Kevin Slams Lionsgate Worst Practices in Seduced; Defends Marc Elliot – Not a Criminal

Marc Elliot is in effect calling Lionsgate a liar.

Marc Elliot is suing Lionsgate for their portrayal of him in Seduced. Lionsgate is seeking to dismiss the lawsuit. See the original complaint.

Elliot points to Episode 2 of Seduced, “Indoctrinated.” 

The producers present audio of Keith Raniere speaking at an SOP meeting.

Raniere says, “The primitive parts of us are hungry fucky beasties. I mean, that’s what we want to do. Just fuck it. Fuck it. Fuck, fuck, fuck. I feel like fucking something today. God, I’m pissed, I want to fuck something, you know. If we conquer a woman, if we grab the thing we want to fuck, whatever it is and fuck it. They enjoy it.”

There was no applause when Raniere spoke to a few dozen people.

But the producers of Seduced added a large audience applause track. 

Following the applause, Seduced shows a clip of Marc Elliot.

Elliot says, ‘No one has ever taught us how to relate to women, nowhere, in all the education of my whole life. And this is, in my opinion, the Harvard of trying to relate to women. You have to come.”

“You have to come” where?

It appears Elliot replies to Raniere’s statement about conquering women by inviting others to attend and learn.

But Elliot made his statement about another matter.

Elliot was interviewing on a promotional video for Jness, a women’s group.

Elliot’s topic was how Jness helped him “build compassion and love for women.”

Elliot claims Seduced’s presentation misleads audiences and slanders him.

Showing Raniere’s conquering women comment, followed by Elliot’s Harvard comment, appears as his endorsement.

Seduced’s attorneys argue this is protected speech.

With that background, make way for Kevin to combat all comers.

 

By Kevin

Marc Elliot, unfortunately, will lose his case against Lionsgate, not because his complaints are invalid, but because the prevailing narrative is that he is part of “Team Bad Guy,” even though he hasn’t done anything bad. 

So the protections that the law should afford to anyone in his position will not be afforded to him.

Here’s the small silver lining, the small victory he gets by showing us.

The manipulation of the footage and audio where the network made it look like he was supporting KR speeches condoning violence when Marc actually responded to completely different statements hammered home to the people paying attention that this is fake, that this is entertainment, a commercial for India Oxenberg (much like The Vow is a commercial for Edmondson and Vicente), and not an objective, educational, informational series on sexual violence.

The manipulation calls into question everything else presented to us in Seduced. It calls into question the honesty and credibility of the narrator of the series, who we now know is unreliable.

Did Allison do those things to India? Did Allison give her an assignment where India was forced to sleep with KR in exchange for Allison being paid for her work in The Source?

Did that happen? Or is that accusation just as manufactured as what they did with the footage of Marc Elliot?

Oh, by the way, if India’s story is 100% accurate, who is she to target Marc Elliot, who, last time I checked, is not linked to any criminal activity?

Layla wrote:

Of course, you are badly portrayed Marc Elliot…you are a loser and liar.

Kevin replied:

There’s a difference between calling someone a loser and a liar, and selectively editing footage to make it look like that person is reacting positively to statements condoning sexual violence.

Penn Station Train 195 wrote:

No one said anything defamatory about Marc in the documentary. The video was slickly edited from public footage.

Legally, Marc is regarded as a public person. So the legal threshold to sue for slander is much higher. He is a motivational speaker who speaks publicly.

Marc Elliot was a member of NXIVM. So it’s not slander to say “he was a member.” 

The lawsuit is a joke.

I suspect Marc’s lawsuit is a PR stunt to vindicate himself with the public.

I believe what the documentarians did was unprofessional and wrong. It’s in the same light as everything Michael Moore does, which is to bend the truth to the point that it’s a lie.

Kevin replied

True, it’s not slander to say that Marc Elliot was a NXIVM member. However, taking footage of him clapping at one speech to make it look like he was clapping at a different speech that seemingly condones violence, yes, that is slander. It portrays him in a false light. It was done intentionally and with the intent to harm.

And the person who is portrayed so positively in the same series was far more involved than he was, to the point where she was considered a co-conspirator by the Federal Government. What nerve these people have.

Aristotle’s Sausage wrote:

So Elliot uses the same law office as his Vanguard? Priceless.

Raniere’s minion will lose his silly defamation suit. The judge will likely dismiss the lawsuit. Not because Elliot’s lawyer isn’t a real lawyer, not because the Democratic Party is corrupt (or so you claim), but because of the First Amendment.

I’m in favor of the freedom of speech. It’s an invaluable protection of our Constitution and a fundamental Enlightenment right.

In the US, we are free to express our opinions. It’s a freedom many nations restrict, even progressive developed nations.

Because we enjoy this essential freedom, it is very difficult to prove defamation in US courts. That’s a good thing.

When Elliot’s silly lawsuit is dismissed, Raniere’s minions will screech how this “proves” the courts are corrupt.

Sigh.

Kevin replied

“I don’t like Aristotle.”

“Aristotle is a jerk.”

“Aristotle smells funny.”

Those statements are all First Amendment protected free speech. 

But to take footage of you cheering your favorite team winning a game, and manipulating the footage to make it look like you’re cheering statements condoning sexual violence against children, is the textbook definition of defamation.

These people did that, and they’re getting a pass that you know they shouldn’t get because they’re on “the right side” of things.

Marc isn’t Keith, didn’t do the things Keith did, and has never been linked to any wrongdoing.

He doesn’t deserve this, especially from a team of filmmakers who went out of their way to cover up things India was linked to.

 

 

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  • But what about Danielle Roberts? Wasn’t Kevin pretending to only care about how Danielle and Allison were treated and that people be kinder to them and more forgiving? Now Kevin thanks maybe evidence was tampered with and Mark Elliot is being defamed by stars. It’s almost as if Kevin has the exact same position on absolutely everything as a dead Ender. Oh wait there are those strategic fake statements about believing Keith was a sexual predator of children back in the 80s and early 90s. Which means Keith is still a sexual predator of children. Because all research and evidence proves that even with extreme counseling and behavioral modification there is no meaningful Rehabilitation of child sexual predators. Definitely a child sexual predator such as Keith who had suffered no consequences would continue to reoffend

    • This is going to be the most astounding thing you’ve ever heard of. I say this knowing a man of your caliber and your profession must have known some astounding things in his time. Alex Jones is married to my sister.

    • That was shown in the previews too and it’s creepy AF. My honest guess is that I’m pretty sure keith made her put it there to freak her out as a way to torment her.

  • Atlas Obscura
    https://www.atlasobscura.com/articles/food-and-cults

    The Curious Connection Between Food and Cults
    From Fruitlands to NXIVM, food has served as the core of Utopia and a tool of control.
    BY SAM O’BRIEN
    OCTOBER 24, 2022

    Food historian Sarah Lohman’s interest in food and cults began with a beautiful set of silverware. After spotting the case of cutlery at a thrift store in Vermont, she wondered who made them and turned the box over. The back held one word: Oneida.

    “I found out that Oneida was a 19th-century cult that, among other things, made flatware to make money for their free-love cult,” Lohman says. “And that sent me down the rabbit hole, because it was from that moment onward that I realized that there are often a lot of connections between food and cults.”

    When it comes to the role of food and drink in cults, most people immediately think of the tragic mass poisoning at Jonestown in 1978. But diets within fringe communities can be a more complex mingling of good and sinister intentions.

    On the positive side, many late 19th-century cults were founded on agrarian principles that promoted vegetarianism and eschewed animal cruelty. But when wielded with malice by cult leaders in the 20th and 21st centuries, food became a tool of manipulation and control.

    [ … ]

    [ … ]

    [ … ]

    NXIVM
    Some cults use food as a way of controlling their members. This was the case with NXIVM, a pyramid scheme and personality cult founded by Keith Raniere in the early 2000s.

    Former members of NXIVM who considered themselves sex slaves to Raniere testified that forced starvation played a role in breaking them down. India Oxenberg, who details her experience in the documentary Seduced, was limited to a 500 to 800 calories each day.

    “In order to evoke control, he was taking very young women, many of whom were involved in acting and who were already feeling the pressure of looking a certain weight, and having them calorie-count and starve themselves to a point that made them completely malleable,” Lohman says. “And then that puts people into a very manipulative state where it’s easy to coerce them.”

    Raniere is currently serving a 120-year prison sentence for crimes including child sex trafficking and conspiracy to commit forced labor.

    A Final Word
    If, like me, you come away from some cult stories with a sense of dread and sadness, you’re not alone. In the worst cases, cult leaders prey upon vulnerable populations in search of community and meaning.

    I think what disturbs me the most about stories such as Jonestown and NXIVM is that their leaders warped food’s most important roles: gathering people and nourishing life.

    For better or worse, cults reveal the incredible power of food. When wielded carefully, food can fund and fuel a community, but in the wrong hands, a diet can be a very dangerous thing.

    You can sign up for Lohman’s class on food and cults here.

    https://www.atlasobscura.com/articles/food-and-cults

  • I think Kevin needs to Google libel law.

    Making somebody look bad in a TV documentary isn’t libel. If it were, there would be no more documentaries.

    Creative editing to make someone look the fool isn’t actionable. Any lawyer should know this. Which may be why Elliot is represented by a guy who’s not really a lawyer?

    So since this isn’t about actionable libel, what is it about? Starz being mean to Marc?

    Boo fuckin’ Hoo.

    What a pussy. “Kevin” (not his real name evidently which makes him a hypocrite and a liar) waxes indignant about poor Elliot and poor Mack and various other cult loyalists who are now paying the price for their folly and misdeeds and their dumbass adherence to that rapey racketeer creep Raniere.

    So what if Elliot wasn’t cheering explicitly for Raniere’s “fuck fuck fuck we grab ‘em [the women] and they like it”. Instead he was cheering for Raniere’s rapey Jness scheme. Big fucking difference.

    Arguably, Starz’s creative editing wasn’t even very misleading. But that’s not relevant.

    What’s relevant is libel law as defined in the United States. And Elliot’s complaint doesn’t even come close.

    But Kevin is upset that Elliot was treated unfairly. That his feelings were hurt. He’s upset when this happens to any of Raniere’s loyal followers.

    Funny he’s not upset for all the women who were branded on their nethers after being blackmailed.

    Funny that. Yes the milk of human kindness dries up pretty quick when it comes to the people who snitched on Raniere and his cult. The people who testified at Raniere’s trial.

    No, for those traitors there’s no mercy. Kindly Kevin’s California granola “forgive! don’t be hurtin’ act vanishes his fangs come out for people like Sarah Edmondson and Moira Penza. With them, Kevin feels entitled to enlarge on their perceived misdeeds, and invent them when possible.

    All the things the Seduced did, he does in spades.

    And he’s so obvious in this. In his hypocrisy. He’s a poor rhetorician. Clyne is much, much better at it.

    “Kevin” must’ve been sleeping during his Knife of Aristotle classes.

    • Hello Aristotle. I hope you weren’t bothered too much by my “Aristotle smells funny” comment. I put quotes around it as part of a bigger point I was making, and was not suggesting that you have any issues with showering and keeping yourself clean down there.

      You’re right, I know very little about libel law. My specialty is in Government Acquisition, so please forgive me for not knowing the appropriate codes and statutes pertaining to slander and defamation.

      I think my overall point makes sense; that if these filmmakers were caught in a lie, and one they had to work hard to manufacture, all to smear a man who isn’t even a subject in the movie that’s being made, that it calls into question everything else we see and hear from these filmmakers.

      You know how I feel about Sarah and Mark Vicente. What’s funny is that you feel the same way, based on comments you’ve made.

      I use my real name. I will not be volunteering my last name, or any other information other than what I’ve already provided, which is far more than 99.9% of the people who comment on this blog.

      The people who I’ve written to outside of this site, they are welcome to ask any questions they want, about anything, at any time, and I will provide them with that information. I will not be disclosing that information to people here.

      I’ve made my positions clear. I don’t want Allison or the women who associated with her to be harmed, smeared or tormented just because they have opinions about this situation that are unpopular. They don’t deserve that. Neither does Marc Elliot.

      They are deserving of friendship, kindness, compassion and community. I hope they find it. And the same goes for the people on the other side of the fence, as long as they’re not accusing other people of things they themselves did.

  • How many people who saw the documentary really focused on the part with Marc Elliott?

    Until the lawsuit came out I didn’t recall him even being a part of the show.

    I haven’t gone back to re-watch it either

    Marc Elliott is making a problem were there isn’t one.

    His biggest problem is his support of Keith Rainier since he got arrested. Being a part of Make Justice Blind and fighting to try to free Raniere.

    Not how he looks in a short clip in a movie most people won’t watch or even remember he is a part of.

  • One must ask how far the sexual interests of adults and their respective sexual orientations conflict with the mandate of any society to protect children and minors from sexual indoctrination and normalization of sexual abuse.
    One must not only deal with Raniere’s behavior, but look at the topic in general and look at the respective developments and currents in society.
    Here is something I found about it. However, the topic is so extensive that individual references are not sufficient to treat it conclusively.

    _________________________________________________________________________________________________

    CJ Magazine

    https://www.city-journal.org/the-real-story-behind-drag-queen-story-hour?wallit_nosession=1

    The Real Story Behind Drag Queen Story Hour
    Aimed at children, the phenomenon is far more subversive than its defenders claim.
    Christopher F. Rufo
    Autumn 2022 The Social OrderEducation
    Drag Queen Story Hour—in which performers in drag read books to kids in libraries, schools, and bookstores—has become a cultural flashpoint. The political Right has denounced these performances as sexual transgressions against children, while the political Left has defended them as an expression of LGBTQ pride. The intellectual debate has even spilled into real-world conflict: right-wing militants affiliated with the Proud Boys and the Three Percenters have staged protests against drag events for children, while their counterparts in the left-wing Antifa movement have responded with offers to serve as a protection force for the drag queens.

    Families with children find themselves caught in the middle. Drag Queen Story Hour pitches itself as a family-friendly event to promote reading, tolerance, and inclusion. “In spaces like this,” the organization’s website reads, “kids are able to see people who defy rigid gender restrictions and imagine a world where everyone can be their authentic selves.” But many parents, even if reluctant to say it publicly, have an instinctual distrust of adult men in women’s clothing dancing and exploring sexual themes with their children.

    These concerns are justified. But to mount an effective opposition, one must first understand the sexual politics behind the glitter, sequins, and heels. This requires a working knowledge of an extensive history, from the origin of the first “queen of drag” in the late nineteenth century to the development of academic queer theory, which provides the intellectual foundation for the modern drag-for-kids movement.

    The drag queen might appear as a comic figure, but he carries an utterly serious message: the deconstruction of sex, the reconstruction of child sexuality, and the subversion of middle-class family life. The ideology that drives this movement was born in the sex dungeons of San Francisco and incubated in the academy. It is now being transmitted, with official state support, in a number of public libraries and schools across the United States. By excavating the foundations of this ideology and sifting through the literature of its activists, parents and citizens can finally understand the new sexual politics and formulate a strategy for resisting it.

