customized hypnosis video, hopefully the<br />
first of at least two, to help improve Plaintiffs eyesight by dilating his pupils, with the second to<br />
help him improve at chess by linking winning at chess to the reward-center response created by<br />
desire for the attractive female hypnotist.<br />
11. Initially, the eyesight video, in which a sexy female hypnotist uses her beauty and<br />
powerful hypnosis technique of the kind possessed by Defendant (and few others, let alone sexy<br />
female others), was Plaintiffs top priority, due to its (relatively) tame content, and commercial<br />
potential. Plaintiff, a successful and profitable producer of hypnosis recordings in his own right<br />
(Anonymistress, Hellen I/I\ Megasleep), had hoped to produce the "eye video" to launch his<br />
Pstient Empowerment Network Of New Yorfr (PENNY), via the website<br />
http://www.patientempowerment.net, which is currently under construction. Penny Parker is<br />
Plaintiffs late mother. With a strong alternative-medicine presence fueling the portal, Defendant<br />
was even more of a perfect fit for the gig.<br />
12. The eye video seemed directly up Defendant's alley, given her willingness to be sexy<br />
on camera, especially for a greater purpose (eyesight), her extreme level of training and polish<br />
generally common only to working performing artists, her three years of experience as a stage<br />
hypnotist, her active hypnosis practice, and that she and her eyes were desirable enough to<br />
3
induce pupil dilation, the goal of the video. Hypnotherapy videos with similar content from<br />
similar talent can easily gross tens of thousands of dollars, more than enough to launch PENNY,<br />
which Plaintiff hopes to one day establish as an empowered-patient portal connecting likeminded<br />
practitioners and patients. The primary barrier to producing such videos is finding talent,<br />
which is why they sell so well.<br />
13. Had the eye video been made successfully, at first for Plaintiffs personal use, Plaintiff<br />
intended to offer Defendant the "number two" role in PENNY, as its spokesmodel and primary<br />
hypnotist, with revenue from the eye video serving as a form of charter contribution (of<br />
Plaintiffs half of the revenue). Her royalty from the eye video would have been 50 percent of<br />
gross profit, while the "charter spokesmodel" gig included five percent ownership of the portal.<br />
For perspective, the painter of Facebook's in-house mural was paid in stock which wound up<br />
worth over $200 million, far more than the value of the actual painting.<br />
14. The eye video was never proposed to Defendant, because Plaintiff soon discovered<br />
that Defendant offered customfetish videos (hypnosis is a known sexual fetish) via the Castoms<br />
Club website (http://www.customs4u.com), to an audience which includes men who, like<br />
Plaintiff, enjoy being hypnotized by beautiful women:
http ://www. customvideosclub. com/customsclub/j acqui -holl and/<br />
Retrieved on June 8,20<strong>15</strong> at9'.07 ant<br />
<strong>15</strong>. Plaintiff was hardly shocked (though delighted) to learn that Defendant had<br />
(apparently) embraced the sexy, cutting-edge side of hypnosis, as her YouTube video had also<br />
indicated. He immediately sought, and found, confirmation that this ad was genuine, via<br />
Defendant's own Twitter account:
Eff[:',m]r*<br />
r@<br />
I sell #customvideo$ @f;u$toms4u! 0rder<br />
yours TODAY at<br />
cu$t0ms4u . c0m/cust0rns/pnwer-. . . !<br />
#customclips #clips #fetish<br />
{ltl*d...r<br />
htrps://twitterrco#:i;:,;|;lily;11,-Ti;ff<br />
A:rrese*te2,<br />
16. Plaintiff has long expected Hollywood and the hypnofetish to finally collide, having<br />
waiting patiently for years for someone with Defendant's skillset and experience to materialize,<br />
and had finally found what he was seeking. Having finally found one, he was going to approach<br />
her with great caution, great respect, substantial compensation, and a vision which he hoped she<br />
would share enough to make real and profitable, not much different from other internet<br />
collaboration.<br />
17. Prior to offering her commercial projects, however, Plaintiffs first goal was to secure,<br />
for his own use, a hypnosis induction video, preferably for chess. He therefore avoided creative
conflict at all costs, deferring to Defendant's wishes regarding scripting, content, and the limits of<br />
sexualized expression for the first video.<br />
18. In the absence of the Castoms Club page,Plaintiff would have simply offered<br />
Defendant the eye video, with its g-ruted script, told her he wanted a deep trance with an eyecontact<br />
induction, and suggestions of extreme pupil dilation, a request to which Defendant<br />
certainly would not have objected. Once completed, Plaintiff would then have offered a<br />
minimum of $5,000.00 for the rights to the video, up to a percentage of PENNY in return for the<br />
spokesmodel gig, with the work already having been performed. Based on information, belief,<br />
and the cofllmon-sense of a kindergartener, Plaintiff avers that Defendant would have accepted<br />
the spokesmodel gig.<br />
19. By working through Customs Club,the parties were still primarily contracted to each<br />
other, but also to the third-party website, thus further ensuring the likelihood that Plaintiff would<br />
actually receive the chess video once ordered. Not long after first viewing her YouTube video,<br />
Plaintiff offered Defendant $1,000.00 to make a "sexy hypnosis video for chess improvement,"<br />
with the type of scripting mentioned earlier in this Complaint.<br />
20. As with the eye video, the chess video's market value was such that Plaintiff had<br />
planned to offer Defendant a substantial amount of money for the rights to this video, for his<br />
Chicks Dig Chessplayers campaign, tied to Plaintiffs successful dating-advice books.<br />
21. Defendant accepted Plaintiffs offer, not once, but twice (Plaintiff had submitted a<br />
duplicate by mistake):
SuQYour Gffer r&fas *,lifiEpted<br />
trat6l4l28<strong>15</strong> 1$:24:12 A-M. Eastem Dayllsht Tirme<br />
Fro@<br />
To:, Bettorsfisin gle@aol -corn<br />
Sslrf frorrt flts lnfpn}Et fsafa#sl<br />
It<br />
Bear Bettoroffsinqfiei@ao!- colll<br />
PEnrcr Girl has accepted yotlr offer! P&ease follow ttre {ink heNoriu to pay<br />
$'lCISS and cornplete tlris srder"<br />
http:/&ffivur.oustomq$u"corfl/pay*for-offe.r{0CI1 1 OQA=<br />
^<br />
w<br />
:YS<br />
;:1* t<br />
;#<br />
,t-df<br />
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l.r:S<br />
,@*1<br />
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ffi<br />
r[rqff;<br />
'#w<br />
ffi M<br />
ffi ffi m<br />
Su|r"Yoilrr Oltlier flSas *GcsFtBtl<br />
t!,a[6/4I2O"$5 t0:30:2't A,-M- Eastem Dayngflt Tlme<br />
Frsr"surs}rrr&@cr.rctpryg1$lc-q€inn<br />
T(}: *El,ettorsfFeif,rqfe@eol-oord!<br />
.Se.nt iikolm? ffls ,rrferxle{ fDefeffs}<br />
U<br />
Dea r EEHp rErei[rgle@asL Gt]r!tr<br />
P11urer Girl ha* ascepted your offer! Fbase firlfichfrI the limk belstv to pay<br />
SIOOO and cemp&ete this orden<br />
h-t@;/finruryr.cu.stnmsdu=Eg'trrlpay.fer.qfferfotr}l "t , ..tlA=<br />
ffi<br />
@8,*,,.<br />
qMW ffiW, ffi {1 ffip ffi<br />
22. A binding contract between the parties now existed.
23. To avoid any confusion created by the duplicate offers, Plaintiffimmediately e-mailed<br />
Defendant at the address listed on her Twitter page to clarify that he was paying $1,000.00 for<br />
the chess video, and for her to delete the second offer. Upon written acknowledgement of which<br />
of the two contracts was the valid one, Plaintiff would immediately pay the $1,000.00 to<br />
Customs Club.<br />
24. Defendant responded to Plaintiffs e-mail with a counter-offer of her own:<br />
1:98:55 F-M" Eastern ilayli$h[T.flne<br />
Wsuld ycu be open {oiust dealing with me and paying &rough paypa!. I<br />
hate t*mt site if,e really comfusing I fried to erase it sm numerous<br />
accasions but cou&ln't figure nt"lt hour to do that ei*len @"<br />
I need to ask you a few questiom? Are you audlo, visl,ml or kinmffrefic? tr<br />
don't know that nruch aMq"*t chess can you telt sne urhen you rrrrim holn<br />
.*&<br />
ffi<br />
;#!F:,:,,<br />
{*D -'::;" ilgn.<br />
ffi<br />
mt#<br />
ffi ffi ffi<br />
25. In response, Plaintiff fired Defendant, due to her extreme lack of ethics, telling her<br />
only that she had "flunked an audition [he] wasn't even giving," as there was no need to inform<br />
someone with whom Plaintiff was breaking contact any further regarding why. In the letter,<br />
Plaintiff requested that Defendant never contact him again.
