Loathesome Molester McVay-I Still Cheat Jews,Tax Departments
GourdMcVay
HenryNAMBLA<her...@mindspring.com>
CALL late nights to discuss: (408)773-0984 or (415) 841-1454,or
VISIT ME, at
55 Chumasero Drive,Daly City, San Francisco 94132 ,or
Email me: bo...@movil.com.
Kenneth McVay,SOBC, convicted of child molesting
and car theft in California and Oregon, the
well-known fag in Canada,Fag McVay of Vancouver,
also a convicted car thief and all round molester,
and still unemployed gas pump boy, mastermind of
the Canadian branch of NAMBLA, wants all to know
about all his fellow criminals and perverts.
Here is the latest.......
From: timg...@NAMBLA.org
Subject: Re:NIZKOR/MCVAY SWINDLE CCRA - ALSO JEWS!!!
Date: Wed, 9 May 2001 20:59:21 +0200 (CEST)
From: NIZKOR WATCH .
Subject: WWW.NIZKOR.ORG IS A TAX SCAM AND YOU,
THE TAX PAYER, ARE FOOTING THE BILL!
Date: Sat, 31 Mar 2001 23:46:30 -0600
One must wonder, who in CCRA is on the take,
that they do not prosecute for JEW TAX FRAUDS,
such as McVay/NIZKOR, or the BRONFMANS??
Straight from CCRA: "we have no record of a registered
charity by the name of Nizkor.org."
THIS POST FILED WITH CCRA
FOREWORD: Canadian revenue payers you need to contact
CCRA and ask them how a website is able to receive
"exempt donations" when it is neither a registered
charity or a Non Profit Organization.
In a new development, victims of the false NIZKOR
charitable donation tax receipts may now contact a
senior official of CCRA (Canadian IRS).
Call Mr.Philippe Robert
Special Investigations - Charities - CCRA
Phone : 1-800-267-2384, or 1-613-946-2423
The equivalent with IRS in the USA,
2 phone numbers for:
IRS Criminal Investigations H.O.
1-800-829-0433
or, 202-622-7796
Looks like McVay/NIZKOR, as well as related crooks
will soon be joining their buddies in the slammer.
A letter (included below) from CCRA advises me they
never heard of NIZKOR.ORG so you all should be asking
how Nizkor is offering:
"Donations over $10.00 will receive a Canadian tax
receipt" when it is nothing more than a website!
It's YOUR tax dollars financing a man who pays HIMSELF
to defame private citizens!
http://www.nizkor.org/funding.shtml
Click here to learn how to make an exempt donation
Canadian receipt)
CCRA said: "we have no record of a registered charity
by the name of Nizkor.org." (Letter included below)
Only registered charities are allowed
to issue "Canadian receipts"!!
"A registered charity is a charity that has specifically
applied to the Canada Customs and Revenue Agency for
registration and has been accepted as such. A registered
charity can issue charitable receipts for tax purposes."
CCRA rule included below with web link for verification!
THE ONE-CREATURE BUSINESS, RUN BY MCVAY SOLELY TO
LINE HIS POCKETS, IN NO WAY IS A CHARITY AS SPECIFIED BY LAW!!!
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
From: Charity webmail <Charities-B...@ccra-adrc.gc.ca>
Sender: "Langdon, Blaine" <Blaine....@ccra-adrc.gc.ca>
To: Scott Bradbury <xxx...@xxxxxx.net>
Subject: Registered charity question.
Date: Fri, 30 Mar 2001 16:23:26 -0500
X-Mailer: Internet Mail Service (5.5.2653.19)
Thank you for your e-mail.
The Charities Directorate of the Canada Customs and
Revenue Agency is responsible for the registration
and compliance of charities in Canada.
These organizations are similar to "exempt organizations"
as are registered in the United States.
However, we have no record of a registered charity
by the name of Nizkor.org.
Additionally, due to the confidentiality provisions
of the Canadian Income Tax Act, I am unable to
disclose information concerning a particular
organization's tax affairs, including measures
taken or to be taken by the Department resulting
from complaints. However, I wish to assure you that
all complaints received by the Department are
treated seriously and are fully investigated,
where appropriate.
Finally, the annual information returns of
Canadian registered charities are available to
the public.
However, as you will note from the above,
Nizkor.org is not a registered charity.
The non-profit information return which you
describe is not available to the public.
Thank you for bringing your concerns to our attention.
Sincerely,
Blaine Langdon
Charities Directorate
~~~~END~~~~
LURKERS: here is how Ken McVay and his Nizkor business
is robbing you:
Folks I am getting CCRA's attention and you
all should be putting forth the effort to find
out just how and why a "website" receives "exempt
donations" and the proprietor "pays himself" from
such donations and also his website has issued
"tax receipts." This is a scam which bilks
the Canadian Tax Payer!
LOOK!
http://www.ccra-adrc.gc.ca/tax/nonprofit/menu-e.html
Non-profit organizations - Canadian Customs and Revenue Agency
Remember Canadian Tax Payers -
It is YOU who is subsidizing Nizkor!
Do you want your tax dollar subsidizing this web site?
http://groups.google.com/groups?q=Nizkor=&rnum=16&seld=909625816&ic
=1&filter=0
From: kmc...@veritas.nizkor.org (Kenneth McVay, OBC)
Newsgroups: alt.revisionism,bc.general,can.general,tor.general,on.general
Subject: Re: ATTENTION NIZKOR: Income Tax Guide to the Non-Profit
Organization (NPO) Information Return Form T1044
Date: Tue, 27 Mar 2001 01:52:00 +0000 (UTC)
Organization: The Nizkor Project, http://www.nizkor.org/
Message-ID: <99oro0$259r$1...@news.tht.net>
References: <eghvbtgm6r3tsa0ef...@4ax.com>
<3abfe742$0$1...@news.impulse.net>
On Tue, 27 Mar 2001 01:52:00 +0000 (UTC), kmc...@veritas.nizkor.org
(Kenneth McVay, OBC) wrote:
>Nizkor is neither an NPO nor a Charity. Nizkor is a website.
Glad to see you making that a public record.
Care to explain how a website not being either an
"NPO nor a Charity" can operate as you
do and issue tax deduction receipts?
No personal attacks now McVay because I WILL HOLD
YOUR FEET TO THE FIRE! I think CCRA would be interested
in what you just declared too!
Personal attack is all people have when they can't
argue their position!
Has everyone ever noticed that trait in people who
have something to hide?
Why do you accept "exempt donations" and issue tax
receipts you bold faced liar and sleaze bag?
Answer that instead of making with the wise cracks.
You are NOT allowed by law to grant tax receipts
according to CCRA statutes which you so conveniently
deleted. The more you act like a pompous arrogant ass -
the more it makes me want to put you in your place.
YOU ARE A LIAR!
Canadian revenue payers take note of this sleazer!
He's being subsidized at your expense!
What sleaze bag McVay deleted because he doesn't want
to deal with it:
http://www.ccra-adrc.gc.ca/E/pub/tg/t4117eq/t4117eq.html#P131_12645
Income Tax Guide to the Non-Profit Organization (NPO)
Information Return Includes Form T1044
Visually impaired persons can get information on services
available to them, and can order publications in braille
or large print, or on audio cassette or computer diskette,
by calling 1-800-267-1267 weekdays from
8:15 a.m. to 5:00 p.m. (Eastern Time).
[...]
An NPO described in paragraph 149(1)(l) of the Income
Tax Act is a club,society, or association that is
organized and operated solely for:
social welfare;
civic improvement;
pleasure or recreation;
or any other purpose except profit.
Also, no part of the income of these organizations can
be payable to or otherwise available for the personal
benefit of any proprietor, member, or shareholder,
unless the proprietor, member, or shareholder was a
club, society,or association whose primary purpose
was to promote amateur athletics in Canada.
<<I don't think Nizkor promotes amateur athletics in
Canada! Please note that the law states above:
"no part of the income of these organizations
can be payable to or otherwise available for
the personal benefit of any proprietor.."
yet Ken McVay is the proprietor or director of Nizkor
(a website) and he is on public record (also shown below)
as responding to this question:
"Does Ken McVay pay himself a salary for his work for
Nizkor?" with "Yup."
Plainly this violates the above and seeing how Nizkor
operates as a back room operation from the "proprietor's"
own house(proven below) this operation should be very
questionable!
Finally note that Ken McVay announced in a public
posting above: "Nizkor is neither an
NPO nor a Charity. Nizkor is a website."
How does a "website" warrant receiving "exempt donations"?
Doc Tavish Comments>>
Distinguishing non-profit organizations from registered
charities
An NPO is not a registered charity.
A registered charity is a charity that has specifically
applied to the Canada Customs and Revenue Agency for
registration and has been ACCEPTED by CCRA as such.
A registered charity can issue charitable receipts for
tax purposes. An NPO does not have to register either
federally or provincially to maintain
its privileged tax status.
Generally, registered charities also have to disburse
80% of the funds for which they issued charitable receipts
on their own charitable activities or as gifts to qualified
donees.
NPOs cannot issue tax receipts for donations or membership
fees contributed, and they are not required to disburse a
specified percentage of their earnings.
<End of CCRA web page>
Notice what CCRA said about "issu[ing] charitable receipts
for tax purposes"? Look at McVay's operation and see if it
complies with the law stated above:
"NPOs cannot issue tax receipts for donations.."
yet Ken McVay's very own BUSINESS - NIZKOR page says:
"Donations over $10.00 will receive a Canadian tax receipt."
Ken McVay also claims that NIZKOR is NOT a charity
as shown down further in this post.
http://www.nizkor.org/funding.shtml
Click here to learn how to make an exempt donation (Canadian receipt)
http://www.nizkor.org/league-donation.html
The Nizkor Project is pleased to announce its
cooperative affiliation with the League for Human Rights
of B'nai Brith Canada. The League is a national volunteer
organization dedicated to combatting antisemitism,
racism and bigotry, and to promoting human rights
for all Canadians.
Donors wishing to use their VISA or MASTER CARD for their
donation may call B'nai Brith directly, at 1-416-633-6224,
and advise the receptionist that they wish to make a
donation to the Nizkor Project;
If you prefer, you can print this form and send to:
The Nizkor Project
c/o
The League for Human Rights of B'nai Brith Canada
15 Hove Street
Toronto, Ontario M3H 4Y8
Name:________________________________________
Street Address:________________________________________________
City_________________State/Province__________Postal Code_______
E-Mail Address:_________________________________
Amount Enclosed: $___________
Please make your donations payable to "The League for
Human Rights of B'nai Brith Canada," and add the words
"Nizkor Trust Fund" to the cheque's memo section.
