Amended and Supplemental Complaint

Case 1:09-cv-00309-MSK -KMT Document 464 Filed 04/07/11 USDC Colorado Page 1 of
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UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO
Civil Action 09-CV-00309 MSK-KMT
SUZANNE SHELL
Plaintiff
v.
AMERICAN FAMILY RIGHTS ASSOCIATION

WILLIAM O. TOWER
ANN TOWER
LEONARD HENDERSON
SUSAN ADAMS JACKSON AKA SUSAN WOLVERTON
CLETUS KIEFER
FAMILIES AT RISK DEFENSE ALLIANCE
FRANCINE RENEE CYGAN
MARK CYGAN
ILLINOIS FAMILY ADVOCACY COALITION
DOROTHY KERNAGHAN-BAEZ
GEORGIA FAMILY RIGHTS, INC.
DENNIS HINGER
NATIONAL ASSOCIATION OF FAMILY ADVOCATES
AIMEE DUTKIEWICZ
THOMAS DUTKIEWICZ
CONNECTICUT DCF WATCH
WILLIAM WISEMAN,
WISEMAN STUDIOS
ANN DURAND
BRENDA SWALLOW
KATHY TILLEY
DEE CONTRERAS
RANDALL BLAIR
LLOYD PHILLIPS
RINGO KAMENS
CHERYL BARNES
CPSWATCH, INC.
DESERE’ CLABO aka HOWARD
SARAH THOMPSON
Unknown defendants Doe 1-15
Defendants
PROPOSED
FIRST AMENDED and SUPPLEMENTAL COMPLAINT
and Demand for Jury Trial
Shell v. AFRA et al First Amended and Supplemental Complaint

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Introduction
1. This is a case of the theft of proprietary methods and copyrighted literary content
developed by the Plaintiff that were so pioneering and unique, that no other similar
product existed or was otherwise available to the consumer. Consumers in this market
welcomed the Plaintiff’s products enthusiastically. Competitors could not compete with
the comprehensiveness and undisputed quality of the Plaintiff’s products. The positive
outcomes that accompanied consumer use of the Plaintiff’s products were so enticing that
the Defendants began to covet, and ultimately conspired to steal Plaintiff’s unique
creations.
2. Defendants stole Plaintiff’s unique and proprietary writings and methods, and are using it
as the centerpiece of their marketing efforts to garner credibility, stature and the large
share of the market that rightfully belongs to Plaintiff by virtue of the quality of her
products and services.
3. Some Defendant(s) joined of the conspiracy and expanded the infringement of her
copyrights and inciting others to infringe in order to make a political statement against
copyright protections of digital content and participated in the original conspirators false
advertising and unfair methods of competition.
4. This lawsuit seeks permanent injunctive relief to prevent the defendants from causing
further harm to the Plaintiff, divestiture of their businesses, as well as damages to redress
Defendants’s copyright infringement in violation of the federal copyright laws,
misappropriation of Plaintiff’s trade secrets and other proprietary and confidential
information, reverse-passing off under the Lanham Act, false and misleading advertising,
unfair or deceptive trade practices and unfair methods of competition, breach of contract,
tortious interference with Plaintiff’s contractual relations, racketeering and anti-trust.
5. As explained more fully below, Plaintiff developed a pioneering and unique method by

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which families involved with child welfare agencies could dramatically speed up the
reunification process for their children in foster care, or even prevent their placement into
foster care, prevent the state from terminating parental rights (TPR) and insure the
welfare and safety of the child in the process. It also reduces the associated burdens on
taxpayers, courts and state agencies. This proprietary method was treated as trade secrets
and any publicly released literary content for marketing purposes was registered with the
U. S. copyright office. This method and her inventory of associated original copyrighted
documents gave Plaintiff a distinct market advantage over other providers of child
welfare services, catapulting her into a position of national dominance in this market.
6. During the process of conspiring and stealing the Plaintiff’s writings and methods and
passing it off as their own, Defendants began a campaign of stalking and terror in
response to the Plaintiff’s efforts to protect her Intellectual Property (IP) rights. This
campaign included libeling the Plaintiff’s profession, her business and her property on the
World Wide Web, in the real world, in person, by phone and over the airwaves. They
published world-wide in every location where the Plaintiff was being discussed or
featured in a publication that the Plaintiff stole her work from others, that she was a
convicted felon, a child abuser, a stalker, that she published kiddie porn, that her
methods were nothing special, that her methods didn’t work and more. When the Plaintiff
had scheduled personal appearances, events and presentations, the defendants contacted
the management of the hosting facilities beguiling the managing personnel to believe that
Plaintiff’s presence would damage the reputation of their facilities. Defendants even
showed up physically at locations to stalk and harass the Plaintiff, her customers,
associates and licensees. They respected no reasonable boundaries, and included attacks
against the Plaintiff’s father, husband and in-laws, as well as involving her children.
7. At the same time, the Defendants used her misappropriated content–the same content that

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they were discrediting–to market their businesses, their organizations, occupations,

services and products, resulting in undeservingly enhancing their credibility, stature and
market share, and eliminating the Plaintiff from competition. To add insult to injury, they
made all of this misappropriated content available for free, having publicly denounced the
Plaintiff for charging fees for her products.
Definitions
8. Agent - is defined as one who is authorized to act for or in the place of another; a
representative.
9. Archives - refers to any method whereby content is affixed and stored and can be
accessed, browsed, searched, downloaded, transmitted and otherwise used by owners,
members, users and/or the general public, including on the Internet. In the context of a
group, archives refers to the storage area on the group web site where all message content
that has been transmitted from users to the entire group is stored. Groups have the ability
to store all messages transmitted to and from users in this archive. This also refers to
personal archives contained in computers or computer systems of the defendants or
plaintiff.
10. Business - is as used in Federal Rules of Evidence 803(b) includes business, institution,
association, profession, occupation, and calling of every kind, whether or not conducted
for profit.
11. Child welfare - refers to child abuse or neglect issues and any state action associated
with child abuse or neglect. It is also referred to as child protective services (CPS). Each
jurisdiction has it’s own designation for this agency, but generically, it is referred to as
child welfare or CPS.
12. Child welfare client - consists of consumers whose children are under the jurisdiction of
the court, or who have voluntarily agreed to receive services from the child welfare

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agency.
13. Consumer - are those who are seeking, receiving or otherwise in the market for services
related to child welfare, child welfare investigations or legal cases, either involuntarily
pursuant to state intervention, court order or coercion, or voluntarily, and/or in order to
preempt state intervention and/or to supplement state provided or court-ordered services
and/or to replace state provided or court-ordered services. Consumers are also child
welfare service providers who are seeking community-based products which address the
needs of families involved with child welfare agencies so as to provide those products to
child welfare clients as part of the case plan.
14. Copy - means to reproduce, perform, print, save, store or affix in any storage device or
medium, distribute, publish, display, transmit, license, or to produce or license, or create
derivatives of the work or any of the other exclusive rights reserved solely to the
copyright owner.
15. Files section - refers to a specific location in a group or web site where users and/or can
upload electronic files to be browsed, transmitted, displayed, downloaded and used by
users.
16. Groups - refers specifically to fully interactive Internet web sites, forums or online
groups, which allow users to do any or all of the following: participate in discussions
online; to transmit and receive and store information and files; to advertise, offer and
provide products and services; to transmit, receive and store infringing content; to
transmit, receive and store advertisements; to transmit, receive and store solicitations for
donations, solicitations for participation in events, court hearings, legislative hearings and
to transmit, receive and store various reports on the businesses of the users and owner.
This list of business conducted on these groups is not exhaustive. Storing all of these
communications and files allows users to browse available information and document

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choices contained in the archives and in the files section of these web sites, selecting what
they want to download for their own use and for transmittal to anyone else. Unless
otherwise specified, as used in this complaint, a group accepts membership from anyone
world-wide, and has never excluded anyone because they reside in Colorado. Each group
has Colorado members. Users and owners have solicited donations directed at Colorado
residents and by Colorado residents. Users have offered their goods and services for sale
and use directed at Colorado residents and offered by Colorado residents. Users have
received and disseminated their transmissions to and from Colorado residents. Users have
provided any or all of their services to and from Colorado residents and have received
information and services from to and from Colorado residents. Users and groups have
directed their activities within the boundaries of Colorado to affect and influence
legislation and court cases and state agency conduct. All of this activity directed at
Colorado and originating from Colorado has been performed on a daily basis, multiple
times a day, during the existence of the group.
17. Members - refers to users who have been approved by the owner or moderator for
participation in a group. In some instances, a person cannot participate in a group unless
they are approved for membership in the group. Membership requirements vary from
group to group. Members also refers to those who have applied for and received
membership in a real-world organization, for those organizations that offer or solicit
membership, including but not limited to Defendants AFRA, CPS Watch, NAFA, IFAC.
18. Moderator - refers to a person with the ability, authority and discretion to do any or all of
the following on a group: approve or disapprove content submitted by users, to add or
remove content from archives or files sections, to remove users from membership, to
approve users for membership, to create and enforce the policies of the group. Unless
otherwise specified, moderators also have access to history files of the group which

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document what action moderators or owners performed and when it was performed.
19. Organization - encompasses all variations of entities established by the defendants to
perform their mission(s) including associations, groups, nonprofit or for profit
corporations, organizations, businesses, companies, trusts, LLC, sole proprietorships, dba,
clubs, and any other designation that describes the entity under which they operate and
conduct business.
20. Owner - or group owner refers to the entity or person who created and/or owns the group.
This person has all the rights and authority as a moderator, with the added abilities to
establish use permissions for users and moderators, to establish or alter the group settings,
and to close and disband the group.
21. Products - includes, but is not limited to goods and services offered by organizations,
individuals, members, and users as support services, advocacy services, information
goods and services, case management advice and services, paralegal services, referral
services, literature or documents, books, advice, lobbying services, legal and document
writing services, and any other goods and services which help promote their expertise,
qualifications and competence in the relevant markets or which promote child welfare
reform and/or government reform or which are intended to assist families involved with
child welfare agencies, service providers and the courts.
22. User - refers to any person participating in a group, including members, owners and
moderators.
PARTIES
23. Plaintiff is Suzanne Shell (hereinafter identified in the first person), an individual who is
domiciled at 14053 Eastonville Rd, Elbert, Colorado, 80106.
24. I have never had a child welfare case filed against me involving my children.
25. I am a nationally recognized expert and leader in the field of Family Rights issues and
related child protection interventions and court cases. I have invested nineteen years of

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hard work, research, diligence, testing and practice in attaining this professional stature.
26. I was held in the highest regard in this market. According to one attorney in 2004,
“Dear Friends:
“There is no one - and I really mean no one - who understands CPS like Suzanne Shell.
Reading her book, Profane Justice, is like exploring a great treasure. I have stood in court
hearings maybe 200 times, and still don't know all that she has figured out by research,
intuition, and inspiration. Every day, I stake my law practice on her being right, and she
invariably is.”
27. I have attended professional training since 1996 to increase my skills and knowledge in
this arena.
28. I am the original author of three books, hundreds of articles, essays and educational
papers on the subject of child welfare practices, legal issues and strategies for families
and professionals who represent family members or who administer child welfare cases.
29. I have created nationally recognized, CLE accredited training programs for attorneys and
judges, and similar training for professionals who practice in this area.
30. I have created appropriately modified educational presentations for parents and family
members who are consumers in the child welfare market.
31. Colorado is the location where my business activities and all property that is the subject
of this complaint is created and centered.
32. All requests for my goods and services are initiated by the consumer or professional, and
are directed to me in Colorado, regardless of the location of the requestor. I receive these
requests via mail, email, telephone or in person. I perform the services for the requestor in
Colorado.
33. My email address had remained the same for over ten years, dsshell@ix.netcom.com. The
defendants’s attempts to take down my web site and have my ISP, EarthLink terminate
my services ultimately resulted in my losing that distinctive key identifier.
34. I own and operate a passive web site with the domain name www.profanejustice.org and

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other aliases that direct to the web site to advertise my business, “American Family
Advocacy Center.” I first published this web site in 1996.
35. I make certain of my documents available on this site as a means to market my goods and
services. These documents and writings are intended to provide sufficient information so
that the consumer who wants more than what I have made minimally available would be
motivated to obtain my superior products over the products of my competitors.
36. On my web site, I advertised my book, Profane Justice (ISBN 096625407) when it was
released in February, 1997. My book is sold through Amazon.com. My current book(s)
is/are likewise advertised and sold.
37. I have registered the copyright to my web site and other publications. I am the sole
copyright owner of the registered content that is the subject of this complaint.
38. Prior to my web site being published, the issues in this market were presented as parental
rights issues.
39. I redefined this principle into family rights, as both a better political alternative to the
artificially adversarial posture that had been implemented as parent’s rights vs. children’s
rights, and as a better description of the consumers served in this market. This
redefinition has proven to be extremely popular and has proven to be the catalyst for
launching the grassroots family rights political movement.
40. Mine was the first web site offering solutions and products to families involved with
child welfare agencies. Other parent’s rights web sites only described the problems
without offering solutions or products to the consumer. There were few, if any, solutions
available to the consumer prior to my publishing my web site.
41. My products were designed for child welfare client families and for the state agencies and
service providers that serve families during child welfare investigations and court cases.
The products for each perspective was designed to complement the others.

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42. I introduced the practice of the family advocate as one of the services offered when my
web site debuted in 1996. This service was immediately popular, because it addressed
some dire needs felt by parents and families in this market.
43. Shortly thereafter, other organizations and individuals began offering family advocacy
and information services to this market. These services were based on my model, and
invariably copied my limited publicly available strategies and content, but the entities
offering these knock-off products did not have my years of research and testing behind
their respective applications and offerings.
44. Often, a consumer would not even have closed their own case or gotten their children
returned before they hung out their own shingle offering advocacy and information
services to consumers in competition with me. This has proven to be detrimental to
consumers as well as to agencies and courts who administer child welfare cases.
45. To the extent the strategies and services disseminated by other organizations or
individuals were copies of my original creations, or were taken from my marketing
documents, I did not object as long as the provider or individual directed the consumer to
me and my web site, and attributed me as the originator. This method operated on the
honor system, and was successful until the defendants appeared on the scene and hung
out their respective shingles to provide information and services to this market.
46. It was by this wide dissemination of my information that I became known to the market
and to the defendants, who chose to patronize my business or to associate with me due to
my qualifications, my professional stature in this market, the quality of my products and
the positive outcomes associated with my methods.
47. Before the defendants even got involved with child welfare, I was nationally recognized
as the foremost family rights expert. I had appeared on numerous radio and television
programs nationwide to promote the family rights agenda and to promote goods and

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services. By 2002, my national reputation was unparalleled in this market.

48. They say imitation is the sincerest form of flattery, but when the products imitated are
stolen and passed off as someone else’s work, it becomes more than flattery, it becomes
tortious. Such is the case here.
49. By virtue of over fifteen years of exceptional analysis, diligence, research, testing and
application, I developed an innovative and pioneering method for use by parents and
attorneys in child welfare cases which significantly reduces the amount of time a child
spends in out-of-home placement, or even prevents out-of-home placement completely. I
protected this method as trade secrets.
50. This method speeds up the reunification process from the normal time frame of months or
years, to mere days or weeks.
51. It reduces the incidence of termination of parental rights from up to 50% of the cases to
less than 10% of the cases.
52. This method makes court-appointed representation much more vigorous and effective
without increasing the costs or workload to the court-appointed attorneys.
53. It reduces the billable time for attorneys who are paid by their clients, giving the client
more bang for the buck and allowing the attorneys to carry a larger case load without
increasing their workload.
54. It reduces the trauma of intervention to children and their parents and empowers families,
who find hope in a formerly hopeless situation. Follow up on families who have been
reunified using this method indicate far fewer future abuse or neglect incidents or reports
than average.
55. This method frees up agency resources to focus on truly abused and neglected children. It
reduces the administration costs of the agency thereby reducing the burden on taxpayers.
56. It reduces the demand for foster homes. Good foster home are in limited supply, and it

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prevents the agency from having to place children in not-so-good foster homes.
57. It reduces the docket on overburdened courts, and dramatically shortens the time a case is
open, or even prevent a case from being opened.
58. It conforms to the statutory mandates of the best interests of the child, the safety and
welfare of the child and achieving permanency within mandated time frames. It does all
this and more. The beauty of this method is that everybody wins.
59. Pursuant to this method and based on the models implemented in various jurisdictions, a
competent attorney or attorney/advocate team along with cooperating parents using this
method can accomplish one or more of the following in over 90% of their cases:
a. Prevent the removal of the children and/or close down the investigation without
court intervention.
b. Prevent the state from retaining custody at the shelter hearing.
c. Get the children returned home before the adjudicatory hearing.
d. Prevent adjudication if the methods are implemented prior to the adjudicatory
hearing.
e. Reunify the family in 1 day to 2 months after adjudication instead of 9-15+
months.
f. Prevent termination of parental rights (TPR) hearing from occurring once the
petition is filed and ultimately get the family reunified.
g. We have even gotten TPRs overturned and the family reunified.
60. I developed a licensing arrangement, whereby qualified leaders of approved organizations
would be granted license to use my intellectual property and methods in exchange for
non-disclosure of the information and agreeing to submit to extensive training,
background checks, and quality assurance oversight over any family advocates practicing
in their organization. This was a marketing scheme intended to advertise the benefits of

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using trained and certified advocates over other advocates, as having superior outcomes
and superior quality of services with greatly reduced risks of damaging a case.
61. In addition to the licensing, after the basic education, the amount of information provided
to the licensees was limited to what they needed to know for a particular situation.
62. This limitation was due in part to the complexity of these kinds of cases and to the sheer
volume of information involved. Most trained licensees have yet to need to know the full
scope of information available to them, and have been able to operate very effectively on
the limited information they possess.
63. Even licensees who have attended five or more training sessions have yet to absorb all the
information disseminated, and profess to learn something new every time they attend
training.
64. Due to the volume and complexity of the information and methods I have devised, I
provide support services to licensees, who call whenever they encounter a situation for
which they need guidance. I walk them through the steps necessary and monitor their
progress.
65. In addition to this restriction, I require licensees to fill out a job application, provide
professional references and submit to a background check. This is intended to weed out
individuals who might pose a risk to the vulnerable consumers we serve or who are
unstable or untrustworthy or otherwise unsuited to this occupation.
66. Once accepted, licensees are on strict probation for a minimum of a year, under the close
hands-on supervision of a trusted and proven supervisor.
67. These conditions are much stricter than those instituted by any state agency regarding
employees who administer child welfare cases.
68. All license agreements are between me and the licensee.
69. I organized Family Rights Advocacy Institute (FRAI or the Institute) to be the vehicle for

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training and licensed it to use my intellectual property.

70. Using FRAI, I instituted a certification program for family advocates which included
training requirements and quality assurance oversight. The training was presented by me
in my capacity as director of American Family Advocacy Center, and was based on my
trade secrets and proprietary information, which I created and own. Trained and certified
advocates go through the licensing process before being certified.
71. My method includes extensive, unique information, strategies and devices which were not
heretofore employed by or known to my competitors and which could not be duplicated
in a reasonable amount of time, and which were classified as trade secrets.
72. The defendants (or anyone else) have not been able to devise similar methods nor create
any new methods nor to improve upon or otherwise expand upon the basic information
that I released to the public under my marketing plan.
73. The defendants (or anyone else) have not been unable to independently duplicate any of
my methods or my successful outcomes in the past nine years, nor have they offered
anything new in the time frame since they have effectively eliminated me from this
market. The products currently available to the market under the dominance of the
defendants are far inferior to my products, years behind my developments and do not
reflect any of the advances I offered in quality or scope.
74. These trade secrets and proprietary information created a distinct market advantage for
me over non-trained, non-certified, self-professed family advocates and increased market
interest in my training and information products.
75. I incorporated parts of my intellectual property and trade secrets into my presentations
and required attendees to affirm and/or sign non-compete, non-disclosure agreements as a
condition of receiving the training and materials.
76. I marketed my advocacy training services in a manner to insure that those who received

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my training would be able to capitalize on the superior outcomes and methods by

advertising they were trained and certified through Family Rights Advocacy Institute, and
were subject to the oversight of the Institute. This would send a message to the
professionals who administer child welfare cases that they would be credible and
effective members of the treatment team and not be loose canons, nor be disruptive, nor
advocate harmful strategies, would not interfere with attorney-client relationships, or
otherwise cause problems necessitating their exclusion from offering services to families
involved with child welfare agencies. This licensing and oversight has proven to be
reassuring to attorneys who want to use FRAI trained and certified family advocates.
77. Portions of this method had been critiqued by Hon. Katharine English (ret) who was on
the faculty of the National Council of Juvenile and Family Court Judges. She found to it
be accurate, innovative and effective.
78. In the materials that I handed out during my presentations–which largely consisted of bare
outlines–I included false information. Anyone simply reading my outlines would not be
aware that there was false information planted within the document. By this fingerprint, I
could ascertain if the information being disseminated by my competitors originated with
me and was, therefore, misappropriated.
79. This fingerprint appears all over the defendants’s (including AFRA and CPS Watch) web
sites, groups, and publications, showing that the information disseminated by the
defendants to this market includes this fingerprint, proving they acquired it from me.
80. I created a complementary Continuing Legal Education (CLE) presentation for attorneys
who represent parents and children in child welfare cases and for judges who hear these
cases. This presentation has been duly accredited in Florida, Colorado, Kansas,
Connecticut and Arizona before my business was brought to a standstill by the
defendants’s overwhelming tortious acts.

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81. I have created other complementary accredited CLE presentations on“Mandated

Reporting” and “Reasonable Efforts” but was unable to continue expanding my
presentations due to the overwhelming tortious conduct of the defendants.
82. I developed a marketing plan, which I also kept confidential, even from licensees. This
plan insured that parents involved with child welfare cases, who were largely indigent,
would not have to bear the expense of the services or products they received from me, or
for the services provided by trained and certified family advocates.
83. Part of this plan included my intention to seek and obtain grants and other funding once I
had established a proven track record and was able to prove the benefits of my method. In
order to obtain said grants and funding, my professional reputation had be pristine. The
defendants have destroyed all chances for me to obtain any independent sources to fund
training, and pay for advocates and legal services for select client families.
84. I used my copyrighted intellectual properties as marketing tools to entice potential
customers to learn more about how they could obtain and use this method.
85. It was a critical component of this marketing plan that I be given credit for everything that
I had written and disseminated so that customers would be directed to come to me for my
products and services and ultimately, my method.
86. Prior to the tortious acts by the defendants which are the subject of this action, I enjoyed
the highest reputation for creativity, credibility, competence, integrity and skill in this
market. Leaders in this movement described me as the “grandmother’” of this movement.
87. Prior to the defendants’s tortious conduct, my web site ranked at the top of Google and
other search engines. By 2005 my web site was getting over 250,000 hits a month. In
2006, that had dropped by 80%.
88. In the year ending April, 2010 I had averaged less than 75,000 hits per month, a reduction
of 70% from my prior prominence, indicating I have only recovered 10% of my lost

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market presence in the past four years.

89. I am not a web design expert or Internet expert or even a computer expert. My skills are
limited to being an end user of web design software and other products available on the
open market.
90. By 2005, my training programs were expanding and the number of presentations each
year was increasing. I was finally beginning to realize a financial return on my fifteen
year investment. My business momentum had increased steadily and my stature within
this market and the political arena had increased correspondingly.
91. The progression of my seminar presentations are as follows:
a. 1998 - five
b. 1999 - three
c. 2000 - one (at this point I wrote my second book and revised the presentation)
d. 2003 - two (expanded to three day presentations hereafter)
e. 2004 - two
f. 2005 - six, accredited in Florida (8.5 C.L.E.R), Colorado (8 C.L.E. twice and 9
C.L.E. once)
g. 2006 - six, accredited in Florida (8.5 C.L.E.R), Colorado (8 C.L.E.), Arizona (8
C.L.E.), Connecticut (8.5 C.L.E.) and Kansas (8 C.L.E.)
92. Requests by new groups seeking my training seminars had dropped to only one by the end
of 2006. The prior year, it was six by the same time. Several of those new groups who
had previously indicated interest declined to bring me in for training immediately after
defendant Swallow began publish her false advertising statements on the defendants’s
interactive web sites, and the defendants joined in with a frenzy and disseminated hers
and their own false statements widely.
93. I have received no requests to present seminars since 2006.

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94. This model had been implemented successfully before the defendant’s tortious conduct
undermined and destroyed what I had built up around the country.
95. This method was so successful, that my competitors–the defendants–wanted it. So they
stole it and passed it off as their own, to increase their own credibility, stature and market
share.
96. My marketing documents were so effective, that they stole those, too, and presented them
to the market as their own, thereby preventing clients from coming to me at all.
97. The defendants published my writings and some of my trade secrets on the Internet. They
gave them away for free because they insisted it was wrong for me to charge for any of it
and they wanted the stature I had achieved with that information, to destroy my existing
stature, and to eliminate me as competition.
98. They used my stolen property to enhance their own stature and increase their own
business, credibility and public presence. They refused to give me credit for the content
they infringed, or for the methods they used that originated with me, or pay license fees. I
cried foul, privately and discreetly, hoping to resolve the escalating problems out of the
public eye to prevent public embarrassment for honest mistakes that might have been
made.
99. The defendants responded publicly, by inundating the market and the world with false
advertisements about how I was abusing, harassing and stalking them. They claimed I
didn’t develop anything special, and that I stole everything I wrote from unnamed others.
They advertised I had no rights to exploit or protect my intellectual properties. My
reputation began to suffer. Consumers and potential customers shied away from me and
my businesses, if for no other reason than to avoid the conflict the defendants incited that
followed me like a cloud and sometimes spilled over into the private lives of others.
Should anyone dare to support me, the defendants would gang up on that supporter,

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harassing, threatening and even taking action on their threats.

100. The defendants told potential customers far and wide to stay away from my products or
services because I was a thief, a criminal, a child abuser and mentally ill. They defamed
my business, my professional reputation and maligned the quality and uniqueness of my
products, while at the same time appropriating my methods and products and offered
them for free as their own products to enhance their own reputations, credibility and
stature.
101. Now, consumers and potential customers of my method and other products believe the
lies the defendants have so liberally advertised about me and my products. They go to my
competitors to receive my products for free, and in the process, are not offered the full
method, which results in predictable and unnecessary harm to them.
102. The defendants disseminate their false representations about me widely and keep them in
their respective archives and files sections for perpetual access by consumers in the
market, insuring that new consumers will know of their false advertisements immediately
upon seeking goods and services.
103. The defendants use their interactive forums, and other public fora to encourage
consumers to eschew my products citing the libelous reasons they manufactured with the
intent to eliminate me from this market.
104. The value of my method and my intellectual property has been severely compromised by
the acts of the defendants.
105. The effects of their acts and advertisements have destroyed my hard-earned stature in this
market and eliminated my livelihood. I had finally achieved good momentum and was
building a strong client base with potential representation in every state, which has now
come to a screeching halt because of the defendants’s unceasing gang efforts to eliminate
me from this market.

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106. Because the defendants have insured that I have been exclusively denied access to the
online interactive web sites, groups and forums which constitute this market–access they
grant to all other providers of products–I have no access to the traditional and established
mediums of advertising.
107. For the groups to which I do belong, if I dare contribute, the defendants immediately gang
up and shout me down. I cannot, in good conscience, allow my mere presence to disrupt
the groups of other organizations in this manner, even if they group owners choose not
remove the disruptive elements.
108. Additionally, those forums are a favored medium for the defendants’s false advertising
and infringements where I cannot observe it or document it, much less refute it.
109. My ability to conduct my business has been destroyed, in part, because potential
customers fear what the defendants will do to them if they advertise or use my products
and services. I don’t blame them. The defendants have threatened, intimidated, harassed
and made false reports and invaded privacy with their vicious online publications against
my licensees, associates and customers the same way they have come after me.
110. Since the defendants’s tortious conduct, their false advertisements– both the original
content they posted about me, and the multi generational handing down of those false
advertisements taken from their sites and other locations where they published their
comments and forwarded repeatedly until the market is saturated– often rank higher on
Google and other search engines and the volume of those false advertisements overwhelm
my own publications, as well as other favorable and neutral online locations where I
appear and in search engine results.
111. Wikipedia has created an entry about me and my web site.
112. Alexa.com reports that Wikipedia ranks fifth in U.S. Internet traffic, and sixth in
Worldwide Internet traffic.

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113. A Google search of my name brings up my Wikipedia entry on the first page, usually as
the first result. Wikipedia is considered a neutral, online, authoritative encyclopedia.
114. None of the defendants nor their organizations has merited a Wikipedia entry.
115. The defendants have continuously vandalized my Wikipedia entry, adding links to the
defendants’s web sites, and adding their false and defamatory and even profane
advertising about me, my business and my professional reputation.
116. Wikipedia has repeatedly removed the vandalized entries, only to have the defendants put
them back in. Identified Wiki vandals include defendants Baez and Wiseman, with other
anonymous offenders being fully documented by Internet Protocol address in Wikipedia
history records.
117. Wikipedia blocks the users who repeatedly vandalize my entry, and the Wiki vandals sign
back in under different Internet Protocol addresses or user names to continue their
vandalism.
118. As the subject of the article, I am not permitted to edit my own Wikipedia entry.
119. Unable to combat the vandalism on my page without shutting the page down, Wikipedia
has resorted to including a notice on my entry page stating,
“This article may violate Wikipedia policy as it may contain unsourced
or poorly sourced controversial claims about a living person. Such
content must be removed immediately. Unsourced or poorly sourced
controversial claims about living people are strictly forbidden on all
Wikipedia pages. In addition, all articles must be neutral, verifiable,
encyclopedic, and free of original research. Editors who continue to
introduce unsourced or poorly sourced contentious material about living
people will be blocked from editing per Wikipedia policy.”
However, Wikipedia has refused my requests to remove unsourced or poorly
sourced controversial claims or libelous content, and has continued to allow the
defendants to submit false and defamatory content into my Wikipedia entry.
120. Wikipedia entries pertaining to me are copied by dozens of other authoritative reference

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resource services on the Internet, and the Wikipedia false entries are duplicated in each
reference resource that copies Wikipedia. By this mechanism, the market is saturated with
false and defamatory entries about me, my business and my professional reputation.
121. The defendants have repeated this conduct on every neutral online authoritative resource
they can find. Because many of them don’t have jobs, they have plenty of free time in
which to saturate the Internet with their defamatory content.
122. Because of my prominent stature in the family rights grassroots movement and my
reputation for fairness and quality, I had been receiving complaints about advocates
harming consumers, stealing from their clients, and not providing the goods or services
paid for among other things since 2000.
123. I had no authority to exercise customer service for other organizations, and my contacting
the offending individual or organization or referring the complainant to the offender was
proving ineffective. This was having an adverse affect upon consumers in this market
and by association, on my business. Customers told me they were hesitant to order
anything from me because they had ordered goods from CPS Watch and never received
them. They knew I operated a different business, but they did not want to be burned
again.
124. One of the biggest complaints by families involved with child welfare is that the
oversight over the professionals (attorneys, judges, case workers, etc.) is perceived to be
non-existent or useless. I felt that we could not complain about their poor oversight if we
did not police our own practice, it would be hypocritical.
125. In 2003, I explained the issues to Henderson and offered AFRA the opportunity to take
responsibility for exercising oversight over advocates and to handle consumer complaints
regarding the practice of advocacy. Henderson and AFRA declined to accept this job.
However, he did agree to publish what I wrote on the AFRA web site.

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126. Since I created the practice of the family advocate, and nobody else wanted to exercise
oversight, and since the consumer market was being harmed as was the reputation of the
practice of family advocacy, I exercised oversight over the practice of family advocacy to
the extent available to me.
127. I decided to accept the complaints and collect documentation in support of the complaint.
I then privately offered the offender an opportunity to respond, rebut or correct the issue.
If they resolved the issue, great. If they didn’t, I conducted an investigation–to the extent
the alleged offender would cooperate–and published findings that affected the consumer
on the Internet. I instituted a mechanism for the offender to have their name removed, but
no one ever utilized it.
128. I assumed full responsibility for what I published. I investigated each complaint
thoroughly and required multiple reliable, independent sources to verify every fact before
I published it. As a result of my investigations or the refusals of some complainants to
provide the necessary documentation, many complaints I received never reached
publication.
129. I have never been sued for any of the content in the articles I wrote.
130. The subjects of these articles are self-professed leaders in the family rights movement,
either regionally or nationally, and on the World Wide Web.
131. They seek and maintain a high public profile.
132. They each claimed to speak for families in this issue of societal importance.
133. They claimed certain authority, expertise and skill in the child welfare arena.
134. They publicly and widely promote their business, their practice and organizations.
135. They are public figures.
136. Their family rights and child welfare related activities are, therefore, subject to public
scrutiny, comment and criticism.

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137. My original article debuted August 7, 2003. Henderson published it on AFRA, but when
he received a threatening and abusive email from defendant R. Cygan, he backed down
and removed it.
138. I did not argue with his decision to remove the articles. My only response was to place the
article on my web site, without fanfare. In response to my publication, I received
threatening and abusive emails from AFRA members R. Cygan and Roxy Weaver.
139. My original consumer advisory articles were well received by consumers when they
debuted. Consumers came forward confirming the concerns about those listed.
Consumers were pleased that this service was available to protect them.
140. Henderson opposed my response to consumer complaints but offered nothing as an
alternative to protect the consumer. (“. . .there is nobody on earth who HATES it as
badly as I do”1). He did not feel warning consumers about advocates who had stolen from
clients and had harmed their cases was beneficial to AFRA. He began his campaign to
divest me of my articles and my publication.
141. When I refused to be divested, he used his influence as CEO of AFRA, and used AFRA
membership and AFRA properties to solicit opposition to the consumer advisory articles,
and to provide the forums for the subjects of those articles and their supporters to defame
me and my business and infringe my IP. He incited public derision and defamation of me
and my business, and provided the forums for this derision and defamation to be
published. He and the defendants influenced the entire market to eschew my business, my
products and to destroy my professional reputation.
1
On or about June 15, 2004, Directors. Henderson took this posture in response to the
success of this list, regretting that he had not thought of it himself. If he endorsed it, or remained
neutral about it, it would subordinate him to me, and that simply was unacceptable. This was the
issue he focused on to sell his campaign to eliminate me from the market, as evidenced by the
response to my offer to eliminate the articles from publication.

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142. If anyone had an issue with what I published, they had appropriate remedies available to
them, including approaching me personally with evidence refuting the publication, or to
correct the conduct with led to their inclusion, or by seeking redress in the courts. This
was clearly stated on the publication.
143. The remedies the defendants sought–retaliatory acts which constitute the causes of action
in this complaint–are not appropriate or even legal.
144. They each admit they committed their hundreds of tortious acts designed to eliminate me
from the market solely because I published a consumer advisory on important issues of
societal importance–a first amendment protected publication–and they didn’t like it, and
because I was not properly influenced by their threats and abuses against me.
145. None of the defendants employed the appropriate remedies. They conspired to commit
wrongful acts intended to harm me and eliminate me from the Internet and from the
market, instead.
146. I gave away my original consumer advisory articles to another publisher in August 2006
under threat of continued and escalating abuse and harm to me and my associates by the
defendants.
147. This publisher has created a web site and has expanded the publication into satire, parody
and mockery. I am not responsible for the content on that site, except for my original
consumer advisory articles which are all signed by me, written and published prior to
March, 2006.
148. My relinquishment of my consumer advisory articles did not cause the defendants to
cease their tortious conduct against me, my business and my property, despite their
promises to the contrary.
149. Once I was effectively eliminated from the market, there was nothing I could to do as far
as my training and advocacy programs. So I decided to publish a fully interactive online

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Consumer Advisory Publication at

http://groups.yahoo.com/group/FamilyRightsAdvocacyIMPROVEMENTProject
(Improvement Project).
150. The Improvement Project debuted on May 20, 2006.
151. This is a privately owned publication, entitled to operate without interference or
tampering by anyone, including critics.
152. The Improvement Project is one of the publications of my publishing business Sage
Wisdom Press, a Colorado-based publishing business, listed in R.R. Bowker since 1996.
153. It is described on the home page, “THIS IS AN INTERACTIVE CONSUMER
ADVISORY PUBLICATION OF SAGE WISDOM PRESS.”
154. Because this publication is interactive and messages are not approved before publication,
the authors of content posted to this publication are considered contributors to this
Colorado-based publication and are solely responsible for the content they publish. This
publication represents a collaborative effort by many authors.
155. The message archives of this publication are searchable to the public.
156. One must be a member to make a contribution to this publication.
157. Joining this group expressly indicates the contributor will abide by the terms of the group,
including honoring Intellectual Property rights and not violating the privacy or online
anonymity of others.
158. Members all start out with a clean slate and the presumption that they are acting in good
faith. That status is subject to change based on their participatory conduct.
159. I set this group up, in part, to provide the defendants with a way to contact me with their
complaints without my having to endure their incessant abusive, harassing and secretive
back channel emails to me. I wanted all communication with the defendants to be
publicly visible for my protection and to expose their abuses to public scrutiny. I

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hereinafter refused to respond to private emails from them and their associates. If they
continued to harass me back channel, I would publish their messages on the Improvement
Project with a demand that they cease harassing me back channel. This put their private
conduct against me in the public spotlight.
160. It was also a publication to replace my consumer advisory articles, which I removed from
publication under threat of further harm by the defendants. Since I could no longer
conduct the business I had created without an onslaught of attacks whenever my name
was mentioned or wherever I appeared, I wanted to have a consumer advisory publication
that was interactive to allow diverse viewpoints, and open to anyone who had an interest
in the practice of family advocacy.
161. It was also intended it to be very public crucible, and in that regard, it was highly
successful. It is read by virtually everyone in this market.
162. I publish a blog discussing child welfare issues at http://profanejustice.blogspot.com. I
cannot publish a blog under my name because the defendants have usurped a blog under
my name to their agenda. As an author and writer in a variety of genres, this has proven to
handicap me in writing and publishing circles.
163. The defendants have set up several web sites and Internet locations populated with their
defamatory content using my name, so as to direct traffic to their defamatory sites when
anyone searches for my name on the Internet. Again, this has a detrimental effect on my
writing career.
164. The wrongful conduct of the defendants far exceeds what they have done to me, my
business and my property. It extends well into the market and adversely affects the
consumer, consumer choices for goods and services, consumer safety and public policy.
165. Competition in this market has virtually been eliminated since 2006, in favor of the
defendants’s chosen few organizations under the permissive licence of AFRA. They have

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even targeted my licensees whenever they have engaged in their occupations, insuring
that legitimate outlets for my information and methods are similarly shut down. These are
grievous wrongs, not only against me, my business and my property but against
competition in a free market and consumer choice.
166. The defendants’s misappropriation and misuse of my products is particularly troubling, as
their misunderstanding of the methods and improper execution of the incomplete methods
they have been able to steal and disseminate has caused repeated and continuing injury to
consumers in this market as well as to the fledgling para-professional practice of family
advocacy. Public policy demands the wrongs in this complaint be redressed.
167. I advised the defendants on August 9, 2006, of my intent to seek legal remedies. They
immediately began destroying incriminatory evidence in their possession and on the
Internet.
Defendants
168. I have first hand knowledge of or was witness to the facts cited herein unless specified
otherwise.
169. The facts in this complaint are at all times relevant to the time frame of this lawsuit.
170. Defendants (except Kamens aka Bryan) have as their purpose the promotion,
advancement and achievement of a specific mission, relating to child welfare reform and
protecting the rights of parents, children and families against government and serving as
government watchdogs.
171. They have formed organizations for the purposes of performing that specific mission
and/or have joined the same to participate in that mission.
172. They have ascribed distinct names to those and created logos, inscriptions, signs, tags or
labels which indicate ownership, control or origin.
173. They have engaged in their occupations and business under the authority and color of

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those organizations.
174. They have established web sites and online interactive groups to make their organizations
and information available to the public.
175. The defendants have maintained and maintain direct responsibility for the selection and
display of the content accessible through their respective web sites and groups.
176. The activities of these organizations are of such a character as to amount to doing the
business of the officers, owners and agents, therefore, the officers, owners and agents are
subjected to personal jurisdiction.
177. In the instances of corporations, the corporations are merely alter-egos of the officers,
having no real separate corporate existence apart from that of the officers. As explained
below, corporations are not even being properly maintained as active pursuant to the rules
of the incorporating state, and have, on occasion, been administratively dissolved and
ordered to cease doing business. The conduct of the corporation(s) is inextricably
intertwined with the conduct of the officer(s), agent(s) or principle(s), and necessitates the
piercing of the corporate veil. Not doing so would justify the wrongs committed and
protect fraud.
178. The defendant organizations operate under a hierarchal structure, under which members
and participants must abide.
179. The defendants have voluntarily joined as officers, members, associates, users or
participants of the defendant organizations, including but not limited to American Family
Rights Association (AFRA), CPS Watch, Inc. (CPS Watch), National Association of
Family Advocates (NAFA), Illinois Family Advocacy Coalition (IFAC), Georgia Family
Rights Association (GAFRA). Connecticut DCF Watch, Oregon Family Rights, and/or
have solicited, offered, and accepted membership from individuals and organizations
nationwide–including Colorado–to participate in the achievement of their respective

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missions and/or the joint mission.

180. The defendants solicit and accept donations from the market they serve and from the
general public in order to accomplish their mission.
181. The defendants conduct the business of selling or having sold products, including but not
limited to apparel and bumper stickers with their organization’s logo or the logo of
associate organizations, publications, advocacy, consulting and legal document writing
services and more to the market they serve and to the general public.
182. The defendants have been and are direct financial beneficiaries of their respective
organization, web sites and groups.
183. The defendants have introduced their own products into the stream of commerce
expecting they will be used in Colorado.
184. None of the defendants have exercised any authority they had in their respective
organizations or groups to prohibit or prevent any individual or organization that resides
in Colorado from joining as a member of their respective organizations or groups, or from
transmitting or receiving information, files, products and services to or from Colorado
residents or any way restricted a Colorado resident’s participation in the defendants’s
organizations or groups.
185. Defendants have purposefully availed themselves of the protection and benefits of the
laws of Colorado by virtue of their contacts with Colorado governmental agencies.
186. Each of the defendants has conducted business with persons in Colorado in that they have
affirmatively offered and provided their products to the relevant market and the general
public in Colorado.
187. Some of them sell or have sold or offered memberships to their organizations or
subscriptions to their publications. These memberships and subscriptions were solicited
from, offered to and accepted from persons who live in Colorado.

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188. Each of the defendants has conspired to commit tortious acts with persons who reside in
Colorado, and part of the conspiracy took place or was otherwise executed in Colorado
and Colorado was where a significant part of the information used for the conspiracy
derived from and where the tortious acts were felt.
189. Each defendant had the duty to insure he or she did not disseminate any content that he or
she was not authorized to have or nor did not have permission to disseminate.
190. As a owners and moderators of online groups the defendants had the ability and authority
to insure the accuracy of advertisements published there. They did not correct or prevent
false advertising.
191. The defendants’s occupations and business operations affect interstate commerce.
192. All of the defendants’s acts involving my Intellectual Property (IP) were and are
performed without my permission, license or consent.
193. As to the defendants who claim to have written original content for this market, one only
needs to read what they have written in the messages contained herein to see that they
lack the most basic spelling, grammar, writing and language skills and they lack the most
basic understanding of the esoteric issues that make up this issue, yet they miraculously
demonstrate superior writing skills and knowledge in their stolen, plagiarized and
infringing content.
194. The defendants’s intentional, tortious, actions were expressly aimed at Colorado. The
defendants engaged in conduct they knew would have, and was intended to have, a
potentially devastating impact upon me, my business and my property. This conduct
includes any one or more of the hundreds of acts described in this complaint.
195. The defendants knew that the brunt of that injury would be felt by me in the State in
where I live and work, and in which the defendants have a presence, and in which the
defendants have offered and provided goods and services to consumers without

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interruption. Under the circumstances, the defendants must “reasonably anticipate being
haled into court here” to answer for their tortious conduct against the me.
196. By virtue of the nature of the mediums of communication favored by a the defendants
(i.e. fully interactive online groups and emails) in the course of their respective
businesses, occupations, their personal operations, their individual advocacy and
activism, the defendants knew and intended that their communications and the
communications of the groups they created and exercised oversight and control over,
were intentionally directed to Colorado, and would be received in Colorado and utilized
by Colorado residents, or would originate from Colorado, would contain information
derived from Colorado to be received by the users of the groups and utilized by them.
197. By virtue of the nature of the mediums of communication favored by the defendants to
conduct their respective business activities, they each had continuous and systematic
contact with Colorado related to their respective businesses involving child welfare. They
participated in, owned and exercised control over groups and organizations that had
Colorado members, representatives, agents and consumers.
198. Defendants availed themselves of the advantages (privileges) of their association with
AFRA & CPS Watch by utilizing the vehicles offered by AFRA and CPS Watch to
participate in communications and expand the sphere of their own influence to encompass
the larger markets advertised by the other defendants.
199. The defendants’s contacts with Colorado are continuous and systematic because, in part,
their respective groups and web sites–containing Colorado-centric advertisements and
Colorado-specific content –are accessible to Colorado-based Internet users and viewers,
and such contacts have been in existence at least in excess of ten years.
200. Contacts were directed, intentional and purposeful, and focused. While some of the
defendants did not formally enter into Colorado, in all other respects, the defendants

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engaged in lengthy business ventures with Colorado entities, directing numerous

communications and revenues into the state, utilizing the services of state offices and
agencies, and engaging in conduct that affected state offices and agencies.
201. The users of the multiple groups transmitted and/or received child welfare and
government watch related content averaging at least once a week to and from Colorado
residents, and up to hundreds of times a day. See attached history of group transmissions;
Exhibit B.
202. By virtue of any communications the defendants initiated with me, seeking my products
or services, the work requested of me and performed by me on their behalf or on behalf of
their organization was performed in Colorado. They would send information relating to
the service they were requesting to me in Colorado as a condition of receiving my
services.
203. Any services or goods offered and provided by the defendants for my benefit or the
benefit of my business was willingly delivered to me in Colorado.
204. In the commission of their conspiracy and in the course of their occupations, the
defendants expressly conducted communications with Colorado residents, including
Colorado defendants, acquiring and using information which derived from Colorado and
disseminating information to the defendants for their use in Colorado and against me.
205. The defendants are each primary participants in multiple wrongful acts intentionally
directed at a Colorado resident, my business and my property, and jurisdiction over them
is proper on that basis.
206. The vast majority of infringing conduct was accomplished electronically. Consequently,
the location of the infringement is of little import inasmuch as the aim of the infringers is
to make the infringed work freely available to anyone with access to an Internet
connection, including computer users in Colorado. In addition, the injury to me as the

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copyright owner residing in Colorado is not as remote as a purely indirect financial loss
given the broad spectrum of rights accorded to me by copyright law and other laws. The
function and nature of the Internet, concurrent with the diverse rights I enjoy as a
copyright owner and business owner in Colorado justifies personal jurisdiction over the
defendants in this case.
207. The context, tenor and tone of the defendants’s publications were clearly vindictive and
indicated intent to deprive me of my property and associated property rights as opposed to
being emotionally neutral recitations of facts, and the messages are replete with personal
attacks, name-calling and taunts, and contain frequent episodes of literary and structural
incoherence indicative of an emotionally aroused state of mind.
208. Colorado has a substantial interest in this matter as it involves wrongs committed against
Colorado consumers, which therefore affects the People of Colorado.
209. Colorado has a manifest interest in providing its residents with a convenient forum for
redressing injuries upon business and property in Colorado inflicted by out-of-state
actors. This is even more axiomatic when the out-of-state actors conspire and act in
concert with actors who are Colorado residents to inflict injuries on a Colorado resident,
as in this case.
Defendant American Family Rights Association
210. I repeat and re-allege the facts in the preceding paragraphs of this Complaint as if fully
set forth herein.
211. American Family Rights Association (AFRA), is “a professional association” created in
2002. It is an association as described on it’s web site and various broadcasts,
congressional testimonies, legal briefs and electronic communications:
“The American Family Rights Association is a professional association of
parents, grandparents, family rights advocates, former foster and adopted
children, attorneys, licensed social workers, medical professionals, human

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rights and freedom advocates. . . .” Mission Statement.

212. AFRA is advertised on its web site as,
“(AFRA) is a true American FREE association operating as an umbrella
organization, created to bring disparate groups and individuals together in
order to generate enough UNITED VOICES to command NATIONAL ATTENTION
to our grievances. . .AFRA's activities promotes both ADVOCACY and
ACTIVISM Whether one is attracted to advocacy or activism is highly related to
one's personality type. Both are highly important.”
213. At all times in this complaint, the defendant designated as AFRA refers to the
professional association. AFRA online interactive groups are referred to by their
respective group designations.
214. AFRA sponsors, owns and operates a large number2 of fully interactive online forums,
groups and/or web sites (AFRA groups or groups), which are properties of AFRA.
215. AFRA groups are used to advertise AFRA, to offer and deliver support services,
information services and various products to the public, for soliciting membership into
AFRA, to advertise AFRA’s business activities and events, to solicit participation in
AFRA campaigns, for general communication and to conduct AFRA business among the
fifty states.
216. The AFRA BOD and defendant Henderson exercise oversight and control over these
interactive groups. During the time frame of this complaint, these AFRA groups include
or included but were not limited to:
http://groups.yahoo.com/group/AFRA_OHIO/; (to provide state-specific product to Ohio
members)
http://groups.yahoo.com/group/wa_fra/; (Washington state specific);
http://groups.yahoo.com/group/Oregon_Family_Rights/, (Oregon state specific);
http://groups.yahoo.com/group/cafra; (California state specific)
http://groups.yahoo.com/group/OKFAMRA/; (Oklahoma state specific)
http://groups.yahoo.com/group/MNFamilyRights/; (Minnesota state specific)
2
At one time advertised as sixty-five groups.

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http://groups.yahoo.com/group/Iowa_Family_Rights/; (Iowa state specific)

http://groups.yahoo.com/group/georgiafamilyrights; (Georgia state specific)
http://groups.yahoo.com/group/fla_afra/; (Florida state specific)
http://groups.yahoo.com/group/SCDSSComplaints;
http://groups.yahoo.com/group/scfamilyrightsassociation/;
http://groups.yahoo.com/group/KFRA/;
http://groups.yahoo.com/group/AFRA_HelpLine/; (To provide support, assistance and
information on individual cases of group members.)
http://groups.yahoo.com/group/familiesatrisk/;
http://groups.yahoo.com/group/vocalnewyork/;
http://groups.yahoo.com/group/childprotectionreform;
http://groups.yahoo.com/group/Justice_For_Families/ (currently moved to
http://groups.yahoo.com/group/JFF-USA/);
http://groups.yahoo.com/group/AFRA_CenCom/; (CenCom–To conduct official AFRA business)
http://groups.yahoo.com/group/AFRA_ALERTS;
http://groups.yahoo.com/group/AFRA_Director; (Directors–The official group of the AFRA
BOD)
http://groups.yahoo.com/group/AFRA_Elders; (For grandparents whose children are involved in
child welfare cases)
http://www.familyrightsassociation.com/departments/horror/;
http://groups.yahoo.com/group/AFRA_Kids;
http://groups.yahoo.com/group/AFRA_Media; (For the official media arm of AFRA)
http://groups.yahoo.com/group/AFRA_Newshawk; (To re-publish child welfare related news
articles)
http://groups.yahoo.com/group/AFRA_PN;
http://groups.yahoo.com/group/AFRA_PR; (Public relations business of AFRA)
http://groups.yahoo.com/group/AFRA_Projects; (To conduct the AFRA business on AFRA
sponsored or initiated projects)
http://groups.yahoo.com/group/AFRA_State_Leadership; (For AFRA state leaders)
http://groups.yahoo.com/group/AFRA_SWAT; (AFRA call-to-action emergency broadcasts)
http://groups.yahoo.com/group/AFRA_SWC;
http://groups.yahoo.com/group/AFRA_TalkLine; (TalkLine–For members to talk about child
welfare related issues)
http://groups.yahoo.com/group/AFRA_TechLine; (To assist members with computer technology)
http://groups.yahoo.com/group/afra_state_chapters; (For state chapters to discuss local AFRA
business)
http://groups.yahoo.com/group/TheAmericanFamilyRightsAssociation;
http://groups.yahoo.com/group/AFRA_CenCom; signature line reads “AFRA OFFICIAL
Leadership Communication Center. AFRA CenCom exist to enable Family Advocacy Leaders to

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conduct AFRA business, strategize ARA endeavors, and enhance the ORGANIZATION of
Family Advocacy Efforts. **AFRA_CenCom messages may constitute sensitive and confidential
internal information. **DO NOT FORWARD INTERNAL discussions to any unauthorized
outside person.”
http://www.groups.yahoo.com/group/AFRA_EAGLE (Later changed to USA_EAGLE)
217. The membership of these interactive online groups consists of consumers in this market,
as well as professionals, individuals and organizations who provide products to this
market and a small percentage of people who just have a general interests in this issue.
218. Membership in AFRA–the association–was originally never a prerequisite of membership
or participation in AFRA groups and visa versa. In most cases, it still isn’t.
219. Messages posted to these groups are widely disseminated from AFRA groups to other
parent’s rights, family rights, children’s rights, civil rights, government watchdog, and
other like-minded interest groups, forums and web sites, effectively saturating the market
with the information contained in the forwarded posts.
220. Some of the interactive groups are public, some are private and only members approved
by the BOD or owners or moderators can access the information contained in the
respective group archives and files sections and participate in the interactive online
forum.
221. At all times relevant to this complaint, I have been a member of at least one of the AFRA
online interactive Yahoo! groups, including but not limited to AFRA_EAGLE,
AFRA_CenCom, AFRA_Helpline, and AFRA_Talkline. In some cases, I have always
been a member. AFRA_NewsHawk is completely open to the public, membership is not
required.
222. I reside in Colorado. Nobody asked if I lived in Colorado when I joined any AFRA
groups, and the application to join did not exclude Colorado residents from membership.
223. Child welfare information and services have been disseminated to me and by me using

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these interactive groups, including information coming out of Colorado and directed at
Colorado.
224. As a member of these groups, AFRA has requested me, along with all other members, to
write white papers for submission to congressional hearings, to participate in AFRA
campaigns directed at various states–including Colorado, to sign up as a volunteer for
AFRA projects and work, to donate money for AFRA trips and presentations, to donate
specific items to AFRA, to purchase AFRA products3, and to call or write the leadership
with the services I could offer.
225. At AFRA’s requests, I have donated computer equipment , licensed software and video
editing hardware and software to AFRA’s use. AFRA has accepted each donation. My
most recent donation was a new Central Processing Unit (CPU) and bare bones computer
to defendant Henderson on or about September 9, 2008, because his computer had died.
226. Defendant Leonard Henderson is the founder of AFRA. He marketed membership in
AFRA by promising that each member of AFRA would enjoy its own autonomy of
operations without interference from AFRA.
227. AFRA was advertised as “supporting and promoting individual members and member
groups who were engaged in fighting Child Protective Services (CPS).”
228. AFRA offered itself as a marketing tool so local organizations could promote their
respective efforts, goods and services, and to advertise what was happening in their
locale, so local organizations and individuals could solicit AFRA members to support
their business, and to provide a unified political voice backed by numbers.
229. There were no conditions or qualifications for membership in AFRA.
230. AFRA members hale from every state–including Colorado–Canada and worldwide.
3
Such as T-shirts with the AFRA logo.

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231. AFRA has commanded the largest presence on the Internet and caters to this market with
an extensive web site and up to dozens of interactive online web sites and groups.
232. Member web sites usually include links to AFRA web sites and “proud member of
AFRA” logo displayed on their web site.
233. AFRA’s online presence has ranked at the top of Google and other search engines since
2005.
234. Henderson has been the web master for AFRA since its inception. He has proven to be
extremely competent and effective in directing Internet traffic to all AFRA web sites and
groups.
235. The primary content of the AFRA web site consists of articles, information and
documents written by others and found online. Much of what is published on the AFRA
web site is done so without the express permission of the copyright owners.
236. From its inception in 2001 to March 2006, AFRA was headquartered in Oregon.
237. Defendant Leonard Henderson was the founder and Chief Executive Officer of AFRA
during this time.
238. AFRA’s ownership and operations of multiple fully interactive web sites, coupled with its
numerous other activities directed at the state of Colorado and derived from Colorado
supply sufficient grounds to exercise personal jurisdiction over this defendant.
239. AFRA and Henderson sought my services and products multiple times, each time by
initiating contact with me at my place of business in Colorado.
240. On a daily basis, AFRA’s business activities were directed toward AFRA members–some
of whom reside in Colorado–receiving and transmitting information, files, services,
solicitations and other transactions to and from Colorado, including files containing
infringing content belonging to me and including content that was used to encourage,
participate in, support and execute the conspiracy against me.

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241. AFRA received information about me that originated in Colorado, from Colorado AFRA
members, and from state and local agencies, to use in the furtherance of the conspiracy
and tortious acts against me.
242. AFRA also directed campaigns to the state of Colorado, including lobbying Colorado
legislature, and contacting Colorado courts on behalf of Colorado AFRA members and to
influence legislation and court cases.
243. In October and November, 2001, Henderson contacted me by email and telephone and
requested me to be on the Board of Directors of the new organization he was forming,
which was AFRA. I declined. I said I was only comfortable serving in an advisory
capacity. He agreed to my being an advisor to the board, and insisted I be considered a
co-founder. I accepted, knowing this designation was purely to garner publicity for AFRA
based on my high-profile, national recognition in this field.
244. In January, 2002, Henderson sent me an email and sought my advice on how to structure
AFRA and we discussed other general AFRA business. He did not implement the advice I
provided.
245. On February 17, 2002, Henderson sent me an email stating, “Some people in Colorado
joined AFRA today and volunteered to ‘help.’ I referred them to you and recommended
your classes.”
246. Henderson also put an article about a committee hearing on Colorado H.B. 1275 on the
AFRA web site.
247. Pursuant to their express authority as agents for AFRA, Colorado AFRA members have
repeatedly submitted testimony to the Colorado legislature and to Boards of County
Commissioners in Colorado, in their efforts to effect reform to child welfare laws in
Colorado and to advocate on behalf AFRA members who reside in Colorado.
248. On or about July 2, 2002, Henderson defined the Responsibility of Advocates on the

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AFRA web site at http://www.familyrightsassocation.com/advocates/responsiblity.html.

He requested my input regarding omissions or errors in the article, which I provided.
249. On November 4, 2002, Henderson sent me an email containing background information
and requesting me to assist AFRA member JL4 with their child welfare case.
250. On November 29, 2002, Henderson sent me an email requesting me to assist AFRA
member JR with a child welfare case.
251. On December 15, 2002, Henderson sent me an email requesting me to write a regular
column for the AFRA Parentnews.net web site.
252. On or about November 29, 2002, Henderson advertised a book written by me for
children, Knowing My Rules, and published it verbatim on AFRA’s web site. He did this
without my knowledge or permission and without giving me credit, usurping my right of
first publication.
253. On or about December 13, 2002, Henderson, on behalf of AFRA, sent a broadcast request
to unknown recipients, including me, seeking a safe house and a job for an AFRA
member, T.M., who was fleeing Oregon CPS’s seizure of her children. I already knew
about this case because I had been contacted by the mother’s attorney. The facts
Henderson published on this case were in error. I did not respond to this request.
254. On or about March 1, 2003, Henderson offered to appoint me the head of AFRA Media
Productions division and asked if I would accept the position. I recognized this as an offer
for me to subordinate my independent media production endeavors to Henderson and
AFRA. I declined. However, I did donate computer hardware and licensed software to
AFRA Media Productions group to facilitate their ability to capture analogue video
footage to their computers and edit it.
4
I am using client initials to protect their confidentiality in the child welfare context.

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255. On or about Aprill 11, 2003, Henderson solicited AFRA membership response–including
my response–in support of Cheryl Barnes whose children were under “siege” in North
Carolina.
256. On or about May 29, 2003, Henderson sent me a request on behalf of a new Colorado
AFRA member, D.J. asking me to assist with the member’s case.
257. On or about November 2003, Henderson began to send me multiple email requests to join
AFRA’s interactive Yahoo! group, AFRA_CenCom (CenCom). I ignored the first
requests before joining sometime around March 2004. There were a number of members
on this interactive web site group from Colorado.
258. On or about December17, 2003, AFRA issued an AFRA Sudden Widespread Awareness
of Tyranny (SWAT) on behalf of Barnes, whose children were seized in Missouri. A
SWAT seeks directed responses to relevant state agencies and institutions from AFRA
members in support of the subject of the SWAT.
259. On or about March 16, 2004, Henderson wrote me a letter of reference and described my
working in glowing terms.
260. On May 7, 2004, Henderson emailed me with a request to purchase a copy of my book,
Profane Justice, directly from me because shipment via Amazon.com would take too
long. He wanted to publish a review on the AFRA web site and groups. I sent him the
book for free on the condition he publish a review. He got the book but he never
published the review.
261. On or about May 13, 2004, AFRA solicited the AFRA membership and the general
public on AFRA online interactive groups, and on the AFRA web site to participate in a
SWAT directed at Weld County, Colorado, on behalf of Colorado AFRA members.
262. On or about June 9, 2004, Henderson advised the BOD on Directors, “The truth is

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[Sworn Affidavits are] the only tool we have5 and the only thing that really matters.”
He exhorted the directors to get the Sworn Affidavit Drive going in every state for every
member who has a child welfare case. AFRA had nothing original to offer the market
other than this useless and harmful product. AFRA had droves of hapless consumers
damaging their child welfare cases with this advice, including parents in Colorado.6
263. On or about July 12, 2004, Colorado AFRA member, Christine Korn, requested AFRA to
add her organization’s name, COFRA, to AFRA’s list of state family advocates for
Colorado. AFRA complied with her request and subsequently referred AFRA members
from Colorado to COFRA for state specific assistance.
264. On or before August 29, 2004, AFRA issued a SWAT to AFRA membership directed at
Fremont County, Colorado, on behalf of a Colorado AFRA member family.
265. Henderson sent out a subsequent request for membership response to officials in
Colorado on all AFRA groups and included a sample letter for member’s use. Letters
were submitted by over one hundred thirty-seven AFRA members to Hon. Charles M.
Barton (11th Judicial District, Colorado) including by defendants W. Tower, A. Tower,
Durand, Jackson, and Henderson.
266. On September 10, 2004, Henderson sent me an unsolicited email with contact
information for AFRA members, J & D requesting my assistance with advocacy services
in Hawaii.
267. On September 20, 2004, Christine Korn was identified as being the leader of Colorado
5
This demonstrates AFRA had virtually no knowledge of my methods prior to
misappropriating them. Sworn affidavits have proved harmful in many child welfare cases.
6
Colorado opponents to my work were actually blaming me for disseminating this
harmful advice, in an effort to discredit my business and obtain administrative and other
sanctions against me, despite the fact that I repeatedly stated AFRA’s tactic was harmful to the
consumer.

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AFRA on AFRA_CenCom.
268. On or about February 8, 2005, Henderson put a link to Colorado AFRA member
Thomas’s blog, which had been submitted to CenCom, on AFRA’s web site. This
Colorado author’s blogs were regular features on AFRA groups and web sites.
269. In March of 2006, AFRA was headquartered in Massachusetts, under the presidency of
Gregory Hession.
270. From approximately mid-March to mid-April, 2006, AFRA was once again
headquartered in Oregon under the leadership and control of defendant Leonard
Henderson.
271. From April 2006 to the present, AFRA has been headquartered in California under the
leadership of defendant William O. Tower who is advertised as President and CEO of
AFRA.
272. AFRA is not registered with the Secretaries of State in California, Oregon, Delaware or
Massachusetts. It is an unincorporated association.
273. On or about October 24, 2006, on the Improvement Project, Henderson stated he, “OWNS
EVERYTHING” and he can “make everything AFRA disappear forever.”
274. On or about March 6, 2007, AFRA Vice President Hinger requested the assistance of
Colorado AFRA member Dee Contreras on behalf of an AFRA representative from
Michigan who was coming to Colorado to obtain a donation from a “well-to-do”
Colorado friend interested in financially backing specific legislation in Colorado. He
requested Contreras to attend the meetings with the AFRA representative and be the local
contact for the friend. This meeting took place in Denver between March 10-14, 2006.
275. On or about April 26, 2007, Hinger published on all AFRA groups the development of a
pro bono legal program for Colorado child welfare cases. Contreras has participated in
this endeavor and, upon information and belief, has provided my proprietary materials to

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these Colorado attorneys.7.

276. Defendant Leonard Henderson has exercised continuous exclusive control over the
content and information contained on AFRA web sites since 2002.
277. Henderson has also held owner and/or moderator status on all AFRA online interactive
groups, with authority and ability to control the content of messages and participation of
members.
278. AFRA business is managed by a Board of Directors (BOD) presided over the president.
The BOD conducts AFRA business electronically, in person, and telephonically. Starting
in 2002, one of the BOD members, Harry Simpkins, was from Colorado.
279. AFRA has gedneral membership in the 50 states, including a significant number of
members who reside in Colorado. See Exhibit C; AFRA Colorado membership.
280. I was a Colorado member of AFRA from 2002 to 2004. During that time I worked with
other AFRA members who lived in Colorado and nationwide.
281. AFRA membership has been advertised as being estimated at 140,000 (one hundred forty
thousand) in 2003. In 2004, Henderson reported an approximate head count of 35,000,
and representing 150,000 voices. He stated that 99% of them are consumers.
282. One of AFRA’s express functions was the dissemination and receipt of information,
articles, news, consumer advice, political activism and advocacy generally related to child
welfare issues through a number of online, fully interactive web sites, groups and forums.
283. A search of the AFRA website on May 6, 2009 revealed the following information
products targeted to Colorado residents:
a. http://www.familyrightsassociation.com/bin/Juvenile_Handbook_Respondents.ht
ml - advertised as materials for respondent parent’s counsel in Colorado.
7
These materials were obtained from AFRA members and defendants Wiseman,
Swallow and Durand, as described later in this complaint.

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b. http://www.familyrightsassociation.com/info/spanking_laws.htm - advice on
spanking laws in Colorado.
c. http://www.familyrightsassociation.com/departments/advocacy/ - Advice from
Colorado-based AFRA member group Colorado Family Rights how to Organize a
Demonstration
d. http://www.familyrightsassociation.com/info/law/all_about_miranda/Questioning
%20of%20Juveniles.htm - advice for Colorado consumers regarding the
questioning of Juveniles citing Colorado case law.
e. http://www.familyrightsassociation.com/info/help/ - Documents from a Colorado
Lawyer’s handbook on Juvenile Courts.
f. http://www.familyrightsassociation.com/bin/FORMS/For_attorney_of_falsely_acc
used_parent.txt - what to advise your attorney in writing from the Colorado-based
AFRA member group Family Solidarity Coalition.
g. http://www.familyrightsassociation.com/bin/white_papers-articles/investigations.
html - Information providing Colorado laws related to the removal of children
from home and contact information for contacting Colorado Department of
Human Services.
h. http://www.familyrightsassociation.com/swat/9-29-04/index.html - AFRA SWAT
page seeking widespread membership response in support of a Colorado family
who were AFRA members. Providing contact information to public officials and
encouraging a letter writing campaign.
i. http://familyrightsassociation.com/news/archive/2008/july/national_council_for_a
doption_7-28-08.htm - A call to state senators regarding the National Council for
Adoption, including a directed plea to Colorado residents.
j. http://www.familyrightsassociation.com/swat/9-29-04/manzoni.html - AFRA

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member writes a letter to Colorado Judge Barton on behalf of a Colorado family.

k. http://www.familyrightsassociation.com/swat/9-29-04/christine_9-29-04.html -
AFRA seeks membership participation in campaign to return Colorado AFRA
member’s grandchild home.
l. http://www.familyrightsassociation.com/hotspots/archive/2005/feb05/2-24-05.htm
l - promoting a Family Rights Advocacy seminar in Colorado.
m. http://www.familyrightsassociation.com/hotspots/archive/2004/feb04/2-1-04.html
- Announcing new web site for activists seeking wholesale impeachment of
Colorado judges.
n. http://www.familyrightsassociation.com/hotspots/archive/2004/oct04/10-25-04.ht
ml - SWAT for Colorado member family.
o. http://www.familyrightsassociation.com/hotspots/archive/2005/jan/1-14.05.html -
seeking AFRA membership support for activist in Colorado court proceedings.
p. http://www.familyrightsassociation.com/hotspots/archive/2004/sept04/9-30-04.ht
ml - seeking membership participation and support for Colorado member family.
q. AFRA web site includes a link to their Parentnews web page entitled “Spotlight
on Colorado”
284. This list does not reflect the volumes of articles and information directed at Colorado or
derived from Colorado prior to 2009, many of which I wrote. AFRA has removed most or
all of the documents directed at Colorado or derived from Colorado from its web site
since May, 2009.
285. An examination of the AFRA members page for Colorado as of May 6, 2009, reveals
eighty-one individual members, including defendant Dee Contreras8, and eight AFRA
member groups. This member page includes links to two AFRA pages for News and for
8
She is still listed as a member as of April 7, 2010.

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Resources specifically directed at consumers in Colorado. AFRA has had Colorado

members and provided Colorado-centric information and resources since its inception.
286. An examination of the AFRA membership pages reveals AFRA membership consists of
a significant percentage9 of current or former consumers of child welfare products.
287. AFRA membership also consists of professionals and other individuals and organizations
who provide products to the consumer in this market via AFRA’s web site, groups and
other mediums.
288. Some of these professionals are seeking products to assist with better serving families
involved with child welfare agencies.
289. Some of these professionals are there to gather information to use against consumers who
are families involved with child welfare agencies.
290. Consumers are permitted by AFRA to obtain their child welfare related products and
services from any provider, not just AFRA, and do obtain their products and services
from a variety of providers.
291. AFRA has always actively promoted the products of both AFRA members and non-
AFRA-members who are providers of goods and services to this market without
exception, regardless of the quality of the goods and services offered.
292. AFRA membership is expressly authorized to speak on behalf of AFRA and perform as
AFRA’s official representative in their area.
“If you are an AFRA member in good standing in your state, you have complete
authority to talk to the media, bureaucrats, and the masses ON BEHALF OF
AFRA. You ARE the representative and official spokesman for AFRA in your
local area and state. . . .You ARE AFRA in your locale, and your standing in the
association is equal to mine.” Leonard Henderson, AFRA_Directors,
AMOJ_MAIN, January 5, 2005.
9
In excess of 90%.

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293. AFRA’s presence in this jurisdiction is manifested by the activities of those who are
authorized to act for it. All AFRA members are authorized to act for AFRA, including
Colorado AFRA members.
294. Members are expressly authorized to use “. . . [AFRA’s] Copyrighted and Trademarked
name “American Family Rights Association©®” and our Logo's [sic] in your
representation of AFRA.”
295. American Family Rights Association or AFRA is not registered with the U.S. Patent and
Trademark Office.
296. AFRA BOD devises policies and conditions for membership, and has the authority to
enforce AFRA policies by revoking AFRA membership. AFRA’s web site states:
Violation of these conditions can result in the suspension of your AFRA
membership by the AFRA Board of Directors, and the requirement that
you cease and desist using the name “American Family Rights
Association” and/or our logo's [sic] or other official identification with
AFRA.” April 20, 2005
297. AFRA has revoked AFRA membership to various members over the years for various
reasons, usually related to sexism thinly disguised as something else. However, AFRA
has never revoked the AFRA memberships of the defendants.
298. AFRA sponsors, owns and operates a partially interactive web site, which is a property of
AFRA–the association. Users of this site may browse available documents and files and
download them, make donations, submit comments, apply for membership, and purchase
products.
299. This web site has a domain name of familyrightsassociation.com, which was registered in
2002. An alias domain name, familyrights.us also directs to the AFRA web site. These
domain names are properties of AFRA.
300. In 2002, the AFRA domain name properties belonged to Leonard Henderson.
301. As of 2006, the domain name properties belong to William O. Tower.

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302. AFRA describes it’s leadership as, “Power remains spread out to individual state
leaders and to the membership in the grand American tradition.”
303. AFRA’s express policy regarding AFRA advocacy was that if someone was trying to help
a family, it didn’t matter whether they harmed the consumer family. “We should refuse to
knock anyone that is out helping others. (At least they are doing something)” W.
Tower February 5, 2005, AFRA_CenCom.
304. AFRA’s philosophy on advocacy has been demonstrated as,“I was victimized by CPS,
therefore I am qualified to advocate for a family being victimized by CPS.”
305. On November 20, 2006 AFRA Executive Vice-President Hinger published an
advertisement on AFRA groups touting AFRA’s successes and cited this Colorado-based
member’s outcome using AFRA’s services:
“A grandmother was referred to AFRA from a Colorado Family Rights
Group she had sought help through, who felt the case was a lost cause.
Her grandchildren were in CPS custody in another state and the case
was scheduled for TPR and the children for adoption. Two AFRA
members pitched in and advised her what motions she needed to file and
assisted her in getting the papers filed in the custodial state. Grandma
file a 50 page motion to the court and a week before the . . .TPR
hearing, CPS granted her custody of the children and. . .the children and
grandma flew home at CPS expense. . .”
306. On or about July 20, 2009, Henderson advertised on Helpline, “[AFRA] is the association
of family rights advocates and activists.”
307. AFRA gives case specific legal advice to users on AFRA groups.
308. AFRA is a principle actor and co-conspirator to the claims raised in this complaint. At all
times relevant to this complaint, AFRA was used as a vehicle used by the defendants, as
were AFRA interactive online groups, for conspiratorial communications, dissemination
of false and misleading advertising, the transmission and display of infringing content,
and the commission of tortious acts against me.
309. AFRA members are agents of AFRA.

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310. AFRA has agents and representatives situated in Colorado, maintains a business presence
in Colorado, and transacts AFRA business in Colorado.
311. The tortious acts of the agents bind the principle, therefore AFRA is liable for the tortious
acts committed by its members, who are its agents, in the name of AFRA or by use of the
properties and mechanisms owned and provided by AFRA, or in response to solicitations
and exhortations broadcast by AFRA and AFRA agents.
Defendant William O. Tower
312. I repeat and re-allege the facts in the preceding paragraphs of this Complaint as if fully set
forth herein.
313. William O. Tower (Tower), an individual domiciled at 7334 Chivalry Way, Citrus
Heights CA 95621-4333, and member and President and CEO of American Family
Rights Association (AFRA).
314. Tower is owner and/or moderator and user of AFRA online groups and interactive web
sites.
315. Tower also claims ownership of AFRA.
316. W. Tower was founded for jeopardy to his children in Maine. He was accused of brutal
physical abuse upon his step children, and arrested. The criminal charges were dropped.
After learning the report originated with the school, police reports reveal he went to the
school told a school worker he had a gun and knew how to use it. The step children were
permanently removed from his home. He appealed the decision and the court upheld the
lower court’s finding. He sued for civil rights violations and the case was dismissed. He
appealed the dismissal of the Maine case in California, which was dismissed for being
brought in the wrong jurisdiction.
317. Prior to April, 2006, when he assumed presidency of AFRA, Tower was the leader of
AFRA’s California state organization and served on AFRA’s BOD.

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318. Tower is a principle actor and co-conspirator to the claims raised in this complaint. At all
times relevant to this complaint Tower expressly conspired with AFRA, Jackson,
Henderson, Hinger and other defendants, using AFRA and non-AFRA interactive online
groups, and electronic and other communications, and expressed his support for the other
conspirators and demonstrated his willing participation in, and instigation of, the tortious
acts against me. He also provided the vehicles for those acts to be discussed and
committed by other defendants and failed and refused to prevent the tortious conduct by
AFRA agents and other defendants against me, which acts used AFRA and AFRA
properties over which he exercised authority and control.
319. W. Tower’s ownership and operations of multiple fully interactive web sites, his personal
participation via those web sites and groups, coupled with his numerous other activities
directed at the state of Colorado and derived from Colorado supply sufficient grounds to
exercise general personal jurisdiction over this defendant.
320. Tower advised me on a telephone call that he initiated in approximately 2005 that he was
the executor of his aunt’s estate valued at forty million dollars, and he received ten
percent of the estate as the executor. He also told me was going to use that money to pay
for law school.
321. On or about August 12, 2004, Tower called me on the telephone, seeking advice and
guidance on several issues that he wanted to present to congress. I disagreed with his
proposals as ineffective. He was not receptive to my observations.
322. On August 21, 2004, he made the same request to me via email.
323. Between 2004 and 2005, W. Tower sent me thirty-six unsolicited emails pertaining to
child welfare reform. This was sent to a list of undisclosed recipients, and was intended to
solicit my participation in building a coalition. I recognized this as an attempt to use my
stature to increase his credibility.

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324. During 2004 - 2005, W. Tower made multiple phone calls, three or four times a month, to
Christine Korn in Colorado who was a licensee of my proprietary IP. He solicited her to
provide him with my proprietary materials on the pretext that he need to assess them
before hosting a seminar in California. She refused his requests and told him to attend a
seminar in Colorado if he needed to assess the program before sponsoring one in
California. When he refused, she said he needed to speak to me. See Exhibit D; Affidavit
of Christine Korn.
325. On May 6, 2004, Tower announced hearings on State Efforts to Comply with Federal
Child Welfare Reviews, soliciting my application to testify.
326. On or about June 17, 2004, W. Tower was part of the AFRA delegation who made a trip
to Washington D.C. to represent AFRA on child welfare issues in a meeting with
congressmen. The delegation reported it met with Colorado then-Senator Ben Nighthorse
Campbell who requested AFRA provide him with information. The delegation also
included defendants T. Dutkiewicz, Hinger, A. Tower.
327. On or about July 2, 2004, Tower posted a request for information to reverse his child
welfare case in Maine, on CenCom,
“is Crawford [v. Washinton] grounds for a appeal and reversal of Jeopardy
order in a child protective case? can I file a Crawford motion for reversal of
my Jeopardy order in the state of Maine? (where this all took place).10”
328. W. Tower has claimed he was a paralegal, a Guardian ad litem (GAL), a Court Appointed
Special Advocate (CASA) and a law student. Subsequent investigation revealed he was
not a GAL, nor a CASA, and was not enrolled at Pacific McGeorge School of Law as he
claimed.
329. In March of 2006, I attempted to negotiate a resolution to the problems with AFRA.
Then-president of AFRA, Gregory Hession, and I arrived at a reasonable settlement and
10
At least two years prior.

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Mr. Hession drafted the contract. However, defendants Kiefer, W. Tower, Dutkeiwicz
and other AFRA leaders vigorously opposed any agreement with me, stating they didn’t
want a negotiated peace, they wanted me gone from the market and gone from the
Internet. As a result of W. Tower’s and other defendant’s intransigence, Mr. Hession
resigned as president of AFRA and the settlement contract was never executed.
330. William O. Tower made numerous and extensive attempts to gain unauthorized access to
my seminar materials from licensees. He even admitted to me that he had gained access to
it. He also submitted evidence in the California lawsuit showing he sent someone to gain
entry to my presentation in Connecticut and acquire the seminar handout.
331. On or about February 27, 2007, W. Tower, on AFRA_TalkLine (TalkLine), W. Tower
solicited members to set up lobbying, track legislation “in every state,” and solicited
donations to fund this work on behalf of AFRA. I was a member of TalkLine and
received this message and solicitation.
332. On or about February 27, 2007, on AFRA groups, W. Tower solicited donations from
AFRA groups (including me on more than one group) to send him to Washington DC to
testify before the Income Security and Family Support Subcommittee.
333. On or about May-August 2007, W. Tower sent multiple solicitations11 to all AFRA
groups for donations and for members to purchase AFRA t-shirts to fund AFRA’s
presence at the “DC Rally.” He also solicited group member participation or to volunteer
for either the D.C. event or in their corresponding local state events. I received these
notices as a member of more than one of these AFRA online interactive groups. For the
record, all requests for accounting of those donations after the event were ignored or
rebuffed.
334. On or about July 25, 2007, W. Tower solicited AFRA group members to submit a report
11
May 3-4, 18, 21-24, 25, 29. June 4, 6, 9, 11, 14. July 15, 17, 26. August 7.

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to Subcommittee on Income Security and Family Support. I received this solicitation as a

member of at least one AFRA group.
335. On or about April 25, 2010, A. Tower and/or W. Tower contacted
KnowYourCOurts.com, a Colorado web site that features issues associated with Colorado
courts, via email through the web site’s Tipline, seeking information about me and
demanding to know about records that he or she claimed had been removed from that site.
Defendant Anne E. Tower
set forth herein.
337. Anne E. Tower (A. Tower), wife of William O. Tower, an individual domiciled at 7334
Chivalry Way, Citrus Heights, CA, 95627, is a member and agent of AFRA and a
contributor to AFRA forums. A.Tower was a moderator of AFRA_EAGLE. She has been
advertised as Assistant Executive Director of AFRA as of the end of 2005 and assumed
some of W. Tower’s duties during his illness. She shared W. Tower’s email address so it
is possible that publications and advertisements attributed to him were actually authored
by her and visa versa. The actions of A. Tower and W. Tower are deliberately intertwined
so as to be unable to distinguish who is responsible for what in some events.
338. A. Tower was founded for jeopardy of her children in Maine, for allowing W. Tower to
physically abuse them. Her children were removed from her home and placed with their
father.
339. A. Tower is a principle actor and co-conspirator to the claims raised in this complaint. At
all times relevant to this complaint A. Tower expressly conspired with AFRA,
Henderson, Jackson, W. Tower and other defendants, using AFRA and non-AFRA
interactive online groups to willingly participation in the tortious acts against me. As
moderator or AFRA groups and an officer of AFRA, she also provided the vehicles for

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those acts to be planned and committed by other defendants. She also provided the
vehicles for those acts to be discussed and committed by other defendants and failed and
refused to prevent the tortious conduct by AFRA agents against me by use of AFRA and
AFRA properties over which she exercised authority and control.
340. A. Tower’s operations of multiple fully interactive web sites and groups, her personal
participation via those web sites and groups, her position as AFRA officer and acting
AFRA officer on behalf of W. Tower during his illness, coupled with her numerous other
activities directed at the state of Colorado and derived from Colorado supply sufficient
grounds to exercise personal jurisdiction over this defendant.
341. A. Tower participated in an August 29, 2004, AFRA SWAT campaign directed at
Fremont County, Colorado, on behalf of a Colorado AFRA member family by writing a
letter to Hon. Charles M. Barton (11th Judicial District, Colorado) in an effort to influence
his decision in a court case.
342. On or about June 17, 2004, A. Tower was part of the AFRA delegation who made a trip
to Washington D.C. to represent AFRA on child welfare issues in a meeting with
congressmen. The delegation reported it met with Colorado then-Senator Ben Nighthorse
Campbell who requested the AFRA delegates to provide him with information.
343. A. Tower has had access to my proprietary content and has used it on behalf of AFRA as
the basis of information she disseminated on the AFRA_EAGLE group.
344. On or about October 22, 2006, A. Tower began participating in providing case
management information to consumers seeking assistance on AFRA_EAGLE interactive
online group. The information she provided was created by in Colorado by me, the
information she disseminated derived from Colorado.
345. I was a member of this group. I received the information she disseminated to Colorado, as
did other Colorado group members. She did not give me credit as the originator of the
methods she disseminated to the users and owners of this group.

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346. On or about February 25, 2007, A. Tower published tactics and recommended letters to
social worker on AFRA_EAGLE group in a document entitled
“lttrs_to_a_social_worker.doc.. She, and no member of AFRA or CPS Watch had never
published such in-depth analysis and tactics on this subject before, nor shown such
comprehensive knowledge of this method. This method is discussed in detail in my
seminars12, is included in my handouts, and constitutes an integral part of my trade secret
proprietary information. A. Tower took credit for this method. This information remains
available in the archives of this group to this day.
347. On at least seven other occasions, on or about March 24, 26 and May 7, 10, 17, 18, and
September 6, 2007, and February 8, 2008, on AFRA_EAGLE A. Tower again offered
advice to the users of the group which she neither she nor any other defendants had never
demonstrated the knowledge of before and which was identical to information contained
in my seminar handout and is based on my proprietary methods and trade secrets. A.
Tower took credit for this method. This information remains available in the archives of
this group to this day.
348. On or about April 25, 2010, A. Tower and/or W. Tower contacted
KnowYourCOurts.com, a Colorado web site that features issues associated with Colorado
courts, via email through the web site’s Tipline, seeking information about me and
demanding to know about records that he or she claimed had been removed from that site.
Defendant Dennis Hinger
forth herein.
350. Dennis Hinger (Hinger), an individual with a last known domicile at 5816 Shadow Creek
Dr. #3, Sacramento, CA 95841, and a member of, agent of and former Executive Vice
12
Which are protected by non-disclosure agreements, infra.