    Start with queer theory, the academic discipline born in 1984 with the publication of Gayle S. Rubin’s essay “Thinking Sex: Notes for a Radical Theory of the Politics of Sexuality.” Beginning in the late 1970s, Rubin, a lesbian writer and activist, had immersed herself in the subcultures of leather, bondage, orgies, fisting, and sado-masochism in San Francisco, migrating through an ephemeral network of BDSM (bondage, domination, sadomasochism) clubs, literary societies, and New Age spiritualist gatherings. In “Thinking Sex,” Rubin sought to reconcile her experiences in the sexual underworld with the broader forces of American society. Following the work of the French theorist Michel Foucault, Rubin sought to expose the power dynamics that shaped and repressed human sexual experience.

    “Modern Western societies appraise sex acts according to a hierarchical system of sexual value,” Rubin wrote. “Marital, reproductive heterosexuals are alone at the top erotic pyramid. Clamouring below are unmarried monogamous heterosexuals in couples, followed by most other heterosexuals. . . . Stable, long-term lesbian and gay male couples are verging on respectability, but bar dykes and promiscuous gay men are hovering just above the groups at the very bottom of the pyramid. The most despised sexual castes currently include transsexuals, transvestites, fetishists, sadomasochists, sex workers such as prostitutes and porn models, and the lowliest of all, those whose eroticism transgresses generational boundaries.”

    Rubin’s project—and, by extension, that of queer theory—was to interrogate, deconstruct, and subvert this sexual hierarchy and usher in a world beyond limits, much like the one she had experienced in San Francisco. The key mechanism for achieving this turn was the thesis of social construction. “The new scholarship on sexual behaviour has given sex a history and created a constructivist alternative to” the view that sex is a natural and pre-political phenomenon, Rubin wrote. “Underlying this body of work is an assumption that sexuality is constituted in society and history, not biologically ordained. This does not mean the biological capacities are not prerequisites for human sexuality. It does mean that human sexuality is not comprehensible in purely biological terms.” In other words, traditional conceptions of sex, regarding it as a natural behavior that reflects an unchanging order, are pure mythology, designed to rationalize and justify systems of oppression. For Rubin and later queer theorists, sex and gender were infinitely malleable. There was nothing permanent about human sexuality, which was, after all, “political.” Through a revolution of values, they believed, the sexual hierarchy could be torn down and rebuilt in their image.

    There was some reason to believe that Rubin might be right. The sexual revolution had been conquering territory for two decades: the birth-control pill, the liberalization of laws surrounding marriage and abortion, the intellectual movements of feminism and sex liberation, the culture that had emerged around Playboy magazine. By 1984, as Rubin acknowledged, stable homosexual couples had achieved a certain amount of respectability in society. But Rubin, the queer theorists, and the fetishists of the BDSM subculture wanted more. They believed that they were on the cusp of fundamentally transforming sexual norms. “There [are] historical periods in which sexuality is more sharply contested and more overtly politicized,” Rubin wrote. “In such periods, the domain of erotic life is, in effect, renegotiated.” And, following the practice of any good negotiator, they laid out their theory of the case and their maximum demands. As Rubin explained: “A radical theory of sex must identify, describe, explain, and denounce erotic injustice and sexual oppression. Such a theory needs refined conceptual tools which can grasp the subject and hold it in view. It must build rich descriptions of sexuality as it exists in society and history. It requires a convincing critical language that can convey the barbarity of sexual persecution.” Once the ground is softened and the conventions are demystified, the sexual revolutionaries could do the work of rehabilitating the figures at the bottom of the hierarchy—“transsexuals, transvestites, fetishists, sadomasochists, sex workers.”

    Where does this process end? At its logical conclusion: the abolition of restrictions on the behavior at the bottom end of the moral spectrum—pedophilia. Though she uses euphemisms such as “boylovers” and “men who love underaged youth,” Rubin makes her case clearly and emphatically. In long passages throughout “Thinking Sex,” Rubin denounces fears of child sex abuse as “erotic hysteria,” rails against anti–child pornography laws, and argues for legalizing and normalizing the behavior of “those whose eroticism transgresses generational boundaries.” These men are not deviants, but victims, in Rubin’s telling. “Like communists and homosexuals in the 1950s, boylovers are so stigmatized that it is difficult to find defenders for their civil liberties, let alone for their erotic orientation,” she explains. “Consequently, the police have feasted on them. Local police, the FBI, and watchdog postal inspectors have joined to build a huge apparatus whose sole aim is to wipe out the community of men who love underaged youth. In twenty years or so, when some of the smoke has cleared, it will be much easier to show that these men have been the victims of a savage and undeserved witch hunt.” Rubin wrote fondly of those primitive hunter-gatherer tribes in New Guinea in which “boy-love” was practiced freely.

    Such positions are hardly idiosyncratic within the discipline of queer theory. The father figure of the ideology, Foucault, whom Rubin relies upon for her philosophical grounding, was a notorious sadomasochist who once joined scores of other prominent intellectuals to sign a petition to legalize adult–child sexual relationships in France. Like Rubin, Foucault haunted the underground sex scene in the Western capitals and reveled in transgressive sexuality. “It could be that the child, with his own sexuality, may have desired that adult, he may even have consented, he may even have made the first moves,” Foucault once told an interviewer on the question of sex between adults and minors. “And to assume that a child is incapable of explaining what happened and was incapable of giving his consent are two abuses that are intolerable, quite unacceptable.”

    [French philosopher Michel Foucault, the father figure of queer theory, an academic discipline that seeks to subvert sexual hierarchies (SOPHIE BASSOULS/SYGMA/GETTY IMAGES)]

    Rubin’s American compatriots made the same argument even more explicitly. Longtime Rubin collaborator Pat Califia, who would later become a transgender man, claimed that American society had turned pedophiles into “the new communists, the new niggers, the new witches.” For Califia, age-of-consent laws, religious sexual mores, and families who police the sexuality of their children represented a thousand-pound bulwark against sexual freedom. “You can’t liberate children and adolescents without disrupting the entire hierarchy of adult power and coercion and challenging the hegemony of antisex fundamentalist religious values,” she lamented. All of it—the family, the law, the religion, the culture—was a vector of oppression, and all of it had to go.

    The second prerequisite for understanding Drag Queen Story Hour is to understand the historical development of the art of drag. It begins with a freed slave named William Dorsey Swann, who dressed in elaborate silk and satin women’s costumes, called himself the “queen of drag,” and organized sexually charged soirées in his home in Washington, D.C. Over the course of his life, Swann was convicted of petty larceny—he had stolen books from a library and dinnerware from a private residence—and then, in 1896, was charged with “keeping a disorderly house,” a euphemism for running a brothel, and sentenced to 300 days in jail. From the viewpoint of modern sexual politics, the story has all the elements of the perfect left-wing archetype: Swann was a man who liberated himself from chattel slavery and then from a repressive sexual culture, despite the best efforts of the oppressors, the puritans, and the police.

    Drag became explicitly political seven decades later, during the Stonewall riots of 1969, in which patrons of a gay bar in New York City rioted against police and began a wave of gay and lesbian political activism. As writer Daniel Harris explained in the counterculture journal Salmagundi, traditional drag performances from William Dorsey Swann until the mid-1960s were sensual experiences, “an innocuous camp pastime,” but with the onset of the sexual revolution, they became forms of resistance and revolution. “After the 1960s,” Harris wrote, “ideology [tightened] its grip on the aesthetic of drag when gay men began to use their costumes to reevaluate the whole concept of normality and thus carry out a crucial part of the cross-dresser’s agenda: revenge.” Drag performers increasingly saw their vocation as political and started street organizations such as Street Transvestite Action Revolutionaries in order to join the wave of activism rising through their communities in New York, San Francisco, and other hubs.

    Suddenly, drag was not a private performance but a statement of public rebellion. The queens began using costume and performance to mock the fashion, manners, and mores of Middle America. In time, the need to shock required the performers to push the limits. “Men now wear such sexually explicit outfits as ball gowns with prosthetic breasts sewn on to the outside of the dresses, black nighties with gigantic strap-on dildos, and transparent vinyl mini-skirts that reveal lacy panties with strategic rips and telltale stains suggestive of deflowerment,” Harris noted. “The less drag is meant to allure, the bawdier it becomes, with men openly massaging their breasts, squeezing the bulges of their g-strings, sticking out their asses and tongues like porn stars in heat, and lying spread-eagle on their backs on parade routes with their helium heels flung into the air and their virginal prom dresses thrown over their heads.”

    “The goal of drag, following Butler and Rubin, is to obliterate conceptions of gender through performativity.”

    The next critical turn occurred in 1990, with the publication of Gender Trouble, by the queer theorist Judith Butler. Gender Trouble was a bombshell: it elevated the discourse around queer sexuality from the blunt rhetoric of Gayle Rubin to a realm of highly abstract, and sometimes impenetrable, intellectualism. Butler’s essential contribution was twofold: first, she saturated queer theory with postmodernism; second, she provided a theory of social change, based on the concept of “performativity,” which offered a more sophisticated conceptual ground than simple carnal transgression. Gender Trouble’s basic argument is that Western society has created a regime of “compulsory heterosexuality and phallogocentrism,” which has sought to enforce a singular, unitary notion of “sex” that crushes and obscures the true complexity and variation of biological sex, gender identity, sexual orientation, and human desire. Butler argues that even the word “woman,” though it relates to a biological reality, is a social construction and cannot be defined with any stable meaning or categorization. There is nothing essential about “man,” “woman,” or “sex”: they are all created and re-created through historically contingent human culture; or, as Butler puts it, they are all defined through their performance, which can change, shift, and adapt across time and space.

    Butler’s theory of social change is that once the premise is established that gender is malleable and used as an instrument of power, currently in favor of “heterosexual normativity,” then the work of social reconstruction can begin. And the drag queen embodies Butler’s theory of gender deconstruction. “The performance of drag plays upon the distinction between the anatomy of the performer and the gender that is being performed. But we are actually in the presence of three contingent dimensions of significant corporeality: anatomical sex, gender identity, and gender performance,” Butler writes. “When such categories come into question, the reality of gender is also put into crisis: it becomes unclear how to distinguish the real from the unreal. And this is the occasion in which we come to understand that what we take to be ‘real,’ what we invoke as the naturalized knowledge of gender is, in fact, a changeable and revisable reality. Call it subversive or call it something else. Although this insight does not in itself constitute a political revolution, no political revolution is possible without a radical shift in one’s notion of the possible and the real.”

    By the 2000s, the performance of drag had absorbed all these elements—the social-justice origin story of William Dorsey Swann, the carnal shock-and-awe of Gayle Rubin, the ethereal postmodernism of Judith Butler—and brought them together onto the stage. The queer theorist Sarah Hankins, who performed extensive field research in drag bars in the Northeast, captured the spirit of this subculture and its ideology in a study for the academic journal Signs. Drawing on the work of Rubin and Butler, Hankins describes three genres of drag—straight-ahead, burlesque, and genderfuck—that range from stripteases and lap dances to simulations of necrophilia, bestiality, and race fetishism. Hankins describes the world of drag as a “sociosexual economy,” in which the members of “queerdom” can titillate, gratify, and reward one another with cash tips and money exchanges. “As an audience member, I have always experienced the tip exchange as payment for sexual gratification,” Hankins writes. “And I am aware that by holding up dollar bills, I can satisfy my arousal, at least partially: I can bring performers’ bodies close to mine and induce them to touch me or to let me touch them.” Or, as one of her research subjects, the drag queen Katya Zamolodchikova, puts it: “I’m literally out there peddling my pussy for dollar bills.”

    The goal of drag, following the themes of Butler and Rubin, is to obliterate stable conceptions of gender through performativity and to rehabilitate the bottom of the sexual hierarchy through the elevation of the marginal. “The act of paying a dominant/domineering woman, a male supplicant, a hapless wage slave, or a boy allows the audience member to temporarily embody one or more of a number of ‘bad/unnatural’ social positions, for instance the pedophile, the closeted gay chickenhawk, the predatory female cougar, the sugar daddy or momma, even the sexualized youth/child themselves,” Hankins writes. And the discipline of “genderfuck” takes it a step even beyond adult–child sex. As Hankins describes, this style of performance “foregrounds tropes of primitivism and degeneracy as tools of protest and liberation” and seeks to subvert taboos against “pedophilia, necrophilia, erotic object fetishism, and human–animal sex.” These performances constitute the end of the line: the culmination of more than a century’s work, from the silk-and-satin drag balls to the hyper-cerebral politics of deconstruction to the annihilation of traditional notions of sex.

    The final turn in the story of drag is, in some ways, the most surprising. As the dark side of drag pushed transgression to the limits, another faction began moving from the margins to the mainstream. Some drag queens—most notably, the drag performer RuPaul—toned down the routines, pushed the ideology deep into the background, and presented drag as good old-fashioned, glamorous American fun. Television producers packaged this new form of drag as reality programming, softening the image of the drag queen and assimilating the genre into mass media and consumer culture.

    This provided an opportunity. As the queer theorists’ vanguard intellectual project was running aground on incest and bestiality fantasies, the most enterprising among them took a different tack: using the commercialization of drag and the goodwill associated with the gay and lesbian rights movement as a means of transforming drag performances into “family-friendly” events that could transmit a simplified version of queer theory to children. The key figure in this transition was a “genderqueer” college professor and drag queen named Harris Kornstein—stage name Lil Miss Hot Mess—who hosted some of the original readings in public libraries and wrote the children’s book The Hips on the Drag Queen Go Swish, Swish, Swish. Kornstein sits on the board of Drag Queen Story Hour, the nonprofit organization that was founded by Michelle Tea in 2015 to promote “family-friendly” drag performances and has since expanded to 40 local chapters that have organized hundreds of performances across the United States.

    [College professor Harris Kornstein, aka Lil Miss Hot Mess, a key figure in transforming drag performances into “family-friendly” events (SANTIAGO FELIPE/FILMMAGIC/GETTY IMAGES)]

    Kornstein also published the manifesto for the movement, “Drag Pedagogy: The Playful Practice of Queer Imagination in Early Childhood,” with coauthor Harper Keenan, a female-to-male transgender queer theorist at the University of British Columbia. With citations to Foucault and Butler, the essay begins by applying queer theory’s basic premise of social constructivism and heteronormativity to the education system. “The professional vision of educators is often shaped to reproduce the state’s normative vision of its ideal citizenry. In effect, schooling functions as a way to straighten the child into a kind of captive alignment with the current parameters of that vision,” Kornstein and Keenan write. “To state it plainly, within the historical context of the USA and Western Europe, the institutional management of gender has been used as a way of maintaining racist and capitalist modes of (re)production.”

