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Case 1:17-cv-01124 Document 2 Filed 04/24/17 Page 1 of 18

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF MARYLAND
NORTHERN DIVISION

KURT EICHENWALD, )
)
Plaintiff, )
) C.A. No. 1:17-cv-01124
v. )
)
JOHN RIVELLO ) Jury Trial Demanded
)
Defendant. )
)

CORRECTED COMPLAINT

Plaintiff Kurt Eichenwald, by his undersigned counsel, with knowledge as to his own acts

and status, and upon information and belief as to the acts and status of others, for his Complaint

against Defendant John Rivello, alleges as follows:

NATURE OF THE ACTION

1. This is an action commenced by Kurt Eichenwald against John Rivello. Mr.

Eichenwald is an award-winning journalist who suffers from epilepsy, a fact that Mr.

Eichenwald has repeatedly written about and is public knowledge. The action arises primarily

from events that took place on December 15, 2016. On that date, Mr. Rivello sent to Mr.

Eichenwald an electronic message over Twitter that contained an animated strobe image flashing

at a rapid speed and the statement "YOU DESERVE A SEZIURE FOR YOUR POSTS." Such

strobe images are known to trigger seizures in people with epilepsy, and as a proximate result of

Mr. Rivello' s actions, Mr. Eichenwald did in fact suffer a seizure and other substantial harm

upon receipt of the Twitter message at his home in Dallas, Texas. At the time Mr. Rivello sent

the Twitter message, he knew that Mr. Eichenwald had epilepsy, knew that a strobe image
Case 1:17-cv-01124 Document 2 Filed 04/24/17 Page 2 of 18

flashing at rapid speed was likely to cause Mr. Eichenwald to have a severe seizure, and intended

to cause precisely that result. Just like a terrorist who mails a bomb, or an envelope filled with

anthrax, Mr. Rivello knew and intended his Twitter message with a flashing strobe light would

cause serious harm-and perhaps even death-to Mr. Eichenwald. This action involves

common law tort claims under Texas law, including battery, assault, intentional infliction of

emotional distress, and purposeful infliction of bodily harm.

THE PARTIES

2. Plaintiff Kurt Eichenwald is a resident of the State of Texas and has his residence

in Dallas, Texas, where he lives with his wife.

3. Mr. Eichenwald is an American journalist who serves as a senior writer with

Newsweek and a contributing editor at Vanity Fair. Mr. Eichenwald previously worked for

twenty years at The New York Times as an investigative reporter, columnist, and senior writer.

He is a two-time winner of the George Polk Award for excellence in journalism, and was a

Pulitzer Prize finalist in 2000 and 2002.

4. Mr. Eichenwald is an author of four books, including Serpent on the Rock (1995),

The Informant (2000), Conspiracy of Fools (2005), and 500 Days (2012). Three of Mr.

Eichenwald's books have been included on the New York Times' bestselling list of books.

Additionally, in 2009 the Informant was made into a motion picture starring Matt Damon.

5. Mr. Eichenwald was diagnosed with epilepsy at the age of 18. While Mr.

Eichenwald suffered from frequent seizures as a young adult, more recently Mr. Eichenwald has

rarely experienced anything more than mild seizures after a medication change in approximately

2009. Another medication change in or around 2013 also improved Mr. Eichenwald's control.

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6. Mr. Eichenwald has been public about his epilepsy in order to serve as an

advocate for those with the condition.

7. Mr. Eichenwald was awarded a journalism prize from the Epilepsy Foundation of

America for his 1987 article titled "Braving Epilepsy's Storm," published January 11, 1987, by

The New York Times Magazine. Exhibit A. The article discusses, among other things, Mr.

Eichenwald's epilepsy diagnosis and how it almost cost him a college education. See id.

8. Mr. Eichenwald also publicly discussed his epilepsy in an article titled "Sean

Hannity: Apologize to Those with Epilepsy, or Bum in Hell," published in Newsweek on August

15, 2016. Exhibit B. In that article, Mr. Eichenwald wrote:

Despite having taken anticonvulsants for almost four decades, I-like many, many
others-have seizures that are not fully controlled. (Those are called refractory
seizures, if you care, Sean.) I have woken up, battered and bruised, when people
who thought they were helping did things to me they had learned from the movies
or television, things that were totally wrong. I lost a job and was tossed out of
college because people were terrified of my seizures.

See id.

9. Mr. Eichenwald's epilepsy is a subject of public knowledge and he continues to

talk and write about it publicly.

10. On information and belief, Defendant John Rivello is a resident of the State of

Maryland and has his residence in Salisbury, Maryland.

JURISDICTION AND VENUE

11. The amount in controversy exceeds the sum or value of $75,000 exclusive of

interest and costs and is between citizens of different States. Subject matter jurisdiction is

founded on 28 U.S.C. 1332(a)(l).

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12. Venue is proper in this District under 28 U.S.C. 1391(b), in that Defendant

resides in this District and a substantial part of the events giving rise to the claims occurred in

this District.

STATEMENT OF FACTS

13. Plaintiff is an active user of Twitter, which is a social media platform where users

can create accounts from which they can post, respond to, and react to electronic messages called

"Tweets." A Tweet may contain photos, videos, links, and up to 140 characters of text. See

Exhibit C. Users of Twitter may "reply" to a Tweet by including the @usemame of the account

that posted the Tweet. See Exhibit D. Users may also "mention" another account in a Tweet by

including the @usemame of the account they wish to mention, and the Twitter system will

recognize and link to the @usemame in the Tweet. Id. When there is a reply or mention to a

user's Tweet, the reply or mention will show up in the user's Notifications tab on Twitter where

the reply or mention can be viewed. See Exhibit E.

A. Background to the Attack on Mr. Eichenwald

14. Plaintiff has posted over fifty-thousand Tweets under his professional Twitter

account @kurteichenwald since joining Twitter in November 2010. Many of Plaintiffs Tweets

concern current matters of public interest as well as Plaintiffs opinions and work, such as

written publications, interviews, and other activities.

15. Plaintiff had been extensively covering the 2016 presidential election, and has

expressed criticism of Mr. Trump.

16. For example, on September 14, 2016, Plaintiffs article, titled "How the Trump

Organization's Foreign Business Ties Could Upend U.S. National Security," was published on

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the Cover ofNewsweek. Exhibit F. Plaintiffs September 14, 2016, article is critical of Mr.

Trump's business ties and the problems they could create during a Trump presidency.

17. As a result of his work as a journalist, and particularly his critical coverage of Mr.

Trump, Plaintiff has received numerous threats and messages over the Internet. Plaintiff

chronicles some of these threats in his article "How Donald Trump Supporters Attack

Journalists," published October 7, 2016, by Newsweek:

Because I have written critically about Trump, I have received innumerable death
threats, sometimes just general invocations that I should die, sometimes more
specific threats that I should be shot or "lynched," as one Trump fan wrote. I have
been called "kike," "Jew" and "anti-American Zionist," even though I'm
Episcopalian with a Jewish father (as if that makes a difference). I have received
video cartoons that look like they are from Nazi Germany of hook-nosed men
dressed in Jewish garb rubbing their hands greedily over piles of money. I have
been told to go back where I came from, whatever that means. I have been called
"fag," "pedo," and once-in an email that made no sense-"nigger-lover." One
Trump fan mentioned he knew which schools my children attended, and correctly
named them. Topping it off, some Trump fans have even gone after one of my
sons online, although he knew enough to immediately block them.

Exhibit G.

18. In the October 7, 2016, article, Plaintiff also describes that he was the target of an

attack on Twitter designed to trigger seizures in individuals like himself who suffer from

epilepsy:

A couple of weeks later, after my article about how Trump's business interests
would create a conflict of unprecedented proportions, I received a tweet from
someone with the twitter handle "Mike's Deplorable AF." Like many Trump
supporters, he has chosen to identify himself as deplorable to mock the label once
used by Clinton to describe the racists, neo-Nazis, homophobes and like who have
crawled out of the sewer to cheer for the Republican nominee. Mike, however, is
indeed deplorable.

In his tweet, which has since been deleted, Mike made mention of my seizures
and included a small video. It contained images of Pepe the Frog, a cartoon
character that has been identified by the Anti-Defamation League as a hate
symbol. I was carrying my iPad, looking at the still image on the video and,
without thinking, touched the PLAY button.

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The video was some sort of strobe light, with flashing circles and images of Pepe
flying toward the screen. It's what's called epileptogenic-something that triggers
seizures. Fortunately, since I was standing, I simply dropped my iPad to the
ground the second I realized what Mike had done. It landed face down on the
bathroom floor.

See Exhibit G.

19. Plaintiff had received the Tweet from the "Mike's Deplorable AF" Twitter on or

about the same night that Plaintiffs September 14, 2016, article criticizing Mr. Trump was

published on the Cover of Newsweek.

B. The Effects of Flashing/Strobe Lights on People with Epilepsy

20. Visual stimuli that form patterns in time or space, such as flashing lights and

strobe lights, can trigger seizures in certain individuals with epilepsy, particularly when they are

tired or under stress. This is sometimes referred to as photosensitive epilepsy.

21. Visible light, including flashing and strobe lights, is described in physics as an

electromagnetic wave formed by an oscillating electric and magnetic field.

22. Maxwell's equations define the relationship between electrical fields and

magnetic fields to form electromagnetic waves, such as visible light.

23. The discovery of Maxwell's Equations is summarized in the Feynman Lectures

on Physics as follows:

And thus is the universe knit together. The atomic motions of a distant star still
have sufficient influence at this great distance to set the electrons in our eye in
motion, and so we know about the stars. If this law did not exist, we would all be
literally in the dark about the exterior world! And the electric surgings in a galaxy
five billion light years away-which is the farthest object we have found so far-
can still influence in a significant and detectable way the currents in the great
"dish" in front of a radio telescope. And so it is that we see the stars and the
galaxies.

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See Exhibit H.

24. Albert Einstein subsequently published a paper describing his particle theory of

light, which states that "when a light ray is spreading from a point, the energy is not distributed

continuously over ever-increasing spaces, but consists of a finite number of energy quanta that

are localized in points in space, move without dividing, and can be absorbed or generated only as

a whole." See Exhibit I. Photons are the force carriers in visible light that give rise to forces

between other particles.

25. When a light wave reflects off an object and strike a person's cornea (the

transparent outer covering of the eye), that focuses the light wave.

26. The iris (the colored portion of the eye that surrounds the pupil), controls the

amount oflight that reaches the inside and back of the eye by automatically making the pupil

bigger of smaller.

27. The lens of an eye further bends the light and focuses and focuses it on the retina

located in the back of the eye.

28. The retina converts optical images into electrical impulses by a process called

visual phototransduction. The retina contains millions oflight sensitive cells, the most common

varieties called rods and cones.

29. The visual phototransduction process is initiated when the photons of light

corresponding to an optical image strike the light sensitive cells of the retina at the back of the

eye, and a vitamin A molecule, called 11-cis-retinaldehyde, contained in those cells changes

configuration.

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Case 1:17-cv-01124 Document 2 Filed 04/24/17 Page 8 of 18

30. The electrical impulses generated by the light sensitive cells of the retina will then

be transmitted by the optic nerve to the visual cortex, the part of the brain that controls Plaintiff's

sense of sight. See Exhibit J.

31. The receipt by the brain of the electrical impulses caused by a flashing or strobe

light can cause a seizure-including a fatal seizure-in a person with epilepsy.

32. In the October 7, 2016, article, Plaintiff described that his epilepsy makes him

vulnerable to such visual stimuli. See Exhibit G.

C. Mr. Rivello Attacks Mr. Eichenwald

33. On December 15, 2016, an anonymous Twitter user by the account name

@jew_goldstein or (((Ari Goldstein))) replied to one of Plaintiff's Tweets on Twitter.

