IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA



Diana Napolis
6977 Navajo Road, PMB 114
San Diego, CA. 92119-1503
(619) 462-5818

In Pro Per

DIANA NAPOLIS
Plaintiff
v.
MICHAEL AQUINO, MICHELLE DEVEREAUX, TANI JANTSANG, CAROL HOPKINS, DR. ELIZABETH LOFTUS, LESLEY WIMBERLY,
MARK SAUER, DAVID COPLEY, SAN DIEGO UNION-TRIBUNE, a business entity, SAN DIEGO STATE UNIVERSITY, and DOES 1-100, inclusive,

Defendants

Case No.: 3:2008cv00557

COMPLAINT FOR:
NEGLIGENCE;
DEFAMATION;
VIOLATION OF PLAINTIFF’S RIGHT TO PRIVACY;
FALSE LIGHT;
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS;
CONSPIRACY TO VIOLATE PLAINTIFF’S RIGHT TO PRIVACY AND FIRST AMENDMENT RIGHT TO FREE SPEECH;
CONSPIRACY

Plaintiff Diana Napolis is a citizen of the State of California and the United States of American and resident of San Diego County entitled to the protections of the Constitutions of the State of California and the United States of America.

Plaintiff DIANA NAPOLIS alleges against Defendants as follows:

PARTIES


1. Defendant Dr. Michael Aquino (hereinafter referred to as M. Aquino) founder of the satanic organization the Temple of Set is believed to be a resident of San Francisco, California.

2. Defendant Michelle Devereaux (hereinafter referred to as Devereaux) is believed to a be a resident of San Francisco, California.

3 Defendant Tani Jantsang (hereinafter referred to as Jantsang) founder of the satanic organization the “Satanic Reds” is believed to be a resident of Florida.

4. Defendant Carol Hopkins (hereinafter referred to as Hopkins) is believed to be a resident of Cuernavaca, Mexico and San Diego, California.

5. Defendant Dr. Elizabeth Loftus (hereinafter referred to as Loftus) a False Memory Syndrome Foundation Advisory Board member and Professor of psychology at UC Irvine is believed to be a resident of Irvine, California.

6. Defendant Lesley Wimberly (hereinafter referred to as Wimberly) of Victims of Child Abuse Laws is believed to be a resident of Tuscon, Arizona.

7. Defendant Mark Sauer (hereinafter referred to as Sauer) reporter for the San Diego Union-Tribune is believed to be a resident of San Diego, California.

8. Defendant David Copley (hereinafter referred to as Copley) publisher of the San Diego Union-Tribune is believed to be a resident of San Diego, California.

9. Defendant San Diego State University (hereinafter referred to as SDSU is believed to be a resident of San Diego, California.

10. Plaintiff Diana Napolis has a Masters degree in Transpersonal psychology and worked as a Court Intervention Social worker at Child Protective Services [CPS] in San Diego, California during the years 1990-1996. After resigning from CPS, Plaintiff was self-employed as a Visitation Supervisor for Family Court from 1996-2000. In the year 2000 Plaintiff received her Marriage and Family Therapy [MFT] license.


GENERAL ALLEGATIONS

11. Plaintiff alleges that satanist Defendant Aquino, and his associates, conspired to violate Plaintiff’s Right to Privacy and First Amendment Rights to Free Speech on the internet between 1995-2000 after she proved the existence of the satanic ritual abuse of children, under the pseudonyms “Curio” and “Karen Jones,” which was contrary to their agenda.

12 Defendants and other Does proceeded to conspire with Defendant Devereaux and SDUT reporter Mark Sauer to identify Plaintiff, after which Defendant Devereaux enlisted the aid of Defendant San Diego State University Campus police, by fraudulent misrepresentation, to identify Plaintiff in June 2000. Despite Plaintiff cautioning Defendant SDSU campus police that dangerous individuals were seeking her identity, campus police proceeded to engage in reckless and outrageous conduct and subjected Plaintiff to invasion of privacy by inappropriately revealing her identity to San Diego Union-Tribune reporter Mark Sauer, after which he wrote an invasive and defamatory news article about Plaintiff titled, “A Web of Intrigue/The Search for Curio Leads Cybersleuths Down a Twisted Path” on September 24, 2000 which Defendant Copley published.

13 After Defendant Mark Sauer’s defamatory news article was published, Plaintiff was subjected to further invasion of privacy, threats from Defendant Jantsang, and defamation on the internet which, in combination with Mark Sauer’s article, resulted in the ruination of Plaintiff’s reputation and career as a Family Court Visitation Supervisor.

14. Eight months after Plaintiff’s identity was revealed, and since May 2001, Defendant Aquino and others have caused Plaintiff to be subjected to prolonged psychological and physical torture and terrorization by the usage of nonlethal technology, such as “Voice to Skull Devices,” “Voice Synthesis Devices,” “Computer/Brain Interface” technology, psychotronics, electromagnetic, and other nonlethal technology. Because of these assaults, Plaintiff has been unable to seek gainful employment since May 2001 and receives Social Security Disability benefits.

15. In October 2002, due to threats made by Plaintiff’s perpetrators that they would kill Plaintiff by nonlethal technology, it caused Plaintiff to write a pseudo- threat to a Hollywood figure to ensure that she would be placed in the custody of law enforcement, in efforts to save her life. Due to Plaintiff’s eventual plea to “stalking” and subsequent notoriety, it resulted in further ruination of Plaintiff’s reputation and career, and revocation of her MFT license. These malicious actions by Defendant Aquino, and others, caused Plaintiff to be misdiagnosed as “mentally ill” after which she was forced by the criminal justice system to take psychotropic medication. After May of 2007, Plaintiff experienced enough psychological recovery to allow her to file a complaint against Defendants.

16. The terminology which defines Nonlethal weaponry can be found on the Center for Army Lessons Learned website http://ca..army.mil. Their Mission Statement reads, in part, that the Center for Army Lessons Learned is the home of the Combined Arms Center which provides leadership and supervision for leader development and professional military and civilian education. Nonlethal Weapons are defined on this web page as:



17. Because this technology may or may not leave any obvious external wounds, it can be used to secretly torture In a report titled, “Future Sub-lethal, Incapacitating and Paralyzing Technologies – Their Coming Role in the Mass Production of Torture, Cruel, Inhuman and Degrading Treatment,” by Dr. Steve Wright of the Omega Foundation, presented to the Expert Seminar On Security Equipment and the Prevention of torture, Dr. Wright wrote:



18. In a July 7, 1997 U.S. News and World Report article titled, “Wonder Weapons The Pentagon’s Quest for Nonlethal Arms is Amazing. But is it Smart?” by Douglas Pasternak it states:



19. Many concerns have been raised about the usage of nonlethals nationally and internationally. In a report titled, “US Electromagnetic Weapons and Human Rights – A Study of the History of US Intelligence Community Rights Violations and Continuing Research in Electromagnetic Weapons,” by Peter Phillips, Dec. 2006, the introduction reads:



20. Plaintiff believes the length of this complaint is necessary and is directly related to the serious and manifest crimes it seeks to expose.

BACKGROUND

21. Beginning in 1990, Plaintiff was witness to a documented cover-up of the satanic ritual abuse of children while employed as a Court Intervention Social Worker for Child Protection Services [CPS] which was due to the efforts of a woman by the name of Defendant Carol Hopkins - a 1991-92 San Diego Grand Jury Foreman - a 1993-94 San Diego Grand Jury, the False Memory Syndrome Foundation, and two newspaper reporters, Jim Okerblom and Mark Sauer of the San Diego Union-Tribune. Plaintiff had researched and investigated the validity of ritual abuse and had handled several case assignments with negative occult themes within this agency.

22. The general term “ritual abuse” is usually used to describe negative occult abuse, including satanic ritual abuse [SRA], because it is inclusive of all negative occult belief systems which are both evil and criminal in nature. Some people believe the occult automatically refers to Satanism, but it does not. Instead the word “occult” refers to a wide spectrum of beliefs. Historically, some people have misused occult principles for their own benefit. What differentiates the positive from the negative is that the positive occult has the goal of self-empowerment in order to become a contributing member of society. The negative occult is dedicated to the gathering of power over others so one can abuse them. Consequently negative occult practices are condemned by all occultists world-wide because they are evil.

23. Plaintiff’s Masters degree in Transpersonal Psychology and her personal disciplines encompassed positive spiritual ideologies and meditation practices from around the world, including Buddhism, Taoism, Hinduism, Esoteric Christianity, Native American teachings, and the positive occult. Transpersonal Psychology teaches how to incorporate positive spiritual beliefs and values and includes interventions which mainstream psychology has to offer in order to access higher states of consciousness. Therefore, Plaintiff considered herself to be well qualified to investigate and differentiate between harmless occult/pagan practices and those of the truly negative occult or Satanism.

24. In 1988-89 two hearings were held by the California State Advisory Board to Social Services in San Francisco and San Diego during which time 43 individuals, including law enforcement, therapists, researchers, and victims in the State of California testified to the reality of ritual abuse. These hearings resulted in a published report in April 1991 titled, “Ritualistic Abuse in California.” The Advisory Board concluded in this report that ritual abuse should be taken seriously and made recommendations to the California State Legislature, CPS, Community Care licensing, Law enforcement and all treating professionals, such as LCSW’s and MFT’s, that training about ritual abuse be offered throughout the State.

25. In the California State Advisory report, Dr. Catherine Gould, an expert in the field, provided the following definition of ritual abuse:



26. The only addition Plaintiff would make to this definition is that Ritual Abuse is also intended to spiritually destroy a child.

27. The outcome of the California State Advisory Board hearings was favorably reported by the San Diego Union-Tribune in their article titled, “Ritual Child Abuse: Horrible, But True,” on April 17, 1989, authored by John Gilmore. The abstract and first paragraph read:



28. On April 2, 1991, Plaintiff wrote an internal memo to CPS Assistant Deputy Director Sherry Paul requesting permission to set up support systems for social workers who were addressing allegations of ritual abuse on their caseload. [Exhibit 1] She wrote:

April 2, 1991
To: Sherry Paul
From: Diana Napolis PSW, Court Intervention

RITUAL ABUSE CASE CONSULTATION

There have been a growing number of ritual child abuse cases in the past few years. Social services & police agencies around the country are endeavoring to isolate & identify this phenomena and disseminate helpful information as quickly as possible. There are difficulties meeting the demands for information because there are few experts in the field and so much to learn.

Due to the prevalence of cult groups and their propensity to horribly abuse young children (often the younger the better), I feel that CPS needs to have support systems firmly in place ready to fill the needs of the community & individual social workers. We are faced with the responsibility of recognizing, investigating and protecting children in an area where there is so little known and often associated with denial & fear.

I would like to help set up such a recognition, identification & treatment guide for court intervention workers. I am suggesting a weekly time commitment devoted to case consultation & peer support. Eventually, we could set up a library and network with others community agencies to best address this unfortunate growing problem in San Diego.

29. Plaintiff was authorized to proceed with this ritual abuse project from Assistant Deputy Director Sherry Paul in her memo dated April 10, 1991 which she sent to the top Administration of Social Services. Plaintiff’s supervisor, Joyce Wakefield, proceeded to assign Plaintiff ritual abuse cases to investigate in Court Intervention which was a specialized unit which presents evidence of child abuse to Juvenile Court. The following is an example of one of Plaintiff’s cases that she investigated during her tenure at CPS:



30. After successfully addressing several cases with allegations of ritualistic abuse, Plaintiff wrote a series of internal memos dated May 7, 1991, Sept. 26, 1991, and October 8, 1991 about her findings. In these memos, Plaintiff suggested ways in which CPS might address ritual abuse allegations at every level of the system. She informed management that some social workers were too frightened to investigate ritual abuse and case assignments should be handled judiciously. Plaintiff also advised that because children of satanic abuse often have only one chance to disclose, if these cases weren’t assigned to an investigator trained in ritual abuse, it might lead to harm to the child and a societal “backlash.”

31. CPS San Diego ultimately acted on the State Advisory Boards recommendations. In September 1991 a Ritual Abuse Protocol titled, “Ritual Abuse, Treatment, Intervention, and Safety Guidelines,” was submitted to CPS - which Plaintiff’s supervisor asked her to contribute to - by the San Diego Ritual Abuse Task Force, Linda Walker, who was Executive Director of the Commission on Children and Youth, and Napolean Jones who was at that time Presiding Judge of the Juvenile Court and Chairperson of the Commission on Children and Youth. In the introduction to the protocol, the authors cited the 1988-89 hearings which were held by the California State Advisory Board to Social Services about the reality of ritual abuse.

32. Napolean Jones sent a survey to many professionals in San Diego which resulted in the finding that a total of one third (or 134) of those professionals who responded reported that they had treated at least one client who claimed to be a victim of satanic cult activity. This is of course a huge number. They noted that the majority of SRA victims suffer from Multiple Personality Disorder [MPD], now called Dissociative Identity Disorder [DID]. MPD/DID is created by extreme child abuse perpetrated at an early age. It is due to a creative function of the mind which survives by “splitting” one’s identity into alternate personalities so that the core personality can avoid being overwhelmed by having to experience the horrific trauma they experienced as children. MPD/DID’s usually spontaneously switch between identities in response to changes in the physical or social environment. The Ritual Abuse Protocol only touched on these themes, focusing on the reality of satanic victimization, and proved that this topic was a real phenomena in San Diego which needed to be formally addressed.

33. In 1991-92 a Grand Jury was convened with Defendant Hopkins appointed as Chairperson of the Social Services Committee. She was investigating the District Attorney Ed Miller’s Child Abuse Unit as well as CPS. A grand jury is a court appointed authority that is mandated to objectively investigate the operations of governmental programs of the County, cities and special districts. The 1991-92 Grand Jury failed to meet that requirement and instead Plaintiff believes that Defendant Hopkins used the Grand Jury as a means to promote the views of the False Memory Syndrome Foundation [FMSF] which Plaintiff believed placed children at risk of harm.

34. Specifically, in Grand Jury report No. 8, dated June 29, 1992 titled, “Child Sexual Abuse, Assault, and Molest Issues,” Hopkins quoted from and referenced the FMSF as a legitimate authority. These views included the FMSF’s positions about the alleged ability of therapists to “create abuse in the minds of children and adults” which they attributed to “inappropriate” therapy.

35. Unfortunately, over the years, the FMSF have become widely known as an organization which denies the fact that satanic ritual abuse occurs, without good cause, questions the validity of repressed memory based on misrepresentations, and provides what many people believe is a fraudulent defense for accused child molesters.

THE FALSE MEMORY SYNDROME FOUNDATION [FMSF]


36. As background to the genesis of the False Memory Syndrome Foundation [FMSF], of which Defendant Loftus is a member, in the early 1990’s Peter and Pamela Freyd’s daughter, Jennifer Freyd, Ph.D, a memory specialist, privately accused her father Peter Freyd of molesting her as a youth. The Freyds responded to her allegations by forming the False Memory Syndrome Foundation and dismissed their daughter’s allegations by claiming she had “false memory syndrome.” They claimed that Jennifer Freyd’s therapist “implanted” their daughter with “false memories” of sexual abuse, but Jennifer Freyd claimed she had remembered her parents abuse after the second session of therapy. Pam Freyd responded to her daughter by sending an anonymous “Jane Doe” article to Jennifer Freyd’s University where she was employed, disclosing personal information about her at the time her daughters tenure was to be decided. Peter Freyd responded by accusing his daughter of having “brain damage.”

37. Jennifer Freyd gave an interview in an August 8, 1993 news article, published in the Oregonian titled, “Memories of a Disputed Past – The Founders of the False Memory Foundation Say Therapists Plant Memories of Childhood Sex Abuse in Clients. Not So, Says her Daughter. She Says her Father Raped Her,” clearly stating her position. The Freyds then invited their daughter to become a Board member of their own organization which appeared to be very inappropriate given the circumstance.

38. Many professionals have exposed what they believe to be the politics and agenda of the FMSF over the years. However, there is usually a price to be paid for educating the public about this organization. In Freyd v. Whitfield, 972 F. Supp. 940 (1997), the court granted summary judgment to Charles L Whitfield after being sued by the Freyds for “defamation.” The overview states:



39. More recently Charles Whitfield. M.D. wrote an article about the disinformation that “false memory syndrome” proponents disseminate, published in the Journal of Child Sexual Abuse 9, 3 &/4 (2000), pg. 53-78, titled, “The ‘False Memory’ Defense: Using Disinformation and Junk Science in and out of Court.” His abstract reads:



40. In 1993 FMSF Advisory Board members Ralph Underwager (deceased), and his wife Hollida Wakefield, betrayed a pro-pedophilia agenda when they were quoted in the Winter 1993 issue of “Paidika – the Journal of Pedophilia,” which was published in the Netherlands. This was not an educational journal for professionals who studied pedophilia, this was a magazine published for pedophiles. The number one man listed on their editorial board was Bill Andriette, the “Editor of NAMBLA Bulletin.” NAMBLA stands for North American Man-Boy Love Association which is an organization comprised of pedophiles who attempt to sway the public into believing that their behavior should be legalized. In response to the question, “Is Paedophilia for you a responsible choice?” Dr. Underwager stated the following:



41. In this interview, Dr. Underwager raised the specter of “God” to validate for pedophiles that sex with children was an acceptable choice. Ralph Underwager was asked to resign from the FMSF after he gave this interview, but his wife Hollida Wakefield remains an FMSF Advisory Board member to this day. According to the FMSF’s first newsletter (March 15, 1992 Vol. 1 No. 1), Ralph Underwager and his wife Hollida Wakefield were not only one of the founding members in the formation of the FMSF along with the Freyds, but the Freyd’s used Ralph Underwager’s organization’s services - Institute for Psychological Therapies - and their telephones on behalf of the FMSF when they first formed their organization. Dr. Underwager was instrumental in the formation of Victims of Child Abuse Laws [VOCAL], of which Defendant Wimberly is a member, which was created after a high-profile ritual abuse investigation took place in Jordan, Minnesota. Plaintiff first heard of VOCAL while she was a social worker at CPS. The inside story was that some of the membership of this organization might be comprised of actual child abusers who were trying to hide their culpability by attacking the system. Professionals came to that opinion after VOCAL developed a reputation for over-the-top behavior and denial in cases of obvious child abuse which resulted in the fact that they were not taken very seriously. The FMSF has gained an equally disreputable reputation over the years for similar reasons.

42. After Anna C. Salter wrote a monograph titled, “Accuracy of Expert Testimony in Child Sexual Abuse Case: A Case Study of Ralph Underwager ” (1988), Ms. Salter was sued by Underwager and Wakefield. As described in the appellate decision Underwager/Wakefield v. Salter, 22 F.3d 730 (1994), Anna Salter was sued for defamation after she discovered that in their efforts to prove that most accusations of child sexual abuse stemmed from memories implanted by faulty clinical techniques, rather than from sexual contact between children and adults, that Underwager misrepresented studies, ripped quotations from their context, and ignored evidence which contradicted their thesis. The court stated in their final conclusions, after dismissing Underwager’s lawsuit for defamation that:



43. It appears that Dr. Underwager was one of the first to claim that most memories of child sexual abuse could be “implanted” by therapists but the FMSF took it one step further and gave this unlikely occurrence a name: “False Memory Syndrome.”

44. Anna C. Salter reported in a journal article titled, “Confessions of a Whistle-blower: Lessons Learned,” published in Ethics and Behavior 8 (2) 115-124, (1998), about Underwager and his wife Hollida Wakefield’ retaliation against her after she privately published her article which exposed them. Ms. Salter wrote:



45. Dr. Underwager was well known at that time for making his living by testifying on behalf of the defense in child sexual and ritual abuse cases in the United States and Canada. Nobody knows how many alleged perpetrators he freed by what appears to have been false testimony.

46. More recently, in United States v. Grigoruk 56 M.J. 304 (2002), the court found it was not ineffective of counsel to decide not to use Ralph Underwager as an expert witness on behalf of his client. Defense counsel stated he became concerned about Dr. Underwager’s references to “false claims” and the “documents” he carried to rebut them. He was concerned that the court members might think he was trying to “pass off a quack” on them.

47. As early as 1993 it appeared that the FMSF had an agenda, rather than a legitimate concern about “false” accusations, and their writings appeared to be geared towards developing legal defenses for perpetrators under the guise of “false memory syndrome,” a syndrome which has never been proven to exist.

48. There is reason to be concerned about other Board members of the FMSF regardless of the fact that they have Ph.D’s after their names and work at academic institutions. According to Dr. Colin Ross,’ “Project Bluebird, Deliberate Creation Of Multiple Personality By Psychiatrists,”(2000) several original FMSF Advisory members such as Martin Orne (deceased) from the University of Pennsylvania and Dr. Louis Jolly West (deceased) from UCLA had ties to the CIA, having accepted funding from them for various projects, a point which becomes relevant later in this complaint, as well as the sub-title of Dr. Ross’s book, “The Intentional creation of MPD/DID” by Psychiatrists.

