Case turns to a SLAPP suit against Ilena Rosenthal Summary: After the Judge granted the motion to move this case to Santa Barbara, my attorney advised me to seek counsel there. I was in the process of doing that, when, without my consent or permission, he dismissed the case without prejudice, meaning I can re-file at a later date. O'Leary's response to this can be seen at: http://x59.deja.com> He claims that this my suit was a SLAPP suit and that I owe him $8300 to pay his attorneys fees. This is my Declaration to the Court in response. It goes with my "Points & Authorities" also posted. There will be a telephonic ruling on Wednesday, August 16th at 2pm pst. ILENA ROSENTHAL, Plaintiff in Pro Per 1380 Garnet #444 San Diego, California 92109 (858) 270-0680 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO ILENA ROSENTHAL in Pro Per Plaintiff,                 v.             AMERICA-ON-LINE; McGHAN CORPORATION, INAMED CORPORATION; PATRICK J. O'LEARY, SUSAN SCHAEZLER, ETC. INFORMATION SERVICES; and DOES 1 to 20, inclusive Defendants.      CASE NO.  GIC739307   DECLARATION OF ILENA ROSENTHAL IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION TO STRIKE AND REQUEST FOR ATTORNEY'S FEES TELEPHONIC NO APPEARANCE REQUIRED Date: August 11, 2000 Time: 2:00 p.m. Dept.: 60 Judge: Honorable William C. Pate Complaint Filed:  Nov. 24, 1999 I, ILENA ROSENTHAL, declare as follows: 1. I am the Plaintiff in the above-captioned action and am currently representing myself in this action. I have personal knowledge of the facts set forth below. If called upon to testify, I could and would competently testify to the facts set forth herein. 2. When my former attorney, Steven B. Morris ("MORRIS") dismissed this case without prejudice after the venue was changed to Santa Barbara, he did so without my permission and against my wishes. I am not in a financial situation to afford to pay an attorney, and have relied upon legal advice from several sources for the purpose of opposing this motion for attorney¹s fees and costs. For the convenience of the court, I have attached as EXHIBIT A a true and correct copy of my Ex Parte Application and Declaration regarding this dismissal. This declaration is already on file with this court. This declaration explains the true circumstances concerning the earlier filed dismissal of my complaint and that it was done without my permission. 3. Attached to this Declaration as EXHIBIT B are true and correct copies of documents illustrating O¹LEARY¹s position with Inamed/McGhan and the International Society of Prosthesis Manufacturers. These are taken the Silicone Gel Breast Implant, Independent Review Group booklet, and the roster of the Institute of Medicine public meeting on July 24, 2000. 4. Attached to this Declaration as EXHIBITS C-Y are true and correct copies of newsgroup postings and emails printed from the Internet. BACKGROUND INFORMATION 5. The public debate over the safety of breast implants is indeed a heated and controversial matter. Co-defendants Inamed/McGhan, are actively and heartily advertising and promoting the breast implant business. Billions of dollars have been at stake in the ongoing litigation. 6. On October 14, 1992, U.S. District Judge Sam C. Pointer, Jr., in the Silicone Gel Breast Implants Products Liability Litigation, issued Order #8, relating to all cases, that defendants in these matters must not "disparage or minimize the claims." This order was in effect during Defendant, Patrick J. O'Leary¹s ("O'LEARY") employment at McGhan. 7. O¹LEARY as an in-house immunologist for Inamed /McGhan and member of the International Association of Prosthesis Manufacturers, was a visible spokesman for the silicone industry. (EXHIBIT B) From 1995 until October 14, 1999, he concealed his identity on the Internet, denied his ties to the silicone industry, and posted hundreds of messages known only as (EXHIBIT D) His identity was only unveiled on that date, when he  sent an email of a dirty joke with his real name visible. (EXHIBIT E). On 10/22/99, he then publicly admitted that he was "the" mplnt on the newsgroup. In an email entitled "The Devil," O¹LEARY wrote, " Š Now that you know who I am Š" On the junkscience.com Trash Talk Bulletin Board, he has also made that admission. 