26' The breach also destroyed Boxing Jacquifor Plaintiffs personal use, since he no<br />
longer trusted the hypnotist "inside his head." Plaintiff elected to cut his losses and continue his<br />
search, lest he be falsely accused of pestering Defendant.<br />
27 - Despite the explicit advisory not to contact Plaintiff in this state, Defendant<br />
immediately e-mailed him three consecutive times, with Plaintiff deleting all three mails without<br />
reading, as he had no intention of ever hiring or speaking with Defendant again.<br />
28' At this point, Defendant's e-mails ceased, and Plaintiff "took his case to the people.,,<br />
29. Between his negative experience with Defendant, and her having ,,stalked,,him three<br />
times, Plaintiff decided to don his social-justice warrior(SJw) cape, andpost online reviews of<br />
Defendant, as well as making "protest" posts on her social-media pages, concerning both the<br />
breach of contract, Defendant's marketing as a fetish model, and the annoyance of having to<br />
remove the "hypnotic seal" Plaintiff had allowed to develop in order to make himself more<br />
receptive to Defendant's anticipated video hypnosis. Even without hypnosis, any dispute will<br />
intensifi' emotions temporarily, until cooler heads prevail.<br />
30' on June 6,20<strong>15</strong>, Plaintiff posted his review of Defendant to yelp!. The fulItext of<br />
the review as it last appeared on June g,2ol5,before Plaintiff voluntarily replaced it pending<br />
adjudication, is attached hereto as Exhibit A and incorporated by reference as if fully stated<br />
verbatim herein.<br />
3 1' Plaintiff avers that there are no false and misleading statements concerning Defendant<br />
in Exhibit A, his Yelp! review of her practice.<br />
32' On June 7,20<strong>15</strong>, Defendant E-mailed Plaintiff, with a copy to her attomey, Steven J.<br />
Dedina, Esq., a cease-and-desist order, threatening legal action if Plaintiff did not remove all of<br />
his postings concerning Defendant and her practice, including the yetp! review.<br />
10
.:ll:\ir.'-l'li. .<br />
Datfs,17120<strong>15</strong> 11:37:38 P.M- Eastern Dayl,ght Tame<br />
To : x Bettoroffsin(rle{@aol-com<br />
GG: stevededina(Orne-corn<br />
Sent from the lnternet (Details)<br />
I suggest you take down everything including the yelp<br />
review. I am taking Iegal action- lt is an offense- You<br />
committed slander and libel on my social media pages I<br />
have kept screen shots of everythingry<br />
ix<br />
-l -t<br />
6t!d<br />
[Ef<br />
m<br />
,::::::,-:<br />
',;\<br />
p;l;i<br />
rtu":-.i.1 ..........<br />
i,ilihq !d.r* ilBrii'i<br />
t€...E]::<br />
Date:6/7/20<strong>15</strong> 1 1 :37:38 P-M- Eastem Daylight Time From:<br />
l@<br />
I am giving yau 12 hours to remove all reviews and posts-<br />
You will be hearing from my lawyer, I have cc'd him in this<br />
email.<br />
Thank you,<br />
Jacqueline Holland<br />
B<br />
?H<br />
@<br />
t_s<br />
ili:!<br />
C.C. Steven Dedina (Attorney)<br />
F0, I d2A fierl<br />
33. Defendant consented to publication on her own social-media pages, and has (or had)<br />
full power to moderate and delete any postings, without involving Plaintiff.<br />
34. At the time of publication, Defendant either knew, or should have known, that the<br />
Yelp! review was not defamatory, and that to threaten litigation over same runs afoul of both<br />
California's anti- SLAPP statute, and Pennsylvania's Dragonetti Act.<br />
35. As mitigation gestures of good faith, and pending the outcome of this litigation, on<br />
June 10, 20<strong>15</strong>, Plaintiffreplaced the Yelp! review with a five-star review of Defendant's "ability<br />
TL
to put people into hypnosis," while noting he may update the review later. He added a rebuttal to<br />
the Ripoff Report review that the audience should reserve judgment until all facts are revealed at<br />
this trial, and that he would retract and abandon any position ruled unfavorably, in lieu of<br />
deletion, which Ripoff Report does not allow. Defendant was immediately put on notice of this.<br />
This is the new Yelp! (five-star) review of Defendant's induction ability, with the oi,ginal on<br />
free-speech chilled ice wrtil adjudication<br />
$t1*/20<strong>15</strong><br />
'All Hypnosis ls Stage Hypnosis"<br />
For ntrhr, I ern going b comment only sn -raoq{^ifs ebality b<br />
puf peple into hypnmis" I rnay updafe both this review<br />
and tfie rating hter as m*re infnffnation becomes dear as it<br />
relates to her pl'acl.ice in gwrmal.<br />
Jacqui F&olland has an amazing tdent for irducirg<br />
hyprmsis" I have persoo*l*y Socrlsad on hor inducilimr video<br />
and can say this furn frsflrand elperiene" l-*ypr*otists who<br />
tefi y6{t that }ro{l wero hypnotiend even if yrau dont{eel<br />
hypmtiaed are usulally oovering for t}*ir weakressee.<br />
t ofren [ile to saybpeopb*rho haveesked me, thatonce<br />
thoy are triy hpnotiesd, tfwy ur{i ktun it. l/lfdh Jacqui.<br />
yottli kns$r- t ray this aa a tifficulf su$eot with fartlr y*ars<br />
uf eryeqeflce, yuho hffitrained hypndists and prudlrcd<br />
slmoe*sfrd hlBnosis reo{rrdings. That I becarne an e{rsy<br />
subject for Jqr*i on e video not a,\rerl interded to<br />
h!rynotias ffiB viesr@r in$cat$s greetns6&,<br />
Orm ceution: JecquFsa ekilled- helned, Flyprmeie<br />
in her hands can be amaziqg, bd a!rc like a wild<br />
anusemeflt park ride- Frepare acmrdingly"<br />
lihfl €:O& am - T:00<br />
TtrE S:OO arn - 7:00<br />
Wei! B:{I0 arn - I:0O<br />
Thu 9:00 arn -<br />
Fri 9:00 arn * I:00<br />
Eiat Closed<br />
$un S:00 *rn * I;S0<br />
Edit bu*lnesE infa<br />
lfiore buslness trnfo<br />
EyAp$oin{rnsnl CInly<br />
Tfi}3 lruslrEss !3 a<br />
LE{IAL BiSC|.&!MER": I raras *nof hypndized into nniting<br />
this revieu-""io Sre hest of rny kncnrledpe-<br />
IIm'iL"-<br />
Erorwe nearby<br />
Reslauma nls, N ightlife-<br />
36. Not content to wait for her day in court, on June 7,20<strong>15</strong>, Defendant posted a rebuttal<br />
to the Ripoff Report:<br />
L2
File Edit View Favorites Tools Help<br />
@ Ripoff Report I New Age H...<br />
fl**<br />
I<br />
Sotd 4k oraDhrc<br />
--<br />
'*-T* ffi<br />
lsl<br />
Con-Man<br />
Howard Needle<br />
Ooeralinq ln<br />
here a Report About You!? Watch This 3 Minute Video!<br />
ffi REBUTTAL Owner of company<br />
lnternet Troll<br />
AUT}{OR: JacqEeline. {USA}<br />
SUBMITTED: Monday, Juneo8, 20<strong>15</strong><br />
A<br />
The man who wrote this review is an intemet troll.<br />
en<strong>cv</strong>clopediadramatica.se/Rav Gordon<br />
#M<br />
Wamane World<br />
of Warcmft<br />
SeryeE Molleo-<br />
UlEg<br />
MottenWow<br />
l4e!E!.@E<br />
@'n<br />
*,***'<br />
-qHm",qXXf REVTEw:<br />
*ffi#ffi<br />
(,<br />
ffi<br />
Greenstar<br />
He attacks attradive hypnotists and tdes to ruin heir careers. I am a legimate board<br />
Respond to this report!<br />
Report & Rebuttal<br />
Respond to this I Also a victim?<br />
report!<br />
I<br />
llhIlLriIIlEIXIEmil-E<br />
RepairYour<br />
Reputation!<br />
http://www.ripoftieport.com/r/New-Age-Hypnotist-Jacqui-Holland/Los-Angeles-California-90064/<br />
New-Age-Hypnotist-Jacqui-Holland-Fetish-Models-Should-Not-Do-Hypnotherapy-Los-Angeles-C a-I234148<br />
-<br />
certified hypnoterapist I am not a fettish hypnotistv<br />
Retrieved on June 9,20<strong>15</strong> at 9:50 pm<br />
37. Defendant's statement contains four parts: a) a claim that Plaintiff tries to ruin the<br />
careers of athactive female hypnotists; b) that Defendant is a "board certified hypnotist," c) that<br />
she is not a "fettish" [sic] hypnotist, and d) that the contents of the site to which Defendant<br />
Linked -- the user-created Encyclopedia Dramatica "wiki" style page about Plaintiff -- were<br />
factually kosher, and painted a correct portrait of Plaintiff.<br />
38. At the time of publication, Defendant either knew or should have known that the<br />
statement in37(a) is false. She has confused Plaintiffs opinionated reviews and speech with<br />
deliberate attempts to ruin careers. Prior to her breach, his only intention was to pay her<br />
13
$1,000.00 for an anazinghypnosis video, and perhaps move on to monetizing their<br />
collaborations.<br />
39. Defendant's claim in 37(b) that she is a "board certified hypnotist" runs afoul of<br />
rurmerous California laws governing commerce and medical practice, while her claim in37(c)<br />
that she is not a "fettish hypnotist" [sic] are refuted by photographs in paragraphs 14-<strong>15</strong>.<br />
Encyclopedia Dramatica (ED)<br />
40. Encyclopedia Dramatica, best described as a Wiki From Hell, andto which<br />
Defendant linked as noted in 37(d), is on a foreign-based server, for all purposes immune from<br />
suit and liability, even for the authors of its user-generated content, who use it as a refuge for<br />
content which would never last on an American server, and which would have them sued<br />
immediately upon publication. Plaintiff became aware that apage devoted to him (the "ED<br />
page") had been created sometime in20l1. Its content has recently changed drastically, and it<br />
was last updated in May, 20<strong>15</strong>:<br />
Gordon<br />
Roy Ff,tfr{rr, wiro lilres to pretend his narne is Ray Eordsn" is a<br />
year old semi*ell known Usenet kook and youTube user Srat llved<br />
his rnother in Hlest Philadetphia. He is Imown through hundreds<br />
usernatflEs online, and seems to have an issue stiddng uist one<br />
*ltity. Meny of tris olderTwiffer accounts are suspended due to hate<br />
Gordon Roy Parker, who<br />
uses thefake narne Hay<br />
Gordon<br />
Retrieved on June 8, 20<strong>15</strong><br />
L4
41. ED is nrn by Lulzsec, a splinter group ftomAnonymous. In late 2011, when Plaintiff<br />
was "following the money," a PayPal donations link was provided to him for the account of<br />
Ryan Cleary, who, at the time, had been ordered off the internet by a British court for various<br />
computer-related crimes.<br />
42. The section of the ED Page entitled "USENET" states the following concerning<br />
Plaintiff:<br />
tlsElflHr<br />
GsdffiE first nntehle a& uns ufien he trarassed e !troman Hemed Tfrhitha Hassell<br />
r/Hmufcgcage"s0rnfgrsuplelttrypnoei$lrn*11945firo8w03007c) into movin$ in urder to<br />
hlm SMsn kas atrx heen lfifiwn k tryto snlidt underaS $ymnasE to ffinvinffi them to<br />
ffidrthffi He aho pmhfanfictfmt r*rrolvee eround himsefftorturin$ repinf; and killin$<br />
Srana# slHf#Ssupn 654[s.ffi m/&up/altserstories/n@e17addtta3645ffi8e) .<br />
hmme hh favorite goup s00n afrer he dismrcred tt, and hls life rel/olved around<br />
s#rsinearfrer<br />
thelerm did wt*, ffnrdnn qlnskry prmlaimed thd fftere wffi n0 si$iflcant los$ of life in<br />