    To disrupt this dynamic, the authors propose a new teaching method, “drag pedagogy,” as a way of stimulating the “queer imagination,” teaching kids “how to live queerly,” and “bringing queer ways of knowing and being into the education of young children.” As Kornstein and Keenan explain, this is an intellectual and political project that requires drag queens and activists to work toward undermining traditional notions of sexuality, replacing the biological family with the ideological family, and arousing transgressive sexual desires in young children. “Building in part from queer theory and trans studies, queer and trans pedagogies seek to actively destabilize the normative function of schooling through transformative education,” they write. “This is a fundamentally different orientation than movements towards the inclusion or assimilation of LGBT people into the existing structures of school and society.”

    For the drag pedagogists, the traditional life path—growing up, getting married, working 40 hours a week, and raising a family—is an oppressive bourgeois norm that must be deconstructed and subverted. As the drag queens take the stage in their sexually suggestive costumes, Kornstein and Keenan argue, their task is to disrupt the “binary between womanhood and manhood,” seed the room with “gender-transgressive themes,” and break the “reproductive futurity” of the “nuclear family” and the “sexually monogamous marriage”—all of which are considered mechanisms of heterosexual, capitalist oppression. The books selected in many Drag Queen Story Hour performances—Cinderelliot, If You’re a Drag Queen and You Know It, The Gender Wheel, Bye Bye, Binary, and They, She, He, Easy as ABC—promote this basic narrative. Though Drag Queen Story Hour events are often billed as “family-friendly,” Kornstein and Keenan explain that this is a form of code: “It may be that DQSH is ‘family friendly,’ in the sense that it is accessible and inviting to families with children, but it is less a sanitizing force than it is a preparatory introduction to alternate modes of kinship. Here, DQSH is ‘family friendly’ in the sense of ‘family’ as an old-school queer code to identify and connect with other queers on the street.” That is, the goal is not to reinforce the biological family but to facilitate the child’s transition into the ideological family.

    After the norms of gender, sexuality, marriage, and family are called into question, the drag queen can begin replacing this system of values with “queer ways of knowing and being.” Kornstein and Keenan make no bones about it: the purpose of what they call drag pedagogy, or the “pedagogy of desire,” is about reformulating children’s relationship with sex, sexuality, and eroticism. They describe drag as a “site of queer pleasure” that promises to “turn rejection into desire” and “[transform] the labour of performance into the pleasure of participation,” and DQSH as offering a “queer relationality” between adult and child. They litter their paper with sexualized language and double entendres, blurring the lines between adult sexuality and childhood innocence. In fact, as the queer pedagogist Hannah Dyer has written, queer pedagogy and, by extension, drag pedagogy seek to expose the very concept of “childhood innocence” as an oppressive heteropatriarchal illusion. “Applying queer methods of analysis to studies of childhood can help to queer the rhetoric of innocence that constrains all children and help to refuse attempts to calculate the child’s future before it has the opportunity to explore desire,” Dyer writes.

    The purpose, then, is to subvert the system of heteronormativity, which includes childhood innocence, and reengineer childhood sexuality from the ground up. And drag performances provide a visual, symbolic, and erotic method for achieving this. Kornstein and Keenan’s language of the discipline—“pleasure,” “desire,” “bodies,” “girls,” “boys,” “glitter,” “sequins,” “wigs,” and “heels”—gives it away.

    Of course, the organizers of Drag Queen Story Hour understand that they must manage their public image to continue enjoying access to public libraries and public schools. They have learned how to speak in code to NGOs and to appease the anxieties of parents, while subtly promoting the ideology of queer theory to children. While many of Drag Queen Story Hour’s defenders claim that these programs are designed to foster LGBTQ “acceptance” and “inclusion,” Kornstein and Keenan explicitly dismiss those objectives as mere “marketing language” that provides cover for their real agenda. “Though DQSH publicly positions its impact in ‘help[ing] children develop empathy, learn about gender diversity and difference, and tap into their own creativity,’ we argue that its contributions can run deeper than morals and role models,” they write. “As an organization, DQSH may be incentivized to recite lines about alignment with curricular standards and social-emotional learning in order to be legible within public education and philanthropic institutions. Drag itself ultimately does not take these utilitarian aims too seriously (but it is quite good at looking the part when necessary).” In other words, as a movement, Drag Queen Story Hour has learned the dance of operating a cash-flow-positive activist organization, winning government contracts, and securing access to audiences, while providing a plausible rhetorical defense against parents who might question the wisdom of adult men creating “site[s] of queer pleasure” with their children.

    This gambit has been remarkably successful. Drag Queen Story Hour began with voluntary programs at public libraries, which are required by law to provide equal access to organizations regardless of political affiliation or ideology. But within a few years, those state-neutral events have turned into state-subsidized drag performances for children. The New York City Council and New York Public Library have provided taxpayer funding directly to the Drag Queen Story Hour nonprofit, sparking a trend of state-subsidized drag readings, dances, and performances across the country. Next, the New York City Public Schools, with more than $200,000 in funding from the municipal government, began hosting dozens of drag performances in elementary, middle, and high schools in all five boroughs. Other political figures seem to want to go even further. The attorney general of Michigan has called for a “drag queen for every school.” California state senator Scott Wiener has suggested in a tweet that he might propose legislation to offer “Drag Queen 101 as part of the K–12 curriculum” and mandate that students attend Drag Queen Story Time as a way to “satisfy the requirement.” Both might have said this tongue in cheek—but in any case, these things have a way of going from joke to reality at the speed of light.

    “New York City began hosting dozens of drag performances in public schools in all five boroughs.”

    Though the spread of sexually charged drag performances has an aura of inevitability, one should keep in mind that transgressive ideologies always contain the seeds of their own destruction.

    As the movement behind drag shows for children has gained notoriety and expanded its reach, some drag performers have let the mask slip: in Minneapolis, a drag queen in heels and a pink miniskirt spread his legs open in front of children; in Portland, a large male transvestite allowed toddlers to climb on top of him, grab at his fake breasts, and press themselves against his body; and in England, a drag queen taught a group of preschoolers how to perform a sexually suggestive dance.

    Scenes from drag events hosted across the United States in bars, clubs, and outdoor festivals have been even more shocking and disturbing: in Miami, a man with enormous fake breasts and dollar bills stuffed into his G-string grabs the hand of a preschool-aged girl and struts her in front of the crowd; in Washington, D.C., a drag queen wearing leather and chains teaches a young child how to dance for cash tips; in Dallas, hulking male figures with makeup smeared across their faces strip down to undergarments, simulate a female orgasm, and perform lap dances on members of a roaring audience of adults and children. Newspaper headlines have also announced abuses: “Tucson High School Counselor Behind Teen Drag Show Arrested for Relationship with Minor”; “Houston Public Library Admits Registered Child Sex Offender Read to Kids in Drag Queen Storytime”; “Drag Queen Charged with 25 Counts of Felony Child Sexual Abuse Material Possession”; “Second ‘Drag Queen Story Hour’ Reader in Houston Exposed as Convicted Child Sex Offender”; “Drag Queen Story Hour Activist Arrested for Child Porn, Still Living with His Adopted Kids.”

    Advocates of Drag Queen Story Hour might reply that these are outlier cases and that many of the child-oriented events feature drag queens reading books and talking about gender, not engaging in sexualized performances. But the spirit of drag is predicated on the transgressive sexual element and the ideology of queer theory, which cannot be erased by switching the context and softening the language. The philosophical and political project of queer theory has always been to dethrone traditional heterosexual culture and elevate what Rubin called the “sexual caste” at the bottom of the hierarchy: the transsexual, the transvestite, the fetishist, the sadomasochist, the prostitute, the porn star, and the pedophile. Drag Queen Story Hour can attempt to sanitize the routines and run criminal background checks on its performers, but the subculture of queer theory will always attract men who want to follow the ideology to its conclusions.

    When parents, voters, and political leaders understand the true nature of Drag Queen Story Hour and the ideology that drives it, they will work quickly to restore the limits that have been temporarily—and recklessly—abandoned. They will draw a bright line between adult sexuality and childhood innocence, and send the perversions of “genderfuck,” “primitivism,” and “degeneracy” back to the margins, where they belong.

    Christopher F. Rufo is a senior fellow at the Manhattan Institute and a contributing editor of City Journal.

    Top Photo: Drag queens read to children at a public library in Chelsea, Massachusetts. (ERIN CLARK/THE BOSTON GLOBE/GETTY IMAGES)

    City Journal is a publication of the Manhattan Institute for Policy Research (MI), a leading free-market think tank. Are you interested in supporting the magazine? As a 501(c)(3) nonprofit, donations in support of MI and City Journal are fully tax-deductible as provided by law (EIN #13-2912529).

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    City Journal is the nation’s premier urban-policy magazine, “the Bible of the new urbanism,” as London’s Daily Telegraph puts it. During the 1990s, City Journal was integral to the revitalization of New York City. The Public Interest called it “the magazine that saved the city.”

    But City Journal is a national, not just a local, force, with a readership that spans the U.S. The country’s most thoughtful journalists are among the quarterly magazine’s subscribers, as are top businessmen and financiers. Public officials from coast to coast look to the magazine as a regular source of policy guidance. Leading newspapers, from the Wall Street Journal to the Los Angeles Times, regularly print adaptations of City Journal articles, disseminating the magazine’s influence to millions of readers.

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  • Hey Ginzo!

    I gotta bone to pick with you! 😡

    The patriots have reported to me that there are a lot of niggers on this goddamn shit hole of a website and I think it’s about time you started cleaning house with them!

    Why you letting all these goddamn niggers run wild and free?!

    This ain’t the place for niggers to be doing all that shit, don’t ya think?! 🤨

    Better get your guido ass moving on that, boy!

    That’s an order, nigger!

    • Well, think again, and think fast! I told that Patriot God of yours he’d have to write to me! He’ll write to me today, or he’s through! Why are you wasting my time? I can get along without you! And another thing: Keep those Night Riders out of my way while you decide. I’ll whoop them, if you don’t!

      I’ll publish Patriot God and McBlack’s interview if it is not too long, limited to 3000 words, and no sentences with all capital letters. I will write my own article, which will be published simultaneously, which will give my perspective on Patriot God’s view and why I think it is flawed. If you want to debate it, we can do it.

      Think it over. You’ve got till midnight tonight to answer. Then you’re either in or out, for keeps!

      • Mr. Parlato, sir.

        I am the one handling this affair. I am the interviewer. I sent Mr. Patriot God the questionnaire via email and he already sent it back. It is out of his hands and is up to me. Please do no not consult with him or Mr. Ludlow about these matters. They have no control over it.

        “I told that Patriot God of yours he’d have to write to me! He’ll write to me today, or he’s through! Why are you wasting my time?“

        With all due respect, Mr. Parlato, no you did not. I cannot get my work done by midnight tonight. I would’ve already been done, but I stopped working when you told me that you were tricking me. That is your fault. Why the rush?! You already delayed Mr. Patriot God’s series of articles for months now! And now you’re trying to put a clock on me?!

        Please be reasonable! Nobody is trying to “waste [your] time” unlike you e done both to me and Mr. Patriot God before! Please do not be this ridiculous of a hypocrite!

        “I’ll publish Patriot God and McBlack’s interview if it is not too long, limited to 3000 words, and no sentences with all capital letters.”

        Mr. Parlato, sir! With all due respect, this was not the original agreement. This is my interview and I want to strictly abide by the U.S. Constitution.

        Meaning: *NO CENSORSHIP WHATSOEVER*!

        That also includes not limiting the length of words or capitalization.

        This is my interview and I wanted the reputation as a reporter as one who strictly follows the U.S. Constitution. If you want to discredit yourself in that way, then as contemptible as it is, I can’t stop you. But for my articles in which my name is on the line, we strictly follow the U.S. Constitution and don’t try to make up excuses to amend it to what we want for ourselves.

        If people don’t like that, then nobody is forcing them to read the articles. These are grown adults who have a choice not to do so. They don’t need a parent to decide what’s “appropriate” for them to read, Mr. Parlato. If you want to play that game then feel free to do so on your own work. Please don’t do it on mine.

        I want all of the articles of both the interview and the series of articles by Mr. Patriot God, PEFT COMPLETELY UNCENSORED. NO EDITS FROM YOU WHATSOEVER!

        That also, includes the comment sections on our articles as well.

        You can be an anti-constitutional tyrant on your own work, but not on mine! It’s everything or nothing with that!

        That was the agreement. Stop trying to flip flop and make up extra rules.

        “I will write my own article, which will be published simultaneously, which will give my perspective on Patriot God’s view and why I think it is flawed. If you want to debate it, we can do it.”

        Thank you for finally stating what you already agreed to previously. I don’t understand why that was so hard for you?! Please do not flip flip on it again! I will remind you about the other part of the agreement and that is the publication of Mr. Patriot God’s series of articles that he already sent to you, IMMEDIATELY AFTER the publication of the interview (and which the entire interview is founded upon).

        If you wish to criticize both the interview and his series of articles in your separate article(s), you are more than welcome to do so. Just please don’t put any commentary in my interview or Mr. Patriot God’s series of articles or edit them.

        I’m working as fast as I can. Do not hold me by midnight, that is completely ridiculous and unfair. I will get it to you as sons as possible.

        Do not change the agreement anymore!

        Thank you, kindly.

          • “By gad, sir, you’re a troll worth knowing. An amazing character. How long do you need?”

            Again, Mr. Parlato, I’m not a “troll”. I don’t k ow why you want to keep calling me that or what I’ve done that qualifies as “trolling” in your eyes, but please stop calling me that!

            I don’t k ow how much time. It depends on many factors!

            Thank you kindly,

    • Better a n*gger than wigger like Scott Johnson.
      ***

      Currently, Scotty is doing the most wiggerly thing possible….

      Making money from multiple revenue streams…..

      …..That don’t cover any of his expenses.

  • This is the only example I’ve heard about re defamation of Marc.

    What other claims/incidents occur in Seduced that support his claim?

  • The government is working diligently to erode our constitutional rights. At least the power/wealth is on the side of free speech in this case, preserving our rights albeit, underhanded tactics of Lionsgate.

  • Is it possible to see the full footage they pulled Marc’s comment from?

    They made it appear as a response to Raniere’s comment, but what damages has Marc suffered as a result?

    Has his reputation or earning ability been negatively impacted? Doesn’t he have to prove a loss?

    There is nothing high level or “Harvard” about the treatment of women even in loose relation to Raniere or DOS.