8. The most contentious and difficult debate in the ongoing controversy is in proving whether or not the claims of systemic illness of hundreds of thousands of implanted women are valid or not. That has become the multi-billion dollar question. Silicone manufacturers have funded studies that they claim disprove this link and hired the largest Public Relations firm in the world to bolster the wounded image of their product. The media is deluged with pro-silicone propaganda and "greedy plaintiff attorneys" and women's health advocates (such as myself) are publicly maligned for "scaring the women unnecessarily" and blamed for the "unfounded hysteria." O¹LEARY has made these claims countless times about me. My position is very clear that I strongly believe that breast implants can be very harmful and that the public is not adequately warned of their dangers. Daily I receive new phone calls and emails from frightened, ill and sometimes dying women with complications from their implants. HISTORY OF DEFENDANTS¹ DEFAMATION CAMPAIGN 9. In September 1995, when I began researching this topic on the Internet at the request of an ill and confused friend, the first pro-silicone contact I encountered was O'LEARY, identified then only as @aol.com." He was posting the silicone manufacturers' viewpoints on AOL, the New York Times, and the sci.med.immunology discussion boards. He rigorously defended all the pro-silicone studies and denigrated all the science that was emerging supporting the harm women were experiencing. He would attack scientists as "biased" and claimed they had a "lucrative business of working with women with breast implants." (EXHIBIT F) even when these claims were unfounded, and without admitting he was employed as a very high level officer at Inamed/McGhan. He was rude and aggressive, and actively arguing with anyone who posted their viewpoints against implants when I joined the discussions. He refused to identify himself, but his Internet presence was at that time the most visible and contentious on the topic. Aligning his opinions with defense attorneys of other silicone manufacturers (such as counsel from Bristol Myers Squibb), he would bully their viewpoint and criticize anyone who wrote to the contrary. If they did not just give up and leave the bulletin boards, as hundreds did, he would allude that they were stupid, greedy, and just there to "mooch" for donations. This was ludicrous, as this issue has been a financial catastrophe for every support group leader, myself included. In fact, most of the former support group leaders are now gone ­ bankrupt, beaten down, and too sick or too dead to any longer withstand their attacks. 10. In the fall of 1995, I created alt.support.breast-implant, as an Internet newsgroup for the unique purpose of offering support and information to women harmed by breast implants. Almost immediately, "mplnt" wrote me and joined the discussion group, refusing to identify himself. Because of the onslaught of aggressive, rude, and domineering postings by O¹LEARY, Susan Schaezler, ("SCHAEZLER") and other named and unnamed defendants ("DEFENDANTS"), and because their obsession became one of defaming me, I was forced to begin an email list for implant victims, away from their harassment on the newsgroup. Maintaining this list today, I have thousands of members from countries throughout the world. The majority are or have been plaintiffs in the ongoing breast implant litigation. DEFENDANTS have used the newsgroup and email lists including lists that have been stolen from me, as the stage for their attacks on other support leaders and myself. This work is very intense, very serious, very energy draining, and extremely time consuming. Being under DEFENDANTS¹ constant scrutiny and attacks, and the object of their false allegations, rumors, and lies, exhausts me and wastes my finite energy and limited resources. I was criticized for everything I did or wrote, and if I posted a study with which he disagreed, O¹LEARY would claim I was "lying" and would publicly berate me for it. DEFENDANTS found nothing too personal or trivial to use as opportunities to insult and harass me. 11. Even after being served with this lawsuit, far from having his first amendment right to free speech "chilled," O¹LEARY has posted over 500 public messages on various internet breast implant related bulletin boards, as well as represented the industry at the FDA Saline Hearings in March, 2000. (EXHIBIT G) 12. However, it is not about the discussions on the merits or harm of breast implants that I bring my complaint. It is about a nearly five year defamation campaign by DEFENDANTS. When they could neither silence nor drive me away from the Internet, they chose instead to harm my reputation by repeatedly posting defamatory and libelous remarks pertaining to me personally -- my character, my finances, my motivations, my mental health, etc. They worked in concert with each other to destroy my credibility on many different levels, as well as waste my time and energy, and detract from my support, public relations, research, and fundraising efforts. The sheer volume of their criticisms is staggering, hundreds of negative, confusing, and untrue postings have been made about me. Email lists stolen from me were deluged with the same negative and false information about me intending to harm my reputation. Because of this, I have had to waste untold thousands of hours dodging their bullets. Although I have attempted to correct the defamatory statements they have