UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action no. 09CV00309

http://familyrightsassociation.com/departments/afra_legal_disclaimer.htm#MONEY

AFRA (the national association) does NOT seek donations or membership fees of any kind. If you want to help Families, we recommend you to contribute your local/state support group. Independent state/ local groups may charge membership fees and/or seek donations. (See NOTE A below)

If you want to help, we recommend you to print large quantities of our Family Survival Info brochure and distribute them widely in your locale to prepare young families for "The Visit"

No Family Rights supporter under the AFRA umbrella charges you for help. You may feel free to help financially, but you are NOT required to do so. (See NOTE A below).

Some of AFRA's member groups may have 501 (c)(3) Non-profit Tax Free status Many do not, and must not represent that donations to them are "Tax Free".

American Family Rights Association does NOT have a 501(c)(3)

And we don't want one because we refuse to have our political activities hand-cuffed.

Here's the IRS Charities & Non-Profits Page

"An IRC Section 501(c)(3) organization may not engage in carrying on propaganda, or otherwise attempting, to influence legislation as a substantial part of its activities."

NOTE A- These lines were inserted in the original statement, in deference to CO-FOUNDER of AFRA Suzanne Shell (See Paragraph 55), because she DID charge for her goods and products, which was a sticky PROBLEM right from the beginning, because Shell's only interest in the Association was to PROMOTE AND ADVERTISE HER OWN NAME, GOODS AND PRODUCTS NATIONALLY TO A "MARKET" she hoped the Association would create for HER.

AFRA did promote Shell's books, websites, and seminars, up until Shell DEMANDED that all mention of her book, website, and seminars be removed from the AFRA website (See Exhibit 1), in RETALIATION for Leonard Henderson's refusal in 2003 to endorse and publish on the AFRA website, Shell's original, pre-AFRA Vendetta List ("Advocate Warning"- Exhibit 7) of her personal enemies later became her bizarre, slanderous and libelous "Bad Advocates" website. Shell felt that I had "shamed and embarrassed her in public" by my opposition to, and refusal to publish that "Advocate Warning".

Leonard Henderson's refusal to endorse and publish that "Advocate Warning" at AFRA is THE ORIGINAL CAUSE of Shell's DISAFFECTION from AFRA and HER SUBSEQUENT BEHAVIOR as an INTERNET TROLL, STALKER, and CYBERBULLY that she has now contrived into this Tinfoil Hat Conspiracy Theory of a "complaint".

Paragraph 3- Leonard Henderson states that the "familyrightsassociation.com" and "oregonfamilyrights.com" website domain names were originally registered with "Network Solutions" by Leonard Henderson in 2002, not by Bill Tower as Shell deceitfully represents. Leonard Henderson paid for the Registrations and hosting fees from his Social Security Disability Checks and now Bill Tower pays for the Registration renewals and hosting fees from HIS Social Security Disability checks.

Leonard Henderson denies that neither AFRA, nor it's principals, nor our members have EVER been a "competitor" of Suzanne Shell or ANYBODY. Bill Tower merely owns and pays for the domain names and hosting costs. Otherwise, there is NOTHING to "own" other than websites that I, the webmaster could make DISAPPEAR in 30 seconds. To argue that "owning" the AFRA website or that "owning" yahoogroups has monetary value- is ABSURD.

Paragraph 4- Leonard Henderson denies Anne Tower is an "agent" of AFRA, as AFRA has NO "agents". Leonard Henderson is unaware of anything Anne Tower has ever "contributed" to AFRA or participated in an AFRA yahoogroup. Leonard Henderson is mystified why Ann Tower is even named.

Paragraph 5- Leonard Henderson states that he was quite ill at the time, but believes that Dennis Hinger was removed due to his egregious behavior. Hinger was also extremely ill and his thought processes apparently deteriorated. Leonard Henderson denies that Hinger was ever an "agent" of AFRA. Henderson denies that AFRA or anybody in AFRA is participating in a "market".

Paragraph 6- Leonard Henderson acknowledges that Shell's statements in this paragraph are unusually accurate, except Leonard Henderson has never been a member of the AFRA Board of Directors.

