IN THE UNITED STATES COURT FOR THE EASTERN DISTRICT
Transcription
IN THE UNITED STATES COURT FOR THE EASTERN DISTRICT
IN THE UNITED STATES COURT FOR THE EASTERN DISTRICT OF PENNSYVLANIA GORDON ROY PARKER, a/k/a "Ray Gordon," 4247 Locust Street, #119 Philadelphia, PA 19104 (267) 298-1257 [email protected], Plaintiff, v. JACQUELINE FAYE GOLDHAGEN, a/k/a "Jacqui Holland" 10524 Pico Boulevard, #216 Los Angeles, CA 90064, Defendant : : : : : : : : : : : : : : : : : : : : Case No: Complaint for Declaratory Relief, Fraudulent Misrepresentation, Breach of Contract, and Defamation COMPLAINT FOR DECLARATORY RELIEF, FRAUDULENT MISREPRESENTATION, BREACH OF CONTRACT, AND DEFAMATION Plaintiff Gordon Roy Parker ("Plaintiff"), in the above-styled action, based upon information and belief, sets forth and avers the following: THE PARTIES 1. Plaintiff Gordon Roy Parker, a/k/a "Ray Gordon," is an adult male domiciled and residing in the Commonwealth of Pennsylvania, who may be served at the address listed for him in the caption. Plaintiff is the owner and operator of Snodgrass Publishing Group, a Pennsylvania Sole Proprietor and Internet media company, whose primary website is toosmarttofail.com. 2. Defendant Jacqueline Faye Goldhagen, a/k/a Jacqui Holland ("Defendant"), is an adult female domiciled and residing in Los Angeles, California. She is a "rising star" actress known for cutting-edge and extremely sexy PG-13 work (e.g., Bikini Avengers, Hollywood Sex Wars, Life As A Hot Loser, etc.), and a hypnotist/life coach, who may be served at the address listed for her in the caption. Her current website is http://www.newagehypnotist.com. NATURE OF ACTION 3. Many years ago, this court branded Plaintiff a serial litigant, though he would assert that time has validated his arguments. With two cataracts, Stage III COPD, two gallstones, high blood-sugar, and numerous other medical concerns, Plaintiff has far better things to do than to "throw down" in Federal court. Nevertheless, this case exists solely because Defendant threatened to sue Plaintiff over a negative Yelp! review, using her attorney to amplify the threat. Plaintiff's review of the underlying facts, and subsequent events, have given rise to this action. 4. This action stems from the breach of a contract, a threat of litigation by Defendant over Plaintiff's negative review of her practice, and alleged defamation of Plaintiff by Defendant in response to said negative review. All attempts at mitigation and settlement have failed. STATEMENT OF JURISDICTION AND VENUE 5. Personal jurisdiction in Pennsylvania is conferred by Defendant's threat to sue Plaintiff, as the defamation suit would have to occur in this jurisdiction. 6. Subject-matter jurisdiction is conferred by diversity jurisdiction and the amount in controversy, both in the Complaint and in the threatened defamation claim. 7. Supplemental jurisdiction is conferred over all other claims. 8. Venue is proper because Plaintiff resides within the Eastern District Of Pennsylvania. 2 BACKGROUND 9. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire contents of all previous paragraphs, and all exhibits to this Complaint. "Boxing Jacqui" 10. On June 4, 2015, after viewing an impressive (and very sexy) display of hypnotic talent from Defendant, in a "past-life regression" video on YouTube, Plaintiff began exploring the possibility of hiring Defendant to make for him a customized hypnosis video, hopefully the first of at least two, to help improve Plaintiff's eyesight by dilating his pupils, with the second to help him improve at chess by linking winning at chess to the reward-center response created by desire for the attractive female hypnotist. 11. Initially, the eyesight video, in which a sexy female hypnotist uses her beauty and powerful hypnosis technique of the kind possessed by Defendant (and few others, let alone sexy female others), was Plaintiff's top priority, due to its (relatively) tame content, and commercial potential. Plaintiff, a successful and profitable producer of hypnosis recordings in his own right (Anonymistress, Hellen I/II, MegaSleep), had hoped to produce the "eye video" to launch his Patient Empowerment Network Of New York (PENNY), via the website http://www.patientempowerment.net, which is currently under construction. Penny Parker is Plaintiff's late mother. With a strong alternative-medicine presence fueling the portal, Defendant was even more of a perfect fit for the gig. 12. The eye video seemed directly up Defendant's alley, given her willingness to be sexy on camera, especially for a greater purpose (eyesight), her extreme level of training and polish generally common only to working performing artists, her three years of experience as a stage hypnotist, her active hypnosis practice, and that she and her eyes were desirable enough to 3 induce pupil dilation, the goal of the video. Hypnotherapy videos with similar content from similar talent can easily gross tens of thousands of dollars, more than enough to launch PENNY, which Plaintiff hopes to one day establish as an empowered-patient portal connecting likeminded practitioners and patients. The primary barrier to producing such videos is finding talent, which is why they sell so well. 13. Had the eye video been made successfully, at first for Plaintiff's personal use, Plaintiff intended to offer Defendant the "number two" role in PENNY, as its spokesmodel and primary hypnotist, with revenue from the eye video serving as a form of charter contribution (of Plaintiff's half of the revenue). Her royalty from the eye video would have been 50 percent of gross profit, while the "charter spokesmodel" gig included five percent ownership of the portal. For perspective, the painter of Facebook's in-house mural was paid in stock which wound up worth over $200 million, far more than the value of the actual painting. 14. The eye video was never proposed to Defendant, because Plaintiff soon discovered that Defendant offered custom fetish videos (hypnosis is a known sexual fetish) via the Customs Club website (http://www.customs4u.com), to an audience which includes men who, like Plaintiff, enjoy being hypnotized by beautiful women: 4 http://www.customvideosclub.com/customsclub/jacqui-holland/ Retrieved on June 8, 2015 at 9:07 am 15. Plaintiff was hardly shocked (though delighted) to learn that Defendant had (apparently) embraced the sexy, cutting-edge side of hypnosis, as her YouTube video had also indicated. He immediately sought, and found, confirmation that this ad was genuine, via Defendant's own Twitter account: 5 https://twitter.com/jacquiholland/status/586806082959441920 Retrieved June 8, 2015 at 9:14 am. 16. Plaintiff has long expected Hollywood and the hypnofetish to finally collide, having waiting patiently for years for someone with Defendant's skillset and experience to materialize, and had finally found what he was seeking. Having finally found one, he was going to approach her with great caution, great respect, substantial compensation, and a vision which he hoped she would share enough to make real and profitable, not much different from other internet collaboration. 