Ryan said:
Reply MPA Motion to Strike said:
In an attempt to evade this precedent and application of the anti-SLAPP statute, HBI first accuses Defendants of "recharacterizing" the posts and asserts that "HBI's teachings and products were not the focus of Defendant's defamatory comments"
Ummm.... I might be missing something here, but hasn't the whole thrust of HBI's argument so far been that HBI are the focus of allegedly defamatory comments made in this thread?!?!?! Isn't that what they are suing about?!?!?! Isn't that how they are claiming jurisdiction in Oregon?!?!? How can they claim that HBI are losing hundreds of thousands of dollars due to allegedly defamatory comments and then turn around and say HBI's teaching and products aren't the focus?!?!?
This just seems like such an incredibly huge cock-up on HBI's part that I'm wondering if I've missed something really obvious.
Interesting point when you consider that they are working so hard to separate Pepin from HBI and to conflate me with everything, including the kitchen sink.
Like Allen said, I noticed a general overall failure of reading comprehension exhibited in the HBI filings. I doubt that those attys are that dense, they are just "doing their job," trying to spin things in their client's favor.
As I've been perusing these documents (the HBI filings)
linked in a previous post, a number of things come to mind and I'll just list them in order as they appear in the
"Opposition to Motion to Dismiss" memorandum - the long and entertaining one. If you have that to hand, you can follow what I am noting here. I'm not commenting on everything, just what occurs to me as I read through it.
First of all, HBI did not send "numerous requests to defendants to cease the defamatory commentary. The request was received via email on Dec. 7th, and we took conciliatory action at that point as we have described (for which we are blamed by HBI in derogatory terms), posted the notice here in the forum (and it is still there) so that other posters would be aware of the situation, and after a few scattered comments, the thread went quiet on Dec 19, with no further posts until I announced the lawsuit on March 7. That is to say, the thread died, and we considered it over and done with. Had nothing further happened, (i.e. filing of a lawsuit) it would have been forgotten and buried forever.
The main changes that were made to the thread were made AT THAT TIME which
mainly included changing the thread title and I softened my comment ever so slightly, and this was announced in the thread as a conciliatory gesture. It was expected that posting the notice, announcing the change that we were willing to make, would bring the matter to an end.
HBI claims to have suffered 1.33 million in damages. How HBI could suffer 1.33 million in damages in a period from early November until the changes were made on December 7th, when the thread was effectively killed is beyond me!!! I reckon I must be in the wrong business since we are always broke and he's making that kind of money! And it's so bizarre that we get accused by those Vinnie Bridges and GLP nutzoids of being a cult. Obviously, I need to take lessons from Pepin about how to run a cult!
Another point is, considering the very limited number of readers of the thread - which I reviewed at the time and took a screen shot of the forum page that shows the page views - it is highly unlikely that more than a dozen or so of forum outsiders even read the thread. After you deduct the number of posts, active posters, the moderators daily checks, etc, there really isn't anything left! In other words, it can be proven that it is impossible for enough people to have even viewed the thread to have made any difference in Pepin's income.
Next:
One of the main planks of the HBI argument seems to be that, even though HBI is a company formed to market the "enlightenment" and "teachings stemming from that enlightenment" of Eric Pepin, it is declared that he has nothing to do with it.
On the other hand, I claim no enlightenment, just a work in progress, working with others, and I am conflated with QFG, QFS and sott to the extent that I am to be considered nothing short of some machaivellian mastermind. I'm not sure when I am supposed to have the time to do all the things it is claimed I do, especially since my health has been severely compromised for years now and I have to guard my energy carefully to be able to do my research and write, let alone manage my living space.
But, according to these goons, I control everything and it is all "the instrumentality" of yours truly!
That's some claim to make about me, now isn't it? I think it is defamatory.
Next item that catches my eye: I am accused of "dipping into the till," so to say, while the fact is ignored that the total QFG income, with which we fund dozens of projects around the year, is about what my husband made alone when working for the DOD sub-contractor in FL. Divided up among the projects and persons who are supported by this income, it's pretty obvious that we actually would qualify to be living below poverty level. Also ignored is the fact that I have licensed the profits from the sales of all my books to the benefit of QFG and its projects and, most of the time, book sales exceed donations so it could be said that, single handedly, I am the main support of QFG and all its projects!
Next point: Yes, indeed, QFG supports sott through supporting the researchers who are involved with that particular project. In that sense, SOTT is a PRODUCT of the researchers supported by sott. Our IRS filings list the various PRODUCTS of the work of those receiving QFG support. This also includes listing Ark's scientific papers as products of an individual receiving QFG support. QFS's efforts to increase general communication and understanding between peoples around the world without regard to nationality or ethnicity is also a product of its members who rely on QFG support for their modes of interaction. QFG also gave support to the Uni of Toulouse ICCA7 conference. Is it "owned" by QFG? Is it an "alter ego" of me or an "instrumentality"? No, it is a product of the work of QFG as is the work of a number of other scientists which is contributed to the pool of QFG efforts, articles, conclusions, etc.
The quantumfuture.net homepage says that QFS has "staff members" - that term is not used in the sense that is implied by Pepin's attys. All it means is that there are QFS members involved "as staff" in the SOTT news database project. The SOTT news project has editors who are NOT QFS members or affiliated with QFG in any way other than the fact that they QFG supported by virtue of participating in that project. The wording on the website is exactly this:
"in-depth commentary by Quantum Future School staff members."