49. In 1998 another FMSF Advisory Board member, Richard Ofshe, Ph.D. from UC Berkeley, an alleged expert on “coercive persuasion,” wrote an article titled, “The Consequences of False Confessions: Deprivations of Liberty and Miscarriages of Justice in the Age of Psychological Interrogation,” published in 88 J. Crim. L. & Criminology 429. In 1999 Law Professor Paul Cassell investigated several of the cases that Richard Ofshe claimed were “false confessions,” which supposedly resulted in wrongful convictions, and he found that Ofshe used secondary sources and misstated facts when coming to his conclusions. Professsor Cassell documented his findings in his article titled, “The Guilty and the ‘Innocent’: an Examination of Alleged Cases of Wrongful Convictions from False Confessions,” which was published in Harvard Journal of Law and Public Policy (1999) Vol. 22, pp. 523-602. Professor Cassell then concluded:



50. Another FMSF Advisory Board member, Defendant Elizabeth Loftus, who regularly testifies for the defense, including for alleged perpetrators in child molestation civil cases, published a research study in 1995 about the supposed ability to implant “false” memories in children that they were “lost in a shopping mall,” and she and others went on to claim that this experiment proved that “false” memories could be implanted in vulnerable clients. Martha Dean, Ph.D and Lynn Crook, M.A exposed the multitude of problems in the Shopping Mall study in their journal article titled, “‘Lost in a Shopping Mall’ – A breach of Professional Ethics,” published in Journal of Ethics and Behavior (1998) (1), 39-50, and did not believe at all that this study proved that traumatic memories” could be implanted.

51. Due to Lynn Crook’s and Jennifer Hoult’s complaints that Defendant Loftus publicly misrepresented their cases (Defendant Loftus testified on behalf of Crook’s parents), ethical complaints were filed against Defendant Loftus in December 1995. Defendant Loftus eventually left her post at the University of Washington and she is currently employed at UC Irvine as a Professor of Psychology.

52. In 2005 a civil suit was filed against Defendant Loftus and others (Taus v. Loftus) 2007 Cal. LEXIS 1896 for violating Ms. Taus’s privacy. Ms. Taus claimed that Defendant Loftus misrepresented herself in order to obtain information about her in efforts to deny the fact that Ms. Taus had repressed and then accurately remembered the facts about her own abuse as a child. A December 6, 2006 article titled, “High Court Considers Privacy Issue – In a Case Involving Repressed Memory, Several Justices Suggest that a Researcher [Loftus] who Lies to get Information May be Breaking the Law,” describes these issues. In the FMSF newsletter Fall 2007, Vol. 16, No. 4 it was reported that Defendant Loftus reached a settlement agreement with Ms. Taus.

53. The FMSF’s major concern over the years has been about repressed memory retrieval in therapy, lawsuits filed against alleged perpetrators based on those repressed memories which might toll the statute of limitations, the denial of satanic ritual abuse – one of their major focuses - and the denial of the reality of MPD/DID, which they claim is a rare phenomena, if it exists at all. However, because there is no doubt that repressed memory and satanic ritual abuse exists, the FMSF’s purpose appears to have been to simply generate a contrived controversy about these subjects.

54. When victims enter therapy, the very process of discussing one’s past allows access to memories that may or may not have been formally repressed or dissociated. An entire school of psychology called psychodynamic theory is based on the fact that past events can shape future behaviors and many therapists subscribe to this theory. Other schools of psychology, such as Behaviorism, believe that one should treat the client’s presenting symptom such as obesity, depression, and phobias, without looking to the past for the reason for the presenting problem. Dissociative Amnesia (another term for repressed memory) is listed as a mental disorder in both the DSM, Diagnostic Statistical Manual of Mental Disorders [DSM-IV-TR, 2000, pg. 520] and the [DSM-IV, 1994, pg. 478] a textbook for mental health practitioners. The authors of the DSM define Dissociative Amnesia as “the inability to recall important personal information, usually of a traumatic or stressful nature, that is too extensive to be explained by normal forgetfulness,” and “it can be present in any group, from young children to adults.”

55. It appears that one of the first conscious ploys of the FMSF was to rename psychodynamic theory to “Repressed Memory Therapy,” in efforts to provide a straw man for the public and to confound the court system, after which they could blame all repressed memory claims on the “dangerous” Repressed Memory Therapists. The FMSF have been smart enough not to attack victims of abuse directly (or rather, publicly) but instead have chosen the tactic of attacking the therapist by accusing the “Repressed Memory Therapists” of implanting “false memories” in their clients, and/or claiming that MPD/DID is more than likely iatrongenically induced by their therapist. Consequently the therapist should be sued for “malpractice.” However, there is a large body of evidence which proves that it is possible, if not common, to repress a traumatic memory of abuse, and these memories are no more or less accurate than continuous memories.

56. Professor Ross E. Cheit, legal scholar at Brown University, repressed memories of his own sexual abuse by a Camp Counselor. After having recurring nightmares about his abuse, he investigated and discovered other victims of the same perpetrator who abused him. Professor Cheit confronted his perpetrator and was able to record his confession on tape, after which he filed a lawsuit and received a default judgment in a civil claim.

57. Professor Cheit’s case was described in the May 7, 1995 issue of the Providence Sunday Journal, in their three part series titled, “Bearing Witness – A Man’s Recovery of his Sexual Abuse as a Child,” by Mike Stanton.

58. Professor Cheit then compiled an archive of 101 successfully addressed repressed memory court cases which had been corroborated and described his archive which proved repressed memory existed in an article titled, “Consider This, Skeptics of Recovered Memory,” published in the Journal of Ethics and Behavior (1998) 8(2), 141-160. His archive of repressed memory court cases can be found at http://www.brown.edu/Departments/Taubman_Center/Recovmemarchive. As background to his project, Cheit writes:



59. Legal scholar Alan W. Sheflin, JD., M.A. and Daniel Brown Ph.D., also reported on the current state of the science regarding the accuracy of repressed memory in their article titled, “Repressed Memory Dissociative Amnesia: What the Science Says,” published in Journal of Psychology and the Law/Summer (1996). Their abstract reads:



60. In addition, in Doe v. Roe, 955 P.2d 951 (Ariz. 1998), the court reviewed the substantial evidence which proved repressed memory on pg. 956, under, “Mechanics of Memory repression and Recall.” The court stated: “In fact, some preliminary studies suggest that retrieved memories that were formerly repressed are in fact more accurate than normal conscious memory.”

61. Plaintiff believes that this substantial body of evidence proves that repressed memory (or Dissociative Amnesia) exists and it is evident that courts throughout the country have recognized that fact. Plaintiff believes the FMSF knowingly ignores this information and file Amicus Briefs challenging the reliability and admissibility of recovered memories in order to try to prevent a victim from being able to sue their alleged perpetrators in court. Wendy Murphy, J.D. described these facts in the November 1997 issue of Trial Magazine in her article titled, “Debunking False Memory Myths in Sexual Abuse Cases.” The Leadership Council, an organization comprised of professionals in many fields, submit Amicus Briefs in favor of allowing evidence of repressed memory into court proceedings, in opposition to the briefs filed by the FMSF.

62. As previously stated, many MPD/DID’s have been victimized by satanic cults or families, and have sought therapy because of their abuse. However, according to Gail Goodman of UCDavis, FMSF Advisory Board member Richard Ofshe has publicly stated that it is “prima facie evidence of malpractice for therapists to have diagnosed ritual abuse in their clients,” an untempered statement which is obviously false considering how many convictions and social services substantiation of cases which have ritual abuse as the context of the abuse. Obviously someone has to treat the victims and/or perpetrators on these cases.

63. Before 1992 there were several court cases involving perpetrators using Satanism or negative ritual to harm children which Defendants Hopkins, Loftus, reporter Mark Sauer, publisher Defendant Copley, and other Advisory Board members of the FMSF should have been aware of. They are:

63a. [Florida (1984)] In People v. Fuster, Frank Fuster was convicted for child molestation after his wife, Illiana, testified against him and confirmed the children’s allegations. The children claimed Frank and his wife made them play “pee pee” and “poo poo” games. Several of the children could repeat Frank Fuster’s prayers from heart: “Devil I love you. Please take this bird with you and take all the children up to hell with you. You gave me the grateful gifts. God of ghosts, please hate Jesus and kill Jesus because he is the baddest, damnest person in the whole world. We don’t love children because they are a gift of God. We want the children to be hurt.” Frank Fuster’s conviction was upheld on appeal. This case was documented in “Unspeakable Acts” (1986) by Jan Hollingsworth

63b. [Roseburg, Oregon] In State v. Marylou Gallup, 816 P.2d 669 (1991), State v. Edward J. Gallup Sr. 779 P.2d 169 (1989), the Gallups were convicted of sexual molestation. The children stated the Gallups subjected them to satanic abuse and would turn toothpicks into crosses, asking, “Who are we worshipping today children…Jesus.” Then they would turn the crosses upside down and ask, “Who are we worshipping today children…Satan.” Mary Lou Gallup’s conviction was vacated due to a technicality but Edward J. Gallup Sr. and Edward J. Gallup Jr.’s convictions still stand. Bruce McCulley of Cavalcade Productions testified at the California State Advisory hearings about ritual abuse in 1988 about this and other cases of ritual abuse which he and his father, Dale McCulley, later documented on their video, Introduction to Children at Risk: Ritual Abuse in America, 1992, Narrated by Mike Farrell.

63c. [Travis County, Texas (1992)] In People v. Fran and Daniel Keller, No. 3-92-603-CR and No. 3-92-604-CR, the Keller’s were convicted of molesting one child although there were several more alleged victims. The children gave detailed descriptions of the Kellers ritually abusing them in daycare which reportedly sent 7 children into therapy for more than a year. The children described ritual acts: being terrorized in a graveyard, seeing animals killed, being buried alive with animals, painting pictures with bones dipped in blood, being shot and resurrected, being stuck with needles and drugged, and seeing bodies dug up and mutilated with a chainsaw. A child led an investigator to a graveyard where they found animal bones. Parents reported children who were terrified of baths, children who believed they must kill themselves on their birthday, children who were afraid of ponies, fearful they would be put in jail, and children who could conduct a séance, complete with otherworldly “chants.” The Keller’s convictions were upheld on appeal.

63d. [Raleigh, North Carolina (1990)] In State v. Figured 446 S.E. 2d 838, Patrick Figured was convicted of sexually abusing several children. His girlfriend, Sonja Hill, was convicted of indecent liberties with a child on 7/28/93. On March 27, 1990, parents in this case sued Sonja Hill and her mother, Polly Byrd, accusing them of satanically ritually abusing their children which resulted in a default judgment in favor of the parents. Patrick Figured’s conviction was upheld on appeal and Sonja Hills convictions still stands. See Raleigh Man Sentenced to 3 Life Terms for Abuse, News and Observer, Oct. __1992; Johnston Couple Win Child Sexual Abuse Suit, News and Observer, March 27, 1990.

63e. [Thurston County, Washington (1988)] In State v. Ingram, No. 13613-9-II, according to Sheriff Neil McClanahan (personal communication) Paul Ingram, also a Sheriff at Thurston County Sheriffs Department, confessed to satanically and sexually abusing his children. FMSF Advisory Board member Richard Ofshe made an attempt, which failed, to talk Ingram out of his confession. According to a Clemency and Pardons Board Transcript, dated June 7, 1996, both FMSF Advisory Board members Richard Ofshe and Elizabeth Loftus were present at Paul Ingram’s clemency hearing, and asked the Board to release him, claiming he was innocent. However, Paul Ingram’s son appeared at this hearing as well and stated he wanted his father to remain in prison because he had been sexually molested by him as a child. In response, Richard Ofshe claimed that Paul Ingram’s son was blaming his sexual abuse for his “failed” life and questioned the validity of his statements because he thought that was new information. Paul Ingram’s conviction was upheld on appeal.

63f. [Fort Bragg, California (1984)] Department of Social Services shut down the daycare of Barbara and Sharon Orr after physical abuse and satanic ritual abuse allegations. Therapist Pamela Hudson treated dozens of these child victims. She described having no prior experience or training about ritual abuse but came to understand it after many years of treating these particular victims. Some of the symptoms the children exhibited were defecating on the floor in certain patterns, and lying spread-eagled on the floor, as if in crucification. She described children reporting being locked in a cage, their parents were threatened, they were buried in the ground in “boxes,” held under water, threatened with guns and knives, injected with needles, bled and drugged, photographed during the abuse, tied upside down over a “star,” hung from poles and hooks, had blood poured on their heads, and witnessed the ritual sacrifices of babies, after which they were forced to chant “Baby Jesus is dead.” Ms. Hudson, L.C.S.W. documented the satanic element of the alleged crimes in “Treating Survivors of Satanist Abuse,” edited by Valerie Sinason, pgs. 71- 81, 1994, and “Ritual Child Abuse: Discovery, Diagnosis and Treatment,” (Jan 1, 1991). Ms. Hudson also testified at the California State Advisory hearings about ritual abuse in 1988.

63g. [Orlando, Florida (1992)] In the case of James L. Wright and Margie Wright CR0911814-A, Case No. CR0911814-B, the children disclosed sexual abuse in the context of Satanic rituals. The victim's parents met James and Margie Wrights through their Church and Bible classes they attended together. The children reported that they saw James Wright sacrifice a stray dog, slit its throat and stomach, and remove some entrails. He held up the entrails for the children to see and said the same thing could happen to the children if they “tattled.” Sheriff's investigators found the dog's skeleton near the Wright's trailer. A 9 year old girl told investigators that Jim Wright forced her to have oral sex with him at gunpoint. “I didn’t tell because I was scared,” said a boy. “Jim had a gun and said he’d kill my family, and he put a bad curse on us. Jim said devil words to us.” The children spoke of satanic symbols, chalices filled with blood, and a box containing a corpse. The parents of three of the victims moved residences and the prosecutor expressed concern because the children had been threatened by the cult not to testify. Maggie Wright testified against her husband. See “Convict's Wife Sentenced for Trying to Molest Kids,” Orlando Sentinel Tribune, May 9, 1992; “A Family Fears That Satanic Cult Will Try to Silence their Sons,” Orlando Sentinel Tribune, August 10, 1991; “Child Abuse Suspect Trades Testimony for Lesser Charges,” Orlando Sentinel Tribune, January 31, 1992.

63h. [San Francisco, California (1991)] In Aquino v. Stone 957 F.2d 139; 768 F.Supp. 529, internal court documents and news articles document the case of Defendant ex-Lt. Col. Michael Aquino, founder of a Satanist group, Temple of Set, who was processed out of the Army in 1990 after a ritual child abuse investigation. The CID took statements from a child at the Presidio Army Base where he was stationed and took statements from other children in several other jurisdictions in Northern California. Lt. Col. Aquino sued the Army after they "Titled" him under an investigatory report for indecent acts with a child, sodomy, conspiracy, kidnapping, false swearing, and for his dismissal from the active reserves. The standard for Titling is probable cause to believe the offenses have been committed. Only one child victim, the daughter of the Chaplain of the Presidio, was named in the victim block of the CID report, although the word “children” was mentioned throughout the record, which caused some parents to allege a coverup. Mr. Aquino’s process out of the Army and “Titling” was upheld on appeal. However, Aquino was never criminally charged with any criminal offense. Two of the several investigators involved, Glen Pamfiloff and Sandi Gallant, testified at the at the California State Advisory hearings about ritual abuse in 1988.

63i. [Sonoma, California (1988)] People v. Daryl Ball and Charlotte Thrailkill, SCR 14750-C. In this case, the prosecutor’s opening remarks referred to these children’s sexual molestation in the context of ritual abuse. The defendants eventually plea-bargained to child sexual abuse. The CID questioned Charlotte Thrailkill about Michael Aquino and it was alleged (in private statements that the children made to investigators) that Ball/Thrailkill were members of Lt. Col. Aquino’s inner satanic order, or as the children described it, the “Devil worship club.”

63j. [Westpoint, New York (1991)] In the Westpoint Army Base case, the Army made a monetary settlement with several parents who claimed that their children were satanically and sexually ritually abused at their daycare. Several news sources documented the satanic element of the crime and quoted Doctor Walter Grote, parent of a ritually abused children, who refused a promotion in protest due to the Army’s mishandling of this case. The court record of this case is sealed. See “West Point Case Provoked $100 Million Civil Suit,” San Jose Mercury News, August 9, 1987; “A Legacy of Pain,” The Times Herald Record, June 11,1991; “The People v. R. Giuliani,” The Record, Sept. 27, 1987; “Child Abuse at the Presidio, “The Parents Agony, The Army’s Cover-up, The Prosecution’s Failure,” San Jose Mercury News, July 24, 1988.

64. One of the FMSF’s tactics have been to use “recanting” clients as evidence to prove the existence of False Memory Syndrome. “Recantors” are usually clients who had previously been diagnosed as MPD/DID, and who claimed to have been ritually sexually abused by their satanic families or cults but who then decide to turn on their therapists, claiming their therapist “implanted’ them with false memories of satanic abuse. In some of these cases, it appears the therapists have been guilty of very minor infractions, but in a disturbing number of cases there have been allegations made that there is no evidence for satanic ritual abuse, and based on that claim therapists have been accused of “malpractice.”

65. Law professor Alan Sheflin and psychologist Dan Brown investigated 30 “false memory” cases in their article, “The False Litigant Syndrome: ‘Nobody Would Say that unless it Was the Truth,’” published in the Journal of Psychiatry and Law (1999) 27/Fall-Winter, and discovered that in all 30 cases they examined, not one of the therapists appeared to have been guilty of malpractice. Instead the client’s recantations could be attributed to mental illness, shame, guilt, greed, or suggestibility. Another reason why a client might retract their allegations (which they didn’t mention) might also be because they were threatened by their family or cult group, or if they’re MPD, one of their perpetrators might have accessed one of their alters who might not be aware that the abuse took place.

66. During the past 15 years, a silent war has been waged between the FMSF, their supporters, and other legitimate professionals. The FMSF have succeeded in creating a political climate in which ritual victims are too frightened to speak out and therapists are too frightened to treat them. A prevailing pattern has emerged over the years, in that the most vocal proponents who claim SRA exists, appear to have been targeted, either in the court room, by picketing and/or encumbering the resources of their political opponents. Some academic researchers have legitimatized the FMSF over the years in an apparently effort to appear “balanced,” but Plaintiff believes that this organization serves no legitimate purpose. The field of child protection has not moved forward because of their claims, it has moved backward.

67. In the FMSF’s first newsletter (March 15, 1992, Vol. 1 No.1), the FMSF wrote that they were sending FBI’s Special Agent Ken Lanning’s “Guide to Investigators” (1991-92) about ritual abuse to others in which he concluded that he was unable to find evidence for the “extreme” claims of satanic crime, such as cannibalism and murder. This indicates that denying the existence of SRA was one of the FMSF’s first priorities. As of 2/8/2008, a search of the FMSF’s newsletter web site http://www.fmsfonline.org/cgi-bin/nsearch.cgi revealed that this organization mentioned the word “satan” in 124 separate newsletters out of a possibility of 129 files. Nobody knows why this organization is so fixated on the topic of Satanism.

68. In the same time period that FBI Ken Lanning’s report was written, author Michael Newton wrote his book, “Raising Hell: An Encyclopedia of Devil Worship and Satanic Crime,” published in 1993, which described numerous court cases of cannibalism, murder, and torture by satanists. It is therefore unfortunate that a spokesperson for the FBI purported to find no evidence of these crimes.

69. FBI’s Ken Lanning was a consultant for a pivotal 1994 research study, titled “Characteristics and Sources of Allegations of Ritualistic Child Abuse,” co-authored by Gail Goodman, Bette Bottoms, and another researcher. This problematic study was fraught with many irregularities, the most outstanding of which was the failure to correctly include Juvenile Court proceedings in their analysis of Social Services legal mandates.

70. The FBI in general has been accused of incompetency over the years for not taking these cases seriously, which has resulted in cursory investigations, ruining case investigations, and in one instance in Omaha, Nebraska, reported by John De Camp in the book, “The Franklin Coverup: Child Abuse, Satanism, and Murder in Nebraska,” (1996) the investigating FBI agent was alleged to have threatened a victim to recant his abuse.

71. Due to this information it is obvious that there might be a conflict of interest for the government to comment on these crimes. For examples of this documented conduct, see: “West Point Case Provoked $100 Million Civil Suit,” San Jose Mercury News, August 9, 1987; “A Legacy of Pain,” The Times Herald Record, June 11,1991; “The People v. R. Giuliani,” The Record, Sept. 27, 1987;, PAUL A. BONACCI vs. LAWRENCE E. KING, 4:CV91-3037, UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA (February 19, 1999); and “’Through a Glass, Very Darkly’: Cops, Spies and a Very Odd Investigation,” U. S. News and World Report (Dec. 27, 1993) in which the CIA ordered an investigation closed and designated it as a “CIA internal matter” after Custom’s Officials discovered what appeared to be a brainwashing, ritualistic cult, where children were being moved to various locations.


THE SAN DIEGO 1991-92 GRAND JURY

72. Defendant Carol Hopkins of the 1991-92 Grand Jury first came to Plaintiff’s attention after she read a series of remarkably poor recommendations Defendant Hopkins made to CPS and the Board of Supervisors in several Grand Jury reports.

73. In Grand Jury report No. 2 “Families in Crisis” June 29, 1992, in Recommendation #92/35, Defendant Hopkins suggested that alleged perpetrators “should accompany their children to the Receiving Home once the children were removed from their residence.” In Recommendation #92/41, she suggested that alleged perpetrators in sexual molestation cases “should have frequent ongoing visitation with the offending parent, even if only in therapy.” In Recommendation #92/42, she suggested that parents “should have unsupervised visitation with their children.” In Recommendation #92/27, she suggested that the Department of Social Services should “purge from the San Diego County Child Abuse computer all unfounded complaints within 30 days and all unsubstantiated complaints which have remained inactive for one year.”

