(Defamation)

(Against All Defendants)

(L) In Chapter 12 of the Book, Defendant Portwood states that Plaintiffs have told the public "this is the only place you can hear the truth" when in fact, Plaintiffs have never made such a statement and have frequently made statements to the contrary.

(M) In  Chapter 12 of the Book, Defendant Portwood claims that anyone that "crosses" Christian Media can expect to be vilified, attacked, falsely accused, stalked, and sometimes assaulted".

(N) In Chapter 12 of the Book, Defendant Portwood claims that Plaintiffs practice "Gnosticism" (an ancient mystical Egyptian tradition), when in fact, Plaintiffs have repeatedly repudiated Gnosticism in print and on the radio.

(0) Defendant Portwood compares Plaintiff Lloyd to the apparently deranged

7- COMPLAINT

kidnapper of Elizabeth Smart, the Utah 14-year old that was snatched out of her bedroom by a man named Brian D. Mitchell. The child was abducted by a former Mormon mystic that molested her. Plaintiffs have never been Mormons, and Plaintiffs are not child molesters.

(P) Christian Media publishes an Internet newsletter that is sent out on a one-time basis to lists of people Plaintiffs think might like it. Occasionally, someone is offended and rather than request deletion from its list, complains about receiving unsolicited material (pejoratively called SP AM in Internet parlance). Because such complaints can cause Plaintiffs to be unfairly kicked off Internet servers even though Plaintiffs stay in strict compliance with all anti-SP AM regulations, on that newsletter, Plaintiffs specifically state they have Websites available for review, but due to threats of a small group of people, the recipient needs to request the net address of those Websites with a reply to Plaintiffs' email. In Chapter 15 of the Book, Defendant Portwood has stated that Plaintiffs do not include the Website contacts because Christian Media is a "cult" that is "hiding doctrine" when the net correspondence itself truly and accurately represents Plaintiffs' doctrine.

(Q) In Chapters 1 and 13 of the Book, Defendant Portwood claims that Plaintiff Lloyd's writings are "required" in order for anyone to be a member of Christian Media. The Christian Media ministry has no "members" and no such statement, written or verbal has ever been disseminated from Christian Media. This assertion is patently false and calculated to characterize Plaintiff Lloyd as a cult leader.

8- COMPLAINT

(R) Christian Media has commercial relations with several shortwave radio broadcast stations. Defendant Portwood wrote that radio station WJIE ended Christian Media's relationship because of venomous on air statements. This statement was calculated to make other stations that Plaintiffs might want to purchase time from to worry that Plaintiffs might say something irresponsible on the air. In Chapter 16 of the Book, Defendant Portwood wrote" . . . James had a commercial association with a 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." This is completely false.

(S) In Chapter 17 of the Book, Defendant Portwood claims that in January of 2003, Plaintiff Lloyd announced that he would begin selling air time to "occult groups" when Plaintiffs have never done any such thing. Plaintiffs have systematically renounced all things occultic in every media they have. This is one of dozens of tactics designed to cause supporters of Christian Media to cease support of their ministry for fear they are contributing to an occultic work.

(T) Plaintiffs sell a health device that produces colloidal silver fluid called a colloidal silver generator. In Chapter 17 of the Book, Defendant Portwood has sought to harm sales of that product with derogatory remarks such as "Never mind the fact that all you are getting is a plastic box with a few wires and 3-9 volt battery attachments inside (batteries not included)." Defendant Portwood omits the fact that Plaintiffs utilize a proven design, include printed instructions, a professionally

9- COMPLAINT

produced audio tape on the subject, and a stock of the pure silver rods needed to produce the colloid compound (enough to last for months). In Chapter 17 of the Book, Defendant Portwood misrepresents the product further by saying that there are no batteries included when every generator Plaintiffs have ever sold has included batteries.

(U) In Chapter 18 of the Book, Defendant Portwood refers to Christian Media when he writes "I have been accused of committing adultery with a sister in Christ. Although we are not having an affair and have been slandered with that charge by those who claim I have, NO EVIDENCE EXISTS TO SUPPORT THE ACCUSATION, I have 'looked upon another woman with lust.' They have used Matthew 5:28 as their proof text, without any proof! have actually done so."

(V) In Chapter 18 of the Book, Defendant Portwood accused Susan Lenox and Plaintiff Lloyd of grand theft auto. Defendant Portwood claims Plaintiffs stopped making payments on a Nissan pickup truck and "a notice informing her [Susan] 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." Defendant Portwood goes on to imply the vehicle in question was reported stolen and "when he drove it, had the police decided to run the VIN, I could have been arrested." The vehicle was never stolen and was never reported as stolen. These statements were plainly contrived to make Plaintiffs look like criminals.

(W) In Chapter 19 of the Book, Defendant Portwood continues his attempt to

10- COMPLAINT

characterize Plaintiffs as law-breakers by referencing a dispute with an adjacent property owner over an easement. In this regard, Defendant Portwood claimed that Plaintiffs' building was done with "no permits" and "denied the poor woman her access". Plaintiffs filed the applications (for two different permits), received the appropriate permits, completed the work in a professional manner, had inspections, and complied with all applicable County requirements.