That means that the in-depth commentary is provided by QFS members who volunteer to "staff" and oversee the SOTT working group, many of whom are NOT QFS members as already mentioned. Enter the term "volunteer staff" into google and you'll get over 400 thousand returns.
Pepin's attys assume: "presumably the staff members providing sott.net content and operating the site are also QFG officers, employees or agents." That's a mighty big assumption and, in fact, wrong.
Moreover, no one who works on SOTT is an "employee or agent" of QFG though, when working on SOTT some of them DO act in their capacity as members of QFS, "staffing" sott with guidance and writing commentary and analysis. Remember, QFS is our project to facilitate understanding and communication among peoples around the world, so that is a natural function of QFS in its relation to SOTT, which is a project of many QFS members who work with non-QFS members also. When working on SOTT, no one acts as an agent of QFG. It is a scientific project of databasing and analyzing current events with a view to solving the problems of humanity.
Suppose a person attends a certain specialized school (QFS). The school is funded and supported by some organization (QFG). Students of the specialized school are encouraged - as part of the educational process - to develop projects on their own or participate in projects that interest them. Say someone proposes to start a club for those interested in collecting archaeological artifacts, showing them, cataloging them, discussing them (SOTT). Maybe one or two of the teachers of the school are also interested in this project and may even have suggested the idea to the students and may have already been collecting artifacts and it just became a "club" by natural development. So, these teachers join the club because they are interested in the topic and wish to share their expert input to the students. Maybe one or two of the officers of the organization that funds the school are also interested in these topics and also join the club, not as administrators of the school, but with the intention of participation as members, sharing their collection, and participating in the discussion.
Now, would you think that the membership of the teachers in the club, or the membership of the officers of the organization that supports the school who join, are there in their capacity as "officers, employees, or agents" of the school or the organization that supports the school? Of course not, they are all there because they are interested in the topics of the club!
Oh, of course, the fact that they have met - encountered one another - is, in part, due to the fact that they are in proximity due to the fact that they attend this particular school (which suggests that they have common interests to begin with), or are working as part of the organization that supports the school, or are teachers at the school, but in the end, the archaeology club could and would exist without any of those organizational factors by virtue of the fact that people who are interested in similar things tend to collect together to share their interests. That is an organic process.
In the case of the archaeology club, yes, the facility they meet in is the same, but it changes its function according to the needs of those with access to it. Just as a classroom can be used for a meeting of the organization that supports the school, or a class, it can also be used as a meeting place for the archaeology club. They could meet anywhere else, it just happens that this meeting place is more convenient. The relationship between the club and the organization that supports the school could be said to exist, but is not really a controlling factor. Because the club does not require the organization or the school to exist or to continue to function, it just facilitates it in response to the needs/wants of the members. Further, the organization and the school did not require the club to exist either nor did it require the club to use one of its classrooms as a place to meet.
The only difference with QFG, QFS and SOTT, is that it is a virtual environment and the members are global and need a global virtual environment in which to "assemble." That is SOTT and this Forum. They are all different, but sometimes overlapping, products of the support of QFG for the members of QFS, as well as non-members of QFS who share the interests of QFS.
Now, regarding the removal of the QFS website: Yes, our webmaster removed the QFS website altogether since it mainly consisted of photo albums of various "archaeology club meetings", several of which were attended by well-known persons in science as well as many private individuals whose privacy will not be violated. There was nothing on that website about "structure and operations" that is not included in our IRS filings. Nothing. This is covered in our responses to HBI's filings.
Regarding current admissions to QFS, yes, I informed that person who signed onto our forum to inquire about the QFS website that QFS is not accepting applications at present for very obvious reasons. See this thread:
http://www.cassiopaea.org/forum/index.php?topic=8513.msg60911#msg60911
As mentioned above, we have some members who are totally private individuals, and we have some members who have some profile in the scientific community. It is not in their interests to have their names smeared because they are doing research into non-mainstream (i.e. not gov funded) topics. With people like Bridges and his gang out there working 24/7 to try to shut down the possibility of non-government controlled scientific research, we are EXTREMELY careful about who we admit to QFS. In case you aren't familiar with what happens to scientists in the academic world who don't toe the mainstream line, I can cite a few cases including that of Nobel Prize winner Brian Josephson. When he talked about his experiments in the "paranormal," a whole gaggle of people began to suggest that he needed psychiatric counseling at most, and a vacation at least.
There is the additional risk factor that many of us have already experienced of harassment and defamation by the Bridges/Williams GLP gang. Is that COINTELPRO? Well, I think we have pretty well demonstrated that it probably is by the very fact that this gang does what it does. It is either COINTELPRO or dangerous pathology, take your pick. See this thread: http://www.cassiopaea.org/forum/index.php?topic=9095
So, yeah, we are secretive about our membership, and maybe about some of the things they are working on (which is natural in science), but nothing else. We've actually made this clear in public writings on a number of occasions, so it is not "for reasons known only to them" that we guard the membership of QFS. Has nothing to do with the "structure" or "workings" - that's pretty public and always has been.
Regarding who operates SOTT.net, In my own declaration for this lawsuit, I pretty clearly state who operates sott.net - the editors who are, as described above, like members of an archaeology club. Their specific and individual identities will be protected for the same reasons that the members of QFS will have their identities protected.
Actually, when one observes the "line of force" of the arguments of HBI, it actually starts to sound like a political witch hunt. I suspect that if the identities of some of our editors were revealed, it would create a scandal at their institutions, they would lose their jobs, their lives would be ruined.