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President of AFRA. He was an owner and/or moderator and user of AFRA online
groups during the time of the allegations in this complaint.
351. He was summarily removed from the AFRA Board of Directors (AFRA BOD) by Tower
for egregious conduct not related to this claim on or about August 25, 2007. Hinger then
allied himself with certain other defendants and continued his wrongful activities against
me in this market.
352. Hinger had his child removed from him in California for approximately two years due to
abuse/neglect allegations, which were founded by the court. He reports his child was also
removed four years prior in Washington.
353. Hinger is a principle actor and co-conspirator to the claims raised in this complaint. At all
times relevant to this complaint Hinger expressly conspired with AFRA, Henderson,
Jackson, W. Tower and other defendants, using AFRA and non-AFRA interactive online
groups to express his support for them and to demonstrate his willing participation in and
instigation of the tortious acts against me. As AFRA executive officer and groups
moderator, he also allowed AFRA properties and groups to be use as vehicles for the
planning, solicitation and commission of the tortious acts described in this complaint and
failed and refused to prevent the tortious conduct by AFRA agents and other defendants
against me by use of AFRA and AFRA properties over which he exercised authority and
control.
354. Hinger’s operations of multiple fully interactive web sites, his personal participation via
those web sites and groups, his position as an officer of AFRA, coupled with his
numerous other activities directed at the state of Colorado and derived from Colorado
355. On or about June 23, 2004, Hinger engaged in a discussion with Colorado member Ms.
Korn on AFRA_CenCom about politics and child welfare. He requested she provide him
with sixteen to twenty-four Colorado cases involving abuse in foster homes to include in

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his submission to HHS13 for AFRA. When asked why by another member, he was
secretive about what use those records were going to be put to.
356. On or about June 23, 2004, on CenCom, Hinger reported on an AFRA-sponsored trip to
meet with congressman Herger in Washington D.C. He falsely stated that much of what
was presented to HHS got into the record. I requested Hinger to identify what record it
got into so I could obtain a copy. He responded, “I have no problem with anybody
requesting a copy of the HSS Record when It is Ready.” He did not provide what
record it appeared in. I did not write back to him. He later reported he had a heart
attack on the trip, which had actually precluded them from attending the HHS hearing.
357. On June 23, 2004, Hinger reported his son was returned home after twenty-one months.14
The agency still had an additional six months of supervision.
358. On or about June 25, 2004, Hinger advertised on CenCom that he had met with Colorado
Senator Ben Nighthorse-Campbell while in Washington D.C. who had requested
information from the AFRA delegation. Hinger reported the delegation provided the
information to the senator.
359. Hinger was advertised as being an advocate on AFRA CenCom’s state advocates list on
or about June 30, 2004.
360. On or about April 11, 2006 Hinger published on AFRA_CenCom, “There is a highly
active and functioning BOD. . .” His signature line stated he was AFRA Director and
Group Moderator signifying his authority to exercise control over the content
disseminated on AFRA groups and over the membership of the groups and the
13
U.S. Department of Health and Human Services
14
This is significant because it does not represent a true victory over what the agency
would have done without AFRA involvement. In fact, it tends to represent that the agency kept
custody of the child longer than normal due to AFRA involvement, since these cases are
mandated to achieve permanency at twelve months.

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association.
361. In May, 2006, Hinger filed a frivolous request for a restraining order against me in
California, and sent the El Paso County sheriff to my house to attempt to serve me in
Colorado.
362. Hinger purchased a document, San Bernardino Congressional Hearing AFAC Comments,
from my web site on or about September 17, 2006. He received download instructions
from my seller account on the site where the document was stored and downloaded the
document after paying for it. By making this purchase, he agreed to a forum selection
clause acquiescing to personal jurisdiction in Colorado.
363. On or before December 15, 2006, Hinger advertised and published a document (htd.pdf)
on all AFRA groups and placing it in their files sections. This document was purportedly
authored by Hinger and contained information heretofore unknown by him, gleaned from
my proprietary information documents that had been obtained illicitly and distributed by
the defendants. Hinger did not give me credit as the source, but took credit as the original
creator.
364. The information contained in this document was created by me in Colorado. The
information disseminated each time someone downloaded this document was derived
from Colorado.
365. On or about December 15, 2006, Hinger announced the debut of his new advocacy
organization and AFRA member group, The American Family Rights Advocacy Project
with a web site at www.afrap.com. He published this advertisement on all AFRA groups.
366. On this web site, Hinger published his document htd.pdf which was an impermissive
derivative work based on my proprietary trade secret methods and copyrighted
information. He proposed to offer the same services I offered, based on my body of work.
He had heretofore never demonstrated the knowledge he was now demonstrating. He
advertised his web site and document again on AFRA_Helpline on January 6, 2007. He

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also stated that he was writing more brochures15 for his web site.
367. On or about December 15, 2006, Hinger emailed me stating Tower had contacted him
about my cease and desist demand regarding his document on AFRA groups. He refused
to address my complaint and offered me a reference to where he could be served legal
papers. When I tried to serve him for this lawsuit, he evaded service and moved.
368. On or about December 19 & 20, 2006, Hinger offered case specific legal advice to an
AFRA group member family in Colorado who had requested information about WIC16
and CPS involvement.
369. On or about March 6, 2007, on AFRA_EAGLE, Hinger requested assistance from
Colorado AFRA member defendant Contreras:
Dee, Nancy Luckhurst will be arriving in Denver on the 9th to meet with a well to do
friend of mine who is interested in a piece of legislation she helped get passed in Mich.
a few years back. He wants to back us in getting it passed in CO. and CA. by making a
generous donation. Do you think you could attend the meetings between them in
Denver on the 10th and 11th and then at the Hot Springs the 12th to the 14th and act
as Jims local contact on this? Nancy is taking her laptop with and will contact you
along the way from Mich. to CO. . . ....Dennis
370. On or about April 26, 2007, on AFRA_HelpLine and Directors, Hinger announced a
project he had participated in creating for AFRA:
GOOD NEWS FOR COLORADO! Something new and different will be happening in
Colorado in the very near future. Several large law firms in the area are
sponsoring the expansion of a group of attorneys doing pro bono work for
families involved with CPS. The group is offering free seminars and workshops
for parents, as well as mock court cases in which public participation will be
encouraged. What an innovative way of educating the public. More
information will be made available over the next few months.
371. On or about August 21, 2007, Hinger published a broadcast message about his being
15
This was the exact suggestion Henderson had made regarding how to publish and
distribute my books and information as described below.
16
Women, Infants, Children program.

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summarily removed from AFRA BOD and alleged,

“Bill has been extremely secretive about Rally details and only came out with
outlandish claims and a sales job after being pressured into it... He again
promised a full accounting of all monies received and how they were disbursed
on the Tshirt sales and just like the funds he handled for the DC trips, when
asked when the accounting would be ready he got angry and absolutely refused.
. .I have no idea why Bill is so adamant about accounting for the funds, or his
actions on the rally other than he does not want to admit that he exaggerated
and out right lied about the rally details. . . There never was a DC Parks
estimate of over 250,000 people attending the rally... DC Parks no longer does
estimates, that is the responsibility of the permit holder... There never was a
pledge of $125,000... The permit did not cost $25,000 and there never was a
Marine Corps Color Guard or Band... Etc... Etc... Etc...”
372. Hinger was removed from AFRA after my expose’ on the Improvement Project about
him turning an innocent parent in to child protective services (CPS).
373. On or about February 23, 2009, I received an email from Hinger’s email address
purporting to be from his disabled son in response to my electronic service of the
summons and complaint in this action stating his father was dying and to let him die in
peace. Subsequent to that email, Hinger was known to be alive and well, evading service
and moving to a new, undisclosed location.
374. Between March 2004 and August 2007, Hinger personally disseminated hundreds of
messages on AFRA groups directed to Colorado members, and exercised oversight over
thousands of messages in his capacity as moderator of AFRA groups and BOD.
Defendant Leonard Henderson
set forth herein.
376. Leonard Henderson (Henderson), an individual domiciled at 4773 Salmon River Hwy.,
Otis, OR 97368. Henderson is founder, member and current Board member and former
President and/or CEO of AFRA and owner of Oregon Family Rights. owner and/or
moderator and user of AFRA online groups; webmaster of the official AFRA web site.
Agent of AFRA.

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377. Henderson’s children were adjudicated dependent in Oregon. The techniques he brags
about which resulted in his case finally being closed after three years include bullying,
threats, intimidation, misogyny and abuse.
378. Henderson is a principle actor and co-conspirator to the claims raised in this complaint.
At all times relevant to this complaint Henderson expressly conspired with AFRA,
Hinger, Jackson, W. Tower and other defendants, using AFRA and non-AFRA interactive
online groups, and to express his support for them and to demonstrate his willing
participation in and instigation of the tortious acts against me. As AFRA executive officer
and groups moderator, he also allowed AFRA properties and groups to be use as vehicles
for the planning, solicitation and execution of the tortious acts described in this complaint
and failed and refused to prevent the tortious conduct by AFRA agents and other
defendants against me by use of AFRA and AFRA properties over which he exercised
authority and control.
379. Henderson’s operations of multiple fully interactive web sites, his personal participation
via those web sites and groups, his position as owner and officer of AFRA, coupled with
his numerous other activities directed at the state of Colorado and derived from Colorado
380. Henderson solicited the general public for membership in AFRA with promises of mutual
support, unity, power in numbers, a national forum, and the sharing of information.
381. He postured as the “old daddy” who was patient and long-suffering, and but his
leadership tools were authoritarian, controlling and condescending.
382. He professed excellent people skills and management talents, and fancied himself a
“wordsmith.” He is a master of propaganda.
383. He promised to bring all like-minded organizations together under the AFRA umbrella
and we could all be one happy family under his benevolent leadership.
384. His tools were gratuitous flattery, shallow ego-stroking and threats, rather than affording

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respect, dignity and self-determination. Should anyone refuse to be gathered into the
AFRA fold, he would publicly admonish them and heap insincere praise upon them, in a
schizophrenic display of pseudo-affection and hate at the same time.
385. On or about October 10, 2000, Defendant Leonard Henderson (Henderson) contacted me
via email with the subject “I want to help” and requested advocacy training from me. He
also offered me a new color printer as a donation, and offered to perform any large
productions of color printing for the cost of consumables, and computer services “from
CD-ROM burning to a custom database.” Henderson sent the printer to me and I received
it within a few days.
386. On October 19, 2000, Henderson contacted me via email requesting my services with a
problem he was having with his children’s school.
387. On or about October 3 & 4, 2001, Henderson contacted me via email offering his
webmaster services for my web site and requesting if I would be interested in doing guest
editorials for his American Family Law Advocacy web site at aflag.faithweb.com. I
recognized this as an attempt to utilize my prominence in this market to enhance his own
stature.
388. On or about October 6, 2001, Henderson contacted me via email and offered to assist
with getting my book published. This offer was unsolicited. I recognized this as an
attempt to enhance his stature by obligating me to him.
389. On or about January 7, 2002, Henderson sent me an unsolicited email requesting my
advice about contacting an FBI web site for civil rights violations, which I provided.
390. On or about January 22, 2002, Henderson sent me an unsolicited email requesting my
participation in forming a national organization which he called AFRA. He continued to
discuss this in subsequent emails and diligently attempted to sell me on the idea of this
organization. I recognized this as an attempt to enhance the stature and credibility of this

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organization through my affiliation with it. I initially did join as a member of AFRA,
trusting he would deliver on his promises.
391. On or about July 18, 2002, Henderson contacted me with an unsolicited email requesting
information about a television producer who had contacted me seeking guests for a
television program. He wanted to use this program as a forum to advertise AFRA. I
recognized this as an attempt to enhance AFRA’s stature based on my contacts and work.
392. On or about September 16, 2002, Henderson requested I write an article about a
Wisconsin case that I had participated in for the AFRA web site.
393. In approximately mid-2002, Henderson contacted me via telephone requesting me to
establish and run an underground railroad for parents who were fleeing from state child
welfare agencies and who needed safe houses. I recognized this as an attempt to get me to
subordinate my dominance in this market to AFRA and as a potential setup for trouble. I
declined.
394. On or about November 29, 2002, Henderson sent me an unsolicited email making
inappropriate personal comments about me and stated his desire to have a photograph of
me. This tactic of personal flattery and gratuitous ego stroking was another tactic
routinely employed by Henderson in his ongoing attempts to convince me to subordinate
my business, my properties and my work to him and AFRA. I was very uncomfortable
with his attempts to get too personal, insulted by the shallow flattery, and repeatedly
asked him to keep it professional.
395. Throughout the entire year of 2002, Henderson personally sent me dozens, if not
hundreds of emails soliciting my participation and input on behalf of AFRA to enhance
AFRA functions and expand the information AFRA disseminated.
396. On or about February 24, 2003, Henderson forwarded a series of emails to me seeking my
assistance for defendant Blair, who had been raided in Michigan for sending threatening
content from the AFRA web site to the Family Independence Agency (FIA) director and

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three employees.
397. On or about April 17, 2003, Henderson sent me an unsolicited private email announcing
his CPS case was closed. This would indicate it took four years for his case to be
resolved.
398. On or about May 7, 2004, Henderson sent me a donation of $100 to be used on behalf of
Colorado AFRA member A.F.
399. On May 15, 2004, in response to Henderson’s increasing encroachments and his publicly
hostile position toward me and his utter refusal to stop exerting inappropriate control over
my business and property, I withdrew my membership from AFRA.
400. Henderson was advertised as an advocate on AFRA CenCom’s state advocates list on or
about June 30, 2004.
401. On or about August 16, 2004, on Directors, Henderson stated that Tower has secured
both copyright and trademark for American Family Rights Association. Names cannot be
copyrighted, and a search of the U.S. and state trademark registrations reveals no such
trademark.
402. On or about November 7, 2004, AFRA advertised for court watchers to attend my trial in
Colorado. Several AFRA members did show up for my trial at a later date. AFRA also
contacted Colorado media about this case.
403. On or about December 11, 2004, Henderson was contacted by the BBC for copyright
infringement. They demanded he remove their content from the AFRA web site.
Henderson’s response included,
“Our position is - AFRA is education and we believe that compiling educational
material so people can find it is highly important. What good is information
that people are unlikely to find?” He subsequently reported to the BOD on
Directors, “So I really jerked this snotty bitches chain and maybe she will trot
over to the BBC ‘legal department’ full of the queen’s barristers and throw a
little snit.”
404. Between the end of January and February 4, 2004, Henderson published AFRA member

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C. Korn’s advertisements on AFRA groups for the seminar she was sponsoring in
Colorado.
405. On or about March 13, 2005, Colorado AFRA member Ms. Korn published on CenCom
that the Florida seminar was a huge success. A press release was also published on AFRA
and non-AFRA groups about the success of that seminar.
406. On or about September 24, 2005, Henderson emailed me denying his authorship of a
document entitled Declaration of Facts, but admitting authorship of the sample
affidavits, grievance letter and Evidence and Statements.
407. On or about September 25, 2006, Henderson joined the Improvement Project, my
Colorado-based, interactive consumer advisory publication, and contributed to it.
408. On or about October 12, 2009, Henderson was hired as a contributor to Examiner.com,
located at 555 17th St. Ste. 400, Denver, CO 80202. He has written thirty-four articles as a
“Family Rights Examiner” for Examiner.com representing AFRA.
Defendant Susan Adams Jackson aka Susan Wolverton
409. Susan Adams Jackson aka Susan Wolverton (Jackson), an individual domiciled at 40
Orlando Ave. #1A, Winthrop, MA, 02152, and agent and member and Board of Director
member of AFRA, and member/moderator of JFF (Justice for Families, an AFRA
affiliate). Jackson was given oversight and control over the interactive online AFRA
groups on or about April 8, 2006. Prior to that, she was a moderator of most AFRA
groups. As a moderator, she had the express authority and ability to moderate and control
all information disseminated and stored on all AFRA interactive groups. Agent of AFRA.
410. Jackson had two state interventions for child abuse and neglect in Massachusetts,
involving a child adopted from a foreign country. People who have been in her home
since these two cases have reported that this child remains locked in her room, and is not
permitted to interact with the family, even taking meals in her room. Jackson alludes to
this child being a problem, due to being adopted.

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411. Jackson is a principle actor and co-conspirator to the claims raised in this complaint. At
all times relevant to this complaint Jackson expressly conspired with AFRA, Henderson,
Henderson, Hinger, W. Tower and other defendants, using AFRA and non-AFRA
interactive online groups to express her support for them and to demonstrate her willing
participation in and instigation of the tortious acts against me. As AFRA executive officer
and groups moderator, she allowed AFRA properties and groups to be use as vehicles for
the planning, solicitation and commission of the tortious acts described in this complaint.
412. Jackson’s operations of multiple fully interactive web sites, her personal participation via
those web sites and groups, her position as officer of AFRA amd moderator of AFRA
fully interactive online groups, coupled with her numerous other activities directed at the
state of Colorado and derived from Colorado supply sufficient grounds to exercise
personal jurisdiction over this defendant.
413. On or about February 28, 2000, Jackson contacted me via email and offered her services
to me for to transcribe audio tapes into transcripts and other volunteer services I might
need. She provided identifying information sufficient for me to perform a background
check that I required of volunteers. She stated she was using her “professional name” to
protect her anonymity online and provided me with her real name. I respected her
confidentiality in this regard, even after she participated in violating my online anonymity
by revealing my maiden and former married name to the world. See ¶ 473.
414. On or about October 20, 2000, Jackson sent me a private email in response to a post on a
non-AFRA interactive group, offering me information and resources for a child with
medical problems.
415. On our about July 2, 2001, in response to a post on a non-AFRA Yahoo! group, Jackson
contacted me directly via email and promised to send money for the legal defense of a
parent whose story was described on that group.

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416. On or about June 11, 2004, Jackson, on Directors, described AFRA BOD as, “AFRA
policy-makers cum enforcers. . .” .
417. On or shortly after August 29, 2004 Jackson participated in an AFRA campaign to write
letters to Hon. Charles M. Barton (11th Judicial District, Colorado) by submitting a letter
to him in an effort to influence the case of a Colorado AFRA member.
418. On or about April 8, 2006, Jackson was appointed as AFRA BOD member overseeing all
AFRA online interactive groups.
419. On or about November 26, 2006, Jackson assumed the role of Vice President of AFRA.
She was given oversight over sixty-five AFRA groups. At all times, Jackson was a
moderator with the authority and discretion to permit or prohibit content, topics and
participants.
420. During the time frame of this complaint, Jackson exercised control over tens of thousands
of messages transmitted via the AFRA interactive online groups. The content of these
messages included content directed to numerous AFRA group members who reside in
Colorado, and included content derived from Colorado to be disseminated for the benefit
of the users and members of AFRA groups.
421. Some of this content consisted of infringement of my IP and communications intended to
support, further and execute the conspiracy.
422. During the time frame of this complaint, Jackson accessed and/or requested and received
extensive content via AFRA interactive online groups from Colorado about me, including
but not limited to information from Colorado state and county public records, Colorado
newspapers, Colorado state and local agencies, and including my copyrighted and
proprietary IP, all of which constitutes information derived from Colorado.
423. During the time frame of this complaint, Jackson also requested and/or received and
disseminated the above content derived from Colorado about me via private

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communications with the other defendants and other AFRA and CPS Watch members
about me.
424. This content was used by Jackson to conspire and to execute tortious acts directed at me
and my business and property in Colorado, as described in this complaint.
Defendant Cletus Kiefer
425. Cletus Kiefer (Kiefer), an individual domiciled at 292 East Ave. Ste 114, St. Louis, MO
63117 . Kiefer is an agent, member and Board of Director member of AFRA, and
President of Families at Risk Defense Alliance (FAR).
426. Kiefer is the person who introduced Wiseman, a vulnerable adult (¶532), to the
conspiracy, and has exploited Wiseman’s disability ruthlessly in the furtherance of the
conspiracy. Kiefer was the original contact between Wiseman and the other co-
conspirators/defendants. Kiefer colluded with and enticed Wiseman dba Wiseman
Studios to publish thetruthistold[dot]com, which is described as an anti-Suzanne Shell
web site and to commit many of the tortious acts which gave rise to this lawsuit.
427. Keifer reports he had a founded child abuse and neglect case in Missouri. His oldest child
was permanently removed from his home, and did not return until she aged out of foster
care at age eighteen. He has routinely advised parents to not comply with court ordered
case plans, and their parental right are consequently terminated.
428. Kiefer is a principle actor and co-conspirator to the claims raised in this complaint. At all
times relevant to this complaint Kiefer expressly conspired with AFRA, Henderson,
Jackson, W. Tower, Hinger and other defendants, using AFRA and non-AFRA interactive
online groups to express his support for them and to demonstrate his willing participation
in and instigation of the tortious acts against me. As AFRA executive officer and groups
moderator, he also allowed AFRA properties and groups to be use as vehicles for the
planning, solicitation and commission of the tortious acts described in this complaint.

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429. Kiefer’s operations of multiple fully interactive web sites, his personal participation via
those web sites and groups, his position as officer of AFRA amd moderator of AFRA
fully interactive online groups, coupled with his numerous other activities directed at the
state of Colorado and derived from Colorado supply sufficient grounds to exercise
general personal jurisdiction over this defendant.
430. On or about November 27, 2004, Kiefer solicited on CenCom and other groups, including
me and other Colorado members, for individuals nationwide to become advocates for his
organization Families at Risk Defense Alliance.
431. On or before March 15, 2006, using AFRA groups, Kiefer requested attendees to my
seminars–including from seminars presented in Colorado–to provide him with the
information they received at my seminar so he could put it on CD and market it.
432. On or about June 9, 2006, Keifer joined my Improvement Project group, which is
centered in Colorado, and became a contributor to that publication.
433. Kiefer’s 123people account lists Wiseman’s web site thetruthistold[dot]com.
434. Kiefer has masterfully manipulated Wiseman to perform Kiefer’s deeds and make it
appear as if Kiefer’s hands are clean.
Defendant Francine Renee Cygan
435. Francine Renee Cygan (R. Cygan), an individual with a last known address at 329 Cornell
Ave., Apt. D, Villa Park, IL, 60181, and board member of National Association of Family
Advocates, (NAFA) and founder and board member of Illinois Family Advocacy
Coalition (IFAC), and agent and member of AFRA and/or AFRA owned online groups.
In 2003, she owned a Yahoo! group Parents Against the System (PATS) and a
corresponding web site at http://illinoispats.tripod.com/parentsagainstthesystem/id1.html.
436. R. Cygan has had all of her children removed from her custody throughout her life. She is
severely mentally ill and supposed to be on medications, but doesn’t take them. She was

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reportedly severely physically abusive to at least one child, and emotionally abusive to all
children. Parental rights to two of her children have been terminated. The other two, she
is ordered not to have contact and are in the custody of their respective fathers. In spite of
the no-contact orders by the court, R.Cygan has stalked the adoptive families and
custodial parents of her children, locating the children and illicitly contacting them,
causing severe problems in their family homes. She filed a false restraining order against
the father of one child and absconded with the child of whom the father had custody,
taking the child from Illinois to Florida, and concealing his whereabouts from his father.
This child has been severely emotionally damaged as a result of his lengthy stay with her
and his relationship with his father is destroyed. She did not put the child in school, and
kept him in filthy homes littered with dog feces. She has falsely accused the father of the
kidnapped child of being abusive during her tenure with the defendants, but an
examination of the court records reveals this is a recent ploy that was never raised until
around 2005. Reports from multiple sources indicate she spends all night on the computer
or engaged in marathon telephone sessions with defendant Baez and others, her house is
unfit for habitation due to her many dogs, and she has a violent and uncontrollable
temper.
437. R. Cygan is a principle actor and co-conspirator to the claims raised in this complaint. At
all times relevant to this complaint R. Cygan expressly conspired with AFRA and other
defendants, using AFRA and non-AFRA interactive online groups to express her support
for them and to demonstrate her willing participation in and instigation of the tortious
acts against me. She used AFRA properties and groups to be as vehicles for the planning,
solicitation and execution of the tortious acts described in this complaint with the full
cooperation of AFRA.
438. R. Cygan’s’ operations of a fully interactive web site, her personal participation via the

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defendants’s web sites and groups, her position as a member of AFRA and officer of
IFAC and NAFA, coupled with her numerous other activities directed at the state of
Colorado and derived from Colorado supply sufficient grounds to exercise personal
jurisdiction over this defendant.
439. In about August, 2003, R. Cygan provided a safe house in the underground railroad to
T.M. T.M reported that R. Cygan was abusive to her and her children, stole her property
including her case files, her children’s clothes and toys and thousands of dollars of
licensed software and computer equipment.
440. R. Cygan also stole the money that had been donated to T.M., and dumped her and her
children on the side of the road with nothing. I received this complaint about R. Cygan
from T.M and participated in efforts to recover the stolen property, but we were
unsuccessful.
441. T.M reported that R. Cygan was engaged in welfare fraud, claiming children she didn’t
have custody of and receiving food stamps under different identities.
442. T.M. also reported R. Cygan bragged about not paying her rent or mortgage, and that she
put illegal plates on her van because she had not made payments on it and took it out of
Illinois to avoid repossession.
443. Cygan admitted she was fired from WalMart for assaulting a co-worker and claimed to be
and exotic dancer and “high-class ‘ho’(whore).”
444. T.M. reported that R. Cygan conned parents out of money to write legal pleadings for
them.
445. She has also made multiple attempt to have parents sign guardianship of their children
over to her fraudulently representing that doing so would protect them from CPS.
446. She reportedly abused her own children and lost all rights to them, and abuses and
neglects her animals.

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447. I had been contacted by T.M.’s attorney prior to this, seeking my assistance on her
situation. I had all the information from this attorney. T.M.’s children were not under
investigation for child abuse nor under any court’s jurisdiction in her home state of Utah,
there was no warrant for T.M. He advised her to move for reasons unrelated to any Utah
child welfare issue. After this single consultation, I did not hear from the attorney again
regarding this situation, and did not know what happened to T.M. until I learned she was
staying with R. Cygan.
448. On or about December 24, 2003, R. Cygan sent out a message to online groups that she
had recently woken up on the bathroom floor one day and didn’t know who she was. She
had amnesia. But she read all her emails and discovered she was an advocate!
449. On or about March 1, 2005, R. Cygan published a defamatory web site entitled “Meet
Suzanne Shell,” at http://meet-suzanne-shell.tripod.com/index.html. See ¶ 1393
450. Cygan is one of Wiseman’s ghost writers for thetruthhistold[dot]com and other locations.
She also manipulates him and exploits his vulnerability so as to appear distanced from the
conspiracy and the tortious acts committed by him at her instruction.
451. On this site, R. Cygan maliciously published the photographs and names of T.M.’s
children, and urged anyone who saw them to turn them in to law enforcement, claiming
they were fugitives from the law.
452. On or about August 17, 2003, R. Cygan began representing herself as “Reverend” Renee
Cygan.
453. See R.Cygan’s relationship to IFAC (¶ 463) and NAFA (¶ 484).
454. Starting on or about December 19, 2006, R. Cygan participated in an online discussion
which occurred at coloradoconfidential.com/showDiary.do?dirayId=1179#17064, a
Colorado based news/blog site discussing Colorado legal issues. This discussion was
about me, wherein she published false and defamatory commentary about my profession,

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my business and my products.

Defendant Mark Cygan
455. Mark Cygan (M. Cygan), an individual domiciled 329 Cornell Ave., Apt. D, Villa Park,
IL, 60181, and board member of National Association of Family Advocates, (NAFA) and
founder and board member of Illinois Family Advocacy Coalition (IFAC), and agent and
member of AFRA and/or AFRA owned online groups.
456. M. Cygan is the husband of R. Cygan. He facilitated her kidnapping of the child from the
custodial father, and assisted with concealing him from his father.
457. M. Cygan is a principle actor and co-conspirator to the claims raised in this complaint. At
all times relevant to this complaint M. Cygan conspired with other defendants, using
AFRA and non-AFRA interactive online groups to express his support for them and to
demonstrate his willing participation in and instigation of the tortious acts against me. He
used AFRA properties and groups to be use as vehicles for the planning, solicitation and
commission of the tortious acts described in this complaint with the full cooperation of
AFRA.R.
458. M. Cygan’s’ operations of a fully interactive web site, his personal participation via the
defendants’s web sites and groups, his position as a member of AFRA and officer of
IFAC, coupled with his numerous other activities directed at the state of Colorado and
derived from Colorado supply sufficient grounds to exercise general personal jurisdiction
over this defendant.
459. On or about April 20, 2006, M. Cygan published on CenCom that he had seen my
proprietary seminar handout that was protected under a non-disclosure agreement. See ¶
1529
460. On or about May 22, 2006, M. Cygan joined my Improvement Project group. His first
post to the group was on May 23. He stated IFAC runs a school to educate advocates.

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461. Starting on or about December 19, 2006, M. Cygan joined and participated in an online
discussion which occurred at
coloradoconfidential.com/showDiary.do?dirayId=1179#17064, a Colorado based
news/blog site discussing Colorado legal issues. This discussion was about me, wherein
he published false and defamatory commentary about me.
462. There is some indication that Renee Cygan, having been shunned my most for her
irrational conduct, impersonated her husband, Mark, and that she was the one responsible
for the acts committed in his name. However, not being fully informed on that matter, and
in view of the fact that the other conspirators’s insistence that Renee did not impersonate
Mark, I am proceeding as if Mark Cygan committed the tortious acts attributed to him.
Defendant Illinois Family Advocacy Coalition
463. Illinois Family Advocacy Coalition (IFAC), a business entity advertised as “Training
Advocates and Empowering parents to fight for themselves.” It was founded on or about
April 16, 2006 by Renee Cygan.
464. IFAC is a principle actor and co-conspirator to the claims raised in this complaint. It is
the vehicle by which Cygans and Baez used and disseminated my proprietary methods
without my permission or license.
465. IFAC is not listed with the Secretary of State of Illinois.
Defendant Dorothy Kernaghan-Baez
466. Dorothy Kernaghan-Baez (Baez),an individual domiciled at 2208 Highland Avenue, Suite
107, Augusta, Georgia, 30904. Baez is founder and Board member of National
Association of Family Advocates, (NAFA) and board member of Illinois Family
Advocacy Coalition (IFAC), owner of Georgia Family Rights, Inc. (GAFR),
cpsabuse.org, and agent and member of AFRA and/or AFRA owned online groups and
moderator of a number of online groups.

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467. Baez is listed on the AFRA web site as AFRA’s Investigations Chief.
468. Baez has repeatedly been accused of and investigated for child abuse and neglect. She
reports she was once substantiated for neglect relating to her children’s nutrition.
469. On or about August 4, 2003, Baez contacted me about R. Cygan’s article on the
Consumer Advisory page asking me to remove the article from my publication.
470. Baez has introduced herself as, “I'm a radical feminist, pro-life Anglican, bleach blond
failed Southern belle, chain smoking, gin and tonic drinking complete nut and am
married to a lapsed Catholic Puerto Rican.” As a self-professed feminist, Baez never
became a target of Henderson’s misogyny.

471. On or about March 25, 2006, on CenCom, Baez requested case specific research
assistance relating to the Americans With Disabilities Act and suing a court appointed
attorney, indicating she did not possess the knowledge to address this problem in the
context of a child welfare case. My proprietary methods do include strategies on this
issue.
472. On or about April 16, 2006, Baez advertised on AFRA_CenCom that Illinois Family
Advocacy Coalition (IFAC) was a member organization of the National Association of
Family Advocates (NAFA). She advertised that they planned training in person and
online and requested to confer with AFRA about the training.
473. Baez has proudly admitted on the interactive online groups that she is the one responsible
for obtaining my maiden and former married name and providing it to the other
defendants around May, 2006. She stated on CPS Watch online group that she obtained
my prior married name from vital records in El Paso County, Colorado, where I was
married. She provided my marriage record to CPS Watch members, Barnes, Thompson
and Howard, as well as other defendants on that group. Using this information, the
defendants expanded the scope of their abuse, stalking and harassment to include my

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father and my children. Defendants actually attempted to personally contact my family

members and elicit information from them without identifying themselves.
474. Baez is a principle actor and co-conspirator to the claims raised in this complaint. At all
times relevant to this complaint Baez expressly conspired with AFRA, Henderson,
Jackson, W. Tower, Hinger, CPS Watch defendants, and other defendants, using AFRA,
CPS Watch and non-affiliated interactive online groups to express her support for them
and to demonstrate her willing participation in and instigation of the tortious acts against
me. She used AFRA and CPS Watch properties and groups to be use as vehicles for the
planning, solicitation and commission of the tortious acts described in this complaint with
the full cooperation of AFRA. She is a member and participant of interactive online
groups belonging to defendants.
475. Baez is an agent of AFRA and of GAFRA and a member of CPS Watch.
476. As a user of AFRA and CPS Watch groups, Baez sent and received hundreds of messages
to and from Colorado users over the years.
477. Baez vandalized my Wikipedia entry to usurp my publicity on behalf of AFRA and
Wiseman’s web site.
478. Baez was advertised as an advocate on AFRA CenCom’s state advocates list on or about
June 30, 2004, with an address, phone number and email address identical to GAFRA’s.
Defendant Georgia Family Rights, Inc.
479. Georgia Family Rights, Inc. (GAFR) is a Georgia non-profit corporation whose registered
agent and incorporator is Dorothy Kernaghan-Baez, 2906 Professional Parkway, Suite
107, Augusta, GA 30907. Baez represents her conduct online as acting in the capacity of
GAFR. It was created on February 5, 2007.
480. GAFRA was involuntarily or administratively dissolved by the Georgia Secretary of State
on September 13, 2010, for failure to file its annual registration. According to GA SOS

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records, GAFRA never filed an annual registration once is was incorporated.

481. GAFRA is a principle actor and co-conspirator to the claims raised in this complaint. At
all times relevant to this complaint Baez’s conduct was inextricably intertwined with
Georgia Family Rights, Inc. Baez and GAFR expressly conspired with AFRA,
Henderson, Jackson, W. Tower and other defendants, using AFRA, CPS Watch and non-
affiliated interactive online groups to express her support for them and to demonstrate her
willing participation in and instigation of the tortious acts against me. As leader of
Georgia AFRA state group and groups moderator, she also allowed AFRA properties and
groups to be use as vehicles for the planning, solicitation and commission of the tortious
acts described in this complaint with the full cooperation of AFRA.
482. Baez’s acts are inextricably intertwined with GAFRA, to the point where it is impossible
to separate her personal conduct from GAFRA conduct.
483. GAFRA was advertised on AFRA CenCom’s state advocates list on or about June 30,
2004, with an address, phone number and email address identical to Baez’s.
Defendant National Association of Family Advocates
484. The National Association of Family Advocates (NAFA), 2208 Highland Avenue, Suite
107, Augusta, Georgia, 30904. A business entity founded by Baez, advertised as “a
professional membership organization founded to serve Family Advocates” consisting of
a Board of Directors and general membership offered to anyone in the 50 states.
485. NAFA is a principle actor and co-conspirator to the claims raised in this complaint. At all
times relevant to this complaint NAFA expressly conspired with AFRA, GAFRA and
other defendants, using AFRA and non-AFRA interactive online groups to express its
support for them and to demonstrate its willing participation in and instigation of the
tortious acts against me. NAFA used AFRA properties and groups to be use as vehicles
for the planning, solicitation and commission of the tortious acts described in this

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complaint with the full cooperation of AFRA.

486. On or about April 16, 2006, Baez wrote on CenCom,
“IFAC is a member organization of the National Association of Family
Advocates. The founding members are still in the process of writing up
guidelines.....also, each member organization might have its own specific
requirements. IFAC, as I understand it, offers their training in person, but one
of the goals of NAFA is to offer various classes as "webinars" so that anyone
may benefit.
Maybe we can do a quick conference call later this week? I'd love to
talk with you about this - it's been sort of a dream of mine to do this and have
a way for those who have been "in the trenches" to teach courses in their
specific area of expertise.”
Defendant Aimee Dutkeiwicz

487. Aimee Dutkiewicz, aka Alyn Dutkiewicz aka Amie Dutkiewicz aka Aimee Lyn Wright
Dutkiewicz, (A. Dutkiewicz), an individual domiciled at 18 Benham St. with a mailing
address at P.O. Box 3022, Bristol, CT 06011-3022, former agent and member of AFRA
beginning in 2003. Owner of New England Parent Advocacy Network (NEPAN).
NEPAN’s web site is/was at http://www.geocities.com/nepan2003ad/ . During the time
frame of this complaint, NEPAN also owned and operated a fully interactive group of the
same name on Yahoo!
488. A. Dutkiewicz never had her children removed, but she was investigated for a report of
child abuse or neglect, along with her husband. Dutkiewicz’s permitted the caseworker
entry into the family home, then sued for fourth amendment violations. She has a history
of disputes with everyone, everywhere. She is always the histrionic victim and a
pathological liar. She stalks, harasses, and threatens her targets with frightening
obsession. She will commit wrongful acts against them, taunting them with screaming
abuses, making outrageous demands as redress for her imagined injuries, while insisting
they don’t contact her back. She then proceeds to publish her victimhood all over the
Internet in an effort to seek public sympathy and vindication. She sued a therapist, lying

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about the claims against her, and when the therapist came one time to deliver a payment
pursuant to the court order, A. Dutkiewicz made a complaint to the police against the
therapist for stalking and harassing. This pattern is repeated in her conduct towards me, as
evidenced by her multiple specious and false reports against me described in this
complaint, and by making a false criminal report against my process server. I had
instructed the process server to video tape the service of the summons and complaint in
anticipation of her false report. The video tape proved to the Bristol police that the
process server did not assault A. Dutkiewicz’s child and did not break and enter as
alleged by A. Dutkiewicz. In another instance, police reports reveal A. Dutkiewicz stole a
BBQ grill from a neighbor, and when the police showed up to charge her, she denied the
theft but went right out and bought a new grill for the neighbor. Another police report
reveals A. Dutkiewicz’s client (A. Dutkiewicz claims she was her advocate), Ms. DeJesus
cursed at her and threatened her with bodily harm if A. Dutkiewicz came anywhere near
her or her court case. She has been repeatedly evicted for non-payment of rent, and
portrays it to everyone as having to move to avoid her ever-present stalkers. She reports
she’s been fired, and blames the victims for her misuse of company property to commit
tortious acts against her victim. She’s sued a private corporation under the whistle blower
act, and naturally lost. I have been the target of her insane obsession since 2003. A.
Dutkiewicz’s pathology has proven to be implacable. If you ignore her or just try to walk
away from her, it incites her to escalate until ignoring her is too damaging for you. If you
exclude her, she escalates against you for daring to consider her antics to be beneath you,
and targeting others who you care about. If you confront her, she escalates into
irrationality, with a gleeful hysteria that she managed to engage you. If you chastise her
victim, even if you chastise her at the same time, she sees it as a victory and brags about
how right she was and how abused she is and escalates to insure her victim gets chastised

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again so she can claim total victory. If you expose her pathology, she rages against you,
escalating and publishing bizarre, transparent lies to discredit you. If she loses, she gets
suicidal so she can be the victim, blaming you to obtain sympathy and support. She does
not respond reasonably to silence, nor to reason, nor to threats, nor to authority. It is
terrifying to be targeted by her, and by those she incites into gang participation due to her
irrational fixations.
489. A. Dutkiewicz is a former AFRA Connecticut Director according to her signature line in
2004. This has never been disputed by AFRA.
490. NEPAN is or was a fully interactive online group for the purposes of offering support,
advocacy and information services to child welfare consumers in New England and and
to advertise A. Dutkiewicz’s NEPAN organization. It was created on or about March, 3,
2003. Jackson was a moderator of that group. I was a member of NEPAN Yahoo! group
from December 2003 until it was disbanded. Baez and Henderson and other AFRA
leaders were also a members of that group.
491. A. Dutkiewicz is a principle actor and co-conspirator to the claims raised in this
complaint.
492. She is or was a member of all the defendants’s interactive online groups.
493. She has advertised herself as a family advocate on multiple public fora.
494. At all times relevant to this complaint A. Dutkiewicz expressly conspired with AFRA, T.
Dutkiewicz, Henderson, Jackson, W. Tower and other defendants, using AFRA and non-
AFRA interactive online groups to express her support for them and to demonstrate her
willing participation in and instigation of the tortious acts against me. She used AFRA
properties and groups to as vehicles for the planning, solicitation and commission of the
conspiracy and tortious acts described in this complaint, with the full cooperation of
AFRA. She is or was a member and participant of interactive online groups belonging to

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defendants.
495. A. Dutkiewicz is or was a member of CPS Watch Yahoo! group.
496. AFRA provided advertising to A. Dutkiewicz on the AFRA web site, which advertised
the book, “Child Protective Services and the Juvenile Justice System: A guide to protect
the rights of both parents and children, Written by Thomas Dutkiewicz and Aimee
Dutkiewicz, New England Parent Advocacy Network.” AFRA also allowed AFRA
groups to be used over the years to advertise this and other products on behalf of the
defendants.
497. On or about April 4, 2003. A. Dutkiewicz contacted me via email and requested to
receive or purchase a copy of my 22 page seminar handout. I declined to provide it to her,
stating that she had to attend the seminar in order to obtain it. I already knew she had a
tendency to plagiarize my work. This denial proved sufficient to spark her obsessive
vendetta against me.
498. On or about December 26, 2003, A. Dutkiewicz sent me an unsolicited email demanding
that I leave her alone, and stating she would “burn my book with glee.” I had never
contacted her. However, this is an admission that she had my book as of 2003, despite
subsequent denials by her and T. Dutkiewicz of ever having seen my book.
499. On or about December 29, 2003, A. Dutkiewicz sent me an unsolicited email telling me
to have my lawyer contact her lawyer. I had still never contacted her.
500. On or about May 18, 2004, Dutkiewicz’s son, Ben, sent me an abusive, profane and
threatening email.
501. On or about May 29, 2004, A. Dutkiewicz advertised on all AFRA groups with the
subject “Did profane-justice redesign their site?,” “Has anyone seen the newly designed
site called www.profane-justice[dot]com? What is all about?” Many consumers stated
they were confused as to whether or not this was my site. My site was [dot]org. The

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defendant deliberately intended to confuse the market by advertising the [dot]com as

mine to send consumers to a site she and T. Dutkiewicz caused to be populated with
defamatory and false content about me, my business, my profession and my products.
502. On or about January 19, 2006, A. Dutkiewicz revealed she has spoken with Rocco
Meconi, Fremont County, Colorado, County Attorney representing DHS, and who has
filed multiple Unauthorized Practice of Law complaints against me17 and who has
engaged in other wrongful efforts to destroy my business18. Her discussion with him was
about me, and she was seeking information and alliances against me. He admitted that he
told her I was a very dangerous person. The Dutkiewicz’s have emulated his tactic of
making UPL complaints against me to the Colorado Supreme Court Attorney Regulation
Counsel, Unauthorized Practice of Law (UPL) Committee, all of which were
unsuccessful.
503. On February 10, 2006, A. Dutkiewicz, on CP_Prosecutions interactive online Yahoo!
group, A. Dutkiewicz revealed she has spoken with Rocco Meconi several times about
me, and how much he and Hon. Judge Julie Marshal hate me.
504. I caused another person to call Mr. Meconi and pose as another adversary of mine. I was
on the phone when the calls were made, and Mr. Meconi confirmed his conversation(s)
with A. Dutkiewicz as well as confirming the information that was exchanged.
505. On or about March 30, 2006, A. Dutkiewicz made a complaint to my Internet Service
Provider (ISP), EarthLink, about a cease and desist harassing email I sent to her,
17
He has. One was prosecuted, the others were not pursued.
18
Including but not limited to telling (or causing or conspiring for them to be told) child
welfare clients in Fremont and Pueblo counties, Colorado, not to attend a Pueblo seminar where I
was scheduled to speak and for which I had obtained CLE accreditation, and threatened they
would never have their children returned if they did attend. Attorneys were similarly threatened
not to attend or they would face complaints with the Attorney Regulation Counsel.

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demanding my web site be shut down. This was the first communication I had made to
her since declining to send her my seminar handout. I received a warning from EarthLink,
that included a threat to shut my service down. EarthLink received a subsequent
complaint against me a day later from the defendant, regarding my post to an online
group of which A. Dutkiewicz was a member, and gave me second warning and
threatened a $250 penalty for shutting down my service. A. Dutkiewicz made a third
complaint, which I had to appeal all the way to the legal department before it was
resolved.
506. On or about March 29, 2006, A. Dutkiewicz filed a criminal harassment complaint
against me in Connecticut for a single cease and desist email I had sent her. I was
contacted by Bristol police as part of the investigation into the complaint. No charges
were filed.
507. On March 29, 2006, A. Dutkiewicz made a second false report to the police, and to my
county sheriff, about me alleging I made a death threat. The police investigated and
determined the report was unfounded. She published to cp_prosecutions,
“TODAY I FIND A THREAT IN MY EMAIL SO I SPENT THE DAY WITH LOCAL
POLICE, EL PASO COUNTY POLICE ON CONFERENCE WITH MY LOCAL POLICE
AND THE FBI.... I TAKE THIS SERIOUS AND EVERY ONE OF YOUR NAMES
WERE GIVEN TO THE AUTHORITIES/”
508. On or about April 15, 2006, A. Dutkeiwicz sent me a self-destructing email, with the
subject line “You IDIOT” using bigstring.com. The return email address was
“gotyanow”. This email contained threats about me spending time in prison, and
contained harassing and false and libelous comments about things she accused me of
doing, and a specific quote that my family was not off limits. This was very alarming.
509. On April 6, 2006, A. Dutkeiwicz called my ISP, EarthLlink,, and represented that she was
speaking on my behalf and cancelled my web site and Internet service. I discovered this

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when I tried to access the Internet on April 30 and could not log in. My email and web
site was gone. EarthLink advised me that “Aimee” had cancelled the service.
510. On or about June 17, 2006 A. Dutkiewicz joined my Improvement Project group under an
alias, using her daughter’s name and placing her in Illinois where R.Cygan was. She
submitted a forged copy of a drivers license as proof of identity, using her daughter’s
photo. She stated in her introduction that she was working with R. Cygan and proceeded
to post profane and abusive attacks.
511. A. Dutkiewicz is a contributor and ghost writer to thetruthhistold[dot]com authoring false
and defamatory content about my profession, my business and my products, using
information derived from Colorado.
512. On or about March 27, 2010, A. Dutkiewicz sent me a handwritten letter purported to be
an apology for “engaging [me] and [my] goomba’s.”
513. In the same time frame, she hand wrote an apology letter to Effie Belou. In this letter she
admitted to authoring content on Wiseman’s thetruthhistold[dot]com site. She accused
Effie and me and our associates of being responsible for the suicides of Michelle Bassette
and Paula Mackintosh. This is one of the false advertisement on thetruthhistold[dot]com.
514. On or about March 25, 2010, A. Dutkiewicz hand wrote an apology letter to Kay Henson,
wherein she admitted calling EarthLink to get my Internet service shut down.
Defendant Thomas Dutkeiwicz
515. Thomas Dutkiewicz (T. Dutkiewicz), an individual domiciled at 40 Central, Bristol, CT
06010, with a mailing address of PO Box 3005, Bristol, CT, 06011, founder and owner of
Connecticut DCF Watch. He has been a member and agent of AFRA since 2003.
516. T. Dutkiewicz is a principle actor and co-conspirator to the claims raised in this
complaint. At all times relevant to this complaint T. Dutkiewicz expressly conspired with
AFRA, Henderson, Jackson, W. Tower, A. Dutkiewicz and other defendants, using

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AFRA and non-AFRA interactive online groups to express his support for them and to
demonstrate his willing participation in and instigation of the tortious acts against me. He
used AFRA properties and groups to be as vehicles for the planning, solicitation and
commission of the tortious acts described in this complaint. He is or was a member and
participant of interactive online groups belonging to defendants.
517. AFRA provided advertising to T. Dutkiewicz on the AFRA web site, which advertised
the book, “Child Protective Services and the Juvenile Justice System: A guide to protect
the rights of both parents and children, Written by Thomas Dutkiewicz and Aimee
Dutkiewicz, New England Parent Advocacy Network.” AFRA also allowed AFRA
groups to be used over the years to advertise this and other products on behalf of the
Dutkiewicz defendants.
518. On or about May 2, 2004, T. Dutkiewicz took a private cease and desist communication
from me and published on CenCom with his false comments,
“I have no idea what your work is. The information comes from case law and
from our federal lawsuit. I have never read your work or know where to find
it. So please explain exactly what is yours.” The information he was
disseminating was a condensation of portions of my book, Profane Justice. In
response to another member he falsely advertised, “There is no mud slinging
going on. Everything was going alright until Ms. Shell started false allegations
of coping [sic] her work. Everybody was minding their own business and then
Ms. Shell thinks I can not have freedom of expression. She thinks I copied her
work when the truth is I have never read her work.”
He and his wife admit to having my book on other occasions, described herein. A.
Dutkiewicz also admitted the book was copied from my work.
519. On or about May 18, 2004, T. Dutkiewicz copied and posted verbatim content from my
web site Consumer Advisory article about A. Dutkiewicz, and irrationally accused me of
“harassment, slandering and outright defamation of character.” He again denied
reading anything of mine and accused me of having “serious issues in my past which

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remain unresolved.”
520. I received a form cease and desist letter from an attorney Lord with pre-paid legal on
behalf of the Dutkiewicz’s. When I responded asking if she was representing the
Dutkiewicz’s in this matter, she advised me to speak with A. Dutkiewicz directly. I
concluded she was not representing A. Dutkiewicz. Nothing ever resulted from this
communication, but the Dutkiewicz’s published claims on the AFRA groups that I had
been successfully muzzled.
521. T. Dutkiewicz was featured on television on or about September, 2005, and his
organization, Connecticut DCF Watch, has been reported in the Hartford Courant.
522. On or about January, 2006, T. Dutkiewicz did, at his own initiative, call Sonia G. Flores,
Sales Manager at the Sheraton Bradley Airport Hotel Hartford, Connecticut ,urging her
not to allow my facilitation of a certification class to take place in the hotel because I was
a dangerous person who would harm the reputation of the hotel if she were to allow it to
happen. This has been admitted and affirmed by defendant A. Dutkiewicz in her letter
she sent to Effie Belou as well as admitted to by defendant T. Dutkiewicz himself in an
e-mail posted on the internet. Defendant T. Dutkiewicz did this to harm me, a Colorado
resident.
523. On or about March 12, 2006, T. Dutkiewicz and Connecticut DCF Watch advertised their
handbook was free on all defendants’s groups. I asked a friend of mine who lives in
Colorado, to request his book at the email address he provided. When she made the
request, he provided the book to her via return email and she forwarded it to me. By this
transaction, he introduced his products into the stream of commerce in Colorado.
524. On or about June 5, 2006, T. Dutkiewicz broadcast a plea to all AFRA groups and some
non-AFRA groups for someone to assist me in Federal Court with Internet Archive v.
Shell. He issued this broadcast request of his own initiative.

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525. During the pendency of this case, T. Dutkiewicz has made two UPL complaints against
me to the Colorado Attorney Regulation Counsel intended to shut my business down.
Neither complaint was pursued because both were frivolous. One was based on my
submission of an expanded media request to a Colorado court, and the other was based on
his complaint that I was representing a corporation in this action. Both were determined
to be groundless on their face. See ¶ 1159.l & 1159.m.
526. T. Dutkiewicz is a contributor to thetruthistold[dot]com and coloradoconfidential.com
and other forums sponsored by the defendants devoted to maligning my business, my
professional conduct and my products as well as public forums
Defendant Connecticut DCF Watch
527. Connecticut DCF Watch, PO Box 9775, Forestville, CT, 06011-9775, an unincorporated
business offering support services, advocacy and information services to the public, and
to consumers of child welfare agencies nationwide and to professionals who administer
child welfare cases.
528. Connecticut DCF Watch has a web site at www. Connecticutdcfwatch.com. This site
maintains a link to Cheryl Barnes’ book, Parent’s Guide to the System.
529. Connecticut DCF Watch is founded, owned and operated by T. Dutkiewicz and A.
Dutkiewicz.19 The conduct of T. Dutkiewicz is inextricably intertwined with Connecticut
DCF Watch and there is no distinction between the conduct of the two parties.
530. Connecticut DCF Watch is a principle actor and co-conspirator to the claims raised in this
complaint. At all times relevant to this complaint, Connecticut DCF Watch was
represented to be involved by and through the representations of T. Dutkiewicz as
“President” and “Special Family Advocate.”
19
As advertised in the Hartford Courant and and on Face the State television program on
Hartford channel 3.

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Defendant William Wiseman

531. William Wiseman (Wiseman), an individual domiciled at 1625 Siskiyou St., Klamath
Falls, OR 97601-2012 with a mailing address of P.O. Box 693, Klamath Falls, Oregon
97601.
532. Wiseman is a vulnerable adult who suffers from a closed head injury, with mental
disabilities exhibited by the mentality of a thirteen or fourteen year old with associated
limited cognitive abilities. He is a product of foster care, and claims he was abused in
foster homes as a child. He is being ruthlessly exploited by the defendants to perform
many of their wrongful acts under his name, with them acting as puppet masters while he
does whatever they bid him to do. It is by this mechanism that they believe they can
distance themselves from the consequences of the actions they initiate because he
executes the actions. He believes them to be his friends, and trusts whatever they tell him
as being the unadulterated truth. They employ flattery and attention to win his trust and
loyalty. He has been included as a member on all of their groups, because it makes him
feel important, and they give him an abundance of public stroking and affection.
533. He is the owner and publisher of unofficial AFRA ad hoc web site
www.thetruthistold[dot]com whose purpose is to hold me out to public ridicule, to
embarrass me, and to use defamation to malign my personal and professional character, to
libel my practice, business and my products, and to undermine my credibility and
professional reputation. It is advertised as an “anti-Suzanne Shell site.”
534. The defendants troll the Internet for any article or publication that is about me or refers to
me. They then post false and defamatory comments about me anonymously or in their
own names, and include a link to this site.
535. This web site was instigated by Kiefer, AFRA BOD, and exploited by the defendants.
Thetruthistold[dot]com has never been publicly maligned or disavowed by AFRA as my

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fact-based consumer advisory was. Using Wiseman to front this publication gives the
appearance of sufficient distance to protect the defendants from liability, however that is
mere posturing. There are many puppet masters, and they start with the AFRA BOD.
536. Wiseman is or was an agent and member of AFRA, and AFRA online groups, including
leadership groups, at the time of the actions alleged in this complaint. Why anyone would
invite a virtual child to participate in these groups is cause for concern, and displays the
callous exploitation of this vulnerable adult practiced by the defendants. No other
children or cognitively disabled adults have ever been permitted to participate as
Wiseman has. Certain AFRA groups actually have adult filters on them to prevent
children from joining.
537. Wiseman remains blindly loyal to the defendants, and doesn’t even realize the scope of
trouble they have gotten him into because he trusted them.
538. They have concealed him to evade service, and frightened him with false stories of what I
would do to him if I found him.
539. I did locate him, and my process server reported Wiseman cowered and expressed fear of
being beat up by him when he learned he was being served by me. He claimed the
defendants had warned him I would have him beat up if I found him.
540. When he began disclosing too much incriminating information in his pleadings in this
case, the defendants placed him across the country with Baez and muzzled him.
541. The defendants still control his every act as far as conduct about me is concerned.
542. He has admitted in document #6 of this lawsuit that other defendants write his web site
and he’s not even allowed to post anything without permission. More than three
defendants have already admitted having editorial control over his web site or submitting
content to his web site. He does not even control his own web site.
543. There are also ample admissions in his pleadings and other writings that others tell him

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what to say a do, and he obeys them.

544. He is clearly being exploited, and undoubtedly pulled in multiple directions by multiple
defendants, all for their own self-interests.
545. Unfortunately, Wiseman is a principle actor and co-conspirator to the claims raised in this
complaint. At all times relevant to this complaint Wiseman expressly conspired with
AFRA, Kiefer Tower, A. Dutkiewicz and other defendants, using AFRA and non-AFRA
interactive online groups to express his support for them and to demonstrate his willing
participation in and instigation of the tortious acts against me. He used AFRA properties
and groups as vehicles for the planning, solicitation and commission of the tortious acts
described in this complaint. He is or was a member and participant of interactive online
groups belonging to defendants and owned by him.
546. Wiseman’s web site, www.thetruthistold[dot]com, is published under the auspices of
“Wiseman Studios, Inc.” The domain name suzanneshell.net directed to that web site
until recently.
547. Wiseman has also usurped my name and created a blog in June 2006 at
http://suzanneshell.blogspot.com, populated with more of the false statements described
so voluminously herein. On this publication, many defendants are praising Wiseman and
encouraging him in his web site and Blair offered assistance to Wiseman with
thetruthistold[dot]com web site which Wiseman accepted.
548. Wiseman also owns a fully interactive Yahoo! group called thetruthistold, which was
created in August 2007. This group is private, and is used to conduct the conspiracy
against me.
549. He has also owned and operated other interactive online groups for the purpose of
forwarding the conspiracy including bashing_shell Yahoo! group.
550. Colorado residents were members of these groups.

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551. He has also created other interactive web sites, often with my name in the site name,
which are devoted to maligning my professional conduct, my business and my products.
The locations and names of all these sites are unknown to me.
552. The content on thetruthhistold[dot]com includes articles written by Wiseman, by other
defendants, anonymous articles, and articles that are attributed to Wiseman but have been
ghost-written by other defendants.
553. The defendants feed information to Wiseman for use in their campaign against me.
Wiseman does not understand much of this information, and relies on the explanations
given to him by the defendants. He is capable of following their instructions.
554. Wiseman solicited others to contribute on or about April 11, 2006, and instructed others
to contact R. Cygan with their submissions if he wasn’t available. Wiseman has admitted
in these proceedings that he does not exercise control over the content of his web site.
555. He published a photo of Christine Korn’s minor granddaughter20 on
thetruthistold[dot]com with ugly commentary21 as well as photos of other associate’s
family members and their homes22. My associates and I were terrified that he seemed to
know no boundaries and was placing our family members in danger in his efforts to harm
us.
556. On or about March, 2006, Wiseman requested and was accepted into membership of
AFRA_CenCom by Hinger.
557. On or about April 11, 2006, Wiseman contacted me via email and demanded I remove his
20
This is dangerous because minor children are vulnerable to many dangers associated
with their photos being published on the Internet.
21
This is cause for concern that an adult would engage in cyber-bullying conduct against
an innocent minor child whose only crime was being related by blood to one of my associates.
22
This is dangerous because I know people whose photos of their homes have been
published on the Internet by others, and the homes were subsequently broken into and robbed.

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name from my web site because it was copyrighted.

558. On or about May 15, 2006, Wiseman sent me a self-destructing email with the subject
line, “think you out smarted me didnt you look at this.” I didn’t open the email.
559. On or about June 6, 2006, Wiseman requested to join my Improvement Project group.
560. Sometime before June 30, 2006, Wiseman contacted the Phillip Miller Library in Castle
Rock, Colorado, where I was scheduled to present Continuing Legal Education training
and advocacy training under the sponsorship of Colorado Family Rights Advocacy
Institute. He attempted to convince the library not to allow me to use their facilities for
this presentation because I was a thief and a scam artist. The library reported he was
contacting them constantly, and they considered him to be obsessive and disturbed.
561. During the June, 2006, Wiseman made repeated phone calls Contreras in Colorado,
providing information about me to her and receiving information about me from her.
562. On or about August 26, 2006, Wiseman called my ISP, EarthLink, to make a complaint
about unidentified photographs on my web site attempting to get my web site shut down.
563. Starting on or about December 19, 2006, Wiseman participated in an online discussion
Colorado based news/blog site discussing Colorado legal issues.
564. On May 14, 2007, I was contacted by ReputationDefender, Inc. on behalf of Wiseman
with a demand that I remove content about him from a web site at
http://home.netcom.com/~dsshell/id16.html. This web space was free for me, and since I
wasn’t using it, I donated it to the publishers of the Consumer Advisory. I advised
reputation defender that I did not own the publication, and advised them to look at
Wiseman’s libelous web site. They dropped Wiseman’s demands against me.
565. AFRA web site provides or provided advertising space on behalf of Wiseman’s business
at http://members.familyrights.us/oklahoma/index.html

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566. Wiseman and the other defendants have submitted false comments and a link to his web
site on hundreds of web pages that are visible to the general public as described at ¶1496.
567. In document #6 and 273 Wiseman admits copying my entire web site and placing it on his
web site. When this happened, he was asked how he circumvented the copy protections.
He said he was a good web site builder.
568. In document # 273 ¶ 2, he says his web site is free speech, and is the truth. He believes
that because that is what the defendants told him, not because he understand the concepts
or the issues.
569. In document #273, he admits he publishes the false advertisements of my competitors.
570. In document #273 Wiseman admits to many of the false advertisements that are published
on his web site, attempting to use them as a defense for publishing them. He parrots many
of the false statements that have been disseminated by the defendants without really
understanding anything about the events. He wasn’t around when the events happened,
He can barely read and write. He never saw anything and understands less. He just knows
his friends don’t like me and believes what they tell him about me.
571. He is a useful tool, able to search the Internet for any instance of publicity relating to me,
sharing his findings with the defendants, and putting his false comments and link to his
web site and usurp my good work. The defendants also make their false contributions to
these locations.
572. Wiseman committed multiple acts in the furtherance of the conspiracy, and provided the
forums and vehicles for the conspiracy and tortious acts to be committed. The context,
tenor and tone of the defendant’s publications is replete with juvenile personal attacks,
name-calling and taunts, and contain frequent episodes of literary and structural
incoherence indicative of an emotionally aroused state of mind and lack of cognitive
understanding.

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Defendant Wiseman Studios

573. Wiseman Studios is an unincorporated business owned and operated by Wiseman, 1625
Siskiyou St., Klamath Falls, OR 97601-2012 with a mailing address of P.O. Box 693,
Klamath Falls, Oregon 97601, which publishes web sites.
574. Wiseman Studios is a principle actor and co-conspirator to the claims raised in this
complaint.
575. Wiseman Studios publishes a semi-interactive web site at www.thetruthistold[dot]com.
The domain name suzanneshell.net directs to that web site. This web site is a publication
directed at this market and at the general public. It purportedly serves consumers and
providers of goods and services in this market.
576. thetruthistold[dot]com is purportedly authored and published by Wiseman. However,
Wiseman has admitted he has no control over what it published on this web site. He has
requested input from others, and the other defendants have contributed content for this
publication. These contributors are anonymous, or ghost writing for Wiseman who takes
the credit, or are identified as the defendants. Some ghost writers have been identified by
content and writing style as Contreras, Blair, Swallow, Durand, A. Tower, A. Dutkiewicz,
R. Cygan.
577. Thetruthistod[dot]com is so full of advertisements and publications directed to the market
audience and the public that I have only been able to include specific references to a small
portion of the total web site in this complaint. This site has also undergone continuing
changes and additions so that is resolves to hundreds of pages in .pdf format. Virtually
every page has an example of at least one of the acts contained in the causes of action in
this complaint. The information on this web site flows from Colorado to the world, and
the effects of the false content on this site are felt in Colorado.
578. Thetruthistold[dot]com has published a photograph of my house in Colorado, taken

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eighty yards inside the property line of my fenced property. My house is one hundred four
yards from the road. I never took the photograph on display at thetruthistold[dot]com. I
don’t know how the defendants obtained this photograph, except that it could only have
originated in Colorado.
579. Significant amounts of the information about me on this web site originated in Colorado,
including private information never published nor made available before the defendants
obtained it. My infringed and stolen intellectual property displayed on that site is centered
in Colorado. My business that is the subject of the articles published is centered in
Colorado, and photographs displayed on that site were taken during my presentations in
Colorado. Information about me included on that site originated from Colorado state and
local records, Colorado newspaper articles and from defendants who reside in Colorado.
The defendants have affirmatively sought information from within Colorado to include in
this publication.
Defendant Ann Durand
580. Ann Durand (Durand), an individual with a last known address at 2142 Sabra Ct.
Kissimmee, FL 34744. Durand attended Shell’s training and signed a nondisclosure
contract as a condition of obtaining access to Shell’s trade secrets. At all times mentioned
in this complaint, Durand was an agent and member of AFRA.
581. Durand never had her own case. Her roommate was accused of child abuse to his children
along with Durand’s husband and daughter. They were all convicted. The two men served
jail time. Durand was accused and convicted of animal abuse. The father of the abused
children served prison time and was ultimately TPR'ed. Durand wrote the legal work and
the appeals on the fathers case and lost them. She also has provided a home for the
convicted child abuser, Hardigree.
582. Durand choose to align herself with me based on my good reputation, credibility,

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competence and professionalism.

583. Durand attended my training seminar in October 2004 and March, 2005, and signed a
non-disclosure agreement and received my proprietary content and training in exchange.
584. Durand voluntarily submitted herself to the authority and rules of the Institute under the
direct supervision of Henson.
585. Durand expressly agreed to honor all non-disclosure and non-compete requirements by
virtue of her attendance at the seminars presented by Shell, wherein non-compete and
non-disclosure terms were prominently posted and explained as a condition of attending
the sessions.
586. Durand agreed to a forum selection clause in this agreement that jurisdiction for
litigation arising out of this agreement would be in Colorado.
587. On or about March 15, 2005, Durand and Hardigree attended a private training session at
Swallow’s residence in Hernando County, where I spent the day instructing the
Defendants how to write motions for attorneys. I was working under the direction and
supervision of a Florida licensed attorney.
588. Durand volunteered her time and services to Florida FRAI until August 7, 2005, when
there arose a professional dispute involving Swallow which was brought to the attention
of Shell and Henson.
589. Durand was, then, formally sanctioned by me in my capacity as manager pro tem of the
Institute and Ms. Henson as the head of Florida FRAI.
590. This dispute was caused by Durand and Doug Hardigree publishing false statements of
fact about the plaintiff to Swallow to Institute clients and fomenting internal dissent based
on those publications.
591. Durand denounced Swallow’s sanction and began an Internet campaign of defamation
and false advertising and other tortious acts against me. She also incited Swallow, who

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fronted everything Durand said.

592. Durand’s publications about me were made in a business capacity as family rights
advocates who operated under the auspices of Colorado-based FRAI.
593. Durand published her statements to the family rights movement on the Internet market
and to Institute clients.
594. Durand is a principle actor and co-conspirator to the claims raised in this complaint. At
all times relevant to this complaint Durand expressly conspired with AFRA, Henderson,
Jackson, W. Tower, A. Dutkiewicz and other defendants, using AFRA and non-AFRA
participation in and instigation of the tortious acts against me. She used AFRA properties
and groups as vehicles for the planning, solicitation and commission of the tortious acts
described in this complaint. She is or was a member and participant of interactive online
Defendant Brenda Swallow
595. Brenda Swallow aka Brenda Mcintosh (Swallow), an individual domiciled at815 Hilltop
Road, Mary Esther, FL 32569. Swallow attended Shell’s training and signed a
nondisclosure contract as a condition of obtaining access to Shell’s trade secrets. At all
times mentioned in this complaint, Swallow was a member and agent of AFRA.
596. Swallow is a principle actor and co-conspirator to the claims raised in this complaint. At
all times relevant to this complaint Swallow expressly conspired with AFRA, Henderson,
participation in and instigation of the tortious acts against me. She used AFRA properties
and groups to be as vehicles for the planning, solicitation and commission of the tortious
acts described in this complaint. She is or was a member and participant of interactive

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online groups belonging to defendants.

597. Swallow is currently under court order in Florida, IN THE CIRCUIT COURT FOR THE
FIFTH JUDICIAL CIRCUIT IN AND FOR HERNANDO COUNTY, FLORIDA CASE
NO: H-27-CA-2006-000181-RT and in violation of that order as follows:
Hereafter, Defendant, Brenda Swallow is ordered to and shall desist and refrain from:
Threatening Plaintiffs, Suzanne Shell and Kay Henson, in any way, whether physically,
financially, or otherwise.
1. Slandering Plaintiffs with false or misleading statements regarding their
personal or professional lives.
2. Disseminating copies of Plaintiffs' copyrighted materials whether by physical or
electronic copy, except with the express written consent of Plaintiffs. (Further,
Defendant will immediately return all copyrighted materials of either Plaintiff to
them; and in complying with this requirement, Defendant shall provide either the
materials or the names of recipients that Defendant disseminated materials to
without the express and written consent of Plaintiffs.)
IT IS THEREFORE ORDERED AND ADJUDGED THAT: (1) Plaintiff Shell
shall recover from Defendant Swallow the sum of $8873.50; for which let
execution issue instanter. DONE and ORDERED in Chambers in Brooksville,
Hernando County, Florida, this 3rd day of July, 2006. Richard Tombrink, Jr.
Circuit Judge.
598. Swallow never had her own case; it was her daughter's case. Twins were born premature
and severely handicapped when the daughter was 17 years of age. Swallow and her
daughter were thrown out of the Ronald McDonald House due to a drunken brawl shortly
after the twins were born. The children were originally removed from their mothers
custody due to the mother being unavailable when needed to sign a consent for surgery on
one of the twins. Swallow and her partner were arrested several times on domestic
violence issues. Swallow is a self-proclaimed recovering crack addict. Swallow was never
allowed to be a party to the case due to domestic violence issues. She turned the case into
a “gay issue” and misled everyone involved, including the attorney. The children were
never placed in Swallow or the daughter's custody. Swallow was thrown out of the

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courtroom due to an outburst. Swallow and Durand wrote the motions in the daughters
case. The attorney refused to sign and file the motions because he said it was kooky law
and Swallow had refused to follow the instructions given to her. That attorney withdrew
from the case and Swallow and Durand attacked him, as well as his assistant, Henson.
The Institute’s efforts to redirect her to fruitful and peaceful solutions failed.
599. Swallow originally choose to align herself with me based on my good reputation,
credibility, competence and professionalism.
600. Swallow attended my training seminar in October 2004 and March, 2005, and signed a
non-disclosure agreement and received my proprietary content and training in exchange.
601. Swallow voluntarily submitted herself to the authority and rules of the Institute under the
direct supervision of Henson.
602. Swallow expressly agreed to honor all non-disclosure and non-compete requirements by
virtue of her attendance at the seminars presented by Shell, wherein non-compete and
non-disclosure terms were prominently posted and explained as a condition of attending
the sessions. Attendees, including Swallow, were instructed to leave the seminar if they
did not agree to the terms. Swallow remained.
603. Swallow agreed to a forum selection clause for disputes arising out of this agreement
placing jurisdiction in Colorado.
604. Beginning on February 1, 2005 and for several weeks afterward, Swallow participated on
AFRA_CenCom in a manner that was disruptive and introduced issues that distracted
from the business of that group. She was also making representations about me that she
was not authorized to make, and which were not entirely accurate. She also started
conducting some Institute business on CenCom. I had to repeatedly tell her to stop it, that
her submissions were inappropriate and that she was not to disrupt AFRA’s forums. She
was resistant to my instruction.

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605. On or about March 15, 2005, Durand and Hardigree attended a private training session at
Swallow’s residence in Hernando County, where I spent the day instructing the
Defendants how to write motions for attorneys. I was working under the direction and
supervision of a Florida licensed attorney.
606. Swallow volunteered her time and services to Florida FRAI, under the supervision of
Colorado-based FRAI, until August 7, 2005, when there arose a professional dispute
between Swallow and FRAI.
607. Swallow was, then, formally sanctioned by me in my capacity as manager pro tem of the
Institute and Ms. Henson as the head of Florida FRAI.
608. This dispute was caused by Durand and Doug Hardigree publishing false statements of
fact about the plaintiff to Swallow and to Institute clients and fomenting internal dissent
based on those publications, and turning clients against their attorney.
609. Swallow denounced the sanction and began an Internet campaign of defamation and false
advertising and other tortious acts against me.
610. Swallow’s publications about me were made in a business capacity as family rights
advocates.
611. Swallow published her statements to the family rights movement on the Internet market
and to Institute clients.
612. Swallow is one of Wiseman’s ghost writers and a contributor to online public fora with
defamatory content about me, my business and products.
613. On or about January 24, 2006, Swallow advertised on AFRA_Talkline, “
"non compete you guys signed"? Ok #1 Mrs. SS will tell you she has NO SIGNED
CONTRACT FROM ME LOL Cause I'm sitting here looking at it LMAO. Oh and
secondly All Contracts become Null and VOID when one party or another attempts
to Violate the Law by Requesting the other Party to be part of a Crime (Especially a
Felony).”
Swallow’s signing this contract was witnessed by Ms. Henson, who placed the

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contract with my belongings at the seminar. Swallow stole it back, intending to

breach it and commit fraud.
614. On or about April 30, 2006, Swallow coached Wiseman as to what responses he should
make to me, see ¶1537.
Defendant Dee Contreras
615. Dee Contreras (Contreras) is an individual domiciled at10571 Colorado Boulevard,
Apartment B-101, Thornton, CO 80233. She is an agent and member of AFRA.
616. Contreras’s daughter’s children were removed by DHS, and placed with Contreras
permanently two years before meeting with Colorado FRAI directer Christine Korn. Her
son’s children were similarity removed by DHS and his parental rights were terminated
shortly after Contreras met Ms. Korn. This grandchild was abused in a Douglas County
foster home and resulted in a lot of media attention.
617. Contreras is a principle actor and co-conspirator to the claims raised in this complaint. At
all times relevant to this complaint Contreras expressly conspired with AFRA, Wiseman,
Baez, Jackson, W. Tower, A. Dutkiewicz and other defendants, using AFRA and non-
AFRA interactive online groups to express her support for them and to demonstrate her
willing participation in and instigation of the tortious acts against me. She used AFRA
properties and groups to be as vehicles for the planning, solicitation and commission of
the tortious acts described in this complaint. She is or was a member and participant of
interactive online groups belonging to defendants.
618. On or about May 7, 2005, Contreras, acting in her capacity as a member of AFRA_Eagle,
solicited my participation in a nationwide mass mailing to encourage accountability in
child welfare cases. She followed this up with details on May 9, 2005.
619. On or about March 20, 2006, Contreras began participating in child welfare reform
discussions with Christine Korn, a Colorado licensee of my trade secrets. She began

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trying to ferret out information from Ms. Korn about a possible civil rights lawsuit on
behalf of her grandchildren in foster care.
620. Contreras disclosed to Korn that she writes legal documents and content for legal
documents for the families she helps. She cites her years of experience as a paralegal to
support this practice.
621. During this same period of time, Contreras had fraudulently represented to Colorado
FRAI director Christine Korn that she wanted to sponsor a training. In anticipation of that
sponsorship, Korn shared some of the information that would be presented at the seminar
for her reference. I was scheduled to meet with Contreras, and waited at the appointed
time and place for over two hours with Ms. Korn. Contreras never showed up. She never
followed through with sponsoring the training, either.
622. In December, 2006, Contreras participated in a debate with other defendants on
coloradoconfidential.com, a Colorado-based web site who published an article about me.
Contreras pretended to represent me while baiting the other defendants to escalate their
defamatory submissions about me. She did not have authorization to speak on my behalf.
I have a strict policy that nobody is authorized to represent me or my position or work on
any public forum, that anyone seeking information about me must come directly to me.
623. I sent her a back channel email (re: coloradoconfidential.com) requesting that if anyone
had issues with me, would they please bring them to me and not discuss them on a public
forum. Dee had posted,
“The thing I would like to understand most is that if nobody is in this for
personal gain, why is there such a controversy regarding written intellectual
property. If nobody plans to use anybody's stuff for personal gain, and
everyone claims the only purpose for its existence is distributing it freely to
indigent parents, what difference does it make who said it first?”
I told her to stop speaking about me and my work, since she knew nothing about it. Ms.
Korn told her, “For the record, the intellectual property which Suzanne works to

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protect, makes money through, is NOT ‘stuff handed out to parents.’”

624. Contreras insisted she had free speech rights, which I did not dispute. She was missing
the point of my request that she stop speaking on my behalf. She accused me in an email
on April 6, 2007, me of ridiculing her for supporting me. She was referring to a comment
she made on badadvocates.com to which the Editors responded. She said, “. . .I won’t
make that mistake [of supporting you] again. The victim stance is laughable, but not
believable.” I told her if she didn’t want to be discussed on that site, why did she post a
comment? It wasn’t my site, so I wasn’t responsible. She responded with taunting and
abuse, and insisted I did own it, because other defendants told her so.
625. On or about February 12, 2007, and continuing for hundreds of messages over several
months Contreras–who lives in Colorado–began providing case specific legal advice to
members on AFRA_EAGLE. She provided information from my methods and took credit
for it. Some of the information she provided included the false information I planted in
my seminar handout, not realizing it was planted to detect misappropriation of my trade
secrets.
626. On or about March 6, 2007, Contreras agreed to Hinger’s request to meet with the AFRA
representative who was coming to Colorado to lobby for legislation and receive a
donation from a “Well-to-do” patron.
627. Contreras was never my client nor a client of the Institute. She did not have a case, her
daughter did. She did not have standing in any case and could not participate. She
admitted she met Ms. Korn two years after her daughters parental rights were terminated.
628. On or about July 21, 2008, Contreras emailed me and stated, “I have been working with
a group of attorneys who do pro bono work for parents involved with CPS.” Given that
she so freely gave my proprietary information to the AFRA groups and given her motives
for doing so, it is reasonable to conclude she gave it to these attorneys, too, and they are

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using my trade secret methods without permission.

629. This was confirmed on May 4, 2010, when she stated in an email to me that her team of
pro bono attorneys, “. . .don’t need your ‘work,’ and quite frankly would reject about half
your suggestions on how to proceed.” The only way she could know this kind of detail
would be if 1) she does have unauthorized possession of or access to my proprietary
content and 2) these attorneys told her they would reject about half of my suggestions.
She went on to make threats about what horrible things would happen to me if I
attempted to continue with my complaint, inferring that the wrath of Colorado courts
would befall me should I attempt to “sully the reputation” of these attorneys by claiming
she gave my proprietary content to them.
630. Contreras is exploiting Wiseman from Colorado, and authoring articles on his web site.
See ¶1650.
631. Contreras admitted in document #59, that her motive for turning against me was that I
asked her to stop speaking on my behalf on public forums. I never authorize anyone to
speak for me.
632. In addition to admitting that she works with pro bono attorneys representing parents in
child welfare cases, Contreras has admitted in document #59 and #141 that she works
with other advocates in Colorado to reform child welfare.
633. Contreras has admitted in document #59 that she was not a consumer at the time she met
with Ms. Korn, and in #141 that she was never a client of mine.
634. In document #59, Contreras admitted that AFRA gave her problems about being
associated with me, sufficient to cause her to remove herself from associating with them
at first.
635. Contraras has made false averments in her pleadings which are inconsistent with her own
out-of-court statements as demonstrated herein.

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636. Certain information about me published by the defendants in online publications came
from Contreras in Colorado and has been disseminated to all defendants by Contreras.
The defendants sought information about me from Contreras and she provided it.
637. I have never met Contreras.
638. Contreras committed multiple acts in the furtherance of the conspiracy.
Defendant Kathy Tilley
639. Kathy Tilley, an individual domiciled at 800 Gibson Dr. #322, Roseville, CA, 95676.. An
agent, member and Board member of AFRA, owner and/or moderator and user of
various AFRA groups, web sites and organizations including but not limited to
AFRA_EAGLE (changed to USA_EAGLE).
640. Tilley is a principle actor and co-conspirator to the claims raised in this complaint.
Defendant Randall Blair
641. Randall Blair, an individual domiciled at 2500 Mann Rd, Clarkston, MI 48346. Member
and agent of AFRA.
642. Blair’s children were adjudicated abused/neglected, and were place with their mother
upon divorce. Blair was accused of sending threatening letters to the case worker during
his case, which resulted in his computers being seized. He was subsequently arrested and
charged with extortion of a judge when he was advocating for a parent on another case.
He allegedly sent a threatening letter demanding the judge step down from the bench or
he would expose her extra-marital affair. He accepted a plea bargain and was convicted.
643. Blair is a computer expert. His occupation is working with computers and networks, both
in the public sector and as a business owner. He claims to travel the world to provide
computer consulting services to customers.
644. Blair is a principle actor and co-conspirator to the claims raised in this complaint. At all
times relevant to this complaint Blair expressly conspired with AFRA, Wiseman,

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interactive online groups to express his support for them and to demonstrate his willing
participation in and instigation of the tortious acts against me. He used AFRA properties
and groups to be as vehicles for the planning, solicitation and commission of the tortious
acts described in this complaint. He is or was a member and participant of interactive
online groups belonging to defendants.
645. Sometime in 2002, Blair contacted me via email requesting help for his case, “For what
it's worth, when I got involved in this CPS mess over 3 years ago (as a victim), I
approached Donna Suzanne Shell about it via email.” Published by Blair August 15,
2005 to over forty individual and group email recipients.
646. On or about May 19, 2003, defendant Blair published a news release to online groups,
including a group I moderated, pursuant to the search and seizure of his computer
equipment arising out of a Temporary Restraining Order (TRO) complaint that he had
sent threatening emails to a caseworker. He denied sending the subject emails that caused
his computer to be seized, and accused R. Cygan of authoring the threatening emails.
647. Blair was advertised as an advocate on AFRA CenCom’s state advocates list on or about
June 30, 2004.
648. On June 19, 2006, Blair joined my Improvement Project group and became a contributor
to that publication.
649. On or about August 3, 2006, Blair sent forged evidence via U.S. mail to the Colorado
Attorney Regulation Counsel intended to initiate or support Unauthorized Practice of Law
(UPL) proceedings against me. The investigation was unfounded.
650. On or shortly before August 6, 2006, Blair filed a criminal complaint against me with
Oakland County, MI, sheriff, alleging extortion because I had sent him a cease and desist
letter copyright infringement letter. I was investigated and the investigation was

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unfounded by Oakland County sheriff

651. A few days later, after failing to have me arrested by his county sheriff, he made the
identical complaint against me with my county, (El Paso) sheriff. I was, once again,
investigated for extortion by El Paso County, Colorado, and was not charged or arrested.
652. Blair provides web site assistance to Wiseman.
653. Blair committed multiple acts in the furtherance of the conspiracy.
Defendant Lloyd Phillips
654. Lloyd Phillips (Phillips), an individual domiciled at 14220 SW 29 Court, Fort
Lauderdale, Florida, 33330, registered owner of the domain name www.profane-
justice.com during the times of this complaint. Phillips is also the registered owner of the
domain name of T. Dutkiewicz’s web site at http://www.connecticutdcfwatch.com.
655. Phillips is a principle actor and co-conspirator to the claims raised in this complaint. His
connection is through the Dutkiewicz’s.
656. The [dot]com extension of my “profane-justice” domain name was registered to Lloyd
Phillips, a friend of the Dutkiewicz’s, on or about May 27, 2004. The side was populated
with false and misleading content about my business and my business practices, including
that I engaged in terrorism and suggested “the death of another human being”; implied
that I committed “libel, defamation, and slander,” and should be “held accountable for
‘Stirring Up Strife,’” and implied that the Dutkiewicz’s were altruistic.
Defendant Ringo Kamens
657. Ringo Kamens aka Alex Bryan (Bryan), an individual domiciled in Centennial,
Colorado, 80015, identified also as Rkamens or 2600denver@gmail.com.
658. Bryan is a principle actor and co-conspirator to the claims raised in this complaint. He
joined the existing conspiracy with the defendants in March, 2007. His participation was
initially to support and incite the defendants’s infringing conduct, and to expand his

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political activism against online copyright protections to include my IP.

