Craig Portwood's response to

James Lloyd's Lawsuit to Keep You From Knowing the Truth

The Answer

Defendant/Counter Plaintiff respectfully answers Plaintiff's/Counter Defendant's complaint as follows:

1.

Defendant/Counter Plaintiff admits the allegations in paragraphs 8, 14(D), 14(E), 14(I), 14(O), 14(U), 14(Y), 14(Z), 14(BB), 14(CC), 21, 22(D), 22(E), 22(I), 22(O), 22(U), 22(Y), and 22(Z), 22(BB), 22(CC), 

2.

Defendant denies the allegations in paragraphs 2, 6, 11, 14(C), 14(F), 14(K), 14(L), 14(N), 14(P), 14(Q), 14(S), 14(T), 14(W), 14(X), 14(AA), 14(DD), 14(EE), 14(FF), 14(GG), 14(HH), 14(II), 14(JJ), 14(KK), 14(MM), 14(NN), 14(OO), 14(PP), 14(QQ), 14(RR), 14(SS), 14(TT), 14(UU), 14(WW), 15, 16, 17, 18, 19, 22(C), 22(F), 22(K), 22(L), 22(N), 22(P), 22(Q), 22(S), 22(T), 22(W), 22(X), 22(AA). 22(DD), 22(EE), 22(FF), 22(GG), 22(HH), 22(II), 22(JJ), 22(KK), 22(MM), 22(NN), 22(OO), 22(PP), 22(QQ), 22(RR), 22(SS), 22(TT), 22(UU), 22(WW), 23, 24, 25, 26, and 27.

3.

Defendant/Counter Plaintiff denies because no information the allegations in paragraphs 5, 7, 14(LL), and 22(LL).

4.

Defendant/Counter Plaintiff denies on information and belief, the allegations in paragraphs 14(VV), and 22(VV). 

5.

With respect to the allegations set forth in paragraph 6 of Plaintiff's/Counter Defendant's complaint, Defendant/Counter Plaintiff admits that he was at one time associated with CHRISTIAN MEDIA NETWORK, but denies each and every other allegation in paragraph 6.

With respect to the allegations set forth in paragraph 9 of Plaintiff's/Counter Defendant's complaint, Defendant/Counter Plaintiff admits that n 2002, Defendant/Counter Plaintiff began a friendship with LINDA KRISTICH ("Kristich"), but denies each and every other allegation in paragraph 9.

Defendant/Counter Plaintiff admits attending a conference in Indiana, but denies each and every other allegation in paragraph 10.

Defendant/Counter Plaintiff admits publishing the book titled "Prophecy for $ale: The Hidden History of the Christian Media Network" , but denies each and every other allegation in paragraph 12.

Defendant/Counter Plaintiff admits publishing the book titled "Prophecy for $ale: The Hidden History of the Christian Media Network" , but denies each and every other allegation in paragraph 14(A).

 Defendant/Counter Plaintiff admits writing "James kept the whole thing.", but denies each and every other allegation in paragraph 14 (B).

 Defendant/Counter Plaintiff admits publishing the Defendants private number, but denies each and every other allegation because no information, in paragraph 14(G).

Defendant/Counter Plaintiff admits writing "Katydine TRK water filter cost him about about $75" but denies each and every other allegation in paragraph 14(H).

Defendant/Counter Plaintiff admits writing "This has led some of his followers to make similar threats and in at least one case led to an assault with a deadly weapon upon an unarmed man", but denies each and every other allegation in paragraph 14(J).

Defendant/Counter Plaintiff admits writing "I can tell you with assurance that should you make any vociferous attempt to hold them to the standard they espouse, you can expect to be vilified, attacked, falsely accused, stalked, and sometimes assaulted" but denies each and every other allegation in paragraph 14(M).

Defendant/Counter Plaintiff admits writing "(although James had a commercial association with shortwave radio station WJIE which is owned by the 501 (c)(3) Church, First Assembly of God in Knoxville, Kentucky, until they ended the relationship because of Lloyd's venomous statements on air).", but denies each and every other allegation in paragraph 14(R).

Defendant/Counter Plaintiff admits writing " A notice informing her of the intention of the lender to repossess the truck was delivered, and rather than pay the obligation or surrender the vehicle, the decision was made to "rescue" it from seizure. This is theft.", but denies each and every other allegation in paragraph 14(V).

With respect to the allegations set forth in paragraph 20, the Defendant/Counter Plaintiff re-answers paragraphs 1 through 19 of this answer as if set forth fully herein.

Defendant/Counter Plaintiff admits publishing the book titled "Prophecy for $ale: The Hidden History of the Christian Media Network" , but denies each and every other allegation in paragraph 22(A).

Defendant/Counter Plaintiff admits writing "James kept the whole thing.", but denies each and every other allegation in paragraph 22 (B).

Defendant/Counter Plaintiff admits publishing the Plaintiff's/Counter Defendant's private number, but denies each and every other allegation because no information, in paragraph 22(G).

Defendant/Counter Plaintiff admits writing "Katydine TRK water filter cost him about about $75" but denies each and every other allegation in paragraph 22(H).

Defendant/Counter Plaintiff admits writing "This has led some of his followers to make similar threats and in at least one case led to an assault with a deadly weapon upon an unarmed man", but denies each and every other allegation in paragraph 22(J).

Defendant/Counter Plaintiff admits writing "I can tell you with assurance that should you make any vociferous attempt to hold them to the standard they espouse, you can expect to be vilified, attacked, falsely accused, stalked, and sometimes assaulted" but denies each and every other allegation in paragraph 22(M).

Defendant/Counter Plaintiff admits writing "(although James had a commercial association with shortwave radio station WJIE which is owned by the 501 (c)(3) Church, First Assembly of God in Knoxville, Kentucky, until they ended the relationship because of Lloyd's venomous statements on air).", but denies each and every other allegation in paragraph 22(R).

Defendant/Counter Plaintiff admits writing " A notice informing her of the intention of the lender to repossess the truck was delivered, and rather than pay the obligation or surrender the vehicle, the decision was made to "rescue" it from seizure. This is theft.", but denies each and every other allegation in paragraph 22(V).

6.

With respect to the allegations set forth in paragraph 28, the Defendant/Counter Plaintiff re-answers paragraphs 1 through 27 of this answer as if set forth fully herein.

7.

With respect to the allegations set forth in paragraph 29, the Defendant/Counter Plaintiff maintains that the Plaintiffs have always had a plain, speedy, and adequate remedy, but have consistently refused to avail themselves of any of them.

The Defendant/Counter Plaintiff has made several attempts to contact the Plaintiff/Counter Defendant , in email communication, and through third parties, in an effort to settle this matter, and to convince the Plaintiff/Counter Defendant to cease his defamatory comments, but the Plaintiff/Counter Defendant has consistently refused to do so, and has informed the Defendant/Counter Plaintiff that he wished no further contact.