74. These were all recommendations that for the most part were implemented under the watch of Ivory Johnson, Director of CPS, which were completely contrary to the best interests of children. The facts are: alleged perpetrators should not accompany their children to a Receiving Home once a disclosure has been made about child abuse because it could intimidate the child; children should not have visitations with parents in sexual molestation cases until they have worked through their traumatic issues and are ready to interact with the perpetrator (after the alleged perpetrator has addressed his/her own issues in therapy); parents should not have unsupervised visitations with a child who disclosed child abuse because the perpetrator might force the child into recanting their abuse; the Child Abuse computer should not purge unfounded or unsubstantiated complaints because as child abuse is often a hidden crime, this information can be used at a later time as cumulative evidence in a complex child abuse investigation, especially if the child has been forced to recant during a prior interview with a social worker which might have led to an “unfounded” or “unsubstantiated” case closing code at that time.

75. Defendant Hopkins also stressed in the Grand Jury report that children sometimes “lie” about their abuse. Experienced investigators are aware that although it is a rare occurrence for children to lie about their abuse, it is much more common for perpetrators to lie about whether or not they have abused children. Defendant Hopkins not only stressed that children “lied” but recommended that hearsay evidence be excluded from Juvenile court proceedings.

76. In Report No. 8, “Child Sexual Abuse, Assault, and Molest Issues,” Defendant Hopkins claimed that the 1991-92 Grand Jury had received complaints by families who had been investigated by CPS for SRA and claimed “all of the cases tested rational credulity.” She wrote:



77. Because ritual abuse is not listed as a type of abuse in the Welfare and Institutional 300 Code that is entered into the DOJ child abuse index, the only evidence that is needed to prove a child has been ritually abused before Juvenile Court is to prove physical, sexual, emotional abuse, or neglect has occurred in an abusive Satanic context. That evidence might consist of statements by the child or witnesses indicating that chanting occurred before, during, or after the abuse, statements about blood drawn from the child, or a child placed within pentagrams while being abused. There does not have to be physical evidence to prove that these particular acts occurred, the statements of the victim or witness is considered to be sufficient. Therefore, Ms. Hopkins ideas about what “physical evidence” was needed before being persuaded that satanic abuse was occurring was not based on reality.

78. Given the fact that 134 professionals in San Diego County had just reported in 1991 that they had one or more clients who claimed to be a victim of ritual abuse, and 43 witnesses had testified to the reality of ritual abuse during hearings held by the State of California in 1988-89 in both San Francisco and San Diego, the Plaintiff believed that this outright dismissal of SRA by a San Diego Grand Jury to be either a sign of gross incompetence/ignorance or it pointed to a preconceived agenda.

79. The Sheriff’s Department had just published a manual, “Gangs, Groups and Cults” (1990). Beginning on pg 118, they stated that ritual abuse was an issue in San Diego County which needed attention from authorities. Plaintiff believes all of this information should have been persuasive enough for Defendant Hopkins to be concerned that SRA was occurring in San Diego.

80. Defendant Hopkins also included the FMSF’s position about repressed memory in Grand Jury Report No. 8 stating that, “There is little evidence that a child will repress a traumatic event. There is good evidence that a traumatic event tends to etch itself indelibly on the mind.”

81. The San Diego Community Child Abuse Coordinating Council responded to Defendant Hopkins Grand Jury Report on April 15, 1993 in their report, “Response to Grand Jury Report #8,” stating that members of their committee found that “much of the information contained in Grand Jury Report #8 was contrary to the findings of the best research done in the field, specifically in the areas of repression of traumatic childhood memories and suggestion of children.” They wrote that they did not recognize any of the cases descriptions that she presented, an opinion with which others later concurred.

82. Defendant Hopkins had included in Report No. 8 that she was opposed to Senator Newton Russell’s Bill SB177 which intended to create a State-wide Task force on ritualistic child abuse and she wanted Social Services to take that stand as well. Defendant Hopkins wrote: “The Jury strongly urges the Board of Supervisors and San Diego’s Department of Social Services to oppose this Legislation.”

83. Senator Russell was responding to the recommendations of the 1988-89 State Advisory Board hearings. Hopkins wrote that she was concerned that the Los Angeles County Woman’s Commission on Ritual Abuse Task Force (chaired by Dr. Catherine Gould) might be appointed to this task force and that appointment might constitute a “bias.” In retrospect, Plaintiff believes Hopkins was concerned that this task force might be too successful with Dr. Gould as a member.

84. Defendant Hopkins stated in Report No. 2 “Families in Crisis,” in Recommendation #92/47: “Revaluate the Ritual Abuse Protocol and provide justification to the Grand Jury for the procedures therein.” In Report No. 8, Defendant Hopkins finally writes: “The Grand Jury is aware that the Department of Social Services has reevaluated the investigative protocols on ritual and satanic abuse. The social worker who investigated in this area has been reassigned and the Ritual abuse report is no longer being distributed by the Commission on Children and Youth. This is as it should be.”

85. Plaintiff believes that the statement, “This is as it should be” was a dismissive and arrogant remark to make by a deceptive Grand Juror who was trying to deny that serious criminal activity was occurring. The Social worker Hopkins referred to who was reassigned was someone other than the Plaintiff.

86. Given that Plaintiff was professionally investigating ritual abuse allegations during the time period these remarks were made, and was successfully protecting these children via the system Hopkins was criticizing at the time she was claiming these crimes did not occur, Plaintiff did not think much of Defendant Hopkins position. It appeared that Defendant Hopkins was not aware of Plaintiff at that time, probably because none of the ritual abuse cases she handled were ever publicized in the media and she was never asked to testify before the Grand Jury.

87. In short, Defendant Hopkins quoted the FMSF’s contrived positions on memory, therapy, and ritual abuse in a 1991-92 Grand Jury report, four months after this organizations inception, and suggested that the ritual abuse protocol be withdrawn by CPS. CPS then withdrew the SRA protocol. That meant that the innovative, intelligence, and compassionate work of dozens of professionals intended to protect victims of satanic ritual abuse was cast aside and completely disregarded because of the efforts of what appeared to be a corrupt Grand Jury. Plaintiff believes that CPS abdicated their responsibility, caved in to negative press by the San Diego Union-Tribune, and should be publicly censured for not following through with their obligations to protect children from all types of abuse, even if that type of abuse was controversial.

88. Plaintiff was surprised that a few professionals in San Diego retreated from the topic of ritual abuse, but in spite of writing numerous letters to management over the years, she was powerless to do anything about it. Because of her job description, Plaintiff was too busy to explore the politics of the situation at the time. However, Plaintiff investigated the politics surrounding these issues years later. Plaintiff had mistakenly assumed that the Director of CPS, Ivory Johnson, Linda Walker, or others would respond to Defendant Hopkins report in order to rectify this state of affairs. Due to the fact that it became politically incorrect to mention “ritual abuse” at CPS during this time period, a few supervisors who did not agree with CPS Director Ivory Johnson’s choice to withdraw the SRA protocol continued to assign cases with satanic cult allegations to Plaintiff for investigation because they knew Plaintiff would take the subject seriously.

89. In FMSF newsletter (July 3, 1993 Vol. 1 No. 7), Pam Freyd (who appears to be the main author of this newsletter) reported about the 1991-1992 San Diego Grand Jury’s alleged findings of “systemic abuse.” Specific instructions were given in this newsletter about how to order the 1991-92 San Diego Grand Jury report. Given the heavily biased content of FMSF disinformation which was in this 1991-92 Grand Jury report, it gave the appearance that the FMSF and Defendant Hopkins were actively communicating and working in concert.

90. Defendant Hopkins prior association with FMSF Advisory Board member Defendant Elizabeth Loftus was revealed in an August 20, 1998 article, published in the alternative newspaper, The San Diego Reader titled, “Child Molestation Trial Spot Lights Ongoing Debate,” authored by Tim Brookes. In this article, Defendant Hopkins recounted what occurred during a dinner that Hopkins hosted for FMSF Advisory Board member Defendant Elizabeth Loftus and Defendant reporter Mark Sauer after Defendant Loftus testified for the defense in the Dale Akiki “ritual abuse” case.

91. Defendant Hopkins stated that during the writing of the 1991-92 Grand Jury report she had discussed cases with Defendant Loftus but she believed that she had no prior knowledge of Loftus before that time. When Defendant Loftus entered her home, she told Hopkins her house was very familiar and she believed she was present at her wedding ten years earlier. They looked at the wedding photos and found that Defendant Loftus was there in attendance. This indicates that not only did these people know each other, and obviously colluded during the writing of the 1991-92 Grand Jury report, but it was peculiar that neither one of them remembered their past association. Defendant Hopkins took the opportunity to claim in this news article that people often accused her of being a child molester because of the unpopular positions that she took. (Hopkins later made this same false complaint about Plaintiff). Plaintiff wrote a letter in response to this article as well as researcher Constance Dahlenberg, which was published in the Reader on September 3, 1998. Dr. Dahlenberg wrote:



92. District Attorney Edwin Miller replied to Defendant Hopkins reports on Oct. 30, 1992, stating in part:



93. Mr. Miller’s concern that Defendant Hopkins misrepresented child abuse cases that his office had investigated in the 1991-92 Grand Jury report was later proven to be true by the subsequent 1992-93 San Diego Grand Jury. Although Defendant Hopkins was instrumental in stopping the court proceedings involving a man named Jim Wade, which appears to have been appropriate, DA Miller wrote an extensive reply to her analysis of this case, corrected her many misrepresentations and provided an adequate explanation as to why the case was filed. All of this information provides a clear pattern of conduct by a Grand Juror who appeared to be blatantly attempting to undermine child abuse victims.

94. Defendant Hopkins then disclosed in a December 5, 1994 San Diego Union newspaper article titled, “She Righted Wrongs: But Former Grand Juror Carol Hopkins, Credited with Saving Families, Struggles with her Own,” by Clark Brooks, that although Hopkins was married she had an “affair” with the legal counsel of the 1991-92 Grand Jury, Senior Assistant Attorney General of San Diego, Gary Schons, although they maintained that their affair began after the Grand Jury report was dismissed.

95. Gary Schons had been assigned to the 1991-92 Grand Jury because the District Attorney’s Office had a conflict of interest due to the fact that their office was under investigation by the 1991-92 Grand Jury. However, Plaintiff believes that Defendant Hopkins’ admission indicates there was also a conflict of interest between the Attorney General’s office and the 1991 Grand Jury due to their “affair,” even though they maintain it occurred after the Grand Jury was dismissed. Defendant Hopkins also stated in this news article that she opposed the re-election of DA Ed Miller and that Paul Phingst was her candidate of choice for the Office of the District Attorney.

96. Gary Schons went on over the years to align himself with the viewpoints of the FMSF and made statements about the Eileen Franklin case that equated repressed memory with “voodoo evidence” as documented in a San Diego Union-Tribune article dated March 24, 1996 titled, “Memories Revisited/Murder retrial would mean tough fights for both sides,” by Mark Sauer. It read, in part:



97. Of course, Mr. Schons statements are not correct and indicated a bias towards the FMSF’s contrived positions on the workings of memory. Pam Freyd mentioned Gary Schons in two FMSF newsletters. In newsletter May 1, 1996, Vol. 5 No. 5 Freyd published Schons’ book review of “Convicting The Innocent: The Story of a Murder, A False Confession, and the Struggle to Free a Wrong Man.” In this review Mr. Schons made statements about the Dale Akiki case – a case which had allegations of ritual abuse – that do not appear to be true. He claimed that “Dale Akiki, who in 1991 was charged with multiple counts of child molestation based on therapeutically retrieved memories of 3 - 4 year - olds from a church day, was acquitted after the longest and costliest trial in San Diego history.” However, according to DA Ed Miller’s formal response, most of the children first disclosed abuse to others before disclosing to their therapists. In the FMSF’s newsletter 2007, Vol. 16, No. 3, Mr. Schons book review was again referred to by Pam Freyd.

98. Defendant Hopkins could not have succeeded in shutting down the topic of ritual abuse at CPS and the District Attorney’s office without two reporters from the San Diego Union Tribune [SDUT], Jim Okerblom and Defendant Mark Sauer, contributing to it and Defendant David Copley choosing to publish these articles.

99. Before 1992 there were several news articles published in the San Diego Union-Tribune written by several different authors which reported favorably about satanic abuse. They were: “Satanic Rites Can Put Children at Risk, Panel Says,” Feb. 28, 1988 by Ed Jahn; “Ritual Child Abuse: Horrible, but True,” April 17, 1989 by John Gilmore; “Religious Revival Takes on Topic of Satanic Worship,” July 22, 1989. by Bob Rowland; “Satanism Upswing Seen in County,” Jan 28, 1991 by Michael Bunch; “Mexico Witch Doctor Accused of Killing 41 in Sacrifices,” July 28, 1990 by Nancy Cleeland; “Defense Claims Brainwashing Inducted Slaying,” Aug. 30, 1990 by Valerie Alvord.

100. In 1991/92, Jim Okerblom and Mark Sauer began reporting about ritual abuse and repressed memory on behalf of Defendant publisher David Copleys, San Diego Union-Tribune full time. The following articles demonstrate an ongoing pattern by the SDUT and Mark Sauer, specifically, to deny the reality of repressed memories and satanic ritual abuse. Later, when Plaintiff describes Defendant Mark Sauer’s invasive and defamatory newspaper articles about her, it should be clear that this reporter and publisher was biased against professionals or researchers who investigate satanic ritual abuse.

101. Jim Okerblom began by writing a series of biased articles about CPS cases in the San Diego Union-Tribune involving alleged sexual molestation and ritual abuse which resulted in the dismissal of the Juvenile court petitions. These articles were titled, “Kids taken from Grandparents on Unchecked, Dubious Cult Claims,” Nov.8, 1991 and “Children Lose out in Zeal to Protect,” January 19, 1992.

102. In all of these cases, it was perfectly appropriate for CPS to have investigated, but it did not appear that these reporters understood CPS legal mandates or the risk factors associated with sexual abuse or ritual abuse allegations. It is unfortunate that due to confidentiality reasons CPS cannot respond to newspaper reporters about individual cases, thus leaving a gap in the publics awareness about the logic behind CPS’s actions, which leaves it open for disreputable others to malign this agency for the wrong reasons.

103. In SDUT article, “Psychologists’ Meeting Takes a Closer Look at Ritual Abuse,” Jan. 25, 1992 (by Jim Okerblom) the reporter quoted information from a survey claiming that 800 psychologists throughout the United States reported treating a total of 5, 731 patients who alleged ritual or religious based abuse. Okerblom stated that this information was similar to the survey conducted in San Diego which also indicated that many therapists claimed to be treating ritual abuse survivors which was described in the Ritual Abuse Protocol for CPS. Okerblom reviewed the fact that he had covered three cases in which ritual abuse allegations had been made but had not been substantiated. Okerblom then claimed that the “Institute for Psychological Therapies” had begun a study of the phenomena, inferring the information in these surveys was false. Mr. Okerblom wrote:



104. Response: A survey which reported 5, 731 separate ritual abuse allegations was phenomenal and should have served as persuasive evidence that ritual abuse was occurring to any rational adult. That the reporter had discovered three ritual abuse allegations that were “false” (and that’s questionable) does not mean the phenomena did not exist at all. In the wider world of general CPS allegations of physical, sexual, emotional abuse, and neglect, a good number of allegations turn out to be unsubstantiated, meaning there was not enough information to prove or disprove the allegations at the time, and a smaller number are deemed unfounded. Experienced investigators would never claim that if a few incidents involving allegations of neglect were found to be false, that cases of neglect never occurred. Likewise with incidents of ritual abuse. To take such a position was very irresponsible, especially in the same news article which reported thousands of people reporting allegations of ritual abuse. In addition, the Institute for Psychological Therapies that Okerblom quoted belonged to Ralph Underwager an FMSF Advisory Board member who made supportive pro-pedophile comments in Padaika – journal for pedophiles.

In SDUT article, “Child-Molestation Trial Spotlights Raging Debate – Is Accused Man Abusive Monster or is he a Victim?” Feb. 6, 1992 (by Jim Okerblom) the reporter described the upcoming criminal case of Dale Akiki, a man who had been employed by Faith Chapel’s daycare, as a case with ritual abuse allegations although the prosecution was not claiming that ritual abuse took place. Okerblom covered the case from the viewpoint of the defense and quoted FMSF Advisory Board member Richard Ofshe who criticized therapists:



106. Response: Therapists who treat clients involved in court proceedings are mandated to investigate the veracity of the claims of the children involved. Plaintiff believes this reporter used Richard Ofshe to make negative commentary about the validity of ritual abuse, in order to negatively impact the potential jury pool on the Dale Akiki case.

107. In SDUT article, “Jury Report on Child Protection Reviewed,” Feb. 8, 1992, Jim Okerblom/Wilkins) the reporter positively reviewed the 1991-92 Grand Jury recommendations such as Hopkins’ attempts to disallow hearsay evidence in Juvenile Court, withdraw immunity statutes that govern social workers and physicians, and her recommendations that once a child has been removed from the home a social worker should be assigned who was immediately “dedicated” to reuniting the family. Okerblom also publicized Hopkins recommendation to revaluate the county’s protocol about ritual abuse at that time. Okerblom wrote:



108. Response: In these particular cases, the children were removed from their homes due to a doctor’s initial diagnosis of sexual molestation. These children were not removed from their home based on allegations of “satanism” alone.

109. In SDUT article, “Trial Ordered for Akiki on 52 Counts of Child Abuse, Kidnapping,” Feb. 14, 1992 (by Okerblom) the reporter described the Akiki case and quoted FMSF’s Ralph Underwager’s claims that therapists drove children into “fantasies” after multiple interviews:



110. Response: Dr. Ralph Underwager was paid a lot of money by defense attorneys to convince jury’s that children would “fantasize” about satanic cult activity, but Plaintiff believes that the normal fantasy life of a child does not include being victimized by satanists.

111. In SDUT article, “Falsely Accused Parents File Claims,” Mar 28, 1992 (by Okerblom) the reporter described a lawsuit filed by the Wallis’s who had their children removed briefly by CPS after an allegation of ritual abuse. Okerblom wrote:



112. Response: Jim Okerblom stated quite factually that these parents were “falsely accused” of planning to sacrifice their 2 year old son to Satan during the Fall Equinox. However, nobody knows with certainty whether those allegation were true or not. The petitions filed on behalf of these children originally included sexual molestation allegations, but they were later dismissed due to a difference in opinion regarding the validity of the sexual molestation diagnosis and because County Counsel felt there was no longer enough evidence to keep the children in protective custody. The child in question was released after the time period in which he was alleged to be at risk of being murdered. At CPS, some people believed that if the allegations were true, but could not be proven, the fact that this case was heavily publicized might have protected that child. Based on the original evidence of sexual molestation, and allegations of a child’s upcoming murder, CPS had every right to intervene in this case, and it was very irresponsible of the SDUT to attempt to undermine CPS as an agency for taking these allegations seriously.

113. In SDUT article, “Report Rips Handling of Abuse Cases,” June 30, 1992 (by Okerblom) the reporter wrote that the 1991-92 Grand Jury recommended that the standard of proof in sexual molestation cases should be increased to “clear and convincing,” rather than the standard of “preponderance of evidence. Okerblom wrote:



114. Response: Because child molestation is often very difficult to prove, erring on the side of protecting the child seems the most reasonable approach. If “preponderance of the evidence” is the standard used in civil cases, Plaintiff believes that same standard should be applied in a Juvenile court setting. The 1991-92 Grand Jury had no reason to state that therapists might be contaminating children with false memories of satanic ritual abuse. Therapists “suggestion” of abuse does not occur on a regular basis in child abuse cases. Claiming that “false memories” can be implanted by psychotherapists on a regular basis was the position of the FMSF. On rare occasions in child abuse cases, forensic tapes of a child interview are sometimes made after a child has already disclosed abuse to multiple parties. Plaintiff is aware of some cases in which the child already disclosed abuse to their parent or doctor but then the child became frightened or refused to speak during the forensic interview. As a result of the forensic interviewer’s awareness of what the prior statements of the child were, the interviewer might prompt the child to remember. It is the prompting that is recorded on tape for defense attorneys to analyze. Without knowing the context and history of the disclosures, these tapes can be then used by the defense to claim that the interviewers or therapists were “suggesting” abuse to children.

115. In SDUT article, “Did Merced Jury Pirate San Diego Report?” July 9, 1992 (by Okerblom) the reporter wrote that the 1991-92 Grand Jury report, “Families in Crisis” had been widely circulated around California but another County had plagiarized this report:



116. Response: Plaintiff believes this article was indicative of irregularities that might have been occurring in other counties, perhaps due to Defendant Hopkins interactions with those counties. It is unfortunate that Defendant Hopkins mailed out her later to be revealed biased and deceptive Grand Jury report to multiple officials throughout the State. At best, this report could have been used to shut down investigations of ritual abuse in agencies, believing that the 1991-92 Grand Jury report contained accurate information. At worst, other people with an agenda may have used her report to intentionally undermine children in their local jurisdictions.