659. Bryan was in contact with the defendants and participated in their conspiracy, most
notably Wiseman, and provided his Colorado based web-sites to publish their
advertisements for viewing by Colorado residents who use the Internet, and encouraged
the defendants and the general public to infringe my copyrights. He committed multiple
acts in the furtherance of the conspiracy.
660. Bryan has removed multiple web pages of his which contain proof tending to support my
claims no longer being available on line, including but not limited to the anti-copyright
site sponsored by Binary Freedom (binaryfreedom.com).
661. On or about February 3, 2009, I replied to Bryan’s May 30, 2007 email to me wherein he
stated he would provide me with his name and address if I intended to sue. I asked for his
identifying information. He never responded. I had to pay for investigations and
surveillance to find him and serve him.
Defendant Cheryl Barnes
662. Cheryl Barnes (Barnes), an individual domiciled at 911 Cliff Dr., Branson, MO 65616.
Founder and National Director of CPS Watch, Inc., and owner of CPS Watch online
interactive groups.
663. Barnes had a child welfare case in Kansas involving her son T.B. in 1998. Barnes lived in
Missouri at the time. She sought my assistance, but would not provide me with her case
records. Her child remained in foster care for over a year, but she continued to contact me
seeking advice and information, which I provided as best I could. Subsequently, she
moved to Heartland ministries in Missouri. They eventually had to demand she leave.
Heartland told a newspaper, “She didn’t want to take care of her kids like we thought
they should be taken care of. Her kids are in desperate need of help.” When she left
there in April, 2003, the pastor published that she had left the home he provided to her

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family in a shambles. There were reportedly holes in the walls, the carpets were stained
with feces and urine, and the interior had to be demolished and restored. He stated, “She’s
not welcome here at Heartland. She’s just a lady you can’t reason with.”
664. Barnes went to North Carolina with her children to assist with the Jack Stratton case.
According to reports I received from those who received her there, when she arrived, the
fifteen year-old was driving the U-Haul van. The children had not been fed and were
starving. The babies’s diapers were so full that it appeared they had not been changed in
over forty-eight hours. They were filthy and stank. They appeared so neglected that a
report was made to the local child welfare agency. The attempt to investigate the
allegations made the news, because Barnes resisted attempts to allow DSS to see the
children. She was arrested for fugitive extradition to another stated and held in jail for a
court appearance the next morning. The arrest was because Barnes did not return the U-
Haul and owed $820.00.
665. The court ordered her to make her children available for interviews.
666. CPS Watch North Carolina Director, Sue Dhermy, resigned over the unethical and
shocking conduct of Barnes. She stated Barnes obtained a $100 donation from her
fraudulently and she wanted a refund.
667. The North Carolina case resulted in a lot of media attention. A local radio program
opened their interactive online forums for discussion, and Barnes featured prominently on
the debates, which frequently degenerated into cyber-brawls. The amateur bickering on a
public forum proved how immature and unprofessional Barnes and the CPS Watch
contingent was.
668. On or about October 14, 2003, Barnes’s home in Branson, MO was raided and authorities
removed her youngest child.
669. On or about December 16, 2003, Barnes home was again arrested for refusing entry to

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police officers on a report of child abuse. They confiscated her computer equipment, and
video tapes.
670. On or about July 19, 2007, Barnes was arrested for physically abusing one of her children.
Police reports indicate the home was a mess, with holes in the floors and walls.
671. Barnes has an extensive court history,
a. May 6, 2003, Guilty Tampering with property of another 2nd degree misdemeanor
b. Jan 15, 2004, guilty of failing to secure a child 1-16 years of age in seat belt–two
counts
c. April 8, 2004, Judgement for past due rent $4250.00, late fees $450.00, damage to
dwelling, $10566.66.
d. February 17, 2006, Guilty speeding, exceeded by 16 -19 MPH
e. August 15, 2006, Guilty operating motor vehicle careless and imprudent manner.
f. June 26, 2007, Judgement $4,978.88
g. July 19, 2007, Warrant and arrest, Endangering Welfare of Child 1st degree
Felony.
672. Barnes is a principle actor and co-conspirator to the claims raised in this complaint. At all
times relevant to this complaint Barnes expressly conspired with CPS Watch, Inc.,
Thompson, Howard, Swallow, Baez, other defendants, using CPS Watch and non-CPS
Watch interactive online groups to demonstrate her willing participation in and
instigation of the tortious acts against me. She allowed CPS Watch properties and groups
to be as vehicles for the planning, solicitation and commission of the tortious acts
673. In 1997-1998, Barnes contacted me multiple times in Colorado seeking my services to
assist her in her child welfare case in Kansas. We subsequently communicated about her

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case via email and telephone.

674. On or about October 5, 1998, Barnes requested my assistance via email because her son’s
Guardian ad litem (GAL) was taking over her son’s civil rights lawsuit.
675. On or about February 18, 1999, Barnes contacted me via email and requested my
assistance in providing her with an attorney in Kansas who could represent her civil rights
claims.
676. On or about April 9, 2000, Barnes send me an email soliciting me to write an expose’ for
publication on her CPSWatch Parent Support group disclosing the information I
possessed about an expert witness social worker who preyed sexually on vulnerable
mothers by threatening to testify against them unless they gave him sexual favors.
677. On or about May 18, 2000, Barnes sent me an email attempting to clear up a dispute
involving Parentsmarch®.
678. On or about January 2, 2000, Barnes sent an email to an interactive online group (syc) on
my behalf alleging plagiarism and copyright infringement based on the organization’s
publication of verbatim content from my web site. I did not solicit Barnes to take any
action on my behalf, including this action.
679. On or about August 15, 2000, Barnes sent me an unsolicited email requesting a written
copy of my Case Management Plan to include in CPS Watch’s Member’s Technical
Assistance Bulletin. She had attended a VOCAL/FRONT conference where I had
presented that information. Barnes had requested permission to use it at the presentation, I
told her she could use if she properly attributed it to me and did not charge for it. In her
email he promised to give me full credit and to include my web site address. I agreed on
the condition that she include the full copyright notice. On August 21, 2000, she
requested me to send the document as a WordPerfect file which I did. This outline was
created by me in Colorado, and formed the basis for her subsequent publication Parent’s

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Guide to the System which violated the express license terms. She did not give me credit,
she did not include links to my web site or my copyright notice, and she charged $9.95 for
the book. Now she gives it away for free, but the other terms have not been met. This is
an ongoing infringement.
680. On or about August 29, 2000, Barnes summarily removed me from all CPSWatch online
interactive groups, without explanation, intentionally concealing her infringing violation
of the license agreement and her reverse passing off from me. All of my attempts to re-
subscribe to her groups were refused. A Parent’s Guide to the System was subsequently
published and sold for $9.95 via her groups, supra.. Her business methods were based on
it and other information she obtained from me. She did not devise the strategies CPS
Watch uses in less than two weeks, much less without having access to my materials.
This book contains the planted false information described above.
681. When I finally obtained a copy of Parent’s Guide to the System in 2005, it was provided
to me from a Colorado resident who had ordered it from Barnes, and who contacted me
saying she was concerned that it looked like my work.
682. Barnes’s strategies are comprised of what I have published and what she has appropriated
from me. However, I have never published any of my strategies to their logical and
favorable conclusions. As a result, without that information from me, Barnes is relegated
to limping along with only a partial remedy. Consequently, she has been forced to
condemn as ineffective or dangerous certain of the methods that she cannot figure out
how bring to the favorable conclusion. Barnes can copy, she can research, she cannot
innovate or postulate.
683. As an example, on November 8, 2008, Barnes published on CPSWatch that Barnes and I
had had a debate,
“I presented case after case stating that schools HAVE to let CPS see your
children. Her side was basically that three nameless attorneys told her she

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was right. When I was clearly winning the debate - she decided she was too
sick to continue the conversation.”
This is a false representation. My 4th Amendment letter was the catalyst of this debate.
She did not understand how that letter could be used to prevent CPS from interviewing
children at school. I was not going to reveal my methods for bringing this issue to the
favorable conclusion and help her improve her practice because she had a propensity to
steal my IP and call it her own. This only shows she cannot figure out what I have figured
out, so she must condemn it.
684. Barnes has a history of taking credit for outcomes for which she is not responsible. For
example, on April 11, 2003, CPS Watch and Barnes took credit for legislation passed in
the Missouri legislature increasing case worker accountability, improving due process for
parents, increasing scrutiny over foster care. Barnes falsely published to all online groups,
“The reform package comes after years of lobbying by CPS Watch. . .” In fact, the
lobbying was done by Deanna Gallager, whom CPS Watch refused to work with. Ms.
Gallager was working with Missouri Council for Children at Risk and Brenda Browning.
685. I had been receiving regular complaints by consumers that Barnes and CPS Watch had
taken their money and never delivered the advertised products or services. This has been
an ongoing issue. On June 18, 2002, James (LNU) contacted me via email to voice his
support for me and say that he had a “Lil Tiff” back 2 years ago over a membership
problem which was NEVER rectified.”
686. LBE also reported to me that she paid for membership, book (Parent’s Guide to the
System) and subscription and never received the publications.
687. Barnes still advertises subscriptions to TCB Chronicles on her web site, which only
published a few issues in 2001.
688. Barnes has introduced products into the stream of commerce, expecting they will be used

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in Colorado. These products include or included membership to her web site, subscription
to TCB Chronicles magazine, her book Parents Guide to the System, and legal document
drafting services @$65/hour.
Defendant CPS Watch, Inc.
689. CPS Watch, Inc., a Missouri non-profit corporation, 911 Cliff Dr., Branson, MO 65616
which offers products nationwide and has state leadership.
690. CPS Watch, Inc. is a principle actor and co-conspirator to the claims raised in this
complaint. The conduct of Barnes, Thompson and Howard is inextricably intertwined
with CPS Watch, Inc. to the point where it is impossible to distinguish their acts as
separate. At all times relevant to this complaint CPS Watch, Inc. expressly conspired
with Barnes, Thompson, Howard and other defendants, using CPS Watch and non- CPS
Watch interactive online groups to disseminate information and to demonstrate her
willing participation in and instigation of the tortious acts against me. CPS Watch
properties and groups were used as vehicles for the planning, solicitation and commission
of the tortious acts described in this complaint.
691. CPS Watch, Inc. was incorporated in Missouri on January 7, 2000.
692. It was administratively dissolved by the Secretary of State on December 18, 2001, for
failure to file annual reports.
693. It was ordered not to conduct business between 2001 and 2008, however, Barnes,
Thompson and Howard still represented their work as being conducted by CPS Watch,
Inc.
694. On or about July 3, 2008, all past annual reports were filed and paid for and the status of
the corporation was reinstated.
695. On December 23, 2009, CPS Watch, Inc. was again administratively dissolved by the
Secretary of State for failure to file a correct and current annual report. It was ordered to

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cease operations.
696. CPS Watch, Inc. is still operating and being advertised on CPS Watch web sites, groups
and other mediums even though it is administratively dissolved. Barnes, Thompson and
Howard publish solicitations for donations and other needs under the auspices of CPS
Watch, Inc.
697. Barnes’s book, “Parent’s Guide to the System” is copyright 2000 and 2004 Cheryl Barnes
and CPS Watch, Inc. However, it is not registered with the copyright office.
698. CPS Watch, Inc. states in its articles of incorporation state, “The corporation is organized
to assist parents and families and to provide them with information and services that
promote family unity and all other legal powers permitted a Nonprofit Corporation.”
699. Membership in CPS Watch, Inc. has been advertised at $35.00 per year and membership
includes consumers as well as service providers.
700. Products offered include but are not limited to, “. . .services needed to regain or keep
custody of their children,” “Legal research and preparation of motions, appeals, affidavits,
etc.,” and “Basically, we will provide families with anything needed to keep the family
intact.”
701. CPS Watch, Inc. has as a subsidiary, CPS Watch Legal Team, with a web site at
www.cpswatchlegalteam.com, and is advertised as23, “. . .an outgrowth of CPS Watch, a
national non-profit organization that provides information and assistance to families
involved with child welfare agencies (CPS).”
702. This assistance includes, “Training of parents in the exercise of the guaranteed rights,”
“Publications explaining those rights and the legal procedures which threaten their
rights,” Legal complaints, motions, briefs and memorandum,” “The conducting of
23
As of April 9, 2010

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training sessions,” “Consultation with parents and parent groups.” The domain name
for this subsidiary is registered to Barnes and was first registered in 2008.
703. The methods used by Barnes, CPS Watch, Inc., Thompson and Howard in their business
originated with me. They have never given credit to me, and have used my information
and methods to enhance their stature and credibility in this market.
704. They have also enhance their credibility by presenting Parent’s Guide to the System as
Barnes original work, when it was plagiarized from me.
705. CPS Watch, Inc. sponsors, currently owns and operates a fully interactive online Yahoo!
group at http://groups.yahoo.com/group/CPSWatch. This group currently lists 526
members. The members constitute the same consumer demographic as AFRA’s members
including members who reside in Colorado. This group sends between one and dozens of
messages a day during the life of the group.
706. CPS Watch, Inc. and Barnes have also, in the past, owned and operated several fully
interactive online lists associated with the CPS Watch web site (www.cpswatch.com)24
for different functions, including Support (offering legal and case management advice),
Legal (to disseminate legal information). CPS Watch, Inc. uses these groups and its web
site to advertise CPS Watch, to promote, offer and deliver support services, information
services and various products to the public, and for soliciting membership into CPS
Watch and to advertise CPS Watch’s business activities and events, and to conduct CPS
Watch business.
707. The CPS Watch BOD exercises oversight and control over these interactive groups, and
24
This domain name was originally registered to Barnes @ PO Box 974, Branson, MO,
65615, and the administrative contact was CPS Watch, Inc. , @ PO Box 6521, Branson, MO
65615, from 25 June, 1998 to 2004. It was abandoned by Barnes in 2004 and is currently owned
by someone else. CPSWatch.com has been removed from Internet Archive (archive.org) since
this lawsuit was filed.

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designates select members to moderate the groups.

708. The CPS Watch lists and groups offer membership to all fifty states. The application for
membership does not exclude members from Colorado. I have been a member of these
groups. I am still a member of the current group. I live in Colorado.
709. In 2001, CPS Watch advertised it had 10,000 members. On February 18, 2010, it
advertised “CPS Watch has thousands of members in all 50 states. . .” The membership
demographic as described includes consumers as well as service providers.
710. I have contributed information from and about Colorado to these lists, to all members
nationwide, including to those members in Colorado.
711. On or about September 9, 2000, CPS Watch Parent Support Group member “Colorado
Survivor” sent a press release on behalf of Colorado-based Family Solidarity Coalition
about legislative committee hearings in Denver.
712. On or about September 17, 2000, Kristina, a Colorado member of CPS Watch Parent
Support Group sought advice from the group about releasing her medical records and the
group responded.
713. Other Colorado-based members of CPS Watch Parent Support Group and Legal Support
Group made themselves known when they sought and received advice and information;
Dizzy and Pandora on September 29, 2000; Twig on December 20, 2000,
ColoradoFamily on February 28, 2001.
714. Sometime after June, 2001, CPS Watch online interactive groups ceased to exist.
715. On or about January 22, 2004, I began receiving messages from CPSWatch Yahoo!
group, again for a short time. The group had been resurrected and the old mailing list had
been used to create the new group membership list. Colorado members of this reinstated
group were revealed to included Christine Korn, “Bev”, Twig, Trina. This does not
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716. Starting January 28, 2004 there occurred on the CPSWatch Yahoo! group a discussion
involving Colorado-specific advice and information on a Colorado-centered case by a
Colorado member and other members of the group.
717. On or about June 16, 2004, Twig, a Colorado member, presented information about
changes to the Colorado Appellate Rules.
718. On or about August 9, 2006, Barnes gave Colorado-specific case-specific legal advice to
a Colorado member of CPSWatch Yahoo! group.
719. On or about January 8, 2004, and on April 7, 2004, Colorado members gave advice to
other members of this group at their request.
720. On or about November 10, 2007, Desere Howard disseminated information about
Suzanne Shell, obtained from a Colorado news paper, Westword, to CPSWatch Yahoo!
group.
721. On or about November 13, 2007, Desere Howard disseminated information about
Suzanne Shell, obtained from the U.S. District Court, District of Colorado, to CPSWatch
Yahoo! group.
722. These instances are not exhaustive. Group archives have been altered, with incriminating
messages being deleted from the archives.
723. By virtue of Colorado members participating in the online interactive groups, receiving
and disseminating content, including infringing content that originated in Colorado, CPS
Watch has reached out beyond its home state and created continuing relationships and
obligations with citizens of Colorado and is subject to regulation and sanctions in
Colorado for the consequences of its activities.
724. The injuries claimed arise out of or relate CPS Watch activities. CPS Watch’s conduct
and connection with Colorado are such that CPS Watch and it’s board of directors should
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725. CPS Watch has transacted business in Colorado and/or has representatives and agents
situated in Colorado, and/or has received information and services from residents in
Colorado, and/or has customers in Colorado, and/or committed tortious acts in Colorado,
therefore, jurisdiction and venue is proper in Colorado.
726. Baez, Swallow, Durand, A. Dutkiewicz and other defendants are or were members of
CPSWatch.
Defendant Desere’ Clabo Howard
727. Desere’ Clabo, aka Desere’ Howard (Howard), an individual domiciled at 4838 Se
Isabelita Ave., Stuart, FL 34997, member of CPS Watch, Inc. and CPSWatch Yahoo!
group and official CPS Watch representative for Florida.
728. Howard is a principle actor and co-conspirator to the claims raised in this complaint. At
all times relevant to this complaint Howard expressly conspired with CPS Watch, Inc.,
Thompson, Barnes, Swallow, Baez, other defendants, using CPS Watch and non-CPS
729. Howard is a member and agent of AFRA.
730. On or about November 12, 2007, Howard joined my Improvement Project and became a
contributor to that publication.
731. On or about November 13, 2007, Howard published a message containing the dismissal
of a prior copyright infringement suit against two Colorado lawyers with the subject, “for
those of you who use shell’s website,” spreading the message that the courts would not
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732. Howard participated on the group by publishing my maiden and first married name, just
like the AFRA defendants always did.
733. On or about December 4, 2009, Howard provided heretofore unknown advice to the
CPSWatch interactive Yahoo! group which constituted part of my proprietary trade secret
methods.
Defendant Sarah Thompson
734. Sarah Thompson (Thompson), an individual domiciled at 412 W. Junge Blvd., Joplin,
MO 64808, serves on the board of directors of CPS Watch, Inc. and is moderator and
member CPS Watch’s interactive online groups.
735. Thompson is a principle actor and co-conspirator to the claims raised in this complaint.
At all times relevant to this complaint Thompson expressly conspired with CPS Watch,
Inc., Barnes, Howard, Swallow, Baez, other defendants, using CPS Watch and non-CPS
736. Thompson moderates CPSWatch group and has the authority and discretion to determine
content and participation. She has sent and received hundreds of transmission to and from
Colorado over the years that CPS Watch groups operated, and has personally introduced
CPS Watch products into the stream of commerce in Colorado.
737. On or about August 8, 2008, Thompson published on CPSWatch that she had joined my
Improvement Project to “monitor that situation.” By joining, she became a contributor to
my publication.
Defendants Doe

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738. Fifteen unnamed defendants Doe whose identities are unknown to me, who participated
in, contributed to or are otherwise liable for the injuries and harm included in this
complaint. I will seek leave of this Court to amend my complaint to include such
person(s) and the applicable allegations against them when that information is
ascertained.
739. One of the defendants who I have not been able to identify has been impersonating me
and my organization to consumers. I received a phone call from Trinia Gray in Illinois in
early October, 2010, stating that she had received a letter from me. This letter claimed to
be from me and stated that I had received her application for “our Family Advocacy
Program” and she wanted information what the letter was about. When I advised her I did
not send the letter, she agreed to forward the letter to me. The heading on the letter states,
“The Family Advocacy Program,” and the letter is signed “Suzanne Shell, Your Family
Advocacy Representative.” The phone number in the letter was mine, and she was
instructed to speak with “one of our team members.” I did not send this letter, and I do
not have applications for advocacy available to the consumer. The signature pretends to
me mine and is forged. Ms. Gray did not keep the envelope it was mailed in. I do not
solicit cases in any manner, including sending out letters.
JURISDICTION AND VENUE
740. The United States District Court has jurisdiction over the subject matter of this action
pursuant to 28 U.S.C. § 1331 and § 1338(a), as this action arises under the copyright laws
of the United States 17 U.S.C. §§ 101 et seq.
pursuant to 28 U.S.C. § 1331 and §1337 as this action also arises under §43 of the
Lanham Act, 15 U.S.C. § 1125(a) and various other state statutes and common law
doctrines.

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pursuant to 28 U.S.C. § 1331 and §1337 as this action also arises under the Sherman Act,
15 U.S.C. §2 et. seq. and various other state statutes and common law doctrines.
743. This complaint is also brought under the federal Racketeer Influenced and Corrupt
Organization (“RICO”) statute, 18 U.S.C. § 1961 et seq., and various other state statutes
and common law doctrines. Jurisdiction is vested in the United States District Court by
virtue of 28 U.S.C. § 1331.
744. Defendants are subject to the personal jurisdiction of this Court and venue is proper in
this District under 28 U.S.C. § 1391(b) and 28 U.S.C. § 1400(a) in that the acts
complained of in this complaint occurred in this District and the Defendants reside, may
be found and/or transact business in this District. Two of the defendants are Colorado
residents. The defendants have maintained systematic and general business contacts with
Colorado and a continuous presence in Colorado since on or before 2000. The defendants
have maintained systematic and general business contacts with Colorado and a
continuous presence in Colorado since on or before 2000. The defendants have pursued
business relationships and other activities with Colorado. The defendants have reached
out beyond their home states and created continuing relationships and obligations with
citizens of Colorado and are subject to regulation and sanctions in Colorado for the
consequences of their activities. The injuries claimed arise out of or relate to the
defendants’s activities. The defendants’s conduct and connection with Colorado are such
that they should reasonably anticipate being haled into court here. The defendants have
pursued business relationships and other activities with Colorado. The out-of-state
defendants have reached out beyond their home states and created continuing
relationships and obligations with citizens of Colorado and are subject to regulation and
sanctions in Colorado for the consequences of their activities. The injuries claimed arise

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out of or relate to the defendants’s activities. The defendants’s conduct and connection
with Colorado are such that they should reasonably anticipate being haled into court here.
745. Because claims brought under state law, are so related to my federal claims, over which
the United States District Court has original jurisdiction, that they form part of the same
case or controversy under Article III of the United States Constitution, the United States
District Court for the District of Colorado also has jurisdiction over my state common law
and statutory claims pursuant to 28 U.S.C. § 1367.
746. Pursuant to Colorado Revised Statutes § 13-1-124, the defendants purposely availed
themselves of the privilege of acting in Colorado or of causing important consequences
here; the cause of action arises from the consequences to me in Colorado of the
defendants’s activities; the activities of the defendants or the consequences of those
activities have a substantial enough connection with Colorado to make the exercise of
Colorado’s jurisdiction over the defendants reasonable. The defendants transact business
in Colorado and/or have representatives and agents situated in Colorado and/or
committed tortious acts in Colorado, therefore, jurisdiction and venue is proper in
Colorado.
747. Claims also arise out of a contractual forum selection clause wherein Colorado is the
agreed upon jurisdiction and venue for disputes arising out of breach of express licensing
and non-disclosure agreements by one or more of the defendants, and other torts and
damages that arise out of such breach and which also arise out of the tortious interference
causing such breach.
748. Pursuant to 28 U.S.C. § 1400(a) and § 1391(b) (1) and (2), Colorado is the proper venue
because the plaintiff in this case is Shell, who (1) resides in Colorado, and (2) conducts
her business primarily in Colorado, and (3) that a substantial part of the events giving rise
to the claims occurred in Colorado, and (4) a substantial part of the property that is the

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subject of this complaint was originally and is situated in Colorado.

FACTUAL BACKGROUND
749. The email messages and group messages described in this complaint which were sent by
the defendants were seen and read starting in 2001 and continuing to the current date, by
as few as one and as many as one hundred Internet email recipients selected by the
respective defendant.
750. The email address recipient lists included single recipients as well as group recipients;
751. The group recipients had as few as a five members and as many as over one thousand
members.
752. The emails were also seen and read by an unknown number recipients of unknown
identities when the defendants’s messages were predictably forwarded to others by their
original recipients. This forwarding occurred repeatedly.
753. These messages also remain archived on various group pages and are searchable. The
messages in the archives can continue to be accessed by any member or user of said
groups at any time.
754. The group messages were direct to and received in Colorado, and derived from Colorado
to be disseminated to each group user.
The Market
755. For the past thirty years, over three million reports of child abuse or neglect are received
by state child welfare agencies annually. Approximately one million of these reports are
“founded” each year.
756. Child welfare is a multi-billion dollar industry, built upon providing goods and services to
families of these founded reports.
757. This industry is served by the public sector and the private sector by for-profit and non-
profit businesses.

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758. Federal legislation mandates that state and local child welfare agencies utilize
community-based goods and services when administering child welfare cases. In practice,
state and local child welfare agencies do provide a wide array of community-based
services for their child welfare clients.
759. Child welfare clients are not denied the right to select and use any community-based
service of their choice during a child welfare case or court action.
760. This market is comprised of family members (i.e. parents, guardians, children) who are
affected by a report of child abuse or neglect, and their extended family members and
friends.
761. This market also includes professionals and service providers who are seeking
community-based services, products and information to provide to families involved in
child welfare cases and investigations, and in obtaining educational services to improve
their practice.
762. Family member consumers in this market are particularly vulnerable to exploitation and
abuse by service providers due to the extremely emotional and intimate nature of the
circumstances surrounding child welfare. There are complex esoteric consumer issues
associated with providing goods and services to this market that do not exist in other
markets.
763. The quality of services historically provided to child welfare clients by child welfare
agencies is dreadfully low resulting in a high rate of failure by child welfare agencies to
rehabilitate the parents and reunify children with their parents. This is evidenced by the
tragically high rates of termination of parental rights and permanent guardianships
awarded.
764. Analysis of these services has revealed that the services offered to child welfare clients
are often inappropriate to the issues that put the child at risk, or are substandard compared

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to the generally accepted practices in the respective professions, or are outright dangerous
in that they are based on untested, unproven, speculative and even disproved theories,
and/or are administered incompetently or abusively.
765. Consumers primarily seek information about goods and services related to child welfare
cases from the Internet.
766. The second most prevalent method of referrals for child welfare goods and services is
word-of-mouth.
767. Following that is media coverage of issues related to child welfare which frequently are
used by providers to direct consumers to providers of relevant information and products.
768. Consumers utilize Google and other search engines to find who is offering information,
services and other products relevant to child welfare on the Internet.
769. These search engines produce results that include web pages, interactive online forums
and groups, blogs, media stories and articles, and other forms of presence on the Internet.
770. Consumers then select from the search results to find the goods and services that are most
appropriate to their specific needs. These resources frequently include links to similar
resources.
771. The most prevalent means of advertising and promotion to this market is on the Internet.
772. This advertising and promotion is done using web sites–both passive and
interactive–which disseminate relevant information to the general public and which
consumers access in seeking services.
773. Most web sites operating within this market are passive or partially interactive.
774. Many of these passive web site owners will have a corresponding interactive online group
for dissemination of information by the provider of products and other participation by
consumers and others interested in this issue. They will also participate in similar
interactive online groups owned and operated by other providers of products to this

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market.
775. They also provide links and other contact information whereby the consumer can contact
them directly to obtain goods or services.
776. Thus, the information made available to consumers saturates this market by use of web
sites and interactive online groups.
777. Web sites catering to the general public which publish articles on a wide variety of
subjects are also accessed by consumers. The subjects include issues involving child
welfare and prominent participants in the family rights arena. These sites often offer the
general public the uncensored opportunity to comment on their products, articles and
news reports relevant to these issues or products sold.
778. When these publications publish a story about child welfare issues, it generates great
interest in the family rights movement, and many participants–including the defendants–
utilize the comment features of those articles. The defendants25 made liberal use of these
web site comments features to disseminate their false and misleading advertising and to
direct readers to thetruthhistold[dot]com.
779. Other Internet means of promotion and advertising includes blogs, and interactive online
groups, forums and bulletin boards dedicated to the discussion and exchange of
information about child welfare issues, legal issues, political issues, constitutional issues,
family issues and more, and on social media sites such as YouTube.
780. There exist hundreds, if not thousands, of web sites, blogs, groups, forums, videos and
other Internet properties owned and operated by hundreds if not thousands of diverse
groups, individuals, organizations and entities that are directed to this market and to the
25
Which opportunity is often exploited in gang-fashion by the defendants to promote
their agendas and organizations, and to libel and defame my products, professionalism and
business, as described herein.

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public in general where relevant information is available.

781. The interactive online groups have anywhere from five to over a thousand members.
Communications to this groups are frequently forwarded to other groups and individual
over and over, saturating the market with the information contained in the forwarded
posts.
782. Most people have a computer and Internet access, or can acquire Internet access through
friends, public libraries, cell phones, tablets and other resources.
783. The Internet is the contemporary advertising alternative to purchasing television air time
or ads in magazines and newspapers, or even leafleting.
784. Internet search engines make finding anyone’s presence anywhere on the Internet simple
and effective, no matter who wrote and published the content about you.
785. These engines also make it very simple for potential customers to find the products and
services they are seeking, or to discover products and services that are not available in
their community or never even knew existed and to find providers who offer the goods
and services they want.
786. Internet advertising and promotion is affordable–often free– and reaches a far wider
audience than any other method of promotion and advertising, and is more directed to the
proper market than other advertising methods.
787. The Internet fosters competition, and it fosters abuses of the competitive market.
788. Defendants advertise and provide goods and/or services to the public and to consumers
and/or professionals involved with Child Protective Services investigations and court
cases nationwide on the Internet and in other traditions and non-traditional mediums.
789. I advertise and provide goods and/or services to consumers and/or professionals and/or
service providers involved with Child Protective Services investigations and court cases
nationwide, using a passive web site and through my participation and membership in

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interactive online groups owned by others. Historically, well over ninety-five percent of
all referrals and requests for my products have come directly or indirectly from my
Internet presence and my participation in groups.
790. These goods and services advertised and offered on the Internet affect interstate
commerce.
791. These goods and services are offered in competition with, and are also offered as
supplemental goods and services to the products offered and provided by state child
protective services (CPS) agencies, CPS agency contractors and alternative and
independent providers of goods and services to consumers of child welfare agencies and
professionals who administer child welfare cases administratively or in the courts across
the nation.
792. The quality of goods and services offered in this market varies greatly, from very good to
very poor and beyond into literally dangerous for consumers.
First Cause of Action
Misappropriation/Theft of Trade Secrets
forth herein.
794. This cause of action includes all defendants except Lloyd Phillips and Alex Bryan.
795. The trade secrets or confidential information (hereinafter refereed to as proprietary
content) included in this claim fall within the definition of formula, patterns, business
plans, compilations of information or technical knowledge which were used in my
business, which were important in my business, which were treated and sought to be
protected as confidential to my business for the purposes of my business, and which
entitles me legitimately, by reason of my exceptional diligence, research, analysis,
technology and discovery to obtain legitimate competitive advantage over competitors,

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including but not limited to the defendants, who did not possess such knowledge or
information and were not able and have proven unable to, legitimately and within a
reasonable time frame, to obtain it otherwise. See ¶50 et. seq.
796. I have made reasonable efforts under the circumstances to maintain the confidentiality of
the Trade Secrets.
797. My trade secrets derive independent economic value from not being generally known to
the public or to other persons who can obtain economic benefit from their disclosure.
798. Defendants’ conduct to appropriate my trade secrets was, is, and remains willful and
wanton, and was undertaken with blatant disregard for my valid and enforceable rights.
799. The defendants improperly obtained these trade secrets illicitly by engaging in long-term
and pervasive campaign designed to induce the breach of known obligations of
authorized users of those trade secrets or to otherwise circumvent the restrictions and
terms I place on the legitimate acquisition and use of that property as described in this
complaint.
800. The improper means employed by the defendants in this misappropriation include theft,
misrepresentation, misappropriation, fraud, breach or inducement of a breach of duty to
maintain secrecy. See ¶ 621
801. Beginning on or about April 4, 2003, the defendants made repeated attempts to
circumvent the restrictions I legitimately placed on anyone accessing or using my trade
secrets and proprietary information no matter the source . See ¶ 619, 431, 1467
802. The defendants entreated authorized users of that proprietary content to abrogate their
contractual obligations related to their possession and use of that information and to give
it to the defendants.
803. The defendants were repeatedly advised that authorized users could not disseminate my
proprietary information to them due to contractual non-disclosure requirements. This

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restriction upset the defendants and they called it tyranny.

804. On August 26, 2004, Hinger stated on AFRA Directors that feedback from attendees at
my seminars was 99.5% positive. He wanted AFRA to create online tutorials and tests
based on my proprietary content to reinforce the training without seeking or obtaining my
permission.
805. On or about February 17, 2005, Durand and Swallow attended a training seminar I
presented in Florida.
806. As a condition of attending that seminar and remaining in the room during the
presentation of the proprietary information, Durand and Swallow signed a non-disclosure
agreement intended to protect the information presented at the seminar as my trade
secrets and proprietary information.
807. Swallow subsequently bragged that she had stolen the signed contract from me at the
presentation and had it in her possession.
808. Durand revealed Swallow had recorded that presentation . Recording was expressly
prohibited at the presentation, and I gave that instruction at the start of the presentation.
Swallow and Durand were present for that instruction.
809. Durand and Swallow knew they were not to disseminate this information to anyone
without my permission.
810. Durand and Swallow disseminated content they were under contractual obligation not to
disseminate.
811. Durand subsequently disclosed that she had received legal advice telling her that she was
bound by the contract, but continued to participate in the conspiracy and misappropriation
covertly.
812. The defendants gained access to and disseminated my proprietary content on the World
Wide Web, via fax and phone lines, through the U.S. Postal Service and via emails.

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813. Baez has admitted gaining access to my proprietary seminar handout in her blog at
http://feedblitz.com/r.asp?l=25719800&f=104839&u=0 wherein she states, “Back in
2005, I received a package in the mail with a Nevada postmark. This package
contained what purported to be a Suzanne Shell seminar handout. Of course I peeked.”
814. On or about April 121, 2006, Durand offered to send A. Dutkiewicz a copy of the seminar
handout, “Aimee, I have a copy, that’s why I asked for your fax number.”
815. On or about April 12, 2006, A. Dutkiewicz published on bashingshell Yahoo! group an
admission of having unauthorized possession of my propriety content,
“Do you think anyone actually read the contract SShitler makes them sign
when they take her seminar. How much of it is really enforceable.... I mean
really. Bren is the only one who was sued and they may at best have won by
default only.... not a real win and certainly not one that allows for any muster
on her part. . .If she were to enforce or attempt to enforce this why hasn't she
gone after anyone else. Because any Judge in their right mind would ROFLTAO
at her. . .Hell I've seen her seminar packet and it ain't worth the paper I wipe
my tushy with...”
816. On or about April 15, 2006, I learned that Wisemen dba Wiseman Studios had published
on thetruthistold.com web site, a copy of the proprietary content I disseminated under the
non-disclosure agreement at the Florida seminar in February, 2005 making it freely
available to anyone who had access to the Internet. I demanded he remove it. He refused.
817. On or about May 19, 2006, I discovered Wiseman had published the proprietary content
on bashing_shell Yahoo! group files section. This gave the defendants on bashing_shell
unfettered access to my proprietary information. They took it, disseminated it to other
defendants, and used it. I demanded he removed it. He refused.
818. During this same time, Wiseman published my this protected information to the files
section of CenCom, making it freely available to those who had been seeking it for years.
819. By these publications of my proprietary content, the defendants acquired my trade secrets
illicitly.

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820. Wiseman admitted in court documents submitted in Tower v. Shell, In the Superior
Court, County of Sacramento, case no. 06AS03504, that he had obtained the proprietary
documents he published on his web site from Swallow. See Exhibit E - Wiseman Motion.
821. I request the court to take judicial notice of this admission, and of the writing skills and
comprehension demonstrated by Wiseman as shown by the content of this document.
822. By virtue of their illicit and unauthorized publications and distributions, the defendants
did acquire, without authorization, my trade secrets and proprietary information and
subsequently used it in their business operations and disseminated it widely amongst
themselves and to the world.
823. In document #141, Contreras admitted to obtaining my proprietary seminar handout,
without permission or authorization from me. This document is merely an outline, and
contains planted false information which the defendant disseminated authoritatively
thinking it was valid information, demonstrating that she also used it without permission,
and with full knowledge she was not entitled to have it. Contreras participates in AFRA
forums, disseminating my proprietary information as services to consumers on those
forums and taking credit for those methods.
824. On or about May 30, 2006, Illinois Family Advocacy Coalition announced a three day
seminar with guest speakers William Tower and Dorothy Baez. The content of this
training looked remarkably similar to my seminars. The presenters had never
demonstrated knowledge of the issues they were planning to teach prior to this
announcement.
825. The defendants also used the proprietary content they acquired as described herein at ¶¶
344, 346, 347, 363, 366, 625, 628
826. The defendants knew or had reason to know that I claimed ownership of the subject
content. My name was written all over the subject content.

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827. Defendants knew or had reason to know that the subject trade secret and proprietary
information was acquired by improper means and that they were expressly excluded from
having legitimate access to it. They had repeatedly and publicly objected to my attempts
to protect my proprietary content and had been advised they were not authorized to have
it.
828. The defendants knew or had reason to know that this disclosure of my trade secrets and
proprietary information was made without my express or implied consent as the owner of
the trade secrets. They and repeatedly and publicly objected to my efforts to limit
dissemination of my proprietary content and discussed methods to circumvent my
restrictions.
829. The defendants knew or had reason to know that their knowledge of this trade secret
information was acquired under circumstances giving rise to another’s duty to maintain
its secrecy or limit its use.
830. It took me ten years to develop this method, and a several more years to refine it all at my
personal expense. The defendants do not possess my analytical skills, some of them can
barely read and write at a high school level. They did not dedicate the time in the field
doing research and hands on application like I did. They did not cultivate the professional
resources I had. They have never demonstrated any independent ability to create anything
original. They have not even demonstrated the ability to take the limited information they
did misappropriate and properly apply it or build upon it. They could never have come
close to developing anything similar to my methods or with the scope of my methods.
831. As a proximate cause of this misappropriation and theft and subsequent dissemination
and use of my trade secrets and proprietary information, defendants have usurped my
hard-earned, legitimately superior market position, and have severely damaged my
business. I have suffered injury and damages including damage to my business and my

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business reputation, loss of my professional reputation, deprivation of my intellectual

property and my rights to control the uses of that property and exploit that property, loss
of stature in the business community, loss of my business and livelihood, loss of
goodwill, diversion of sales, continued, ongoing and far-reaching intellectual property
thefts and infringements, effectuation of new and further thefts and infringements,
depreciation in the value of and ability to sell and license my work, and lost profits and/or
opportunities.
Second Cause of Action
Copyright Infringement
forth herein.
833. All defendants are liable for this cause of action except Lloyd Phillips.
834. I have the following copyrights registered with the U.S. Copyright Office which are
implicated in this claim (certificates of registration attached):
a. TXu1-364-413, June 7, 2007; Family Advocacy Consumer Advisory web site
www.badadvocates.com; jointly registered to Suzanne Shell and to The Editors
@badadvcoates.com, a web site. This copyright registration does not infer
authorship of any of the content contained therein unless expressly stated. This
copyright registration does not signify my ownership of any web site or domain.
b. TX6-404-010; April 10, 2006; profane-justice.org, the entire web site content.
c. TX5-989-070, June 21, 2004; profane-justice.org, the entire web site content.
d. TX5-907-307, March 15, 2004, profane-justice.org, the entire web site content.
e. TX5-677-193; December 2, 2002; Profane Justice: A Comprehensive Guide to
Asserting Your Parental Rights, Second Edition, a book.
f. TX4-842-955; August 24, 1998; Profane Justice: A Comprehensive Guide to
Asserting Your parental Rights, a book.

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g. TXu001588498; October 23, 2008; Unpublished Proprietary Documents - this

registration includes all versions of my proprietary seminar handouts that are
mentioned in this complaint. These documents were never published by me. The
defendants usurped my right of first publication.
835. At all times relevant to this complaint, I have been and still am the owner of all
copyrights in my books, web site, articles and unpublished documents as described above.
I have never assigned, licensed or otherwise transferred my copyright rights to any of the
defendants nor dedicated any of my copyright rights to the public.
836. My web site (http://profane-justice.org) is a collection of discrete documents, each written
at different times, starting in 1996 and continuing to the present. Each document is a
entire work that stands alone, exploring a single subject. The works contained in the web
site are issued separately, organized to be viewed individually and one at a time, and are
designed to be licenced for copying individually. The web site acts as a store front, where
the public can enter and select the individual items they want to read or obtain a license to
use. The documents contained on this site each have been assigned their own,
independent economic value and are not offered for license or use as part of a compilation
or collection. They are presented and offered as separate and distinct individual works.
837. The defendants, with knowledge of my copyrights to my web site, books, articles and
unpublished documents wilfully infringed my rights by repeatedly and continuously
copying, distributing and displaying and otherwise exploiting the infringing content after
being formally placed on notice of my rights.
838. The defendants infringing conduct described herein was never authorized, licensed,
permitted or ratified by me.
839. None of the defendants have registered with the U.S. Copyright Office Identifying their
respective web sites or groups as DMCA-compliant Online Service Provider In

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accordance with 17 U.S.C § 415(c)(2).

840. None of the groups owned and operated by the defendants has any policy to remove
infringing content on their groups, to prohibit copyright infringement, nor do they have
any policy requiring that repeat infringers be removed from their groups.
841. The defendants have knowledge of infringing activity occurring on their groups.
842. The defendants receive financial gain as described in the No Electronic Theft Act for the
infringements that occur on their groups and web sites including receipt, or expectation of
receipt, of anything of value including increased traffic to their Internet sites, increased
patronage, increased market share, increased credibility, increased membership, increased
sales of their products, and including the receipt of other copyrighted works. The
infringing content was intended to be and was designed by me to attract consumers. The
defendants recognized the value of this content and infringed it to attract members, clients
and professionals to their own organizations and groups. As a draw for increasing the
defendants’s client and member base, the infringing content has proven to be very popular
and successful. More consumers become members of AFRA and CPS Watch than any
other family rights organization, and more consumers seek the services, patronize the web
sites, and participate in the online business activities of CPS Watch and AFRA than mine,
attributable to their increasing and expanding infringements. This infringement is not
only committed by AFRA and CPS Watch. AFRA and CPS Watch members and users
also promote these organizations by drawing the public into these organizations with the
promise of quality services–shown by the quality of the infringing content–when the users
redistribute the infringing content to all related online fora and give credit to AFRA
and/or CPS Watch. Finally, CPS Watch and AFRA advocates and consultant appear to
have more credibility and skill than they actually possess by deceiving the market into
believing they created the infringing content and are, therefore, most qualified to provide

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competent goods and services. CPS Watch, AFRA, and the other defendants build their
marketing plans and their businesses based upon infringing my copyrighted content.
843. AFRA and CPS Watch have an express and implied policy, and a long running practice to
engage in wholesale copyright infringement and other misappropriation of intellectual
property belonging to a plethora of authors.
844. Part of this practice as to AFRA is based on Henderson’s refusal to verify sources of
documents he puts up on the AFRA web site so as to properly attribute credit or seek
appropriate permission before copying and displaying. On May 6, 2008, he explained this
to me in and email, “I have no way of knowing who the authors were of the numerous
documents people sent me over the years to compile to help people in trouble.” By this
mechanism, he can garner unwarranted credibility, authority and control over the market
for himself and AFRA, and acquire the lion’s share of Internet traffic to the AFRA web
site(s) and groups.
845. This policy is based, in part, on the erroneous premise that anything published on the
Internet is in the public domain, and they surf the web to find whatever they can to
enhance their message.
846. On or about June 28, 2004, on AFRA_CenCom, Hinger began distributing an image of
the cartoon character Calvin (of Calvin and Hobbs) urinating on the initials “CPS.”
AFRA member Hall subsequently made a request of the copyright holder for permission
to use the image. This request was denied,
“We cannot give the permission you request. Use of the CALVIN AND HOBBES
cartoon feature in the way you describe is unauthorized by Mr. Watterson or
our company and is ILLEGAL. We spend much time and money going after
those who make and distribute "peeing" Calvin images. We are happy that you
will not be added to the list of offenders.” Hinger responded, “well then they
better go after the sign shop franchises that sell them. . .”
AFRA leadership and membership has continued to use and distribute this image in spite

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of being denied permission.26

847. On or about September 13, 2004, Henderson published my 4th Amendment Letter without
permission on CenCom. He did not attributed this article to me. I advised him it was mine
and asked him to remove it. Subsequently, this same letter came periodically came
through AFRA groups submitted by a variety of AFRA members, and Henderson would
place it on AFRA’s web site and not attribute this document to me, and not prevent
infringement by AFRA members. I repeatedly told him it was mine.
848. On or about January 10, 2009, Henderson admitted on Helpline,
“I have been cobbing graphics that strike me as interesting since 1996. I even
cobbed the waving flag .gif off the Whitehouse [sic] website when it was brand
new in ‘96. Clinton never did find out I stole it.27”
849. I have exercised my rights as copyright owner to expressly exclude the defendants from
using my IP after their failures and refusals to properly attribute my content to me, and
after repeatedly, wilfully and maliciously infringing my copyrights. The defendants
believed I did not have the right to exclude them from using my protected content.
850. The infringing content copied by the defendants is impermissibly affixed, displayed and
published on the respective computers, web sites, groups and forums of the defendants,
and on other public fora, all of which are made accessible by the defendants to the entire
world on the Internet, and in their possession as tangible digital or hard copies.
851. Henderson, speaking for AFRA, has provided instruction to its members on it’s groups
how to copy entire web sites without seeking prior permission.
852. As a regular practice, AFRA publishes copyrighted content not authored by Henderson or
AFRA members on the AFRA web site and on AFRA groups without seeking or
26
Hinger as his signature line August 27, 2004;
27
Notwithstanding the fact that government created IP is public domain, this shows
Henderson’s in-your-face intent to wilfully and maliciously infringe.

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obtaining prior permission from the copyright owners, and without properly attributing
the content to the author. Their only concern is getting the information out to the people
who need it, regardless of who wrote it and without proper attribution.
853. The defendants and AFRA members and associates have accepted and endorsed this
policy and practice and used it to justify their pervasive infringing practice on their
respective web sites and online groups and public forums.
854. The defendants deliberately attempt to conceal their infringement from me by denying me
access to their groups for observation. Only group members can access their
transmissions, archives and files sections.
855. The defendants utterly refuse to insure infringement does not occur, becoming hostile and
abusive when anyone dares support copyrights or attempts to enforce their rights under
copyright.
856. On July 31, 2004, Henderson published and advertised on AFRA Directors that I had left
AFRA, and that my efforts to protect my intellectual property was a “problem” for
AFRA.
857. On or about March 18, 2006, T. Dutkiewicz dba Connecticut DCF Watch published a
broadcast email on all AFRA groups and on AFRA affiliate groups, on the express behalf
of AFRA Board of Director member Tower, that my web site was no longer copyrighted.
This publication did not mention that I still held a valid copyright on that content.
858. On or about March 19, 2006, AFRA’s new president, Gregory Hession, negotiated an
agreement between myself and Mr. Hession, wherein, inter alia, Mr. Hession would
establish and enforce a policy for AFRA and its members designed and intended to
protect the intellectual property rights of anyone.
859. W. Tower, Kiefer, Hinger and others in the AFRA membership and leadership, acting in
collusion with T. Dukiewicz and A. Dutkiewicz, undermined and sabotaged this

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agreement causing Mr. Hession, to resign as president of AFRA.

860. W. Tower was later appointed President and CEO of AFRA.
861. On April 25, 2006, AFRA published an express policy on AFRA groups stating that
articles from any web resource could be re-published on their groups.
862. On or about May 20, 2006, I was advised by my web host that the web site tracking
programs indicated the defendants were engaging in copying my web site content.
863. On September 26, 2006 Executive Vice President of AFRA Hinger published a broadcast
message on all AFRA groups, and to a list of private individuals, that I had lost all rights
to claim any copyright protections, and expressly encouraged the public to infringe my
copyrights.
864. Hinger also advised users on AFRA groups how to prevent their Internet Service
Providers (ISPs) from removing my copyrighted content from their web sites and groups
when I made copyright infringement claims against them to their ISPs. As a result, ISPs
have refused my copyright infringement takedown demands. This email was disseminated
directly to Henderson, Baez, Wiseman, Contreras, M. Cygan and all AFRA online
interactive groups.
865. Bryan engages in wilful acts of infringement, and encourages others to infringe as part of
his political activism against copyright protections for online content.
866. On or about May 2, 2007, Mark’s Blog, http://markdarb.blogspot.com/, published a
communique from “Comrade Ringo Kamens” discussing an encryption key which had
been broken allowing infringers to copy copy-protected DVDs. Bryan included the
copyright circumvention key to decrypt movies and encouraged others to distribute the
key far and wide. Bryan also wanted to be advised if anyone disseminating the key was
threatened with legal action or sued and provided his email address.
867. On or about June 7, 2007, Bryan submitted a comment to The Editors at

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badadvocates.com, saying “I thought you might want to add me, I’ve been doing a
campaign against you for a while. http://binaryfredom.info/node/136. Comrade Ringo
Kamens.” His link goes to a page authored by him that solicits the public to infringe my
copyright:
“Did you view a copy of her website? Did it get put in your browser cache? Did you
copy it to another directory? Did you print off a copy? Did you view her site in the
frame of another site? Did you visit her site from digg? If so, you are, according to
her, violating the law. Tell her you did it so she can sue and arrest all of us!”
868. Barnes has stealthily built CPS Watch on my methods and copyrighted content, passing it
off as her original work while excluding me from observing her business operations.
Much of her business is conducted via telephone and private electronic communications.
869. There are multiple instances of copyright infringement by the defendants occurring
between 2000 and 2009, including but not limited to:
a. On October 28, 2008, I discovered that or about June 5, 2004, AFRA member and
agent Linda Weston impermissibly published infringing content on
AFRA_Helpline from my copyrighted web site. She published it verbatim and in
its entirety, the document Letter to Attorney (registration ¶834.d here, ¶834.c here
and ¶834.b here. ). This document was not attributed to me, and is one of my
copyrighted marketing documents from my web site. This content is still on that
web site as message # 4181. I had requested and was denied access to this group,
and could not discover the infringement prior to this date. Yahoo! failed and
refused to honor my copyright infringement notice. This infringement is ongoing.
Weston was asked by AFRA member and agent Christi Amtower for permission
to disseminate. Weston said, “Be my guest I am going to also post it on other
groups.” This letter was not attributed to me. I did not give Weston or AFRA
permission to copy or disseminate it. This document is still available in the group

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archives. The AFRA BOD and moderators had been repeatedly notified this was
my copyrighted content, and did nothing to prevent this infringement. By
presenting this infringing document as their own, AFRA and Henderson intended
to increase membership, web site traffic, stature, credibility and market share.
b. This letter was subsequently copied in its entirety from that group by AFRA
member and agent Christy Amtower and republished on the web site at
http://www.geocities.com/family_rights_wv?sample_letters.html with credit given
to Linda Weston. This document was not attributed to me, and is one of my
copyrighted marketing documents. It was still displayed as of October 28,2008.
This infringement is ongoing. The ISP refused to remove the infringing content
pursuant to my copyright infringement notice based on the instructions provided
to AFRA membership by Hinger.
c. I discovered my copyrighted 4th Amendment Letter (first registration ¶834.f here,
subsequently included in all web site registrations ¶834.d, 834.c. 834.c, 834.b)
from my web site published on the AFRA web site on November 13, 2005. This
document was not attributed to me, and is one of my copyrighted marketing
documents from my web site and in my book. It was copied and disseminated
verbatim in its entirety.
d. I discovered my copyrighted Letter to Attorney, ¶ 869.a here impermissibly
published on the AFRA web site on November 13, 2005, verbatim or substantially
similar, in its entirety and is one of my copyrighted marketing documents from my
web site.
e. I discovered my copyrighted Treatment Plan Objection (first web site registration
¶834.d here) impermissibly published on the Child Protection Reform28 Yahoo!
28
This group has about a thousand members

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group on January 6, 2006. (I was not a member of this group and did not have
access to files). It was copied verbatim in its entirety and disseminated by AFRA
member and agent cha/kwaina chakwaina@comcast.net. It remains in the
archives of this group and constitutes an ongoing infringement.
f. On March 10, 2006, Kiefer impermissibly published distinctive copyrighted
verbatim content ¶1457, (first registration ¶834.d here, subsequently included in
all web site registrations) from my web site on an online forum to promote
himself and his radio show. He continued to use this content for several months
on AFRA groups and other groups, despite cease and desist demands, including
one written by an attorney.
g. On March 14, 2006, Wiseman circumvented copy protections on my web site and
impermissibly copied and distributed on AFRA groups and an email list complete
verbatim copies of four discrete, stand-alone documents and/or articles from my
copyrighted web site on AFRA_CenCom Yahoo! Group. The articles were
entitled Advocate Warning, Follow Up on Advocate Warning dated Aug. 12, 2003
(first registration ¶834.c here), another followup to Follow Up on Advocate
Warning, dated February 20, 2005 (registration ¶ 834.b here) and my Seminar
page (registration ¶ 834.b here).
h. On or about March 18, 2006, W. Tower impermissibly copied and distributed
verbatim content from the article about Dutkiewicz’s in its entirety from the
Consumer Advisory page when it was on my web site (registration ¶ 834.a here)
to multiple AFRA groups and affiliate groups. On August 2, 2006, he admitted to
my associate in an email that he had copied and pasted and sent it to AFRA.
i. On or before April 11, 2006, Wiseman and defendants assisting Wiseman
impermissibly circumvented copy protections that I had installed on my web site

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and copied the verbatim contents of my entire web site www.profane-justice.org

(registration ¶ 834.b here) and displayed it on his web site, thetruthistold[dot]com
at “A shelly link” button. This was still displayed as of May 11, 2006. This
impermissible copying include bypassing membership restrictions and making my
paid membership pages available for free. In document #6 and #273 of this
lawsuit, Wiseman admits copying my entire web site and placing it on his web
site. When this happened, he was asked how he circumvented the copy
protections. He said he was a good web site builder.
j. I discovered that Henderson had impermissibly published a discrete article and/or
document from my web site, Letter to Attorney, ¶869.k, 869.a, on September 24,
2006. This article was not attributed to me, AFRA took credit for it. It is still
displayed at archive.org in dozens of locations including
http://web.archive.org/web/20030619182720/familyrightsassociation.com/bin/FO
RMS/contract_for_appointed.htm. This infringement was ongoing since before
2003.
k. This document, Letter to Attorney, ¶869.a, 869.k, was copied verbatim and in its
entirety and disseminated by Henderson on September 24, 2006, to all members
on AFRA_ CenCom on as message #8526 and remains in the group archives to
this day. It was not attributed to me, Henderson and AFRA took credit for it.
AFRA members and group users have re-distributed this infringing content over
and over. This infringement is ongoing.
l. On June 6, 2007, AFRA agent and member Lisa R. Smith impermissibly copied
an entire article, 4th Amendment Letter, (registration ¶ 834.d) from my web site to
syc Yahoo! group. She gave credit for the letter to Henderson/Oregon Family
Rights. Henderson is a member of syc and did not deny authorship. This letter was

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distributed verbatim, in its entirety and remains in the group archives to this day.
This is an ongoing infringement.
m. In 2007, the document htd.pdf was impermissibly copied on all AFRA groups by
AFRA Director, member and agent Hinger, and also published it on a web site of
his, and is an impermissive derivative work of my copyrighted seminar handout
(registration ¶ 834.g here). It was placed in the files sections of AFRA groups by
Hinger. My demand for AFRA to remove the documents from their files sections
was refused. It is impossible to determine how many copies of this document were
distributed giving credit to Hinger.
n. On October 1, 2007, AFRA BOD, member and agent Kiefer impermissibly copied
an entire article Nazis and CPS (registrations ¶ 834.b here, and ¶ 834.c here, and
¶ 834.d here) and distributed it verbatim on USA_EAGLE, after deliberately
removing my name as author. My cease and desist demand was met with denials
and excuses by W.Tower. This document remains in the group archives to this
day. This is an ongoing infringement.
o. On an unknown date, discovered on October 29, 2008, Wiseman circumvented
copy protections and copied 10 pages from www.profane-justice.org; a copy-
protected document Igeeks.pdf (registration ¶834.b) in its entirety, verbatim, and
converted it to HTML and published it to
http://thetruthistold[dot]com/1internet_geeks.htm. This was done as a result of
Wiseman’s contacts with Bryan and his articles encouraging infringement of my
web site.
p. Bryan advised me on March 17, 2007, that he had printed out a copy of a page on
my web site as an act of civil disobedience (registration ¶834.b). He disseminated
this letter to me to a mailing list and published it on numerous web sites

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encouraging others to do the same. He signed as Ringo Kamens of

BinaryFreedom.info, Centennial, Colorado. He stated,
“True your intellectual property is covered by law however since you're
giving it away for free it seems ridiculous to stop others from providing
copies of it. . .Oh, and I still have the printed copy and Im also am
cross-posting these letters to a mailing list so don’t make statements if
you can’t back them up.”
I was not giving it away for free. There was a license fee for copying and
distributing.
q. Bryan advised me on May 30, 2007, that he had willfully circumvented my copy
protections and copied my entire website (registration ¶834.b here) and affixed it
onto his hard drive, then onto a removable USB drive, and then printed it out
without my permission. Bryan published articles on the World Wide Web, and
links to those articles on numerous web sites, urging the public to infringe my
copyright as he had, which many did.
r. Barnes, CPS Watch, Inc.,Thompson and Howard disseminated and published
Barnes book, A Parent’s Guide to the System, since 2000 and sold it to the public
for $9.95. A Parent’s Guide to the System was a book which was distributed to the
general public, distinctly different from the proposed Technical Assistance
Bulletin purported to be distributed only to CPS Watch members. This book is
also recommended and disseminated by AFRA members on their forums. There
are links to this book on the AFRA defendants’s web sites. This book is an
impermissive derivative work of my unpublished copyrighted (registration ¶834.g
here) works (see ¶679 et. seq. here ) that violates my express licence agreement
with Barnes. The content in this book was heretofore unknown by Barnes, who
had never demonstrated even the most minimal understanding of how to deal with
the issues associated with child welfare. The most recent infringements occur

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when new members join the CPS Watch Yahoo! group. When I joined this group
in 2008, I was sent fan electronic copy of this book upon my membership (under
an alter-ego) being accepted, with instructions to read it. This publication has been
automatically sent to the new members. It is also posted in the CPS Watch group
files section and members are constantly referred to that document and told to
download it. By creating an impermissive derivative work from my content
without properly attributing to me or otherwise complying with the license terms,
defendant Barnes and CPS Watch effectively abrogated to herself and CPS
Watch, my important right of first publication, a marketable subsidiary right. This
is an ongoing infringement.
870. The defendants’s infringements have been committed willfully, and have been and are
being engaged in with total disregard for my intellectual property rights.
871. The defendants are in fact acting egregiously and are not merely engaged in technical
violations of the law. Factors to show that the defendants are acting egregiously include:
(1) defendants engaged in a significant amount of infringement against numerous authors,
and has institutionalized the infringing conduct as a matter of practice; (2) the infringing
activity occurred repeatedly over a lengthy period of time, by placing copies of my and
other author’s intellectual property in their permanent storage and publicly displaying
them; (3) the defendants are so involved in wholesale infringement as to lead unavoidably
to the conclusion that their actions were willful; (4) the defendants’s communications
indicating their intent to infringe reflects their knowledge of the illegality of their
conduct, and/or malice or other criminal intent; and (5) the defendants refused to pay
license fees demanded by me for the property it acquired in violation of my exclusive
rights as copyright owner, (6) the copyrighted works that are the subject of this complaint
belong to a much smaller company or single individual, namely me, whose sole assets

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consist of my intellectual property inventory and whose profitability has certainly been
jeopardized by the defendants’s gang conduct, (7) the defendants refused demands to
remove infringing content and refuse to cease infringing, (8) defendants have instructed
others to infringe, and instructed them how to prevent having their infringing content
removed by their ISP, (9) defendants have deliberately concealed their infringements
from me.
872. The copyright infringement of my web site, books and other literary and works is ongoing
since 2000.
873. Defendants’s infringing conduct has caused and, unless restrained by this Court, will
continue to cause me irreparable injury. I have no adequate remedy at law for
Defendants’s infringement.
874. I am entitled to an injunction restraining Defendants, their officers, agents, and
employees, and all other persons acting in concert with them, from engaging in further
such acts in violation of the federal copyright laws.
875. As a proximate cause of this infringement, I have suffered continued, ongoing and far-
reaching copyright infringement, effectuation of new and further infringements,
depreciation in the value of and ability to sell and license my work, lost profits and/or
opportunities, and damage to my goodwill and reputation.
876. Among the harms suffered by this ongoing infringement is the loss of any incentive to
write or publish, since I am not going to be able to exploit my property as I wish. This
disincentive also harms public policy and the public interest to support the creative arts.
877. The harm to my property interest is irreparable in light of the market confusion associated
with my property and the business which is built upon it.
878. As a proximate cause of this infringement, I have suffered actual and statutory damages.

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Third Cause of Action

Contributory Copyright Infringement
879. I repeat and re-allege the facts in the preceding paragraphs this Complaint as if fully set
forth herein
880. The defendants had knowledge of the aforementioned infringing activity, and induced,
caused or materially contributed to the infringing activity of another.
881. The defendants knew the subject content was copyrighted. They had repeatedly been
advised that the subject content was protected, that it belonged to me, yet they refused to
prevent infringement from occurring on their forums and web sites.
882. The existence of copyright on my site and my enforcement of those rights was hotly
debated on the Internet and the defendants participated in that debate.
883. The defendants also refused to establish or enforce a policy prohibiting their members
from infringing, and requiring them to insure their use was permissive before submitting
content.
884. The defendants knew the particular use violated copyright law. They intended to infringe.
885. The defendants knew of the direct infringement when it occurred by virtue of my repeated
claims to them, to the point where they outright refused to remove infringing content or
prevent or correct infringements.
886. The defendants encouraged or facilitated the infringement and provided multiple
locations accessible to the entire world for the infringing content to be copied, displayed
and infringed further.
887. On or about September 26, 2006, Hinger sent a broadcast email message to all AFRA and
non-AFRA groups, claiming I plagiarized all my intellectual property and instructed
thousands of members how to infringe my copyright and how to prevent their ISPs from
responding to my DMCA demands to remove my copyrighted content from their web
sites and groups. Subsequently, AFRA members infringed my copyrighted work by

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copying and displaying them on their web sites and groups. Defendants are members of
those group and know of the infringement when it occurs.
888. On or about March 19, 2009, on Libervis.com,
http://www.libervis.com/article/binary_freedom_vs_suzanne_shell, a copy of Bryan’s
letter that he had sent to me was included in a call for others to infringe my copyrighted
web site by copying, as an act of civil disobedience.
889. Wiseman (and/or other defendants) was following Bryans’s campaign against my rights
under copyright and commented in support of Bryan as “Anonymous” twice, @2007-03-
29 05:48 and 2007,-03-23 08:44, and included links to thetruthhistold[dot]com.
890. On or about May 30, 2007, Bryan again distributed a mass email directing the public to
http://wiki.binaryfreedom.info/index.php/Arrest_me_Suzanne%21 and encouraging
others to infringe my copyright has he had. He stated he copied my web site to his hard
drive, then onto a removable USB drive, and printed out a copy of my website. He also
visited the “hijacked version of [my] web site published by fifteen year old [Jeff ]
Villiete.”
891. Bryan had, by his first article on March 17, incited Jeff Villiete to infringe, Villiet did
infringe on March 19, and bragged to me and the world that he had infringed, daring me
to sue him. Villiete had established another web site and populated it with my entire web
site. Bryan admitted he patronized the infringing site.
892. The wiki.binaryfreedom link above (¶ 890) directed readers to a page created by Bryan
entitled “Suzanne’s Blacklist.” It stated, “Dear Suzanne Shell, We the undersigned invite
you to sue us and file police reports against us.” The version I have indicates it was
signed by defendants Wiseman and Baez, along with four others and Bryan. This page
has since been removed by Bryan so I don’t know how many other signed. These
signatories indicated that they copied my web site without my permission. Some of them

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described exactly how they infringed. Bryan was thereby advised of these infringements.
893. Bryan enticed Wiseman to copy my web site with his articles and with personal
communications, which Wiseman did, publishing the infringing content on thetruthistold
web sites and on AFRA groups. Bryan intended for Wiseman to infringe and knew of this
copying and displaying. This is especially egregious because Wiseman is a vulnerable
adult susceptible to being misled.
894. See ¶869.b AFRA benefitting when Amtower took my content and disseminated it
again.
895. See ¶869.e, AFRA member disseminating content from AFRA infringements to other
groups, by virtue of AFRA’s enticements to infringe.
896. See ¶869.f, AFRA BOD Kiefer plagiarizing my copyrighted content freely without
restriction on AFRA groups.
897. See ¶869.a, Henderson infringing same document again on AFRA groups.
898. See ¶869.g, Wiseman copying and disseminating my articles on advocacy and my
seminar page. Wiseman knew AFRA would do nothing to prevent him from this
infringement, and felt safe using AFRA groups to infringe.
899. See ¶869.j, Henderson publishing letter to attorney on AFRA groups.
900. See ¶869.l, Smith taking infringing content provided AFRA to other group.
901. See ¶?, Hinger providing plagiarized content to AFRA groups for AFRA benefit.
902. See ¶869.n, Kiefer infringing Nazi article. Kiefer knew AFRA groups were a safe place to
infringe.
903. See ¶869.r, CPS Watch being used to contribute to and facilitate Barnes’s infringement
with Parent’s Guide to the System by distributing it to members for the benefit of the CPS
Watch defendants.
904. The defendants not only expected but invoked infringing use by advertising steps to take

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in support of another’s infringement and accepted infringing content on their web sites
and groups, and are therefore liable for infringement.
employees, members and all other persons acting in concert with them, from engaging in
further such acts in violation of the federal copyright laws.
Fourth Cause of Action
Vicarious Copyright Infringement
forth herein.
912. The defendants had the right and the ability to control any infringer’s acts which occurred
on their respective organizations, web sites, groups and forums as described in this
complaint. Moderators, owners and web master all have the ability to prevent infringing
content from being submitted, and the ability to remove repeat infringers from access to

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their online fora. They did not exercise their authority to prevent infringement by users.
913. See ¶869.a, 869.k, AFRA benefitting from Weston disseminating letter to attorney on
AFRA group.
914. See ¶869.e, AFRA member disseminating content from AFRA infringements to other
groups, enhancing AFRA’s stature and credibility.
915. See ¶869.k, Henderson infringing same document again on AFRA groups for the benefit
of AFRA.
916. See ¶869.j, Henderson publishing letter to attorney on AFRA groups again for the benefit
of AFRA.
917. See ¶869.m, Hinger providing plagiarized content to AFRA groups for AFRA benefit.
918. See ¶869.n, Kiefer infringing Nazi article to benefit AFRA.
919. See ¶869.r, CPS Watch being used to contribute to and facilitate Barnes’ infringement
with Parent’s Guide to the System by distributing it to members for the benefit of the CPS
Watch defendants.
920. On or about May 10, 2007, infringing content Parent’s Guide to the System, ¶869.r, was
uploaded to the files section of AFRA_Talkline by AFRA member and agent bellasmom
at
http://groups.yahoo.com/group/AFRA_TalkLine/files/parents%20guide%20to%20the%2
0system.pdf. AFRA BOD knew this was infringing content and permitted it to be copied
and displayed there. The defendants did nothing to prevent this file being uploaded an
did not cause it to be removed. AFRA benefitted from this infringement by not having to
pay license fees to me for this content and for the reasons stated herein.
921. The defendants receive financial benefit as described in ¶842.

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employees, members and all other persons acting in concert with them, from engaging in
further such acts in violation of the federal copyright laws.
Fifth Cause of Action
Breach of Contract
forth herein.
929. Breach of Contract claims are not preempted because the defendants’s violations are
predicated upon acts incorporating elements beyond mere reproduction or the like,
therefore, my rights involved are not equivalent and preemption will not occur; and this
cause of action does not provide a substitute rule of law, but merely an additional means
of recovery.
Count One
930. On March 11, 2005, Ann Durand, as a condition of attending my training seminar,
entered into an express contract with me wherein she agreed not to copy or distribute any

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written handout, or audio or video recording of a seminar I presented and which she
attended in Ft. Lauderdale, FL, except upon prepayment of license fee of $300,000.00 per
copy or portion thereof. She also agreed that any violation of the terms constitutes Harm
or Injury to me and shall constitute actual damages of $100,000.00 per violation as well
as other penalties which would apply.
931. She received the information from me during the seminar.
932. Durand knowingly and wilfully breached this contract by disseminating at least one copy
and possibly more copies of the written handout to the defendants or others in direct
violation of the terms of the contract without prepaying the license fee.
933. This dissemination was without my authorization.
934. I suffered injury as result of this breach, as described at the end of this cause of action.
Count Two
935. On March 11, 2005, Brenda Swallow, as a condition of attending my training seminar,
entered into an express contract with me wherein she agreed not to copy or distribute any
written handout, or audio or video recording of a seminar I presented ans she attended in
Ft. Lauderdale, FL, except upon prepayment of license fee of $300,000.00 per copy or
portion thereof. She also agreed that any violation of the terms constitutes Harm or Injury
to me and shall constitute actual damages of $100,000.00 per violation as well as other
penalties which would apply.
936. Swallow received the information from me during the seminar.
937. Swallow knowingly and wilfully breached this contract by disseminating at least one copy
and possibly more copies of the written handout to the defendants or others in direct
violation of the terms of the contract without prepaying the license fee.
938. I suffered injury as result of this breach, as described at the end of this cause of action.
939. Defendants Swallow and Durand were bound by the Terms and Conditions of their

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agreement with me concerning the proprietary documents and trade secret methods they
learned at the seminar they attended.
940. In accordance with these contracts, Defendants were only entitled to utilize the methods
only with my authorization. They were not entitled under any circumstance disseminate
the proprietary documents.
941. In accordance with these contracts, Defendants Swallow and Durand were bound to hold
all of my Trade Secrets and proprietary documents in strictest confidence.
942. In breach of their contractual obligations, Defendants Swallow and Durand without my
knowledge or consent have continued to utilize my methods.
943. In breach of their contractual obligations, Defendants Swallow and Durand without my
knowledge or consent have continued to use, disclose and/or share with third parties and
with my competitors my proprietary content and Trade Secrets.
Web Site
944. At all times relevant to this complaint, the .html content of my web site was secured with
copy protection code preventing copying, saving and printing. Any attempt to copy this
protected content was thereby prevented. Copying that was performed by the defendants
involved circumventing this copy protection code.
945. At the time anyone attempted to access a page from my web site, a window popped up
that said, “Copying, printing, saving, or distributing is prohibited without permission.”
The reader must click the “OK” button to close that pop up window.
946. .PDF documents were similarly protected to prevent copying or printing, and also
required a password to open them. This password was provided in the left margin and as
a link to each document which stated, “Password to open all docs is ‘I agree’ indicating
your express agreement to terms of use.” “Term of use” was hyperlinked to the Copyright
Notice and Security Agreement page.

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947. The bulk of the documents on my site were protected .PDF documents.
948. The following counts each represent an instance where the named defendant expressly
and knowingly entered into a contract with me when they performed the affirmative act of
copying, defined and published on my web site as “Copyright notice/security agreement”
(agreement).
949. The terms of this contract were briefly listed at the bottom of every page, in capital
letters, “IF YOU COPY OR DISTRIBUTE YOU ARE ENTERING INTO A CONTRACT.
SEE [hyperlinked to] Copyright Notice and Security Agreement (Read before accessing
this site).”
950. In the same section, “The content if this web site is intended to generate income, it is not
free if you intend to archive, copy, print or distribute anything electronically fixed herein.
Simply put, read, browse, learn freely. Copy, print, save, or distribute - get permission first
or pay.” Emphasis in original.
951. The left margin of every page includes a box [entire box is hyperlinked to Copyright
Notice and Security Agreement] which states, “Looking at & reading this web site is
great. Copying, downloading, distributing, printing or saving is not permitted. Thank you
for respecting intellectual property rights.”
952. In addition, the home page included at the very top states “Terms simply put - read,
browse, learn freely, no strings attached. Copy, print, or save, get permission first or
pay.”
953. There is an express clause in my agreement which states, “Circumvention of copy
protections included in this web site constitutes theft and expressly precludes the user
from asserting any fair use affirmative defense against a claim of copyright
infringement.”
954. There is another express clause in my agreement which states, “Commercial/financial

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gain also includes any act where the User has circumvented copy protections installed on
this site, regardless of the operating system or browser employed by the User.”
955. The terms include an offer to copy or distribute any content on my web site profane-
justice.org in exchange for pre-payment of posted license fees equal to $5,000.00 per
printed page per copy.
956. If the defendant did not want to pay the fee, he had the option to contact me and seek a
fee waiver or a fee reduction and thereby obtain permission to copy. I only provide said
permission in writing.
957. The named defendant(s) expressly accepted the posted offer and agreed to the terms when
he or she affirmatively bypassed the pop-up notices or entered the password in the pop-up
notices and/or circumvented the copy protection code and performed the act of copying,
saving, printing any portion or all of the content displayed on my web site, profane-
justice.org, and/or
958. When he or she distributed my copyrighted content verbatim or as a derivative work on
the location(s) named in the respective count.
959. The act of copying or distributing caused the defendant to receive the consideration
offered.
960. If a person copied without permission or prepaying the fee, the terms included liquidated
damages of $250,000.00 and penalty for failure to prepay of $50,000.00.
961. Ironically, to date, everyone who has asked permission to copy and requested a fee
waiver, and designated an appropriate use and gave proper attribution for that content has
received it both my permission and a fee waiver. It’s not that difficult. The defendants
simply refused to ask permission or give credit.
962. The terms also include a forum selection clause whereby the person who copies agrees,
“User agrees that jurisdiction and venue for all legal actions arising out of this

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agreement shall be initiated and maintained in the home county and state of the copyright
owner”
963. The named defendants circumvented copy protections, and copied without permission
and without prepayment of license fees in violation of the published contract terms,
making them subject to the damages clause in the contract.
964. The named defendants all knew of these terms attached to all my online literary content
because these terms and my content were the subject of frequent, heated debates privately
and on their public forums.
965. They participated in these debates, denouncing me for restricting their use, licensing my
property, and charging excessive fees. They encouraging each other and others to copy
and distribute my content without seeking permission or paying.
966. The defendants provide the vehicles for the tortfeasers to demonstrate their breaches of
contract by allowing them to copy and display the content without hindrance on their web
sites and groups.
Count Three
967. Sometime between March 25, 2007 and October 12, 2007, Wiseman accessed my web
site, copied igeeks.pdf, circumvented copy protections, converted it to .html and
published it at http://thetruthistold.com/1internet_geeks.htm This document is still being
displayed on that web site as of October 29, 2008. This document is six pages. The
copyright terms are clearly stated at the end of the document with a hyperlink to the
agreement page on my web site. He did not seek permission to copy. He did not prepay
the posted license fees or request a fee waiver. He received the consideration I offered,
that being the document. He refused my demand for payment, resulting in this lawsuit. I
was deprived of the license fee associated with his receipt and use of that content, and
deprived of my right to exploit my property to my benefit by licensing the use of that

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content.
Count Four
968. I discovered my copyrighted 4th amendment letter from my web site published on the
AFRA web site by Henderson on November 13, 2005. This document is one page. This
content is from my copyrighted web site and was in violation of the security agreement
described above. This was one of my marketing documents, intended to direct consumers
to me. Henderson did not attribute the document to me. Henderson is the web master, and
the only one responsible for including content on the AFRA web site. Henderson knew of
the terms associated with the use of my web site content. He refused to pay the license fee
or request a fee waiver. He received the consideration, that being the document. I was
deprived of the license fee associated with his receipt and use of that content, and
content. I had already expressly forbidden AFRA from exploiting my IP, including my
web site content, for AFRA and defendants’s benefit.
Count Five
969. I discovered my copyrighted Letter to Lawyer from my web site impressibly published on
the AFRA web site by Henderson on November 13, 2005. This document is four pages.
This was one of my marketing documents, intended to direct consumers to me.
Henderson did not attribute the document to me. Henderson is the web master, and the
only one responsible for including content on the AFRA web site. Henderson knew of the
terms associated with the use of my web site content. He refused to pay the license fee or
request a fee waiver. He received the consideration, that being the document. I was
deprived of the license fee associated with his receipt and use of that content, and
content. I had already expressly forbidden AFRA from exploiting my IP, including my

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web site content, for AFRA’s and the defendants’s benefit.

Count Six
970. I discovered my copyrighted treatment plan objection impermissibly published on the
Child Protection Reform Yahoo! Group on January 6, 2006. (I was not a member of this
group and did not have access to files). It was attributed as being published by AFRA
agent and member cha/kwaina chakwaina@comcast.net. This document is eight pages.
The copyright notice and terms are referenced at the end of the document. I am holding
AFRA responsible for the actions of its agent. AFRA knew of the terms associated with
the use of my web site content. AFRA refused to pay the license fee or request a fee
waiver. AFRA received the consideration, that being the document. I was deprived of the
license fee associated with his receipt and use of that content, and deprived of my right to
exploit my property to my benefit by licensing the use of that content. I had already
expressly forbidden AFRA from exploiting my IP, including my web site content, for
AFRA’s and the defendants’s benefit.
Count Seven
971. On March 10, 2006, Kiefer accessed my web site, circumvented copy protections and
impermissibly published copyrighted content from my web site on an online forum
owned and operated by the defendants to promote himself and his radio show. This
content is one page. Kiefer used it multiple times and distributed to a vast audience. This
was one of my distinctive marketing themes, intended to direct consumers to me. Kiefer
did not attribute the document to me. Kiefer knew of the terms associated with the use of
my web site content. He refused to pay the license fee or request a fee waiver. He
received the consideration, that being the document. I was deprived of the license fee
associated with his receipt and use of that content, and deprived of my right to exploit my
property to my benefit by licensing the use of that content. I had already expressly

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forbidden AFRA and AFRA members from exploiting my IP, including my web site
content, for AFRA’s and the defendants’s benefit.
Count Eight
972. On March 14, 2006, AFRA member and agent Wiseman accessed my web site,
circumvented copy protections on my web site and impermissibly copied and distributed
complete, verbatim copies of four discrete, stand-alone documents about my seminars
and/or articles from my copyrighted web site. He distributed these documents on
AFRA_CenCom Yahoo! group. The documents were entitled Do you Know What to Do
When a Social Worker Knocks on Your Door? (Two pages), Advocate Warning (seven
pages), Follow Up On Advocate Warning (three pages), and another untitled follow up
document (one page) dated February, 20, 2005. Neither AFRA, nor the BOD nor Jackson
exercised any of their authority or control to stop the infringing conduct, or to remove the
infringing contend, therefore I hold AFRA liable for the conduct of its agent(s). I also
hold Wiseman liable. AFRA and Wiseman knew of the terms associated with the use of
my web site content. They refused to pay the license fee or request a fee waiver. They
Count Nine
973. On or about March 18, 2006, AFRA BOD, member and agent W.Tower impermissibly
accessed my web site, circumvented copy protections, and copied and distributed
verbatim content from an article about the Dutkiewicz’s (one page) from the consumer
advisory page on my copyrighted website to multiple groups owned and operated by the

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defendants and on AFRA affiliate groups. I hold W.Tower liable, and AFRA liable for
the act of its agent. AFRA and Tower knew of the terms associated with the use of my
web site content. They refused to pay the license fee or request a fee waiver. They
associated with their receipt and use of that content, and deprived of my right to exploit
my property to my benefit by licensing the use of that content. I had already expressly
Count Ten
974. On or before April 11, 2006, AFRA member and agent Wiseman accessed my web site,
circumvented copy protections and copied the content of my entire web site and
published it on his web site, thetruthistold.com. My web site resolved to hundreds of .pdf
pages. He did not seek permission to copy. He did not prepay the posted license fees or
request a fee waiver. He received the consideration I offered, that being the documents
contained on my web site. He refused my demand for payment, resulting in this lawsuit. I
was deprived of the license fee associated with his receipt and use of that content, and
content. I had already expressly forbidden AFRA and AFRA members from exploiting
my IP, including my web site content, for AFRA’s and the defendants’s benefit.
Count Eleven
975. I discovered that Henderson had impermissibly published a discrete article and/or
document from my web site, Letter to Attorney on September 24, 2006. This article was
not attributed to me, AFRA took credit for it. It is still displayed at archive.org in dozens
of locations including
http://web.archive.org/web/20030619182720/familyrightsassociation.com/bin/FORMS/c

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ontract_for_appointed.htm. This document is four pages. Henderson did not attribute the
document to me. Henderson is the web master, and the only one responsible for
including content on the AFRA web site. Henderson knew of the terms associated with
the use of my web site content. He refused to pay the license fee or request a fee waiver.
He received the consideration, that being the document. I was deprived of the license fee
forbidden AFRA from exploiting my IP, including my web site content, for AFRA’s and
the defendants’s benefit.
Count Twelve
976. On October 1, 2007, AFRA Board member Kiefer impermissibly copied an entire article,
Nazis and CPS, from my web site verbatim on USA_EAGLE, after removing my name as
author. This document is fifteen pages. Kiefer did not attribute the document to me and
published for the benefit of AFRA. Kiefer knew of the terms associated with the use of
my web site content. He refused to pay the license fee or request a fee waiver. He
forbidden AFRA from exploiting my IP, including my web site content, for AFRA’s and
the defendants’s benefit.
Count Thirteen
977. Defendant Bryan advised me on May 30, 2007, that he had accessed my web site,
willfully circumvented my copy protections and copied my entire website onto his hard
drive, then onto a removable USB drive, and then printed it out without my permission in
violation of the terms printed on my web site. He did this as a deliberate act of

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infringement and breach of contract, daring me to sue him for it. My web site resolves to
hundreds of .pdf pages. Bryan knew of the terms associated with the use of my web site
content. He refused to pay the license fee or request a fee waiver. He received the
consideration, that being the documents contained on my web site. I was deprived of the
license fee associated with his receipt and use of that content, and deprived of my right to
exploit my property to my benefit by licensing the use of that content. Bryan breached the
contract knowingly and wilfully as a political statement, and must be held responsible for
the consequences of that political statement. I am not a body politic, I am a private
citizen, and I should not have to suffer this kind of egregious injury so that the defendant
can make a foolish political point at my expense.
978. Defendants were bound by the Terms and Conditions of their agreement with me
concerning the copyright terms published on my web site. If they disagreed with those
terms, their available options included leaving my web site or simply not copying.
979. In accordance with these contracts, Defendants were only authorized to copy the content
with my written authorization or after paying the posted license fee.
980. As a proximate cause of these breaches of contract, I have suffered continued, ongoing
and far-reaching copyright infringements and breaches of contract, effectuation of new
and further infringements and breaches of contract, depreciation in the value of and
ability to sell and license my work, lost profits due to non-payment of license fees, lost
opportunities, theft of property, damage to my goodwill and reputation, damage to my
business and my business reputation, loss of my professional reputation, deprivation of
my property and my rights under copyright to control the uses of that property and exploit
that property, loss of stature in the business community, loss of my business and
livelihood, diversion of sales, and loss of income associated with each breach.
981. I am entitled to liquidated damages pursuant to the terms of use on that were violated.

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Sixth Cause of Action

Tortious Interference with Business Relationship and/or Business Contract
set forth herein.
983. The defendants intentionally interfered with my existing or potential economic relations
for an improper purpose and with improper means as described in this complaint, causing
injury to me.
984. On or about March 2006, W. Tower sent James Williams to a conference29 I was speaking
at to attend my presentation, obtain my proprietary information under false and fraudulent
pretenses and to disseminate said proprietary information to W. Tower in violation of the
non-disclosure agreement in place at that presentation, to which Williams expressly
agreed.
985. W. Tower’s act was intentional and carried out for the purpose of illicitly acquiring my
proprietary content and trade secrets for his use and the use of the other defendants. W.
Tower’s acts were malicious, designed to cause harm to me and my property and
business, and had no economic justification.
986. There existed an express contractual relationship between me and Durand and between
me and Swallow as described in Counts One and Two of the Breach of Contract claim.
987. The defendants had knowledge of that relationship.
988. The defendants intended to induce and did induce Durand and Swallow to breach the
relationship and violate the terms of the contract by disseminating the seminar handout to
them.
989. Durand and Swallow breached the contract and disseminated the seminar handout.
29
Family Law Conference sponsored by A Child Caring Concern in Windsor Locks,
Connecticut.

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990. The defendants’s acts were intentional and carried out for the purpose of illicitly
acquiring my proprietary content and trade secrets for their use and the use of the other
defendants. The defendants’s acts were malicious, designed to cause harm to me and my
property and business, and had no economic justification.
991. There existed other contractual relationships as published on my web site described in
Counts three through fourteen of the Breach of Contract cause of action, wherein the
defendants induced others to breach that contract by encouraging them on public and
private fora to copy my web site content and exhorting the public not to abide by the
terms of that contract by refusing to seek permission and refusing to pay license fees as
described herein.
992. The other defendants were strangers to these contractual relationships and had no right or
authority to induce such a breach.
993. As a proximate cause of this tortious interference with business relationships or contracts,
I have suffered continued, ongoing and far-reaching copyright infringement, effectuation
of new and further infringements, depreciation in the value of and ability to sell and
license my work, lost profits and/or opportunities, theft of property, damage to my
goodwill and reputation, damage to my business and my business reputation, loss of my
professional reputation, deprivation of my property and my rights under copyright to
control the uses of that property and exploit that property, loss of stature in the business
community, loss of my business and livelihood, diversion of sales, and loss of income
associated with the breach.
Seventh Cause of Action
Racketeering or RICO
994. I repeat and re-allege the facts in the preceding paragraphs of the Complaint as if fully set
forth herein.

