2. In approximately late 1996 or early 1997, Defendant/Counter Plaintiff began listening to shortwave radio hosts Steve Quayle on the "Blueprint for Survival" broadcast and Pastor David Lankford on his "Voice of Evangelism" broadcast. Defendant/Counter Plaintiff made regular donations of money to both of them.

3. In about spring of 2000, both men began buying radio time from Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK and Defendant/Counter plaintiff began listening to Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK at that time.

4. In January of 2001, both Pastor Lankford and Steve Quayle left CHRISTIAN MEDIA NETWORK and after CHRISTIAN MEDIA NETWORK co-owner James Lloyd began accusing both men of sinful practices and behaviors, and of being "in league with the Devil" on Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK. As a result of the accusations made by CHRISTIAN MEDIA NETWORK against Steve Quayle and Pastor Lankford Defendant/Counter Plaintiff stopped making donations to Pastor Lankford and Steve Quayle and began donating money to and purchasing products from Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK.

5. In or about July 2001, Defendant/Counter Plaintiff received a letter from CHRISTIAN MEDIA NETWORK co-owner and Plaintiff/Counter Defendant Susan Lenox which accused Defendant/Counter Plaintiff of using inappropriate language during a call in broadcast on the network. Knowing that Defendant/Counter Plaintiff had done no such thing, Defendant/Counter Plaintiff began to have serious doubts about the spiritual claims of Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK, and aside from a $100.00 cash donation given to James Lloyd in August 2001 at a "Prophecy" conference in Lansing Michigan, Defendant/Counter Plaintiff stopped giving donations to CHRISTIAN MEDIA NETWORK at that time.

6.On or about August 2002 after becoming friends with Craig Portwood, certain representatives of CHRISTIAN MEDIA NETWORK began broadcasting unsubstantiated statements about me which were sanctioned by Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK to the effect that Defendant/Counter plaintiff was an "adulteress" and similar slurs.

7. On or about October 18, 2002, Plaintiff/Counter Defendant JAMES LLOYD began making unsubstantiated allegations about the me on Plaintiff/Counter Defendant James Lloyd’s radio program "The Apocalypse Chronicles during which he falsely stated that the Defendant/Counter Plaintiff is an "adulteress", and stated falsely that Defendant/Counter Plaintiff "ran off with" Craig Portwood and that Defendant/Counter Plaintiff was "going to court trying to get the money from the inheritance that the husband got".

8. On the same October 18, 2002, broadcast Plaintiff/Counter Defendant James Lloyd encouraged his listeners to read the article and stated: "you can go to CHRISTIAN MEDIA DAILY DOT COM, and our cover story is there, available for all to see." which was posted in the same form on his website located at www.christianmediaresearch.com since May 2005. Since that time James Lloyd and Susan Lenox dba CHRISTIAN MEDIA NETWORK published two other defamatory articles which accused me of being and "adulteress" and similar slurs, and published statements to the effect that I was engaged "legal wrangling" and making "efforts to coerce half of Linda’s then husband’s substantial inheritance from his late mother’s estate."

9. Similar statements were published by James Lloyd and Susan Lenox dba CHRISTIAN MEDIA NETWORK which implied that my ex-husband had testified under oath in Court that the defamatory comments published about me by James Lloyd and Susan Lenox dba CHRISTIAN MEDIA NETWORK were true.

10. Representatives of Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK began stapling posters bearing an edited photograph of me taken with Craig Portwood to hundreds of telephone poles in and around the vicinity along Michigan State Highway M-29 where I lived in an attempt to embarrass me. These posters stated in 15 point bold type "NOTICE OF ADULTERY LINDA KRISTICH & CRAIG PORTWOOD."

These posters further stated in 19 point bold type, "REPENT AND STOP THE WHORING".

11. These posters were visible to thousands of people who used the highway each day, and had been placed on telephone poles along both directions of Michigan State Highway M-29 from Bethuy Road where CHRISTIAN MEDIA NETWORK representatives Ralph and Kathy Haaff lived, to Marine City Michigan, a distance of more than 20 miles. There were also several posters placed on poles visible to the hundreds of people in automobiles waiting to board the ferry to Harsens Island each day where Defendant/Counter Plaintiff lived.

12. On, before, or about January 2003, Defendant/Counter Plaintiff’s husband received a large envelope represented to be from CHRISTIAN MEDIA NETWORK and exclaimed in Defendant/Counter Plaintiff’s hearing "I’ve got her now!", indicating that there was information which would be of some help to Defendant/Counter Plaintiff’s husband in the divorce action. This was confirmed when I was later told by my daughter that the package had been sent by James Lloyd.

13. In August and September of 2004, I mailed three demand for retraction letters to CHRISTIAN MEDIA NETWORK. The first which was stolen and is listed as undelivered by the Jacksonville Post Office, came into possession of James Lloyd. He admitted taking the letter but refused to sign the receipt which was destroyed unsigned. The Jacksonville Post Office cannot verify delivery of that letter. The other two were ignored by CHRISTIAN MEDIA NETWORK.

14. James Lloyd has since made several threatening and harassing gestures against me including hiring Private Investigators to stakeout my home and approach me on behalf of CHRISTIAN MEDIA NETWORK, driving up to my home on February 23, 2005, even making harassing telephone calls to my home the following day.