17. Prior to offering her commercial projects, however, Plaintiff's first goal was to secure, for his own use, a hypnosis induction video, preferably for chess. He therefore avoided creative 6 conflict at all costs, deferring to Defendant's wishes regarding scripting, content, and the limits of sexualized expression for the first video. 18. In the absence of the Customs Club page, Plaintiff would have simply offered Defendant the eye video, with its g-rated script, told her he wanted a deep trance with an eyecontact induction, and suggestions of extreme pupil dilation, a request to which Defendant certainly would not have objected. Once completed, Plaintiff would then have offered a minimum of $5,000.00 for the rights to the video, up to a percentage of PENNY in return for the spokesmodel gig, with the work already having been performed. Based on information, belief, and the common-sense of a kindergartener, Plaintiff avers that Defendant would have accepted the spokesmodel gig. 19. By working through Customs Club, the parties were still primarily contracted to each other, but also to the third-party website, thus further ensuring the likelihood that Plaintiff would actually receive the chess video once ordered. Not long after first viewing her YouTube video, Plaintiff offered Defendant $1,000.00 to make a "sexy hypnosis video for chess improvement," with the type of scripting mentioned earlier in this Complaint. 20. As with the eye video, the chess video's market value was such that Plaintiff had planned to offer Defendant a substantial amount of money for the rights to this video, for his Chicks Dig Chessplayers campaign, tied to Plaintiff's successful dating-advice books. 21. Defendant accepted Plaintiff's offer, not once, but twice (Plaintiff had submitted a duplicate by mistake): 7 22. A binding contract between the parties now existed. 8 23. To avoid any confusion created by the duplicate offers, Plaintiff immediately e-mailed Defendant at the address listed on her Twitter page to clarify that he was paying $1,000.00 for the chess video, and for her to delete the second offer. Upon written acknowledgement of which of the two contracts was the valid one, Plaintiff would immediately pay the $1,000.00 to Customs Club. 24. Defendant responded to Plaintiff's e-mail with a counter-offer of her own: ` 25. In response, Plaintiff fired Defendant, due to her extreme lack of ethics, telling her only that she had "flunked an audition [he] wasn't even giving," as there was no need to inform someone with whom Plaintiff was breaking contact any further regarding why. In the letter, Plaintiff requested that Defendant never contact him again. 9 26. The breach also destroyed Boxing Jacqui for Plaintiff's personal use, since he no longer trusted the hypnotist "inside his head." Plaintiff elected to cut his losses and continue his search, lest he be falsely accused of pestering Defendant. 27. Despite the explicit advisory not to contact Plaintiff in this state, Defendant immediately e-mailed him three consecutive times, with Plaintiff deleting all three mails without reading, as he had no intention of ever hiring or speaking with Defendant again. 28. At this point, Defendant's e-mails ceased, and Plaintiff "took his case to the people." 29. Between his negative experience with Defendant, and her having "stalked" him three times, Plaintiff decided to don his social-justice warrior (SJW) cape, and post online reviews of Defendant, as well as making "protest" posts on her social-media pages, concerning both the breach of contract, Defendant's marketing as a fetish model, and the annoyance of having to remove the "hypnotic seal" Plaintiff had allowed to develop in order to make himself more receptive to Defendant's anticipated video hypnosis. Even without hypnosis, any dispute will intensify emotions temporarily, until cooler heads prevail. 30. On June 6, 2015, Plaintiff posted his review of Defendant to Yelp!. The full text of the review as it last appeared on June 9, 2015, before Plaintiff voluntarily replaced it pending adjudication, is attached hereto as Exhibit A and incorporated by reference as if fully stated verbatim herein. 31. Plaintiff avers that there are no false and misleading statements concerning Defendant in Exhibit A, his Yelp! review of her practice. 32. On June 7, 2015, Defendant E-mailed Plaintiff, with a copy to her attorney, Steven J. Dedina, Esq., a cease-and-desist order, threatening legal action if Plaintiff did not remove all of his postings concerning Defendant and her practice, including the Yelp! review. 10 33. Defendant consented to publication on her own social-media pages, and has (or had) full power to moderate and delete any postings, without involving Plaintiff. 34. At the time of publication, Defendant either knew, or should have known, that the Yelp! review was not defamatory, and that to threaten litigation over same runs afoul of both California's anti-SLAPP statute, and Pennsylvania's Dragonetti Act. 35. As mitigation gestures of good faith, and pending the outcome of this litigation, on June 10, 2015, Plaintiff replaced the Yelp! review with a five-star review of Defendant's "ability 11 to put people into hypnosis," while noting he may update the review later. He added a rebuttal to the Ripoff Report review that the audience should reserve judgment until all facts are revealed at this trial, and that he would retract and abandon any position ruled unfavorably, in lieu of deletion, which Ripoff Report does not allow. Defendant was immediately put on notice of this. This is the new Yelp! (five-star) review of Defendant's induction ability, with the original on free-speech chilled ice until adjudication 36. Not content to wait for her day in court, on June 7, 2015, Defendant posted a rebuttal to the Ripoff Report: 12 http://www.ripoffreport.com/r/New-Age-Hypnotist-Jacqui-Holland/Los-Angeles-California-90064/ New-Age-Hypnotist-Jacqui-Holland-Fetish-Models-Should-Not-Do-Hypnotherapy-Los-Angeles-Ca-1234148 Retrieved on June 9, 2015 at 9:50 pm 37. Defendant's statement contains four parts: a) a claim that Plaintiff tries to ruin the careers of attractive female hypnotists; b) that Defendant is a "board certified hypnotist," c) that she is not a "fettish" [sic] hypnotist, and d) that the contents of the site to which Defendant Linked -- the user-created Encyclopedia Dramatica "wiki" style page about Plaintiff -- were factually kosher, and painted a correct portrait of Plaintiff. 38. At the time of publication, Defendant either knew or should have known that the statement in 37(a) is false. She has confused Plaintiff's opinionated reviews and speech with deliberate attempts to ruin careers. Prior to her breach, his only intention was to pay her 13 $1,000.00 for an amazing hypnosis video, and perhaps move on to monetizing their collaborations. 