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995. Racketeering claims are not preempted because the defendants’s violations are predicated
upon acts incorporating elements beyond mere reproduction or the like, therefore, my
rights involved are not equivalent and preemption will not occur; and this cause of action
does not provide a substitute rule of law, but merely an additional means of recovery.
996. Regardless of whether a RICO claim is predicated upon state or federal criminal
violations (or a combination of both), the defendant need not be criminally convicted
before a civil plaintiff can sue for treble damages under RICO. The statute requires only
that the criminal activities are “chargeable” or “indictable” under state or federal law, not
that the defendant has already been charged or indicted.
997. The defendants operate or manage an enterprise or are associated with the enterprise
which is engaged in, or the activities of which affect, interstate or foreign commerce, to
conduct or participate, directly or indirectly, in the conduct of such enterprise's affairs
through a pattern of racketeering activity.
Defendant Persons
998. Named as RICO defendants are defendants American Family Rights Association, Ann
Tower, Leonard Henderson, Susan Adams Jackson aka Susan Wolverton, Cletus Kiefer,
Francine Renee Cygan, Mark Cygan, Illinois Family Advocacy Coalition, Dorothy
Kernaghan-Baez, Georgia Family Rights, Inc., Dennis Hinger, National Association of
Family Advocates, Aimee Dutkiewicz, Thomas Dutkiewicz, Connecticut DCFWatch,
William Wiseman, Wiseman Studios, Dee Contreras, Randall Blair, Brenda Swallow,
Ann Durand, Alex Bryan, Cheryl Barnes, CPS Watch, Inc., Sarah Thompson and Desere’
Clabo.
Victims
999. Victim of the defendants’s pattern of racketeering activity in this action is the plaintiff
Suzanne Shell.

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1000. Victims of the pattern of racketeering activity who are not named in this complaint
include American Family Advocacy Center, Family Rights Advocacy Institute, Sage
Wisdom Press, Effie Belou, A Child Caring Concern, Inc., Kay Henson, Florida Family
Rights Advocacy Institute, Vickie Burris, Citizens for Change, Christine Korn, Colorado
Family Advocacy Institute, Robin Scoins, Arizona Family Rights Advocacy Institute–all
licensees of the copyright content criminally infringed by the defendants–and The Editors
@badadvocates.com (pseudonym for the editors of an online publication to whom the
copyright is pseudonymously registered) . Other known victims include Pearson
Assessments30 (for the MMPI); and Mr. Watterson and Andrews McMeel Universal (for
Calvin and Hobbs); British Broadcasting Corporation31 (for BBC web site content); Mr.
Inkel32 (for web site content).
The Enterprise
1001. At all relevant times, the defendants’s association-in-fact consisting of American Family
Rights Association (AFRA), William O. Tower, Ann Tower, Leonard Henderson, Susan
Adams Jackson Aka Susan Wolverton, Justice for Families (JFF), Keith Fredericks, Tere
Fredericks, Cletus Kiefer, Families at Risk Defense Alliance (FAR), Francine Renee
Cygan, Mark Cygan, Illinois Family Advocacy Coalition (IFAC), Dorothy Kernaghan-
Baez, Georgia Family Rights, Inc. (GAFR), Dennis Hinger, National Association of
Family Advocates (NAFA), Aimee Dutkiewicz, Thomas Dutkiewicz, Connecticut DCF
Watch (CTDCFWatch), William Wiseman, Wiseman Studios, Dee Contreras, Ann
Durand, Nancy Luckhurst, CPS Watch, Cheryl Barnes, Amanda James-Faulkner, Betty
30
March 10, 2004
31
December 10, 2004
32
March 25, 2006

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Kilbride, Brenda Swallow, Desere Clabo, Randall Blair, Kathy Tilly, AFRA_EAGLE aka
USA_EAGLE (USA Eagle), Robert T. McQuaid, Roz McAllister, Christina Amtower,
Alex Bryan, Cheryl Barnes, CPS Watch, Inc., Sarah Thompson and Desere’ Clabo
constituted an “enterprise,” within the meaning of 18 U.S.C. §§ 1961(4) and 1962(c).
1002. The defendants each are an individual “person” within the meaning of 18 U.S.C.
§§ 1961(3) and 1962 (c) and (d), and Colorado Revised Statutes § 18-17-103(4) and §
18-17-104(3) who associated with and/or participated in the conduct of said enterprise’s
affairs.
1003. The Enterprise possesses continuity of structure and personnel, beginning in 2000 and
continuing to the present with an administrative hierarchy and command structure.
1004. This structure was described above, and included the hierarchy of AFRA and the
hierarchy of CPS Watch with certain members of each hierarchy belonging to both
hierarchies and with the AFRA component dominating. It was by this mechanism of
shared members that communications and information used by both organizations were
shared and used in tandem to commit the same or similar predicate acts against me and to
engage in the pattern of racketeering activity.
1005. The defendants are an association-in-fact enterprise in that they are a group of individuals
or legal entities that are linked by the fact or circumstance that they are or were
intertwined as members or affiliates, users or associates of AFRA, CPS Watch and other
child welfare reform organizations, and they share the same purpose.
1006. Members of the Enterprise bear some relationship in that they have a common or shared
purpose both in the geographic United States and on the Internet, through AFRA, CPS
Watch and other child welfare reform groups, and/or through AFRA online groups and
web sites, and/or through AFRA members’s, associates’s, and affiliates’s or other child
welfare reform online groups and web sites for the united purpose to engage in legitimate

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activities related to child welfare reform.

1007. The Enterprise has an ascertainable structure distinct from that inherent in the pattern of
racketeering activity.
1008. If the predicate acts were removed from the situation, the enterprise would cease to exist
and would break into its constituent components to pursue their separate missions in their
separate ways. The enterprise exists solely to engage in a pattern of racketeering activity.
1009. The enterprise is distinct from the defendant persons in that the defendants each conduct
legitimate affairs related to child welfare reform and the promotion of family rights or
parental rights according to their respective organizations’s missions, and also join
collectively under the umbrella of AFRA or CPS Watch separately–each commanding a
different share of the market–to conduct legitimate affairs related to child welfare reform
and the promotion of family rights or parental rights.
1010. Defendants and their co-conspirators constitute a group of person associated together for
the common purpose of carrying out the acts described in this complaint. Defendants used
the Internet, the U.S. mail, wireless and wired telephone for the purpose of executing
their fraudulent scheme, therefore interstate commerce has been affected. Defendants and
their co-conspirators, as part of AFRA and CPS Watch, constitute an association-in-fact
enterprise under 18 U.S.C. §§ 1961(4) and 1962(a) and (c).
1011. The defendants directed, caused, operated or managed other individuals, legal entities, or
a group of individuals to commit a series of crimes which are predicate acts under RICO.
1012. Each of the defendants aided and abetted the racketeering activity of the defendants, as
alleged in this complaint, in that, to at least two of the predicate acts of the racketeering
activity, he or she was associated with the wrongful conduct, participating in it with the
intent to bring it about, and sought by his or her actions to make it successful.
Unlawful Goal of the Enterprise

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1013. The overall purpose and goal of the defendants was to enrich themselves, their co-
conspirators, and those who aided and abetted them by 1) using the enterprise as a tool to
criminally infringe my copyright and use the infringing content for their personal use and
benefit, and 2) using the enterprise to disguise their fraud and infringing conduct and
maintain their ability to continue their scheme.
1014. Defendants enriched themselves by deceiving the consumer and the public that the
infringing content they acquired and offered to the public was owned by them or they had
authorization to use or disseminate it, and by deceiving the public into eschewing my
business and patronizing their organizations where they only offered incomplete, inferior
and dangerous products.
Predicate Acts
1015. I repeat and re-allege the infringing events in the Copyright Infringement claim as if fully
set forth herein, which constitute fifteen predicate acts of criminal copyright infringement
within the past ten years. Each instance of infringement listed has a contractual value of at
least $2000.00 per infringing event.
1016. Additional predicate acts of criminal copyright infringement include:
1017. February 17, 2004 Jackson posted the following admission of infringement referring to
my 4th amendment letter from my web site, “Heigh Ho, Heigh Ho, a-stealing we will go...
duly lifted and placed in our JFF files section, Al!! Best, Sue "The Filch" J. in Mass.”
1018. At the same time, I discovered JFF had also impermissibly copied my letter to lawyer and
placed it in their files section.
1019. JFF had also accepted and displayed infringing content from my web site in five
messages ## 33963, 33962, 33218, 27402, and 27389.
1020. On or about April 6, 2004, I discovered that AFRA member and agent, James Roger
Brown, had impermissibly published on his web site, the sociologercenter.com, an

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evidence book that I had written and published on my web site.

1021. On May 2, 2004, I discovered that defendants T. Dutkiewicz and A. Dutkiewicz had
published infringing content from my copyrighted works on AFRA groups as “Tip of the
Week”and on their web site as a handbook on parent and children’s rights. I advised them
of the infringement and they refused to cease publishing their infringing content.
defendants, who were group owners, refused to prevent future infringement by the
Dutkiewicz’s. They still publish their handbook to this day. This has been an ongoing
infringement.
1022. On or a about August 7, 2004, AFRA CenCom member Cherrie Webb requested a copy
of the letter stating that no government official can talk to your children without their
parents being present. Henderson responded that he published a link to the AFRA Back to
School page containing my 4th Amendment Letter on the AFRA web site front page. He
did this after he had been instructed to remove all of my copyright property from AFRA
publications.
1023. Henderson impermissibly copied an entire article from my web site to AFRA_Cencom
on September 13, 2004.
1024. On April 8, 2005, Henderson impermissibly published an entire document from my web
site in the files section of the AFRA website.
1025. The predicate acts have been committed by The Enterprise continuously since 2000. The
actors have gone to great lengths to conceal their activities and I do not know the full
scope of their criminal copyright infringements against me over the years.
1026. From 2002 continuously to the present, in Colorado and elsewhere, defendants and their
co-conspirators have combined, conspired, agreed and reached tacit understanding with
each other and with others known and unknown to violate 18 U.S.C.; this is to conduct
and participate, directly and indirectly, in the patter of racketeering activity described in

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this complaint.
1027. Defendants have committed, caused to be committed, a series of overt acts in the
furtherance of the conspiracy which was to infringe my copyrights and use the infringing
content for their benefit and enrichment and to hide their misconduct from me to continue
the operations of the enterprise.
1028. The defendants receive “financial gain” as defined in the No Electronic Theft Act for
their criminal copyright infringement, including receipt, or expectation of receipt, of
anything of value, including but not limited to the receipt of other copyrighted works.
1029. Over the course of the conspiracy, for the purpose of executing and in furtherance of the
unlawful scheme described throughout this complaint, defendants knowingly and wilfully
caused (or aided and abetted, counseled or commanded those who caused) to transmit
certain signals and sounds in interstate commerce by means of wire or wireless
communication using the Internet and phone.
1030. Each and every transmission which carried infringing content constitutes an independent
violation of wire fraud:
Mail and Wire Fraud e.g. 18 U.S.C. § 1343. Fraud by wire, radio, or
television and § 1341. Frauds and swindles: The defendants have devised or
intended to devise a scheme or artifice for acquiring intellectual property and
maintaining interest and control in the illegally acquired intellectual property by
means of false or fraudulent pretenses, representations or promises, which scheme
to defraud includes material misrepresentations, or the omission or concealment
of material facts, including conduct which fails to conform to standards of moral
uprightness, fundamental honesty, and fair play, and including conduct calculated
to deceive, whether it be by direct falsehood or by innuendo, by speech or silence,
by word of mouth, by look, or by gesture, including the suppression of the truth,
wherein fraud and deceit arose from the defendants’s silence where there was an
affirmative legal and moral duty to seek permission from the copyright owner
prior to acquiring copyrighted intellectual property, and where the defendants’s
silence associated with its acquisitions and disseminations of that property was
wilful and intentional fraud in order to avoid paying permission license fees or
obtaining permission from the copyright owners thereby causing injury to the
copyright owners and their intellectual property and businesses, when they

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covertly, secretly and stealthily transmitted or caused to be transmitted by means

of wire or other communication in interstate or foreign commerce, any writings,
signs, signals, pictures, or sounds for the purpose of executing such scheme or
artifice of finding and acquiring said intellectual property by means of wire or
other communication and to covertly, secretly and stealthily transmit the stolen
copy of that property to their respective servers or computer systems for their
own use and purposes.
1031. Each and every infringing act constitutes an independent violation of criminal copyright
infringement:
a. 18 U.S.C. § 2319. Criminal infringement of a copyright 17 U.S.C. § 506. By
knowingly and wilfully having caused or allowed to be caused repeated copyright
infringement of Shell’s property and other copyright owners’ copyrighted content
for purposes of commercial advantage or private financial gain e.g. increased
consumer patronage, increased membership, increased sales, market advantage,
donations, unjust enrichment, enhanced reputation, and the expectation of
acquiring intellectual property, etc. - including but not limited to illegally copying,
distributing, displaying and using infringed and stolen intellectual property - or by
the reproduction or distribution, including by electronic means, during any
180-day period, of 1 or more copies of 1 or more copyrighted works, which have a
total retail value of more than $1,000; as described in the Copyright Infringement,
Vicarious Copyright Infringement, and Contributory Copyright Infringement
causes of action above wherein each infringement is contractually established as
having a minimum retail value of $5000.
1032. Each and every act of copyright infringement constitutes an independent violation of
computer crime:
a. § 18-5.5-102(a) C.R.S. Computer crime. By knowingly and wilfully devised,
caused to be devised or perpetuated and expanded an existing scheme to access,
and encouraged accessing the computer, computer network, or computer system
or any part thereof wherein Shell’s web site was situated and exceeded authorized
access to that computer, computer network, or computer system or any part
thereof; or used a computer, computer network, or computer system or any part
thereof without authorization or in excess of authorized access; by illegally
circumventing copy protections installed on her web site content and copying her
web site which exceeded their published authority to do so, and transmitted or
caused to be transmitted the stolen copies of her intellectual property to servers
and computer systems owned an operated by the defendants where it could be
stored, disseminated and displayed.

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b. § 18-5.5-102 (d) Computer Crime. By knowingly and wilfully devised, caused to

be devised or perpetuated and expanded an existing scheme to access, and
encouraged accessing the computer, computer network, or computer system, or
any part thereof, which hosted Shell’s web site, to commit theft of Shell’s
intellectual property e.g. her web site profane-justice.org and theft of her trade
secret and proprietary information.
1033. Between 2000 and the present, and with regard to Shell for the purposes of this
complaint, the defendants conducted, participated in, engaged in, conspired to engage in,
or aided and abetted, the conduct of the affairs of the enterprise through a pattern of
racketeering activity within the meaning of 18 U.S.C. §§ 1961(1), 1961(5) and 1962(c)
and (d) and within the meaning of Colorado Revised Statutes §§ 18-17-103(3), 18-17-
103(5) and 18-17-104(3), the defendants’s pattern of racketeering activity consisted of :
a. Mail and Wire Fraud e.g. 18 U.S.C. § 1343. Fraud by wire, radio, or television
and § 1341. Frauds and swindles as described in ¶ 1030
b. 18 U.S.C. § 2319. Criminal infringement of a copyright 17 U.S.C. § 506 as

described in ¶ 1031.a
c. § 18-5.5-102(a) C.R.S. Computer crime as described in ¶1032.a.
d. § 18-5.5-102(d) C.R.S. Computer Crime as described in ¶1032.b
1034. At all relevant times, the enterprise alleged herein was engaged in, and the defendants’s
activities affected, interstate commerce and foreign commerce.
1035. All of the predicate acts described herein were related so as to establish a pattern of
racketeering activity, within the meaning of 18 U.S.C. § 1962(c) and (d) and § 18-17-
104(3) C.R.S., in that their common purpose was to infringe copyrights and acquire
intellectual properties by theft and/or fraud; their common result was to infringe
copyrights, including but not limited to my copyrights, and acquire intellectual property,
including my property, to deprive me of the benefits of that property, including but not
limited to my intellectual property, by theft and/or fraud; the defendants, personally or
through their actors or agents, directly or indirectly, participated in all of the acts and

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employed the same or similar methods of commission; I was the victim of the acts of
racketeering; and/or the acts of racketeering were otherwise interrelated by distinguishing
characteristics and were not isolated events.
1036. All of the predicate acts described herein were continuous so as to form a pattern of
racketeering activity in that:
a. The defendants engaged in the predicate acts over a substantial period of time; or
b. The patterns of racketeering activity engaged in by the defendants continues or
threatens to continue because the such conduct has become a regular way of
conducting the defendants’s respective on-going business activities.
1037. As a result of the defendants’s scheme of omissions, false representations, criminal
copyright infringement and computer crimes, the defendants have injured me as described
in this complaint.
Count One
Henderson
1038. Henderson is an individual “person,” within the meaning of 18 U.S.C. §§ 1961(3) and
1962(c), Colorado Revised Statutes § 18-17-103(4) and § 18-17-104(3) who associated
with and/or participated in the conduct of said enterprise’s affairs.
1039. Between May 2002 and November 2008, Henderson conducted, participated in, engaged
in, conspired to engage in, or aided and abetted, the conduct of the affairs of the
enterprise through a pattern of racketeering activity within the meaning of 18 U.S.C. §§
1961(1), 1961(5) and 1962(c) and (d). Henderson’s pattern of racketeering activity
consisted of:
a. Mail and Wire Fraud e.g. 18 U.S.C. § 1343. Fraud by wire, radio, or
television and § 1341. Henderson knowingly or intentionally devised a scheme or
artifice for acquiring intellectual property and maintaining interest and control in
the illegally acquired intellectual property by fraud, and encouraged others to
covertly, secretly and stealthily transmit the stolen copy of that property to the
respective servers or computer systems of other defendants for their own use and

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purposes and to AFRA’s servers or computer systems for storage and display and
dissemination.
b. 18 U.S.C. § 2319. Criminal infringement of a copyright 17 U.S.C. § 506.
Henderson established and implemented the policy endorsing wholesale copyright
infringement, with a focus on infringing my intellectual property to be used for the
benefit of AFRA and AFRA members, affiliates and associates and to cause injury
to my intellectual property and my business. He accepted and published and
disseminated and caused to be disseminated infringing content on all AFRA web
sites, forums and groups and advised members, affiliates and associates how to
infringe copyrights.
c. § 18-5.5-102(a) C.R.S. Computer crime. Henderson knowingly and wilfully
devised, caused to be devised or perpetuated and expanded an existing scheme to
access, and encouraged accessing the computer, computer network, or computer
system or any part thereof wherein Shell’s web site was situated and exceeded
authorized access and or encouraged and instructed others to exceed authorized
access to that computer, computer network, or computer system or any part
thereof; or used a computer, computer network, or computer system or any part
thereof without authorization or in excess of authorized access; by illegally
circumventing copy protections installed on my web site content and copying my
web site which exceeded his and others authority to do so, and transmitted or
caused to be transmitted the stolen copies of my intellectual property to servers
and computer systems owned and operated by the defendants where it could be
stored, disseminated and displayed.
d. § 18-5.5-102 (d) C.R.S. Computer Crime. By knowingly and wilfully devised,
caused to be devised or perpetuated and expanded an existing scheme to access,
and encouraged accessing the computer, computer network, or computer system,
or any part thereof, which hosted Shell’s web site, to commit theft of Shell’s
intellectual property e.g. her web site profane-justice.org and theft of her trade
1040. American Family Rights Association (AFRA), William O. Tower, Ann Tower, Susan
Adams Jackson Aka Susan Wolverton, Justice for Families (JFF), Cletus Kiefer, Keith
Fredericks, Tere Fredericks, Cletus Kiefer, FAR Defense Alliance, Francine Renee
Durand, Brenda Swallow, Nancy Luckhurst, Randall Blair, Kathy Tilly, Alex Bryan,
Cheryl Barnes, CPS Watch, Inc., Sarah Thompson and Desere’ Clabo violated section

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1962(d) in that they they knowingly furthered, advanced or participated in Henderson’s

1962 violation within the meaning of 18 U.S.C. § 1962 (d).
1041. These acts all occurred after the effective date of RICO and more than two such acts
occurred within ten years of one another.
Count Two
Kiefer
1042. Kiefer is an individual “person,” within the meaning of 18 U.S.C. §§ 1961(3) and
1962(c), and Colorado Revised Statutes § 18-17-103(4) and § 18-17-104(3), who
associated with and/or participated in the conduct of said enterprise’s affairs.
1043. Between May 2002 and November 2008, Kiefer conducted, participated in, engaged in,
conspired to engage in, or aided and abetted, the conduct of the affairs of the enterprise
through a pattern of racketeering activity within the meaning of 18 U.S.C. §§ 1961(1),
1961(5) and 1962(c) and (d). Kiefer’s pattern of racketeering activity consisted of:
television and § 1341. Kiefer knowingly or intentionally devised or perpetuated
and expanded an already devised scheme or artifice for acquiring intellectual
property and maintaining interest and control in the illegally acquired intellectual
property by means of false or fraudulent pretenses. Kiefer exploited Wiseman dba
Wiseman Studios to accomplish his fraud, and to accomplish the purpose of
executing such scheme or artifice of finding and acquiring said intellectual
property by means of wire or other communication and to covertly, secretly and
stealthily transmit the stolen copy of that property to Wiseman’s dba Wiseman
Studios’ servers or computer systems for their own use and purposes and to
AFRA’s servers or computer systems for storage and display.
Kiefer knowingly and wilfully caused or allowed to be caused repeated copyright
infringement of Shell’s property by Wiseman dba Wiseman Studios on
Wiseman’s web site, the truthistold.com. He further orchestrated the escalation of
copyright infringement against me by other defendants.
c. 18 U.S.C. § 2319. Criminal infringement of a copyright 17 U.S.C. § 506.
Kiefer knowingly and wilfully caused or allowed to be caused repeated copyright
infringement of Shell’s property on other defendants’s web sites and online
groups. He further orchestrated the escalation of copyright infringement against
me by other defendants.
d. § 18-5.5-102(a) C.R.S. Computer crime. Kiefer knowingly and wilfully

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access my information, and transmitted or caused to be transmitted the stolen

copies of her intellectual property to his, Wiseman’s and AFRA’s own servers and
computer systems where it could be stored and displayed.
e. § 18-5.5-102 (d) C.R.S. Computer Crime. Kiefer knowingly and wilfully
devised, caused to be devised or perpetuated and expanded an existing scheme
exploiting Wiseman to access, and encouraged accessing the computer, computer
network, or computer system, or any part thereof, which hosted Shell’s web site,
to commit theft of Shell’s intellectual property e.g. her web site profane-
justice.org.
1044. American Family Rights Association (AFRA), Leonard Henderson, William O. Tower,
Ann Tower, Susan Adams Jackson Aka Susan Wolverton, Justice for Families (JFF),
Keith Fredericks, Tere Fredericks, FAR Defense Alliance, Francine Renee Cygan, Mark
Cygan, Illinois Family Advocacy Coalition (IFAC), Dorothy Kernaghan-Baez, Georgia
Family Rights, Inc. (GAFR), Dennis Hinger, National Association of Family Advocates
(NAFA), Aimee Dutkiewicz, Thomas Dutkiewicz, Connecticut DCF Watch
(CTDCFWatch), William Wiseman, Wiseman Studios, Ann Durand, Brenda Swallow,
Nancy Luckhurst, Randall Blair, Kathy Tilly, Alex Bryan, violated section 1962(d) in that
they they knowingly furthered, advanced or participated in Kiefer’s 1962 violation within
the meaning of 18 U.S.C. § 1962 (d).
Count Three
Hinger
1046. Hinger is an individual “person,” within the meaning of 18 U.S.C. §§ 1961(3) and
1962(c), and Colorado Revised Statutes § 18-17-103(4) and § 18-17-104(3), who
1047. Between May 2003 and November 2008, Hinger conducted, participated in, engaged in,
1961(5) and 1962(c) and (d). Hinger’s pattern of racketeering activity consisted of:

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television and § 1341. Hinger knowingly or intentionally devised or perpetuated
property by means of false or fraudulent pretenses. Hinger encouraged or caused
the defendants’s and Wiseman’s dba Wiseman Studios’s silence associated with
their illicit acquisitions of that property, and provided the information needed to
illicitly acquire the property, and provided instructions to store and display an
disseminate the illicitly acquired property. Hinger assisted and exhorted Wiseman
dba Wiseman Studios to covertly, secretly and stealthily transmit or cause to be
transmitted by means of wire or other communication in interstate or foreign
commerce, any writings, signs, signals, pictures, or sounds for the purpose of
executing such scheme or artifice of finding and acquiring said intellectual
property by means of wire or other communication and to covertly, secretly and
stealthily transmit the stolen copy of that property to Wiseman’s dba Wiseman
Studios’s servers or computer systems for their own use and purposes and to
AFRA’s servers or computer systems for storage and display and dissemination.
Hinger knowingly and wilfully caused or allowed to be caused repeated copyright
infringement of Shell’s copyright. He exploited the illicit access to her content by
creating and offering to the public unauthorized derivative works based on her
trade secret and proprietary information which was provided to him by other
defendants. He also encouraged others to commit copyright infringement my
advising them that I had no copyright protections, and instructing them how to
avoid having infringing content removed pursuant to a DMCA claim.
c. § 18-5.5-102(a) C.R.S. Computer crime. Hinger knowingly and wilfully
devised, caused to be devised or perpetuated and expanded an existing scheme of
computer crime association with the fraudulent acquisition of Shell’s property
d. § 18-5.5-102 (d) C.R.S. Computer Crime Hinger knowingly and wilfully
system, or any part thereof, which hosted Shell’s web site, to commit theft of
Shell’s intellectual property e.g. her web site profane-justice.org and her trade
Ann Tower, Susan Adams Jackson Aka Susan Wolverton, Cletus Kiefer, FAR Defense
Alliance, Francine Renee Cygan, Mark Cygan, Illinois Family Advocacy Coalition
(IFAC), Dorothy Kernaghan-Baez, Georgia Family Rights, Inc. (GAFR), National
Association of Family Advocates (NAFA), Aimee Dutkiewicz, Thomas Dutkiewicz,
Connecticut DCF Watch (CTDCFWatch), William Wiseman, Wiseman Studios, Ann
Durand, Brenda Swallow, Nancy Luckhurst, Randall Blair, Kathy Tilly, Alex Bryan,

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violated section 1962(d) in that they knowingly furthered, advanced or participated in

Hinger’s 1962 violation within the meaning of 18 U.S.C. § 1962 (d).
occurred within ten years of one another..
Count Four
Barnes
1050. Barnes is an individual “person,” within the meaning of 18 U.S.C. §§ 1961(3) and
1051. Between 2000 and 2009, Barnes conducted, participated in, engaged in, conspired to
engage in, or aided and abetted, the conduct of the affairs of the enterprise through a
pattern of racketeering activity within the meaning of 18 U.S.C. §§ 1961(1), 1961(5)
and 1962(c) and (d). Barnes’s pattern of racketeering activity consisted of:
television and § 1341. Barnes knowingly or intentionally devised a scheme or
artifice for acquiring my intellectual property and maintaining interest and control
in the acquired intellectual property by fraud, and encouraged others to covertly,
secretly and stealthily transmit the stolen copy of that property to the respective
servers or computer systems of the defendants and of her membership or by using
the U.S. Mail, for their own use and purposes and to defendants’s servers or
computer systems for storage and display and dissemination.
Barnes advanced the policy endorsing wholesale copyright infringement, with a
focus on infringing my intellectual property to be used for the benefit of CPS
Watch and AFRA members, affiliates and associates and to cause injury to my
intellectual property and my business.
1052. American Family Rights Association (AFRA), William O. Tower, Ann Tower, Susan
Adams Jackson Aka Susan Wolverton, Justice for Families (JFF), cletus Kiefer, Keith
Fredericks, Tere Fredericks, Cletus Kiefer, FAR Defense Alliance, Francine Renee

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Durand, Brenda Swallow, Nancy Luckhurst, Randall Blair, Kathy Tilly, CPS Watch, Inc.,
Sarah Thompson and Desere’ Clabo violated section 1962(d) in that they they
knowingly furthered, advanced or participated in Barnes’s 1962 violation within the
meaning of 18 U.S.C. § 1962 (d).
Count Five
Jackson
1054. Jackson an individual “person,” within the meaning of 18 U.S.C. §§ 1961(3) and
1962(c),and Colorado Revised Statutes § 18-17-103(4) and § 18-17-104(3), who
1055. Between May, 2003 and November 2008, Jackson conducted, participated in, engaged in,
1961(5) and 1962(c) and (d). Jackson’s pattern of racketeering activity consisted of:
television and § 1341.. Jackson knowingly or intentionally devised or perpetuated
property by means of false or fraudulent pretenses. She was instrumental in
acquiring much infringing intellectual property by means of wire or other
communication and to covertly, secretly and stealthily transmit the stolen copy of
that property to JFF and AFRA groups. In fact, JFF’s infringing conduct, under
Jackson’s oversight, was so egregious that Yahoo! was compelled to shut the
group down due to repeated copyright infringement complaints. Jackson also had
oversight over AFRA’s servers or computer systems for storage and display an
dissemination of infringing content.
Jackson knowingly and wilfully caused or allowed to be caused repeated
copyright infringement of my property and other copyright owners copyrighted
content for purposes of commercial advantage or private financial gain, often

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bragging about stealing other’s protected content. She provided online locations,
safe from my scrutiny, to display and disseminate her illicitly acquired infringing
content.
c. § 18-5.5-102(a) C.R.S. Computer crime. Jackson knowingly and wilfully
system or any part thereof wherein Shell’s web site was situated and exceeded
authorized access to that computer, computer network, to steal intellectual
property.
d. § 18-5.5-102 (d) C.R.S. Computer Crime Jackson knowingly and wilfully
system, or any part thereof, which hosted Shell’s web site, to commit theft of
Shell’s intellectual property e.g. her web site profane-justice.org.
Ann Tower, Dennis Hinger, Justice for Families (JFF), Keith Fredericks, Tere Fredericks,
Cletus Kiefer, FAR Defense Alliance, Francine Renee Cygan, Mark Cygan, Illinois
Family Advocacy Coalition (IFAC), Dorothy Kernaghan-Baez, Georgia Family Rights,
Inc. (GAFR), National Association of Family Advocates (NAFA), Aimee Dutkiewicz,
Thomas Dutkiewicz, Connecticut DCF Watch (CTDCFWatch), William Wiseman,
Wiseman Studios, Ann Durand, Brenda Swallow, Nancy Luckhurst, Randall Blair, Kathy
Tilly, violated section 1962(d) in that they they knowingly furthered, advanced or
participated in Jackson’s 1962 violation within the meaning of 18 U.S.C. § 1962 (d).
Count Six
Bryan
1058. Bryan is an individual “person,” within the meaning of 18 U.S.C. §§ 1961(3) and
1059. Between 2007 and 2009, Bryan conducted, participated in, engaged in, conspired to
engage in, or aided and abetted, the conduct of the affairs of the enterprise through a

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pattern of racketeering activity within the meaning of 18 U.S.C. §§ 1961(1), 1961(5)

and 1962(c) and (d). Bryan’s pattern of racketeering activity consisted of:
television and § 1341. Bryan knowingly or intentionally devised a scheme or
artifice for acquiring my intellectual property and maintaining interest and control
in the acquired intellectual property by fraud, and encouraged others to covertly,
secretly and stealthily obtain and transmit stolen copies of that property to the
respective servers or computer systems of others, or by using the U.S. Mail, for
their own use and purposes and to his, or defendants’s, or others’s servers or
computer systems for storage and display and dissemination.
Bryan advanced the policy endorsing wholesale copyright infringement, with a
focus on infringing my intellectual property to be used to cause injury to my
intellectual property and as a means of proving that copyright protections on
digital content were invalid. He caused Wiseman dba Wiseman Studios to
infringe my copyrighted web site content and encouraged him to publish it on his
web site. He also encouraged the general public to infringe my copyright in
similar manner, which infringements occurred on a wholesale basis.
c. § 18-5.5-102(a) C.R.S. Computer crime. Bryan knowingly and wilfully
system or any part thereof wherein my web site was situated and exceeded
authorized access to that computer, computer network, to steal intellectual
property.
d. § 18-5.5-102 (d) C.R.S. Computer Crime. Bryan knowingly and wilfully
system, or any part thereof, which hosted my web site, to commit theft of Shell’s
intellectual property e.g. her web site profane-justice.org.
1060. William Wiseman, Wiseman Studios, Dorothy Baez, and other unnamed defendants
violated section 1962(d) in that they knowingly furthered, advanced or participated in
Bryan’s 1962 violation within the meaning of 18 U.S.C. § 1962 (d).
1062. As a direct and proximate result of, and by reason of, the activities of the defendants and
their conduct in violation of 18 U.S.C. §§ 1962(c) and (d) and § 18-17-104(3) C.R.S., I
have been injured in my business or property, within the meaning of 18 U.S.C. § 1964(c)

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and § 18-17-106(7) C.R.S. Among other things, I have suffered damages to the extent
the defendants infringed my copyrights and incited others to infringe my copyrights, and
illegally obtained my copyrighted intellectual property and copyrighted proprietary
content by theft and exploited it, and exercised dominion and control over that property,
deprived me of dominion and control of that property, deprived me of my rights to exploit
my property, and refused to pay license fees for the acquisition and use of that property
and deprived me of the use and benefit of that property and harmed my business and
property. I am, therefore, entitled to recover threefold the damages I have sustained
together with the cost of the suit, including reasonable attorneys’ and experts’ fees.
Eighth Cause of Action
False and Misleading Advertising
§43(a) of the Lanham Act, 15 U. S. C. §1125(a)
forth herein.
1064. All defendants are liable for the injuries and harms named in this cause of action.
1065. I offer and provide information, goods and services (products) to the public, to consumers
and to professionals related to the administration of and response to child welfare
investigations and court cases nationwide.
1066. The defendants offer and provide information, goods and services (hereinafter “products”
as defined in ¶21) to the public, to consumers and to professionals related to the
administration of and response to child welfare investigations and court cases in their
respective jurisdictions and nationwide.
1067. The defendants used in commerce either a false designation of origin, or any false
description or representation in connection with their products as described herein.
1068. The misrepresentations are material, and they are likely to influence the purchasing
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1069. The defendants’s statements were made in the course of business operations and
constitute the promotion of and/or representations of my products and/or of the
defendants’s products on the Internet, the medium that represents over 95% of the
advertising by the defendants.
1070. The subject statements misrepresent the nature, characteristics, qualities, association,
approval or origin of my products and/or of their products.
1071. The misrepresentations actually deceive or have the tendency to deceive a substantial
segment of the audience.
1072. The defendants know or should know that the representations concerning their products
and/or my products are false and misleading. When they published their false statements,
readers, as well as myself, to the extent we could appropriately access the forum, would
advise them they were false and explain the truth. The defendants ignored this
information and expanded their campaign to locations where any attempt to refute the
defamatory allegations would cast me in a bad light by exposing consumer to this dispute.
1073. The defendants are users, owners and operators of web sites and groups where this false
and deceptive advertising is disseminated.
1074. The defendants are directly liable and vicariously liable for false representations in
connection with any goods or services.
1075. The defendants fraudulently, willfully, knowingly, or intentionally made and caused to be
made statements to the public and to the relevant market the for the purpose of
influencing the public to seek and obtain the defendants’s products and/or eschew my
products.
1076. The contested statements were disseminated sufficiently to the relevant purchasing public
to constitute "advertising" or "promotion" within the industry.
1077. Between the dates of August 2000, and continuing to the date of this complaint,

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defendants made or caused to be made multiple false or misleading descriptions or

representations of facts about my products and/or about the defendants’s products.
1078. The subject false or misleading statements were made or caused to be made before the
general public in the United States and around the world, including inter alia, on the
Internet, person to person, via wired and wireless telephone and in various other public
fora.
1079. This false advertising is ongoing and continues to this date.
1080. These false and misleading statements about my products and my business include
repeated and multiple advertisements as follows:
1081. I committed wrongful acts against the defendants:
a. On May 22, 2006, Hinger published and falsely advertised on defendants’s groups
that “people”33 called Herger’s office to get Tower kicked off the speaker’s list,
tried to cancel his airline reservation, car rental and hotel room, and expected
these people to show up at the hearing and try to disrupt Tower’s testimony, so
they had advised House Security of potential problems. This falsely portrayed me
and my associates as stalking and harassing the defendants. I have no knowledge
of any such acts and did not perform these acts.
1082. That I am a convicted criminal;
a. On or about August 10, 2007, Hinger falsely advertised on AFRA_Helpline in
comments directed to M. Cygan, that I was convicted twice of UPL, and that I was
attempting “entrap” AFRA members into a UPL charge. I have not been convicted
of anything. I did not entrap anyone nor file complaints alleging UPL against
anyone.
b. On an unknown date and still on display as of September 9, 2009 Wiseman or a
33
The context inferred me and my associates.

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defendant posing as Wiseman also falsely advertised Hinger’s previous broadcast

message to AFRA groups on thetruthistold[dot]com/swallow.html and
/shellylinks.html and /hession/html that I was twice convicted if Unauthorized
Practice of Law. I have never been convicted of anything.
1083. That I am awaiting sentencing for criminal convictions;
a. On February 10, 2006, A. Dutkiewicz posted on NEPAN and other groups, “Be
Wary.... I heard Shell was found guilty but have not found proof of this
YET...... I heard a potential six months in jail.” This was false.
b. On March 18, 2006, T. Dutkiewicz and Connecticut DCF Watch advertised and
published on all AFRA groups and on AFRA affiliate groups and on other non-
AFRA groups, with the express consent of W.Tower and group owners, that I was
a convicted criminal awaiting sentencing. I have never been convicted of any
crime.
c. On March 28, 2006, A. Dutkiewicz wrote to several online groups, to the
individual defendants and to Hon. Judge Mack (keynote speaker at Connecticut
Conference where I appeared), and the advocates at FAVOR34 who were to be
trained, “Judge Mack, I would be happy to send you the data on Suzanne Shell. .
.I think you may want to be careful of your assocaitaion Suzanne Shell is
appealing a jail sentence in Colorado.” I never received a jail sentence to appeal.
1084. That I committed crimes of violence; and
a. On an unknown date and on display as of October 29, 2008, Wiseman and/or one
of the defendants posing as Wiseman falsely advertised on
thetruthistold[dot]com/response.html that I had attempted to murder Hinger. I
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have never made any attempt to murder anyone. I have never seen Hinger, and, to
the best of my knowledge never been within a thousand miles of Hinger.
b. On an unknown date and still on display as of October 29, 2008, Wiseman faslely
advertised on thetruthistold[dot]com/reneereponn.html that I had attempted to
murder Hinger.
1085. That I committed other crimes against the defendants and/or clients;
a. On and before May 30, 2003 thetruthistod[dot]com falsely advertised, “she is
nothing but a thief herself. . .”
b. On or about June 26, 2004, on CenCom, AFRA member Amtower falsely
advertised, “
I received a threatening email from suzanne also. Suzanne had the
"[consumer advisory]" on her site, trashing a large number of
parents/advocates. The other advocate reportedly got an attorney and
filed action against suzanne, and suzanne's site was removed (suzanne
then restarted it under .org.”
This is all false. I never sent her a threatening email. I never threatened the life of
anyone, I was never sued by A. Dutkiewicz. My web site was always .org since
1996.
c. On or about August 21, 2005, Swallow advertised on four groups including
CenCom that I was being “investigated for UPL and other felonies,” and would
be incarcerated before long. I have not been charged, tried, convicted or
incarcerated or anything similar as Swallow stated.
d. On or about December 24, 2006, Wiseman published on
coloradoconfidential.com, “mrs shell is a crook 100% Thief. . .”
e. On November 8, 2007, Shelia Vives falsely advertised on CPS Watch that I had
assaulted someone in Washington D.C.
“. . l she physically assaulted Rick Thoma (author CPS website "Lifting

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the Veil") at the ParentsMarch conference before everyone arrived. I

feel if I hadn't been there early there would have been some serious
injury. Rick was there with his 3 year old daughter and Suzanne walked
up to him to start a fight and started shoving him etc.”
I have never laid hands on anyone in my life, and I never laid hands on Thoma. I
did confront him, and insisted on answers that he did not want to give, but I never
touched or threatened him. I had dinner with him after the event. Thompson and
Barnes allowed this false advertisement to publish without correcting it, because it
serves their purpose to undermine my credibility and stature in this market.
f. On or about August 30, 2008, Swallow falsely advertised on CPS Watch that,
“SS is the L-O-S-E-R, Liar Theif, cam artist, manipulator and pschopath.
She is the worst of the worst and anyone thats gets sucked into her trap
ends up being scrutinized, sued , harrassed, stalked. . .”[sic].
This publication is still available to the members as of April 11, 2010.

g. On an unknown date and on display as of October 29, 2008, Wiseman or other
anonymous defendants falsely advertised on thetruthistold[dot]com the
“Shell/Korn scam” and “Shell a Thief?”
h. On an unknown date and on display as of October 29, 2008, Wiseman or
defendant(s) posing as Wiseman falsely advertised on
http://www.freewebs[dot]com/billywiseman/wisemanthree.htm that I blackmailed
and/or extorted him. I sent a cease and desist copyright infringement and demand
for payment.
i. On an unknown date and on display as of October 29, 2008, Wiseman and/or one
of the defendants posing as Wiseman and/or Mark Cygan and Renee Cygan
falsely advertised on thetruthistold[dot]com/yourselves.html that I stole from
them. I’ve never even met them, never been near them, never stolen anything from
them.

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j. On an unknown date and still on display as of October 29, 2008, Wiseman or

thetruthistold.com/tradesecret.html that my authorship and copyright registration
of two linked documents (famrightsamendrev.pdf and revisestats.pdf) are proof of
a crime committed by me. These are original works authored by me.
k. On an unknown date and on display as of October 29, 2008, Wiseman and/or one
or more of the defendants posing as Wiseman falsely advertised on
thetruthistold.com/stalking2.html that I was a Federal Criminal. I am not a federal
criminal.
l. On an unknown date and on display as of October 29, 2008, Wiseman and/or one
thetruthistold[dot]com/assortedshelllinks.html that I was a thief and committed
slander. I have stolen nothing from anyone and I have not slandered anyone.
m. In March, 2010, A. Dutkiewicz published on thetruthistold[dot]com falsely
accusing Effie Belou and myself of attempted murder upon defendant A.
Dutkiewicz, inferring that we were guilty of slashing her seatbelts in her car and
that Effie Belou and I also murdered Paula Makintosh (sic) and Michelle Bassette.
I did not know Bassette, I had not had any contact with Macintosh since 2005. I
didn’t even know A. Dutkiewicz owned a car, much less know what kind of car it
is. I’ve stayed away from this woman, she scares the daylights out of me.
1086. That I demanded the defendants commit crimes;
a. On or about August 13, 2005, Swallow falsely advertised to over forty recipients
including groups that she was sanctioned by FRAI for
“failure to commit fraud, failure to lie to protect unethical practices. . .
.[she] was not part of a cover-up operation to protect the Institute. . . .I
will not be part of [Shell’s] corruption. . .failure to report a criminal act,

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namely a felony makes you and accessory after the fact. . .the attorney
was a theif. . .How much money did Mr. Fillenbaum pay the Institute to
cover up his criminal acts. . .Suzanne is a criminal.”
Again, no criminal charges filed against me, no conviction, no crime committed.

Swallow’s statements are all false.
1087. That I teach advocates how to commit crimes;
a. On or about August 13, 2005, Swallow falsely advertised to over forty recipients
including groups,
“. . .Suzanne Shell who sent Kay into the courtroom to make her own
advocate a party to a criminal act. . .THE ONE WHO SENT HER INTO A
COURT ROOM CLAIMING TO BE A REPRESENTATIVE FOR "ATTORNEY
JIM Filenbaum.”
Ms. Henson was under the supervision and acting according to the direction of
Mr. Filenbaum, a licensed attorney in Florida. The Court took no offense that Ms.
Henson advised the Court Mr. Filenbaum had cancer and couldn’t appear, and
was withdrawing from the case.
b. On or about August 13, 2005, Swallow falsely advertised to over forty recipients
including groups,
“. . .SO-CALLED INSTITUTE [FRAI] THAT IS A SHELTER FOR
RACKETEERING. . . .SUZANNE WANTED AT LEAST 3 OF HER
ADVOCATES INCLUDING MYSELF TO KEEP FAMILIES OF CHILDREN IN
FOSTER HELL IN THE DARK AND NOT TO EXPOSE THE ATTORNEY OR
THE INSTITUTE ALL THREE OF US WERE LOYAL TO THOSE FAMILIES.”
c. On or about November 21, 2005, Swallow published to eight individual and group
recipients, “She placed another advocate Kay Henson up for a UPL by
instructing her to appear n this attorneys behald in court proceedings after her
knowledge he was disciplined.” I did not provide this instruction. Ms. Henson was
acting on the instruction of the attorney.
d. On or about December 2, 2005, Swallow advertised to over one hundred

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individuals and groups,

“Kay Henson contacted this clients SISTER and got a credit card number
stating Jim needd more Money to continue the case..The client himself
informed Kay previously HE WILL NOT GIVE JIM ANOTHER
PENNY,,This is FRAUD......#1 Kay did not work for Jim #2 Kay utilized
a credit card fradulantly. There were at least 5 other clients I have been
in contact with all Negative interactions with Kay as well as Jim and
sometimes Suzanne Shell.”
This is false, Ms. Henson has no means to conduct a merchant credit card
transaction, which requires an intensive application process. All monetary
transactions between client and attorney are handled by the attorney.
Institute (FRAI) policy is that advocates never participate in collecting
money for attorneys.
e. On July 31, 2006, W. Tower published and falsely advertised on AFRA
interactive online groups and to a private distribution list that I trained advocates
to break the law.
f. On or about April 11, 2006, A. Dutkiewicz advertised on bashing_shell, “In one
of her seminars in Fl she was encouraging parents to use force to keep CPS out,
to carry a gun.” This is false.
g. On or about December 31, 2006, R. Cygan falsely advertised, “[Shell] Aids others
in violating court orders and clearly condones child abuse!” I have never told
anyone to violate a court order.
1088. That I publish pornography on my web site, including kiddie porn or support kiddie porn;
a. On or about December 19, 2003, A. Dutkiewicz published an advertisement on
the defendants’s interactive online groups directing the public to a web site she
represented to be mine, with a [dot]com extension instead of [dot]org,:
“Oh MY GOD what kind of crap is this Shell woman promoting. I just went to
www.profane justice.com and came up with a message baord where the posters
were writing stuff about F-ing and arm pits and dirty body functions. AND THIS

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WOMAN HAS A NERVE TO CRITISIZE GROUPS LILE NEPAN!!!!!!!!! Oh my

GOD-dess this is just DISGUSTING. MY littlke respect for S Shell just flew out
the door. IF it is a case of not being able to keep up her web pages than she
should spend less time attacking us PEONS and doing more freakin promotions.
I was about to promote her book at my next local event. I WILL NOT NOW. I
WILL NOT say ANYTHING BAD about her to the public but I WILL NOT SUPPORT
HER> AND NEVER EVER EVER EVER AGAIN WILL I WRITE LETTERS AND
MAKE CALLS ON HER BEHALF. ANY TOP ADVOCATE that has to detract from
us little-uns is no real advocate after all.”
b. On or about May 17, 2006, R. Cygan made a false report to the company that
hosted my web site content (cbyond.net) that I was publishing kiddie porn and
falsely claimed I was publishing her confidential medical records. The company
shut down my web site and R. Cygan took credit for that shut down. She later
admitted filing the complaint was a “cheap shot” and that it wasn’t kiddie porn.
See ¶1547.
c. On or about April 11, 2006, A. Dutkiewicz advertised on bashing_shell about
content on my web site , “Folks what this says to me is Shell is encouraging soft
porn and kiddi porn......when you think about it.”
d. On or about May 30, 2006, thetruthistold[dot]com reported, “From the Editors of
the Truthistold[dot]com it seems that this time Suzanne Shell's website was shut
down Due to The Fact That Suzanne Shell had kiddy porn on her website. . .”
and stated I had photos of naked children and that my site needs to be shut down
for good. I had no photos of naked children or kiddie porn on my web site.
e. On or about December 29, 2006, a defendant signing as T.M. falsely advertised on
coloradoconfidential.com that I advocate video taping “beatings of children” and
saving the tapes in my home as soft porn.
1089. That I abused or allowed my children to be abused;
a. On or about April 11, 2006, Wiseman published on bashing_shell, ¶1499, that

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“both kids got beat with this wip [sic] that you beat horses with and it was not
just her husband that beat the kids it was none other then MRS.shell. . .” My
children were never beaten by me or my husband.
b. On or about December 26, 2006, Wismean published on coloradoconfidetial.com,
“. . .no one has the right to have children kidnapped unless they are being
abuse like shell was doing.” I was never even accused of child abuse.
c. On or about December 29, 2006, a defendant signing as T.M. falsely advertised on
coloradoconfidential.com that I was , “A fine citizen who would video tape the
physical beating of children. . .” I do not advocate beating children, much less
video taping it.
d. On an unknown date and on display as of October 29, 2008, Wiseman and/or one
thetruthistold.com/misty[dot]html that I beat my kids and then threw away my
own son. I was never charged with child abuse. I never had a dependency and
neglect (D&N) case. My husband was charged with misdemeanor child abuse for
a spanking and was acquitted at trial. I never threw away my son.
e. On an unknown date and still on display as of October 29, 2008, Wiseman or
thetruthistold.com/atttackanswer.html an advertisement that I allowed my husband
to “beat” my kids with a “cat of none[sic] tails” and that the court then sent my
children to live with their father. My husband was acquitted, therefore there was
no “beating.” There was no “cat-o-nine” tails . The court did not make any ruling
as to the custody of my children because no court ever assumed jurisdiction over
my children.
1090. That my children were removed from my custody and I never got them back;

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a. On or about November 4, 2004, Blair published to numerous AFRA and non-

AFRA online groups, “. . .they may have realized that you [Shell] didn’t manage
to get your own children back, and figure that you weren’t qualified to get
theirs back, either.” I had one child removed for four days, and then returned
without any conditions. This child was returned without a D&N petition ever
being filed as to my children.
b. On October 12, 2006, Wiseman wrote an email to AFRA online groups and
individual recipients, and to Contreras specifically, “dee, shell did not get her
kids back and they are now growen and want nothing to do with her whoever
told you that lied...billy” I had one child removed for four days, then returned. No
case was ever opened. For fear of what the defendants will do with my private
information, I cannot comment on the rest of the statement except to say it is false.
c. Wiseman published this same false advertisement that I never got my kids back on
thetruthistold[dot]com where it remained on display even after he was told it was
false.
1091. That I did not possess the credentials I claimed;
a. See ¶1170.c re: A. Dutkiewicz contacting Judge about my CLE accreditation.
b. The truthistold[dot]com has consistently advertised since 2006, advertised that I
do not posses a valid press pass. I posses two press passes, issued by different
independent media organizations.
c. On or about September 26, 2006, Hinger falsely advertised that I had “Phoney
Press Credentials.” See above paragraph.
d. On March 29, 2006, A. Dutkiewicz published to cp_prosecutions that my training
seminar was not CLE accredited in Connecticut as I advertised. It was accredited
by the Connecticut Bar Association.

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e. On or about April 12, 2006, A. Dutkiewicz published on bashing_shell, “Oh by

the way. . . . as to the CT Seminar, they NEVER had the CT Bar Assoc behind
them. The CT Bar knew NOTHING of the claim of 8.5 cec’s cle’s.” This
particular presentation was CLE accredited both in Connecticut and Colorado.
1092. That the articles, books, web site and other intellectual property I authored was
plagiarized and/or stolen from others;
a. On or about March 18, 2006, Jackson falsely advertised on Directors,
“Here is a little trivia -- it was *I* who "invented" Reverse Miranda for
children while I was subscribed as a member of the CPSWatch support list
years ago, where SS was also subscribed until her falling-out with Cheryl
Barnes. . . . SS in NO WAY contributed to the formulation of the concept. Now
she is claiming Reverse Miranda to be her baby, a pure fantasy on her part.
Her copyrighting Reverse Miranda is ludicrous and serves no benign purpose.”
I have never claimed the two sentences that comprise the Reverse Miranda to be
authored by me and have never claimed copyright infringement when it was used
by others.
b. On May 10, 2006, thetruthistold[dot]com published a statement by “anonymous”
which said, “She claims her web site is copy righted but she has copied from
others.” My web site was the first one of its kind, making it impossible to copy
from others. The content is original and authored by me.
c. On or about September 26, 2006, Hinger published on all AFRA groups,
“There are several items that Dances With Chickens [Shell] attempts to
claim as her copyright that were plagiarized from others in this
movement. . .the number on her list is the CPS Manual written by
Cheryl Barnes, copyrighted by Cheryl in November 1999. . .Another
item DWC tries to attack people for using is the paper on What to Do
When CPS Knock On Your Door, she copyright this piece when she go
tthe second copyright on her book in 2001 or 2002. Yet it was published
on the Vocal NY website in January 1999. . .None of her work on this
issue is in fact her work it has been plagiarize from others without their
permission. . .the list continues, but you all get the general idea.”

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Barnes book is not registered with the copyright office. It was first published in
2001. As for the VOCAL web site, the content Hinger refers to was published in
the first edition of Profane Justice in 1997, suggesting VOCAL copied it from
me. I have always credited sources, and all my books, articles and papers have
bibliographies or footnotes where appropriate.
d. On or about December 24, 2006, Wiseman published on
coloradoconfidential.com, that I cost him money and had his domain shut down
(with a DMCA complaint) for “something that mrs. Shell has stolen?” inferring
that my work was stolen from others.
e. On or about March 29, 2007, a defendant anonymously posted on Libervis.com a
link to the thetruthistold[dot]com and said, “shell claims copyright but you cant
claim that when you steal the wrorks of others.”
f. On an unknown date and on display as of October 29, 2008, Wiseman or other
anonymous defendants falsely advertised on thetruthistold[dot]com/ and that I
“steal stuff from all over the web and [copyright] it and claim is as [my] own.” I
have not stolen anything that wasn’t mine and claimed it as my own.
g. On an unknown date and still on display as of October 29, 2008, Wiseman and/or
one os the defendants posing as Wiseman and/or Renee Cygan falsely advertised
on thetruthistold[dot]com/suzannw_shell.html that I stole the works of others and
claimed it as my own.
h. On an unknown date and still on display as of October 29, 2008, Wiseman or
thetruthistold.com/tradesecret.html that my authorship and copyright registration
of two linked documents (famrightsamendrev.pdf and revisestats.pdf) are proof of
a crime committed by me.

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i. On an unknown date and on display as of October 29, 2008, Wiseman or

thetruthistold.com/my_dearest_suzanne.html that I plagiarized “most if not all” of
my book. Nothing like what was in my book existed before I wrote it.
thetruthistold[dot]com/chickens.html a previous broadcast originating with Hinger
to all AFRA groups that I stole intellectual property from Cheryl Barnes (CPS
Watch) and VOCAL NY; that I plagiarize work from others without their
permission; and that what I have copyrighted is plagiarized. This is all false.
k. On an unknown date and on display as of October 29, 2008, Wiseman and/or one
or more of the defendants posing as Wiseman falsely advertised under the heading
of “More stolen goodies” on thetruthistold[dot]com/stolenpage.htm, claimed I
stole a quote which I properly attributed to Alexander Solzhenitsyn, and that
another quote–which was my original work– was stolen from Citizens
Commission on Civil Rights–who appear to have stolen it from me.
l. See ¶1155.k, re: A. Dutkiewicz Amazon.com book review of my book.
m. On and before May 30, 2006, thetruthistold[dot]com advertised,
“One must wonder why Mrs. Shell cannot seem to make money off her
own writings without stealing someone else’s. It is also reported that
much of what Mrs. Shell has claimed to be her intellectual content is
nothing more then a compilation of things stolen from various places.”
n. On or about December 29, 2006, a defendant signing as T.M. falsely advertised on

coloradoconfidential.com , “. . .Ms. Shell (author plagerist extrodinare. . .”
1093. That the resultant intellectual properties were not protected under copyright laws or other
intellectual property laws;

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a. On or about March 18, 2006, T. Dutkiewicz and W. Tower published a broadcast

email to over 50 interactive online groups in this market asserting that my web
site was no longer copyrighted inferring that any copying of my content would not
constitute infringement. I still hold valid copyright registrations to that property.
1094. That I and my associates “con” our clients; and
a. On March 3, 2007, Kiefer falsely advertised on AFRA_EAGLE Yahoo! Groups
that Citizens for Change and their radio show providers, were “less than
honorable.” This advertisement was made in response to an announcement that I
was scheduled as a guest on that show and directly inferred that my appearance
gave rise to this advertisement. This false advertisement was endorsed by AFRA
members and defendants Contreras and Durand. The advertisement was deleted
from the archives by Durand, but never retracted by anyone. It was never taken
back from the hundreds of email recipients of that message and nothing was done
to prevent any recipient from forwarding that information to others.
b. On or about September 14, 2004, A. Dutkiewicz stated that I charged attendees
$50 for a book that is free at Connecticutdcfwatch[dot]com, and that I reprinted it
without permission. The sponsor is responsible for all printing, and had
permission to reprint that book, and charged only for the cost of reprinting for
those who had no computer access for online the online link. I had nothing to do
with any transactions associated with this book.
c. See ¶1085.f re: Swallow on CPS Watch
1095. That I and my associates force our clients to hire disreputable attorneys; and
a. On an unknown date and still on display as of October 29, 2008, Wiseman and/or
one or more of the defendants posing as Wiseman, and or Brenda Swallow, in
violation of a Florida Court injunction against Swallow publishing defamatory

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statements against me, falsely advertised on thetruthistold[dot]com/simple3.html

that I defended a “scam attorney;” that I endanger families; that I allowed an
attorney to rob families after he was disbarred; that I am not qualified to teach
advocacy; that attorneys who work with the Institute rob clients; that I let children
remain in “foster hell” to defend criminal conduct by an attorney; that I screw up
cases. This is all false.
b. On or about September 5, 2005, Swallow stated on
Justice4ChildrenParentsAndFamilies_NW_FL group, “Secondly the attorney
they had us referring all clients to (so Kay could get a kickback) was some
shady characture a created a nightmare in every case he was on.” Swallow
seems to have forgotten that Greg Pound was the one who introduced Mr.
Filenbaum to Ms. Henson and Swallow. Swallow subsequently hired Mr.
Filenbaum without a reference from FRAI, and Swallow referred other clients to
him. Furthermore, there never were any kickbacks. I observed he was ethical and
competent, to the extent the clients would follow his and the advocate’s
instructions.
c. On or about September 5, 2005, Swallow advertised on FloridaStoleMyChild,
“[Shell] advised all of her ‘advocates’ to refer clients to Mr Filenbaum.” I did not
run Florida FRAI, Ms. Henson did. Ms. Henson solicited attorneys she worked
with to represent FRAI clients. The representation agreement was always between
the client and the attorney. I provided support and training according to the
instructions of the attorney.
d. At this same time Swallow stated, “In all the cases Mr Filembaum took the
money and failed to represent.” This is false. In many cases, he wasn’t even paid.
But he did represent and he did a good job.

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e. She also stated he had five cases pending before the bar. Swallow and Durand
spread these lies about him to Institute clients, “. . .that their attorney was
disbarred and instructed them on how to contact the bar and state attorneys
office.” He was not disbarred in Florida at the time we worked with him. None of
the complaints they incited were founded.
f. At this same time Swallow said, “Suzanne was notified of this and not only
refused to take action but advised her "advocates" TO NOT TELL JIM'S
CURRENT OR PAST CLIENTS OF THIS INFORMATION.....” By this time, I knew
what had happened in New York, Swallow didn’t. I told Swallow and Durand as
long as he was an attorney in good standing in Florida, they should not be
maligning him. That was up to Florida to decide what to do, not us. This practice
of maligning attorneys who worked with the Institute would make it difficult if
not impossible to recruit competent professionals to represent clients who work
with the Institute. Swallow and Durand didn’t care, they wanted to destroy my
business.
g. On or about December 24, 2006, R. Cygan falsely advertised on
coloradoconfidential.com that I scammed parents into using disreputable
attorneys, and received kick-backs from them under the table, and that my
advocates charge fees for paralegal work, and I get a cut of that. This is all false.
1096. That disreputable attorneys are members of my and/or my associates’s respective
organization(s);
a. See ¶1095 re: Wiseman web site claiming FRAI used unscrupulous attorney.
b. On or about September 5, 2005, Swallow advertised on FloridaStoleMyChild,
“Suzanne Shell added an attorney James R. Filenbaum to her Institute.” The
Institute did not have attorneys on staff, or as members, or in any other capacity.

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This was given in the context that he was disreputable. He was an attorney in
good standing when he represented Institute clients.
c. On or about January 19, 2006, Swallow misrepresented to twenty six recipients
and groups reporting James Filenbaum had been disbarred and said, “The first on
my long list to bite the dust. . .I’m almosta a Happy Caper here I com SS.” Mr.
Filenbaum was not disbarred for any misconduct on any Florida case. He had
surrendered his license in New York due to cancer preventing him from defending
a claim about commingling funds, which followed him to Florida whose rules
required disbarment as a result of his status in New York. Mr. Filenbaum had a
recurrence of cancer while working with FRAI. He was highly regarded by his
peers and made national case law on vaccination issues. Swallow smeared this
fine attorney just to get back at me.
d. On or about August 21, 2005, Swallow falsely advertised on four groups
including CenCom that I knew Mr. Filenbaum was disbarred in Florida. He was
not disbarred at the time he donated his law office to hold Ms. Henson’s
conference or when he represented Institute clients. He was disbarred in January
2006, and was eligible for reinstatement in 2008.
e. August 31, 2008, Swallow falsely advertised on CPSWatch group,
“I can tell you names of 4 families right now who LOST CUSTODY
TPR’D because of shell and her actions all involving Jim
Felenbaum and her other dquggly attorneys she worked with.”
This was false. The cases she refers to were not Institute cases.
f. On an unknown date and on public display as of October 29, 2008, Wiseman

and/or one of the defendants posing as Wiseman falsely advertised on
thetruthistold[dot]com/stunned.html under the heading “‘An FRAI lawyer’ We
were stunned,” that a Florida attorney, Jim Filenbaum was “brought on board” as

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a lawyer for the Family Rights Advocacy Institute after being disbarred in New
York, and that I knew he had no license to practice law in Florida at the time of
his attendance at an Institute seminar in November, 2004. Family Rights
Advocacy Institute (FRAI)35 does not have attorneys on board, nor on staff, nor on
the board of directors. Mr. Filembaum was an attorney in good standing in Florida
at the time of the seminar mentioned. He provided his law office as the location
for the Florida seminar. I had no knowledge of his licensure in New York at that
time because this was a Florida seminar for a Florida group.
1097. That I am responsible for a child being in a coma;
a. On an unknown date and still on display as of October 29, 2008, Wiseman and/or
one or more of the defendants posing as Wiseman, falsely advertised on
http://thetruthistold[dot]com/Swallow.htm that I am responsible for a child in a
coma. This appears to be Swallow’s ghostwriting.
1098. That certain individuals who had committed unethical acts or demonstrated incompetence
were part of my “group” and/or were trained and certified by me; and
a. On or about February 8, 2005, Cathy (catzcandu) published on
FloridaStoleMyChild interactive online Yahoo! group that C. Merwin had been
trained by me and was a student of mine. She was advised by Swallow that
Merwin has not been trained by me and is not a student of mine.
b. On or about August 2, 2006, W. Tower published on all AFRA groups,
“I guess that it took one of the PROFESSIONAL, KNOWLEDGEABLE AND
WELL TRAINED FRAI advocates to come up with this one. So, I am so
glad I was not trained to do this sort of thing. And here is the scary
part others that have been trained by FRAI are out there.”
35
FRAI is a licensee of my trade secrets and intellectual property. I provide CLE and
other education through FRAI. I am the manager pro tem of the Institute. FRAI is not a plaintiff
in this lawsuit.

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This was a deliberate false advertisement in retaliation for Merwin asking if a

certain sex offender record was his. Merwin was not trained nor certified by me or
FRAI and w. Tower never asked before publishing this false statement.
c. On an unknown date and still on display as of September 9, 2009, one of the
defendants, Swallow, falsely advertised on thetruthistold[dot]com/Swallow.htm
that Corinne Meriwin was one of my trained and certified advocates, stating she
had turned Swallow in for child abuse. Merwin was never trained nor certified and
never worked for me.
d. On an unknown date and still on display as of September 9, 2009 Wiseman or a
defendant posing as Wiseman also falsely advertised on
thetruthistold[dot]com/attackanswer.html that Corinne Merwin, whom he reports
has some criminal history and who turned in a family to CPS, was part of my
organization. She wasn’t.
1099. That I engage in stalking and harassment of the defendants; and
a. On an unknown date and still on display as of October 29, 2008, Wiseman or
other anonymous defendants falsely advertised on thetruthistold[dot]com/ that I
and my associates engage in stalking and Internet stalking against others. I have
never engaged in stalking of anyone.
b. See ¶1085.f re: Swallow on CPS Watch accusing me of stalking.
c. On or about February 5, 2010, A. Dutkiewicz published at
http://auto216295.weebly.com/1/post/2008/03/first-post1.html#comments,
“. . .but maybe the world of readers need to hear more about the
ramifications of the antics of this one woman steam roller.... I am
considering posting all that has happened since the suit was filed.... I
believe I will call it MY Suzanne Shell Horror Story A.K.A. "Stalked
Nearly to Death"... or at least close to financial ruin.... AND it is most
definitely a CRIME to have someone garner a person's SS # and then

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use it for illegal and stalking purposes. . .”
A. Dutkiewicz was evading service. My use of this information was legitimately

related to locating her to effect service of process.
1100. That I phoned in a bomb threat to Amtrack;
a. On or about January 16, 2006, A. Dutkiewicz and Connecticut DCF Watch
advertised to an undisclosed list inferring that I called in a bomb threat to Amtrack
for the entire North East regions on the date she was supposed to go to
Washington D.C. with an AFRA delegation. She stated the police said the call
came from a cell phone in Colorado. I never phoned in a bomb threat to anyone.
An investigation into this claim with the U.S. Department of Transportation,
Amtrak, law enforcement and news sources revealed there was no bomb threat,
and that trains ran on schedule. She later36 contradicted herself and stated she was
moving that weekend and couldn’t go, but never withdrew or corrected this
allegation against me.
b. On or about January 16, 2006, A. Dutkiewicz advertised on DCFreformFL,
“. . .calling in a bomb threat to Amtrack for the entire North East region
on the day I was supposed to travel. (Hum oh and Amtrack Police said
the call came from a cell phone in Colorado... um wonder which of the
SS’s little band of militants did that one?????)
c. On or about April 14, 2006, A. Dutkiewicz accused me of making a bomb threat

to Amtrak on the bashing_shell group.
“I was supposed to go to D.C. with the AFRA Suzanne tried to shut me
down, withdraw support etc... She even called Senator Bacca's Office to
claim I was a dangerous person and they should not let me near D.C
The night I was supposed to leave on Amtrack a bomb threat was called
in to Amtrack from Bangore Maine to D.C it shut the rail system done
for the entire evening. Service went back up after 1am. I had a family
36
In April, 2006

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ememgency and could not go after all..... the call to Amtrack came from
a cell or card call out of Denver and the call was linked to a small cell of
a Patriot group.... That is all Amtrack Authorities would tell me...... this
is in part why the FBI took my call to them about Shell's threats to
me.... I filed a report with Amtrack and the FBI of the goings on because
Shell emailed me personally to tell me she would stop at nothing to keep
me out of D>C and if I did try to go she would be sure she got the whole
hearing shut down.....”
This was all false. I never emailed or called the Senator’s office. There was no
bomb threat.
1101. That my clients and the clients of anyone associated with me end up having their children
removed or losing their children forever;
a. On or about March 9, 2005, AFRA BOD Martin on Directors questioned my
methods, stating, “. . .it seem the ‘in your face’ attitude cause the second
kidnapping for Christine Korn’s grandchild.” Korn had steadfastly, publicly
refuted that anything I did caused this tragedy. Additionally, my methods do not
include anything “in your face.”
b. On September 8, 2005, Swallow advertised on
Justice4ChildrenParentsAndFamilies_NW_FL court watchers of Florida,
“SUZANNE ALLOWED 5 OR MORE FLORIDA DCF CASES TO KEEP
CHILDREN IN DANGEROUS ENVIRONMENTS AND DEADLY FOSTER
HOME.” Swallow is including cases she insists were Institute cases but were not,
and cases that the Institute had withdrawn from when the attorney withdrew
because the client refused to follow instructions. If the children were not returned
home, it wasn’t due to anything I did, or Ms. Henson did.
c. On November 8, 2007, Barnes falsely advertised on CPSWatch,
“She continued to boast a "100%" success rate - but to this day
there is not even one person that will say "I got my kids back
because of Suzanne Shell. . .she forces them to do everything

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exactly as she says - and they lose their kids forever. There
isn't one person that Suzanne has "helped" that has custodoy of
their children now.”
I never boasted a 100% success rate. Over 90% of the families I helped do get
their children returned and are happy to tell others.
d. On November 10, 2007, Barnes falsely advertised on CPSWatch, “Kay Henson
does NOT have custody of her children AND she was arrested following
Suzanne’s advice.” Henson got her children back in three weeks. Her jail time had
nothing to do with me or my advice. Her probation was revoked and she was
jailed awaiting her revocation hearing, which she won pro se.
e. On an unknown date and still on display as of October 29, 2008, Wiseman falsely
advertised on thetruthistold[dot]com/attackanswer.html a false advertisement
authored by Hinger which stated that I advised a family in Oregon, the Christines,
to grab their kids [from foster care] at gunpoint and run. The Christine’s were
subsequently arrested and convicted and sentenced to prison. I have never had any
contact with the Christine’s. In fact, the AFRA and Oregon Family Rights web
sites featured the Christine’s story from the time their children were removed,
consulted with them on their case, and remained the primary contact with the
Christines, giving a play by play description of their conduct, trial and
incarceration. Henderson, Roger Wiedner and Wil and Pam Gaston of Oregon
handled the Christine case.
f. At the same time, they also falsely advertised that every family I and Kay Henson
attempted to help in that manner has been caught and had their parental rights
terminated. Neither I nor my trained advocates have ever advised parents take
their children from CPS custody and run.
1102. That I have never gotten a single child returned to his or her parents or that I rarely get

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children returned to parents;

a. On or about January 18, 2006, A. Dutkiewicz told consumer Christy
(jones33773@yahoo.com) to “GET OUT NOW while you have a chance of getting
your kids back. . .Honey your kids are as good as gone if you stay on this path
with these two,” in response to a question about me.
b. On May 10, 2006, thetruthistold[dot]com published a statement by “anonymous”
which said, “Instead she has hurt to many parents and grand parents.”
1103. That I suffer from mental problems and was a sociopath;
a. On or about March 23, 2005, Jackson advertised on Directors,
“. . .[Shell] feels no empathy, and even less compunction in humiliating
and degrading us. In my cursory readings about sociopaths, this
dehumanisation and dissociation is a prevalent characteristic. There is
nothing to prevent a sociopath from being a very productive member of
society, most blend in wonderfully, but for everything fixed, something
else must be "traded" and sacrificed to a mauling.”
b. On or about July 6, 2004, Henderson advertised on AFRA Directors that he

thought I had “Alzheimer’s or what. . .”
c. On or about September 5, 2005, Swallow stated on
Justice4ChildrenParentsAndFamilies_NW_FL group,
“Crazy now would be a term used on someone that wants others to
believe in them, someone that creates a persona and self generated
"Institutes" for shallow minded individuals whom they think they can
manipoulate. Crazy would be someone who thinks their ‘followers’ are
so dedicated to them (not a movement)that these people who place
themselves in danger of inprisonment for them. Now that is Crazy and
Suzanne if the shoe fits. . .the wear it.”
d. On and before May 30, 2006, thetruthistold[dot]dom by A Person Concerned,

advertised that I am a socioapath because I claimed to be the creator of family
advocacy. I am the creator of family advocacy.

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e. On an unknown date and on display as of October 29, 2008, Wiseman and/or one
thetruthistold[dot]com/peace.html that I am not only mentally ill, but a vicious,
narcissistic sociopath. I’m not mentally ill, and I have no diagnosis of narcissism
or sociopathy.
f. See ¶1085.f re: Swallow’s advertisements on CPS Watch
g. See ¶1242 Alleging I have MS which is causing mental problems.
1104. That I am a terrorist;
a. On or about April 9, 2006, A. Dutkiewicz wrote to CFC saying, “Oh and I have
an open FBI investigation on Suzanne with the New Haven Ct FBI office under
Patriot act ‘TERRORISM.’” I have never been investigated for terrorism, and a
privacy act request from the FBI reveals no complaints or investigation against me
for any reason.
1105. That I am part of the group that did the Ruby Ridge standoff;
a. On or about April 9, 2006, A. Dutkiewicz wrote to CFC saying,
“she got terribly Upset over the man who talked about the Soverign or
Patriot Citizen laws…. She said ‘I will not discuss this with you’ Yea
dear heart these are the folks that did the Ruby Ridge stand off… these
are the people Suzanne is part of.”
I am not a member of any militia, nor the NRA or any other political group or
party. I had nothing to do with Ruby Ridge.
1106. That I made death threats against the defendants;
a. See ¶1158.d re: A. Dutkiewicz death threats
b. On or about May 25, 2004, A. Dutkiewicz published to the online groups that a
Bible verse from Exodus that I published on my web site was a death threat under
homeland security.

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c. On or about March 29, 2006, A. Dutkiewicz advertised on cp_posecutions, “When

the [consumer advisory] when up, I was getting death threats from someone
claiming to be a supporter of Shell.” I have no knowledge of anyone making
death threats on my behalf. I never made any.
1107. That I was engaged in “cult building;”
a. This description first appeared on AFRA_Directors and was presented by Linda
Martin to the AFRA BOD on April 13, 2005,
“Her tactics are very reminiscent of cult-building. As someone who's
researched cult activities intensely - there's no way I can look at this
scene and not think the words, "Information Control". Very cult-like.”
b. See ¶1675.b re: I operate a Jim Jones style cult.

1108. That I am connected with Scientology;
a. On or about June 3, 2003, Bryan published an interview purported to be by
Wiseman at http://www.binaryfreedom.info/node/139, with his own
“Note From Ringo: Yes, she does have connections with Scientology. She
was interviewed in their magazine and they only interview their own.
So fight both Shell and Scientology. They are both very dangerous.”
b. In this same article, Bryan posed the question, “If the campaign against Suzanne
continues will people disappear during the night like other critics of
Scientology?” The defendant posing as Wiseman37 responded,
“Ms. Shell has a lot of friends I would consider dangerous, but I don’t
know which ones, if any are involved with Scientology. I know there are
many people who are afraid of what she will have done to them. I know
she has contacted hospitals and other entities to try to destroy the
families of people with whom she disagreed.”
I have never contacted hospitals or other entities as alleged. If people are afraid of
me, it’s solely due to the defendants’s false publications about me. I have not seen
37
This is Contreras or another defendants

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any indication that any of my friends are dangerous.

c. In this same article, Bryan posed the question, “At what point will Scientology
stop defending Suzanne?” The defendant posing as Wiseman responded,
“Because her viewpoint on corporal punishment is in keeping with their own,
I’m not sure they would ever be willing to stop defending her, if they are doing
so now.” I have no knowledge of the Church of Scientology defending me, they
have never contacted me and advised me of their support.
1109. That I am a threat to society;
a. On or about June 3, 2003, Bryan published an interview purported to be by
Wiseman at http://www.binaryfreedom.info/node/139. The responses in this
article are far beyond what Wiseman is capable of, another defendant submitted
these responses posing as Wiseman. Bryan asked, “Is Suzanne a threat to
socieity? If so, why? The defendant posing as Wiseman responded, “
I believe she is a threat to society in several different ways. She claims
that she helps families, and has been reprimanded for overstepping the
boundaries of UPL laws.38 Her methods have been declared by judges to
be harmful to her “clients”.39 She professes to be the founder of the
family rights movement40 and, as such, claims she is the only person
who can or should oversee any advocacy program that is recognized in a
court of law.41 However, right now she is being sued by William O.Tower
38
I admitted UPL the first time I did it, and agreed not to do it again. I never did do it
again. That the Colorado attorney regulation system or judicial system isn’t perfect isn’t my
fault.
39
Not all judges. In fact very few judges have actually said that, and the few that have are
all in Colorado and are prejudiced. Many judges, particularly outside of Colorado find my
methods to be extremely appropriate and helpful.
40
I am the founder of family advocacy and I was a catalyst for the grassroots family rights
movement.
41
What does this mean? I do exercise oversight because nobody else wanted to.

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for defamation,42 and many of her filings have been thrown out. If Shell
knew how to handle herself in court, I would say she is not a danger;
however when she makes errors indicating a lack of understanding of
legal terminology and procedural errors, I don’t think she has the
knowledge to properly train advocates43, much less to appoint herself as
guardian over the entire movement. She is harming families and
children by posting home addresses and phone numbers of those she
considers competition44 on either or both of her websites,45 claiming
these people deserve to be tormented for their sinful ways.46
Furthermore, she advocates corporal punishment; assists people who
have been convicted of felony child abuse keep their children (and
continue to abuse them)47; and has made claims, in her own writings, to
advocating the punishment of her own child with a martinet. She
employs patriot law in her dealings with the courts,48 but decries the use
of patriot law by others, as though she believes she is entitled to sole
ownership of that, as well as everything else to which she claims
ownership. She has a very warped sense of what competition is.49 She
has been known to attack people who defend her, calling them names
and verbally abusing them for defending her50, and then calling them
42
I never defamed him, he’s trying to hold me liable for what someone else published.
43
Five states have accredited my training for Continuing Legal Education Credits.
44
They published their own addresses on line.
45
I do not own or author badadvocates.com
46
Absolutely false.
47
Absolutely false. Yes, I do assist families who have abused, but not to protect their
abuse. They are entitled to the same protections of the law as falsely accused. The purpose of
these cases is to rehabilitate the parents, they are not intended to be punitive. However, The only
persons I know with felony child abuse convictions were several members in Ann Durand’s
family, her houseguest, Hardigree, who are all associates of the defendants.
48
Absolutely false.
49
I rely on the existing law for this determination.
50
This is Contreras. I merely advised her privately she was not authorized to speak on my
behalf, and to stop engaging my detractors on public web sites on my behalf because I did not
want my name to be associated with the kind of disruption that was occurring on a neutral web
site. She considered this abusive and complained all over the groups about it.

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names and verbally abusing them if that person does not defend her in
a separate incident. In other words, she claims dictatorship over anyone
who makes any effort to help others understand the system51, anyone
who is a member of a group she does not endorse, anyone who defends
her, anyone who doesn’t defend her, and anyone who refuses to do her
bidding. She uses badadvocates.com to publicly humiliate them in an
attempt to gain control over their words and actions.
b. Bryan closes this same article with his comment, “For more information, see
[link to http://wiki.binaryfreedom.info/index.php/Arrest_me_Suzanne%21]
Suzanne Shell. This woman is dangerous, we need to stop her NOW. Solidarity,
Comrade Ringo Kamens.”
1110. That people are afraid of what I will have done to them; and
1111. That my seminar products and training programs were not unique and that I had no
proprietary rights to the methods I had developed;
a. On or about September 8, 2004, A. Dutkiewicz and Connecticut DCF Watch
advertised on JFF52 that my seminar consisted of information stolen from others
and it was “DUH it is COMMON SENse. [sic]” It wasn’t common sense before I
created it and advertised it.
b. On or about April 16, 2005, AFRA BOD Martin advertised on AFRA groups,
“AFAC has nothing unique. If SS thinks her stuff is unique with copyrightable
techniques she's deluded.”
c. See ¶1423, re: On or about April 20, 2005, Jackson published on AFRA Directors
disparaging my right to protect my IP.
d. On or about April 23, 2005, AFRA BOD Martin published on Directors,
51
Absolutely false. There are many individual and organizations working who have not
been trained by me.
52
Justice for Families interactive online Yahoo! group.

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“We're all free to operate without fear of SS ... except those who signed
"non-disclosure agreements" ... if they decide to become independent of
FRAI they could be using things they learned at these elite seminars. If
they then wanted to remain active advocates they could be breaking
their agreements, and could be rendered useless by not using ideas they
picked up at the seminars rather than elsewhere. So it appears they are
imprisoned and constrained by the deal they chose. The rest of us are
using the same techniques because they've been around for years and
we knew about them from way back when.”
1112. That I had offered to “represent” one of the defendants in a case for $5000;
a. On or about August 15, 2005, Blair falsely advertised to over forty recipients,
including groups, “I approached . . . Suzanne Shell about it via email.. . .She
first suggested that I cough up $5,000 so she could come over to Michigan to
‘represent’ me. (I thought she was an attorney.)” I never represented myself to
be an attorney. I never offered to represent anyone for any reason, nor ever asked
for money to do so. Blair never contacted me. This is a fabrication.
1113. That I fabricated sexual harassment charges against one of the defendants;
a. On or about February 17, 2005, AFRA BOD Linda Martin published to
AFRA_Directors that I was setting Henderson up for sexual harassment charges
because I complained to him to stop making personal and sexual innuendos
toward me. Jackson agreed with her on February 18, and stated I had a screw
loose.
b. On or about May 23, 2005, on Directors, Henderson said, “ She even went so far
as offering to fabricate a sexual harassment case against me because I used to
end my phone conversations with the Christian "I love you".
http://groups.yahoo.com/group/AFRA_CenCom/message/9875 This was a
misrepresentation of the comments he made to me.
1114. That I shoot at people with guns;

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a. On or about December 3, 2004, A. Dutkiewicz published to undisclosed recipients

in response to my request for information from families supporting a Justice
Department investigation,
“Serving [Shell] will be a problem as she told me that if a process
server shows up on her property she WILL shoot to kill. . . . Rocco
Meconi has her served by certified mail the courts will NOT risk sending
their people in there anymore as she has fired shots but CO law is such
that she can do this and not be in trouble.”
I have never shot at anyone, nor pointed a gun at anyone, nor threatened to shoot
anyone. If Meconi has made such claims, that is yet to be determined and could
constitute grounds to add him as one of the unnamed defendants. Colorado law
does not permit anyone to use a firearm as A. Dutkiewicz has described.
b. On or about January 16, 2006, A. Dutkiewicz advertised on DCFreformFL, “She
also has shot at people with her gun.” This never happened.
c. On or about February 10, 2006, A. Dutkiewicz falsely advertised on
cp_prosecutions,
“Just wanted to know so a process server can meet you and save me
the costs of sending to Colorado and him/her getting shot by you as you
once promised me you would do to any process server on your
property.... it is also why Julie Marshall, Rocco Meconi and many others
process serve you through the mail now..... say aren't you suppose to
serve time for that contempt charge sometime soon... hope it doesn't
happen when you are supposed to be at one of your seminars.......”
d. In a subsequent message on the same date, she said, “By the way i would advise
that you do not bring your gun to CT unlike the hicksville of Colorado where
you hail from we have laws against gun toting nut jobs...”
e. On or about December 28, 2006 believed to be a defendant (possibly Swallow or
Durand) signed as consumer advisory anonymously posted on
coloradoconfidential.com,

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Here is one for you all to ponder.