In one instance, Alan Weiner, owner of Radio Station WBCQ who sells airtime to both Plaintiff/Counter Defendant LLOYD ("Lloyd"), and Defendant/Counter Plaintiff, contacted Plaintiff/Counter Defendant LLOYD ("Lloyd") on July 5, 2004. Plaintiff/Counter Defendant LLOYD ("Lloyd") refused to accept Mr. Wieiners mediation effort, and responded by sending Mr. Weiner notice that CHRISTIAN MEDIA would reduce the amount of airtime purchased from Mr. Weiner by 100 hours each month.

In another instance, Plaintiff/Counter Defendant LLOYD ("Lloyd"), was contacted by a third party who forwarded a letter authored by the Defendant/Counter Plaintiff which consisted of an offer to settle the issue between Defendant/Counter Plaintiff PORTWOOD and Plaintiff/Counter Defendant LLOYD ("Lloyd"). The only response received was an email from Plaintiff/Counter Defendant LLOYD ("Lloyd"), which referred to the third party as a "sniveling coward" for his efforts to facilitate an amicable resolution.

8.

With respect to the Plaintiff's/Counter Defendant's requests that the Court issue a Writ of Assistance as set forth in paragraph 30, the Defendant/Counter Plaintiff prays that the Court deny the Plaintiffs/Counter Defendant's requests to order the Sheriff to confiscate Defendants/Counter Plaintiffs computer hardware and software, as the Defendant/Counter Plaintiff does not own said equipment and is forced by economic circumstances to defend himself in Pro Per, which will require the Defendant/Counter Plaintiff to use the same computer hardware and software, to perform research involving case law, and in typing any required responses for presentation to the Court.

9.

With respect to any and all other allegations set forth in the complaint, the Defendant/Counter Plaintiff issues a general denial.

10.

For a FIRST AFFIRMATIVE DEFENSE, Defendant/Counter Plaintiff alleges:

On or about October 18, 2002, Plaintiff/Counter Defendant JAMES LLOYD ("Lloyd") began making unsubstantiated allegations about the Defendant/Counter Plaintiff on Plaintiff/Counter Defendant JAMES LLOYD's ("Lloyd's") radio program "The Apocalypse Chronicles" (hereafter referred to as the "program") , on 8 separate internationally allocated standard carrier shortwave radio frequencies, which are heard internationally. On Plaintiff/Counter Defendant JAMES LLOYD's ("Lloyd's") program, he has falsely stated on many occasions that the Defendant/Counter Plaintiff is an "adulterer", and stated falsely about the Defendant/Counter Plaintiff ""Portwood is uh raging over there in uh his uh Motel Room that's being paid for by the husband of the woman that he ran off with (laughing) and the two kids you know so she's he's living off of her hoping to get a nice big fat divorce settlement to pay for his airtime", and "Here's Craig Portwood right now. This guy will be on the radio this Friday night. He's an adulterer. He's shacked up in a Motel right now with another man's wife going to court trying to get the money from the inheritance that the husband got to finance himself in a new Christian Network because he wants to be James Lloyd when he grows up I guess-I'm not sure. He needs the money for his dental work-his smile is uh (laughter)- He's a liar. He's just a stoned liar"

On the same October 18, 2002, broadcast Plaintiff/Counter Defendant LLOYD ("Lloyd") stated: "A couple of house keeping notes. (laughter) Housekeeping as in we're going to sweep out the crud-uh (more laughter). The puppy's made a mess (Laughter) so we do some house keeping and in this case the mess that was made is-uh- listed on the internet. So if you'd like to read the account of the latest series of attacks against this ministry, you can go to CHRISTIAN MEDIA DAILY DOT COM, and our cover story is there, available for all to see. And-uh- this should be hopefully our last word on the subject. We're trying not to give this moron any more attention than he deserves and he deserves none because he's thoroughly reprobate."

On the same October 18, 2002, broadcast Plaintiff/Counter Defendant LLOYD ("Lloyd") stated: "And so well- let the heathen rage. But uh- if you'd like to- an actual blow by blow account of what actually has occurred -which brings it up to the present-uh- go to CHRISTIAN MEDIA DAILY DOT COM. If you're not on the internet- maybe go down to the library and take a look at it- if you don't want to do it fine-go away".

Defendant/Counter Plaintiff believes this was done in an attempt to tarnish the Defendant/Counter Plaintiff's previously good reputation among Defendant/Counter Plaintiff's radio listeners with the intent of destroying any support financial or otherwise, the Defendant/Counter Plaintiff might receive from those listeners.

The Plaintiff/Counter Defendant's made many other false and misleading statements on the same October 18, 2002 broadcast which stated that the Defendant/Counter Plaintiff has "Run off with his listeners wives". This program was re-aired six (6) times.

On his program the Plaintiff/Counter Defendant LLOYD ("Lloyd") continues to assert falsely that the Defendant/Counter Plaintiff uses illegal drugs, even though the Defendant/Counter Plaintiff has published the results of a drug test on his website, which prove the Plaintiffs assertion to be false.

Defendant's/Counter Plaintiff's JAMES LLOYD ("Lloyd") and SUSAN LENOX ("Lenox") had knowledge and reason to believe that these statements were false but Defendant/Counter Plaintiff's JAMES LLOYD ("Lloyd") made them anyway as evidenced from his statement made on October 18, 2003 that: " So those that are attempting to send emails and want to entreat and so forth, he said, she said, we're not interested. People don't realize you know when you go over to the Devil's turf over here, over there and mess with these guys, 'Craig said this', well you see, you went over there and you got filled with the spirit of Antichrist and you brought it over here. I don't want it. Get out of here. Don't come here and bring that spirit of puke over here. We don't want it. We're not interested and we don't want to interact. We don't want any part of anybody who wants to interact. So here it is and it's on the internet if you'd like to see it. That will be there for a while and then that uh article will be turned into an archive which will land on CHRISTIAN MEDIA RESEARCH."

On the same October 18, 2002 broadcast, Plaintiff/Counter Defendant LLOYD ("Lloyd") again stated "so there's a lengthy written account of the Craig Portwood mess and it's called "The Rise and Fall of Craig Portwood". You can find that at CHRISTIAN MEDIA DAILY."

In addition, Plaintiff/Counter Defendant LLOYD ("Lloyd") has made several inflammatory statements on his program over the course of the last 23 months, calling the Defendant/Counter Plaintiff "Pig Portwood", "Craig Wormwood", and similar slurs.

Plaintiff/Counter Defendant also published an article he called "The Hidden Things of Dishonesty: The Rise and Fall of Craig Portwood", which contained numerous falsehoods, inaccuracies, and innuendo about the Defendant/Counter Plaintiff . This article was emailed to every person in the Plaintiffs customer database, and included a request of the recipients to "Email this to a friend".

This article was widely published on other internet websites, which were controlled by some of the recipients. This article was also published on the Plaintiffs "Christian Media Daily" website, and his "Christian Media Research" website.