(X) Defendant Portwood has printed an extensive occultic work propagating evolution and espousing the existence of aliens and attributed it to Plaintiffs in Chapter 20 of the Book. Defendant Portwood writes: "Another teaching James Lloyd has used to make money, maintains that a 'Rogue Planet' will appear and bring about a 'shift' in the magnetic orientation of the poles of planet earth. There is of course, NO BIBLICAL EVIDENCE to support such a statement, but there are MANY OCCULTIC WRITINGS which would concur with his teaching on this portion of end time events. . . . Another proponent of the Planet X scenario is a new age-occult writer Zecharia Sitchen. According to Sitchen in his book on the subject 'the 12th Planet', we must be prepared for the imminent return of an alien race 'who created us some 300.000 years ago'. Rather than criticize James Lloyd's source, why not examine in his own work, an excerpt from his treatise 'THE CASE OF ADAM'S ALIEN GENES' [this makes it look like the lengthy quote which follows was written by Plaintiff Lloyd.] 'In whose image was The Adam - the prototype of modern humans, Homo sapiens - created?' 'The Bible asserts that the Elohim said: "Let us fashion the Adam in our image and after our likeness." But if one is to accept a tentative explanation for enigmatic genes that humans possess, offered when the deciphering of the human genome was announced in mid-February, the feat was decided upon by a group of bacteria!' 'In the evolutionary progression from bacteria to invertebrates (such as the lineages of yeast, worms, flies or mustard weed - which have been deciphered) to vertebrates (mice, chimpanzees) and finally modern humans, these 223 genes are completely missing in the invertebrate phase. Therefore, the scientists can explain their presence in the human genome by a "rather recent" (in evolutionary time scales) "probable horizontal transfer from bacteria." "In other words: At a relatively recent time as Evolution goes, modern humans acquired an extra 223 genes not through gradual evolution, not vertically on the Tree of Life, but horizontally, asa sideways

11 - COMPLAINT

insertion of genetic material from bacteria. . . '. 'But if Man gave those genes to bacteria, where did Man acquire those genes to begin with?' 'Readers of my books must be smiling by now, for they know the answer.'"

(Y) In Chapter 20 of the Book, Defendant Portwood has claimed that the loss of two of Plaintiffs' hosts was because of a prediction Plaintiff Lloyd issued which did not come to pass. Defendant Portwood has also claimed Plaintiff Lloyd lost a shortwave outlet for the same reason. These statements are false. Defendant Portwood states: "Not only has he lost many listeners, but he has also lost two paying network hosts and a shortwave outlet (which gave up more than $4,000 a month) who peered behind the curtain of deception, due to his proud, pompous, prevarication regarding his Feigned Prophecy".

(Z) In Chapter 26 of the Book, Defendant Portwood writes that "Postal fraud. . . is a regular part of the business practice at Christian Media".

(AA) In Chapter 20A (?) of the Book, Defendant Portwood has printed a counterfeit identification of Plaintiff Lloyd indicating it is his driver's license. On his website, Defendant Portwood states that "one lie he tells on a regular basis is that he does not have a driver license." This is accompanied by what represents to be Plaintiff Lloyd's driver's license. Plaintiff Lloyd does not have a driver's license. The driver's license has the wrong birth date, and expiration date, so it is derived from someone else's driver's license apparently with a cut and paste of Plaintiff Lloyd's photograph.

(BB) Defendant Portwood has placed several old civil collection suits involving Plaintiff Lloyd on his website, citing collection actions - (Southern Oregon Credit

12 - COMPLAINT

Service, Jackson County, and GMAC) that were filed against Plaintiff Lloyd. Defendant Portwood trumpets the statement "the issue seems not to have been James' righteousness, but a failure on Lloyd's part to honor his promise to pay MONEY!"

(CC) In Chapter 23 of the Book, Defendant Portwood placed file numbers and statements concerning criminal arrests for auto theft and for Driving Under the Influence on his web site pertaining to Plaintiff Lloyd. Both charges were dropped and Plaintiff Lloyd was completely exonerated - but those facts were omitted.

(DD) Repeated posts are made on the CMWF by Defendant Portwood. Under a bold heading dated March 24, 2004, the headline blares in large letters "LIFE THREATENING PRODUCTS MARKETED BY JAMES LLOYD." The posting continues to libel Christian Media when it states "Lloyd knowingly packaged and sold a defective and dangerous product." (CMWF 3/24/04.)

(EE) On a CMWF posting, a legitimate news article written by one Christina Almeida of the Associated Press is posted on March 25,2004. The article deals with the federal grand jury indictment of anti-tax author Irwin Schiff. Defendant Portwood has changed the large headline to read "Clown organization operates like CMN with bogus charges." (CMN being a widely recognized acronym for the Christian Media Network). (CMWF 3/25/04.)

(FF) On a CMWF posting, CMN host John "Doc" Franz is accused of snorting cocaine while he broadcasts a daily news program he hosts for Christian Media. In this essay, Defendant Portwood also implies that Plaintiff Lloyd takes Cocaine. Here is the quote concerning John Franz: "Then he inhales deeply - pulling for all to hear what sounds to be nostril substances. It is difficult to determine if he is merely imitating his idol James Lloyd or if he is a user ofthe 'MSM' white powder that Lloyd uses also." (CMWF 4/16/04.)