1. In 1998 Donna Suzanne Shell was arrested in the Colorado airport for trying
to get on a plane carrying a GUN AND EXPLOSIVES.
2. She was headed to Washington, D. C. to a protest.
3. Inquiring minds want to know just who the target was.
4. Who was Donna gunning after and what were her plans with the explosives?
5. She claimed dumb, and that she did not know that the gun was in her purse?
6. What do you think? Just how stupid does she think we are?
After all she has Kay Henson of Florida deliver her a hand gun when she
arrives to do one of her seminars t here. What is she scared of? Who many
people has this person ripped off?
Sounds like a terrorist to me, what do you think?
I was arrested for a gun. I was acquitted at trial. There were no explosives. There
was no target, I wasn’t gunning for anyone. The gun wasn’t in my purse. It was an
honest mistake made after an exhausting week of travel and speaking
engagements, and I was suffering from a very bad cold and lack of sleep. Ms.
Henson does not provide me with a gun when I arrive in Florida to do seminars. I
haven’t ripped anyone off.
1115. That I ran over someone in my driveway;
a. On or about January 16, 2006, A. Dutkiewicz advertised on DCFreformFL, “she
has. . .ran her neighbor over in the driveway.” I was the one hit by a car in my
driveway by a neighbor. The neighbor was initially charged with attempted 2nd
degree murder.
1116. That I am a liar and scam artist;
a. On or about August 21, 2005, Swallow falsley advertised on CenCom and three
other groups, “[Shell] is nothing but a liar and a scammer.”
b. On or about April 7, 2006, in response to a guest appearance on an Internet radio
show hosted by Citizens for Change, Hinger advertised on AFRA_CenCom, “. . I
could care less about who listens to Shells [sic] rambling and lies. . .” Other
AFRA members picked up the chant, “She has lied and said she took her list

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down.” I did license the articles to others. What they did with them is their
business.
c. On or about April 9, 2006, R. Cygan advertised on bashing_shell, “She is a liar
and a minipulator [sic] and it should be told.”
d. On or about April 11, 2006, A. Dutkiewicz advertised on bashing_shell, “Shell
lies so much she doesn't remember when she has lied or not.”
e. On or about December 22, 2006 Wiseman published on coloradoconfidential.com
that I was a “lier” and provided a link to thetruthistold[dot]com.
f. On or about December 24, 2006, Wiseman published on
coloradoconfidential.com, “shell is a 100% scam. . .”
g. On or about December 31, 2006, R. Cygan signing as “Another harmed by Shell”
falsely advertised on coloradoconfidential.com, “She is vicious. A liar and a con
artist. . .Lies Lies and more lies!”
h. On an unknown date and still on display as of October 29, 2008, Wiseman and/or
one or more of the defendants posing as Wiseman falsely advertised on
thetruthistold[dot]com/stalking2.html “ poof that Shell is a liar.” There was no
legitimate proof that I was a liar.
1117. That I was being investigated for various crimes including inter alia racketeering, kiddie
porn, stalking and extortion and there were multiple open FBI cases against me;
a. On or about March 27, 2006, Wiseman wrote to Citizens for Change and told
them I was under investigation by the Justice Department. I have never been
contacted or investigated by the Justice Department.
b. On an unknown date and on display as of October 29, 2008, Wiseman or a
defendant posing as Wiseman falsely advertised on
http://www.freewebs[dot]com/billywiseman/wisemanthree.htm that I blackmailed

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and/or extorted him. I sent a cease and desist copyright infringement and demand
for payment according to the terms on my web site.
c. On an unknown date and still on display as of October 29, 2008, on
thetruthistold[dot]com/attackanswer.html Wiseman falsely advertised a previous
publication by Hinger I was under investigation by the FBI for my part in an
underground railroad. I have contacted the FBI who have advised me there have
never been any open complaints against me and I have never been under
investigation.
d. On or about April 7, 2006, A Dutkiewicz communicated with Citizens for Change
and told them
“Why don't you invite me on to share with you and the public how this
woman linked to a Christian Patriot movement has so terrorized my
life and the lives of others that a fair # of us have open FBI cases on
Suzanne.”
There are no FBI cases against me, I am not associated with a Christian Patriot
movement (whatever that is), and I have not terrorized anyone.
1118. That I owned and operated an illegal underground railroad to conceal fugitives from the
law;
a. See ¶1210; re: Jackson providing safe house to fugitive family
b. See ¶1153.a: re: Kiefer collecting funds for family in Famtrak.
c. During the summer of 2005, AFRA member Nancy Luckhurst solicited donations
from a local politician to transport the Lake family from Michigan to a safe house
in Oregon sponsored by another AFRA member. The Lake family was
subsequently removed to another AFRA safe house owned by Roger Weidner,
whose house was ultimately raided by law enforcement on August 14, 2005. Lake
was taken into custody and transported back to Michigan on criminal charges.

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Luckhurst was the conductor in the underground railroad for this family.
d. During July and August 2003, Cygan provided a safe house to a family T.M. in
the underground railroad. See 439¶.
e. During December 2003, Swallow provided her home in Florida as a safe house in
the underground railroad for the Stratton family of North Carolina at the request
of Keifer.
f. During mid 2005, AFRA BOD Kiefer provided his home in Missouri as a safe
house in the underground railroad for the Stratton family from North Carolina.
Kiefer was the conductor in the underground railroad for this family. Barnes and
CPS Watch provided advocacy services to Strattons, whose parental rights were
ultimately terminated.
g. On July 16, 2007, Hinger falsely advertised on AFRA_Talkline and AFRA
HelplineYahoo! groups that my organization ran an underground railroad for
parents involved in CPS cases, and falsely claimed that parents who participated
were put in jail and their parental rights terminated. Members responded in
support of AFRA’s position against me, including Contreras, “. . .the
underground Raiload is as bad as CPS or worse.” Hinger responded that AFRA
welcomed “support of my post trying to inform our newer members of the
deceitful faction on these groups.” I have never operated or participated in any
underground railroad. I have observed the defendants operating and participating
in this underground railroad.
h. On or about August 25, 2007, Hinger falsely advertised to a private list of
recipients which was disseminated by the recipients to the online groups,
“AFRA's groups are ripe with Suzanne Shell, and a constant source of
her efforts to entrap people into UPL and tie Fam Track to AFRA so she
can slip out from under it now that it is public knowledge.”

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Famtrack–the name for the underground railroad–was an AFRA endeavor from its
inception.
i. The same statement ¶1118.g by Hinger was republished and on display as of
September 9, 2009 at thetruthistold[dot]com/SoosieFloosie2.htm.
defndant(s) posing as Wiseman falsely advertised on
thetruthistold[dot]com/atttackanswer.html an advertisement that I was fully
involved with FamTrack, which was being described by the defendants as illegal
activity.
1119. That I issued death threats against others;
a. On March 29, 2006, A. Dutkiewicz published to cp_prosecutions that she had
received death threats from me and/or my supporters.
1120. That I was linked to the Christian Patriot and/or Sovereign Citizen movement and I had
participated in a tribunal and adjudicated A. Dutkiewicz to death;
a. On or about December 3, 2004, A. Dutkiewicz falsely advertised to unknown
recipients in this market,
“Shell belongs to a growing militia movement called by many names but
is known widely as Soverign Citizens. She and her Common Law cronies
have actually held their own cort like preceedings and I personally have
been adjudicated for death because of my Pagan choices.”
It will surprise the defendant to know that I didn’t pay that much attention to her
being that I was too busy with my legitimate work.
b. On or about April 12, 2006, Durand falsely advertised on bashing_shell,
“Aimee, She’s in with those ‘patriot’ types....ya know the militia types
she’s always bad mouthing....Brend [Swallow] has a tape where ss
advocates the use of a gun. . .”
I don’t advocate the use of a gun. I am not “in” with militias or patriot types.

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1121. That I had committed perjury and was going to jail,

a. On or about June 14, 2006, R. Cygan published to my Improvement Project
group, “You have continuously lied to people in this movement and have gone
so far with your dishonesty as to commit purjury in a court of law.”
1122. The false statements made about me and about by associates described above, and
concerning criminal conduct, abuse or neglect of children, abusive parenting,
pornography, violence, deception, wrongs against others, competence, outcomes, skill,
and efficacy, directly reflect on my professional abilities, and on the quality of the goods
and services I created and which I personally represent as part of my commercial
activities and which I offer to the public based substantially on my competence, integrity
and skill.
1123. The defendants’s false advertisements on those subjects are intended to undermine my
business reputation and goodwill by suggesting I conduct my commercial activities in an
incompetent, unethical or immoral manner or that I am unqualified to practice in a
profession that involves children and vulnerable families.
1124. There are false and misleading statements made by the defendants about the defendants’s
products include repeated and multiple false advertisements as follows:
1125. That any or all of the defendants claim to posses credentials they do not posses; and
a. On December 28, 2003, Westlaw Legal Directory
(http://pview.findlaw.com/view/31844061) displayed CPS Watch, Inc. as a law
firm specializing in Family Law, Civil Rights and Constitutional Law. Cheryl
Barnes was listed a Public Interest attorney. This advertisement was submitted by
Cheryl Barnes and CPS Watch, Inc. Barnes was not and is not an attorney, and
CPS Watch, Inc. is not and was not a law firm.
b. On or about July 11, 2004, Henderson advertised on CenCom, “Dorothy [Baez] is

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AFRA's official Private Investigator. Maybe we should talk with her.” Baez is
not a licensed Private Investigator. Her license had lapsed.

c. W. Tower represented in multiple fora starting in 2005 that he and A. Tower
were law students. An investigation into this claim in May of 2006 revealed that
Tower was never enrolled in Pacific McGeorge School of law as he claimed.
d. W. Tower advertised on AFRA groups that he was a CASA (Court Appointed
Special Advocate) and a GAL in California. Investigations into these claims in
July and August 2006, revealed that he was not a CASA nor a GAL.
e. Since July, 2006, Wiseman has claimed to be a journalist and the defendants have
endorsed this. The defendants claim that he publishes a web site is not sufficient
to support this specious claim of being a journalist. He can’t even write.
f. On or about March 24, 2006, Hinger advertised on Directors that W. Tower
served “30 years in the military,” “was a First Sergeant,” and,
“. . .was a California Certified Para Legal and well on his way to

becoming a lawyer. Plus he has many contacts in Washington
with HHS as well as the Judiciary Committee. And he has had
many successful cases on behalf of families throughout the
country and is recognized by many attorneys throughout the
country as an expert in family rights cases.”
An FOIA request to National Personnel Records Center, Military Personnel

Records, reveals W. Tower served in the Army National Guard from March 26,
1978 to March 31, 1981 (Active duty). There is no such thing as a “California
Certified Paralegal,” California does not have licensing or certification
requirements for paralegals. Tower is also not enrolled in a law school, which
indicates he is not well on his way to becoming a lawyer. I believe he could not
pass the LSAT. He does not have “many contacts” in HHS or the Judiciary
Committee. His purported “successful” cases do not include instances where the

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subject children were reunited more quickly than is the agency norm, nor any
other measures that indicate his participation resulted in a better outcome than
agency norms. He is not recognized by attorneys throughout the country as an
expert in family rights cases.
g. On or about December 29, 2006, one of the defendants signing as T.M falsely
advertised on coloradoconfidential.com, “. . .William O Tower (retired military
officer and respected legislative congressional speaker” So, which was it, Non-
commissioned officer or Officer? How does one retire after less than three years
service? The statement is so absurdly false.
1126. Statements which exaggerate or misrepresent the rate of their successful outcomes on
cases which they provided services as advocates;
a. On or about May 13, 2004, Henderson took credit on behalf of AFRA on CenCom
for advocacy in the nationally publicized He case in Tennessee. He made it appear
that AFRA had more influence on that case than it did. The He’s TPR was
overturned due to participation by a FRAI trained and certified advocate. The
language in the Tennessee Supreme Court decision was the FRAI consultant’s
language.
b. On or about May 14, 2004, Kiefer falsely advertised on all AFRA groups, “We
just got back Alisha this year after a FOUR YEAR Battle.” Kiefer’s daughter,
Alisha, had aged out of the child welfare system at age eighteen. He falsely
portrayed this as a victory based on his skills, when it was only that the child
voluntarily returned to the family after being kicked out of the foster home when
the state could no longer provide services. He ignored subsequent requests to
clarify whether she aged out or he won on his merits.
c. On or about October 4, 2004, T. Dutkiewicz advertised to an undisclosed list of

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recipients, of which I was one that W. Tower had gotten child number twenty-five
returned home due to his quick wit in court. He effectively argued jurisdiction,
reasonable efforts and just plain incompetence. He stated Tower has a “proven
formula” on what to argue and the techniques to argue with the best of them.
Tower is not an attorney. Furthermore, the content and performance during his
public speeches and in his conversations with me and my associates are not
consistent with this analysis. Hinger debunked this when he was kicked out of
AFRA. See 1128.a¶.
d. On or about December 5, 2004 T. Dutkeiwicz advertised to an undisclosed list of
recipients, of which I was one, “Mr. Tower is a good friend and has gotten over
25 children home in the last several months in California.” This is misleading.
If he did not get those children home in less time than they would have come
home without his participation, he didn’t contribute to their coming home.
e. On or about April 7, 2006, A. Dutkiewicz published to CFC “Bill Tower the man
she links with my name has brought 28 home in the last month himself..... he
was also a big part of that family in Calf that won 2.6 mil for wrongful
abduction of their children.... he also was part of the investigation that is
forcing one county in CA to pay back 400 million to the FEDS.” He did not
bring home 28 children in March, 2006. He was not part of the lawsuit as she
represents. He is not part of the investigation as she represents.
f. See ¶1127.d, re: AFRA false advertising as responsible for winning TPRs.
g. See ¶1125.f, re: false claims about W. Tower successful outcomes.
1127. Statements which exaggerate or misrepresent their expertise in certain areas of skill and
knowledge; and
a. On or about May 16, 2004, T. Dutkiewicz answered a request on CenCom for

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someone to help with a civil lawsuit they were trying to file. T. Dutkiewicz
offered advice about naming the defendants in their “official capacity” and
“individual capacity” and asked for case specific details needed to draft the
pleading. He also referred the member to W. Tower as being capable of handling
this. T. Dutkiewicz had previously advertised W. Tower to consumer(s) as “the
master of civil rights lawsuits.” See ¶316 regarding Tower filing an appeal for
his Maine case in California, which obviously refutes this claim.
b. On or about December 5, 2004 T. Dutkeiwicz advertised to an undisclosed list of
recipients, of which I was one, “These questions were put together by William
Tower who is an authority on "reasonable efforts" covered under Title IV-E.”
Tower is no authority on Reasonable Efforts. What he knows he got from my
proprietary content, and didn’t even get that right when testifying before a
congressional committee.
c. See ¶1126.e, false advertising re: Tower accomplishments
d. On or about July 7, 2007, Hinger falsely advertised on AFRA groups that AFRA
members were responsible for the reduction of children in California foster care
by 25,000, and that as many people who used to lose Termination of Parental
Rights (TPR) hearing were now winning them, and that “lawyers across the
country are now coming to [AFRA] for advice on how to pull lost cases out of
the fire.” I has been my experience and the experience of my associates that
lawyers drop clients who associate with AFRA and legislators view AFRA as
kooks. AFRA has a very bad reputation with professionals in this market.
e. On or about August 2, 2007, Hinger falsely advertised on AFRA_Helpline again
that AFRA was responsible for more than 25,000 foster children being returned to
their parents in Los Angeles county.

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f. On or about August 2, 2007, on AFRA_Helpline, Hinger stated AFRA was

getting laws changed nationwide. No new laws promoting family rights have been
changed in any state due to AFRA lobbying.
1128. Statements which exaggerate or misrepresent their competence or qualifications to offer
goods and services; and
a. On or about August 25, 2007, Hinger published to a list of recipients who
transmitted to online groups exposing AFRA’s advertisements W. Tower’s
expertise as being false and misleading,
“Another thing that Bill [Tower] is trying to keep from coming to light is
his alleged Habeaus Writ that he says he can't share with anybody but
an attorney . .and Bill failed to produce anything...When Nancy
Luckhurst confronted Bill, he still failed to prove he actually has such a
miracle bullet as he brags and boast about.”
b. On or about January 29, 2010, Barnes and Howard were ejected from a
courthouse in Arkansas in a case (Tony Alamo Ministries) where they had
advertised in their own publications they were advocates for the parents They
were ejected for violating gag order with the media. They were not actually
working with the parents’s attorneys as evidenced by them not being allowed in
the court room during the proceedings. Competent advocates or consultants who
are part of the legal team aren’t excluded from courtrooms, even closed courts,
much less being removed from the entire courthouse. And they don’t violate court
orders. Parental rights were ultimately terminated in this high profile case and
appeals failed because the appealable issues weren’t raised at trial.
c. CPS Watch, Inc., Barnes and Howard also advertised they worked on the civil
rights lawsuit for these families, which was dismissed.
1129. Statements which exaggerate or misrepresent the mental health and stability of certain
defendants;

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a. On or about September 5, 2005, Swallow stated on

Justice4ChildrenParentsAndFamilies_NW_FL group, “No actually I am vvery
[sic] mentally stable.” Swallow was histrionic, irrational, unstable and very
difficult to keep focused and on an even keel when I worked with her. That was
one of the reasons Ms. Henson and I revoked her certification.
b. On or about February 13, 2005, Baez falsely published on Cencom that R. Cygan
“suffers from no mental illness whatsoever.” In fact, R. Cygan has been
repeatedly diagnosed with bi-polar mental illness, and is supposed to be on
medications. R. Cygan herself published and admitted she does not take her
medication, and instead, relies on “service dogs” to provide the therapy she claims
she requires for her mental instability.
1130. Statements which exaggerate or misrepresent the origin or efficacy of publications and
training offered or promoted by them;
a. All references by CPS Watch , Barnes, Howard and Thompson that Parent’s
Guide to the System was the result of Barnes’s research and original authorship.
b. All references by the Dutkiewicz’s that their book and tips of the week were the
result of their research and original authorship.
c. All references to Hinger’s brochures, including htd.pdf, being the result of his
research and original authorship.
d. Henderson’s taking credit for AFRA for my children’s book, Knowing My Rules.
1131. Statements which offer harmful or false advice to consumers about how to handle their
family’s child welfare case or to advocates to protect themselves in their work;
a. On or about April 8, 2004, T. Dutkiewicz offered erroneous advice on AFRA

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groups, “Under reasonable efforts53, CPS is compelled by law to place the child in
"kinship care" before going to foster care. A back ground check is the only
requirement.” This is in error. There is no mandate to place a child in kinship care,
and background checks are not required under reasonable efforts for kinship care.
b. On or about July 5, 2004, Connecticut DCF Watch and T. Dutkiewicz provided
this analysis to all online groups,
“Those of you who had their rights terminated or in the process thereof,
should go their state's supreme court and use Crawford v. Washington if
hear say [sic] was used or the only thing used in order to overturn or to
seek injunctive relief.”
This case refers to criminal proceedings. T. Dutkiewicz’ analysis completely

misses that critical point when he attempts to advise consumers to apply it to child
welfare proceedings.
c. On the AFRA web site, AFRA advises parents to represent themselves in child
welfare cases at http://familyrigths[dot]us/how_to/fight_cps.html This is
extremely harmful advice, especially in the context of the advice AFRA gives
parents on how to represent themselves including filing affidavits to “get your
version of history on the record.” AFRA provides a link to a sample sworn
affidavit to be filed in the case at http://familyright[dot]us/bin/forms/sworn-
affidavit.html. This advice has literally harmed me, too, because the Colorado
Attorney Regulation Counsel attributed this legal advice to me during my UPL
contempt proceedings, despite the fact that I did not promote or support this
advice, and witnesses testified that I did not.
d. On that same page, AFRA advises the parents to ask the court if they are in “a
Constitutional court of due process,” ignoring the proper procedures and
53
A federal mandate administered by the states.

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jeopardizing their case.

e. On or about August 10, 2007, Hinger advised advocates on AFRA_Helpline to be
sure to put a disclaimer on all of their legal advice emails that they are not
attorneys as a protection against a UPL complaint for the case-specific legal
advice they disseminate.
f. On or about January 20, 2008, Henderson advised on AFRA_Swat and
USA_EAGLE that parents should file an Affidavit in their child welfare case.
Consumers have actually been harmed by following this advice from AFRA for
years.
g. On or about March 6, 2008. Henderson advertised on HelpLine that parents
should obtain the book Sui Juris by Pamela Gaston and follow the book’s advice
in their child welfare cases. This book cites “patriot law” fallacies which have
been proven to harm a person’s legal interests in court.
h. On or about March 17, 2008, Henderson again advertised Sui Juris on Helpline
and provided links to AFRA’s web page where he gave advice into some of the
methods from this book that parents should use in their child welfare case.
i. Throughout 2008-2010, Henderson advised AFRA group members hundreds of
times to file their “Sworn Affidavits” in their respective court cases and to follow
the directions at AFRA’s link “How to Fight CPS,” including each new member
who had just joined. In each instance, the advice given was case specific.
j. On or about November 13, 2009, Henderson gave case specific legal advice to a
member on Helpline stating, “The only thing that matters is GET YOUR VERSION
OF HISTORY ON THE RECORD IN COURT. Everything else is fluff and bullshit.”
k. On or about November 25, 2009, Henderson published a listing on AFRA
attorney’s page for Julie Hatcher (Kansas) who stated she was willing to represent

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parents in their civil rights claims nationwide. Henderson referred many members
of AFRA groups to Ms. Hatcher for legal representation. My investigation
revealed Hatcher was not an attorney, but a mother whose child had been taken by
Kansas SRS.
l. On or about November 25, 2009, on AFRA Helpline, Henderson advised
members that they can “kick ass” filing Sworn Affidavits and, “It’s the only
‘legal’ thing I know how to do. But all legal papers filed in court follow the
same format. You learn how to do this and the same format is used for
EVERYTHING else.” Sworn affidavits are not effective.
1132. Statements which falsely represent that they work with attorneys and that the attorneys
find their services valuable on cases.
a. See ¶1127.d, re: lawyers relying on AFRA advice.
b. See ¶1128.b re: CPS Watch on Tony Alamo Ministries. They were not working
with the parent’s attorneys on this case.
1133. The statements made by the defendants were literally false on their face or by necessary
implication, or that the statements were literally true but likely to mislead or confuse
consumers.
1134. The statements were made on multiple public forums which are used to conduct our
respective businesses activities for the express purposes of soliciting consumers to utilize
the defendants’s respective products and services, and on multiple public forums directed
to the general public.
1135. The defendants’s false advertising included but was not limited to product disparagement
directing consumers to eschew my products by libeling and slandering my products, my
qualifications, my competence, my ethics, my morals, my outcomes and my commercial
activities.

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1136. The defendants’s false and misleading advertisements and product disparagement
statements about me and my associates were done deliberately, maliciously and in bad
faith and include representations that the defendants had no reasonable basis to believe.
1137. The effect of the false and deceptive advertising was that the consumers, being so
inundated with these incessant ugly messages finally just didn’t care about the debate,
regardless of the fact that I didn’t participate. They recognized I was not participating.
They were fed up with the impact on innocent bystanders. They wanted nothing to do
with any of us. The defendants had accomplished their objective to eliminate me from the
market and the Internet.
1138. Another effect of the false and deceptive advertising was that the consumers believed the
defendants’s false advertisement and have eschewed my business, my products and my
services. The defendants have accomplished their objective.
1139. Another effect was the fear expressed by those who wanted to obtain my products from
me that they would be similarly targeted by the defendants, so they felt they had no choice
and could not obtain products from me.
1140. As a proximate cause of the pervasive false and deceptive advertising, I have suffered
substantial damages including but not limited to loss of business, diversion of sales, loss
of goodwill, loss of business reputation and consumer confusion. I have has suffered
professional shame and mortification, loss of business, impairment of standing in the
family rights community, mental pain and anguish, damage to my business and
professional reputation, humiliation and depression; and an impairment of my ability to
promote my training and products in this market, and impairment of my ability to acquire
new licensees and expand my influence, to announce recent accomplishments and
appointments and upcoming presentations for fear that such announcements will unleash
another round of defamatory publications which expose me, my business and my

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professional reputation to abuse, contempt, ridicule and obloquy by others and which will
cause the business associations and contracts to be interfered with to my detriment.
1141. This injury is not limited to my work in the child welfare arena. The defendants’s false
advertisements are so pervasive, that should I attempt to ply my craft–writing–in another
arena, that potential outlets to sell my work would shrink from me based on the bad
reputation the defendants have created about me and the conflict that so obviously
surrounds me where ever I go.
Ninth Cause of Action
Unfair or Deceptive Trade Practices and Unfair Methods of Competition
6-1-105 C.R.S and 5 U.S.C. §§ 1051; 15 U.S.C. § 1127
forth herein.
1143. All defendants are liable for the injuries and harms claimed in this cause of action.
1144. From the period of time starting on or about August 2000, continuing to the present, the
defendants have engaged in unfair or deceptive acts or practices, or in unfair methods of
competition in or affecting commerce.
1145. The defendants engaged in unfair or deceptive trade practices with the intent to injure
competitors and to destroy or substantially lessen competition.
1146. Defendants’ acts were and are intentional and carried out for the purpose of competing
unfairly with me.
1147. The defendants acted in bad faith and their conduct was fraudulent, willful, knowing or
intentional.
1148. The challenged practices occurred in the course of defendants's businesses, vocations, or
occupations and/or the defendants conspired with others who were engaging in the
challenged practices in the course of their businesses, vocations or occupations.
1149. The challenged conduct significantly impacts the public as actual or potential consumers

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of the defendant's goods, services, or property.

1150. In the course of the defendants’s business, vocation, or occupation, the defendants
knowingly make false representations as to affiliation, connection, or association with or
certification by another; knowingly makes a false representation as to the characteristics,
uses, benefits, property or a false representation as to the sponsorship, approval, status,
affiliation, or connection of a person therewith; represents that goods, services, or
property are of a particular standard, quality, or grade, or that goods are of a particular
style or model, if they know or should know that they are of another; knowingly
disparages the goods, services, property, or business of another by false or misleading
representation of fact; make false or misleading statements of fact concerning the price of
goods, services, or property or the reasons for, existence of, or amounts of price
reductions; with intent to injure competitors and to destroy or substantially lessen
competition.
1151. The unfair or deceptive trade practices and unfair methods of competition committed by
the defendants include, inter alia;
1152. Theft and misappropriation of my trade secrets and proprietary information to the
defendants’s use;
a. On or about April 13 through 20, 2005, AFRA Directors, including defendants
Kiefer, Jackson, Henderson and W. Tower, discussed their disapproval of my
protecting my intellectual property rights as “compromising AFRA’s potential
effectiveness.” The AFRA BOD decided AFRA should not put up with my
“dictatorial control” of my business operations and intellectual property and
conspired to “duplicate” my “innovative” and “pioneering” body of work. They
subsequently acquired unauthorized access to some of my work as described in
the First Cause of Action in this complaint.

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b. ¶823 Prior references to Contreras obtaining and using my proprietary content.

c. ¶813 Prior references to Baez having my proprietary content.
d. ¶1537, 814 Prior references to Swalllow and Durand disseminating my proprietary
content.
e. ¶815 Prior references to A. Dutkiewicz having seen my proprietary content.
f. ¶1529 Prior references to R. Cygan having possession of my proprietary content.
g. ¶984 Prior references to W. Tower having my proprietary content.
h. ¶¶ 347, 344, 346 Prior references to A. Tower using my proprietary content.
i. ¶366 Prior references to Hinger using my proprietary content.
1153. Fraud or misrepresentation in a commercial setting;
a. Around March 2003, Kiefer publicly solicited donations for a family in the
underground railroad on the groups, T.M. He did raise funds for them through
AFRA groups and other arenas, but none of the money he collected went to this
family.
b. Around July to August 2003, R. Cygan publicly solicited donations on behalf of
T.M. who was being housed with R. Cygan in the underground railroad. Terrilyn
Simpson sent money to R.Cygan for T.M.. This money was never given to T.M.
R. Cygan also stolen T. M.’s personal belongings and kicked her out of the house.
c. Between mid 2001 to 2003, I received multiple complaints that Barnes and CPS
Watch had advertised subscriptions and products, had received the payments for
those products, but had never received those products. I advised Barnes of these
complaints, who did not provide the products to the customers who had purchased
them.
d. On August 14, 2003, I was contacted by a client of Barnes, Greg Riley, who
complaint she had taken his money but not provided the advertised products.

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e. On or about April 8, 2006, a member posted on CenCom that she had information
that an AFRA member price-gouged a parent for $500 and did not deliver
promised services. I had previously received the same complaint, and attempted to
contact the offending advocate with the complaint who verbally abused me. The
victimized parent subsequently put the same complaint to W. Tower on an AFRA
group, who responded with verbal abuse and denials and ultimately rejected the
complaint publicly. M. Cygan, IFAC, took responsibility and oversight for that
advocate, and also refused to investigate or make the advocate refund the parent’s
money, and who verbally abused me on CenCom, when I wasn’t even a
participant.
f. On February 18, 2010, Howard advertised on CPS Watch Yahoo! group, “CPS
Watch®54 is a non-profit Christian charity corporation duly organized under
the State of Missouri Nonprofit Corporation Law. CPS Watch, Inc. is an IRS
501(c)(3) tax-exempt organization, to which all contributions are tax-
deductible.” A search of the IRS records of 501(c)(3) non profit organizations, and
a subsequent phone call to the IRS reveals CPS Watch, Inc. is not listed as a
501(c)(3) organization, and does not have an Employer Identification Number.
CPS Watch, Inc. is and/or has been administratively dissolved by the Missouri
Secretary of State and ordered not to conduct business for years during the time
frame of this complaint and therefore cannot be a 501(c)(3) tax-exempt
organization pursuant to IRS regulations.
g. See ¶333, re: no accounting for AFRA fund raising.
h. According to internal information disclosed by unhappy clients early in 2010, CPS
54
A search of the U.S. Patent and Trademark Office reveals no such trademark
registration.

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Watch, Inc., misrepresents to those who approach them via CPS Watch Legal
Team web site during the initial consultation saying they would represent parents
in a child welfare case for free, the only cost being that CPS Watch would require
a donation from the proceeds of any civil lawsuit arising out of the child welfare
case. However, once the client was accepted, they employed a “bait and switch”
tactic, charging a retainer of $500.00 to get started, and hourly rates of $125.00 for
“litigation specialists” Barnes and Howard, and $350.00 for Phillip Kuhn for
civil, $500.00 for criminal. In response to the customer’s complaint about bait and
switch, Howard got offended and reminded the clients they were allowed to join
CPS Watch support network for free and gave them Parent’s Guide to the System
book for free. Howard stated CPS Watch is, “the best at what they do and
nobody can compare.”
1154. Situations in which the defendants divide up a territory in order to minimize competition;
a. On July 1, 2004, Hinger recommended on AFRA Directors that I was a
“problem” and must be brought “into line” with “the rest of the movement”
(meaning AFRA) or else AFRA should discredit me.
b. On July 7, 2004, Henderson offered the recommendation on AFRA Directors to
“pull [my] fangs and remove [my] power.” Since my market power was vested in
my superior products, AFRA had to divest me of those products, and take them
for AFRA’s use.
1155. Libeling or slandering my business, my products or my business activities;
a. On or about May 18, 2004, T. Dutkeiwicz broadcast to defendants’s interactive
online groups and a list of undisclosed recipients stating that I was slandering and
harassing the Dutkiewicz’s and that I had “impersonated to be an attorney
several times.” I had never represented myself to be an attorney, and was never

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accused of that. The publications I authored on my web site were truthful, and
were never advertised by anyone (except the defendants) on any group. People
had to go to my web site to see them, I did not post links on any group. The
defendants were the ones blabbing about what was on my site all over the Internet.
See ¶519.
b. On or about July 6, 2004, Henderson advised AFRA BOD on Directors about a
new consumer advisory article on my web site and stated, “I have been doing my
best to get people to ignore it and deny it any power.” He did this by maligning
my research and reporting skills, and by maligning me and my business.
c. On or about June 26, 2004, on CenCom, AFRA member Amtower falsely
advertised,
“The problems in this group were started by Suzanne and her cohorts . .
.I know by posting the truth here, AFRA will step up the trashing and
discrediting and credit grabbing campaign which was already started by
suzanne and cohorts long ago.”
Henderson orchestrated all the problems, and provided the forums freely to those
who implemented his agenda to bring me under AFRA control.
d. On or about July 27, 2004, on CenCom, AFRA member and agent Jack Stratton
wrote,
“Then, because individuals may not agree with the pronouncements of
these self proclaimed ‘gurus’ (referring to me), the dissenters are
deemed as worthless or worse, traitors to the cause. . .you would not be
so self deluded that you think your every pronouncement was correct
and anyone who disagrees is a ‘bad advocate’. . .”
The consumer advisory had nothing to do with disagreement, or not taking my

training. The criteria for inclusion was clearly defined, and included fraud, theft,
and harm to their clients.
e. On or about February 16, 2005, AFRA BOD, member and agent Martin stated on

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Directors that I had a “. . .proclivity for causing trouble, finding trouble,

pontificating on trouble, and getting into trouble with the law. . .”
f. See ¶1101.a; re. March 9, 2005 attributing “in your face” methods to me.
g. On or about August 13, 2005, Swallow falsely advertised to over forty recipients
including AFRA and non-AFRA groups,
“URGENT: SUZANNE SHELL SOON TO BE CHARGED WITH UPL,
RACKETEERING, CONSPIRACY TO COMMIT FRAUD AS WELL AS
ANY OTHER CHARGES PENDING INVESTIGATION. During the past
year Suzanne Shell has been engaging in numerous "Illegal" "Unethical" and
morally unacceptable behaviors in regards to our movement "Child and
Family Protection".First and foremost is the development of FRAI-" Family
Rights Advocacy Institute" The Institute in itself is a cover-up to secure and
protect Unethical Attorney's for Profit of the Institute not to secure Ethical
Attorneys to represent clients in need of legal representation to gain or
regain custody or protect their family/children from the system. I have
evidence that Suzanne Shell had knowledge one of her "Attorney's Mr James
R Filenbaum"was disbarred in not only New York but recently in Florida as
of June 2005.”55
This was all false. This advertisement was not disputed nor removed by AFRA
moderators.
h. On or about September 9, 2005, Swallow published to over forty AFRA and non-
AFRA groups,
“Shell-The Worst Advocate or Advisor as well as in NO WAY SHAPE OR
FORM QUALIFIED TO TEACH ADVOCACY . . .She turns in Advocates and
Families....She contacts Probation Officers with False Information and
advises her "Followers" to do the same...She only has Seminars for
Profit to make money and sell more books and literature.”
This was all false. This advertisement was not disputed nor removed by AFRA
moderators.
i. On or about September 9, 2005 Swallow brought AFRA’s message to other
55
James Filenbaum was an attorney in good standing in Florida until July, 2005. At that point, he
was suspended, not disbarred.

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groups and advertised to Parents-VS-CPS group, “Jim's financial records indicat

in no way shape or form was he employing Kay henson or Suzanne Shell
therefore both are guilty of practicing law without a license.” This is a straw
man. We working under this direction and supervision.
j. She also stated in disparagement of my products and ethics,
“KAY AND SUZANNE ARE BOTH LIARS, SCAMMERS AND SHOULD BE
STEERED CLEAR OF...AS FAR AS HER ADVOCACY AND INSTITUTE... IT
IS BULLSHIT NOT WORHT THE PAPER IT IS PRINTED ON.....BEWARE
THIS IS ANOTHER SUZANNE SHELL ACCIDENT WAITING TO HAPPEN,”
k. On January 15, 2006, A. Dutkiewicz , using an alias, published a review of my

book, Profane Justice, on Amazon.com. The subject line is “The SS SHAM” and
the review states,
“While this book is one of the first of its kind, buyers and readers must
be aware that the author does not speak with complete truths. . . .So
while this is a plethora of helpful information..... most of which was
stolen from others and written in this book as her own ideas...”
l. On or about January 16, 2005, Swallow falsely advertised on DCFReformFL that

I was slandering her, that I brought a disbarred attorney “on board,” that my
advocate committed credit card fraud, that the attorney would not file motions that
I wrote, and that I told an advocate to commit UPL.
m. On or about January 19, 2006, A. Dutkiewicz revealed to a consumer, Christy,
that she has spoken with Rocco Meconi, Fremont County, Colorado, County
Attorney representing DHS, and who has filed multiple Unauthorized Practice of
Law complaints against me. He told her I was a very dangerous person. She then
passed this information on to consumers and my competitors, including the
defendants. She specifically recommended Christy seek assistance from Baez.
n. On or about March 7, 2006, Keifer disparaged trained and certified family

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advocates under my supervision by falsely advertising on his Internet radio show

that FRAI advocates charge fees for their services. Wiseman owns the radio
station that hosts Keifer’s program. This program was widely advertised on the
defendants’s interactive online groups and was available to listen to at any time
after the broadcast. FRAI trained and certified advocates have not charged fees.
o. On April 2, 2006, Dutkiewicz’s advertised on the Internet and on the interactive
online groups owned and operated by the defendants and one private email lists
about a new web site at www.thetruthistold[dot]com under the subject line,
“Family Advocate is Finally Exposed on New Web Site.” This web site was
instigated by the defendants and purportedly published by Wiseman. The
defendants contribute to it’s content, including false and defamatory statements of
fact about my business and business activities from previous postings to the
groups owned and operated by the defendants over the years.
p. On or about May 22, 2006, Hinger falsely advertised on AFRA groups,
“. . .people calling Congressman Hergers Office trying to knock [Tower]
off the speakers list and attempting to discredit Mr. Tower and AFRA. .
.They also tried to cancel hi airline reservations . . .They tried to learn
what hotel he is staying in and what car rental agency his is using. . .I
fully expect them to show up at the hearing and attempt to disrupt
while Bill is speaking, but The House Security Office is well aware of all
the efforts to prevent us . . .and will have extra security. . . Dennis
M.Hinger, Executive Vice President, American Family Rights
Association.”
Readers understood this to refer to me. I took no action regarding AFRA’s
or Tower’s trip, and I have no knowledge that anyone else did. Some of
these accusations are so bizarre in view of contemporary security and
privacy policies as to be unbelievable.
q. On or about May 22, 2006, Hinger published to all AFRA groups, AFRA’s terms
of use for groups membership. There was no provision for preventing copyright

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infringement or other misappropriation of intellectual property.

r. On and before May 30, 2006, thetruthistold[dot]com, written by A Person Very
Much Concerned About Ms. Shell’s Threats (Durand or Swallow),
“I remember when she first came online and was asking for help with
her own case and all the people who helped her. Now she is claiming to
have created advocacy herself. What a fraud.” And I have “caused harm
to children.”
This article raises virtually all the issues contained in this complaint. It is
false. My family was investigated in 1991. I was not online at the time
because there was barely an Internet in 1991. The case was closed in 4
days, there was no D&N petition as to my children. I did create the
practice of family advocacy.
s. On or about August 3, 2006, Hinger put out a call to all online interactive family
rights groups, stating I was responsible for Merwin posting a question about a
criminal record with the name Billy Ray Tower, calling for all groups to
“blackball” me and my associates and to get my Improvement Project shut down.
This was an interactive group. Posts by members are not screened prior to posting.
When Merwin asked the question on the group, I responded that no, it wasn’t
Tower’s criminal record. Tower had all those posts, including the ones where I
said it wasn’t his record, deleted from the group archives and used that thread to
justify AFRA’s advising consumers to boycott me and my associates.
t. On or about October 1, 2006, Henderson falsely advertised on Improvement
Project that I was “. . .an instigator, facilitator and active participant in the
[online interactive group] wars.” This characterization was false. The archives
reflect I never instigated, never provided the forum for the disruptions, and had
not participated in any AFRA groups for years, and had not participated in their

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“wars” even when I was the subject of the heated debates.

u. On or about October 6, 2006, Hinger falsely advertised on AFRA groups that I
illegally shut down Justice for Families (JFF) interactive online Yahoo! group and
was trying to “destroy AFRA.” JFF was moderated by Jackson, and routinely
infringed my copyrights. I did make a DMCA complaint to Yahoo! after Jackson
and the other moderators refused to remove the infringing content. I was never
advised as to the outcome of that complaint. However, a DMCA complaint to an
ISP is not illegal. I also had no desire to “destroy AFRA.” If my legitimate
demands for AFRA to stop infringing my copyrights tended to destroy AFRA, I
was not responsible for that outcome.
v. On or about March 20, 2007, Wiseman sent an email to defendants containing a
comment posted by “FlaccidWanker”56 on March 19, on Digg.com. It contained
false and libelous statements about not only me and my business, but about my
parents and parents-in-law, my husband and my children. This was in connection
to the publicity surrounding the Internet Archive case. The Internet Archive story
made the front page of the very popular Digg.com57 as well as other popular social
networking sites. The defendants exploited this publicity about me to widely
disseminate their false articles about me and to divert millions of users and
consumers around the world to thetruthistold[dot]com. They usurped my publicity
to expand their agenda to destroy me. The defendants have never made the front
page of Digg.com.
w. On http://binaryfreedom.info/node/139, authored by Bryan, June 3, 2007, one of
56
An anonymous article authored by one of the defendants.
57
This is an extremely rare feat. My web site got 25 million hits arising out of that
publicity.

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the defendants posing as Wisemann falsely advertised to Bryan, who then

republished that I defamed Wiseman and other people; and that badadvocates.com
was my web site; and that I accused him of stealing a domain name,
familyrightsradio.us; that I accused others of what I was guilty of; that I was guilty
of cyber-stalking, defamation, outright lies and false claims of copyright;
infringement for things published by others; he claimed I had stolen information;
that my methods have been declared harmful to [my] “clients”; that I don’t have
the knowledge to properly train advocates; that I harm families and children by
posting home address and phone numbers on “both” of my web sites and that I
said they deserve to be tormented; that I help felony child abusers continue to
abuse their children; that I employ patriot law; that I use badadvocates.com; that
many people are afraid of what I will do to them; that I have contacted hospitals
and other entities to destroy the family of anyone who disagreed with me; that my
press pass is fake due to being printed off of my computer; and that my actions
and attacks harm children, families and the family rights movement and
advocates. Bryan published this as a purported interview, but never contacted me
during the course of his investigation into the issues raised. These are all false
advertisements about my products, my business and my profession.
x. On or about July 31, 2007, on AFRA_Talkline, Hinger posted a photo of a
skeleton collapsed before a computer and stated, “Below is picture of Shell trying
to pick something both legal and socially acceptable that she can do for living
that is suitable to her moral character and ability. . .hang in there Sue, there
has to e something besides cleaning toilets out there for you.. . .Dennis”
y. On an unknown date and still on display as of October 29, 2008, Wiseman falsely
advertised on thetruthistold[dot]com andpublishes the introduction from a letter

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to foster children from my web site stating that I put “child actor at risk no kid is
safe [sic].”
z. On or about September 5, 2008, Henderson falsely advertised on Helpline, “there
are no press conferences on CPS Corruption.” In fact, I have organized or
participated in many press conferences on this subject across the country during
my years working in this field, as have my associates.
aa. On or about December 17, 2008, Henderson published on Helpline, “After the go-
arounds with ‘her high royal highness the smartest person in the universe’ in
the distant past, I have a real short patients [sic] span.” The “go-arounds”
involve my resistance to his instigating repeated attempts to control my property,
my business and his allowing AFRA to be used as the vehicle to libel my
property, my business and my professionalism. I was minding my own business,
engaged in my work and he would contact me.
ab. On an unknown date and still on display as of October 29, 2008, Wiseman or
thetruthistold[dot]com/martinet.html that I support child abuse. I have never
supported child abuse.
ac. See ¶1095 re: I made clients hire disreputable attorneys.
ad. On an unknown date still on display as of October 29, 2008, Wiseman and/or one
thetruthistold.com/welfarefraud.html that I, identified as a “cohort,” committed
libel and that my participation in online groups was disruptive. I have never
libeled anyone and I wasn’t allowed to participate on groups.
ae. On an unknown date and on display as of October 29, 2008, Wiseman and/or one

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thetruthistold[dot]com/index.html that I that I stole the name “American Family

Advocacy Center” from a government web site.
af. On or about November 8, 2008, Barnes falsely advertised,
“I disagree [Suzanne had contributed to some positive things infamily
rights]. She crafted out an income for herself at the expense of parents
who relied on her advice. Suzanne has said several times that her goal
was to make an income selling her books and speaking. When her bad
advice didn't work and cost parents their parental rights - she attacked
the parents to protect her reputation. She continued to boast a "100%"
success rate - but to this day there is not even one person that will say
"I got my kids back because of Suzanne Shell.
She teaches parents to do things that aren't legal, don't work -
and she forces them to do everything exactly as she says - and they lose
their kids forever. There isn't one person that Suzanne has "helped"
that has custodoy of their children now. They may have a stack of tape
recordings and been converted into one of Suzanne's free helpers - but
they don't have their kids.”
I did nothing at the expense of any parents. I did not give bad advice or tell them
to do illegal things, and my methods work very well. I did not attack parents for
any reason, even when the occasional one turned on me. It has always been my
practice just to walk away from those I cannot work with and leave them alone. I
never boasted a 100% success rate, and many families are reunited because of my
work. I don’t have any helpers, much less free helpers.
1156. Reverse "passing off" of my superior products as originating with the defendants;
a. On November 29, 2002, I discovered on the AFRA web site that Henderson had
published my children’s book ¶252, without giving me credit, taking credit for
AFRA.
b. AFRA’s web site is contains my methods and strategies, presenting as originating
with AFRA and not giving credit to me as the originator of these methods. By
taking credit for my work, the defendants enhance their own status, credibility and

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market share at my expense. On

http://familyright[dot]com/how_to/fight_cps[dot]html, the list of strategies
contained on that page originated with me as follows:58
i. Document. The methods of documentation were first published in my
book Profane Justice, in 1997, four years before AFRA existed. It was
included on my web site and expanded in my subsequent books and
seminars. In 1997, the methods were innovative and daring. Now, they are
common-place. AFRA has attributed these methods to anyone, including
themselves, except me.
ii. Hire a good lawyer. While this may appear to be common sense, the
advice associated with selecting and obtaining legal counsel on this page
again, originated with me in 1997.
iii. Be polite. AFRA’s and CPS Watch’s public posture of the professionals
who administer these cases is overtly hostile, sarcastic and denigrating.
This is the only AFRA location where there is any motion of being polite
exists. I originated this principle in 1997, as part of my overall method of
handling these cases. AFRA has taken credit for this.
iv. Letters to and from agencies, is my original idea, that did not exist in 1997
when I first presented this method. Again, it is my original idea which
AFRA and CPS Watch is taking credit for.
v. Get your records. In 1997, there was no recommended method of
58
I may be that these recommendations appear to be common sense and what is done
under any normal circumstance. However, in 1996 when I wrote my book and published my web
site, this was not standard practice in child welfare cases. In 1996, this was innovative and
pioneering in this arena. I introduced these practices, and because they were so effective, they
became very popular, and today, form the foundation of my proprietary methods, but do not
constitute the full scope of my proprietary methods.

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obtaining your own child welfare records. Again, this was already an
established practice originating with me by the time the defendants,
including AFRA, became involved with child welfare issues.
vi. Clean up your house and your life. In this instance, AFRA went from
being overtly opposite “It’s none of their business,” to clean up. This,
again, originated with me as part of my overall method for participating in
a child welfare case. AFRA has taken credit as originating this principle.
vii. The methods advertised for responding to the service plan have, once
again, originated with me, before the existence of AFRA or the appearance
of the defendants. Yet AFRA is taking credit for this.
These methods and strategies did not appear on the AFRA web site until well after
it’s original publication date and after I had left AFRA. AFRA did not originate
them, AFRA copied them. On May 6, 2008, Henderson expressly told me via
email, “I want NOTHING of yours,” yet he, as AFRA’s web master continues to
use my work to enhance the reputation and stature of AFRA, through the
mechanism of denying its my work.
c. On or about March 10, 2006, I discovered Keifer was plagiarizing verbatim
content from my web site without giving me credit and without my permission.
He was using it to promote his Internet radio show and advertising it on the
interactive online groups owned and operated by the defendants, creating, inter
alia, a false impression that he was associated with me.
d. In a series of broadcast publications on the defendants’s online interactive groups,
culminating with a broadcast publication on or about May 2, 2004, T. Dutkiewicz
representing Connecticut DCF Watch published information “To the new comers
and the old timers” giving condensed instructions and advice from my book and

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web site. During this series of “Tips of the Week,” the defendant never gave credit
to me as the source of that information. I contacted the Dutkeiwicz’s with a cease
and desist letter. The defendants responded by broadcasting to all groups that I
had threatened them and was lying about the origin of the information they posted.
In the subsequent heated online discussions over this issue, T. Dutkiewicz wrote,
“Ms. Shell is not the only one who can right [sic] a book on ones [sic]
experience.” Mr. Dutkiewicz’s prior and subsequent original writings never
demonstrated the same degree of skill, expertise, competence or command of the
English language as the ones he copied from my work. The Dutkiewicz’s
continued to use AFRA groups to disseminate their copied content, and the AFRA
defendants responsible for moderating the AFRA groups allowed their groups to
be used to commit these acts.
e. On May 13, 2004, A. Dutkiewicz announced on NEPAN that their handbook
came from my web site–thereby admitting they copied my work–with express
permission. “Group, Check this out. I found this on Profane-Justice....... hum
our handbook is for educational purpose and we do not charge for it AND WE
ARE AFRA members................. So Suzanne can BITE me when it comes to her
threats of suit.” She included 0the express-permission-to-copy clause from my
web site.
“Members of American Family Rights Association (AFRA) ONLY may copy and
distribute website material for education and training purposes without fee,
provided this entire copyright notice is included. Parents seeking assistance
with their own cases may freely use documents on this website as models for
their own cases. This permission expressly excludes any person or
organization listed on American Family Advocacy Center “Bad advocates” web
site pages regardless of their membership status with AFRA. IF YOU COPY OR
DISTRIBUTE ANYTHING ON THIS SITE - YOU ARE ENTERING INTO A
CONTRACT. READ THE CONTRACT BEFORE YOU COPY OR DISTRIBUTE. YOUR
ACT OF COPYING AND/OR DISTRIBUTING OBJECTIVELY AND EXPRESSLY

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INDICATES YOUR AGREEMENT TO AND ACCEPTANCE OF THESE TERMS.
This clause required anyone using my content include my entire copyright notice,
which the defendants did not do. Dutkiewicz’s were listed on the bad advocates
pages, which expressly precluded them from permissive use. The defendants have
continued to publish advice and information obtained from my publications
without giving proper credit to the source.
f. On or about December 1, 2006, Hinger announced on all AFRA groups that he
had uploaded a document “How to Document Your CPS Case” file name htd.pdf
to the files section of each group. This document, ¶869.m, was based on my
proprietary information. Hinger took credit for these strategies, without ever
having evidenced any knowledge of this information prior to gaining unauthorized
access to my proprietary information. My demands for AFRA to remove these
documents from their group files sections was denied by Tower, Henderson and
the AFRA BOD.
g. On or about January 23, 2007, T. Dutkiewicz and Connecticut DCF Watch
advertised on all groups the Tennessee Supreme Court decision on the Anna Mae
He case wherein the termination of parental rights was overturned and the child
returned to her parents. AFRA had taken credit for this case in the past, however,
FRAI trained advocates worked with counsel on that writ of certiorari. The
Tennessee Supreme Court’s ruling reflects language provided by FRAI advocates
in the briefs. This was the Family Rights Advocacy Institute’s victory, not
AFRA’s. The FRAI advocate has remained in contact with the Hes after they
returned to China.
h. On or about February, 2007, ¶625, on AFRA_EAGLE, Contreras began a series of
responses to members requests for services and information by disseminating vast

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amounts of my proprietary methods as case specific legal advice and taking credit
for herself and for AFRA for those methods. Durand similarly participated in this
dissemination. Durand and Contreras often tag-teaming the responses. The
methods she disseminated included information from my seminar handout. The
advice Contreras disseminated included my planted false information. Not
knowing false information was intentionally placed in my seminar handouts to
trap anyone who misappropriated my trade secrets, Contreras provided it if it were
valid advice to a consumer on the group.
i. On or about May 29, 2007, Hinger promoted my method of documenting a case
on AFRA_Helpline, stating it is very successful. He did not give me credit for that
method, but passed it off as his own creation and referred members to his
publication htd.pdf on his web site. He further stated that as a result of his using
this method, he was advised by judges that he needed to become an attorney and
bragged about a 100% success rate.
j. On or about May 16, 2008, Howard advertised on CPS Watch that they conduct
training classes. These classes, being consistent with the information disseminated
by CPS Watch, are based on my methods and publications. CPS Watch is
enhancing their credibility and stature in this market based on my work, at my
expense for which I do not receive credit or remuneration.
k. On or about July 3, 2008 Howard referred a new consumer on CPS Watch to read
Parent’s Guide to the System passing it off as CPS Watch work.
l. On or about July 13, 2008, Howard referred consumers to the CPS Watch files
section for Parent’s Guide to the System and passed it off as CPS Watch work.
m. On or about August 15, 2008, Henderson published methods pertaining to service
plans on AFRA_Helpline that are part of my trade secrets and proprietary

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methods. He stated the contributor of this information was a “long-standing

member” but did not identify who that was. This knowledge was not previously
exhibited by any AFRA member prior to my proprietary information being stolen
and published on AFRA_CenCom files section.
n. On August 18, 2008, Howard passed off Parent’s Guide to the System as CPS
Watch work.
o. On or about August 23, 2008, Thompson directed consumers to a CPSWatch link
containing a copy of Parent’s Guide to the System and recommended they
download it, passing it off as CPS Watch work. Barnes also recommended it as
her own work.
p. November 16, 2008, Barnes advised a parent to make a time line of events for the
case. This was my method, but she didn’t get it right. She gave a description
which was not proper, it put the parent in an inappropriately bad light.
q. The defendants are all enhancing their credibility, misrepresenting their skills and
expertise, and promoting their services using my plagiarized, stolen and infringed
intellectual property, without giving credit and without paying the required license
fees. When I attempt to protect my property, they gang up and disseminate their
false advertisements not only all over their own fora but in the general public and
to professionals to whom I market my products.
r. Defendants, in the course of their respective business, have intended by the
aforesaid acts to:
i. cause likelihood of confusion or misunderstanding as to the origin,
sponsorship or approval of the goods and services of the defendants;
and/or
ii. cause likelihood of confusion or misunderstanding as to Defendants’

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affiliation, connection, or association with me;

iii. represent that my goods and services are the goods and services of
Defendants; and/or
iv. represent that Defendants’ goods and services are my goods and services;
and/or
v. engage in other conduct which has similarly created a likelihood of
confusion or misunderstanding as to the source of origin of the methods,
strategies and documents provided by the defendants.
s. Defendants’ use and promotion of the methods they provide creates a false
indication of origin and is calculated to deceive the public into believing that
Defendants are the owners, creators and/or developers of my protected methods,
in violation of Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a).
1157. Wrongful interference with my contracts and business relationships;
a. March 19, 2007, the defendants sabotaged the contract that AFRA President
Hession and I had agreed upon to end hostilities between our organizations.
Tower, Hinger, Kiefer, and T. Dutkiewicz and A. Dutkiewicz demanded terms
that were not considered and became disruptive enough that Mr. Hession said he
couldn’t deal with the psychos, that AFRA was full of them and they were out of
control, and resigned.
b. On or about April 5, 2006, A Dutkiewicz contacted the host of a radio show,
Citizens for Change (CFC),59 where I had just been a guest, maligning my
business and my business practices, and advised CFC not to have anything to do
with me. CFC was considering sponsoring my seminars, but was unwilling to deal
with this kind of harassment simply for associating with me.
59
I was negotiating a training seminar with Citizens for Change.

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c. On or about April 7, 2006, Wiseman began a series of harassing and threatening

emails to the Citizens for Change radio show host in an attempt to intimidate her
from associating with me.
d. On or about April 9, 2006, A. Dutkiewicz contacted the CFC radio show host
again and made great effort to get her to dissociate from me with comments
maligning my business and business practices.
e. On or about October 16, 2006, R. Cygan sent a threatening self-destructing email
message to my associate Christine Korn, in an attempt to get her to disassociate
from me.
f. On or before March 29, 2006, the Dutkiewicz’s contacted FAVOR and began
harassing them for their association with me. I advised them to cease harassing
them. The defendant’s conduct made FAVOR wary of associating with the
Institute, as this kind of harassment intruded on business operations.
g. Sometime in the ten days prior to June 6, 2006, T. Dutkiewicz sent an email to
FAVOR, Inc., a Connecticut organization who had expressed an interest in
receiving my training and certification for their advocates. He provided false and
derogatory information about me intended to prevent them from affiliating with
the Institute.
1158. Filing false reports to get my business services, including inter alia, my internet services,
cancelled or revoked;
a. Hinger contacted me about a complaint to my web host alleging I had kiddie porn
on my web site, bragging about my site being taken down.
b. On or about January 23, 2006, my Internet Yahoo! account was cancelled without
notice or explanation. The Yahoo! group I owned and my memberships in all
other Yahoo! groups were cancelled along with it. I had been completely excluded

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from the Internet market. A. Dutkiewicz publicly took credit for this cancellation.
c. On March 1, 2006, A. Dutkeiwicz published and advertised on all groups owned
and operated by the defendants, “Please pass this on if we all get together and
file complaints we can get Suzanne Shell shut down” and directed consumers to
the WHOA web site which takes complaints about cyber-stalking.
d. On March 29, 2006, I was contacted by my Internet Service Provider (ISP),
EarthLink, stating that A. Dutkiewicz had filed a complaint against me for a cease
and desist letter I had sent her. She claimed it was a death threat. I was given a
warning against future violations. I appealed this finding, providing proof of her
harassment, stalking and abuse and that the content was a metaphor, not a death
threat. EarthLink refused to withdraw the warning.
e. A. Dutkiewicz immediately falsely reported me to my ISP again for violating the
prior warning by posting a message to an interactive online group where she was a
member under an assumed identity. EarthLink issued a final warning. I appealed
this finding and ended up taking it to EarthLink’s legal department. This issue was
not closed until April 3, 2006.
f. On April 30, 2006, my Internet access through EarthLink was shut down. I
contacted EarthLink who advised me that “Aimee” had called them on April 6,
2006, and had represented herself to be calling on my behalf, and had cancelled
my Internet services. In order to do so, she had to know my security question.
EarthLink procedures established my father’s middle name as that identifier. Baez
had done the investigation to find out my maiden and former married
names–names that I had never published anywhere, especially not online–and
provided that information to the other defendants. Thus, having access to my birth
certificate gave A. Dutkiewicz the information she needed to breach the security

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of my EarthLink account. This account was also used by my husband for his
business, and this shut down affected his business, too. Baez intended to harm me
and knew the other defendants intended to harm me when she provided that
information to them.
g. On June 3, 2006, I published what A. Dutkiewicz had done to my Improvement
Project, with the supporting documentation. On that same day, I received an email
from EarthLink advising me that I had contacted them. They provided me with the
case number and wanted my feedback. I had not contacted them, so I called them
to find out who had. The customer service representative advised me that A.
Dutkiewicz had called them again, this time to correct what she told them last
time and to say that what she really meant to tell them that my web site contained
pornography.
1159. Filing false police reports to create a criminal history as to me or making false complaints
to state agencies, which complaints or reports would not be justified to any reasonable
person. These reports and complaints had no legitimate basis in fact, and they were ALL
deemed unfounded;
a. See ¶361 re: Hinger restraining order. On October 12, 2006, I received a Request
for Protective Order from Hinger which he filed in a Sacramento Court. This
request was based on many of the false advertisements published on the
defendants’s interactive online groups and falsely alleged that I posed a threat of
physical harm to Hinger and his son. There was no evidence of threats of harm
from me to Hinger or his son. The permanent order was denied.
b. See ¶1158.c re: A. Dutkiewicz urging consumers to complain about me
cyberstalking when I had not committed any of the elements of stalking against
anyone.

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c. See ¶ 1176.d re: A. Dutkiewicz reporting I made a death threat to the FBI.
d. On March 13, 2006, A. Dutkiewicz filed a false police report against me with the
Bristol Police Department incident to my impending appearance in Connecticut.
She has subsequently advertised on the groups owned and operated by the
defendants that there are police reports filed against me. In this report, she made
false and derogatory statements of fact about me, which are now public record,
including claims that I made threats against her, was stalking and harassing her
and had “done things” to others. She claimed I wanted her address to locate her
and harm her. She stated I called her and identified myself by my first name,
which I never do.
e. On and before March 30, 2006, Tower and Hinger used AFRA to obtain and
transmit information about me for the purposes of filing complaints with an
unidentified east coast state Attorney General.
f. On March 29, 2006, A. Dutkiewicz made a second false report to the police about
me alleging I made a death threat. The police investigated and determined the
report was unfounded. She published to cp_prosecutions,
“TODAY I FIND A THREAT IN MY EMAIL SO I SPENT THE DAY WITH
LOCAL POLICE, EL PASO COUNTY POLICE ON CONFERENCE WITH MY
LOCAL POLICE AND THE FBI.... I TAKE THIS SERIOUS AND EVERY ONE
OF YOUR NAMES WERE GIVEN TO THE AUTHORITIES/”
g. On or about May 17, 2006, R. Cygan, reported to the FBI in Colorado that I had
kiddie porn on my website. I had no photographs of unclothed children on my
web site. The FBI conducted an investigation, and determined the complaint was
unfounded.
h. See ¶1176.y re: T. Dutkiewicz calling for all to report me to police
i. On or about August 3, 2006, Blair sent forged evidence to the State of Colorado

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through the U.S. Mail intended to initiate or support Unauthorized Practice of

Law (UPL) proceedings against me.
j. On or about August 7, 2006, Blair filed a false criminal extortion complaint
against me with the Oakland County, Michigan, Sheriff. In his complaint, Blair
cobbled together several years of posts and articles from the Internet and claimed
the forged document was a message I had sent to him a few months prior. The
sheriff investigated and determined the complaint was unfounded.
k. When Blair’s first attempt to get me arrested failed, he filed the same complaint
with El Paso County, Colorado, sheriff’s office on August 11, 2007. El Paso
County sheriff investigated and determined it was unfounded.
l. On or about March 3, 2009, T. Dutkiewicz made a false report, Case No.
09UPL016, to Colorado Supreme Court Attorney Regulation Counsel (OARC)
alleging I had engaged in UPL on the basis I was representing the legal interests of
Family Rights Advocacy Institute in this action. I was requested to file a response
to the complaint. I declined to file a response. On March 25, 2009, OARC advised
Mr. Dutkiewicz that there was insufficient evidence to establish that I was
engaging in the unauthorized practice of law by attempting to represent FRAI’s
legal interests as if such interests belonged to me.
m. On or about May 6, 2009, T. Dutkiewicz made false report , Case No. 09UPS057,
to OARC alleging I had engaged in UPL for filing a request for expanded media
coverage in a Colorado court pursuant to Colorado code of Judicial Conduct,
Canon 3(A)(7). The complaint was deemed unfounded without conducting an
investigation.
1160. Submitting forged or falsified evidence to support those false reports;
a. See ¶1159.ire: Blair forged UPL complaint

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b. See ¶1159.j re: Blair false criminal extortion complaint.

1161. Causing messages posted on my Improvement Project Yahoo! group consumer advisory
publication to be deleted from the public archives;
a. Starting on or about August 1, 2006, the defendants began a campaign to tamper
with my Consumer Advisory publication and got Yahoo! customer service to
delete 111 consumer advisory posts from the public archives of my publication
because the posts presented them in a true, but unflattering light. [## 1022, 1089,
1694, 1973, 2088, 2056, 2230, 2231, 2018, 1353, 1356 ,1357,1358, 1359, 1360,
1361, 1362, 1363, 1364, 1365, 1366, 1367, 1368, 1369, 1370, 1371, 1372 , 1373,
1374, 1381, 1383, 1384, 1386, 1392, 1583, 1596, 1598, 1599, 1600, 1606, 1607,
1612, 1636, 1713, 1714, 1799, 1800, 1801, 1802, 1803, 1804, 1806, 1807, 1808,
1809, 1814, 1821, 1893, 1895, 1899, 2191, 2205, 2254, 2259, 2267, 2270, 2271,
2275, 2279, 2283, 2313, 2345, 2346, 2347, 2348, 2349, 2350, 2351, 2352, 2357,
2357, 2359, 2362, 2326, 2364, 2365, 2366, 2367, 2370, 2371, 2372, 2373, 2374,
2376, 2377, 2375 ,2378, 2379, 2382, 2391, 2394, 2397, 2398, 2399, 1316, 1331,
3363, 3330, 3281, 3414, 5123.]
b. On or about June 22, Moderator Henson reported that A. Dutkiewicz and Baez
had accessed the group without joining and had been forwarding messages off of
the group.
c. On this same date, it was discovered that the defendants had tampered with the
database containing group members, names and organizations, replacing
legitimate information with profane and derogatory information. Swallow, A.
Dutkiewicz Baez, M. Cygan and R. Cygan had been added. This information had
to be deleted and the original database was never able to be restored.
d. The account was also hacked by someone appearing to be member Marlene and

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all of the files that had been uploaded to the files section were deleted. We know
it wasn’t Marlene because she was not an owner. She had briefly been made an
owner by K. Henson for the sole purpose of accessing the group activity files to
determine what was going on. Henson had several people trying to preserve the
activity history before the defendants destroyed it. Every computer that made that
attempt during that evening, no matter what part of the country, crashed during the
attempt. Immediately after Marlene was removed as moderator, and while she was
still on the phone with Henson, it appeared she logged in again, when she didn’t.
Henson kept getting messages that she could not access the moderator features
because someone else was accessing it. None of the other legitimate moderators
were accessing it.
1162. Falsely attributing publications to me which are not my publications and which I did not
author;
a. On or about July, 31, 2007, Hinger advertised on AFRA_Talkline that I was the
author of badadvocates.com, and claimed I made false accusations about him
being a womanizer and a pervert. I do not own or author or publish that web site. I
don’t even own the domain name.
b. See ¶1176.ac, re: defendants getting BAL shut down.
c. On an unknown date and still on display as of October 29, 2008 and September 9,
2009, Wiseman falsely advertised on thetruthistold[dot]com/response.html that I
author and own the badadvocates.com web site.
d. On an unknown date and on display as of October 29, 2008, Wiseman or a
defendant posing as Wiseman falsely advertised on
thetruthistold.com/atttackanswer.html an advertisement authored by Contreras
which falsely advertised that I taunted her on badadvocates.com. All my articles

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on that site are signed by me and were authored before August 2006.
e. On an unknown date and still on display as of October 29, 2008, Wiseman faslely
advertised on thetruthistold[dot]com/watch.html a false advertisement made by
AFRA member Jill Manzoni that I had slandered and defamed her on
www.badadvocates.com.
1163. Engaging in “bandwidth theft” intended to use up my or my associates’s web site
bandwidth allotments in the beginning of the month consequently causing our web sites
to be shut down until the end of the month and/or costing me tens of thousands of dollars
in excess bandwidth fees;
a. On or about September 3, 2006, the defendants accessed one of my web site
hosting servers and commenced downloading web site content for hours at a time,
which caused the site to be shut down for exceeding allotted bandwidth traffic for
the entire month.
1164. Falsely representing themselves as my agent and cancelling my business services;
a. See ¶509, re: A. Dutkiewicz cancels my EarthLink account.
1165. Altering my and my associates advertisements and promotional publications and
disseminating the altered content to misdirect the public to their businesses and
publications or to change the content of the advertisement to their version;
a. On May 29, 2004, A. Dutkeiwicz published an broadcast advertisement on the
defendants’s interactive online groups with the subject line, “Did profane-
justice.com redesigned their site?” directing readers to the .com web site she had
commissioned. This was intended to mislead consumers to their web site and
falsely represent that it was mine. Many consumers advised me they were
confused and thought it was my site.
b. On January 18, 2006, T. Dutkiewicz altered an advertisement published by Effie

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Belou about an upcoming Family Law Conference in Connecticut where – I was

scheduled to be an instructor – by changing the web site to which consumers were
referred for more information from www.profane-justice.org to his www.profane-
justice.com site. He then republished this altered advertisement to all the
interactive online groups owned and operated by the defendants and made it look
like it came from me.
c. On January 25, 2005, the Dutkiewicz’s tampered with another advertisement for
the Family Law Conference in Connecticut, by adding a false and derogatory
disclaimer pertaining to me to the advertisement and republished it to all the
interactive online groups owned and operated by the defendants making it appear
to have come from the sponsor of the conference.
1166. Threatening my business service providers with legal action if they didn’t stop providing
their services to me;
a. See ¶1176.c re: A. Dutkiewicz threatens my web host if he doesn’t close down my
web site.
b. See ¶1176.f re: R. Cygan sending threatening notice to my web host if he doesn’t
take down my web site.
c. See ¶1176.h re: A. Dutkiewicz II
d. On or about May 6, 2006, Cygan(s) contacted my web host and demanded he stop
hosting my web site and threatened legal action if he did not comply with their
demand.
e. See ¶1176.a re: A. Dutkiewicz files frivolous copyright infringement notice to
web host.
f. See ¶1176.i re: A. Dutkeiwicz makes AT&T threats to web host
1167. Harassing, stalking and threatening my associates and licensees with harm, legal action or

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bad publicity if they continue to support me, endorse me or associate with me;
a. See ¶1157.c, re: Wiseman issues threats to Citizens for Change
b. On May 3, 2006, A. Dutkiewicz advertised on the interactive online groups owned
and operated by the defendants that anyone associating with me would be equally
culpable for unnamed offenses.
c. See ¶1157.e re: R. Cygan threatening Colorado associate with self-destructing
email.
d. Contreras admitted in her court pleadings that she turned my associate, Henson, in
to the FBI for running an illegal underground railroad. This was a false allegation,
Henson was never investigated, this was intended to make my associates afraid to
conduct business with me. Subsequently, Hinger falsely advertised to the market
that my associate was under investigation by the FBI.
1168. Creating web site with a [dot]com extension of my web site domain name, populating it
with derogatory content about my business and misdirecting the public to that site
representing it as my site;
a. On or about May 29, 2004, A. Dutkiewicz and T. Dutkiewicz each sent a
broadcast email to the defendants’s online groups, non-AFRA groups and an
undisclosed list of recipients with the message, “Has anyone seen the newly
designed site called www.profane-justice.com? What is all about?” The subject
line read, “Did profane-justice.com redesign their site?” I was contacted by
consumers and service providers who expressed confusion about this new site
being mine. The domain name had just been registered to Phillips on May 27,
2004. Dutkiewicz stated, “There are hundreds of individuals who are very
disappointed with Ms. Shell and this site was in response to her false misleading
statements and her on-going violations of federal law.”

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b. See ¶656 re: Lloyd Phillips participation in the [dot]com acts.

c. See ¶1165.b re: T. Dutkiewicz altering advertisement.
1169. Coercing me to utilize AFRA as a “delivery system” for my products and retaliating
against me when I refused;
a. On July 26, 2004, Henderson stated on CenCom , State_Leadership, and
Directors, that Henderson created the delivery system, i.e. AFRA, for my goods
and services. He subsequently attempted to force me utilize “his” delivery system
against my will. AFRA members subsequently stated they forwarded his message
to other groups, including AFRA and non-AFRA groups. I refused and AFRA
escalated wrongful conduct against me.
b. On or about July 27, 2007, on AFRA_Talkline, Hinger characterized my refusal to
let AFRA take over or exert control over my property and my business as, “. . .the
one group who refuses to work and play well with others. . .”
1170. Contacting and harassing the locations were I was appearing as a speaker, and contacting
and harassing the sponsors, other speakers and hosts with disparaging descriptions about
me and telling them not to do business with me or to appear with me; and
a. Sometime before June 30, 2006, Wiseman or defendant(s) representing himself to
be Wiseman contacted the Phillip Miller Library in Castle Rock, Colorado, where
I was scheduled to present Continuing Legal Education training and advocacy
training under the sponsorship of Colorado Family Rights Advocacy Institute. He
attempted to convince the library not to allow me to use their facilities for this
presentation because I was a thief and a scam artist.
b. On or about January 18, 2006, T. Dutkiewicz called the Sheraton Bradley Airport
Hotel in Windsor Locks, Connecticut where the Family Law Conference was
being held and advised the staff “that he was concerned that the Hotel will be

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affiliating itself with Suzanne Shell . . .” He stated that Shell and Child Caring
Concern60 are not people that the Hotel should be doing business with due to our
criminal activities. See ¶522.
c. On March 28, 2006, A. Dutkiewicz published and advertized on the interactive
online groups owned and operated by the defendants that she had contacted one of
the speakers at Ms. Belou’s conference, the Honorable Judge Mack, and made
false and defamatory statements about me including that I was appealing a jail
sentence in Colorado; and that I had not received Continuing Legal Education
accreditation for my presentation in Connecticut as I had advertised.
d. See ¶1157.b re: A. Dutkiewicz and threats to Citizens for Change
e. See ¶1157.c, re: Wiseman and Citizens for Change
f. See ¶1157.d re: A. Dutkiewicz 2nd attempt to threaten CFC
g. On or about April 2, 2006, Wiseman or someone posing as Wiseman, using
AFRA_CenCom, contacted CFC demanding a copy of her radio who where I was
the guest. This was in conjunction with the debut of his web site. There were
heated discussions on the groups, instigated by the defendants, about my
appearance on this radio program. After a few appearances, CFC decided they
needed to cease broadcasting altogether to avoid the hassle caused by the
defendants. Another competitor of the defendants was eliminated for associating
with me.
h. On or about April 5, 2006, A. Dutkiewicz initiated a series of emails with CFC
claiming I lied on her program and urging her to dissociate with me.
1171. Encouraging the public not to attend any function where I was speaking, usually in
conjunction with the advertisements of my appearance;
60
The event sponsor.

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a. On or about September 8, 2004, A. Dutkiewicz responded to an advertisement

published by Kay Henson on the defendants’s groups about an upcoming seminar
that she was sponsoring in Florida, were I was the instructor, disparaging my
products and services so that people would not attend.
1172. Physically appearing at my presentations seeking to discourage the staff from allowing
me to speak;
a. On or about March 17, 2006, T. Dutkiewicz and A. Dutkiewicz were observed by
three witnesses stalking the hotel where the Family Law conference was being
held in Connecticut. They spoke with staff at the hotel seeking information about
“people from Colorado” who were attending the conference and wanted to know
where “the cars from Colorado” were parked.
1173. Sending people to my presentations to fraudulently obtain my proprietary content to
deliver to the defendants;
a. On March 16-18. W. Tower sent James F. Williams to the Family Law
Conference in Connecticut under false and fraudulent pretenses to obtain my
proprietary information.
1174. Causing a national continuing education company to breach its contract with me and
discharge me from the faculty;
a. In November 30, 2005, I had negotiated an agreement with Lorman Education
Services to be on their faculty and present a Continuing Education seminar on
Reporting Child Abuse in Denver on May 9, 2006. I had also submitted my Bio
and agenda. Lorman said it looked great and produced the advertising pamphlet. I
had also negotiated to present similar presentations in other states, and to expand
their presentation offerings into other Child Welfare arenas including Reasonable
Efforts and Appropriate Case Planning. Despite the fact that the contract with

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them stated they would never cancel the speaker once the brochure was printed,
Lorman contacted me on February 28, 2006, after the brochures were distributed,
stating it was not in their best interests to have me present the seminar as agreed
upon. Lorman revealed that someone had contacted them with information about
me that made them arrive at this decision.
1175. Altering my Wikipedia entry to mislead the public and to using my Wikipedia entry to
redirect the public to their organizations;
a. The defendants have vandalized my Wikipedia entry since it first appeared in
2007. Defendants have added links to their web sites thereby capitalizing on my
publicity, injected profanity and false advertising intended to smear me and my
family, and projected their false illusion of my profession, my business and my
practice. They have used my Wikipedia entry to abuse and batter me publicly, and
to promote their conspiracy, their agenda and to usurp my legitimate advertising
to their benefit.
i. Defendant Baez has admitted on May 6, 207, on her blog at
http://feedblitz.com/r.asp?l=25719800&f=104839&u=0 that she
vandalized my Wikipedia entry, “I visited the ‘Suzanne Shell’ page at
Wikipedia.com this past weekend. I added two links, the AFRA site and
Billy Wiseman's ‘TheTruthIsTold[dot]com’ site.” She has vandalized this
page multiple times according the history of this page and her additions
were considered vandalism and removed by Wikipedia staff repeatedly:
(cur | prev) 22:02, 1 October 2009 Dorothybaez (talk | contribs) (6,308 bytes) (6External links) (undo)
(cur | prev) 22:01, 1 October 2009 Dorothybaez (talk | contribs) (6,307 bytes) (6External links) (undo)
(cur | prev) 22:00, 1 October 2009 Dorothybaez (talk | contribs) (6,246 bytes) (6Notable legal cases)
(undo)
(cur | prev) 11:42, 29 September 2009 SmackBot (talk | contribs) m (6,040 bytes) (Date maintenance
tags and general
(cur | prev) 06:11, 8 August 2007 OrphanBot (talk | contribs) (5,890 bytes) (Removing image with no
copyright information. Such images that are older than seven days may be deleted at any time.) (undo)

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(cur | prev) 14:51, 5 August 2007 Dorothybaez (talk | contribs) m (5,836 bytes) (Reverted to revision
149035799 by Dorothybaez; mistake. using TW) (undo)
(cur | prev) 14:50, 5 August 2007 Dorothybaez (talk | contribs) m (5,363 bytes) (Reverted 4 edits by
Dorothybaez identified as vandalism to last revision by
MartinBot. using TW) (undo)
(cur | prev) 23:59, 3 August 2007 Dorothybaez (talk | contribs) (5,836 bytes) (undo)
(cur | prev) 20:30, 3 August 2007 Dorothybaez (talk | contribs) (5,812 bytes) (6Notable legal cases)
(undo)
(cur | prev) 20:22, 3 August 2007 Dorothybaez (talk | contribs) m (5,565 bytes) (6External links)
(undo)
(cur | prev) 21:53, 30 July 2007 Dorothybaez (talk | contribs) m (5,384 bytes) (added maiden name)
(undo)
(cur | prev) 18:42, 1 July 2007 MartinBot (talk | contribs) m (5,363 bytes) (Reverted edits by
69.241.126.114
(cur | prev) 16:22, 12 May 2007 AntiSpamBot (talk | contribs) (5,391 bytes) (BOT--Reverting edits by
Dorothybaez to revision 130125872 (thetruthistold\.com))(undo)
(cur | prev) 16:21, 12 May 2007 Dorothybaez (talk | contribs) (5,536 bytes) (6External links) (undo)
ii. The Dutkiewicz’s have vandalized my entry as follows:

(cur | prev) 05:04, 11 November 2009 Versageek (talk | contribs) m (6,308 bytes) (Reverted to revision
317361947 by Dorothybaez; rv unsourced, blp & npov
issues .) (undo)
(cur | prev) 04:20, 11 November 2009 Parrotcentral (talk | contribs) (6,764 bytes) (6References)
(undo) (Tag: reference list removal)
iii. Wiseman has vandalized my entry as follows:

(cur | prev) 22:27, 9 May 2007 Wisemanstudios (talk | contribs) m (5,192 bytes) (6External links)
(undo)
(cur | prev) 22:26, 9 May 2007 AntiSpamBot (talk | contribs) (5,350 bytes) (BOT--Reverting edits by
Wisemanstudios to revision 129656085 (thetruthistold\.com))
(undo)
(undo)
(cur | prev) 22:20, 9 May 2007 Beetstra (talk | contribs) (5,350 bytes) (Popups-assisted revert to
revision 129654470 (2007-05-09 22:14:27, by Veinor) - rv link
addition) (undo)
(undo)
(cur | prev) 22:14, 9 May 2007 Veinor (talk | contribs) m (5,350 bytes) (Reverted edits by
Wisemanstudios (talk) to last version by Veinor) (undo)
(cur | prev) 22:10, 9 May 2007 Wisemanstudios (talk | contribs) m (5,652 bytes) (undo)
(cur | prev) 16:30, 9 May 2007 Veinor (talk | contribs) (5,350 bytes) (remove disclaimer and
iv. There are numerous other vandalizations done by the defendants

anonymously. On November 2, 2007, AFRA member Cheryl Moyer asked

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CPSWatch group if anyone knew how to edit a Wikpedia entry.

1176. Repeated attempts to have my web site taken down or to take over my web site
publications;
a. On or about December 19, 2003, A. Dutkiewiczsent a copyright infringement
takedown notice to my web host, alleging my web site at profane-
justice[dot]COM contained infringing content, citing her emails which I published
with criticism and commentary. He was compelled to seek advice from his
attorney who advised him to take it down, notice me and put it back up after I file
a counter notice.
b. On May 16, 2004, Hinger made recommendations on to AFRA on
AFRA_CenCom with the subject “On Going [sic] Disruptive Disputes” as to how
AFRA could take over one of my online publications.
c. On or about May 24, 2004, A. Dutkiewicz sent a take down notice to my web host
demanding my web site be shut down and threatening legal action if he failed to
take down my web site.
d. At the same time, A. Dutkiewicz and T. Dutkiewicz filed a complaint with the
FBI alleging I had made death threats against A. Dutkiewicz on my web site. Due
to a DNS transfer interval, my web site was not accessible using the domain name
for 24 hours, however, it was still accessible via the web host service name.
During this time A, Dutkiewicz bragged “. . .the web site is DOWN DOWN DOWN
and will stay so. Hon the FBI is involved... the scripture used in Exodus is
considered a DEATH threat under home land security....” This claim was
nonsense, and false.
e. On or about May 29, 2004, A. Dutkiewicz again demanded my web host take
down infringing content, and stated she had turned me in to the FBI, I just wasn’t

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high enough on the terrorist activity list yet, but insinuated my web host was.
f. On or about May 31, 2004, Cygan sent a threatening take down notice to my web
site host in an attempt to get my web site shut down.
g. On or about May 31, 2004, Baez sent a take-down notice to my web host alleging
the content was defamatory and libelous.
h. On or about June 1, 2004, A. Dutkiewicz sent another takedown demand to my
web host, citing the Patriot Act. This message crashed his computer. She claimed
she had a brother in-law named David in the FBI in Connecticut and he was not
happy with my publication. She implied an impending investigation and made a
threatening comment about the individual hosting my site being “well known” to
the FBI as a “minor terrorist” under homeland security. She also cited names of
her co-conspirators “ Renee [Cygan], Sue J[ackson], Sue V, Dorothy [Kernaghan-
Baez], Dean, Tim Shepard, Eric, Roxxy.”
i. On or about June 4, 2004, A. Dutkiewicz reiterated her takedown demand and
introduced threats about AT&T legal team contacting him about “this serious
matter.”
j. On or about June 4, 2004, R. Cygan again harassed my web host with her take
down demand and threatened to sue him.
k. On February 14, 2005, Henderson and Jackson, in a discussion on
AFRA_Directors, resurrected the idea the AFRA should divest me of consumer
advisory publications and forwarded discussion on how to accomplish that
divestiture.
l. On February 16, 2005, Henderson stated on AFRA Directors his intent to “boot”
me from the market if I did not withdraw my Consumer Advisory publication
from my web site, and discussed concerns about the legal ramifications.

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m. On or about February 20, 2005, AFRA Directors discussed tactics to usurp my

Consumer Advisory publication.
n. On or about February 20, 2005, AFRA Directors Henderson and Jackson again
resurrected and discussed tactics to usurp my Consumer Advisory publication.
o. See ¶1166.d re: Cygans contacting web host to get my site shut down.
p. See ¶1088.b re: Cygan complaint shutting my web site down.
q. On or about April 24, 2006, A. Dutkiewicz advertised to all groups that my web
site was shut down again, taking credit for that. Swallow responded that
thetruthistold[dot]com was still up.
r. On or about April 25, 2006, A. Dutkiewicz posted to DCFReformFl group,
“Shell's site is down.... now JUST WHO is Peeing down a leg?????
Celebrate while it lasts because she will probably have a heart attack
and it will be WELL DESERVED!!!!!!!!!!!”
s. On or about April 25, 2006, Dutkiewicz’s son again contacted me with a profane
and threatening demand to remove his mother from my web site.
t. On or about May 18, 2006, I learned from Hinger that my web site was down. I
was advised by the web host that it was removed for allegations of kiddie porn,
filed by Hinger.
u. On May 17, 2006, R. Cygan made a false complaint to the service hosting my web
site and got it shut down based on lies, including that I made death threats, was
harassing people, published child pornography, had her medical records and more.
All of her claims were false. I had to find a new web hosting service. This one had
been free, but they were intimidated by the defendants. Who can blame them?
They offered this space for free to support my work, but they didn’t sign up for
this barrage of threats. I had to pay for the new hosting service.
v. On or before May 30, 2006, thetruthistold[dot]com exhorted readers, “contact

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www.cbeyondonline[dot]net or calling 770-874-xxxx and tell them that these sites

need to be shut down,” referring to my web site and the web site of my web host,
whose web site had nothing to do with mine except hosting it.
w. On August 1 and 2, 2006, T. Dutkiewicz disseminated a message from Hinger on
the all interactive online groups in this market stating that I had libeled Tower and
that my intention was to destroy AFRA. He urged the market to take action
against me,
“Therefore I call on all AFRA Members and persons of integrity to flood
Yahoo groups with request to shut down her Family Advocacy
Improvement Project Yahoo Group! I also call on all of you to Blackball
Suzanne Shell and her cohorts from this movement and all groups and
organizations that are a part of it.”
x. AFRA had steadfastly advertised that there was no anti-Shell campaign, but every
person who associated with me or even appeared to associate with me was
harassed and threatened, subjected to public ridicule on thetruthhistold[dot]com
and banned from all AFRA forums. This caused many who were undecided or
who wanted my products to withdraw and eschew me, my business, my associates
and my products, if those products came from me in order to avoid having what
was done to me being done to them.
y. On August 2, 2006, T. Dutkiewicz recommended on all the interactive online
groups that everyone should contact law enforcement and Internet providers to get
my groups and my web site shut down.
z. On or about March 18, 2007, a story broke on Information Week and in the
blawgs61 about my lawsuit with Internet Archive and my surviving the motion to
dismiss on the breach of contract claims. It was picked up over and over and made
61
Law blogs.