In addition, Plaintiff/Counter Defendant's JAMES LLOYD ("Lloyd") and SUSAN LENOX ("Lenox") knowingly and substantially aided and assisted and or sanctioned similar false and defamatory comments by their "hosts"/, which were made on their CHRISTIAN MEDIA (Christian Media") radio network, and replayed throughout the week on two separate frequencies on Radio station WBCQ, on two other separate frequencies on Radio Station WWRB, and on a several frequency on Radio Station WRMI. Among those comments, were false statements broadcast on the radio that the Defendant/Counter Plaintiff "Slept in the same bed" with a seven year old boy, and about the Defendant/Counter Plaintiff , one of the Plaintiffs hosts/representatives stated on radio "He's a pervert, and he's proven that". Plaintiff's/Counter Defendant's LLOYD ("Lloyd") and LENOX ("Lenox") refused to condemn those statements, and Defendant's LLOYD ("Lloyd") laughed on air about the incident when he was confronted about the comments.

Plaintiff's/Counter Defendant's LLOYD ("Lloyd") and LENOX ("Lenox") also knowingly and substantially aided and assisted and allowed these defamatory comments to be repeated on the "streaming audio" broadcast, accessed on their 3 websites. The statements made by Plaintiff/Counter Defendant LLOYD ("Lloyd") about the Defendant/Counter Plaintiff, as well as those statements made about the Defendant/Counter Plaintiff by their network hosts/representatives, which were sanctioned by Plaintiff's/Counter Defendant's LLOYD ("Lloyd") and LENOX ("Lenox"), were false, unprivileged, malicious misleading, and defamatory .

After six months of this defamatory behavior on the part of Plaintiff's/Counter Defendant's LLOYD ("Lloyd") and LENOX ("Lenox") network "hosts"/representatives Ralph and Kathy Haaff of the CHRISTIAN MEDIA NETWORK sponsored "OPS SHOW", and Rick Walters of the "ACTS ONE EIGHT" show, as well as knowingly and substantially aiding, assisting and sanctioning the propagation of false, misleading, and malicious statements made by Plaintiff/Counter Defendant LLOYD ("Lloyd"), the Defendant/Counter Plaintiff began to publish the truth about how the situation came about, with the object of clearing his name, and restoring his previous good reputation in the community.

11.

For a SECOND AFFIRMATIVE DEFENSE, Defendant/Counter Plaintiff alleges:

Plaintiffs/Counter Defendants have not satisfied the requirements of ORS 31.210-31.225 which states;

Over the course of the past 23 months, Plaintiff/Counter Defendant LLOYD ("Lloyd"), has been resolute in his refusal to settle the issue peacefully.

The Defendant/Counter Plaintiff has made several attempts to contact the Plaintiff/Counter Defendant , in email communication, and through third parties, in an effort to settle this matter, and to convince the Plaintiff/Counter Defendant to cease his defamatory comments, but the Plaintiff/Counter Defendant has consistently refused to do so, and has informed the Defendant/Counter Plaintiff that he wished no further contact.

In one instance, Alan Weiner, owner of Radio Station WBCQ who sells airtime to both Plaintiff/Counter Defendant LLOYD ("Lloyd"), and Defendant/Counter Plaintiff, contacted Plaintiff/Counter Defendant LLOYD ("Lloyd") on July 5, 2004. Plaintiff/Counter Defendant LLOYD ("Lloyd") refused to accept Mr. Wieiners mediation effort, and responded by sending Mr. Weiner notice that CHRISTIAN MEDIA would reduce the amount of airtime purchased from Mr. Weiner by 100 hours each month.

In another instance, Plaintiff/Counter Defendant LLOYD ("Lloyd"), was contacted by a third party who forwarded a letter authored by the Defendant/Counter Plaintiff, dated March 13, 2004, which consisted of an offer to settle the issue between Defendant/Counter Plaintiff PORTWOOD and Plaintiff/Counter Defendant LLOYD ("Lloyd"). The only response received was an email from Plaintiff/Counter Defendant LLOYD ("Lloyd"), which referred to the third party as a "sniveling coward" for his efforts to facilitate an amicable resolution. A copy of this email and the response from Plaintiff/Counter Defendant LLOYD ("Lloyd") (hereafter the "First Response") , is attached to this Answer/Counter Complaint as Exhibit "101" and is incorporated into the Answer/Counter Complaint herein by this reference.

On August 1, 2004, Defendant/Counter Plaintiff made a formal demand for retraction of the defamatory statements made, and or sanctioned by Plaintiff/Counter Defendant LLOYD ("Lloyd"), and at that time made yet another offer to resolve the issue. Plaintiff/Counter Defendant LLOYD ("Lloyd"), refused to respond. A copy of this demand (hereafter the "Demand") is attached to this Answer/Counter Complaint as Exhibit "201" and is incorporated into the Answer/Counter Complaint herein by this reference.

12.

For a THIRD AFFIRMATIVE DEFENSE, Defendant/Counter Plaintiff alleges:

The Defendant has made every attempt to be accurate and truthful his publication. Any inaccurate statements in the Defendant's/Counter Plaintiff's book, could have been brought to the Defendant's/Counter Plaintiff's attention, and could have been redacted, or corrected, and the Defendant/Counter Plaintiff could have published a timely retraction, if events warranted. No specific statements were made by the Plaintiff/Counter Defendant to the effect that Plaintiff/Counter Defendant believed the Defendant/Counter Plaintiff to be in error, instead the Plaintiff/Counter Defendant LLOYD ("Lloyd") simply issued uncorroborated statements on his program, and in print, that the Defendant/Counter Plaintiff is "a liar", a "drug addict", and other false, unprivileged, malicious, defamatory, and verbally abusive terms.

13.

For a FOURTH AFFIRMATIVE DEFENSE, Defendant/Counter Plaintiff alleges:

The Beacon of Truth Online Newsletter is entitled to the same protection afforded other organs of the Public Press, enumerated by the First Amendment of the Constitution of the United States. Every effort has been made by the Defendant/Counter Plaintiff to report truthfully and accurately in the matter. By reason of their regular appearance on CHRISTIAN MEDIA NETWORK ("Christian Media"), the Plaintiffs are all public figures having free access to mass media, and any errors or omissions in reporting any story in which a public figure is covered in that story, must be proven to be malicious and intentional to meet the legal standard of Defamation.

In New York Times Co. v. Sullivan, 376 U.S. 254, 279 -280 (1964), the U.S. Supreme Court held that, in a libel suit brought by a public official, the First Amendment requires the plaintiff to show that in publishing the defamatory statement the defendant acted with actual malice - "with knowledge that it was false or with reckless disregard of whether it was false or not." The U.S. Supreme Court held further that such actual malice must be shown with "convincing clarity." Id., at 285-286. See also Gertz v. Robert Welch, Inc., 418 U.S. 323, 342 (1974). These New York Times requirements we have since extended to libel suits brought by public figures as well. See, e. g., Curtis Publishing Co. v. Butts, 388 U.S. 130 (1967).

