4.

5.

6.

7.

8.

9.

10.

11.

PAGE-4 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

12.

13.

14.

15.

16.

17.

18.

19.

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

PAGE-6 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

Defendant/Counter Plaintiff has no ownership, controlling interest, nor equity position in the Beacon of Truth ministry nor have ever had any such ownership, controlling interest, nor equity position in the Beacon of Truth ministry, and could not have engaged in any conduct which is alleged against Defendant/Counter Plaintiff in connection with the Beacon of Truth ministry.

20.

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

Defendant/Counter Plaintiff has no ownership, controlling interest, nor equity position in the Beacon of Truth website nor have substantially aided nor assisted in any aspect of publishing, financing, nor authorship of the Beacon of Truth website, and could not have engaged in any conduct which is alleged against Defendant/Counter Plaintiff in connection with the Beacon of Truth website.

PAGE-7 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

21.

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

Defendant/Counter Plaintiff has no ownership, controlling interest, nor equity position in any the "CHRISTIAN MEDIA WATCH" forum, nor has had any in the past, nor has substantially aided nor assisted in any aspect of publishing, financing, nor authorship of the "CHRISTIAN MEDIA WATCH" forum, and could not have engaged in any conduct which is alleged against Defendant/Counter Plaintiff in connection with any "CHRISTIAN MEDIA WATCH" forum.

22.

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

Defendant/Counter Plaintiff has no knowledge of, ownership in, controlling interest, nor equity position in any "TRIBULATION CHRONICLES" forum nor has had any in the past, nor has substantially aided nor assisted in any aspect of publishing, financing, authorship nor had any participation in or of the "TRIBULATION CHRONICLES"

PAGE-8 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

forum of any kind, and could not have engaged in any conduct which is alleged against Defendant/Counter Plaintiff in connection with any "TRIBULATION CHRONICLES" forum.

23.

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

Any statement Defendant/Counter Plaintiff may have made on any radio broadcast on January 1, 2005 was the truth.

24.

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

Any statement Defendant/Counter Plaintiff may have made on any radio broadcast on January 1, 2005 was Defendant/Counter Plaintiff’s opinion and is therefore protected speech under the FIRST AMENDMENT of the CONSTITUTION OF THE UNITED STATES.

25.

NATURE OF ACTION

Defendant/Counter Plaintiff brings this action for relief of violation of Defendant/ Counter Plaintiffs' rights protected under the common law.

26.

In approximately late 1997 or early 1998, 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 and either bought products or donated to them in the value of approximately $2,000.00.

27.

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 on the international shortwave radio bands from Defendant/Counter Plaintiff home in Michigan.

28.

After Defendant/Counter Plaintiff began listening to Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK Defendant/Counter Plaintiff also began listening to CHRISTIAN MEDIA NETWORK host Chris Blodgett to whom Defendant/Counter plaintiff donated approximately $200.00.

29.

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. The amounts given by Defendant/Counter Plaintiff to Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK as

donations and or purchases were in the total amount

of approximately $1,500.00.

30.

In approximately June of 2001, Defendant/Counter Plaintiff became a regular caller to the CHRISTIAN MEDIA NETWORK show called "The Stupid Friday Show" hosted by Francis Steffan and Craig Portwood.

31.

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 on "The Stupid Friday Show" broadcast. 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 Defendant/Counter plaintiff gave to Plaintiff/Counter Defendant 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.

32.

After much soul searching and prayer, Defendant/Counter Plaintiff began after that time to make donations to Craig Portwood, and knowing that Craig Portwood was in ill health, Defendant/Counter Plaintiff began to send Craig Portwood gifts of essential oils, and other products which Defendant/Counter Plaintiff believed would improve Craig Portwood’s health. Defendant/Counter Plaintiff also anonymously donated about $200.00 to Craig Portwood and anonymously sent Craig Portwood a one ounce gold coin valued at approximately $290.00.

33.

After Defendant/Counter Plaintiff stopped making regular donations to Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK, CHRISTIAN MEDIA NETWORK co-owner and Plaintiff/Counter Defendant Susan Lenox called Defendant/Counter Plaintiff on the telephone in the Fall of 2001, asking Defendant/Counter Plaintiff to co-host with Plaintiff/Counter Defendant Susan Lenox on Plaintiff/Counter Defendant Susan Lenox’s "Sound Body " show, which Defendant/Counter Plaintiff did. Plaintiff/Counter Defendant Susan Lenox and CHRISTIAN MEDIA NETWORK co-owner also called Defendant/Counter Plaintiff on the telephone in or about January of 2002 asking Defendant/Counter Plaintiff to host

the show for Plaintiff/Counter Defendant Susan Lenox and Defendant/Counter Plaintiff did so.