made about me, their malicious lies continue to this day. 13. O'LEARY was not the only representative from Inamed/McGhan to infiltrate the support system. The Executive Secretary of Scott Eschback, President of McGhan, was also hidden in my support list as an alias. EXHIBIT H illustrates that Ms. M. Molnar was also in violation of the breast implant Court Order #8 (EXHIBIT C) and gained personal information from the members without their knowledge of her position. My former attorney, MORRIS, dismissed my complaint against McGhan and Inamed prior to having taken any discovery from them. 14. DEFENDANTS aligned themselves to infiltrate the group and denigrate me in creative ways. Shills (or decoys) were created to spread their message. One was "Linda Reiter," previously unknown to me, who suddenly and very publicly declared me as having been diagnosed as a "borderline personality" and assured all readers that "Ilena is deteriorating and her current position will cause her to harm others." (EXHIBIT I) These remarks and several other libelous statements attributed to "Linda Reiter" were posted via co-defendant Susan Schaezler¹s ("SCHAEZLER") group conveniently just days after O'LEARY's true identity as a silicone manufacturer was uncovered and revealed to the group. These allegations were circulated wide and far and published by SCHAEZLER on various public bulletin boards. These accusations backed up the ugly and untrue story SCHAEZLER had been painting about me over several years, that I was from an abusive background, tortured as a child, and a danger to myself and others. None of these allegations are true, but they had the affect of creating dissension, paranoia, doubt and distrust amongst the support network. 15. In December, 1999, SCHAEZLER suddenly announced the tragic death of this shill, "Linda Reiter," who had been presented as a young breast cancer and implant victim, and mother of two young children. The support network was grieving, frightened for their own fate, as SCHAEZLER embellished the sad story with requests for donations for the poor children and tales of Child Protective Services. 16. Suspicions arose as to the credibility of the story whose topic had engulfed and distracted the entire network, and as supporters mourned and grieved her passing, "Linda Reiter" was discovered alive and well by the police in Olathe, Kansas, and actively hustling Beanie Babies on the world wide web. 17. "Linda Reiter" was merely a shill created to defame my reputation by her libelous statements, and to distract the support group from the new discovery that SCHAEZLER's anonymous "caring professional" was O'LEARY, a former President of McGhan/Inamed. SCHAEZLER had invited and welcomed him into her support group, while concealing his identity from the group. (See declarations of Ms. Schorer and Ms. Jeffcoat) 18. DEFENDANTS posted that I had "cancelled 5,000 messages, implying I was destroying evidence unfavorable to me. This is the Internet equivalent to Nixon's eighteen and a half minute gap on his tapes. SCHAEZLER and O'LEARY continued the charade, and hundreds of postings were made to further spread their untrue propaganda that I was rapidly destroying evidence. One would affirm the others misrepresentations. I destroyed no evidence, yet they created a whole campaign against me based on these accusations. (EXHIBIT J) 19. The DEFENDANTS have exhibited an obsessive interest in me, and have made their untrue version of my life the subject of many hundreds of postings. This serves the multiple purpose of distracting readers from the stated purpose of the newsgroup (supporting women harmed by breast implants), defaming me, driving people away, and causing others to doubt my character, my motives, and my credibility. I was called a "fraud," the Humantics Foundation, which I head, was declared illegal by them, and many lies regarding the IRS were circulated. DEFENDANTS even admitted trying to get the IRS withdraw our non-profit status. Anything and everything to diminish my effectiveness and harm me financially was done. Even when I corrected all their errors, their libel continued. (EXHIBIT K) 20. O'LEARY would often be the nidus of false statements about me. O¹LEARY innocuously admits in his declaration, "I have raised questions with regard to the source of funding of plaintiff's activities. I have publicly questioned how plaintiff can manage the news group, carry on her activities as a public figure with regard to the silicone breast implant issue, and yet have no obvious source of income for over four years. I have raised public questions with regard to the funding of plaintiff's organization, described as the "Humantics Foundation for Women." However, I have at no time made any public assertion of fact, orally or in writing, that plaintiff has misappropriated funds donated to her organization." 