(GG) On the Christian Media Watch Forum (CMWF), there are repeated posts that represent to be written by Plaintiff Lloyd, when in fact they are written by Defendant Portwood. These posts have "Plaintiff Lloyd" making embarrassing statements.

(HH) On a CMWF posting dated 9/23/03, Defendant Portwood states that Plaintiff Lloyd is consuming Cocaine. The relevant quote is "James has been consuming a lot of nose candy of late and sometimes he says things that he doesn't mean to say." The article continues to represent that it was written by someone within the ministry when it says "Here at CMN we are concerned. . . ". The drug theme is rampant as the article says "Listen for James sniffling between his words and maybe you get a sense of what we are up against here folks."

(II) On a CMWF posting dated 11/4/03, the heading reads "On The Air Snorting." There are three posts representing to be written by Plaintiff Lloyd, but are in fact written by Defendant Portwood.. One of them states: "When Susan and I first met we both were in love with this substance as we still are . . .".

(JJ) Numerous web site articles have been posted by Defendant Portwood on CMWF falsely representing they are from Plaintiff Lloyd. 09/24/03 - "Let me say this here and now, I have always made a profit in this ministry and the bottom line has

14 - COMPLAINT

always been uppermost;" 08/12/03 -" . . . I was under the influence of a substance which originated in South America and was ingested through my nostrils;" 1 0/27/03 - references statements concerning "this definitive work from me, the incomparable James Lloyd® ."

(KK) On the CMWF posting dated 08/12/03, a Defendant Portwood post claims to originate with Rick Walters stating "Thanks for the recognition, James. It goes without saying that I would do anything for you." Similar posts representing they are from Rick Walters occurred on 07/14/03, 07/30/03, 08/02/03, 08/05/03, etc.

(LL) On a CMWF posting dated 10/18/03 written by Defendant Portwood, he states that Susan Lenox and Kristin Lenox are both on drugs. Defendant Portwood accuses Kristin of being suicidal and addicted to Prozac. The quote, referencing Susan's alleged drug use, refers to "Susan Lenox (and her suicidal, Prozac® addicted sister Kristin) . . . ".

(MM) On a Tribulation Chronicles forum (TC) posting from Defendant Portwood dated 1 0/01/03 falsely reported to be written by Plaintiff Lloyd, the post claims that "my ex wife would not go to the length that Miss Lenox has. There have been times when I was out of blow (cocaine) and Susan came through in a pinch." (TC, You Should All Be Ashamed Of Your Actions, 10/01/03.)

(NN) On a dozen posts of TC from Defendant Portwood, the opening paragraph reads ". . . many of us are under a lot of stress here at the secret mountain place due to a shortage of prozac and beer."

(00) A TC post from Defendant Portwood falsely representing to be from Plaintiff

15- COMPLAINT

Lloyd states "Having listened to .the National Review and other political programs for many years while stoned on Coke, 1 have learned. . . ". (TC Day Eight-The UmFactor,7/12/03.)

(PP) On the TC 11/11/03 post, Defendant Portwood claims that Christian Media will ordain others through another ministry known as ordination.org. The post says "do you know about our ordination program that is now associated with CMN? ... You can learn more about this by going to http://www.ordination.org/media.htm Christian Media has no such ordination program and no affiliation with the mentioned web site. (TC, Trenchcoat Kirke and ord dot org, 11/11/2003.)

(QQ) On the CMWF posting 11/04/03 from Defendant Portwood, the headline story banner reads "Lloyd And Coke Snorting" In the body of the "story" we find the following statement: "I suspect that CMN is nothing more than a money laundering operation for the cocaine trade and that an investigation should ensue immediately. "

(RR) Many emails have been sent to many people as though they were sent by Christian Media hosts and friends. One email was a complete copy of Plaintiffs' Internet newsletter Christian Media CURRENTS. The entire format was counterfeited by Defendant Portwood (color, borders, fonts, etc) to make it look like it came from Plaintiff's ministry. The article was written by Defendant Portwood posing as Plaintiff Lloyd. Statements such as "I have become so obsessed by my own sense of self-importance, that 1 can no longer be trusted to do the right thing" and "I have determined that personal flattery is the most effective way to manipulate

16 - COMPLAINT

people into doing my will" are commonplace throughout.

On CMWF post of 8/19/03, the post attacking Plaintiff Lloyd is stated to be from "anonymous", but is in fact from Defendant Portwood. This post states:, "James Lloyd - calls it as he sees it . . . and if he doesn't see it, he makes it up . . . or changes it . . . whichever seems more profitable at the time."

(TT) There are counterfeit posts on CMWF written by Defendant Portwood that represent themselves as written by Christian Media volunteer Claire Mason (8/2/2003), CMN host Tom Collins (08/05/03), and former CMN host Stewart Best 08/16/03) in addition to the many posts representing themselves as from Susan Lenox, Petitioner Lloyd, Rick Walters, Kirke Wise, and Ralph Haaff.

(UU) Posts from Defendant Portwood mock CMN and state that we're all out of "Prozac and Beer." The alleged beer drinking by Susan is a regular theme originating with Defendant Portwood as is the Prozac accusation aimed at Susan's sister Kristin.