34.

In or about January 2002, Craig Portwood announced that he would be producing a conference in Indiana with several network hosts speaking on various subjects, which was scheduled for the Memorial Day weekend of 2002.

35.

Also in or about January of 2002, and after learning of the conference, Defendant/Counter Plaintiff called Craig Portwood after his 10:00 PM PST broadcast and offered to speak on the subject of Home Schooling of children, and Craig booked Defendant/Counter Plaintiff to speak at the conference.

36.

Defendant/Counter Plaintiff began speaking regularly on the telephone with Craig Portwood after his 10:00 PM broadcast at that time, and mentioned that Defendant/Counter Plaintiff had previously mentioned to CHRISTIAN MEDIA NETWORK co-owner and Plaintiff/Counter Defendant Susan Lenox some months before that

Defendant/Counter Plaintiff was planning to relocate to Southern Oregon after Defendant/Counter Plaintiff’s husband followed through on his announced plans to divorce Defendant/Counter Plaintiff, and related stories about abusive treatment Defendant/Counter Plaintiff had suffered at the hands of Defendant/Counter Plaintiff’s husband. Defendant/Counter Plaintiff also offered to rent a room to Craig Portwood at such time as Defendant/Counter Plaintiff should relocate to Oregon.

37.

At that time Craig Portwood gave counsel to the effect that Defendant/Counter Plaintiff should make demands to Defendant/Counter Plaintiff’s husband that he cease from any abusive behavior, and that Defendant/Counter Plaintiff should make other efforts to keep Defendant/Counter Plaintiff’s marriage intact until such time as Defendant/Counter Plaintiff’s husband files for divorce. Defendant/Counter Plaintiff made no plans to leave Defendant/Counter Plaintiff’s husband, and further asked Defendant/Counter Plaintiff’s husband several times if Defendant/Counter Plaintiff’s husband would attend the conference. Defendant/Counter Plaintiff’s husband refused the invitation each time the invitation was extended to Defendant/Counter Plaintiff’s husband.

PAGE-15 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

38.

After the first day of the conference, Defendant/Counter Plaintiff again spoke with Craig Portwood about Defendant/Counter Plaintiff’s husband’s announced plans to divorce Defendant/Counter Plaintiff, and at that time Craig Portwood again gave counsel to the effect that Defendant/Counter Plaintiff should make more efforts to keep Defendant/Counter Plaintiff’s marriage intact until such time as Defendant/Counter Plaintiff’s husband files for divorce. It was also at that time that Craig Portwood stated that he would be "honored" to wed Defendant/Counter Plaintiff, should "God release" Defendant/Counter Plaintiff from Defendant/Counter Plaintiff’s wedding vows.

39.

Defendant/Counter Plaintiff agreed to confront Defendant/Counter Plaintiff’s husband, if Craig Portwood would agree to follow Defendant/Counter Plaintiff home after the conference, as a protection from any abusive behavior which Craig Portwood agreed to do.

40.

The following day, Craig Portwood mentioned to CHRISTIAN MEDIA NETWORK "host" Rick Walters, that Craig hoped God would release Defendant/Counter Plaintiff from her wedding vows, and referred to Defendant/Counter Plaintiff as his "future fiancé". Craig Portwood also gave Defendant/Counter Plaintiff a kiss at that time. CHRISTIAN MEDIA NETWORK "host" Rick Walters shook Craig Portwood’s hand at that time and asked Defendant/Counter Plaintiff to take a photograph of the two men. Defendant/Counter Plaintiff later told Craig Portwood that the announcement was "inappropriate" and "premature" as Defendant/Counter Plaintiff and Craig Portwood are still "just friends", and Craig agreed and apologized to Defendant/Counter Plaintiff.

41.

Craig Portwood followed Defendant/Counter Plaintiff to Defendant/Counter Plaintiff’s home in Michigan as asked and was introduced to Defendant/Counter Plaintiff’s husband. Defendant/Counter Plaintiff at that time demanded that Defendant/Counter Plaintiff’s husband cease from being verbally abusive to Defendant/Counter Plaintiff in the presence of their children. At that time Defendant/Counter Plaintiff’s husband told Defendant/Counter Plaintiff to get out of the house and sue

Defendant/Counter Plaintiff’s husband for divorce, which Defendant/Counter Plaintiff did the following week.