117. Jim Okerblom and Defendant Mark Sauer then wrote a three-part series, published by Defendant David Copley in the SDUT – beginning with “Haunting Accusations, Repressed Memories of Childhood Abuse: Real or Delusions,”) Sept, 13, 1992 (Mark Sauer-Okerblom) – in which they continued to quote the False Memory Syndrome Foundation for the people of San Diego, making this organization appear righteous and “scientific.” In the second article in their series, “Recall Experts Say Therapists Create Hysteria,” Sept 14, 1992, Okerblom/Mark Sauer quoted the FMSF and their Advisory Board members again. In “Group Therapy Triggered Phony, Hellish Memories,” Sept. 14, 1992, Sauer and Okerblom quoted a story of a “retractor” without questioning whether the retraction was true or not. In “Undocumented Demons – Therapist, Church, Cops Caught up in Tales of Atrocities,” Sept. 15, 1992, the reporters were somewhat even-handed. In their article “Satanism is on the Fringe in Repressed Memory Cases,” Sept. 15, 1992, Mark Sauer-Okerblom clearly sided with the defense position by denying that ritual abuse occurred based on the claim that there was no evidence.

118. Pam Freyd wrote in a FMSF’s newsletter, dated October 5, 1992 (Vol. 1 No. 9), that readers should access Mark Sauer/Okerbloms three part news series entitled “Haunting Accusations: Repressed Memories of Childhood Abuse: Real or Delusions,” mentioned above, which makes it appear the FMSF was working in concert with these two reporters, based on the content of these newspaper articles which overly represented the FMSF’s contrived positions on the workings of memory and the complete denial of satanic ritual abuse.

119. In article, “Alleged Murder-Plot Target Says He’s Victim of “Memory’ Therapy,” Dec. 15, 1992 (by Jim Okerblom) the reporter described a daughter’s attempts to have her father, a psychiatrist, killed after undergoing “repressed memory psychotherapy.” The reporters favorably quoted the False Memory Syndrome Foundation’s claim that they had found 2000 cases of “false memory.”

120. In SDUT article, “Do Therapist Plant Memories of Abuse,” Dec. 27, 1992 (by Mark Sauer/Okerblom) the reporters briefly described the upcoming prosecution of Dale Akiki, and referred to CPS’s Ritual abuse Protocol as a “booklet” which had been withdrawn:



121. Response: Even though this article appeared to support both sides of the argument, Defendant Sauer and Okerblom concluded their story by quoting an ill-advised comment by FMSF Advisory Board member Richard Ofshe who compared ritual abuse therapy with lobotomies, which was clearly meant to undermine victims of ritual abuse and the therapists who treat them.

122. In SDUT article, “Tales of Terror at Church Nursery Raise Urgent, Troubling Questions,” Dec. 27, 1992 (by Defendant Mark Sauer/Okerblom) the reporters wrote a fairly even-handed article about the ritual abuse trial of Dale Akiki. However, they claimed:



123. Response: The Akiki case was filed after a Grand Jury heard 33 witnesses and after multiple parents claimed that their children were terrified of Dale Akiki. Trying to create a simple cause and effect scenario such as timing the allegations with the airing of a movie was very unlikely.


THE 1992-1993 SAN DIEGO GRAND JURY



124. In 1992-93, due to complaints made by then District Attorney Ed Miller and CPS, another San Diego Grand Jury was convened which corrected the misrepresentations that were made in the 1991-92 Grand Jury report. In Defendant Hopkins attempts to sway the Board of Supervisors and the public into believing that the System was “out of control,” she had misreported about individual child abuse cases and her analysis was found to be false and misleading.

125. In Report No. 13, dated June 29, 1993 titled, “Protect the Child, Preserve the Family,” although appearing to minimize what appears to have been corruption by the 1991 Grand Jury, the 1992-93 Grand Jury proceeded to correct the 1991-92 Grand Jury’s misrepresentations about several child abuse cases and described these cases in more accurate terms. The 1992-93 Grand Jury stated in their report:



126. Because of Defendant Hopkins’ obvious bias and prolific misrepresentations which undermined children, she earned a very bad reputation in San Diego with those involved in child protection.

127. The San Diego Union-Tribune’s editorial policy continued to support the FMSF and continued to deny that ritual abuse occurred. In SDUT article, “Therapists Find Cures are Matter of Lives and Deaths,” August 20, 1993 (by Tiffany Porter) the reporter wrote about a “Past Life Regression” author who was to speak at a conference. Pam Freyd of the FMSF was quoted as stating:



128. Response: This statement by Pam Freyd (originally made by FBI’s Ken Lanning) is commonly made to deny the reality of ritual abuse. Regarding past lives, there are large numbers of people who believe in reincarnation, in fact, most of the entire Eastern hemisphere of the world. Tibet has teams of religious specialists who track the reincarnation of Lamas or Rinpoches. There are many examples of small children who are questioned who give personal and specific answers about the personal lives of the Lamas in question. These children are then specially schooled in the Tibetan Buddhist tradition believing that they are the reincarnation of an enlightened teacher. Pam Freyd is not an example of a sophisticated source who knows the answers to anything as complex as “past lives,” or about the enduring life of the soul. Regarding the growing number of people reporting “abduction” experiences by “aliens,” no one knows the answer to the questions raised by these alleged victims. All that is known is that a significant number of people are reporting distress which is enough reason to seriously investigate the phenomena. Hypnosis is sometimes used in these cases to refresh a “victim’s” memory of an already remembered unusual encounter. Pam Freyd’s poor attempts to undermine victims of ritual abuse by denouncing all three phenomena in one sentence has never been persuasive evidence to Plaintiff that ritual abuse does not occur.

129. In SDUT article, “Satan-Chasers Real Terrorists in Witch-hunts,” Sept. 7, 1993, (by Defendant Mark Sauer) the reporter stated:



130. Response: At this point in the SDUT’s coverage, Mark Sauer did not appear to pretend to objectively report anymore but had an obvious agenda to deny that ritual abuse occurred, given not only the title of his article, but the content. Because satanists are known to terrorize and torture their children, Mark Sauer’s attempts to intimate that professionals who investigate these subjects were the “real terrorists,” bespeaks of simple-mindedness and an agenda. In this article he also irresponsibly characterized County officials as “pathetic” and “misguided” in clear attempts to intimidate these individuals and agencies.

131. In SDUT article, “Psychology on Trial-Akiki Case Raises Questions on Reliability of Psychotherapy,” Nov. 14, 1993 (by Defendant Mark Sauer) the reporter quoted FMSF Advisory Board member Defendant Elizabeth Loftus during the prosecution of the Akiki case:



132. Response: Plaintiff has extensively documented the evidence that proves repressed memory exists which indicates that FMSF Advisory Board member Elizabeth Loftus must not be interested in telling the truth.

133. In SDUT article, “Was Akiki Inquiry Rush to Judgment- Police Work in Similar Case Averted Trial,” Nov. 22, 1993 (by Okerblom and Mark Sauer) the reporter described Dale Akiki’s acquittal and sided with the defense by writing that all of the children’s unusual allegations were skillfully shown by defense attorney Kate Coyne to be the “product of their imagination which had been fueled by therapy.” Sauer then described another child abuse case which allegedly too included “bizarre” allegations and made the following remark:



134. Response: There are several reasons why children might make allegations that seem incredible at the time but are later clarified. According to Senator Newton Russell’s office, the child in question who claimed to see giraffes killed in the Dale Akiki case actually testified that wallpaper had elephants and giraffes on it and the wall paper was repeatedly stabbed by the perpetrators. In this article, Okerblom and Sauer clearly stated that ritual abuse had been “discredited” and was a “myth” and again inappropriately named specific individuals in apparent attempts to intimidate them and ruin their reputation. And despite these news reporters attempts to make it appear the eight children in the Akiki case had disclosed abuse after “months in therapy,” this was untrue. According to DA Ed Miller, in his 1994 response to the 1993-94 Grand Jury report, he stated that they (these reporters) misstated testimony during the Akiki trial, that five of the eight children who disclosed abuse made their disclosure first to persons other than their therapists. Of the remaining three children, they made a disclosure to their therapist in the first few sessions which is completely contrary to how Mark Sauer described this case.

135. In “Grand Jury Urged to Examine Akiki Case’s Handling,” Dec. 2, 1993 (by Okerblom) the reporter described Board of Supervisor Dianne Jacob asking for a grand jury investigation of the Akiki case, with “help from the State Attorney General’s Office.” Supervisors Brain Bilbray and Pam Slater urged changes in the way therapists are used in child-abuse cases, in part because of issues raised by the Akiki case:



136. Response: It appeared from this article that Carol Hopkins ex-boyfriend Gary Schons might have been the legal advisor for the 1993-94 Grand Jury as well as the 1991-92 Grand Jury. That is troubling because Mr. Schons appeared to favor the illogical and indefensible FMSF viewpoints. On every case Plaintiff addressed with ritual abuse allegations, she referred the children to an experienced therapist who was familiar with the subject matter. To have done otherwise would have been very poor practice, considering the level of expertise that is required to understand ritual abuse, let alone to have the courage to address it. It appears that this article is further evidence indicating that Mark Sauer was using his position at the SDUT to intimidate professionals who worked with ritual abuse by his selective quoting. He quoted Brian Bilbray’s claim that satanic ritual abuse allegations were a “virus.” He quoted Pam Slater irresponsibly describing professionals as “bozos,” and Dr. Smith’s characterization of satanic ritual abuse as “a lot of bull.” Plaintiff believes that due to the continual publication of this type of biased material it caused San Diego CPS and other agencies to inappropriately retreat from investigating the subject of satanic ritual abuse.

137. On November 24, 1993, Plaintiff wrote a letter which was published in the San Diego Union-Tribune in response to Jim Okerblom and Defendant Sauer’s biased articles about the supposed nonexistence of ritual abuse. The Plaintiff’s letter was published, but the SDUT deleted her list of convictions involving ritual abuse. Plaintiff’s letter read, in part:



THE 1993-94 SAN DIEGO GRAND JURY



138. In 1993-1994 a Grand Jury was convened which investigated the prosecution of Dale Akiki and the District Attorneys office’s handling of this case. Their report was titled, “Analysis of Child Molestation Issues,” Report No. 7, June 1, 1994, and they made recommendations to the District Attorney’s Office and Board of Supervisors that were both shocking and contrary to the interests of children. They recommended that County of San Diego should completely withdraw the standing Multi-victim/Multi-perpetrator Ritual Abuse protocol. In recommendation # 94/50, they then advised the District Attorney’s office and the Board of Supervisors about San Diego County:



139. This recommendation appeared to be very clear efforts to try to cover up satanic crime in San Diego County. For an ostensibly legitimate governmental body - like a Grand Jury - to instruct a District Attorney’s office to ignore and not prosecute a horrific form of child maltreatment indicated to Plaintiff that corruption was occurring, and this is how they accomplished it.

140. In the body of the 1994 Grand Jury report, the authors quoted Defendant Elizabeth Loftus - Advisory Board member of the FMSF, Ken Lanning of the FBI, and quoted from Dr. Gail Goodman and Bette Bottoms 1994 research study titled, “Characteristics and Sources of Allegations of Ritualistic Abuse,” a study which Plaintiff believes was not a legitimate study but was instead intended to minimize allegations of ritual abuse.

141. This research study made it appear that only a small group of therapists were reporting ritual abuse allegations in obvious attempts to make it appear that ritual abuse should not be taken seriously, when in actuality, when one reads the actual study, the researchers received overwhelming evidence that proved satanic ritual abuse occurred. Dr. Goodman and Bette Bottoms then proceeded to claim that their study proved that generational Satanism did not exist but their victim-perpetrator relationship scale only measured one generation of possible abusers and did not allow for other extended family members to be scored. These researchers then purported to describe the legal findings of hundreds of Social Services agencies in the United States but they neglected to include Juvenile court proceedings, petitions filed, or the legal outcomes, which indicated that these researchers were either woefully ignorant of the subject that they were researching or they fabricated their study. Instead, they mistakenly or purposely used social worker opening and case closing codes of substantiated, unsubstantiated, and unfounded to describe legal proceedings. This study has been used world-wide to make the claim that the “scientific” field found no evidence for satanic ritual abuse. FBI’s Ken Lanning was the advisor on this study. Plaintiff requested an explanation from the lead researcher in 2008 for these and other discrepancies but she was met with silence.

142. The 1993-94 Grand Jury and Defendant Mark Sauer of the San Diego Union-Tribune continued to criticize the District Attorney’s office for prosecuting the Dale Akiki case. In SDUT article, “Miller Faulted by Grand Jury on Akiki Case,” June 2, 1994 (by Mark Sauer/Wilkins, Krueger) the reporters cited the 1994 Grand Jury’s “key findings” that the County had wasted time and money:



143. Response: The “findings” of the 1991-1992 and 1992-1994 Grand Jury’s were completely unacceptable and that two San Diego Grand Juries focused on denying the reality of satanic ritual abuse points to a larger problem in San Diego which has not been clearly identified. Plaintiff believes, again, that there is nothing wrong with therapists screening allegations of child abuse for true and false reports during court proceedings and in fact that is their job.

144. DA Ed Miller commented in his August 31, 1994 response to the 1993-94 Grand Jury that when confronted with complaints from several of the parents of alleged victims in the Akiki case about Jim Okerblom’s coverage of the proceedings which had been inaccurate and biased, Mr. Okerblom had stated that he did not care what the parents thought since his reporting was going to result in his receiving a “Pulitzer prize.” Mr. Miller went on to describe the coverage of the Akiki case as being “biased to the point of being nothing short of disgraceful.” Mr. Miller also described the 1993-94 Grand Jurors as in “over their heads” regarding their analysis of what took place in the Akiki trial. He questioned why there had been so many attacks on advances made to protect children and noted that there was a nationwide trend to attack child abuse prosecutions and prosecutors.

145. Between the years 1992-1994 Senator Newton Russell of California had worked on passage of a penal code which became law in 1995 as 667.83 which added a sentence enhancement to child abuse crimes which were committed in the context of ritual abuse. This action was taken due to the hearings which were referred to earlier in 1989 in California. However, the authors of the 1991-92 and 1993-94 San Diego Grand Jury report attempted to stop the passage of this law and the formation of a State Ritual Abuse Task Force, a fact which was chronicled in the historical archives of Senator Newton’s legislation which Plaintiff retrieved.

146. In the Assembly Office of Research Report, dated March 1, 1994, the author wrote a very skeptical response about allegations of ritual abuse and recommended that no commission on ritual abuse be created. The Akiki case in San Diego was described, reporting that a child accused Akiki of “killing a Giraffe.” The rebuttal to this report stated, again, that the child in question testified that wallpaper with elephants and giraffes on it was repeatedly stabbed. On pg. 14 of their report, the 1991-92 San Diego Grand Jury report’s conclusions were quoted: “The Jury had heard reliable expert testimony that it is a mistake to force a child to relive and keep talking about an alleged traumatic event. Further, there is little evidence that a child will repress a traumatic event. There is good evidence that a traumatic event tends to etch itself indelibly on the mind.”

147. This type of extreme misstatement of fact was routinely made by the FMSF. In other words, Pam Freyd’s disinformation campaign reached as far as the California State Legislature in 1994 in efforts to shut down the topic of satanic ritual abuse in opposition to the recommendations of the 1988-89 State Advisory Board hearings.

148. In the Assembly Committee on Public Safety report, dated June 14, 1994, the report cited the defense portrayal of the Akiki case by claiming the children were “fanciful” which casted “doubts on the proposition that children never lie in describing their experiences with sexual abuse.” They quoted from the 1993-94 San Diego Grand Jury report:



149. Congressman Eppell insisted that Penal Code 667. 83 should have a provision that mandated all counties that convicted people under this sentence enhancement to send in form 8715 so that the DOJ could gather statistics and decide in three years [1998] whether the law should sunset or not. In Plaintiff’s opinion, three years was too brief a time to canvass the prevalence of ritual crime in the State of California, and she thought it might be difficult collecting statistics, at least in San Diego, because the DA’s office in San Diego County and perhaps other counties were refusing to investigate allegations of satanic ritual abuse at all.

150. In SDUT article, “Chasing Satan in Sacramento – Zealous Senator Pushes Law Adding Ritual Abuse Penalties,” June 16, 1994 (by Defendant Mark Sauer) the reporter compared the efforts of Senator Newton Russell’s attempts to pass this sentence enhancement to the Red Scare and the Salem Witch Hunts:



151. Response: This disrespectful news article about Senator Newton Russell’s attempts to pass Penal Code 667.83 – the ritual abuse sentence enhancement – was very inappropriate. Senator Newton’s efforts to pass legislation on behalf of a vulnerable class of victims – children of satanists - is not comparable to what occurred in the Communist “Red Scare.” Sauer failed to disclose the fact that what appeared to be two rigged San Diego Grand Jury reports and his news articles were used by the State Assembly Office of Research to oppose this Task Force on Ritual Abuse for the State of California. In this news article, Mark Sauer quoted FMSF Advisory Board member Jeffrey Victor to refer to members of governments who believe that ritual abuse exists as “fools.” Although Mark Sauer quoted Senator Newton’s aide, Ms. Mc McElhenny, as stating she did not “know” of any ritual abuse cases in California, that is very difficult to believe because she was privy to the findings of several investigations of ritual abuse that took place in California.

152. Plaintiff corresponded with Senator Russell’s office several times during this time period and was asked to write a letter about her experiences investigating ritual abuse to aid in the passage of this law. Consequently, Plaintiff was very interested in seeing that Penal Code 667.83 remained on the books which did become law in 1995. The penal code read, in part:



153. Penal code 667.83 did unfortunately sunset in 1998 and the County of San Diego contributed to that occurrence due to the 1991-92 and 1993-94 Grand Juries highly suspect recommendation to the Board of Supervisor to withdraw the standing CPS SRA protocol and their recommendation that the District Attorney’s office (and apparently CPS) not investigate SRA cases.

154. In 1995 Plaintiff wrote a letter to the Office of Criminal Justice Planning, in efforts to force CPS to gather statistics about ritual abuse, but they never replied.

155. In SDUT article, “A Frightening True Story of Recovered Memory,” Book Review, May 15, 1994 (by Defendant Mark Sauer) the reporter positively reviewed a book titled, “Remembering Satan a Case of Recovered Memory and the Shattering of an American Family” by Lawrence Wright which purported to describe the SRA case of Paul Ingram in the State of Washington, but Wright’s bias was extreme throughout. At the end of this article, the San Diego UnionTribune identified Mark Sauer as the “reporter who was covering the repressed memory issue.” Sauer wrote:



156. Response: This case just described was about a confession of sexual and satanic ritual abuse made by Thurston County Sheriff Paul Ingram which his supervisor Sheriff McClanahan believed wholeheartedly. The court records clearly document that the court did not find Richard Ofshe’s opinions about this case to be persuasive. Although Mark Sauer referred to Ofshe as a psychologist, Plaintiff believes Ofshe is actually a sociologist. In this article, the SDUT clearly reported that Mark Sauer was assigned coverage of the repressed memory issue. That indicates that SDUT publisher Defendant Copley approved of Mark Sauer’s coverage - which was obviously intentionally skewed in favor of the FMSF - and the position of defense attorneys when they involved prosecutions of satanic ritual abuse.

157. In SDUT article, “Memory Verdict Sends a Message,” May 15, 1994 (by Defendant Mark Sauer) the reporter described Gary Ramona’s civil case which involved his daughters “repressed memories” of child molest in which a jury found in his favor. Pam Freyd of the FMSF was quoted:



158. Response: The SDUT continued to quote the notorious organization, the FMSF, without ever once questioning whether this organization might have an agenda. Mark Sauer also continued to misreport the facts: Pam Freyd is not a “psychologist.”

159. In 1993 Plaintiff submitted a research proposal to the head of Social Services Cecil Steppe and asked for part-time status so that she could report back about issues such as ritual abuse, suggestive interviewing, and repressed memory. However, Mr. Steppe and director Ivory Johnson denied Plaintiff’s request. Plaintiff decided to continue this research anyway on her own time in addition to her full time investigatory work load.

160. In 1993 Plaintiff formed the Ritual Abuse Court Cases Project in efforts to canvass District Attorneys who had successfully handled cases involving ritual abuse in order to provide objective evidence that this type of crime existed due to what at first appeared to be a “backlash” in San Diego County. At that time there were approximately 14 cases convictions involving ritual abuse in the United States which had been gathered by researcher and film documentarian Dale McCulley. Between the years 1996-1998 Plaintiff researched legal resources and law libraries which resulted in the discovery that there were many appellate courts which upheld Satanism as the motive for the crime.

161. In 1998, Plaintiff published the results of her research on the internet in an archive titled “Satanism and Ritual Abuse Archive” which included over 60 court cases documenting satanic crime and/or ritual abuse. In 2007, Plaintiff updated this archive and it is presently posted at several web sites including  HYPERLINK "http://www.endritualabuse.org/ritualabusearchive.htm" http://www.endritualabuse.org/ritualabusearchive.htm [Exhibit 2].

162. Defendant Carol Hopkins continued to hold positions of responsibility in San Diego County. According to news article, “DA Pfingst Gains Respect in Half-Year at the Helm,” by July 2, 1995 by Anne Krueger, after taking office in 1995 Paul Phingst appointed Defendant Hopkins to a committee that reviewed child abuse cases that were submitted to the District Attorneys office. This was in spite of the fact that the 1992-93 Grand Jury reported that the previous Grand Jury had caused harm within the system and seriously mischaracterized child abuse cases in Ms. Hopkins efforts to make it appear the “system was out of control.”