Paragraph 7- Leonard Henderson does not know if Susan Jackson's address is correct. Leonard Henderson denies that Susan Jackson is an "agent" of AFRA.

Paragraph 8- Leonard Henderson does not know if Cletus Kiefer's address is correct. Leonard Henderson denies that Cletus Kiefer is an "agent" of AFRA. Leonard Henderson does not know (but highly doubts) whether Cletus Kiefer "colluded with and enticed Wiseman dba Wiseman Studios to publish "thetruthistold.com" as alleged.

Paragraph 9- Leonard Henderson states that Rene Cygan's membership in AFRA was removed in approximately 2003 due to her behavior ALLEGED by "double-agent" Kay Henson, which was the very beginning and cause of Suzanne Shell's vendetta against AFRA. Leonard Henderson denies that Rene Cygan was ever an "agent" of AFRA.

Paragraph 10- Leonard Henderson believes that Mark Cygan's membership in AFRA was also removed at about the same time as Rene Cygan's was. Leonard Henderson denies that Mark Cygan was ever an "agent" of AFRA.

Paragraph 11- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraph 11 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations.

Paragraph 12- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraph 12 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations. Leonard Henderson denies that Dorothy Kernaghan-Baez was ever an "agent" of AFRA.

Paragraphs 13-14- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraphs 13-14 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations.

Paragraph 15- Leonard Henderson states that Aimee Dutkewitcz' membership in AFRA was removed after she and Shell got into a raging cat fight on Aimee's NEPAN yahoogroup, which was a continuation of the Internet Troll behavior of Shell. Time frame was about the same as Cygans above. Leonard Henderson denies that Aimee Dutkewitcz was ever an "agent" of AFRA.

Paragraphs 16-17- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraphs 16-17 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations. Leonard Henderson denies that Thomas Dutkewitcz was ever an "agent" of AFRA.

Paragraph 18- Leonard Henderson observes that Billy Wiseman's membership in AFRA groups was apparently discontinued sometime in 2006. Wiseman absolutely operates on his own and I, Leonard Henderson have begged and pleaded with him to take his website down for years. Leonard Henderson strenuously denies that Billy Wiseman is, or ever was "exploited by the defendants to front many of their wrongful acts". Leonard Henderson strenuously denies that Billy Wiseman's website is, or ever was an "unofficial AFRA ad hoc web site". Leonard Henderson observes that Billy Wiseman apparently positions his website as presenting "Anti-Stalking" information about the egregious activities of Suzanne Shell and her colluding actors. Leonard Henderson denies and specifically reiterates that at no time has Billy Wiseman ever been an "agent" for AFRA.

Paragraphs 19-20- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraphs 19-20 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations. Leonard Henderson denies that Ann Durand was ever an "agent" of AFRA.

Paragraph 21- Leonard Henderson states that Brenda Swallow was Suzanne Shell's agent, who joined Suzanne Shell's organization, received Suzanne Shell's training, who turned against Suzanne Shell for whatever reason Leonard Henderson does not recall, or if I ever knew. At that time of Swallow's disaffection from Shell's organization, AFRA Board Member (and Shell "double-agent") Kay Henson gave me the "heads up" and I put Swallow on "Moderated'. Swallow then DID send scathing emails about Shell to the AFRA CenCom yahoogroup, which were captured in the "Moderate" bin, which emails Leonard Henderson happily deleted. Swallow's participation on the AFRA groups was banned because she proceeded to launch a WAR against Shell and intended to utilize the various AFRA yahoogroups to do her flaming. Leonard Henderson specifically denies that Brenda Swallow was ever an "agent" of AFRA.

Paragraph 22- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraph 22 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations. Leonard Henderson denies that Dee Contreras was ever an "agent" of AFRA.

Paragraph 23- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraphs 23 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations. Leonard Henderson denies that Kathy Tilley, was ever an "agent" of AFRA.

Paragraph 24- Leonard Henderson believes that Randal Blair's membership was removed in 2006 due to his involvement in some sort of yahoogroup flame war. Leonard Henderson specifically denies that Randal Blair was ever an "agent" of AFRA.

Paragraphs 25-31- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraphs 25-31 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations.

Paragraphs 32-37- Leonard Henderson does not have sufficient knowledge of the allegations or CLAIMS asserted in paragraphs 32-37 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations or CLAIMS.

