Plaintiff JAMES LLOYD ("Lloyd") is, and was, at all material times, a resident of

Jackson County, Oregon. Plaintiff SUSAN LENOX is, and was, at all material times, a resident

of Jackson County, Oregon, and, is and was married to Plaintiff Lloyd. Plaintiff Lloyd operates a

ministry called the Christian Media Network ("Christian Media").

4.

Defendant LINDA KRISTICH ("Kristich") is, and was, at all material time, a resident of

Jackson County, Oregon.

FACTS COMMON TO ALL CLAIMS FOR RELIEF

5.

Plaintiff Lloyd owns and operates a ministry called Christian Media Network ("Christian

Media") in Jacksonville, Oregon. Christian Media has shortwave radio bible based broadcast

programs hosted by Lloyd, Susan Lenox, and others.

6.

In late 2001, a former host of Christian Media named Craig Portwood ("Portwood")

began to have a romantic relationship with a married female listener of Portwood's radio show,

Defendant LINDA KRISTICH ("Kristich"). Several weeks later, Portwood informed Plaintiffs

that he was going to the State of Michigan, where Defendant Kristich lived, for an unspecified

period of time and that he and Defendant Kristich were going to come back to Oregon to set up a household together.

Portwood was subsequently informed by Plaintiffs that Portwood's course of action would require

Christian Media to sever their ministry association with him.

Portwood and Defendant Kristich subsequently attended a fellowship conference in

Indiana where several Christian Media hosts were scheduled to speak, and announced they were

engaged. Defendant Kristich subsequently became separated from her Michigan based husband

in order to be with Portwood. Portwood was subsequently privately confronted by friends of the

Christian Media in an effort to deter Portwood's unscriptural behavior.

Portwood subsequently began to clash with friends of the Christian Media after being

privately confronted about his behavior. Because the Plaintiffs and others refused to condone

Defendant Kristich and Portwood’s affair, and bless their impending marriage plans, Defendant

Kristich and Portwood began to launch a false, vindictive, and malicious campaign against

friends of the Christian Media, to defame the Plaintiffs and interfere with the Plaintiffs' ministry,

Christian Media. Defendant Kristich regularly ad substantially aided and assisted Portwood to

utilize Portwood's shortwave radio program to defame the Plaintiffs and to utilize a website(s)

Portwood owned or controlled including, but not limited to, the Beacon of Truth, Christian

Media Watch Forum ("CMWF"), and Tribulation Chronicles ("TC"), to constantly and

continuously defame the Plaintiffs and to interfere with business of Christian Media.

Defendant Kristich substantially aided and assisted Portwood on their web site, The

Beacon of Truth. com, to publish a book in serial form, one chapter at a time. This book,

originally entitled "Liars for the Lloyd", is now presently entitled "The Hidden History of the

Christian Media Network". This 27 chapter work contains a multitude of claims, which are

patently false and which have been brazenly fabricated by Defendant Kristich and Portwood.

FIRST CLAIM FOR RELIEF'

(Defamation)

Plaintiffs reallege paragraphs 1 through 9 of this Complaint as if set forth fully herein.

11.

On or about January 1,2005, Defendant Linda Kristich repeatedly slandered Christian

9Media and James Lloyd on a Beacon of Truth broadcast on WBCQ in engaging in the following

acts and omissions:

11 (a) Linda Kristich repeatedly referred to Lloyd as the "adversary". This is a term that

is widely known in the Christian community to refer to the devil, e.g., "your

adversary the devil, as a roaring lion, walketh about, seeking whom he may

devour" (I Peter 5:8).

11 (b) Linda Kristich repeatedly referred to Lloyd as the "self proclaimed remnant

Pope", a term which James Lloyd has never used. It is a fictional position that

James Lloyd has never aspired to. This is a derisive term that is original to the

Beacon of Truth ministry. The title would appear to be related to a reference to

James Lloyd made by Craig Portwood on his June 23,2004, Beacon of Truth

broadcast in which Portwood compared James Lloyd to the "Pope" by stating that

James Lloyd was asserting that his teachings are "infallible".

11 (c) Linda Kristich repeatedly urged the listeners to do "research" on James Lloyd, and

that "research" could be found at www.beaconoftruth.com.