(VV) Defendant Portwood equates the Plaintiffs with the devil.

(WW) On the CMWF posting of 8/25/03 from Defendant Portwood entitled One Picture, A Thousand Words, the main story text says "Has anyone Been to httm.://network54.com/forum256626 A Road Sign That Is Pictured There That is Quite A Revelation". When going to the link, the image is of Plaintiff Lloyd, so it is evident the image has been changed as there is no "road sign." The "road sign" in question is a doctored Interstate highway sign that has been altered to read

"Lloyd Expwy To Sheardom" with the highway numbers changed to read "666".

17 - COMPLAINT

17.

The false statements set forth in paragraph 14 above were published by Defendants to thousands of people over the Internet, and were also published by Defendants to thousands of 5 people who listened to the Defendants' radio program.

16.

The statements made by Defendants as alleged in paragraph 14 above were false, defamatory, and unprivileged, and tended to subject Plaintiffs to hatred, contempt, ridicule and diminish the respect, good will, confidence and esteem in which the Plaintiffs were held in the community and/or excited adverse, derogatory, or unpleasant feelings, opinions of or concerning Plaintiffs. Defendants actually intended to defame the Plaintiffs, and Defendants had actual knowledge of the falsity of the statements they made, but continued to make them anyway.

17.

These statements as alleged also imputed the unfitness or lack of integrity of the Plaintiffs', prejudiced the Plaintiffs in their trade or profession; and/or implied that the Plaintiffs committed crimes involving moral turpitude and other misconduct. Therefore these statements are defamatory per se, whereby special damages need not be proved.

18.

As a direct and proximate result of the unprivileged, defamatory false statements, the Plaintiffs have suffered loss of business, loss of clientele, loss of profits, sponsorships, and donations, for total economic damages in the amount of$100,000.00.

19.

As a further direct and proximate result of Defendants' defamatory statements, Plaintiffs

18 - COMPLAINT

have suffered emotional distress, mental anguish, embarrassment, injury to reputation, and loss of self esteem and dignity for total non economic damages for emotional distress in an amount approximately equal to $100,000.00.

(Intentional Interference with Economic Relations)

(Against All Defendants)

20.

Plaintiffs reallege paragraphs 1 through 19 of this Complaint as if set forth fully herein.

21.

At all material times herein, Plaintiffs had an economic relationship with the listeners, clients, customers, hosts, financial supporters, and associates of Christian Media Network who listened to the program and purchased products from Christian Media, and gave donation or provided financial assistance or sponsorship to Christian Media.

22.

Between on or about May of 2002, to the present, Defendants took the following acts and omissions, or knowingly substantially aided and assisted Defendant Portwood in taking the following acts and omissions:

(A)

Published an online 27 chapter book on Defendant Portwood's website, originally entitled "Liars for the Lloyd", which is now presently entitled "The Hidden History of Christian Media Network", which contains multiple claims which are

patently false and were brazenly fabricated by the Defendants. A copy of this 27 chapter work (hereafter the "Book") is attached to this Complaint as Exhibit "A" and is incorporated into the Complaint herein by this reference. The Book has

19 - COMPLAINT

been published to thousands of people who have accessed Defendant Portwood's web site.

(B) In Chapter 5 of the Book, Defendant Portwood writes that when a sizable donation came in to support Christian Media, "James [Lloyd] kept the whole thing". This is untrue, and is a brazen lie made to convince others not to donate to

Christian Media.

(C) In Chapter 6 of the Book, Defendant Portwood claims that Plaintiffs publicly accused him of "having sex with fairies".

(D) Defendant Portwood claims that Linda Kristich's seven year old son "was threatened by a network host".

(E) In Chapter 7 of the Book, Defendant Portwood claims that Plaintiff s wife Susan was drunk "on a daily basis".

(F) In Chapter 7 of the Book, Defendant Portwood tried to manipulate a fight between two Christian Media hosts in an effort to create strife between two separate Christian Media clients.

(G) In Chapter 9 of the Book, Defendant Portwood printed Plaintiff Lloyd's private telephone number to cause him to receive unwanted telephone calls. In the place where Defendant Portwood printed Plaintiff Lloyd's private telephone number, Defendant Portwood acknowledged it was Plaintiff Lloyd's "private number".

(H) Christian Media distributes a high-end Swiss made water filter called a Katadyn for health purposes. In Chapter 11 of the Book, Defendant Portwood claims Plaintiffs were overcharging for their filter, and indicated the markup

20 - COMPLAINT

demonstrates Plaintiffs' greed. The suggested list price on the filter in question is commonly charged by virtually all outlets handling this particular unit. Plaintiffs sell it for the same suggested list price of $220.00, plus shipping. Defendant Portwood states the "Katadyn water filter costs him about $75.00" which is patently false. This is plainly calculated to make Plaintiffs appear incredibly greedy, when in fact, Plaintiffs' markup is about average for such products.

(I) Defendant Portwood claims that Christian Media uses new age, propaganda, cult, and brainwashing techniques, when in fact, Christian Media has broadcast many programs specifically denouncing all of these tactics.

(J) In Chapter 12 of the Book, Defendant Portwood claims Christian Media's teachings led to an "assault with a deadly weapon" when no such assault has ever occurred.