kurers- Gildnn qul@ tof,lr step h rernoue the psts frorn the Goo$e Group arfiiue, but<br />
rre syed trranla tc seueml pef,ple repffiting them all ouer the rseneE<br />
43. Defendant's chosen source, a website which claims that the Jews did WTC, contains a<br />
link to a USENET posting in alt.sex.stories,which the ED page claims was authored by Plaintiff,<br />
and which is"fanJic that resolves around himself torturing, raping and killing young<br />
gymnasts." The link to theftrst part of thestory is in Google's USENET archive at<br />
http://groups.google.com/group.alt.sex.stories lmsglel7add4a3645c68e. That story states, in part,<br />
verbatim (with headers truncated):<br />
From: Iown...@hotmail.com<br />
Subject: Ray Gordon vs. The Magnificent Seven<br />
Date: 1998/09/18<br />
Message-ID: <br />
<strong>15</strong>
Newsgroups : alt.sex.stories<br />
Ray Gordon vs. The Magnificent Seven<br />
My name is Ray Gordon. I'm a mercenary, a soldier of fortune, a hired gun, a bounty hunter, only I<br />
don't fight wars or catch crooks. My work is .. shall we say .. a little more specialized. People pay me<br />
to stalk, tenorize, torture, rape and sometimes ..yes .. even snuffbeautiful young starlet cunts. In<br />
other words, I'm a pussy hunter, a cunt commando, if you will. I love my work, and I ask no<br />
questions. Someone wants me to stalk, rape and snuff some stuck-up starlet cunt, that's their business.<br />
As long as they pay the bills and the veal is fresh, that's all I care about.<br />
That's why I don't bat an eyelash when the limo pulls up to Divers Bar & Gnll,my favorite hangout,<br />
and some chink in a suit and tie steps out. I'd gotten a page an hour before, made the call, and<br />
arranged the meeting. When the chink walks in the door, I can tell he's a spook. He spots me right<br />
away and gestures at me with his finger. I smirk, get up, and follow him out the door.<br />
The limo door opens and the chink slides in. I scan the area for trouble, see nothing, and follow<br />
suit. A fat, smelly, chink in a sweaty uniform is sprawled out along the back seat. He is eating an ice<br />
cream sundae, and strawberry sauce is smeared over his mouth like bad lipstick, making him look a<br />
little queer. The chink in the suit gives me another finger wag, and I decide to commit myself by<br />
taking a seat. As soon as I'm completely inside, the chink slams the door behind me, and the limo<br />
speeds off.<br />
"You were recommended to me," the fat chink in the uniform lisps. "My people tell me you ..do<br />
things for people .. for a price."<br />
"Your people were right," I counter. "The price depends on thejob. High profile, high overhead. I<br />
don't take any jobs where I can't come away clean. That kind of security takes money. I'm a pro .. the<br />
best in the business .. and I only work with pros."<br />
"I assure you, Mr. Gordon," the chink in the suit finally speaks, only it's more like a sneer. "We are<br />
professional ... thoroughly professional. You, on the other hand, don't appear to be any more than a<br />
beer-swilling ... how do you Americans say it ..? loser ..."<br />
"Appearances can be deceiving, Charlie," I return his gaze with some ice of my o!vn. ,,perhaps<br />
you'd like to pull over and see how much of a loser I am."<br />
"That won't be necessary, Mr. Gordon," the fat chink in the ruriform intemrpts. "My sources<br />
are impeccable. They tell me you're the man we need for this operation, and that .. as they say .. is<br />
that."<br />
The chink in the suit tums away from me and stares out the tinted windows.<br />
"So, tell me about this operation ..?" I tum to the fat chink. "Just who the fuck are you guys?<br />
Vietnamese? Korean?"<br />
"Chinese," the fat man doesn't look pleased.<br />
"I am General Chow-Fat of the People's Republic of China. This man is an agent of my govemment's<br />
intelligence organization. We call him Dragoncock."<br />
"Cute ..." I almost laugh.<br />
"I assure you, Mr. Gordon," the general was trying to sound threatening. "Mr. Dragoncock is anything<br />
but cute."<br />
"So what do you want with me?' I ask, tiring of the game. "You obviously want me to bag some<br />
cunt for you, so why don't we just cut to the chase."<br />
1.6
The general smiles and hands me an envelope. There's a photo inside, a photo that almost makes my<br />
jaw hit the floor. Almost ...<br />
"That's the US Women's Gymnastics team,,, I try not to sound apprehensive.<br />
"I believe your press has dubbed them the Magnificent Seven," chow Fat licks his lips<br />
as he speaks. "They are due to appear at the olympic Games in Atlanta in two days. we<br />
believe they will defeat our glorious team. They cannot be allowed to do so. Am i making<br />
myself clear?"<br />
"You want me to nab these cunts so they don't show up your slanty-eyed gook girls<br />
at the big Games," I laugh, "That's a new low, even for me."<br />
"You won't do the job, then?" Chow Fat seemed puzzled. ..I was told you ...,,<br />
"I didn't say that, Fat Man," I cut him off<br />
"Perhaps, Mr. Gordon knows when ajob is beyond his abilities," Dragoncock spoke softly.<br />
"Ttrere ain't no cunt bagging job beyond my abilities, Snailcock," I glared at him. ..I,m just<br />
trying to figure out the angle here. So, you guys need to win. I can respect that. so why<br />
not just snip their brake cables or something. why do you need me? I'm a cunt hunter; i<br />
don't fix sporting events. The mob takes care of that kind of shit.,,<br />
"Just eliminating the girls is not enough, Mr. Gordon,,, Chow Fat lisped. ,,They are an<br />
affront to our way of life. They are admired as capitalistic idols while our girli cower in<br />
their shadow. Death is not .. suitable. It is not enough. They must be shamed, broken,<br />
defiled, rendered inhuman. They must have every bit of their dignity stripped away before<br />
the world's eyes. They will be the butt of every bathroom joke in the world. Theywill<br />
be so shamed, they will wish to die. Our ideals will prevail, and our girls will be ihe darlings<br />
of the world ..."<br />
"I'm beginning to get the picture," I cut him off. ..This isn't aboutjust winning the<br />
Olympics. This runs deeper, more political."<br />
"It is not political, Mr. Gordon," chow Fat wheezed. "It is a matter of survival. Since<br />
the accursed Russians and their allies have fallen, we are the last bastion of Truth in the<br />
world. we will not be denied our glory by seven young teenage cuntso as you call<br />
them." He paused. "So will you take the job?"<br />
I paused. I had to hand it to Fatty. He krew how to pitch. I could just see myself choke fucking one<br />
of the little cunts, jamming my cock dorvn her throat, and making her bend to my iron will. He had me<br />
interested, and he knew it."<br />
"This is some serious shit," I spoke after another moment. ,ol,ll need some men for<br />
Inrs ..^"<br />
"Your fabled Zero Squad," Fatty winked at me.<br />
'oThat's right," I nodded, impressed that he had obviously done his homework.. ..I get<br />
one million; my first lieutenant Killjoy gets a half mil; each man gets a quarter."<br />
"And how many men will you need?" Fatty didn't even bat an eyelash when he heard my<br />
price.<br />
"At least 25 if you want the job done right."<br />
"2 5?" Dragoncock exclaimed.<br />
17
"You can pay me, or let Snaildick here handle it," I smirked. "Although I guess you already<br />
considered that option, which is why I'm sitting here." I paused. "That's my offer. I don,t dicker.<br />
You have three more seconds to consider it.,,<br />
"You will have your money," Fatty didn't even drop a beat. "But, you will be accompanied by<br />
Dragoncock in order that we may keep track of our investment.,'<br />
From the tone ofhis voice, I knew this was non-negotiable, a necessary evil, ifyou<br />
will. I thought of the money and the tight teenage pussies that awaited me. 'oOkay,<br />
you've got a deal." Like I said, I enjoy my work.<br />
44. In December,2011, Plaintiff asked the ED administrators to delete the ED page,<br />
which prompted them to taunt him that the serverrs real address is hidden behind its proxy host,<br />
CloudFlare, of California, and to effectively threaten to attempt to make Plaintiff homeless<br />
should he frle suit, with the following threatening e-mail:<br />
Please delete the infringing hate page about me on your site (thanks!)<br />
312011 6:11:55 A.M. Eastem Daytight Time<br />
* BettorOffSinsle@aol. com<br />
from the lnternet (Details)<br />
I think we will post some of your fanfic to your neighbors. A few<br />
hundred copies per house should be fine. It's also against the law to<br />
write stories involving underage girls. welcome to the sex offenders<br />
registry.<br />
iE<br />
ff<br />
r4iity<br />
- /=\ ;t:J<br />
ffi<br />
&$yttt<br />
i::3,<br />
*u:*<br />
iiii l<br />
,{1b1<br />
E:*U<br />
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Hll #ll @<br />
45. The ED page has been linked to or referenced by many of Plaintiffs political<br />
adversaries, including notable "revenge porn" advocates Adam Steinbaugh and Amanda<br />
18
Levendowski,bothiuris doctors. The existence of the ED page has isolated Plaintiff to the point<br />
where interacting with others risks violent vigilante "justice"; he has often contemplated suicide,<br />
though has no plan or intent (his COPD would seem to allow him to off himself in Oregon).<br />
46. At the time of publication, Defendant either knew or should have known that plaintiff<br />
did not author this essay. It was authored by athirty-eight year-old man from Massachusetts<br />
named David Clanton, a gymnastics groupie who was enlisted, in exchange for personal access<br />
to the MagniJicent Seven and other elite gymnasts, via a female coach named Linda McNamara,<br />
who admitted a few years ago in an article that she covered up sexual abuse in the gym where<br />
she worked, run by disgraced elite coach Don Peters. McNamara had taken it upon herself to<br />
attempt to discredit Plaintiffs claims that Olympic gymnast Dominique Moceanu had been<br />
abused, orgaruzinga group of fans, including Clanton, who would call itself the Gymnastics<br />
MaJia.<br />
47. The male Mafia members were given duties that included a) sending a computer virus<br />
to Plaintiff b) threatening violence and death against Plaintiff and his mother; and c)<br />
impersonating Plaintiff online and making sexualized comments to gymnasts in order to shift<br />
the blame to Plaintifl who survived any and all investigations into his conduct, as he is simply<br />
not a pedophile and was merely seeking to stop child abuse.<br />