34. The use of multiple parentheses, or an "echo," around a name on Twitter is a

typographical practice sometimes used to identify as user as an anti-Semite. See Exhibit K. The

Anti-Defamation League has listed the triple parentheses or "echo" in its Hate Symbols

Database, and its website explains that "in the spring of 2016, some anti-Semites began using the

echo when responding to or re-tweeting Jewish journalists, or journalists thought to be Jewish."

Id.

35. The reply from the@jew_goldstein Twitter account to Plaintiff included a

Graphic Interchange Format (GIF) file extension containing an animated strobe image flashing at

a rapid speed (the "strobe GIF'').

36. Defendant John Rivello created the @jew_goldstein Twitter account.

37. Defendant sent the Twitter reply to Plaintiff containing the strobe GIF.

38. Defendant knew that Plaintiff has epilepsy when he sent the tweet containing the

strobe GIF.

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39. Defendant intended that Plaintiff receive the strobe GIF when he sent the tweet

containing the strobe GIF.

40. The strobe GIF further depicts the words "YOU DESERVE A SEZIURE FOR

YOUR POSTS ."

41. A photo of Defendant's tweet on Twitter is reproduced below.


c:--- --v o , , .--.-- - - - - - - - - - - - - - - - - - - - - - --
All
176 new notifications

(((Ari Goldstein))) @jew_goldstein. 4m


@kurteichenwald

42. A screenshot of the strobe GIF sent by Defendant is reproduced below.

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Exhibit L.

43 . On December 15, 2016, at approximately 10:15pm central time, Plaintiff clicked

on the notification button on twitter, which immediately loaded tweets that had been sent to him.

The Defendant's tweet appeared, and the strobe GIF automatically started playing as it was

displayed in Plaintiffs browser on his computer in his home office in Dallas, Texas.

44. Defendant intended the strobe GIF to cause Plaintiff to have a seizure.

45 . As a proximate result ofreceiving and displaying the Twitter message sent from

Defendant with the automatically playing strobe GIF, Plaintiff suffered a severe seizure, as

intended by Defendant.

46. As a proximate result of Defendant's actions, electromagnetic waves of visible

light corresponding to the Strobe GIF, as received and displayed on Plaintiffs computer, struck

Plaintiffs corneas and passed through Plaintiffs eyes.

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47. As a proximate result of Defendant's actions, these waves of visible light passed

through Plaintiff's eyes' lens, which further bent the light in order to focus it on Plaintiff's

retinas.

48. As a proximate result of Defendant's actions, the photons from these waves of

visual light struck Plaintiff's retinas, which in tum generated electrical impulses that were sent to

Plaintiff's cortex.

49. As a proximate result of Defendant's actions, Plaintiff suffered a seizure from the

electrical impulses corresponding to the strobe GIF transmitting through Plaintiff's cortex.

50. Plaintiff's wife, Theresa, witnessed Plaintiff's seizure and made sure that Plaintiff

was in a safe location on the floor where he would not injure himself on any furniture during the

seizure. Once Plaintiff's seizure stopped, Plaintiff was unable to speak clearly and needed to

sleep to overcome its effects.

51. After witnessing Plaintiff's seizure, on December 15, 2016, Theresa posted on

Twitter, using Plaintiff's account, "This is his wife, you caused a seizure. I have your

information and have called the police to report the assault." A screenshot of the Tweet is

reproduced below.

Kurt Eichenwald [ ._ Follow


@kurteichenwald

@jew_goldstein This is his wrfe, you cause,d a seizur,e. I have your


infonnation and h1ave ca irred the police to report the assault.
11 -31 PM -15 Dec 2016

~ t."l- 2.627 4.028

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52. Plaintiff's wife called 911 to report the assault and was instructed to call the

computer crimes division. On calling that number, a recording instructed her to call back in the

morning, which she did, eventually leaving a message.

53. On infonnation and belief, Defendant had been corresponding electronically with

others, including through Twitter, about his intent to physically harm Plaintiff by causing

Plaintiff to suffer a seizure.

D. Arrest of Mr. Rivello

54. In a related criminal investigation, information was sought and obtained from

Twitter Inc., AT&T, and Apple, which led investigators in that case to believe that Defendant

operated the Twitter account, @jew_goldstein, which sent the tweet containing the strobe GIF to

Plaintiff on December 15, 2016. See Exhibit Mat~~ 16, 19, and 25.

55. Based on this information, a criminal complaint was filed in the United States

District Court for the Northern District of Texas on March 10, 2017, and an arrest warrant was

executed against Defendant on March 17, 2017.

56. As such, the information obtained in the criminal investigation included

information sufficient to identify Defendant as John Rivello, but the third parties' responses to

search warrants also contained additional information regarding other communications and

actions made by Defendant.

57. On information and belief, before and after his December 15, 2016 attack on

Plaintiff, Defendant discussed with one or more third parties Plaintiff's epilepsy, a desire to harm

Plaintiff, and how to maximize the chance and degree of harm inflicted on Plaintiff.

58. The contents of Defendant's communications with third parties concerning the

attack on Plaintiff, as well as the identities of those third parties, are presently unknown to

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Plaintiff. On information and belief, Defendant is in possession of information that would

identify such communications and third parties.

59. For example, on December 13, 2016, Defendant, using the@jew_goldstein

Twitter account, sent a direct message to other Twitter users stating that Plaintiff "[Plaintiff] 1

deserves to have his liver pecked out by a pack of emus." Exhibit Mat ,i 17.

60. On December 16, 2016, the very next day after Defendant's December 15, 2016,

attack on Plaintiff, Defendant, using the @jew_goldstein Twitter account, sent four direct

messages to other Twitter users stating: (1) "I hope this sends him into a seizure," (2) "Spammed

this at [Plaintiff] let's see ifhe dies," (3) "I know he has epilepsy," (4) "Ifl haven't been banned

yet check my feed when you wake up. @[Plaintiff]." Exhibit Mat ,i 17. The first and second

Twitter messages were accompanied by a linked or pasted item, such as a GIF or a photo. Id.

61. Additional review of the Twitter search warrant materials after the identification

of John Rivello include direct messages sent to the @jew_goldstein account further supporting

the association of John Rivello with that account. For example, a message on the day of the

strobe GIF tweet stated "Awesome JR," while another sent two days later also refers to "JR." Id.

at ,i 32.

62. Additionally, information was obtained from Apple's iCloud service as a result of

the search warrant. An iCloud account which was registered to John Rivello contained

information which links him to the sending of the tweet, related information regarding epilepsy,

information regarding Plaintiff - including other tweets, news coverage regarding the tweet, and

Plaintiff's personal information. Id. at ,i,i 27-31.

1
The cited affidavit identifies Plaintiff, Kurt Eichenwald, anonymously as "Victim#l ." Quotes with
[Plaintiff] from that affidavit refer to Kurt Eichenwald, but are written as [Victim#l] in the affidavit.

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63. For example, Defendant's iCloud account contained the strobe GIF which was

sent to Plaintiff. Id. at ,r 27. The iCloud account also contained a screen capture of that GIF

having been sent to Plaintiff's Twitter account and a tweet from Plaintiff's wife in response to

the GIF. Id. Additional screenshots in the account included a list of commonly reported epilepsy

seizure triggers and a news report discussing Plaintiff's prior efforts to identify the operator of

the @jew_goldstein Twitter account. Id. at ,r 30.

64. Further, the iCloud account contained a screen capture of Plaintiff's Wikipedia

page, which had been altered to show a fake date of death of December 16, 2016, for Plaintiff, as

well as including other edits including anti-Semitic references. Id. at 28. A review of the page's

history shows that the page appears to have been altered to show these changes in the early

morning the day after the strobe GIF tweet was sent. Exhibit N. These changes were continually

made and reverted over a period of about 40 minutes before the page was locked from revisions.

Id. This suggests that the person who took the screen capture was involved or at least monitoring

the vandalism of the page during this narrow time period.

65. On March 20, 2017, Defendant was indicted by a grand jury of Dallas County,

Texas, for the offense of aggravated assault with a deadly weapon by "inducing a seizure with an

animated strobe image." Exhibit 0. On information and belief, the grand jury was presented with

sufficient evidence to support such an indictment. On information and belief, Defendant is in

possession of much of the same information and other information of the type which was used as

evidence in, and supported, the grand jury indictment.

D. Harm to Mr. Eichenwald

66. Three business days later, on December 22, 2016, Plaintiff went to see his

neurologist, Dr. Venkatesh Nagraddi. Plaintiff was informed by his neurologist that the seizure

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caused by Defendant had increased the probability of more seizures, and that Plaintiffs dosage

of anticonvulsants should be raised for at least two months in hopes of preventing another

episode.

67. Plaintiffs children asked Plaintiff if he could delay increasing his medication

because they knew the increased dosage could have a significant impact on Plaintiffs ability to

think and function, and they hoped to avoid those problems until after Christmas.

68. However, on December 23, 2016, Plaintiff woke up in a post-ictal (post-seizure)

state. Plaintiffs speech was slurred, he had trouble getting out of bed, and his left arm was

paralyzed due to a post-seizure condition called Todd's Paralysis. Such symptoms could only

have been the consequence of a seizure Plaintiff experienced in his sleep.

69. Since Plaintiff had experienced another seizure, Plaintiff decided he had to

immediately increase his medication despite his family's hopes that he could make it through

Christmas without him having to deal with the significant side-effects of these drugs.

70. Plaintiff was sedated both on Christmas Eve and on Christmas because of the

Todd's Paralysis and increase in his medication, and required assistance from his family to

perform routine tasks.

71. Plaintiff was embarrassed, humiliated, and deeply upset that he had become so

dependent on others for basic care.

72. Plaintiff has suffered severe emotional distress as a proximate result of

Defendant's actions.

73. Plaintiff suffered and continues to suffer bodily and emotional harm from side-

effects from the increased dosage of medication as a result of Defendant's Twitter attack.

COUNTI
(Battery Under Texas Law)

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74. Mr. Eichenwald repeats and re-alleges each and every allegation of paragraphs 1-

73 as if fully set forth herein.

75. Mr. Rivello intentionally, knowingly, or recklessly caused Mr. Eichenwald to

suffer bodily injury because of his acts described herein. For example, Mr. Rivello's acts of

sending a strobe GIF Mr. Eichenwald over Twitter caused Mr. Eichenwald to suffer bodily

injury, including but not limited to a seizure.

76. Mr. Rivello, by his acts described herein, intended to cause a harmful or offensive

contact with Mr. Eichenwald, and a harmful contact with Mr. Eichenwald resulted. For example,

Mr. Rivello's acts described herein set a force in motion that ultimately caused Mr. Eichenwald

to suffer bodily injury, including but not limited to a seizure.

77. By reason of these acts, Mr. Eichenwald has suffered substantial injury.

COUNT II
(Assault Under Texas Law)

78. Mr. Eichenwald repeats and re-alleges each and every allegation of paragraphs 1-

77 as if fully set forth herein.

79. Mr. Rivello intentionally and/or knowingly threatened Mr. Eichenwald with

imminent bodily injury because of his acts described herein. For example, Mr. Rivello's acts of

sending a strobe GIF to Mr. Eichenwald over Twitter placed Mr. Eichenwald, who suffers from

epilepsy, in apprehension of imminent bodily injury, including but not limited to a seizure.

80. By reason of these acts, Mr. Eichenwald has suffered substantial injury.

COUNT III
(Intentional Infliction of Emotional Distress Under Texas Law)

81. Mr. Eichenwald repeats and re-alleges each and every allegation of paragraphs 1-

80 as if fully set forth herein.