15. James Lloyd and Susan Lenox have published false statements which suggest that my ex-husband made statements under oath which support their published statements that I am a "Liar", have a "Spirit of Evil", am an "adulteress" , brought my son to a Motel to "be with Craig Portwood", that I battled my husband "for his substantial inheritance monies", was involved in a "relationship that was clearly improper" , that I "visited in the evenings " with Craig Portwood, that I was planning to "build a house somewhere in the vicinity of Christian Media", that I was involved in a "looming scandal", that I was "engaging in an adulterous relationship", that "Craig and Linda were going to come back to Oregon and set up a household together", that I had threatened people, had "manipulated" people, that I was Craig Portwood’s "paramour", that my painful divorce was "conveniently timed to coincide with the apparently substantial inheritance he had received", that "Linda Kristich’s young son was present with her and Craig in a Midwest motel.", and that "Linda Kristich herself suggested the child may have been molested", and similar false statements.

James Lloyd and Susan Lenox also knowingly re-broadcast a radio show on their network of their representative Rick Walters telling the listeners that I paid for a Motel room so my "little boy could sleep in the same bed with Craig Portwood" after I sent them an email pleading with them to repudiate the statement on the air. James Lloyd mocked me on his "Apocalypse Chronicles" show the following day and callously laughed about the incident.

I have never done any of those things, and my husband never said such things under oath nor in any other situation, and James Lloyd and Susan Lenox have refused to retract this false statement despite my repeated requests.

16. The previously mentioned statements published by James Lloyd and Susan Lenox about me in the articles "The Hidden Things of Dishonesty", "The Rise and Fall of Craig Portwood" and "The Wrath of Mr. Wormwood", are false and were published after I had stopped giving money to CHRISTIAN MEDIA NETWORK, and after I began to show kindness to Craig Portwood, and were clearly improper and should not have been done.

These false statements were published by James Lloyd and Susan Lenox to thousands of people over the Internet, and were also published and to thousands of people who listened to the radio network owned by James Lloyd and Susan Lenox.

17. I was shocked, embarrassed, and humiliated after I learned that James Lloyd and Susan Lenox had published statements that I was "an adulteress", had taken "my young son to a Motel" to be with Craig Portwood, was "threatening" CHRISTIAN MEDIA NETWORK supporters, was making efforts to "coerce half of Linda’s then husband’s substantial inheritance from his late mother’s estate", had been involved in an "illicit relationship between the married Craig Portwood and the then married Linda Kristich", that James Lloyd and Susan Lenox published the statement "We learned that Linda’s husband had recently inherited a substantial amount of money, and Linda was attempting to gain a sizeable portion of those funds by divorcing her husband.", had a "spirit of evil", that a witness approached Christian Media Network representatives "What’s up with Craig and Linda? He was all over her at the restaurant last night" when no such thing occurred, that they "stand by their original statements" in the face of overwhelming evidence to the contrary, that "no attempt was made to conceal the relationship, word of the budding "romance" quickly spread" between myself and Craig Portwood, that "Craig and Linda [were] repeatedly kissing", "broadcast fees are coming from Linda as she battles her husband for his substantial inheritance monies", that I was "grandiose", that "Linda’s effort at divorcing her husband was conveniently timed to coincide with the apparently substantial inheritance he had received", "…Linda had just become separated from her Michigan based husband in order to meet Craig at the event.", "Linda had met with Craig and they stayed together at a motel in the area.", speaking of Craig Portwood "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.", I was involved in a "looming scandal", that I was "engaging in an adulterous relationship", that I had threatened people, had "manipulated" people, was angry and abusive because an individual had refused to baptize me, was involved in an "inappropriate relationship", was described as Craig Portwood’s "paramour", "Linda Kristich’s young son was present with her and Craig in a Midwest motel.", "Linda Kristich herself suggested the child may have been molested", "…Linda Kristich, then a married woman, arrived directly from the motel where she had met with Craig -- less than 72 HOURS after she left her husband.", that I "left [my] husband", of a "courtship between Craig and Linda Kristich", that I was involved in a "relationship that was clearly improper", that I had announced a "betrothal" to Craig Portwood while married to my husband, that I "met [Mr. Portwood] in a motel" and "went directly from [my] husband’s bed to that motel to meet a man [I] had never seen…", and that James Lloyd and Susan Lenox would publish the statement that "My wife Susan and I by our original statements concerning our personal discovery of the relationship between Craig Portwood and Linda Kristich.", and that "…as of this writing, they are NOW living together a few miles away from my home. However, it seems they forgot about the `getting married’ part of the relationship.", that "… Craig and Linda have now been cohabitating together for many months without the benefit of marriage...", that "In summary, Craig (and his "non" significant-other Linda Kristich) are liars", and similar slurs on the Internet.

I have never done any of the things I have been accused of by CHRISTIAN MEDIA NETWORK and since none of these allegations were based in fact, they could have no other basis but malice.

18. The statements made and sanctioned by James Lloyd and Susan Lenox which alleged that I had endangered my son and which surrounded charges of sexual molestation, were published at the same time that I was involved in a custody dispute with my ex-husband and were especially grievous to me.

19. These statements are false and injurious to my reputation. I do not see how Plaintiffs/Counter Defendants James Lloyd and Susan Lenox could have made these statements about me in good faith.