48. In late 1997, Clanton taunted Plaintiff that he had impersonated Plaintiffs late mother,<br />
Penny Parker, twice, on USENET, in a manner which has subsequently sent men to prison:<br />
19
Post #l:<br />
CucryIe<br />
Search for topics -l q<br />
Show oDly message<br />
Subject: Use my mouth! I !<br />
Date.= L99] l12lLB<br />
Message-ID: *1,/1<br />
x-Deja-AN: 29979647L<br />
X-XS4AIL-DaIe: Thu, 18 Dec 1,997 02:44:10 CET<br />
Content-Type : text/plain<br />
organization: Replay and Company Unlimited<br />
X-001: This message was forr.rarded by an automated remailing service-<br />
X-0O2: No attempt was made to verify the senderrs identity,<br />
X-003: Please report misuse to <br />
Nelrsqroups : a.Lt . personals , bondage<br />
Hello sugar,<br />
You like getti-ng blowjobs, and I NEED to fee]- your hot hard manhood in<br />
my mouth! ! Call {2<strong>15</strong>1 386-7366 (Phifade}phia PA) and ask for Penny-<br />
You'll NEVER find a girl more eager to suck, or more grateful for the<br />
opportunity to swa11ow.<br />
Penny Parker<br />
4247 locust St. # 806<br />
Philadelphia, PA 191O4<br />
CaII me. use me! Irm HORNY! l!! l!!!!!!!l<br />
ps://groups.google.<br />
Retrieved June 11, 20<strong>15</strong> 2:07 arrr<br />
20
ffi https://groups-goog1... P - I 0<br />
Post #2:<br />
fi*#<br />
Erom: "Penny Parke.r" <br />
subject: Thirsty slave seeks Master<br />
Date: L991/L2/LA<br />
Message-ID: *1/1<br />
x-Deja-AN:2993453?5<br />
x-xS4AIL-Date: Thu, 18 Dec 1997 <strong>15</strong>:38:21 CET<br />
Content-Type: text/p]ain<br />
organizati-on: Replay and company Unl,imited<br />
x-OO1: Ttrls message was forwarded kry an automated remailing service-<br />
X-OO2: No attempt was made to ver1fy the senderrs identity.<br />
x-OO3: Please report mj-suse to <br />
Newsgroups: al.t - personals. bondage<br />
HelLo, Sir"<br />
I am a slave qirf in desperate need of discip].ine and the cum of a big<br />
strong man- or, better yet, l4EN! ! ! ! !<br />
I am available day oR night. anytime you or your friends brant to use a<br />
qirl with a severe semen jones- Come by ANYTIME, I liwe in the Eaj-rfax<br />
Apartments, Locust Street, Philadelphia, Apartment No- 806.<br />
Feel free to call me at (2<strong>15</strong>) 386-7366. I donrt usua1fy read email from<br />
this address, becauae of alL the junk that comes in. But PLEASE PLEASE<br />
PLEASE feef free to calf Ine" Me and my mouth are at your disposa]-.<br />
Slave Penny<br />
Retrieved June I l, 20<strong>15</strong> 2:10 an<br />
49. Plaintifl who quickly posted a response to the first message, warning men not to call,<br />
knows exactly how many did so anyway, because he answered each call;four. The purpose of<br />
the ad was to drive Plaintiffs mother -- like the astrologer Defendant, a Taurus born in mid-May<br />
-- into evicting her caregiver son, so as to cut off his internet access. Further playing to the<br />
stereotype of the loser-who-lives-with-his-mother by Clanton and other Mafia males included<br />
false claims that Plaintiff was on welfare and food stamps. In reality, Plaintiff had grown up<br />
well-off on the Upper East Side of New York, and had long since tired of using money and status<br />
to win the approval of individuals like Clanton.<br />
2t
50. The purpose of the female Mafia members, most notably McNamara and Pearson, was<br />
to make false allegations against Plaintiff, and to enlist the males in various tasks to intimidate or<br />
harm Plaintiff, all in the rutme of covering up the Moceanu abuse story. When Moceanu ran<br />
away in October, 1998, this conflict effectively ended, though various skirmishes would continue<br />
through the 2000 Olympics.<br />
51. In the section of the ED page entitled Ray's Self-Proclaimed Careers, any job or<br />
business engaged in by Plaintiff is defaulted to scam status, further evidence that Plaintiff is just<br />
an overall fraud:<br />
th€ past, Gordon has clalmed to bot<br />
E pro gymnastics coach - Clalms to train s8veral gymnasts online<br />
n Pro chsss player and/or dress coach - only a hlt shy of bs{omln6 World Champlon.<br />
le be lntorns*onally rankad Noto: tho USCF has N0 listlng of hlm on their wshsltE. t<br />
lnformatlon yyo h6ve, Rat's old ratingsxbt& but his msmbsrship ls not currBnt<br />
p Pro handleapper and oddrmaker - Accordlng to hie web sits<br />
"<br />
Pro finance market anallu€r - According to hii ry$b site<br />
s Pro relatlonships adviser -Teaches men 'how to get laidr<br />
o Pro hypnotist and hypnosis in$tructor - Harasses and bsd mouths female hypnotists<br />
o Writer - Writes a book sbout ssductlon, horse raclng and Dcminlqua Moceanu<br />
s Besl sscretary ln the U$A - But got firad beceuss he wasnt an ioffioe whord'<br />
E PalalogEl- P€nnsylvsnla requlres somo eort of profs$sional cortiflcatlon, but Ray dossnt know<br />
that.<br />
o ActMst aElainst chlld abuse snd soxual harassmont - Claims that Smnastacs coaches ars ehild<br />
ebusers<br />
Ir Professional psychic . And still doasn'l have a clue about the Edltorial Staff of I<br />
o Civil Rigrrts Activi$t - Clalms th€t hiring dlBcriminoiion hss prsvonted him from<br />
Flled sult agninst UPenn. Hmmm,,.<br />
a Journallst - Not accrodltod by any nems agjenry, though.<br />
a Softwcre Compeny CEO & entreplenaur - Own company, ol course<br />
n Successful buslnese owner - Also known as broko. and fllod banlauptcy ln 1I)97.<br />
E<br />
E<br />
n<br />
tr<br />
E<br />
Body bulldor - And sf coura.e extremely good looklnd<br />
Jasus Chmt. Only ln psst llfo though.<br />
Skllled Hypnotlet - Oalms to be abls to rGaln TOTAL $oxuel Control! owr women<br />
Source: ED PAGE, Retrieved June 9,20<strong>15</strong><br />
22
52. At the time of publication, Defendant either knew or should have known that<br />
numerous of the above statements conceming Plaintiff are false and/or misleading, to the point<br />
of portraying Plaintiff in a false light. Plaintiff has a 4.0 GPA from a year at SUNY, his USCF<br />
rating peaked at Expert (90th percentile) within two years of his first tournament game. Plaintiff<br />
coached the 1990 Parkway Gamma High School from an 0-3 record when he got them, to a 5-5<br />
finish, third place, and a 9-1 crushing win over third-ranked Washington to close the year. He<br />
has given paid psychic readings (Defendant does similar and is not mocked), has produced<br />
hypnosis mp3 recordings that have grossed five figures, grew up among a home-based<br />
transcription service which was the largest in NYC at its peak in 1979, has designed popular and<br />
profitable methods for rating horse races and sports teams, types 100 wpffi, has worked for years<br />
as a high-leveI secretary and paralegal, and published an article about the Moceanu abuse case in<br />
1995, and again in 1997,long before the truth was known to the public.<br />
53. At the time of publication, Defendant either knew or should have known that the<br />
imputation of unauthoiz<strong>edpa</strong>ralegal practice upon Plaintiff is false, although an investigative<br />
reader would quickly verifi, that Pennsylvania has no such restrictions, contrary to the claim.<br />
RavFAO: 1999-2014<br />
54. Even after Moceanu's scandal resolved, the RayFAQ continued to follow Plaintiff<br />
wherever he went online, including allseduction.fast, Ground Zerc for the intemet "pickup<br />
artist' (PUA) movement,populaized by Neil Strauss's The Game (2005) and VH-l's The<br />
Pickup Artist In tow from alt.sports.gtmnastics car.,rc Thom E. "Subzero" Geiger (Posting as<br />
SubZer0@freon.net), who registered the domain ray-gordon.com, where he ultimately hosted the<br />
RayFAQ, but only after he was banned from hosting it on the server of hardcore white-<br />
23
supremacist group The Order Of White Knights. "Subzero" is not to be confused with the "zero<br />
squad" referenced in the rapelmurder essay.<br />
55. Immediately upon publication of Outfoxing The Foxes, Plaintiff became a target for<br />
defamation in the USENET group allseduction.fast (ASF), Ground Zero for the internet "P[JA"<br />
movement which would mainstream in 2005 with Neil Strauss's The Game. This was<br />
painstakingly detailed in Plaintiffs RICO claims in Parker v. Learn The Skills Corp. (I-[D, (case<br />
cites omitted). Leading the charge from alt.sports.gymnastics was Geiger, who originally<br />
claimed his wife, Susan, was so enraged by Plaintiffs postings that Geiger was spuffed into<br />
action. Joining Geiger on ASF was Derek "Odious" Trunk, the group's self-proclaimed "FAQ<br />
administrator," and an internet right-hand to Ross Jeffries, another PUA guru featured in The<br />
Game, a teacher of NLP seduction, or the use of covert hypnosis to seduce women.<br />
56. On ASF, the RayFAQpage had morphed from its original pu{pose in the gyrnnastics<br />
community, to a robo-defamation machine which conferred Section 230 immunity on anyone<br />
who linked through it to ray-gordon.com, including Geiger (or so he claimed), the sole individual<br />
Plaintiff could sue directly, in Columbus, Mississippi. Geiger had repeatedly threatened Plaintiff<br />
with physical violence, making it terrifying for Plaintiff to file suit in Mississippi; he instead<br />
pursued a RICO action in this district (Pa*eIr-LISq D, which failed.<br />
57. Beginning in 2001, aman later identified as John J. Tashjian ("JJT") began posting to<br />
ASF, repeatedly linking to the RayFAQ, and eventually claimed the RayFAO.com domain when<br />
Plaintifffinally abandoned it. In conjunction with Trunk (Odious), Geiger, and others on ASF<br />
loyal to Jeffries, they disrupted every thread to which Plaintiff would post, in order to destroy his<br />
ability to communicate with his fan base, and to defame him at every turn.<br />
24
58. Tashjian's many threats against Plaintiff are already canonized in the Parker v. LTSC<br />
trilogy. Typical of his conduct, which includes thousands of similar postings all tarring Plaintiff<br />
while linking to the RayFAQand Google-bombing his birth nzlme, was the following (split into<br />
parts):<br />
Search for topics *l C-<br />
Shouonly message<br />
Path: g2newsl.google.com!news3.google.com!news.glorb.com!borderl.nntp.dca.giganews,<br />
NNTP-Posting-Date: Tue, 07 Jun 2005 20:50:49 -0500<br />
Erom: j jt <br />
Newsgroups: aLt.support.lonelinessralt.support.shynessrsoc.women'soc.singlesralt.<br />
Subject: Re: Another single mother whore<br />
Date: Tue, 07 ilun 2005 2I:55:00 -0400<br />
Organization: Your Red I'ilagon<br />
RepIy-To: Diddy-wah-Diddy<br />
Mes sage-ID : < r}j cal-9 62 4j o4 6br3 j 7bh6s 94a7ohoe7 1 j B 4ax. com><br />
References : <br />
X-Newsreader: Eorte Agent 2.O/32. 652<br />
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' X-Complaints-To: ab...Ggiganells-com<br />