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82. Mr. Rivello intentionally or recklessly performed the acts described herein, his

conduct was extreme and outrageous, his actions caused Mr. Eichenwald emotional distress, and

the resulting emotional distress was severe.

83. For example, Mr. Rivello's intentional and reckless acts of sending a strobe GIF

to Mr. Eichenwald, who suffers from epilepsy, over Twitter, is outrageous in character, and so

extreme in degree, as to go beyond all possible bounds of decency and is regarded as atrocious

and utterly intolerable in a civilized community.

84. Mr. Eichenwald's resulting distress is so severe that no reasonable man could be

expected to endure it and it is reasonable under the circumstances.

85. By reason of these acts, Mr. Eichenwald has suffered substantial injury.

COUNTIV
(Purposeful Infliction of Bodily Hann/Prima Facie Tort Under Texas Law)

86. Mr. Eichenwald repeats and re-alleges each and every allegation of paragraphs 1-

85 as if fully set forth herein.

87. Mr. Rivello purposefully caused bodily harm to Mr. Eichenwald by Mr. Rivello's

affirmative conduct described herein, and Mr. Eichenwald did not consent to Mr. Rivello's

conduct as described herein. For example, Mr. Rivello purposefully caused bodily harm to Mr.

Eichenwald, including the inducement of a seizure, by sending a strobe GIF to Mr. Eichenwald,

who suffers from epilepsy, over Twitter. Mr. Rivello's conduct was without excuse or

justification, and Mr. Eichenwald did not consent to Mr. Rivello's conduct.

88. By reason of these acts, Mr. Eichenwald has suffered substantial injury.

JURY DEMAND

89. Kurt Eichenwald hereby requests a trial by jury pursuant to Rule 38 of the Federal

Rules of Civil Procedure.

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PRAYER FOR RELIEF

WHEREFORE, Kurt Eichenwald prays that the Court enter judgment against John

Rivello and in favor of Kurt Eichenwald in his favor on each and every claim for relief set forth

above and award the relief set forth such that:

A. Defendant accounts for damages adequate to compensate Plaintiff for Defendant's

assault upon Plaintiff, battery upon Plaintiff, intentional infliction of emotional distress upon

Plaintiff, and purposeful infliction of bodily harm upon Plaintiff, together with prejudgment

interest;

B. Costs, including reasonable attorneys' fees, be awarded to Plaintiff;

C. Plaintiff be granted such other and further relief as the Court may deem proper

under the circumstances.

DATED: April 24, 2017

Steven Lieberman
Jennifer B. Maisel*
607 14th Street, N.W. - Suite 800
Washington, D.C. 20005
Tel: (202) 783-6040
Fax: (202) 783-6031
Email: slieberman@rfem.com
Email: jmaisel@rfem.com

Attorneys for Plaintiff

*Application for admission pro hac vice is being filed herewith.

18
EXHIBIT A
BRAVING EPILEPSY'S STORM - The New York Times http://www.nytimes.com/1987/01/11/magazine/braving-epilepsy-s-storm....

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January 11, 1987

By Kurt Eichenwald; Kurt Eichenwald is on the staff of The New York Times.

I WITNESSED AN EPILEPTIC seizure for the first time in 1979, when I was 18. In the center of my
college dining hall, a young man who worked in the kitchen had collapsed in a convulsion. Four
students quickly piled on top of him. His arms and legs jerked violently and, in the process of trying
to hold him down, the students seemed to be smothering him. The young man's face, twisted and
red, made him appear to be in great pain and, somehow, inhuman. Yet I could see myself in his
place - I had just found out that I had epilepsy.

I did not want to say anything, but I thought the four students, in their panic, might kill the young
man. So I told the largest of them, who by then had a headlock on the kitchen worker, to let go. The
student brushed off my concern and seemed irritated that I would bother him at such a time. I
paused, then repeated my statement in louder tones.

The student was angry. ''Look, kid,'' he said, ''I'm a pre-med. I know what I'm doing. What makes
you think you know so much?''

I opened my mouth, but no words came. Instead, I walked to a corner and leaned against the wall.
As the young man's convulsions grew more violent, I whispered an apology to him and began to cry.

Just four weeks before, back home in Dallas, a neurologist had diagnosed my epilepsy. The doctor
warned me - and so did members of my family soon afterward - that if I did not keep my epilepsy a
secret, people would fear me and I would be subject to discrimination. Even now, seven years after
that scene in the dining hall, it is difficult for me to say that I have epilepsy. Back then, it was
impossible. In the years since, I have had hundreds of various types of seizures. I have experienced
the mental, physical and emotional side effects caused by changes in the anticonvulsant drugs I take
each day. Yet, for the first two years, I refused to learn about epilepsy. My fears of being found out
were my real concern.

But from the beginning, I kept a sporadic record of the impact epilepsy had on my life. I wrote notes
to myself and eventually made tape recordings, expressing feelings I thought no one else could
understand. Later, I asked my family and friends to record their own feelings about dealing with
someone with epilepsy, promising not to listen to the tapes for years. I heard the tapes and read all
of the notes for the first time in preparation for this article.

My note-taking began the evening after the kitchen worker's seizure. In my room, I took out a piece
of paper and wrote: ''Look, kid, I'm a pre-med, I know what I'm doing.''

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EPILEPSY IS A CONDITION ENCOMPASSING about 20 different types of seizures, uncontrolled


bursts of electrical energy in the brain. Convulsions, while among the most dramatic, are only one
type of seizure.

According to the Epilepsy Foundation of America, there are more than two million Americans with
epilepsy. Half have what I have, idiopathic epilepsy, meaning there is no known cause for the
seizures. Of the two million, partly because of misunderstanding about the symptoms, about three-
quarters of a million go undiagnosed or untreated.

By the time I arrived for my freshman year at Swarthmore College in 1979, I had already had many
seizures, although my family, friends and I did not know it.

''You always had these staring spells, but it never worried me,'' Mari Cossaboom, a longtime friend,
recalled. ''Everyone always said they were happening to you because you were tired.''

My staring spells - periods of a few seconds of mental absence -had been going on for as long as I
could remember. Although I mentioned them to my doctor and my parents occasionally, the events
did not seem significant.

Then, in my first semester at college, I was horsing around in the dorm with my roommates, and I
fell, hitting my head against a chair. I had a concussion. No one to this day knows if the concussion
affected my seizures, but the staring spells soon increased in frequency and severity. I learned they
were different from other people's passing moments of distraction.

I remember once, in the dining hall, suddenly realizing everyone was looking at me. My lap was wet.
I thought someone had thrown something at me. In fact, I had begun to stare while holding a glass
of Coca-Cola in my hand. It had fallen between my legs and shattered.

I do not remember my first major seizure, which followed soon after. Mostly, I remember my own
stunned silence. My memory of the visit to my first neurologist, in Dallas that Thanksgiving, is
sketchy, although, sitting in a hospital hallway waiting to have my first CAT scan, I recall thinking
that I might have a brain tumor and could die.

After the scan, an electroencephalogram and other tests were over, my neurologist told me that I
had epilepsy. I was overjoyed. I did not completely understand the meaning of the diagnosis, but I
knew I was not dying.

The doctor gave me several warnings: Never tell anyone unless necessary, because I might be
ostracized. Call it ''seizure disorder,'' not epilepsy, because fewer people would be frightened. Try to
choose a profession as free from stress as possible.

For a long time, I followed his advice, afraid that if the truth were known, I would lose my friends
and never get a job.

I was given a prescription of Tegretol, an anticonvulsant, which I believed would stop the seizures
almost immediately. I was wrong.

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''So many people come in and think seizure control is easy,'' Steven Linder, a neurologist in Dallas
who later witnessed one of my convulsions, said to me recently. ''Seizures often aren't controlled on
the first try, or the side effects are too severe. So we have to adjust the medication or eventually try
another.''

That Thanksgiving vacation, I started adjusting to my new restrictions: I could not drive until the
seizures were controlled, I could not drink alcohol and I had to stay rested.

I first learned of the difficulty epilepsy posed for my relatives in a conversation with my father.
When I mentioned my concern that my epilepsy was not controlled, he tersely replied that I had a
seizure disorder, not epilepsy. When I said the words meant the same thing and he refused to listen,
I realized that he did not accept my condition.

My father is a pediatrician, but with his own family, his reactions were more human than scientific.
''I went through a fairly long period of denial,'' he would say later. ''I kept thinking this was a
passing sort of a thing, perhaps because you'd taken a fall. I thought it would just heal and go away.
Then when it didn't, I tried to put it out of my mind.''

At the time, I could not understand my father's reaction. Much later, however, I realized it was the
same as my own. Over the next two years I sometimes ignored the limitations on my life and
sometimes did not talk to my doctor. I also asked the doctor to say nothing to my parents. I knew my
condition deeply troubled my family and that made me feel guilty. Unlike the other feelings that
accompanied my condition, guilt was one I could control. I stopped talking about my epilepsy.

WHEN I RETURNED TO SWARTHMORE, I told my roommates about the diagnosis and


emphasized the importance of secrecy. Carl Moor and Franz Paasche took it in stride. For the next
few years, they would learn to cope with my deteriorating health. At night, when the seizures most
often occurred, I stayed in my room, hiding my condition. My roommates understood. ''It was
tremendously important for you,'' Franz said later, ''to see that those of us who knew still loved you
and that you weren't going to become a pariah.''

The seizures always felt the same way, and Carl and Franz told me of my consistent behavior. As my
brain builds towards a convulsion, I slow down, mentally and physically. My speech slurs and my
syntax inverts. My face gets pale and my eyes dilate. I become difficult to engage in conversation.

I experience what is called an ''aura'' as random brain cells start to fire. I feel a sense of separation.
My head throbs, and I see a flash of lights. Even today, I am not sure of the order of these feelings or
the amount of time separating them.

As the electrical firestorm sweeps across my brain, I lose consciousness and fall to the ground. The
muscles in my body tighten up and my jaw clenches, the teeth possibly biting and bloodying my
lips, tongue or cheek. My body jerks for a period, usually for less than a minute. During that time, I
often get excessive amounts of saliva in my mouth, creating a froth. My breathing becomes irregular,
sometimes even stopping. I also can become incontinent.

The convulsion ends, and I fall into a deep, though brief, sleep. As I wake up, another seizure can be

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triggered, starting the process again.

While unconscious, I do not respond to pain, such as the injection of needles. I have awakened
half-frozen in a snowdrift but unaware, until my waking, of the cold.

When fully awake, I am very confused and panicked. Often, it takes time for me to realize a seizure
has occurred. I am unsure where I am, who is with me or even what day it is. My speech is broken,
and I stutter horribly, so that I am unable to ask questions except of the most patient observers.

CARL AND FRANZ developed a routine that always reassured me when I woke up. They would
identify themselves, tell me I had had a seizure, where I was, the time and, if they knew, what I was
doing before it began. Carl would make jokes to lighten the event, such as reciting dialogue from the
scene in ''The Wizard of Oz'' where Dorothy wakes up in Kansas. The humor and the consistency let
me know I was safe. My fears calmed, I would fall asleep for anywhere between 15 and 23 hours.

Over time, my roommates won my complete trust. While ty y occasionally made mistakes, they were
always calm when I awoke. They never treated me with pity; my seizures were treated with an
attentive disregard. We were normal friends who had fights along with fun, petty hatreds along with
love.

That was enormously important in helping me believe I could live in the world with epilepsy
without excuses. Each time I began to get an emotional foothold, however, a seizure would send me
back into despair.

After each convulsion, I called my doctor in Dallas, hoping to learn what had gone wrong. In late
April of 1980, he added another anticonvulsant, Depakene, to my daily drug regimen. Weeks later,
my seizure control still had not improved, but I had no thought of changing doctors. I still saw him
as my only chance.