39. Defendant's claim in 37(b) that she is a "board certified hypnotist" runs afoul of numerous California laws governing commerce and medical practice, while her claim in 37(c) that she is not a "fettish hypnotist" [sic] are refuted by photographs in paragraphs 14-15. Encyclopedia Dramatica (ED) 40. Encyclopedia Dramatica, best described as a Wiki From Hell, and to which Defendant linked as noted in 37(d), is on a foreign-based server, for all purposes immune from suit and liability, even for the authors of its user-generated content, who use it as a refuge for content which would never last on an American server, and which would have them sued immediately upon publication. Plaintiff became aware that a page devoted to him (the "ED page") had been created sometime in 2011. Its content has recently changed drastically, and it was last updated in May, 2015: https://encyclopediadramatica.se/Ray_Gordon Retrieved on June 8, 2015 14 41. ED is run by Lulzsec, a splinter group from Anonymous. In late 2011, when Plaintiff was "following the money," a PayPal donations link was provided to him for the account of Ryan Cleary, who, at the time, had been ordered off the internet by a British court for various computer-related crimes. 42. The section of the ED Page entitled "USENET" states the following concerning Plaintiff: 43. Defendant's chosen source, a website which claims that the Jews did WTC, contains a link to a USENET posting in alt.sex.stories, which the ED page claims was authored by Plaintiff, and which is "fanfic that resolves around himself torturing, raping and killing young gymnasts." The link to the first part of the story is in Google's USENET archive at http://groups.google.com/group.alt.sex.stories/msg/e17add4a3645c68e. That story states, in part, verbatim (with headers truncated): From: [email protected] Subject: Ray Gordon vs. The Magnificent Seven Date: 1998/09/18 Message-ID: <[email protected]> 15 Newsgroups: alt.sex.stories Ray Gordon vs. The Magnificent Seven My name is Ray Gordon. I’m a mercenary, a soldier of fortune, a hired gun, a bounty hunter, only I don’t fight wars or catch crooks. My work is .. shall we say .. a little more specialized. People pay me to stalk, terrorize, torture, rape and sometimes .. yes .. even snuff beautiful young starlet cunts. In other words, I’m a pussy hunter, a cunt commando, if you will. I love my work, and I ask no questions. Someone wants me to stalk, rape and snuff some stuck-up starlet cunt, that’s their business. As long as they pay the bills and the veal is fresh, that’s all I care about. That’s why I don’t bat an eyelash when the limo pulls up to Divers Bar & Grill, my favorite hangout, and some chink in a suit and tie steps out. I’d gotten a page an hour before, made the call, and arranged the meeting. When the chink walks in the door, I can tell he’s a spook. He spots me right away and gestures at me with his finger. I smirk, get up, and follow him out the door. The limo door opens and the chink slides in. I scan the area for trouble, see nothing, and follow suit. A fat, smelly, chink in a sweaty uniform is sprawled out along the back seat. He is eating an ice cream sundae, and strawberry sauce is smeared over his mouth like bad lipstick, making him look a little queer. The chink in the suit gives me another finger wag, and I decide to commit myself by taking a seat. As soon as I’m completely inside, the chink slams the door behind me, and the limo speeds off. “You were recommended to me,” the fat chink in the uniform lisps. “My people tell me you ..do things for people .. for a price.” “Your people were right,” I counter. “The price depends on the job. High profile, high overhead. I don’t take any jobs where I can’t come away clean. That kind of security takes money. I’m a pro .. the best in the business .. and I only work with pros.” “I assure you, Mr. Gordon,” the chink in the suit finally speaks, only it’s more like a sneer. “We are professional ... thoroughly professional. You, on the other hand, don’t appear to be any more than a beer-swilling ... how do you Americans say it ..? loser ...” “Appearances can be deceiving, Charlie,” I return his gaze with some ice of my own. “Perhaps you’d like to pull over and see how much of a loser I am.” “That won’t be necessary, Mr. Gordon,” the fat chink in the uniform interrupts. “My sources are impeccable. They tell me you’re the man we need for this operation, and that .. as they say .. is that.” The chink in the suit turns away from me and stares out the tinted windows. "So, tell me about this operation ..?” I turn to the fat chink. “Just who the fuck are you guys? Vietnamese? Korean?” “Chinese,” the fat man doesn’t look pleased. “I am General Chow-Fat of the People’s Republic of China. This man is an agent of my government’s intelligence organization. We call him Dragoncock.” “Cute ...” I almost laugh. “I assure you, Mr. Gordon,” the general was trying to sound threatening. “Mr. Dragoncock is anything but cute.” “So what do you want with me?’ I ask, tiring of the game. “You obviously want me to bag some cunt for you, so why don’t we just cut to the chase.” 16 The general smiles and hands me an envelope. There’s a photo inside, a photo that almost makes my jaw hit the floor. Almost ... “That’s the US Women’s Gymnastics team,” I try not to sound apprehensive. “I believe your press has dubbed them the Magnificent Seven,” Chow Fat licks his lips as he speaks. “They are due to appear at the Olympic Games in Atlanta in two days. We believe they will defeat our glorious team. They cannot be allowed to do so. Am I making myself clear?” “You want me to nab these cunts so they don’t show up your slanty-eyed gook girls at the big Games,” I laugh. “That’s a new low, even for me." “You won’t do the job, then?” Chow Fat seemed puzzled. “I was told you ...” “I didn’t say that, Fat Man,” I cut him off “Perhaps, Mr. Gordon knows when a job is beyond his abilities,” Dragoncock spoke softly. “There ain’t no cunt bagging job beyond my abilities, Snailcock,” I glared at him. “I’m just trying to figure out the angle here. So, you guys need to win. I can respect that. So why not just snip their brake cables or something. Why do you need me? I’m a cunt hunter; I don’t fix sporting events. The mob takes care of that kind of shit.” “Just eliminating the girls is not enough, Mr. Gordon,” Chow Fat lisped. “They are an affront to our way of life. They are admired as capitalistic idols while our girls cower in their shadow. Death is not .. suitable. It is not enough. They must be shamed, broken, defiled, rendered inhuman. They must have every bit of their dignity stripped away before the world’s eyes. They will be the butt of every bathroom joke in the world. They will be so shamed, they will wish to die. Our ideals will prevail, and our girls will be the darlings of the world ..." “I’m beginning to get the picture,” I cut him off. “This isn’t about just winning the Olympics. This runs deeper, more political.” “It is not political, Mr. Gordon,” Chow Fat wheezed. “It is a matter of survival. Since the accursed Russians and their allies have fallen, we are the last bastion of Truth in the world. We will not be denied our glory by seven young teenage cunts, as you call them.” He paused. “So will you take the job?” I paused. I had to hand it to Fatty. He knew how to pitch. I could just see myself choke fucking one of the little cunts, jamming my cock down her throat, and making her bend to my iron will. He had me interested, and he knew it." “This is some serious shit,” I spoke after another moment. “I’ll need some men for this ...” “Your fabled Zero Squad,” Fatty winked at me. “That’s right,” I nodded, impressed that he had obviously done his homework.. “I get one million; my first lieutenant Killjoy gets a half mil; each man gets a quarter." “And how many men will you need?” Fatty didn’t even bat an eyelash when he heard my price. “At least 25 if you want the job done right.” “25?” Dragoncock exclaimed. 