x-DMcA-Notif ications : http : / /wr+w. gl ganews . com/ inf o./dmca . html<br />
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X-Postfilter: 1 - 3. 32<br />
Xref: g2news1. google. com alt. support. loneliness:26330 alt. support. shyness:97 019 soc.<br />
>Very touching.<br />
Nasty shit. I post it only because Gordon Roy Parker<br />
has threatened me, my familyr my friends, both on and<br />
25
Search for topics<br />
- | q<br />
Show oflly message<br />
MY sin. - I came on]-ine to talk ak)out my romaflce, and he<br />
went, what; ls now known as "..grp ie-." Records show a1f..<br />
..itrs tris own posts.-not my vjiews. He tried to nuke them-.<br />
..1 have EVERYBODYTS posts for years-. He couldnrt run away fast enough..<br />
He has known my home addres.s (I posted it here often) and has<br />
called me John Doe *17. He tras threatened my parents, my friends,<br />
THEIR CHILDREN ! ! ! ! I, and UNKNOIJCN CHII.DREN NOT INVOI,VED IN his fantasy.<br />
*f* Talked to His tlonor Judge Kelly- I doubt id grp-ie ever dj-d.<br />
Notice I se1dom post "..on t:opj:c--" here, itrs not *I{Y* red wagon,<br />
I feel that till grp-ie stops threatening me et all, and allows me<br />
to answer his threats 84 a "..fuckinr judge./court--" like he has BEGGED<br />
to happen for D-E C A-D-E s-- .fust- what IZ stopping t,he gut-1ess coward--?<br />
His o!'rn biqi mouth, his or,rn Lhreats, hi.s persona]. herpes 1nfested cake-hole..<br />
hle have met in person. Euz spit on him. He fras video of hj-s momie..<br />
-.and the REAL hot babe !'rho threw the drink in his face. I trave it on<br />
my desktop-. grp-i,e, you need "..Curves." U is getting fat & stupid.<br />
TeIl ttle world, ctri]-d molester-.why have you never suede Fuz da' Bun..?<br />
https://groups.google.com/forum/#!originaValt.support.loneliness/QflJGMkCXgVQ/Z3eLO6qJiJoJ<br />
Retrieved June 11, 20<strong>15</strong> 2:22 am<br />
59. On July 7,2010, Tashjian threatened to "bitchslap the dogfuck out of' Plaintiff leave<br />
him in a wheelchair, and "maybe film it":<br />
26
Gt:ngle<br />
Search fcr topics I Cl" Bettor---<br />
rtt<br />
T:I<br />
raa<br />
@<br />
Groups<br />
l<br />
Harun al Rashid Raycordon wrote: Snno<br />
g<br />
JJrj<br />
Re: UGLY<br />
3[7nA<br />
>> I never said I 'was hiring 2 ment to beat you up and would vicleotape if-<br />
>The cat{ot-the-keyboarcl excuse! Too bad the messages say otherwise-<br />
>Now that he knows he's fucked, he's gonna keep backpedaling- Won't do<br />
>him any good, hwoever- He will have brought every last legal<br />
>consequence upon himself, and there's not a THING he can do to stop<br />
>it. He knows this.<br />
Here is the message: I stated:<br />
>> >Everybody knows you iust post this crap to piss others off, and in my case,<br />
>> >you did years ago. Next time I see you in person, I WLL bitch slap the<br />
>> >dogfuck out of you- Maybe break a leg or arm. Maybe iust have someone<br />
>> >else do it. Maybe film it. Maybe buy the wheelchair you will be lefi in.<br />
And itstrue, NEXTTIME ISEEYOU lN PERSON,lwill<br />
bitchslap the dogfuck out of you. Then it's maybe maybe maybe-<br />
NO 2 men'. lF you are so afraid, why not call the police NOW! ?<br />
https://groups.google.com/forum,/#!search/JJT$20threat$20beat$20me$2Oup$20video/alt.seduction.fast/TZYeSOkY_I4lPjdQPTGjH3AJ<br />
*^**3:;tr;:t'::r;#:ir,fiy:'{:;;'#'**^<br />
60. This was far from the only threat from Tashjian (this Complaint would run flve<br />
thousand pages if it included everything), who had claimed to have Plaintiffs mother on video.<br />
Tashjian's relatives include prominent attorneys and municipal employees (retired) in Worcester,<br />
not far from Clanton's Boston-area residence at the time. Tashjian is apparently on disability and<br />
"judgment-proof " a perfect beard for more powerful, more sinister forces.<br />
61. In2004, JJT posted repeatedly that he had been contacted by "folks" about making a<br />
movie concerning Plaintiff:<br />
27
Gmcrgle<br />
Search for iopics - | q.<br />
Re: ..Update on the movie....<br />
>then some good peopie (self included i hope) can make a documentary movie<br />
>about your internet ramblings, make a fortune doing so, and you won't be<br />
>able to do anything about it except cry.<br />
l've been getting email about the movie. Here's an update:<br />
The folks interested in it have spoken of making it an<br />
animated cartoon/live thing. I havent yet seen the<br />
outline yet, so I dont know what that means. From<br />
what I have heard, the'cartoon'would be based on<br />
the old'Thunderbirds" and'Supercaf' Marionation.<br />
I am NOT joking or making this up, boyz n girls-.<br />
the'staf newsloon will be live, the rea! world: F.A-B / Live .<br />
l've been watching old G/Anderson stufithis week, buying<br />
all the DVDS- AMAZING stuff. Now the G/A people are NOT<br />
involved, this is all iust the talk stage, but GOTO:...-<br />
http://wl,w.sci-ti-on lane-50megs.corn/Features/supermarionation.htm<br />
62. While the ASF extension of the Mafra,linked through Geiger, continued its<br />
harassment of Plaintiff, anonymous postings diverted most ASF traffic to commercial websites<br />
like fastseduction.com, on which a parallel, commercial PUA community was built, with the<br />
public never the wiser regarding the lack of free speech, the stealth marketing, or Plaintiffs early<br />
contributions, due to the perpetual noise and ostracizing on ASF, of which the foregoing is the<br />
mere tip of the iceberg. Once The Game dropped, ASF all but lost relevance to the PUA<br />
community, though it will exist in perpetuity.<br />
63. Also as noted on the ED page, Plaintiffs mother was contacted offline by Trunk, in<br />
April, 2007, by letter, just months prior to her death from cancer in July, 2007 .<br />
28
64. A few days after the first letter, which Plaintiff mentioned on ASF in order to flush out<br />
the author, a second letter arrived, notifying Plaintiff that copies of the second letter were being<br />
circulated around his neighborhood.<br />
65. After Plaintiff published the notice that he had received a "death threat" against his<br />
mother (veiled, a reference to how Plaintiff could not survive financially after her impending<br />
passing), Trunk claimed to have found the letter online, read it, andthatit did not contain any<br />
such threat. Trunk had also continued to link to the RayFAQ,now hosted by Tashjian.<br />
66. On January 26,2010, Plaintiff officially retired as a pickup artist (PUA), published<br />
Bettor Off Single for free, with advertising links to his other writing, on PUA and beyond.<br />
67. Thanks to mass murders by failed PUA (Sodini, Rodger), Plaintiff has been thrust<br />
back into the spotlight, with a new generation of his haters linking to the ED page and the<br />
RayFAQ, with the former updated to reflect Plaintiffs new imputed "failures." Ironically, these<br />
are often anti-PUA feminists who are unwitting pawns of the very men they claim to despise.<br />
Where Are They Now?<br />
68. No one in this drama went on to rescue a drowning Brooke Shields, only to blow the<br />
reward money by hiring Van Halen to play their birthday party,nor, to Plaintiffs knowledge, has<br />
anyone used hot coffee to foil a convenience-store robbery. Instead, the modern internet, and<br />
current events, have, for Plaintiff, just as they have for @AdamFGoldberg, made the past keep<br />
getting clearer every day.<br />
69. As KTLzI-Sb award-winning news desk may have reported, on February 8,2012,5an<br />
Diego resident Derek "Odious" Trunk, the self-appointed anti-pedophilia crusader whose sole<br />
mission on the internet seemed tobe To Catch A Plaintiff, was sentenced to seventy-five (75)<br />
29
months in prison for trafficking in child pornography, an offlense he would not have been able to<br />
commit for as long had he been prosecuted for his conduct towards Plaintiff years earlier:<br />
CHILD EXPLOITATIOFI<br />
02t0&120't2<br />
Sgn-t!_jqgo man seilteilced to 20 years for possessioil<br />
of child pornography<br />
ICE arrests 3 other area defendanh pn unrelated child ponrography charges<br />
SAN DIEGO - A registered sex aflender has heen sentenced to 20 years in federal pnson for<br />
possession of cftild pomognaphy following an inuesligation by U.S. tmmigration and Castorm<br />
Enforrement s (lCE) Homeland Serurity lnvestigations (HSt).<br />
Jeny Louis Tiahrnan, 69, of San Diego, was senlenced Monday in federal murt by U,S. District Court<br />
Judge Roger T- Benitez. At the hearing, Judge Benitez told Tinbrnan, "This is one of tfre lorqest<br />
sentences I have euerimposed, and you si1 are deservirp of it-,'<br />
Tinlsman has been in federal custody since his arrest hy HSI special agents October 19,2010.<br />
Follotring his anel special agents exes.rted a federal search wanant on Tinlsmas's horne comprter<br />
where more than 6{XI images of chitrd pomography were discovered- He pleaded guilg to federal child<br />
pomography charges in December 20tr$,<br />
Tintsman was prevlously mnvided of felony charges lor lerrvd ac{s involvirE two glrls under age tr4 arfi<br />
was listed on ihe Califomia Megan's Lavr registered sex offender database ai the time of his arrest.<br />
'This sentence stnuld serue as a warning to those who seek to victimize and rob young children of<br />
their innocerrce," said Derek Benneq special agenl in cfiarge for HSI San Diego. "HSl will continue to<br />
aggressively hunt dorn chiH predalors who use the lnternet to prcy on m:lnerable children. We will<br />
ensure this $pe of crirninal aclivity is pursued and chiH predators are hetd amuntable for their<br />
despicable behavior.'<br />
According to the court documents, f intsman engaged in an online chatnrith an undercover HSI special<br />
agent whom he thought was the rnother of a se\ren-year-oH daughter. During the chat, llnbrnan<br />
revealed he had a sexual interest in ctrlldren foe and oHer and told the undercover agenl he wanted to<br />
erEage in sexual aondud with frte futitous seven-year-old daughter. He then toH the undercover agent<br />
he had dated the mother of his two pdor victims.<br />
Tintsman's sentencing comes less tfian a week after federal agenb frorn the HSI cybercrimes unit in<br />
San Diego arrested three San Diegoarea mer on federat cfrild pornograptry charges as part of an<br />
ongoing sex predator inuestigation, All three were taken into custody for possessftrn of child<br />
pomography and willbe proomuted in lederal aourt<br />
The indiuiduals arrested are.<br />
. James Achenbach, 52, of Nat&onal City;<br />
. Derek Trunlg 34, of San Diego; and<br />
h@://www.ice.gov/news/releases/san-diego-man-sentenced-20-years-possession-child-pornography<br />