''If people are not happy with their seizure control and have not been re-evaluated for a couple of
years,'' William N. McLin, executive vice president of the Epilepsy Foundation, said in a recent
interview, ''our advice is run, do not walk, to a new doctor.''

B ECAUSE OF MY trust in my roommates, I began to go out at night with them, increasing the
likelihood of a public seizure. My hopes that I could keep my secret ended one morning in the dining
hall, when two acquaintances were talking about a rock concert that had taken place the previous
night. One complained that the fans were having ''epileptic seizures.''

''They couldn't be,'' the second student said. ''Kurt wasn't there.''

Embarrassed and ashamed, I stared down at my breakfast. His comment, while not malicious,
stunned me. I had lost control of my secret.

Because of my expanded freedom, though, I met Julia Cutler, a junior, and soon faced a new
problem - explaining my seizures to a girlfriend. It took me days to overcome my fear of rejection.
Finally, I realized that if I did not tell her, my symptoms eventually would.

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One night, sitting on a curb with Julia, staring at my knees as I spoke, I rambled through an
explanation of my condition. She was compassionate and wanted to know what she should do if I
had a seizure. Some of what I told her, I later learned, is part of the first aid recommended by the
Epilepsy Foundation to anyone who witnesses a seizure.

The first thing to remember is to stay calm and reassure others. Clear away hard objects and loosen
neckties. Then, put something soft, such as a jacket, under the head. Turn the person on his side to
keep the airway open. Do not hold the person down. And do not worry about tongue swallowing.

The myth that people with epilepsy swallow their tongues is very injurious. When I had seizures
without my roommates present, I would often wake up with my gums bleeding, my teeth hurting or
my jaw aching. Often, well-intentioned people, believing I would choke on my tongue, tried to force
open my clenched jaw to put in a hard object. My teeth would then crush against it. One person I
know of had his mouth pried open with a bottle opener; several teeth were broken.

An ambulance is not necessary unless the seizure lasts for longer than 10 minutes, or unless another
begins soon after the first, or unless the person cannot be awakened.

After the person wakes up, someone should calmly describe what happened and, if the person is
ready, help him to leave or, if he wants to go to sleep, ask him if there is anyone to call who can get
him home.

In the months that followed this conversation, as I began to talk about my fears, I recognized the
mistakes I had made. I told my parents that I was very sick, that I had kept them in the dark to
protect myself. With their help, I arranged to see a new neurologist near the school in March 1981.
He said I had complex-partial seizures and generalized seizures but that my prior treatment had
been insufficient. He increased my dosage and told me to call after every convulsion.

After my third call, he told me to increase my dosage again and continued to increase the drugs until
late April, by which time I was taking 11 pills a day.

I began to stagger slightly and developed continual nausea coupled with intense heartburn. I
thought I had the flu. Most confusing for me, my convulsions increased until they occurred every
other day.

When my hair began to come out in my hands, I knew the medicine was making me sick. My doctor,
however, attributed my symptoms to stress.

In June, dazed by seizures and 35 pounds lighter than just four months before, I traveled with my
roommate Carl to his home in Chicago. A doctor there, in the course of a routine blood test, found
that the drugs I had been given had reached a toxic level and were killing me. They were
suppressing bone-marrow production and giving me the symptoms of leukemia. The medication was
stopped, and phenobarbital, another anticonvulsant, was substituted.

Carl had invited me to Chicago that summer because he knew that, unable to drive, I often got
stranded in Dallas. Chicago had a subway system, and I could get around. I got a job as an intern for
a political action group.

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My blood tests returned to normal, but my seizures, though milder, often occurred more than once a
day and were more varied because of the rapid change of medicine. I began to fall to the ground with
little warning. I fell against a pot of boiling water. I fell down staircases and in the middle of a busy
street.

I had decided by then that nothing could be done for me, that my seizures simply could not be
controlled. I had no choice but to live my life always expecting another seizure.

My parents begged me to return home, but I told them that, with a doctor in Chicago, leaving my job
for Dallas would not make any difference. Unsure of what to do, my mother tried to understand the
nonmedical aspects of epilepsy. She went to the Epilepsy Foundation in Dallas and told a counselor
my story. She asked if she and my father should take me home despite a threat I had made to run
away if they tried. She was told, she said on a tape, that ''Kurt must be allowed to come to terms
with this in his best way, and that he must be allowed to make his own decisions. Otherwise, he
might give up.'' Toward the end of the summer, with my work at the office suffering badly, I
reluctantly went home to see a new neurologist my mother had found. I had grown tired of doctors
and did not want them to hurt me anymore. I was convinced I would not live to see my college
graduation. I would die from an accident, a stroke or by my own hand.

When I met Allan Naarden, the doctor whose patience and wisdom would save my life, I thought he
was odd. He was cheerful, not aloof like the others. He quoted Greek mythology and Henry James as
often as medical textbooks. He explained to me why he thought we should try a particular
treatment. No doctor had done that before. He was against hiding, saying it encouraged ignorance
in the people around me. He also said that he could not guarantee I would ever get complete control,
but I could get better control. I cried, relieved to have found a doctor who was honest about the
limits of medical knowledge.

After tests, Dr. Naarden prescribed Dilantin, another anticonvulsant. My sudden ''drop attacks''
stopped. Soon, with convulsions occurring only twice a month, I finally believed that my life was
coming together.

I N SEPTEMBER, I RE-turned to Swarthmore for my junior year. I was happy, even though the
medication gave me severe drowsiness and slightly changed my personality, making me more dour
than I usually am. I began to tell friends about my condition, easing the burden on Carl and Franz.
For the first time in two years, I walked the campus by myself. Over the next weeks, I had two
seizures outside and campus security and the health center, not my roommates, dealt with them.

In the first week of November, the administration of Swarthmore dismissed me from school because
of my health. My fears from years earlier were realized. After my first eight weeks of honesty, control
of my life had been taken away from me.

My parents and Dr. Naarden had been told of the pending dismissal. Dr. Naarden wrote to the dean
advising against it. ''Educational opportunities lost in youth cannot be made up for later in life,'' he
wrote. ''It is extremely important for students to continue their education even if seizure control is
not perfect.'' My mother flew east to the school to meet with me and the college authorities.

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''Kurt began to come apart,'' she said later. ''He cried and he hollered and he begged and he pleaded.
He said, 'Don't do this, don't do this to me now. If you send me away from here, I will not come
back. I will not be able to make it.' ''

The administration's misunderstanding of epilepsy contributed to my dismissal. ''At Swarthmore, we


had put epilepsy in a closet,'' Janet Smith Dickerson, dean of the college, recently recalled. ''People
were frightened, because no one knew what was causing the seizures. But you had already reached a
turning point. We didn't understand enough to recognize that.'' After I arrived back home, my
dismissal triggered an intense rage. I screamed at my family, my friends, sometimes at myself on my
tape recordings. The explosion of anger was so strong that all of us worried that I was losing my
sanity.

My father changed. When it appeared that I would not be readmitted to Swarthmore, his own anger
overtook him. Finally accepting my condition, he became enraged that anyone would deny me a
normal life.

By December, I learned that I could not be dismissed from school because of my health under
section 504 of the Rehabilitation Act of 1973, which provides rights to the handicapped. With advice
from the Government's Health and Human Services, my family and I contacted school officials and
lawyers to get me back to school.

At the end of the first week of the second semester of my junior year, without going to court, I was
readmitted to Swarthmore and continued my studies as a political science major.

The school was beginning to understand my condition. ''We learned, as a school, that epilepsy is a
handicap,'' Ms. Dickerson said. ''But certainly one that is manageable and not one that should be
regarded as a significantly limiting disability.''

In my final years at school, I did not go back into hiding, but I never stopped being cautious. In
June of 1983, I graduated with distinction.

I found work as a political speechwriter and a writer with CBS News before joining the staff of this
newspaper. I now live in New York, where I can function without a car. The man and wife from
whom I rent my apartment know all about my condition. I carry an emergency card with the phone
numbers of people who can help. My epilepsy is under good control, although I still sporadically
have convulsions. I have had to struggle with various problems, such as the difficulty of obtaining
health insurance and sometimes of working with colleagues who are unsure, or wary of me. My
doctor tries for better control, still making occasional changes in my medication dosage, including
one while I worked on this article.

I still get angry that people with epilepsy feel driven to hide their condition, but I understand why. I
know now that there is discrimination and fear but have learned that the best way to address
(Continued on Page 36) that is through educating people and, if necessary, turning to the law.

I now believe what Carl once said to me: ''If everybody in the world knew now to deal with epilepsy,
if everybody in the world were not mystified by a seizure, if everybody in the world were willing to

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help out when they see a stranger have a seizure, then the life of people with epilepsy would be
infinitely easier. They would be able to go everywhere and do just about everything and not worry.''

I WITNESSED A SEI-zure for the second time when I was 22. I was in Washington for my first job
interview after college, and, while answering a question, heard a panicked voice cry out, ''Does
anybody know anything about seizures?''

I stopped in mid-sentence and yelled, ''I do.''

I was taken outside where an elderly man was having a convulsion in the street. One passerby was
pinning the man's shoulders to the ground. When I told him to let go, he did. I leaned down and
pulled off my coat to put under the man's head so that he would not hit himself on the sidewalk.

As I checked the man's pockets for signs that he had epilepsy - a bottle of medicine or a card - I
noticed the look of fear on the faces of the people surrounding him, a look I knew. And I was
surprised that something so minor was so shocking.

Someone came out of a building with a spoon to put in the man's mouth. I stopped him and
explained why it was unnecessary. The tension of the crowd eased.

The man woke up and was very disoriented. I explained what was going on, and he seemed calm.
Two people helped me get him back to the office I had left, where he sat and gradually became more
coherent.

Soon he said he wanted to go home. I got up and went with him to make sure he was ready to leave.

Walking down the street on a sunny day in Washington, I told the man not to feel embarrassed,
although I understood how he felt, because I had the same condition.

When we reached the corner, he took my hand and squeezed it. ''We're both gonna be all right,'' he
said.

I watched him slowly cross the street, and, for the first time, I believed that was true.

Drawing

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Sean Hannity: Apologize to Those with Epilepsy, or Burn in Hell Page 1 of 10

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OPINION

SEAN HANNITY: APOLOGIZE TO THOSE WITH


EPILEPSY, OR BURN IN HELL
BY KURT EICHENWALD ON 8/15/16 AT 11:56 AM

OPINION HILLARY CLINTON FOX NEWS 2016 PRESIDENTIAL ELECTION

For more than two decades, the lunatic fringe has gradually taken control of the Republican Party, thanks to
craven media figures like Fox Newss Sean Hannity.

A man who purports to be a dutiful Catholic, Hannity has made a career out of violating the ninth
commandment (or eighth in his faith) against lying about others. If Hannity stopped vomiting up falsehoods,

http://www.newsweek.com/sean-hannity-lies-hillary-clinton-health-490469 4/24/2017
Sean Hannity: Apologize to Those with Epilepsy, or Burn in Hell Page 2 of 10

his program would be nothing but a test pattern. From him and the others in the Who cares if its false?
conservative media camp, we have heard over the decades that Hillary and Bill Clinton murdered many
people, that the Bush administration found weapons of mass destruction in Iraq, that Obama could be on the
verge of declaring martial law, and on and on.

They are pretend journalists pumping out propaganda to scared, foolish people.

Try Newsweek from $3.25 per week


But now, Hannity and his ilk have gone too far with their recent lies about Hillary Clintons health, a
conspiracy theory conservative media groups have seized upon with no regard for truth. They have used
misrepresented photos, theories from quacks and other nonsense to back up their story line.