    • Case 2:21-cv-08206 Document 1 Filed 10/15/21 Page 1 of 29 Page ID #:1

      Joseph M. Tully (CASBN: 201187)
      Tully & Weiss Attorneys at Law
      713 Main Street
      Martinez, CA 94553
      Phone: (925) 229-9700
      Fax: (925) 231-7754
      Email: Joseph@Tully-Weiss.com

      Attorneys for Plaintiff Marc Elliot

      UNITED STATES DISTRICT COURT
      CENTRAL DISTRICT OF CALIFORNIA

      MARC ELLIOT,
      Plaintiff,
      v.
      LIONS GATE ENTERTAINMENT CORPORATION
      and STARZ, INC.,
      Defendants.

      Case No.:

      COMPLAINT AND DEMAND FOR
      JURY TRIAL

      COMPLAINT
      Plaintiff, Marc Elliot (“Plaintiff”), by and through his attorneys, Tully & Weiss Attorneys at
      Law, respectfully alleges as follows:

      INTRODUCTION
      1. Plaintiff brings this action against Defendants, acting in concert, jointly and
      severally, for statutory and common law defamation per se, defamation by implication, and
      violation of Plaintiff’s right to privacy by the unconsented to appropriation of Plaintiff’s name and
      likeness, placing Plaintiff publicly in false light, and by intentionally inflicting upon Plaintiff severe
      emotional distress.
      2. Defendants filmed, produced, wrote, and broadcasted a limited television series
      named, “Seduced: Inside the NXIVM Cult” (“Seduced” or “Series”), wherein by misleading
      splicing of words, editing, and use of Plaintiff’s images, Defendants insinuate that Plaintiff is
      dangerous, has been trained to kill, is capable of killing himself if told to, and condones sexual
      violence against women. Further, in the series Defendants equate Plaintiff to the likening of a rapist,
      an ISIS and Al Qaeda terrorist, a Nazi experimenter, and a murderer on command.
      3. Defendants’ false and inflammatory statements and portrayal of Plaintiff were
      abusive, vulgar, intentionally misleading, and damning to Plaintiff’s reputation and good name.
      Defendants’ communications were spread to the public through Defendants’ platform, STARZ, as
      well as other major streaming platforms and television networks, including but not limited to Hulu,
      YouTube TV, Sling TV, Amazon Prime Video, Google Play Movies and TV, Apple TV, and Vudu.
      4. Plaintiff is a private citizen in that he is neither a politician nor a celebrity.
      5. Defendants’ actions were malicious, intentional in nature, and undertaken to damage
      Plaintiff’s reputation and career, as well as for Defendants to profit financially through their actions.
      6. As a result of Defendants’ extreme and defamatory conduct, Plaintiff has been
      subject to widespread humiliation, denigration, mental and emotional anguish, social stigma,
      threats, professional backlash, and occupational losses.
      7. In light of Defendants’ campaign of public humiliation and stoking outrage against
      Plaintiff, Plaintiff seeks judicial intervention to preserve and reinstate his previously unblemished
      personal and professional reputation.
      JURISDICTION AND VENUE
      8. Pursuant to 28 U.S. Code section 1332, subdivision (a) (1), this Court has original
      subject matter jurisdiction over this civil action in that Plaintiff and Defendants are citizens of
      different states, and the amount in controversy at issue exceeds $75,000.
      9. Pursuant to 28 U.S. Code section 1391, subdivision (b), venue is proper in the
      Central District of California as Defendants conduct business in the Central District of California, a
      substantial part of the events giving rise to Plaintiff’s claim occurred in the Central District of
      California, and Defendants reside in the State of California as determined pursuant to 28 U.S. Code
      section 1391, subdivision (c)(2).
      PARTIES
      10. Marc Elliot, hereafter “Plaintiff,” is a natural person and a resident of St. Louis,
      Missouri.
      11. Lions Gate Entertainment Corporation, hereafter “Defendant(s),” is a corporation
      headquartered in the State of California. Lionsgate Television is the television division of
      Lionsgate.
      12. STARZ, hereafter “Defendant(s),” is a corporation with offices in the State of
      California and a subsidiary of Defendant Lionsgate since 2016.
      BACKGROUND
      Plaintiff is Diagnosed with Tourette Syndrome and Becomes a Nationally Recognized
      Inspirational Speaker
      13. Plaintiff grew up in St. Louis, Missouri. At nine years old, he was diagnosed with
      Tourette Syndrome. The medical community deems Tourette’s to be a genetic, neurological,
      involuntary, and incurable disorder that manifests in both vocal and motor outbursts known as
      “tics.” As he got older, his tics progressively became worse, resulting in violent head shaking, hip
      thrusting, and eventual profanity and racial slurs, which only a subset of individuals with Tourette
      Syndrome exhibit known as coprolalia.
      14. Over the 20 years he suffered from Tourette’s, Plaintiff’s family took him to
      renowned doctors throughout the nation to find treatments to alleviate his tics. At the time of his
      diagnosis and still, to this date, the American medical community’s stance is that there is no known
      cure for Tourette’s. Throughout middle and high schools, Plaintiff took neuroleptic medications that
      sedated him to such a degree that he was almost forced to extend high school to a fifth year. He
      tried hypnosis and habit reversal, a type of cognitive behavior therapy, and multiple medicinal
      treatments.
      15. In 2008, after graduating from Washington University in St. Louis, Plaintiff
      launched a career as an inspirational speaker. Drawing from his lessons of living with Tourette’s for
      17 years, he created a presentation on compassion and tolerance entitled “Don’t Judge a Book by Its
      Noises.” The purpose of the presentation was to encourage people not to judge others because, as
      Plaintiff would share, “We all have struggles that no one knows about.”
      16. The initial response from high school and college student audiences was so positive,
      Plaintiff decided not to pursue medical school, as he initially planned, and instead moved from St.
      Louis to New York City in the fall of 2009.
      17. In his first year of speaking, Plaintiff booked between 60 to 70 engagements at
      middle schools, high schools, and colleges across the nation and was signed by a top college
      speaking agency in 2009. Eventually, he changed the title of his presentation to “What Makes You
      Tic?”
      18. Over the next four years, Plaintiff traveled across the country and internationally to
      spread a message of tolerance using the old adage “Live and Let Live.” At the age of 24, Plaintiff
      was named 2011 College Speaker and Diversity Speaker of the Year by Campus Activities
      Magazine. From 2009 to 2013, Plaintiff booked and performed at approximately 450 speaking
      Engagements, and, in 2011, he self-published a book, “What Makes You Tic? My Journey from
      Tourette’s to Tolerance.”
      Plaintiff Introduced to NXIVM’s Executive Success Programs
      19. In 1998, Keith Raniere and Nancy Salzman founded NXIVM, a personal
      development company offering Executive Success Programs (“ESP”), and a range of techniques for
      self-improvement. While NXIVM was the parent company for many offshoot companies, ESP was
      one of the prominent companies under the NXIVM umbrella, operating training centers and
      programs internationally.
      20. In or about Fall 2009, Plaintiff met another speaker at a college speaking conference
      in Portland, Oregon. This speaker was a coach with ESP and spoke to Plaintiff about taking some of
      the company’s courses. This speaker described ESP as courses on emotional intelligence that help
      people break through limiting beliefs. Plaintiff did not sign up for the courses at that conference but
      continued communicating with this speaker over time.
      21. In the summer of 2010, following more conversations, Plaintiff eventually signed up
      for ESP’s 5-day introductory course. The course was held in New York City, where Plaintiff was
      living. Plaintiff experienced such positive transformations and insights into himself during the
      course that he decided to continue with the remaining 11 days of ESP’s introductory courses in
      Albany, New York.
      22. After completing the 16-day ESP introductory course that summer, Plaintiff began
      his speaking tour, which aligned with the school calendar, in the fall of 2010. Over the 2010-2011
      school year, Plaintiff continued to speak at schools across the nation and did not take any other ESP
      training during that time. By the end of that school year, Plaintiff had noticed dramatic
      improvements in his Tourette’s due to ESP’s 16-day introductory course. His tics lessened to such a
      degree, that he believed that he could overcome his Tourette’s entirely.
      23. In the summer of 2011, one year after taking his initial 16-day course, Plaintiff took
      two advanced level ESP courses. He entered those courses with only one mission in mind – to
      overcome his Tourette’s. Plaintiff did just that. After completing those two ESP trainings, he saw a
      90% reduction in his verbal and nonverbal tics. Though the process was unconventional, it was safe,
      noninvasive, non-hypnotic, non-meditative, and entirely talk-based.
      24. Plaintiff continued his Tourette’s speaking tour that year, but with one significant
      difference: his Tourette’s was no longer visible. Because he was no longer visibly ticcing, he had to
      show a video of his life with Tourette’s to convey to audiences what his life was like when he was
      plagued with Tourette’s.
      25. Overjoyed at the results he experienced from ESP’s curriculum, Plaintiff began
      taking weekly ESP classes, known as “Ethos,” in Manhattan to further his personal growth. In May
      of 2013, Plaintiff decided to become a coach in ESP to help others have the same type of
      transformations he experienced. For the next year, Plaintiff continued to do public speaking while
      he was a coach in ESP.
      26. In the Spring of 2014, after four successful years of speaking engagements, Plaintiff
      decided to temporarily “retire” his speaking career to focus full time on becoming a trainer in ESP,
      also known as a “Proctor.” While Plaintiff loved giving inspirational speeches, he noticed that
      speaking about tolerance did not inspire the sustained and dramatic behavior changes that he saw
      others experience in the ESP curriculum.
      27. In 2014, Plaintiff was approached by others in NXIVM to see if he wanted to be a
      part of a team that would attempt to replicate the results he experienced with Tourette’s Syndrome.
      Plaintiff worked with Mr. Raniere and Ms. Salzman to find others suffering with Tourette’s and to
      see if these other individuals could see the same results in overcoming Tourette’s as Plaintiff did.
      Clare Bronfman, founder of the Ethical Science Foundation (“ESF”), was willing to fund this entire
      project. Plaintiff viewed this as a once-in-a-lifetime opportunity to help others afflicted with
      Tourette’s.
      28. Within a year, the team found one individual with Tourette’s interested in using
      ESP’s curriculum to overcome their condition. The individual came to Albany and worked with
      Plaintiff and the rest of the team over the summer to overcome his Tourette’s. After completing the
      curriculum, the individual was able to attend his freshman year of college completely free of
      Tourette’s. Encouraged by their results, Plaintiff and team continued their work, and over the next
      four years, the team replicated these unprecedented results with other individuals who had severe
      Tourette’s. Some participants saw a measurable 70-90% permanent reduction in their tics in a
      matter of hours. These transformations, and the process used to achieve them, were documented on
      video.
      29. Inspired by these profound results, a filmmaker began to document the work. The
      film took nearly three years to complete. In 2017, with Plaintiff as an assistant producer and
      prominent subject in the film, it had its international debut at the Cinequest Film festival in
      California. The film went on to earn official selection at several international film festivals and won
      “Best-Documentary” at the 2018 Harlem Film Festival. The documentary allowed a handful of
      audiences to see how the techniques of Rational Inquiry, a methodology consisting of only
      conversations, helped people overcome this unexplainable and “incurable” neurological disorder.
      30. Plaintiff’s dramatic transformation stood as an example to others with Tourette’s,
      which allowed Plaintiff to mentor the other participants as they began their own journey to
      overcome Tourette’s.
      31. From April 2014 to May 2017, Plaintiff continued to take many courses offered in
      ESP and other training from other companies under the NXIVM group of companies. Over the
      years, he recommended the ESP courses to many friends and family, who took the courses and in
      turn became coaches. He earned income teaching classes in ESP, conducting ESP training around
      the country, becoming a salesperson in ESP, and giving introductory sales presentations that
      educated people about ESP’s training.
      Criminal Allegations in the Media Lead to NXIVM Ending Operations and Plaintiff Being
      Threatened with Federal Prosecution
      32. In May 2017, a blog called the Frank Report began to publish posts about a secret
      women’s society that allegedly was associated with NXIVM, and was purported to be involved in
      sex trafficking. The blog publicly exposed people’s names and personal information without those
      people’s consent. Because of the salacious nature of the articles, many people in the NXIVM
      community feared being mentioned in the blog, despite the fact that they were not affiliated with the
      women’s group in question; being mentioned in the blog could have potentially devastating effects
      to someone’s reputation. The women’s group was not formally a part of the NXIVM group of
      companies.
      33. In March 2018, Plaintiff was subpoenaed by the FBI to testify before a grand jury in
      a case pertaining to NXIVM and the women’s group in question, despite Plaintiff having no
      affiliation with the women’s group nor any knowledge of the group.
      34. In the spring of 2018, as a result of the FBI’s investigation into the allegations of Sex
      Trafficking, among other criminal allegations, NXIVM closed its operations.
      35. In the summer of 2019, Plaintiff launched promotional material for a new
      presentation entitled, “Who’s Next? The Rise of Character Assassination and Loss of Human
      Decency.” The presentation explored his journey of overcoming Tourette’s through ESP training,
      the negative press against him and NXIVM, and how to deal with adversity with ethics, love, and
      compassion. The speech was intended to invoke teachings of nonviolence from notable thinkers
      throughout history.
      36. Within days of posting an advertisement for the talk on Instagram, Plaintiff’s
      attorney received a call from a federal prosecutor. The prosecutor inaccurately alleged that this talk
      was seen as a recruitment for NXIVM, which was no longer in business. The prosecutor threatened
      that if Plaintiff went ahead with giving the presentation, he would be indicted. The charge for which
      he would be indicted remains unknown, as it was never communicated. As a result of these threats,
      Plaintiff did not give the talk. He did not hear again from the prosecutor.
      Defendants Broadcast Defamatory Television Series
      37. On October 18, 2020, Defendants broadcast a limited series entitled, “Seduced:
      Inside the NXIVM Cult” (“Seduced” or “Series”). The series was directed by Cecilia Peck and
      executively produced by Peck, Inbal Lessner, Daniel Voll, Alexandra Michan, and India Oxenberg.
      Oxenberg had previously been involved in NXIVM for seven years and was friends with Plaintiff
      during that time.
      38. Seduced contained multiple false statements about Plaintiff, painting him in a false
      light and implying false negative information about Plaintiff through its use of editing. Oxenberg,
      Seduced’s Executive Producer and a former member of NXIVM, had knowledge of the falsity of
      Seduced’s content. Plaintiff was never approached, interviewed, or consulted on the content
      included in Seduced, which featured his name, likeness, and image. Plaintiff never provided consent
      for the commercial use of his name, likeness, and image in the series.
      39. Even though Plaintiff had no criminal history, had no pending criminal charges or
      allegations against him, and had no association with the woman’s group that accounted for the bulk
      of NXIVM’s negative press, Plaintiff’s likeness was used over 19 times in the Seduced series to
      insinuate that Plaintiff was a recruiter and member of a purported sex cult.
      Defendants use Epithets and Derogatory Suggestions to Insinuate Plaintiff Endorses Sexual
      Abuse Against Women
      40. In the second episode of Seduced and in the subsection “Radicalization: The SOP
      Courses,” Defendants manipulated and spliced video footage from a Society of Protectors (“SOP”)
      meeting, together with footage from a testimonial given by Plaintiff at a JNESS meeting, a different
      group than SOP, to imply that Plaintiff supports sexual misconduct against women in that he is
      recruiting men to SOP training based on Plaintiff’s implied belief that grabbing women, having
      sexual relations with them, and them liking it is a way to relate to women that has never been taught
      to men and that men should attended the SOP course to learn this purported way to relate to women.
      Notably, the JNESS meeting that Plaintiff spoke at was an educational course on gender issues and
      focused entirely different issues than the SOP courses.
      41. In fact, the purposes, and missions of JNESS and SOP were entirely different. The
      purpose of the specific JNESS meeting that Plaintiff spoke at was to help men and women
      understand and relate to each other better. The purpose of SOP was to help men develop more
      discipline, commitment, and honor, by understanding the nature of the male body and overcoming
      its impulses by exercising character.
      42. Defendants intentionally used a testimonial that Plaintiff gave for the JNESS
      meeting, along with an edited and spliced together audio clip of Raniere from an SOP training, so
      that it appears that Plaintiff supported “fucking,” “grabbing,” and “conquering” women, and invited
      other men to do the same.
      43. Plaintiff’s testimonial is predicated by an audio clip of Raniere, which are actually
      three audio clips that were spliced together but played as though it was one sentence spoken by
      Raniere. The spliced audio clip resulted in the following verbal statement: “The primitive parts of
      us are hungry fucky beasties. I mean, that’s what we want to do. Just fuck it. Fuck it. Fuck, fuck,
      fuck. I feel like fucking something today. God, I’m pissed, I want to fuck something, you know.”
      “If we conquer a woman, if we grab the thing we want to fuck, whatever it is and fuck it…” “…they
      enjoy it.” The sound of applause follows the edited together audio clip. However, in the actual
      footage of Raniere speaking in the SOP training, there is no applause. Defendants intentionally took
      the footage out of context, and manipulated it, and added applause to give a false appearance that
      those in attendance supported sexual violence and misconduct against women.
      44. Defendants then immediately cut to the testimonial of Plaintiff given at the JNESS
      meeting, where Plaintiff states, “No one has ever taught us how to relate to women, nowhere, in all
      the education of my whole life. And this is, in my opinion, the Harvard of trying to relate to women.
      You have to come.” This testimonial was related to the purposes of the JNESS meeting, and not to
      the SOP meeting from where the spliced audio clip was taken. However, a viewer of the Series
      would reasonably assume that Plaintiff’s glowing review referred to Raniere’s statement, which the
      Defendants intentionally manipulated to imply that Plaintiff supported and encouraged sexual
      violence and misconduct against women.
      Defendants Compare Plaintiff and Other NXIVM Members to Members of the Terrorist
      Organizations ISIS and Al-Qaeda
      45. At the end of Plaintiff’s testimonial, while his face is still on the screen, there is a
      voice-over that states, “Cult indoctrination is actually a mind-control regime…” and then cuts to an
      interview of Steven Hassan, who is labeled as a “Cult Expert” and a “Mental Health Counselor,”
      finishing his quote, “…to reprogram your beliefs and to foster obedience.” With Plaintiff’s image
      still on the screen during the voice-over, Defendants make it clear that the expert is implying that
      Plaintiff, and others like him, support such allegedly profane and disgusting behavior because they
      are under “mind-control.”
      46. Another purported “cult expert,” Rick Ross, then follows Hassan’s quote. Ross
      states, “What you see in NXIVM is the same indoctrination and coercive persuasion process used
      by terrorist organizations like ISIS and Al-Qaeda.” This quote is a voice-over of video clips of
      children at a soldier training camp with the caption on the screen, “ISIS CHILD SOLDIER
      TRAINING.”
      47. Here, Defendants, through the “cult experts” they filmed for Series, explicitly equate
      ISIS child soldiers being trained to kill to people who took NXIVM classes. This comparison places
      members of NXIVM, including Plaintiff, in a false light, particularly as all NXIVM companies were
      devoted to nonviolence and had no relation to any militia groups or soldier training camps. Plaintiff
      was never trained to kill or hurt others, and Plaintiff knows of no members of NXIVM who were
      trained or encouraged to do so.
      48. Defendants use a misleading, spliced together audio clip of Raniere from an SOP
      meeting followed by Plaintiff’s testimonial from a JNESS meeting to convey to viewers that
      Raniere has followers that have been “radicalized” through “indoctrination” and that their beliefs
      have been “reprogrammed” to “foster obedience,” to perform acts of terror analogous to actions
      attributed to the terrorist organizations ISIS and Al-Qaeda.
      49. Out of over 17,000 individuals who took the NXIVM courses, Plaintiff is the only
      video and audio testimonial used in this section. He is represented as a loyalist and follower of
      Raniere. This section included audio of a “cult expert” stating that members were trained to be
      violent and weaponized to the likes of ISIS and Al-Qaeda.
      Defendants Compare Plaintiff, a Person of Jewish Descent, to Nazis to Convey that Plaintiff is
      Dangerous
      50. In the same episode entitled, “INDOCTRINATED,” Defendants focus on studies
      conducted within NXIVM by a Dr. Brandon Porter. In describing the studies completed by Dr.
      Porter, Defendants next use another purported “cult expert,” Dr. Janja Lalich, who states, “Makes
      one immediately think about what the Nazis were doing, where they carried out horrific
      experiments under the guise of great medical experiments. This is completely unconscionable,
      illegal activity–even if this were in a medical institution, and of course it wasn’t. In my opinion, this
      is one of the most horrific things I’ve ever heard of, and I’ve been studying cults for 30 years.” As
      she began to make this statement, Defendants display a clip of Plaintiff laughing hysterically, sitting
      next to Dr. Porter and Nancy Salzman. In actuality, this is a clip taken while they were discussing
      working with individuals with Tourette’s and having great success in doing so. Defendants’ implied
      message to viewers is that Plaintiff’s participation in NXIVM is comparable, and similar to the
      “horrific experiments” conducted by Nazis, with Plaintiff engaging in allegedly “unconscionable”
      and “illegal” activity.
      51. Before the use of Plaintiff’s image during this voiceover of being compared to Nazis,
      Plaintiff’s image/likeness had been used in a section only two minutes earlier dedicated to talking
      about how NXIVM supposedly worked with people scientifically and the company “claimed” to
      help people. Defendants falsely implied a connection between Plaintiff and medical studies
      conducted by Nazis. Not only has Plaintiff never injured anyone and has not been accused of
      injuring anyone, but Plaintiff is also Jewish, and his relatives were murdered by Nazis. Therefore,
      his comparison to the likes of Nazis here is particularly disheartening, and repugnant.
      52. Defendants intentionally targeted Plaintiff in this section. They could have used any
      picture or video of any of the thousands of NXIVM students who appeared with Dr. Brandon
      Porter. However, Defendants chose a clip with Plaintiff. By this point in the series, viewers had well
      been introduced to Plaintiff, as his image was prominently displayed multiple times.
      53. In the first episode, Plaintiff is referred to with his image/likeness as someone who
      beat Tourette’s. In the second episode, Plaintiff’s testimonial is used to establish that he is a
      brainwashed “follower” of Raniere, a proponent of sexual violence against women, and is likened to
      ISIS and Al-Qaeda terrorists. His first and last name appear on the screen for viewers to see and
      remember. There is then an entire section on NXIVM doing scientific experiments on people,
      wherein Defendants establish Plaintiff as someone related to Tourette’s experimentation and
      associate him in multiple shots to Nancy Salzman and Dr. Porter. During that section, his likeness is
      on the screen for another 15 seconds. Then only a minute and a half later, is the quote about Nazis.
      Layering the Plaintiff throughout the episode equates in viewers’ minds that Plaintiff is a danger to
      society.
      Defendants Manipulate Footage to Insinuate that Plaintiff is Dangerous, and Capable of
      Committing Murder on Command
      54. Approximately five minutes after the Nazi quote, there is a new section in the
      episode two titled, “ULTIMATE DEVOTION: THE “ETHICIST” COURSE.” The Ethicist course
      was a course Raniere created to help individuals understand, build, and strengthen their own set of
      ethics. Defendants add the words “ultimate devotion” to continue the falsified notion that members
      of NXIVM, such as Plaintiff, would do anything for Raniere, such as fight or kill for him as implied
      in earlier scenes of the series. Oxenberg states at the beginning of the section, “Keith became
      obsessed with having us watch these movies that were all about people sacrificing themselves for a
      greater cause.”
      55. Purported “cult expert” Rick Ross then follows, “In a destructive cult, there is an
      absolute authoritarian leader who becomes an object of worship. Everything in the group becomes,
      ‘How much are you willing to do for Keith Raniere?’ And Keith Raniere was teaching a philosophy
      that the ends justify the means. If we lie, but our goal is to save the world, isn’t that justified?’”
      56. Here, viewers are led to falsely believe any follower of Raniere learns that doing
      destructive things is okay so long as one’s goal is “good.” Defendants utilize purported “cult
      experts” to imply that this is the indoctrination of all “followers,” including Plaintiff.
      57. In the video clips immediately following, Defendants use purposeful editing and
      misinformation to make it appear as though Plaintiff is receiving orders from Raniere to kill
      someone and that such actions are justified. Despite what the manipulated cuts show, in the
      unedited cuts it can be seen that Raniere was talking about building compassion and empathy for all
      individuals, and the importance of extending that compassion to all humans, including someone
      who had committed a horrible act, like murder. He was not condoning the action of murder and was
      not giving someone instructions to kill, as Defendants falsely portrayed. Rather, he was speaking
      about building compassion for why someone would commit horrific acts. This is evident from
      watching the original, unedited footage. Still, Defendants gathered and edited footage in a way to
      create a false narrative and communicate this false narrative to the viewers.
      58. Additionally, the raw footage clearly shows that Raniere is addressing someone other
      than the Plaintiff, yet the Defendants edit the raw footage to make it appear as if Keith is giving
      Plaintiff specific instructions to kill someone specifically:
      (1) Defendants cut to Keith sitting in a chair appearing to speak to someone and stating,
      “You can understand killing when you feel it is necessary. So here you have these
      women….”;
      (2) Defendants then cut to Plaintiff holding a microphone appearing to be the receiver of
      Raniere’s statement with a voiceover of Raniere stating, “…and let’s suppose these women
      are representative of a gang that is killing your family…”;
      (3) Defendants cut back to a clip of Raniere stating, “…and that you feel that if you don’t do
      this, your family is going to die or people you know are going to die. So, you feel they must
      die”;
      (4) Defendants cut to Ross stating, “Whatever I ask you to do, don’t worry about whether it
      is illegal, it’s criminal, it’s unethical, because our goal is to improve the world and as long as
      that’s our stated goal, whatever I ask you to do is justified.” Defendants then cut to footage
      of burning buildings from the “Waco siege,”1
      followed by dead bodies on the ground from
      Jonestown, 2 with the voiceover, “Historically, the most terrible example would be Waco or
      Jonestown, where you have people willing to die and let their children die because the leader
      says this is what we must do”; and
      ________________________________
      1 The Waco Siege began in early 1993, when a government raid on a compound in Axtell, Texas, led to a 51-day standoff between
      federal agents and members of a millennial Christian sect called the Branch Davidians. See Waco Siege, HISTORY.COM,
      https://www.history.com/topics/1990s/waco-siege (last updated Aug. 21, 2018). The siege ended dramatically on April 19, 1993,
      when fires consumed the compound, leaving some 75 people dead, including 25 children. Id.
      2 The “Jonestown Massacre” occurred on November 18, 1978, when more than 900 members of an American cult called the Peoples
      Temple died in a mass suicide-murder under the direction of their leader Jim Jones (1931-78). See Jonestown, HISTORY.COM,
      https://www.history.com/topics/crime/jonestown (last updated Nov. 20, 2019). It took place at the so-called Jonestown settlement in
      the South American nation of Guyana. Id