Retrieved June 11, 20<strong>15</strong> 3:39 am<br />
30
70. Dominique Moceanu later admitted to having been kept in the dark "about a lot of<br />
things" as a teenager. She is now a mother and roving gymnastics coach, and learned not long<br />
ago that she has a biological sister who was born without legs and given up for adoption at birth.<br />
Plaintiff had alleged that Moceanu was pledged by her parents to Bela Karolyi in return for the<br />
latter helping the former escape communist Romania ("An American Slave," USENET,1997).<br />
71. 1n2009, Thom E. Geiger ran as an "indie" for mayor of Columbus, Mississippi...and<br />
lost. He still practices political activism.<br />
72. When we come back, we'll reveal the most interesting Where Are They Now? of all.<br />
COUNT (SUB)ZERO: RICO VIOLATIONS AGAINST NO ONE<br />
73. Plaintiff incorporates by reference, the entire contents of all previous paragraphs, as if<br />
fully stated verbatim herein.<br />
A Friend To All Is A F'riend To None<br />
74. One of the silent partners of the Gymnastics Majia was a teenager who went by the<br />
handle Merlock06@ aol. com.<br />
75. On December 14,7997, while Plaintiffs mother was being impersonated by Clanton<br />
and or Merlock and the MaJia, in exchange for celebrity access to sexually abused gymnasts,<br />
Plaintiff posted a "protective" warning message to alt sports.gtmnastics, concerning Merlock,<br />
which was replied toby MaJia member Kevraxx, likely an alternate identity for Merlock:<br />
31
$earch for topies<br />
rlq<br />
Show unmasked eruil afi reseE<br />
I'ronr kev...8aol.con (Kevruxl<br />
Suhject: Re: Jay ard l,lissy figure out Ray-IIIIAIII<br />
Date: i99?/12/14<br />
Uessage-ID: d9971214075301.CnA02570Bladder0l,news.aol,con)#111<br />
X-neja-AI{: 298031898<br />
References :
Guug}*<br />
Search for topics<br />
-l q<br />
Show unmasked email addresses<br />
Eromr merl.,.<br />
Subject: Re: *0ff Topicr I!1 with Ray<br />
Date:1998/06/29<br />
Message-ID:
Seareh for toPics<br />
"l q<br />
show unmasked €mail addrcsses<br />
&#Jfi;;*- ',i.*.-p..pre really are in the line of work you claim to be in.<br />
CYouIn2000: And one lhing they can't stand is a wannabe<br />
iiouln2000: 5o when you {et a-n education on how things are done on that<br />
side of the fence, donrt lrhine to me'<br />
iioorrrZOOOt I wouLd suggest you not try that stunt on anyone else because<br />
others would be far less tolerant of it than I'<br />
CYouIn2000:Andthatisfriendlyadvice.eventhoughyouarenrtdeserving<br />
of any.<br />
cYour;2000: Good boY. StaY quiet'<br />
CYouIn2000: You need to if you don't want further problems'<br />
tIerlock06: HAHAHA i was woidering do you think its heatthy to talk to<br />
yourself?<br />
CYouIn2000: You donrt get it<br />
CYouIn2000i If you are lucky you never will get it<br />
!terlock06:<br />
CYouIn2000: Oh I have a clue<br />
CYouIn2000: You don't<br />
CYouIn2000: Your protection has the opposite effect<br />
you have no clue myfriend" - but youll learn soon enough<br />
;i;;i;r000, Anything that happens to me happens to them 10 times norse<br />
CYouIn2000: You call that an even trade be ny girest<br />
Merl,ock06:goooyoutlneeditllAllAllAYoudolrhatyouhavetodoandil}do<br />
what i have to do remenber that SON"<br />
!lerlock06: this book is shut<br />
CYouIn2000: You 3til1 don't get it<br />
Merlock06: ciao<br />
CYouIn2000: But You uill<br />
CYouIn2000: You're a goner<br />
CYouIn2000: LegaIlY<br />
CYouIn20003 sorrY l-ittle nan<br />
CYouIn2000: Thinis he can scare people with that mouth'<br />
CYouIn2000: You know you don't have a Ieg to stand on<br />
CYouIn2000: Pathetic geek<br />
cyouln2000: you,re a iot rLore intelligent vhen you say nothing.<br />
CYouIn2000: AII you do is hurt those girls with your words'<br />
cYouln2000: You ran your mouth before Iike this, renember?<br />
CYouIn2000: Once I forgave; twice no way'<br />
cioufrrZOOO: By the urayi you'll be putting your friends in prison possibly<br />
PartZ Above<br />
34
Sear*h for topics<br />
,lq<br />
Showonlymessqe<br />
Show unmashed email addresses<br />
CYouIn2000: 0nce I forgave; twice no way'<br />
cyouln2000: By the way, you'1l be putting your friends in prison possibly<br />
this tine.<br />
cyouln2000: And they'tl be the ones who get you in trouble to save<br />
themselves.<br />
Herlock06: You wanna kaow what i find funny. Is lrn right you ale<br />
dellusional your having an imaginary conversation with me when im not even<br />
saying anything LOI<br />
CYouIn2000: Youtre the delusional one<br />
CYouIn2000: You can't stoP anYthing<br />
CYouIn2000: I know it annoys you to be so powerless<br />
MerLock06: hahahaha<br />
CYouIn2000: You had manY chances<br />
CYouIn2000: StuPid geek<br />
CYouIn2000: All you did was speed up the lawsuit<br />
CYouIn2000: Your protection is the nost dangerous thing your friends have'<br />
CYouIn2000: To themselves.<br />
CYouIn2000: You speak for them when you try to be a terrorist<br />
cyouln2000: Try to find more productive outlets for your jealousy next<br />
tfune.<br />
cyouln2000: It,s not rny fault you aren't even 1 percent of the man I am.<br />
CYouIn2000: You said aII the same words months ago<br />
CYouIn2000: l,ook at aII that good it did you<br />
cyouln2000: oh well I best be going nora. Try your wannabe tactics on<br />
someone who isnrt already what you "wannabe.' It's a lot less risky. Bye,<br />
.Ieff .<br />
Herlock06: hahahahahahaha feel pitty for the uneducated ciao<br />
Wannabe"tshizz"<br />
Merlock06: It seemB to me you "WANNABE" alot of things like a qyrnastics<br />
coach of a llorld class g1'mnast and a member of the moceanu family" but<br />
basically you Just dont have it IIAHAIIA<br />
(The bleepis were for Vulgar Ianguage that he used and I find it very EUNNY<br />
that firsi he says im all talk but when i dont say a word he makes up another<br />
excuse.. TRyTNG io find a way around the FEAR well here it is guys! Think what<br />
you wish but rie al"l knor+ the truth<br />
Everyones friend<br />
.Ieff<br />
Part 3 Above<br />
77. This exchange has temporal proximity to the creation of the RayFAQ, and followed<br />
numerous direct, terroristic, and frightening threats made against Plaintiff in an IM, and in the<br />
Gymnastics Chatroom on AOL.<br />
7g. Though Plaintiff said most of the words in the chat, itwas Merlo ck's presence which<br />
did the real talking, revealing his protector role. His lines were straight out of mafia fiction:<br />
35
of story." (Part I)<br />
a) "My friend...you do what you have to do and I'11 do what I have to do period end<br />
b) "hahaha I was wondering do you think it's healthy to talk to yourself?" (Part II)<br />
c) "You do what you have to do and I'11 do what I have to do remember that SON...'<br />
(to the best of his knowledge, Plaintiffs late mother and Merlock never had sex). (II)<br />
d) "You wanna know what I find funny. Is Im right you are dellusional [sic] your<br />
[sic] having an imaginary conversation with me when im not even saying anything LOL." (m)<br />
e) [in response to being called awannabe] "hahahahahahaha feel pitty for the<br />
uneducated Ciao Wannabe "Whizz'. (Plaintiffs AOL name in1996 was WhizardRay) It seems to<br />
me you "WANNABE" alot of things like a gymnastics coach of a World class gymnast and a<br />
member of the moceanu family.. but basically you Just dont have it HAHAHA" (I[)<br />
f) [to the audience]:<br />
(The bleep's were for Vulgar language that he used and I find it very FUNNY<br />
that first he says im all talk but when i dont say a word he makes up another<br />
excuse.. TRYING to find a way around the FEAR well here it is guys! Think<br />
what you wish but we all know the truth Everyones friend Jeff<br />
79. All Plaintiff knew in 1998 was that Merlock lived near...Boston, claimed to be short,<br />
fat, Sicilian, and went by the name Jeff, information not sufficient, even if accurate, to identify<br />
him without subpoena to AOL.<br />
80. Also on Jvre29,1998, Merlock posted the following to USENET:<br />
36
https://groups.google.com/forum/# !original/alt.sports.gymnastics/bAfQhOU6D3o/pNmxelx8iPoJ<br />
Retrieved June 11, 20<strong>15</strong> 6:2lanr<br />
81. "Vance" refers to Vance Lear, a judgment-proof, homeless member of the Hypnosis<br />
MaJia, based in San Francisco compensated for hiding the true source of internet attacks against<br />
Plaintiff. Vance has falsely claimed a Ph.D. in psychology, and that his late wife, Leslie Harivel,<br />
a big-firm paralegal, was an attorney, an insult to big-firm paralegals everywhere. Just as<br />
Defendant found the ED page a convenient ally, friend-to-all Merlock immediately embraced<br />
37
Vance, who had once threatened to "come after" Plaintiff during a harassing telephone call in<br />
2002. Lear has also claimed to have worked with the world's leading psychiatrists; about this<br />
Plaintiff has absolutely no doubt.<br />
82. Emboldened by his new legal advisor, Vance Lear, Merlock (the webmaster for<br />
several elite "MaJia-protected" gymnasts, and editor of a gymnastics website) forged ahead with<br />
his mission to completely ruin Plaintiff, hopefully to the point of suicide. Merlock's motivation<br />
for this burst ofverbal aggression had been posted one day prior:<br />
firlngtc<br />
Groups<br />
Searchfortopics -l q Bettor...<br />
Show only message<br />
@<br />
-1 Erorn: merl. -.Gaol.com (Merlock06)<br />
I Subject: Re: Why Radio Broadcaster tlannabes Should Not practice<br />
J<br />
Law<br />
Date: 1998 /06128<br />
Message-ID : # 1/1<br />
X-Deja-AN: 366852574<br />
References :
claimed that Plaintiffs claims that Moceanu was being abused were libelous, and that she could<br />
sue him over that (Plaintiff wanted sunlight on the abuse).<br />
84. During one of theirlM sitdowns, Merlock parted with some central wisdom:<br />
ttRevenge has NO time limit," he said. By this, Plaintiff mistakenly believed that Merlock was<br />
referring to there being no limit on how long one could delay exacting revenge, but it appears<br />
Merlock also meant that there was no limit on how long he could ruin Plaintiff for here we are in<br />
20<strong>15</strong> with Defendant grinding the eighteen-year-old axe of this thirty-five year-old man who<br />
warned Plaintiff never to forget him as a threat. Heeding this warning, Plaintiff internet-snooped<br />
the Mer1ock06@ao1.com e-mail address, just in case this Merlock loser still held a grudge:<br />
.Iozek I{alitka<br />
jpirx@ccrncast.net<br />
Jozek Kalitka<br />
Mark Kalivas<br />
Mark l(alivas<br />
JeffKalligheri<br />
Jeff Kalligheri<br />
JeffItulligheri<br />
Jeff I(alligheri<br />
.feffKalligheri<br />
jpin
,-<br />
clX<br />