42.

Knowing that Defendant/Counter Plaintiff having no money nor means of support, Craig Portwood asked Defendant/Counter Plaintiff to stay at his campsite near Port Huron Michigan and Defendant/Counter Plaintiff agreed to do so and asked Defendant/Counter Plaintiff brought enough camping gear to accommodate Defendant/Counter Plaintiff and Defendant/Counter Plaintiff’s children.

43.

After the Saint Clair County Court ordered Defendant/Counter Plaintiff to return to the marital home, Defendant/Counter Plaintiff did so and continued to live in the marital home as ordered until after Defendant/Counter Plaintiff’s divorce was finalized in May of 2003.

44.

broadcasting unsubstantiated statements about Defendant/Counter Plaintiff which were sanctioned by Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK to the effect that Defendant/Counter plaintiff was an "adulteress" and similar slurs.

45.

46.

47.

On the same October 18, 2002, broadcast Plaintiff/Counter Defendant LLOYD ("Lloyd") stated: "you can go to CHRISTIAN MEDIA DAILY DOT COM, and our cover story is there, available for all to see." Plaintiff’/Counter Defendant’s did not attend the Indiana conference, and yet Plaintiff/Counter Defendant’s wrote numerous articles about the Indiana conference.

48.

Plaintiff/Counter Defendant JAMES LLOYD ("Lloyd") knew these statements to be false but made them anyway as evidenced from his statement made on the October 18, 2003 "Apocalypse Chronicles" 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

PAGE-20 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

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."

49.

50.

These posters further stated "THESE TWO PEOPLE ATTENDED A

CHRISTIAN GATHERING. EACH IS MARRIED TO ANOTHER PERSON. THEY CAME FROM (sic) DIFFERNT STATES. HIM ALONE, AND HER WITH HER

PAGE-21 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

CHILDREN. UNKNOWN TO THE OTHER CHRISTIANS, THESE TWO DID NOT COME FOR FELLOWSHIP OF THE BODY OF CHRIST, BUT FOR THE LUST OF EACH OTHER. UNKNOWN TO THEIR SPOUSES, THESE TWO HAVE BEEN HAVING A LONG DISTANCE LOVE AFFAIR AND NOW WANTS US, THE BODY OF CHRIST, TO THINK GOD CONDONES THESE ACTIONS!!!"

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

51.

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.

PAGE-22 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

52.

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.

53.

Numerous broadcasts were done by CHRISTIAN MEDIA NETWORK "hosts" calling Defendant/Counter Plaintiff a "whore", a "slut", and a "slut puppy" from about September 2002 to at least December 2004.

54.

On or about October 21 2002, CHRISTIAN MEDIA NETWORK began publishing a series of false, unprivileged, defamatory statements about Defendant/Counter Plaintiff which attacks Defendant/Counter Plaintiff’s fitness as a mother, beginning with a mass emailed "Bible prophecy newsletter" which CHRISTIAN MEDIA NETWORK calls "CHRISTIAN MEDIA CURRENTS" under the heading

PAGE-23 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

"The Hidden Things of Dishonesty" which was mailed to every person in Plaintiff/Counter Defendant’s "database", which Plaintiff/Counter Defendant’s have claimed contains the names of about 50,000 people. Plaintiff/Counter Defendants also published

this article under the heading "The Hidden Things of Dishonesty" which contains multiple claims which are patently false and were fabricated by the Plaintiff/Counter Defendants. A copy of article (hereafter "The Hidden Things of Dishonesty") is attached to this Counter Complaint as Exhibit "101" and is incorporated into the Complaint herein by this reference. This article "The Hidden Things of Dishonesty" was published by Plaintiff/Counter Defendants on their "CHRISTIAN MEDIA DAILY" "news" website located on the internet at www.christianmedia daily.com.

This article was published to each individual in Plaintiff/Counter Defendant’s "database" which Plaintiff/Counter Defendants have claimed contains the

names of over 50,000 people. This article was also published on Plaintiff/Counter Defendant’s "CHRISTIAN MEDIA RESEARCH" website located on the internet at

www.christianmediaresearch.com/cmc-43.html where it exists to this day.

PAGE-24 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

55.