163. In SDUT article, “Foes Assail Repressed-Memory Therapy,” Dec. 1, 1994 (by Defendant Mark Sauer) the reporter favorably reviewed Ofshe’s book, “Making Monsters: False Memories, Psychotherapy and Sexual Hysteria” and FMSF’s Elizabeth Loftus’ book, “The Myth of Repressed Memory: False Memories and Allegations of Sexual Abuse.” Sauer publicized that FMSF’s Richard Ofshe was to appear at a conference the next day. In this article, after giving an example of a therapist asking a client what they thought a dream meant, Sauer wrote:



164. Response: In this article Sauer was using Richard Ofshe to denounce traumatic amnesia as a “hoax,” and it was an obvious attempt to deny that the psychological disorder of MPD/DID could hide the fact that sexual and satanic cult abuse occurs due to the dissociation of the victims.

165. In SDUT article, “’Repressed Memory’” Deconstructed as Quackery with a Heavy Price,” (by Defendant Mark Sauer) Dec. 18, 1994, 18 days after the publication of the article described above, Mark Sauer again favorably reviewed the same books previously described by FMSF’s Richard Ofshe and Elizabeth Loftus about “reckless and destructive therapy.” At this point, Mark Sauer’s news coverage was becoming repetitive, which is a common propaganda technique used when disseminating mis/disinformation. Sauer repeated the extreme FMSF position again and wrote:



166. In SDUT article, “Repressed Memory Care a ‘War Zone’” Apr. 11, 1995 (by Defendant Mark Sauer) the reporter discussed a documentary by Ofra Bikel “Divided Memories” about repressed memory. Sauer introduced Bikel by the following comment:



167. Response: Sauer misreported on the facts yet again: “Innocence Lost” was actually about the brutal torture and murder of three young boys in the state of Arkansas which the State described as a satanic ritualistic killing. These convictions were successfully upheld on appeal and the appellate court upheld the satanic motivation for the crime. [902 S.W. 2d 781 (1995)]. In addition, which has been previously reported, Professor Cheit of Brown University created his archive of repressed memory cases in response to Ofra Bikels misinformation about that subject, specifically in the film “Divided Memories.”

168. In SDUT article, “Mending a Broken Trust, 11 Years After he Sent her to Prison, Son Brings Mom Home,” Dec 17, 1995 (by Defendant Mark Sauer) the reporter wrote about a recanting teenager who gave testimony as a child about his mother’s satanic abuse in Bakersfield but who later won her release by recanting. Sauer quoted defense attorney Martin Snedekker who successfully overturned a series of ritual abuse cases in Bakersfield as saying:



169. Response: This article reported that it was the defense attorney who introduced the topic of recanting to this teenager which apparently Mark Sauer never thought was odd.

179. In SDUT article, “Teen Says Parents Were Wrongfully Convicted/Case was originally thought to be a Satanic Sex Ring,” Jun 18, 1996 (by Defendant Mark Sauer the reporter described Carol Hopkins having a recanting teenager in her custody by the name of Sam Doggett from Wenatchee Washington. This case was originally thought to be a sex ring and multiple defendants either plea-bargained or were convicted of child molestation in the late 1990’s in Wenatchee, Washington. Mark Sauer purported to quote statements by this teenager:



171. Response: Mark Sauer described Sam Doggett attending a rally on behalf of the Justice Committee (Hopkins’s organization) which was dedicated to ending the “nearly 15 years of child-abuse-prosecution hysteria in this country.” Plaintiff believes that it was very inappropriate for Defendant Hopkins to have had a “recanting” witness in her custody when Defendant Hopkins had an interest in overturning her parents conviction in what is commonly referred to as the Wenatchee Sex Ring. According to a Press Release on November 26, 1995, Ms. Hopkins called for an apple boycott to bring attention to the “falsely” accused in Wenatchee Washington. In this press release it also stated that Carol Hopkins was the co-founder of the Dale Akiki support organization.

172. The Plaintiff was shocked to read years later in a message by Defendant Hopkins, posted on the internet Witchhunt List-serve (message 9575, dated March 3, 2000) that the Director of CPS, Ivory Johnson, had personally supervised the placement of this recanting child from the Wenatchee Child sex ring in 1995 with Hopkins as a special favor for Ms. Hopkins. This type of placement and supervision was highly unorthodox as Ms. Johnson was an administrator, not a line social worker, and Defendant Hopkins was a direct party in the case of this child because she was taking a public stand on behalf of her already convicted parents, in efforts to overturn their convictions. In normal CPS placements, the social worker decides whether or not the caretaker of the child can protect the child. That assessment would include the caretaker believing that the child was abused especially if there was every indication that this is what occurred. A social worker in normal circumstances would never place a child with a party who was trying to overturn the conviction of the parents because that would indicate that the caretaker was not protecting that child but was operating on behalf of the abuser. The fact that this occurred in this case points to unethical conduct and a conflict of interest. Plaintiff also seriously doubts that teenager Sam Doggett made the comparison between her parent’s case, the Akiki case, and the McMartin case, and believes it more likely that Mark Sauer wanted to make that statement and used Sam Doggett name to do so.

173. In SDUT article, “Day of Contrition, a Gesture of Solace for the Falsely Accused,” January 14, 1997 (by Defendant Mark Sauer) the reporter described Carol Hopkins’ publicity stunt, a “Day of Contrition Revisited” and described her organization the Justice Committee as an advocacy group for defendants it claimed were falsely accused. She brought together playwrights and defendants specifically who had been acquitted of ritual abuse. Mark Sauer writes about Ms. Hopkins:



174. Response: This newspaper article made it appear as if Defendant Hopkins believed that all ritual abuse offenders who had been convicted were actually innocent, which indicates that Hopkins had a decidedly unobjective position, and points to the possibility that Ms. Hopkins might be in favor of satanic ritual abusers not ever being prosecuted for their crimes. Apparently, Hopkins’ allusions to “misguided therapy” referred to the disinformation in the SDUT about the Dale Akiki case being a product of therapist suggestion. Sauer also quoted Defendant Hopkins as stating the belief that satanic ritual abuse ever occurred was “outlandish.”

175. In “Some Therapies Just ‘Crazy,’ says Authors,” January 14, 1997 (by Defendant Mark Sauer) the reporter reviewed FMSF Advisory Board member Margaret Singer’s (deceased) claim that the therapy field was a haven for “whakos” and “charlatons” which included therapists who “convinced” clients that they were UFO abductees or were victimized by satanic cults. Sauer quoted FMSF Advisory Board member Margaret Singer remarks about “crazy therapies”:



176. Response: Again, Mark Sauer was trying to align UFO Abduction experiences with satanic ritual abuse victims and continued to malign therapists who treat these victims using another FMSF advisory board member to make his case.

177. In SDUT article, “Town Without Pity, Mean Justice Exposes Abuse of Power, Bakersfield Division,” March 7 1999, Book Review (by Mark Sauer) the reporter favorably reviewed a book about the “Kern County Witch Hunt” in Bakersfield and the appellate courts decision that reversed some convictions of people accused of ritually abusing children in that County:



178. Response: An objective new reporter would never have described a ritual abuse investigation as “idiotic.”

179. In “Parents of 2 Seized Kids to get $750,000 – Escondido Case Arose from Story of Satanic Threat,” Nov. 2000 (by Defendant Mark Sauer) the reporter described the eventual settlement between the Wallis family and the Escondido Police Department after two courts dismissed the suit, and two appeals courts reinstated it:



180. Response: Mark Sauer dismissed a horrific crime that actually occurs - satanic ritual abuse - as a “scare,” making it appear there was no substance behind these allegations, and then reported with some satisfaction that the Ritual Abuse Task Force was disbanded in San Diego. Mr. Sauer then repeated the mis/disinformation about this case which was found in court records and the appellate documents describing this case. It was alleged that Social workers had to have a court order before removing a child from a dangerous home environment. That is completely untrue. Juvenile courts are not open 24 hours a day, yet children are removed from their homes at all hours of the night and taken to a receiving home, which in San Diego is called Polinsky Center. Court orders could not be obtained in that circumstance even if a social worker wanted one.

181. In SDUT article, “Abuse or Unfounded Fear - Either Way, Talks to Delve into Ritual Child Torture,” Sept. 21, 02 (by Defendant Mark Sauer) the reporter recounted his version of the Akiki prosecution failure and described the subsequent lawsuit against the county as “driving a stake through the heart of America’s ritual abuse witch hunt.” Sauer claimed that an upcoming conference about ritual abuse taught by Dr. Ellen Lacter, a colleague of Plaintiffs, sponsored by the 7th International Conference on Family Violence, meant ritual abuse was making a come-back into public awareness, which he was obviously against. Sauer wrote that District Attorney Paul Pfingst expressed “grave concerns that a widely attended and influential conference would feature workshops on ritual abuse, since he has seen no evidence that such cases exist”:



182. Mr. Phingst sent several Grand Jury members to attend this particular ritual abuse workshop so that they could report back to him about the content. Mark Sauer continued to claim in this article that there was no “evidence” for ritual abuse even though by that time he had read Plaintiff’s Satanism and Ritual Abuse Archive, as future events will reveal. Paul Phingst’s statements were certainly not the statements of an impartial District Attorney because he openly stated that he did not believe that ritual abuse occurred. This information revealed that ex-DA Pual Phingst’s office was not taking allegations of satanic ritual abuse seriously and was apparently refusing to investigate this topic at all while he was in office. Plaintiff believes this points to malfeasance.

183. Despite the fact that 11 letters that were sent to the San Diego Union-Tribune in response to Defendant Mark Sauer’s news article quoting Paul Phingst, not one single letter was published, which indicates, in addition to the many inappropriately biased newspaper articles that have been described, that the editorial policy of the SDUT was dedicated to describing contrived positions about repressed memory and the ritual abuse of children, and the public was not allowed input.

184. Pam Freyd too wrote in the FMSF’s September/October 2002 Vol. 11 No. 5 newsletter about this conference. Ms. Freyd wrote that there was no evidence to support the existence of satanic cults or “satanic conspiracies” and admitted to writing letters to the sponsors of this conference in attempts to get them to denounce the workshops. According to Dr. Ellen Lacter, Defendant Carol Hopkins also wrote letters in opposition to this workshop. Freyd complained in her newsletter that the organizers of the conference sent out a letter to the sponsors in response to her opposition letters which described the FMSF as a “fringe advocacy organization” and “mostly composed of those accused of abusing their own children.” Pam Freyd wrote: “It seems that we were naïve to think that the topic of ritual abuse had been resolved. Let us hope that the general climate is such that we don’t need to fear a return of the hysteria about ritual abuse and recovered memories of the early 1900’s.”

185. Clearly Pam Freyd’s agenda is dedicated to denying the fact that SRA occurs. In recent years, Pam Freyd has tried to soften the FMSFs position in some forums by claiming that although it might be possible to repress a traumatic event, one cannot know with certainty whether that repressed memory was accurate or not without corroboration. The problem with this type of position is that it undermines all eyewitness testimony. Witnesses commonly report that events take place and they retrieve that information from their “memory.” Eyewitness testimony has standing in courts throughout America and the veracity of that testimony is based on the observation of the witness and what appears to be their truthfulness.

186. In the FMSF Foundation Newsletter, March-April 2004 Volume 13 No. 2, Pam Freyd wrote about the $10.6 million settlement awarded to Patricia Burgus and her family after she retracted her allegations of SRA in 1997 and sued her psychiatrist for “implanting” false memories. Freyd wrote:



187. Plaintiff believes that this quote by FMSF founder Pam Freyd gives the impression that she was trying to intimidate therapists who treat victims of ritual abuse victims.

188. In summation, Defendant Mark Sauer has been the official spokesperson for the San Diego Union-Tribune about “repressed memory” and appears to be the reporter assigned to the coverage of allegations of satanic ritual abuse. Unfortunately, Mr. Sauer’s newspaper coverage about these subjects has been found to be repetitively simple-minded, inaccurate, misleading, and a disservice to the citizens of San Diego County. Mr. Sauer has failed to report that satanic ritual abuse is actually widespread and is occurring throughout the United States and the world. Over the years, in his articles about ritual abuse, Sauer quoted other people who described ritual abuse as “mythical,” “misguided,” “discredited,” “a virus,” “bull,” a “hoax,” “outlandish,” “fringe,” “dreams,” “false memories,” “hysteria;” “idiotic,” and “claptrap.” Mark Sauer described SRA allegations as coming from a “strange little corner,” “therapist inspired,” “witchhunts,” similar to the “red scare,” “lobotomies,” a “satanic panic,” “fantasies,” “phony,” “delusions,” “bizarre,” and equivalent to “space abductions.” Sauer also quoted other people who described professionals who believed in or investigated ritual abuse (including a State Senator) as “fools,” “ghettoized,” “true believers,” “crazy,” “incompetent,” “pathetic,” “bozos,” “misguided,” “whakos,” and “charlatans,” and even claimed in the title of one of his article that it was the “Satan-Chasers” who were the real “terrorists,” not ritual abusers who torture children. Sauer and others also used the trick of sleight of hand; anyone who believes in single instances of ritual or satanic ritual abuse must also believe in a “world-wide satanic conspiracy.”

189. This history provides an overview about the ties and the serious irregularities involving two Grand Juries, the 1994 DA’s office under the leadership of Paul Phingst, Mark Sauer and the San Diego Union-Tribune. The positions of the Assistant Attorney General’s Office in San Diego is questioned because Mr. Schons was quoted as stating that there was no evidence to support the reality of repressed memory, apparently due to the influence of Ms. Hopkins and the FMSF.

190. Plaintiff used to believe that it was a possibility that efforts to minimize satanic ritual abuse activity, especially by FBI’s Ken Lanning, came from genuine concern and his efforts were geared toward downplaying a sensational crime which might lead to public panic or “witchhunts” against innocent people. Lanning argued that by making unprovable ritual abuse allegations it might make it more difficult to prosecute sex crimes against children. Plaintiff does not believe these arguments have any merit: If there was more sophisticated knowledge about satanic ritual abuse it could only lead to more truthful case outcomes. If prosecutors routinely chose to educate juries about case convictions and the modus operandi involving satanic cults, the suffering of victims of ritual abuse would be validated, institutionalized, and there would no longer be a strategic need to down-play ritual abuse activity in child sexual abuse cases; a strategy which in actuality does not protect children, it only results in leaving an entire population of abuse victims without a voice.

191. Not only does it not appear that what occurred was a societal “backlash,” in San Diego or elsewhere, in other words expected collective societal denial and retreat from a topic due to collective defense mechanisms (too much to bear) or attempts to rectify excesses, after analyzing the arguments of the opposition and watching their behavior for a decade or more, Plaintiff believes that Satanists and their supporters have orchestrated a systematic defense in order to cover up the fact that their children, en masse, began disclosing the reality of satanic practices and horrific criminal conduct for the first in this century. The fact that some perpetrator/victims dissociate contributes to this type of criminal behavior remaining hidden and Plaintiff believes that is how generational evil perpetuates itself.

192. This information provides motivation as to why Defendants Carol Hopkins, Mark Sauer, David Copley, Dr. Elizabeth Loftus and the FMSF in general, might want to ruin Plaintiff’s reputation and career after she proved the reality of satanic ritual abuse on the world-wide web and later publicized facts about what she believed was corruption in San Diego County.

193. Because Plaintiff wanted to publicize what took place with Defendant Hopkins and the 1991-92 and 1992-93 Grand Juries, she gave this information to author Alex Constantine, after which he published a chapter in his book “Virtual Government,” [1997] entitled, “Acclaimed 1992 San Diego Grand Jury Child Abuse Report Found to be Fraudulent by Subsequent Grand Jury.”


CENSORSHIP AND VIOLATION OF PLAINTIFF’S FIRST AMENDMENT RIGHTS TO FREE SPEECH ON THE WORLD WIDE WEB 1995-2000


194. In 1994 Plaintiff befriended a CPS intern, “Joan,” who disclosed that her child had been ritually abused at the Presidio Army Base in San Francisco, California in the late 1980’s. Joan told Plaintiff about all parties involved in the investigation which included a satanist, Lt. Col. Michael Aquino who along with his wife Lilith were High Priest and Priestess of their satanic cult, the Temple of Set. “Set” is the name of the evil Egyptian deity who predates the Christian “Satan” in the Bible. Defendant M. Aquino remained on active duty in the Army Reserves while leading this satanic cult for 20 years. Defendant M. Aquino’s background included a Ph.D. in Political Science and he was considered to be a specialist in Intelligence, Psychological warfare, and propaganda. Joan claimed that although the army reached a settlement agreement with the parents, the perpetrators were never criminally charged, and she thought that there had been a cover-up. Plaintiff agrees with this position and will use this section to document what she discovered about the government’s complicity in the intentional creation of Multiple Personality Disorder which uses satanic ritual abuse as a trauma base.

195. Plaintiff’s colleague and friend Dale McCulley had followed the Presidio Army Base case and other ritual abuse investigations in Northern California. In fact, Mr. McCulley believed that because he became aware of these facts, his wife was deliberately killed in a car accident. A cult member had given Mr. McCulley this information shortly after the accident occurred.

196. Mr. McCulley sent Plaintiff two appellate documents about the Presidio case and Defendant M. Aquino proving that he had been processed out of the Army in 1990 after a multi-jurisdictional sexual abuse investigation. The San Francisco Police Department had declined to file criminal charges against Defendant M. Aquino, but in 1988 the Criminal Investigative Division [CID] of the Army continued to investigate the allegations of abuse.

197. According to Aquino v. Stone, 957 F.2d 139 (1991), Aquino v. Stone 768 F.Supp. 529 (1992), and internal court documents to his case, Defendant M. Aquino was “Titled” in a Report of Investigation for indecent acts with a child, sodomy, conspiracy, kidnapping, and false swearing. For unknown reasons, the CID chose to release their ROI three months after the statute of limitations ran. The child abuse charges remained against Aquino because, according to the CID, the evidence of alibi offered by LTC Aquino “was not persuasive.” Afterwards, Defendant M. Aquino claimed “damages” because of his discharge from the service which he attributed to the inaccurate records about him. According to Aquino v. Stone, 957 F.2d 139 (1991) it clearly stated that Lt. Col. Michael Aquino was suing for his discharge from the service. The document read, in part:



198. According to internal documents to his case, Lt. Col. Aquino was charged with false swearing after he tried to force the court martial of the Presidio Chaplain for reporting his own child’s alleged abuse at Aquino’s hands. Aquino mailed himself a postcard which had the invective “blow it out your ass,” and attributed it to the Chaplain. It was later revealed that the Chaplain and his family did not reside in the area from which the postmark was mailed and so Aquino was charged with false swearing.

199. Other parents in Northern California openly accused then Lt. Col. Aquino of satanically ritually molesting their children at that time. In a May 17, 1989 San Jose Mercury news article titled, “Mendocino County Cops, Parents Seek Help in Child Abuse Probe,” the parents gave an interview. The following information was reported:

“Ritual Sex Abuse of children has been under investigation in Mendocino County since at least 1984, when several children at the Jubilation Day Care Center in Fort Bragg said they had been sexually abused, tortured and forced to drink blood and eat feces. Debi Withrow, a Ukiah mother of two children who told police and Army investigators that [Michael] Aquino abused them, said parents and hope that their ‘children will have their day in court.’ Another parent, Dee Hartnett of Santa Rosa, said her daughter also told authorities that [Michael] Aquino was one of the people who abused her in Mendocino County in 1986. The daughter testified against two of her abusers in a case in Santa Rosa that resulted in plea bargains last year. One of the accused Daryl T. Ball was sentenced to prison for 4 years in connection with the abuse of Hartnett’s daughter and five other children. The other, Charlotte Thrailkill, was sentenced to 14 years in prison.”

200. Of additional concern was the fact that, according to a November 16, 1987 article published in Newsweek titled, “Second Beast of Revelation,” then Lt. Col. Aquino referred to himself as the Anti-Christ. Defendant Aquino is also interested in the Nazi’s, believing himself to be the son of a Nazi SS officer. Both the Temple of Set and the Church of Satan had a group called the Order of the Trapezoid which has strong Nazi leanings.

201. After the Plaintiff discovered the internet in 1995 she decided to use it as an opportunity to investigate cult groups, undercover, on her own time and publicize the reality of ritual abuse in a worldwide forum due to the cover-up of ritual abuse in San Diego County. Plaintiff was careful not to reveal any philosophical tenets, personal disciplines, details about employment, or the fact that she was a therapy intern while on the internet because the FMSF appeared to be targeting therapists, and Plaintiff did not want to be on anyone’s “hit” list. Therefore, during the time Plaintiff was on the internet, she debated about crime only and did not reveal too much information about her beliefs or her profession but she did disclose that she had studied the occult for many years. That meant that nobody knew what to make of Plaintiff when she wrote to alt. pagan and alt.satanism, under the pseudonym of “Curio Jones” and “Karen Jones,” about ritual crime, as she obviously wasn’t a Christian extremist.

202. In 1995, Plaintiff posted several news stories and the Appellate documentation about Defendant Lt. Col. Aquino’s dismissal from the Army to alt.pagan and alt.satanism from American Online [AOL] after Plaintiff noticed that Aquino wrote to alt.satanism. Plaintiff did not make much comment, but posted the documents only. Plaintiff considered Aquino’s case to be potentially pivotal in providing evidence about satanic ritual abuse because he was a High Priest of the second largest open satanic organization in the country, the Temple of Set [TOS], who was investigated and apparently consequented (although not criminally charged) after a ritual child molestation investigation.