And then came a video of Clinton making goofy movements with her head when a reporter held a tape
recorder very close to her face. Being pulled in different directions by multiple speakers at once, Clinton
playfully acted like a bobblehead doll, smiling and then speaking after the joke was over.

Hannity and his lying pals shrieked: Clinton had a seizure! Right in front of the cameras! Are there many
seizures like that? Hannity said. This looks like violent, out of control movements on her part.

I know this response to Sean Hannity is a little raw, but as someone with epilepsy, I hope my editors will let
this slip through: Fuck you, Sean. Your willingness to deceive your viewersto degrade those of us with
epilepsy, to suggest something is a seizure when it looks nothing like one, to leave people dumber about this
conditionis unforgivable.

What kind of seizure do you think it was, Sean? Jacksonian? Tonic-clonic? Atonic? Complex-partial? You
have no idea, do you Sean? You dont even know what any of that means. You just spat it out, and in the
process made the lives of tens of millions of people who deal with this condition on a daily basis just a little
more dangerous and a little more unpleasant.

Despite having taken anticonvulsants for almost four decades, Ilike many, many othershave seizures that
are not fully controlled. (Those are called refractory seizures, if you care, Sean.) I have woken up, battered
and bruised, when people who thought they were helping did things to me they had learned from the movies
or television, things that were totally wrong. I lost a job and was tossed out of college because people were
terrified of my seizures. (I only was able to complete my education thanks to the government you hate so
much Sean, because the school broke the law when it booted me.)

Some Catholics still view epilepsy as religious punishment, which is why for centuries those with seizures
have not been allowed to become priests. Is Sean Hannity now saying we should be blocked from holding
public office as well?

Many people have heard that Chief Justice John Roberts of the Supreme Court has experienced seizures.
Unfortunately, Roberts doesnt talk about it, robbing the many, many children who suffer with this condition
of a possible role model, someone who could show them that they can accomplish anything, even if they have
epilepsy. And perhaps he wont talk about it because of people like Hannity who are sending the clear
message that people with seizures are somehow the other, something to fear.

http://www.newsweek.com/sean-hannity-lies-hillary-clinton-health-490469 4/24/2017
Sean Hannity: Apologize to Those with Epilepsy, or Burn in Hell Page 3 of 10

What makes it worse, other than Hannitys willingness to convey the message to millions of children that
their place in society should be limited because of their seizures, is that he has painted a false image of what
seizures look like and what to do about them. People do not smile during a seizure while standing upright
and then immediately launch into a coherent sentence. Theres no smiling because, if for some reason the
person experiencing the seizure has not collapsed to the ground in unconsciousness, the moment the body
begins to move uncontrollably is terrifying. After a seizure, someone does not instantly jump back into a
conversation, making jokes. Instead there is a period of at least 5 minutes (and often much longer) when the
person is unable to think clearly, is very confused, can have trouble speaking and other problems.

Worse yet, will epilepsy now become the next area of relentless condemnation for Hannitys gullible Fox
News viewers who believe they have found a new political talking point? Will people with epilepsy be more
reluctant to be open about revealing their condition because of Hannitys deceitful, ignorant attack?

Related Stories

Donald Trumps History of Lying Under Oath

An Open Letter to Paul Ryan on Donald Trump

Is Donald Trump Really Being Audited by the IRS?

Trump: Clinton, Obama 'Co-Founded' ISIS

The answer, Sean, is yes. While I know you almost never apologize for anything you do on the air, this sin
requires some penance. It can be done in secret if you dont have the character to make a public
pronouncement of regret. Write a check. Make a donation to help those you demeaned and damaged.

Here is the address for the Epilepsy Foundation:

Epilepsy Foundation
8301 Professional Place, Suite 200
Landover, Maryland 20785

As for anyone else reading this article, if Sean Hannity doesnt bother to take any public action, please let him
learn of your outrage by making a contribution. And make sure to call it just that: A contribution in honor of
those harmed by Sean Hannity.

And as for you Sean, if you are unable to show the backbone to undo the damage you have done, you can
understand why I say you purport to be a Catholic. If you really were one, youd be worried about burning
in hell for what youve done.

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EXHIBIT F
EXHIBIT G
How Donald Trump Supporters Attack Journalists Page 1 of 11

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THE SCOOP
HOW DONALD TRUMP SUPPORTERS ATTACK
JOURNALISTS
BY KURT EICHENWALD ON 10/7/16 AT 11:25 AM

Error loading playlist: Error loading file

THE SCOOP DONALD TRUMP EPILEPSY

Shortly after I wrote an article for Newsweek about how Donald Trumps business interests
could undermine national security should he be elected president, one of his supporters
assaulted me. He used the internet to do it.

Throughout my adulthood, I have never made a secret of the fact that I have epilepsy. Its better
controlled now than it has been during other parts of my life, but not completelymy
neurologist tells me I have intractable epilepsy, meaning treatment will never bring the
condition fully under control. I know how peopleparticularly childrenwith seizures suffer

http://www.newsweek.com/epileptogenic-pepe-video-507417 4/24/2017
How Donald Trump Supporters Attack Journalists Page 2 of 11

when uninformed idiots suggest they should impose limits of their lives or quell their
aspirations. So when Fox News blowhard and college dropout Sean Hannity practically drooled
in delight this election season as he falsely proclaimed that Hillary Clinton suffered from
seizures based on her acting goofy in a short video clip, it infuriated me. I knew how his message
would be heardpeople with seizures look ridiculous, they should be afraid of others laughing at
them, they should listen to the voices telling them they cant do what they want (even be
president). And so I raged at Hannity in the pages of Newsweek, on cable television news shows
and on Twitter.

A couple of weeks later, after my article about how Trumps business interests would create a
conflict of unprecedented proportions, I received a tweet from someone with the twitter handle
Mike's Deplorable AF. Like many Trump supporters, he has chosen to identify himself as
deplorable to mock the label once used by Clinton to describe the racists, neo-Nazis,
homophobes and like who have crawled out of the sewer to cheer for the Republican nominee.
Mike, however, is indeed deplorable.

Try Newsweek from $3.25 per week


In his tweet, which has since been deleted, Mike made mention of my seizures and included a
small video. It contained images of Pepe the Frog, a cartoon character that has been identified by
the Anti-Defamation League as a hate symbol. I was carrying my iPad, looking at the still image
on the video and, without thinking, touched the PLAY button.

The video was some sort of strobe light, with flashing circles and images of Pepe flying toward
the screen. Its whats called epileptogenicsomething that triggers seizures. Fortunately, since I
was standing, I simply dropped my iPad to the ground the second I realized what Mike had
done. It landed face down on the bathroom floor.

The deplorables are real. The deplorables are dangerous.

Because I have written critically about Trump, I have received innumerable death threats,
sometimes just general invocations that I should die, sometimes more specific threats that I
should be shot or lynched, as one Trump fan wrote. I have been called kike, Jew and anti-
American Zionist, even though Im Episcopalian with a Jewish father (as if that makes a
difference). I have received video cartoons that look like they are from Nazi Germany of hook-
nosed men dressed in Jewish garb rubbing their hands greedily over piles of money. I have been
told to go back where I came from, whatever that means. I have been called fag, pedo, and
oncein an email that made no sensenigger-lover. One Trump fan mentioned he knew
which schools my children attended, and correctly named them. Topping it off, some Trump

http://www.newsweek.com/epileptogenic-pepe-video-507417 4/24/2017
How Donald Trump Supporters Attack Journalists Page 3 of 11

fans have even gone after one of my sons online, although he knew enough to immediately block
them.

My family has been through this beforeit is sometimes a consequence of writing about
controversial topicsbut this is the first time we have discussed whether I should continue
investigating an issue. All of them agreed I should stay on this story since Trump wont release
much information about himself, digging up everything that can be found before the election is
important for the country. But why is this even a discussion? We do not live in a third-world
nation where journalists who report unpleasant realities are in danger. While I believe that most
of these threatsexcept for Mikesare from internet blowhards, why does my family even have
to wonder about this? And why am I convinced that, just by writing this article, Mike will get lots
of new Twitter followers and praise from profoundly evil people?

I am far from the only journalist exposed to the bottom-feeders among Trump supporters who
traffic in violence, threats, racism and anti-Semitism. In a tweet, Charles Blow, an African-
American columnist for The New York Times who has been harshly critical of Trump both in the
newspaper and on television, told me he is bombarded with racist fury through email. Katy Tur
of NBC reported in an article in Marie Claire that she had to be escorted out of a Trump rally in
December by Secret Service to protect her from raging Trump supporters who had sicced on her
by their candidate. She was also the primary subject of a death threat two weeks later on Twitter.

MAYBE A FEW JOURNALISTS DO NEED TO BE WHACKED, the tweet from someone with
the handle GuyScott33 read. MAYBE THEN THEYD STOP BEI[N]G BIASED HACKS. KILL EM
ALL STARTING W/ KATY TUR.

There are more. According to The Daily Beast, Bethany Mandel, a conservative essayist who has
written about her opposition to Trump, had been so violently attacked on social media that she
felt compelled to purchase a gun for protection. Jeffrey Goldberg, national correspondent for
The Atlantic, received an email telling him he would be sent to a camp when Trump wins.
After she published an article in GQ about Melania Trump, Julia Ioffe, a Jewish journalist,
received death threats by phone and email, and tweets showing vile images such as an anti-
Semitic caricature of a Jewish man on his knees being shot in the back of the head; she filed a
police report. Jonathan Weisman, deputy Washington editor of The New York Times, tweeted a
link to a Washington Post opinion piece that was harshly critical of the Trump phenomenon.
The vicious attacks on Weisman, who is Jewish, came quickly.

Jonathan Weisman Follow


@jonathanweisman

I will leave @twitter to the racists, the anti-Semites, the Bernie


Bros who attacked women reporters yesterday. Maybe Twitter

http://www.newsweek.com/epileptogenic-pepe-video-507417 4/24/2017
How Donald Trump Supporters Attack Journalists Page 4 of 11

Get used to it you fucking kike, tweeted one of the deplorables who goes by the handle
deplorable basket weave. You people will be made to pay for the violence and fraud you've
committed against us.

This is not an unavoidable consequence of a contentious political campaign. This is exceptional,


a circumstance brought about by the gutter rants of Donald Trump and his refusal to condemn
the racists, neo-Nazis and other deplorables who support him. That our country has reached this
point, where the line between modern American political supporters and Hitlers brownshirts is
becoming thinner by the day, is unacceptable. That GOP candidates have stood by and allowed
this ugliness to flourish without aggressively condemning their candidate for what he has set
loose, simply because they are seeking re-election or fear losing their jobs at the mid-terms, will
stain the Republican Party for decades.

I write this knowing that it will spur more vile and violent online attacks on me. I have warned
my children and my wife to be extra careful. And now that I have revealed how easy it is to inflict
an injury on me, until this election is over, I will not be pushing PLAY on any unsolicited video I
receive. Its simply too dangerous.

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http://www.newsweek.com/epileptogenic-pepe-video-507417 4/24/2017
EXHIBIT H
The Feynman Lectures on Physics Vol. I Ch. 28: Electromagnetic Radiation http://www.feynmanlectures.caltech.edu/I_28.html

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A A A

SUMMARY
MATHJAX

28Electromagnetic Radiation

281Electromagnetism

The most dramatic moments in the development of physics are those in which great syntheses take place, where phenomena which previously had appeared to
be different are suddenly discovered to be but different aspects of the same thing. The history of physics is the history of such syntheses, and the basis of the
success of physical science is mainly that we are able to synthesize.

Perhaps the most dramatic moment in the development of physics during the 19th century occurred to J. C. Maxwell one day in the 1860s, when he combined
the laws of electricity and magnetism with the laws of the behavior of light. As a result, the properties of light were partly unravelledthat old and subtle stuff
that is so important and mysterious that it was felt necessary to arrange a special creation for it when writing Genesis. Maxwell could say, when he was finished
with his discovery, Let there be electricity and magnetism, and there is light!