(K) In Chapter 12 of the Book, Defendant Portwood claims that one man that refused to "accept the authority" of the ministry [Christian Media], led to "a violent attack" when no attack ever occurred. Similarly, in a post on the Portwood owned forum, Christian Media Watch Forum ("CMWF"), Defendant Portwood edited and allowed the following statement concerning Rick Walters: " . . . who tries to kill non-violent and non-aggressive joggers with an axehandle." (CMWF 08/06/03.) Plaintiffs believe that Defendant Portwood wrote this statement using a fictitious name.

(L) In Chapter 12 of the Book, Defendant Portwood states that Plaintiffs have told the public "this is the only place you can hear the truth" when in fact, Plaintiffs have

21 - COMPLAINT

never made such a statement and have frequently made statements to the contrary.

(M) In Chapter 12 of the Book, Defendant Portwood claims that anyone that "crosses" Christian Media can expect to be vilified, attacked, falsely accused, stalked, and sometimes assaulted".

(N) In Chapter 12 of the Book, Defendant Portwood claims that Plaintiffs practice "Gnosticism" (an ancient mystical Egyptian tradition), when in fact, Plaintiffs have repeatedly repudiated Gnosticism in print and on the radio.

(O) Defendant Portwood compares Plaintiff Lloyd to the apparently deranged kidnapper of Elizabeth Smart, the Utah 14-year old that was snatched out of her bedroom by a man named Brian D. Mitchell. The child was abducted by a former Mormon mystic that molested her. Plaintiffs have never been Mormons, and Plaintiffs are not child molesters.

(P) Christian Media publishes an Internet newsletter that is sent out on a one-time basis to lists of people Plaintiffs think might like it. Occasionally, someone is offended and rather than request deletion from its list, complains about receiving

unsolicited material (pejoratively called SPAM in Internet parlance). Because such complaints can cause Plaintiffs to be unfairly kicked off Internet servers even though Plaintiffs stay in strict compliance with all anti-SP AM regulations, on that

newsletter, Plaintiffs specifically state they have Websites available for review, but due to threats of a small group of people, the recipient needs to request the net address of those Websites with a reply to Plaintiffs' email. In Chapter 15 of the Book, Defendant Portwood has stated that Plaintiffs do not include the Website

22 - COMPLAINT

contacts because Christian Media is a "cult" that is "hiding doctrine" when the net correspondence itself truly and accurately represents Plaintiffs' doctrine.

(Q) In Chapters 1 and 13 of the Book, Defendant Portwood claims that Plaintiff Lloyd's writings are "required" in order for anyone to be a member of Christian Media. The Christian Media ministry has no "members" and no such statement, written or verbal has ever been disseminated from Christian Media. This assertion is patently false and calculated to characterize Plaintiff Lloyd as a cult leader.

(R) Christian Media has commercial relations with several shortwave radio broadcast stations. Defendant Portwood wrote that radio station WJIE ended Christian Media's relationship because of venomous on air statements. This statement was calculated to make other stations that Plaintiffs might want to purchase time from to worry that Plaintiffs might say something irresponsible on the air. In Chapter 16 of the Book, Defendant Portwood wrote" . . . James had a commercial association with a 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." This is completely false.

(S) In Chapter 17 of the Book, Defendant Portwood claims that in January of 2003, Plaintiff Lloyd announced that he would begin selling air time to "occult groups" when Plaintiffs have never done any such thing. Plaintiffs have systematically

renounced all things occultic in every media they have. This is one of dozens of tactics designed to cause supporters of Christian Media to cease support of their ministry for fear they are contributing to an occultic work.

23 - COMPLAINT

(T) Plaintiffs sell a health device that produces colloidal silver fluid called a colloidal silver generator. In Chapter 17 of the Book, Defendant Portwood has sought to harm sales of that product with derogatory remarks such as "Never mind the fact that all you are getting is a plastic box with a few wires and 3-9 volt battery attachments inside (batteries not included)." Defendant Portwood omits the fact that Plaintiffs utilize a proven design, include printed instructions, a professionally produced audio tape on the subject, and a stock of the pure silver rods needed to produce the colloid compound (enough to last for months). In Chapter 17 of the Book, Defendant Portwood misrepresents the product further by saying that there are no batteries included when every generator Plaintiffs have ever sold has included batteries.

(U) In Chapter 18 of the Book, Defendant Portwood refers to Christian Media when he writes "I have been accused of committing adultery with a sister in Christ. Although we are not having an affair and have been slandered with that charge by those who claim I have, NO EVIDENCE EXISTS TO SUPPORT THE ACCUSATION, I have 'looked upon another woman with lust.' They have used Matthew 5:28 as their proof text, without any proof! have actually done so."

(V) In Chapter 18 of the Book, Defendant Portwood accused Susan Lenox and Plaintiff Lloyd of grand theft auto. Defendant Portwood claims Plaintiffs stopped making payments on a Nissan pickup truck and "a notice informing her [Susan]

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." Defendant Portwood goes on to imply the vehicle in question was reported stolen and "when he drove it, had the police decided to run the VIN, I could have been arrested." The vehicle was never stolen and was never reported as stolen. These statements were plainly contrived to make Plaintiffs look like criminals.