Paragraphs 38- 40- To the best of Leonard Henderson's knowledge, only one named AFRA defendant is in Colorado, which Leonard Henderson knows only because of her listing in Shell's "complaint". AFRA otherwise has no current associates in Colorado. AFRA has certainly NOT "maintained systematic and general business contacts" in Colorado, especially not since Shell's pretentious disaffection from AFRA. I am unaware of any "conduct and connection with Colorado are such that they should reasonably anticipate being haled into court" in Colorado.

AFRA has NOT "purposely availed themselves of the privilege of acting in Colorado or of causing important consequences" in Colorado. Plaintiff Shell operates nationally, where she did indeed avail herself of the privilege of acting in number of States, such as Florida, Arizona, and Wisconsin, were Henderson personally helped Plaintiff Shell get out of jail for filming inside the Walworth County Courthouse- which assistance Shell denies happened, due to her inordinate pride. AFRA has committed no tortious acts anywhere, let alone in Colorado.

Paragraph 41- Leonard Henderson believes that None of the alleged events giving rise to Shell's claims occurred in Colorado. The actual location of our involvement and Shell's entire "Tin Foil Hat Conspiracy Theory" arises from is "yahoogroups" on THE INTERNET, where her participation in it was as a TROLL, STALKER, and CYBERBULLY.

Paragraph 42- Leonard Henderson states that AFRA does absolutely no advertising, provides no goods, nor services. AFRA does have several members who are lawyers who offer their professional services, who are listed on our "Legal Page" by their authorization.

Paragraph 43- Leonard Henderson is unaware of any advertising done by Shell at any time. AFRA did promote Shell's books and websites, up until Shell DEMANDED that all mention of her books and websites be removed from the AFRA website (See Exhibit 1), in response to my, Leonard Henderson's refusal in 2003 to endorse and publish on the AFRA website, Shell's original, pre-AFRA vendetta list ("Advocate Warning") which later became the bizarre, slanderous and libelous "Bad Advocates" website. My refusal is THE ORIGINAL CAUSE of Shell's PRETENTIOUS DISAFFECTION from AFRA and THIS continuing Internet Troll behavior by Shell.

Paragraph 44- Leonard Henderson is unaware of any goods or services Shell offers that at any time have every had value to CPS or their contractors.

Paragraph 45- Leonard Henderson is confused what Shell's "market" is. If her "market" is selling books, then the "favored medium" to promote that would be Internet Sites such as Barnes and Noble or Amazon. The term "the Internet" is rather vague and non-specific. The Internet is a system for transportation of digitized data between computers, not a "market".

Paragraph 46- Leonard Henderson, having been a businessman most of his life, is confused by Shell's identification of venues for the advertising and promotion of her "business". Shell's identified advertising by "ownership of and participation with and input to various online groups and forums dedicated to this issue" is called TRAWLING, and it's really in BAD TASTE.

Paragraph 47- Leonard Henderson observes that Shell's appraisal of "goods and services' varying in quality is her subjective and rather self-serving opinion. I am still confused by her repeated use of the word "market". Exactly WHO might be "literally dangerous" is also highly subjective. (Note added not in original - See newspaper article "Beyond Contempt")

Paragraphs 48-50- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraphs 48-50 of Plaintiff’s Complaint to be able to respond.

Paragraph 55- Leonard Henderson agrees that Suzanne Shell was a co-founder of AFRA in 2002. As a co-founder of AFRA, Shell knows perfectly well that AFRA is not a "business" or "enterprise" as she now attempts to contrive. As a CO-FOUNDER, Shell certainly would NOT have participated in the creation of a COMPETITOR. If there are any "deficiencies" in the structure of AFRA, Shell as a CO-FOUNDER is complicit in CREATING those alleged "deficiencies" that she now attempts to fabricate an exploit.