21. O¹LEARY fails to state that these interrogations by him, which soon were joined by other DEFENDANTS, were made while hiding his own identity as a silicone manufacturer. Repeatedly, they questioned me, implying I was being dishonest, "mooching off of," and "ripping off," women, and although I publicly posted the truth that I was losing money every month, my donations were minimal, and the expenses and time and emotions invested in this work very high, that would not deter them. O¹LEARY found every reason to insult, degrade, and misrepresent me, "quoting" me on things I never said, and falsely representing my intentions. 22. DEFENDANTS made their version of my life the subject of the newsgroup for years, claiming I was an "opportunistic parasite" even though they knew that none of the support leaders, myself included, financially benefited, and we were all donating our time. (EXHIBIT L) They intimated that I had "handlers" and that this cause was some cash cow, when it was and continues to be a financial drain. In fact, I have spent over $100,000 of my own money, and donated all of my time in the last 5 years to raising awareness as to the dangers of breast implants, while continually being harassed and defamed by DEFENDANTS. 23. O¹LEARY would not even reveal who he was while interrogating me, when who he was, was President of McGhan, Ireland, an important European hub for Inamed/McGhan. When repeatedly asked by many interested parties if "mplnt" was a silicone manufacturer, DEFENDANTS claimed he was a "caring professional." (See declarations of Ms. Schorer and Ms. Jeffcoat). DEFENDANTS used a newsgroup created solely to support women harmed by breast implants, and made it center stage for their attacks using several aliases. It was exhausting and a losing battle, there were no possible right answers for me. DEFENDANTS picked apart and criticized me over a period of nearly 5 years, wasting my time and expending my energy. As one DEFENDANT threatened, she was going to be "my fourth skin," and SCHAEZLER at one point even threatened to crash a Support Meeting sponsored by the Humantics Foundation, creating much distress and wasted energy. The only way to have avoided them, would be for me to leave the Internet and my group of thousands of harmed women with no central hub of information, something I am not willing to do. 24. My personal life is an ongoing topic for my DEFENDANTS. One Saturday night, SCHAEZLER posted several pornographic websites, just because they had the name "ilena" mentioned in them. (EXHIBIT N) 25. O'LEARY, too has made references to his version of my sexuality, illustrated here as EXHIBIT O: for example by writing:   "I am sorry coleah, but you remind me of a women(term used loosely) that hasn't gotten off in a long long time.  Maybe Ilena could help. 26. Other DEFENDANTS claimed I was a "Madam" and raised the question, shown in EXHIBIT P: "San Diego, eh? Is it true that you service the fleet for free or do you get paid?  Do you bring your own bag or does the fleet supply it." 27. DEFENDANTS have attempted to link me intimately to defense attorneys, scientists, the Navy, alleycats, husbands of women in the group, industry Public Relations flack, Steve Milloy of www.junkscience.com, and to O'LEARY himself. SCHAEZLER posted a series of false rumors that I had been seen "dancing with the enemy" -- Don McGhan, O'LEARY'S former employer. (EXHIBIT Q) The volume of energy expended to destroy my reputation by DEFENDANTS is staggering in both quantity and the depths they go to in their zeal to defame me. 28. SCHAEZLER posted as fact a creative tale that she witnessed that I exposed myself to the panelists at the Institute of Medicine (IOM) at a meeting at the National Academy of Sciences in Washington DC, and fashioned this descriptive fabrication about me in EXHIBIT R: ". . . --all I could picture was her sitting at the IOM meeting with both feet propped up on the seat in front of her & the IOM members directly in front on a stage with a great view--during one session, she sat in front of me--yukkkkkkkkk.  Of course, I'm glad I didn't have to sit in the same seat later!" This assertion was completely concocted by SCHAEZLER and made deliberately by her with a complete disregard for the truth. 29. Frequently I sign my messages, "May God bless us All," and several times I have been quoted on television, radio and the press referencing God. Reuters recently published (EXHIBIT S) "God knows there aren't supposed to be foreign objects in the body," said Ilena Rosenthal, director of the Humantics Foundation for Women, a major anti-implant support group. 