FACTS COMMON TO ALL CLAIMS FOR RELIEF

14.

From October of 2000 to December 31, 2000, and from February 2001, to May 2002 after numerous requests from Plaintiff/Counter Defendant JAMES LLOYD ("Lloyd") to quit Defendant/Counter Plaintiff's live-in job helping an elderly Jacksonville man with activities of daily living, Defendant/Counter Plaintiff agreed to work in the employ of Plaintiffs/Counter Defendants JAMES LLOYD ("Lloyd"), and SUSAN LENOX ("Lenox"), and was required by the nature of Defendant/Counter Plaintiff's duties to reside on the property located at 10250 Little Applegate Road, Jacksonville, Oregon, to be an on site manager for Plaintiffs/Counter Defendant's CHRISTIAN MEDIA NETWORK ("Christian Media"), running two (2) separate network studios, writing, and producing commercials. Defendant/Counter Plaintiff also provided Defendant/Counter Plaintiff's voice for commercials which advertised the Plaintiffs/Counter Defendants merchandise on Plaintiffs/Counter Defendants radio network, for which Defendant/Counter Plaintiff has received no remuneration. Defendant/Counter Plaintiff also wrote and produced an audio tape set titled "Police 101" of which the Plaintiffs/Counter Defendants JAMES LLOYD ("Lloyd"), and SUSAN LENOX ("Lenox"), sold hundreds of copies, and for which Defendant/Counter Plaintiff received no remuneration.

15.

Defendant/Counter Plaintiff also had responsibility for producing programs and writing articles for Plaintiffs/Counter Defendants JAMES LLOYD's ("Lloyd's"), and SUSAN LENOX's ("Lenox's"), "Christian Media Daily" internet newsletter, as well as having duties related to the maintenance and upkeep of the real property of Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox), in addition to work relating to the care and feeding of Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox), livestock, and running errands. The Defendant/Counter Plaintiff was also required to operate Plaintiffs/Counter Defendants Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox), tape duplication battery and operate Plaintiffs/Counter Defendants Plaintiffs/Counter Defendants LLOYD's ("Lloyd's") and LENOX's ("Lenox's), retail storage food canning operation.

(A)

With the exception of the period from October 2000 to December 2000 when the Defendant/Counter Plaintiff received no pay for his services, Defendant/Counter Plaintiff worked in the Plaintiffs/Counter Defendants employ approximately eighteen (18) hours each weekday, and eight (8) hours each Sunday and was compensated $300.00 weekly, at a rate which is approximately equal to three (3) dollars an hour.

16.

In July 2001, while in the employ of Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox"), Defendant/Counter Plaintiff became ill, suffering breathing difficulties, and severe chest pains. The Defendant/Counter Plaintiff also began having numbness in his feet, pain in his arms, and other somatic ailments. At that time, these facts were made known to Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox"). Plaintiff/Counter Defendant LLOYD ("Lloyd") did offer the Defendant/Counter Plaintiff an aspirin on one occasion to treat the malady in an effort to keep the Defendant/Counter Plaintiff at the Defendant/Counter Plaintiff's duty station. Plaintiff/Counter Defendant LENNOX ("Lenox") also offered the Defendant/Counter Plaintiff a white crystalline substance she calls "MSM" which Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox), sell, and a solution of "Colloydal Silver" as an alternative to medical treatment. On three (3)other occasions when Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENNOX ("Lenox") had an infected tooth, Defendant/Counter Plaintiff was offered some antibiotic powder by Plaintiff/Counter Defendant LENNOX ("Lenox") which Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENNOX ("Lenox") had purchased to treat their cattle for an unspecified illness, in an effort to keep Defendant/Counter Plaintiff at his duty station.

17.

In early 2002, Defendant/Counter Plaintiff was assigned to promote and organize a speaking engagement (hereafter called the "event") by Plaintiff/Counter Defendant LLOYD ("Lloyd") , produced for and sponsored by CHRISTIAN MEDIA NETWORK, which was held from May 31, to June 2, 2002, at Clifty Falls State Park in Madison, Indiana, and which included five (5) network representatives (also known as "network hosts") of CHRISTIAN MEDIA NETWORK. Defendant/Counter Plaintiff attended and produced the event, and at the direction of Plaintiff/Counter Defendant LLOYD ("Lloyd"), offered merchandise for sale at the event, for the benefit of Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox"). During the event, Defendant/Counter Plaintiff did two (2) live broadcasts for the benefit of Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox") on their CHRISTIAN MEDIA NETWORK.

18.

One month before leaving to produce the event, Defendant/Counter Plaintiff informed Plaintiffs/Counter Defendants LLOYD and LENOX that the Defendant/Counter Plaintiff would not return to the CHRISTIAN MEDIA NETWORK for about six (6) weeks, in an effort to recuperate from the aforementioned ailments. The Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox") were also informed that the Defendant/Counter Plaintiff would not be returning as an on site manager of the network nor be able to continue working such extensive hours as previously, but would instead rent a room from LINDA KRISTICH ("Kristich"), who was planning to move to the area of Jackson County, Oregon, sometime after the event.

19.

On or about July of 2002, the Defendant/Counter Plaintiff notified Plaintiff/Counter Defendant LLOYD ("Lloyd") by telephone, that the Defendant/Counter Plaintiff would be returning that week to Oregon to resume Defendant/Counter Plaintiff's duties at the network. At that time Plaintiff/Counter Defendant LLOYD notified the Defendant/Counter Plaintiff, that the Defendant/Counter Plaintiff's services would no longer be needed.

(A)

Shortly thereafter in July of 2002, the Defendant/Counter Plaintiff began to resume his shortwave radio broadcast on radio station WBCQ, which is known as "The Beacon of Truth", which he has done since February of 1999. Shortly thereafter, Plaintiff/Counter Defendant LLOYD, and three (3) of Plaintiff/Counter Defendant LLOYD's ("Lloyd") network hosts/representatives Ralph Haaff, and Kathy Haaff of the CHRISTIAN MEDIA NETWORK (Christian Media") sponsored "OPS Show", and Rick Walters, of the "ACTS ONE EIGHT" show, began making defamatory comments about the Defendant/Counter Plaintiff on radio on his CHRISTIAN MEDIA NETWORK ("Christian Media").

20.

On or about August of 2002, Defendant/Counter Plaintiff began to be repeatedly accused by hosts/representatives of CHRISTIAN MEDIA NETWORK ("Christian Media") Ralph Haaff, Kathy Haaff of the CHRISTIAN MEDIA NETWORK (Christian Media") sponsored "OPS Show", Rick Walters of the "ACTS ONE EIGHT" show, of committing adultery, was the object of gossip and innuendo propagated by these hosts.