For this culminating moment there was a long preparation in the gradual discovery and unfolding of the laws of electricity and magnetism. This story we shall
reserve for detailed study next year. However, the story is, briefly, as follows. The gradually discovered properties of electricity and magnetism, of electric
forces of attraction and repulsion, and of magnetic forces, showed that although these forces were rather complex, they all fell off inversely as the square of the
distance. We know, for example, that the simple Coulomb law for stationary charges is that the electric force field varies inversely as the square of the distance.
As a consequence, for sufficiently great distances there is very little influence of one system of charges on another. Maxwell noted that the equations or the
laws that had been discovered up to this time were mutually inconsistent when he tried to put them all together, and in order for the whole system to be
consistent, he had to add another term to his equations. With this new term there came an amazing prediction, which was that a part of the electric and
magnetic fields would fall off much more slowly with the distance than the inverse square, namely, inversely as the first power of the distance! And so he
realized that electric currents in one place can affect other charges far away, and he predicted the basic effects with which we are familiar todayradio
transmission, radar, and so on.

It seems a miracle that someone talking in Europe can, with mere electrical influences, be heard thousands of miles away in Los Angeles. How is it possible? It
is because the fields do not vary as the inverse square, but only inversely as the first power of the distance. Finally, then, even light itself was recognized to be
electric and magnetic influences extending over vast distances, generated by an almost incredibly rapid oscillation of the electrons in the atoms. All these
phenomena we summarize by the word radiation or, more specifically, electromagnetic radiation, there being one or two other kinds of radiation also. Almost
always, radiation means electromagnetic radiation.

1 of 5 2/28/2017 6:12 PM
The Feynman Lectures on Physics Vol. I Ch. 28: Electromagnetic Radiation http://www.feynmanlectures.caltech.edu/I_28.html

And thus is the universe knit together. The atomic motions of a distant star still have sufficient influence at this great distance to set the electrons in our eye in
motion, and so we know about the stars. If this law did not exist, we would all be literally in the dark about the exterior world! And the electric surgings in a
galaxy five billion light years awaywhich is the farthest object we have found so farcan still influence in a significant and detectable way the currents in
the great dish in front of a radio telescope. And so it is that we see the stars and the galaxies.

This remarkable phenomenon is what we shall discuss in the present chapter. At the beginning of this course in physics we outlined a broad picture of the world,
but we are now better prepared to understand some aspects of it, and so we shall now go over some parts of it again in greater detail. We begin by describing
the position of physics at the end of the 19th century. All that was then known about the fundamental laws can be summarized as follows.

First, there were laws of forces: one force was the law of gravitation, which we have written down several times; the force on an object of mass m, due to
another of mass M, is given by

F = GmMe r / r 2,

where e r is a unit vector directed from m to M, and r is the distance between them.

Next, the laws of electricity and magnetism, as known at the end of the 19th century, are these: the electrical forces acting on a charge q can be described by
two fields, called E and B, and the velocity v of the charge q, by the equation

F = q(E + v B).

To complete this law, we have to say what the formulas for E and B are in a given circumstance: if a number of charges are present, E and the B are each the
sum of contributions, one from each individual charge. So if we can find the E and B produced by a single charge, we need only to add all the effects from all
the charges in the universe to get the total E and B! This is the principle of superposition.

What is the formula for the electric and magnetic field produced by one individual charge? It turns out that this is very complicated, and it takes a great deal of
study and sophistication to appreciate it. But that is not the point. We write down the law now only to impress the reader with the beauty of nature, so to speak,
i.e., that it is possible to summarize all the fundamental knowledge on one page, with notations that he is now familiar with. This law for the fields of an
individual charge is complete and accurate, so far as we know (except for quantum mechanics) but it looks rather complicated. We shall not study all the pieces
now; we only write it down to give an impression, to show that it can be written, and so that we can see ahead of time roughly what it looks like. As a matter of
fact, the most useful way to write the correct laws of electricity and magnetism is not the way we shall now write them, but involves what are called field
equations, which we shall learn about next year. But the mathematical notations for these are different and new, and so we write the law in an inconvenient
form for calculation, but in notations that we now know.

The electric field, E, is given by

q er r d er 1 d2
4 [ r c dt ( r ) c ]
E= 2
+ 2
+ 2
er .
0 dt 2

producing the field; e r


discoveries of the 19th century showed that influences cannot travel faster than a certain fundamental speed c
correct that the first term is Coulombs law, not only because it is not possible to know where the charge is now and at what distance it is now, but also because
the only thing that can affect the field at a given place and time is the behavior of the charges in the past. How far in the past? The time delay, or retarded time,
so-called, is the time it takes, at speed c

So to allow for this time delay, we put a little prime on r


that the charge carried a light, and that the light could only come to P
where it was at some earlier time. What appears in our formula is the apparent direction e r
at the retarded distance r

There are several more terms. The next term is as though nature were trying to allow for the fact that the effect is retarded, if we might put it very crudely. It
suggests that we should calculate the delayed Coulomb field and add a correction to it, which is its rate of change times the time delay that we use. Nature
seems to be attempting to guess what the field at the present time is going to be, by taking the rate of change and multiplying by the time that is delayed. But we
are not yet through. There is a third termthe second derivative, with respect to t
and that is all there is to the electric field from an arbitrarily moving charge.

The magnetic field is given by

B = e r E / c.

it is possible to write so much in such a small space, but (28.3) and (28.4) contain the machinery by which electric generators work, how light operates, all the
phenomena of electricity and magnetism. Of course, to complete the story we also need to know something about the behavior of the materials involvedthe
properties of matterwhich are not described properly by (28.3).

To finish with our description of the world of the 19th century we must mention one other great synthesis which occurred in that century, one with which
Maxwell had a great deal to do also, and that was the synthesis of the phenomena of heat and mechanics. We shall study that subject soon.

What had to be added in the 20th century was that the dynamical laws of Newton were found to be all wrong, and quantum mechanics had to be introduced to
correct them. Newtons laws are approximately valid when the scale of things is sufficiently large. These quantum-mechanical laws, combined with the laws of
electricity, have only recently been combined to form a set of laws called quantum electrodynamics. In addition, there were discovered a number of new

2 of 5 2/28/2017 6:12 PM
The Feynman Lectures on Physics Vol. I Ch. 28: Electromagnetic Radiation http://www.feynmanlectures.caltech.edu/I_28.html

phenomena, of which the first was radioactivity, discovered by Becquerel in 1898he just sneaked it in under the 19th century. This phenomenon of
radioactivity was followed up to produce our knowledge of nuclei and new kinds of forces that are not gravitational and not electrical, but new particles with
different interactions, a subject which has still not been unravelled.

For those purists who know more (the professors who happen to be reading this), we should add that when we say that (28.3) is a complete expression of the
knowledge of electrodynamics, we are not being entirely accurate. There was a problem that was not quite solved at the end of the 19th century. When we try
to calculate the field from all the charges including the charge itself that we want the field to act on, we get into trouble trying to find the distance, for
example, of a charge from itself, and dividing something by that distance, which is zero. The problem of how to handle the part of this field which is generated
by the very charge on which we want the field to act is not yet solved today. So we leave it there; we do not have a complete solution to that puzzle yet, and so
we shall avoid the puzzle for as long as we can.

282Radiation

That, then, is a summary of the world picture. Now let us use it to discuss the phenomena called radiation. To discuss these phenomena, we must select from
Eq. (28.3) only that piece which varies inversely as the distance and not as the square of the distance. It turns out that when we finally do find that piece, it is so
simple in its form that it is legitimate to study optics and electrodynamics in an elementary way by taking it as the law of the electric field produced by a
moving charge far away. We shall take it temporarily as a given law which we will learn about in detail next year.

Of the terms appearing in (28.3), the first one evidently goes inversely as the square of the distance, and the second is only a correction for delay, so it is easy to
show that both of them vary inversely as the square of the distance. All of the effects we are interested in come from the third term, which is not very
complicated, after all. What this term says is: look at the charge and note the direction of the unit vector (we can project the end of it onto the surface of a unit
sphere). As the charge moves around, the unit vector wiggles, and the acceleration of that unit vector is what we are looking for. That is all. Thus

q d 2e r
E=
4 0c 2 dt 2

(The parts that go as the square have fallen off so much that we are not interested in them.)

Now we can go a little bit further in studying (28.5) to see what it means. Suppose a charge is moving in any manner whatsoever, and we are observing it from a
distance. We imagine for a moment that in a sense it is lit up (although it is light that we are trying to explain); we imagine it as a little white dot. Then we
would see this white dot running around. But we dont see exactly how it is running around right now, because of the delay that we have been talking about.
What counts is how it was moving earlier. The unit vector e r
curve, so that its acceleration has two components. One is the transverse piece, because the end of it goes up and down, and the other is a radial piece because
it stays on a sphere. It is easy to demonstrate that the latter is much smaller and varies as the inverse square of r
when we imagine that we move a given source farther and farther away, then the wigglings of e r
radial component of acceleration is varying much more rapidly than inversely as the distance. So for practical purposes all we have to do is project the motion
on a plane at unit distance. Therefore we find the following rule: Imagine that we look at the moving charge and that everything we see is delayedlike a
painter trying to paint a scene on a screen at a unit distance. A real painter, of course, does not take into account the fact that light is going at a certain speed,
but paints the world as he sees it. We want to see what his picture would look like. So we see a dot, representing the charge, moving about in the picture. The
acceleration of that dot is proportional to the electric field. That is allall we need.

Thus Eq. (28.5) is the complete and correct formula for radiation; even relativity effects are all contained in it. However, we often want to apply it to a still
simpler circumstance in which the charges are moving only a small distance at a relatively slow rate. Since they are moving slowly, they do not move an
appreciable distance from where they start, so that the delay time is practically constant. Then the law is still simpler, because the delay time is fixed. Thus we
imagine that the charge is executing a very tiny motion at an effectively constant distance. The delay at the distance r
following: If the charged object is moving in a very small motion and it is laterally displaced by the distance x(t)
displaced is x / r
finally we get the law we want, which is

q r
E x(t) =
4 0c 2r
(
ax t
c ).
Only the component a x
unit vector in that direction does not wiggle at all, and it has no acceleration. So it is only the sidewise motion which is important, only the acceleration that we
see projected on the screen.

283The dipole radiator

As our fundamental law of electromagnetic radiation, we are going to assume that (28.6) is true, i.e., that the electric field produced by an accelerating charge
which is moving nonrelativistically at a very large distance r
of the charge, projected onto the plane of sight, and this acceleration is not todays acceleration, but the acceleration that it had at an earlier time, the amount
of delay being a time, r / c
it to understand all of the phenomena of light and radio propagation, such as reflection, refraction, interference, diffraction, and scattering. It is the central law,
and is all we need. All the rest of Eq. (28.3) was written down only to set the stage, so that we could appreciate where (28.6) fits and how it comes about.

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The Feynman Lectures on Physics Vol. I Ch. 28: Electromagnetic Radiation http://www.feynmanlectures.caltech.edu/I_28.html

Fig. 281.A high-frequency signal generator drives charges up and down on two wires.