A portion of amounts donated to the Trust Fund is used
to build the Nizkor Endowment Fund. If you prefer that
all of your donation be invested for Nizkor's future needs,
please earmark your cheque or draft with the notation
'For The Nizkor Endowment Fund Only.
(All bequests should be to the 'Nizkor Endowment Fund,
Care of The League for Human
Rights of B'nai Brith Canada'.)
Donations over $10.00 will receive a Canadian tax receipt.
[#0235903-43-13]
-----------------------
Notice what is said above?
Look what Ken Mcvay has said not too long ago:
http://groups.google.com/groups?q=charity=&rnum=4&seld=955885050&ic=1
From: Kenneth McVay, OBC (kmc...@veritas.nizkor.org)
Subject: Re: JEWS DUMPED FAG MCVAY!!!
Newsgroups: alt.revisionism
Date: 2000-12-05 13:46:34 PST
"McVay/Nizkor" has never issued tax receipts of any sort,
Mr.Grosvenor, so it's rather silly to suggest we got
"caught at it."
<end>
Notice how McVay says one thing and then says another?
His very own "website" says: "Donations over $10.00
will receive a Canadian tax receipt."
http://www.nizkor.org/league-donation.html
Yet in the post just above McVay said:
"McVay/Nizkor" has never issued tax receipts of any sort,
Mr. Grosvenor, so it's rather silly to suggest we
got "caught at it."
McVay is a LIAR anyway you look at it! I provided the
links to all of my proofs so that you all, the
concerned citizenry may verify my claims.
It is also plain that McVay does not claim Nizkor
to be a charitable organization as shown here:
http://groups.google.com/groups?q=charitable=&rnum=1&seld=943267125&ic=1
From: Kenneth McVay, OBC (kmc...@veritas.nizkor.org)
Subject: Re: Is Ken McVay's WWW.NIZKOR.ORG A Sham
Which Gets its Director Spending Money? R 2
Date: 2001-01-06 00:00:08 PST
In article <8kjd5t0el7tbd9lv4...@4ax.com>,
Doc Tavish <doc_tavi...@my-deja.com> wrote:
>We know that the Nizkor website relies on charitable
>donations in order to survive. We also accept that any
>organization whose survival depends on charitable
>donations should make its records open to the public.
>Will Ken McVay answer these questions as he is the sole
>director of Nizkor!
How does Mr. Bradbury "know" these things?
How does Mr. Bradbury "know" that Nizkor is a "charitable
organization?" (Can he show that anyone from Nizkor has
ever claimed to be such an organization?)
<end>
Well now we know Nizkor is not a "charitable organization"
so it has to be an NPO?!
So why does Ken McVay's NPO declare at its web page:
"Donations over $10.00 will receive a Canadian tax receipt"
which would be in violation of: "NPOs cannot issue tax
receipts for donations" but Ken McVay lies to a person
who's an object of his smear campaign: "McVay/Nizkor" has
never issued tax receipts of any sort.."
Then again KcVay admitted higher up in this post:
"Nizkor is neither an NPO nor a Charity. Nizkor is a website."
See how NIZKOR skirts all criteria of the tax laws?
Does Nizkor or does Nizkor not look crooked?
Seeing how Ken McVay's Nizkor accepts "exempt donation[s]"
it would be interesting to see why the Canadian Government
actually approves an organization with such tax status to
operate under the conditions Ken McVay's Nizkor does.
To this very day Ken McVay will not answer these
questions:
1) What is the tax number of Nizkor?
2) What is the physical address of Nizkor?
3) What is the phone number of Nizkor?
4) Where can one find the organizational papers for Nizkor?
a) How many people compose the Nizkor staff?
According to ex-staffers who have posted articles to newsgroups, McVay IS THE
SOLE PAID EMPLOYEE OF THE BUSINESS!!!
b) What are the financial responsibilities of Nizkor?
5) What is the evidence offered that Nizkor is authorized to
solicit tax free contributions?
6) How much money does Nizkor Org receive yearly as charitable donations?
7) You show below that you pay yourself-- what is your yearly pay?
Subject: Re: How much of a cut does the B'nai Brith get from Nizkor?
Date: 05/08/2000
Author: Kenneth McVay, OBC <kmc...@vex.net>
>f) Does Ken McVay pay himself a salary for his work for Nizkor?
Yup - I also appreciate revenue from public speaking and site advertising.
~~~~~~~End Archival Excerpt~~~~~~
8) Is Nizkor proper (it's office and main facilities)
located in a back room of your own residence as this says?
http://www.Xgeocities.com/dcjarviks/Idler/vIn15.htmlX
(Remove the X's to view the site, this is to help prevent
McVay from spamming the search engines. Link active March 24, 2001)
"A Voyage to Nanaimo-- It takes two hours to cross the
Georgia Strait by ferry from Vancouver, British Columbia,
another half-hour by jitney from the Nanaimo terminal to
reach the home of Kenneth N. McVay, webmaster for
The Nizkor Project . The address is an ordinary
suburban split-level in a middle-class neighborhood.
There is nothing distinctive about its location. ....
I am taken to a back room, filled with computer equipment,
monitors, and books... Seated in front of the array is
McVay, apparently a 50-something computer nerd. He is
tall, thin, with short hair and glasses, wired to the
world through his ISP. The Nizkor project which McVay
runs from this room in the back of his house... " <END>
A question for all reading this:
How many organizations which receive charitable
contributions operate from the backroom of the
director's home? He claims to be non-profit and
it appears that he would have a low overhead--
so how much money does Ken McVay receive for
his backroom operation?
Why won't Ken McVay make public his budget?
9) What sort of legitimate organization keeps
files on private citizens and publicly defames
people on its "hit list" as Nizkor does?
"Canada's Very Own Nizkor's Lies, Smears, and Defamation Answered"
http://groups.google.com/groups?q=digsig=&rnum=5&seld=921850669&ic=1
"Pathological Liar Tubby Edeiken's Perjured Fabricated Evidence"
To continually propagate information which has been
proven false, perjurious, and fabricated and by a person
who incited murder against the person he has litigated
is most deplorable BUT this is what Ken McVay's Nizkor
does with "exempt donation[s]."
An organization such as Nizkor would not be able to
operate in this manner in the United States
and perhaps this is why Ken McVay left the
United States to operate from Canada!>>
Time will tell. Those interested in finding out why
Nizkor can operate in this manner should contact:
http://www.ccra-adrc.gc.ca/contact/
which is the Canada Customs and Revenue Agency.
Nizkor would not be allowed to operate in the manner
it does in America and perhaps this is why Ken McVay,
director of Nizkor, diverts attention
from having an American money pot!
[...]
For those who are curious, here the details of
<http://www.geektools.com/cgi-bin/proxy.cgi?query=MAZAL.ORG>
the neutral people behind Mr Mazal:
His above website is registered by the
"San Antonio Area Foundation - Nizkor Fund" c/o BASIC of
600 Sandau Suite 400,
San Antonio, TX 78216, in Texas, USA.
The billing contact is Mr Harry Mazal of the same address:
San Antonio Area Foundation - Nizkor Fund c/o BASIC,
600 Sandau, Suite 400, San Antonio, TX 78216,
and their phone number is 210-377-2422.
Somebody might like to check them out in more details.
We will be happy in the spirit of openness to post all
that we are told of these people.
It is the old Nizkor gang at work again.
~~~~END~~~~
Again- Canadian tax payers- do you wish to subsidize Ken McVay?
Doc Tavish
---
I am together with McVay, regional managers for NAMBLA.
We like young children, so that we can train them our way.
I like late night discussions, even from Stormfront,
Christian Identity, PAMYAT, HAMAS or Aryan Nations,etc.
CALL late nights best, or even VISIT me:
Dr Laurence B. Shiff (Nazihunter)
327 Cortleigh Boulevard
Toronto, Ontario M5N 1R2 CA
Tel: 416-785-4574.
alternate
KASPU COM
2788 Bathurst St.
Toronto, Ontario m6b3a3 CA
Tel: 416-789-5691
(FAX) 416-789-5691
E-Mail: sh...@kaspu.com
P.S. I would love to give the first 100 callers blow jobs.
I do love the taste of Cum and Cock. Yum yum yummy.
My associate in the USA, who is like me, is:
Donald Ray Ellis
aka Pat Blakely/RevWhite/Mike Kalvatis/Rob Stewart ET AL
108 E. Victory Street
Star City, Arkansas 71667
Tel: (870) 628-1437
Lawyers, politicians, and judges need to be recycled - as fertiliser!!
"At a time of universal deceit - telling the truth
is a revolutionary act."
(George Orwell)
David Icke - '...and the truth shall set you free'
"All truth passes through three stages.
First, it is ridiculed, second it is violently opposed,
and third, it is accepted as self-evident."
(Arthur Schopenhauer)
"The reason men are silenced is not because they speak falsely,
but because they speak the truth. This is because if men speak
falsehoods, their own words can be used against them; while if
they speak truly, there is nothing which can be used
against them -- except force." -- John Bryant
"To attempt to silence a man is to pay him homage, for it is an
acknowledgement that his arguments are both impossible to answer
and impossible to ignore."
--John Bryant
If you believe in the TRUTH and the RIGHT,
then visit www.freedomsite.org
Posted courtesy of : Paul Kneisel, who likes late
night discussions, even from Christian Identity,
Pamyat, Aryan Nations, Stormfront, HAMAS, etc.
I am together with McVay and L.Schiff,
regional managers for NAMBLA.
We like young children, so that we can train them our way.
CALL, best late nights (718)390-8692
or even VISIT me:
Outerbridge, Peter
54 Wall St,
Staten Island, NY 10301-1869
My business contact is:
Outerbridge, Peter
tall...@NYCT.NET
NAMBLA.org
200 East Tenth Street #603
New York,, NY 10003
(212)-568-6690
Posted by: Boris Dynin = NAMBLA executive &
Henry<her...@mindspring.com> who like
late night discussions, even from Stormfront,
Christian Identity, Pamyat, Aryan Nations, etc.