Defendant/Counter Plaintiff was harassed and hounded for his friendship with Linda Kristich who was in the process of a divorce, though there was no evidence of or witnesses to the accused behavior and all accusations and gossip were firmly denied by Ms. Kristich and Defendant/Counter Plaintiff. Disapproving of the friendship between Defendant/Counter Plaintiff and Ms. Kristich, Plaintiff/Counter Defendant LLOYD and the hosts began a vicious campaign against Defendant/Counter Plaintiff attempting to enlist support from attendees of the event and radio show listeners.

Unbeknownst to Defendant/Counter Plaintiff at the time, the aforementioned hosts/representatives of CHRISTIAN MEDIA NETWORK contacted several regular supporters of CHRISTIAN MEDIA NETWORK by phone and email to disparaged the name and reputation of Defendant/Counter Plaintiff stating the charge of adultery and expecting the contactees to denounce both Defendant/Counter Plaintiff and Ms. Kristich. CHRISTIAN MEDIA NETWORK ("Christian Media") hosts/representatives Ralph Haaff, Kathy Haaff, Rick Walters, and Kirke Wise made many accusations of supposed adulterous behavior of Defendant/Counter Plaintiff with Ms.Kristich, but could not supply names of witnesses to the accused behavior nor would any witnesses come forth.

 21.

CLAIM FOR RELIEF

Defendant/Counter Plaintiff realleges paragraphs 1 through 20 of this Complaint as if set forth fully herein.

22.

(A)

On or about October 2002, Plaintiff/Counter Defendant JAMES LLOYD ("Lloyd") began making unsubstantiated allegations about the Defendant/Counter Plaintiff on his radio program "The Apocalypse Chronicles" (hereafter referred to as the "program"), on eight (8) separate shortwave radio frequencies, which are heard internationally. On his program, he has falsely stated on many occasions that the Defendant/Counter Plaintiff is an "adulterer", and falsely stated that the Defendant/Counter Plaintiff "...is shacked up in a motel right now with another mans wife". Plaintiff/Counter Defendant LLOYD ("Lloyd") also made false statements that the Defendant/Counter Plaintiff was trying to get money from "...the inheritance that the husband got to finance himself in a new Christian Network". Defendant/Counter Plaintiff believes this was done in an attempt to tarnish the Defendant/Counter Plaintiff's previously good reputation among Defendant/Counter Plaintiff's radio listeners with the intent of destroying any financial support the Defendant/Counter Plaintiff might receive from those listeners.

(B)

Plaintiff/Counter Defendant JAMES LLOYD ("Lloyd") had reason to believe that these statements were false but made them anyway as evidenced from his statement made on the October 18, 2003 program that: " So those that are attempting to send emails and want to entreat and so forth, he said, she said, we're not interested. People don't realize you know when you go over to the Devil's turf over here, over there and mess with these guys, 'Craig said this', well you see, you went over there and you got filled with the spirit of Antichrist and you brought it over here. I don't want it. Get out of here. Don't come here and bring that spirit of puke over here. We don't want it. We're not interested and we don't want to interact. We don't want any part of anybody who wants to interact. So here it is and it's on the internet if you'd like to see it. That will be there for a while and then that uh article will be turned into an archive which will land on CHRISTIAN MEDIA RESEARCH."

(C)

On his October 18, 2002 program Plaintiff/Counter Defendant JAMES LLOYD ("Lloyd") stated: "Portwood is uh raging over there in uh his uh Motel Room that's being paid for by the husband of the woman that he ran off with (laughing) and the two kids you know so she's he's living off of her hoping to get a nice big fat divorce settlement to pay for his airtime", and "Here's Craig Portwood right now. This guy will be on the radio this Friday night. He's an adulterer. He's shacked up in a Motel right now with another man's wife going to court trying to get the money from the inheritance that the husband got to finance himself in a new Christian Network because he wants to be James Lloyd when he grows up I guess." and then made the statement that "You can go to christianmediadaily.com and our cover story is there, available for all to see".

(D)

On his October 18, 2002 program Plaintiff/Counter Defendant JAMES LLOYD ("Lloyd") also stated: "And so well- let the heathen rage. But uh- if you'd like to- an actual blow by blow account of what actually has occurred-which brings it up to the present-uh- go to CHRISTIAN MEDIA DAILY DOT COM. If you're not on the internet- maybe go down to the library and take a look at it- if you don't want to do it fine-go away".

(E)

On the same October 18, 2002 broadcast, Plaintiff/Counter Defendant LLOYD ("Lloyd") stated: "A couple of house keeping notes. (laughter) Housekeeping as in we're going to sweep out the crud-uh (more laughter). The puppy's made a mess (Laughter) so we do some house keeping and in this case the mess that was made is-uh- listed on the internet. So if you'd like to read the account of the latest series of attacks against this ministry, you can go to CHRISTIAN MEDIA DAILY DOT COM, and our cover story is there, available for all to see. And-uh- this should be hopefully our last word on the subject. We're trying not to give this moron any more attention than he deserves and he deserves none because he's thoroughly reprobate."

(F)

On the same October 18, 2002 broadcast, Plaintiff/Counter Defendant LLOYD ("Lloyd") stated "so there's a lengthy written account of the Craig Portwood mess and it's called "The Rise and Fall of Craig Portwood". You can find that at CHRISTIAN MEDIA DAILY."

(G).

Plaintiff/Counter Defendant LLOYD ("Lloyd") also falsely stated on the October 18, 2002 broadcast about the Defendant/Counter Plaintiff "He's a liar. He's just a stoned liar". Plaintiff/Counter Defendant LLOYD ("Lloyd") made many other false and misleading statements on the October 18, 2002 broadcast which implied that the Defendant/Counter Plaintiff has "Run off with his listeners wives". This program was re-aired six (6) times. On his program the Plaintiff/Counter Defendant LLOYD ("Lloyd") continues to assert falsely that the Defendant/Counter Plaintiff uses illegal drugs, even though the Defendant/Counter Plaintiff has published the results of a drug test on his "Beacon of Truth" website, which prove the Plaintiff's/Counter Defendant's assertion to be false, and at no time while Defendant/Counter Plaintiff was employed by Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox") did Plaintiffs/Counter Defendants ever state or accuse Defendant/Counter Plaintiff either publicly or privately of drug use while in his employ.

(H).

In addition, the Plaintiff/Counter Defendant has made several inflammatory statements on his program directed towards Defendant/Counter Plaintiff, calling the Defendant/Counter Plaintiff "Pig Portwood", "Craig Wormwood", and similar slurs.

(I).