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the front page at Digg.com.62 The defendant’s exploited that publicity to their own
end, and, as evidenced by their incriminating comments on Digg.com.
SlashDot.org and other participating social networking sites, they participated in
the “Digg effect” campaign that got my web site shut down, but not before I
accumulated $8441.94 in excess bandwidth fees. This campaign included setting
up other web sites and hotlinking63 to my web site as well as downloading and
copying my site multiple times as a protest against my protecting my copyright.
The campaign was designed to crash the server due to excess traffic. It worked.
My web site was down for the entire month of April, right when I had the most
publicity and the most legitimate traffic would have been directed to my site. My
site registered over twenty five million hits in less than a week, before it was shut
down. I was also subjected to non-stop harassing and threatening64 phone calls for
days, because the defendants published my phone number on those sites. I have
had this same phone number since 1997, and this number is known to the family
rights movement, which is the source of information in this market. I did not want
to change the number because it was identified with my business.
aa. The defendants also signed me up for hundreds of subscriptions to email news
letters. Each subscription required me to cancel it individually using various
62
A magnificent publicity opportunity for my business.
63
The web master would set up their copycat web site, and instead of copying my files to
their server, would have the web pages and documents downloaded from my server, transmit
them through the copycat web site for display to the viewer. At the viewers end, it looked like the
copycat site server hosted the web pages. On my server, it looked like my web site was receiving
millions of hits and I was responsible for the bandwidth being used.
64
Callers made threats against my children, threatening to kill and sodomize them. They
made threats against me and my family. Nothing was off limits. The calls were all anonymous.
The police said they would do nothing.

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cancellation methods, taking hours a day for several weeks.

ab. On or about May 30, 2007, Bryan originated a discussion on digg.com at
Remember the iGeeks - New Campaign takes on “I hate digg” Suzanne Shell. The
campaign commented on how the previous campaign had successfully gotten me
knocked offline. Bryan solicited readers to invite a lawsuit and participate in a
“Googlebomb” using terms like “free lesbian xxx” “waraz,” :nulled scripts” and
piracy terms. Then spam links my site all over “spammy guestbooks.” Then they
should report me for spam to the major search engines. He also recommended that
hackers make my name, the title of my book and the name of my company link to
“our page.” This campaign worked. My web site was shut down and I was
charged excess bandwidth fees amounting to $1254.69. It also adversely affected
my web site’s representation in search engines. By this, Bryan joined the
defendants’s campaign against my web site publications and launched it out of the
family rights movement and market to the entire Internet community, multiplying
the harmful effect of that campaign exponentially.
ac. On or about July 31, 2007, on AFRA_Talkline, Hinger announced, “. . .I just
learned that Shell’s BAL website has been shut down by EarthLink, wonder how
long it will last this time?” In a subsequent message he stated, “Not [kidding], it is
down. . . .but for how long?” Despite the fact that this was not my web site, the
defendants still worked to get it shut down because they believe it is mine.
Another example of harming anyone who they believe associates with me to
further their campaign against me.
ad. On July 11, 2008, Henderson admitted to me in an email, “You know perfectly
well that I tried very hard to get you to take down your. . .site.”
ae. On or about December 17, 2008, unknown defendants reported to my web host

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that my web site contained malware and my web host suspended my account. This
occurred when I was out of the country and I had not updated my web site for
months. My web site was down for four days while I was gone. When I returned
home, I located the identified file and scanned it for malware. It came up clean.
My web site was then reinstated.
1177. Contacting professional associations attempting get professional endorsement to discredit
my credentials.
a. On or about October 13, 2007, Blair emailed the Ethics Committee Chair for the
Society of Professional Journalists, Andy Schotz, attempting to discredit me as a
journalist and published the emails of this communication to other defendants and
to the market.
b. At the same time he also contacted the issuer of one of my press passes, Rocky
Mountain Media Collective, in an attempt to have this organization revoke my
press pass.
1178. Impersonating me and my business as described in ¶739.
1179. The aforementioned acts by the defendants are unconscionable, wilful and malicious.
1180. The effect of the unfair trade practices was that the consumers, being so inundated with
these incessant ugly messages finally just didn’t care about the debate, regardless of the
fact that I didn’t participate. They recognized I was not participating. They were fed up
with the impact on innocent bystanders. They wanted nothing to do with any of us. The
defendants had accomplished their objective to eliminate me from the Internet and from
the market.
1181. Another effect of the unfair trade practices was that the consumers believed the
defendants’s false advertisement and have eschewed my business, my products and my
services. The defendants have accomplished their objective.

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1182. Another effect was the fear expressed by those who wanted to obtain my products that
they would be similarly targeted by the defendants, so they felt they had no choice and
could not obtain products from me.
1183. I have suffered irreparable harm and there is no adequate remedy at law.
1184. Unless Defendants are restrained from their wrongful conduct, Defendants will continue
to cause injury to my business and my business reputation.
1185. As a proximate cause of the Unfair or Deceptive Trade Practices and Unfair Methods of
Competition by the defendants, I have suffered substantial damages to my legally
protected interests in Colorado and nationwide, including, but not limited to loss of
business, loss and or diversion of sales, loss of goodwill, loss of business reputation, loss
of public speaking and training appearances, and monetary damages exceeding
$10,000.00 due to bandwidth theft and other wrongful interferences with business
activities. I have has suffered professional shame and mortification, loss of business,
impairment of standing in the family rights community, mental pain and anguish, damage
to my business and professional reputation, humiliation and depression; and an
impairment of my ability to promote my training and products in this market, and
impairment of my ability to acquire new licensees and expand my influence in the market
using my superior products, to announce recent accomplishments and appointments and
upcoming presentations for fear that such announcements will unleash another round of
defamatory publications which expose me, my business and my professional reputation to
abuse, contempt, ridicule and obloquy by others and which will cause the business
associations and contracts to be interfered with to my detriment.
1186. Pursuant to Section 35(a) of the Lanham Act, 15 U.S.C. § 1117(a), because of
Defendants’ malicious, fraudulent, deliberate and willful misconduct and wrongful acts, I
am entitled to an award of treble damages, attorneys’ fees, and exemplary damages.

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Tenth Cause of Action

Conspiracy
set forth herein.
1188. The parties to the conspiracy are American Family Rights Association, William O.
Tower, Ann Tower, Leonard Henderson, Susan Adams Jackson Aka Susan Wolverton,
Cletus Kiefer, FAR Defense Alliance, Francine Renee Cygan, Mark Cygan, Illinois
Family Advocacy Coalition, Dorothy Kernaghan-Baez, Georgia Family Rights, Inc.,
Dennis Hinger, National Association of Family Advocates, Aimee Dutkiewicz, Thomas
Dutkiewicz, Connecticut DCFWatch, William Wiseman, Wiseman Studios, Dee
Contreras, Randall Blair, Brenda Swallow, Ann Durand, Lloyd Phillips, Alex Bryan,
Cheryl Barnes, CPS Watch, Inc., Sarah Thompson, and Desere’ Clabo.
1189. The defendants knowingly entered into the conspiracy. This should be evident from the
acts cited prior to this.
1190. The conspiracy began in August 2000.
1191. The conspiracy has continued to the date of this filing, with the most recent act occurring
as of the date of this filing.
1192. The defendants used legal means to accomplish an illegal result, and/or used illegal
means to achieve something that in itself is lawful in furtherance of the conspiracy.
1193. The defendants acted intentionally, purposefully and without lawful justification.
1194. The purpose of the conspiracy has been to deprive me of my business and my business
reputation, to deprive me of my professional reputation, deprive me of my property, to
deprive me of my property rights under copyright to control the uses of or exploit my
intellectual property, to deprive me of my property rights to my trade secrets, to deprive
me of my professional reputation and stature, to deprive me of my legitimate livelihood,
to drive my business off of the Internet and out of the relevant market, to defraud the

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public, and to eliminate me as competition.

1195. The defendants conspired to commit multiple wrongful acts against me including but not
limited to false advertising and unfair trade practices, copyright infringement, theft and/or
misappropriation of trade secrets and proprietary information, plagiarism, a pattern of
racketeering activity, to induce or commit breach of contract, and tortious interference
with business relationships and acts described in this complaint.
1196. I was a recipient on some of their conspiratorial back channel emails which were directed
to and from the defendants at "Wm Tower" <sureshot50@sbcglobal.net> To: "Renee
Cygan" <family_rights_advocate@yahoo.com>, "Mark not given [Cygan]"
<ifac_president@yahoo.com>, "Kathy" <tilley_kathy@yahoo.com>, "Dorothy
Kernaghan-Baez" <dorothy@cpsabuse.org>, "Dennis Hinger"
<budhunter2@yahoo.com>, Dee Contreras” <dee7020@aol.com>, "Connecticut DCF
Watch" <CT.DCF.Watch@snet.net>, "Cheryl Dunlap" <cdunlap@bvunet.net>,
cafra@yahoogroups.com, AnnD122@aol.com, "AFRA_EAGLE Moderator"
<AFRA_EAGLE-owner@yahoogroups.com>, AFRA_CenCom@yahoogroups.com,
AFRA_BB@yahoogroups.com. This list of senders or recipients is incomplete.
1197. This conspiracy was conducted, in part, on the defendants’s online interactive groups. I
was a member of those groups and observed the conspiracy unfold and grow.
1198. Some of the groups were set up strictly to conduct the business of the conspiracy and
conceal that business from me and the public.
1199. Some of the conspiratorial acts were planned and executed via private emails, phone
calls, text messages, social networking, in person, and other covert methods.
1200. I submit the following facts showing the existence of the conspiracy alleged in this
complaint, each showing the conspirator and his or her participation in the conspiracy.
1201. Elements of this conspiracy were conducted in full view of the public from the start, but

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major elements of the conspiracy were conducted on private groups, intending the acts to
be private by virtue of controlling who had access to those groups. Other elements
were/are being conducted using the more controlled mechanisms of social media, texting,
telephone and in person, methods whose evidence of their existence lies solely with the
conspirators.
1202. The issue of my copyrighted and trade secret property was discussed extensively between
the conspirators. These discussions occurred on public and private forums and on groups
where defendants were moderators, leaders and/or members. Whenever I would advise
the defendants of their infringing conduct, they would be critical of my efforts to protect
my intellectual property, advertising that my written works were not copyrighted and
encouraged others to infringe. AFRA advertised and endorsed an express policy to
infringe my copyrights.
1203. Henderson’s participation in this conspiracy was the instigator, acting in the role of the
facilitator and the propaganda master. The premise was that all individuals and
organizations, especially those that commanded significant influence in this market ,were
to be subordinated to Henderson and AFRA.
1204. His favorite method was to use AFRA’s immense market presence to portray the resistant
independents as misguided, or mentally ill, or as a rabid feminists (this was often used
against women who refused to submit to his and AFRA’s control) who still had worthy
contributions to be embraced by AFRA members but those contributions were best
administered and managed by AFRA rather than by the misguided independents who
created and owned them.
1205. The ultimate insult to his efforts was for anyone who held a superior market position or
superior reputation to outright refuse his self-serving advances.
1206. Since AFRA was entitled to control the property and work of others, Henderson

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structured his publicity campaign to achieve that end, and use his influence to destroy
those who refused to subordinate themselves to the benefit of AFRA.
1207. Under Henderson’s implementation of AFRA, autonomy was not allowed. Anyone
exercising self-determination and autonomy from AFRA must be discredited.
1208. Henderson brought to bear his considerable powers of persuasion to accomplish his
goals.
1209. He proved to have sufficient influence over the market to convince them to believe his
characterizations, and his version of the events he published about me. It is noteworthy
that he accomplished this on many forums where I was not a participant and could not
respond to his false advertising, or if I did respond in my defense, he blamed me for
“disrupting” the group and convinced the consumer of his version.
1210. Between September 2002 and January 2003, Jackson provided a safe house in the
underground railroad to the Lethbridges from Michigan. They reported they were locked
in the basement and not allowed to leave for any reason. I was subsequently accused of
running this underground railroad to sully my credibility and reputation.
1211. On or about November 29, 2002, Henderson sent me an email suggesting that I handle
responses to an AFRA ad AFRA had placed in the classifieds in Wisconsin newspapers
related to a case I was working on. This was an attempt to redirect the public spotlight
from my organization’s hands-on participation on this case to AFRA.
1212. On or about November 29, 2002, Henderson advertised a book written by me for
children, Knowing My Rules, and published it on AFRA’s web site. He did not attribute
me as the author. I had expressly requested he not publish this book on his web site, I
only asked him to review it, which he never did. He usurped my right of first publication.
I had to tell him to take it down. He later questioned that I was even the author.
1213. On or about February 4, 2003, R. Cygan published to a list of recipients, which included

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me, “Suzanne Shell is a wonderful person.” I did not know R. Cygan then, but this does
establish what my public reputation was at this time.
1214. On or about February 7, 2003, R. Cygan emailed me and offered her assistance and stated
I was held in high regard by many parents. This offer was unsolicited.
1215. On August 2, 2003, Henderson agreed to publish an article I had written about advocates
who had harmed consumers. He published it on the AFRA web site. This article featured
several self-professed advocates, including Renee Cygan. Faced with complaints from R.
Cygan, Henderson pulled the article from the AFRA web site. I then placed it on my own
web site.
1216. On August 4, 2003, T.M. (a crisis family who was housed by Cygan) advised me that she
had observed R. Cygan spending marathon sessions online and on the phone with Baez
each night.
1217. On or about August 4, 2003, Baez contacted me via email about R. Cygan’s article on the
Consumer Advisory page. Baez stated that she had contacted T.M. while she was at
Cygan’s and asked her to “hack” someone else’s computer for an acquaintance, figuring
T.M. could use the money and claims T.M. stated she did not have her computer. This
was not consistent with the corroborating statements of six impartial witnesses who
didn’t all know each other. Baez insisted that R. Cygan had not stolen anything from
T.M. and warned me that she hoped I would not slander an innocent person. Baez was not
a witness to the events, and was relying solely on R. Cygan’s side of the story. I did not
give her statement any weight because Baez’s account was hearsay, uncorroborated and
self-serving.
1218. I responded to Baez and told her the events had been thoroughly documented, and I had
an itemized listing of the missing articles from several witnesses who saw them in T.M.’s
possession prior to and upon her arrival at R. Cygan’s house, and corroborating

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statements from independent witnesses.

1219. I advised Baez that I gave R. Cygan the dignity of contacting her privately to resolve this
and she took it public. I stated that I was prepared to consider the entire episode a simple
misunderstanding if R. Cygan would return the missing property intact. I provided an
address for R. Cygan to ship the property to. I suggested that Baez carefully consider who
might be lying.
1220. Subsequently, T.M. received a shipment purported to be her property. It included moldy
children’s clothing that didn’t belong to her children, and trash.
1221. T.M. told me Baez had offered her money to hack into and wipe out the web site of a
competitor, Tana Investigations. T.M. declined, because she was not so desperate for
money that she was willing to break any laws.
1222. T.M. told Baez she did not have a keyboard, but that R. Cygan had promised T.M. one of
her spare ones, which she had not yet done. This fact was verified by witnesses, T.M. had
a computer, but not a keyboard. This was converted by Baez into T.M. not having a
computer so as to make it appear that R. Cygan didn’t steal T.M.’s computer.
1223. Starting in August 2003, Henderson spearheaded a campaign within this market to
control the consumer advisory articles on my web site. He initially published the
objectionable articles on the AFRA web site, then changed his mind and told me he
wouldn’t keep the articles up there. I said no problem, that was fine with me. I put the
articles on my web site.
1224. Henderson and the defendants maligned me and my business all over the AFRA
interactive online forums and non-AFRA forums, demanding I remove the articles from
my web site. I refused to argue about it, simply stating AFRA had no right to control what
I publish on my web site.
1225. With Henderson’s nudge here and prod there, the defendants began to wage a campaign

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on all online interactive online forums, to attack me, libel my business and my products,
to exhort consumers to eschew my products and services, then to steal my products and
give them away, all because I insisted AFRA and the defendants had no right to control
what I write or publish on my web site.
1226. Henderson allowed, and even encouraged AFRA members to participate in the campaign
and allowed AFRA groups and properties to be used to conduct this campaign of
destruction against me. Henderson instigated many of the events described in this
complaint, specifically those listed herein on Cencom July 1, 2004; Directors July 17,
2004; CenCom July 24, 2004, State_Leadership, CenCom, & Directors July 26, 2004,
CenCom February 11, 2005; CenCom Febrary 13, 2005; CenCom February 14, 2005;
February 16, 2005; Directors February 17, 2005; Cencom February 17, 2005, Directors
March 22, 2005; April 21, 2005; AFCRM May 1, 2005; Cencom & Directors April 4,
2006; Improvement Project September 25, 2006; Helpline May 17, 2009.
1227. Once instigated–all in the name of forcing me to remove articles from my web site–he
would stand back and fan the flames when they started to die down, berate me publicly
for causing the disruption, issue edicts which he wouldn’t enforce, and the cycle would
begin again.
1228. I left AFRA, and the campaign escalated to the horror it is today. I finally offered to
remove the articles, and the defendants said it wasn’t good enough, now they wanted me
eliminated from competition and from the Internet. It was evident it was never about the
consumer advisory articles, that was just an excuse. It was about eliminating from
competition.
1229. In December 2003, Barnes sought and obtained the assistance of AFRA, Leonard
Henderson and AFRA membership in contacting the Missouri Governor and other
officials in conjunction with a child abuse investigation and police raid on her home.

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Despite the fact that the defendants have steadfastly refused to help anyone who abused
children, and Barnes has an extensive history of child abuse and neglect, AFRA
determined that Barnes was worthy of their assistance.
1230. On or about December 19, 2003, Henderson contacted me about a consumer advisory
article on my web site asking if I had the proof that the subject AFRA member had
scammed $10,000 from a donor. I advised him I had seen the wire transfer documents and
spoken with the donor, but the AFRA member refused to return my calls. He did not
object to this article. In fact, in his subsequent criticisms of my consumer advisory, this
AFRA member was never brought up by him.
1231. On or about February 5, 2004, despite her amnesia (¶448), R. Cygan sent me a demand
for an apology and threatened a class action lawsuit against me.
1232. On or about December 27, 2003, Henderson, acting on his belief of the false claims made
by A. Dutkiewicz on NEPAN, responded stating his displeasure that I had instigated
“off-list CC battles”, when I had not. He characterized my defense against A.
Dutkiewicz’s accusations that I operated a porn site as “a cat fight.” When I advised him I
had not contacted her off list and objected to the public humiliation of his demeaning
characterization, it marked the beginning of his support for the Dutkiewicz’s campaign of
false advertising against my attempts to protect my property and my business. He then
used AFRA to increase this campaign to harm my business and infringe and
misappropriate my intellectual property.
1233. On or about January 1, 2004, on Cencom, Henderson expressed his “curiosity” about my
what intellectual property of mine was being disseminated by him, asking whether the
widely disseminated advice for families could be claimed by me as being copyrighted.
Since this communication, he has steadfastly denied I that created the strategies and
methods being disseminated by family rights organizations, and has taken every

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opportunity to advertise that disbelief using the authority of AFRA throughout the entire
market and to publicly malign me for taking credit for those strategies and methods
stating,
“. . .Shell believes she invented Family Rights advocacy and it’s anybody’s guess what
she will claim ownership of anytime in the future. . . It doesn’t matter who owns it, I
only care about getting the info about it to the people who NEED TO KNOW it.”
1234. He also expressed his doubts that I wrote the children’s book, Knowing My Rules,
stating, “I had no idea who wrote it. . .You claimed it and you are selling it.”
1235. On or about January 3, 2004, Hinger responded to R. Cygan’s complaints on AFRA and
non-AFRA online groups about my consumer advisory articles,
“Suzzane is not making these acusations on the groups, she is doing so on her own
website which would allow anyone being falsely accuses to file legal action to resolve
the problem. You are broadcasting your accusations over the groups. This type of
activity tends to discredit the accuser when done on the groups. . .Not to mentions
drives away members who would otherwise contribute to a national effort. . .”
He advised members to take their complaints off list.
1236. On or about March 9, 2004, in response to Henderson’s request that I contribute to AFRA
by writing “The Definitive Manual on Family Rights Advocacy,” I asked,
“I make my living as writer and exploiting my copyright protected intellectual property
to fund my work. Is anyone else on this list being requested to donate all the fruits of
their labor and talents for the benefit of AFRA? If I do donate my research and
creative writing to AFRA, will AFRA fund my work and pay my bills in exchange for
the right to exploit my intellectual property? Or does AFRA espouse the position that it
is entitled to the fruits of my labor just because I'm a 'member' and I'm expected to
give freely?”
Henderson responded with an insulting speech requesting soft music and a candle light
dinner, explaining that sometimes one should say “no,” sometimes some should say
nothing. Then a nasty comment about how ones’ perspective might be prejudiced and
over-stated.
1237. I was rebuked for making the comments above, so I responded on March 13, 2004,

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“Please advise as to what information one is permitted to share. (I must confess some
confusion - for example: I submit information about copyrights associated with the
MMPI. That is was acceptable. But a discussion about copyrights in the context of
AFRA exploiting my property was deemed to be 'prickly' and non-peaceful). I've
recently observed much more 'prickly' discussions about 501(c)(3)'s than my post
was. The 501(c)(3) posts rightfully were not (and should not have been) cause for
corrective input by anyone.
“Am I correct in understanding that if I employ any meager research and
persuasive language skills I might posses on behalf of AFRA that AFRA is eager and
pleased to exploit the results? But if such skills are used to support my position which
may be in dispute with any 'unofficial' AFRA position, then those efforts would be
subjected to public rebuke? How is it that one use of this discussion is considered
'peaceful' and the other is not, even though the content and presentation was
substantially similar? Could it be that anyone took personal offense (or was
anticipated to take personal offense) at my recitation of impersonal facts which
supported my position? Facts which were clearly not directed toward any particular
individual or organization?”
1238. On or about April 29, 2004, Henderson published on CenCom in response to an article I
had written and disseminated,
“I, Leonard Henderson, co-founder of AFRA hereby state that I support Suzanne Shell's
efforts. Suzanne's missive below is the best I have ever seen her articulate the
importance of her efforts on behalf on ALL family advocacy. I encourage the AFRA
membership to get behind Suzanne Shell in her litigation.”
1239. On or about May 2, 2004, T. Dutkiewicz took a private cease and desist communication
from me and published on CenCom with his false comments,
“I have no idea what your work is. The information comes from case law and from our
federal lawsuit. I have never read your work or know where to find it. So please
explain exactly what is yours.”
The information he was disseminating was a condensation of portions of my book,

Profane Justice. In response to another member he falsely advertised,
“There is no mud slinging going on. Everything was going alright until Ms. Shell
started false allegations of coping [sic] her work. Everybody was minding their own
business and then Ms. Shell thinks I can not have freedom of expression. She thinks I
copied her work when the truth is I have never read her work.”
He and his wife admit to having my book on other occasions, described herein. A.

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Dutkiewicz also admitted the book was copied from my work.

1240. On or about May 2, 2004, acting on the Dutkeiwicz’s publication to AFRA groups, of a
private cease and desist demand I had sent to the Dukiewicz’s, Henderson publicly asked
for my biography and history on AFRA_CenCom in support of my claims that I had
created the methods and strategies being disseminated by AFRA and that Connecticut
DCF Watch and the Dutkiewicz’s and their Tip of the Week articles were merely copies
of my published work. He characterized my claims as “chilling” and called it the “Death
Knell of Family Advocacy.” Unwilling to believe the historical account as requested,
Henderson and the Dutkeiwicz’s subsequently increased their false advertisements that
these “simple and effective” methods did not originate with me.
1241. AFRA has continuously provided advertising to A. Dutkiewicz on the AFRA web site,
which advertised the book, “Child Protective Services and the Juvenile Justice System: A
guide to protect the rights of both parents and children, Written by Thomas Dutkiewicz
and Aimee Dutkiewicz, New England Parent Advocacy Network.”
1242. On or about May 6, 2004, A. Dutkiewicz published on NEPAN, “Thank You for the
support. Yea I get my panties in a bunge and I pop off at the mouth real fast.
Unfortunately I have just learned that Suzanne Shell has MS and it may be affecting
her thinking..... so now I feel a bit of remorse for really lambasting her.”
1243. On or about May 6, 2004, Jackson responded on NEPAN, “This is confirming something
I have suspected for a long while, Aimee, that Suzanne is suffering from a disability
and from a natural anxiety arising from her failing health.”
1244. On or about May 12, 2004, Baez falsely advertised on CenCom that R. Cygan, who was
featured in the consumer advisory for stealing property from a fugitive family she has
housed in the underground railroad, had contacted me with proof supporting her denial.
She stated the burden of proof should rightfully be on the shoulders of the accuser. I was

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not the accuser, I was the publisher. Cygan never did anything more than deny and make
threats.
1245. Baez stated her support for R. Cygan and demanded I provide the proof on CenCom. It is
a standard practice of journalism not to reveal sources to protect them. Baez participated
in the campaign against me for my exposure of R. Cygan on the Consumer Advisory
because I did not provide my sources to R. Cygan or Baez for fear the defendants would
similarly abuse them.
1246. On or about May 12, 2004, Henderson put CenCom on moderated status due to an
ongoing debate about my consumer advisory articles, saying,
“If the CIA had devised a psychological operation to destroy the organization of family
advocates, they couldn't possibly do better that this [Consumer Advisory] . . . AFRA is
paralyzed and rendered impotent because our LEADERSHIP Central Communication
System (AFRA CenCom) is full of static and noise. There is absolutely no difference
between this and SABOTAGE. . .So, I am going to clear the air out completely until
people start listening to ME.”
1247. I did not participate in that debate. I advised Henderson on May 13, 2004, that I had not
been following what was happening for three days. I advised him privately,
“I object to your position regarding the [consumer advisory] and I will withdraw from
AFRA membership if it is so offensive to you that you must attack it or me publicly in
this fashion. I had no objection to your position that AFRA did not support the list. I
had no objection to your recent message clarifying that point. . .I do object to you
taking sides on the issue by unfairly condemning the [consumer advisory] as the focus
of the problem when it is, in fact, only a symptom of the difficulties in unifying this
movement. If it wasn't the [consumer advisory], it would be something else, you know
that as well as I do. You decline to condemn all kinds of illegitimate and questionable
activities by others, but you condemn me for taking the higher ground. . . Thank you
very much. I object to being the ONLY advocate/activist who is targeted by you for
public condemnation for the actions I determine I and my organization will take or for
defending my position when it becomes a topic on your list. . . a topic, I remind you,
that I did not raise. I have as much right to support my positions and actions as
anybody else has to attack them. If you don't muzzle the attacks, you'd better not
muzzle my defense. Fair is fair. Don't ever do this to me again, Leonard. Don't you
ever take sides again on an issue which is in contention like you have done the past
two times against me. It is extremely disrespectful and disingenuous. I don't need

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alliances that will attack me and I won't tolerate it again.”
1248. Henderson responded with shallow flattery and his complaints about wanting to promote
my work,“I have actually tried to promote GOOD PR on your behalf. . .I would LOVE to
tell [what you have accomplished]. Do I have the whole, great big story to publicise?
Hell no. Why not? Because of this WAR in the ranks.” I didn’t want him to publicize his
version of my accomplishments, and this insincere flattery was insulting.
1249. On or about May 15, 2004, I asked Henderson on CenCom if A. Dutkiewicz’s public
“sarcasm and disrespt[ful]” comments were tolerated on this leaders’ list. He responded
publicly that he had “. . .addressed it OFF LIST so as not to create a PUBLIC
SPECTACLE,” and chastised me for mentioning it. He never afforded me a private
warning for my comments or for situations when I was not participating but was the
subject of the debate. All of his derogatory comments about me were public on AFRA
groups, and he lumped my conduct in with the bad conduct of the defendants, so that it
was indistinguishable to an outsider.
1250. On or about May 15, 2004, Henderson stated on CenCom, “Nobody has been banned or
unsubbed by any of the Moderators at CenCom.” despite his complaints about the
conduct.
1251. On May 15, 2004, in response to Henderson’s increasing encroachments and his publicly
hostile position toward me, I withdrew my membership from AFRA, hoping I could
continue my work in peace without being disrupted by AFRA outbursts.
1252. On or about May 16, 2004, Hinger showed that he was being influenced by Henderson’s
campaign and advertised on CenCom that I had “slandered his name” on my web site and
demanded I remove it. I contacted him privately and pointed out that the content he
contested wasn’t defamatory and he subsequently issued a public apology for his false
advertisement that I had slandered him.

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1253. On or about May 18, 2004, T. Dutkiewicz copied and posted verbatim content from my
web site Consumer Advisory article about A. Dutkiewicz, and accused me of
“harassment, slandering and outright defamation of character.” He again denied
reading anything of mine and accused me of having “serious issues in my past which
remain unresolved.”
1254. He then falsely advertised that I “impersonated an attorney several times.” He told the
recipients that I would be hearing from their legal team.
1255. I did get a form cease and desist letter from an attorney Lord with pre-paid legal. When I
responded asking if she was representing the Dutkiewicz’s in this matter, she advised me
to speak with A. Dutkiewicz directly. I concluded she was not representing A.
Dutkiewicz.
1256. Dutkiewicz’s never took this alleged defamation to court. They did make numerous
requests in online legal forums and were always told by the lawyers that what was on my
web site was not defamation.
1257. On or about May 19, 2004, the Dutkiewicz’s were banned form AFRA CenCom for
complaining about my consumer advisory articles. They remained on other groups and on
CenCom under assumed identities, and were permitted to forward false advertisements
without restraint on AFRA groups, including Cencom. This was a “wink, wink” banning
strictly for appearances.
1258. On or about May 22, 2004, Hinger proposed on CenCom that AFRA devise a written
code of ethics and standards for all persons professing to be advocates, and institute a
registration or certification “AFRA Advocate” procedure to improve AFRA’s credibility.
1259. On or about May 22, 2004, Hinger recommended on CenCom, that AFRA develop a
complaint resolution procedure about any group using the AFRA name. He claimed to be
buried in complaints about one group (referring to my business) and insisted that AFRA

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exercise control over my business. He reminded Henderson that “to be an AFRA group
creates an AFRA Responsibility and Liability.” I was not a member of AFRA. I didn’t
have any groups. I do not have membership.
1260. On or about May 24, 2004, on CenCom, after a heated debate with many references to
me, a debate in which I did not participate, Henderson put all members on moderated and
exaggerated the debate,
“I have had it completely to the gills with this war. I remember exactly who
and what started this war, because I was there when it happened. I never
needed to hear excuses or explanations. Now it escalates to threats. AFRA
CenCom WILL NOT be the forum for point-counter-point. Nothing further on this
war is going to be posted on AFRA CenCom.If this war is the thing that
destroys AFRA, then so be it. I am done with this war. The war is not going to
be waged on AFRA forums. It is obvious that AFRA is completely paralyzed and
unable to act on ANY family rights advocacy.”
1261. On or about May 24, 2004, Henderson reported on AFRA_CenCom that he was up to
Chapter 2 of Profane Justice and it was “EXCELLENT.”
1262. On or about May 29, 2004, A. Dutkiewicz advertised on all AFRA groups with the
subject “Did profane-justice redesign their site?,” “Has anyone seen the newly designed
site called www.profane-justice.com? What is all about?” See ¶ 501.
1263. On or about June 2, 2004, Henderson established an interactive on line group at Yahoo!
called Directors, designated to conduct AFRA business by the Board of Directors (BOD).
Henderson set the tone for the BOD, and appointed like-minded people to serve as
directors who would not contest his increasingly controlling agenda for AFRA.
1264. The BOD first order of business was to revoke specific AFRA memberships for various
reasons. Many of the membership revocations were the same people listed in my
consumer advisory articles. Names of revoked members were displayed in bright yellow
boxes on the AFRA web site state membership pages describing the reasons for the
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1265. Henderson often brought issues from other AFRA groups to the Directors site in order to
convince the BOD of his side and obtain a consensus to his agenda. I was one of his
agendas, as was anyone else who dared disagree with him publicly or who challenged his
attempts to force others to do his will for their own good.
1266. The fact is, Henderson managed to effectively obtain a consensus on virtually every issue,
and then send his little army out to perform their deeds in support of his agenda to insure
there was no effective opposition or competition with AFRA or Henderson.
1267. AFRA’s agenda was becoming more controlling, requiring all family rights organizations
to be subordinate to AFRA, and AFRA was to have all rights to exploit their work and
take credit for their positive outcomes under the AFRA banner, while being able to safely
distance AFRA from any derogatory implications arising out of associating with the
wrong person or organization.
1268. Minor organizations with little influence in the market were permitted to function
unhampered.
1269. I and my associates resisted AFRA’s control over our businesses or organizations.
1270. At this time, our influence exceeded AFRA’s influence in the market based on the merits
of my work, which Henderson could not allow.
1271. On or about June 3, 2004, Henderson published to AFRA groups, “I really care about
how effective somebody is as an advocate and I am very willing to overlook
abrasiveness, obnoxiousness and a degree of feminism.” He was referring to me.
1272. On June 4, 2004, Henderson admitted he did not have the influence he demanded over
my business to a private individuals and on AFRA_Directors online interactive group.
1273. I became an ongoing subject of debate within the AFRA BOD covering issues of how my
attempts to control my own Intellectual Property (IP), my refusing to divest myself of
publications and properties AFRA wanted, my fee structure, my refusal to share my

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proprietary methods and more, were problematic for AFRA. Their debates were carefully
guided by Henderson until they arrived at the consensus Henderson wanted, and the
members–including the defendants–went out to accomplish the desired mission on behalf
of AFRA.
1274. Often, the BOD consensus wasn’t even necessary, because Henderson simultaneously
guided similar debates on AFRA myriad online interactive groups (groups) to the same
effect.
1275. He accomplished this with a pattern he used for years. He’d set the stage with gratuitous
ego stroking and present Henderson as the “good guy” while simultaneously introducing
a derogatory fallacy as fact and establish the target as morally, intellectually or in some
significant manner deficient and in dire need of Henderson’s personal guidance to be
brought under AFRA’s wing. He would make his argument for his position based on
fallacy after fallacy, then present the set-up for his brilliant, irresistible solutions to the
problematic fallacies he’d just constructed before our very eyes. He’d add a little bit more
gratuitous and disingenuous ego-stroking to grease the way, then enlist the aid of all those
eager readers so they’d feel empowered. He might sprinkle in some critical but loving
fatherly advice, add a dollop of grandiose pontificating, then demand you donate your
first born child in exchange for a photocopy of a three dollar bill in such an elegant
scheme that you feel honored to hand the baby over and never complain that you were
cheated. Then repeat as needed to reinforce the fallacies. If you did complain, his
by-now-adoring groupies would beset you with outrage that you dared refuse Henderson’s
magnanimous and totally selfless offer. Henderson would fan the flames as needed until
the stupid, selfish, wayward miscreant was shouted into silence or submitted under the
incessant pressure.
1276. On or about June 16, 2004, on Directors, Jackson evidenced her assimilation of

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Henderson’s party line regarding my consumer advisory articles, stating the consumer
advisory was “personal and adversarial.” It was not personal, it was objective, well
researched and documented consistent with accepted journalistic practices. In this same
message, Jackson admitted I had “invented many anti-CPS wheels.”
1277. She also admitted deleting electronic evidence from the NEPAN group that would
support the facts in my articles, thereby insuring she could fabricate what really happened
so she court protect A. Dutkiewicz and so there would be no record to contradict her
version.
1278. She stated my articles should be “administered by a joint effort” supporting Henderson’s
desire to have AFRA take control of my publication. She stated, “The idea [of my
consumer advisory articles] is fine. The execution is faulty.”
1279. On or about June 17, 2004, Jackson conspired with the BOD on Directors about divesting
me of my consumer advisory articles, and stated, “This is an earnest effort that
[Henderson] has initiated.” She later stated, “One would hope that a group [AFRA] would
be more objective. . .”
1280. In response to a comment about defining the criteria for being include on a consumer
advisory, Jackson responded that she felt it was equally important who administers the
advisory. She expressed opposition to me doing it, admitting she was biased against me,
and inferred that one–referring to me– could provoke another to do wrongful things
which might cause them to included on the advisory.
1281. On or about June 17, 2004, Hinger participated in the conspiracy to divest me of my
consumer advisory articles on CenCom attempting to define the circumstances where one
should be appropriately included in the advisory, and define what a Family Advocate is.
He agreed with a prior suggestion about establishing a rating system, a registry and
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“I also would like to . . .see [Suzanne] back as a member of AFRA. . .she has made
numerous contributions to our cause. I pray we never grow to the point where we fail
to take into consideration the contribution of our individual members when negotiating
issues such as these. Suzanne proposed the [consumer advisory articles] before posting
it herself and I think we can work out an agreement to reappraise her original request.
. .Some may see Suzanne as opinionated, out spoke and unyielding, but she is without
a doubt sincere in her beliefs and willing to present her arguments to public scrutiny.
By not allowing her that opportunity, we disrespect an acknowledged leader in this
movement.”
He went on to reiterate his beliefs about a rating system and review process administered
by AFRA upon my divestiture of my publication.
1282. On or about June 18, 2004, Jackson continued her participation in the conspiracy on
Directors, falsely advertising to the BOD that I provoke inappropriate conduct by
advocates. She went on to say,
“Yes, SS is THE Grande Dame of the movement. She is brilliant, fearless invented the
wheel, and merits a gargantuan amount of respect, certainly ‘due process.’ But she
needs to cut the crap.”
1283. On or about June 18, 2004, Hinger continued his participation in the conspiracy on
Directors stating his disagreement with my publication because it conformed to
journalistic standards for publication. He insisted that the proper methods should conform
to a court case, requiring a jury trial, prosecutor, judge and findings by clear and
convincing evidence. He advocated AFRA taking control of oversight over
advocates–regardless of their AFRA membership– and having a page on the AFRA web
site listing advocates that had been sanctioned by AFRA.
1284. On or about June 22, 2004, on Directors, Henderson demonstrated his autocratic rule over
AFRA when he unilaterally revoked the membership of K.L and admonished the BOD,
“The decision has been made. . .and you still want to debate about it. . .This issue is
done.”
1285. On or about June 23, 2004, Henderson reported to the BOD on Directors that he had

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revoked the membership of C. O. stating she was a nut case that AFRA had endured too
long, and was nothing but trouble. Her email that was attached as justification for
revoking her membership discussed her defense of copyright issues wherein she stated,
“Taking someone’s essay and changing it would fall in the category of opportunism,
which was my point. We all know what difficulties Ms. Shell has borne with that
problem.”
1286. On or about June 26, 2004, Henderson posted on CenCom under the subject heading,
“Professional decorum,” “Christi, why don't you take a Midol and go do something fun
for a while until your belligerent mood passes? I am ready to clean this list up and
return it to being the Central Communications System of AFRA LEADERSHIP.”
1287. On June 27, 2004, Henderson initiated an unsolicited email to me offering information
about “weird attacks” and wanted information to compile that data and asked for my
input. I declined to provide my information to him.
1288. Roz McCalister, in her capacity as CPS Watch state director for Ohio, was advertised as
an advocate on AFRA CenCom’s state advocates list on or about June 30, 2004.
1289. On or about June 30, 2004, Hinger raised the question if I was an AFRA member, and if
not, why was I on CenCom? BOD and CenCom moderator McGrath responded, “She has
not bashed anyone or caused any trouble on the e-group so why would one remove
her? AFRA is a free association and Suzanne’s book, Profane Justice, is posted on the
americanfamilyrights.com website at the discounted price.” Hinger responded with a
false claim, “. . .somebody did raise an allegation that she is harassing other AFRA
Leaders Off Group due to what is said on group.” He advocated conducting an
investigation into the allegations against me.
1290. On or about July 1, 2004, on Directors, Jackson stated she had better become friends with
R. Cygan if they were going to be “partners-in-lawsuit,” referring to defendant A.

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Dutkiewicz's and R. Cygans' threats to sue me.

1291. On or about July 1, 2004, a known associate of mine who was a member of AFRA, and
who had made a donation made a request on CenCom for an accounting of the funds
donated to the AFRA delegation that went to Washington D.C. and to be able see the hard
copies and transcripts of the presentation made by the delegation. Hinger responded, “. .
.when people are so intent on destroying the work of others to further who knows
what cause that they come right out and call me a liar, well you can take this and stick
it where the sun doesn't shine... I QUIT!!”
1292. On or about July 1, 2004, in response to this same member’s request for an accounting of
donations to the AFRA delegation trip to Washington D.C. Henderson stated on
CenCom,
“Absolutely nothing AFRA does is one person's exclusive property. . . Personally, there
are days I would just as soon shit-can this whole thing. And I can too, because I OWN
most of it and I can shut down the entire thing in a manner of minutes. The
benevolent dictatorship of Leonard Henderson is alive and well. . .Are we going to
finish destroying AFRA, or are we going to buckle down, start paying attention, and
stop the noise and clatter?”
He characterized the member’s legitimate request as “kiddie fights.”
1293. On or about July 1, 2004, on Directors, Henderson misrepresented that my leaving AFRA
was because of A. Dutkiewicz. My leaving was due to his poor leadership skills, his
misogyny and propensity to publicly belittle and malign me on AFRA groups and his
refusal to stop trying to control my business and property.
1294. On or about July 1, 2004, Hinger urged the BOD to act against me on Directors,
“. . the time has come to settle the Suzanne Problem. . .It is time to bring SS in line
with the rest of the movement or totally discredit her. . .it is time fo SS to play team
ball or go away.”
1295. On or about July 5, 2004, Hinger complained on Directors about having to “fight”
Suzanne Shell, and others, calling us “mal contents.”

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1296. On or about July 6, 2004, Henderson stated, “I sure wish the utterly divisive [consumer
advisory articles] would just go away and SS could be more of a team player.” He
ignored the fact that I had quit the AFRA “team” and therefore I was not required to be a
team player.
1297. On or about July 6, 2004, Jackson reinforced Henderson’s characterization of me to the
BOD, and suggested AFRA publish a poll regarding my consumer advisory articles,
presenting limited alternatives including
“. . .is SS playing judge and jury and selectively publishing private correspondence out
of context” and “is SS carrying on personal vendettas to a pinnacle of public pettiness
.. . .if only the votes would be overwhelmingly disparaging off SS. .”
1298. By July 7, 2004, Hinger was toeing Henderson’s line regarding my consumer advisory
publication, demanding I prove what I wrote in my articles to AFRA’s BOD or else the
credibility of my publication should be publicly maligned by AFRA.
1299. On or about July 8, 2004, Henderson argued with Jackson on Directors about who
invented the strategy known as “document,”
“Hey!, I am the one who made ‘Document, Document, Document’ famous. I invented
the phrase. You and hundreds of others are using my intellectual property. Which is
want I had in mind when I started hammerin on it years ago. . .Leonard, a true
altruist whose only goal is to destroy government corruption and doesn’t care about
getting credit.”
Tower concurred with Henderson’s claims in his response. This strategy was debuted on
my web site in 1996.
1300. On or about July 8, 2004, on Directors, Jackson stated about me, “I agree with Leonard,
that there is a screw loose. . . are we negotiating with a terrorist?”
1301. On or about July 8, 2004, on Directors, Henderson made profuse flatteries to new BOD
Nev Moore in conjunction with his request for her to write articles and press releases for
AFRA. He signed it, “Leonard, gushing and proud to hang around with people the

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stature of NEV”
1302. On or about July 11, 2004, Hinger asked the BOD on Directors, “Has anybody heard
anything about a shooting at Suzanne Shell's House? There is supposed to be an article
in the Elpaso CO. newspaper about this... But I can't find the paper online...”
1303. Hinger engaged Ms. Korn in a public discussion on AFRA_CenCom on or about July 17,
2004, demanding I prove the content of my articles.
1304. On or about July 13, 2004, Henderson revealed more of his disrespect for women when
he expounding on his first marriage and referred to the ex as “a rotten little snot” who
exhibited, “shitty temper tantrums and constant threats.”
1305. On or about July 17, 2004, Henderson send me an email and copied it to Directors with
the subject line, “TRUCE DOGONNE IT!” He suggested, “I have been reading your book
and the #1 thing my head keeps screaming is-‘This Needs Broken Down into pamphlets
with graphics that people will read- not a ‘boring BOOK.’” He made an offer he was sure
that I couldn’t refuse, “AFRA has made your goals achievable. The organization is
sitting here, waiting. . .If you invented it, I made it happen. . .here’s your chance to be
the STAR.”
I reminded him I had left AFRA alone to function peace and that I didn’t need nor
want AFRA. Recognizing his insincerely flattering offer to be an attempt to subordinate
my work and property to AFRA, I said, “You aren't offering me anything I didn't
already attain on my own. . .You really got some balls, Leonard, coming to negotiate a
truce without anything worthwhile to offer me.”
1306. Henderson then reported back to Directors confirming my recognition of his desire to use
me to enhance his and AFRA’s status,
“I am reasonably sure that SS's mental capacity does not exceed mine, for she refuses
to see the opportunity in a fresh, clean start and my promotion to her stardom at
exactly the time when she could SHINE.- NOW of all times with National Attention

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where I would LOVE to thrust her into the spotlight and turn her loose to tear CPS a
new asshole. Can you imagine how much fun it would be to send HER to DC?”
1307. On or about July 23, 2004, AFRA members on CenCom began advocating training for
advocates, specifically--my training--and wanted to salvage the situation between me and
AFRA. I did not instigate nor participate in this discussion. AFRA BOD McGrath
reported, “I've 'met', on-line, one family that attended one of Suzanne's family
advocacy training's and since then, this family has turned their case completely
around.” AFRA member Weston agreed and said, “I have read Suzzanes site and I do
like it very much.” Members rallied in support of my training and complemented my
products and customer service. One pointed out how I had been abused by AFRA, which
is why I withdrew.
1308. On or about July 24, 2004, AFRA BOD McGrath wrote to my associate, Ms. Belou and
said,
“I know that you were referring to Suzanne and that she has a training program
already in place. Problem is that Leonard is so adamant against the training and all
the e-groups worship him. If she comes to NYS, will you come on down? I'll go to CT
for that training! . . Certainly, there will either be an 'agreement' e-mail this evening
from Leonard or a 'NO WAY' e-mail from Leonard, this evening - on advocacy training.
Either way is okay because so many (more than six people, if those not on CenCom
count, which they do) people are demanding the training and the lawyers need trained
advocates as well to work with them.
“I know Suzanne was sent an e-mail, last week, by Leonard. Suzanne has every
right to be angry but she still realizes that the children are at greater risk without
training.”
“This week was four days and still counting on damage control for a prominent
NY City Lawyer who had a real bad advocate mess up his case... we are almost done
with damage control, had a five minute spot on TV last night, and shall see on Monday
if we succeeded or not and I don't like to be so uncertain about this stuff.
“Perhaps those that sit behind the computer screens and never see or hear of
the huge messes created by untrained advocates don't get it? Writing letters to
politicians if fine ... if one can spell. But attending and being involved with families at
CPS meetings and then in Court - that requires training. No way around this one.
“And this training must be done in groups and not over the Internet.”

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1309. On or about July 24, 2004, Henderson responded with a forked tongue to the CenCom
members saying,
“This has been near and dear to my heart for a long time. I would LOVE to have
Suzanne Shell do Advocate Training. Those of us who KNOW Suzanne Shell, know that
she is The Expert on Advocate Training. This is her main forte. . .As for an apology,
we know from long experience that participating in yahoogroups is NOT Suzanne
Shell's forte. Honest, and enough said.”
Henderson used his influence to divert attention from my training without actually telling
the members he did not want anyone to take my training, and reinforced his false
impression that I was disruptive.
1310. On or about July 25, 2004, AFRA member and Colorado AFRA leader Korn appealed to
Henderson about my training and proposed certification, and to duplicate the family
advocate legislation I had gotten passed in Hawaii.
1311. On July 25, 2004, AFRA BOD McGrath suggested AFRA lobby in Colorado for a law
protecting family advocates, because that is the state where I live and Colorado advocates
needed protection. McGrath presented Colorado specific information to solicit AFRA
efforts to pass similar legislation. This discussion continued with participation by many
members.
1312. On or about July 25, 2004, AFRA member Manzoni wrote on CenCom, “Another thing
is right that you said, we DO use [Shell’s] methods from many years ago. They ARE
also in her book. I would apologize to her, but she already knows I love her LOL.”
Member Belou responded, “Guess that makes two of us who love her but I know first
hand, many, many members here feel the same way.” The members began working on
fund raising ideas for me to free me up to train them.
1313. On or about July 26, 2004, AFRA CenCom member J. asked the group, “As much as I
personally admire Suzanne, there is a lot of bad blood among the groups between her
and other old-timers. These people aren't going to support her. So, any suggestions as

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to how these fences can be mended?” She later observed, “I think Suzanne should be
out there, not only training, but engaging in public speaking, etc. She is an amazing
force in our movement.”
1314. AFRA member Belou responded,
“I've been around for six and a half years and the only people I know who don't like
Suzanne the ones who were put on her [consumer advisory]. I meet more intelligent
and poised people who like her than don't and that is the honest truth. Now, I also had
bad experiences (exclusive of ever speaking with Suzanne) about the people on the
[consumer advisory] except for two. Don't you think that it is more than coincidence. I
keep telling you that unless we are willing to regulate ourselves, we will never be
taken seriously buy the public or the government. Now, my lists I moderate or co-own
add up to a membership of over 1,000 people. Anyone who doesn't like Suzanne on
those lists has never voiced it. . .So, here is what I say, leave personal dislikes out of
this and let's do what we need to do keep moving this thing forward.”
1315. All of this support and action on behalf of me and my training was more than Henderson
could endure. On or about July 26, 2004, Henderson posted to all AFRA groups that he
was the “old-timer” and “THE fence-mender.” His proposed fence mending included my
ignoring his past abuses and his gagging me in this market,
“We fix it by saying "To hell with the past" and work together NOW. Of course, this
involves Suzanne Shell NOT participating in yahoogroup chats, because of her ‘magic’
ability to piss people off in this medium.”
Naturally, this solution was unacceptable to me, as it facilitated his and AFRA’s
usurpation of my business and my property. Henderson again admitted my contribution to
this market,
“Suzanne Shell absolutely knows what she is talking about. She has been "in the
trenches" for many, many years. . .Suzanne Shell has spent YEARS building the tools
and expertise to destroy CPS.”
He then continued to describe AFRA’s desire to usurp those tools and expertise for
AFRA in spite of my prior refusals to him and the fact that I had my own delivery system,
“Leonard Henderson, in only 2 ½ years has assembled the DELIVERY SYSTEM. And
YOU ARE IT. So, now do you see how it needs to work?”

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He stated,
“Our recent, heroic attempts to affect legislation seem to have fallen flat. . . Of course,
the things [AFRA member] Suzy Nickel have been developing are unique and HIGHLY
effective, too. . .let us not forget Pamela Gaston’s SUI JURIS - the keys to the kingdom
on kangaroo court. . .So let’s talk about HOW to assemble all the pieces into a WHOLE,
and construct a cohesive effort on ALL FRONTS- . . .”
This message was widely distributed to AFRA and non-AFRA online interactive groups.
Henderson’s genius was in crafting an offer I couldn’t accept, so my refusal would make
me the bad guy.
1316. Henderson’s intended message to usurp my business and my intellectual property was
being absorbed by users. In response to this, J. posted to CenCom,
“It just occurred to me that Suzanne doesn't need to come to us. We can go to her. She
could conduct seminars in good ole Colorado . . . It would be a good place to start and
she could branch out from there. I can see her being offered paid speaking
engagements at conventions and college campuses across the country. She would be
perfect in such a role and AFRA could be her marketing department.”
I did not want AFRA as my marketing department, and Henderson knew it. I was
proceeding with my training without AFRA’s help, or input, or control.
1317. Responses to this thread exhibited enthusiasm and agreement with Henderson’s
proposals. It was obvious that my veto to this plan was irrelevant. There was also a
general consensus with Henderson’s portrayal that I was disruptive and abusive on the
groups. Members asked that I join in the CenCom discussion to mend the fences. I did not
participate, because of Henderson’s propensity to use my participation to as his forum to
bloviate, and publicly malign me with his twisted version of me and my business while
offering gratuitous flattery.
1318. On or about July 26-27, 2004. Henderson allowed a lengthy debate on CenCom about my
consumer advisory articles, most of which supported his position. . .that AFRA should
control what I publish on my web site, and control my business. Members suggested my

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book could be used by AFRA to substitute for my training.

1319. On or about July 27, 2004, on CenCom, Jack Stratton wrote,
“As far aa all this talk of ‘copyright’ infringment, what are these people more
interested in, saving children or protecting what they apparently consider as their
infallible pronouncements which they apparently consider as coming down straight
from Mt. Siani.”
1320. On or about July 27, 2004. Henderson offered an observation on Directors to another
BOD’s comments that others provide advocacy training, “I don’t think SS has the patent
on PARENT ADVOCATE. She seems to think she has invented everything else.”
1321. On or about July 27, 2004, Henderson published on CenCom in response to a member’s
observation that I was on the list but hadn’t responded to the discussion, “*SIGH* Leonard
concurs. Giving up fence mending for a while.” He was able to lay the blame for the
failure on me, rather than on the fact that he offered a solution that he knew and intended
would be unacceptable.
1322. On or about July 28, 2004, AFRA CenCom member and BOD Hession posted on
CenCom that he could produce a simple training video to fight CPS.
1323. On July 31, 2004, Henderson published and advertised on AFRA Directors that I had left
AFRA, and that my efforts to protect my intellectual property was a “problem” for
AFRA.
1324. On or about July 31, 2004, Henderson responded to Hinger’s request regarding the status
of my AFRA membership on Directors stating,
“There is a real sticky problem. . .I am really at a loss about what to do with/about
Suzanne Shell. . .Suzanne may very well have ‘invented’ Family Rights Advocacy and
about everything we do that is now ‘common knowledge. I put a blanket
acknowledgment on the AFRA Copyrights page a couple months ago. She told me to
take if off, but DAMNIT!, I am not going to take if off because I am the last person on
earth who wants to get into a pissing match with SS over ‘intellectual property’.”
1325. On or about August 15, 2004, Blair wrote to Henderson, “[Shell’s] a lunatic, who never

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got her own kids back, and you know it.” He expressly included the definition of lunatic,
“adj, 1. Suffering from lunacy; insane.” In his complaint to Henderson, he complained
about the same things I had before I left AFRA.
1326. On or about August 26, 2004, on Directors, Hinger stated,
“From feedback I get on Suzannes [sic] seminars, I would have to guess she would be
in the 99.5% approval rating area. . . BUT! Most of our people can’t afford $25 or $50
plus travel, etc. to attend one of her seminars. . .We need online tutorials and test etc.
And a means of knowing that if we list somebody as an advocate, they have the
knowledge to do the job. . .”
1327. On or about September 1, 2004, Henderson issued an advertisement promoting my

seminar in Florida and included his own disinformation intended to piggyback AFRA on
my credibility, and containing blatant errors about the attendance fees intended to turn the
public against me. In that regard, it was successful. This advertisement was not
authorized nor permitted by me.
1328. On or about September 7, 2004, on Directors, Henderson described AFRA’s practice to
subordinate all associated with AFRA to AFRA, “The reason AFRA works is the
founders do no[t] pretend to be anybody special. AFRA delegates authority out to all
who are worthy.” He described certain strong-willed woman AFRA state leaders as
having, “. . .feminist stupidity. . .We are all supposed to pretend that anything that
goes through a woman’s head at any time is gospel and God help you if you disagree.”
1329. On or about October 22, 2004, Henderson issued an advertisement on AFRA groups
promoting my trademarked name Parentsmarch® and my Petition to Congress, soliciting
AFRA membership to incorporate my name and my property, claiming I gave him
permission to use it in an AFRA campaign for December 2005. This was a
misrepresentation. I said we could discuss it, that I had terms that needed to be met. He
provided his version of disinformation about the Parentsmarch® event. This
advertisement was not authorized by me. I also believed our conversation was not for

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general distribution. He was, once again, attempting to appropriate my credibility and

stature to AFRA and setting it up so if I disputed his version, I was the bad guy.
1330. On or about November 1, 2004, AFRA Bod Hession, J.D. wrote on CenCom, “I attended
Suzanne's seminar in Florida, and she provided the missing links that I needed to have
a seamless strategy to fight the usurping despotic criminal tyrants at all stages of a
case. It was nothing short of brilliant! I am so glad that I went.”
1331. In response to another member, Hession stated, “I think we could do our own seminars
in the New England States. Also, I have discussed with Suzanne putting out a series of
short, inexpensive, elementary DVD's or videos on how to fight CPS, for parents, that
advocates can get to the parents.” I had not agreed to this plan at this point.
1332. On or about November 4, 2004, AFRA CenCom member Roxy Weaver advertised in
response to favorable comments about my recent Florida training seminar on CenCom,
“I believe people want advocacy to be, and remain, as total volunteerism and not ran
as a BUSINESS venture. People get turned off when money is mentioned,. . .We believe
that advocacy, and training for advocacy, should always remain on a volunteer basis
and remain free, forever. . .That we will resist any person or group that attempts to
prevent advocacy or advocacy training to any indigent person or any person who
desires or needs help. . .”
1333. On or about November 4, 2004, Blair published to numerous online groups in this
market, “Suzanne, perhaps the Floridians are wiser than you think. I believe these
people can recognize a self-aggrandizing, hypocritical thug when they see one. . .when
you choose not to be an Independent Advocacy that doesn’t play well with others. . .”
1334. On or about November 4, 2004, Baez sought legal advice on behalf of R. Cygan on a
public forum at
http://forum.freeadvice.com/libel-slander-defamation-88/libel-net-203320.html regarding
libel in reference to my consumer advisory article about her. She wrote,
“This is interstate.....the states involved are: Colorado, South Carolina, Georgia,
Montana, Idaho, and Florida. I wonder how one might deal with slander/libel on the

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Net? We have tried the upstream providers, etc....and no one will help us. My friend
(among others) is being accused of felonies, etc., on a website. Nothing posted about
my friend is true, but we have all been having serious trouble dealing with the
upstream providers re removing the defamatory content. I will be happy to post the
URL to the defamatory site if seeing it could be helpful to those who might want to give
us some advice. Please let me know.”
She later provided the URL to the article about R. Cygan, and got this response, “The link
you provided is HILARIOUS!!!!!!!!!!!!!!! and protected free speech. NEXT?”
1335. On or about November 7, 2004, Henderson issued an edict, “Family Advocacy needs
trained ADVOCATES.” He stated this was a front burner issue at AFRA and solicited
members to tell him about their training programs. No members had any. I responded
asking if he needed to know about my training program or was he satisfied with attorney
Hession’s endorsement? Henderson ignored me and responded to another member, “We
need to train hundreds of Advocates. So step up the to the plate and do it.”
1336. On November 14, 2004, Henderson initiated an unsolicited email to me, telling me that in
order for him to help me “improve my stature,” I needed to remove my consumer
advisory articles from my web site. He obviously knew he could control public opinion
about me and was inferring he would exercise power that according to my response. He
blamed all the disruption on the groups on me. He asked how to make it go away. I
advised him that AFRA had no right to exert control over my publications nor to tell me
how to run my business. I also told him to stop promoting me, because his style of
promotion was harming me. In response to my response, he stated “AFRA does both
Advocacy and Activism.”
1337. During his phone calls to Ms. Korn in 2004-2005, W. Tower kept insisting that my
methods were nothing special, and that I should be providing my materials and products
free of charge if I were truly concerned about the reforms I was advocating. He only
ceased calling her when she refused to take his calls any more.

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1338. Tower later admitting to me and to the public as having gained access to my proprietary
materials. He has used those materials in his presentation to a congressional committee in
Washington D.C.
1339. Tower profusely defended the Dutkiewicz’s insisting they had not done anything wrong
to me or my associates and licensees.
1340. On or about January 6, 2005, Hinger contacted me via email and offered his prayers and
best wishes, as well as any other help I might need for an upcoming hearing in Colorado.
1341. On or about January 7, 2005, Henderson characterized Theresa Brewer, President of
AFRA-Missouri as “nutzoid” and questioned her mental health. She confronted
Henderson and demanded an apology, which was never forthcoming.
1342. On or about February 8, 2005, a message was forwarded to CenCom showing an AFRA
member, Cathy (catazcandu), conspiring on FloridaStoleMyChild interactive online
Yahoo! group with Swallow and CPS Watch member Howard to create their own training
from my work “By the way, Brenda, you and Desere should get together and build a
training syllabus so we dont have to deal with the compromise it takes to be around
Shell.”
1343. On or about February 11, 2005, Baez responded to CenCom members who were
supporting me and working to sponsor seminars saying, “I cannot in good concience
support slanderous activities combined with secret ‘evidence’ as contained in what my
kids call ‘The Bad List.’”
1344. During late 2004 and early 2005, there were multiple expressions of interest from AFRA
group members to sponsor one of my seminars for their states.
1345. In 2005, R.Cygan lived with defendant Baez.
1346. On or about February 9, 2005, on Directors, Henderson again raised the dead issue of my
consumer advisory articles. This incited AFRA members to take up the debate on

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CenCom and malign me, thereby distracting attention from Ms. Korn’s upcoming
seminar and to adversely affect attendance.
1347. On or about February 11, 2005, in response to the growing support and interest by
membership for my training program on AFRA_CenCom, defendants participated on
CenCom under aliases maligning me and discussing my consumer advisory articles to
convince consumers to eschew my products. They believed AFRA had the right to
exercise control over my business and my publications on my web sites. I did not
participate in these debates.
1348. On or about February 11, 2005, Henderson responded to the heated debate he instigated
on CenCom,
“AFRA's CEO, Leonard Henderson has caught HE- double toothpicks from just about
every actor involved in the [Consumer Advisory articles] fiasco over the past 3 years.
Every time we try to promote the SORELY NEEDED Family Advocacy training, this
[Consumer Advisory] comes back on the front burner. . .The world would be so much
happier place if people would just listen to me. Right now, I, Leonard Henderson am
CEO of AFRA because I am the only guy in the entire family advocacy business who
can hold this truckload of dynamite together. . . Suzanne, Please, please, please send
the [Consumer Advisory articles] to digital heaven. . .So can we toss all the pettyness
to the side and focus on the agenda and THE GOAL?”
1349. Henderson expounded on Cencom on February 12, 2005 injecting his own disinformation
and hyperbole to this debate under the subject, “My Vote,” as if he were entitled to exert
AFRA control over my business and publication, “Only a list of Trained and Certified
Advocates. The Family Advocacy Center's Alumni. We have to exude the behaviour of
Free Americans. Freedom and Liberty. Not the tyranny of lists branding others as
enemies.” His decree was supported by Swallow and other members, and the dispute
escalated.
1350. On or about February 12, 2005, W. Tower contributed to the escalating defamatory
debate about me on CenCom:

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“I am saddened to see this kind of thing here on cen-com. I personally don't know
Suzanne Shell, I have talked with her a couple of times and she sounds very
knowledgeable on the issues. I believe she has a lot to offer as do many others. And
from what I see she is doing something instead of just sitting in front of her computer
screen and typing notes to others. I believe we all have valuable information to pass
along to others. And we all have the right to: freedom of speech. (Or have some
forgotten) Everyone is different and gets things done differently. But the main thing is
getting things done.”
1351. On or about February 12, 2005, I responded to Henderson’s public demand on CenCom,
“American Family Advocacy Center's Director, Suzanne Shell is declaring once again
that this issue is not open for discussion. AFRA was offered the opportunity to take
control over this issue prior to the publication of the [Consumer Advisory]. AFRA
declined to exercise jurisdiction over complaints about harmful advocates. I respected
that decision and, since bad advocates are a direct reflection on my organization's
mission, I proceeded on my own course of action. I suggest that how one deals with
this list is a strong indicator of one's motives and solidarity within this movement.
People who use their disagreement with this list to foment discord among our ranks
have exposed how self-serving and divisive their motives are. I will remind the reader
that I have employed the same practices used by news reporting agencies in gathering
information and publishing. I am solely responsible for any defamatory remarks. That
should be sufficient proof of the truth of the reports. If it's not, tough. I am entitled to
the same privacy as anyone else and I do not owe this movement access to my files
and information upon anybody's demand.”
1352. In response to one of Henderson’s supporters who disputed my missive, I stated,
“The [Consumer Advisory] has remained solely on my website - I never bring it up on
any forum. Since I have never raised this topic on any public forum, I am NOT the one
causing divisiveness . . . since I have repeatedly ignored the topic when it was raised, I
am not the one causing divisiveness . . . since I control the [Consumer Advisory] and
have declared that the subject is not open for discussion, I am not the one causing
divisiveness . . . since AFRA has no authority over this list, I strongly urge Leonard to
say what should have been said long ago - - - "If you have a problem with the
[Consumer Advisory articles], bring your problem to Suzanne. Since AFRA has nothing
to do with [these articles], there is no place on AFRA forums for this discussion and
any discussion on this subject will not be tolerated." End of divisiveness on AFRA
forums.”
Henderson never took this advice. His intention was to use the few who objected to my
publication as the springboard for his disinformation campaign to force me to subordinate
my business and property to him and AFRA or else completely “discredit [me]”. . .his

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words. He allowed known disruptive elements who he had banned earlier to rejoin under
aliases and exacerbate the disruption using me as the subject.
1353. Henderson allowed the debate to degenerate into personal attacks against me, and I
responded that both I and AFRA had internal organizational issues that are not subject to
public debate. I stated that each organization has the right to conduct their business as
they see fit without outside interference,
“I see this list has once again degenerated into a 'bash Suzanne Shell' forum. .
.Leonard - I assure you, I don't like this kind of activity any more than you do,
however revealing these debates may be regarding one's competence, professionalism
and trustworthiness or the lack thereof.
I reiterate my previous suggestion. . . You have the authority to make it clear
that AFRA forums will not be used to discuss issues that are outside of AFRA's sphere
of influence. My 'list' is outside the sphere of AFRA's influence. . .therefore, discussion
on that topic should not be tolerated on AFRA forums. Alternatively - AFRA business
can continue to be diverted to arguing about something that AFRA cannot change or
influence. Truthfully, Leonard, nobody will change anybody's minds on this issue. I
don't try, and I suggest you don't either. . .Our limited resources are better focused on
the common goals which bind us together rather than endlessly debating the single
issue which, if it is given too strong a voice, has the potential to divide the movement.”
1354. On or about February 13, 2005, Jackson wrote to Directors and said, “While [Shell’s]
work and stand against Big Government are, in my opinion, beyond reproach, she is
very small emotionally.”
1355. On or about February 13, 2005, Jackson told the BOD on Directors that A. Dutkiewicz “.
. .is insane, Leonard, or at the lease, a Toxic Mouth, but her husband does some good
work, and they somehow work in tandem. Some people don’t cotton to him, either,
though.”
1356. On or about February 13, 2005, Swallow published an advertisement to over eighty
individual and group recipients, including AFRA groups, for an upcoming Florida
seminar where I was speaking.
1357. On or about February 14, 2005, Durand stated on CenCom, “I Do know Suzanne and

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Kay and they are Not liars.”

1358. On or about February 14, 2005, on Directors, Jackson wrote, “. . .I perceive her
advocacy work is unrivaled, she really puts it on the line.” She supported AFRA’s
posture on my articles, “The question is not so much whether Shell should drop the list.
. .but HOW to get her to DO it.”
1359. On or about February 14, 2005, Henderson published a message to all AFRA groups full
his disinformation and discrediting me based on my consumer advisory articles, stating
“I Leonard Henderson absolutely hate, abhor and despise the [consumer advisory]. As
far as I am concerned, most of the people listed there should NOT be listed there. . .I
find I DO have jurisdiction over the [consumer advisory articles.]”
He was not privy to the details of investigations or evidence, and proceeded to

authoritatively discredit the publication based on his uninformed opinion. When asked by
a group member if he had seen the evidence or documentation, he said he “believed
Cygan stole the families’ belongings” without admitting he had seen any of my research
or evidence supporting the article. He only believed it because another BOD, Henson,
told him she helped investigate it.
1360. I responded to the AFRA BOD privately, advising the BOD that ,
“. . .[Henderson’s disagreement with the [consumer advisory articles] is NOT the issue,
his facilitating others attacks against me and contributing his own attacks against me
because of his disagreement are the issue. . .The issue resurfaced again on AFRA
sponsored forums. In this case, I made multiple reasonable pleas for AFRA to deny a
forum for this divisive and fruitless argument. Leonard ignored them. I made a plea
for unity based on the issues we agree on and Leonard spit on it and publicly attacked
me with the message in red below.”
1361. I also responded to Henderson’s message on the CenCom, advising him he had
misrepresented the facts, and that his Monday morning quarter backing was without
authority or factual basis. I stated my objection to his public displays of disrespect,
“. . .Since Leonard's attacks have been predicated on my website contents, I strongly

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urge AFRA to establish a written policy regarding AFRA's scope of authority to

influence the contents of other non-AFRA websites and publish and enforce that policy.
. .I TOLD you Leonard was allowing this discussion to continue without intervening
because it served HIS personal agenda and he was happy to allow the malcontents to
foster divisiveness in an effort to put pressure on me where he and AFRA had no
authority over me - didn't I?”
1362. On or about February 14, 2005, a BOD member suggested on Directors, “. . .AFAC and
AFRA should operate as two completely separate advocacy organizations. No harm in
that and no reason to post anything about the organization.” Jackson responded, “Too
bad if that happens, but it might have to.” I had already left AFRA ten months before
and was operating separately, yet AFRA still refused to acknowledge that I was not
subject to their authority and control.
1363. Users on AFRA groups by now were being swayed by Henderson’s misinformation
campaign and were expressing their support for him on AFRA groups. His messages
were being forwarded far and wide to other groups.
1364. On or about February 14, 2005, Henderson posted on AFRA groups,
“The [Consumer Advisory] does not exist. I am done with it. I have cut the chain to
this crusty anchor that has been the single issue that blows up every attempt at
progress we try. I want to never hear about it again.”
1365. On or about February 15, 2005, I had a demand sent to AFRA BOD stating my
complaints, including but no limited to, “
“I don't care who disagrees with the list. I do care that my professional reputation has
been publicly maligned by AFRA with these comments which clearly call my character
and integrity into question. This isn't about hurt feelings. . . it's about my reputation.
Comments like: "she's going to shove it up my ass one way or another" - unjustified
because I never demanded AFRA approval or support. My position was that AFRA has
no authority to dictate what I publish on my website. Leonard didn't get it. He wanted
me to acquiesce to his demands. When I didn't, he deliberately made me appear to be
unreasonable, which is in direct contradiction to my standards of practice and harms
my reputation within this movement which I have worked very hard to build.
"She wanted me to address it., I DID address it." - I accepted AFRA decision
and NEVER RAISED THE ISSUE on any AFRA forum OR ON MY WEBSITE. I never

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demanded him to change his mind. My only demand was that he reciprocate. . .stop
using AFRA forums to pressure me into acquiesing to his demands by making
defamatory comments about me. He refused, and escalated it when I ignored his
demands about the list. Once again, he made me appear to be unreasonable simply
because I quietly stood my ground and didn't make an issue of it.
"I find that I DO have jurisdiction over the Bad Advocate List." I find that he
only has an opinion about the list. . .unless AFRA is going to publicly claim it has
jurisdiction over the content of every anti-CPS website out there. This is a bad move,
full of bluster and bravado but lacking substance. Please advise of AFRA's position on
assuming jurisdiction over non-AFRA website content so that I may publish it.”
I pointed out Henderson’s factual errors and misinformation on his public point-by-point
attack on those included in the consumer advisory including how they defrauded
consumers, committed theft, and harmed cases. I observed,
“Leonard and AFRA have clearly mistaken my reasonableness for weakness. This was
an error. Having been the subject of multiple unfair AFRA attacks, I will not cease
hostilities until amends are made. My reputation, character and integrity have been
publicly maligned by AFRA for the third time now. I have been extremely reasonable
and AFRA has abused that forbearance.”
1366. AFRA BOD Hession contacted me and suggested I over-reacted. I responded that I could
not trust AFRA, “[AFRA has] accomplished what the child savers were never able to.”
1367. In response to my demand, on or about February 16, 2005, Henderson announced a
massive cleanup of CenCom membership to eliminate, trolls, molls, and anonymous
screen names. He stated unknowns would not be permitted in this leadership group.
1368. On or about February 16, 2005, Henderson described me to the AFRA BOD as if he was
an authority on me,
“I think I know the inside of Shell's head better than most people. She views herself as
a great legend, the inventor of the concept of Family Rights, the copyright holder on
most of the words in the dictionary and ENTITLED to be the BOSS of the entire
movement. And her mode of operation is OLD FEMINISM and getting her way by
throwing huge bitch fits and tantrums Every tantrum is justifiable because it is always
made to be someone else's fault. The apology from her terrified victims is expected and
the proof that the problem was THEIR FAULT. We are talking about a big old spoiled
rotten brat.”

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After establishing this foundation, he proceeding to discuss why I must be brought into
line with AFRA and how he was saving me from myself.
1369. On or about February 16, 2005, AFRA BOD Martin advised AFRA to remove me from
AFRA groups, “
. . .we're endangering this organization and its members, especially those of us
on the Board of Directors who are going to have to defend ourselves and AFRA
in court if she files suit. This is why I recommend a quick apology and goodbye-
to-Suzanne for the sake of AFRA.”
In a subsequent response, Martin said “As long as she's not causing problems on them
or being the main topic of heated discussion65, I don't see any reason to delete her
from other lists.”
1370. On or about February 17, 2005, I advised AFRA BOD that the “cleanup” was not a
sufficient response to my demand.
1371. In response to my letter to the AFRA BOD regarding Henderson’s public discrediting of
me on AFRA forums and one BOD suggestion to apologize, Jackson responded, “Yeah
and blah blah blah by Shell. . .Shell’s big stink about her reputation is a farce. . .NO.
NO apology to Shell.. .REMOVE that putrefied [consumer advisory], and we’ll talk
detente.”
I subsequently remove the articles under AFRA’s pressure, but AFRA refused to stop
their tortious conduct. There was no detente.
1372. In response to a BOD comment on Directors that my web site was not accessible,
Henderson said, “. . .it’s probably a temper tantrum. Gonna quite everything to punish
us. That would fit the logic profile.”
1373. On or about February 17, 2005, Jackson posted to Directors, “I owe everything to
65
Here it is demonstrated that disruptions due to my being a topic of discussion on AFRA
groups was my fault, even if I did not participate.

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CPSWatch, maybe more than everything.”

1374. On or about February 17, 2005, Henderson reported on Directors, “CPS Watch has
survived well at archive.org and I have permission to put it back together and host it
at AFRA.”
1375. On or about February 17, 2005, Henderson wrote to Directors with a big headline, “DO
NOT FORWARD To Suzanne.” He submitted his mendacious fabricated , delusional
version of the history between me and AFRA, insisting he had never publicly disparaged
me, intended to make my ultimatum appear unreasonable in the face of his fairness to me.
He had planned to “. . .remove [my] name, your advocacy’s name, every vestige and
mention of your training seminars and any known or possibly imaginable “intellectual
property” even conceivably belonging to you from the AFRA national website and
instructions to AFRA members to do the same to their sites.”
1376. In response to yet another misinformation campaign about me by Henderson, I published
to CenCom my objection to that defamatory misrepresentation and advised Henderson
that I had held many of his personal and professional offenses confidential. I proceeded to
describe the personal liberties he attempted to take with me, and his offensive personal
intrusions to the exclusion of professional respect for my accomplishments. “I warned
you over and over to keep it professional, but you refused to ‘get it.’. . .You refused to
stop doing it when I repeatedly told you to stop. And like a self-righteous raving idiot,
you did it with witnesses on three way phone calls to a phone you KNEW was
recording.” I pointed out that my husband had heard Henderson’s offensive personal
comments to me when he called and observed that Henderson was acting like a spurned
suitor.
1377. On or about February 17, 2005, Henderson posted a gracious victory speech on CenCom
and Directors,

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“It appears that the debate with Suzanne Shell over the contentious Bad Advocate List
has become moot. Suzanne Shell removed her entire website from the internet last
night, including the Bad Advocate List. Which complete shutdown could appear as being
a tad overreactive.
“Suzanne Shell, the person, author, Family Rights Advocate Trainer, and
virtual grandmother of Family Rights Advocacy has long ago earned the right to be
treated with respect and civility. Those of us who have been Suzanne Shell's friends
for so many years take no joy in the pain caused to our old mentor by having to
confront her obstinance, especially in the public forum. Everybody- Please give the
entire subject a rest. Please, no questions or comments at this time. I think it is finally
over. Let it rest.”
1378. AFRA member Belou pointed out Henderson’s error, that my site was not taken down.
Henderson responded, “Hmm. Very interesting. It had been off the air since last night.
So I guess we will see what does or does not happen next.”
1379. On or about February 18, 2005, Henderson told Directors, “. . .being on yahoogroups has
historically been Suzanne’s downfall. . .She is her own worst PR when it comes to
playing nice on yahoogroups.” Henderson was responsible for the PR that I was
disruptive on the groups, even if I was only the topic and didn’t participate.
1380. On or about February 18, 2005, Jackson wrote to Directors, “shell, having now stated
that she no longer even wants an apology, is setting you up, Leonard. She has a
serious screw loose.”
1381. On or about February 18, 2005, Henderson announce on CenCom that all members of
CenCom would be unsubbed and members would have to rejoin. Lurkers were not going
to be permitted. Only known leaders would be allowed. Only thirty members were
unsubbed, I was among them. However, Henderson and other detractors were not
unsubbed and continued to use CenCom to wage their campaign against me.
1382. On or about February 18, 2005, Jackson told Directors that A. Dutkiewicz’s false
advertisement on NEPAN about my web site being a porn site were merely, “stupid and
uncalled-for” being in complete denial as to the harm that kind of accusation caused in a

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market devoted to protecting children.

1383. Jackson also stated, “[Shell] is a strategist of uncommon ability. . .”
1384. On or about February 19, 2005, Leonard presented his falsified history to AFRA groups
which he titled, “Wars, Rumors of Wars, Some Light History, and a Proposal” saying,
“Suzanne did quickly and joyfully generate such [consumer advisory articles]” I
deliberated seriously and treated the process as a solemn responsibility.
1385. Henderson then stated he pulled the article off of the AFRA and falsely advertised,
“Suzanne Shell started HOWLING about being betrayed by AFRA” I made no objection to
Henderson’s decision not to publish these articles. It was his right to publish or not. He
created the illusion that this was an issue as far as I was concerned, when I never made an
issue of it. My complaints about betrayal were predicated upon him creating a false public
persona of me so he could blame me for all the problems he created.
1386. Henderson when on to illustrate that his threats to harm my reputation for publishing
those articles had born fruit, “Against all odds, logic and in spite of the cost to her in
political capital, Suzanne Shell has maintained the [consumer advisory articles] on her
web site.”
1387. He misrepresented the source of disruption on AFRA groups, attributing it to me, “. . .
we noticed that anytime Suzanne Shell entered into a conversation on a yahoogroup, in
no time at all, another war was released.” He neglected to mention all the non-AFRA
groups that I participate on without problem.
1388. He admitted that AFRA groups were used by the defendants to sabotage my seminars, “.
. .EVRY TIME we schedule a seminar and try to promote it, Suzanne Shell’s enemies
come crawling out of the wood work expressing their extreme dislike of her.” AFRA
never scheduled or promoted my seminars. And the only reason the defendants came out
to oppose them was because AFRA and Henderson facilitated their efforts to discredit

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me.
1389. After providing his false history and character assassination of me, he proposed AFRA
form a Grand Jury to investigate complaints from consumers about advocates, and
attempted to discredit my articles by starting with an investigation I had closed.
1390. On or about February 20, 2005, on Directors, Henderson stated,
“. . I hope this causes Shell to finally abandon her [consumer advisory articles] because
she has been screaming about it from the beginning and in her twisted head, she
thinks she has taken the high moral ground.”
The only person screaming about it was Henderson. I refused to engage him on this issue.
1391. On or about February 20, 2005, Henderson revised history for the BOD on Directors, “. .
I didn’t like the smell of the [consumer advisory] from the beginning, and it has
certainly worked out to be infinitely more devisive and destructive than I ever
imagined.” Henderson exploited that publication and used it to create the very
divisiveness he postured against.
1392. On or about February 20, 2005, on Directors, Jackson took up Henderson’s gauntlet about
the AFRA Grand Jury (GJ) and discussed divesting me of my consumer advisory articles,
“If we might keep and refine The List, should all candidates for The List be GJ’d first?”
She went on to present alternatives for managing it, and agreed with starting with the
selected incident which I had investigated and closed involving co-conspirators.
1393. On or about March 1, 2005, R. Cygan published a web site entitled “Meet Suzanne
Shell,” at http://meet-suzanne-shell.tripod.com/index.html.
“Though I truely believe she will be frog hopping mad at the audasity of us mere little
people for exposing her for what she really is. Just who is she and what is she all
about??? Suzanne Shell has attacked far too many good, decent and honest advocates
for no reason other then in this authors opinion pure jelousy. I cannot imagin any
other reason for such hateful behaviour. While it is recognized that there was a time
where Mrs. Shell brought much to the table and did some good things it is this writers
opinion that she has lost track of the whole point of advocacy and turned her efforts
from helping people to in many cases harming people and causing some serious
damage to peoples lives. If you have been attacked and or harmed by this woman you

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need not be afraid any longer please contact us and we will gladly look into the
situation.” She stated, “I Renee Cygan pissed in this womans cheerios and I am not
ashamed nor sorry for it.”
1394. On or about March 1, 2005, on Directors, Henderson said,
“I understand very well Kay and Suzanne's position that as a professional association,
we need to police ourselves. And we need to warn the public about systers, bad actors,
and crooks who presume to operate in the realm we have defacto authority over.
Suzannes list was plainly done without benefit of any semblance of due process.”
Henderson’s expectations and advertisements to the contrary, this was not a court or
administrative hearing. It was a publication, and it conformed to accepted practices of
journalism. Henderson felt that standard was insufficient for articles published by me.
The BOD continued to conspire to divest me of this publication and replace with a more
formal hearing process, complete with discovery and prosecutors, run by AFRA.
1395. On or about March 5, 2005, on Directors, Henderson claimed taking me off of CenCom
solved a great deal of the “problem.” I was still on CenCom anonymously.
1396. On or about March 6, 2005, on Directors, Henderson accused me of “lifting” a phrase
from a pamphlet of his, complaining that he could not claim infringement because none
of AFRA content was copyrighted, he had put it all in public domain. He speculated that I
would allege infringement over six words. He observed that it was a good thing I had
installed copy protection code on my web site,
“. . .I congratulate SS for taking effective preemptive action to retain ownership of her
stuff. Woe be to the smart ass who does know how to grab this stuff. Or the box of
rocks that would spend an hour and a half typing it up by hand.”
1397. On March 6, 2005, Henderson published on AFRA at

www.familyrightsassociation.com/hotspots/archive/2005/march/bal/, that he, “. .
absolutely despise the [consumer advisory articles] and opposed [them] from the first
day. . .” He did not oppose it from the first day, he published it himself on the first day.
He now called it, “absurd, fatuous, ultimately divisive and serving no good purpose.”

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1398. Despite the fact that those listed could take corrective action (i.e. refunding money for
goods advertised but not delivered, returning stolen property, etc.) he called it “A list of
the eternally damned with no opportunity or possibility for redemption.” He stated he
preferred to be “in the salvation business.”
1399. He made the brazenly false claim, “At no time have I publicly disparaged Suzanne
Shell.” His publications were designed to undermine my own investigative journalism
practices without offering any verifiable facts in support of his sweeping claims.
Henderson had actual, contemporaneous knowledge of some the facts he now discredited.
1400. In response to this article, AFRA BOD demonstrated the effectiveness of Henderson’s
persuasion by agreeing with his article, “It appears she’s not a team player unless she
can be in charge.” Another said, “Some people have to always be in the swirl of
controversy. If there isn’t one, they’ll cause one. . .” Henderson had expertly directed
the readers attention away from the fact that I was not on the AFRA team, and owed no
allegiance to AFRA. He had convinced the public that I had no right to enforce my rights
to my own business and property or exclude AFRA from exerting any control over my
business or my property.
1401. In response to this article, which was broadcast to all AFRA groups, I contacted
Henderson privately and said,
“Leonard, why do you persist in the mistaken belief that YOU have any authority or
input over what I publish or don’t publish on my web site. . .I have NEVER told you
what to publish on your web site. Please be decent enough to return the courtesy. .
Publicly.”
I asked him, again, to leave me alone and mind his own business. He took this private
message to AFRA Directors with the comment,
“*SIGH* I feel like an adult children who aging parent (whom I respected very much)
has developed dementia.” In a subsequent message, he wrote, “I remember when
Ronald Regan got really bad, they just disappeared im from the public eye so his legacy

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could remain unbesmirched by his meltdown years.”
This is a classic example of a batterer’s technique of making the victim appear to be

mentally ill who deserved the abuse.
1402. On or about March 6, 2005, on Directors, Jackson stated, “Perhaps we collectively
provoked Shell . . .that may be the best we can do and might actually be a good thing.
. .Ask what kind of person would want to crash and burn such an organisation [AFRA]
just to preserve his/her right to publish vitriol uncontested.” She later affirmed
Henderson’s posture, “Hats off, Leonoard. I like how you handled this affair.”
1403. On March 8, 2005, Henderson sent an unsolicited email to me requesting if he could keep
my copyrighted content on the AFRA web site, assuring me it was profusely credited to
me. Since he had demonstrated neither the desire or capacity to insure his group members
did not infringe my work or take credit for it, and since I knew he only wanted to use my
property and my name to enhance AFRA’s stature but would continue to malign me, I
denied his request.
1404. On or about March 9, 2005, Jackson responded to Henderson on Directors, “. . .it’s
easier for those of use who never had a relationship at all with her, to watch her
disintegration. . .Her seeming ‘nuttiness’ is a lot more complex than at first glance. I
do think that Shell is privately afflicted somehow. . .I just don’t like a LOT of what she
wants. . .”
1405. On or about March 13, 2005, Ms. Korn published on CenCom that the Florida seminar
was a huge success. A press release was also published on AFRA and non-AFRA groups
about the success of that seminar.
1406. On or about March 18, 2005, BOD Martin, on Directors, demonstrated her belief of
Henderson’s rendition,
“I’m just sick of hearing people talk about Suzanne as if she were some kind of saint. .
.I cannot wait until the day I never hear her name again. Maybe that’s one more

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reason I should retreat into my own world of FightCPS[dot]com where I have over 500
people signed onto my message board . . .”
Defendant Jackson responded with, “. . .Linda, you have my sympathies.”