In this respect, the HBI/Pepin lawsuit has the distinct smell of a fishing trip. You see, it is clear that they seek to drive Discovery. My natural defense against being accused of being the Omnipotent Machiavellian Svengali Being would be to to show how all these other beings (Sott Editors, QFS members, Forum Moderators etc) are naturally capable and talented people doing what they want and like because that is their choice.
That reveals the drive for "Limited discovery" which is just another way to say that what they want is to do a dragnet through all our QFS and forum members to discover if anybody might possibly be an "agent of QFG" under my "mind control." That would provide identities and details about those who read sott, work on sott, read and participate in the forum, that the Vinnie gang haven't been able to obtain to date, though they have really tried for the past 7 years to get that information for their gov. sponsors.
So, basically, what we see is HBI/Pepin and this suit acting as a front for obtaining the very information that others have sought to obtain by other means for years.
What does that suggest?
The truth about QFG, QFS and sott is this: I don't control any of it: I'm just the one who takes all the flak because I refuse now, and will continue to refuse, to release any details whatsoever about anyone who reads or participates in SOTT or QFS activities. Period. If I have to go to jail for refusing to reveal that information, I'm ready. Ya'll come and get me.
But, I digress.
Regarding the fact that I have a signs of the times email on my personal website, yep, I do. But it's an old one from before sott.net became sott.net. It doesn't work anymore I don't think. I never received a single email from there anyway.
As for the reason I used a signs of the times email addy, that's pretty easy: because I don't give out my personal email due to the years of endless attacks from people like Vincent Bridges and gang. Also, I will point out the fact that my emails are often censored by my husband and others who do not allow me to read the hate mail from people like Vinnie Bridges or political right wingers because they know how deeply it upsets me and how adversely that sort of thing affects my health. So, far from controlling things, I am actually shielded from a great deal.
I'm not sure exactly how Pepin's attys took that short quote from my personal website and turned it into "proof" that I control everything since it was a pretty clear statement that I do NOT! But, that's "legal spin" for ya.
Note also that Pepin's attys don't seem to realize that there was no "underscore emphasis," but that the underscore was the html hyperlink coding. But that's just computer ignorance.
Regarding Pepin's attys attempt to characterize us as claiming to present the whole, objective truth and that's it, I'm not sure how they take a statement where we clearly say that we ATTEMPT to see objective reality, that we are LEARNING as we go, and that it is an ongoing process of UNCOVERING more as we go along, and turn it into an assertion that we are claiming to purvey the "purest form of truth" that is "unvarnished and objective."
There they go spinning again.
From our point of view, our stated mission strongly suggests that we are a "work in progress" and we don't have the whole banana, but we are working on it. Pepin, via HBI, on the other hand, DOES claim to have the whole Banana.
Regarding their assertion that I claim to "impart to the world higher forms of truth" blah blah. Gads, there they go projecting. That's what Pepin claims and HBI sells, not me. I do not ever claim that I "impart to the world higher forms of truth" but I do say I'm researching the facts of our present reality and working on understanding and explication.
I do not claim that I discover any of this through channeling alien life forms. THAT is defamatory. That is also straight from Vincent Bridge's playbook because that has been his rant for YEARS and is simply NOT true! Also, that is certainly NOT what my pages on cass.org say so we hit the spin phenomenon yet again.
Regarding the "channeling aliens" thing, I wrote about this in some detail on this thread: http://www.cassiopaea.org/forum/index.php?topic=9016 pointing out that the Cs are NOT "alien life forms" and never identified themselves as such. Unfortunately, Tom French, of the St. Pete Times, (or his editors) used the "channeling aliens " thing as a way to sell more papers, I guess. He made other errors in his article such as confusing me and some of my questions or information from the Cs with that of guests. But that's journalism for you. Except for these minor errors, he didn't do a bad job.
Now, regarding the conspiracy theorist "smear." Yeah, I'm a "conspiracy theorist" if that's what they want to call it. Yes, I do believe that the evidence shows that Israel was behind 9-11 in cahoots with the Far-right neocons. I'm not the only one who thinks that, however. People with more brains and public presence than me say the same thing. Heck, we published a great piece by Les Visible on the topic recently. See: http://www.sott.net/articles/show/159708-Israel-and-9-11-are-Siamese-Twins
But this point is interesting for a lot of reasons. Aside from the obvious attempt to present me as a nutcase, borrowing heavily from Vincent Bridge's own slander, libel, and defamation techniques, Pepin's attys later mention that Pepin's target audience is the kind of people who read sott. Hmmm... I don't think so!
But, let's suppose for a minute that this is true. That would mean that Pepin targets conspiracy theorists with his marketing. Yet his atty's mention this as a negative in respect of sott. That would suggest that Pepin, through his attorneys, is expressing contempt for the very people he seeks to persuade to become customers!
There's another, more sinister interpretation that can be put on this item: IF, in fact, Pepin targets "conspiracy theorists" as his potential customers, and wants to sell them his version of "the truth" and his "meditation techniques," and his "super duper psychic pill," and, at the same time, holds them in contempt, does that mean that these methods he is selling are really, as was suggested earlier in this thread, designed to "put people to sleep"??? !!! That does seem to be a conclusion that can be drawn from the memorandum.
Moving along now, next item that catches my eye is where Pepin's attys say I "operate and control" all other defendants. As mentioned above, I would have to be super-woman to do all the things that are attributed to me when the facts are so different as to be laughable. Half the time, when anyone asks me a question about how anything is done, who is doing what, who is responsible for what, I have to ask someone else to tell me because, quite frankly, I don't know!