File fdit ldie$r Fayorines Tools<br />
r<br />
r Jeffffielligheri pn Twittefi',..<br />
li{cmmwnitX-ogrlr r<br />
@Em todd mcl6 @d*tstgu' 25 ltla', 2$12<br />
ffi[iffim I fla] lll€ ktd rtq, '$En I$Uno g*E &drt& l*uts{t ruFce{Gaily }E[, TE{r,rE<br />
&& sEc&hlngniysh[fF<br />
{a {5* fr * ta .rl<br />
tlryb o*Hauisheri<br />
$fr* fl g"lcffiaeghari<br />
rnolay haha ld bet rnontsy u arfint<br />
lyimg,lm tfis kid that rnrhen geffililg Into fights<br />
wCIuld s&y "l beat up kids like you on the<br />
way to fiEfih*<br />
{tfif**.<br />
ffi ffi &Effi<br />
,.;fiF.<br />
w& -t W '& *Ll:''#'*<br />
v<br />
85. Plaintiff hears that Kalligheri is physically tough; mostly from Kalligheri, but that's<br />
what he hears. The modern internet tells all: Merlock06@aol.com, a/WaEveryone,s Friend,
furns out to have been Kalligheri, who recently built a strong filming presence in eatar, and<br />
whose most recent film, Big Game, starring Samuel L. Jackson and, athirteen year-old Dutch<br />
actot, has received international critical acclaim. Following is a list of production companies<br />
involved inBig Game:<br />
Production<br />
companies<br />
Distributed by<br />
Altitude Film<br />
Entertainment Ltd<br />
Bavaria Film Partners<br />
Egoli Tossell Film GmbH<br />
Film House Germany<br />
Head Gear Films<br />
Ketchup<br />
Metrol Technology<br />
bzero Fil<br />
Entertainment<br />
VisionPlus Fund I<br />
Waterstone<br />
Nordisk Film Distribution<br />
86. Kalligheri produced this fiIm in partnership with Subzero Film Enturtainment.<br />
87. For this "count to nowhere," Plaintiff asserts a global, association-in-fact zuCO<br />
enterprise based on traditional Sicilian MaJia crime, which also includes international child sex<br />
trafficking, masterminded by proven child-abuse enabler Jeff Kalligheri, and recently furthered<br />
by Defendant's predicate act of extortion in violation of the Hobbs Act. This, however, is no<br />
longer Plaintiffs dogfight, and is set forth solely (as background, not an actualcount) to rebut<br />
Defendant's statements concerning Plaintiff via her link to the ED pa1e,the one Defendant called<br />
research in her second Ripoff Report rebuttal:<br />
41
@ http://wmnr.ripoffreport ..-. I - O<br />
File Edit View Favorites Tools Help<br />
& Ripoff Report I New Age H-..<br />
fl*S<br />
Is There a Report About You!? Watch This 3 Minute Videol<br />
A<br />
#1 REBUTTRL owner of company<br />
To be fair<br />
AUIHOR: Jacqueline - (USAI<br />
SUBMITTED: Monday, June 08,20<strong>15</strong><br />
I posted a link about Ray Gordon that lfound online while researching the man<br />
bullying me. He was harassing me and slandering my name repetitivety and making<br />
my life a living hell. I am a healer and a very spiritual person so I feel like I must say<br />
this in good faith. I do not have any evidence that all this information in the link is<br />
e,orrect. I do know that the majority seems to check out.<br />
Respond to this report!<br />
ffi<br />
r' tldi:,.:i<br />
M r-1 \l<br />
File a Rebuftal<br />
a<br />
I<br />
*a<br />
;ifffr'Ei;r,<br />
l-l{"" 1.[<br />
><br />
v<br />
^ 4:47 AM w<br />
6t1ot2o$ w<br />
88. Defendant notes here that she "[does] not have any evidence that all this information<br />
in the link is correct." Speaking of which:<br />
COUNT ONE: DEF.AMATION (AS PUBLISHER)<br />
89. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire<br />
contents of all previous paragraphs.<br />
90. The following statements by Defendant are in controversy in this count:<br />
(paragraph 88);<br />
a) The claim that Plaintiffwas "harassing [her] or slandering [her] name"<br />
42
) 1) The contents of both the ED Page and the essay authored by Clanton to which<br />
it links (paragraph 36),2) all factual misstatements from the page noted hereinabove, including<br />
but not limited to Plaintiffhaving authored the essay or being apedophile.<br />
c) All other statements, to the extent they are proven individually defamatory at<br />
trial, or, collectively, that they portray Plaintiff in a false light, bringing shame and disgrace on<br />
he and his family for generations to come.<br />
9I. The statement in 93(a) is false; indeed, it was Defendant who "harassed" Plaintifi<br />
first making him r,ulnerable by posting a powerful hypnosis video, then by breaching the<br />
contract, and then by ignoring his request to cease all contact once fired. Defendant's<br />
protest/warning posts, and his review, were made "on the way out," and did not constitute direct<br />
contact with Defendant, but rather public-square corlmentary. By contrast, Defendant has been<br />
inciting her minions to contact Plaintiff directly, and with threatening hostility:<br />
43
Find tacas, cheap dinner, Max's<br />
l,lear Philadelphia, PA<br />
Home About lih ltYrite a Review Find Friends Messages Talk Events<br />
The P. and Ray G.<br />
You knory what? l'm sick of you. Youle harassed Kismet, Katherine Anne,<br />
Nisiyod and now Jacqueline...<br />
I know all about you and lVe told Jacqueline as such.<br />
You sued Google and lost. You know shit about hypnosis and you live with<br />
your mother at 40 + years old. You have no money.<br />
You post about cyberbullying on yelp, yet that's exacfly what your doing to<br />
Jacqueline. I'm telling everyone in the communig of you're return and fom<br />
now on you wanna pick on someone you freaking lowlife, you pick on me!<br />
G. lfJacqui didn't ask you to contact me, 'you* are the one stalking her by<br />
adelpNa' PA<br />
involving yourself in her life. lf she DID ask you to contact me, she's the<br />
0 4 source slthe conduct.<br />
I'll patiently let the truth reveal ibelf in court.<br />
YeIp Message From rrThe P,<br />
92. The statements on the ED page in 93(b), including but not limited to the claim that<br />
Plaintiff authored the rapelmurder essay, are false and misleading, as set forth inparugraph46.<br />
93. The statements were a) made to third parties, who b) clearly understood their meaning,<br />
c) were not privileged, d) not consented to by Plaintiff, and e) libelousper se. Based on<br />
preponderance of the evidence, f) similarly slanderous statements have been made verbally, by<br />
Defendant, to friends and acquaintances, adding g) slander as an element of this count.<br />
44
94. By endorsing the link to ED, claiming she had performed "research" on Plaintiff rather<br />
than just making a casual link, and saying "most of the information seems to check out,"<br />
Defendant made the ED Page her own, elevating herself to the status of publisher. Alternatively,<br />
Defendant has not proven the third-party origination of the content required for immunity.<br />
95. As set forth hereinabove, Defendants statements run afoul of the Pennsylvania tort of<br />
libel; Plaintiff states this claim for relief on that basis.<br />
96. As a direct and proximate result of Defendant's statements, Plaintiff has suffered<br />
irreparable harm, including, but not limited to, pain and suffering, loss of current and retirement<br />
income, fear for his safety at the hands of vigilantes r,vho might "Google" him when encountering<br />
Plaintiff in his daily life, and loss of reputation and social standing.<br />
97. Plaintiff is entitled to a) compensatory damages in an amount to be proven at trial; b)<br />
punitive damages, for Defendant's willful and malicious conduct; and c) injunctive relief<br />
sufficient to terminate the actionable conduct and make Plaintiff whole.<br />
COUNT TWO: DEF,AMATION (AS DISTRIBUTOR)<br />
98. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire<br />
contents of all previous paragraphs.<br />
Section 230 Constitutional Challense Mini-Memorandum (X'ederal Rule 5.1)<br />
99. Jeff Kalligheri may be everyone'sfriend, but Section 230 is his best friend. To quote<br />
the parrot:<br />
" Rraaaach ! ! Section 23 0 !.....Section 23 0 t....nraaaach ! ! DISMISSED ! ! "<br />
100. This parrot, now extinct in the remainder of the world, where Plaintiff would win this<br />
lawsuit without difficulty in five hundred out of every hundred jurisdictions not named America,<br />
has lobotomized Plaintiffs home-country judiciary, while ignoring two key factors: a) the<br />
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SCOTUS has never ruled on Section 230; andb) the law, as written, says nothing about<br />
distributor liability. Now, all but the first of an infinite gang of defamers are given a license to<br />
destroy anyone's reputation at will, without consequence, making I heard it on the internet as<br />
absolute a defense as truth, even as one is told not to trust what one reads online.<br />
1 01 . Plaintiff is currently seeking legal representation in Australi a and the United<br />
Kingdom, where judgments for equally defamatory statements run well into the six-figures. He<br />
asks this court to consider why this case would win so easily, so it may address the right to<br />
reputation for which the SCOTUS laid the foundation in Paul v. Davis ,424IJS 693 (1976),<br />
where the dissent said the constitutional right to reputation -- recognizedinthe EU, where the<br />
right to beforgotten exists and even truth is not a defense to defamation -- aheady exists, and<br />
the majority said that a secondary harm, such as the loss of employment to internet-searching,<br />
were presefi; in20<strong>15</strong>, unlike 1976, secondary, constitutional harm can now be inferred.<br />
102. If Judge Parrot hears this case, surlmarily dismissing it solely because of Section<br />
23},Plai*iff will be relegated to a lifetime of having to answer for decades-old lies which, to<br />
this day, continue to harm his career, chances for regular employment and to fulfill the public<br />
interest of self-sufficiency, and ability to form social and business connections. The public will<br />
continue to simultaneously harmed by deception.<br />
103. Public-interest arguments in favor of Section 230 are wiped by the greater<br />
constitutional interest in truth, an interest which spawns public interests such as the need for<br />
reliable consumer data, also rendered impossible by Section 230's "freedom to lie" interpretation.<br />
Why should a consamer trust any information about any product or service, if no one can be<br />
suedfor lies? Section 230 or not, Defendant accused Plaintiff of pedophilia. Under existing<br />
law in all fifty states, that is actionable defamation, atort developed to replace dueling.<br />
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-:<br />
104. While this court was threatening Plaintiff with sanctions for suing Google for<br />
distributor libel, Plaintiff had predicted at the time that as more sympathetic targets -- i.e.,<br />