(W) In Chapter 19 of the Book, Defendant Portwood continues his attempt to characterize Plaintiffs as law-breakers by referencing a dispute with an adjacent property owner over an easement. In this regard, Defendant Portwood claimed that Plaintiffs' building was done with "no permits" and "denied the poor woman her access". Plaintiffs filed the applications (for two different permits), received the appropriate permits, completed the work in a professional manner, had inspections, and complied with all applicable County requirements.

(X) Defendant Portwood has printed an extensive occultic work propagating evolution and espousing the existence of aliens and attributed it to Plaintiffs in Chapter 20 of the Book. Defendant Portwood writes:

"Another teaching James Lloyd has used to make money, maintains that a 'Rogue Planet' will appear and bring about a 'shift' in the magnetic orientation of the poles of planet earth. There is of course, NO BIBLICAL EVIDENCE to

support such a statement, but there are MANY OCCULTIC WRITINGS which would concur with his teaching on this portion of end time events. . . . Another proponent of the Planet X scenario is a new age-occult writer Zecharia Sitchen. According to Sitchen in his book on the subject 'the 12th Planet', we must be prepared for the imminent return of an alien race 'who created us some 300,000 years ago"'. Rather than criticize James Lloyd's source, why not examine in his

25 - COMPLAINT

own work, an excerpt from his treatise THE CASE OF ADAM'S ALIEN GENES' [this makes it look like the lengthy quote which follows was written by Plaintiff Lloyd.]  'In whose image was The Adam - the prototype of modern humans, Homo sapiens - created?' 'The Bible asserts that the Elohim said: "Let us fashion the Adam in our image and after our likeness." But if one is to accept a tentative explanation for enigmatic genes that humans possess, offered when the deciphering of the human genome was announced in mid-February, the feat was decided upon by a group of bacteria!' 'In the evolutionary progression from bacteria to invertebrates (such as the lineages of yeast, worms, flies or mustard weed - which have been deciphered) to vertebrates (mice, chimpanzees) and

finaZZv modern humans, these 223 genes are completely missing in the invertebrate phase. Therefore, the scientists can explain their presence in the human genome by a "rather recent" (in evolutionary time scales) "probable horizontal transfer from bacteria." "In other words: At a relatively recent time as Evolution goes, modem humans acquired an extra 223 genes not through gradual evolution, not vertically on the Tree of Life, but horizontally, asa sideways insertion of genetic material from bacteria. . . '. 'But if Man gave those genes to bacteria, where did Man acquire those genes to begin with?' 'Readers of my books must be smiling by now, for they know the answer. ",

(Y) In Chapter 20 of the Book, Defendant Portwood has claimed that the loss of two of Plaintiffs' hosts was because of a prediction Plaintiff Lloyd issued which did not come to pass. Defendant Portwood has also claimed Plaintiff Lloyd lost a shortwave outlet for the same reason. These statements are false. Defendant Portwood states: "Not only has he lost many listeners, but he has also lost two paying network hosts and a shortwave outlet (which gave up more than $4,000 a month) who peered behind the curtain of deception, due to his proud, pompous, prevarication regarding his Feigned Prophecy".

(Z) In Chapter 26 of the Book, Defendant Portwood writes that "Postal fraud. . . is a regular part of the business practice at Christian Media".

(AA) In Chapter 20A of the Book, Defendant Portwood has printed a counterfeit identification of Plaintiff Lloyd indicating it is his driver's license. On his

26 - COMPLAINT

website, Defendant Portwood states that "one lie he tells on a regular basis is that he does not have a driver license." This is accompanied by what represents to be Plaintiff Lloyd's driver's license. Plaintiff Lloyd does not have a driver's license. The driver's license has the wrong birth date, and expiration date, so it is derived from someone else's driver's license apparently with a cut and paste of Plaintiff Lloyd's photograph.

(BB) Defendant Portwood has placed several old civil collection suits involving Plaintiff Lloyd on his website, citing collection actions - (Southern Oregon Credit Service, Jackson County, and GMAC) that were filed against Plaintiff Lloyd. Defendant Portwood trumpets the statement "the issue seems not to have been James' righteousness, but a failure on Lloyd's part to honor his promise to pay MONEY!"

(CC) In Chapter 23 of the Book, Defendant Portwood placed file numbers and statements concerning criminal arrests for auto theft and for Driving Under the Influence on his website pertaining to Plaintiff Lloyd. Both charges were dropped

and Plaintiff Lloyd was completely exonerated - but those facts were omitted.

(DD) Repeated posts are made on the CMWF by Defendant Portwood. Under a bold heading dated March 24,2004, the headline blares in large letters "LIFE THREATENING PRODUCTS MARKETED BY JAMES LLOYD." The posting continues to libel Christian Media when it states "Lloyd knowingly packaged and sold a defective and dangerous product." (CMWF 3/24/04.)

(EE) On a CMWF posting, a legitimate news article written by one Christina Almeida

27 - COMPLAINT

of the Associated Press is posted on March 25,2004. The article deals with the federal grand jury indictment of anti-tax author Irwin Schiff. Defendant Portwood has changed the large headline to read "Clown organization operates like CMN with bogus charges." (CMN being a widely recognized acronym for the Christian Media Network). (CMWF 3/25/04.)