I rarely involve myself in anything except HUMAN issues dealing with emotions, suffering, etc. I try to teach people how to understand and get along with others. I do seem to be good at that since I raised 5 children and I know how to be a referee. To call my input "policing and controlling" is so ridiculous that it is literally jaw- dropping. Like I said, these guys have been reading Vinnie Bridges rants and that guy really wants to destroy me because I ejected him from our groups long ago. He did not play nicely, you could say.
What do I do? Mainly, I read, research, and write. And everyone around me tries to ensure that I am able to do that with the limited amount of energy I have.
Next item: Yes, I reimburse what is spent on a QFS project (sott), sponsored by QFG with QFG funds. That's what it's for.
Now we come to the alleged "defamatory statements" in
Section C of the document. We notice that HBI is being separated from Pepin even though the alleged sexual misconduct occurred as a consequence of his HBI activities (claimed to be part of the teachings), and at HBI HQ according to the Oregonian articles. Very strange. Of course the articles cited in the thread did not make a specific reference HBI as being a front for pedophilia... but they sure talked about its founder, his ideas, and what he had been doing and where and for what reason! I think that any reasonable individual would have drawn the same conclusions from that information.
As noted already, I did not "post a sott forum thread" - the thread already existed - it had died in June, and was revived by another invasion of Pepin trolls in November. After dealing with all that, I changed the title of the thread to stop the nonsense. I noted in the first post of the thread:
Administrator's note: I have changed the title of this thread to better reflect the information that has been revealed about Eric Pepin and his "Higher Balance Institute."
That remark was NOT in the same post that I made the remarks about Eric Pepin and cointelpro and pedophilia, etc. Consequently, the accusation that I deleted that from my post is inaccurate at best, poor reading skills, failure to really examine the material, or something else. I never deleted ANY of what I had posted in the first post. It is still there. So this accusation (and the wildly dramatic way it is made) is quite simply defamatory.
As I have already written, after receiving the "take down demand" from Eric Robison, we did all we were willing to do: change the thread title, and I very slightly softened my comment. It was already soft because it began with "It's really starting to look like..."
So, the whole thing about a "shameful attempt to deceive the Court" is all a load of hooey and defamation to boot.
Next, they come back to the assertion that we hold the sott website out as a source of objective facts. That's not the case as I already covered above. The sott editors certainly make herculean efforts to sort through tons of material looking for definite facts in news sources or eyewitness accounts. SOTT makes it clear that they are working on it, that it is a process, that sott is not perfect and when it is wrong, they admit it and correct it.
This is just plain and simple spinning the facts. Geeze, these guys act like they studied law under Alberto Gonzalez or Mukasy or John Yoo or even Wayne Jaeschke!
Next we come back to the claim that many members of Pepin's target audience read sott and the obvious conclusion that, if that is the case, that must mean they are "into conspiracy theories." It also may suggest that Pepin's techniques may very well be designed to co-opt our audience and "put them to sleep" with his nonsensical meditation and "psychic pill" scam.
What's he doing trying to steal OUR readers and convert them to his nonsense?
Next item, Pepin's attys assumption that Robison's request for removal of the posts about Pepin was posted as mockery only indicates a rather twisted way of looking at the world. Geeze, talk about conspiracy theories! Even I'm not that paranoid!
As noted, we did all we were willing to do at that time to quash the discussion - changed the thread name, posted the notice, and let it "die." We are not in the habit of censoring discussions on matters of public interest as the case of Pepin and what goes on in his HBI most assuredly are.
What others had to say about Robison's request are not my responsibility.
Everyone who posts on the forum, myself included, post as an agent only of themselves unless specifically noted to be otherwise.
The next item is a doozie: To suggest that the QUALITY of HBI's metaphysical teachings and meditation products" have nothing to do with Eric Pepin and who and what he is is jaw dropping. Remember, HBI markets metaphysical products and claims to sell "the world's most advanced sixth sense meditation" program and a dietary supplement, "Magneurol6-S," that is guaranteed to make the consumer an "instant telepath", and all this came about because Eric Pepin says so because he is enlightened and a great remote viewer and so on. Oh, I suppose they will fall back on "no, the customers say so" or the company managers have tried it and they say so. But the bottom line is this: it originated with Eric Pepin and his alleged enlightenment. Eric Pepin is the "product of HBI."
Now, concerning Eric Pepin and his ideas and techniques, the PRODUCT that HBI sells, that is, in fact, the whole point. How can any meditation teachings - a product of the psyche of the individual creating them - be anything other than a reflection of that individual??? And it is a fact that Pepin was teaching some weird stuff. According to the court testimony, as reported in the Oregonian, the victim said:
"He [Eric Pepin] was going to try and fix my energy and he needed me to trust him," the accuser said. Pepin touched the teen's "chakra points" on his heart, head and lower abdomen.
"Eric asked me to tell him everything I had done in my life that I was ashamed about," the teen added.
Geeze, that's a technique taken right from the Skull and Bones Club initiation...
But within days the two were having sex, including a three-way encounter with Priebe, the youth testified. Pepin called it "crossing the abyss," the accuser said, "surrendering yourself to your teacher, your master."
Another article states:
Young said he met Priebe at a Starbucks, and within days was in the Higher Balance offices on Southwest Second Street in Beaverton. Investigators said the company appeared to be "cult-like" and said Pepin introduced himself dressed in a robe emblazoned with the words "Master Eric." Young testified that Pepin touched him sexually, and spoke of "crossing the abyss," a term referring to a heterosexual man performing homosexual acts for spiritual enlightenment.