17 “You can pay me, or let Snaildick here handle it,” I smirked. “Although I guess you already considered that option, which is why I’m sitting here.” I paused. “That’s my offer. I don’t dicker. You have three more seconds to consider it.” “You will have your money,” Fatty didn’t even drop a beat. “But, you will be accompanied by Dragoncock in order that we may keep track of our investment.” From the tone of his voice, I knew this was non-negotiable, a necessary evil, if you will. I thought of the money and the tight teenage pussies that awaited me. “Okay, you’ve got a deal.” Like I said, I enjoy my work. 44. In December, 2011, Plaintiff asked the ED administrators to delete the ED page, which prompted them to taunt him that the server's real address is hidden behind its proxy host, CloudFlare, of California, and to effectively threaten to attempt to make Plaintiff homeless should he file suit, with the following threatening e-mail: 45. The ED page has been linked to or referenced by many of Plaintiff's political adversaries, including notable "revenge porn" advocates Adam Steinbaugh and Amanda 18 Levendowski, both juris doctors. The existence of the ED page has isolated Plaintiff to the point where interacting with others risks violent vigilante "justice"; he has often contemplated suicide, though has no plan or intent (his COPD would seem to allow him to off himself in Oregon). 46. At the time of publication, Defendant either knew or should have known that Plaintiff did not author this essay. It was authored by a thirty-eight year-old man from Massachusetts named David Clanton, a gymnastics groupie who was enlisted, in exchange for personal access to the Magnificent Seven and other elite gymnasts, via a female coach named Linda McNamara, who admitted a few years ago in an article that she covered up sexual abuse in the gym where she worked, run by disgraced elite coach Don Peters. McNamara had taken it upon herself to attempt to discredit Plaintiff's claims that Olympic gymnast Dominique Moceanu had been abused, organizing a group of fans, including Clanton, who would call itself the Gymnastics Mafia. 47. The male Mafia members were given duties that included a) sending a computer virus to Plaintiff b) threatening violence and death against Plaintiff and his mother; and c) impersonating Plaintiff online and making sexualized comments to gymnasts in order to shift the blame to Plaintiff, who survived any and all investigations into his conduct, as he is simply not a pedophile and was merely seeking to stop child abuse. 48. In late 1997, Clanton taunted Plaintiff that he had impersonated Plaintiff's late mother, Penny Parker, twice, on USENET, in a manner which has subsequently sent men to prison: 19 Post #1: https://groups.google.com/forum/#!original/alt.personals.bondage/EdpOnxy4zfM/Z7XBusJSTecJ Retrieved June 11, 2015 2:07 am 20 Post #2: https://groups.google.com/forum/#!original/alt.personals.bondage/EdpOnxy4zfM/Z7XBusJSTecJ Retrieved June 11, 2015 2:10 am 49. Plaintiff, who quickly posted a response to the first message, warning men not to call, knows exactly how many did so anyway, because he answered each call: four. The purpose of the ad was to drive Plaintiff's mother -- like the astrologer Defendant, a Taurus born in mid-May -- into evicting her caregiver son, so as to cut off his internet access. Further playing to the stereotype of the loser-who-lives-with-his-mother by Clanton and other Mafia males included false claims that Plaintiff was on welfare and food stamps. In reality, Plaintiff had grown up well-off on the Upper East Side of New York, and had long since tired of using money and status to win the approval of individuals like Clanton. 21 50. The purpose of the female Mafia members, most notably McNamara and Pearson, was to make false allegations against Plaintiff, and to enlist the males in various tasks to intimidate or harm Plaintiff, all in the name of covering up the Moceanu abuse story. When Moceanu ran away in October, 1998, this conflict effectively ended, though various skirmishes would continue through the 2000 Olympics. 51. In the section of the ED page entitled Ray's Self-Proclaimed Careers, any job or business engaged in by Plaintiff is defaulted to scam status, further evidence that Plaintiff is just an overall fraud: Source: ED PAGE, Retrieved June 9, 2015 22 52. At the time of publication, Defendant either knew or should have known that numerous of the above statements concerning Plaintiff are false and/or misleading, to the point of portraying Plaintiff in a false light. Plaintiff has a 4.0 GPA from a year at SUNY, his USCF rating peaked at Expert (90th percentile) within two years of his first tournament game. Plaintiff coached the 1990 Parkway Gamma High School from an 0-3 record when he got them, to a 5-5 finish, third place, and a 9-1 crushing win over third-ranked Washington to close the year. He has given paid psychic readings (Defendant does similar and is not mocked), has produced hypnosis mp3 recordings that have grossed five figures, grew up among a home-based transcription service which was the largest in NYC at its peak in 1979, has designed popular and profitable methods for rating horse races and sports teams, types 100 wpm, has worked for years as a high-level secretary and paralegal, and published an article about the Moceanu abuse case in 1995, and again in 1997, long before the truth was known to the public. 53. At the time of publication, Defendant either knew or should have known that the imputation of unauthorized paralegal practice upon Plaintiff is false, although an investigative reader would quickly verify that Pennsylvania has no such restrictions, contrary to the claim. RayFAQ: 1999-2014 54. Even after Moceanu's scandal resolved, the RayFAQ continued to follow Plaintiff wherever he went online, including alt.seduction.fast, Ground Zero for the internet "pickup artist' (PUA) movement, popularized by Neil Strauss's The Game (2005) and VH-1's The Pickup Artist. In tow from alt.sports.gymnastics came Thom E. "Subzero" Geiger (Posting as [email protected]), who registered the domain ray-gordon.com, where he ultimately hosted the RayFAQ, but only after he was banned from hosting it on the server of hardcore white- 23 supremacist group The Order Of White Knights. "Subzero" is not to be confused with the "zero squad" referenced in the rape/murder essay. 