11 (d) Linda Kristich made slanderous characterizations of James Lloyd throughout the

broadcast, such as a reference to Lloyd as a "self-proclaimed big shot with a field

of rotten fruit". James Lloyd has never proclaimed himself to be a "big shot" and

because the Bible tells the believer "ye shall know them by their fruits" (Matthew

7: 16), these false characterizations of Lloyd's "fruit" are attempts to turn people

away from the Christian Media ministry.

11 (e) Linda Kristich claims "the remnant Pope ... will tell you I should have cast Craig

off the moment he was out of money after Craig had run through a substantial

amount of money supporting my children and myself'. Kristich further states "the

advice of these co-called godly people was to kick him [Portwood] to the curb".

James Lloyd has never made such a statement, and has never given Linda Kristich

any "advice" at all. This was a slanderous characterization to make James Lloyd

appear cruel.

11(f) Linda Kristich states that when Kristich was about to settle her divorce amicably,

"James Lloyd personally called my husband and stirred up the divorce

proceeding". James Lloyd has never called Kristch's husband, he does not know

the man, and has never spoken to him.

11 (g) Linda Kristch states that "James Lloyd personally sent him [Linda's estranged

husband] a large packet of information to prove how awful I was so he could

dominate the situation". James Lloyd has never sent James Kristich a large packet

of information. James Lloyd has never sought to prove how "awful" Linda is, and

Lloyd had no interest in attempting to "dominate" Kristich's divorce proceedings.

action". James Lloyd had nothing to do with Defendant Kristich's divorce. These

statements are false.

11 (i) Linda Kristich claims that she and Portwood are being harassed "because of a self

proclaimed busybody remnant Pope decided we weren't good for business, and

began his own". James Lloyd and Christian Media have not harassed Kristich,

they have not "decided" they weren't good for business, and they did not "begin"

their own... business" in response to anything Kristich and Portwood have or

have not done.

11(j) Linda Kristich states the alleged "investigators looked through our garbage,

watched us day and night, all to justify the lies of the mighty remnant Pope James

Lloyd". There has been no attempt to justify any alleged "lies" of the "mighty

remnant Pope James Lloyd" through an investigation into Kristich or Portwood's

garbage.

l1(k) Linda Kristich warns Christians listening to her on the radio that they will be

persecuted by James Lloyd at some point in the "future" - presumably seeking to

microcosm, sort of end times like. Ignorant people who refuse to do any research

have enabled and embodied the evil leaders like James Lloyd and George Bush to

persecute God's people". This is a complete false characterization of the Christian

11(1) Linda Kristich actually threatens listeners that support the Christian Media

ministry. "And to those of you who have made this possible, your time is coming,

and when it does do you really think God will hear your prayers?" This reference

is obviously calculated to stop financial support of Christian Media by threatening

that God will not hear listener's prayers if they make "this possible" by tithing to

the Christian Media ministry.

l1(m) Linda Kristich states that James Lloyd "the remnant Pope ... is using his spoils to

attack those who won't bow the knee to him". This misrepresents that James

Lloyd is a power mad egomaniac seeking to force all to "bow the knee" to him.

l1(n) Linda Kristich seems to be menacing James Lloyd on the air with a veiled threat

urging listeners to bring about some sort of unspecified action when she states: "I

am aware that this passage describes the Antichrist, but if the remnant Pope James

Lloyd insists on acting in the spirit of the Antichrist, he must be dealt with

accordingly" .

11(0) Linda Kristich defiantly railed on for some time "We must not succumb to the

remnant Pope's authority". Kristich further states "And 1 will not prostrate myself

before any man". At no time has James Lloyd ever sought to assert any kind of

authority over Linda Kristich or Craig Portwood, nor has James Lloyd ever

attempted to get anyone to bow down before him.

11 (p) Linda Kristich openly states her belief that God has brought her and Craig

Portwood together to "judge" Christian Media - "It is my personal belief that

when God brought Craig and me together, it was to judge the hearts of the

remnant, the remnant Pope, and his minions".

Between on or about May of 2002, to the present, Defendant Kristich engaged in the

following acts and omissions, in concert with Portwood, and/or knowingly conspired and

substantially aided and assisted Portwood in taking the following acts and omissions:

12(a) Published an online 27 chapter book on Portwood's web site, originally entitled

"Liars for the Lloyd", which is now presently entitled "The Hidden History of

Christian Media Network" (hereinafter the "Book"), which contains multiple

claims which are patently false and were brazenly fabricated by Defendant

Kristich and Portwood. The Book has been published to an indeterminate number

of people who have accessed Portwood's website.