Paragraph 56- Leonard Henderson states that Shell's given excuse for withdrawing from AFRA had nothing whatsoever to do with her alleged "reasons". Shell disaffected from AFRA because Leonard Henderson refused to endorse and publish her personal Vendetta List- "Advocate Warning" (which later became her bizarre, slanderous and libelous "Bad Advocate List") of her chosen enemies going back at to least "Parents March '98" (allegedly ©Suzanne Shell), long before AFRA existed. (Which original names she seems to have long forgotten). AFRA did NO advertising, let alone false advertising. Leonard Henderson states that upon Shell's departure, Shell assisted Plaintiff Henderson in removing everything that Shell had given to AFRA, to her satisfaction and agreement. See Exhibit 1.

Paragraph 57- Leonard Henderson observes that Shell put her materials on her websites into Adobe PDF format files with the password "I agree", which password Shell prominently displays and severely warns that by typing "I agree" the reader is agreeing to her malevolent agreement for use. My quotation of the words from her website, "I agree" here may constitute a violation of Shell's stated copyright.

Paragraph 58- Leonard Henderson does not have sufficient knowledge of the allegations asserted in Paragraph 58 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations. Leonard Henderson does note Shell's assertion that she "withheld releasing any new intellectual property during this time." (See Paragraph 73) Shell also states on her "Improvement Project" yahoogroup in message #4899 on 15, 2008 that-

This group has been in operation for 2 years, now. It hardly seems that long, does it?

During that time, I have refrained from any participation in advocacy or training and withheld my information from dissemination...(Exhibit 11)

So between 2002 and 2005, Shell was a principal in AFRA and after her disaffection, she released nothing new, and REFRAINED from doing advocacy or training. Shell now brings the allegation that AFRA stole her copyrighted materials ON HER WATCH, that she alleges had already been stolen by 2001, before AFRA existed, which she did NOTHING about, released NOTHING new after her disaffection, and claims AFRA prevented her from doing advocacy or seminars, which Shell states SHE REFRAINED FROM DOING. Also see Exhibit 13- "Beyond Contempt" by Alan Prendergast, published on February 10, 2005 in Village Voice Media, wherein we read about Shell's infamy, bad reputation and numerous other contradictions to Shell's claims in this "Complaint".

Paragraph 59- Leonard Henderson notes that so far as he knows, Shell's "certification program" springs from her own self-certification and Shell's term "quality assurance oversight" alludes to her pathological need to be the "boss of the universe". Leonard Henderson does not know what this proclaimed "trade secrets and proprietary information" is, but apparently it's what many of us stumbled upon on our own as a result of own own experiences with the system, massive self-study and learning curve. The knowledge Leonard Henderson utilizes springs from Pamela Gaston's "Sui Juris" research and from Roger Weidner's "Weidner Method", both of which were absolutely and irrefutably independent from Suzanne Shell, whom Gaston and Weidner regarded as a misguided "wanna be" and source of endless trouble. Shell's claim to "extensive and unique information which was not employed by or known to my competitors" is rather ambiguous, amorphous, indeterminate, undefined, unspecified, and contemptuous.

Paragraph 60- Leonard Henderson agrees that if Shell does possess "trade secrets and proprietary information" that there indeed would be a "market" for "training and information products" to people who want to be "family advocates". If Shell's assertion is true, her error is in not understanding how to run, promote, and advertise a BUSINESS. Shell making the claim that everybody is stealing her stuff and fighting with everybody on earth is a poor business model. Shell's assertions ignores the fact that SHE herself is a "non-trained, non-certified, self-professed family advocate".

Paragraph 61- Leonard Henderson observes that Shell's assertion of "advertised" means she put it on her rarely-visited website, which is to this day hardly found by the usual Internet Search criteria people are looking for. Which would be HOW somebody trying to conduct BUSINESS on the internet would be found. Leonard Henderson has just now checked the HTML source code on Shell's http://profane-justice.org website and finds NO "meta tags" directing search engine robots to index her material for searchers. Additionally, had Shell KNOWN anything about robots, she could have directed the robots NOT to index her site, and thus her suit against Internet Archive should NOT have had any merit. Like this "complaint", that complaint was frivolous and vexatious, and Leonard Henderson regrets that court didn't hand her her head over it. Leonard Henderson is rather dumbfounded that Shell claims to "advertise" "via the internet". Shell completely fails to do the learning curve to learn how, but yet sues the Internet Archive for it's robots finding and archiving her website. Which "being found" and indexed by search engines is EXACTLY HOW you promote your website "via the internet". This could be a description of the definition of "schizophrenia".