      (5) Defendants then cut to video footage of dead bodies from Heaven’s Gate.3 The section
      ends with Rick Ross stating, “It’s very scary to think where Keith Raniere really was leading
      this group because year after year it escalated.”
      59. Raniere never asked Plaintiff for devotion, or called upon Plaintiff to blindly follow
      him. On the contrary, there are many documented instances of Raniere calling his students to
      question everything he says.
      60. Defendants’ intent as it spliced together and purposely edited the montage is clear.
      Defendants were falsely communicating to the viewers that members of NXIVM, such as Plaintiff,
      who had been featured heavily on screen at this point, were being controlled and trained by Raniere
      to the point where they would die for and allow their children to die for Raniere. Additionally,
      Defendants had just falsely communicated to the viewers that Raniere was giving Plaintiff
      instructions to kill someone.
      61. This segment ends with the horrific intentional insinuation by the Defendants that a
      NXIVM member like the Plaintiff could commit murder or suicide just like in “Jonestown,” where
      you have people willing to do and let their children die because the leader says this is what we must
      do.”
      62. Defendants knowingly and intentionally targeted to discredit, defame, and destroy
      Plaintiff. First, the segment in this section depicting Raniere “giving instructions to kill” is from a
      training called, “The Source,” an acting curriculum that Raniere had created, not the Ethicist
      training, as was implied in the section’s title. The Defendants knowingly used video footage from
      different trainings by different subcompanies under NXIVM and misrepresented it to fit their
      defamatory narrative and to attract viewers for pecuniary benefit.

      ________________________________________________

      3 On March 25, 1997, following an anonymous tip, police enter a mansion in Rancho Santa Fe, an exclusive suburb of San Diego,
      California, and discover 39 victims of a mass suicide. See Heaven’s Gate cult members found dead, HISTORY.COM ,
      https://www.history.com/this-day-in-history/heavens-gate-cult-members-found-dead (last visited Oct. 14, 2021). The deceased—21
      women and 18 men of varying ages—were all found lying peaceably in matching dark clothes and Nike sneakers and had no
      noticeable signs of blood or trauma. Id. It was later revealed that the men and women were members of the “Heaven’s Gate” religious
      cult, whose leaders preached that suicide would allow them to leave their bodily “containers” and enter an alien spacecraft hidden
      behind the Hale-Bopp comet. Id.