Priebe and Pepin both denied this ever happened. Videotape seized from a safe at Pepin's house showed Priebe, Pepin and Young in a three-way sexual act, but the defendants insisted it happened after Young turned 18. Using a child in a sexual display is a Measure 11 crime punishable by a mandatory minimum of 5 years and 10 months in prison.
http://blog.oregonlive.com/hillsboroargus/2008/03/socalled_psychic_files_suit_ag.html
To try to so completely separate Pepin from HBI - when HBI is a company that essentially markets PEPIN and his "crossing the abyss" stuff - is so absurd as to be laughable.
Talk about "spin"!!!
I re-read Robison's take-down demand that is posted in this thread, and yes, he has Pepin and HBI connected together. But then, I re-read the retraction demand written by Renee Routhage, dated December 26, sent to the Colorado P.O. Box and re-mailed to us in a batch mailing, received by me sometime in mid to late January, and it specifically mentions HBI ONLY. There is no mention of Eric Pepin whatsoever.
So, it is clear that they realized that they didn't have a leg to stand on regarding Pepin himself, they aren't even defending him! The whole substance of their case is the claimed innocence of the legal entity, HBI - "an Oregon company".
It is also obvious that they are applying a double standard - one set of rules for Eric Pepin and HBI, and another set for me. As I mentioned above, it also strikes me that a lot of projection is going on. The truth about Pepin is being concealed and projected onto me!!!
As I also mentioned already, it really is beginning to look like a witch hunt, specifically targeting sott. They have tried to make it look like just a financial thing on the part of HBI, but that really doesn't hold water.
Bridges and gang have been defaming me for years in an attempt to suggest that anything I say or do is some kind of attempt to create a cult. He has never managed to succeed because people come to my website and, if they can read, they easily see that what he writes is nonsense. So, indeed, in a sense, my work and efforts are the inspiration for much of what QFG, QFS and sott do, but I am most certainly not the controller or owner since the essence of what I teach is that people need to think and act for themselves, to do their own research, to answer questions for themselves, to find what works for each of them individually.
Pepin, on the other hand, sells a "one size fits all" meditation technique that he claims is the one and only most advanced, super duper truth getter on the planet. On top of that, he sells a pill that could very well be dangerous to the health!
So just WHO is controlling who and identified with what here?
To say that HBI is not concerned here because it has never been accused of child sexual abuse is disingenuous at best, deliberately obfuscatory at worst. HBI IS ERIC PEPIN and ERIC PEPIN IS HBI because of the nature of what he is doing and selling!!!
To say that HBI and its products are not of public interest when they are advertised and sold to the public - including the fact that the target audience includes sott readers - OUR public - is so twisted I can't even wrap my head around it.
Moving along now we come to the point that HBI - not Eric Pepin - is sueing me, in particular. However, since I don't own sott or QFS or QFG, unlike Pepin, who DOES own HBI, he can't legitimately sue them. I was not acting as an agent of QFG or QFS or SOTT when writing my comments. I am a human being entitled to assess information and evidence and form an opinion and state that opinion. It doesn't matter what "title" anyone has on this forum, that is only to designate levels of permissions for operating the software and all opinions are the opinions of the writers unless specifically stated to be otherwise.
The yahoo case cited is really bizarre. Yahoo created false profiles and was sued for that, rightly so. What does creating false profiles have to do with a group of individual's from around the world discussing Pepin and HBI? If they are trying to claim that this applies because, supposedly, sott and QFS and QFG are responsible for creating or developing false identities or profiles by itself, that only reveals another part of their strategy for doing "limited discovery." Otherwise, it is stretching the ruling to the point of ridiculousness. That is so thin I can't even imagine that anybody with two neurons firing would buy it! (I won't comment on the neuron firing capacity of the individual who came up with that one and wrote it!)
So, we come to the part where they declare openly that the claims are being made against me, directly. I'll take the heat. Like I said, I am a human being entitled to read material and form opinions and state them. I am entitled to my opinion and judgment of Pepin and HBI based on the fact that it is of public interest, so much interest that it was published in a newspaper. I also have a particular interest in it because I am a mother of five children and knowing about pedophiles and sexual predators is of extreme interest to me as a mother, and to other mothers as well. As a member of the club of mothers, I feel it is a responsibility to warn other mothers that their offspring may fall victim to such individuals as Eric Pepin and his company, HBI, started by him to market HIM and his "enlightenment" and his procedures for enlightenment, such as the above described "crossing the abyss."
Pepin's atty's attempts to conflate ME acting on my OWN initiative, as my OWN agent, with my OWN opinion, with QFS, QFG and sott as responsible parties is just simply not the way things are. And again, that smells of a witch hunt with possible political motivations.
The example of the archaeology club is pertinent here. If Eric Pepin comes to the archaeology club and tries to pass off a plastic dinner plate as a rare archaeological find, and I expose his fraud, is he going to blame the archaeology club, the school, and the organization that funds the school, the teachers and the people who run the organization that he was exposed for his fraud by ME?
Even if he was exposed by a member of the organization that funds the school, or a teacher at the school, or an "officer" of the archaeology club, what does that have to do with the fact that he was making claims that were exposed as fraudulent, who exposed them, that he was kicked out of the club for his fraud? Each individual in the club is his own agent with his own mind and knowledge and right to utilize that. The exposure may, certainly, occur in a room in the school , the people who support the exposure of the fraud may be other members of the club, some of whom may be officials of the school, but each member presents his artifact and makes his claims as his own agent, and those that have the knowledge to criticize those claims does so on his own merits, is his own agent, and is participating because he is interested in the topic and for no other reason.