In addition, the Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox") sanctioned similar false and defamatory comments by their clients, which were made on his CHRISTIAN MEDIA (Christian Media") radio network, and replayed throughout the week on two separate frequencies on Radio station WBCQ, on two other separate frequencies on Radio Station WWRB, and on a several frequency on Radio Station WRMI. Among those comments, were false statements broadcast on the radio on January 9, 2003, by CHRISTIAN MEDIA NETWORK host/representative Rick Walters on the "ACTS ONE EIGHT" show, that the Defendant/Counter Plaintiff "Slept in the same bed" with a seven year old boy, and made other statements on the same January 9, 2003 broadcast about Defendant/Counter Plaintiff saying "He's a pervert, and he's proven that". The Plaintiff/Counter Defendant LLOYD ("Lloyd") refused to condemn those statements, and laughed on air on his program "The Apocalypse Chronicles" when he was confronted about those comments.

 (J).

The Plaintiffs/Counter Defendants LLOYD ("Lloyd") and LENOX ("Lenox") also allowed these defamatory comments to be repeated on the "streaming audio" broadcast, accessed on their 3 websites. The statements made by the Plaintiff/Counter Defendant LLOYD ("Lloyd") about the Defendant/Counter Plaintiff, as well as those statements made about the Defendant/Counter Plaintiff by the Clients of Plaintiff/Counter Defendant LLOYD ("Lloyd") were sanctioned by Plaintiff/Counter Defendant LLOYD ("Lloyd"), and were unprivileged , false, misleading, and malicious.  

(K).

Plaintiff/Counter Defendant LLOYD ("Lloyd") also published an article he called "The Hidden things of Dishonesty: The Rise and Fall of Craig Portwood" (hereafter referred to as the "article") , which contained numerous falsehoods, inaccuracies, and innuendo about the Defendant/Counter Plaintiff. This article was emailed to every person in the Plaintiff/Counter Defendants customer database, which by Plaintiff/Counter Defendant LLOYD's ("Lloyd's") own reckoning contains the names and addresses of thousands of individuals. This article included a request to the recipients that they "Email this (article) to a friend".

(L).

This article was widely published on other internet websites, which were controlled by some of the recipients. This article was also published on the Plaintiff's/Counter Defendant's JAMES LLOYD'S ("Lloyd's") and SUSAN LENOX's ("Lenox's") "Christian Media Daily" website, as well as their "Christian Media Research" website. That article remains on the "Christian Media Research" website to this day.

(M).

After six months of this defamatory behavior on the part of the Plaintiffs/Counter Defendant's, on or about February, 2003, the Defendant/Counter Plaintiff began to publish the truth about how the situation came about, with the object of clearing his name, and restoring his previous good reputation in the community.

23.

 In paragraph 2 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "there was always a secretive, darker side of Craig that was rarely seen. It is that dark side that has resisted the work of the Holy Spirit that has proven to be his undoing."

24.

 In paragraph 5 of the article, the Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "After having experienced the latest salvo apparently originating with one of God's "helpers," I'm reminded of the Apostle Paul's incredulity when he encountered particularly wicked behaviour among the church at Corinth. In that instance, he marveled that the sin that had taken root among the Corinthian believers was so far over the line that it was "not so much as named among the Gentiles'' (I Cor 5:1), and by reference have accused the Defendant/Counter Plaintiff by implication, of an inclination to commit fornication with his own own mother, using the passage in the Bible book of 1st Corinthians, chapter 5, verse 1, which states "It is reported commonly that there is fornication among you, and such fornication as is not so much as named among the Gentiles, that one should have his father's wife.".

25.

In paragraph 8 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "Some weeks later, Craig informed us he would be taking a leave of absence to go to Indiana and Michigan where he would attend the Clifty Falls Fellowship event produced by another Christian Media Network host named Rick Walters. Several Christian Media hosts including Kirke Wise and Ralph Haaff (as well as Craig Portwood himself) were scheduled to speak at that event. Craig had also arranged for Linda Kristich to be a guest speaker who would give a talk related to child rearing." This statement contains numerous intentional falsehoods, as Plaintiff/Counter Defendant LLOYD ("Lloyd") was fully aware that Defendant/Counter Plaintiff not only organized and produced the event at the direction and benefit of Plaintiff/Counter Defendant LLOYD ("Lloyd"), but Defendant/Counter Plaintiff had arraigned for all scheduled speakers to attend, and also wrote, produced, and edited a commercial for the event, which was run on CHRISTIAN MEDIA NETWORK from approximately April 2002, to June 2002.

In paragraph 9 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "A week before he left Oregon, Craig casually informed me that after the weekend event he would be staying in Linda's home state of Michigan for an unspecified period and then he and Linda were going to come back to Oregon and set up a household together! I was aghast as I asked Craig ''Isn't she a married woman?'' He responded that she was getting a divorce. Realizing that a very serious problem had quietly crept in to our midst, I calmly told Craig that his present course of action would require me to sever our ministry association with him." This statement intentionally misrepresents the conversation which took place between Plaintiff/Counter Defendant LLOYD ("Lloyd") and the Defendant/Counter Plaintiff.

27.

In paragraph 10 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "At about the same time Craig told me of his relationship with Mrs. Kristich, he also mentioned it to my wife Susan. She related that Craig told her the couple was planning on returning to the Jacksonville area where they would build a house somewhere in the vicinity of Christian Media. Craig provided Susan with a detailed description of a survivalist oriented structure that would be custom designed to be able to deflect the effects of the HAARP technology (a well known black budget system the government is known to be deploying) as well as other threats that are expected during the forthcoming tribulation". This statement intentionally misrepresents the conversation which took place between Plaintiff/Counter Defendant LENOX ("Lenox") and the Defendant/Counter Plaintiff.

28.

In paragraph 12 of the article, Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote "Craig Portwood has now been transformed into a thoroughly reprobate individual that is completely devoid of any presence of the Holy Spirit. In short, Craig Portwood, the host of a "Christian" radio show, CAN NO LONGER DISCERN BETWEEN RIGHT AND WRONG."

29.

In paragraph 13 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "We learned that Linda Kristich's husband, a man named James Kristich, had recently inherited a substantial amount of money, and his wife Linda was attempting to gain a sizeable portion of those funds by divorcing her husband. The justification for the planned divorce was that he was an ungodly man that wanted to put the couple's children into Catholic school. Craig sought to give the impression that James Kristich was some sort of monster and Linda was perfectly justified in divorcing the man." This is a complete and intentional misrepresentation of Defendant/Counter Plaintiff's statement, which was designed to make Ms. Kristich appear to be avaricious, and designed to make the friendship that the Defendant/Counter Plaintiff had with Ms. Kristich to be based upon calculated self interest and greed, in an effort to destroy Defendant/Counter Plaintiffs previously good public image.

30.

 In paragraph 14 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "I was already aware that Craig Portwood had come to the point where he held me in disdain and gave others the impression that he should be running the Christian Media Network." This is a complete falsehood which was intended to give those listeners who hold Plaintiff/Counter Defendant LLOYD ("Lloyd") in high esteem the impression that the Defendant/Counter Plaintiff was disloyal to Plaintiff/Counter Defendant LLOYD ("Lloyd") and to erode any type of support, financial or otherwise that the Defendant/Counter Plaintiff might receive from those listeners.