      63. Secondly, Plaintiff was one of the first participants in The Source training. In it, he
      did ask questions to Raniere that were on camera. As can be seen by the original footage of The
      Source training with no cuts, someone else asked Raniere a question that prompted Raniere’s
      response about killing. Defendants spliced Plaintiff asking Raniere a question from one section of
      the raw footage and Raniere responding to another participant from a different section of the raw
      footage, making it look as though Raniere was directly talking to Plaintiff instead. Defendants
      falsely and intentionally made it appear that Plaintiff was receiving orders from Raniere to kill. Not
      only did these edits grossly mischaracterize Raniere’s statement, but they also falsely portrayed
      Plaintiff as the intended audience of Raniere’s words and purported commands.
      64. Defendants proactively incorporated Plaintiff into the segment to create the
      impression that Plaintiff was the ultimate loyalist of the insinuated sex cult, and extremely
      dangerous. Defendants had layered Plaintiff throughout the episode in the series to build to this
      moment. As stated by Ross earlier in the episode, “He wanted his followers weaponized to take on
      his enemies.” Viewers are left to believe that Plaintiff and anyone like him are now weaponized
      with no moral compass to do horrific acts on other human beings. This notion is the opposite of the
      nature of the ESP courses that Plaintiff studied and taught to entrepreneurs and executives.
      65. The fact that Defendants had to manipulate and splice together footage containing
      Plaintiff, unrelated to the purported sex cult narrative in order to fit such narrative, shows that all
      statements made by Defendant in which Plaintiff was a subject through his likeness, were false,
      intentionally injurious to Plaintiff, and known to be such by Defendants.
      Defendants Intentional Conduct Resulted in Irreparable Harm to Plaintiff’s Reputation, has
      Caused Him to Suffer Financial Loss, Great Humiliation, Emotional Distress, and Threats to His
      Safety
      66. Plaintiff has committed no crimes, nor has he been accused of any crimes. However,
      through creative film editing, voice-overs, and out-of-context statements, Defendants have
      communicated to viewers of the series that Plaintiff is dangerous, has been trained to kill, is capable
      of killing himself if told to, and condones violence against women. Defendants characterize Plaintiff
      to the likening of a rapist, a terrorist in training, a Nazi experimenter, and a potential murderer at the
      direction of Raniere. Viewers are left with an indelible imprint that Plaintiff is dangerous follower
      who is weaponized.
      67. Defendants not only broadcast the Seduced series on the STARZ network and its
      streaming platform, but also provided the series for publication to other major television streaming
      platforms, including Hulu, YouTube TV, Sling TV, Amazon Prime Video, Google Play Moves and
      TV, Apple TV, Vudu4
      , all of which have a combined viewership of several million subscribers, with
      175 million viewers subscribed to Amazon Prime alone specifically to watch series and movies.
      5
      Thus, on information and belief, Defendants published their defamatory content about Plaintiff to
      millions of people not only in the United States, but worldwide.
      68. Plaintiff has dedicated the last 20 years of his life trying to better the lives of others
      to find more tolerance, compassion, and possibility in their own life. Seduced’s executive producer,
      Oxenberg, has known Plaintiff for seven years and knew this to be true, and knew that Defendants’
      defamatory communications and implications about Plaintiff were false. It is clear that Defendants’
      actions were malicious, purposeful, premeditated, egregious, and an irreparable attack on Plaintiff’s
      reputation.
      AS TO THE FIRST CAUSE OF ACTION
      (DEFAMATION PER SE)
      69. In October 2020, Defendants broadcast the television series Seduced containing false
      negative information about Plaintiff. Defendants, through the use of edited video and audio clips,
      voice-overs, written content, and statements taken out of context, have communicated to millions of
      people in the United States and worldwide that Plaintiff is dangerous, has been trained to kill, is
      capable of killing himself if told to, and condones sexual violence against women. Defendants

      _____________________________________________________

      4 Seduced Google search with streaming options can be found at
      http://www.google.com/search?q=seduced+nxivm&oq=seduced&aqs=chrome.0.69i59j46i39j69i57j69i59l2j69i60l2j69i61.2370j0j4
      &sourceid=chrome&ie=UTF-8 (last visited Oct. 14, 2021).
      5 For the first time, Amazon provided some hard data on how many of its Prime subscribers are watching TV shows and movies on
      the platform. See Adam Epstein, Amazon’s streaming audience is almost as big as Nexflix’s, QUARTZ,
      https://qz.com/2003812/amazon-prime-has-almost-as-many-streaming-subscribers-as-netflix/ (Apr. 30, 2021).

      equate Plaintiff to the likening of a rapist, an ISIS and Al Qaeda terrorist in training, a Nazi
      experimenter, and a potential murderer at the direction of Raniere. Viewers are left with an indelible
      false imprint that Plaintiff is a dangerous weaponized follower. Specifically:
      I. Defendants spliced audio and video footage together to make it appear as though
      Plaintiff gave a glowing endorsement of the statement, “The primitive parts of us are
      hungry fucky beasties. I mean, that’s what we want to do. Just fuck it. Fuck it. Fuck,
      fuck, fuck. I feel like fucking something today. God, I’m pissed. I want to fuck
      something, you know.” “If we conquer a woman, if we grab the thing we want to fuck,
      whatever it is and fuck it…” “…they enjoy it.”
      II. Defendants played the statement “cult indoctrination is actually a mind-control
      regime…to reprogram your beliefs and to foster obedience” over an image of Plaintiff’s
      face. This was immediately followed by the statement, “What you see in NXIVM is the
      same indoctrination and coercive persuasion process used by terrorist organizations, like
      ISIS and Al-Qaeda.”
      III. Defendants played the statement “He wanted his followers weaponized to take on his
      enemies,” immediately followed by Plaintiff’s image, which was shown simultaneously
      with the statement “Whatever shit goes on with us, we do what’s necessary.”
      IV. Defendants played a clip of Plaintiff laughing while a voiceover states, “Makes one
      immediately think about what the Nazis were doing, where they carried out horrific
      experiments under the guise of great medical experiments. This is completely,
      unconscionable, illegal activity, even if this were in a medical institution, and of course,
      it wasn’t. In my opinion, one of the most horrific things I’ve ever heard of, and I’ve been
      studying cults for 30 years.”
      V. Defendants spliced footage of Plaintiff and Raniere to make it appear as though Plaintiff
      was receiving orders from Raniere to kill someone, including the following statements:
      “You can understand killing when you feel it is necessary. So here you have these
      women… and let’s suppose these women are representative of a gang that is killing your
      family… and that you feel that if you don’t do this, your family is going to die or people
      you know are going to die. So, you feel they must die. Whatever I ask you to do, don’t
      worry about whether it is illegal, it’s criminal, it’s unethical, because our goal is to
      improve the world and as long as that’s our stated goal, whatever I ask you to do is
      justified.”
      70. Defendants’ statement created by intentionally manipulating segments of NIXVM
      footage containing Plaintiff’s likeness cannot be reasonably construed or interpreted as opinion, or
      hyperbole. Defendants’ statements using such manipulated footage were assertions of fact.
      71. Defendants’ statements were false and known by Defendants to be such, in that
      Defendants had to manufacture such statements by splicing together out-of-context footage to create
      statements about Plaintiff that are defamatory.
      72. Plaintiff is not dangerous or violent, has never been dangerous or violent, does not
      condone sexual violence against women, and has not, in any way, been brainwashed. As such,
      Defendants’ statements were made with actual malice in that Defendants had knowledge of the
      falsity of the statements.
      73. Further, Defendants recklessly disregarded the falsity thereof by creating such
      statements themselves to appease Defendants’ narrative. When Defendants made the statements
      above, they knew or should have known that the statements pertaining to the Plaintiff were false.
      74. When Defendants made the statements above, they acted in an intentionally reckless
      manner without appropriate consideration for the standards for information gathering and
      dissemination ordinarily followed by responsible parties.
      75. Defendants’ statements were not privileged, as the statements were not published in
      the kind of circumstances in which absolute protection applies, or in which it was necessary or
      appropriate to make those communications subject to a qualified privilege.
      76. Defendants’ statements about Plaintiff are not about matters of public interest as
      Defendants’ manufactured the statements themselves.
      77. Defendants’ statements were defamatory per se in that the statements epithetically,
      impliedly, and falsely accused Plaintiff of the serious crimes of abuse and assault.
      78. Defendants’ statements were defamatory per se in that the statements epithetically,
      impliedly, and falsely accused Plaintiff of sexual immorality, and sexual misconduct against
      women.
      79. Defendants’ statements were defamatory per se in that the statements resalted in
      Plaintiff’s shame, hurt feelings, and mortification.
      80. Defendants’ false statements were a substantial factor in causing Plaintiff to suffer
      contempt, aversion, and hatred. Plaintiff’s reputation has been irreparably damaged as the result of
      Defendants’ defamatory statements. Further, Plaintiff has and continues to endure emotional pain
      and suffering as the result of Defendants’ defamatory statements as well as financial and career
      damages.
      81. Plaintiff is further entitled to actual damages, compensatory damages, and punitive
      damages for Defendants’ malicious, and intentional defamatory statements, as Plaintiff has been
      damaged in an amount to be determined at trial.
      82. Defendants’ conduct was willful, wanton, and malicious such that punitive damages
      should be awarded.
      AS TO THE SECOND CAUSE OF ACTION
      (DEFAMATION BY IMPLICATION)
      83. Plaintiff repeats and re-alleges each and every allegation above as if fully
      set forth herein.
      84. Defendants, without Plaintiff’s prior knowledge or consent, through use of edited
      video and audio clips, voice-overs, written content, and statements taken out of context in the series,
      have communicated to millions of people that Plaintiff is brainwashed and dangerous, has been
      trained to kill, is capable of killing himself if told to, and condones sexual violence against women.
      Defendants equate Plaintiff to the likening of a rapist, an ISIS and Al Qaeda terrorist in training, a
      Nazi experimenter, and a potential murderer on command.
      85. Plaintiff’s interpretation of Defendants’ statements as noted herein is reasonable, and
      is clearly the only reasonable interpretation that can be drawn from Defendants’ statements.
      86. Defendants’ implications are neither true nor substantially true in that Plaintiff is not
      dangerous or violent, is not brainwashed, has never been dangerous or violent, does not condone
      sexual violence against women, does not harbor behavior comparable to a member of ISIS or AlQaeda terrorist organization. Further, Plaintiff is of Jewish descent, and has relatives were murdered
      by Nazis during the holocaust. As such, Defendants’ insinuation that Plaintiff participated in Nazilike experiments is extremely repugnant.
      87. Defendants’ implications regarding Plaintiff are not matters of public interest
      because Defendants created said statements themselves.
      88. The fact that Defendants had to splice together footage and present it out of context
      to create statements about Plaintiff that are defamatory is evidence that Defendants’ statements were
      made with actual malice in that Defendants had knowledge of the falsity of the statements, and
      recklessly disregarded their falsity. As such, Defendants’ statements, as published about Plaintiff,
      are defamatory by implication.
      89. Defendants not only broadcast the Seduced series on the STARZ television
      streaming platform, but also provided the series for publication to other major television streaming
      platforms, including Hulu, YouTube TV, Sling TV, Amazon Prime Video, Google Play Moves and
      TV, Apple TV, Vudu, all of which have a combined viewership of several million subscribers, with
      175 million viewers subscribed to Amazon Prime alone specifically to watch series and movies.6
      Thus on information and belief, Defendants published their defamatory content about Plaintiff to
      millions of people in the United States and worldwide.
      90. Plaintiff’s friends, family, colleagues, neighbors, acquaintances, and a significant
      number of the members of the general public saw the series portray Plaintiff in a degrading,
      embarrassing, and scandalous manner.

      __________________________________________________

      6 Amazon provided hard data related to Prime subscribers watching TV shows and movies on the platform. See Adam Epstein,
      Amazon’s streaming audience is almost as big as Nexflix’s, QUARTZ, https://qz.com/2003812/amazon-prime-has-almost-as-manystreaming-subscribers-as-netflix/ (Apr. 30, 2021).