To say that Pepin was exposed for his fraud ONLY because he was trying to pull it off in a particular classroom of a particular school, supported by a particular organization, and because I am a teacher at the school, or because I am also a member of the organization that funds the school is totally absurd.
The fraud is what it is and the exposure is what it is regardless of the venue.
This whole thing amounts to Eric Pepin trying to find someone else to blame for his own failings. The most likely reason that his sales dropped is because the news of his court case spread over the internet by means other than the sott discussion which was, as I understand it, only one small exchange on the big wide internet with extremely limited readership.
Moving along: Section C of document: "To establish actionable defamation, a plaintiff must prove that a defendant made a defamatory statement that was false and that was communicated to a third party."
Wow, I can't believe that they think they can win on this one! Oh, of course! Pepin's criminal records have been sealed/expunged and they are going to try to keep them that way. And they are going to try based on the fact that Eric Pepin is not a party to the suit, it is HBI ONLY that is suing!!! Got that? Very clever. As ole StormBear would say, "Enron Clever"!
Fact is, under the circumstances, Pepin and HBI, owned by Pepin, which markets Pepin and his ideas, had already lost "esteem, respect, goodwill, confidence" because of Pepin's conduct for which he was indicted by a grand jury, tried, and only escaped conviction on a technicality according to the statements of both the judge and the prosecutor, according to the Oregonian. We didn't come up with that stuff, it was in the Oregonian! We just discussed it!
Based on the case citations Pepin's attys are using here, they really need to be suing the Oregonian, not us! If they actually have a case, they might stand to gain something by it. They will get nothing from me, QFG, sott or QFS.
Which brings me to another thing: The very fact that I, personally, and QFG and QFS and SOTT literally have NO assets is another curious point here. What is all this really about? The information about Eric Pepin and his antics is not going to disappear if they whack me and SOTT, QFG and QFS. In fact, as I've pointed out already, these guys aren't even defending Pepin. So what can they REALLY gain?
The only thing that they think they can get, and the thing they seem to be driving for is "limited discovery," i.e. a list of names and addresses or IPs or whatever of QFS members, SOTT editors, forum members, etc. They already know all about QFG because that is publicly available information.
Notice this: HBI - in their view - has absolutely nothing to do with Eric Pepin, the subject of the articles. HBI, which sells Eric Pepin, is pure as a newborn baby! It's just a "company" that never did anything bad to anybody. So that is their justification for suing which is driving toward "discovery."
"HBI had never been accused of having any involvement in such a depraved practice..." But PEPIN was! So, they are admitting that what Pepin was accused of WAS a "depraved practice" but gotta remember here that HBI can't be conflated with Pepin, even though Pepin is HBI, and HBI sells Pepin.
Absolutely bizarre.
Moving along now: They really do NOT like HBI being connected to the term "COINTELPRO" for some reason. As for COINTELPRO being "illegal" - well, that's a matter of opinion. Nowadays, all the stuff that COINTELPRO used to do illegally is now legal under TIA.
Their next point: "The totality of the circumstances". They are barking up the wrong tree here. If they assert that just because *I* say something as an opinion, that people will take it as a fact, that's totally absurd and quite contrary to what we promote on sott, in QFS, etc. So the "tenor" of the sott website argument flies out the window because we promote the exact opposite of what they claim we promote!
On the other hand, this could be another manifestation of "projection."
I think they are on dangerous ground trying to claim that there is no possibility that the statements cannot be proved true or false - unless, of course, they are relying on Pepin's criminal records remaining unavailable.
Next point: We do not hold ourselves out as "experts" in identifying COINTELPRO. We just point out that we have had a lot of experience. (Boy, have we!) And we share that with others.
I think that most readers would be left with the impression that HBI is rotten not because of anything I said, but because of the articles about Pepin that have spread like wildfire around the net mainly because people look it up in response to the appearance and bizarre claims and statements of the HBI trolls trying to sell more Pepin flicks and pills.
Next point: It should also be noted that the sott forum is just that, a forum. It is not the sott news site nor is it devoted to the sott news site. The forum has a sub-section for discussion of sott and news, but most of it is devoted to other things that have no relationship to news or even to sott! So applying the promotional words of the sott news site to the contents of the forum is mixing apples with oranges.
Next they come back again to their false assertions that I deleted part of my post. Again, there were no deletions of portions of my post. What I wrote is still there where it was originally written. Not only that, but we have a complete snapshot of the forum from back then that can prove it!!!! Thankfully, one of the sott forum members did that and made it available to me.
Next, for Pepin's (oh, excuse me, HBI's) attys to assert that what I wrote was disconnected from the facts contained in the Oregonian articles is bizarre beyond belief! I wrote what I wrote in direct reference to those articles and quoted the parts that I was concerned with!!! How could anyone think that what I said was based on anything other than an assessment of this information? Indeed, the Oregonian articles contain facts that lead me to believe that Eric Pepin is a lying pedophile, and those facts were direct quotes from both the prosecutor and the judge. If those quotes cannot be considered as facts, then Pepin needs to be suing the judge, the prosecutor and the Oregonian, not me.