women -- emerged, that legislative judicial gymnastics would ensue. The revenge porn crusaders<br />
have proven this, with entirely new federal laws specifically drafted as an end-run around23},<br />
such as the proposed federal anti-revenge-porn law. The simpler option of fixing 230 inthe first<br />
place for all people has yet to penetrate the public consciousness.<br />
105. For this count, Plaintiff avers identical damages, motivation, and level of malice,<br />
pleading his claim for relief identically to Count One above, except based on distributor liability,<br />
and seeking identical relief.<br />
106. Alternative to the foregoing, Plaintiff asks that this court apply British and Australian<br />
defamation law here, on the grounds ofjudicial economy, and because both parties derive<br />
income from an intemational audience which includes these countries.<br />
COUNT THREE: BREACH OF CONTRACT<br />
107. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire<br />
contents of all previous paragraphs.<br />
108. A deal is a deul (paragraphs 19-22). Defendant broke the deal (paragraph 24),thus<br />
violating the Pennsylvania tort of Breach of Contract; Plaintiff states this claim for relief on that<br />
basis.<br />
109. This case is analogous to Kim Basinger's having bailed out of Baxing Helena,for<br />
which she paid $3.8 million in settlement.<br />
110. While no distribution rights for either video had been negotiated, for purposes of this<br />
suit, Plaintiff had an audition with Defendant, which, if successful, would have lead to<br />
commercialization of the work, and future projects. Alternatively, even without<br />
47
conrmercialization, the contracted video was to play apivotal role in furthering both the eye and<br />
chess video projects. The breach cost Plaintiff that chance-of-a-lifetime audition, in a manner<br />
which cannot easily be restored.<br />
111. Absent Defendant's breach, Plaintiff would have a chess video for personal use, and<br />
have completed his "audition" for commercial partnership and continuing collaboration.<br />
ll2. Direct restoration of Plaintiff to "whole" status via performance of the contract is not<br />
possible, given what has transpired. Plaintiff estimates that, starting from scratch, it could cost<br />
as much as $325,000.00 to yield a comparable video from a SAG-AFTRA actress with<br />
comparable skill. That this was not a SAG-AFTRA gig is not relevant when calculating the<br />
replacement cost of the breach, especially since Plaintiff had every intention of becoming a<br />
signatory had the need for him to do so arisen.<br />
113. Because the breach was wanton, willful, and intentional, Plaintiff is entitled to<br />
punitive damages, in addition to the compensatory damages outlined hereinabove, and any<br />
injunctive relief necessary to make him whole.<br />
COT]NT FOUR: FRAUDULENT MISREPRESENTATION<br />
1 14. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire<br />
contents of all previous paragraphs.<br />
ll5. "I am not afettish model!," Defendant cried, oblivious to her spelling eror.<br />
48
116. Defendant could have fooled Plaintiff...indeed, as if mother nature performing tricks<br />
with margarine, she did fool Plaintiff into thinking she was butter. In the course of fooling him,<br />
49
Defendant ran afoul of the Pennsylvania tort of fraudulent misrepresentation; Plaintiff states this<br />
clum for relief onthat basis.<br />
117. Defendarfi, a SAG-AFTRA actress who wouldn't have dreamed of pulling a stunt like<br />
this on a big-studio executive like Jeff Kalligheri, should have known better. Her actions were<br />
intentional and self-serving.<br />
118. But for the fraudulent misrepresentation outlined hereinabove, Plaintiff would have a)<br />
proposed the eye video instead of the "edgier" chess video, and b) not dealt with Defendant via<br />
Customs Club,doing so instead as a regular hypnotherapy/hypnosis client, thus avoiding her<br />
issues withthefettish world of which she claims not to be a part, reality notwithstanding.<br />
119. The damages and remedies pled in Count Three above (paragraphs 107-113) are<br />
identical to those which Plaintiff now sets forth for this Count Four, as if fully stated verbatim.<br />
COUNT F.IVE: DECLARATORY RELIEF<br />
120. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire<br />
contents of all previous paragraphs.<br />
l2l.Inthe absence of a responsive pleading which includes a counterclaim for defamation,<br />
Plaintiff seeks a declaration that his Yelp! review contains no false and misleading statements<br />
conceming Defendant.<br />
122. Altematively, even if this court finds that there are false and misleading statements in<br />
the Yelp! review, rather than mere opinion, Plaintiff seeks a declaration that he has retracted his<br />
statements, and attempted to mitigate arry and all harm to Defendant (such as with the temporary<br />
five-star review emphasizing only Defendant's induction skills). This court now has apractical,<br />
real-world example of how Plaintiffs speech was chilled by the litigation threat.<br />
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PRAYER TOR RELIEF<br />
Plaintiff prays to God Almighty, His Son, and the Holy Ghost, but also to this Court, for the<br />
following relief:<br />
1. Compensatory damages in the amount of SIX-HUNDRED SIXTY-ONE<br />
THOUSAND DOLLARS ($661,000.00), including $325,000 for the breach and fraud claims,<br />
and $336,000 for the defamation claims.<br />
2. The maximum punitive damages allowable by law.<br />
3. Costs of suit, including attorney fees, where permiued.<br />
4. An order declaring that Plaintiffs Yelp! review contains no false and misleading<br />
statements concerning Defendant.<br />
5. Absent a timely counterclaim, a "put up or shut up" order barring Defendant from<br />
ever bringing her previously threatened lawsuits, and further deeming any such action, if<br />
permitted, in violation of both the anti-SLAPP laws and the Dragonetti Act.<br />
JURY TRIAL DEMANDED<br />
Plaintiff demands that the instant action be tried by a competent jury of his civic-minded<br />
peers.<br />
This the l2thday of June,20<strong>15</strong><br />
6"a&e eq-*<br />
f r-{<br />
;r',-,<br />
fl*d<br />
.{ .-$re I fu<br />
Gordon Roy Parker, Pro Se<br />
4247 Locust Street, #119<br />
Philadelphia, PA 19104<br />
(267)2e8-12s7<br />
SnodgrassPublish@aol.com<br />
PLAINTIF'F'<br />
51
EXHIBIT A<br />
Plaintiffs Yelp! Review Of Defendant<br />
Hypnosis is a known sexual fetish, which is why athactive female hypnotists can write their own ticket. Jacquie has<br />
provable ties to the hypnofetish community. See her interview at the "Girls And Corpses Graveside Zombie<br />
*Fetish* event from 2013:<br />
[external link redacted]<br />
She and Hypnotist Joel Silver performed at the Girls And Corpses Spring Issue 2013 Premier And Hypnosis Show:<br />
[external link redacted]<br />
Jacqui has also said she has performed at"grad nights." There are MINORS at those shows. Would anyone want a<br />
male hypnofetishist hypnotizing their underaged daughters? It's not that Jacqui herself is a problem per se, but the<br />
hypnosis she performs triggers fetishes in 4-6 percent of the population, more at a show.<br />
Any woman intelligent enough to hypnotize people on stage is more than intelligent enough to know she's turning<br />
on almost every male who falls under her spell. Beauty itself is hypnotic, and adds to the trance, even if the<br />
ostensible purpose is therapeutic. As a general rule, it is wise to keep the lines between stage hypnosis, fetish<br />
hypnosis, and therapeutic hlpnosis well-drawn; this is why I never became a hypnotherapist.<br />
After finding a very powerful induction (and very sexy, replete with phone-sex voice and dominant overtones), from<br />
Jacqui on YouTube, I tried to see if she had any videos for sale on the clips site. It is there that I found this highly<br />
trained SAG actress (all of which make for vastly superior hypnotists) had apage on "Customs Club," a website for<br />
custom fetish hypnosis videos. I offered Jacqui $1,000 to perform a sexy induction with deep mind control, for the<br />
purpose of helping my chess (by Eing the motivation to win to getting a beautiful woman, and through the<br />
rejuvenative effects ofthe hypnosis itself). She accepted my offer, but I had sent a duplicate and asked her to clear<br />
that up by e-mail. Jacqui's response to my e-mail was a request for me to pay her by PayPal, which would have<br />
risked my account, as they don't allow adult transactions, and it would have required me to cut out Customs Club,<br />
which was not fair to them.<br />
I immediately declined the transaction, and was no longer comfortable dealing with Jacqui, who put me in a bad<br />
position since now she is useless to me as a hypnotist, as I didn't trust what she had done, and other hypnotists are<br />
useless because they lack her extreme level of talent and training. It's like hypnosis suddenly becomes a drug you<br />
know isn't the strongest. Hypnosis's fatal flaw is that other people control its dosage. In this case, I have to use what<br />
my brain knows to be inferior hypnosis while patiently waiting for a superior hypnotist to come along, what could<br />
be a long wait though I'm guessing Jacqui's ultimate gift to me will be the hundreds of copycats who come around<br />
later. Someone who claims to understand artists didn't do a good job in my case, and I would rather have never seen<br />
her hypnosis at all than to be bait-and-switched in what I consider such a dishonest manner. Is she talented?<br />
Extremely. Would I recommend letting her inside your head? Never. I've been doing hypnosis since I was eight.<br />
Hypnotists like Jacqui are gteat if they like you or want something, and can be a psyche-injuring nightmare<br />
otherwise. She crossed into a seriously controversial gray area when she put up that fetish video page as well. A<br />
male hypnotherapist with a similar duality would be met with skepticism at best.<br />
Technically speaking, she has a "theoretical seal" based on my perception of her ability that will not be broken until<br />
a superior trance is induced. I've been through this before; the longest I had to wait for one to break was nine years.<br />
Because a hypnotist is not obligated to work on a subject, there is no penalty for leaving one sealed, but there should<br />
be. Anyone who can hypnotize you can seal you, intentionally or unintentionally, and if they do, you are at their<br />
mercy. You've seen how she behaved in that position with me. I cannot speak for what she would do with anyone<br />
else.