12(b) In Chapter 5 of the Book, Defendant Kristich and Portwood write 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.

12(c) In Chapter 6 of the Book, Defendant Kristich and Portwood claim that Plaintiffs

publicly accused Portwood of "having sex with fairies".

12(d) Defendant Kristich and Portwood claim that Linda Kristich's seven year old son

"was threatened by a network host".

12(e) In Chapter 7 of the Book, Defendant Kristich and Portwood claim that Plaintiff's

 wife Susan was drunk "on a daily basis".

12(f) In Chapter 7 of the Book, Defendant Kristich and Portwood tried to manipulate a

fight between two Christian Media hosts in an effort to create strife between two

separate Christian Media clients.

12(g) In Chapter 9 of the Book, Defendant Kristich and Portwood printed Plaintiff

Lloyd's private telephone number to cause him to receive unwanted telephone

calls. In the place where Defendant Kristich and Portwood printed Plaintiff

Lloyd's private telephone number, Defendant Kristich and Portwood

acknowledged it was Plaintiff Lloyd's "private number".

12(h) Christian Media distributes a high-end Swiss made water filter called a Katadyn

for health purposes. In Chapter 11 of the Book, Defendant Kristich and Portwood

claim Plaintiffs were overcharging for their filter, and indicated the markup

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

Kristich and Portwood state the "Katadyne 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.

12 (i) Defendant Kristich and Portwood claim 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.

12 (j) In Chapter 12 of the Book, Defendant Kristich and Portwood claim Christian

Media's teachings led to an "assault with a deadly weapon" when no such assault

has ever occurred.

12(k) In Chapter 12 of the Book, Defendant Kristich and Portwood claim 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 Kristich

and Portwood controlled forum, Christian Media Watch Forum ("CMWF"),

Defendant Kristich and Portwood edited and allowed the following statement

concerning a former Christian Media radio host Rick Walters: " . . . who tries to

kill non-violent and non-aggressive joggers with an axehandle." (CMWF

08/06/03.) Plaintiffs believe that Defendant Kristich and Portwood wrote this

statement using a fictitious name.

12(1) In Chapter 12 of the Book, Defendant Kristich and Portwood state 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.

12(m) In Chapter 12 of the Book, Defendant Kristich and Portwood claim that anyone

that "crosses" Christian Media can expect to be vilified, attacked, falsely accused,

stalked, and sometimes assaulted".

12(n) In Chapter 12 of the Book, Defendant Kristich and Portwood claim that Plaintiffs

practice "Gnosticism" (an ancient mystical Egyptian tradition), when in fact,

Plaintiffs have repeatedly repudiated Gnosticism in print and on the radio.

12(0) Defendant Kristich and Portwood compare 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.

12(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 Web sites available for review,

but due to threats of a small group of people, the recipient needs to request the net

address of those Web sites with a reply to Plaintiffs' email. In Chapter 15 of the

Book, Defendant Kristich and Portwood have 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.

12( q) In Chapters 1 and 13 of the Book, Defendant Kristich and Portwood claim 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.

12(r) Christian Media has commercial relations with several shortwave radio broadcast

stations. Defendant Kristich and Portwood wrote that radio station WJIE ended

their relationship with Christian Media 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 Kristich and 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.

12(s) In Chapter 17 of the Book, Defendant Kristich and Portwood claim 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.

12(t) Plaintiffs sell a health device that produces colloidal silver fluid called a colloidal

silver generator. In Chapter 17 of the Book, Defendant Kristich and Portwood

have 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 Kristich and

Portwood omit 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 Kristich and Portwood

misrepresent the product further by saying that there are no batteries included

when every generator Plaintiffs have ever sold has included batteries.

12(u) In Chapter 18 of the Book, Defendant Kristich and Portwood refer to Christian

Media when they write "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."

12 (v) In Chapter 18 of the Book, Defendant Kristich and Portwood accused Susan

Lenox and Plaintiff Lloyd of grand theft auto. Defendant Kristich and Portwood

claim 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 Kristich and

Portwood go 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 and Plaintiffs owned no

money at all on the vehicle. These statements were plainly contrived to make

Plaintiffs look like criminals.