30. To detract from this, DEFENDANTS on several occasions, under several email names, including "IlenaSaid" and "IlenaSpeak," made a collage of atheist remarks, including a joke, "Thank God I'm an Atheist" that I had posted on an atheist satire newsgroup in 1995. In the collage, were ugly added remarks, all attributed to me which I did not and would not write. This tainted message was posted several times on several public boards, and circulated throughout the support groups, made to erroneously look like I wrote the following when I did not. EXHIBIT T shows this posted by Ilena with this headline: "WARNING--THE FOLLOWING ARE IN ILENA'S OWN WORDS." This is clearly defamatory. "alright, great concept, anybody can use "god" as an excuse for theirviolence...as atheists we lack the mendacious shroud of righteousness provided by a "god" but, what the fuck, let's use "god" anyway my vision is clear, where once it was muddy, thank you, jesus, now i know that i have to kill somebody." 31. SCHAEZLER has admitted that she has posted under the email alias, Ilena which is a violation of AOL posting rules prohibiting "imitating" another. (EXHIBIT U) Discovery would show that several email aliases were used, and everything that could diminish my personal credibility and tarnish my good name and reputation have been posted, and these examples merely summarize and skim the mountains of evidence. DEFENDANTS SCHAEZLER AND O¹LEARY ACTED IN CONCERT WITH EACH OTHER TO DELIBERATELY DECEIVE THE MEMBERS AND INFILTRATE THE BREAST IMPLANT SUPPORT SYSTEM 32. A common practice for corporations in environmental and health issues such as the multi billion dollar breast implant controversy, is to align with "insiders" to infiltrate, gain access to, create bonds with, and for all intensive purposes, to spy from within. 33. Even more damaging to the unity of a cause than external attacks, is to have a sympathetic insider act as a "mole" and gain trust and access to the internal information flow. As Vice President of McGhan Medical O¹LEARY forged such a bond with SCHAEZLER and extracted an oath from her to never reveal his hidden identity as a silicone manufacturer. In this newsgroup posting on May 25, 1997, he had become President of McGhan, Ireland less than three weeks earlier and his disruptive and antagonistic omnipresence on the newsgroup was being questioned. He wrote, "You also know that Susan has an oath not to tell who I am." (EXHIBIT V) 34. They were each other¹s number one fans. In scores of posts over a four year period, SCHAEZLER would defend O¹LEARY¹s masquerade. One clear example of his infiltration to a group which included Inamed plaintiffs, can be seen in Exhibit W. Here, SCHAEZLER, as leader of this "BIS" or "Breast Implant Support" group, has invited list members to send their personal information to all on the list. In the middle is O¹LEARY, then Vice President of McGhan Medical in Santa Barbara. (EXHIBIT W) 35. In this post of February, 1997, SCHAEZLER admits her personal relationship with "mplnt." She writes in EXHIBIT X: ". . . I have been lucky to know their identity, talked to them, their associates, their spouse, know their dogs, and lucky enough to have them find a solution to my most unusual implant situation." SCHAEZLER and O¹LEARY¹s relationship continues to this day. On October 21, 1999, after his identity was discovered, SCHAEZLER acted as his Spokespersonto the support network and made this posting claiming "Š  He did not agree with how we were treated & has left the industry." (EXHIBIT Y) 36. This soon proved to be totally untrue and just another attempt to obfuscate O¹LEARY¹s continued vested manufacturing interest. Just months later, in March 2000, O¹LEARY was representing PIP, a breast implant manufacturer who was unsuccessfully trying to get their saline breast implants FDA approved. (EXHIBIT G) Please notice in O¹LEARY¹s presentation in speaking about the manufacturers, he uses "we." This is taken from the March 2, 2000 minutes of the FDA Saline Meeting: "DR. O'LEARY:  . . . . . .  So the manufacturers were trying to make a thinner and thinner shell, and that's what led to that rupture. So what we've done now is we've gone back and we've thickened the shell up and strengthened it so that we don't have those kind of ruptures, which is demonstrated in the clinical studies of which you can see the rupture rate is 5.3 percent in the sampleŠ"   37. I submit these as introductory evidence to the relationship between manufacturer O¹LEARY and SCHAEZLER as his "mole" or access into the implanted women¹s network. While O¹LEARY was often in the background, SCHAEZLER had the most visible presence on the Internet of any implanted woman making thousands and thousands of postings, and regularly rounding up women to join various groups she created. She was recognized as the "computer expert" and they worked in tandem, he would often open up a topic, and SCHAEZLER would then take the ball and run with it. At one point O¹LEARY posted lies that I had been "thrown off" several newsgroups. Thereafter, SCHAEZLER would quote it as fact. 38. Another example was in O¹LEARY¹s early questions about my foundation and why it was "incorporated." From then on, SCHAEZLER began making hundreds of defamatory postings and sent thousands of emails claiming that that the foundation was illegal and a fraud. Even when presented with the IRS letter (EXHIBIT K) indicating that The Humantics Foundation was a tax exempt, 50l(c)3 non-profit, DEFENDANTS continued making hundreds of postings using several email aliases repeating the libelous allegation. As recently as June, 2000, DEFENDANTS were posting that "she doesn't have a business license." (EXHIBIT K) when this too, in false and libelous. 