      91. Defendants’ conduct harmed, and continues to harm, Plaintiff’s reputation by
      lowering his estimation in the community, as well as among friends, family, colleagues, neighbors,
      acquaintances, and millions of members of the general public.
      92. As a direct and proximate result of the Defendants’ filming, editing, production, and
      broadcast, Plaintiff has been and continues to be exposed to public contempt, ridicule, and threat of
      harm.
      93. Further, as a direct and proximate result of the filming, editing, production, and
      broadcast, Plaintiff has suffered, and continues to suffer, emotional distress, mental anguish,
      symptoms of anxiety and depression, humiliation, insomnia, social stigma, loss of reputation, and
      other physical and psychological harm.
      94. As a direct and proximate result of the Defendants’ conduct, Plaintiff sustained
      tremendous damages, including, without limitation, emotional distress, and other direct and
      consequential damages.
      95. As a direct and proximate result of the Defendants’ conduct, Plaintiff is entitled to
      damages in an amount to be determined at trial, plus prejudgment interest, attorneys’ fees, expenses,
      costs, and disbursements.
      96. Further, Defendant’s conduct was reckless and intentional such that an award of
      punitive damages is proper, the amount of which is to be determined by a jury at the time of trial.
      AS TO THE THIRD CAUSE OF ACTION
      (APPROPRIATION OF NAME OR LIKENESS)
      97. Plaintiff repeats and re-alleges each and every allegation above as if fully set forth
      herein.
      98. Without Plaintiff’s prior knowledge, Defendants included in their series multiple
      images of Plaintiff, along with his full name, and caused these images of Plaintiff to be broadcast to
      millions of people worldwide.
      99. Plaintiff did not consent to Defendants’ use of his likeness or his name for any
      purpose.
      100. Defendants spliced together out-of-context footage in order to create statements
      about Plaintiff that are defamatory in that Defendants insinuate that Plaintiff is dangerous, has been
      trained to kill, is capable of killing himself if told to, and condones sexual violence against women.
      Defendants equate Plaintiff to a rapist, an ISIS and Al-Qaeda terrorist in training, a Nazi
      experimenter, and a potential murderer at direction of Raniere.
      101. Defendants gained commercial benefit from using Plaintiff’s likeness in the
      production of the Seduced series, including pecuniary benefits for publishing the series on the
      STARZ network and its platforms, as well as pecuniary benefit resulting from Defendants’
      dissemination of the series for publication to other major television streaming platforms including
      Hulu, YouTube TV, Sling TV, Amazon Prime Video, Google Play Moves and TV, Apple TV,
      Vudu, all of which have a combined viewership of several millions of subscribers.
      102. Plaintiff was harmed by the publication as noted herein. Plaintiff’s friends, family,
      colleagues, neighbors, acquaintances, and a significant number of the members of the public saw
      the series portray Plaintiff in a degrading, embarrassing, and scandalous manner. As such, the
      filming, editing, production, and broadcast of the series prejudices Plaintiff in the eyes of a
      substantial and respectable segment of the community.
      103. Defendants’ conduct has harmed, and continues to harm, Plaintiff’s reputation by
      lowering his estimation in the community, as well as among friends, family, colleagues, neighbors,
      acquaintances, and millions of members of the general public.
      104. As a direct and proximate result of the Defendants’ conduct, Plaintiff has been and
      continues to be exposed to public hatred, ridicule, and threat of harm.
      105. As a direct and proximate result of Defendants’ conduct. Plaintiff has suffered, and
      continues to suffer, emotional distress, mental anguish, symptoms of anxiety and depression,
      humiliation, insomnia, social stigma, loss of reputation and other physical and psychological harm.
      106. As a direct and proximate result of Defendants’ conduct, Plaintiff has sustained
      tremendous damages, including, without limitation, emotional distress and other direct and
      consequential damages.
      107. As a result of the foregoing, Plaintiff is entitled to damages in an amount to be
      determined at trial, plus prejudgment interest, attorneys’ fees, expenses, costs, and disbursements.
      108. Further, Defendant’s conduct was reckless and intentional such that an award of
      punitive damages is proper, the amount to be determined by a jury at the time of trial.
      AS TO THE FOURTH CAUSE OF ACTION
      (FALSE LIGHT)
      109. Plaintiff repeats and re-alleges each and every allegation above as if fully set forth
      herein.
      110. Defendants, without Plaintiff’s prior knowledge or consent, included in their
      television series multiple images of Plaintiff, along with his full name, and caused these images of
      Plaintiff to be broadcast to millions of people worldwide
      111. Defendants’ publication falsely and reasonably offensively portrays Plaintiff as a
      dangerous, brainwashed, and trained killer, who will kill on command, who condones sexual
      misconduct and violence against women, and whose conduct is akin to that of a member of ISIS and
      Al Qaeda, and the Nazis.
      112. Defendants knew that the disclosure of the information in their statements would
      create a false impression of Plaintiff because Defendants created the statements themselves by
      splice footage to achieve a false narrative of Plaintiff.
      113. The fact that Defendants had to splice footage together to achieve the false narrative
      of Plaintiff is evidence that Defendants’ statements were made with actual malice in that
      Defendants had knowledge of the falsity of the statements, and recklessly disregarded the falsity
      thereof by creating such statements themselves to satisfy Defendants’ narrative.
      114. The fact that Defendants had to splice footage to achieve the narrative above shows
      that Defendants acted intentionally, recklessly, and without appropriate consideration for the
      standards for information gathering and dissemination ordinarily followed by responsible parties.
      115. Defendants’ statements portray Plaintiff publicly in a false light in that Plaintiff is
      not dangerous or violent, is not brainwashed, has never been dangerous or violent, does not condone
      violence or sexual violence against women, does not harbor any behavior that is comparable to a
      member of ISIS or Al-Qaeda terrorist organizations. Further, Plaintiff is of Jewish descent, and his
      relatives were murdered by Nazis during the holocaust. As such, Defendants’ insinuation that
      Plaintiff participated in Nazi-like experiments is tremendously repugnant.
      116. As a direct and proximate result of the Defendants’ filming, editing, production, and
      broadcast, Plaintiff has been and continues to be exposed to public hatred, ridicule, and threat of
      harm.
      117. Additionally, as a direct and proximate result of the filming, editing, production, and
      broadcast, Plaintiff has suffered, and continues to suffer, emotional distress, mental anguish,
      symptoms of anxiety and depression, humiliation, insomnia, social stigma, loss of reputation and
      other physical and psychological harm.
      118. As a result of the foregoing, Plaintiff is entitled to damages in an amount to be
      determined at trial, plus prejudgment interest, attorneys’ fees, expenses, costs, and disbursements.
      119. Further, because Defendants’ conduct was reckless and intentional, an award of
      punitive damages is proper, the amount of which is to be determined by a jury at the time of trial.
      AS TO THE FIFTH CAUSE OF ACTION
      (INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)
      120. Plaintiff repeats and re-alleges each and every allegation above as if fully set forth
      herein.
      121. Based on the facts and circumstances noted above, Defendants intentionally inflicted
      emotional harm by communicating defamatory content about Plaintiff through a television series
      watched by millions of people, including Plaintiff.
      122. Defendant’s actions were so outrageous as to go beyond all possible bounds of
      decency, and are utterly intolerable in a civilized community in that Defendants intentionally
      broadcast Plaintiff’s name, image, and likeness while communicating that Plaintiff is brainwashed,
      dangerous, trained to kill, capable of killing himself if told to, and condones sexual violence against
      women. Additionally, Defendants equate Plaintiff to a rapist, an ISIS and Al-Qaeda terrorist in
      training, a Nazi experimenter, and a potential murderer.
      123. Defendants blindsided Plaintiff with the broadcast, communication, and
      dissemination of knowingly false allegations, as Defendants’ themselves created the statements.
      124. In publishing and disseminating false, defamatory statements about Plaintiff as noted
      above, Defendants acted with an intent to cause, and with reckless disregard of the substantial
      probability of causing Plaintiff severe emotional distress; it was foreseeable that Defendants’
      publication of knowingly false statements about the Plaintiff as noted above would cause Plaintiff
      severe emotional distress.
      125. Defendants’ actions did cause Plaintiff severe emotional distress, mental anguish,
      symptoms of anxiety and depression, humiliation, insomnia, social stigma, loss of reputation, and
      other physical and psychological harm.
      126. As the direct and proximate result of Defendants’ conduct, Plaintiff’s health has
      suffered, as he suffers from symptoms of anxiety and depression.
      127. As a direct and proximate result of the above conduct, Plaintiff sustained tremendous
      damages, including but not limited to emotional distress and other direct and consequential
      damages.
      128. As a result of the foregoing, Plaintiff is entitled to damages in an amount to be
      determined at trial, plus prejudgment interest, attorneys’ fees, expenses, costs, and disbursements.
      129. Further, Defendant’s conduct was reckless or intentional such that an award of
      punitive damages is proper, the amount to be determined by a jury at the time of trial.
      DEMAND FOR JURY TRIAL
      130. Pursuant to the Seventh Amendment of the United States constitution, and Federal
      Rule of Civil Procedure 38, subdivision (b), Plaintiff hereby exercises his right to a trial by jury, and
      demands said right herein.
      PRAYER FOR RELIEF
      AS TO THE FIRST CAUSE OF ACTION
      (DEFAMATION PER SE)
      131. For injunctive relief precluding further defamatory statements against Plaintiff by
      Defendants and all of their agents.
      132. For a Judicial finding that Defendants libeled and defamed Plaintiff through the
      filming, editing, production, and broadcast of their television series “Seduced.”
      133. For a Judicial finding that Defendants defamatory statements were communicated
      with actual malice and intent.
      134. For a judicial finding that Defendants’ statements about Plaintiff are not matters of
      public interest and concern.
      135. For a Judicial finding that Defendants’ publication and dissemination of the
      defamatory statements were grossly irresponsible and without due consideration for the standards of
      information gathering and dissemination ordinarily followed by responsible parties.
      136. A judgment awarding plaintiff damages in an amount to be determined at trial but in
      no event no less than $3,000,000, plus interest, attorney’s fees, expenses, costs, and disbursements,
      as described below:
      a) Judgment for Plaintiff of per se damages in an amount to be determined at trial, but
      in no event less than the amount of five hundred thousand dollars ($500,000).
      b) Judgment for Plaintiff of actual and compensatory damages in an amount to be
      determined at trial, but in no event less than the amount of five hundred thousand
      dollars ($500,000).
      c) Judgment for Plaintiff of punitive damages in an amount to be determined at trial,
      but in no event less than the amount of two million dollars ($2,000,000).
      137. For judgment for Plaintiff’s attorneys’ fees as against Defendants, in an amount to be
      determined at trial.
      AS TO THE SECOND CAUSE OF ACTION
      (DEFAMATION BY IMPLICATION)
      138. For injunctive relief precluding further defamatory statements against Plaintiff by
      Defendants and all of their agents.
      139. For a Judicial finding that Defendants libeled and defamed Plaintiff through the
      filming, editing, production, and broadcast of their television series “Seduced.”
      140. For a Judicial finding that Defendants’ defamatory statements were communicated
      with actual malice and intent.
      141. For a Judicial finding that Plaintiff’s interpretation of Defendants defamatory
      statements is reasonable under the circumstances deduced herein.
      142. For a judicial finding that Defendants’ statements about Plaintiff cannot be
      reasonably construed or interpreted as opinion, or hyperbole, but were assertions of fact.
      143. For a Judicial finding that Defendants’ publication and dissemination of the
      defamatory statements were grossly irresponsible and without due consideration for the standards of
      information gathering and dissemination ordinarily followed by responsible parties.
      144. A judgment awarding plaintiff damages in an amount to be determined at trial but in
      no event no less than $3,000,000, plus interest, attorney’s fees, expenses, costs, and disbursements,
      as described below:
      a) Judgment for Plaintiff of per se damages in an amount to be determined at trial, but
      in no event less than the amount of five hundred thousand dollars ($500,000).
      b) Judgment for Plaintiff of actual and compensatory damages in an amount to be
      determined at trial, but in no event less than the amount of five hundred thousand
      dollars ($500,000).
      c) Judgment for Plaintiff of punitive damages in an amount to be determined at trial,
      but in no event less than the amount of two million dollars ($2,000,000).
      145. For judgment for Plaintiff’s attorneys’ fees as against Defendants, in an amount to be
      determined at trial.
      AS TO THE THIRD CAUSE OF ACTION
      (APPROPRIATION OF NAME OR LIKENESS)
      146. For a judicial Finding, that Defendants used of Plaintiff’s name and likeness.
      147. For a judicial finding that Defendants gained a commercial benefit from the use of
      Plaintiff’s name and likeness.
      148. For Judgment for Plaintiff in the amount of Defendants’ profits that are attributed to
      the use of Plaintiff’s name and likeness, to be determined at trial but in no event no less than one
      quarter of all Defendants’ profits derived from the direct publication of the Seduced series on any of
      Defendants’ STARZ network platforms, and any of Defendants’ subsidiary networks.
      149. For Judgment for Plaintiff in the amount of Defendants’ profits that are attributed to
      the use of Plaintiff’s name and likeness, to be determined at trial but in no event no less than onequarter of all Defendants’ profits derived from the direct or indirect publication of the Seduced
      series on any streaming platform including but not limited to Hulu, YouTube TV, Sling TV,
      Amazon Prime Video, Google Play Moves and TV, Apple TV, Vudu, or any television network
      authorized by Defendants to publish the series.
      150. For Judgment for Plaintiff for punitive damages in an amount to be determined at
      trial, but in no event less than the amount of two million dollars ($2,000,000).
      151. For judgment for Plaintiff’s attorneys’ fees as against Defendants, in an amount to be
      determined at trial.
      AS TO THE FOURTH CAUSE OF ACTION
      (FALSE LIGHT)
      152. For a judicial finding that Defendants’ defamatory conduct placing Plaintiff in false
      light was done with actual malice and intent.
      153. For a judicial finding that there is clear and convincing evidence that Defendants
      knew that their publications would create a false impression about plaintiff.
      154. For a judicial finding that the false light about Plaintiff created by Defendants’
      statements is highly offensive to a reasonable person.
      155. For a judgment for Plaintiff awarding him damages in an amount to be determined at
      trial, including, without limitation, damages to physical well-being, emotional and psychological
      damages, damages to reputation, plus prejudgment interest.
      156. For Judgment for Plaintiff of punitive damages in an amount to be determined at
      trial, but in no event less than the amount of two million dollars ($2,000,000).
      157. Judgment for attorneys’ fees as against Defendants, in an amount, to be determined
      at trial.

      AS TO THE FIFTH CAUSE OF ACTION
      (INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)
      158. For a judicial finding that Defendants’ defamatory statements were extreme and
      outrageous.
      159. For a Judicial finding that Defendants’ defamatory statements were communicated
      with reckless disregard of the probability that Plaintiff if exposed to such statements would suffer
      emotional distress.
      160. For a judgment for Plaintiff awarding him damages in an amount to be determined at
      trial, including, without limitation, damages to physical well-being, emotional and psychological
      damages, damages to reputation, plus prejudgment interest.
      161. For Judgment for Plaintiff of punitive damages in an amount to be determined at
      trial, but in no event less than the amount of two million dollars ($2,000,000).
      162. Judgment for attorneys’ fees as against Defendants, in an amount, to be determined
      at trial.
      163. Further, Plaintiff prays for any other further relief as the court deems just and proper.
      Dated: October 15, 2021

      Respectfully submitted,
      /s/ Joseph M. Tully____________
      Joseph M. Tully, CASBN 201187
      Tully & Weiss Attorneys at Law
      713 Main Street
      Martinez, CA 94553
      Telephone: (925) 229-9700
      Fax: (925) 231-7754
      Email: Joseph@Tully-Weiss.com

  • Yes, free speech….

    Trouble with the Constitution, as the word itself suggests, is that it’s rigid, fixed, immutable. That’s fine if you want something protected forever, something sacred that should never be compromised. Societies, change over time, values and culture changes, and sometimes it emerges that a Constitution devised by a bunch of guys in wigs and gowns fleeing religious persecution and imperial oppression maybe needs to be tweaked a little from time to time.

    Of course the right to bear arms was an important consideration too in its day. In frontier towns without laws where criminals were numerous and law enforcement scant, non-existent, or corrupt, a gun was a useful way to protect yourself and your family. A gun. Usually a small handgun, or possibly a shotgun / rifle. It could be used to kill animals for food too at a time there were no supermarkets or refrigeration. Fast forward to the last 10-15 years where 18-year-old incels wearing body armour take a quick break from 4Chan to go shoot up a load of kids and their teachers with an AR-15 automatic assault rifle. Not quite what the founding fathers had in mind, but as I said, it’s in the Constitution and hard to change, especially in a bipartisan country split down the middle.

    But let’s get back to “free speech”, something so cherished by the right, and particularly the alt-right. Why? Just ask Alex Jones, the gun toting piece of shit who loved to lie about parents being actors who lost their kids in what must be the worst possible way anyone could lose their kids – an Elementary school massacre in Sandy Hook. And he has the audacity to disseminate mendacious BS of the worst kind through his well-resourced social media platforms using the first amendment to protect the second. Wow! And that’s free speech??? And that right is worth protecting???

    Of course, as I’ve said before, we now live in a world of social media where truth is sacrificed at the altar of algorithms ensuring massive profits to giant corporations. Lack of proper regulation means our new rulers can absolve themselves of all responsibility. “Nothing to do with us”, they say. “It’s just free speech – folks should be allowed to say whatever they want in a free world!” And let’s be honest, this at a time when those same organisations know exactly how easy it is for well resourced people to manipulate others. We think we’re clever as a species. The truth is, as Daniel Kahneman and others have pointed out, we share many of our cognitive biases with apes and monkeys; why do you think it was so easy for Raniere and others like him to manipulate their prey? The same goes for people with extremist religious and political beliefs and ideologies.

    So to get back to the point, it’s not often I agree with Kevin, but on this occasion he/she has a point. I haven’t seen the documentary yet, but from what I’ve heard it sounds like a poorly produced load of shit. If what Kevin says is true, then whatever the laws of the state, I believe it’s morally wrong to deliberately take what someone has said out of context and attribute it to an altogether different context. To me that is defamatory and contrary to journalistic integrity.