12(w) In Chapter 19 of the Book, Defendant Kristich and Portwood continue their

attempt to characterize Plaintiffs as law-breakers by referencing a dispute with an

adjacent property owner over an easement. In this regard, Defendant Kristich and

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.

12(x) Defendant Kristich and Portwood have 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 Kristich and Portwood write:

"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 vears 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 vrogression 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, as a 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.'"

12(y) In Chapter 20 of the Book, Defendant Kristich and Portwood have claimed that

the loss of two of Plaintiffs' hosts was because of a prediction Plaintiff Lloyd

issued which did not come to pass. Defendant Kristich and Portwood have also

claimed Plaintiff Lloyd lost a shortwave outlet for the same reason. These

statements are false. Defendant Kristich and Portwood state: "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" .

12(z) In Chapter 26 of the Book, Defendant Kristich and Portwood write that "Postal

12(aa) In Chapter 20A of the Book, Defendant Kristich and Portwood have printed a

counterfeit identification of Plaintiff Lloyd indicating it is his driver's license. On

Portwood's website, Defendant Kristich and Portwood state 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.

12(bb) Defendant Kristich and Portwood have placed several old civil collection suits

involving Plaintiff Lloyd on Portwood's website, citing collection actions

(Southern Oregon Credit Service, Jackson County, and GMAC) that were filed

against Plaintiff Lloyd. Defendant Kristich and Portwood trumpet 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!"

12(cc) In Chapter 23 of the Book, Defendant Kristich and Portwood placed file numbers

and statements concerning criminal arrests for auto theft and for Driving Under

the Influence on Portwood's web site pertaining to Plaintiff Lloyd. Both charges

were dropped and Plaintiff Lloyd was completely exonerated - but those facts

were omitted.

12( dd) Repeated posts are made on the CMWF by Defendant Kristich and 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.)

12( ee) On a CMWF posting, a legitimate news article writ1;en 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 Kristich

and Portwood have 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.)

12(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 Kristich and Portwood also implied 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.)

12(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 Kristich and Portwood. These posts have "Plaintiff Lloyd" making

embarrassing statements.

12(hh) On a CMWF posting dated 9/23/03, Defendant Kristich and Portwood state 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."

12(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 Kristich and Portwood.. One of them states: "When Susan

and I first met we both were in love with this substance as we still are. . .".

12(jj) Numerous web site articles have been posted by Defendant Kristich and 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."

12(kk) On the CMWF posting dated 08/12/03, a Defendant Kristich and 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

fraudulently representing they are from Rick Walters occurred on 07/14/03,

07/30/03,08/02/03,08/05/03, etc.

12(1l) On a CMWF posting dated 10/18/03 written by Defendant Kristich and Portwood,

they state that Susan Lenox is on drugs.

12(mm) On a Tribulation Chronicles forum (TC) posting from Defendant Linda Kristich

and Portwood dated 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.)

12(nn) On a dozen posts of TC from Defendant Kristich and 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."

12(00) A TC post from Defendant Kristich and 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.)

12(pp) On the TC 11/11/03 post, Defendant Kristich and Portwood claim that Christian

Media will ordain others through another ministry known asordination.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.)

12(qq) On the CMWF posting 11/04/03 from Defendant Kristich and 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."

12(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 Kristich and Portwood (color, borders, fonts, etc) to make it look like it

came from Plaintiff s ministry. The article was written by Defendant Kristich and

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.

12(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 Kristich and 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."

12(tt) There are counterfeit posts on CMWF written by Defendant Kristich and

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.

12(uu) Posts from Defendant Kristich and Portwood mock CMN and state that we're all

out of "Prozac and Beer." The accusation implies that people at Christian Media

are drunks and on drugs.

12(vv) Defendant Kristich and Portwood equate the Plaintiffs with the devil.

12(ww) On the CMWF posting of 8/25/03 from Defendant Kristich and Portwood

entitled One Picture, A Thousand Words, the main story text says "Has anyone

Been to http://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 Sheardon" with the highway numbers changed to read

"666".