The arguments following, that again conflate the sott news site with the forum are ridiculous. In hundreds of places on the forum it is made clear by my posts that my participation here is exactly on the same level as the participation of everyone else - it is a discussion among equals. Even if I do have the "powah" to ban or delete or whatever (as do others), I use it VERY sparingly. I prefer to help people to understand one another, not fight with one another. And that doesn't mean I'm a wimp, either.
However, it seems that Pepin and his attys don't understand that concept. They are so twisted up in their conspiracy theories about machaiavellian svengalis who control their minions (as Pepin obviously does) that one is forced to conclude that this is their world view and it colors everything they see.
Next, for these guys to say that the Oregonian articles are the very type of mainstream news that sott supposedly disavows and professes to discredit is again evidence of failure of reading comprehension. Perhaps they should notice that the news we carry on sott IS mainstream news and that we point out that the truth is out there, you just have to read carefully, compare, and look for the facts and consider the sources. That's the point.
In the case of the Oregonian, we aren't talking about an article about a political figure that might be slanted by undue influence as much of mainstream journalism is; we are talking about a story about a guy who was found not guilty on a technicality, which quoted the judge and the prosecutor remarks verbatim. Those quotes are facts, data. It all presents a picture of a real machiavellian svengali on a power trip: Master Eric Pepin.
Manny Otto was encouraged to find out how the forum works, to do his own research - but he didn't even understand what that means. He could have learned a lot about NLP and various psychological manipulation ploys and might have learned how they were evident in the work of Pepin, but he chose to simply think that he was being put off, toyed with. He wasn't. He was being told what everyone is told who wants to have simple answers handed to them on a platter: do your own work, do your own research, don't expect us to give you the answers!!!
Next item, very often, on this forum, references to COINTELPRO are hyperbolic; other times, they are not. We constantly refer to cointelpro as a MODEL even if, in some cases, it may actually be a gov psy-op. Obviously, no one can really tell the difference so the best policy is to just consider if it walks like a duck, quacks like a duck, swims like a duck, it's a duck. We also know that many cointelpro "agents" are unconscious of being "agents." That has been discussed in congressional hearings on MKULTRA mind control experiments conducted by agents of the CIA. On the sott forum, in many instances, "cointelpro" is exactly as hyperbolic as "horse hockey" and "fishy" and "bull feathers" etc. In other instances, which are usually made explicit, it CAN mean a real gov program. But in those cases, it would be so noted at least in context.
Regarding the cointelpro thing (which really bugs them for some reason!) they come back to the truth or falseness of the issues. "A statement is capable of such proof where it rests on a "core of objective evidence."
Is, or is not HBI involved in a government conspiracy to disrupt political dissidents? Well, you know what they say: if it walks like a duck, quacks like a duck, swims like a duck...
The very fact that this suit has been filed with no possible gain to HBI other than their drive for discovery of the names of QFS, SOTT, and forum members is certainly suggestive...
Is it conscious on the part of Pepin, HBI, or the HBI attorneys? Who knows? I don't. I just know the signs and I know that it is often NOT conscious and right now there's some duck behavior in evidence.
Next, the media defendant issue is interesting. Pepin's attys claim that we cannot assert that we are media defendants because we "scoff at and mock traditional standards of journalism." That is, in fact, not true. We strongly uphold traditional standards of journalism and employ them ourselves. We just don't see the mainstream media doing that. And that's not just our opinion, that's the opinion of many experts.
Next, they bring up the "alien revelations" bit again in a defamatory remark. Nicely done! Never mind that the sott news site has nothing to do with the cass website, and my experiments in those areas are kept separate. And, again note that the sott forum as a separate and independent project of QFS/SOTT encompasses all manner of discussions and is its own unique product of the people who post there.
Additionally, I would like to point out that the issue of "aliens" is very much a matter of newsworthy discussion - it is even discussed recently by the vatican . Add to this the fact that several people "in the know" have recently suggested that George Bush intends to convert to Catholicism after leaving office just as Tony Blair did, and one can't help but wonder if there is not a connection. Mainstream news articles on these topics can be found on sott!
Nevertheless, notice that no one purports ANYWHERE on sott news site to achieve "objective reality" through "revelations by aliens." Again, this is quite simply defamatory.
To say that the discussion of Eric Pepin - the author of a book about his one and only true method of obtaining higher consciousness (which includes, apparently, some weird group sex called "crossing the abyss"), seller of snake oil psychic pills, molester of young men, indicted by a grand jury, found not guilty on a technicality - is not a matter of public interest... is, to put mildly, jaw dropping.
To declare that what is a matter of public record about Pepin who IS HBI is false simply because Eric Robison says that HBI has never been accused of anything and Eric Pepin has nothing to do with HBI is ludicrous. For Robison to say that no children under 18 is permitted to be involved is a bit like closing the barn door after the horse has been let out.
Yeah, I communicated what I said to third, fourth, fifth - and however many other parties. It's a matter of public interest and SAFETY.
Now we come to HBI's damages. Boy, is this a load of horse hockey. (Not being hyperbolic here, either.) The remarks were published in November, and they claim to have lost 32 K in one month? Wow. With the readership of the sott forum being so miniscule, I'm not sure how that could even happen. Like I said, I took a screen shot of the page views of the thread in March. After deducting the moderators and posters to the thread, only a couple dozen possible readers remained, IF that!
The next month, AFTER the thread name had been changed, when the thread had died to the point that it had dropped off the google and sott forum radar because nobody was reading or posting to it, he claims a loss of 59 K! And then, another 37 K??? That's amazing! Methinks that something else is at work here and it ain't a discussion on sott!
And then, losing 705 K in long term revenue? From a couple dozen readers at most????