Paragraph 62- Leonard Henderson does not have sufficient knowledge of the assertions in paragraph 62 of Plaintiff’s Complaint to be able to respond, and therefore, denies such assertions.

Paragraph 63- Leonard Henderson does not know whether her alleged CLE classes were actually accredited anywhere. Leonard Henderson HIGHLY doubts her assertion that her CLE classes were of value to JUDGES. It seems that Shell would supply evidence for her incredible and probably mendacious assertions.

Paragraph 64- Leonard Henderson asserts that AFRA advertises NOTHING. The "oversight" we specify at http://familyrights.us/join/join.html is-

Paragraph 70- Leonard Henderson states that Shell merely alleges she possesses "trade secrets or confidential information" or "proprietary content", which Henderson does not know whether she possesses such or whether she ever actually conducted a BUSINESS. Leonard Henderson denies being a "competitor" of Shell. Leonard Henderson highly questions Shell's assertion that "the defendants, who did not possess such knowledge or information and were not able, legitimately and within a reasonable time frame, to obtain it otherwise" as she does not define the time frame. Since Leonard Henderson does not know Shell's alleged top secret information, Henderson has no basis to compare what he has learned through the years, or had learned from Gastons and Weidner prior to Leonard Henderson knowing Suzanne Shell existed.

Paragraph 71- Leonard Henderson does not know Shell's "trade secrets" or whether she actually possesses such as she asserts. Leonard Henderson denies the allegations in Paragraph 71.

Paragraph 72- Leonard Henderson denies the allegations in Paragraph 72.

Paragraph 73- Leonard Henderson states that in Paragraph 51 of this complaint, Shell claims

a. Shell herein provides the evidence (Attached to her "Complaint"- TXu1-364-413, June 7, 2007) that puts the lie to her continuous denial of owning, or controlling the bizarre, slanderous and libelous content on the "Badadvocates" website and threats to sue anybody who alleged she did. (See Exhibit 2)

Paragraph 95- Leonard Henderson denies the allegations in Paragraph 95. We PROMOTE the works of others, highly credited and linked to the original sources. We have always wanted people to know we weren't making up our case against CPS operations in our own heads, and HIGHLY RECOMMEND people go see the ORIGINAL SOURCES. Additionally, we plainly and prominently display at our About Copyrights page- http://familyrights.us/copyrights/index.html

"In accordance with Title 17 U.S.C. Section 107, any copyrighted work on this website is distributed under fair use without profit or payment for non-profit research and educational purposes only. We ENCOURAGE you to go to the original sources to read the WHOLE STORY. Read all about Copyright & Fair Use at- http://fairuse.stanford.edu/"

See Exhibit 9- Suzanne Shell's Mar 10, 2004 advice to AFRA about "fair use".

Paragraph 96- Leonard Henderson denies that AFRA has ever had such policy or attitude about "anything on the internet is public domain".

Paragraph 97- Leonard Henderson observes that Shell's assertion is rather non-specific who, what, where. Leonard Henderson denies the assertions and allegations in Paragraph 97.

Paragraph 98- Leonard Henderson is unaware of when or who might have provided instructions on copying entire websites, but this information is widely available on the internet.

Paragraph 99- Leonard Henderson states that AFRA most certainly DOES publish HEADLINES and LINKS to prominent news stories on the front page of AFRA and at AFRA News, which we disbelieve that we are required to obtain permission from those sources to PROMOTE public awareness of their stories. Other studies and reports we compile, which have been produced funded by government grants ARE Public Domain, and we carefully and fully give attribution to the author(s). Some of the White Papers and reports, THE AUTHORS ask us to publish. Recently, on November 17, 2008, Oregon CPS worker Rich Rigney ASKED US to publish his white paper ""Child (or agency) Protection? ". On April 10, 2009, we published AT HIS REQUEST, a white paper by William G. White, MSW, LMSW entitled "Keeping It Simple ".

Paragraph 100- Leonard Henderson denies the assertions and allegations in Paragraph 100.