CALL late nights to discuss: (408) 773-0984
Email me: bo...@movil.com , or even
VISIT me at:
55 Chumasero Drive, Daly City, San Francisco 94132
Ken McVay invites callers to his homosexuals escorts office:
1-250-616-9431
Or, VISIT at:
#5 - 1601 - Bowen Road, Nanaimo, B.C., Canada
For the real TRUTH about ZHIDS, visit the website for JEW-WATCH:
http://www.jewwatch.com
Or, other useful websites include:
National Alliance - www.natvan.com
OSTARA - www.ostara.org
IHR - www.ihr.org
ZUNDELSITE - www.zundelsite.org
AL JAZEERA - http://tarjim.ajeeb.com/ajeeb/default.asp?lang=1
And the star spangled banner in triumph shall wave
O’er the land of the free, and the home of the brave!
Francis Scott Key
~~~~~~~~~~~~~~~~~~~~~
This message was posted via one or more anonymous remailing services.
The original sender is unknown. Any address shown in the From header
is unverified.
MazalTov
Ken McVay
--
If Ernst Zundel is a refugee, Daffy Duck is Albert Einstein. Some
propositions are so ludicrous that they are a betrayal of common
sense and human dignity if allowed a moment's oxygen.
-REX MURPHY, The Globe and Mail
Tavish
kmc...@vex.net (Ken McVay) wrote:
>Grosvenor
So you went from accusing me to accusing another person. Looks like you are
swinging the bat in the dark. BTW when are you going to refute this and it
concerns B'nai Brith giving a communist financial aid:
http://groups.google.com/groups?hl=&selm=prbo5vkp1825141dem99scia1676el7nqd%404ax.com
Subject: Anti-American Communist Agitator and Tax Exempt Religious Org Which
Gave Him Financial and Moral Support
Date: Tue, 25 Feb 2003 21:07:42 -0600
Message-ID: <prbo5vkp1825141de...@4ax.com>
GourdMcVay
Black Knight
Get a job, you bum.
Black Knight
Shoo,fly.
MolesterMcVay
Ken McVay
Archive/File: people/g/grosvenor.william/gruber-10q
Last-Modified: 2000/04/24
Mr. "Grosvenor,"
It would be unfair to label you as either a liar or
an irrational hater of Jews without offering you the
opportunity to explain the distortions and errors noted below.
As I am certain you are a busy chap, I will republish these
questions on a regular basis, in order to provide you with
ample time to deal with the issues raised. I will also add to
them, in the event you continue to publish similarly
misleading material.
Question 1
----------
On May 13, 1996, you made the statement:
"Mind you,they do support the Jew Morgentaler and his murder
of unborn babies at his abortionariums." (Grosvenor,
Jews for Faggots)
Question 1 is a two-parter:
1. What proof do you offer that this doctor is Jewish?
2. What difference would it make if he were?
Question 2
----------
In May of 1996, you, Sir, made the following statements:
"In Alberta Canada Senator Ghitter,together with Bnai Brith
and other jewish groups are openly supporting special rights
for faggots and for more powers for the socalled human
rights commission." (Grosvenor, Jews for Faggots)
and...
"If you feel that faggots should not get special rights
at the expense of your dollars and those of all normal humans,
then join AFL - ANTI-FAGGOT LEAGUE." (Grosvenor, Support AFL)
and...
"I feel that they should NOT GET SPECIAL RIGHTS,even if the
faggot loving Canadian government wants to give them."
(Grosvenor, Faggots Spread)
and...
"Here in Alberta Senator Ghitter and the Bnai Brith are
supporting the faggots and lesbians. The groups want the Alberta
government to give special rights to the perverts,presumably as
one more attempt to destroy the traditional family."
(Grosvenor, Why Are Jews)
The question, Mr. "Grosvenor," is why you have lied about
B'nai Brith and others, who have not called upon the
government to "give special rights" to gays and/or
lesbians?
Question 3
----------
On May 30, 1996, you posted the following article to an
Internet topical discussion group:
"Canadian news media report that the subject of the KOSHER
TAX is again under investigation by Revenue Canada Taxation.
"The story on the business page, states that many manufacturers,
such as for Saran Wrap, sanka Coffee,Mr.Clean, etc. must pay
extra fees to rabbis to have their products declared kosher.
"This extra cost is then passed on to every customer.
"Some people have been trying to claim the extra $300 per person
per year as a so-called charitable donation on their tax returns.
The tax department has disallowed this fraud, since no willing
charitable donation was given, nor a receipt provided.
"Apparently some non-Jews tried to claim this,and are now very
angry at being disallowed. To add insult to injury, they had no
choice in the costs of their purchases, since the extra costs
paid to the rabbis is buried in the total costs."
(Grosvenor, Kosher Tax)
Here is the ACTUAL text of the article you cited:
"Tall tax tale isn't kosher"
"Kosher Question: Can I claim a $300 kosher tax deduction for
buying Saran Wrap, Mr. Clean, Sanka and other products that
have been blessed by rabbis and identified by secret symbols?
"Answer: No. This old and vicious rumour is based on anti-Semitic
scapegoating that tries to blame Jews for higher prices - to pay
the rabbis - then claims Jews are the only ones who know the
secret symbols and claim the kosher deduction. It's all false."
(Chalmers, Ron. Edmonton Journal, Business section, "Money
Matters," front page, May 29, 1996)
The question, of course, is why you misrepresented (to be
kind) the contents of this article?
Question 4
----------
You wrote (September 1996):
"Ken OyVey, the maggot representing the Jewish Terrorist groups
including JDL..." (Grosvenor, OyVey Concerned)
Please provide the proof of your assertion that someone named
"Ken OyVey" represents any terrorist group.
Question 5
----------
In the same article, you also said:
"The fact that Revenue Canada and the Auditor General of Canada
fingered the Bronfmans for moving 2 BILLION DOLLARS out of Canada
in contravention of Revenue Canada tax laws has also increased
anti-JEW feelings in Quebec." (Ibid.)
http://www.fja.gc.ca/en/cf/1999/vol2/html/1999fca23735.p.en.html
contains the judgment of the Federal Court of Canada in this
matter.
Please demonstrate (1) that the government, in fact, "fingered"
the Bronfman family as you have described, and (2) provide
documentation supporting the assertion that the Bronfman
family has "increased anti-JEW feelings in Quebec."
Take your time, Mr. Grosvenor.. I have several decades to
wait, although in your case it won't matter.
Question 6
----------
Moving right along, you added:
"The fact that the JEWS do not obey the French label laws for
foods imported into Quebec has of course antagonised the normal,
mainly Catholic residents of Quebec." (Ibid.)
Please name the statute that the Quebec Jews are not obeying. Provide
a reference to the complete text - don't bother reporting on it
yourself, you are an established liar and cannot be trusted in such
matters. Once you have made your case by doing that, we can move on to
the second part of the question.
Question 7
----------
In full cry, you continued with:
"Notice that OyVey refuses to answer complaints about the actions
of the JEWS. Rather, it prefers to continue asking irrelevant
personal questions, based on false news clippings.But, what can
one expect from such as OyVey, who was for some reason relieved
from the US Military, according to other posts." (Ibid.)
Please provide a precise reference for the "false news clippings"
which prompt "irrelevant personal questions." Given your
history of frivolous litigation, explain why you have not sued
the publishers of these "false news clippings" for libel.
The second part of this question, of course, is to ask that you
identify this "OyVey" you seem to be obsessing over.
Question 8
----------
Capping off your frenzy of vomitus, you conclude:
"One must also wonder about its' sexual orientation, since he
is very favourably inclined to the AIDS carrying faggots. Is it
one of them,which is why it has no family or children??One must
wonder about other aspects of the background of this piece of
foreign excrement living in Canada." (Ibid.)
Please identify this "it" that you are talking about in the
paragraph above, Mr. Grosvenor.
Question Nine
-------------
On October 3, 1996, you outdid yourself, Mr. Grosvenor, and
offered us a whopper that amazed even hardened Grosvenor
readers:
"Particularly when the respected International Red Cross stated
that only 320,000 Jews were unaccounted for as a result of the
war???"(Grosvenor, Don't Forget)
I ask you to consider the following, Mr. Grosvenor, and then explain
your comment above after doing so:
COMITE INTERNATIONAL DE LA CROIX-ROUGE
Geneva, 10 May 1979
[...]
Unfortunately, we are not able to provide you with the figures
you are seeking, since the ICRC has never tried to compile
statistics on the victims of the war and has never certified
the accuracy of the statistics produced by a third party. In
fact, the basic aim of the ICRC is to come to the aid of
victims of armed conflicts and not to act as a commission of
enquiry or a statistics service.
With regard to the figure of 300,000 victims quoted on page 28
of the document you sent us, on 19 January 1955 the newspaper
"Die Tat" published an article (of which a photocopy is
enclosed) giving figures for the victims of the Second World
War, including that of 300,000.
As you will see upon reading this article, first, the figure
of 300,000 was not given by the ICRC and, secondly, it refers
only to the _German_ victims (Jews and non-Jews) of the
concentration camps. The authors of the booklet have therefore
doubly falsified their information, by claiming that the
figure relates to all the Jewish deportation victims and by
naming the ICRC as its source.
[...]
Yours faithfully,
s/
R. Gaillard-Moret
Head of Documentation
and Dissemination
(For the complete letter, see http://ftp.nizkor.org/ftp.cgi?orgs/international/red-cross/300000-victims.response
Question Ten
------------
In a series of January 1997 articles, you included the following text:
"Since Ken McVay also operates out of a synagogue, wondering minds
now really want to know about what is he REALLY doing in the
synagogue???" (Grosvenor, KIDDIE PORN)
The challenge, of course, is simple - As I operate out of my
home, and am happily prepared to establish that fact in a court
of law, please provide some explanation of why you have claimed that I
do not.
Question Eleven
---------------
In early 1999, you claimed that a news article reported that a
Federal Court judge had "...ruled that the JEW Bronfmans must pay the
more than $700 Millions unpaid taxes!!!" (Grosvenor, Mudloon,
3 January 1999)
The actual Canadian Press article, however, said nothing of the
sort.
(http://www.nizkor.org/ftp.cgi/people/g/grosvenor.william/lies/
lie-muldoon.990103)
Why did you make this false claim?