Oh, come on! That is so ridiculous it isn't even rational!
In contradiction to what HBI's attys claim, I would say that the damages DO result from the publication of the Oregonian articles and their gradual spreading across the internet because I can sure prove that not enough people even read that thread to make a dent in Pepin's operation. The forum counts every single page view. So these jerks need to be suing the judge, the prosecutor and the Oregonian, not me.
Pepin and HBI ARE public figures. If they weren't before the Oregonian published those articles, they sure were after!
Again, to try to separate Eric Pepin from the case because he is "not a party to this action," when HBI sells Eric Pepin and Eric Pepin IS HBI is bizarre beyond belief.
HBI brought suit on behalf of itself????
In that case, HBI needs to sue Eric Pepin for shaming the company that sells him and his claims.
And they say that they are suing us, not because of anything said about Pepin, but because of what was said about HBI??? Then why did Eric Robison's take-down letter talk about Eric Pepin and HBI in the same breath? See:
I am requesting you immediately remove any thread, story or article, regardless of content, mentioning Eric Pepin or Higher Balance Institute. You will also actively moderate to remove any mention of Eric Pepin, Higher Balance Institute from appearing on your sites in the future. As Quantum Future Group, Inc has created and allowed to continue harmful, damaging statements regarding these two parties it is clear that any content on your site involving these two entities will be used to cause further harm to Eric Pepin and Higher Balance.
Any future mention of Eric Pepin or Higher Balance Institute that is allowed to appear in static form or mature on your sites will constitute a failure to comply with this request. At that time we will immediately seek all damages related to this matter.
Quantum Future Group, Inc has also reprinted, or allowed to be reprinted, false, damaging statements made by news organizations and not followed up by offering or reprinting retractions regarding the false, libelous statements contained within those articles.
Your moderators and administrator have also made public, defamatory remarks regarding Eric Pepin and Higher Balance Institute. Among these statements:
- That Eric Pepin is a "psychopath" who "hunts for prey" (children) - That Higher Balance Institute is a front for pedophilia - That Eric Pepin is a "human deviant" - That Eric Pepin is a pathological deviant and his deviant followers con the public - That meditation, as sold by Higher Balance Institute, is an act of falling into confluence with a psychopathic reality
Most of those statements were made by an agent of your company, Laura. Given the anonymous nature of the internet where people can speak free of personal responsibility, I can see how you could be caught up in making such statements. Yet each of us are solely responsible for our words and actions regardless of where and in what format they take place. As the owner of sott.net, Quantum Future Group, Inc is responsible for the public views expressed by their owners and agents published on domains owned and run by them.
You have now been given notice the statements on your site are false, damaging, and have caused and are continuing to cause immediate, irreparable harm to Eric Pepin and Higher Balance Institute.
Please comply with my request within the next 24 hours or Eric Pepin and Higher Balance Institute will be forced to take immediate joint, legal action against Quantum Future Group, Inc, its owners and agents.
So, obviously, Eric Robison had a different view of things BEFORE he wrote his declaration for the HBI suit.
If he had written and made the difference between Eric Pepin and HBI clear, we would have gladly complied and removed HBI from the discussion since it was about Eric Pepin. But you see, Eric Robison obviously perceives Eric Pepin and HBI as one and the same entity.
Furthermore, as a properly formed and incorporated Oregon company, HBI is, by definition, a public entity.
On page 34, I am quoted completely out of context. It is certainly not evidence of "reckless disregard." Again, these guys demonstrate their poor reading comprehension. When I said I had never heard of Eric Pepin and didn't care about him, I was referring specifically to the initial invasion of Pepin trolls. It was only AFTER they behaved in such a persistent way, and AFTER the Oregonian articles were shared that I became interested enough to look into the matter.
Section D. HBI's claims for false light satisfy no claims as far as I can see.
The Oregonian published the matter and the Pepin trolls brought it on our forum, we only did due diligence and read the reports carefully, with an eye to details of fact; some members examined the Pepin/HBI material; and drew our own conclusions based on what was available.
Oh, yeah, Manny Otto promised that we would have a different view if we had the court transcripts and suggested we get them, but he probably knew they were no longer available. He didn't even bother to go back and check them and provide us with verbatim quotes as we asked him to. In fact, after we asked for that evidence, he disappeared and within an hour or so, Robison sent the take-down demand on behalf of Eric Pepin AND HBI.
Coincidence? I think not!
Certainly, a reasonable person would be highly offended by a false accusation that he or she is involved in the sexual abuse of children. It is certainly loathsome. But we notice that Pepin's attys are talking about HBI, which they are attempting to separate entirely from Pepin who, obviously, is loathsome in their eyes by the terms of their own arguments.
As to COINTELPRO, we rest on the duck argument.
Additionally one could certainly say that HBI's attys have made every effort to place me, QFG, QFS, sott, and others, in a false light.
This gang is nothing but a bunch of snake oil salesmen trying to sell a sick pervert as some kind of guru. Pepin is THE PRODUCT of HBI, and he's a sick puppy; even the attys he pays with his own money won't defend HIM.
Sure, our website receives about 10 to 14 K visitors per day, but that's the sott news site. Each thread in the forum counts the number of views and it's a certainty that they aren't reading the Pepin thread in any great numbers. Oh, yeah, since the start of the lawsuit, a lot more readers have come along, but before that, hardly anybody outside of forum members - who were not likely to be Pepin customers anyway - had read it.
If it looks like a duck, quacks like a duck, walks like a duck....