1407. On March 22, 2005 Henderson contacted me and copied Directors wanting a truce. He
offered that AFRA would abandon advocacy in deference to me and recharacterize it as
supporter or promoter. He also offered to include some kind of blurb about Cygan. He
claimed he and never stopped being my friend and wanted to promote my training
seminars if I would “call off the war.”
1408. I advised him that his overture was “superficial and insulting placating based on his
false assumptions,” and his cheap offer was a worthless bone. I told him I had no desire
to take over or control AFRA, that I’d left AFRA alone because I didn’t need AFRA. I
stated I still required his false publications about me be corrected. He published my
response on Directors stating,
“There was a time limit on the option of redemption by licking her boots and
apologizing for imagined evils, the greatest of which seems to be being a man. . .My
last threads of friendship and obliged loyalty to her are pretty frayed after 4 years of
putting out the fires she starts and cleaning up the mess she creates, plus taking this
overt hostility and abuse from her. She has always been incautious about picking her
battles and seemed like she would just as soon be SS vs. World.”
1409. On or about March 23, 2005, Jackson responded to Henderson comments on Truce?
“AFRA, by SS's definition, will ALWAYS be spreading disinformation, because the
overwhelming majority of AFRAdites are not SS-trained, SS being the only
certification-show in town. Those of us who are not certified are subhuman in her
view. . .” This misrepresentation was instigated by Henderson. My training and
certification was a marketing tactic intended to entice participation based on quality and
oversight, not a means to discredit anyone who didn’t take it. It was logical that attorneys,
courts and agencies would prefer a known element with a proven track record over

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amateurs. There are many organizations out there who offer advocacy, not just AFRA and
CPS Watch.
1410. On or about April 16, 2005, in response to AFRA BOD Henson’s explanation on
Directors,
“Suzanne's training program is copyrighted and confidentiality/non-disclosure
agreements have been signed. We can't provide the service she does. We can provide
some different things, but nothing that will compare to what she's doing with the
Institute,”
Kiefer challenged, “Why Is This? Is She Not In This For The Cause Or Is She In This
For Herself?”
1411. On or about April 13, 2005, Henderson reported to AFRA BOD on Directors, “Wow.
Suzanne is being a real snot.” Arizona AFRA member had contacted him mistakenly
saying that in order to attend my training, she had to quit AFRA. This was never a
condition of AFRA members attending, however, AFRA members had to pay higher fees
to cover the added trouble their participation incurred to my organization. AFRA
members incurred much more one-on-one supervision and oversight, extensive damage
control efforts, and additional protective procedures to insure my proprietary methods
were not disseminated to AFRA. This was due to the fact that AFRA accepted anyone
into membership no matter what they did, including mentally unstable, con artists,
theives, cheats and–as one judge put it–whackadoodles.
1412. Henderson advised the AFRA member to quit, take my training, then join up with AFRA
again–effectively committing fraud to obtain my training. He indicated his intent to
inappropriately interfere with my business and credentialing, “Now if Suzanne is going
to threaten your credentials if you rejoin, we may have to be forced to do something
about that sort of dictatorial tyranny.”
1413. BODs Martin and Kiefer responded,

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“Leonard, you're coming across as a doormat to my way of thinking, letting this totally
spoiled rotten god-wannabe walk all over you. You are so nice, but there's gotta be
limits and I don't put up with this much nonsense, not for anything, not even to be a
‘trained advocate’ which to me always sounds like ‘trained monkey’. . .My opinion on
the matter (not that anyone cares) is to split from any association with her. I think
her ‘trained advocates’ should pack up and move out of AFRA permanently.”
Again, AFRA had denied the fact that I had disassociated with AFRA over a year earlier,
yet AFRA and the defendants refused to let me go and run my business without their
incessant attempts to control me and my business.
1414. BOD attorney Hession advised the BOD that “[she can] price her seminar any way she
wants. . .” He later observed, “She is likely worth the higher price, frankly.”
1415. On or about April 14, 2005, Henderson again published his version of the history on
AFRA groups, spinning the historical account so that I appeared to be a “feminist”
“pre-menopausal, psychotic female” whose “petty tyranny is intolerable” to AFRA.
1416. Henderson falsely reported I demanded AFRA members quit AFRA to obtain my
training. He invokes disgusting imagery coupled with threats ,
“Suzanne just keeps throwing the tampons on the floor like a spoiled rotten brat
instead of in the garbage can. So maybe it is time for me to quit playing nice? It is
obvious that I have the stuff to cut her to shreds. I may very well be the only person
on earth who has the ability to destroy her, and I am nearly in the mood to do so.”
In his typical fashion he portrays my refusal to associate with AFRA and my legitimate
business decisions to protect my property as a personal vendetta irrationally fueled by
female hormones. His intent to destroy my business and my professional reputation, being
clearly stated, was enthusiastically implemented with the cooperation and participation of
the other defendants.
1417. AFRA BOD discussion then turned to how to develop and supplant my training with
AFRA’s training. There ensued a lengthy debate between the AFRA BOD over what
property of mine they could or couldn’t use to create their own training. Henson kept

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insisting my property was protected. The other BOD members argued against it, trying to
find loopholes to use my property, suggesting if someone created a seminar based on my
book, it would not be infringing, etc.
1418. On or about April 15, 2005, on Directors, Tower stated about my methods, “this is not
anything that is protected by SS or anyone else.”
1419. On or about April 15, 2005, Jackson responded on Directors, “I’d like to see AFRA get
some credit and credibility, in addition to SS and you. . .”
1420. Jackson responded to AFRA BOD Henson’s comments about my non-disclosure terms,
“. . .no matter what we do, SS will litigate over her intellectual property. Nice. . . I
serve AFRA, and I will remain positive. I think we can indeed develop a training
methods – if SS feels she has to undermine our efforts in order to glorify hers, so be
it.”
1421. On or about April 20, 2005, on Directors, Henderson again raised the issue of Suzanne
Shell,
“All I can remember happening over the past several months is Suzanne Shell's
arrogant pontificating. Suzanne Shell has been taking our energy and focus. My best
guess is she thinks AFRA was invading her turf. We did NOT invade her turf- we were
PROMOTING her turf.”
Henderson perpetuates the mischaracterization that he was promoting me, when he was
maligning me. He continues his typical “promotion” of me by adding,
“So what did we learn? Suzanne Shell is an irrational BITCH. Was this any epiphany?
Certainly not to those of us who have tried to be Suzanne's friend over the years. It
was rather surprising to me the level of insane shit she was willing to sink to- to drive
me out of her fold. She plainly told me a long time ago she didn't want my help. So be
it.”
1422. On or about April 20, 2005, Tower responded to the AFRA BOD debate about my IP
making wholly irrelevant and specious arguments,
“1. using the theory you have just given, lets take for instance every lawyer and
attorney in the country, and lets say they copyright their tactics, after a short time
there would be nothing left to use for (tactics) a defense in court. so how could legal

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tactics be copyrighted???? (this would be a ridiculous claim)2.And once a book is

published, the information is public. If it was to be kept a secret then she should not
have 3. published it in a book. 4. and made it available to the public to buy. We buy
books to learn from and use the information that it has given us or that we have
learned from it.”
1423. On or about April 20, 2005, Jackson responded to the debate about whether my IP was
protected with, indicating she had some knowledge of the exclusive right of IP property
owners,
“Certain teaching methodologies for, say, teaching reading and reading comprehension
to the learning disabled, are, I believe, copyrighted. Certainly the training and testing
materials are copyrighted, and the teachers often must be certified by the methodology
owner in order to claim to teach the proprietary method. I imagine that if a renegade
wishes to produce a "knock-off" of the method and its materials, that person might be
stepping on intellectual property. But how, agreeing with you, Gregory, would SS's or
FRAI's "method" be copyrighted? She is not using any original science or statistics.
While fighting CPS is indeed a revolutionary notion, FRAI is espousing how to use
legal/tactical mechanisms which are already in place and used widely in other arenae,
not at all new or proprietary. . .This concerns most of us here, if I might be so bold as
to make assumptions for our abstaining members. The SS/FRAI claim that materials
will be abused unless SS/FRAI keeps a tight reign, while initially sensible, is, on deeper
consideration, a thinly disguised bid for domination and exclusivity.”
AFRA could not permit me to dominate the market by virtue of my exclusive licensing
and use of my IP.
1424. Jackson later wrote about AFRA not being able to help members without my property,
“We should simply FREEZE OUT these families, and DRIVE THEM to SS/FRAI training,
offer them NO ALTERNATIVE?”
1425. On April 21, 2005, Henderson sent an unsolicited email to me expressing his opposition
to my fee structure for AFRA members who wanted to attend my seminars. He then
proceeded to advise AFRA members on AFRA groups and Directors who wanted to
attend my training how to defraud me so as to circumvent the fee structure. His advice
was: Leave AFRA membership, attend the seminar as a non-member to pay the reduced
fee, take the seminar, rejoin AFRA and use the information for AFRA’s benefit.

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1426. On or about April 21, 2005, on Directors, Henderson again raised the issues of an AFRA
Grand Jury to handle a consumer complaint that he had received.
1427. On or about April 22, 2005, Henderson reported to the BOD on Directors that he had
been advised by Arizona AFRA member that she had misunderstood that she had to leave
AFRA to attend my seminar in Colorado. Robin, the AFRA attendee, had extended the
courtesy of bringing her confusion directly to me, and I explained the matter correctly.
She stated she had believed everything Henderson had said about me being unreasonable,
abusive and a bitch. After talking to me, she realized she had been misled and went to
Henderson to set him straight. She apologized to Leonard for the misunderstanding and
attempted to correct the mistake.
1428. Henderson responded on Directors, “This business of leaving Robin holding the bag for
‘misunderstanding’ really rubs me the wrong way. She misunderstood nothing.”
1429. Henderson also advised the BOD with a forked tongue,
“I have purposefully left the thing alone because I want Suzanne's training to succeed
and not have a big stupid war at exactly the time her efforts are finally paying off for
her. It is just old loyalty on my part. Suzanne needs to pick her fights more carefully
because AFRA is not her enemy. And neither am I. But I will say this about that: My
patience is wearing really thin with her brat antics.”
1430. In response to Henderson’s broadcast to AFRA groups about AFRA membership

attending my presentations, I contacted him privately to challenge his highly public slam
against me about my seminar fee structure and calling it “whacky circular logic.”
1431. He publicly blamed me for the “war” he had spent years inciting, while simultaneously
professing undying loyalty to me and decreeing he wasn’t my enemy.
1432. I reminded him he had allowed AFRA to be nothing more than “bash Suzanne” forums
for over a year, and that despite my repeated pleas, AFRA would not leave me or my
business alone. He copied my response to Directors, saying,
“*SIGH* The only word that comes to mind is-im-plac-a-ble. . .Be it hereby known that

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from this moment forward-ALL ties and relationship between AFRA and Suzanne Shell
are hereby severed. Discussion of Suzanne Shell and anything she does is expressly
forbidden on ANY of AFRA's forums. Suzanne Shell's ["Consumer Advisory"] has no
credibility and no authority and can be considered not to exist. Discussion of said
['Consumer Advisory"] is hereby expressly forbidden on ANY of AFRA's forums.
Anybody can feel free to attend Suzanne Shell's Advocacy Training Seminars, but we
can no longer promote those seminars for the simple reason that every time we do,
Suzanne's enemies crawl out of the woodwork to rehash the same old, SAME OLD noise
over and over again. Which "support" Suzanne does NOT appreciate, nor do I. Be it
hereby known, by official proclamation- ANYBODY who feels the urge to denigrate
Suzanne Shell or the otherwise good work she does on ANY of AFRA's forums or even
**BACK CHANNEL**, when I hear about it, your membership in AFRA will be
summarily revoked. AFRA's forums are NOT for bashing other advocates!”
Henderson was advised by the BOD not to post this on AFRA group. He did not enforce
this edict.
1433. On or about April 22, 2005, on Directors, Jackson said, “Trying to actually assist
SS/FRAI in protecting its materials is compromising AFRA's potential effectiveness.
Let's leave it up to legal minds to determine if FRAI materials may or may not be
used.”
1434. On or about April 28, 2005, Henderson told AFRA BOD on Directors,
“I do like my point that it isn't my job to make people like her. Her sociopathic
presentation by email reminds me of Road Rage. You know- an otherwise gentle,
caring, intelligent, polite person who turns into a raging monster behind the steering
wheel. That's the problem, and it's not my fault. She sure reminds me of my ex-wife.
No matter what happened, she had to twist it around to make it somebody else's fault.
I swear, it's like Suzanne and my ex have been exchanging Bitch Tips in the advanced
art of blaming Leonard.”
1435. On or about May 3, 2005, AFRA had the BOD address an issue involving abuse on the
underground railroad, “Famtrak” that was run by Henderson and four other AFRA BOD
members. This issue involved an AFRA member family who was conducted by Nancy
Luckhurst, an AFRA member, to a third AFRA member’s home in another state.
Henderson decided to conduct an AFRA Grand Jury to resolve this issue.
1436. On or about June 8, 2005, on Directors, Henderson told the BOD,

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“Notwithstanding all these other things, THIS Hunter vs. Luckhurst sandbox war got
nipped in the bud and handled properly by THE ASSOCIATION. It seems to be the
general consensus that this sort of thing IS what a professional association is supposed
to do. We have the power and we need not to be terribly timid about using it. If we had
been able to do this 2 years ago, Suzanne Shell's insane and damnable [Consumer
Advisory] wouldn't exist.”
While I didn’t agree with AFRA’s methods and the outcome was highly suspect, I offered
no comment on their handling of this complaint. What AFRA did with AFRA members
was AFRA’s business.
1437. On or about August 12, 2005, Swallow published on four groups including CenCom,
“AND DON’T FORGET I HAVE KAYS CORRECT ADDRESS AS WELL AS SUZANNES DON’T
MESS WITH FIRE YOU MAY GET BURNED.”
1438. On or about August 20, 2005, Henderson issued a decree on CenCom,
“I wish to see absolutely nothing said or discussed on any of the AFRA groups about
Suzanne Shell or the latest Brenda Swallow thing.I am BEYOND DONE with the
constant whirlwind of trouble that the mere mention of Suzanne Shell has caused over
the years. I absolutely want NONE of the latest soap opera to detract from AFRA's
agenda.We are not going to participate in any slime war in any way, shape, or form.
This cat fight can play out in a dark corner somewhere without an audience. We are
NOT going to have anything to do with it. I am as serious as a heart attack. NO
Suzanne Shell and Brenda Swallow noise allowed here.”
He issued this edict only after allowing Swallow’s incessant defamatory advertisements
about me and my business to be freely disseminated on AFRA groups for nearly a year.
They served his purpose to undermined my business and my products while making him
to appear at a safe distance. This demonstrates he had the authority and ability to
moderate content and participants, he just never chose to exercise that authority.
1439. On or about August 21, 2005, Swallow’s partner, Paula McIntosh called Ms. Henson and
left a profane anti-semitic message and threatened various iterations of violence,
including to take her unborn baby out of her if it wasn’t born by the time she showed up
to beat her up. Swallow was in the background inciting McIntosh.

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1440. On or about September 1, 2005, on Directors discussing a CenCom published “advocate

warning,” Jackson wrote,
“Since I see Shell's ID in the distribution, it is apparent that this is one of Shell's Killer
Bee Pack of Informants, who consider informing Shell to be of foremost importance,
superceding all other allegiances. People are welcomed to their opinions, but if
allegiance becomes an issue, then decisions have to be made.. . .The [consumer
adcvisory] is just a chip of the iceberg. I am leary of the ‘just let it go’ mantra. . . .The
less we see Shell's name the better -- including in AFRA's self-affirmation notice.”
1441. On or about September 5, 2005, Swallow stated on
Justice4ChildrenParentsAndFamilies_NW_FL group discussing me, “You on the other
hand seem to be manipulated by others, even playing right into the hands of the devil
based on not your own knowledge but what you have heard from the devils mouth.”
1442. On or about September 5, 2005, Swallow stated on
Justice4ChildrenParentsAndFamilies_NW_FL group, “HEY WHENS THE NEXT
SEMINAR?????LOL I BET ATTENDANCE WILL SURELY BE ON A LOW...”
1443. At the same time, Swallow claimed, “Even though the institute voided their own
contract when they became a party to a crime andattempted to have their advocates be
a party to a crime..a felony at that..”
1444. On or about September 9, 2005, Swallow published to over forty groups and individuals
under the subject , “Florida’s Bad Advocates,” and advertised her collusion with
Wiseman on thetruthhistold[dot]com , “Just to let you know I am in the Process of
creating a "Bad Advocates" List myself.”
1445. On or about September 19, 2005, Henderson told the BOD on Directors a bizarre story,
“I think am in the most trouble because I am one of Suzanne's oldest and most loyal
supporters. A couple years ago, I merely wondered about her extremely belligerent and
self-destructive behavior being something like Alzheimer's. And the fat has been in the
fire ever since. . .Last time we were having a ‘spirited debate’ in the public forum, she
offered to fabricate a sexual harassment allegation against me and played the militant
feminist card.”
1446. On or about November 12, 2005, Henderson stated in an email to me,

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“I never claimed to have anything to do with Famtrak beyond putting T.M. into it. I
have tried to portray it as totally defunct in order to deflect ‘official’ interest from it. .
.[Detlefsen] claimed that I was the founder of the underground railroad. . .Even if that
were true, I most certainly would NOT want that to be public information. Would I?”
I recognized this as his attempt to rewrite the history of an issue that he was using to
malign me.
1447. On or about November14, 2005, I sent a cease and desist copyright infringement letter to
Jackson. She responded with taunts me and refused to stop infringing.
1448. On or about November 19, 2005, T. Dutkiewicz, Connecticut DCF Watch and A.
Dutkiewicz hosted a two hour conference at Foxwoods Casino in Mashantuket,
Connecticut. Speakers were W. Tower , Executive Director of the American Family
Rights Association, Richard Wexler, Anne E. Tower, Executive Assistant Director and
Thomas Dutkiewicz. I am compelled to observe that neither I nor my associates
performed any obstructive or stalking acts in response to the announcements or the event.
1449. On or about December 2, 2005, A. Dutkiewicz published on dcfreformfl group, “Believe
me I have never hated two people like I hate Effie and Suzanne. . .”
1450. On or about December 2, 2005, I sent Swallow a private letter about her
misrepresentations being posted on the interactive online groups,
“Family Rights Advocacy Institute has been advised that you are representing yourself
to be a 'Certified Family Rights Advocate.' I remind you that your certification was
revoked on August 14, 2005. At this time I requested you return all Institute
information, materials and documents in your possession. You have failed and refused
to honor that demand. I am demanding the return of all Institute materials
immediately. I am also demanding you cease and desist representing yourself as a
'Certified Family Rights Advocate' and publish a retraction in all forums where you
have made that false representation. If you fail and refuse, I will be forced to seek
legal remedies.”
Swallow responded to this private demand by publishing to over hone hundred online
groups and individuals,
“Are you so blind to think you are the only group/Institute offering training. I am a

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certified Advocate but no longer affiliated with FRAI or yourself in any way. I refuse
to be connected to your criminal act of Practicing Law without a License as well as
setting up families for failure while defending unethical Attorneys who are under
Florida Disciplinary Action. . I have no Institute Material it went out with the rest of
the trash. Additionally I will not cease called myself a Certified Family Rights Advocate
as stated before you are NOT the only one to provide such a service..You are just the
worst to provide such a Certification. Current Leadership would Never defend the
actions of an attorney over the safety ofa family/children. . . So seek legal remedies
and I will provide evidence to disprove your False Allegations and then have more dirt
on Ms SS...Oh boy you need to get over yourself...we all intend to take you the
so-called Institute as well as Kay to the cleaners.. meaning Class Action suit..Ring a
Bell? P, W , B, T the list goes on LOL Oh and you claim to have reason to take legal
action against me..Lets see who has more Power . . bet its me..”
1451. On or about December 3, 2005, Swallow published,

“The "secret" is this...Suzanne Shell and Clan are out to Sabatoge the Movement and
Any and All. . .groups not participating or connected to FRAI....I. . .Support all those
wrongly listed on Shell's [Consumer Advisory] List many of whom contacted me with
the TRUTH about their negative exp. with Shell. Brenda (Certified Family Rights
Advocate Michigan/Florida).”
1452. In December, 2005, Henderson phoned me to apologize. He stated he had just recovered
from a near-death experience and he harbored the delusion that we had made up. He
claimed his death bed thoughts were of me and he felt so guilty he couldn’t shake it. It
took some convincing that we had not resolved our disputes. He attempted an insincere
apology, he didn’t know what for, so I left it at that.
1453. On or about January 19, 2006, A. Dutkiewicz revealed she has spoken with Rocco
Meconi, Fremont County, Colorado, County Attorney representing DHS. Her discussion
with him was about me, and she was seeking information and alliances against me.
1454. On February 10, 2006, A. Dutkiewicz, on CP_Prosecutions interactive online Yahoo!
group, A. Dutkiewicz revealed she has spoken with Rocco Meconi several times about
me, and how much he and Hon. Judge Julie Marshal hate me.
1455. In March of 2006, AFRA was headquartered in Massachusetts, under the presidency of
Gregory Hession. I negotiated an agreement whereby AFRA would implement and

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enforce a policy regarding intellectual property rights and would stop the false and
malicious advertising about me on the AFRA online interactive groups. I offered to
remove the consumer advisory articles and make all attendance fees the same for all
attendees at my seminars.
1456. Defendants Kiefer, Tower, Hinger, A. Dutkiewicz, T. Dutkiewicz objected to any
agreement between AFRA and myself, insisting the only acceptable solution was for me
to “be gone” from the market, but they would still use my property. Mr. Hession resigned
as president of AFRA in the face of this rabid response.
1457. On or about March 10, 2006, Kiefer lifted distinctive introductory sentences from my
web site, which is centered in Colorado, and used it to promote his online radio program.
“You have just been accused of abusing or neglecting your child. You have no idea where
this accusation came from. Your first impulse is to cooperate with the social worker.
After all, you have nothing to hide. And so. . .the nightmare begins. . .” People know that
this unique and punchy content is on my website, and when he uses it for his purposes, he
is implying association with me in order to boost his credibility and reputation unjustly.
Any reasonable person would be mislead by his presentation and think we were
associated. I advised AFRA President of this and the appearance that AFRA was
endorsing this plagiarism because Kiefer was on the AFRA BOD and advertised on
AFRA forums using my content.
1458. I immediately sent Kiefer a cease and desist letter demanding he publish a retraction for
plagiarizing my content.
1459. He forwarded that letter to a “christian common-law legal-counsel for Brother Cletus,”
Charles Steward. Stewart admitted on behalf of Keifer that “Brother Cletus does forward
out much material which honestly looks to him to be a part of the public domain.” Mr.
Hession responded to Stewart as an attorney and advised him that his assessment of my

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content being in the public domain was in error. Kiefer never retracted his advertisement.
1460. On or about March 13, 2006, after an investigation into a complaint about a disputed
domain name, I contacted Kiefer with the complaint and provided the facts. I suggested it
was a clerical error on the part of the domain registrars which caused two people to have
purchased the same domain name. I suggested that since the other party had the prior
claim (by virtue of a purchase receipt dated more two weeks before Kiefer’s purchase)
and owned all the other variations on the name, they would be wiling to assist Keifer with
getting a refund for his purchase price and he could relinquish it to the other party. Kiefer
did not respond to this or other complaints.
1461. Instead Kiefer forwarded my correspondences to Wiseman, who injected himself into this
issue. In retaliation, Wiseman, with Kiefer’s participation and information, instituted a
web site at thetruthistold[dot]com dedicated to maligning me.
1462. Wiseman was became the mechanism used by the defendants to perform their tortious
acts, intending that he could appear to be responsible, but that his disability would hold
him harmless, while they maintained a safe distance from liability for the acts he
committed on their behalf.
1463. Wiseman’s web site was instigated by AFRA directors, particularly Kiefer, but other
directors contributed to it and influence Wiseman. It’s sole purpose was false advertising
about me and the publication of stolen content from me. It expressly supported AFRA
and the defendants’s campaign to eliminate me from competition, misappropriate and
disseminate my trade secrets and infringe my IP.
1464. Even though Wiseman was member of AFRA, AFRA interactive online groups and
leadership, AFRA and AFRA BOD never publicly disavowed nor tried to control the
content on Wiseman’s thetruthistold[dot]com web site and never revoked Wiseman’s
AFRA membership nor his membership in AFRA groups. Henderson claimed he thought

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Wiseman’s site was disgusting and foul, but never attempted to control it, or to use bad
publicity to force him to remove his content like he had spent years forcing, coercing,
harassing, and threatening me to do. Wiseman’s web site served Henderson’ purpose to
destroy my business and my property while he and AFRA could appear to be at arm’s
length from it.
1465. In retaliation and at the urging of the defendants, Wiseman took the contents of my entire
web site and circumvented the copy protections to publish it on thetruthistold[dot]com.
1466. On or about March 12, 2006, Wiseman was allowed to join CenCom leaders list.
1467. On or before March 15, 2006, Kiefer solicited seminar attendees requesting they provide
him with the information they received at my seminar so he could put it on CD and
market it.
1468. On or about March 16, 2006, Tower conducted a dialog on CenCom regarding a
Colorado-based seminar of mine to be hosted by Colorado AFRA member Christine
Korn, and Ms. Korn responded to his requests for information. The seminar was
advertised on AFRA groups by the Colorado AFRA affiliate organization. Tower
questioned my credentials and the certification process for applicants who wanted to be
family advocates. His comments were intended to distract from the event and discredit it
and me.
1469. On March 17, 2006, Tower sent me and several AFRA Yahoo! groups an unsolicited
email overreacting and objecting to my publishing that he supported defendants Thomas
and Aimee Dutkiewicz. I had previously asked him if he supported them and he stated he
did. He did not deny supporting the Dutkiewicz’s, but he demanded I remove that
statement and warned me I should be careful, “it might come back to bite [me].”
1470. In this message, he included the verbatim text from my web site, in violation of my
published copyright terms. I contacted him privately to ask if anything I published was in

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error. His reply was non-responsive, focusing only on his outrage that I “made him
choose sides.” He never denied he supported the Dutkiewiczs, which was all I reported.
1471. On or about March 17, 2006, Wiseman published on CenCom that I was a “troll.” When
corrected that I wasn’t a troll, he said, “I couldnt find the right name for her from the
wizzard of OZ.”
1472. On or about March 19, 2006 Wiseman published on CenCom,
“Im Not Making a pact with the delvil and i have nothing Further to say on the subject
other then if MRs.Shell Cant make a witten apology to the people she hurt..she can go
jump in a lake because i dont dance with the devil...Billy boy”
1473. On March 18, 2006, Tower advised Mr. Hession on AFRA_CenCom that he was opposed
to any agreement Mr. Hession made with me as long as I refused to apologize for my
publications. There was no mention of AFRA meeting my prior demands for apologies or
retractions by W. Tower, nor in our agreement. The defendants refused to apologize to
me for their tortious conduct but demanded I publicly apologize to them for publishing
the irrefutable truth. W. Tower was not a party to this contract, and had no business
interfering with Mr. Hession’s agreement with me or influencing AFRA membership
against this contract.
1474. On or about March 18, 2006, on Directors, Tower justified his outburst toward me and
his attempt to sabotage my negotiations with AFRA President Hession,
“I sent a copy to both ss & tom as both are involved. I was staying in the middle untill
ss decided for me. I then took my own side. based on her actions of adding me to her
shit list. Lets put the blame where it belongs, and that is with SS. I have not and will
not, even when SS demands of me, play her kid games. say what you want but put the
blame where it belongs and that is with none other than SS.......and her ["Consumer
Advisory"] Page. I want an apologe for the harm done to my name by your beloved SS.
and I want it posted on her web page for all to read. She picked this fight, not me.”
His posturing was seriously over-reactive to the pretended offense. It wasn’t about not
having taken a side. He was disingenuous, this was just another Henderson devotee acting

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on prior indoctrination by Henderson against me.

1475. On or about March 19, 2006, Tower advertised on CenCom that I “drew first blood,” and
accused me of “sneaking behind ones back and post[ing] things that involve them.” My
web site is public, that is undisputed. Nothing anyone says to me is off the record. I have
no duty to advise anyone prior to publishing anything. He was unreasonable. I spoke with
Tower in person, face-to-face, before publishing anything. He knew about my articles.
There was no “sneaking.” I was open and above board when I spoke with him. He even
said what he meant. I just reported it.
1476. On or about March 19, 2006, Baez agreed on Cencom with the fact that I must extend
apologies to W. Tower and Wiseman as a crucial step to ending “this whole wheelbarrow
full of crap.” She also stated,
“This whole mess has caused a great deal of hard feelings. I freely admit to having
hard feelings, pretty close to the point of bursting a blood vessel - I've been THAT
angry. On a personal level, I'll admit to disliking some of those on the other side of
this.”
1477. On or about March 19, 2006, Baez responded on CenCom to AFRA President Hession’s
report about a resolution to the issues between me and AFRA by saying, “I do hope that
the outcome of your meeting will be a solution that we all can live with.” Within hours,
Hession resigned as president of AFRA, recognizing he would not be able to satisfy the
membership.
1478. On or about March 22, 2006, Baez admitted on Cencom that my report in the Consumer
Advisory articles about her supporting R. Cygan were accurate.
1479. On or about March 23, 2005, on CenCom, Baez asked Wiseman to call her tonight once
his cell minutes are free, she needed to talk to him.
1480. On or about March 24, 2006, M. Cygan publicly expressed his support and
encouragement for Wiseman on CenCom even though Wiseman had butted in to a

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situation where his assistance was not requested or warranted. It was clear Wiseman was
incapable of understanding what was going on.
1481. On or about March 24, 2006, Henderson, again at the helm of AFRA, stated his position
regarding me,
“Let me re-state where and how I stand with Suzanne Shell. As far as I am concerned,
she is one of the, if not possibly THE grandmother of Family Rights Advocacy, and she
deserves respect and honor for that. In spite of the fact that she somehow chose to
become my great enemy, I have NEVER ceased recommending her book and seminars.”
1482. On or about March 24, 2006, an AFRA CenCom member advertised that Kiefer had
described Wiseman as “the backbone and brains that makes things go.” He had been
“spoken of highly and obviously a lot of people on [CenCom] love Wiseman.”
1483. On or about March 24, 2006, on CenCom, Wiseman said, “. . .its nothing like when i got
mad at MRS.X as im still mad at her. . .”
1484. On or about March 26, 2006, a press release about my upcoming appearance on Citizens
For Change (CFC) radio program was disseminated by CFC to AFRA and non-AFRA
groups. This proved to be cause for AFRA’s army of detractors to emerge and begin
slinging defamatory messages about me, unhindered, on AFRA groups, encouraging
consumers to eschew me, CFC and the radio program.
1485. On or about March 29, 2006, A. Dutkiewicz filed a criminal harassment complaint
against me in Connecticut for a single cease and desist email I had sent her. I was
contacted by Bristol police as part of the investigation into the complaint. No charges
were filed.
1486. On or about March 29, 2006, Tower transmitted information to Hinger using
AFRA_CenCom, relaying information about me for unknown purposes, requesting to be
advised as to the result of his use of that information. The defendants were becoming
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1487. On or about March 29, 2006, Hinger responded to Tower on AFRA_CenCom that he had
received the information about me that W. Tower had sent him and promised to keep him
advised when her heard back from the AG’s office. When asked on the group what that
was about, Hinger responded that the information was sent via fax to him from W.
Tower. Hinger then reported to W. Tower that the AG was ready to prosecute, and
wanted the entire file by Monday.
1488. On March 30, 2006, Bill Tower sent me an email stating he had seen my proprietary
information “many times.” He refused my demands to identify who provided it to him.
He and his wife, Anne Tower, have used this information on behalf of AFRA and other
organizations without giving me credit.
1489. On or about March 30, 2006, Tower again transmitted information about me he professed
to have obtained from a Colorado state agency to Hinger via AFRA Cen_Com. Tower
also advised other defendants of his opposition to the agreement between AFRA and
myself.
1490. On or about March 30, 2006, A. Dutkiewicz made a complaint to my ISP, EarthLink,
about a cease and desist email I sent to her. See ¶ 505.
1491. From April, 2006, and on, W. Tower used AFRA and AFRA properties to eliminate me
from the market because his feelings were hurt that I dared publish he supported the
Dutkiewicz’s and I refused to be bow to his commands.
1492. By April, 2006, AFRA had devolved from the advertised free association it advertised
itself to be to an autocratic organization with a pathology of using force of threats and
intimidation to exert arbitrary and capricious control over members by the leadership; to
exert inappropriate control over other groups or individuals outside their membership
who refused to submit to AFRA leadership; to engage in censorship of speech within or
outside of their sphere of influence; to engage in infringing conduct, with institutionalized

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secrecy conventions intended to cover up questionable practices or tortious conduct;

discriminatory practices based on sex, religion, etc.; engaging in retaliation against critics
including illegal or tortious conduct, refusal to disavow, sanction or expel members who
engaged in illegal or tortious conduct in the furtherance of AFRA’s agenda; and issuing
threats, conducting campaigns of harassment and abusive actions against any critic’s
personal safety and family members. In short, AFRA had devolved to a haven for
batterers, abusers, con artists and the mentally unstable, guilty of the same wrongful
conduct they accused child welfare agencies of committing.
1493. There was, at the time, an exodus of competent, independent women who objected to the
misogynist, control-freak and battering pathologies employed by AFRA leadership, which
included to publicly and privately characterize women who were critical of AFRA or the
leadership as mentally ill, pre-menstrual, unstable, radical feminists, spoiled brats
throwing temper tantrums and used tampons on the floor, and issuing edicts that must not
be questioned, and other disrespectful acts intended to minimize her competence and
merits. The leadership disrespected the fact that a woman was entitled to the fruits of her
labor, especially when her labor was far more fruitful than theirs, and they appropriated
her work to themselves. This had happened to several women by this time.
1494. On or about April 1, 2006, Wiseman purchased the domain name
“thetruthistold[dot]com” and began publishing that web site shortly thereafter. This web
site was instigated by Kiefer, in response to my participation in the domain name dispute
with CFC. The purpose of this site is to hold me out to public ridicule, to embarrass me,
and to use defamation to malign my personal and professional character, to libel my
practice, business and my products, and to undermine my credibility and professional
reputation. It is advertised as an “anti-Suzanne Shell site.” The defendants troll the
Internet for any article or publication that is about me or refers to me, where they post

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false and defamatory comments about me anonymously or in their own names, and
include a link to this site.
1495. In document #273 Wiseman admits to many of the false advertisements that are published
on his web site, attempting to use them as a defense for publishing them. He parrots many
of the false statements that have been disseminated by the defendants without really
understanding anything about the events. He wasn’t around when the events happened,
He can barely read and write. He never saw anything and understands less. He just knows
his friends don’t like me and believes what they tell him about me.
1496. Wiseman and the other defendants have submitted false and defamatory comments about
me, my business and my products and a link to his web site on hundreds of web pages
that are visible to the general public, including:
a. http://msmvps.com/blogs/spywaresucks/archive/2007/05/05/891156.aspx
b. binaryfreedom.info
c. various facebook accounts
d. www.famozz.com/hot-people/john-tesh
e. www.p2pnet.net/story/11696http://wakeupproject.com/Forum/viewtopic.php?p=9
1293&sid= 949d2d0695bda6f1866b20f870787253
f. wisemanstudios.net/default2.html
g. http://m.vcstar.com/comments/list/news/stories/148812/0/
h. www.mihanrobot.com/ObamaCrimes.com--page6.html
i. donsingleton.blogspot.com/.../colorado-woman-sues-to-hold-web.html
j. http://www.facebook.com/posted.php?id=88739104280&start=50&hash=819c7c2
c49db71d7d2dd2b945bc37b3e
k. http://174.143.205.35/user/wisemanstudios/favorites/updates/recent?page=2&limi
t=10&filter%5Bprofile%5D%5B0%5D=9761&filter%5Bapproved%5D%5B0%5

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D=1&filter%5Btype%5D%5B0%5D=PROFILE_ASSET_HISTORY&filter%5Bt
ype%5D%5B1%5D=PROFILE_ASSET_DEFAULT&filter%5Btype%5D%5B2%
5D=FEED_VERSION&filter%5Btype%5D%5B3%5D=WIKI_VERSION&filter
%5Btype%5D%5B4%5D=PAGE_VERSION&filter%5Btype%5D%5B5%5D=P
ROFILE_CHANNEL_HISTORY&filter%5Btype%5D%5B6%5D=PAGE_HIST
ORY
l. wholinkstome.com/url/downloadyoutubevideos.com
m. neopa.net/bookmarks-may2009.html
n. http://www.notsorryaboutourpresident.com/index.php?d8c2c0=30
o. http://www.zoominfo.com/people/Bendt_Bruce_1177961099.aspx
p. http://www.lexferenda.com/18032007/profane-injustice/
q. familyrights.us/news/archive/2010/march/doc_397/240.pdf
r. http://digg.com/security/Suzanne_Shell_Photo_of_the_woman_who_is_trying_to
_bring_down_the_Internet
s. www.free-press-release.com/news/200705/1180381125.htm
t. binaryfreedom.info/?q=node/139
u. www.youtube.com/user/wisemanstudios
v. http://lookhorribleidea.blogspot.com/2007/03/digg-has-made-me-sad.html
w. giza.livejournal.com/411256.htm
x. www.kevo.com/profile/billy/history/WIKI_VERSION/14319
y. ebaysellingcoach.blogspot.com/.../ebay-coach-giveaway-25-shell-gas-gift. html
z. www.swotti.com/ficha/gente/shirley-baez_84427.htm
aa. http://www.yasni.com/cletus+kiefer/check+people
ab. http://takethu.com/blog/2007/03/17/woman-sues-wayback-machine/
ac. http://www.facebook.com/l.php?u=http%253A%252F%252Fthetruthistold.com%

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252Favoice%252Farrest.html&h=4c0bbb2c91bc354f757191bd2f556df5&ref=sha
re
ad. http://jangpaul.com/jboard/?p=detail&code=board&id=4072&page=87
ae. http://www.wakeupproject.com/Forum/viewtopic.php?p=88431&sid=6d919b742
776025c9c759886174c55c1
af. http://identi.ca/notice/8594180
ag. http://www.taewoocutex.com/cgi-bin/technote/read.cgi?board=eoperation&y_nu
mber=3
ah. http://pythonline.com/users/billywiseman
ai. http://yourdiabeticcat.com/forums/post.asp?method=ReplyQuote&REPLY_ID=93
848&TOPIC_ID=6456&FORUM_ID=4
aj. http://webmaster101.blogspot.com/2007/03/webmaster-claims-spider-entered.html
ak. http://ta-in.facebook.com/posted.php?id=59395956426&share_id=106573845687
&comments=1
This list is far from complete, but it is sufficient to show how the defendants have
saturated the market with their false information about me and my business.
1497. Wiseman has admitted in document #6 that other defendants write his web site and he’s
not even allowed to post anything without permission. More than three defendants have
already admitted having editorial control over his web site or submitting content to his
web site. He does not even control his own web site. Contributors to thetruthistold are
anonymous, or ghost writing for Wiseman who takes the credit, or are identified as the
defendants. Some ghost writers have been identified by content and writing style as
Contreras, Blair, Swallow, Durand, A. Tower, A. Dutkiewicz, R. Cygan.
1498. T. Dutkiewicz has contributed to thetruthhistold[dot]com under the pseudonym T.M. In
one instance he offered a public comment to Wiseman on one of Wiseman’s forums,

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“suzanneshell.blogspot[dot]com,”
“Billy, I have been watching the evolution of this website and you are a super genius...
is there somewhere that we can send an email to nominate this site for an award. For
those who were not there in the begining, the first site was good, but true child's play
compared to this. Billy has shown himself to be thoughtful, competent, skilled and a
virtual brain child of the technological information age.”
“What do you keep in the dark and feed Sh*t???? besides a mushroom.....right
SS and her friends.”
1499. On or about April 2, 2006, Wiseman’s web site displayed a new link called Shell bashing,
to a newly formed Yahoo! group named bashing_shell. At the start this group was open to
the public. Then, concerned about their communications being publicly available, they
closed the group to the public and only members were permitted to view or participate. I
joined this group and observed the defendants conspiring to commit acts described herein
and other acts intended to deprive me of my business and my business reputation, to
deprive me of my professional reputation, deprive me of my property, to deprive me of
my property rights under copyright to control the uses of or exploit my intellectual
property, to deprive me of my professional reputation and stature, to deprive me of my
legitimate livelihood, to drive my business off of the Internet, to defraud the public, and
to eliminate me as competition. Information flowed out of this group to other defendants,
and from other defendants into this group for use in the furtherance of the conspiracy. The
group owner was Wiseman. R. Cygan and Baez were moderators. Members included
defendants Durand, Wiseman, A. Dutkiewicz, Swallow and other AFRA members and
some consumers. Some of the conspiratorial communications include:
a. “so how do you all like the website? what can i do to make it better...yours in
christ john Doe” Wiseman, April 11, 2006.
b. “I love it. It's so deserving....” Durand April, 11, 2006.
c. “Thank You as you can Tell I put alot Of Work into it...if you need something
Posted about shell on it im the person to see. . .” Wiseman, April 11, 2006

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d. “i talked to someone who knows and am waiting on the proof which is comming
soon and will be put up on the website and what i heard it was both kids got
beat with this wip that you beat horses with and it was not just her husband
that beat the kids it was none other then MRS.shell.” Wiseman, April 11, 2006
e. “She is a liar and a minipulator and it should be told. . . .I guarentee she does
not know Georgia law like Dorothy Baez does. Sorry but someone who advises
people to break the law should NOT be teaching anyone anything.” R. Cygan,
April 11, 2006.
f. “In the Truth website she reccomends that parents tape a spanking given to a
child to prove there was no abuse???? Folks what this says to me is Shell is
encouraging soft porn and kiddi porn......when you think about it.” A.
Dutkiewicz April 11, 2006.
g. “ <did she say that about a gun?? > Brenda has it on tape...I must have slept
through that part of the seminar...I slept through a lot of it...” Durand, April
11, 2006.
h. “Hay can she get on here and read this???? I was able to log in from the
website. Is that because I am a member or can she also get in.” A. Dutkiewicz
April 11, 2006.
i. “You cant get in if you're not a member But anyone can read the messages... I
read them from AOL.” Durand, April 11. 2006.
j. “Don't ever say I'm in any way a part of that group [FRAI]. I got out when I
found out what they were doing. I know you're paying for this site and it is
appreciated. cracks me up.” Durand, April 11, 2006.
k. “Wondering if I should change my ID on here.... If SShitler and her band of
braggarts can read this stuff. I had better be more careful because I filed a

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Police report for her threatening me... and she would love to turn the tables
and file one on me.” A. Dutkiewicz, April 11. 2006.
l. “I think you did a very good job on that webpage [ thetruthhistold[dot]com ]...I
can't build one...my hats off to you on that one.” Durand, April 11, 2006.
m. “I think she’s pure evil. . .” Durand, April 11, 2006
n. “Her comments about Cletus? That info was placed on a public domain...Did
Cletus give you permission to copy it to your webpage? First off, set the
controls of this group so no one can read messages except members....do you
want the sscrew knowing everything you say and do???” Durand, April 11,
2006.
o. “how do i do it??” Wiseman
p. “Does anyone knpow Bill Tower well enough to find out if the crew are
gone???? [from AFRA]” Durand.,
q. “I know Bill well enough to talk with him almost daily. Not all are gone Linda
Elf (aka Effie) was voted off Cen Com. Don't know bout the rest they are so
sneaky... Like this Rusty Beach person. Shellbasher think about taking the time
to have the moderator make phone contact with potential members it weeds
them out fast. Home Phone too with a # that can be tracked.” A. Dutkiewicz,
April 11, 2006.
r. “It is about landing her fat bottom right where it belongs. . . . ON THE
STINKING CURB! As well as dismantling her phoney lil empire!” R. Cygan, April
11, 2006.
s. “When im Able to speak freely im no loger upset at snout face and its so good
to see her pig hoping mad. . . .however id othink that people need to work to
help familys no rip them off like she does saying people has to bur her a ticket

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to come and give them a good talking to at there exspence. . .nutty people we
have wanting a farm hand to teach about kids shen her own kids want nothing
to do with her and she supports beating up kids.” Wiseman, April 11, 2006.
t. “I do not blame you one bit she has to be stopped. She needs to be gagged and
hung out to dry. . .I think we should tell everyone that we comeinto contact
with the beware of the PIG SHELL.” AFRA member and agent Linda Weston,
April 11, 2006.
u. “It’s far better to be silent and do what ever you have to do.” Durand, April 12,
2006.
v. “Also, can someone post the names that the moles [me go by so I can check to
groups I am on to see if they are there?” A. Dutkiewicz, April 12, 2006.
w. In response to Wiseman posting my demand for payment for his copying my
entire web site on thetruthhistold[dot]com, “This almost sounds like extortion. .
.is that allowed on the Internet?” She added later, “Blackmail???” Durand, April
12, 2006.
x. “You mean the SS crew can read everything on here.” A. Dutkiewicz April 12,
2006.
y. Baez was a moderator and responded to membership requests, “Hi! Would you
please write to family_rights_advocate@yahoo.com for approval? She is
handling membership requests. As I'm sure you can understand, we are trying
to be very careful.”
The group message archives were made private after these messages. Membership
requests were carefully scrutinized, unknown applicants were denied. As of June
5, 2006, this group had been closed and the defendants turned to more covert
methods to participate in, promote and execute the conspiracy.

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1500. Other, similar groups were created to replace or supplement this group. The common
element was the participants were comprised of various combinations of the defendants,
and the objective was destroying me and my business. Information developed by these
methods was disseminated to the other defendants for their use.
1501. To accomplish the ends of the conspiracy, Henderson forwarded certain premises on his
forums and encouraged the market to use those forums to debate those premises, to
exaggerate and escalate the facts, and to arrive at a predetermined consensus under his
careful direction. The characteristics he attributed to me and successfully contrived for
the market to believe include the facts in this complaint as well as the false claims that I
asserted only I could train advocates, that I was “off my meds,” that I was “hormonal,”
that I demanded “love me love my [consumer advisory articles],” that I had no right to
protect my IP because it was “tyranny.”
1502. On or about January 16, 2006, Swallow posted on DCFReformFL,
“First and foremost Aimee I will provide you my phone number in a private e-
mail. Now I will tell all why I am so persistent, so angry and will see Suzanne
Shell, Kay Henson and if they keep posting (False, Derogatory, Slanderous)
information about myself and my family Rose and Effie are subject to Claims
against them.”
1503. There was much debate during this purge about removing me and anyone associated with
me, specifically insuring that neither I nor my associates would be able to know what was
transpiring on that group. We were all subsequently removed from membership.
1504. There was an appeals process, with the AFRA BOD having full discretion to uphold or
reverse the decision.
1505. CenCom was advertised as,
“for strategizing, formulating plans and coordinating projects so more people
can participate and help make American Family Rights Association the true
force to be reckoned with. . .where the Family Rights Advocacy LEADERS can
easily toss ideas and questions back and forth.”

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1506. On or about April 4, 2006, Henderson published on all AFRA groups, that an ongoing
argument on AFRA groups where I was the topic–but I was not a participant–was part of
an “ongoing sandbox war with Suzanne Shell,” and “. . .it is impossible to prevent the
combatants in the Suzanne Shell wars from taking swipes at each other.”
1507. On April 6, 2006, A. Dutkeiwicz called my ISP, EarthLlink,, and represented that she was
speaking on my behalf and cancelled my web site and Internet service. See ¶509.
1508. On or about April 7, 2006, Kiefer disputed an announcement made by CFC regarding the
large listening audience for my appearance on their radio program. Kiefer erroneously
assumed it was only an Internet broadcast, when it wasn’t. Hinger and other AFRA
members also challenged the numbers, but the source was provided.
1509. On or about April 7, 2006, Tower announced as his first official act as President of
AFRA, that he was designating AFRA Cen_Com for AFRA members to conduct AFRA
business. Subsequently, the business of AFRA and its members included defamatory
advertisements and conspiratorial discussions and acts against me, my business and how
to misappropriate my property.
1510. On or about April 7, 2006, Hinger advised that Citizens For Change (CFC)
announcement of the listening audience for my appearance on their program did not
constitute AFRA business and such announcement should not be published to CenCom.
CFC was, at the time, a member of AFRA.
1511. On or about April 7, 2006, Wiseman’s commented on CenCom, “if she wants the truth
out write me,” to which Kiefer replied, “Let The Truth Be Known!”
1512. On April 8, 2006, Hinger sent me an email in which he stated,
“In my opinion, you are nothing more than a fraud, a liar, and a plagiarist attempting
to cover up crimes against those who need our help the most. . .I have been
investigating you and your cohorts for a long time now and your little scam is all but
over.”

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1513. On or about April 8, 2006, M. Cygan advised communicated with W. Tower on

AFRA_Cencom regarding his plans to institute training, which was based on my
proprietary information. W. Tower advised him to take this discussion back channel
stating, “. . .I will explain what so far can not [sic] be posted on these groups.”
1514. On or about April 11, 2006 on bashing_shell, Durand wrote, “I don't want to disillusion
any of you but SS is not the one who orchestrates the attacks or picks the new
victims..”
1515. On or about April 11, 2006 on bashing_shell, Durand wrote,
“First off, check it out, my certification was pulled after I put it through the paper
shredder...second, I was minding my own business until K's attack dog tried to drag
me into Brens chit. You want to be paranoid, that's fine, but leave me out of that chit.
I detest that crew as much if not more than you do...they hurt your feelings...join the
club...as per the chicken coup, my lawyer already looked into chit...and you're right I
won't get into the sandbox wars because the ss crew gets off on that chit...”
1516. On or about Aril 11, 2006, I sent another cease and desist demand to Keifer whowas still
using my plagiarized content. Keifer forwarded it to Wiseman who took up the gauntlet. I
included a cease and desist for circumventing my copy protections and copying my web
site onto thetruthistold[dot]com. They responded by publishing more defamatory content
on the thetruthhistold[dot]com web site.
1517. During this time, Wiseman kept up a campaign of email harassment, threats and abuse
directed toward me, my associates and our families. His emails indicated that he did not
understand much of what was going on, and would request time to research before
answering their questions. When he came back to the discussion, he clearly had been
coached to perform certain tasks and say certain things. It was clear he was being
exploited by the defendants, especially by Kiefer at this time.
1518. Wiseman solicited others to contribute to thetruthistold on or about April 11, 2006, and
instructed others to contact R. Cygan with their submissions if he wasn’t available.

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Wiseman has admitted in these proceedings that he does not exercise control over the
content of his web site.
1519. On or about April 11, 2006, Wiseman contacted me via email and demanded I remove his
name from my web site because it was copyrighted, Henderson and Keifer have also
made similar claims citing absurd patriot law.
1520. On or about April 12, 2006, Durand told Wiseman to make the bashing_shell group
private, “. . .do you want the sscrew66 knowing everything you say and do???” The
defendants instituted safeguards stating “ALL the information on this group is
confidential and of such nature that the "other side" does not know we have even a
tenth of it. You can add to that or be left out of the loop. The choice is yours.”
1521. On or about April 12, 2006, A. Dutkiewicz stated on bashing_shell, “In fact it was in one
my worst fits that I took her book pored lighter fluid on it and burned then told her I
sacrificed it to Kali and Morgaine (goddesses of war.)”
1522. On or about April 13, 2006, Swallow advertised thetruthhistold[dot]com to over a
hundred individual and group recipients, including AFRA and non-AFRA groups. This
site had a link to a private Yahoo! Group called Shellbash where members must be
approved so that the membership can participate in the conspiracy without being
detected. This site is a location where Brenda participated in providing my proprietary
materials and trade secrets for publication and access to my competitors, the defendants.
1523. On or about April 15, 2006, A. Dutkeiwicz sent me a self-destructing email, with the
subject line “You IDIOT” using bigstring.com. The return email address was
“gotyanow”. This email contained threats about me spending time in prison, and
contained harassing and false and libelous comments about things she accused me of
doing, and a specific quote that my family was not off limits.
66
The defendant refer to me in variations of “ss,” in this instance ss-crew.

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1524. On or about April 16, 2006, Jackson posted on CenCom,

“Mark [Cygan], I am very interested in your certification process, and would like to
hear MUCH more. Would you consider posting some of your guidelines here, or might
you email me offline? AFRA is investigating the possibility of a formal program to
cultivate advocates, and I am out to pilfer ideas to that end!”
1525. On or about April 16, 2006, AFRA_CenCom was purged and all members had to sign a
Mandatory Confidentiality Agreement. It required,
“Absolutely NOTHING posted, discussed, debated, or otherwise taken up on this
Yahoo! group as official AFRA business may be forwarded, re-posted to another
group, displayed on any website, e-mailed or otherwise disseminated, divulged
or move beyond the confines of discussion between members of the Central
Communications group for unless specifically designed for and approved by the
Board of Directors for public dissemination.”
In response to a member’s query, W. Tower stated, “. . .we are trying to be careful as to

what happens with the info.” Signatories to this agreement include but are not limited to,
W. Tower, Jackson, Wiseman, M. Cygan, Baez, Kiefer, Durand, Hinger, T. Dutkiewicz.
1526. On or about April 17, 2006, Jackson participated in requiring confidentiality agreements
to be a member of CenCom and full identification of all members. She stated this was to,
“route [sic] out the very people who have a tendency to disloge the fronturnners in
advocacy.”
1527. On or about April 17, 2006, M.Cygan reported to CenCom that Wiseman was not online
and requested the AFRA BOD grant him extra time to sign the CenCom confidentiality
agreement.
1528. On or about April 19, 2006, Wiseman published that he wanted me to send an email
saying how sorry I was to him, and it will never happen again, so he can post it up on his
web site proving how sorry I was. I have no clue what he needed an apology for, but his
friends were demanding apologies, so he went along with them.
1529. On or about April 20, 2006, M. Cygan published on CenCom that he had seen my

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proprietary seminar handout that was protected under a non-disclosure agreement. He

used this information to create and promote IFAC.
1530. On April 21, 2006, in response to a comment on AFRA_EAGLE about the link to
thetruthhistold[dot]com being a bash Suzanne site, Kiefer said,
“This Appears Not To Be Bashing But A Link To Of Someone Who Is Seeking Relief
From Her Threats and Intimidations. This Is What Happens To People Like Her Who
Pulls Things Such As She Does. End Of Subject. Together for the Cause, Brother Cletus -
Pres. of FAR Defense Alliance.”
1531. On or about April 22, 2006, the Dutkiewicz’s, who had been banned from
AFRA_Cencom (CenCom) by Henderson around 2004, were openly readmitted into
membership under W. Tower.
1532. On April 24, 2006, Swallow again disseminated thetruthhistold[dot]com link to over a
hundred recipients, and laughed that my web site was down.
1533. On April 24, 2006, W. Tower maliciously interjected himself into a lawsuit I was a
defendant in, and contacted the law firm representing the plaintiff, Internet Archive, in
my copyright infringement lawsuit, Perkins Coie LLP. He proffered false evidence to
them which would tend to support Internet Archive’s claim that California had personal
jurisdiction over me. In a declaration filed by Michael Rubin, Tower falsely claimed to be
a paralegal and law student. Tower falsely represented to Mr. Rubin that I has in
California in September 2005 working with a paying client in connection with my
advocacy business. Tower falsely represented that I was appearing in a court in San Jose.
Mr. Rubin signed his declaration under the penalty of perjury.
1534. I contacted Mr. Rubin, who stated that W. Tower had initiated the contact and had
volunteered the information contained in his declaration. I provided Mr. Rubin with the
facts and evidence; that I was not in California with a paying client, that I was not
performing advocacy and that I was not appearing in or even attending any court case.

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Consequently, Mr. Rubin determined that W. Tower was an unreliable witness and
decided not to solicit his false testimony. However, I was compelled to participate in
limited discovery and depositions as a result of W. Tower’s proffered false testimony
after which Internet Archive ultimately stipulated to having the case transferred to
Colorado.
1535. After this event, the defendants began to include four counsel from Perkins Coie, who
were representing Internet Archive, in their private email distribution lists when they
were engaging in their conspiratorial communications and disseminated false advertising
about me. This was intended to provide as much harmful information as possible to
opposing counsel with the intention it would help Internet Archive prevail in their lawsuit
against me.
1536. On or about April 27, 2006, Kiefer hosted an Internet Radio show which accepted calls
from listeners. The subject of this program included making references to FRAI certified
advocates charging for their services—which was false–and claims about FRAI advocates
not being any better than other advocates.
1537. On or about April 30, 2006, Swallow provided Wiseman the response he should submit
to me in my response to him when he was harassing me. She manipulated him by
belittling me and making him look important, kept telling him I was lying, and full of it.
She advised him to “call my bluff.” He did as she told him. Swallow included counsel for
Internet Archive in this and subsequent email distributions about me.
1538. An article by Swallow was featured on thetruthhistold[dot]com and it contained false
advertisements including claims that I and/or FRAI referred clients to disreputable
attorneys, received kickbacks, I committed crimes and had advocates commit crimes. She
stated, “She is a sick, nasty, mean, evil woman who will stop at noting to get
"revenge" well SS you've met you match baby I've got a few Aces you have'nt seen

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Yet wanna play some Poker?”

1539. Baez has proudly admitted on the interactive online groups that she is the one responsible
for obtaining my maiden and former married name and providing it to the other
defendants around May, 2006. I have never published nor used my maiden name or my
prior married name online or in public in order to protect my children and my family from
potentially dangerous elements associated with this industry. Baez gave it to the
defendants who caused it to be published on multiple web sites worldwide, placing my
children in danger and causing my frail father to require hospitalization when he was
attacked and defamed by the defendants in articles on high-traffic web sites like
Digg[cot]com.
1540. Baez has admitted writing content on thetruthhistold[dot]com.
1541. On or about May 3, 2006, Baez sent me an unsolicited request to be allowed past my
spam blocker and added to my private email address book. She then asked me to correct
the spelling of her name on my consumer advisory article where she was listed as a
supporter of R . Cygan because nobody who Googles her name can find my Consumer
Advisory page. She signed her email “Georgia Family Rights.”
1542. On or about May 15, 2006, Wiseman sent me a self-destructing email with the subject
line, “think you out smarted me didnt you look at this.” I didn’t open the email.
1543. On May 16, 2007, Baez wrote in her blog at
http://feedblitz.com/r.asp?l=25719800&f=104839&u=0
“As for my having done "background" on Suzanne Shell for Dennis Hinger, that is
false. I have been collecting various pieces of information for several years now, ever
since I realized I might one day need to protect my family and myself. I am not the
only person to do this. While I did not give any information to Dennis Hinger directly, I
have given it freely to those who have requested it. I am glad to be of help when I can
and have no problem with others using information I have gathered. Dennis had
certain materials forwarded to him with my very best wishes.”
Baez also wrote, “It is true that Renee and Mark Cygan and I have at times

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collaborated on the development of various training materials. Our collaboration has

not been limited to Family Rights issues, and we often have several irons in our
collective fires.”
Baez added, “I still remain, however, a loyal member of AFRA. I am very proud of our
leadership and am supportive of the goals of this fine grass-roots organization.”
1544. On or about May 18, 2006, Hinger sent me an unsolicited email about my web site:
“Suzanne, I just went to check your website to see if I was still on your bad advocates
list and low and behold it is off the net... I understand the fed's took it off this time,
something to do with kiddie porn or something like that... God lady with all your self
professed legal knowledge I would think you would know better than to put pictures
like that on your website, hell it is against the law to even have them on your
computer... Guess it doesn't pay to piss off the wrong people does it...Dennis”
The photo to which he was referring had been published in the Village Voice in New
York City (NYC) and aired on NYC cable access television before I published it. I knew
the photographer personally who had given me express permission to publish the photo
on my web site. It depicted what the mother/photographer had discovered when she came
home early one day: the father, a NYC law enforcement officer, naked in bed, on top of
the covers, with his six year old daughter, who was clothed. A judge had subsequently
given custody of the child to the father.
1545. Hinger continued sending me a series of abusive and harassing emails after I repeatedly
told him to stop harassing me. He conducted himself as a batterer, intent upon forcing me
to bend to his will, and would not relent with contacting me. I reported his continued
abuse to Hotmail, and provided them with his emails. Hotmail shut his account down. He
then posted to AFRA groups, “Due to a vindictive, malicious b****, MSN closed down my
popsplace920 hotmail account based on a false and unfounded complaint lodged by that
person.”
1546. On or about May 21, 2006, Hinger contacted Gregory Hession, my friend who happens to

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be an attorney, asking if he was “representing me in legal matters or just doing it as a

friend.” He asserted he needed to know where legal papers could be sent. He
subsequently sent El Paso county sheriff to serve me papers for a restraining order in
California. The restraining order was ultimately denied.
1547. On or about May 21, 2006, R. Cygan joined my Improvement Project group. She posted
her first message on that same day. She said,
“Suzanne, Kay, Effie, I sincerly apologize to the three of you for every bit of
retaliation I took part in and perpetuated against you. Two wrongs do not make a
right. And nothing as far as i am concerned justifies how down right nasty I have been
up to this point.
“Suzanne, I owe you the biggest apology there is of them all. For every name I
called you, for every wise crack I made and for ever posting I made. And most of all
for having your site shut down. ( Though that was a disgusting picture) But I know
WHY you had it posted there. I understand the intention behind posting it and I
apologize for the cheap shots. EVERY single one of them”
1548. R. Cygan admitted having access to my proprietary seminar handout,

“I apologize for picking apart that seminar handout and making fun of it. It was well
written and put together and I give credit where credit is due. I will be sending a copy
of this posting to Billy Weisman at thetruthistold[dot]com and asking that he put it up
as my statement. . .I will also be asking dorothy first thing in the AM to take down my
writings about you on her site as well. While I cannot control the actions of others I
will say this, I will no longer be participating and will not do so at any time in the
future either.”
She stated she teaches classes for IFAC. However, they never had classes, and IFAC
never even existed before they obtained my proprietary seminar outline.
1549. On or about May 22, 2006, R. Cygan posted on the Improvement Project,
“I would like to address the issue of a complaint filed by me with cbeyond. (my web
site host service after I had to leave Earthlink). Recently I filed a complaint regarding
content on Mrs. shells website www.profane-justice.org with respect to a published
photo. The allegation was for kiddie porn. As I have statted both publicly and privatly
it is my opinion that the photo published was in poor taste HOWEVER the intention of
Mrs. Shell when posting this was very obvious. It was a cheep shot on my part to file
such a complaint and I want to set the record straight. There is no way I can ever
erase the origional complaint or the malice with which it was done. But right is right

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and setting the matter straight is what is in fact RIGHT. So I am sending this to Mrs.
Shells group and to cbeyond to publicly withdraw my complaint and apologize to
Suzanne for perpitrating such juvenile tactics. There are many ways to work out
personal disagreements and this is not one of them. Suzanne may be a lot of things in
a lot of different opinions but a promoter of kiddie porn she is not.”
R. Cygan’s complaint to Cbeyond resulted in them asking me to remove my web site
from their server.
1550. On or about May 25, 2006, Hinger joined my Improvement Project interactive online
consumer advisory group. He expressly agreed to all the terms of membership of that
group. He stated, “AFRA does not tolerate or condone dissemination of information
detrimental to this movement...Dennis”
1551. On or about June 5, 2006, T. Dutkiewicz broadcast a plea to all AFRA groups and some
non-AFRA groups for someone to assist me in Federal Court with Internet Archive v.
Shell. He issued this broadcast request of his own initiative.
1552. On or about June 6, 2006, Wiseman requested to join my Improvement Project group.
1553. During the June, 2006, Wiseman made repeated phone calls to Contreras in Colorado,
providing information about me to her and receiving information about me form her.
alias to harass and abuse.
1555. On June 11, 2006, Blair sent his cousin, Kathy Kidwell to join my Improvement Project
group on to speak on his behalf.
1556. On or about June 14, 2006, Blair sent an email to other defendants and competitors with a
link to an audio file that was to be included on thetruthistold[dot]com. Wiseman had
requested Blair’s help for his web site, and Blair accepted. This email was widely
disseminated.
1557. During this time, many of my associates reported having their computers hacked into.
Private files, including original graphic art, taken from their computers began appearing

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on thetruthhistold[dot]com, where the defendants were including defamatory content

about them and their families. When they visited thetruthhistold[dot]com, their computers
would be subject to freezing, or sudden disconnection, or infected with malware. They
provided me with the reports of scans before and after accessing thetruthhistold[dot]com
showing malware that had been detected.
1558. On June 14, 2006, Cygan stated she had control over the content in Wiseman’s site in a
post to my Improvement Project group, “i asked billy to remove [a photo of an
associate’s child] because he thought it was you and it in actuality was your daughter.
He did remove it so no big deal.”
1559. On or about June 14, 2006, after having a series of her increasingly vitriolic and abusive
posts moderated by me on my Improvement Project group, R. Cygan threatened me with,
“You opened a huge can of worms now. I think you should know that we are about to
post a lovely video of your ugly yap running off at the mouth. No involvment with
california huh? hmmmm you better get out a big bottle of pepto bismol because your
about to start feeling really sick over “the truth being told.’. . .I am going to see to it
that that video live and in color goes out to every single group on yahoo and then
some. You are a fake and a con artist and you can't hide it forever. Are you getting
tired of back peddling yet?”
1560. On or about June 15, 2006, R. Cygan admitted more control over thetruthistold[dot]com
web site when she posted to Improvement Project, “I asked Billy to transfer the video to
the website so thay it can be viewed.” She is referring to a six hour video of one of my
seminars, I do not permit others to film my seminars, so Wiseman’s ownership of this
video is illicit and unauthorized.
1561. June 16, 2006, I had to publicly advise R. Cygan on Improvement Project to stop
harassing me with back channel emails, that any further discussions with me must be in
public view on this forum.
alias—which was not permitted under the group rules–using her daughter’s name and

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placing her in Illinois where R.Cygan was. She submitted a forged copy of a drivers
license as proof of identity, using her daughter’s photo. She stated in her introduction that
she was working with R. Cygan and proceeded to post profane and abusive attacks.
1563. On or about June 18, 2006, Wiseman wrote to my associate and licensee, K. Henson,
“will you please ask shell please stop picking on ammie [A. Dutkiewicz} on this one
please The True person who it is below..billy.”
1564. On June 19, 2006, Blair joined my Improvement Project group.
1565. On or about July 7, 2006, after extensive debate on the AFRA_Directors group, lead by
Henderson putting his spin on me and my business, and after AFRA BOD arriving at a
general consensus (there were three in dissent) on how to best present me and my
publications so as to malign me as described in this complaint, Henderson announced, “I
am de-fanging her.” An examination of the record seems to indicate he is using Wiseman
to de-fang me.
1566. On or about July 7, 2006, Wiseman sent an email to Tower, Durand, Contreras, Tilley,
Hinger, and to four counsel for Internet Archive,
“i could not connect to godaddy.com and i even used a proxie but the website is down
for some reason as soon as i get the rent from one of my tenants im outa here so i
wont get any emails untill i return...my cell phone is going to be with me so i can still
get calls i will start bugging the people i bug most tomorrow an ken the email below is
from shell she is dening that is her intellectual property but the below is what she is
using and shutting peoples webisites down because of it..if anyone writes me back
please dont do so at this email address still send it as always to nextfriend.us i just
could not send out a email...Billy Wiseman”
1567. On or about July 25, 2007, I received information that Contreras was in regular telephone
contact with Wiseman, and that during this particular conversation, she revealed that
“someone” was about to do something that would finally shut me down for good, even
earning me jail time. She made a specific reference to kiddie porn.
1568. On or about July 29, 2006, Tower responded to an email that Wiseman had sent to him

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from my Improvement Project, showing that he was participating with Wiseman, “I have
read this email with great intrest and knew that it was Mark and not Renee, (Mark
left out all the swear words) Renee would not have been this candid and careful with
the wording. I did get a great big laugh out of reading this. I nedd the cheering up this
eve. Thanks” Wiseman replied, “ bill im glad to be of service :+}”
1569. On or about July 29, 2006, Contreras had been the recipient of emails from other
defendants, which list included counsel from Perkins Coie, and responded,
“The [consumer advisory] IS what started this. I do not disagree with the idea of
having such a list, DISCREETLY, available to the public if they choose to investigate for
themselves before choosing an advocate, I do think that the manner in which it was
done was not beneficial for anyone and did cause a lot of discord and wasted time. We
are advocating having a committee for families to go to when they have problems with
CPS corruption, and we need to have the same for public complaints about advocates.”
1570. On July30, 2006. Durand published to online groups encouraging them to continue their
conspiratorial acts, “Keep your page [thetruthhistold[dot]com] up and running, Billy
[Wiseman], those individuals who were writing complaints about certain problems
should continue to do so.”
1571. On or about July 31, 2006, on the Improvement Project, Merwin was publishing arrest,
court and criminal histories of all advocates, including me and my associates as well as
the defendants. She published the sex offender record of a Billy Ray Tower in California.
She asked one question, was this “their faithful leader?” I stated, “This record below is
not Bill Tower. He was in Maine in 1997. His first appearance in this movement
wasn't until late 2003 or early 2004. If the group wants, I will go back and remove
the post - in fairness to the truth.”
1572. Hinger then falsely advertised all over the online interactive groups that I had said Tower
was a sex offender, even after I stuck up for Tower and said he wasn’t.
1573. On or before July 31. 2006, R. Cygan called the FBI in Colorado to report that I had

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kiddie porn displayed on my web site, intending to get my web site shut down and have
me arrested and convicted. Colorado FBI agent Robert Mauer investigated this complaint
and determined the complaint was unfounded.
1574. Wiseman also owns a fully interactive Yahoo! group called thetruthistold [truthistold
group], which was created in August 2007. This group is private, and is used to conduct
the conspiracy against me.
1575. On or about August 1, 2006, R. Cygan posted to the Improvement Project, “I have not
change my opinion of you Suzanne nor my desire to have your site shut down.”
1576. On or about August 1, 2006, R. Cygan published on the Improvement Project, “I am not.
. .apologizing for wanting [Shell’s] site shut down or working to get it shut down.”
1577. On or about August 1, 2006, in his “Blackball Suzanne” broadcast email to over fifty
groups, Hinger said, “Suzanne, you are currently throwing another tantrum . . .you are
going to need every dime you can scrape together fighting the additional lawsuits
currently being prepared... Dennis M. Hinger.”
1578. On or about August 1, 2006 on the Improvement Project, Blair stated, “From my
perspective, [the ongoing dispute with Shell] IS all about the [Consumer Advisory].” I
didn’t own this any more. He never contested the content, and had thanked me saying it
was good publicity for him.
1579. On or about August 2, 2006, R. Cygan posted to the Improvement Project, “Corinne do
you not understand that you right along with Suzanne and several others are being sued?”
She disclosed this before Tower’s suit was filed on August 16, 2006. Having been banned
from AFRA membership, it is reasonable to conclude that she came into this information
via the conspiracy.
1580. On or about August 5, 2006, R. Cygan evidenced a new email address, with Wiseman’s
domain name.

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1581. On or shortly before August 6, 2006, Blair filed a criminal complaint against me with
Oakland County, MI, sheriff, alleging extortion because I had sent him a cease and desist
letter copyright infringement letter. I was investigated and the investigation was
unfounded.
1582. Blair is or was a member of CPS Watch.
1583. On or shortly before August 11, 2006, Blair called my county sheriff and filed a criminal
complaint against me for extortion, and mailed forged evidence to El Paso County
Sheriff, intending to have me arrested and convicted because of a cease and desist
copyright infringement letter I had sent him. I was investigated and the investigation was
unfounded.
1584. On or about August 13, 2006, Connecticut DCF Watch and T. Dutkiewicz sent out a
broadcast email to all online interactive groups,
“Does anyone know what Cheryl Barnes is up to. If you have information, that
would be great. Please respond to my private email address at
Admin@connecticutDCFwatch.com. Thomas M. Dutkiewicz, President, Special
Family Advocate”
1585. Tower filed a defamation lawsuit against me in August, 2006. Other defendants included
fifty Does, Ms. Belou and Ms. Merwin in California for conspiracy and defamation, etc.,
as a result of Merwin’s question on the Improvement Project ¶1571 . This was an
overreaction to a question, done maliciously, and an abuse of process, because I am
immune form liability because I am not the author of the content he contested. The other
defendants were gleeful that I was being sued by W. Tower. Merwin was never served.
Ms. Belou won at trial–which took mere minutes–because W.Tower’s admissions
showed he was not harmed. I have won a default against Tower on my counterclaims.
Tower has failed and refused to respond to all my requests for discovery.
1586. On or about August 26, 2006, Wiseman called my ISP, EarthLink, to make a complaint
about unidentified photographs on my web site attempting to get my web site shut down

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1587. On or about August 29, 2006, Wiseman sent a comment to The Editors at the Family
Advocacy Consumer Advisory thinking it was me,
“im so mad at you i no you the web master suzanne my website is sposed to be the
rocken one not youres mine is going to haft to be better i will make it better you cant
show the proof i dont hav why wont anybudy send me thare proof.”
1588. On or about September 26, 2006, Tower sent me a communication via email, claiming I
had stolen copyrighted property from him and demanded I removed it from a web site
belonging to someone else. I did not own the actual web site or control the content on the
site. He did not identify the contested content nor provide any other information required
pursuant to the DMCA. He subsequently identified the “stolen” content as a photograph
which was published on AFRA’s web site, that contained express permission to copy and
distribute the contents of that web site. The request was specious and intended to harass. I
advised him I was not the owner or author of the web site in question and he would have
to contact the owners.
1589. On or about September 26, 2006, Hinger sent me a communication via email, claiming I
had stolen copyrighted property from him and demanded I removed it from
badadvocates,com. He did not identify the contested content nor provide any other
information required pursuant to the DMCA. He subsequently identified the “stolen”
content as a photograph which was published on AFRA’s web site or other publications.
This photograph was published with the express permission to copy and distribute the
contents of that web site. I advised him I was not the owner or author of the web site in
question and he would have to contact the owners.
1590. On or about September 27, 2006, Hinger sent me an email wherein he admitted legally
purchasing products from me to use in “pending legal action.”
1591. On or about September 30, 2006, Henderson admitted on the Improvement Project, “. .
.a week or two ago, I got commanded by Suzanne not to remove or delete any

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information–destroy evidence. . .” This is an admission of a notice sent to him, which

was sent to all potential defendants at the same time, not to destroy electronic evidence
due to pending litigation.
1592. Henderson never attempted to control the content of any other AFRA member’s or
anyone else’s web site. He was dedicated to controlling my content and my web site as a
pretext to conduct his campaign to eliminate me from competition. Coincidentally, I was
the only threat to AFRA market superiority.
1593. On or about October 6, 2006, Wiseman sent a communication to R. Cygan’s ex-husband
stating he talks to R. Cygan every day and that they are friends.
1594. On October 12, 2006, Wiseman wrote to one my my associates and stated, “. . .shell
started this war and im going to finish it.”
1595. On or about October 23, 2006, AFRA Exec. VP Hinger caused Henderson to send a
message from AFRA to my Improvement Project stating AFRA’s intent to willfully
infringe regarding my 2004 revocation of AFRA’s express license to use my intellectual
property, “. . .once you freely give something, you can not turn around and demand it
back at a much later date. . .it becomes our property to be distributed freely. . .” He
unilaterally rejected the license agreement of his predecessors and publicly expanded
AFRA-sponsored enticements to misappropriate my IP.
1596. On or about December 15, 2006, I demanded AFRA remove a document posted by
Hinger, htd.pdf, from all AFRA groups files sections. W. Tower, Henderson, Hinger, and
AFRA refused to remove it from AFRA groups. This document was an impermissive
derivative work of my unpublished proprietary materials.
1597. Starting on or about December 19, 2006, M. Cygan participated in an online discussion

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about me, wherein he published false and defamatory commentary about me.
1598. Starting on or about December 19, 2006, R. Cygan participated in an online discussion
about me, wherein she published false and defamatory commentary about me.
1599. Starting on or about December 19, 2006, Wiseman participated in an online discussion
Colorado based news/blog site discussing Colorado legal issues. The article and
discussion was about me. He represented himself to be Suzanne Shell during some of
these discussions. He also provided links to his web site, and published false and
defamatory commentary about me. Much of the content purported to have been authored
by him was too advanced for his abilities, indicating it was authored by someone else.
1600. Starting on or about December 19, 2006, Contreras began participated in an online
discussion which occurred at
coloradoconfidential.com/showDiary.do?dirayId=1179#17064, a Colorado based
news/blog site discussing Colorado legal issues. The article and discussion was about me.
Contreras provided information about me, information that originated in Colorado to the
other defendants in this lawsuit.
1601. On or about December 25, 2006, Wiseman wrote on coloradoconfidential.com, “shell is
more then wecome to stay if she would stop steali ng other peoples words and
threating to sue if someone used them and knows full well where she got them from
but shell is shell as she will never change. . .”
1602. On or about December 26, 2006, Contreras wrote on coloradoconfidential.com
expressing thinly veiled envy that I was the focus of the article and the discussion,
“This article IS about [advocacy], but not ONLY about Suzanne. Are you saying that
Suzanne is the only newsworthy part of the article? I think not. This article goes

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beyond Suzanne Shell to the heart of what advocacy is all about...the problems faced
by indigent parents as a result of a corrupt system. It is not ALL about Suzanne Shell,
it is also about the victimization of parents. Even if you want to view it as the parents
have enough problems without getting mixed up with this advocate and getting a
double whammy, it is still not ONLY about Suzanne Shell.”
1603. On or about December 26, 2006, Contreras wrote on coloradoconfidential.com,

“Maybe indigent parents deserve to have their children judicially kidnapped because
they turned to Suzanne Shell, as has been posted here. Maybe the whole point of
advocacy is that we need to avoid the parents Suzanne Shell would take as clients
because not a single one of them is innocent, as has been posted here. Maybe the point
is that Suzanne Shell goes out and looks for parents guilty of child abuse so she'll have
friends who think like her, as has been posted here.”
1604. On or about December 26, 2006, Wiseman wrote on coloradoconfidential.com, “. . if

korn and shell dont like it tough stop running scams. . .I say contact an attorney and
the FBI and the AG about shell and her gang and raise heck untill so meone listens.”
1605. During the coloradoconfidential discussion, Wiseman repeatedly took content I had
written on my own forum, and published it to coloradoconfidential.com under my name,
out of context, making it appear that I was disrupting the forum.
1606. On or about December 26, 2006, Contreras wrote on coloradoconfidential.com,
“The thing I would like to understand most is that if nobody is in this for personal
gain, why is there such a controversy regarding written intellectual property. If
nobody plans to use anybody's stuff for personal gain, and everyone claims the only
purpose for its existence is distributing it freely to indigent parents, what difference
does it make who said it first?”
1607. On or about December 26, 2006, signed by Another harmed by Shell, unknown
anonymous contributor believed to be a defendant and/or AFRA member,
Good one, Dee And to dovetail on your excellent point, Dee, is to add that most of what
Suzanne Shell suggests (and plagiarized by Christine Korn in her "Christine's CPS
Newbie List") is really simply common sense. That is, the stuff that's not actually
illegal that they advise you to do. But, like you say, if the purpose is to help the
indigent, and to spread it far and wide to help people, th en who cares who said it
first? Hopefully, this gives a clearer picture of who is the problem in this movement.

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1608. On or about December 26, 2006, Wiseman wrote on coloradoconfidential.com,

“i have been told by others that they asked Suzanne Shell for help and was told to buy
her book and was not given help and further more the only research mrs.shell has
doen was to steal it from someone eles. and Disliking Suzanne ?? Only the scams is
what i dislike kandy and the need for people like Suzanne Shell is only by people who
dont know that they will lose there kids because of shell and what do you mean
"GLOAT." shell ha s done wrong and by letting people know is not "GLOAT." as you
put it but by making people aware that there are pe ople out there who claims they
know your case better then you do are called attorneys and people who really know
the law not scamers like Suzanne Shell. and people should know when a advocate is
trust worthy and not pulling a scam on you and you Lose your kids ...think about it.”
1609. On or about December 27, 2006, Contreras was participating with many of the defendants
who were commenting on coloradoconfidential.com with their typical defamatory
advertisements about me, my business and products. Dee was engaging them and inciting
them, intentionally baiting them to keep publishing defamatory comments about my
business, my profession and my products on this impartial public forum.
1610. On or about December 27, 2006, Dee admitted, “I know you didn’t write the pleadings.
. .I know you didn’t give legal advice,” referring to my being found in contempt for
writing legal pleadings. Yet she later went on to profusely advertise I was guilty of
Unauthorized Practice of Law (UPL), including on thetruthhistold[dot]com and to this
court in her pleadings. Contreras also told me, “Scream at me Suzanne. Make me
understand why the hell nobody gets the point.” I responded, not screaming, why this
wasn’t about making them get the point, it was about her engaging them in a public forum
purportedly on my behalf. I did not want my presence to disrupt any forums, because that
was the effect the defendants were looking for. She subsequently intentionally kept
fanning these flames until coloradoconfidental had to stop accepting public comments.
1611. On or about December 27, 2006, Contreras admitted AFRA was exploiting Wiseman, “I
understand the dynamics of his relationship with AFRA,” but excused Wiseman’s
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“Even though what you say [about Wiseman being the pawn of AFRA] is true, being
angry at him is just wrong. If could take medication and make it go away, and shose
not to do that, the he could be faulted, but that’s not just the case. He had TWO closed
head injuries. The first left him retarded, the second nearly killed him. Neither injury
was his fault, but both left him vulnerable to the manipulation of thers and unable to
comprehend their motives–or yours.”
1612. On or about December 29, 2006, demonstrating how the defendants attack anyone who
doesn’t attack me, an anonymous contributor to coloradoconfidential.com believed to be
a defendant wrote,
“So what you're saying is Ms. Shel was responsible for the return of your sister and
not your mother's hard work? I've taken a look at that bad advocates page and it's
disgusting. You justify the actions of this group you are involved with? I would be
embarassed to allow anyone to think I knew these people. You may wish to go back
and view that page and then decide in what way that trash benefits anyone.”
1613. On or about December 29, 2006, Contreras wrote on coloradoconfidential.com, “Knowing

how your mind works, I believe that you believe in what you're doing. God loves you,
Billy, and so do I. I know you try to do the right thing.”
1614. In document #59, Contreras admitted that AFRA gave her problems about being
associated with me, sufficient to cause her to remove herself from associating with them
at first.
1615. In document #59, Contreres admitted to turning me in to the FBI for running an
underground railroad, a false allegation.
1616. At this time, she also told me, “Put me on the [consumer advisory] for trying to defend
you.”
1617. I responded, “What did I do to deserve this kind of comment?. . .I don’t even own it
any more and can’t put anyone on or take anyone off. This is an AFRA-inspired
characterization of me, and it looks like you bought into it.”
1618. Contreras responded, “That was out of line on my part and I do owe you an apology for
that remark..”