55. Immediately upon publication of Outfoxing The Foxes, Plaintiff became a target for defamation in the USENET group alt.seduction.fast (ASF), Ground Zero for the internet "PUA" movement which would mainstream in 2005 with Neil Strauss's The Game. This was painstakingly detailed in Plaintiff's RICO claims in Parker v. Learn The Skills Corp. (I-III), (case cites omitted). Leading the charge from alt.sports.gymnastics was Geiger, who originally claimed his wife, Susan, was so enraged by Plaintiff's postings that Geiger was spurred into action. Joining Geiger on ASF was Derek "Odious" Trunk, the group's self-proclaimed "FAQ administrator," and an internet right-hand to Ross Jeffries, another PUA guru featured in The Game, a teacher of NLP seduction, or the use of covert hypnosis to seduce women. 56. On ASF, the RayFAQ page had morphed from its original purpose in the gymnastics community, to a robo-defamation machine which conferred Section 230 immunity on anyone who linked through it to ray-gordon.com, including Geiger (or so he claimed), the sole individual Plaintiff could sue directly, in Columbus, Mississippi. Geiger had repeatedly threatened Plaintiff with physical violence, making it terrifying for Plaintiff to file suit in Mississippi; he instead pursued a RICO action in this district (Parker v. LTSC I), which failed. 57. Beginning in 2001, a man later identified as John J. Tashjian ("JJT") began posting to ASF, repeatedly linking to the RayFAQ, and eventually claimed the RayFAQ.com domain when Plaintiff finally abandoned it. In conjunction with Trunk (Odious), Geiger, and others on ASF loyal to Jeffries, they disrupted every thread to which Plaintiff would post, in order to destroy his ability to communicate with his fan base, and to defame him at every turn. 24 58. Tashjian's many threats against Plaintiff are already canonized in the Parker v. LTSC trilogy. Typical of his conduct, which includes thousands of similar postings all tarring Plaintiff while linking to the RayFAQ and Google-bombing his birth name, was the following (split into parts): 25 https://groups.google.com/forum/#!original/alt.support.loneliness/QfUGMkCX9VQ/Z3eLO6qJiJoJ Retrieved June 11, 2015 2:22 am 59. On July 7, 2010, Tashjian threatened to "bitchslap the dogfuck out of" Plaintiff, leave him in a wheelchair, and "maybe film it": 26 https://groups.google.com/forum/#!search/JJT$20threat$20beat$20me$20up$20video/alt.seduction.fast/TZYeSOkY_l4/PjdQP7GjH3AJ Message ID: [email protected] Retrieved on June 11, 2015 2:40 am 60. This was far from the only threat from Tashjian (this Complaint would run five thousand pages if it included everything), who had claimed to have Plaintiff's mother on video. Tashjian's relatives include prominent attorneys and municipal employees (retired) in Worcester, not far from Clanton's Boston-area residence at the time. Tashjian is apparently on disability and "judgment-proof," a perfect beard for more powerful, more sinister forces. 61. In 2004, JJT posted repeatedly that he had been contacted by "folks" about making a movie concerning Plaintiff: 27 62. While the ASF extension of the Mafia, linked through Geiger, continued its harassment of Plaintiff, anonymous postings diverted most ASF traffic to commercial websites like fastseduction.com, on which a parallel, commercial PUA community was built, with the public never the wiser regarding the lack of free speech, the stealth marketing, or Plaintiff's early contributions, due to the perpetual noise and ostracizing on ASF, of which the foregoing is the mere tip of the iceberg. Once The Game dropped, ASF all but lost relevance to the PUA community, though it will exist in perpetuity. 63. Also as noted on the ED page, Plaintiff's mother was contacted offline by Trunk, in April, 2007, by letter, just months prior to her death from cancer in July, 2007. 28 64. A few days after the first letter, which Plaintiff mentioned on ASF in order to flush out the author, a second letter arrived, notifying Plaintiff that copies of the second letter were being circulated around his neighborhood. 65. After Plaintiff published the notice that he had received a "death threat" against his mother (veiled, a reference to how Plaintiff could not survive financially after her impending passing), Trunk claimed to have found the letter online, read it, and that it did not contain any such threat. Trunk had also continued to link to the RayFAQ, now hosted by Tashjian. 66. On January 26, 2010, Plaintiff officially retired as a pickup artist (PUA), published Bettor Off Single for free, with advertising links to his other writing, on PUA and beyond. 67. Thanks to mass murders by failed PUA (Sodini, Rodger), Plaintiff has been thrust back into the spotlight, with a new generation of his haters linking to the ED page and the RayFAQ, with the former updated to reflect Plaintiff's new imputed "failures." Ironically, these are often anti-PUA feminists who are unwitting pawns of the very men they claim to despise. Where Are They Now? 68. No one in this drama went on to rescue a drowning Brooke Shields, only to blow the reward money by hiring Van Halen to play their birthday party, nor, to Plaintiff's knowledge, has anyone used hot coffee to foil a convenience-store robbery. Instead, the modern internet, and current events, have, for Plaintiff, just as they have for @AdamFGoldberg, made the past keep getting clearer every day. 69. As KTLA-5's award-winning news desk may have reported, on February 8, 2012, San Diego resident Derek "Odious" Trunk, the self-appointed anti-pedophilia crusader whose sole mission on the internet seemed to be To Catch A Plaintiff, was sentenced to seventy-five (75) 29 months in prison for trafficking in child pornography, an offense he would not have been able to commit for as long had he been prosecuted for his conduct towards Plaintiff years earlier: http://www.ice.gov/news/releases/san-diego-man-sentenced-20-years-possession-child-pornography Retrieved June 11, 2015 3:39 am 30 70. Dominique Moceanu later admitted to having been kept in the dark "about a lot of things" as a teenager. She is now a mother and roving gymnastics coach, and learned not long ago that she has a biological sister who was born without legs and given up for adoption at birth. Plaintiff had alleged that Moceanu was pledged by her parents to Bela Karolyi in return for the latter helping the former escape communist Romania ("An American Slave," USENET, 1997). 71. In 2009, Thom E. Geiger ran as an "indie" for mayor of Columbus, Mississippi...and lost. He still practices political activism. 72. When we come back, we'll reveal the most interesting Where Are They Now? of all. COUNT (SUB)ZERO: RICO VIOLATIONS AGAINST NO ONE 73. Plaintiff incorporates by reference, the entire contents of all previous paragraphs, as if fully stated verbatim herein. A Friend To All Is A Friend To None 74. One of the silent partners of the Gymnastics Mafia was a teenager who went by the handle [email protected]. 