Paragraph 101- Suzanne Shell has been banned from all AFRA yahoogroups because she is arrogant, caustic, insolent, self-aggrandizing. Psychiatrists might describe her as a predatory psychopath - a smart, charming liar with "a preposterously grand superiority complex, a revulsion for authority and an excruciating need for control." Shell meets all the definitions of INTERNET TROLL, STALKER, and CYBERBULLY and does nothing but start flame wars. Only in her own mind does she imagine that we talk about her or her stuff. Shell imagines that the world is all about her, and we couldn't possibly be doing anything but talk about her and plot against her. Psychiatrists have many terms to describe this pathology.

Paragraph 102- Leonard Henderson states that to the best of his knowledge, no "infringements" are occurring. See Exhibit 1

Paragraph 103- Going back through the archives, Leonard Henderson finds for July 31, 2004, I find no such message.

Paragraph 104- Leonard Henderson cannot find any such message at AFRA Cencom or AFRA Talkline as Plaintiff Shell alleges as having originated from T Dutkewitcz.

Paragraphs 105-106 - Leonard Henderson does not know what the detail of this alleged "deal" was, as I was extremely ill at the time. I do recall expressing to Hession the pointlessness of trying to make a "deal" with Shell, as she was implacable, psychotic, irrational, and her allegations were spurious and deceitful. I was terribly disappointed in Hession's resignation over it, when I plainly told him to begin with that trying to "make peace" with Shell was pointless, because she was never anything but a sandbox bully, FLAME WARRIOR, STALKER, and internet TROLL. See Exhibit 3

Paragraph 107- Leonard Henderson appointed William Tower as President of AFRA, because I was a VERY ILL man, completely unable to handle AFRA any longer. At the time, my test for suitability was "If I get better, will you give it back to me?" This question was because of the pervasive existence of self-aggrandizing "wanna-be's" who wanted to "make a big name for themselves", just like Shell, and I had seen plenty of them over the years. Tower said Yes he would.

Paragraph 108- Leonard Henderson cannot find any such thing as Shell alleges occurred on April 25, 2006.

Paragraphs 109-110- Leonard Henderson observes that Shells' reading comprehension isn't so good. Or Shell is a deliberate prevaricator. See Exhibit 4

Paragraph 111- Leonard Henderson states-

a- This message is gone, and it is unknown when. The logs do not find anything about Message #1481. 
I suspect that probably I nuked it at Shell's demand at the time.

b- Leonard Henderson visited http://www.geocities.com/family_rights_wv/?sample_letters.html on February 20, 2009 at 8:37pm PST and find no such document. Leonard Henderson further denies that Christy Amtower is an "agent" of AFRA.

c- I have no idea what this alleged 4th Amendment letter is.

d- I cannot find any such thing as "Letter to Lawyer" on the AFRA website.

e- I have no idea what goes on at the Child Protection Reform yahoogroup, which is not an AFRA group. A Google Search of the entire AFRA website does not produce any such thing as "cha/kwaina" or "chakwaina".

f- I have no knowledge of what Kiefer might have done with a radio show.

g- Leonard Henderson states- I have examined the AFRA Cencom archives for March 14, 2006, beginning with message #11867 and ending with message #11937. All messages occur sequentially with no missing messages. I find Wiseman produced announcements of a Shell Seminar. I find no such thing as copyrighted work.

Message #12016 of 17750
http://groups.yahoo.com/group/AFRA_CenCom/message/12016

Thu Mar 16, 2006 5:11 am
"Gregory A. Hession" <hession@crocker.com>

Shell

No talk. No bash. No mention. No opinion. Either by friend or foe. Suzanne has made it clear that any thought she has put on paper is copyrighted and its repetition will be met with vicious threats of lawsuits. She has also made it clear that anyone expressing opinions about her will be met with vicious attacks. Therefore, no words of hers should be repeated, and no opinions about her should be stated here, by friend or foe. Because even when friend (Kay) does it, others want to comment. So, the rule is NOTHING.