31.

 In paragraph 16 of the article under the heading "The Portwood Plot" Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote "Craig indicated to Susan that he had worked hard all of his life, and ''it's my turn for someone else to take care of me.'' He seemed to give the indication that he was destined for something great like this to happen, and this was his chance at ''the brass ring." This is a complete, intentional misrepresentation of the conversation. Defendant/Counter Plaintiff believes this was intended to give the reader the impression that the Defendant/Counter Plaintiff is avaricious and opportunistic.

32.

In paragraph 18 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "I firmly but gently told him Christian Media could have no association with him based upon his planned course of action. I resolved to take a hands-off approach and keep my distance." This statement is a complete fabrication designed to hide the fact that Plaintiff/Counter Defendant LLOYD ("Lloyd") had sanctioned accusations which were made by hosts/representatives of CHRISTIAN MEDIA NETWORK ("Christian Media") Ralph Haaff, Kathy Haaff of the CHRISTIAN MEDIA NETWORK (Christian Media") sponsored "OPS Show", Rick Walters of the "ACTS ONE EIGHT" show, to the effect that Defendant/Counter Plaintiff was guilty of committing adultery.

 33.

 In paragraph 18 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") also wrote: "A week later, I was informed by our people (Ralph Haaff and Kathy Haaff of the CHRISTIAN MEDIA NETWORK (Christian Media") sponsored "OPS Show") present at the event that Linda had just become separated from her Michigan based husband in order to meet Craig at the event." This statement is a complete and intentional misrepresentation of the facts, as Plaintiff/Counter Defendant LLOYD ("Lloyd") was aware that Ms. Kristich was a scheduled speaker at the event, and her participation in the event had been publicized for at least two (2) months prior to the event, and was designed to make Ms. Kristich's presence at the event, appear to be a romantic liason with the Defendant/Counter Plaintiff.

34.

 In paragraph 19 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "The following day, at least one person present at that dinner approached Kathy Haaff (co-host of the Christian Media Ops program with her husband Ralph) and asked `What's up with Craig and Linda? He was all over her at the restaurant last night." This statement was made without any proof that such conversation ever took place, and no witnesses were named to verify the account given by Plaintiff/Counter Defendant LLOYD ("Lloyd"), and no such wintesses were brought forth to substantiate this accusation.

35.

 In paragraph 20 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "As no attempt was made to conceal the relationship, word of the budding �romance� quickly spread among the attendees at Clifty Falls. Event producer Rick Walters testifies that on Sunday, he observed Craig and Linda repeatedly kissing as they jubilantly announced they were getting married." This statement contains numerous falsehoods. It falsely identified CHRISTIAN MEDIA NETWORK host/representative Rick Walters as the event producer, and mentions alleged, unnamed "attendees" as witnesses. Aside from CHRISTIAN MEDIA NETWORK host/representative Rick Walters who took part in the malicious campaign of spreading false information and accusations against Defendant/Counter Plaintiff, no witnesses have come forth to support this allegation.

36.

In paragraph 22 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "Portwood then called me and sought to drive a wedge between Walters and Haaff and myself claiming ''they aren't helping the ministry'' with their narrow-minded ways". This statement is a complete and intentional misrepresentation of the conversation Defendant/Counter Plaintiff had with Plaintiff/Counter Defendant LLOYD ("Lloyd"), and was designed to foster the lie that the Defendant/Counter Plaintiff was involved in an adulterous affair with a married woman.

37.

In paragraph 23 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "As the event ended, Craig relocated to Linda's home state of Michigan, and opened a post office box address in her small town. He subsequently moved into a motel where, as of this writing, he is visited in the evenings by Linda Kristich -- who is still living with the husband she is divorcing." This statement is a complete and intentional misrepresentation of the conversation Defendant/Counter Plaintiff had with Plaintiff/Counter Defendant LLOYD ("Lloyd"), and was designed to foster the lie that the Defendant/Counter Plaintiff was involved in an adulterous affair with a married woman.

38.

 In paragraph 23 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") also wrote: "As I had quietly dropped Craig's program from our schedule as soon as I learned of the looming scandal, Craig quickly arranged to purchase shortwave time in the hour immediately following Christian Media's broadcast sign-off -- thus giving many listeners the impression that the program that had previously been on Christian Media's broadcast schedule was still on the network". This is a complete and intentional falsehood, designed to make Defendant/Counter Plaintiff appear to deceive Defendant/Counter Plaintiffs radio listeners.

 39.

In paragraph 24 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote "Because Craig didn't have much money when he left Oregon and producing a daily shortwave hour is a relatively expensive proposition, we can't help but presume the broadcast fees are coming from Linda as she battles her husband for his substantial inheritance monies". Defendant/Counter Plaintiff believes that this "presumptive" statement was designed to make Ms. Kristich appear to be avaricious and greedy, and was improperly designed to make Defendant/Counter Plaintiff appear to have improper motives in Defendant/Counter Plaintiffs friendship with Ms. Kristich in the eyes of Defendant/Counter Plaintiffs radio listeners, and was designed to erode any type of support, financial or otherwise that the Defendant/Counter Plaintiff might receive from those listeners. No evidence was offered by Plaintiff/Counter Defendant LLOYD ("Lloyd") which would support Plaintiff/Counter Defendant LLOYD's ("Lloyd's") stated conclusion that "Craig didn't have much money when he left Oregon"..

In paragraph 27 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "The simple truth was Craig was exposed for engaging in an adulterous relationship by his own open conduct in front of many witnesses". This statement is a complete fabrication, and none of the "many witnesses" Plaintiff/Counter Defendant LLOYD ("Lloyd") claims as the source of this false statement have been named or come forward with a testimony which would justify such a statement.

41.

In paragraph 33 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "Craig has surreptitiously arranged to have two avowed enemies of Rick Walters substitute host for him on his shortwave program. This was clearly retaliatory. In the process, Portwood has been blatantly lying to cover his attacks. For example, in a Beacon of Truth broadcast by a substitute host named Greg Jones that was aired on October 17^{th 2002, Mr. Jones vehemently criticized Rick Walters by name". This is a complete falsehood, and no evidence exists to support this accusation. Plaintiff/Counter Defendant LLOYD ("Lloyd") intentionally fabricated this statement to make Defendant/Counter Plaintiff appear to be vengeful and vindictive.} 

^42.

^{In paragraph 35 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "The very same day, I received an email threat from Craig Portwood '' stating I'm the one that needs to repent '' as well as claiming the real problem is ''the counsel'' that I have received concerning him. This email from Craig ominously stated that I was ''warned months ago by telephone'' concerning the matter. Craig then demanded that I ''repent and recant'' of my stating of the facts or else he will ''attack'' the ministry". Plaintiff/Counter Defendant LLOYD ("Lloyd") intentionally misrepresented the context of that communication in an effort to justify Plaintiff/Counter Defendant LLOYD's ("Lloyd's") defamatory campaign against Defendant/Counter Plaintiff.}

^{In paragraphs 36, 37, 38, 39, and 42 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") accuses the Defendant/Counter Plaintiff with "email fraud" with no proof that Defendant/Counter Plaintiff has done so.}

^{In paragraph 45 of the article, Plaintiff/Counter Defendant LLOYD ("Lloyd") by innuendo accuses the Defendant/Counter Plaintiff of committing "a federal felony to commit interstate fraud" and a "deliberate theft" of radio airtime.}

^45.