(FF) On a CMWF posting, CMN host John "Doc" Franz is accused of snorting cocaine while he broadcasts a daily news program he hosts for Christian Media. In this essay, Defendant Portwood also implies that Plaintiff Lloyd takes Cocaine. Here is the quote concerning John Franz: "Then he inhales deeply - pulling for all to hear what sounds to be nostril substances. It is difficult to determine if he is merely imitating his idol James Lloyd or if he is a user of the 'MSM' white powder that Lloyd uses also." (CMWF 4/16/04.)

(GG) On the Christian Media Watch Forum (CMWF), there are repeated posts that represent to be written by Plaintiff Lloyd, when in fact they are written by Defendant Portwood. These posts have "Plaintiff Lloyd" making embarrassing statements.

(HH) On a CMWF posting dated 9/23/03, Defendant Portwood states that Plaintiff Lloyd is consuming Cocaine. The relevant quote is "James has been consuming a lot of nose candy of late and sometimes he says things that he doesn't mean to say." The article continues to represent that it was written by someone within the ministry when it says "Here at CMN we are concerned. . . ". The drug theme is rampant as the article says "Listen for James sniffling between his words and

maybe you get a sense of what we are up against here folks."

(II) On a CMWF posting dated 11/4/03, the heading reads "On The Air Snorting." There are three posts representing to be written by Plaintiff Lloyd, but are in fact written by Defendant Portwood.. One of them states: "When Susan and I first met we both were in love with this substance as we still are . . .".

(JJ) Numerous web site articles have been posted by Defendant Portwood on CMWF falsely representing they are from Plaintiff Lloyd. 09/24/03 - "Let me say this here and now, I have always made a profit in this ministry and the bottom line has always been uppermost;" 08/12/03 -" . . . I was under the influence of a substance which originated in South America and was ingested through my nostrils;" 10/27/03 - references statements concerning "this definitive work from me, the incomparable James Lloyd.® "

(KK) On the CMWF posting dated 08/12/03, a Defendant Portwood post claims to originate with Rick Walters stating "Thanks for the recognition, James. It goes without saying that I would do anything for you." Similar posts representing they are from Rick Walters occurred on 07/14/03, 07/30/03, 08/02/03, 08/05/03, etc.

(LL) On a CMWF posting dated 10/18/03 written by Defendant Portwood, he states that Susan Lenox and Kristin Lenox are both on drugs. Defendant Portwood accuses Kristin of being suicidal and addicted to Prozac. The quote, referencing Susan's alleged drug use, refers to "Susan Lenox (and her suicidal, Prozac® addicted sister Kristin) . . . ".

(MM) On a Tribulation Chronicles forum (TC) posting from Defendant Portwood dated

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10/01/03 falsely reported to be written by Plaintiff Lloyd, the post claims that "my ex wife would not go to the length that Miss Lenox has. There have been times when I was out of blow (cocaine) and Susan came through in a pinch." (TC, You Should All Be Ashamed Of Your Actions, 10/01/03.)

(NN) On a dozen posts of TC from Defendant Portwood, the opening paragraph reads ". . . many of us are under a lot of stress here at the secret mountain place due to a shortage of prozac and beer."

(00) A TC post from Defendant Portwood falsely representing to be from Plaintiff Lloyd states "Having listened to the National Review and other political programs for many years while stoned on Coke, I have learned. . . ". (TC Day Eight-The UmFactor,7/12/03.)

(PP) On the TC 11/11/03 post, Defendant Portwood claims that Christian Media will ordain others through another ministry known as ordination.org. The post says "do you know about our ordination program that is now associated with CMN? ...You can learn more about this by going to http://www.ordination.org/media.htm Christian Media has no such ordination program and no affiliation with the mentioned website. (TC, Trenchcoat Kirke and ord dot org, 11/11/2003.)

(QQ) On the CMWF posting 11/04/03 from Defendant Portwood, the headline story banner reads "Lloyd And Coke Snorting" In the body of the "story" we find the following statement: "I suspect that CJ\1N is nothing more than a money

laundering operation for the cocaine trade and that an investigation should ensue immediately."

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(RR) Many emails have been sent to many people as though they were sent by Christian Media hosts and friends. One email was a complete copy of Plaintiffs' Internet newsletter Christian Media CURRENTS. The entire format was counterfeited by Defendant Portwood (color, borders, fonts, etc) to make it look like it came from Plaintiff's ministry. The article was written by Defendant Portwood posing as Plaintiff Lloyd. Statements such as "I have become so obsessed by my own sense of self-importance, that I can no longer be trusted to do the right thing" and "I have determined that personal flattery is the most effective way to manipulate people into doing my will" are commonplace throughout.

(SS) On CMWF post of 8/19/03, the post attacking Plaintiff Lloyd is stated to be from "anonymous", but is in fact from Defendant Portwood. This post states:, "James Lloyd - calls it as he sees it . . . and if he doesn't see it, he makes it up. . . or changes it . . . whichever seems more profitable at the time."

(TT) There are counterfeit posts on CMWF written by Defendant Portwood that represent themselves as written by Christian Media volunteer Claire Mason (8/2/2003), CMN host Torn Collins (08/05/03), and former CIv1N host Stewart Best 08/16/03) in addition to the many posts representing themselves as from Susan Lenox, Petitioner Lloyd, Rick Walters, Kirke Wise, and Ralph Haaff.