GAH
===============

h- I have no idea what to look for, as Shell's description "verbatim content from an article on my copyrighted website" is rather vague.

i- I have no idea what did or did not happen with Wiseman.

j- I, Henderson have absolutely no idea what Shell is referring to as a "a discrete article and/or document from my web site". I, Henderson, of ALL PEOPLE in the universe have absolutely NO INTEREST WHATSOEVER in publishing anything of Shell's.

k- I have absolutely no idea whether Lisa Smith was an AFRA member or not, what state of the United States she is in, nor do I have any idea what this "entire article from my web site" might be that Shell alludes to.

l- I have searched the AFRA groups, and Google Searched the entire World Wide Web for "hdt.pdf" and find no such thing relating to Family Advocacy anywhere on the earth.

m- No knowledge

n- No knowledge

o- No knowledge

p- This was a dubious claim originating many years ago.

Paragraph 145 - Leonard Henderson cannot imagine what Shell is referring to as "verbatim content from an article on my copyrighted website" and therefore, denies same.

Paragraph 146 - Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraph 146 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations.

Paragraph 147- Leonard Henderson cannot imagine what Shell is referring to as "a discrete article and/or document from my web site" and therefore, denies same.

Paragraph 148-150- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraph 148-150 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations.

Paragraph 151- Leonard Henderson denies the allegations contained in paragraph 151

Paragraph 152 - Leonard Henderson re-denies everything in the preceding paragraphs of this Complaint already denied, and further denies Shell's assertion that she has stated "facts", except those previously assented to by Leonard Henderson.

Paragraph 153- Leonard Henderson denies the allegations contained in paragraph 153.

Paragraphs 154-160 Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraph 154-160 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations.

Paragraph 161- Leonard Henderson re-denies everything in the preceding paragraphs of this Complaint already denied, and further denies Shell's assertion that she has stated "facts", except those previously assented to by Leonard Henderson.

Paragraphs 162-163- Leonard Henderson denies the allegations contained in paragraphs 162-163.

Paragraph 164- Leonard Henderson does not operate or manage an "enterprise", and does not directly or indirectly conduct the affairs of any such "enterprise", particularly not through a pattern of "racketeering activity" and therefore, denies the allegations contained in paragraph 164.

Paragraphs 165-167- Leonard Henderson denies the allegations contained in paragraphs 165-167, whatever they are.

Paragraphs 168-175- Leonard Henderson denies that AFRA is an "Enterprise" by any definition, especially not as a business enterprise. Leonard Henderson denies the allegations contained in paragraphs 168-175.

Paragraph 176- Leonard Henderson re-denies everything in the preceding paragraphs of this Complaint already denied, and further denies Shell's assertion that she has stated "facts", except those previously assented to by Leonard Henderson.

Paragraphs 177-182- Leonard Henderson does not have sufficient knowledge of the allegations asserted in paragraph 177-182 of Plaintiff’s Complaint to be able to respond, and therefore, denies such allegations.

Paragraph 271- See Video "Susan Shell Part 5" at http://www.youtube.com/watch?v=0jpN5HnSzlQ

Paragraphs 272-273- Leonard Henderson denies the allegations contained in paragraphs 272-273.

Paragraph 274- The judges hearing this complaint are qualified to determine whether THIS COMPLAINT is Perjury.

Paragraphs 275-276- The judges hearing this complaint are qualified to determine if these statements are the CRUX of the on-going problem anybody has who has the misfortune to come into contact with Shell.

Paragraphs 277-281- Leonard Henderson denies the allegations contained in paragraphs 277-281.

Paragraph 282- The judges hearing this complaint are qualified to determine if Shell's filing of this COMPLAINT seems to be the work of a "mentally healthy" individual.

Paragraphs 283-284- Leonard Henderson denies the allegations contained in paragraphs 283-284.

Paragraph 285- Leonard Henderson refers to the list of "AFRA's Lawyer Friends" at http://familyrights.us/info/law/ who are listed AT THEIR REQUEST.  Also see "How to Help Your Lawyer" at http://familyrights.us/educate/help_lawyer/

Paragraphs 286-290- Leonard Henderson denies the allegations contained in paragraphs 286-290.

Paragraph 291- Leonard Henderson re-denies everything in the preceding paragraphs of this Complaint already denied, and further denies Shell's assertion that she has stated "facts", except those previously assented to by Leonard Henderson.

Paragraphs 292-316- Leonard Henderson denies the allegations contained in paragraphs 286-316.