Plaintiff/Counter Defendants also published a similar article which contains multiple claims which are patently false and were fabricated by the Plaintiff/Counter Defendants, containing false, unprivileged, defamatory statements about Defendant/Counter Plaintiff which attacks Defendant/Counter Plaintiff’s fitness as a mother, under the heading "The Rise and Fall of Craig Portwood". A copy of this article work (hereafter "The Rise and Fall of Craig Portwood") is attached to this Counter Complaint as Exhibit "102" and is incorporated into the Complaint herein by this reference. This article remains on the internet to this day at Plaintiff/Counter Defendant’s "CHRISTIAN MEDIA RESEARCH" website, located on the internet at www.christianmediadaily.com.

56.

PAGE-25 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

Defendant/Counter Plaintiff immediately sent an email to CHRISTIAN MEDIA NETWORK condemning this false and brazenly callous comment. The following day in an apparent response to the email, CHRISTIAN MEDIA co-owner and Plaintiff/Counter Defendant James Lloyd commented on the email, laughed about it and stated Plaintiff/Counter Defendant’s intention of replaying the show later that evening on which the comments were made about Defendant/Counter plaintiff’s seven year old son being molested by Craig Portwood, wherein Craig Portwood was referred to as a "pervert".

57.

On or about June of 2004, CHRISTIAN MEDIA NETWORK and Plaintiff/Counter Defendant’s hired private investigators to stakeout Defendant/Counter Plaintiff’s home, and these private investigators approached Defendant/Counter Plaintiff’s home on behalf of and Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK in what Defendant/Counter Plaintiff belies to be an

PAGE-26 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

attempt to harass and intimidate Defendant/Counter Plaintiff.

58.

Defendant/Counter Plaintiff believes that one of these private

investigators also burglarized Defendant/Counter Plaintiff automobile, taking Defendant/Counter Plaintiff’s registration and insurance information shortly after the filing of a lawsuit by and Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK against Craig Portwood to whom Defendant/Counter Plaintiff rents a room.

59.

Defendant/Counter Plaintiff has also been told by neighbors that a letter has been circulated in the neighborhood making slanderous accusations about Defendant/Counter Plaintiff. A similar letter was also sent to Defendant/Counter Plaintiff’s landlord, presumably in an attempt to have Defendant/Counter Plaintiff evicted from Defendant/Counter Plaintiff’s home. These letters bore a copy of a photo which is in possession of and Plaintiff/Counter Defendant’s CHRISTIAN MEDIA NETWORK, bearing an image of Craig Portwood, to whom Defendant/Counter Plaintiff rents a room.

PAGE-27 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

60.

61.

Plaintiff/Counter Defendants refused to retract the false statements and instead responded to the demand for retraction by publishing another series of false, unprivileged, defamatory statements on or about September 17, 2004, about Defendant/Counter Plaintiff which attacks Defendant/Counter Plaintiff’s fitness as a mother, in another publication titled "The Wrath of Mr. Wormwood" on Plaintiff/Counter Defendant’s "CHRISTIAN MEDIA RESEARCH" website located on the internet at www.christianmediaresearch.com. This article published under the heading "The Hidden Things of Dishonesty" contains multiple claims which are patently false and were fabricated by the Plaintiff/Counter Defendants. A copy of this publication

PAGE-28 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT

(hereafter "The Wrath of Mr. Wormwood") is attached to this Counter Complaint as Exhibit "103" and is incorporated into the Complaint herein by this reference.

62.

retraction of the second article titled "The Wrath of Mr. Wormwood" on September 17 2004, and September 20 2004. Plaintiff/Counter Defendants refused to retract any of the

false, unprivileged, defamatory statements about Defendant/Counter Plaintiff.

63.

Plaintiff/Counter Defendant James Lloyd has since made other efforts to harass Defendant/Counter Plaintiff. On February 23, 2005, Plaintiff/Counter Defendant James Lloyd drove up Defendant/Counter Plaintiff’s lengthy private drive, stopping in front of Defendant/Counter Plaintiff’s home at 4025 Little Applegate Road at about 5:15 PM PST in an effort to menace Defendant/Counter Plaintiff. The private drive is approximately one half mile in length and terminates in a cul de sac.

PAGE-29 DEFENDANT/COUNTER PLAINTIFF LINDA KRISTICH’S AMENDED ANSWER WITH AFFIRMATIVE DEFENSES AND COUNTER COMPLAINT