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1619. Contreras told me, “. . .I don’t understand what you are competing for. I have this
we’re-all-in-this-together-for-the-sake-of-the-parents mentality with the understanding
that advocates don’t charge anything.”
1620. Contreras admitted that AFRA was harassing her for her position, “I got a very terse call
from Bill Tower this morning saying that my support of the [consumer advisory] was
brought to his attention.”
1621. Contreras also admitted that AFRA’s campaign against me was successful,
“The way it usually goes is that someone makes a comment about what “Shell” is
doing. . .I say, ‘Well why is that a bad idea?’ They go off on a tangent about it. . . The
ideas you present make sense, but because you thought of it nobody wants to hear
it–bottom line.”
1622. Contreras also admitted, “I erred [re: Colorado Confidential], from lack of knowledge
and I recognize that now. I’m not posting anything else.” Yet, she did post again,
baiting the defendants to continue disrupting the forum and to publish more and more
defamatory content. The debate on coloradoconfidential.com became very orchestrated,
with defendants–some anonymously–offering what appeared to be point-counterpoint, but
was actually choreographed posturing to arrive at a predetermined conclusion that I was
incompetent, abusive, immoral, unethical and all the characterizations Henderson
preached, much in the same way Henderson was able to make AFRA arrive at his
predetermined consensus. This debate was complete with red herrings and distractions to
insure the casual reader would not recognized it for what it was. Then R. Cygan began
sending messages and responding to them using an alter-ego, in an attempt to copy what
the other defendants were doing. This went on for pages and pages of comments,
devolving into a “let’s all smear Suzanne because of the Consumer Advisory” fest,
complete with pretended supporters becoming convinced after providing their
manufactured lies as reasons to eschew my business and my products, even if offered by

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my associates and licensees. The resemblance in content and style to the paper brawl that
has comprised the defendants’s filings in this lawsuit is remarkable. The fact that I did not
participate in this debate served only to convince them they were right.
1623. On January 3, 2007, Dee posted to AFRA_EAGLE, “I had to take some time to do some
soul searching, but, yes, I am back. . .Hi Ann [Durand], Billy [Wiseman], Tom
[Dutkiewicz], Kathy [Tilley]. . .” She stated she believed in what AFRA leadership was
doing.
1624. On or about February 2, 2007, Contreras agreed in AFRA_EAGLE that Ann Durand was
“awesome and a very wise woman.”
1625. On or about February 15, 2007, Contreras posted on AFRA_EAGLE, “Ann [Durand] is
one person whose advice I would take very seriously. I watched her posts of over a
year before having peroneal contact with her, and I’m convinced she knows what she’s
talking about.”
1626. On or about February 17, 2007, Contreras concurred with Durand’s advice to write follow
up letters, advice from my seminar on AFRA_EAGLE. She followed up on March 2,
2007, with several messages offering more case specific legal advice using methods from
my proprietary information.
1627. On or about March 3, 2007, Contreras expressed her wholehearted support and agreement
on AFRA_EAGLE with Kiefer’s advertisement to all online groups where he published,
“Some of the Owners [familyrightsradio.net] and Operators [CFC] Are Less Than
Honorable People.” She expanded on that, “I assure you, he was being cautious.”
1628. On or about March 25, 2007, Contreras indicated her long-term affiliation with the
defendants, including during the time she tried to obtain my information from Ms. Korn
and when she was purportedly supporting me on coloradoconfidential.com, when she
posted to AFRA_EAGLE, “After all these years, I couldn’t imagine a day without

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Kathy [Kidwell] or AnnD [Durand]. . .I’ve come to know and love.” Durand responded,
“Dee, you are amazing. You’ve been so supportive and a great source of information. I
think you k now we luv ya bunches.”
1629. Contreras insisted she had free speech rights, which I did not dispute. She was missing
the point of my request that she stop speaking on my behalf and causing disruption on
public fora. She accused me in an email on April 6, 2007, me of ridiculing her for
supporting me. She was referring to a comment she made on badadvocates.com to which
the Editors responded. She said, “. . .I won’t make that mistake [of supporting you]
again. The victim stance is laughable, but not believable.” I told her if she didn’t want to
be discussed on that site, why did she post a comment? It wasn’t my site, so I wasn’t
responsible. She responded with taunting and abuse, and insisted I did own it.
399. On April 6, 2007, I also advised Contreras,
“. . .whatever you said in a forum regarding me and my work was without my
authorization, and therefore, entirely your responsibility.. . .you got a lot of critical
facts wrong which caused me harm and continues to require that I engage in damage
control. In response to your causing me so much harm, I never published anything
about the horrendous misrepresentation by you–no matter how well or ill motivated it
was–on any public forum nor did I ever attack you back channel when you saw fit to
refuse my request to stop engaging Billy et al. . .Do you get it? You were speaking for
me in a public forum without my permission. I asked you to stop because it was
harming me and because I did not want to be represented in that manner. You
stubbornly refused to stop.”
1630. Subsequent to this, Contreras began back channel harassment, blaming me for things I
had nothing to do with, saying I called her a liar when I didn’t, accusing me of owning the
Consumer Advisory, insisting I had no right to control my own publicity or business, and
getting personally offended when I disagreed with her. She stated, “The only thing this
nonsense shows consumers is that they need to be careful not to make the mistake I
did in believing in the great and powerful Wizard of Shell.”
1631. On May 14, 2007, I was contacted by ReputationDefender, Inc. on behalf of Wiseman

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with a demand that I remove content about him from my web site at
http://home.netcom.com/~dsshell/id16.html. This web space was free for me, and since I
wasn’t using it, I donated it to the publishers of the Consumer Advisory. I advised
reputation defender that I did not own the publication, and advised them to look at
Wiseman’s libelous web site. They dropped Wiseman’s demands against me.
1632. At this time, I discovered AFRA web site provides or provided advertising space on
behalf of Wiseman’s business at http://members.familyrights.us/oklahoma/index.html.
Henderson is the webmaster and the only person with the ability to add or remove content
from this site.
1633. On or about March 17, 2007, Bryan contacted me via email, with the subject line, “Stop
attacking online free speech!” expressing his outrage that I was counter-suing Internet
Archive for copying my web site. He threatened to boycott me unless I dropped the suit
and issued an apology. He also stated he copied my entire web site and printed out a page
as an act of civil disobedience.
1634. On or about May 18, 2007, on AFRA groups, Henderson advertised he was back as
AFRA’s web master and founder, and offered to provide the history of the family rights
movement stating he had lived it since 1999. His representation was a rewrite of history,
full of disinformation and outright lies designed to promote his agenda against me and my
business because I refused to let AFRA take control of my business or my property.
1635. On or about May 28, 2007, Dee posted on USA_EAGLE, “Billy! [Wiseman] You’re here!
Glad you decided to stay on board.” Durand responded, “Billy adores Kathy. Of course
he’s here.”
1636. In response to Tilley’s refusal to bend to AFRA’s will regarding her online interactive
group and her withdrawal from AFRA BOD and change of group name, Dee wrote on
USA_EAGLE, under the subject line, “Bill / Dennis.”

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“When I joined AFRA_EAGLE, my understanding was that each AFRA group was
individually run by its “owners”. The “free states” were allowed to govern themselves,
but had specific guidelines that had to be followed (i.e., nothing that could give AFRA a
bad name). This understanding was supported by the fact that each group was run
differently--hence the fact that EAGLE was the only one I felt met my needs. If, when,
or how that changed, I don't know. This dispute arose despite the fact that Kathy ran
this group in a manner that did not give AFRA a bad name. It arose when someone (I
thought the BOD, but it has now been posted that it was actually two people and not
the BOD) made the decision that any group bearing the AFRA name had to post what
they wanted posted. For the first time, it was “my way or the highway”. Kathy took
the highway, and I'm proud of the strength she showed in refusing to compromise her
values.
“It disturbs me that AFRA_EAGLE was dissolved, only to have the name revived
by AFRA and/or members or the BOD of AFRA. Kathy made a good name for
AFRA_EAGLE, and if the revived AFRA_EAGLE is run in the manner as has recently
been proposed, I feel that would reflect poorly on Kathy's work. I think it is an
improper move and intended to capitalize on someone else's work. This would imply
that certain negative things that have been said about the AFRA leaders are true and
valid claims, and does nothing but blacken the reputation of AFRA. I sincerely hope
they have the decency to rethink this move.”
1637. On or before June 3, 2007, upon information and belief, Contreras and/or other
defendants posed as Wiseman to respond to the questions in Bryan’s interview, “An
interview takes you farther down the rabbit hole” published at
http://www.binaryfreedom.info/node/139. In this interview, the defendant made many
false advertisements about me and my business identical to the false advertisement made
on AFRA and CPS Watch groups.
1638. On or about June 6, 2007, Bryan published an article purported to be an interview with
Wiseman as the owner of thetruthistold[dot]com.“This is an interview with the owner of
http://www.truthistold.com, an anti-Suzanne Shell site.” This interview was responded
to by other defendant(s) posing as Wiseman, including but not limited to Contreras.
Wiseman is not capable of the responses shown in this interview. Bryan’s questions were
phrased to indicate his support of Wiseman’s web site and the defendants’s campaign
against me, including, “Why have you chosen to give up your valuable time to fight

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Suzanne?” “Is Suzanne a threat to society? If so, why?” “Somebody has 5 minutes.
What is the best thing they can do in that five minutes to fight Shell?” His joining
forces with them and his publication of their false advertising was intended to bolster his
own anti-copyright campaign against me.
1639. Wiseman submitted this article to Digg.com stating he had express permission from
Bryan to distribute it.
1640. On or about June 7, 2007, Bryan submitted a comment to The Editors at
badadvocates.com, saying “I thought you might want to add me, I’ve been doing a
campaign against you for a while. http://binaryfredom.info/node/136. Comrade Ringo
Kamens. His link goes to a page authored by him that asks,
“Did you view a copy of her website? Did it get put in your browser cache? Did you
copy it to another directory? Did you print off a copy? Did you view her site in the
frame of another site? Did you visit her site from digg? If so, you are, according to
her, violating the law. Tell her you did it so she can sue and arrest all of us!”
1641. On or about July 20, 2007, Contrereas posted on USA_EAGLE, “Oh, Dennis [Hinger], I
love you. See you guys, I told you you could count him him when you need him.”
1642. On or about July 22, 2007, on TalkLine, tp4pc wrote, “. . .we support and condone the
actions of AFRA, but do not support or condone the actions or verbage ofMs. Shall
and/or her band of miscreants.” Contreras responded, “Well spoken.”
1643. On or about July 25, 2007, Contras told me, “I won’t associate with you because of the
Consumer Advisory.” She believed AFRA’s propaganda that I had control over it and
that the original articles I had written were false.
1644. On or about July 25, 2007, I received information that Contreras was in regular telephone
contact with Wiseman, and that during this particular conversation, she revealed that
“someone” was about to do something that would finally shut me down for good, even
earning me jail time. She made a specific reference to kiddie porn.

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1645. On or about July 29, 2007, Contreras joined the Improvement Project.
1646. On or about July 30, 2007, Hinger described the conspirators’ attempts to eliminate me
from the market on AFRA_Talkline as,
“Ignore them, the courts will be ridding us of them sooner than they think. . .go
about your business and ignore the knats [sic] circling overhead, they are about
to get swatted and swatted hard. . .”
1647. On or about July 31, 2007, in the context of a discussion about me on AFRA_Talkine,
Hinger stated, “I don’t get mad, I get even.”
1648. On or about July 31, 2007, Contreras published on TalkLine a long discussion about how
I was a stalker, untrustworthy, and other derogatory false commentary.
1649. Hinger responded and said the consumer advisory had been shut down by EarthLink,
claiming it was mine. Contreras responded, “WHAT!?? . . Now THAT is good news.”
1650. Contreras is exploiting Wiseman, and authoring articles on his web site. She has authored
false advertising and caused it to be published on his web site including but not limited
to:
a. that I was removed from Colorado legislative hearings and barred from attending
future hearings
b. that I own and author the consumer advisory
c. that I run an underground railroad
d. that I have been convicted of UPL
e. that I am a liar
f. I am barred from assisting individuals with child welfare cases
g. that I am trying to destroy AFRA
h. that I should not be allowed to charge for my products
i. that my proprietary IP was not unique
j. that I plagiarized the work of others and called it my own

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k. that I committed libel and slander

l. that I am stalking and harassing the defendants and others
m. that I engage in criminal activities
All of this constituted information she was in possession of at the time she fraudulently
represented to Ms. Korn that she wanted to sponsor a seminar. At that time, to all
appearances, she did not believe any of these claims.
1651. On or about July 31, 2007, on TalkLine, Hinger was engaged in a discussion about me
with other members, including the defendants, and showed his malice when he stated,
“Personally, I prefer driving the B**** nuts and causing her to continue eating herself
to death.”
1652. I applied to join CenCom on October 1, 2007, as well as all other AFRA groups. All of
my applications were denied.
1653. On or about October 1, 2007, in response to a copyright infringement notice to AFRA
BOD, Tower published to AFRA groups,
“Ms. Shell has demanded membership on all AFRA Groups claiming she needs to
protect her “IP”. In response I have denied her membership to any and all AFRA
Groups. I have kind of been hoping that she just would go away and leave us alone, but
she refuses to do that. I believe this little rant/act will only further harm her
creditability and this is the reason no one want to associate with her and her little
group.”
1654. On or about November 10, 2007, Sheila Vives wrote on CPSWatch,

“Apparently someone posted a copyrighted article of [Shell’s] on their site without her
permission and without giving her proper credit. So she is out and about and keeping
an eye on things out here. This is where it gets back to the teamwork thing I
mentioned. Copyright or not, if it helps parents then share it !!! I don't think any of us
can be ‘self-centered’ when we all are subject to these kind of government abuses. Did
Suzanne forget that she was once fighting the system for her kids ? She likes to rant
and rave but does she really care about others out here ?”
1655. On or about May 23, 2008, Henderson was asked questions about this anti-Shell
conspiracy by users on the Improvement Project, and whether or not he supported it or

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condemned it. He inferred blame belonged to the victims of this conspiracy.

1656. On July 11, 2008, Henderson sent me an unsolicited email demanding the removal of
badadvocates.com, which he erroneously considered to be mine, from the Internet. In
exchange, offered to get defendant William Wiseman to take the “shit out of his site.” I
told him the subject publication wasn’t mine to remove. However, this did prove he had
the ability to control the content of Wiseman’s web site, thetruthhistold[dot]com.
1657. On July 12, 2008, Henderson sent me an unsolicited email requesting my assistance with
new AFRA members who needed an advocate in Arizona. I advised him that the Arizona
organization advised me they would not do damage control on AFRA cases. This refusal
made him angry.
1658. On or about August 30, 2008, Swallow falsely advertised on CPSWatch ,
“She a spy and has others among her such as Kay Henson, Effie, and more beware of
these individuals. SS herself usually lies very low to the ground..you know like a
snake, she has her groupies handle all the drama........She is good at hiding and
stalking and tending to her chicken farm where she needs to stay......She has many
lawsuits pending against her even with the internet, as well as her site gets shut down
on a weekly basis I just watch and LMAO....”, as well as her site gets shut down on a
weekly basis I just watch and LMAO....”
1659. On or about August 31, 2008, Swallow falsely advertised on CPSWatch, “And as far as
SS has done "some good work"....No she hasnt she done more to screw up the
movement and make an eisode of Jerry Springer at anything shes done.” Consumers
believed I had been on Jerry Springer, which never happened.
1660. On or about October 26, 2008, Tilley responded to a question about anyone having
personal knowledge about my work on USA_EAGLE, “She is not with AFRA. Brother
Cletus (Kiefer) can shed light on this more then I can. . .I only hear negativity, so ask
the above people who [know] her and of her.” Evidently Kiefer was considered a reliable
repository of information about me.
1661. On or about March 27, 2010, A. Dutkiewicz sent me a handwritten letter purported to be

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an apology for “engaging [me] and [my] goomba’s.” In the same time frame, she hand
wrote an apology letter to Effie Belou. In this letter she admitted to authoring content on
Wiseman’s thetruthhistold[dot]com site. She accused Effie and me and our associates of
being responsible for the suicides of Michelle Bassette and Paula Mackintosh. This is one
of the false advertisement on thetruthhistold[dot]com.
1662. On or about March 25, 2010, A. Dutkiewicz hand wrote an apology letter to Kay Henson,
wherein she admitted calling EarthLink to get my Internet service shut down.
1663. The defendants have been engaging in the wholesale spoliation of electronic evidence
relevant to this case, including but not limited to destroying evidence of the conspiracy.
Incriminating publications have been removed from known locations on the Internet.
Groups containing evidence in the archives have been deleted or the incriminating
messages have been deleted. I have received reliable information from an associate of
theirs that incriminating evidence has been/ is being deleted from their respective
computer hard drives.
1664. The defendants committed multiple overt acts in furtherance of the common design and
each defendant committed at least one act in the furtherance of the conspiracy as
described herein.
1665. As proximate cause of the conspiracy, I have suffered injury and damages including
damage to my business and my business reputation, loss of my professional reputation,
deprivation of my property and my rights under copyright to control the uses of that
property and exploit that property, loss of stature in the business community, loss of my
business and livelihood, loss of goodwill, diversion of sales, continued, ongoing and far-
depreciation in the value of and ability to sell and license my work, and lost profits and/or
opportunities.

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Eleventh Cause of Action

Antitrust / The Sherman Act
15 U.S.C. §2 et. seq
forth herein.
1667. A combination or conspiracy among all of the defendants existed as described in the
cause of action for Conspiracy and in the rest of this complaint.
1668. Another purpose of this conspiracy was to engage in price-fixing of the products offered
to the public by me and by the defendants.
a. On or about April 15, 2005, on Directors, Tower said, “The thing we need to
remember is that it is not about making money for us it is about families first
and foremost.”
b. On March 24, 2005, Keifer responded to CenCom member Stratton’s statement,
“I am offering my hard earned knowledge and expertise, which is worth a fortune,
to anyone who wants it free of charge,” with “PTL67 Did I Hear It's Free. I
wouldn't Have Any Other Way My Self!”
c. On or about April 16, 2005, AFRA BOD Martin agreed with AFRAs posture on
charging for my work,
“I agree with Brother Cletus that it appears she's working for her own
self-aggrandizement and money rather than to try to benefit the greatest
number of victims.”
d. On or about August 14, 2005, Swallow advertised to forty recipients including

groups, “we still have individuals claiming to have more power than GOD
hisself, so that they can make a buck.”
67
Praise the Lord.

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e. On or about April 4, 2006, A. Dutkiewicz wrote to me,

“I THREW you off NEPAN because personally I think an Advocate that
would take a families money like you have done over and over ,without
getting any result for them is just DISGUSTING!!!!!!!!!!!!!!”
f. On or about May 30, 2006, T. Dutkiewicz advertised to all AFRA groups, talking
about me and my associates, “We must be a threat to their very survival,
integrity and their ability to rake in money.”
g. On or about April 26, 2007, a defendant anonymously (as sHellscammer)
published on Libervis.com that I was a money grubbing scammer.
1669. The defendants determined that the products and services offered should be made
available to the public for free.
a. On or about November 4, 2004, the defendants’s posture on making services
available for free had spread to others, as evidences by this comment on CenCom
by an AFRA member,
“I believe people want advocacy to be, and remain, as total volunteerism and
not ran [sic] as a BUSINESS venture. . .We believe that advocacy, and training
for advocacy, should always remain on a volunteer basis and remain free,
forever.” She stated in a subsequent message, “advocacy as a business venture
is, in my opinion, unwise and will poison the waters. . .Advocacy of this type
should not be professionalized and institutionalized.”
b. On or about February 9, 2005, on AmericanFamilyRightsAssociation Yahoo!

Group, a member advertised,
“Advocates DONT take money from people there trying to help, They
don’t BED for money either, They DON’T have DONATE Buttons all over
there websites, I Never seen anything like this before, ITS DISGUSTING.
. .[Shell] is not worth shit, All she is doing is going to SELL all this crap
at her Seminar when she should be giving it away”.
c. On or about March 8, 2005, Kiefer advertised on his Internet radio show that my
advocates charged fees for their services and the public should avoid them. When

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he was contradicted by a caller, he disconnected the caller. This radio show was
widely publicized on AFRA and other groups. The recording of this program is
available online on Keifer’s radio show web page, familyrightsradio.us.
d. On or about March 9, 2006, Baez published on CenCom,
“As for Georgia Family Rights, we welcome anyone for our training.
But....there are certain rules for those who want to be affiliated with us
as family advocates. One of those rules is not charging for advocacy
services.”
e. On or about March 14, 2006, Wiseman published on CenCom that I charged for
advocacy services, which was “not proper.”
f. On May 10, 2006, thetruthistold[dot]com published a statement by “anonymous”
which said, “she also charges for her seminars. . .she is slanderous and a
danger to the family rights cause. anyone dealing with her must be
carefull.[sic]”
g. On or about July 16, 2007, Hinger advertised on AFRA groups, “AFRA does not
sanction advocates or the accepting of payment for anybody helping with cps
cases.”
h. See ¶1155.af Barnes complaints about crafting an income for myself.
1670. The defendants subsequently made their products (and my products that they were
passing off as their own) available to the public for free.
a. AFRA has a legal notice posted on the AFRA web site that says, “We do NOT seek
donations or membership fees of any kind.”
b. When CPSWatch shut down in 2003, they were selling Parent’s Guide to the
System for $9.95. When the group was resurrected after a hiatus of several years,
they gave the book away for free. This book was plagiarized from my content.
c. On or about July 6, 2004, AFRA BOD McQuaid reinforced Henderson’s posture
on my work,

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“Any work I do to shut down child protection, Children's Aid in my

locality, may be freely copied or repeated by others. . .It appears that
others68 who assert rights to their method of advocacy are not
encouraging the elimination of child protection abuses, but promoting
their preservation, at least to the degree that their advocacy is
effective.”
d. On or about July 6, 2004 AFRA BOD Simpkins stated he was one of my
staunchest supporters, and in view of this, “I therefore must abstain from
involving myself in any punitive action against Mrs. Shell.” This shows that the
BOD was intending and planning punitive action against me even though I was
not, at this time, a member of AFRA and was a competitor of AFRA.
e. Henderson responded to this by stating, “We cannot operate with such a
powerful loose cannon... er.. out of control?” He stated he thought I had
Alzheimer’s and his desire was to “pull my fangs and remove my power.” My
power was in my Intellectual Property and in my skill and knowledge.
f. On or about July 27, 2004, On CenCom, Jack Stratton wrote,
“I will be with you all and continue to fight the fight without any
concern about whether I'm getting CREDIT for my actions. If I get
banned, it's been a priviledge to know you all. I just couldn't take this
insider destruction of the movement anymore. If anyone ever sees
anything written by me you consider helpful, whether it be books or
antything else, feel free to publish it all over the world.”
He did not get banned. Others supported this posture during this discussion.
g. On or about September 8, 2004, in response to Kay Henson advertising a training
seminar featuring me as the speaker, A. Dutkiewicz and Connecticut DCF Watch
advertised on JFF that they offered the same information as mine for
“FREE YES FREE FREEE FREE info available... you DO NOT HAVE TO
PAY Suzanne Shell and her Shisterism network for the info. . . .IN FACT
we GAIN NO NOT ONE BIT OF PROFIT... as it should be..... Family
68
The context of this discussion was Suzanne Shell.

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Protection belongs to people who protect their blood born not to

ADVOCATES who renounce their own for PROFIT!!!!!!!!!!!!!!!!!!!!!”
h. On or about May 19, 2005, R. Cygan published on her web site,

“I am a successful advocate not thanks to any training from [Shell] and
I encourage others to learn and teach others for free. This certainly
would piss off the Almighty Suzanne Shell I mean after all if I go around
doing this too much I will keep her from snowballing people into paying
her money for training they can easily get on their own or from others
for free.”
i. Sometime before February 10, 2006, A. Dutkiewicz advertised on NEPAN, “our
handbook is for educational purpose and we do not charge for it AND WE ARE
AFRA members................. So Suzanne can BITE me . . .”
j. On or about March 14, 2006, AFRA member Weston advertised on CenCom,
“There is going to be a free training seminar in June or July in Illinois I will
find out the dates and let you know. It will be 2 days.”
k. On April 12, 2006, A. Dutkiewicz published on bashing_shell, “When we had our
[convention] at Foxwoods, (in November 2005) we charged no money, took no
money.”
l. On or about May 30, 2006, IFAC advertised a training seminar, “Our seminar is
*Free but you must Register with us to assure a spot as seating is limited.”
m. On or about December 3, 2006, in response to a question by an AFRA group
member about another organization requesting payment for goods and services
said, “Credible Organizations Like AFRA do not ask for payment for providing
help for fighting CPS. Only Bar Certified attornies [sic] and paralegals working
under an attorney should be paid for their services. AFRA does not condone or
sponsor Family Rights Advocates for hire.”
n. On or about January 20, 2008, Henderson advertised on USA_EAGLE and
AFRA_SWAT, “And by the way, regarding money: AFRA does not charge for

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anything. It’s all free because that’s what our clientele can afford. Justice
should not have a price tag.”
1671. When I charged for certain of my products and services, the defendants attempted to
eliminate me as competition by engaging in the acts describe herein.
1672. The defendants also stole my copyrighted intellectual property that I license for a fee,
without paying for it, and gave it away to the public for free, sometimes as verbatim
content, sometimes after altering it and creating derivative works from it without given
credit to the source.
a. See ¶1670: defendants giving my information away for free.
1673. The defendants also encouraged the public to boycott and eschew my and my associates’s
products, services and training events.
a. See ¶1176.w re: T. Dutkiewicz and Hinger call to blackball me and my products.
b. Every time a seminar would be announced where I was a speaker, the defendants
would begin a smear campaign to convince consumers to eschew the seminar.
This occurred on all forums serving this market.
c. On or about September 5, next seminar attendance will be low. At this time
Swallow also stated that she had attended my “sham seminars (what a waste).”
d. On September 8, 2005, Swallow advertised on
Justice4ChildrenParentsAndFamilies_NW_FL court watchers of Florida,
“I WARN YOU ALL TO STEER CLEAR OF THIS OR YOU WILL ENDANGER
YOUR FAMILY AND THE FAMILIES OF OTHERS BY AFFILIATION WITH
THESE DAMGEROUS PEOPLE...THEY CARE NOTHING ABOUT THE
MOVEMENT,PROTECTING FAMILY THEY ARE IN IT FOR MONEY AND
THEIR OWN PROFIT.”
e. On or about September 8, 2005, Swallow advertised on nine AFRA and non-

AFRA groups, “
”People to attend these Seminars Suzanne Shell is requiring background
checks, Criminak Reports, Mental heath evaluations...a background

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similiar to what DCF would use in an investigation..Then note she will

use this to Plaster all over the Internet the second you do not partake in
CRIMINAL ACTIVITY...Not Advised to attend or get involved with FRAI
Suzanne Shell or affiliates..Others have been harmed in the past
numerous previous attendees Regret this decision. Deemed as dangerous
nd harmful.”
This was not true. Anyone applying to be a certified advocate had
to have a background check. This was held confidential. I never
plastered anything all over the Internet. The defendants would take
my private communications to them and plaster them all over the
Internet.
f. September 9, 2005, Swallow published to over forty AFRA and non-AFRA
groups that I teach seminars only for profit and I am not qualified, See ¶1155.h.
She also stated, “FRAI her so-called bullshit Institute" had attorneys working
for them..LOL Robbing clients to be more exact.”
g. September 9, 2005, Swallow advertised to steer clear of FRAI seminar
See¶1155.j.
h. On or about November 21, 2005, Swallow advertised to a list of eight individual
and group recipients, including Henderson,
“WARNING DO NOT ATTEND THIS SEMINAR..STEER CLEAR OF SUZANNE
SHELL, KAY HENSON, EFFIE AND ANYONE ELSE CURRENTLY
ASSOCIATED WITH SUZANNE SHELL..SHE IS DANGEROUS TO FAMILIES
AND THE MOVEMENT HER ONLY GOAL IS MONEY AND PROFIT..OH
BTW DID I MENTIONED SHE SOLD FAMILIES OUT AS SHE WAS
RECIVING A KICK BACK ON INSTIUTE CASES.”
i. On December 2, 2005, Swallow advertised on FLFamRights group,
”Suzanne Shell is a Joke,,FRAI is a bogus Institute to lure attorneys
whom have already presumed parents are "guilty" as DCF alledges and
yet still steals their money then lies to remove themself from the
case..Beware and I will reward the groups numerous ones with
documentation from Jim's ex clients and their contact with jim, Suzanne
as well as Kay..Brenda (Certified Family Rights Advocate
Michigan/Florida) Proudly Not under Direction of Suzanne Shell/Non-

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Affiliated with FRAI.”

j. On or about January 5, 2006, in response to an advertisement for a seminar,
Swallow advertised on four groups, “THE SEMINAR IS A WASTE OF TIME
MONEY AND EFFORT,,,,”
k. On or about January 9, 2006, in response to the advertisement for the Connecticut
Family Law Conference, Swallow published to falsely_accused group,
“Having attended 3 Shell Seminars and having previously been affiliated
with Family Rights Advocacy Institute. I can assure you and anyone else
that it is Bogus. First and Foremost Certification is not required in any
State as Advocates are generally not recognized in the Courts.69. .Shell's
Seminars are Bogus an effort not for the Movement but for her own
Selfish Financial gain and notority. She will use you and then turn on
you like a snake.”
This missive went on to falsely advertise that I had participated in criminal
activity, encouraged advocates to take part in criminal activity, engage in
UPL, protect unethical attorneys, steal her property and take a gun to a
seminar and committed credit card fraud, the same false and defamatory
claims as made in other groups and times. These were all false.
1674. On or about January 13, 2006, in response to an advertisement for an upcoming
conference, Swallow advertised,
“Suzanne's "Certification" Is'nt worth the paper it is printed on.
Have'nt you ever gotten an award like "Grandparent of the Year"
"Mother of the Year" Award...you can but them at many gift/card
shops....Well thats what this can be compared to signed by Suzanne
Shell and Kay Henson... Advocates are not recognized in Courts Period
(Except for ADA Advocates) not in our dependency courts unless you
are with the GAL Program. A few select groups have been providing
training with a little certificate of completetion..no biggie means nothing.
But Suzanne Shell is not the only one and other are in the process of
organizing Better more Effective Training which does'nt require you to
cease affiliation with other groups, sign contracts, or obligate you to
partake in "Shady business". I will let you know more as information
69
Partially true, but misleading.

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becomes availible (PS It is FREE not at Shell's Expensive Rates that is

bizarre) Why is it FREE because people that care donated anything and
everything to make it FREE so that properly trained people can help
save our children.”
1675. On or about January 14, 2005, Swallow disseminated my strategies to a consumer

on childprotectionreform70 group and stated about my business,
“Ps steer clear of Kay Henson, Effie, Rose, Suzanne Shell or anyone
associated with FRAI (Family Rights Advocacy Institute). These are
"Shady People" to associate yourself with. Please be careful...”
a. On or about January 16, 2006, Swallow advertised on childprotectionreform
group, “I still advise all to be warned for the safety of their family to steer
clear of FRAI, SS, Henson, Effie and Rose...Enough said.”
b. On or about January 16, 2006, on DCFReformFL, Swallow advertised,
“Your choice, its up to you..Risk your children by attending a seminar
and becoming part of a "Jim Jones "Cult" or protecting your family
seeking help outside the Institute.”
c. On or about January 19, 2006, Swallow responded to an advertisement for the
conference on AFRA groups, “As most of us are aware SS is having one of her
"Yearly" Money Making Seminars again so she can take another cruise.”
d. On or about November 11, 2008, Barnes advertises that I crafted out an income
for myself and disparaged my products and profession so consumer would eschew
them. See ¶1155.af.
1676. This combination or conspiracy was an unreasonable restraint of trade or commerce.
1677. The trade or commerce restrained was interstate or international in nature or the
conspiracy affected interstate or foreign trade in that it deprived the consumer of choices
in the market. It eliminated me and my bushiness and my associates businesses from the
70
One of the most highly regarded (at this time) online interactive groups, with over a
thousand members. Swallow’s campaign caused them to ban me from participation in this group,
and it has since degenerated into a “bash Suzanne” alliance.

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competition and preserved the businesses of the AFRA defendants and CPS Watch.
1678. It left the consumer with only inferior choices for products in this market, because my
products were not available, or if they were available, came with the unconscionable
price tag of potential stalking and harassment by the defendants.
1679. As proximate cause of the antitrust conspiracy, I have suffered injury and damages
including exclusion from the relevant market, damage to my business and my business
reputation, loss of my professional reputation, deprivation of my property and my rights
under copyright to control the uses of that property and exploit that property in this
market, loss of stature in the business community, loss of my business and livelihood,
loss of goodwill, diversion of sales, continued, ongoing and far-reaching copyright
infringement, effectuation of new and further infringements, depreciation in the value of
and ability to sell and license my work, and lost profits and/or opportunities.
CONSTRUCTION
1680. This complaint is intended to be construed in it’s entirety and in toto , with all relevant
supporting facts to be applied as appropriate to the generally descriptive statement(s),
whether the supporting fact appears before or after the descriptive statement. I have tried
to organize properly and cross reference as appropriate but there may be some errors and
omissions with cross referencing and organizing.
1681. The facts cited in this complaint include numerous instances of actual events, but not
every instance of the act or actor committing the tortious act is cited due to the
overwhelming quantity of tortious acts committed in this conspiracy. I selected the most
significant events and acts.
1682. I reserve the right to correct errors. This is a long document, I had a short time to
complete it. Any errors are innocent and inadvertent.
RELIEF

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(Damages and Injunctive Relief)

Wherefore, plaintiff Shell demands trial by jury and judgment from the Court as
follows:
a. To accept jurisdiction over this case;
b. To immediately issue protective orders requiring all defendants who intend to
submit any of my proprietary content or information related to my business
methods for this Court’s consideration to submit them under seal to protect my
trade secrets from public disclosure; and
c. To order parties and counsel for this case that any content submitted under seal to
be held confidential and not used or disclosed by them; and
d. To award damages against all defendants, jointly and severally, for copyright
infringement, vicarious copyright infringement and contributory copyright
infringement for a sum of money equal to the amount of damages and/or losses
Shell has sustained or will sustain; or
e. In lieu thereof, should Shell elect an award of statutory damages, pursuant to 17
U.S.C. § 504(c) against the defendants, jointly and severally, to be increased to the
maximum permitted by law, for each act of willful, copyright infringement,
vicarious copyright infringement and contributory copyright infringement;
f. To award damages against all defendants, jointly and severally, for a sum of
money equal to the amount of damages and/or losses Shell has sustained or will
sustain, for engaging in a pattern of racketeering activity, and to treble the amount
of said damages pursuant to 18 U.S.C. § 1964(c) and C.R.S. § 18-17-106(7).
g. To award damages against Ann Durand and Brenda Swallow equal to the amount
of damages and/or losses Shell has sustained or will sustain as defined in the
contract and security agreement, plus triple damages, for breach of contract

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pursuant to the agreement they expressly entered into with Shell by virtue of their
signing that contract and,or attending the seminar;
h. To award damages against the defendants, jointly and severally, equal to the
amount of damages and/or losses Shell has sustained or will sustain as defined in
the copyright notice and security agreement on her web site, for breach of contract
when they copied her web site content without her permission and without
prepaying the posted license fees; and
i. To award damages against the defendants, jointly and severally, for a sum of
sustain for engaging in tortious interference with contractual relationships; and
j. To award damages against all defendants, jointly and severally, for a sum of
sustain for engaging in unfair or deceptive trade practices, plus triple damages and
attorneys fees and costs as authorized by state statute, and to enjoin the defendants
from engaging in Unfair or Deceptive Trade Practices;
k. To award damages against all defendants, jointly and severally, for a sum of
sustain for engaging in false advertising and to enjoin the defendants from
engaging in false advertising; and
l. To award damages against all defendants, jointly and severally, for a sum of
sustain for the defendants’s anti-trust practices, plus triple damages and attorney’s
fees and costs as authorized by statute, and to enjoin the defendants from engaging
in antitrust activities and/or to seize the defendants’s businesses; and
m. To award damages against all defendants, jointly and severally, for a sum of

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sustain for engaging in a conspiracy to commit the wrongs named in this
complaint; and
n. To award punitive damages pursuant to Colorado statutory or common law; and
o. To enjoin all defendants, from all future copyright infringement and theft of
intellectual property and theft or misappropriation of trade secrets, and to require
them to pay license fees or to negotiate fee reductions or waivers of license fees
for its original acquisitions, and to obtain written permission from and/or to
establish an affirmative ‘opt-in’ policy and technology which is executed solely by
the copyright owner, before copying, storing or publicly displaying anyone’s
intellectual property in any format anywhere; and
p. To enjoin Billy Wiseman and Wiseman Studios from publishing anything on the
Internet about the plaintiff or any of the plaintiff’s associates, due to his cognitive
disability, without his proposed content first being verified for accuracy and the
absence of other violations related to this complaint by a qualified professional or
designee of this court, and to enjoin him from carrying out any instructions,
commands or suggestions from any of the defendants, their agents, associates,
members and assigns; and
q. To enjoin defendants from any publishing or uttering any false advertisement
about me, my business or my products and order defendants to print retractions
and apologies for each violation in the market and forum where the false
advertising or other violation was originally published; and
r. Issue appropriate orders pursuant to 18 U.S.C. §1964, including, but not limited
to: ordering all defendants, to divest themselves of any interest, direct or indirect,
in the enterprises known as American Family Rights Association, Illinois Family

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Advocacy Coalition, National Association of Family Advocates, Georgia Family

Rights, Inc., Families at Risk Defense Alliance, Connecticut DCF Watch, CPS
Watch, Inc., and Wiseman Studios; imposing reasonable restrictions on the future
activities or investments of the defendants, including, but not limited to,
prohibiting all defendants, from engaging in the same type of endeavor as they
have been engaged in, the activities of which affect interstate or foreign
commerce; or ordering dissolution or reorganization of American Family Rights
Association, Illinois Family Advocacy Coalition, National Association of Family
Advocates, Georgia Family Rights, Inc., Families at Risk Defense Alliance,
Connecticut DCF Watch, CPS Watch, Inc., and Wiseman Studios; and
s. To award prejudgment interest on the amount of damages and/or losses that Shell
has sustained; and
t. To award all costs of litigation incurred by Shell, including her reasonable
attorney’s fees and experts’ fees, pursuant to 18 U.S.C. § 1964(c) and § 18-17-
106(7) C.R.S.; and
u. To provide Shell with opportunity to correct deficiencies or errors associated
with her pro se pleadings in the interests of justice; and
v. To award such other and further relief as the Court deems just and equitable.
Respectfully Submitted April 7, 2011
/s/ Suzanne Shell
Suzanne Shell - pro se
14053 Eastonville Rd.
Elbert, CO 80106
719.749.2971
dshell@gmail.com

page 398
Case 1:09-cv-00309-MSK -KMT Document 464-1 Filed 04/07/11 USDC Colorado Page 1
of 67
Table of Contents of Exhibits
Exhibit A - copyright registrations
Exhibit B - Message transmission histories of defendants’s groups.
Exhibit C - AFRA Membership
Exhibit D - Affidavit of Christine Korn
Exhibit E - Wiseman motion in California case admitting he obtained seminar handout from
Swallow
Case 1:09-cv-00309-MSK -KMT Document 464-1
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Filed 04/07/11 USDC Colorado Page 2
_\,__.L \i:.>'! of 67 Exhibit A
ThisC-eltifkate issued under the seal of the Copyright
Office in accordance with tItle 17, United States Code,
.aUests that registration has been made for the work.
identified below: Theiriformationon this certificate has
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RECI TX 5-989-070
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PUBLICATION AS A CONTRIBVTION IE this work _ published • a l'OIItribulioolO a periodical, serial. or co1lectiOl1, give informallon about the
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If published in a periodital or ICriaI give: Volame Y NamberY llaut Date Y
- NAME OP AUIlfOR ... DATIlS OP BIR11I AND DEA111

a Suzanne Shell
Year Bom ...
1956
Year Died ...
NATURE OF AVTHORSHIP ,Briefly desc:rlbe natwe of malerial created by this.uthor in wtildioopyriahlls claimecC ~, ,':' ,)
NOiTE Text, content,
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emploYlr, nOI Was thiaconln'bulion 10 the work a AVTHOR'S NATlONALrrY OR DOMIOLE WAS 11IIS AVTHOR'S CONTRIBUTION TO
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NATVRE OF AUTHORSHIP Briefly de5Cribe natwe of material created by this .uthor in which c:opyrighlls claimed. •
a YEAR IN WHICH CREATION OF 11115

WORK WAS COMPLllTllD 1ItII1nfonnIIIOa
b DATIl AND NAnON OF RRst PVBUCATION OF 11IIS PARTICULAR WORK
~ IIlIt InforNllon Manlll" 05 IS Day"
2004 v......
2004 "'v~, :::::::.- .=L...:..-::::.... USA - " ... NaIIan
COP\1UGHT CLAIMANT(S) Name aNI ~dciMsniU8t'be'Biven even If the claImanl is the.ame as
4 the author given in space 2. Y
Suzanne ShelI
14053 Easto.wille Rd., Elbert, CO 80106
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Suzanne SheU I
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14053 Eastonville R~.
Elbert, CO 80I06
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CERTlFICAnON- I, the undtlSipd, hereby ClUtify that I am the author
Oeck only one ~ 0 ~copyrlghtclaim8nt
I n.O"A'~~·-f OIIil"",cne.i(a) "~
oj de work iti8Uititd m il'i'nJip1iation UId"diilI the sta~ents made authorized agellt of
by me in thll appliCition are comet to the best of my IcnowledlJe. N..... d ~ orolhilt ClllI¥W>t deIment. o r _ d....... rtohtlll.
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CERTIFICATION' I. the undersigned. hereby certify that lam the illl'author
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EfI'ec:tiye date of
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-'-;"'----'~-~'-~~>~'~-- ~,~"~-""",,--,~,-
October 23. 2008
Title - - - - - - - - - - - - - - - - - - - - - - - -
ntle of Work: Unpublished Proprietary Documents
Hawaii Key Issues Matrix
Arizona Case Plan Key Issues Matrix
Arizona Reasonable Efforts Key Issues Matrix
Connecticut Issues &. Strategies in Dependency &. Neglect
Key Issues Matrix
Kansas Key Issues Matrix
Florida Issues &: Strategies in Dependeney " Neglect CLB
Arizona Family Rights Seminar Handout
CLE Issues in Dependency &. Neglect
Florida Issues at Strategies in Dependency at Neglect, Family Rights
Hawaii Seminar Handout
Case Management
Completion/Publication - - - - - - - - - - - - - - - - -
Year olCompletioB: 2001
AuthOr
• Author: Suzanne Shell
Author Created: text, editing
Work made for bire: No

Cltlzea or: United States Domiciled in: United States
Copyright daimant
Copyright Claimant: Suzanne Shell
14053 Eastonville Rd, Elbert. CO, 80106, United States
Umitation of copyright claim

Material extluded from tbis elalm: some preexisting legal text
Certification
Page 10f2
of 67
Name: Suzanne Shell

Date: October 23, 2008
CorrespoadeDee: Yes
/,
Page 20f 2
of 67
IPN#:
II
**
RegistratioD II: TXUOO1583498
Senite Reqaeat#: 1·126668661

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GeorgiaFamilyRights : Georgia Family Rights Association 4/1/11 1:51 PM
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Category: Politics
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Founded: Mar 26,
2003 own values into our
Language: English children; controlling
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ILLINOIS_FAMILY_RIGHTS_Association : ILLINOIS Family Rights 4/1/11 1:51 PM
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Founded: Jun 20,
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Language: English Illinois_Family_Rights MISSION STATEMENT
The Mission Statement of The Illinois_Family_Rights:

Yahoo! Groups Tips The insertion of the coercive force of government into the private lives of
families, without accountability, due process, or recourse to redress the
Did you know... government for grievances is epidemic nationally and invariably harms families,
Message search is communities, threatens our country's future and should be vigorously opposed.
now enhanced, find As an association we are dedicated to assisting families and their children by
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Illinois_Family_Rights Association uses Family Rights Advocates
in the very same way as The Juvenile Court uses Court Appointed Special
Advocates.
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Massachusetts_Family_Rights : Massachusetts Family Rights 4/1/11 1:52 PM
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Founded: May 16,
2007
Language: English Welcome to Massachusetts Family Rights. This group endeavors to support
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Social Services (DSS). By gathering here we hope to become educated and
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Oregon_Family_Rights : Oregon Family Rights of 67 4/1/11 1:53 PM
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Case Colorado
1:09-cv-00309-MSK -KMT Document 464-1 Filed 04/07/11http://members.familyrights.us/colorado/index.html
USDC Colorado Page 46
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Exhibit C
News and resources for

Colorado.
Colorado Also see- Colorado Info Page
Corrupt-o-meter: sixth ranked state
We add new members at the top so they feel more welcome!
member anonymous
Colorado Springs Colorado 80910
website www.list-me.co.uk/
hide name, address, phone, email
date June 25, 2007
comments Had a case in Adams county. They ran all over us. Now it is continuing in El Paso
county.
member anonymous
Colorado
email wolfberry23@yahoo.com
hide name
date May 30, 2007
comments My story is on www.coloradoan.com May 27, 2007: Mother stands behind accused
fiance.
member Debbie Evans

2070 West Iliff Avenue
Englewood Colorado 80110
phone 303-936-2029
email thesixty9erdiner@msn.com
date March 21, 2007
member Susan Fretwell

Canon City Colorado 81212
persons 2
phone 719-371-2251
email snsanty@yahoo.com
hide address
date March 13, 2007
comments The DHC Nazis in Fremont County, Colorado took my children away a year ago for no
reason based on any abuse or gross neglect. My husband and I have been constantly
harassed by DHC and I have been called a 'bad mother'and forced to undergo
1 of 17 5/6/2009 10:28 AM
AFRA Members
Case Colorado
of 67
humilation such as UAs when I have never had a drug or alcohol problem. They took my
newborn baby away from birth without even having a case against her (they invented
one) Please help us with this hell we have gone through!
member anonymous
Pueblo Colorado 81004
persons 3
hide name, address, phone, fax, email
date March 6, 2007
comments Do whats best for your children! Record everything and keep a log in case they try and
twist your words. Thats what I did.
member Michele Wolf

639 Brookside Drive
Longmont Colorado 80501
phone 303-682-1689
email Wolfmichele@AOL.com
date January 24, 2007
comments I am in desperate need of help and direction as I have nowhere else to turn. Hearing
from my current attorney that I need to just play their game and maybe I will get my
children back is not acceptable. My story is a classic Parental Alienation horror story, my
children have been removed from my custody due to me trying to protect my children
from a documented abuser. I have been given limited supervised visits at the whim of
Boulder County Social Services, the system has truly failed my family. What do I do
next?
member Jessica Barnes

2028 31st Street
Greeley Colorado 80631
phone 970-392-2860
email jessicaebarnes@comcast.net
date December 20, 2006
comments Is any defense against CPS in Colorado? They invaded my child's dignity by having her
undress with no witnesses. This happened at school without my knowledge. I would
have thought the school district would have some responsibility to my child's safety.
After visiting the three children I have in school they came to my house. I was told that I
would receive a letter in the mail about the findings. Two weeks went by no letter, so I
called the intake CPS worker who informed me over the phone of their (supervisor)
findings. They are finding my husband and me for neglect that will be put on our civil
background report without us seeing a judge!!! Can they just slander like that, are there
no laws for them to follow? I feel all this taken place because 1) My husband and I are a
thrown together family yours mine and ours. With the child in question with CPS being
Black That we do not treat her the same as all the white children the other five children
we have. 2)That we are studying to be Jehovahs Witnesses and so are pulling our
children from the holiday celebrations at school. Also there is documentation of the
numerous "drama" issues with my child visiting the school nurse every other day with no
report from school to say hey! have you noticed similar behavior at home etc? The
school is responsible for calling CPS. My daughter went school ONE time without a
jacket. So instead of calling us to say do you need help with clothes, nope they make
2 of 17 5/6/2009 10:28 AM
AFRA Members
Case Colorado
of 67
their assumption and then call CPS. We have been visited every year for four years now
"BECAUSE OF AN ASSUMED ACCUSATION". I am a hard working mom who left crack
ville to return to reality put my self through school and become a medical assistant work
hard to support my disabled husband and six children. Please if anyone has ideas,
solutions, attorneys ANYTHING would be great. — Thank you, Jessica Barnes
member Tieannie Abel-Lehmann

2228 Ontario Dr
Colorado Springs Colorado 80910
phone 719-231-0636
email angeleyestie@yahoo.com
date November 24, 2006
comments I am a victim of Colorado Springs DHS along with my two boys and four siblings I need
some help to get mine back.
member Stephanie S. Malouff

456 Madison St.
Monte Vista Colorado 81144
email malouffs7@yahoo.com
comments I am involved in a D&N due to being a victim of domestic violence. DSS has now
managed to remove all four of my children from my home.
member Jami McMurray

Fort Collins Colorado 80526
email msjaimz@hotmail.com
hide address, phone
date October 18, 2006
comments CPS has sent my 15 year old son out of state to live with his estranged father. Thanks
Uncle Sam.
member Sueann Ashcraft

Canon City Colorado 81212
email star1ight34@yahoo.com
hide address, phone
member Tammy Burr

1016 Plum Ave
Lochbuie Colorado 80603
phone 303-659-2717
email TammyBurrs@aol.com
date October 2, 2006
comments My son was taken by Weld County CPS a couple of days ago. He was ditching class
and running away and I called the police on him. Now he is claiming abuse. Mind you he
is 15 and only wants to have his way and can't take being told "NO"
3 of 17 5/6/2009 10:28 AM
AFRA Members
Case Colorado
of 67
member Sara
Colorado
email ulvmyhair@hotmail.com
hide address, phone, fax
date August 29, 2006
comments A friend is having trouble so I joined!
member anonymous
Colorado
email cheffuehrer@comcast.net
hide name, address, phone, fax
date August 15, 2006
member Lisa Mae Sherwood

1701 North Lake Avenue
Estes Park Colorado 80517
phone 970-586-5363 X160
email little_mae_angel@hotmail.com
date August 7, 2006
comments August 30, 2006, Weld County will wrongly terminate my parental rights and my
beautiful 8 month old daugter will be put up for adoption. Isn't there some way??????
It's becoming harder to smile and breath everyday! I LOVE YOU ZOIE OLIVIA.
member Susan Spies

1328 S. Coffman St #4
Longmont Colorado 80501
phone 720-364-1636
email spies2mclarty@yahoo.com
date July 15, 2006
comments I had to deal with CPS bs most of my adult life. My 18-year-old daughter just got her son
back. Only because a judge in New Mexico ordered it and dismissed the case. CPS was
so furious that attorneys have warned her that NM CPS might contact Colorado CPS for
no other purpose than to harass my daughter. My daughter and grandson now reside in
my home in Colorado. No visits from Colorado CPS yet but can't be to careful.
member Christina
Woodland Park Colorado 80863
group Laswell/Wight Family
phone 719-687-4511
email Chrslaswe@aol.com
hide address
date July 14, 2006
comments I'm looking for some answers. Teller County DSS has been making threats to us now for
almost six months and told lies about us to the judge to have our kids taken away. Since
our kids have been placed in foster care, the case worker has called me names, made
threats to me, and yells at me on some of our phone conversations. How can they get
away with that? Since my children have been placed in foster care our daughter (6) was
4 of 17 5/6/2009 10:28 AM
AFRA Members
Case Colorado
of 67
bitten by their dog, our son (10) who has bipolar ADHD and OCD is allowed to ride
around the city with no supervision and our son (11) is scared of the foster father
because he told my son about a story where the foster father punched a guy one time
until he was almost dead. NOW you tell me that is safe? Please help us.
member Dee Contreras

Thornton Colorado 80233
email dee7020@aol.com
date June 22, 2006
comments Kathy Tilley asked me to join, and here I am.
member Debbie Falb-L'Heureux

2070 West Iliff Avenue
Englewood Colorado 80110
persons 5
phone 303-936-2029
email Thesixty9erdiner@aol.com
date June 12, 2006
comments Social Services is the modern day equivilant to the Nazi SS (probably why their initials
are the same!). There needs to be some kind of system that parents can use to fight
these monsters, because something is wrong when social workers are so credible and
everyone else is not!
member Nicole
7545 Bradburn Blvd.
Westminster Colorado 80030
phone 720-839-5271
email djudie@comcast.net
hide address, phone
date May 25, 2006
comments Three young kids taken away by CPS on allegations of non-accidental trauma, being
harassed by police and mistreated by government officaial who say they are to help.
member Leslie Peppo

6000 S. Fraser St. Apt. 4-204
Centennial Colorado 80016
phone 303-269-9878
email lesliepeppo@yahoo.com
date May 20, 2006
comments I need help ASAP!!!!
member John Frantum & Lori Dunn

Denver, Colorado 80219
phone 303-761-2603
email octomocktus@yahoo.com
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hide address
comments Ran across your site, you hit the nail on the head. I'm currently dissecting a HS case
report. It is truly unbelievable, but sadly it's going on in epidemic proportions here in
Colorado. If you are interested, I'll send a copy of the rebuttal I'm writing as soon as it's
finished. If for no other reason, it might be beneficial to some of the members.
member Kimberly Helka

Thornton, Colorado 80241
persons 4
phone 303-252-0822
email rockiemountainwy@aol.com
hide address
comments CPS has caused us nothing but hell, I was given by the court 2 visits a week I have only
gotten 1 2hr visit a week. My son is 2 1/2. I have proved I don't have a drug problem like
they said and still no son. The Police that took him. They USED MY SON AS TRADING
TOOL, when I knew nothing... they stole him. CPS has admitted screwing up, but still no
son returned. As this point I have no faith. The Judge I hope again sees it in my favor as
returns him back to me. I miss my baby. He quit talking for almost 2 months after they
took him, he is getting better, He spoke just fine. Anyone that can help me please email
or call Court date is on the 7th of Sept in Brighton. help me get Robbie back.. CPS is
FULL of lies and false promises.... Also when I start getting upset with them they always
threaten to ask the courts for my rights... I don't have anyone now. They gave him shots
when he didn't need them, they put him in speech class without my consent, they do
whatever they want.
member A Member
Canon City, Colorado 81212
persons 3
email star1ight34@yahoo.com
hide name, address, phone
member Shell Krager

Currently Homeless thanks to Weld Co. CPS
Colorado
hide address, phone, email
comments I lost everything when my two youngest were taken from me in 2002 — they were 13
(girl) and 15 (boy). You'd think old enough to express their desire to remain with mom,
not leave the state with all around abusive dad. Woman judge said she didn't CARE
what they wanted. Six months later dad died, could they return to mom? NO! Again
Judge said she didn't care. It's too late to help ME or my kids, due to all this. The four of
age kids now hate me and completely shut me out of their lives. I WISH I had known
there was help, back in 2002, but truthfully, I was in such SHOCK and depression I
couldn't have found you then. Somehow, people need to KNOW BEFORE it happens to
them, before they beat you down! I moved my kids here from Utah after divorcing the
abusive father, I should have STAYED where I was!! I don't have an address -- I lost my
home when I couldn't pay for it and attorneys, psychiatrists etc.
member AC
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Colorado
email amsnwoo2@yahoo.com
website www.geocities.com/amsnwoo2/fight_co_cps.html
comments Fighting against Colorado CPS. They kidnapped my children!
member Jessica Yamaguchi

Colorado
email jessiesuniverse@yahoo.com
hide address, phone
comments My case is set for termination of parent child relationship on the 29th of this
month(aug29th) I NEED HELP! TIME IS OF THE ESSENCE!! PLEASE ANYONE
WILLING TO HELP CONTACT ME IMMEDIATELY!
member Amber C
Colorado
email mclamber@hotmail.com
member Judy Leithead

Colorado
email jleithead@kci.net
hide address, phone
comments DHS took my children from my home on November 8, 2004 and their GAL told me at the
time that if I would waive my hearing that day that he would make sure that I would get
my children back soon. My children made false accusations against my husband and
have since admitted to lying. They even have given reasons and where they got the idea
from. But DHS still is saying that the abuse happened. Although they will tell you that
they think my children are liars. I have done everything that the courts have asked and
yet they still refuse to allow the children to come home.
member anonymous
Colorado
member Sanita Swisher

Colorado Springs, Colorado
hide address, phone, fax, email
comments I'm a mother who lost seven children acquitted of all charges of abuse my rights were
still terminated. The Judge here in Colorado Springs is a known judge for termination of
African American children. I want to fight and will continue to fight until Child Welfare is
brought down or the government stops these false termination of parental rights. What
do you do when Child welfare has done far worse than you've ever in the care of your
children? I'll Never Give up my Fight
member Shannon and John Cervantes
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Pueblo, Colorado 81004
group Support for Parental Alienation Issues
persons 75-100
phone 719-564-0693
email Jaccerv@aol.com
msn groups.msn.com/SupportforParentalAlienationIssues
comments This is a Community created as a safe place to go and discuss Parental Alienation
Issues. The community is a locked support group, so please let us know in your
application where you found us!
member Katlynn Kirkwood

Colorado
email Katlynn4michelle@aol.com
comments I have had three children taken in Adams county, which I was also in social services
same county, The Judge who took them, was my GAL when I was in the system, the
case worker and all involved said that I wasn't able to raise my children because their
doctors said I was bipolar. Which I'm not they terminated two of my children because of
this and I also feel that they did this because, of unknown reasons, to try and make up
for what they failed to do with me, which two of my children when taken were told by
doctors they were normal 2 and three year old children. After being in abused foster
homes and so on, they said my children had problems I caused to them, which i'm not
saying I was a perfect parent i'm saying I never beat them. Like what happened to them
in a foster home, it wasn't intill I took my son to the bathroom and saw a hand print on
his butt. And all the foster family got was they need more training. Crap. Now I'm
involved again because of my youngest son who was living with his father, If anyone
wants to know more or something please e-mail me back.
member anonymous
hide first and last name
comments screen name: 1voshioenletv3 colorado/ireland
member anonymous
Colorado/Wyoming
email name, email
comments link for comments
member David Slater

132 West Ida Ave. #5
Littleton, Colorado 80120
phone 303-730-0490
cell 720-338-1010
email dlorenslater5@yahoo.com
member Jessica
Brighton, Colorado 80601
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email Jessmom81@yahoo.com
hide address
comments I am a mother of two wonderful children who were "kidnapped" by CPS!! I would like to
join to help in the fight against these "evil" people and get some info so I can WIN and
get my two children back who are rightfully mine!
member Sandra Paul

Broomfield, Colorado
email Spaulyn278@aol.com
comments I have been going through hell for the last year and have had my children taken away
from me and placed with their father. I have not been allowed contact except for two
monitored phone conversations. I have cooperated, been investigated, passed two
polygraph exams, and the "charges" were dropped. However, Boulder County Social
Services continues to be involved testifying that I am "unsafe" to be around my children,
and they do not believe "my children need to be around me or have contact with me".
member AM
Canon City, Colorado
comments I would like just my initials and city and state made public. I would like join, to gain
knowledge of my rights an how to clear my name and my husband.
editor We can sure understand why you would want to retain anonymity. You are living in the
most corrupt county, in the most corrupt state in the US.
member (Updated 9-15-2004) Richard & Missie Deherrera

13172 Rd. 5 S
Alamosa, Colorado 81101
group Parents with Rights
persons app. 77
phone 719-587-5492
fax 719-587-3755
email felltaken@aol.com
comments We have a whole new ball game here. We are getting ready to bust Colorado wide
open. This a royal mess-up by CPS, and what a joy to help expose them. We only have
to wait until charges are filed, and all our people who have transcripts need to gather all
their papers and transcripts up and get ready for a big downfall. Once this story hits the
papers we will be ready to go. Keep in mind this is not for monetary benefit, our work is
free! And if you have abused your children don't call. This is for parents who are falsely
accused, child removal without proof, medical documentation. A lot of this is based on
the Bill of Rights and will stand up in court. Believe me when I say, this story will set you
on your heels. It will show just how out of control (or should I say in control) they are. We
all should realize "the bigger they are, The harder they fall" And fall they will when this
story hits the news. Watch the Pueblo Chieftain, Denver Post, Canon City Record and
your local news stations.
member JT Young
Aspen Colorado 81621
phone 970-384-7900
comments I own the "Disgusted American Digest" print magazine ( www.thedad.net ) And the
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United American Voice video magazine ( www.uavmagazine.com ) and the "Fully
Informed Citizen Associations of America FICAA. We publish articles about
governmental abuse, victims of government abuse. We show people how to unite and
overturn bad law. We stand with Americans for freedom. Voice your comments about
what we do on our radio comments line at 970-384-7903. I will enjoy being part of your
chat groups. Thanks!!!!
member Regina Autobee

Pueblo Co 81001
email reginaautobee@earthlink.net
member Pamela Phipps

email COFAMILIESFIGHT@yahoogroups.com
comments Yes, I would like to join AFRA and include you as a link for my yahoo group.
member Bernie F. Jungkind

0297 Rabbit Road
Carbondale, Colorado 81623
email berninaspen@comcast.net
website home.comcast.net/~berninaspen/SAVEMYKIDS.html [defunct]
member anonymous
Center Colo.
hide name, phone, eamil
comments Yes I have been fighting to keep my children for almost two years. DPS has never given
me an answer to what they want. I have complained to the governor asking for an
investigation and he did nothing but pass it on and it got back to the department. Now
they are threatening the removal of my children. I have documented proof of all this and
also have cassette recordings of them threatening as well as video tape recordings. My
attorney appointed by the courts has done nothing. If you can give me the name and
number of a lawyer who will take on a lawsuit I would appreciate it. I have no money to
pay up front and I am a single father. Don't give my name or phone number or E- Mail
unless it is someone who you feel can help me. DPS has threatened a person I know
who has sued them.
editor It is NORMAL that what CPS won't tell you what they want you to do or change. I
experienced it myself, and the only way to describe it is the torture scene in Orwell's
1984
at the "Ministry of Love" when Winston finally figures out they want him to wish the
torture onto his girlfriend instead. Another way to describe it — I felt like the person who
had been set up in a ridiculous and confusing situation by Candid Camera. But no. CPS
people are simply stupid, incompetent communists with no clue about American
Constitutional Rights.
member anonymous
Douglas County, Colorado
comments My four-year-old son was physically abused and continues to be emotionally abused at
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the hands of his mother, my ex-wife, who is bipolar with extreme mood swings and has
several personality disorders. Social Services and the Special Advocate try to blame me
instead of his mother for the abuse and resulting devastation upon my little boy. After my
son was taken from me and despite all the evidence disputing the false allegations,
since March 2003 I have been restricted to supervised visits, we've both been forced to
undergo counseling, and we suffer through the "system" because of the mother's lies
and her ability to deceive the idiots running the asylum. Why won't they open their eyes
and listen to the truth?
editor Hate to tell you this- CPS are not only idiots, they are Evil idiots.
member Amy Jennings

3282 East 103rd Dr #1610
Thornton Colorado 80229
phone 303-949-6146
email Mihighlady@aol.com
comments link to comments:
member Brenda
Clifton, Colorado 81520
email bredae@msn.com
member Jason A. Steelman

2801 120th ave #I-311
Thornton, Co. 80233
phone 303-478-3112
email jsteelman@battlereadyblades.com
website Battle Ready Blades [defunct]
comments All is welcome to be published, though I myself am in a case with the Weld County
Colorado CPS.
member Dan Maus

PO Box 120
Cripple Creek, Colorado 80813
group The Maus Family
persons 5
phone 719-689-5964
email dan@MyNet.org
comments We are under attack by the Teller County, Colorado Department of Social Children For
Sale Services
member Rebecca Longbrook

897 S. Carr Ave.
Lafayette, Colorado 80026
phone 720-434-4890
email bl1016@msn.com
comments My husband and children would like to join AFRA as we are going through hell with
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Boulder County social services.
member Terry Leiter 2nd

Greeley, Colorado
email amtl2@yahoo.com
comments Friend of somebody whose four kids got kidnapped and little brother of somebody who
was falsely accused and annihilated.
member Delaina Saylor

Aurora, Colorado 80018
persons 50
email austinlainie@netzero.net
website www.falseallegations2001.com
hide address, phone
comments I recorded a conversation I had with a Case Worker in Arapahoe County. The Case
Worker called to "investigate" an allegation against my husband made by his ex-wife. I
recorded the conversation to have proof that the ex-wife's story had probably changed
yet again. Little did I know I'd be using that tape later to defend myself against the CASE
WORKER'S lies! She made reports and testified in court that I said things during that
conversation that I absolutely did NOT say!! I'm told there's an investigation yet NO ONE
from that agency has asked to listen to the very tape that proved that woman lied?
COME ON!
update November 25, 2006
member Delaina Saylor

Colorado
comments Hi, I'm on the member's page but some of my information has changed since I signed
up. My e-mail is austinlainie@netzero.net and my URL is Can you change those on the
member's page for me? Thanks!
member Melissa Rimel

group Women Against Domestic Violence, Inc.
persons 35
email Melissa@wadv.org
website www.wadv.org
hide address, phone
editor From the WADV website -
WADV, Inc. is a group of women from across the world who have joined together in the
struggle against domestic violence. We are not a feminist group or an anti-men group.
We are here to help all of those affected by abuse. The women of WADV are dedicated
to stopping dv through communication and support.
member anonymous
Wheat Ridge, Colorado 80033
persons 4
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phone 303-462-0415
email Minirocs@AOL.com
hide name, address
member Arthur Gallegos & Christy Bailey

416 S 9th St
Manassa, Colorado 81141
persons 4
phone 719-843-5022
email christypb@aol.com
comments I or should I say we are having problems with cps also any suggestion very helpful
member Patricia Thompson

PO Box 142
Arriba, Colorado 80804
phone 719-768-3210
email patriciathompson807@hotmail.com
comments Please e-mail more info. Do you have lawyers names who specialize in helping people
with these issues.
editor Unfortunately, very few lawyers will take a case against CPS. And it appears that most
lawyers will sell you out to CPS. CPS is so powerful that they can take out anybody on
their whim with a character assassination. That includes doctors, politicians, and
lawyers.
member Charlene Port

Trinidad, Colorado 81082
email cheezer@starband.net
hide address, phone
editor You can tell the CPS Nazi's are BAD when so many people are scared to death to list
their names.
member anonymous
Littleton, Colorado 80120
email Jfcasias@aol.com
member anonymous
Greeley, Colorado 80634
comments I'm just a mom, that was accused. Now I'm fighting the system.
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member D. Michelle Jensen
Westminster, Colorado 80030
email shelljag2u@yahoo.com
hide address, phone
comments My kids have been gone for a month now. I have no family here in Colorado. Only
myself. One four-year-old boy, and at time of their removal, my baby girl was 13 days
old. She is now six weeks old. I have been doing their (DSS) hoops from day one. I have
a court date on June 2, 2003. I'm not sure what for, and I am scared to death. I have
found AFRA now and I am hoping to find out what is going on. I agree that something
has to be done, and done quickly. For all our sakes especially our kids. I have to admit, I
am quite "overwhelmed" with everything. I feel it's all "a setup for failure". I would
appreciate any and all suggestions, and a point in the right direction.
member Greg Boyles

13553 W. 24th Pl
Golden, Colorado 80401
group Parental Rights
persons 4 so far
email webmaster@parentalrights.net
website www.parentalrights.net [defunct]
hide phone
comments I just would like to try through my site to address the issues of some of the CPS
injustices perpetrated against parents and families. Right now we are a Colorado Based
Org but will be addressing national issues.
member Kevin Strait

email totalrecall2003@cs.com
member Ariane Hildenbrandt

11715 Black Forest Road
Colorado Springs, Colorado 80908
phone 495-1698
email blhincs@earthlink.net
member Kate O. Fell

24454 C. R. 18, P.O. Box 100
Blanca, Colorado 81123
persons 50
phone/fax 719-379-3339
email fellham1@aol.com
website incomplete
comments Parents with Rights is fighting the "system" in Colorado to reunite families, we use
media columns, we are in the court rooms, we teach and educate parents of the illegal
actions with-in CPS. We are non-profit, and do not use federal or state grants. (much
like asking our adversaries to provide our weapons to fight them). Kate Fell Executive
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Director PWR
member Vickie Carley

2050 Yeager Drive
Longmont, Colorado 80501
phone 303-678-9467
fax 303-678-3058
email vickiesplayhouse@msn.com
comments Need help for son who wife left him and will not let him see his son. She sees things that
are not there. Also help for my daughter to get help getting money from her kids father,
one has c p.
member The Sound of A Trumpet

Pagosa Springs, Colorado 81147
group Group name-The House of David
email HisVanguard@aol.com
website www.InJesus.com
comments All I know is the Lord is moving mightily and he is in total control. People are fearful, but
if they would read and truly study God's word and cultivate a personal relationship with
Christ Jesus and live "holy" and follow His ways they will be okay when "His" storm hits!
Job 36:32-33.Amplified for more clarity. Amen Malachi 3:16-18; Psalm 4:3 for sure!!!
editor How about Isaiah 3:4, 5, and 12
member Stuart Grauberger

Keenesburg, Colorado 80643
email indeepos@yahoo.com
hide address, phone
comments Hi I personally , as of yet don't have a problem with the CPS, but my brother is and I'm
going to fight them with him.
member anonymous
email Sunshine0110@hotmail.com
comments I am just a mom who is being victimized by the Fremont county CPS. Does this
corruption surprise anyone?
member Lisa Gonzales

863 E. Main St. # 23
Rangely, Colorado 81648
phone 970-675-8163
email sweetherb2002@msn.com
comments I have been falsely accused!!!!!
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member anonymous
Loveland, Colorado 80537
persons 2
comments My husbands children were taken away by CPS in Baytown, Texas in the 1980's! This is
what you call "THE WITCH HUNT" His brother in Illinois sent a lawyer down to Baytown,
Texas and they went to the Family Court House to pull his file and the Lady said "His file
is in a closed file and nobody has access to it!". If this isn't illegal then I don't know what
is! My husband says the reason why he couldn't get his kids back is because of money!
Welcome to AMERICA!
member William Bruce

2323 Cortez Rd.
persons 2
phone 719-543-7397
email dimitri_7@hotmail.com
member Donna Hillman

Greeley, Colorado
email silversdesk@cs.com
comments I just want people to be able to reach me in case they need support or a friend.
member Kate Fell

PO Box 100
Blanca, Colorado 81123
persons 25+
phone 719-379-3339
email fellhan@aol.com
comments Our organization is based on reunification of families, prevention of removal, petitioning
of this state's governor to answer in truth to his executive order on family protection. I
am the Exe. Director and have been a parent, foster parent an adoptive parent, and a
victim of CPS. All the claims of services to families are not accurate. In Colorado the
budget for 2002 is 1.9 billion dollars the second highest budget ever. There are no
investigations into any reports, and parents in this state are charged with D and N
without regard to proven guilt or innocence. Dependency- Children depend on parents
from birth to adult. Neglect- Anything CPS can think of. The average person (by CPS
Standard) did I say standard? is guilty of neglect. We have people who are mentally
slow, who with in home services, could parent. Those services are not available, except
on paper. The "99" CO. task force recommended all counties have a grievance
committee, they do , on paper.
member Harry L. Simpkins

group Assaulted by the CPS
email cpsassault@aol.com
website members.aol.com/cpsassault/index.html
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comments Local site for AFRA members in Weld county Colorado (www.cpsassault.150m.com/)
member Victoria Roberts

PO Box 482
Limon, Colorado 80828
email roberts2001@earthlink.net
member Ray Thomas

PO Box 16247
Denver, Colorado 80216
email raythomas101@hotmail.com
website www.geocities.com/thomasreport
member Jody L. Kimble-Livermore

Greeley, Colorado 80631
member Sharlene Farmer

1217 29th St Rd #101
Greeley, CO 80631
email charliebrn1@earthlink.net
member April Ward

Greeley, Colorado
comments Mother of 4 kidnapped children.
member Marilyn Salzman

Greeley, Colorado
editor Harry L. Simpkins notes- This woman had her children taken from her because they
were skipping school, and was told that she HAD to plead guilty to educational neglect
in order to have her children returned. Apparently she has been counseled, classed, and
certified to death for over a year and is still jumping thru hoops.
BACK
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Exhibit D
CHRISTINE M. KORN
226 G Street
Penrose, Colorado 81240
Affidavit Regarding: Suzanne She~~, American Fami~y Rights

Association and Wi~liam Tower, President
May 4, 2006
I became acquainted with William Tower through our mutual association with the American
Family Rights Association (AFRA) sometime in the year 2003. During the course of our internet
contacts, we worked with several others to expose corruption in the child protection system.
In March, 2004, both Mr. Tower and I attended a Congressional Hearing in San Bernardino,
CA. at which we both testified, I, as a representative ofAmerican Family Advocacy Center
(AFAC),Mr. Tower as a representative ofAFRA. After that point, Mr. Tower would telephone
me fairly often to discuss various facets of cases in which he was advocating for parents accused
of child abuse or neglect. Most often, his calls appeared to be intended to inflate his own
importance by apprising me of his impact on the "system" in California, and his supposed
successes in the effort to get children returned to their families. A component of nearly every call
was his implied and sometimes direct request to have portions ofthe AFAC advocacy training
materials sent to him for review, for various reasons, but mqstly so that he could "assess" them
for validity, and determine if Suzanne Shell's training was going to be applicable to California.
This was a source ofconcern for me because to my knowledge, no request had been made ofMs.
Shell directly. I tried to remain open to the possibility that Mr. Tower was truly making the
strides in California that he claimed, but as his claims escalated in scope, I began to doubt him
and to request to hear exactly how he was accomplishing these things.
Despite my repeated requests to see evidence of the success stories claimed by Mr. Tower,
none were ever provided, however his calls did not stop. In mid 2005, I began avoiding his calls.
It seemed to me that every time he called, he was seeking to gain information from me regarding
the practices and strategies employed by the organization ofwhich I am a part, FRAI. This
organization is engaged in education ofadvocates who then take that training and use it to help
families and attorneys who are battling protracted child protection interventions and court actions.
The course materials and manuals were all created by Suzanne Shell and are protected as trade
secrets and by copyright. As a part of my membership in this organization, I have signed an
agreement that prohibits me from sharing the training materials with persons who are not
approved and registered with AFAC. I would decline to comment to Mr. Tower, and suggested
of 67
over and over that he either attend a training session, offered several times every year, or contact
Ms. Shell directly ifhe had need of assistance.
Mr. Tower ignored my insistence that he attend training, and continued to call and attempted
several ploys to try to gain my help to secure the information. He went to the extreme of
challenging me with various statements of disbeliefthat Ms. Shell's material was even her own.
He railed over and over that her listing of some of his AFRA associates on a consumer advisory
page on her website was unfair. He protested that Ms. Shell was dishonest in requiring that her
materials be purchased from her. He even inferred that her training and materials should be
freely accessible; she had no right to withhold information that could save families from
destruction. He suggested that she cares more about her own profits than about helping families
stay together. He did not seem capable of grasping that her expenses had to be reimbursed, and
kept insisting that she was profiting. At one juncture, he told me he would not consider flying to
Colorado for a training seminar without being able to review the course materials before
attending. He tried to convince me that I should send him the Colorado-specific course materials
so that he could judge the quality ofthis training for himself. I declined.
When I realized that Ms. Shell would be in California, and in the same general area as Mr.
Tower, I suggested that they should meet. He had been given a large amount of false information
about her, had never met or spoken with her, had made several disparaging public remarks and
accusations about her and had formed some opinions based on poor information. I suggested that
he should reserve his opinion until he had met and spoken with her. I had hopes that he would be
able to realize that the information that he had heard was false. At that time, I still had hope that
Mr. Tower would attend training in Colorado to enhance his efforts to establish advocacy in
California.
I am a FRAI trained and certified family advocate. I now train and supervise other advocates.
In the entire history of my involvement with FRAt and Suzanne Shell, I have heard her
repeatedly instruct new advocates that they are prohibited from charging a family for assistance,
and that ifan advocate is asking a client family for money, it is the red flag that the advocate is
not legitimate. I have heard her repeatedly warn advocates that charging a client for services
would result in instant revocation oftheir certification. Knowing her and working with her over
the course ofnearly five years, I can assure anyone who questions her integrity that Suzanne
Shell has incredibly high personal and professional standflrds, that she is rigidly unwilling to bend
those ethics and that she expects and demands that other people who are associated with her
maintain professional standards and ethics which are commensurate with her own. I shared all of
these things with Mr. Tower many times. After several months ofconversations and phone calls, I
began having my family deflect Mr. Tower's phone calls because they were redundant and
pointless, wasting my fairly valuable time.
The FRAt organization is located in Colorado. Although Ms. Shell is hired to speak at various
functions around the country, and is engaged to teach her advocacy training and Continuing Legal
Education courses in other states, and for other organizations, FRAt is located in Colorado, and is
the only home of the business offices and activity. There are no "branches" ofFRAI or of
Suzanne Shell's business ventures. Ms. Shell accepts paid speaking engagements, and produces
written and documentary pieces for sale. She is a published author, and has books for sale to the
public. Mr. Tower attempted many times to circumvent the need to attend the training, sign the
required non-compete/non-disclosure agreements, and pay the sponsoring organizations' fees for
the training by attempting to convince me that he had a legitimate need to "review" the materials.
He attempted to gain access to Ms. Shell's legal education and seminar content and advocate
of 67
training materials by manipulation and poorly cloaked claims to need to know various
infonnation in order to help clients. He resisted my many requests to attend training by making
excuses for his inability to travel to Colorado, and later, by refusing to pay the additional tuition
for those seminars which is charged to AFRA members. After repelling his attempts to
circumvent the FRAI policies for several months, while continuing to insist that he should attend
training, I finally gave up and began to refuse his calls. I have continued to avoid contact with
him because he did not seem to grasp my steadfast refusals, and his calls became irritating and
harassing in nature.
Mr. Tower has, for at least two years, possibly much longer. been vested in the AFRA effort to
discredit and defame Ms. Shell because they perceive that she should not have the right to recover
her expenses for this altruistic endeavor to bring accountability to family courts and intervention
agencies. She was their hero as long as she flew all over the country teaching these classes and
absorbing her own expenses for flights; car travel. food, vehicle, printing; etal. When she became
unable to do this work without requiring that her expenses be reimbursed; she was accused of
profiteering. Mr. Tower, while pretending to be a neutral operative, bas clandestinely supported
several members ofthe AFRA association who have continued to malign and undermine Suzanne
Shell. He and his associates have made similar false statements to law enforcement agencies and
other officials for several months in retaliation for Ms. Shell's refusal to retract her assessments
of their business practices. They have even gone to the extreme of contacting attomeys
representing counties where Shell associates do business in attempts to influence specific cases.
Mr. Tower has been instrumental in this effort clandestinely, while claiming to remain neutral and
uninvolved.
This attempt is yet the latest ofmany. His statements are untrue. If hetestifres to these things
under oath, I would believe he would stand open to prosecution for perjury. There is no way that
he could misconstrue the facts to the extent necessary to claim these statements were simple
misunderstanding. They are pure malicious fabrication. I had withdrawn from active participation
in the AFRA association in mid-200S. I have recently removed myself from all involvement with
that organization because ofthe appointment ofBill Tower to succeed the founder as their
president.
I attest that the foregoing statement is true and correct to the best ofmy knowledge under penalty
ofpeJjury.
&r
_~5;.....". I 20b 10
Christine M. Kom Date

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of 67
Exhibit E
1 SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF SACRAMENTO
2
3
WILLIAM O. TOWER
4 Plaintiff Case No.:06AS03504
THIRD PARTY motion for Dismissal
5 And Counterclaim Fo infliction of emotional
Distress and in sion of privacy
6
v.
7
SUZANNE SHELL
8 Family Rights Advocacy Institute
9 Family Rights Advocacy CENTER
Defendant and '
10
Counterclaim Plaintiff and
11 Third Party Claim Plaintiff
v.
12
AMERICAN FAMILY RIGHTS
13 ASSOCIATION, a professional association
ANN TOWER, an individual
14
LEONARD HENDERSON, an individual
15 SUSAN ADAMS JACKSON AKA SUSAN
WOLVERTON, an individual
16 CLETUS KffiFER, an individual
17
FAMILIES AT RISK DEFENSE ALLIANCE,
a Missouri unincorporated business
is FRANCFNE RENEE CYGAN, an individual
MARK CYGAN, an individual
19 ILLINOIS FAMILY ADVOCACY
20 COALITION, an Illinois unincorporated
business
21
DOROTHY KERNAGHAN-BAEZ, an ) Case No.: 06AS03504
individual )
[Pleading title]
22 GEORGIA FAMILY RIGHTS, INC. (GAPA) :
a non-profit corporation )
23
DENNIS HINGER, an individual )
24
3 NATIONAL ASSOCIATION OF FAMILY )
ADVOCATES, a professional membership :
25 organization )
AIMEE DUTKIEWICZ, an individual
26
5 THOMAS DUTKIEWICZ, an individual
27 CONNECTICUT DCF WATCH, an
unincorporated business
28 WILLIAM WISEMAN, an individual,
7 WISEMAN STUDIOS, an unincorporated
THIRD PARTY motion for Dismissal And Counterclaim
For and infliction of emotional distress and invasion of privacy - 1
of 67
1 This oourt Dismissed Family Rights Advooaoy Institute Beoause They

were Not Served, well now J: Think It Might Be Time To Revive It Mrs.
2 shell ola~s -en or before April 11, 2006, wiseman impermdssibly
oiroumvented copy proteotions and oopied the oontent of ~ entire web
3
site www.profane-jsutioe.org- this is false at no time did % publish
4
anything from www.profane-jsutioe.org on the truth is told website or
anywhere else J: linked to her site this was it. The File J: got about
5 The igeeks Came from the website http://badadvooates.oom/ whioh she
sworn up and down to everyone that she didn't own...she wrote Go daddy
6 about This page about the igeeks and had m.Y domain by Proxy where ~
name and address was private shut down with out a oourt order 47
7 U.S.C.A. Section 551(2)(B) and they oharged me money because of her
clai~ng copyright Then she went after m.Y website beoause J: linked too
8 her website and had m.Y website shut down in whioh % got an attorney
and got the website Back up and now oa11 it the truth is still told •••
9
And Mrs. shell even went as far as Putting MY name and home address
10 with that of a fifteen year old uP On her website www.profane
jsutioe.org
11 Brenda swallow sent me a pdf File that shell gave to people at her
seminar held %n Florida and I took it apart and used oopyscape.oom
12 To Find out where it came from and that pdf file was taken from a
government website and J: threw a fit and I was told by a friend too
13 take it off m.Y website and destroy it whioh I did bu~ i~ made me
wonder what else did she steal and just about everything she writes
14
has oame from somewhere else aooording too copysoape.com, even her
15
oopyright notioe that she has on her website was taken from
printusa.com out of 'the Denver area_
16 Mrs. shell sued Brenda swallow For sending me The seminar handout that
shell gives away at the seminars and won a default judgment of eight
17 thousand dollars Because Mrs. Swallow wanted to go party then fight
with the likes of shell and now she is acousing ~ friend ann of the
18 very thing she sued Mrs. swallow for
Mrs. shell Has JUst admitted To This court That she is the owner of
19 www.profane-jsutioe.org Family Rights Advocacy Institute and on her
website the sites name is Family Rights Advocacy CENTER so Now Mrs.
20
Suzanne Shell and the Family Rights Advocaoy CENTER and Family Rights
21 Advooacy J:nstitute is Properly served as They Are One and The Same
person...
22
As for copyright every time You make changes too your website You must
23
reoopyright the website and aocording too go daddy when they was
24
offering the servioe it cost 69 dollars to register with the copyright
25
office each time that you made ohanges too your website. and Mrs.
26
shell sued. :Internet Archive for copying her website 87
27
times for all the changes shell has made •• and my
28
question is did shell pay the copyright office those 87
THIRD PARTY motion for Dismissal And Counterclaim
For and infliction of emotional distress and invasion of privacy - 5

Amended and Supplemental Complaint

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Case 1:09-cv-00309-MSK -KMT Document 464 Filed 04/07/11 USDC Colorado Page 1 of

UNITED STATES DISTRICT COURT

Civil Action 09-CV-00309 MSK-KMT

AMERICAN FAMILY RIGHTS ASSOCIATION

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

they were discrediting–to market their businesses, their organizations, occupations,

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

services. By 2002, my national reputation was unparalleled in this market.

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

training and licensed it to use my intellectual property.

Shell v. AFRA et al First Amended and Supplemental Complaint

my training would be able to capitalize on the superior outcomes and methods by

Shell v. AFRA et al First Amended and Supplemental Complaint

81. I have created other complementary accredited CLE presentations on“Mandated

Shell v. AFRA et al First Amended and Supplemental Complaint

market presence in the past four years.

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

harassing, threatening and even taking action on their threats.

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Consumer Advisory Publication at

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

missions and/or the joint mission.

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

engaged in lengthy business ventures with Colorado entities, directing numerous

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

rights and freedom advocates. . . .” Mission Statement.

Shell v. AFRA et al First Amended and Supplemental Complaint

http://groups.yahoo.com/group/Iowa_Family_Rights/; (Iowa state specific)

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

AFRA web site at http://www.familyrightsassocation.com/advocates/responsiblity.html.

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint

these Colorado attorneys.7.

Shell v. AFRA et al First Amended and Supplemental Complaint

Shell v. AFRA et al First Amended and Supplemental Complaint