39. DEFENDANTS have repeatedly posted and emailed the support group that I was "living off of donations of implanted women," "ripping off," "shaking down," and "mooching off" women for donations. (EXHIBIT K). 40. I deny all of these allegations. In fact, I have spent over $100,000 of my own money, and worked uncompensated for five years of my life to raise public awareness as to the harm of breast implants, the largest manufacturer now being O¹LEARY¹s former employer. The donations the foundation has received have been minimal and have barely covered hard costs. We have also funded several breast implant removal surgeries for women without means. As a director of the Humantics Foundation, I take no salary, to the contrary, I have for the most part funded all of my work. This has not stopped DEFENDANTS from labeling me a "opportunistic parasite" and have gone so far as to write support group members advising them not to donate to me. My financial demise was obviously a goal of DEFENDANTS. (EXHIBIT L) 41. DEFENDANTS also created havoc in other business relationships of mine. At one point, SCHAEZLER had harassed a foundation board member repeatedly, claiming the Attorney General was going to arrest her because of "Ilena's fraudulent foundation," and then posted her home address on the newsgroup. She publicly humiliated Ms. Bonny Royce, claiming she been sent cash money with requests for information and had pocketed the money. This director quit the board after this harassment. None of SCHAEZLER's allegations was true, and yet she repeated these lies several times publicly. CONTRARY TO O¹LEARY¹S DECLARATION HIS BULLETIN BOARD POSTINGS MIRROR THOSE MADE AS EMPLOYEE OF MCGHAN / INAMED 42. In O¹LEARY¹s Declaration in Support of Motion to Strike Plaintiff¹s Complaint, page 2, he claims that "all communications sent by me to the news group were made on my own behalf, and not as a representative of any company." 43. However, O¹LEARY clearly is, and has been for several years, a spokesman for the silicone industry. His scientific viewpoints espoused on the Newsgroup while undercover as "mplnt" were indistinguishable from those he represented to the Independent Review Group in Great Britain in 1998. In the "Independent Review Group" Report, he is listed as having given "Oral Evidence considered by the Independent Review Group, and is identified as "Dr P O'Leary, International Association of Prosthesis Manufacturers: McGhan " (EXHIBIT B) 44. Further, The Institute of Medicine lists him on the Participant Roster of the public meeting on 7/24 and 7/26/98 as: "Patrick J. O'Leary, President, McGhan Limited, County Wicklow, Ireland. (EXHIBIT B) 45. As Vice President, and later President of McGhan, Ireland, O¹LEARY was in direct and blatant violation of U.S. District Court, MDL 926, The Honorable Samuel C. Pointer's Court Order #8 prohibiting silicone manufacturers and their employees from contacting plaintiffs in the on-going breast implant litigation and influencing their cases. (EXHIBIT C) Although not a plaintiff myself, the Newsgroup I created, and the email lists I maintain, reach thousands of plaintiffs. 46. Further, he represented silicone manufacturer PIP at the recent FDA Saline Breast Implant Hearings in March, 2000. (EXHIBIT G) BASED UPON MY KNOWLEDGE OF THESE FACTS, T IS MY BELIEF THAT: DEFENDANTS were actively involved in the public debate over the safety of breast implants as was I. However, this lawsuit arose not from these discussions, but from over four years of a personal defamation and libel campaign against me whose purpose was to destroy my reputation and credibility, bankrupt me, and diminish my voice on this issue. Far from having his first amendment rights to participate in the public debate of implants "chilled," O'LEARY has posted over 500 messages on public bulletin boards and recently represented industry at the FDA in Washington DC since this lawsuit was filed. DEFENDANTS worked in concert to infiltrate the support network, create dissension from within, and diminish its effectiveness. DEFENDANTS did not stop publishing libelous and defamatory statements, even after public corrections were made by PLAINTIFF, indicating their malicious intent of repeating what they knew to be untrue. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed this 31st day of July, 2000.