We shall discuss (28.3) further next year. In the meantime, we shall accept it as true, but not just on a theoretical basis. We may devise a number of experiments
which illustrate the character of the law. In order to do so, we need an accelerating charge. It should be a single charge, but if we can make a great many
charges move together, all the same way, we know that the field will be the sum of the effects of each of the individual charges; we just add them together. As
an example, consider two pieces of wire connected to a generator, as shown in Fig. 281. The idea is that the generator makes a potential difference, or a field,
which pulls electrons away from piece A
electrons out of B
moment, and a moment later they are accelerating downward in wire A
this is a way of doing it. The net result is that we merely have a charge accelerating up and down as though A
short compared with the distance light travels in one oscillation period is called an electric dipole oscillator. Thus we have the circumstance that we need to
apply our law, which tells us that this charge makes an electric field, and so we need an instrument to detect an electric field, and the instrument we use is the
same thinga pair of wires like A
down on both wires. This signal is detected by means of a rectifier mounted between A
where it is amplified so we can hear the audiofrequency tone with which the radiofrequency is modulated. When this probe feels an electric field, there will be
a loud noise coming out of the loudspeaker, and when there is no electric field driving it, there will be no noise.

Because the room in which the waves we are measuring has other objects in it, our electric field will shake electrons in these other objects; the electric field
makes these other charges go up and down, and in going up and down, these also produce an effect on our probe. Thus for a successful experiment we must
hold things fairly close together, so that the influences from the walls and from ourselvesthe reflected wavesare relatively small. So the phenomena will not
turn out to appear to be precisely and perfectly in accord with Eq. (28.6), but will be close enough that we shall be able to appreciate the law.

Fig. 282.The instantaneous electric field on a sphere centered at a localized, linearly oscillating charge.

Now we turn the generator on and hear the audio signal. We find a strong field when the detector D
the same amount of field also at any other azimuth angle about the axis of G
the field is zero. That is all right, because our formula said that the field should be the acceleration of the charge projected perpendicular to the line of sight.
Therefore when we look down on G
when the charge is moving directly toward us. Secondly, the formula says that the electric field should be perpendicular to r
we put D
to some intermediate angle, we see that the strongest signal occurs when it is oriented as shown, because although G
is simply parallel to itselfit is the projection of the acceleration perpendicular to the line of sight that counts. The signal is weaker at 2
because of the projection effect.

284Interference
Next, we may test what happens when we have two sources side by side several wavelengths apart (Fig. 283). The law is that the two sources should add their
effects at point 1
is the sum of the two and is twice as strong as it was before.

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The Feynman Lectures on Physics Vol. I Ch. 28: Electromagnetic Radiation http://www.feynmanlectures.caltech.edu/I_28.html

Fig. 283.Illustration of interference of sources.

Now comes an interesting possibility. Suppose we make the charges in S 1


out of phase. Then the field produced by S 1
we should get no effect at point 1
this pipe we change the time it takes the signal to arrive at S 2
place where there is no more signal left, in spite of the fact that both S 1
cut one out, we can see the motion of the other. So the two of them together can produce zero if everything is adjusted correctly.

Now, it is very interesting to show that the addition of the two fields is in fact a vector addition. We have just checked it for up and down motion, but let us
check two nonparallel directions. First, we restore S 1
shown in Fig. 284. Now we should have at point 1
of these two in-phase signalsthey are both strong at the same time and go through zero together; the total field should be a signal R
the maximum noise, it should be at about 45
Indeed, we observe just such behavior!

Fig. 284.Illustration of the vector character of the combination of sources.

Now, how about the retardation? How can we demonstrate that the signal is retarded? We could, with a great deal of equipment, measure the time at which it
arrives, but there is another, very simple way. Referring again to Fig. 283, suppose that S 1
produce equal electric fields at point 1
that the acceleration should be retarded by an amount equal to r / c
possible to find a position at which the distances of D
distance
whole cycle; that is to say, the signal from the first antenna reaches point 3
of time it takes for the electric current to oscillate once, and therefore the two electric fields produced at 3
again.

This completes our discussion of the experimental verification of some of the important features of Eq. (28.6). Of course we have not really checked the 1 / r
variation of the electric field strength, or the fact that there is also a magnetic field that goes along with the electric field. To do so would require rather
sophisticated techniques and would hardly add to our understanding at this point. In any case, we have checked those features that are of the greatest
importance for our later applications, and we shall come back to study some of the other properties of electromagnetic waves next year.

Copyright 1963, 2006, 2013 by the California Institute of Technology,


Michael A. Gottlieb, and Rudolf Pfeiffer

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EXHIBIT I
Albert Einstein's Year of Miracles: Light Theory : NPR http://www.npr.org/2005/03/17/4538324/albert-einsteins-year-of-miracles...

books
ON AIR NOW
WAMU 88.5

1905: science's miracle year

Albert Einstein's Year of Miracles: Light Theory


Listen Queue Download

March 17, 2005 12:00 AM ET


Heard on Morning Edition

RICHARD HARRIS

1 of 9 2/28/2017 6:13 PM
Albert Einstein's Year of Miracles: Light Theory : NPR http://www.npr.org/2005/03/17/4538324/albert-einsteins-year-of-miracles...

Albert Einstein as a clerk in Bern, Switzerland, 1905.


Harvard University Press

One hundred years ago today, Albert Einstein finished a scientific paper that would
change the world. His radical insight into the nature of light would help transform
Einstein from an unknown patent clerk to the genius at the center of 20th-century
physics.

Web Resources Scientists call 1905 Albert Einstein's annus


mirabilis his year of miracles. Within a few
'Einstein 1905: The
Standard of Greatness' by months, Einstein wrote a series of papers that
John Rigden
would transform the way we see the universe. They
Einstein Overview at Amer. included his theory of special relativity and the
Inst. of Physics
famous equation E=mc.
Albert Einstein Archives
Online The first paper described his particle theory of
Einstein Papers Project light, which became one of the foundations of
modern physics. Just as popular legend has it,
Einstein really was a patent office clerk when he
conceived his radical theories but he was also a doctoral candidate who spent his
free time debating cutting-edge physics with his friends.

Excerpt from John Rigden's 'Einstein 1905':

In the March paper of 1905, Einstein directly challenged the orthodoxy of physics:

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Albert Einstein's Year of Miracles: Light Theory : NPR http://www.npr.org/2005/03/17/4538324/albert-einsteins-year-of-miracles...

orthodoxy that had grown and strengthened for over a century; orthodoxy that rested on
bedrock experiment and far-ranging theory.

All physicists in 1905 knew what light was. Whether from the Sun or an incandescent light
bulb, light was known to be a wave; that is, a succession of equally spaced crests
separated by equally spaced troughs where the distance between the crests (or the
troughs) determined the light's color. All scientists knew, without doubt, that light
originated at a source, spread out evenly and continuously through all the space
accessible to it, and propagated from place to place as electromagnetic crests and
troughs. Light was called an electromagnetic wave or, more generally, electromagnetic
radiation. In 1905, the wave nature of light was an established, incontrovertible fact.

In the face of this universally held knowledge, Einstein proposed that light was not a
continuous wave, but consisted of localized particles. As Einstein wrote in the introduction
to his March paper, "According to the assumption to be contemplated here, when a light
ray is spreading from a point, the energy is not distributed continuously over
ever-increasing spaces, but consists of a finite number of energy quanta that are
localized in points in space, move without dividing, and can be absorbed or generated
only as a whole."

This sentence has been called "the most 'revolutionary' sentence written by a physicist of
the 20th century."

Einstein anticipated the impact of his paper, In May 1905, before the paper appeared in
print, he informed his friend Conrad Habicht that a forthcoming paper on the properties of
light was "very revolutionary." From a modern perspective, at least three of Einstein's
1905 papers were similarly innovative, but for Einstein in 1905, it was only the
"assumption considered here [the March paper]" that represented a sharp break with
established tradition. It was revolutionary at the time and it remained revolutionary. In
June 1906, the future Nobel Prize-winning physicist Max Laue wrote to Einstein

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Albert Einstein's Year of Miracles: Light Theory : NPR http://www.npr.org/2005/03/17/4538324/albert-einsteins-year-of-miracles...

unequivocally denying Einstein's assumption:

"When, at the beginning of your last paper, you formulate your heuristic standpoint to the
effect that radiant energy can be absorbed and emitted only in specific finite quanta, I
have no objections to make; all of your applications also agree with this formulation. Now,
this is not a characteristic of electromagnetic processes in vacuum but rather of the
emitting or absorbing matter, and hence radiation does not consist of light quanta as it
says in s.6 of your first paper; rather, it is only when it is exchanging energy with matter
that it behaves as if it consisted of them."

Laue was apparently willing to concede that in the emission and absorption process light
quanta were involved, but beyond that, he was adamant: light traveled through the
vacuum of space as a wave, not as quanta. Laue was not alone in his belief. In 1905, the
magnitude of Einstein's departure from the sanctioned belief about light was so unsettling
that his particle theory of light was not accepted for two decades.

Related NPR Stories


Einstein Centennial Feb. 18, 2005

Einstein, Bohr and the Nature of Light July 30, 2004

Author Richard Panek on Einstein and Freud July 30, 2004

Gravity Probe B to Test Einstein's Theory April 19, 2004

Books Featured In This Story

Einstein 1905
The Standard of Greatness
by John S. Rigden

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EXHIBIT J
THE BRAIN FROM TOP TO BOTTOM http://thebrain.mcgill.ca/flash/d/d_02/d_02_cr/d_02_cr_vis/d_02_cr_vis.html

Funding for this site is provided by readers like you.

THE EYE

Vision
Functionally, the eye can be
compared with a camera, and
the retina with photographic
film. The purpose of the
camera is to focus an image
that is sharp and neither too
dark nor too light onto the film.
The photographer uses the
camera's focus ring to bring the
image into focus and its
diaphragm to ensure that the
amount of light entering the
camera is just right for the
The Blind Spot
sensitivity of the film being
Optics
used.

Your eye does exactly the same thing, all day long, without your even being
aware of it! Your cornea and lens provide the focus, while the iris adjusts to let
Visual acuity is the eye's the optimal amount of light reach your retina. But your retina, with its many
ability to distinguish two
points that are very close
layers of neurons, is far more complex and sensitive than any photographic
to each other. This ability film. The two are similar, however, in that the image focused on both of them is
depends on many factors, inverted.
but especially on the
precision of the eye's
The main optical components of the
refraction and the ratio
of cones to rods at a eye are as follows. First comes the
given location on the cornea, the transparent, slightly
retina. convex outer surface at the centre of
the eye. The cornea does not have
any blood vessels, so its takes its
nutrients from the fluid behind it,
known as the aqueous humour, as
well as from the fluid in front of it, the
tears, which are spread across your
cornea when you blink your eyelid.

Next comes the pupil, the opening


that lets light enter the eye and
ultimately reach the retina. The pupil
appears black because of the layer of
black pigmented cells that line the
back of the eye and absorb the light.

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The diameter of the pupil is


controlled by the iris, a circular
muscle whose pigmentation gives the
eye its colour and whose contraction
lets the eye adapt continuously to
changing light conditions. On a dark
night, your pupils are big and black,
because your irises open wide to let
in as much as possible of the little
light available. This reaction is called
the pupillary reflex. You can observe
it easily yourself, by watching your
eyes in a mirror while you turn a
nearby light on and off.

After passing through the pupil, the


light goes on through the lens, which
is suspended between the aqueous
humour and the vitreous humour,
the fluid that fills the inside of the
eye.

The lens in turn focuses the light rays


onto the retina, lining the back of the
eye. The retina converts the image
formed by the light rays into nerve
impulses. The optic nerve, composed
of the axons of the retina's ganglion
cells, then transmits these impulses
from the eye to the first visual relay in
the brain.

THE TARGETS OF THE OPTIC NERVE

The axons of the retina's ganglion cells collect in a bundle at the optic disc and
emerge from the back of of the eye to form the optic nerve. The optic nerve is
the pathway that carries the nerve impulses from each eye to the various
structures in the brain that analyze these visual signals.