75. On December 14, 1997, while Plaintiff's mother was being impersonated by Clanton and or Merlock and the Mafia, in exchange for celebrity access to sexually abused gymnasts, Plaintiff posted a "protective" warning message to alt.sports.gymnastics, concerning Merlock, which was replied to by Mafia member Kevraxx, likely an alternate identity for Merlock: 31 https://groups.google.com/forum/#!original/alt.sports.gymnastics/mmp58gdPuMo/lWWOVlGsw6kJ (Quoting Plaintiff's Allegations) Retrieved June 11, 2015 5:57 am 76. On June 29, 1998, Merlock06 posted, to alt.sports.gymnastics, a purported IM exchange with Plaintiff (in parts): 32 https://groups.google.com/forum/#!original/alt.sports.gymnastics/ecx9_kWyILQ/7WG5X0_J5wEJ (all parts at link) Part 1 Above Retrieved June 11, 2015 4:55 am 33 Part 2 Above 34 Part 3 Above 77. This exchange has temporal proximity to the creation of the RayFAQ, and followed numerous direct, terroristic, and frightening threats made against Plaintiff in an IM, and in the Gymnastics Chatroom on AOL. 78. Though Plaintiff said most of the words in the chat, it was Merlock's presence which did the real talking, revealing his protector role. His lines were straight out of mafia fiction: 35 a) "My friend...you do what you have to do and I'll do what I have to do period end of story." (Part I) b) "hahaha I was wondering do you think it's healthy to talk to yourself?" (Part II) c) "You do what you have to do and I'll do what I have to do remember that SON..." (to the best of his knowledge, Plaintiff's late mother and Merlock never had sex). (II) d) "You wanna know what I find funny. Is Im right you are dellusional [sic] your [sic] having an imaginary conversation with me when im not even saying anything LOL." (III) e) [in response to being called a wannabe] "hahahahahahaha feel pitty for the uneducated Ciao Wannabe "Whizz'. (Plaintiff's AOL name in 1996 was WhizardRay) It seems to me you "WANNABE" alot of things like a gymnastics coach of a World class gymnast and a member of the moceanu family.. but basically you Just dont have it HAHAHA" (III) f) [to the audience]: (The bleep's were for Vulgar language that he used and I find it very FUNNY that first he says im all talk but when i dont say a word he makes up another excuse.. TRYING to find a way around the FEAR well here it is guys! Think what you wish but we all know the truth Everyones friend Jeff 79. All Plaintiff knew in 1998 was that Merlock lived near...Boston, claimed to be short, fat, Sicilian, and went by the name Jeff, information not sufficient, even if accurate, to identify him without subpoena to AOL. 80. Also on June 29, 1998, Merlock posted the following to USENET: 36 https://groups.google.com/forum/#!original/alt.sports.gymnastics/bAfQhOU6D3o/pNmxe1x8iPoJ Retrieved June 11, 2015 6:21am 81. "Vance" refers to Vance Lear, a judgment-proof, homeless member of the Hypnosis Mafia, based in San Francisco compensated for hiding the true source of internet attacks against Plaintiff. Vance has falsely claimed a Ph.D. in psychology, and that his late wife, Leslie Harivel, a big-firm paralegal, was an attorney, an insult to big-firm paralegals everywhere. Just as Defendant found the ED page a convenient ally, friend-to-all Merlock immediately embraced 37 Vance, who had once threatened to "come after" Plaintiff during a harassing telephone call in 2002. Lear has also claimed to have worked with the world's leading psychiatrists; about this Plaintiff has absolutely no doubt. 82. Emboldened by his new legal advisor, Vance Lear, Merlock (the webmaster for several elite "Mafia-protected" gymnasts, and editor of a gymnastics website) forged ahead with his mission to completely ruin Plaintiff, hopefully to the point of suicide. Merlock's motivation for this burst of verbal aggression had been posted one day prior: https://groups.google.com/forum/#!original/alt.sports.gymnastics/vZBkQyhDQVw/UyQ7RqI-zGMJ Retrieved June 11, 2015 7:18am 83. Merlock claimed that he was friends with Magnificent Seven gymnasts Moceanu and Amanda Borden, making him a firsthand witness to their private lives. In another post, he 38 claimed that Plaintiff's claims that Moceanu was being abused were libelous, and that she could sue him over that (Plaintiff wanted sunlight on the abuse). 84. During one of their IM sitdowns, Merlock parted with some central wisdom: "Revenge has NO time limit," he said. By this, Plaintiff mistakenly believed that Merlock was referring to there being no limit on how long one could delay exacting revenge, but it appears Merlock also meant that there was no limit on how long he could ruin Plaintiff, for here we are in 2015 with Defendant grinding the eighteen-year-old axe of this thirty-five year-old man who warned Plaintiff never to forget him as a threat. Heeding this warning, Plaintiff internet-snooped the [email protected] e-mail address, just in case this Merlock loser still held a grudge: 39 85. Plaintiff hears that Kalligheri is physically tough; mostly from Kalligheri, but that's what he hears. The modern internet tells all: [email protected], a/k/a Everyone's Friend, 40 turns out to have been Kalligheri, who recently built a strong filming presence in Qatar, and whose most recent film, Big Game, starring Samuel L. Jackson and a thirteen year-old Dutch actor, has received international critical acclaim. Following is a list of production companies involved in Big Game: 86. Kalligheri produced this film in partnership with Subzero Film Entertainment. 87. For this "count to nowhere," Plaintiff asserts a global, association-in-fact RICO enterprise based on traditional Sicilian Mafia crime, which also includes international child sex trafficking, masterminded by proven child-abuse enabler Jeff Kalligheri, and recently furthered by Defendant's predicate act of extortion in violation of the Hobbs Act. This, however, is no longer Plaintiff's dogfight, and is set forth solely (as background, not an actual count) to rebut Defendant's statements concerning Plaintiff via her link to the ED page, the one Defendant called research in her second Ripoff Report rebuttal: 41 88. Defendant notes here that she "[does] not have any evidence that all this information in the link is correct." Speaking of which: COUNT ONE: DEFAMATION (AS PUBLISHER) 89. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire contents of all previous paragraphs. 90. The following statements by Defendant are in controversy in this count: a) The claim that Plaintiff was "harassing [her] or slandering [her] name" (paragraph 88); 42 b) 1) The contents of both the ED Page and the essay authored by Clanton to which it links (paragraph 36), 2) all factual misstatements from the page noted hereinabove, including but not limited to Plaintiff having authored the essay or being a pedophile. c) All other statements, to the extent they are proven individually defamatory at trial, or, collectively, that they portray Plaintiff in a false light, bringing shame and disgrace on he and his family for generations to come. 91. The statement in 93(a) is false; indeed, it was Defendant who "harassed" Plaintiff, first making him vulnerable by posting a powerful hypnosis video, then by breaching the contract, and then by ignoring his request to cease all contact once fired. Defendant's protest/warning posts, and his review, were made "on the way out," and did not constitute direct contact with Defendant, but rather public-square commentary. By contrast, Defendant has been inciting her minions to contact Plaintiff directly, and with threatening hostility: 43 Yelp Message From "The P" 92. The statements on the ED page in 93(b), including but not limited to the claim that Plaintiff authored the rape/murder essay, are false and misleading, as set forth in paragraph 46. 