Followups directed to can.general
[Work cited section follows]
Work Cited
Grosvenor, William. UseNet can.general,tor.general,ab.general,
van.general,mtl.general,ott.general,edm.general,
Subject: "Support AFL - ANTI FAGGOT LEAGUE," May 6, 1996,
Message-ID: 318D41...@compusmart.ab.ca, archived in
(one line) http://ftp.nizkor.org/ftp.cgi?people/g/grosvenor.william/1996/grosvenor.0596
------------------. Usenet alt.revisionism. Subject: "Jews for
Faggots in Alberta," May 13, 1996. Message-Id: 4n7r5c$h...@news.sas.ab.ca
archived in (one line) http://ftp.nizkor.org/ftp.cgi?people/g/grosvenor.william/1996/grosvenor.0596
------------------. UseNet edm.general,ab.general,can.general,
tor.general,alt.revisionism,van.general,calgary.general,
Subject: "FAGGOTS SPREAD AIDS-WHY PROTECT THEM?," May 15, 1996,
Message-ID: 3198F7...@compusmart.ab.ca, archived in
(one line) http://ftp.nizkor.org/ftp.cgi?people/g/grosvenor.william/1996/grosvenor.0596
------------------. UseNet ab.general,can.general,alt.revisionism,
tor.general,calgary.general,van.general, Subject: "Why are Jews
Supporting Faggots?," May 15 1996, Message-ID:
319986...@compusmart.ab.ca, archived in
http://ftp.nizkor.org/ftp.cgi?people/g/grosvenor.william/1996/grosvenor.0596
------------------. UseNet alt.revisionism, Subject: "KOSHER TAX
in Canada," May 30, 1996, Message-ID:
Pine.SUN.3.93.960530...@voyager.cris.com,
archived within
http://ftp.nizkor.org/ftp.cgi?people/g/grosvenor.william/1996/grosvenor.0596
------------------. UseNet alt.revisionism,can.general,qc.general,
mtl.general. Subject: "OyVey Concerned About Quebec JEWS,"
Date: Sep 27, 1996, Message-ID:
Pine.A32.3.91.960927...@freenet.edmonton.ab.ca
------------------. UseNet alt.revisionism, Subject: "Re: DON'T FORGET
JEW SET UP CHEKA FOR COMMIES," October 3, 1996, Message-ID:
Pine.A32.3.91.961003073...@freenet.edmonton.ab.ca
archived within
http://ftp.nizkor.org/ftp.cgi?people/g/grosvenor.william/lies/lie-320000-jews
------------------. UseNet ns.general. Subject: "SYNAGOGUE CANTOR
CONVICTED OF KIDDIE PORN IN HALIFAX!!!!," January 7, 1997.
Message-Id: Pine.SUN.3.95.970107...@galileo.cris.com
------------------. UseNet: ont.general,qc.general,mtl.general.
Subject: "SYNAGOGUE LEADER IS KIDDIE PORN CRIMINAL!!!," January 8, 1997.
Message-Id: Pine.SUN.3.95.970108...@galileo.cris.com
------------------. UseNet soc.culture.lebanon,alt.revisionism.
Subject: "SYNAGOGUE LEADER IS KIDDIE PORN CRIMINAL!!!," January 8, 1997
Message-Id: Pine.SUN.3.95.97010...@galileo.cris.com
------------------. UseNet alt.culture.saudi,alt.illuminati. Subject:
"SYNAGOGUE LEADER IS KIDDIE PORN CRIMINAL!!!," January 8, 1997
Message-Id: Pine.SUN.3.95.970108...@galileo.cris.com
------------------. UseNet: soc.culture.arabic,soc.culture.german,
soc.culture.quebec. Subject: "SYNAGOGUE LEADER IS KIDDIE PORN
CRIMINAL!!!," January 8, 1997
Message-Id: Pine.SUN.3.95.970108...@galileo.cris.com
------------------. UseNet: soc.culture.canada,can.general,
soc.culture.russian,soc.culture.polish,alt.revisionism,
alt.white-power,soc.culture.swiss. Subject: "COURT ORDERS JEW
BRONFMANS TO PAY TAXES!!!"
Message-ID: <368fa125...@news.sprint.ca>
Peter Outerbridge
Black Knight
<deletia>
Absolute bullshit. Nobody believes this crap, Fatslob.
Bruno
Ken McVay
Last-Modified: 2001/02/15
IN THE COURT OF COMMON PLEAS OF LEHIGH COUNTY
CIVIL DIVISION -- LAW
YALE F. EDEIKEN :
:
Plaintiff :
:
vs. : No. 99-C- 2786
:
SCOTT BRADBURY a/k/a :
"DOC TAVISH" a/k/a :
"doc_t...@bigfoot.com" a/k/a :
"sonnyboy@ flash.net" :
:
[removed]xxxxxxxxxxxxx :
Bellville TX xxxxxxxxx :
:
Defendant JURY TRIAL DEMANDED
COMPLAINT
1 Plaintiff Yale F. Edeiken (hereinafter "Plaintiff") is a an
adult citizen and resident of Lehigh County, Pennsylvania.
2. Defendant Scott Bradbury (hereinafter "Defendant") is an adult
citizen and resident of the State of Texas residing at [removed]xxxxxxxxx,
Bellville, Austin County, Texas xxxxx with a telephone number of
xxx-xxx-xxxx.
3. At all times material hereto Defendant was supplied access to
the Internet and to electronic mail (hereinafter "e-mail")by Flash.net
Communications, Inc., (hereinafter "flash.net") an internet service
provider located in Forth Worth, Texas, and by other internet service
providers unknown to Plaintiff including several services which allowed
Defendant to publish and communicate by e-mail anonymously.
4. At all times material hereto Defendant published material on
the Internet and by e-mail using aliases which include but are not limited
to of "Doc Tavish," "sonn...@flash.net," "Secret Squirrel," "Mixmaster,"
"Horst Wessel," "-88-," and "Heinrich Himmler."
5. Defendant is a virulent anti-Semite who refers, inter alia, to
Jews as "vermin," advocates a "final solution" to the "Jewish problem" in
the United States and endorses the stereotype of Jews propagated by Julius
Striecher and Adolf Hitler stating, inter alia:
"What I like is the Nazi stereotype which shows the Jew as having
brushy eye brows, close set dark beady eyes and all accented by the
bulbous proboscis (big hook nose). I've seen the cartoons which shows Jews
looking like rats and I really think they are some of the most hilarious
visual images around- after all look at the typical Hollywood comedians--
all Jews! Who can't laugh at those rat like faces with the wiggling bushy
eye brows and those rat like snozzolas flapping in the breeze!"
6. At all times material hereto Defendant uses the services
provided by flash.net, with the knowledge and approval of flash.net, to
propagate his message of hate on the internet.
7. In addition to propagating his anti-Semitic propaganda on the
internet, Defendant has in the past and continues in the present to conduct
campaigns of harassment, defamation, and threats of violence against
individuals, including inter alia, the Plaintiff to this action, who
oppose his bigotry meant to frighten, annoy, and intimidate his opponents.
8. Said campaign of stalking and intimidation has been a
consistent pattern of behavior conducted by the Defendant over an extended
period of time.
9. Said campaign has included in the past threats of violence
against his opponents which has included, inter alia, the following threats
of violence:
a. On December 19, 1996, the Defendant publically made the following
threat to Keith Morrison, a citizen of Canada "I am a good shot Talmudist
if you come and find me I will demonstrate my skill to you. Do you have
any idea what the Desert Eagle .50 would do to your head? I would be legal
too- self defense from a rabid virulent anti-Christ. I promise you that
your kind are not welcome in my part of the country and I am on first name
basis with the local D.A. Hunt me down and you will be put out of your
misery like a rabid dog. One shot one kill. dead eye Doc Tavish."
b. On March 9, 1997, Defendant publically made the following
threat to person unknown "Author: Billy Dale McTavish . . . .Vengeance is
sweet and I know that the day will come when I'll get to see the sneak
that did this to me get a thorough interrogation from Bruno! I will love
standing there watching him peel your skin off layer by layer with his lash
and ever so methodically. Your screams of pain will fall on deaf ears. I
will take extreme delight in watching the foam come spewing out of your
vile mouth as Bruno gives you another! Do not worry for I will not let him
kill you. You must heal up and become well- so the process can start right
back over again to be repeated again and again. You will see no end to your
pain! I solemnly promise the day will come when the tables will turn.
Destiny will place you at my feet and you will pray for death and it will
by no means come. /s/ Tavish."
c On April 15, 1997, Defendant published the following threat to Daniel
Keren, Ph. D.: "I do believe that Bruno would derive great pleasure in
applying his craft to Mr. Keren. Yes Bruno is from the old Bavarian School
of inquisitive acquisition. Bruno knows how to stimulate every nerve but
yet not do any sort of damage. Yes Bruno would spend hours in a cold dark
damp dungeon with him. Bruno is a firm believer in the old adage: "No pain,
no gain." :-) Mr. Keren will probably over react to Bruno BUT Bruno went
back home to Bavaria a while back because certain ones in this ng hurt his
feelings! He is a big dumb brute in the common sort of way but he's such a
likable lug too! I may be able to persuade him to come back but I don't
know. If I can get Bruno back then may be Gunther and Gerhardt may return
too! They all claim that life is too hard for them in America with all of
this hatred by Nizkooks running around. They say it reminds them of when
the Communists ruled and how the Commies kept files on everyone. Reminds me
of what commie East Germany used to be!"
d. On May 2, 1998, Defendant published the following threat to someone
who disagreed with one of his bigoted rants:: "I just wish these dumb asses
would realize that they can't get away with this. I'll send a copy to
tavish-central, a copy to the Houston Branch of the FBI and a copy to the
nut cake's ISP. Now people can understand why I positively abhor the
majority of Kikes I encounter. Bruno at the moment is muttering about how
nice it would be if he would be allowed to interrogate this person. I agree
that Bruno should be able to apply his talents. I could picture Bruno being
slow and very methodical too! :-)"
e Defendant published the following threat to Mark Van Alstine, a
researcher on the Holocaust: " . . . . . Mr. Van Alstine is a saboteur of
Nizkor [http://nizkor.org; a site on the Internet about the history of the
Holocaust] and that is all we need to bring hin in for an especially
vigorous interrogation! He will not be so cocky after Bruno works with him.