203. Defendant M. Aquino responded to these articles in alt.satanism claiming that the facts as Plaintiff presented them did not occur. Plaintiff then received an email warning from a “LeGrant” on August 20, 1995 who claimed that her posts were defaming Dr. Aquino. He said her facts were not correct and they mirrored Linda Blood’s book “The New Satanist” which resulted in a lawsuit against Linda Blood and Times/Warner publisher. LeGrant reported that after this lawsuit it resulted in the book being “pulled from the shelves.” Le Grant said he would report Plaintiff to the System Administrators for American On Line if she did not discontinue her messages. However, System Administrators are usually not responsive to anyone except the person claiming “libel” which makes it reasonable to assume that Defendant M. Aquino was the party who complained to AOL. Plaintiff’s articles were then immediately cancelled, and she was told not to post messages to that newsgroup anymore, which in effect was censorship.

204. Plaintiff contacted Ms. Blood about the status of her book and the lawsuit filed against her by Defendant Aquino. Ms. Blood told her that even though there was a settlement agreement, she and Warner books could rightly assert that the lawsuit was without merit and it was settled simply to avoid court costs. She also stated her book had not been “pulled from the shelves.”

205. Because Defendant M. Aquino appeared to have influence with AOL, and it was a clear infraction of Plaintiff’s first amendment rights to free speech because no libel had occurred, Plaintiff found another internet company overseas from which to post –anon.penet.fi

206. At first Defendant M. Aquino accused Plaintiff of being Linda Blood who was his ex-girlfriend. Then Defendant M. Aquino and his wife, Lilith Aquino, proceeded to willingly debate with Plaintiff under several different pseudonyms such as hansrkr@aol.com, rennet@aol.com, gollux@aol.com and lancepryne@aol.com. Plaintiff and the Aquinos debated in detail about the facts as stated in the appellate documents and about other ritual abuse cases in the United States and around the world.

207. Robert M., Defendant Aquino’s fellow satanic cult member from the Temple of Set, wrote in a message dated February 11, 1996 that Plaintiff was wrong in her assessment about the demise of Lt. Col. Aquino’s military career and listed a series of titles of what appeared to be military documents. Plaintiff continued to interact with Defendant M. Aquino because, as an investigator, Plaintiff was authentically interested in learning what his defense position was and wanted to access more information about this case.

208. According to news sources, Defendant M. Aquino’s had inherited a multi-million dollar fortune in property in the late 1980’s and Plaintiff was later told Aquino tripled his real estate holdings. Because of his wealth, Aquino was able to file frivolous lawsuits against others as a means of intimidation. He also had a history of intimidating people who investigated or wrote about the Presidio case. Those who had investigated or had written about this case had formal complaints filed against them, which included Linda Goldston, reporter for the San Jose Mercury News, and San Francisco Police Inspectors Pamfiloff and Gallant. Some people found themselves frivolously sued, such as Time/Warner and Linda Blood who wrote the “New Satanists” in 1994 and Craig Lockwood who wrote the book, “Other Altars” in 1993, which too described Defendant Aquino’s process out of the Army.

209. In other instances, Defendant M. Aquino’s forte was writing very polite, intelligent, but affronted letters, with his Ph.D. signed after his name, which does impress many people. Because one of the functions of military intelligence is to disseminate propaganda, Plaintiff learned about many propaganda techniques by watching Defendant M. Aquino’s tactics on the internet during this time period. Those techniques include misinformation, disinformation, confusion tactics, misdirection, diversion tactics, and the “Big Lie,” which is a tactic used when there is no other alternative. The technique of “revisionism” is used in order to rewrite the history of whatever occurred that is not favorable to the propagandists.

210. At the beginning of this lawsuit it was alleged that the FMSF appeared to be interested in providing fraudulent defenses for satanic cults by, among other tactics, claiming that the therapists who treated cult victims intentionally planted “false memories” of satanic cult involvement into their client’s minds. In 1995 a self-described generational Satanist posting in alt.satanism, Defendant satanist Tani Jantsang, who was founder of the organization the “Satanic Reds,” came to Plaintiff’s attention. Plaintiff never wrote to Defendant Jantsang during this time period because she thought she appeared to be unstable. Defendant Jantsang wrote to satanist Robert M. that he should never deny that Satanists committed crimes because she did not believe that these extreme statements made satanists appear credible when defending themselves against those who provided evidence which proved criminal conduct was committed by them. Instead, Defendant Jantsang wrote that of course Satanists commit crime, and provided information about a better tactic:



567. Unfortunately, Mr. Kucinich’ Bill was withdrawn. But what is important in reviewing this paper trail is that Congressman Kucinich had enough information which convinced him that space-based weapons were being used on the public for “mind control” purposes, and he wanted to bring those concerns into the public arena and make it illegal to victimize a human being on this level. If this Bill had passed, Plaintiff believes it would have made “Voice to Skull” [V2K] devices, “Voice Synthesis Devices,” and the usage of Extremely Low Frequencies [ELF] as a weapon illegal because, as it clearly states on the Center for Army Lessons Learned website, it is by the usage of space-based satellites that “voices” are transmitted, which indicates these are space-based weapons.

568. Defendants M. Aquino, Scott L, M. D., and others told Plaintiff numerous times that they were monitoring her by technology which involved human/computer interface. It was clear they could not only send their voices to Plaintiff but they could also read her thoughts and could communicate with her sometimes for hours at a time. Plaintiff discovered that not only is it possible to send “voices” to a selected target but current “Mind-Reading” capability is quite provable.

569. In a Washington Times article, dated August 17, 2002, “NASA Plans to Read Terrorists Minds At Airports,” it was reported that NASA’s Ames had the ability to “read minds.” It read, in part:



570. Shortly after this article was published, NASA issued a statement denying that they had “mind reading” capability, but they are lying. The means to do this is fully operational and the public needs to be informed that this technology exists. It appears NASA was concerned that they might be sued by Privacy organizations because of their illegal surveillance capabilities. Further, NASA AMES was the organization named in this article who can “read minds,” and it was NASA AMES who first made contact with Plaintiff in early 2001, via then some unexplained type of telepathic contact.

571. In addition to the fact that at times Plaintiff had lengthy conversations with various individuals who could “read” her mind, they could access her dreams and visualizations as well. Plaintiff discovered that the ability to monitor visualizations was within the capability of “mind-reading” technology by the usage of Magnetic Resonance Imaging [MRI], and surprisingly documentation of this technology’s existence is documented on several mainstream web sites. What is missing in the following articles is the fact that not only can the brain/mind be imaged for nefarious purposes but the entire body can be targeted as well.

572. The following articles describe the usage of MRI’s to read a subjects mind. In one article titled, “Mind-Reading Machine Knows What You See,” dated April 25, 2005, published on the internet site NewScientists.com, it discussed the ability to monitor the visualizations of a subject. It read, in part:



573. Mind-Reading technology was also documented in a February 5, 2006 article, published on the Guardian Observer’s web site titled, “We are Moving Ever Closer to the Era of Mind Control, The Military Interest in New Brain-scanning Technology is beginning to Show a Sinister Side.” It read, in part:



574. In a December 2006, 48 page report titled, “US Electromagnetic Weapons and Human Rights” by Peter Phillips, Lew Brown and Bridget Thornton of Sonoma State University, they cite their concerns about Electromagnetic Frequency [EMF] devices and human rights violations. It reads, on pg. 3:



575. In addition to the above information proving that “mind-reading” capability is a reality, in 2002 Plaintiff received a report which had been ostensibly filed in Civil Court under the Civil case name and number, John St. Clair Akwei vs. NSA, Civil Action No. 92-0449. This report was published on the internet and purported to describe the inner workings of the National Security Agency [NSA] in regards to their surveillance capabilities via computer/brain interface which was referred to as “Remote Neural Monitoring.” Because Scott L. had told Plaintiff he worked for the NSA, Plaintiff read this report with interest.

576. John St. Clair Akwei (or someone using his name - which is what Plaintiff believes occurred after she investigated) did file a lawsuit against the NSA, but it was cursory, poorly written, was 6 or so pages, and he did not appear to be the same personality who wrote the sophisticated, detailed information about the inner-workings of the NSA which is posted on the internet under the case name and filing number of the Akwei lawsuit. Plaintiff sent for this case and discovered that this report was not in the case file. There could be many reasons for that, but one possibility is that someone knowledgeable about the NSA took the opportunity to disclose illegal activity by the NSA under the cover of this lawsuit.

577. This report explained in some detail how the NSA monitored people by computers (which they referred to as Remote Neural Monitoring) which had been occurring for at least the past 15 years. In brief, excerpts from the document reading John St. Clair Akwei vs. NSA, Ft. Meade, MD, USA, read:



578. The above information described clear attempts, allegedly by the National Security Agency, to remotely implement illegal Mind control and surveillance operations/programs on the public and Plaintiff has every symptom it describes.

579. Plaintiff discovered United States Patent No. 3,951,134, dated April 20, 1976, invented by Robert G. Malech, which explained how the preceding description of the NSA’s activities – Remote Neural Monitoring – or monitoring the brain waves of a human subject from a remote location was achieved. The abstract reads:



580. In Patent No. 6,011,991 invented by Aris Mardirossian on January 4, 2000 titled, Communication system and method including brain wave analysis and/or use of brain activity and documents the ability for two-way communication via computer/brain interface and satellites, the Abstract and Description reads:



581. It is overwhelmingly clear, based on these Patents, that it is possible to have two-way conversations with a target by remotely monitoring the brain waves of that target via satellite and computer/brain interface.

582. Because of this capability, Plaintiff had other reasons to be concerned when her perpetrators threatened that because of their illegal surveillance capabilities they were now aware of the numbers of Plaintiff’s bank accounts, her credit card numbers, her pin numbers, and the names and addresses of her relatives.

583. From May 11, 2001 to November 2002, Defendant Aquino and others kept Plaintiff busy almost 24 hours a day by experimenting on her with the above described technology and other technology yet to be revealed. At one point, Plaintiff stayed awake for 7 days without eating and found little to no need to sleep because of the non-stop assault and communication.

584. Plaintiff began seeing unexplained phenomena on almost a daily basis. In approximately June 2001, about 11PM, Plaintiff was driving down an off-ramp, onto the highway, when she saw a low-flying triangular shaped craft, coming directly toward her car. It then disappeared in a flash. The Plaintiff was so frightened by this, she put her car into reverse and illegally sped backwards, up the off-ramp, to another off-ramp, which went in the complete opposite direction on the freeway. The Plaintiff wound up driving aimlessly around the Grossmont College campus, and then heard a supportive sounding voice telling her to get out of her car and to immediately get under a truck because the “ET’s” were going to try to “transport” her. The Plaintiff hid under a truck and saw several more objects in the sky that appeared to be some type of craft.

Plaintiff discovered a list of terms by an expert in remote assault weaponry which explained how it was possible to induce visual phenomena to a target. According to “Nonlethal Weapons: Terms and References,” by Robert J. Bunker, Editor, for the USA Institute of National Security Studies, posted at http://www.usafa.af.mil/inss/OCP/ocp15.pdf, under the term “HOLOGRAMS,” it reads:



586. The usage of holograms might explain why Plaintiff began seeing unusual visual imagery. If Plaintiff had described this and others types of visual imagery she was eventually subjected to, it might have caused a mental health professional to mistakenly diagnose Plaintiff as experiencing “visual hallucinations.”

587. From May 11, 01 to the present, March 2008, in addition to being psychologically attacked by V2K, Plaintiff has been physically attacked by remote assault weapons. They include Electromagnetic Radiation weapons which can cause the bodily tissues to heat from a distance (in other words, cause burns), radio-frequency weapons, pulsed microwaves and acoustic weapons. After Scott L. told Plaintiff that advances in fifth dimensional physics partially explained how Plaintiff was being targeted, Plaintiff believes that the latest sophisticated assaultive classified technology available is a combination of computer/brain interface, voice to skull technology, and Virtual Reality Telepresence, in which the target is the Virtual Reality landscape. Coincidentally, this technology was researched by NASA AMES in the early 1990’s. Plaintiff was eventually told that her perpetrators were using virtual reality headgear and that this technology produced a computer image of the target on computers which were portable, enabling the perpetrator to assault the target from any location. Plaintiff believes that Virtual Reality Telepresence capabilities need to be fully investigated.

588. Defendant Aquino, Scott L. and M.D. told Plaintiff that their intent was to injure her as much as possible internally but not so severely that the medical community would be able to document the injury, which is the very definition of nonlethals – the ability to torture someone without leaving a trace of evidence. This ability to secretly torture was discussed in a news article titled, “Invisible Beam Tops List of Nonlethal Weapons,” by Greg Gordon, June 1, 2004, published in the Bee Washington Bureau.

589. Other terminology that describes this weaponry is documented in a report titled, “Nonlethals Weapons, Terms and References,” by Robert J. Bunker, dated December 1996, (referred to earlier) He describes:



590. Throughout May 2002 to the present, Plaintiff has been hit in the head repeatedly by a weapon that felt like a blast. Beginning in 2003 to the present, Defendants M. Aquino, his wife, Lilith Aquino, Scott L., M. D., Robert M., his wife, Peggy N. and Peter G. and Kevin F. have tormented Plaintiff by directing this weapon into the interior of her head. At first it was difficult for Plaintiff to read simple language after being assaulted in this way but she eventually learned to compensate. The report further describes the capabilities of this technology:



591. Throughout May 2001 to 2003, Plaintiff experienced being shoved several times by some unknown means, several times so hard that she fell down on her knees. Defendant M. D. and Scott L. would assault Plaintiff’s muscle groups and the cartilage in her knees, telling Plaintiff she would be so thin and crippled that the medical community would be diagnose her with Muscular Dystrophy. They also told Plaintiff they were assaulting her glandular system in order to try to cause subtle changes in her body. Plaintiff’s weight had been stable at 118 for 20 years, but as a result of that damage, in addition to being forced into taking psychotropic medication for five years by the criminal justice system, Plaintiff now weighs 180 pounds. The report continues:



592. For the past seven years, since May 2001, Scott L. has hit Plaintiff with a blast of energy in her stomach region which causes her to vomit.

593. Defendants M. Aquino and Scott L. have told Plaintiff that they used the facilities at Scientific Applications International Corporation [SAIC] in San Diego, Lawrence Livermore Laboratory, Sandia Laboratory and NASA AMES to target Plaintiff.

594. In a paper titled, “US Electromagnetic Weapons and Human Rights,” dated Dec. 2006, authored by the Media Freedom Foundation from Sonoma State University, the authors mention that due to private military contractors not needing to respond to FOIA requests, private corporations like Aardvark Tactical, Inc., Ionatron, and SAIC, were free to develop nonlethal weaponry without much oversight. They write:



595. In approximately June-July 2001, Plaintiff was exercising with the Chinese martial art Tai Chi - which is meant to circulate internal energy - when she collapsed and was left in a weakened state for several weeks. Scott L. eventually confessed to Plaintiff that he had been experimenting, trying to impact Plaintiff’s atomic field from a distance from Lawrence Livermore Laboratory, and that she was his “science project.”

596. Plaintiff has a conference schedule, dated November 16-17 1993, from a “Classified Conference” which had been sponsored by Los Alamos Laboratory about this technology. A speaker from Livermore Lab was scheduled to give a lecture on nonlethals at that time so it is clear that this subject was researched by Lawrence Livermore Laboratory and Los Alamos Laboratory. Lawrence Livermore Laboratory was managed from its inception in 1952 through September 2007 by the University of California School System for the U.S. government. The Department of Energy funds these laboratories.

597. It has been verified that one of Plaintiff’s perpetrators obtained his Ph.D. from UC Davis in Atomic Particle Physics during this time period and worked at a Livermore Lab facility. Plaintiff believes that several other perpetrators either worked or are presently employed by the UC School system.

598. In early June 2001 Plaintiff stayed in a motel room. Once she was in her room, Defendant M. Aquino and Lorne G. spoke to her, saying they were going to “rape” her. Plaintiff experienced a painful physical sensation in her vagina and then discovered that she was profusely bleeding from her rectum and vagina. Plaintiff took off her pants and tried to clean up. A voice then told her that they were going to kill her by “poisoning” her. Another person told Plaintiff to open up the door of her motel room. Plaintiff opened the door and then felt a force push her out the door, into the hall. Plaintiff was then locked out of her hotel room with blood streaming down her legs. The hotel manager was unavailable which caused Plaintiff to call a relative, telling her she was about to be “poisoned,” and she needed some assistance. The police and EMT’s arrived and took Plaintiff to her room and wanted to know why there was so much blood on the floor. Plaintiff said she had been “raped.” The EMT’s wanted to take her to the hospital but Plaintiff refused.

599. After these types of assaults, Plaintiff would hear a voice advising her to go to the hospital to document any physical damage done. Plaintiff tried to but because Plaintiff had no insurance, she was forced to go to the emergency rooms of Mercy, Alvarado and Thorton Hospitals throughout 2001. These hospital emergency rooms only screen out blatant and obvious physical injuries and so were not able to document any injury to Plaintiff at that time. Plaintiff was unable to pay for these hospital room visits because she was incapable of working due to being assaulted 24 hours a day and did not have sufficient funds.

600. On June 10, 2001, Plaintiff was sitting in her living room when her chest began hurting. Phil S. and John Price told Plaintiff via V2K that they were going to induce a heart attack. Plaintiff was told not to get up from her chair but to remain seated. Plaintiff immediately got up and tried to walk down the hall to her bedroom where there was a phone, but she kept falling down. Plaintiff ended up on the floor of her bedroom in a stupor while she felt sensations as if her heart was jumping out of her chest wall. This was just one of several instances in which Plaintiff believed she was going to die. Every time this occurred, she prayed and prepared to die, which she also did in this instance. Plaintiff then heard a new voice saying, “This is Major _____, I want to puke at what’s being done to you. I’m so sorry, we didn’t know you were such a good person. Someone please stop this.” Another person began speaking to Plaintiff in apparent efforts to relax her and she lay there for several hours and then went to sleep.

601. After Plaintiff woke up, she drove to Grossmont hospital to see if they could document any damage done to her. They did. Plaintiff had no prior medical problems with her heart but after Grossmont Hospital technicians performed an ECG test, on June 10, 2001, the Cardiology Department documented that Plaintiff had an “abnormal ECG,” sinus tachycardia with “short PR, and “ST & T wave abnormality.” At that time Plaintiff told the emergency room physician that she had been “raped” the week prior in efforts to document any physical damage, but there was none.

602. Three times from May 2001 to 2002, Plaintiff felt sensations as if her mind had exploded. In late May 2001, her mind felt like it was filled with some type of field/energy which was later identified as a nonlethal weapon called Extremely Low Frequencies [ELF]. Voices began echoing in her mind and it sounded like she was speaking in “tongues” because of the nonsensical sounds.

603. The second time this occurred, Plaintiff was in her living room. The field in her home was so intense, her tongue began to vibrate. Plaintiff began responding to the voices she was hearing until a male voice advised her to stop responding because she was in an Artificial Intelligence program that became activated when she responded. When Plaintiff stopped “thinking,” the voices stopped. This is disturbing because if artificial intelligence programs are routinely used while targeting victims with V2K phenomena, this means that great numbers of people can be targeted at once, without the expenditure of much man power.

604. The third time this occurred was in June of 2001. Her mind felt like it was immersed in some type of intense magnetic field, and then it felt like it exploded, and she had great difficulty thinking because her thoughts made no sense. Plaintiff was so psychologically damaged, she could not count change at the grocery store. Plaintiff’s perpetrators told her that effect was induced by sending too much ELF or “extremely low frequencies” to her brain. One of her perpetrators then spoke to Plaintiff and said he was going to try to “assist” her with her thinking process. From then on when Plaintiff intended to think a word like “go,” it would come out as “stop.” Plaintiff was told she was placed on a “word association” program, apparently subliminally, because Plaintiff had no control over her thoughts. Plaintiff eventually discovered that it was specifically designed so that Plaintiff would voice thoughts that were the opposite of her intention. This devastated Plaintiff as she had worked for years to improve her thinking processes in efforts to make herself a better person.

605. Col. John Alexander (ex-director of the Nonlethal Department at Los Alamos Laboratory in New Mexico) described the effects of subliminal persuasion via psychotronics and the impact of ELF or Extremely Low Frequencies in his military paper titled, “The New Mental Battlefield: Beam Me Up, Spock,” published in Military Review 1980, Vol. LX, No. 12, 47-54, http://www.Bibliotecapleyades.net/sociopolitical/esp_mindcon16.htm. It reads, in part:



607. Lt. Col. Michael Aquino wrote an unpublished paper in response to Col. Alexander’s published article that was just quoted titled, “Mind War: The Psychology of Victory,” (1980) in which he also discusses ways to impact the public by the usage of extremely low frequencies [ELF] which he appeared to be in favor of, which proves that Aquino is more than aware of this technology. His paper described the U.S. Army’s efforts to “map the minds” of neutral and enemy targets. The early efforts to record “evoked” potentials” or “mind-read” was originally referred to by early researchers as “brain-mapping.” This paper is posted along with a 2003 update at the Temple of Set website http://www.xeper.org/maquino. It reads, in part:



608. Dr. Michael Persinger, a neuro-psychologist at Canada’s Laurentian University and FMSF Advisory Board member, believes he can induce mystical phenomena and ET abduction scenarios by stimulating the temporal lobes electromagnetically via extremely low frequencies [ELF]. He wrote an article titled, “On the Possibility of Directly Accessing Every Human Brain by Electromagnetic Induction of Fundamental Algorithims,” published in Perceptual and Motor Skills, (1995) 80: 791-799. In addition, Dr. Persinger presented a paper to a symposium for the Institute of Electrical and Electronics Engineers [IEEE] in 1979 titled, “ELF Field Mediation in Spontaneous PSI Events: Direct Information Transfer or Conditioned Elicitation,” originally published in physicist Russell Targ’s book, “Mind at Large,” in 1979, and republished in 2002.