12(xx) On an audio file that was originally broadcast on the Beacon of Truth radio

program on January 10,2003, the Beacon of Truth ministry has edited recorded

material from James Lloyd in such a fashion as to hold James Lloyd up to

contempt. The audio file has been placed on the Beacon of Truth website with an

Internet link in Chapter 24 of the online book, and this clip has been online for an

indeterminate period (but at least six months) since on or about June 2003, when

Plaintiffs first discovered it shortly after on or about June 15, 2004. The audio file

was online as recently as October 10, 2004. The audio clip is 4 minutes 57

seconds in length. On this audio file, Defendant Kristich and Portwood allege that

Christian Media orchestrated an accusation that Portwood molested Linda

Kristich's then 8 year old son in an Indiana motel. Defendant Kristich and

Portwood further state that this allegation was made to an unspecified child

protection agency in order to subject "an 8 year old boy to a series of

Defendant Kristich and Portwood infer in this clip that this child molestation

accusation was an attempt by Christian Media to destroy them. The statements

made in paragraph 12 (d) of Plaintiff's First Claim for Relief speak of one of the

many printed statements in the book wherein Defendant Kristich and Portwood

claim that Linda Kristich' s 7 year old son "was threatened by a network host".

The former quote is from Chapter 7 of the book, whereas Chapter 11 states that a

former network host "threatened Linda Kristich's 8 year old son, in an attempt to

smear me with allegations of sexual abuse".

12(yy) The audio accusations that are currently posted on the Beacon of Truth website

have been restated for over two years in various forms. On the Beacon of Truth

radio show of on or about January 3, 2003, Defendant Kristich and Portwood

claimed that this was" ... a cowardly attack on the children ... trying to attack her

children to get me ... we have documentation, she's going to bring them into this."

It was also stated on the Beacon of Truth radio program of January 10,2003,

where Defendant Kristich and Portwood referred to it as "a blackmail tactic" in

which he faulted Christian Media by name and said "they're starting to attack

innocent children now...". Referring to James Lloyd, the audio clip further

alleges that "attacks" on an innocent child were "made on this network by

network hosts". The audio file then plays a clip of James Lloyd allegedly

laughing about such a serious matter, when in fact the clip of James Lloyd

laughing was edited out of context. The audio clip then features Craig Portwood

asking "So Mr. James Lloyd, what do you think about people attacking innocent

though he were laughing at the question posed by Mr. Portwood. The clip also

features an audio recording of Linda Kristich's own son, J.P. Kristich, denying

that he slept in the same bed as Craig Portwood - a denial of an allegation that

Christian Media, James Lloyd, and Susan Lenox have never made. Defendant

Linda Kristich, the child's mother, arranged for her son to record this slanderous

attack against the Christian Media ministry and James Lloyd. The entire audio

clip is highly defamatory, slanderous, and inflammatory.

12(zz) On or about June 23, 2004, Defendant Kristich and Portwood slandered Christian

Media and James Lloyd when he claimed that James Lloyd said on the air, "the

devil stopped a prophecy of mine with his time machine." Plaintiff James Lloyd

said no such thing, and the accusation was designed to make Plaintiff James Lloyd

appear to be crazy by claiming Satan has a "time machine".

On that same June 23,2004, program, Defendant Kristich and Portwood

repeatedly slandered and defamed the Christian Media ministry by claiming that a

former host of Christian Media "accused me of molesting little boys". Defendant

Kristich and Portwood further insinuate that this same former Christian Media

host, Rick Walters, brought about an investigation of Craig Portwood and the 7 .

year old son of Linda Kristich by calling authorities and claiming Portwood had

molested the child when they stayed together in an Indiana motel room

unsupervised. This accusation was made even though Defendant Kristich and

Portwood knew that no such investigation was ever launched and no such

complaint was ever filed. On that same June 23, 2004, program, Defendant

Kristich and Portwood repeatedly referenced the false child molestation allegation

of Rick Walters, and then sought to involve James Lloyd in the accusation by

stating "Why? Because that's how they live. They live that way, they're thugs.

It's like a mafia". In the context of the broadcast as Portwood repeatedly focused

on James Lloyd, it was clear the "they" being referred to was the Christian Media

ministry. The "mafia" label also has a print corollary on the website. On that

same June 23, 2004, program, Defendant Kristich and Portwood repeatedly sought

to direct listeners to the website article and audio clip of the molestation charge

a site where Christian Media is the primary subject matter. "It's serious folks, it's

on the website, you can go there". On every radio program referenced here, the

host - Craig Portwood or Linda Kristich - both repeatedly direct the listeners to

the www.beaconoftruth.com website.

On that same June 23, 2004, program, Defendant Kristich and Portwood

asserted that James Lloyd believes his religious statements are inerrant, and as a

result, Defendant Kristich and Portwood compared James Lloyd to the Pope.