Don't worry Bruno has never killed anyone yet and he is a master at his
craft. Bruno could rightfully be called a master of pain for he knows how
to work every nerve and fiber to achieve the results desired with the very
least amount of tissue damage. The man is devoted to his work as a true
artisan!"
f Defendant has published the following threat to Jeffrey G. Brown
"I'll beat you to a bloody pulp."
g. Defendant has publically addressed the following threat to a person
publishing anonymous material: "Why don't you identify yourself then? Bruno
has already picked the lash he will use in my interrogation of you. He at
first opted for his short fat bull whip. This whip does not cut the flesh
but it makes extremely painful throbbing welts that only diminish in pain
over a few days. He has chosen his custom stage coach style whip that is
nearly twenty feet long. Each stroke is just like a hot knife hitting
butter. This whip n each stroke cuts beyond the subcutaneous epidermal
layers. He'll literally peel you like an onion. Each stroke of this lash
will feel just like having a white hot wire streak across your back and
buttocks. Bruno is an artisan at his craft and he most eagerly awaits
hoisting you up in manacles to administer the "truth serum." I will relish
watching you flop around like a fish. Pleasant dreams!"
h. Defendant addressed the following threat to Joel Rosenberg, a citizen
of Minnesota: " Herr Rosenberg so very nice of you to slither out and play
tonight! We all see that you have not for once changed your tone yes? You
will change your tune very soon! They all do; believe me they all do! We
have a nice damp dungeon all prepared for you in Berlin. We will talk at
great length and get to the very root of your attitude yes? I personally
will not let Bruno interrogate you too long no!"
i. Defendant publically addressed the following threat of violence to
another person: "Yeah SOG [sic] just keep your mouth running while you can.
You'll be squealing like stuck pig when we shove the rotisserie skewer
where the sun don't shine on April 20th! You'll cook quite well over an
open fire! You'll probably give us all gas BUT that is why we'll have
plenty of Tagment [sic] on hand. Burp! Bruno says that he knows how to
tenderize you too. I think he wants to use his 20 foot whip! Ouch!:
j. Defendant has publically addressed the following threat to another
person: "I can only say that Bruno knows that this happened and right now
he is outside practicing with his whip. Her looks mighty g-d damned furious
in the hot Texas sun cracking that whip. Damn it sounds like a 30' 06 going
off each time he pops that thing. I'd hate to "Count 25" for him! Yes,
indeedy!! :-) Doc Tavish Singing "Our Day Will Come!"
k. In December, 1999, Defendant publically addressed the following threat
to Sara Salzman, a citizen of Colorado: "Bruno [sic] eagerly awaits the day
when he is able to peel your kind like onions with his lash. I could just
see the sweat and blood spray when Bruno lays on the flay. In your case I
wouldn't want him to damage your hide. I want a new shade for my floor lamp
and a new holster for my Desert Eagle pistol. Bruno would, in your case,
use electricity and the various exploitations of body cavities with large
blunt objects. :-) . . . . .Mazel Tob you witch. /s/ Doc Tavish.
j. On or about December 7, 1999, Defendant published the following threat
to an unknown person: "I will get revenge sooner or later for your inciting
blacks to harass me by e-mail. You're on federal territory now! You WILL be
ferreted out- make no mistake about it! BTW if you were to only think about
it- your very actions only make others believe that I am justified in my
dislike of your kind. You are sneaky rat like vermin meant to be hunted
down and eliminated. :-) Just call me the Verminator! /s/ Doc Tavish/"
10. Said campaign of threats was maliciously designed to frighted,
intimidate, annoy, harass, and silence any person who objected to
Defendant's anti-Semitic agenda by having a chilling effect on any person
expressing or considering expressing opposition to Defendant's bigotry.
11. Said campaign of harassment and intimidation has included,
inter alia, the publication of the private names and addresses of his
victims and their families with suggestions of violence and the offering of
rewards to those who would supply him with the addresses and telephone
numbers of his victims.
12. Said campaign of harassment has included the forging of
communications and publishing such forgeries representing that they
originated with the victims of his campaigns of harassment.
13. Said campaign of harassment has included the publication and
circulation of claims which are false and known by Defendant to be false
concerning the sexual orientation and practices of his opponents.
14. Said campaign of harassment has included harassment by sending
his opponents harassing electronic communications (e-mail) including sexual
innuendo, threats, and bigoted slurs.
15. Defendant is supported and assisted in his campaigns of
harassment as aforesaid by various accomplices who Plaintiff believes and
therefore avers include, inter alia:
16. The aforesaid campaigns arise from Defendant;'s pathological
hatred of Jew and/or any person opposed to his pathological hatred and are
conducted maliciously, wantonly, wilfully, and recklessly by the Defendant
and his accomplices and in outrageous disregard of the rights of his
victims with the specific purpose of intimidating and silencing his
opponents, intentionally causing them mental distress, anguish and grief,
and adversely affecting their reputation in the communities in which they
reside.
17. That such purpose and intent of Defendant is known to
Defendant's accomplices who actively support Defendant's goals and purposes
and assist him in stalking his victims during his campaigns of harassment,
defamation, and intimidation.
18. Such agreement on the part of his accomplices includes the
ethnic prejudice and hatred that motivates Defendant.
19. That said accomplices include, inter alai:
a. David E. Michael, a British neo-Nazi and denier of the Holocaust who is
an adherent of and/or organizer for the neo-Nazi British National Party.
b. Don Ellis, an anti-Semite and debunker of the Holocaust who resides in
Star City, Arkansas.
c. A person publishing material on the internet through remarq.com under
various pseudonyms including but not limited to, "Mike Kalvatis," "Pat
Blakely," "Jesus Christ," "RevWhte," "Rabbi Brimstone" and various forged
headers. Plaintiff believes and therefore avers that said person is the
aforementioned Don Ellis.
20. That the various accomplices of Defendant are aware of his
activities and act in concert with him and with his aid, assistance and
approval.
21. That the existence, purpose, nature, and intent of Defendant's
activities is know to flash.net which continues to allow the Defendant to
use their facilities for such purposes and otherwise supports the
activities of the Defendant.
COUNT I: Harassment by Telephonic Communication
21. Plaintiff hereby incorporates by reference Paragraphs 1
through 20 of this Complaint as though set forth fully at length.
22. At various times Defendant has communicated with Plaintiff by
electronic mail (e-nail) which is sent through interstate telephone lines
and received through a telephone connection maintained by Plaintiff and, as
such, constitutes telephonic communication.
23. That as part of his campaign of harassment and intimidation
Defendant has, in the past, sent Plaintiff electronic communications
consisting of the word "kike" repeated several hundred times.
24. That on December 5, 1998, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"You only want to blow Joe
You want to suck Joe's Aryan cock, don't you Yale?
Doc Tavish"
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-1."
25 That on December 5, 1998, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
Joe me thinks Yale wants to suck your cock and you're right --Yale is a
queer -- he does suck cock
Doc Tavish"
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-2."
26 That on December 5, 1998, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"Are you homosexual, Yale?
Your last lines look like a faggot speaking or are you merely trying to
make trouble like a malicious fag does
Doc Tavish"
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-3."
27. That on December 5, 1998, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"Yale wants to suck your cock Joe and he doesn't know how to ask so he
persists in his silly games to get your attention -- fags are in a lot of
ways just like little girls -- just ignore cock sucker Edeiken and he'll
most likely will try to go after another person."
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-4"
28 That on December 5, 1998, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"and you still want to wrap your lips around his aryan cock"
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-5."
29 That on December 6, 1998, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
Yale Edeiken wants to suck Joe Bellinger's cock
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-6"
30. That on December 6, 1998, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"Yale still wants to suck Joe's aryan cock"
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-7"
31 That on December 6, 1998, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"So why do you still want to suck his cock?
Do you think you'll become a man by ingesting his manhood?
Doc Tavish"
32 That on December 6, 1998, Defendant sent Plaintiff
an electronic communication stating in pertinent part:
"And you're still a flaming fag cock sucker/"
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-9."
33. That on December 6, 1998, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"What are you doing, Yale trolling for young boys again ? We all know you
have homosexual tendencies and you call all people homophobes who
oppose"gay rights" We also know how you have slandered the most righteous
Rev Fred Phelps in the past for his stands against the homosexual
lifestyle.
When are you militant homosexuals going to stop your perversions and seek
to live a meaningful life with purpose? Why do you wish to portray
yourself as a thirteen year old female -- what would your neighbors in
Allentown Pennsylvania think of your current degradation -- have you no
pride at all?"
I guess all you want to do is suck some young boys cock -- typical
homosexual sympathist from Nizkor you are -- why are Nizkorians so
pro-homosexual -- is it because all of you or at least most of you are
homosexual. If any group is comprised of liars it has to be your group
because you all even stoop to trying to deceive nature -- now go play with
your Barbie doll faggot child molester
Doc Tavish:
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-10."
34 That on December 8, 1998, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
All Nizkooks need to be apprehended, interrogated, and placed in protective
custody until a final solution can be made.
Doc Tavish"
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A11."
35 That on July 31, 1998, Defendant sent Plaintiff an electronic
communication stating in pertinent part:
"You want to suck Tavish's, Vange's and Phillips' Nazi cocks. Why does your
side call others homophobes? You must either be homo or at least
sympathetic to their utterly disgusting ways! I'd bet that you suck cock
and butt fuck too! Careto deny it?
Bickhus Dickhus
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-12."
36. That on November 11, 1999, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"You want to lick Tavish's prick like a little kid licks a lollipop."
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-13."
37 That on November 11, 1999, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"You only act up because Tavish won't let you use your tongue on him."
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-14."
38 That on November 11, 1999, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"Yale and Jeffrey want to gang rape Tavish because Tavish won't give in to
their homosexual lusts."
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-15."
39 That on November 11, 1999, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"You are just as much of a filthy little cock sucker vermin as your butt
buddy Jeff Brown. You have to rely on out of context quotes and character
assassination. It would be a pleasure to see someone slowly work you over
with an ice pick Yale!"
--digsig
Authentic Doc Tavish
191xllxyGtVQwy0mtCiBjivyX+knCUXYwdRt ptdrtqb
qfQbXQtisWlB/E1+yWkYkw1Wr7mGiAFcJ w6Wl/aU
4GEbQtlQOHN/G3asOLBC9JmQXWuqXwj BnPCuOV9cd
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-16."
40. Said telephonic communications were intended and designed to
alarm, harass, intimidate, annoy, distress, and inflict emotional distress
upon Plaintiff and that such damages actually occurred.
41. As a result of which Plaintiff suffered great distress and
mental anguish and was deprived of the enjoyment of life's pleasures.
42, Said telephonic communications were received by the Plaintiff
within the City of Allentown, County of Lehigh, Commonwealth of
Pennsylvania whereby jurisdiction is vested in this Honorable Court.