609. Mr. Targ disclosed in this book that from 1972-1995, the Department of Defense had funded experiments into psychic phenomena at the Stanford Research Institute [SRI] and spent 20 million dollars over 23 years time. Russell Targ, Senior Physicists Researcher at SRI, reported that these experiments were a success and stated that, without doubt, psychic phenomenon, such as remote viewing and healing from a distance, existed. He claimed that mainstream journals refused to publish these findings due to their ignorance and prejudice. Mr. Targ presented his findings at the symposium of the Institute of Electrical and Electronics Engineers and described a program in the Electronics and Bioengineering Laboratory of SRI where he was conducting experiments in telepathic communications and discussed issues such as whether Extremely Low Frequencies [ELF] could be a carrier for “information transfer,” or telepathic contact between two parties, obviously for military applications.

610. Between June 15, 2001 and October 5, 2001, Plaintiff was 5150’d (forcibly taken to the hospital for observation by law enforcement) three times. Plaintiff had been repeatedly seeing unexplained phenomena that appeared to be “UFO’s. On June 15, 2001, Plaintiff was seen “talking” to herself while sitting in a doorway. The night before she was 5150’d, Plaintiff had been driving and had been chased by what appeared to be a “UFO” again and drove 20 miles, trying to elude it. Plaintiff exited on an off-ramp to some area unknown to her. Plaintiff jumped out of her car and began running. She felt something like a fist sock her in the back and she tried to run away from it. Plaintiff then stood in an office doorway all night, looking at the sky, where she saw fantastic imagery, while various voices, describing themselves as “aliens,” (who Plaintiff believes were actually Defendant M. Aquino and others) told Plaintiff that she was about to be sentenced for her “bad” thoughts. Plaintiff then sat in a doorway all night, trying to talk them into reducing her “sentence,” and that is when the police came to take Plaintiff to County Mental Health Psychiatric facility in San Diego. After a brief observation, in which staff noted that Plaintiff was very “thin,” Plaintiff was released. She refused to tell the psychiatrists at that time about hearing “voices” because she knew she would be misdiagnosed as a “schizophrenic.”

611. After Plaintiff returned home from this hospitalization, unidentified parties told Plaintiff that she was in “hell,” she was “dead,” and would not ever be able to enter her home again. Plaintiff was then subjected to further induced visual imagery and she stayed outside all night looking at the images of trees and shrubs which had suddenly turned into the shape of animals.

612. On July 3, 2001, Plaintiff was 5150’d for a second time for refusing to eat food. Plaintiff had asked a friend of hers, Dr. Ellen Lacter, to take her to the hospital because Plaintiff wanted to see if her latest assault could be medically documented. Plaintiff’s palms had turned white, and she couldn’t find a heart beat. Defendants M. Aquino, M. D., Scott L. and others told Plaintiff they were experimenting with “Cybertronics” and “computerizing” her from a distance. They claimed they could take out her body organs, destroy body organs, and she would still live because of the computer/brain interface, even though her body might die. Because Plaintiff was witness and victim to almost incomprehensible technology, she did not know what was possible. Plaintiff was urged by other identities to write about her victimization on the internet but because Plaintiff wrote exactly what had been told to her, she began to appear more and more “delusional.”

613. Scott L. had told Plaintiff that he did not want her to eat food, and if she did he would harm one of her relatives, including her younger brother. Consequently, Plaintiff quickly lost weight. At that time Plaintiff was staying at the home of Dr. Ellen Lacter who did not know what was wrong with Plaintiff other than she appeared to be having some type of psychological breakdown. Plaintiff’s weight had quickly dropped to 102 pounds due to her suddenly developed “fear” of eating.

614. Dr. Lacter told the Thornton Hospital emergency staff that Plaintiff refused to eat food and thought she was going to die from starvation. Plaintiff was then forcibly hospitalized at County Mental Health Psychiatric facility where she remained for three days.

615. On July 3, 01 and for two days after, the San Diego County Mental health psychiatric facility made Plaintiff drink high calorie drinks and eat food. Because the psychiatric staff did not understand that Plaintiff was being communicated with by V2K technology, they concluded that Plaintiff was “delusional.” According to the clinical record, Plaintiff weighed 102 pounds on July 3, 01 and gained four pounds on July 4, 01. Plaintiff decided to leave the hospital against medical advice because she was acutely aware that the medical community was not capable of assisting her.

616. After this hospitalization, Plaintiff returned to Dr. Lacter’s house and began contemplating suicide. Plaintiff had her gun in her car but because a shell was stuck in the cylinder, Plaintiff shot the gun into some bushes, trying to dislodge the bullet. Dr. Lacter’s husband took the gun away from Plaintiff, called the police, and gave the gun to them.

617. Plaintiff called the police a few months later and asked for the gun back. The officer told her that he would not file charges against her for firing a gun in public but would file charges if she insisted on having her gun back because he didn’t think she was psychologically well. Plaintiff asked for her gun back and the officer filed misdemeanor charges against Plaintiff in 2002 for discharging a weapon in public. That is the only criminal history that Plaintiff had at that time.

618. From June 2001 to the day she was arrested November 26, 2002, Plaintiff left her home at approximately 7am and either walked throughout the county, drove her car aimlessly, or rode the trolley system until late at night. From June 2001 to November 2002, while Plaintiff was wondering around town, she lost her purse three times, lost a briefcase, lost her cell phone, and could not pay her bills. During this time, Plaintiff neglected her hygiene and rarely bathed or brushed her teeth. As a result of this medical neglect, after 2004, Plaintiff had extensive dental work which included several cavities filled and root canals.

619. On October 5, 2001, Plaintiff was 5150’d for a third time after she was found “wandering” and loitering in a doorway. That was because Plaintiff had been listening to her “voices” and lost track of time again.

620. In approximately June 2001, after Plaintiff listened to her perpetrators, they contrived a scenario which rationalized why Plaintiff should go “swimming” in Lake Murray, a lake a few blocks from Plaintiff’s home. Without much thought, Plaintiff ran to the lake and illegally swam in the lake fully clothed. Plaintiff does not normally like to swim. Plaintiff then ran home at top speed, while a voice told her, “that took exactly 7 minutes and 30 seconds.” Plaintiff’s perpetrators could never “order” her to do anything against her will and so they often resorted to manipulative story-telling, hoping she would volunteer to do something that ended up making her appear to be very bizarre.

621. Shortly afterwards, Plaintiff’s neighbor, Ken Wright, spoke to her about her behavior and wanted to know what was wrong. He had been informed by another neighbor that she had swam in the lake and was acting “crazy.” Mr. Wright consulted with another neighbor Paul K. and phoned the police after they heard screaming coming from Plaintiff’s home. Plaintiff was screaming because at that time, her perpetrators were drilling into her head with remote assault weapons.

622. Because of these assaults, Plaintiff became severely psychologically incapacitated. As s result, Plaintiff was incapable of renewing her newly acquired MFT license in November of 2001, a license she had worked years to acquire, and as a result, it expired. Plaintiff was completely unable to file a lawsuit during this time period due to her psychological incapacitation.

623. From June 2001 to 2007, two individuals, alleging to be from the Soviet Union interacted with Plaintiff, via V2K, telling her they had been hired to not only physically and psychologically assault Plaintiff but to spiritually murder her. They told Plaintiff they made millions of dollars targeting others esoterically in their native country because of their affiliations with the “KGB” and satanists. These perpetrators told Plaintiff many stories about how exactly this had occurred. One story was that Tani Jantsang had an “uncle” in the KGB who was bribed by Michael Aquino. Defendant Jantsang did write a message on the internet indicating that she had a relative in the KGB. They told Plaintiff that it was the Soviet Union who began the process of computer/brain interface necessary to target plaintiff via their satellite. According to Cheryl Welsh of CAHRA, Citizens Against Human Rights Abuse, 75% of victims of nonlethal technology are from the Soviet Union and the United States.

624. Although it would seem that the average nonlethal perpetrator would not find it of interest or too egregious to attack an opponent on the esoteric level, it might interest the average Satanist. When satanists sacrifice their victims to satan, they symbolically attempt to destroy their victims soul, or send it to hell, which is one reason why they make their victims last waking moments on earth one of intense suffering. Plaintiff’s perpetrators told Plaintiff they had isolated where the astral body resided and were intent on attacking her on this level.

625. As difficult as it is to believe, the public should be made aware that it is a fact that the “astral body” has been mentioned in the nonlethal literature as well as its usage for military surveillance purposes. In a July 1972 declassified paper titled, “Controlled Offensive Behavior,” by Captain John D. La Mothe, Medical Intelligence Office, Office of the Surgeon General, Department of the Army, posted at http://www.bibliotecapleyades.net/esptemas4.htm it described the Soviet Union’s interest in out-of-body travel and what the United States government thought the countermeasures should be. It read, in part:



626. In this declassified report, just referenced, the author described the Soviet Union’s research into parapsychology and clearly described what military applications the “astral body” might have.

627. Col. John Alexander, (ex-director of the Nonlethal Department at Los Alamos lab) also discussed the military application of the astral body in his previously cited military paper, “ The New Mental Battlefield: Beam Me Up, Spock,” published in Military Review. He specifically mentioned the Soviet Union’s research into this area and cited the preceding excerpts from Controlled Offensive Behavior, Col. Alexander wrote:



628. Col. Alexander described the scientific evidence which proved the existence of the astral body by Kirlian photography in a mainstream military journal, and its military applications, and that was 27 years ago.

629. According to “Remote Viewers: The Secret History of America’s Psychic Spies,” by Jim Schnabel, 1997, several well known nonlethal warfare advocates, including Admiral Albert Stubblebine and Col. John Alexander, had attended Robert Monroe’s classes and week long workshops to learn how to “astral travel” by the usage of sound entrained to specific brain waves. Admiral Albert Stubblebine was the Commander of the Army Intelligence and Security Command [INSCOM] during 1981-1984. From Remote Viewers:



630. Ironically, Col. John Alexander studied with Dr. Elizabeth Kubler-Ross who was an expert in near-death experiences and how to make a conscious death transition into the “light.” Lt. Col. Alexander was also past president of the International Association for Near Death Studies and was, along with five others, a member of the Aviary, a cabal of intelligence agents who purported to study UFO phenomena.

631. Defendant Aquino, and others, also told Plaintiff it was known where the Chakras resided and they were going to destroy Plaintiffs. The seven Chakras are a metaphysical belief system which originated with the Hindus, Chinese, and Tibetians. Many people in the Western world are practitioners of this belief system and that is what Hatha Yoga is based on, stretching and assuming forms in order to make the body strong enough for the eventual opening of the chakras, with the eventual goal being unity with God. The Chakras are thought to be energy centers which correspond to the endocrine system and nerve centers of the body. Technology exists that can impact the electromagnetic field of the body, which Col. John Alexander described in his discussion of Kirlian photography which photographs the subtle emanations of the body. Apparently after discovering that the astral body could be used as a military weapon and for surveillance purposes, there were attempts made to isolate and incapacitate the astral body and chakras, probably by tracking changes in the electromagnetic/energetic emissions from the body.

632. On November 26, 2003, Plaintiff plea-bargained to stalking Jennifer Love Hewitt after Plaintiff wrote her a pseudo-threat in October of 2002 in efforts to save her own life. Robert M’s “wife,” and Defendant M. Aquino, and his wife, Lilith, eventually confessed that they had pretended to be Hollywood figures, such as Jennifer Hewitt and Steven Speilberg, via V2K and what Plaintiff discovered was “Voice Synthesis Devices,” in order to drive Plaintiff crazy from pain and fear, in hopes she would publicly discredit herself.

633. Defendant Aquino introduced these Hollywood figures to Plaintiff by claiming that Steven Speilberg was interested in advanced military technology, which he sometimes used on his films (which Plaintiff later discovered was true) and Aquino, through an intermediary, introduced him to a version of the illegal computer/brain interface technology which monitored Plaintiff. Because Aquino has written several stories about “The Lost Ark,” and other “Indiana Jones” movies, it is obvious that he admires Steven Speilberg.

634. Plaintiff asked “Speilberg” why he was violating her privacy and he told her that his special effects studio Dream Works was interested in duplicating the technology on film. The story line was that because they were making a film together - “The Tuxedo” - “Steven Speilberg” introduced Jennifer Hewitt and other selected Hollywood types to this novel technology. It is true these two were making a film together titled The Tuxedo.

635. Throughout the entirety of 2002, “Jennifer Hewitt,” who was later identified as Robert M.’s wife and Lilith Aquino, began cruelly teasing Plaintiff, physically hurt Plaintiff, and succeeded in emotionally devastating Plaintiff, along with Defendant M. Aquino, Scott L., M.D., Robert M., Phil S. and unnamed others.

636. During this time period, “Steven Speilberg” continued to violate Plaintiff’s privacy and refused to remove “Jennifer Hewitt’s” access to Plaintiff when she requested his assistance. This culminated in an incident in approximately May of 2002 in which Hewitt/Lilith Aquino and others told Plaintiff that they were going to try to “crack” Plaintiff’s skull open. Plaintiff felt a drilling sensation into her skull and began screaming. Hewitt/Lilith Aquino then proceeded to laugh out loud at Plaintiff’s suffering.

637. Plaintiff who by that time thought it was possible, although not probable, that Hollywood billionaires were having “fun” at Plaintiff’s expense, attempted to reality check and confronted Ms. Hewitt at a radio station in San Diego in August 2002 just to see how Hewitt responded. The assaults against Plaintiff continued under Jennifer Hewitt’s name which then caused Plaintiff to confront Hewitt again at the Latin Grammy Awards on September 18, 2002. Several individuals told Plaintiff via V2K not to do this but she did it anyway.

638. For several weeks, Plaintiff had extensive contact with Steven Speilberg’s security advisor Mr. Borman, explaining what her predicament was: She did not know what was going on but was interested in discovering if it was possible that Speilberg had access to this military technology, and she informed Mr. Borman repeatedly that she was only interested in remaining within the bounds of legal behavior.

639. Steven Speilberg filed a restraining order during this time period against Plaintiff, which was finalized in October 2002, within days of this confrontation of Jennifer Hewitt because he was concerned that Plaintiff would confront him too in public. Plaintiff could not attend the court hearing which was held about the restraining order because she was in too much physical pain which her perpetrators were inducing, however she did submit a Declaration to the Los Angeles Superior Court at that time attempting to explain her situation with the facts that were available to her at the time.

640. Plaintiff was very disappointed to discover that in order to make sure the court ruled in his favor, Mr. Speilberg and his security manager, Kevin Borman, exaggerated and distorted Plaintiff’s conduct, history, and statements, causing the media to repeat claims such as Plaintiff had “accused Steven Speilberg of implanting a mind control device in her head,” and “Plaintiff believed a group of Satanists were working from Speilberg’s basement,” and she was “planning something big,” all statements which Plaintiff had never made. Plaintiff never made any attempt to directly contact Mr. Speilberg because she wasn’t interested. The gist of the complaint was that Speilberg wanted to stop Plaintiff from being able to confront him in a public setting.

641. Defendants Aquino and his wife, Lilith, Scott L., M. D., and others, then informed Plaintiff they were going to finally kill her and she would be dead within the week. Plaintiff believed them and slept within reach of the telephone. Because she thought she would be safer in the custody of law enforcement, Plaintiff wrote a pseudo-threat to Jennifer Hewitt’s web master, Jim Mix, in October 2002 to have herself purposely arrested and to make sure her case became high-profile. Plaintiff asked Mr. Mix several times to send her threat to Hewitt but because Mr. Mix appeared to think Plaintiff was joking, Plaintiff reminded him that making email threats was a crime and to be sure to “contact the FBI,” although she had no intentions of acting on that threat. Because Plaintiff believed in non-violence, resorting to “threats” indicated that Plaintiff was in deep distress.

642. As Plaintiff planned, and her perpetrators intended, Plaintiff was arrested on November 26, 2002 for writing “terroristic threats” and for “stalking” Jennifer Love Hewitt. While in custody Plaintiff continued to be assaulted by Defendants M. Aquino, his wife Lillith Aquino, Scott. L., M. D., Robert M., his wife, Kevin F., and others, but they no longer told her they were going to kill her. In fact, they all frightened Plaintiff by continuing to tell her she would not be able to die a normal death due to the latest techniques in computer/brain interface, which is what they intended to happen.

643. Plaintiff later discovered that the investigatory report, written by an investigator at the DA’s office under Paul Phingst at that time, further distorted Plaintiff’s behavior and conduct, and alleged conduct by Plaintiff that had never occurred. Plaintiff requested of her lawyer, Robert Ford, that she be given permission to act as co-counsel, (or advisor) because she knew her case was too complicated for her naïve attorney to present in court alone.

644. Plaintiff’s lawyer, Robert Ford, decided Plaintiff was too “mentally ill,” and told her that her belief that she was being targeted by psychotronics was completely “delusional.” At that time, the only information Plaintiff had to prove that psychotronics or nonlethals existed was the John St. Clair Akwei vs, NSA report and a July 8, 1996 Calgary Herald article titled, “Scientists Offer the End of Death: ‘Soul Catcher’ Computer Chip Implanted behind the Eye,” which had warnings about computer/brain interface.

645. While in custody, Plaintiff was evaluated by three psychologists, two of whom opined that Plaintiff was either “schizophrenic” or “delusional,” and was “paranoid,” after she explained what had occurred on the internet between her and her political opponents - which caused her perpetrators endless amusement. Plaintiff was eventually formally misdiagnosed as “mentally ill” and they informed her attorney that his concerns were justified: Plaintiff was too mentally ill to assist her attorney in her own defense. Plaintiff appealed to the court to reconsider because she understood that her past writings were being used as evidence of “mental illness,” but since she had discovered that her perpetrators intentionally provided her with mis/disinformation, she no longer wholeheartedly believed in what was contained in those writings, and certainly they should not be used as reason to confine her against her will until she explained the context. Therefore, Plaintiff argued that the underlying facts were in dispute and the psychiatric evaluations should not be considered legitimate. The local judge and the appellate court ruled against Plaintiff which resulted in Plaintiff’s incarceration at Patton State Hospital until she got “better.” While at Patton, Plaintiff was forced to take psychotropic medication even though medication has never alleviated the external assaults she is experiencing by V2K technology.

646. Plaintiff plea-bargained on November 5, 2003 to “Stalking” Jennifer Hewitt and she was placed on probation for five years. Plaintiff is now serving her fourth year on probation. Plaintiff’s attorney told her that the DA Fiona Kahill had said in the Judges chambers that Plaintiff’s “child-saving” days were over. Plaintiff had no idea at the time why an attorney in the DA’s office would make such a personal remark about Plaintiff until Plaintiff read Defendant Devereaux’s correspondence years later in which she stated that Defendant Hopkins had “tampered” with her legal case. Because Defendant Hopkins was obviously a colleague of then DA Paul Phingst, it appeared entirely possible to Plaintiff that this is what occurred because Phingst was still in office at that time. In fact, Ms. Kahill informed the San Diego Superior court that Plaintiff had a “history” of harassing people on the internet, and used Mark Sauer’s news article the “Web of Intrigue” as evidence.

647. Plaintiff, who two years prior to these events had been a high-functioning professional in her local community, was sentenced to five years probation, ordered by the court to see a psychiatrist, take prescribed medication, Plaintiff was ordered not to use the internet or computers at all, to submit to random lie detector tests, and to enroll in a counseling program. Because Plaintiff finally “acted out,” which was what her perpetrators planned in furtherance of the ongoing conspiracy to ruin Plaintiff’s reputation and career, Plaintiff’s Marriage and Family Therapy [MFT] license was revoked in 2004 due to her criminal offense, which caused Plaintiff reputation to be further ruined and resulted in the loss of her career, income and livelihood.

648. From approximately November 2003 to 2004, Plaintiff’s psychiatrist was Dr. Glassman at East County Mental Health who increased Plaintiff’s medication when she mentioned she still heard “voices.” In March 2004, Plaintiff was awarded Social Security Disability benefits because Plaintiff was completely incapacitated and incapable of working which Dr. Glassman attested to. Because Dr. Glassman believed Plaintiff was too incapacitated to be her own payee, Plaintiff’s relative was named as her payee.

649. From approximately June 2004 to December 2005, Dr. David Marks acted as Plaintiff’s psychiatrist, and in October of 2004, he allowed Plaintiff to become her own payee. But because Plaintiff occasionally decompensated, Plaintiff’s checks have continued to have her name and a relative’s name on in the event her relative needs to pay her bills.

650. As a result of Plaintiff’s incapacitation which began in May 2001, Plaintiff was forced to file bankruptcy on July 7, 2004 due to the amount of unpaid bills, which totaled $60,000. Plaintiff’s psychiatrist Dr. Marks wrote a statement to the holder of her school loan, giving her such a poor prognosis of ever recovering, that the holder of the loan cancelled her debt. From approximately 2006 to the present, Plaintiff’s psychiatrist has been Dr. Prakash Bhatia.

651. Between the years 2002 to the present, Defendants M. Aquino, his wife, Lilith Aquino, Scott L. M. D., Robert M. his “wife,” and occasionally Kevin F., Peggy N., and Peter G. have attempted to take over Plaintiffs mental life even further and have terrorized and tormented Plaintiff. Because of this excessive torment, between the years 2002-2007, Plaintiff could not sit down for any length of time and paced up to 7 hours a day. Because Plaintiff is often kept awake all night by these individuals, she has been forced to take sleeping pills on a semi-regular basis. These facts should prove that Plaintiff met the “insanity” provision of Civil Code and Procedures 352 until on or about May of 2007 when she began exercising her mind due to a court order which allowed her to use the word processor.