Paragraph 317- Leonard Henderson states this is ABSOLUTELY, patently false. Shell was a willing CO-FOUNDER of AFRA. Shell eventually disaffected from AFRA because I, Leonard Henderson refused to endorse and publish her original, pre-AFRA vendetta list, which evolved into her "Bad Advocate List", which soon included ME, Leonard Henderson for refusing to endorse and publish it. Everything that has happened since is her evolving "Tinfoil Hat Conspiracy Theory" that has grown wilder and wilder, until it came to "fruition" as THIS COMPLAINT. Prior to that time, we were PROMOTING AND ADVERTISING HER BUSINESS. To say she was coerced and retaliated against is absurd. (See Exhibit 8) Shell herself is the retaliatory party.

Paragraphs 318-323- Leonard Henderson denies the allegations contained in paragraphs 318-323.

Paragraph 324- I HAVE repeatedly tried to get her bizarre, slanderous and libelous "Bad Advocates List" website taken down. Her webhost has advised me to "get a court order". Hopefully, this court WILL order http://badadvocates.com taken down due to it's bizarre, slanderous and libelous content, which unknown "the editors" claim is "parody" or "entertainment".

Paragraphs 325-327- Leonard Henderson denies the allegations contained in paragraphs 325-327.

Paragraph 328- Leonard Henderson re-denies everything in the preceding paragraphs of this Complaint already denied, and further denies Shell's assertion that she has stated "facts", except those previously assented to by Leonard Henderson.

Paragraphs 329-331- Leonard Henderson denies the allegations contained in paragraphs 329-331

Paragraph 332- Leonard Henderson states that AFRA did not exist before 2002. Which AFRA, Shell was a CO-FOUNDER and participated in AFRA until her final disaffection on or about February 17, 2005 (Exhibit 6) because I, Leonard Henderson refused to endorse and publish her original "Advocate Warning".

Paragraph 333- Leonard Henderson denies the allegations contained in paragraph 333

Paragraph 334- Leonard Henderson cannot decipher what this paragraph says. Therefore, Leonard Henderson denies the allegation or whatever it is in Paragraph 334.

Paragraphs 335-339- Leonard Henderson denies the allegations contained in paragraphs 335-339.

Paragraph 340- Leonard Henderson re-denies everything in the preceding paragraphs of this Complaint already denied, and further denies Shell's assertion that she has stated "facts", except those previously assented to by Leonard Henderson.

Paragraphs 341-342- Leonard Henderson denies the allegations contained in paragraphs 341-342

Paragraphs 343-344- Leonard Henderson affirms these statements, except for the description of "goods and services" and "products". We see the assertion of "free" here in Paragraphs 343-344 contradicting Shell's allegations that we receive "financial gain". Shell herself, being a CO-FOUNDER of AFRA was part of the determination that information should be free. (Note added not in original - See newspaper article "Beyond Contempt"  Shell said she worked for free too.)

Paragraphs 345-350- Leonard Henderson denies the allegations contained in paragraphs 345-350.

1- Order Donna Suzanne Shell to cease and desist harassing, stalking, threatening, defaming me and others in all mediums, by phone, email, postings to her "Family Rights Advocacy IMPROVEMENT Project" yahoogroup and "Bad Advocates" website.

2- Order http://badadvocates.com taken down due to it's bizarre, slanderous and libelous content where I have been portrayed as a pervert, accused of abusing my wife and children, and vile character assassination.

3- Order http://groups.yahoo.com/group/FamilyRightsAdvocacyIMPROVEMENTProject taken down due to it's bizarre, slanderous and libelous content.

4- That the court finds Donna Suzanne Shell as a frivolous and vexatious litigant in light of this complaint, a virtually identical complaint filed against us in November 2008 in California, and virtually identical complaints against others-

Shell v. Devries, No. 06-318, 2007 WL 324592 D. Colo. Jan. 31, 2007, and,

Internet Archive, et al. v. Suzanne Shell, No. 06-cv-01726-LTB-CBS, D. Colo.

5- Bar Donna Suzanne Shell from threatening to, or filing complaints or lawsuits against anybody, anywhere, ever again.

6- Order Donna Suzanne Shell to bear all costs associated with her litigations.

7- To award other relief as the court deems just and equitable.

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