43. Said telephonic communications were made in violation of the
criminal laws of the United States and the criminal laws of the
Commonwealth of Pennsylvania.
44, Said telephonic communications were made in violation of the
laws of the Commonwealth of Pennsylvania related to ethnic intimidation.
45. Said telephonic communications were made willfully, wantonly,
and in outrageous disregard of the rights of Plaintiff with the malicious
intent of harassing, alarming, annoying, and/or intimidating Plaintiff and
to have a chilling effect upon his exercise of his right of free speech.
WHEREFORE Plaintiff demands compensatory damages in an amount in
excess of the statutory limit for arbitration in the Court of Common Pleas
of Lehigh County, Commonwealth of Pennsylvania together with punitive
damages in excess of the statutory limits for arbitration in the Court of
Common Pleas of Lehigh County, Commonwealth of Pennsylvania together with
interest costs and a reasonable attorney's fee.
COUNT II: Harassment by Terorrostic Threat
46. Plaintiff hereby incorporates by reference Paragraphs 1
through 45 of this Complaint as though set forth fully at length.
47. Defendant has, at various times, publically made threat of
violence against Plaintiff consistent with the pattern of his threats
against others.
48 That on November 11, 1999, Defendant sent Plaintiff an
electronic communication stating in pertinent part:
"You are just as much of a filthy little cock sucker vermin as your butt
buddy Jeff Brown. You have to rely on out of context quotes and character
assassination. It would be a pleasure to see someone slowly work you over
with an ice pick Yale!"
--digsig
Authentic Doc Tavish
191xllxyGtVQwy0mtCiBjivyX+knCUXYwdRt ptdrtqb
qfQbXQtisWlB/E1+yWkYkw1Wr7mGiAFcJ w6Wl/aU
4GEbQtlQOHN/G3asOLBC9JmQXWuqXwj BnPCuOV9cd
Said telephonic communication is attached hereto and made part
hereof as Exhibit "A-16."
49. Said telephonic communication was received by the Plaintiff
within the City of Allentown, County of Lehigh, Commonwealth of
Pennsylvania whereby jurisdiction is vested in this Honorable Court.
50. On November 14, 1999, Defendant made the following public
statement to Plaintiff:
"I'd say that the above is explicit evidence of libel and slander. I surely
wish Mr. Richard Phillips et al immediately files suit, has subpoenas
herewith issued. I will be glad to attend the trial and I hope that a good
public flogging is part of the reparations Yale has to receive in lieu of
monetary damages he will have to render. . . . BTW Richard- Bruno has
volunteered to administer the flogging if is permissible [sic] by the
court. He has been practicing a lot lately. Perhaps he senses something
in the air. I hate saying it but he is somewhat bestial or animalistic in
his instincts but he is loyal to me to the end."
51. On December 18, 1999, Defendant published the following threat
to Plaintiff:
Subject: Re: WHERE OR WHERE IS TAVISH - I'm standing behind you with my
Desert Eagle .50AE locked and loaded.. . . . . . . I'm standing behind you
with my Desert Eagle .50AE locked and loaded slowly squeezing the trigger
for an excellent one shot- one kill! :-) Sleep on that a whil "nazihunter."
Doc Tavish Knowing Time is on His Side"
52. On December 18, 1999 Defendant published the following
threat to Plaintiff:
"Remember Yale- the jury award I seek is not monetary but to have full
access to you for thirty [sic] minutes in front of the court house to
literally beat you black and blue without any civil or criminal
repercussions. I really believe that this would be the only fair and
equitable verdict! : It will be just you and me Yale and I promise you that
you will think a long damned time because you will hurt for a long time
before you will engineer anymore of your malicious devilish mischief. Doc
Tavish Merrily Waiting on Judgment Day."
53. On December 19, 1999, Defendant published the following
threat to Plaintiff:
"Subject: Re: WHERE OR WHERE IS TAVISH (Standing Behind Yale With a Big Fat
Truncheon) . . . . Give me a break and just let a court grant me thirty
minutes immunity from any criminal or civil action- I would just love to
beat Yale to a jolly bloody pulp in front of his family. To me this is the
only form of fair justice. I promise that I will not take his life nor do
any permanent physical harm but I guarantee Yale will be sore for a very
long time. That is a solemn promise I would like to make and keep!"
54. Defendant has repeatedly published this and similar threats
to Plaintiff on various occasions since the original publication of these
threats.
55. Said threats were intended and designed to alarm, harass,
intimidate, annoy, distress, and inflict emotional distress upon Plaintiff
and that such damages actually occurred.
56. As a result of which Plaintiff suffered great distress and
mental anguish and was deprived of he enjoyment of life's pleasures.
57. Said threats were made over the internet in violation of the
criminal laws of the United States and the criminal laws of the
Commonwealth of Pennsylvania.
58, Said threats were made in violation of the laws of the
Commonwealth of Pennsylvania related to ethnic intimidation.
59. Said threats were made willfully, wantonly, and in outrageous
disregard of the rights of Plaintiff with the malicious intent of
harassing, alarming, annoying, and/or intimidating Plaintiff and to have a
chilling effect upon his exercise of his right of free speech.
WHEREFORE Plaintiff demands compensatory damages in an amount in
excess of the statutory limit for arbitration in the Court of Common Pleas
of Lehigh County, Commonwealth of Pennsylvania together with punitive
damages in excess of the statutory limits for arbitration in the Court of
Common Pleas of Lehigh County, Commonwealth of Pennsylvania together with
interest costs and a reasonable attorney's fee.
COUNT III: Harassment by Incitement of Others
60. Plaintiff hereby incorporates by reference Paragraphs 1
through 59 of this Complaint as though set forth fully at length.
61. As part of his consistent pattern of harassment Defendant has,
individually and in collaboration with others published the names,
addresses, and telephone numbers of his opponents with requests that others
harass those who object to the anti-Semitic propaganda he distributes.
62. Said information has included the names, addresses, and
telephone numbers of his detractors families, parents, children, employers,
associates, and neighbors with instructions that they be contacted with
false and/or outrageous material about his detractors private lives.
63. Said campaigns of stalking and harassment have included the
offering of rewards and other encouragements to various of Defendant's
accomplices to provide him with such information to assist Defendant in his
stalking, harassment, and intimidation of his victims.
64. Together with the accomplices named above and various others
unknown to Plaintiff, Defendant has compiled and published and/or assisted
in the compilation and publication of the "Nizkor Telephone Book" which
publishes such information in a malicious effort to harass, annoy, and
intimidate his detractors and to have a chilling effect upon their exercise
of their right of free speech
65. Such acts were done maliciously with the intent of harassing,
annoying and intimidating his detractors, adversely affecting their private
lives and employment, and chilling their exercise of their right of free
speech.
66. In or about April, 1998, Defendant commenced such a public
campaign of stalking, harassment, and intimidation against Plaintiff.
67. Prior to commencing this campaign of harassment Defendant
published the following statement on April 28, 1998, directed at Plaintiff
under his nom de plume of "Doc Tavish":
Hey, Yale, you were right about you being easy to find . What do the folks
in Allentown think knowing the have a socialist living on the block? :-) Be
sure to give my regards to "Alta" if you get my drift! /s/ Tavish
Said publication is attached hereto and made part hereof as Exhibit "B-1."
68. Said message was intended and published in order to alarm and
harass Plaintiff and by making him believe that Defendant knew where
Plaintiff lived, intimidate Plaintiff from publishing material critical of
Defendant.
69. At approximately the same time Defendant, referring to himself
as "Gumshoe Tavish" made similar claims about the location of one Jeffrey
G. Brown and threatened to reveal to the alleged neighbors of Jeffrey G.
Brown that he was a pederast.
70. Shortly thereafter Defendant began to publish Plaintiff's
name, address, and telephone number using a variety of services which
disguised his location together with requests that others harass the
Plaintiff.
71. The first such message was published on June 1, 1998, with the
phrase "Reach out and touch someone." Attached. Said post is attached
hereto and made part hereof as Exhibit "B-2."
72. That the intention of such message was to alarm Plaintiff and
intimidate him from criticizing Defendant and inciting others to criminally
harass Plaintiff.
73, That similar messages were published by Defendant on a regular
and continual basis with the final form of the message being to following
example published on December 7, 1999:
Yale F. Edeiken, ZHID, of 1590 Alta Dr., Allentown, Pa, wants lots of
late night callers, and will even welcome visitors, late nights, to
discuss the Holohoax. He can be reached at 610 435-9820 He even likes
discussing, and even meeting with faggots, and other pedophiles to discuss
matters. His specialties are butt-fucking, cocksucking, and fondling
tinky winkies.
Yale likes to go to peep shows and likes group grope at the local gay bar
in Allentown. -88- Horst Wessel
Said publication is attached hereto and made part hereof as Exhibit
"B-3."
74. Said message was published by Defendant over one hundred (100)
times.
75. That the intention of such message was to alarm Plaintiff and
intimidate him from criticizing Defendant and inciting others to criminally
harass Plaintiff.
76. In addition to publishing the Plaintiff's name, address, and telephone
number, Defendant acting individually and by and/or in concert with his
aforementioned accomplices published the names addresses and telephone
numbers of Plaintiff's ,family including his wife, father, brother, sister,
stepmother and business associates with similar invitations to harass,
annoy and frighten them.
77. Said information was provided both separately and as part of
the aforementioned "Nizkot Telephone Book" where other opponents of
Defendant and his accomplices were similarly harassed.
78. All such publications were made either by the Defendant and/or
with his knowledge, consent, approval, and cooperation.
79. Said publications and incitements were intended and designed
to alarm, harass, intimidate, annoy, distress, and inflict emotional
distress upon Plaintiff and others and that such damages actually occurred.
80. As a result of which Plaintiff suffered great distress and
mental anguish and was deprived of he enjoyment of life's pleasures.
91. Said publications and incitements were made over the internet
in violation of the criminal laws of the United States and the criminal
laws of the Commonwealth of Pennsylvania.
82, Said threats were made in violation of the laws of the
Commonwealth of Pennsylvania related to ethnic intimidation.
83. Said threats were made willfully, wantonly, and in outrageous
disregard of the rights of Plaintiff with the malicious intent of
harassing, alarming, annoying, and/or intimidating Plaintiff and to have a
chilling effect upon his exercise of his right of free speech.