(UU) Posts from Defendant Portwood mock CMN and state that we're all out of "Prozac and Beer." The alleged beer drinking by Susan is a regular theme originating with Defendant Portwood as is the Prozac accusation aimed at Susan's sister Kristin.

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(VV) Defendant Portwood equates the Plaintiffs with the devil.

(WW) On the CMWF posting of 8/25/03 from Defendant Portwood entitled One Picture, A Thousand Words, the main story text says "Has anyone Been to http://network54.comlforum256626 A Road Sign That Is Pictured There That is Quite A Revelation". When going to the link, the image is of Plaintiff Lloyd, so it is evident the image has been changed as there is no "road sign." The "road sign" in question is a doctored Interstate highway sign that has been altered to read

"Lloyd Expwy To Sheardon" with the highway numbers changed to read "666".

23.

Defendants' actions and omissions in paragraph 22 above constituted improper methods, and directly interfered with the Plaintiffs then existing economic relationship with others, including but not limited to, clients, customers, hosts, financial supporters, and all other associates of Christian Media.

24.

Defendants' actions were not motivated with the intent to serve a purpose of Plaintiffs, but instead were taken with the specifically improper intent of interfering with Plaintiffs' existing economic relationship with those associated with Christian Media, because of a personal vendetta and resentment against Plaintiffs, a retaliatory motive, a desire for pecuniary benefit, because Plaintiffs had severed their ties with Defendant Portwood and refused to condone his affair.

25.

Defendants' actions were taken with the knowledge that the interference with the

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Plaintiffs' existing and prospective economic relationship with associates of Christian Media was a necessary consequence of such actions and certain to occur.

26.

As a direct and proximate result of Defendants' actions constituting intentional interference with Plaintiffs' economic relations, Plaintiffs have sustained loss of business, loss of profits, loss of sponsorships, and donations. Plaintiffs have suffered economic damages in an amount approximately equal to $100,000.00.

27.

As a further direct and proximate result of Defendants' intentional interference with Plaintiffs' economic relations, Plaintiffs have suffered emotional distress, mental anguish, embarrassment, injury to reputation, loss of self esteem and dignity. As compensation, Plaintiffs should be awarded non economic damages against Defendants in the amount approximately equal to $100,000.00.

(Injunctive Relief)

(Against All Defendants)

28.

Plaintiffs reallege paragraphs 1 through 27 of this Complaint as if set forth fully herein

29.

The Plaintiffs have no plain, speedy, or adequate remedy at law because the Defendants persist in continuing to publish false and defamatory statements on their beaconoftruth.com, Tribulation Chronicles, and Christian Media Watch Forum websites, and on their radio show, Beacon of Truth. Because the Defendants continue to intentionally defame and interfere with the

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Plaintiffs' business, the Plaintiffs seek a temporary, preliminary, and permanent injunction restraining, enjoining the Defendants from publishing any information about the Plaintiffs, and/or referring to the Plaintiffs on the Defendants' radio program or Defendants' websites beaconoftruth.com, the Tribulation Chronicles, and the Christian Media Watch Forum, and/or restraining and enjoining the Defendants from publishing or disseminating the 27 chapter book entitled The Hidden History of the Christian Media Network, attached as Exhibit "A" on any web site, forum or publishing to any third party.

30.

Plaintiffs further seek a Writ of Assistance from the Sheriff in enforcing the injunctive relief requested above and requiring the confiscation of the Defendants' computer hardware, software, and network technology enabling Defendants to continue to publish the defamatory matter on the Beacon of Truth website, Tribulation Chronicles, and the Christian Media Watch Forum.

WHEREFORE, the Court should grant judgrnent in favor of the Plaintiffs and against Defendants and issue an order and judgment for the following relief:

1. An award of economic damages on Plaintiffs' claims against the Defendants in the amount of$100,000.00;

2. An award of non-economic damages on Plaintiffs' claims against the Defendants in the amount of$100,OOO.00;

3. The Plaintiffs seek a temporary, preliminary, and permanent injunction restraining, enjoining the Defendants from publishing any information about the Plaintiffs, and/or referring to the Plaintiffs on the Defendant's radio program or Defendants' websites

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beaconoftruth.com, the Tribulation Chronicles, and the Christian Media Watch Forum, and/or restraining and enjoining the Defendants from publishing or disseminating the 27 chapter book entitled The Hidden History of the Christian Media Network, attached as Exhibit "A" on any website, forum or publishing to any third party. Plaintiffs further seek a Writ of Assistance from the Sheriff in enforcing the injunctive relief requested above and also requiring the confiscation of the Defendants' computer hardware, software, and network technology enabling Defendants to continue to publish the defamatory matter on the Beacon of Truth website, Tribulation Chronicles, and the Christian Media Watch Forum.

4. An award of post judgment interest against Defendants on all of Plaintiffs' claims at the maximum rate permitted by law until such time as all amounts, damages, and awards have been satisfied; and

5. An award of Plaintiffs' costs and disbursements and such other relief as the Court may deem appropriate to accomplish substantial justice.