Because James Lloyd's listener and reader base is largely Protestant, this

characterization was designed to damage James Lloyd's reputation and

characterize James Lloyd as behaving in an unscriptural fashion. The "Pope"

charge is related to a similar slander repeatedly made by Linda Kristich on the air

on or about January 1, 2005. On that same June 23, 2004, program, Defendant

Kristich and Portwood asserted that James Lloyd went on the air and claimed that

Craig Portwood was ill because Defendant Kristich and Portwood came against

the Christian Media ministry. This tactic was used to imply that James Lloyd is

so deluded that he believes that James Lloyd (or God) can make people sick if

they move against him.

12(aaa) On or about December 8,2004, Defendant Kristich and Portwood slandered

Christian Media and James Lloyd on a Beacon of Truth broadcast on WBCQ by

referring to the purchase of "Moldy Beef Jerky from the local prophet".

Shortwave listeners are well aware that Christian Media periodically sells Beef

Jerky - and it is not moldy. This was a direct attempt to disparage Christian

Media's product.

12(bbb) On or about December 15, 2004, Defendant Kristich and Portwood slandered

Christian Media and James Lloyd on a Beacon of Truth broadcast on WBCQ by

referring by name to a former host and friend of Christian Media named Richard

Stone. Defendant Kristich and Portwood stated that Stone had followed the "false

prophet" James Lloyd and his life was destroyed as a result. With this statement,

Defendant Kristich and Portwood are cleverly telling listeners if they listen to

and/or follow the teachings of James Lloyd, their lives will be ruined.

12(ccc) The Beacon of Truth web site goes on to claim that an unspecified James Lloyd

biography states "After 20 years of studying Bible prophecy, he wrote Beyond

Babylon - his first prophecy book. The book was followed by the publication of

The Apocalypse Chronicles, a prophecy newsletter first published in 1992". In

this transparent slur, the Beacon of Truth plainly misrepresents the date of the

writing of Beyond Babylon in an intentional attempt to place the emergence of

Lloyd's prophecy work two years earlier in 1990, at a time when Lloyd's life was

most certainly not in conformity with the Biblical principles he would publicly

espouse in 1992. This is a brazen attempt to defame and libel both parties that

was specifically engineered to embarrass and defame both James Lloyd and Susan

Lenox. The inside jacket of Beyond Babylon states that the book was written and

published in 1992, and since the Beacon of Truth website quotes extensively from

that book, Defendant Kristich and Portwood have a copy of the book with the

publication date. Internal evidence in the book itself plainly shows when it was

written as it references numerous events - see the footnotes - that did not occur

until late 1991 and early 1992. It is well known to Defendant Kristich and

Portwood that the first publication of The Apocalypse Chronicles newsletter was

immediately after the first publication of Beyond Babylon, and the Beacon of

Truth website itself notes The Apocalypse Chronicles was published "in 1992".

12(ddd) The Beacon of Truth web site inaccurately states that James Lloyd owns

American Voice Radio, an entirely independent broadcast group. Even though

James Lloyd has repeatedly stated on the air that Christian Media has no position

in American Voice Radio, Defendant Kristich and Portwood intentionally

included this as a way of diminishing the inevitable testimony of the owner of

12(eee) In Chapter 23 (Revised version) of the book, under the sub-heading The Arresting

Behavior of James Lloyd, Defendant Kristich and Portwood state that James

Lloyd and Christian Media sold broadcast air time to a broadcaster named Brother

Stair. "Brother" R.G. Stair is a South Carolina broadcaster that is the subject to

several criminal investigations, including sex with underage girls on his

communal ministry farm. He is held in disrepute in most Christian circles, thus

the statement that Christian Media has sold air time to Brother Stair was intended

to make Christian Media and James Lloyd look so greedy that they even sell air

time to perverts. Plaintiffs James Lloyd and Christian Media have never sold air

time to Brother Stair.

12(fff) Between on or about November 3 and November 11,2004, Defendant Kristich

and Portwood posted the following reference to a demand for retraction letter

mailed to James Lloyd from Linda Kristich on their web site:

"To prevent Linda from being able to prove to the Court that the letter was

delivered, James Lloyd STOLE the letter without signing the return receipt ( a

Federal offence and a Felony). destroying it instead! As a result of that foolish