WHEREFORE Plaintiff demands compensatory damages in an amount in
excess of the statutory limit for arbitration in the Court of Common Pleas
of Lehigh County, Commonwealth of Pennsylvania together with punitive
damages in excess of the statutory limits for arbitration in the Court of
Common Pleas of Lehigh County, Commonwealth of Pennsylvania together with
interest costs and a reasonable attorney's fee.
COUNT IV: Defamation
84. Plaintiff hereby incorporates by reference Paragraphs 1
through 83 of this Complaint as though set forth fully at length.
85. As part of his publications concerning Plaintiff and other,
Defendant consistently fabricated false allegations against Plaintiff and
others and knowingly published said fabrications as fact with the malicious
intent of damaging the reputations of Plaintiff and others.
87. Said fabrications were known by the Defendant and his
accomplices to be false and defamatory.
88. Many of the said defamatory publications were made directly to
third parties within the Commonwealth of Pennsylvania with the intention of
damaging the reputation of Plaintiff within the community in which he
resides thereby vesting jurisdiction with this Honorable Court.
89. On or about October 26, 1999, Defendant began a campaign of
defamation against Plaintiff by publishing a claim that Plaintiff had sent
hin and electronic communication stating: ""Scottie if only I have you just
one night I's give you something no woman will ever be able to give you.
Give up women and join our ranks." Said publication is attached hereto and
made part hereof as Exhibit "C-1."
90. Said publication was false and defamatory in that it
represented that Plaintiff had made unwanted sexual advances to Defendant.
91. No such communication was made but, rather, it was
maliciously fabricated by Defendant with the intent of defaming Plaintiff.
92. When Plaintiff complained to Defendant about his forgery,
Defendant again published said forgery and threatened to send said
publication to Plaintiff's internet service provider who would then
"wonder" about the Plaintiff. Said publication is attached hereto and made
part hereof as Exhibit "C-2."
93. Said publication is a direct admission of the malicious intent
on the part of Defendant to defame Plaintiff.
94. On or about November 2, 1999, Defendant published the claim
that "You have threatened to do a "homosexual gang rape" to be ASSisted by
your pals Jeffrey G. Brown and Ken McVay - what else can you say other than
you're gay? /s/ Doc Tavish." Said publication is attached hereto and made
part hereof as Exhibit "C-3."
95. Said publication was false and defamatory in that it
represented that Plaintiff had threatened Defendant with sexual
molestation.
96. No such communication was made but, rather, it was
maliciously fabricated by Defendant with the intent of defaming Plaintiff.
97 On or about October 27, 1999, Defendant published an article
entitled "Attention Faggots Yale F. Edeiken and Jeffrey G. Brown" in which
he again repeated\ his allegation that Plaintiff had made unwanted sexual
advances to him. Said publication is attached hereto and made part hereof
as Exhibit "C-4."
98. Said publication was false and defamatory in that it
represented that Plaintiff had made unwanted sexual advances to Defendant.
99. On or about October 27, 1999, Defendant again maliciously
published a communication which he falsely and maliciously claimed had been
written by the Plaintiff and, again, falsely and maliciously claimed that
the Plaintiff had made unwanted sexual advances to hi,. Said publication
is attached hereto and made part hereof as Exhibit "C-5."
100. Said defamatory publication was forwarded directly to
Enter.net, business located within the County of Lehigh. Commonwealth of
Pennsylvania, thereby vesting jurisdiction in this Honorable Court.
101. On or about October 28, 1999, Defendant again refused to
retract his false and defamatory statements insisting that the fabrications
he had published were accurate. Said publication is attached hereto and
made part hereof as Exhibit "C-6."
102. Defendant again forwarded said malacious and defamatory
communication to Enter.net, a third person located within Lehigh County,
Commonwealth of Pennsylvania.
103. On or about October 28, 1999, Defendant again refused to
retract his false and defamatory statements insisting that the fabrications
he had published were accurate, stating in pertinent part:
". . . . what we have here is a textbook case of how homosexuals really
hate being rejected. Yale will not take "NO" as answer [sic] O don't
care that he can use his tongue in his misguided attempt to show "50 Ways
to Leave My (Female) Lover."
Said publication is attached hereto and made part hereof as Exhibit "C-7."
104. On or about November 3, 1999, published a false and
defamatory statement claiming that Plaintiff was sexual pervert engaging in
sex with animals. Said publication is attached hereto and made part
hereof as Exhibit "C-8."
105. On or about November 3, 1999, Defendant made a further false
and defamatory publication again stating that Plaintiff had sex with
animals and further stating that Plaintiff was a "neo-Bolshevist" who
wanted to turn the United States into a Soviet-style dictatorship. Said
publication is attached hereto and made part hereof as Exhibit "C-9."
106. On or about November 7, 1999, Defendant again fabricated
material which he claimed had been written by Plaintiff and maliciously
published it on the int4rnet and sent a copy of his false and defamatory
statement to Enter.net, a business located within the County of Lehigh,
Commonwealth of Pennsylvania. Said publication is attached hereto and made
part hereof as Exhibit "C- 10."
107. On or about November 11, 1999, Defendant published the
following false and defamatory statement about Plaintiff on the internet
stating in pertinent part:
" . . . . .faggots Brown and Edeiken will positively not leave me alone.
What is it about homosexuals that the more they are rejected and dejected
the more they have to keep coming after a person? It must be some
"feminine" quirk resembling "hell hath no fury like a rejected or scorned
woman." . . . .Again Yale F.. Edeiken won't leave me alone and now his
fellow anti-Christ and Sodomite is moving in for the kill. See what being
the quintessential Aryan gets you."
Said publication is attached hereto and made part hereof as Exhibit "C-11."
108. In addition to the defamatory material recited above
Defendant has continually referred to Plaintiff in his various publications
as a "shyster," a "criminal" and a "Bolshevist."
109. In each of the hundreds of times Defendant has maliciously
published such false and defamatory material both published on the internet
and communicated to third persons within the County of Lehigh, Commonwealth
of Pennsylvania material Defendant has intended to adversely effect the
reputation of the Plaintiff.
110. Plaintiff has continually contacted Defendant, informed him
of the defamatory nature of the material that he publishes and sends to
third parties.
111. Plaintiff has additionally contacted Flash.net Communications
and informed them of the various defamatory statements made by Defendant
and the various forgeries he has distributed through their facilities.
112. In response to the demands for retraction Defendant has
replied "Fuck off, Kike." and "Eat shit, Kike."
113. Defendant has, further, acted in concert with Flash.net
Communications to block any demands for a retraction by threatening the
internet services of others.
114. Defendant has, further, acted in concert with his accomplices
named above to further spread the defamatory statements published by
Defendant.
115. Said publications and their distribution were intended and
designed to injure the reputation of Plaintiff and alarm, harass,
intimidate, annoy, distress, and inflict emotional distress upon Plaintiff
and others and that such damages actually occurred.
116. As a result of which Plaintiff suffered great distress and
mental anguish and was deprived of the enjoyment of life's pleasures.
116. Said defamation was done maliciously willfully, wantonly, and
in outrageous disregard of the rights of Plaintiff with the malicious
intent of harassing, alarming, annoying, and/or intimidating Plaintiff and
to have a chilling effect upon his exercise of his right of free speech.
WHEREFORE Plaintiff demands compensatory damages in an amount in
excess of the statutory limit for arbitration in the Court of Common Pleas
of Lehigh County, Commonwealth of Pennsylvania together with punitive
damages in excess of the statutory limits for arbitration in the Court of
Common Pleas of Lehigh County, Commonwealth of Pennsylvania together with
interest costs and a reasonable attorney's fee.
COUNT V: Invasion of Privacy
117. Plaintiff hereby incorporates by reference Paragraphs 1
through 116. of this Complaint as though set forth fully at length.
118. The falsehoods and forgeries as stated above constitute an
invasion of privacy under the false light doctrine.
119. Said invasions of privacy and their distribution were
intended and designed to injure the reputation of Plaintiff and alarm,
harass, intimidate, annoy, distress, and inflict emotional distress upon
Plaintiff and others and that such damages actually occurred.
120. As a result of which Plaintiff suffered great distress and
mental anguish and was deprived of the enjoyment of life's pleasures.
121. Said invasions of privacy were done maliciously willfully,
wantonly, and in outrageous disregard of the rights of Plaintiff with the
malicious intent of harassing, alarming, annoying, and/or intimidating
Plaintiff and to have a chilling effect upon his exercise of his right of
free speech.
WHEREFORE Plaintiff demands compensatory damages in an amount in
excess of the statutory limit for arbitration in the Court of Common Pleas
of Lehigh County, Commonwealth of Pennsylvania together with punitive
damages in excess of the statutory limits for arbitration in the Court of
Common Pleas of Lehigh County, Commonwealth of Pennsylvania together with
interest costs and a reasonable attorney's fee.
Respectfully submitted,
________________________
Yale F. Edeiken
c/o Trainor Law Offices
1720 Fairmont Street
Allentown PA 18104
610-435-9820
PeterOuterbridge
PeterOuterbridge
Criswell The Psychic Weatherman
--
"A belief is not merely an idea the mind possesses;
it is an idea that possesses the mind." Robert Bolton
Criswell The Psychic Weatherman
sse...@mindless.com
Peter Outerbridge
Ken McVay
Last-Modified: 2001/02/14
REQUESTS FOR ADMISSION
NOW COMES Plaintiff Yale F. Edeiken and demands that, pursuant to Rule
4014, Pennsylvania Rules of Civil Procedure, Defendant Scott Bradbury
admit or deny the truth of the following within thirty (30) days of service
or, by failing to do so, admit the truth of the matters asserted:
1. Defendant Scott Bradbury publishes material on the Internet under
the pseudonym "Doc Tavish."
2. Defendant Scott Bradbury has in the past and continues in the
present to use various services to publish his material in a manner in
which it cannot be traced back to its source.
3. Defendant Scott Bradbury has published material on the Internet
under the pseudonym "Nazihunter."
4. Defendant Scott Bradbury has created and published on the
Internet under the name of "Nazihunter" a website which gives his own
address and telephone number.
5. Defendant Scott Bradbury has thereafter falsely claimed that said
website was created by others in an attempt to harass him.
6. Defendant Scott Bradbury has, at various times, published his own
address and telephone number under the name of "Nazihunter" together with
various threats of violence.
7. Defendant Scott Bradbury has thereafter made the false claim,
based upon such publications, that he is being harassed and threatened by
others.