    Free speech should not extend to allowing hate speech or deliberately spreading disinformation for nefarious purposes. If you knowingly slander or libel someone, you should be held accountable whatever the platform is, and likewise social media companies should share in that liability too. What we do need to protect though, now more than ever, is the right of honest journalists with integrity to investigate and report on the serious stuff that each and everyone of us should know about. That’s how democracy works; it’s what the alt-right calls fake news and wants to clamp down on!

    • —I haven’t seen the documentary yet, but from what I’ve heard it sounds like a poorly produced load of shit.

      Wow Peter! That’s a qualified opinion! “From what you heard,” from Kevin. Kevin is a reliable source of information. He’s a ‘bottomless well’ of information on restraining orders and Allison Mack. According to Kevin Allison Mack doesn’t recycle or line her trash cans.
      “It was so incredible disgusting, but my love required me to sift her garbage. Now, I simply send Allison dozens of postcards every day.”
      -Kevin (Thomas Sekera,)

      • Since we’re really starting to pile on the dirt, Allison also would occasionally throw away leftover food. This shocking revalation, and Allison not tipping her hairdresser double during the Christmas season of 2003, will be covered extensively in season 3 of The Vow.

      • No, not just Kevin. I’ve read quite a lot of negative comments. The positive ones don’t come across as that convincing either.

      • Yes Alanzo, but to what degree? These days they’re barely able to agree on a government budget.

        Where do you stand on abortion and gun control? The former should be in the constitution whereas the latter should not.

      • Fact:
        Alanzo is the second best French kisser in the world, right after his grandma…

        …. Or so his uncle Ross claims. Mmmh!

        • You were always an active, phallic woman, an intellectual virago with a fire of your own. I appreciate your comments.

          • Self-denial can lock women into a smug and critical condescension to other, less devout women. But in your ex’s case, it was not self-denial – it was self-preservation. Hope that answers your question.

    • “ ‘free speech’, something so cherished by the right, and particularly the alt-right. Why? Just ask Alex Jones, the gun toting piece of shit”

      Freedom of speech has traditionally been a right friendly to liberal causes. The Free Speech movement of the 60’s that began in the Berkeley campus (important to the opposition to the Vietnam War). Universities used to regulate and limit student’s political speech, arguing it enabled ‘troublemakers’. The Berkeley Free Speech protests, which spread nationwide, put an end to that.

      Liberal Anti war activists during the First World War were prosecuted for expressing their opposition to that futile bloody war. They appealed all the way to the Supreme Court, where they lost. That was the where the infamous “Like shouting ‘Fire!’ in a crowded theater” analogy was born.

      Conservatives have historically opposed the right to free speech.

      Arguing to legalize access to contraception was criminalized. People were jailed for handing out leaflets.

      People were jailed for protesting in favor of women’s right to vote.

      People were persecuted for speaking out in favor of legalizing cannabis. For gay rights.

      Freedom of speech has been essential to get liberal causes heard. To change minds and attitudes. Freedom of speech is essential for progress.

      Freedom of speech is necessary in a democracy. It is a fundamental human right.

      Yet it’s a freedom that’s not an easy sell. Everyone’s initial impulse is to prevent the other guy from talking. His ideas are crazy! What he’s saying is harmful, it’s misinformation! It’s ridiculous!

      When you think that, remember that all those things were said when someone first came out arguing in favor of gay marriage.

      Problem with limiting free expression – censorship – is, who gets to decide? I found it bizarre that Leftists began calling for censorship during the Trump administration.

      It’s the people in power who always get to decide whose speech is allowed and whose is not. That’s the main reason against restricting free expression.

      Nobody has argued in favor of this right better than the 19th century philosopher John Stuart Mill. How strange that he was more liberal than many liberals in the 21st century. I encourage anyone to read Mill if they have doubts about free speech.

      • Big fan of JS Mill and the various progressive movements you describe.

        My main point is that the notion of free speech has recently been hijacked by the extreme right and big business social media companies to allow hate speech and deliberate disinformation campaigns that undermine legitimate social discourse. Not even Aldous Huxley or George Orwell could have imagined anything like the current state of our dystopian world.

        Of course you are right: there has never been a time when free speech has reigned supreme in any society. In many it is not even regarded as something we should even aspire to. I certainly don’t agree with censorship of any kind, but anyone exercising free speech should not do so in a way that encourages hatred to defined groups or individuals without proper and provable justification.

        And of course it’s essential in any democracy: how can people come to a decision if they don’t hear the facts and the arguments? And it’s the former we must agree on. Someone once said that opinions are free but facts are sacred, or something like that. The Trumpists now talk about ‘alternative facts’, which of course is oxymoronic. The Big Lie (the ‘stolen election’ is now something that a majority of Republican voters believe. Was it Stalin who said if you tell a lie often enough, people are going to start believing it. 80% of Russians still believe they’re winning the war (sorry, limited military operation) in Ukraine.

        What I remember during the Trump administration is ‘the President’ and his various press secretaries repeatedly accuse the MSM of spreading “fake news”. It’s kind of ironic that when DT and his entourage use this term it’s almost certain that the fake news is factual. I wasn’t aware Leftists were calling for censorship during Trump’s administration, but if they were it was probably because he and his cohorts were actively spreading lies and disinformation – remember hydroxychloroquine and injecting bleach during Covid? Meanwhile his core were urging people not to get vaccinated because it would either poison them or allow the authorities to implant tracker chips!

        All I’m saying is that yes, freedom of speech is of course essential and must be protected, but also it comes with responsibility and should not be abused. To that end, as with all rights, there needs to be regulation in place to ensure that. The difficulty is of course getting lawmakers to agree on what that regulation should be at a time when they don’t seem able to agree on very much at all.

    • It is not about what Kevin thinks. It is about the debate of ideas. Raniere makes a perfectly reprehensible statement. Seduced shows Elliot responding to something else as if he is responding to the reprehensible statement. Is that honest?

      • It’s absolutely acceptable because Mark was an enthusiastic follower of Keith the vanguard.

        If he has footage of himself objecting to all the things that Keith said about raping babies and lowering the age of consent and that women like being raped and that children are perfectly fine being molested then Mark Elliott should post that footage of himself objecting to the teachings.

        Mark Elliott doesn’t have such footage because Mark Elliot was 100% a follower of Keith. And bought whole cloth into all of this absolutely offensive misogynistic and child predatory rhetoric. If a person belongs to a church and they frequently hold sermons that are homophobic or racist and the person who is very much an active church member is shown attending services and supporting various statements it doesn’t matter if you have the exact statements lined up with the support the overall truth is that the person is a supporter of the beliefs of the church. Or they wouldn’t belong to the church. And they wouldn’t actively be seeking to enroll people into the church.

        Mark Elliott was a supporter of believer and a teacher who gave lectures on his own free time trying to enroll people into ESP. There is nothing nefarious in Stars portrayal of Mark Elliott

        • Mark Vicente, Sarah Edmondson and India Oxenberg were also supporters of KR. All three held higher positions than Marc Elliot, and in Sarah and Vicente’s case, much, much higher positions. India was considered a co-conspirator at one point.

          So what would happen if we held those three to the same standard you’re holding Marc Elliot to?

          • What are you even talking about? This is about the starz civil lawsuit. Which Elliot instigated.

            It’s not a Tit for Tat analogy as you try to make everything out to be.

            Marc Elliot is a robust follower of Keith Raniere. To this day. Footage of Elliott participating in a passionate way to show support for the teachings of this cult leader are a true and accurate portrayal.

            Keith is Marc’s vanguard. Marc is still trying to persuade people to follow his “genius” federally convicted and imprisoned cult leader.

            Baby blow jobs, woman orgasming for the first time during rape, children loving incest, fish holes, all women are parasites but Asian women slightly less so and so much more. Marc Elliot was all in.

            Maybe when Elliot goes to court he could use the opportunity to stand up and publicly disavow in detail all of these utterly horrible things that Keith said and did? If Elliot truly cares about his reputation and wants to clear up any misunderstanding about his belief system he has an opportunity. It would be public record. But it’s doubtful that he’s going to criticize Keith and all the things he said and did.

            Marc certainly hadn’t done that at the time the documentary was made. Seems like a fair and accurate portrayal of things that Marc Elliott probably believed in quite strongly. Or Marc would not still follow Keith even now.

            This wasn’t just showing footage of Marc Elliott gaga gushing over the experience in the moment, those are actual testimonials that Mark Elliott chose to participate in and to promote the teachings of Keith and ESP..

            Since that time, Marc has only doubled down on his support and belief in both the ESP/Nxivm teachings and Keith.

            How is it damaging to a person’s reputation If the filmmaker usjust showing what the person themselves enthusiastically endorses to be true, as their opinion?

          • Kevin-

            Why should anything happen?

            “The world doesn’t function according to Kevin. My sweetie.”
            (Kevin’s Mom)

            Help the DOJ and receive
            leniency, by becoming a government witness. A government wittiness usually gains a level immunity from prosecution.

            I’d expect a 53-year-old man like yourself Mr. Sekera(Kevin) would know a little something about criminal law. Tee he!

            What have you been doing all these years, just stalking people and watching reruns of the television show, “Bewitched?”

          • I have no objection to anyone’s sex life, as long as they don’t practice it in someone’s bushes and frighten the occupants of the house.

            Mr. Tate, can you honestly say you did not observe the Sekera matter, because you were there?

          • Frank,
            —Mr. Tate, can you honestly say you did not observe the Sekera matter, because you were there?

            I moonlight for Uber Eats. Kevin ordered lobster bisque.

            That’s why I was there.

            BTW: He’s a shitty tipper.

          • Sekera was rude, crude, and inappropriate. But you were taken with him the moment you saw him in the bushes.

          • “But you were taken with him the moment you saw him in the bushes.”

            While it’s true I like bush – Kevin needs to trim his hedge.

          • You are like a god, like an immortal one,’ your wife whispered one night in your bed, her naked body covered with sweat golden and glistening in the candlelight. Too bad you happened to be away and didn’t hear her say it or to whom. [Hint -No it was not Scott Johnson.]

      • No, it’s not honest. They shouldn’t have done that. It’s also counterproductive because now you start questioning the authenticity of rest of the docu too.

        If I’m not mistaken Eliot is still on “team Keith”. That’s not a crime but it is more damaging to his public image and credibility then that short clip in Seduced.

          • There was nothing misleading or dishonest about it.

            Marc Elliot is a supporter of a convicted criminal who groomed a thirteen year old, had underage sex with her, and possessed child porn of her on computer devices that belonged to him. Raniere was recorded to have said some particular misogynistic words on a video. The documentary showed how what Marc claimed about a women’s group within NXIVM whose conceptual founder is Raniere was clearly contradictory to what Raniere was preaching to his SOP students.

            If Raniere says such vile things about women in one context while Marc claims the opposite in another context, but both contexts are part of proselytizing NXIVM, then the group is presenting two contradictory viewpoints to audiences and no one else.

            It’s not defamatory to Marc any more so than belonging to a cult whose leader is a convicted criminal and still supporting him.

            I’ve never seen a bunch clowns who can’t see the obvious contradictions.

      • I saw that episode. Two clips were juxtaposed together from different events and times. Nothing in that juxtaposition implied Elliot was specifically responding to a statement Raniere made, and I have no idea why anyone would think so. What it showed was how what Elliot claimed about Jness (this alleged to be beautiful group that taught him how to understand and deal with women in a unique way that he thought had never been done before) significantly contrasted with a clearly misogynistic and disgusting view that Raniere held about women. The point wasn’t to defame Elliot, it was to emphasize a contradiction.

    • Amen anonymous @1:47pm

      Frank. Where’s my censored previous comment? It’s a post or its not. But if you can post Kevin than what’s the hold up? It’s been awhile. Post it as a comment at least, as it was originally intended to be.

      Thanks!

    • Just think about it. The filmmakers went out of their way to manipulate that footage, and to a person who wasn’t a subject of the film and isn’t linked to any wrongdoing.

      What does that mean for the rest of the footage we see in the same series?

      It’s not easy to think about. It’s Food Lion journalism (look it up).

      • It’s indicative of your arrogance that you say just think about it to people often. You operate under the assumption that you’re the only thinking commenter. People have thought about it and they May have a different opinion than yours. That doesn’t mean they’re not thoughtful people. It just means they disagree.

    • I care. What would we relentlessly ridicule or be utterly annoyed by if it weren’t for Kevin ?

      Kevin isn’t a broken anti-anti-cult record like Aloonzo

      I for one am thankfully Kevin is here.

      The world needs more stalkers!

      Crazy people make the world go around!

      Kevin, I sincerely enjoy hearing your perspective!

  • Elite Modeling received a settlement from the BBC — a BBC doc was accused of libel via “unethical editing.” That was in the UK though, not sure how that same case would’ve gone in the U.S.
    Gerald Marie was the main sleazeball investigated in the doc. So I think it’s feasible Marc could have it work out in his favor despite being seen as “one of the bad guys” as I think Kevin said.

About the Author

Frank Parlato is an investigative journalist.

His work has been cited in hundreds of news outlets, like The New York Times, The Daily Mail, VICE News, CBS News, Fox News, New York Post, New York Daily News, Oxygen, Rolling Stone, People Magazine, The Sun, The Times of London, CBS Inside Edition, among many others in all five continents.

His work to expose and take down NXIVM is featured in books like “Captive” by Catherine Oxenberg, “Scarred” by Sarah Edmonson, “The Program” by Toni Natalie, and “NXIVM. La Secta Que Sedujo al Poder en México” by Juan Alberto Vasquez.

Parlato has been prominently featured on HBO’s docuseries “The Vow” and was the lead investigator and coordinating producer for Investigation Discovery’s “The Lost Women of NXIVM.” Parlato was also credited in the Starz docuseries "Seduced" for saving 'slave' women from being branded and escaping the sex-slave cult known as DOS.

Additionally, Parlato’s coverage of the group OneTaste, starting in 2018, helped spark an FBI investigation, which led to indictments of two of its leaders in 2023.

Parlato appeared on the Nancy Grace Show, Beyond the Headlines with Gretchen Carlson, Dr. Oz, American Greed, Dateline NBC, and NBC Nightly News with Lester Holt, where Parlato conducted the first-ever interview with Keith Raniere after his arrest. This was ironic, as many credit Parlato as one of the primary architects of his arrest and the cratering of the cult he founded.

Parlato is a consulting producer and appears in TNT's The Heiress and the Sex Cult, which premiered on May 22, 2022. Most recently, he consulted and appeared on Tubi's "Branded and Brainwashed: Inside NXIVM," which aired January, 2023.

IMDb — Frank Parlato

Contact Frank with tips or for help.
Phone / Text: (305) 783-7083
Email: frankparlato@gmail.com

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