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The optic nerves of the two eyes


emerge from their optics discs
and intersect at the optic chiasm
just in front of the pituitary gland.
In the optic chiasm, some of the
axons from the two retinas
undergo decussation: they switch
sides to allow crossed processing
of the visual signals.

The axons from the nasal side of


each retina cross sides in the
optic chiasm so that the left half
of the field of vision is perceived
by the right cerebral hemisphere,
and vice versa. But because the
visual information that reaches
the temporal side of each retina
comes from the opposite side of
the visual field to begin with, the
axons from this side of the retina
do not need to cross sides.
Instead they proceed straight
ahead through the optic tract.

The vast majority of the nerve fibres in the optic tract project to the lateral
geniculate nucleus (LGN) in the dorsal part of the thalamus. The LGN is the
main relay in the pathway to the primary visual cortex. The projection from the
LGN to the visual cortex is called the optic radiation. Because damage at any
point along the pathway from the retina to the cortex results in some degree of
blindness, this is clearly the pathway through which conscious visual
perception takes place in human beings.

THE VARIOUS VISUAL CORTEXES

The image captured by each eye is transmitted to the brain by the optic nerve.
This nerve terminates on the cells of the lateral geniculate nucleus, the first
relay in the brain's visual pathways. The cells of the lateral geniculate nucleus
Brodmann's Cortical then project to their main target, the primary visual cortex. It is in the primary
Areas
visual cortex that the brain begins to reconstitute the image from the receptive
fields of the cells of the retina.

Brodmann Areas

Seeing without knowing it : the


strange phenomenon of
blindsight

People whose primary


visual cortexes have
been damaged consider

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themselves to be blind
and unable to discern
anything in their visual
environment. But if you
ask these people to "take
a chance" and point their
finger at a dot of light in
space, they will point
straight at this target. And
the data show that this
result is not random. This
phenomenon is called
blindsight.

Thus these people are


still processing some
visual information, even
though part of the neural
pathways in V1 have
been destroyed. The
mechanisms by which
they do so may involve
little understood transfer Also known as the striate cortex, or simply V1, the primary visual cortex is
pathways that bypass V1, located in the most posterior portion of the brain's occipital lobe . In fact, a large
as well as certain part of the primary visual cortex cannot be seen from the outside of the brain,
subcortical visual
nuclei. Some researchers because this cortex lies on either side of the calcarine fissure. This fissure,
also believe that the however, is clearly visible in a sagittal section made between the two cerebral
dorsal visual pathway hemispheres.
plays a role in this
phenomenon.

The primary visual cortex, with its distinctive cell architecture, also corresponds
to Area 17 described by the anatomist Brodmann in the early 20th century (link
to Tool module from the sidebar to the left).

The primary visual cortex sends a large proportion of its connections to the
secondary visual cortex (V2), which consists of Brodmann's areas 18 and 19.
Though most of the neurons in the secondary visual cortex have properties
similar to those of the neurons in the primary visual cortex, many others have
the distinctive trait of responding to far more complex shapes.

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The analysis of visual stimuli


that begins in V1 and V2
continues through two major
cortical systems for processing
visual information. The first is
the ventral pathway, which
extends to the temporal lobe
and is thought to be involved
in recognizing objects. The
second is the dorsal
pathway, which projects to
the parietal lobe and appears
to be essential for locating
objects.

Similarly to the other sensory systems and the motor system, there is a correspondence or
"mapping" between the arrangement of the elements of the visual field as they strike the retina and
their arrangement on the surface of the visual cortex. This mapping onto the visual cortex is called
retinotopy, because it is the retina that serves as the reference for the cortical maps of the various
visual areas.

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In retinotopic maps,
the zone of greatest
discrimination in the
retinathe fovea, a
small area at its
centreis
represented by a
disproportionately
large area on the
cortex. The centre of
the visual field,
covered by the fovea,
occupies the entire
posterior portion of
the primary visual
cortex, while the
entire peripheral zone
of the visual field is
analyzed in the
remaining anterior
portion.

enter word(s) here Presentations | Credits | Contact | Copyleft

6 of 6 2/28/2017 6:21 PM
EXHIBIT K
Echo http://www.adl.org/combating-hate/hate-on-display/c/echo.html

About Your Local ADL Take Action Blog Video Newsroom

Hate on Display HATE SYMBOLS DATABASE


149
Echo
Imagine a World SEARCH HATE SYMBOLS
Without Hate

Anti-Semitism
Combating Hate VIEW SYMBOLS BY CATEGORY
Domestic Extremism & Terrorism Any
Also known as: Parentheses, Parenthesis
International Extremism &
Terrorism Multiple parenthesesor the "echo," as it is sometimes referred
Hate Crimes Law tois a typographical practice used by some anti-Semites
Cyberhate on-line. It typically consists of three pairs of parentheses or
Community Security brackets used around someone's name or around a term or
Law Enforcement phrase.
Hate Symbols Database When used around someone's namesuch as (((Natalie
Israel & International Weiss)))it is intended by the user to indicate to others "in the
know" that the person being referred to is Jewish.
Civil Rights
When used around a term or phrasesuch as (((banker)))the
Education & Outreach intent is generally that the word "Jewish" be placed in front of the
term or phrase, or simply that the term or phrase is actually
synonymous with Jews.

Journalists Cooper Fleishman and Anthony Smith traced the


origins of this anti-Semitic typographical symbol to a 2014
podcast that used an audio echo as a sound effect when
someone on the podcast mentioned a Jewish name. Other
anti-Semites translated the audio echo into a typographical
symbol used primarily on social media sites such as Twitter.

The use of the echo was relatively uncommon, but in the spring
of 2016, some anti-Semites began using the echo when
responding to or re-tweeting Jewish journalists, or journalists
thought to be Jewish, which brought more attention to the
practice.

The publicity generated by news coverage of the symbol resulted


in a much larger counter-use of the echo, as thousands of
anti-hate activists and others began changing their Twitter screen
names to echo themselves in an "I am Spartacus" fashion.
Others used inverted parenthesessuch as )))Jane Doe(((for
the same purpose.

Following this, some anti-Semites began using inverted


parentheses themselves, on their own screen names, to indicate
that they were not Jewish or were anti-Jewish. This use of the
inverted parentheses has become more common.

Additional Images

Follow ADL on:

Get ADL Updates

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under Internal Revenue Code section 501(c)(3).

2 of 2 1/30/2017 12:06 PM
EXHIBIT L
NO. DC-16-16077

INRE ) IN THE DISTRICT COURT


)
PETITION OF KURT EICHENWALD ) DALLASCOUNTY,TEXAS
)
REQUESTING PRE-SUIT ) 44TH JUDICIAL DISTRICT
)
DEPOSITION UNDER RULE 202 )
)
V. )
)
JOHN DOE, a/k/a Ati Goldstein )

AFFIDAVIT OF JOHN DOE

NOW COMES THE AFFIANT, JOHN DOE a/k/a Ali Goldstein, AND SWEARS AND
AFFIRMS AS FOLLOWS UNDER PENALTIES OF PERJURY AND UPON
PERSONAL KNOWLEDGE:

1. I am a legal adult and am compet~nt to testify as to the matters stated

herein.

2. I am the John Doe a/k/a Ari Goldstein who, on December 15,2016,

"tweeted," tluough the interactive computer service/platform known as "Twitter," cetiain

electronic content (known as a "GIF") created by others and made publicly and widely

available by Google ("the Subject Tweet"). Petitioner refers to the GIF in his Petition as a

"strobe image flashing at a rapid speed."

3. This Affidavit is offered in support of John Doe's Special Appearance in

Case No. DC-16-16077, a purp01ied Rule 202 proceeding initiated by Petitioner and

pending before the 44 111 Judicial Distlict in Dallas County, Texas.

1 EXHIBIT

I 41
.......Jl'
4. I did not formulate, author, draft, type, draw, or otherwise create any of the

content within the Subject Tweet. The content within the Subject Tweet (the GIF) was

"copied and pasted" (in its entirety, as is) from Google's searchable images, to Twitter,

through a Twitter account I established, using a fictitious name.

5. Notably, the subject GIF is available not only on Google, but also at

GIPHY.com, an on-line library of animated GIFS. GIPHY.com is pminered with Twitter

to provide native access to animated GIF images both on desktop and mobile

applications, for ease of posting to Twitter.

6. I found this on Google.corn:


r.._,.,. . .. .
-- '.

7. GIPHY.com has the following posted on its website url www.giphy.com:

2
8. Upon infonnation and belief, a Google user (not the undersigned) posted to

the Web the subject GIF on a site url: www.justplainpolitics.com, on or about May 23,

2012, years before I ever saw it and re-posted it through Twitter in December 2016 (the

page is in two parts below):

3
,_,_
~~--------~ ~s~
...
~~
-
.........
f'Wnl;ed 1.115 rmn
..,.,
.,...,._,..
loA.,t."t
J:"l72
ltlll
., ,.Ill~
....... 6J6
~ 706 r.-.s n 6S. P..l\.."1
flbo[rCI:flo l

4
9. Upon information and belief, and based on a simple reverse search of the

subject GIF, there are millions of similar images available on-line.

10. Petitioner alleges that I "sent" the subject GIF to Petitioner "with the intent

of causing a seizure, as evidenced by the words Doe typed onto the [GIF], 'you deserve a

seizure for your posts."' Petition, at ~1. This is not tme.

11. First, I did not type any words or other content into or onto the GIF -again,

I copied and pasted the GIF, in its entirety, as it was created by someone else.

12. Second, I did not "send" the GIF to Petitioner; rather, I copied it (without

altering it or adding any content), through use of a Twitter account that I established, into

a "tweet" that was in reply to a "tweet" made by Petitioner.

13. Third, I did not intend to cause anyone to suffer a seizure, nor did I

appreciate or understand that the subject GIF had the potential of causing anyone

(including Petitioner) to suffer a seizure of any kind (if in fact it has or had that potential).

I merely posted the GIF to annoy Petitioner, with whom I disagree politically. The

Petitioner's Twitter page is full of political commentary and often biting, personal, verbal

attacks and memes (photographs and drawings with political satire). These Tweets are

both by Petitioner and literally thousands of others.

14. I am not and have never been a resident of the State of Texas. I have never

been to the State of Texas, other than one time travelling through Dallas-Fmi Worth

AirpOti. I have no business dealings or activities, and never have, in the State of Texas. I

do not own and have never owned any property in the State of Texas. I do not maintain

and have never maintained any place of business in the State of Texas. I am not an entity

5
organized or registered to do business in the State of Texas. I do not have any employees

or representatives in the State of Texas, and I never have. I do not advertise in or solicit

customers in the State of Texas, and I never have done so.

15. When I posted the subject GIF on Twitter, I had no awareness or

knowledge, or expectation, that it would actually be seen or "clicked on" by Petitioner,

and I had no awareness or knowledge at all that Petitioner might see or "click on" the

GIF while Petitioner was in the State of Texas, or any other pruiicular place.

I HEREBY SWEAR AND AFFIRM UNDER PENALTIES OF PERJURY AND UPON

PERSONAL KNOWLEDGE THAT THE CONTENTS OF THE FOREGOING

AFFIDAVIT ARE TRUE.

J?~ v~ a~ Atr ~o/djelh


John Doe, a/k/a "Ari Goldstein"

STATE OF DELAWARE
SS.
COUNTY OF SUSSEX

SWORN TO AND SUBSCRIBED before me this 29th day ofDecember, 2016, by

JOHN DOE, a/k/a Ari Goldstein, who is personally known to me.

Notafo Public
( JAMIE C. KING
ATI'ORNEY AT LAWvmH
PO'Mm TO ACT AS NOTARY PU8UC
PER 29 DEL. C SEC 4323 (A) 3

6
EXHIBIT M
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