8. Defendant Scott Bradbury has at various times contacted various
internet service providers and, using the false pretense that he was the
author, cancelled the published work of others.
9. Defendant Scott Bradbury has participated in campaigns of
threats, defamation, forgery, and harassment in order to intimidate and
harass his opponent and prevent them from exercising their rights of free
speech.
10. Defendant Scott Bradbury has assisted and/or obtained the
assistance of others in said campaigns, including but not limited to David
E. Michael, Donald Ellis, and "Pat Blakely."
11. That Donald Ellis has published material under the pseudonyms
"Mike Kalvatis," "Pat Blakely," "RevWhite" and "Rabbi Brimstone."
12. That at all times relevant hereto Defendant Scott Bradbury was
aware of the use of those pseudonyms by Donald Ellis.
13. The targets of said campaigns of harassment have included, inter
alia, Plaintiff, Sara Salzman, Jeffrey G. Brown, Ken McVey, Scott Murphy,
David Gehrig, Andrew Skolnick, Steven Wolk, Mike Curtis, Andrew Mathis, and
all others named in "The Nizkor Phonebook."
14. Defendant Scott Bradbury has forged material which he claimed
originated from Jeffrey G. Brown and published said material on the
Internet falsely claiming that it originated from Jeffrey G. Brown.
15. Defendant Scott Bradbury has forged material which he claimed
originated from Andrew Skolnick and published said material on the Internet
falsely claiming that it originated from Andrew Skolnick.
16. Defendant Scott Bradbury has forged material which he claimed
originated from Plaintiff and published said material on the Internet
falsely claiming that it originated from Plaintiff.
17. Said forgeries have included forgeries making unwanted sexual
advances to Defendant Scott Bradbury.
18. That no such unwanted sexual advances were ever made.
19. That notwithstanding the fact that said communications were
forgeries and known to be such by Defendant Scott Bradbury, Defendant Scott
Bradbury forwarded them to third persons claiming that they were true and
accurate.
20. That the purpose of Defendant Scott Bradbury in distributing said
forgeries was to injure the reputation of Plaintiff and to induce others to
terminate a business contract with Plaintiff.
21. Defendant Scott Bradbury has published the statement that he has
been threatened with homosexual rape by Plaintiff, Jeffrey G. Brown and
Kenneth McVay.
22. Said claim was published despite the fact that no such threat had
ever been made to Defendant Scott Bradbury.
23. Defendant Scott Bradbury has published the claim that Andrew
Mathis, Ph. D., had solicited minor boys by offering them alcoholic
beverages.
24. Said claim was made despite the fact that Defendant Scott
Bradbury knew that no such offer or solicitation had ever been made.
25. Since the filing of this lawsuit Defendant Scott Bradbury
increased his efforts to harass and threaten Plaintiff and to distribute
false and defamatory information about him in an effort to intimidate
Plaintiff.
26. Defendant has been assisted in this effort by David E. Michael
and Donald Ellis publishing material either under their own names,
pseudonyms, or anonymously.
27. Defendant Scott Bradbury, either personally and/or acting through
others who were, then and there, acting with his knowledge assistance and
consent have attempted to disrupt Plaintiff's internet service by
"mailbombing" him by sending gigantic files to him as electronic
communications.
28. Defendant Scott Bradbury, either personally and/or acting through
others who were, then and there, acting with his knowledge assistance and
consent have attempted to disrupt Plaintiff's internet service by asking
various commercial services to send him electronic communications thereby
overwhelming his service provider with "spam."
29. Defendant Scott Bradbury, either personally and/or acting through
others who were, then and there, acting with his knowledge assistance and
consent have attempted to disrupt the internet service of others by send
them "mailbombs" in Plaintiff's name and using Plaintiff's name to spam
such persons.
30. On or about July 2, 2000, Defendant Scott Bradbury either
personally or acting through his associates acting then and there with the
knowledge, consent, approval and assistance of Defendant Scott Bradbury
published personal information about Plaintiff's family including his
father, mother, sister and brother including their names addresses,
telephone numbers with instructions to call and harass them. Said
publication is attached hereto and made part hereof as "Exhibit "A."
31. The purpose of said publication was to threaten, harass, and/or
intimidate Plaintiff and to encourage others to commit acts of violence
against him and his family.
32. Said purpose was at all times known to Defendant Scott Bradbury.
33. On or about July 7, 2000, Defendant Scott Bradbury either
personally or acting through his associates a ting then and there with the
knowledge, consent, approval and assistance of Defendant Scott Bradbury
published four threats of violence against Defendant Scott Bradbury. One
such publication is attached hereto and made part hereof as Exhibit "B."
34. The purpose of such forgeries was to harass Plaintiff with false
charges.
35. Notwithstanding that he was aware said publications were
forgeries, Defendant Scott Bradbury forwarded copies of said publications
to Plaintiff's internet provider claiming that Plaintiff had published said
material.
36. That Donald Ellis a/k/a "Pat Blakely" a/k/a "RevWhite" forwarded
said publications to the law firm of Todd S. Miller & Associates
notwithstanding the fact that said publications were known to him to be
forgeries.
37. The purpose of said action was to adversely affect the
professional standing of Plaintiff.
38. That such distribution was done with the approval, consent, and
knowledge of Defendant Scott Bradbury who was at all times aware of the
forgery.
39. Said publication was made with the consent, approval, and
knowledge of Defendant Scott Bradbury who had, at that time, a full
understanding of the purpose and intent of that publication.
40. That Donald Ellis a/k/a "Pat Blakely" a/k/a "RevWhite" forwarded
said publications to Plaintiff's internet service provider and to various
law enforcement agencies notwithstanding the fact that said publications
were known to him to be forgeries.
41. The purpose of said action was to adversely affect the
professional standing of Plaintiff and to have fraudulent criminal charges
brought against him.
42. That such distribution was done with the approval, consent, and
knowledge of Defendant Scott Bradbury who was at all times aware of the
forgery.
43. On or about July 10, 2000, a forgery was published under the name
of Plaintiff making a death threat against the Woman's Center of Allentown.
Said publication is attached hereto and made part hereof as Exhibit " C."
44. Said publication was made by Donald Ellis a/k/a "Pat Blakely"
a/k/a "RevWhite" a/k/a "Rabbi Brimstone" with the purpose of harassing,
threatening, and intimidating the persons named on said list.
45. Said publication was made with the assistance, consent, approval,
and knowledge of Defendant Scott Bradbury who had, at that time, a full
understanding of the purpose and intent of that publication.
46. On or about July 14, 2000, a forgery was published under the name
of "Wendy Edeiken" making a death threat against Plaintiff. Said
publication is attached hereto and made part hereof as Exhibit " D."
47. Said publication was made by Donald Ellis a/k/a "Pat Blakely"
a/k/a 'RevWhite" a/k/a 'Rabbi Brimstone" with the purpose of harassing,
threatening, and intimidating the persons named on said list.
48. Said publication was made with the assistance, consent, approval,
and knowledge of Defendant Scott Bradbury who had, at that time, a full
understanding of the purpose and intent of that publication.
49. On or about July 22, 2000, Defendant Scott Bradbury published a
direct threat of violence against Plaintiff. Saud threat is attached
hereto and made part hereof as Exhibit 'E."
50. Defendant Scott Bradbury has contributed to, participated in
and/or cooperated with the establishment on the Internet of a site known as
"The Nizkor Phonebook."
51. The purpose of "The Nizkor Phonebook" is to threaten, harass,
and/or intimidate Jews and others who disagree with Defendant Scott
Bradbury and his accomplices.
52. The purpose of 'The Nizkor Phonebook" was at all times known to
Defendant Scott Bradbury.
53. On or about July 24, 2000, "The Nizkor Phonebook" was edited to
display a picture of an automatic pistol above personal information about
Plaintiff and his wife including their names addresses, telephone numbers,
and a map whereby they could be located.
54. The purpose of said publication was to threaten, harass, and/or
intimidate Plaintiff and to encourage others to commit acts of violence
against him.
55. Said purpose was at all times known to Defendant Scott Bradbury.
56. On or about July 25, 2000, "The Nizkor Phonebook" was edited to
display personal information about Plaintiff and his wife including their
names addresses, telephone numbers, and a map whereby they could be located
surrounded by images of dripping blood.
57. The purpose of said publication was to threaten, harass, and/or
intimidate Plaintiff and to encourage others to commit acts of violence
against him.
58. Said purpose was at all times known to Defendant Scott Bradbury.
59. On or about July 29, 2000, "The Nizkor Phonebook" was edited to
display personal information about Plaintiff's father, mother, sister, and
brother including their names addresses, telephone numbers, and a map
whereby they could be located surrounded by images of dripping blood.
60. The purpose of said publication was to threaten, harass, and/or
intimidate Plaintiff and to encourage others to commit acts of violence
against them.
61. Said purpose was at all times known to Defendant Scott Bradbury.
62. On or about July 14, 2000, a publication called "The Dead Pool"
was made by Donald Ellis under the pseudonym "Rabbi Brimstone" which named
various opponents of Defendant Scott Bradbury and his associates asking for
wagers as to which would die first. Said publication is attached hereto
and made
part hereof as Exhibit "F."
63. Said publication was made by Donald Ellis a/k/a "Pat Blakely,"
a/k/a "RevWhite" a/k/a "Rabbi Brimstone" with the purpose of harassing,
threatening, and intimidating the persons named on said list.
64. The title of said publication was intended as a reference to a
list of death threats in a motion picture of the same title, and in said
motion picture members of the "Dead Pool" list were murdered.
65. In subsequent publications on the topic, Donald Ellis a/k/a "Pat
Blakely" demonstrated that he was familiar with this significance of the
title, and therefore the "Dead Pool" post can reasonably be construed as a
series of death threats against the individuals listed therein.
66. Defendant Scott Bradbury was aware of the threatening nature of
the publication at the time that it was made.
67. Defendant Scott Bradbury advocates that Jews be deprived of the
civil, political, and human rights in the United States.
68. Defendant Scott Bradbury endorses the stereotype of Jews as
depicted in the propaganda of Adolf Hitler and the Nazis as true and
accurate.
69. Defendant Scott Bradbury has claimed that the Holocaust
did not occur.
70. Defendant Scott Bradbury has endorsed the positions of William
Pierce and the National Alliance, a neo-Nazi and violently anti-Semitic
organization which teaches that Jews are "mud people" who should be
murdered in a nationwide pogrom.