 ^{In paragraph 47 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote "The evidence now firmly indicates that while Craig was sending me emails threatening me with dire consequences if the ministry exposed his involvement with Linda Kristich, he was already planning a smear campaign against my wife Susan, myself, and others at the network." in an effort to justify Plaintiff/Counter Defendant LLOYD's ("Lloyd's") defamatory campaign against Defendant/Counter Plaintiff.}

^{In paragraph 48 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote "Yet almost two months before this letter, evidence exists that Portwood was already planning a slander campaign against Christian Media". in another effort to justify Plaintiff/Counter Defendant LLOYD's ("Lloyd's") defamatory campaign against Defendant/Counter Plaintiff.}

^{In paragraph 53 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "Craig blatantly lied in print".}

^48.

^{In paragraph 58 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") knowingly and deliberately took out of context statements made by Defendant/Counter Plaintiff as Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "Craig Portwood actually indicated he would assist the IRS in an effort to destroy Christian Media. In a personal email to me, Craig wrote ".....expect me to cooperate with the IRS." He then boasted that he would "notify them of where you do your banking...." Defendant/Counter Plaintiff believes this statement was made to further tarnish the reputation of Defendant/Counter Plaintiff in the eyes of CHRISTIAN MEDIA NETWORK followers, who accept the teaching of Plaintiff/Counter Defendant LLOYD ("Lloyd") that all organs of government are "corrupt" and that all government employees are in the words of Plaintiff/Counter Defendant LLOYD ("Lloyd"), "wicked, criminal bastards".}

^49.

^{In paragraph 59 of the article Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "This is, of course, the classic pattern of the Antichrist religious spirit providing spiritual justification for the Beast government's persecutions of the Saints.", implying that Defendant/Counter Plaintiff is persecuting Plaintiff/Counter Defendant LLOYD ("Lloyd") .}

^50. 

^{In paragraph 60 of the article, Plaintiff/Counter Defendant LLOYD ("Lloyd") wrote: "By December, on his shortwave broadcast, Portwood announced that he had taken a job as a chef in a restaurant, and he hoped that Ralph Haaff would eat there so he could "spit on his steak." This is yet another false, unsubstantiated statement designed to make Defendant/Counter Plaintiff appear to be spiteful, vindictive, and petty.}

^{In paragraphs 62 and 63 of the article, Plaintiff/Counter Defendant LLOYD ("Lloyd") accuses Defendant/Counter Plaintiff of involvement in threatening the elderly mother of one of Plaintiff/Counter Defendants LLOYD ("Lloyd") and LENOX'S ("Lenox's") CHRISTIAN MEDIA NETWORK hosts/representatives, stating "The latter move amounts to an implied threat of violence against Mr. Walter's elderly mother. Clearly, Craig Portwood's cowardly actions indicate that he has been given "over to a reprobate mind". Plaintiff/Counter Defendant LLOYD ("Lloyd") has also made claims to his listeners which suggest that Defendant/Counter Plaintiff posted pictures of the same elderly woman in "Bad neighborhoods" in the area of Madison Indiana, to encourage others to commit a violent crime against her. No proof exists for these accusations, and no such witnesses or Police report were brought forth to substantiate this accusation.}

 ^52.

 ^{In paragraph 66 of the article, Plaintiff/Counter Defendant LLOYD ("Lloyd") accused Defendant/Counter Plaintiff by implication of theft, writing "During Craig's tenure at Christian Media, he repeatedly clashed with another show host named Chris Blodgett. When Blodgett left the ministry, he stole approximately 5,000 pounds of stored dehydrated food from a storage facility. He also `liberated' a number of items from the network's studio -- in addition to waging a vicious campaign of slander against Christian Media and myself that, in retrospect, is eerily similar to that which has just occurred with Portwood. Oddly enough, Portwood and Blodgett both lived in the same small town (Pahrump Nevada) before they came to Christian Media." insinuating that Defendant/Counter Plaintiff had committed theft and despite the fact that Defendant/Counter Plaintiff never had residence at Pahrump, Nevada}

^53.

^{In paragraph 78 of the article, Plaintiff/Counter Defendant LLOYD ("Lloyd") accuses Defendant/Counter Plaintiff of illegal drug use and wrote "I later learned that during my absence, Craig became decidedly more arrogant towards Susan, and openly walked around the premises smoking marijuana with a pipe that is known as a "bong." No evidence has been offered which would support this accusation. This accusation is repeated in paragraphs 79 and 81.}

^54.

 ^{Plaintiffs/Counter Defendants actions and omissions in paragraphs 2, 5, 8, 9, 10, 12, 13, 14, 16, 18, 19, 20, 22, 23, 24, 27, 33, 35, 36, 37, 38, 39, 42, 45, 47, 48, 53, 58, 59, 60, 62, 63, 66, 66, and 68, constituted improper methods, and were taken with the specifically improper intent of destroying Defendant/Counter Plaintiff's reputation with the listenership of the Beacon of Truth broadcast, to prevent the Plaintiffs/Counter Defendants customers from knowing the truth of Plaintiffs/Counter Defendants culpability as regards the deteriorating health of the Defendant/Counter Plaintiff, and a desire for pecuniary benefit from the supporters of the Defendant/Counter Plaintiff's listenership .}

^55.

^{Plaintiffs/Counter Defendants actions were taken intentionally with the knowledge that Plaintiffs/Counter Defendants actions would damage Defendant/Counter Plaintiff's previously good reputation in the community, and would interfere with any type of support, financial or otherwise the Defendant/Counter Plaintiff's might receive from the listenership of the Defendant/Counter Plaintiff's radio broadcast.}

^56.

^{As a direct and proximate result of Plaintiffs/Counter Defendants defamatory actions, the Defendant/Counter Plaintiff has suffered emotional distress, mental anguish, embarrassment,, injury to reputation, and loss of self esteem and dignity. As compensation, Defendant/Counter Plaintiff should be awarded non economic damages against the Plaintiffs/Counter Defendants in the in the token amount of One (1) Dollar, plus any other amount as to the court seems just.}

^{WHEREFORE, Defendant/Counter Plaintiff prays for judgment in Defendant's/Counter Plaintiff's favor and for an award of costs and disbursements plus any other amount as to the court seems just.}

^{DATED this 3rd day of September, 2004.}

^{_____________________________________}

^{CRAIG PORTWOOD}

^{Defendant in Pro Per}