93. The statements were a) made to third parties, who b) clearly understood their meaning, c) were not privileged, d) not consented to by Plaintiff, and e) libelous per se. Based on preponderance of the evidence, f) similarly slanderous statements have been made verbally, by Defendant, to friends and acquaintances, adding g) slander as an element of this count. 44 94. By endorsing the link to ED, claiming she had performed "research" on Plaintiff rather than just making a casual link, and saying "most of the information seems to check out," Defendant made the ED Page her own, elevating herself to the status of publisher. Alternatively, Defendant has not proven the third-party origination of the content required for immunity. 95. As set forth hereinabove, Defendants statements run afoul of the Pennsylvania tort of libel; Plaintiff states this claim for relief on that basis. 96. As a direct and proximate result of Defendant's statements, Plaintiff has suffered irreparable harm, including, but not limited to, pain and suffering, loss of current and retirement income, fear for his safety at the hands of vigilantes who might "Google" him when encountering Plaintiff in his daily life, and loss of reputation and social standing. 97. Plaintiff is entitled to a) compensatory damages in an amount to be proven at trial; b) punitive damages, for Defendant's willful and malicious conduct; and c) injunctive relief sufficient to terminate the actionable conduct and make Plaintiff whole. COUNT TWO: DEFAMATION (AS DISTRIBUTOR) 98. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire contents of all previous paragraphs. Section 230 Constitutional Challenge Mini-Memorandum (Federal Rule 5.1) 99. Jeff Kalligheri may be everyone's friend, but Section 230 is his best friend. To quote the parrot: "Rraaaach!! Section 230!.....Section 230!....rrraaaach!! DISMISSED!!" 100. This parrot, now extinct in the remainder of the world, where Plaintiff would win this lawsuit without difficulty in five hundred out of every hundred jurisdictions not named America, has lobotomized Plaintiff's home-country judiciary, while ignoring two key factors: a) the 45 SCOTUS has never ruled on Section 230; and b) the law, as written, says nothing about distributor liability. Now, all but the first of an infinite gang of defamers are given a license to destroy anyone's reputation at will, without consequence, making I heard it on the internet as absolute a defense as truth, even as one is told not to trust what one reads online. 101. Plaintiff is currently seeking legal representation in Australia and the United Kingdom, where judgments for equally defamatory statements run well into the six-figures. He asks this court to consider why this case would win so easily, so it may address the right to reputation for which the SCOTUS laid the foundation in Paul v. Davis, 424 US 693 (1976), where the dissent said the constitutional right to reputation -- recognized in the EU, where the right to be forgotten exists and even truth is not a defense to defamation -- already exists, and the majority said that a secondary harm, such as the loss of employment to internet-searching, were present; in 2015, unlike 1976, secondary, constitutional harm can now be inferred. 102. If Judge Parrot hears this case, summarily dismissing it solely because of Section 230, Plaintiff will be relegated to a lifetime of having to answer for decades-old lies which, to this day, continue to harm his career, chances for regular employment and to fulfill the public interest of self-sufficiency, and ability to form social and business connections. The public will continue to simultaneously harmed by deception. 103. Public-interest arguments in favor of Section 230 are wiped by the greater constitutional interest in truth, an interest which spawns public interests such as the need for reliable consumer data, also rendered impossible by Section 230's "freedom to lie" interpretation. Why should a consumer trust any information about any product or service, if no one can be sued for lies? Section 230 or not, Defendant accused Plaintiff of pedophilia. Under existing law in all fifty states, that is actionable defamation, a tort developed to replace dueling. 46 104. While this court was threatening Plaintiff with sanctions for suing Google for distributor libel, Plaintiff had predicted at the time that as more sympathetic targets -- i.e., women -- emerged, that legislative judicial gymnastics would ensue. The revenge porn crusaders have proven this, with entirely new federal laws specifically drafted as an end-run around 230, such as the proposed federal anti-revenge-porn law. The simpler option of fixing 230 in the first place for all people has yet to penetrate the public consciousness. 105. For this count, Plaintiff avers identical damages, motivation, and level of malice, pleading his claim for relief identically to Count One above, except based on distributor liability, and seeking identical relief. 106. Alternative to the foregoing, Plaintiff asks that this court apply British and Australian defamation law here, on the grounds of judicial economy, and because both parties derive income from an international audience which includes these countries. COUNT THREE: BREACH OF CONTRACT 107. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire contents of all previous paragraphs. 108. A deal is a deal (paragraphs 19-22). Defendant broke the deal (paragraph 24), thus violating the Pennsylvania tort of Breach of Contract; Plaintiff states this claim for relief on that basis. 109. This case is analogous to Kim Basinger's having bailed out of Boxing Helena, for which she paid $3.8 million in settlement. 110. While no distribution rights for either video had been negotiated, for purposes of this suit, Plaintiff had an audition with Defendant, which, if successful, would have lead to commercialization of the work, and future projects. Alternatively, even without 47 commercialization, the contracted video was to play a pivotal role in furthering both the eye and chess video projects. The breach cost Plaintiff that chance-of-a-lifetime audition, in a manner which cannot easily be restored. 111. Absent Defendant's breach, Plaintiff would have a chess video for personal use, and have completed his "audition" for commercial partnership and continuing collaboration. 112. Direct restoration of Plaintiff to "whole" status via performance of the contract is not possible, given what has transpired. Plaintiff estimates that, starting from scratch, it could cost as much as $325,000.00 to yield a comparable video from a SAG-AFTRA actress with comparable skill. That this was not a SAG-AFTRA gig is not relevant when calculating the replacement cost of the breach, especially since Plaintiff had every intention of becoming a signatory had the need for him to do so arisen. 113. Because the breach was wanton, willful, and intentional, Plaintiff is entitled to punitive damages, in addition to the compensatory damages outlined hereinabove, and any injunctive relief necessary to make him whole. COUNT FOUR: FRAUDULENT MISREPRESENTATION 114. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire contents of all previous paragraphs. 115. "I am not a fettish model!," Defendant cried, oblivious to her spelling error. 48 116. Defendant could have fooled Plaintiff...indeed, as if mother nature performing tricks with margarine, she did fool Plaintiff into thinking she was butter. In the course of fooling him, 49 Defendant ran afoul of the Pennsylvania tort of fraudulent misrepresentation; Plaintiff states this claim for relief on that basis. 117. Defendant, a SAG-AFTRA actress who wouldn't have dreamed of pulling a stunt like this on a big-studio executive like Jeff Kalligheri, should have known better. Her actions were intentional and self-serving. 118. But for the fraudulent misrepresentation outlined hereinabove, Plaintiff would have a) proposed the eye video instead of the "edgier" chess video, and b) not dealt with Defendant via Customs Club, doing so instead as a regular hypnotherapy/hypnosis client, thus avoiding her issues with the fettish world of which she claims not to be a part, reality notwithstanding. 119. The damages and remedies pled in Count Three above (paragraphs 107-113) are identical to those which Plaintiff now sets forth for this Count Four, as if fully stated verbatim. COUNT FIVE: DECLARATORY RELIEF 120. Plaintiff incorporates by reference, as if fully stated verbatim herein, the entire contents of all previous paragraphs. 121. In the absence of a responsive pleading which includes a counterclaim for defamation, Plaintiff seeks a declaration that his Yelp! review contains no false and misleading statements concerning Defendant. 122. Alternatively, even if this court finds that there are false and misleading statements in the Yelp! review, rather than mere opinion, Plaintiff seeks a declaration that he has retracted his statements, and attempted to mitigate any and all harm to Defendant (such as with the temporary five-star review emphasizing only Defendant's induction skills). This court now has a practical, real-world example of how Plaintiff's speech was chilled by the litigation threat. 50 PRAYER FOR RELIEF Plaintiff prays to God Almighty, His Son, and the Holy Ghost, but also to this Court, for the following relief: 1. Compensatory damages in the amount of SIX-HUNDRED SIXTY-ONE THOUSAND DOLLARS ($661,000.00), including $325,000 for the breach and fraud claims, and $336,000 for the defamation claims. 2. The maximum punitive damages allowable by law. 3. Costs of suit, including attorney fees, where permitted. 4. An order declaring that Plaintiff's Yelp! review contains no false and misleading statements concerning Defendant. 5. Absent a timely counterclaim, a "put up or shut up" order barring Defendant from ever bringing her previously threatened lawsuits, and further deeming any such action, if permitted, in violation of both the anti-SLAPP laws and the Dragonetti Act. JURY TRIAL DEMANDED Plaintiff demands that the instant action be tried by a competent jury of his civic-minded peers. This the 12th day of June, 2015 Gordon Roy Parker, Pro Se 4247 Locust Street, #119 Philadelphia, PA 19104 (267) 298-1257 [email protected] PLAINTIFF 51 EXHIBIT A Plaintiff's Yelp! Review Of Defendant Hypnosis is a known sexual fetish, which is why attractive female hypnotists can write their own ticket. Jacquie has provable ties to the hypnofetish community. See her interview at the "Girls And Corpses Graveside Zombie *Fetish* event from 2013: [external link redacted] She and Hypnotist Joel Silver performed at the Girls And Corpses Spring Issue 2013 Premier And Hypnosis Show: [external link redacted] Jacqui has also said she has performed at "grad nights." There are MINORS at those shows. Would anyone want a male hypnofetishist hypnotizing their underaged daughters? It's not that Jacqui herself is a problem per se, but the hypnosis she performs triggers fetishes in 4-6 percent of the population, more at a show. Any woman intelligent enough to hypnotize people on stage is more than intelligent enough to know she's turning on almost every male who falls under her spell. Beauty itself is hypnotic, and adds to the trance, even if the ostensible purpose is therapeutic. As a general rule, it is wise to keep the lines between stage hypnosis, fetish hypnosis, and therapeutic hypnosis well-drawn; this is why I never became a hypnotherapist. After finding a very powerful induction (and very sexy, replete with phone-sex voice and dominant overtones), from Jacqui on YouTube, I tried to see if she had any videos for sale on the clips site. It is there that I found this highly trained SAG actress (all of which make for vastly superior hypnotists) had a page on "Customs Club," a website for custom fetish hypnosis videos. I offered Jacqui $1,000 to perform a sexy induction with deep mind control, for the purpose of helping my chess (by tying the motivation to win to getting a beautiful woman, and through the rejuvenative effects of the hypnosis itself). She accepted my offer, but I had sent a duplicate and asked her to clear that up by e-mail. Jacqui's response to my e-mail was a request for me to pay her by PayPal, which would have risked my account, as they don't allow adult transactions, and it would have required me to cut out Customs Club, which was not fair to them. I immediately declined the transaction, and was no longer comfortable dealing with Jacqui, who put me in a bad position since now she is useless to me as a hypnotist, as I didn't trust what she had done, and other hypnotists are useless because they lack her extreme level of talent and training. It's like hypnosis suddenly becomes a drug you know isn't the strongest. Hypnosis's fatal flaw is that other people control its dosage. In this case, I have to use what my brain knows to be inferior hypnosis while patiently waiting for a superior hypnotist to come along, what could be a long wait though I'm guessing Jacqui's ultimate gift to me will be the hundreds of copycats who come around later. Someone who claims to understand artists didn't do a good job in my case, and I would rather have never seen her hypnosis at all than to be bait-and-switched in what I consider such a dishonest manner. Is she talented? Extremely. Would I recommend letting her inside your head? Never. I've been doing hypnosis since I was eight. Hypnotists like Jacqui are great if they like you or want something, and can be a psyche-injuring nightmare otherwise. She crossed into a seriously controversial gray area when she put up that fetish video page as well. A male hypnotherapist with a similar duality would be met with skepticism at best. Technically speaking, she has a "theoretical seal" based on my perception of her ability that will not be broken until a superior trance is induced. I've been through this before; the longest I had to wait for one to break was nine years. Because a hypnotist is not obligated to work on a subject, there is no penalty for leaving one sealed, but there should be. Anyone who can hypnotize you can seal you, intentionally or unintentionally, and if they do, you are at their mercy. You've seen how she behaved in that position with me. I cannot speak for what she would do with anyone else.