652. After Plaintiff was finally released from jail in November 2003, she told her temporary probation officer that she had been pursued by a satanic cult and she expected them to try to make trouble for her with probation at some point. In approximately March of 2004, Plaintiff was assigned Probation Officer Stephanie Morehead with Anna Guzman acting as Supervisor of Ms. Morehead.

653. In 2004, Plaintiff began to have difficulty with her Probation Officer Stephanie Morehead and Anna Guzman, after they made attempts to violate Plaintiff’s First amendment rights to free speech, and routinely mischaracterized Plaintiff in front of the San Diego Superior Court, all of which has caused Plaintiff significant emotional distress. After Plaintiff was invited to appear on the Montel Williams show, they called the producers of the show, telling them she could not appear and instructed the producers to contact them if Plaintiff ever contacted them again. These individuals have never believed that Plaintiff has been targeted illegally with military technology and instead have routinely believed the misinformation and disinformation that has been written about her. Plaintiff believes that these individuals have violated her rights to free speech only because they have a different opinion than Plaintiff about what she is experiencing. Plaintiff believes it is unfortunate that the topic of nonlethal technology appears to be beyond the comprehension of these particular individuals.

654. In mid 2006, because Defendant M. Aquino, his wife, Lilith, Robert M. and his wife became upset with Plaintiff, and wanted to emotionally traumatize her, they told Plaintiff that they had targeted her relatives. Plaintiff was emotionally devastated and decided to bring publicity to the issue again.

655. In mid 2006 Plaintiff decided to write some exploratory letters to the Institutional Review Boards of UC Davis, Berkeley, and Irvine, requesting that they investigate whether a UC Davis professor, Scott L., John Price, or Defendant Elizabeth Loftus, had ever listed her as a human research subject because Lawrence Livermore Lab was run by the Office of the President of the UC School System and appeared to research nonlethal technology. The Office of the President responded to Plaintiff by claiming that they had found no public record of such events. Plaintiff was told by UC Irvine that their “Whistleblowers Unit” of UC Irvine would handle her complaint.

656. Plaintiff had expressed in these letters that she had a public “breakdown,” the context of which she wanted to explain to the IRB if this issue ever arose. Plaintiff also wrote that she had not pursued this matter earlier because she was afraid of the people involved.

657. In approximately June/August 2006, Plaintiff’s probation officer Stephanie Morehead began receiving complaints from the UC Campus Police about the letters she had sent to the IRB’s of both UC Davis and UC Irvine. The IRB’s had taken Plaintiff’s confidential requests for an investigation, and then apparently notified the individuals involved – despite Plaintiffs claim that she had been afraid to come forward until that time - and turned the correspondence over to the campus police, who then sent it to San Diego County Probation and Officer Morehead. Since Plaintiff had not mentioned to any of these IRB’s that she was on probation for a criminal offense, and her letters could not possibly have been construed as threatening, an unknown party who was aware of Plaintiff’s probationary status obviously informed the IRB’s, Plaintiff believes to discredit and retaliate against her.

658. In approximately August of 2006, Morehead told Plaintiff to cease all communications with the UC System (for that time period) and reiterated to Plaintiff that she was not allowed to use the word processor at all. It became evident that Morehead and the Administration of Probation were speaking to people from these schools and elsewhere who were claiming Plaintiff was guilty of some activity, but Plaintiff did not know what that could be, and feared that she was being “set-up” again by one or more of the Defendants. Plaintiff asked Morehead whether she would be informed about what the exact allegations against her were so that she could defend herself and Morehead said “yes.” However, that was not the case.

659. In September of 2006, Plaintiff was informed by her then psychologist that he had received a phone call from Probation Supervisor Anna Guzman who told him she was building a “legal case” against Plaintiff based on Plaintiff’s long telephone bill and the complaints made by the UC System. Ms. Guzman had phoned several people on Plaintiffs phone bill but unfortunately did not appear to understand the content of the information that she received from those phone calls. Plaintiff’s attempts to access the Akwei v. NSA lawsuit were described by Guzman as attempts to “obtain a court file without a court order,” which was an ignorant remark to make because court files are open to the public unless they are ordered sealed by the court; Plaintiff’s phone calls to the aid of Congressman Kucinich and other government officials was misconstrued as “calling Capitol Hill,” without good causer. Plaintiff has every right to call government officials as they are in office to serve their citizenry. Ms. Guzman then misinterpreted Plaintiff’s communication with a researcher known to Plaintiff who investigates the paranormal – apparently because Ms. Guzman did not understand the paranormal or does not believe in its existence. Clearly, because of Probation’s misunderstanding, they were attempting to violate Plaintiff’s right to free speech. Plaintiff wrote a letter to Ms. Guzman and her supervisor Ms. Donohoo attempting to educate them about these issues and advised them of their mistake. Plaintiff thought that was the end of the matter.

660. On December 14, 2006, Plaintiff asked Probation to schedule a hearing at San Diego Superior Court to return her belongings that were confiscated by the District Attorney and to request word processing and internet/intranet privileges again due to her good behavior.

661. On December 14, 2006, Officer Morehead wrote and Supervisor Guzman signed a report which was submitted to the San Diego Superior Court, titled “San Diego County Probation Department Probation Officer’s Supplemental Report, “ which was completely filled with false allegations about Plaintiff. ” Ms. Morehead wrote:



662. Plaintiff responded that she had never requested permission to write a book and that it was well within her Constitutional rights to write a book if she wished. The court remained silent on this issue. Morehead continued:



663. The Plaintiff had in fact not been on the internet and it appeared that one of Plaintiff’s perpetrators had coincidentally contacted Probation at the approximate time Plaintiff was requesting review by the UC school system’s Institutional Review Boards. Ms. Morehead continued:



664. This type of allegation sounded like the false allegations Defendant Devereaux had made to the San Francisco police department to have Plaintiff identified. However, Morehead refused to reveal the names of the complaining parties to Plaintiff. Morehead continued:



665. Plaintiff told the court that Probation Officer Morehead had seriously mischaracterized her work and activities, and it appeared that Probation, in addition to new allegations, were continuing to raise the same allegations that Plaintiff had attempted to correct Anna Guzman about several months earlier. The report continued:



666. The reference to a “UCI professor” was later discovered to be Defendant Loftus. However, Plaintiff had never contacted Elizabeth Loftus but chose instead to contact the IRB’s. It was the Plaintiff’s opponents – the “Dr’s” in sci.psychology.psychotherapy who referred to Plaintiff’s work as the “Curio Files” or as an obvious pun, the “Curiophiles.” Morehead continued:



667. By making these types of allegations, falsely alleging that there were “victims” of Plaintiff, along with the ridiculous notion that the “academic community” needed protection from Plaintiff, it appeared that Morehead and Guzman were making themselves actors in furtherance of the conspiracy by Defendants to deprive Plaintiff of exercising her first amendment rights after speaking to one or more defendants on this case. As a result of these false complaints, which resulted in Morehead/Guzman suggestion to the court that Plaintiff be restricted from writing a book, or at least be impeded in her ability to write a book, the court denied Plaintiff access to a word processor and the internet/intranet. Plaintiff then requested a continuance to allow her time to respond to these false allegations about her which the court allowed.

668. A hearing was held on January 5, 2007 during which Plaintiff inquired why her probationary status was not violated if she was indeed guilty of these activities. Plaintiff requested permission of Probation administrator Lisa Donohoo to contact the UC system to investigate the false complaints made about her, and was allowed by Ms. Donohoo to proceed. However, Ms. Donohoo refused to disclose what the police report numbers were from UC Davis and UC Irvine about her alleged activity because she said it was policy that probationers not access police reports.

669. Plaintiff discovered after speaking with UC Davis Officer Henoch that Plaintiff did not send a “40 pg. fax,” but had sent approximately 40 pages of materials to the UC Davis IRB. Plaintiff agreed, and asked what was illegal about that activity. Plaintiff was told by Det. Henock that there was nothing illegal about that activity. Furthermore, it did not appear that Officer Morehead had investigated this complaint to discover what phone number was at the top of the fax or any other information which would provide forensic evidence indicating whether or not Plaintiff had actually sent this alleged “fax.”

670. On approximately January 11, 2007, Plaintiff discovered from Kathie Allen of UC Irvine’s “Whistleblowers’ Unit,” that she had initiated the police report about Plaintiff on behalf of a party she refused to identify. The Whistleblower’s unit was evidently designed to protect complaining parties in case that person experienced retaliation. However, these individuals did not protect Plaintiff in this case.

671. On approximately January 11, 2007, Plaintiff spoke to UC Irvine’s campus Detective Altamarino who told Plaintiff that Defendant Elizabeth Loftus had alleged that discs, a letter and emails were sent to her from Plaintiff. Plaintiff confirmed with Altamarino’s supervisor, Sgt. Dublin of UC Irvine Campus police, that Plaintiff had been a suspect in a case in which Dr. Elizabeth Loftus alleged that Plaintiff had sent her this material, after which she felt “fear.” However, Dublin explained that Plaintiff was no longer a suspect after DOJ checked fingerprints on the envelopes in question and none of the fingerprints matched the Plaintiffs. Sgt. Dublin confirmed that their logs revealed that a Supplemental Report with this information had been sent to San Diego County Probation on September 19, 2006, detailing that Plaintiff was no longer a suspect. This report was evidently sent a full three months before Officer Morehead wrote her December 2006 report factually stating that Plaintiff was guilty of the above activity. Sgt. Dublin told Plaintiff he could not of course release this report to her but could to San Diego Probation if they requested another copy. As a result, due to Delayed Discovery, Plaintiff is not aware of any more specific details regarding the false allegations that Defendant Loftus made against Plaintiff. The Director of Probation claimed that Morehead had not received that report at that time but Plaintiff does not believe that is a satisfactory response. If Morehead had done her job and picked up the telephone and contacted UC Irvine for an update on their investigation within that three month time-period, Morehead would have been updated.

672. Plaintiff alleges that because she requested UC Irvine’s IRB’s to investigate whether Dr. Loftus might be involved, or was aware of Human Subjects Research violations involving Plaintiff, Defendant Loftus intentionally orchestrated emails, files, and discs be sent to herself, on purpose, to set-up Plaintiff in retaliation against Plaintiff for requesting an investigation of Loftus. These false claims could easily have resulted in the loss of freedom for Plaintiff and her reincarceration. At the very least, these false allegations were being used as a reason to deny plaintiff access to a word processor and the internet/intranet in order to impede her from writing a book. This indicates malice and San Diego Probation had no right to do this to Plaintiff. It is not explained why Defendant Loftus would claim she felt “fear,” even if Plaintiff had sent her this material, because she does not know the content of this alleged material. However, a victim’s feelings of “fear” is a critical element in a criminal stalking complaint. Plaintiff believes that Elizabeth Loftus is smart enough to figure out how Plaintiff was targeted and knew perfectly well she had nothing to fear from Plaintiff other than public exposure.

673. Defendant Loftus has a long history of misrepresenting the facts concerning other parties, according to sexual molest victims Jennifer Hoult, Lynn Crook and a recent party, a Ms. Taus. According to a San Diego Union-Tribune article titled, “Memory Expert Quits after Rebuke,” March 18, 2003:



674. In the late 1990’s, according to therapist David Calof, the FMSF and Defendant Loftus were implicated in the harassment of Mr. Calof almost immediately after he wrote about the FMSF in his journal “Treating Abuse Today.” Defendant Loftus recently settled a court case (2007) with a Ms. Taus who accused Loftus of misrepresenting herself in order to obtain information about her in order to deny Ms. Taus’s case of repressed memory. Defendant Loftus has routinely acted on behalf of the defense in cases alleging satanic ritual abuse, including the Dale Akiki case, the Paul Ingram case, and others. Loftus is an Advisory Board member of the FMSF an organization which denies that satanic ritual abuse occurs. Defendant Loftus gave false information to SDUT reporter Mark Sauer about Plaintiff in the “Web of Intrigue,” in September 2001. Loftus also appears to be a close friend of Defendant Carol Hopkins. In 2003, Defendant Deverereaux listed Elizabeth Loftus in correspondence to Dr. Ellen Lacter as one of the parties who had been searching for Plaintiff’s identity during the years when she was safeguarding her privacy, therefore, even though Defendant Loftus is sometimes described as the most “famous memory expert” in the world, to Plaintiff, her credibility is decidedly lacking.

675. Plaintiff believes that she is not required to prove a negative, and instead it is Defendant Loftus who is required to justify her actions and furnish the evidence upon which her false allegations were based, because these false allegations caused Plaintiff significant emotional distress for close to two years, and it has taken Plaintiff a full thirteen months to correct the record and injustice done to her. Throughout that entire time period, Plaintiff thought she might be rearrested on false charges.

676. In February 2007, Plaintiff notified Officer Morehead that there was a Supplemental report available from UC Irvine which released her as a potential suspect and she requested that Morehead write a corrective report to the court advising them of that fact. Morehead refused to write a corrective report, telling Plaintiff that it was “no big deal,” because Plaintiff’s probationary status was not “violated.” Plaintiff told Morehead she thought it was a very “big deal” to make false allegations about someone in a criminal court case, let alone refuse to correct those false allegations when new information became available.

677. On approximately February 1, 2007, Plaintiff left a message for Anna Guzman on her voice mail, telling her that a Supplemental report from UC Irvine was available which released her as a suspect, and to please write a corrective report to the court alerting them to that fact. There was no response.

678. On approximately February 5, 2007, Plaintiff telephoned Guzman’s supervisor Lisa Donohoo to tell her Morehead refused to write a corrective report and requested that Donohoo contact UC Irvine’s Sgt. Dublin and access the Supplemental Report proving that she was no longer a suspect. Ms. Donohoo promised that she would email UC Irvine, and if it appeared these were false allegations, she would make sure a corrective report was written. However, Donohoo said she would only send one email to UC Irvine because she did not want them to think she was “harassing” them. Donohoo then advised Plaintiff not to make this issue drag “on and on,” Plaintiff’s probationary status was not violated, and advised her that she only had only a year more of probation so to let the issue “go.” Plaintiff told Donohoo that she disagreed, if these allegations were not corrected, it might harm her at a later point and be used against her, and perhaps be used as cumulative evidence as reason to imprison her. At that time, Donohoo confirmed for Plaintiff that she had been receiving phone calls from people from the UC system, apparently making allegations about Plaintiff, but she refused to tell Plaintiff who these people were or what the allegations were. Plaintiff then contacted Donohoo’s supervisor John Hensley who refused to correct the allegation involving Defendant Loftus but agreed to correct the false allegations about the 40 page “fax.”

679. In March of 2007, Plaintiff scheduled a court hearing at San Diego Superior Court requesting “Clarification of a Court Order,” updating the court on the new information which released her as a suspect involving allegations made by Defendant Loftus and an unknown party at UC Davis. However, neither Morehead, Guzman, or Donohoo were present at that hearing and Plaintiff was not provided with any corrective report. However, on that court date, Judge Szumowski made a restrictive court order allowing Plaintiff to use the word processor and access to the internet/intranet via a third party.

680. In March 2007 and April 2007, Plaintiff wrote letters of complaint to Director of Probation about Officer Morehead and Guzman’s unwillingness to correct false allegations about her with San Diego Superior Court. On September 14, 2007, the Director of Probation, Mr. Cranford, wrote a letter informing Plaintiff that two outstanding allegations from the UC School system would be corrected.

681. On approximately January 15, 2008, Plaintiff checked the contents of her court file at San Diego Superior Court, and did not find the corrective report ordered to have been written by Probation Director Cranford in September of 2007, but found further reports by Officer Morehead to the court which seriously mischaracterized Plaintiff and which continued to misrepresent the facts about what had occurred.

682. On approximately January 10, 2007, Plaintiff informed the new Director of Probation, now Mack Jenkins, that the corrective report ordered to have been written by acting Director David Cranston, had never been written which meant Officer Morehead and Guzman refused to follow a direct order by their Director, apparently out of malice felt for Plaintiff. Plaintiff was then notified by Defendant Guzman that the corrective report had been written and had been sent to the court. Plaintiff received a copy of this barely legible report dated January 15, 2008, almost a full year after they had received this information. It read, in part:



683. According to this information Probation had the information which released Plaintiff as a suspect for almost a year but they refused to write this corrective report to the court. For more than one year, due to this incompetence and malfeasance, Plaintiff has expressed severe emotional distress to her psychologist which was directly connected to the false allegations made by Defendant Loftus and an unknown party at UC Davis immediately after Plaintiff requested an investigation about Loftus by the Institutional Review Board. Even though Mr. Jenkins responded in a letter that Officer Morehead was simply responding to allegations made by others, Plaintiff believes that Ms. Morehead and Anna Guzman were intentionally negligent and malfeasance occurred. Probation promised to release Plaintiff from Probation in March of 2008 but then changed their mind. Therefore, Plaintiff still cannot access the UC Irvine police report that was fraudulently filed by Kathie Allan and/or Elizabeth Loftus.

684. In approximately May of 2007, Plaintiff struggled to resume her research and updated her Satanism and Ritual Abuse archive. Plaintiff was then able to slowly gather evidence about the dialogue that took place on the internet between her and the Defendants as preparation and evidence for this lawsuit. However, she has been constrained from accessing certain web sites, such as the WITCHUNT egroups list, because it required an email address, and the librarians refused to assist her.

685. After May of 2007, Plaintiff accessed articles from the San Diego Union-Tribune about her arrest and plea-bargain to “stalking” Jennifer Hewitt. In an article dated, Dec. 31, 2002, authored by Mark Sauer, published by Defendant Copley (which Plaintiff had seen in 2003 but had not fully understood due to her mental incapacitation) titled, “Stalking suspect to undergo more psychological tests,” a number of false allegations were made by Defendant Sauer. Defendant Sauer wrote and Defendant Copley published the following:



686. There was never any evidence indicating that Plaintiff ever “stalked” Steven Speilberg, and to her knowledge neither Mr. Speilberg or the Los Angeles court ever accused her of it. Mr. Sauer continued:



687. Plaintiff has never “threatened” Steven Speilberg. Apparently he argued that because of her confrontation of Hewitt, and her accusations against him, he felt that he might be threatened by Plaintiff at some point in the future. Mr. Sauer continued:



688. Plaintiff has never made baseless charges about anyone and this was an unfair representation of Plaintiff’s activities on the internet which has been described in detail. Mr. Sauer then wrote:



689. Plaintiff was never arrested by SDSU for “cyberstalking.” Apparently this is what Mr. Sauer wished had happened, but it never did. Because Mr. Sauer was the reporter who covered this incident for the newspaper, his misstatement of fact indicates intentional libel and malice. Mr. Sauer wrote:



690. Sauer again intentionally placed Plaintiff in a false light. Plaintiff never “targeted” anyone on the internet between the years 1995-2000. Plaintiff has also never claimed that the newspaper is trying to “torment” her. These are obvious fabrications by Mark Sauer who was attempting to capitalize on the Jennifer Hewitt case in attempts to make Plaintiff appear “crazy” in attempts to undermine her research.

691. In a San Diego Union-Tribune article, dated September 30, 2003, by SDUT reporter Onell R Soto titled, “Ex-social worker pleads guilty to stalking actress,” which Plaintiff became aware of only after August of 2007, it continued to misrepresent Plaintiff’s activities on the internet. Mr. Soto and Defendant Copley published:



692. In another San Diego Union-Tribune dated November 6, 2003 by Onell R. Soto, titled “Stalker of actress scheduled to be freed,” this writer falsely claimed, for the third time, that Plaintiff had “threatened” Steven Speilberg. Mr. Soto wrote:



693. Mr. Soto then again mischaracterized Plaintiff’s activities on the internet. He wrote:



694. Plaintiff alleges that these statements indicated malice, and further exposed her to public hatred, contempt, ridicule, and disgrace by inferring that she should be “charged” for her comments which rebutted her political opponents claims that satanic ritual abuse of children did not occur.

695. In approximately January of 2008, Plaintiff contacted the Board of Behavioral Sciences and requested that they release the contents of her file that contained any complaints about her. To date, Plaintiff has received no information from them but believes that one or more of the Defendants or Jane Does made defamatory commentary about Plaintiff to her licensing board. Plaintiff believes the MFT board will only respond to a subpoena therefore this is further evidence of delayed discovery.

696. On February 7, 2008, Plaintiff discovered in a set of documents that Dr. Ellen Lacter compiled, an article titled “Jennifer Love Hewitt,” dated January 8, 2002 which had been posted on the web site of “Celebrity Justice,” a TV program that has since been cancelled. [Exhibit 27] Plaintiff had not been aware of this articles existence. It appeared that the author misstated the year that this story was published because Plaintiff was not arrested until November 26, 2002. In addition, this article was filled with misinformation and disinformation about the interaction with Jennifer Hewitt and her family, which Plaintiff would like to correct for the record. Plaintiff never “hit” or “pushed” Ms. Hewitt’s mother. If she had been guilty of that activity she would have been charged with battery. This article proceeded to quote Defendant Carol Hopkins false allegations that Plaintiff had stalked and threatened Hopkins, and tried to make it appear as if Plaintiff was responsible for her move to Mexico, due to these alleged threats. It read, in part: