Professional Documents
Culture Documents
CVCV - Xcentric Moves To Disqualify Ben Smith, Smith Responds Full PDF
CVCV - Xcentric Moves To Disqualify Ben Smith, Smith Responds Full PDF
From:BenjaminJohnSmith[mailto:[email protected]]
Sent:Monday,August18,20149:05AM
To:PeterW.Berger
Subject:Re:Bergerletter
Peter,
I disagree with all the allegations contained in your correspondence. For the reasons I have previously stated, I
will not be withdrawing from this case. Your client does not get to choose who prosecutes him and / or his
company / employees. Your client(s)' decision to publish stories about me on its website, which began four
months after he / it learned I was investigating it / one of his / its employees, will not cause me to withdraw
from this matter; neither will threats of civil lawsuits or Bar complaints. Your client needs to proceed as he / it
feels is appropriate.
Today I will be asking the Court to issue county attorney subpoenas (Rule 2.5(6)) to your client, Ed Magedson,
and the following Xcentric Ventures employees: Adam Kunz, J ustin Crossman, and Anette Beebe. Please let me
know if your client(s) and / or its employees / agents will voluntarily comply with any Rule 2.5(6) subpoena, or
whether I need to go through the processes contained in Iowa Code sections 819.2 622.84 to secure their
attendance.
Ben
Ben Smith
Sac County Attorney
On Aug 15, 2014, at 9:26 AM, Peter W. Berger <[email protected]>wrote:
Ben,
Thereisanotherimportantethicsrule(setoutbelow)thatwebelieveyouclearlyviolated,andshould
bepartofyourdecisionwhetherornottopersonallymoveforward,asopposedtoobtainingoutside
independentcounsel.TheallegationscontainedinthethreepublicdocumentsthatIamawarecontain
manycommentsandassumptionsthatareexactlywhattheethicsruleisdesignedtoprevent.
Followingtherule,IalsoincludedthethreadofAugust12,whichcontainstheletterrequestingyouto
voluntarilywithdraw.Manyknownantagonistsofmyclienthavebeenpubliclyusingyourfilingsagainst
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
2
him,asyouknow,andthesearetheverysamepeopleyouhavebeencommunicatingwiththroughout
thiscase.
Peter
Rule32:3.8:SPECIALRESPONSIBILITIESOFAPROSECUTOR
Theprosecutorinacriminalcaseshall:Ch32,p.58RULESOFPROFESSIONALCONDUCTSeptember2012
(a)refrainfromprosecutingachargethattheprosecutorknowsorreasonablyshouldknow
isnotsupportedbyprobablecause;
(b)makereasonableeffortstoensurethattheaccusedhasbeenadvisedoftherightto,and
theprocedureforobtaining,counselandhasbeengivenreasonableopportunitytoobtain
counsel;
(c)notseektoobtainfromanunrepresentedaccusedawaiverofimportantpretrialrights,
suchastherighttoapreliminaryhearing;
(d)maketimelydisclosuretothedefenseofallevidenceorinformationknowntothe
prosecutorthattendstonegatetheguiltoftheaccusedormitigatestheoffense,and,in
connectionwithsentencing,disclosetothedefenseandtothetribunalallunprivileged
mitigatinginformationknowntotheprosecutor,exceptwhentheprosecutorisrelievedofthis
responsibilitybyaprotectiveorderofthetribunal;
(e)notsubpoenaalawyerinagrandjuryorothercriminalproceedingtopresentevidence
aboutapastorpresentclientunlesstheprosecutorreasonablybelieves:
(1)theinformationsoughtisnotprotectedfromdisclosurebyanyapplicableprivilege;
(2)theevidencesoughtisessentialtothesuccessfulcompletionofanongoinginvestigation
orprosecution;and
(3)thereisnootherfeasiblealternativetoobtaintheinformation;and
(f)exceptforstatementsthatarenecessarytoinformthepublicofthenatureandextent
oftheprosecutorsactionandthatservealegitimatelawenforcementpurpose,refrainfrom
makingextrajudicialcommentsthathaveasubstantiallikelihoodofheighteningpublic
condemnationoftheaccusedandexercisereasonablecaretopreventinvestigators,law
enforcementpersonnel,employees,orotherpersonsassistingorassociatedwiththeprosecutor
inacriminalcasefrommakinganextrajudicialstatementthattheprosecutorwouldbe
prohibitedfrommakingunderrule32:3.6orthisrule.
From:PeterW.Berger[mailto:[email protected]]
Sent:Tuesday,August12,20144:32PM
To:'BenjaminJohnSmith'
Subject:Bergerletter
Ben,
Iappreciatethefactyouhavebeenwillingtospeakwithmeaboutthe915Motionandrelated
matters.Asyoucanwellimagine,byclientisdisturbedbyit,aswellastheunsealingofthewarrant,
andleakingofotherinformation,andalloftheaccusationsyouhavepubliclylodgedagainsthim,using
thepowerofsubpoenaandprobablecauseonly.Attachedisaletteronbehalfofmyclientrequesting
youtowithdrawandtoseekindependentcounseliftheinquiriesyouareengagedinaretocontinue.As
thelettersetsout,IwillfollowitwithaMotiontoExcludeyouascounsel,astheonlyviablewayto
proceedifyoudonotactvoluntarily.Iamsendingthisingoodfaith,andbelieveyouhaveanobvious
conflictintheeyesofanylaypersoninviolationofethicsrules.
BestRegards,
Peter
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
3
PeterW.Berger
BergerLawFirmP.C.
5152888888
5152888182(fax)
[email protected]
petebergerlaw.com
pbergerlaw.com
<20140812105409944.pdf>
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
EXHIBIT 3
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
DISTRICT CGLi1\ 1 OF 10\lii".
SAC COUNTY
FIL0
IN THE IOWA DISTRICT COURT IN AND FOR SAC JUL -9 AH 8: 08
(Magistrate Division)
IN THE MATTER OF AN APPLICATION
FOR A SEARCH WARRANT FOR THE
RESIDENCE AT 4221 155TH STREET,
URBANDALE, IOWA 50323
SEARCH WARRANT APPLICATION
COMES NOW, the State of Iowa, through Sac County Attorney (SCA) Ben Smith, and being
duly sworn on oath, states the following:
That at 4221 155TH STREET, URBANDALE, IOWA 50323, the residence of ANNA
RICHTER, at which there are computers and other electronic storage devices that contain
information I documents (digital media) all of which are identified in Attachments A and B to
this Search Warrant Application and I or were used to facilitate I commit the crimes listed in
the Affidavit.
That said property I information is relevant and material as evidence in a criminal prosecu-
tion. That the facts establishing the foregoing ground(s) for issuance of a search warrant are
as set forth in the affidavit and attachments, which, by this reference, are made by part of
this Search Warrant Application.
WHEREFORE, the undersigned asks that a Se:oorr=->"'
N SMITH
SAC COUNTY ATTORNEY
Subscrtbed and sworn to before me July
1
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
.. i
'
\
._IN THE IOWA DISTRICT COURT IN AND FOR SAC COUNTY
(Magistrate Division)
IN THE MATTER OF AN APPLICATION
FOR A SEARCH WARRANT FOR THE
RESIDENCE AT 4221 155TH STREET,
URBANDALE, IOWA 50323
SEARCH WARRANT APPLICATION:
AFFIDAVIT
COMES NOW, Sac County Attorney (SCA) Ben Smith, and being duly sworn on oath,
states the following:
Your applicant has been the elected prosecutor in Sac County, Iowa, for close to four years.
The Iowa Supreme Court has found that the County Attorney can apply for a search
warrant. State v. Jensen, 189 N.W.2d 919 (1971) Three years prior, your applicant worked
for the Iowa Attorney General's Office as an Assistant Attorney General (AAG) assigned to
represent the State of Iowa's Child Support Recovery Unit. In the last three years, your
applicant has drafted numerous search warrants, and has conducted numerous county
attorney investigations per Rule 2.5(6), including, two "cold case" homicide I murder
investigations, both of which resulted in arrests being made. The investigation into these
matters began in April 2012, when your affiant was first contacted by Laguna Beach,
California, resident DARREN MITCHELL MEADE (DOB: January 3, 1967).
During this investigation, your applicant listened to hundreds of hours of recorded phone
conversations between TRACEY R I H T ~ R and her friends and family, which made from
either the Sac County Jail in Sac City, lc:>wa, or the Iowa Women's Prison in Mitchellville,
Iowa, as well as audio recordings of conversations between TRACEY RICHTER and her
family and friends during their prison visits. Additionally, your applicant has issued over 100
Rule 2.5(6) County Attorney Investigatory Subpoenas Duces Tecum in furtherance of this
investigation and has obtained and reviewed thousands of documents, and has spoken with
numerous witnesses. In total, your applicant has spent well over 1 ,500 hours investigating I
working on this case.
The facts alleged and information contained in this affidavit come from your affiants
personal observations, training, experience, and research, as well as the same from other
law enforcement officials I investigators and licensed private investigators. The facts alleged
and information contained herein are made and set forth to the best of my ability with the
information available to me at the time. Your applicant has given his best efforts to ensure
the information contained in this application is accurate and reliable, however, considering
the incredible complexities and the general subject matter of the case, it is possible for there
2
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
to be inadvertent, factual inaccuracies. Lastly, this affidavit is intended to show merely that
there is sufficient probable cause for the requested warrant and DOES NOT set forth all of
my knowledge about this matter.
Your applicant is actively investigating the following crimes: Ongoing Criminal Conduct, a
Class "B" Felony (IOWA CODE 706A.2); Conspiracy, a Class "D" Felony (IOWA CODE
706.1 ); Solicitation, a Class "D" Felony; Extortion (IOWA CODE 705.1 ), a Class "D" Felony
(IOWA CODE 711.4); and Witness Tampering, an Aggravated Misdemeanor (IOWA CoDE
720.4), Facilitation of A Criminal Network By Attempting To Induce A Witness" commits a
Class "B" Felony. IOWA CODE 706A.2 (2013)
I make this affidavit in support of an application for a search warrant for the items and
information set forth in Attachments A and B to this Search Warrant Application.
IMPORTANT NOTE ABOUT THE CHRONOLOGY OF EVENTS AS OUTLINED IN THIS
AFFIDAVIT: Where possible, the events described herein are laid out in strict chronological
order. However, due to the complexity of the case, and the number of different timeline
arcs, in some instances, a series of related events that extend over long periods of time are
nested together so as to improve comprehension and readability; thereafter, the normal
timeline will resume. Consequently, the last incident described in a nested event may be for
a date that comes after the next incident described in the general timeline.
Unless specifically stated otherwise, all conversations referenced herein, to which TRACEY
RICHTER is a party, were initiated by TRACEY RICHTER from a prison phone at the Iowa
women's prison in Mitchellville, Iowa.
TRACEY RICHTER and Dr. John Pitman were married on or around August 14, 1988. On
February 1, 1990, TRACEY RICHTER (then Tracey Pitman) gave birth to Dr. John Pitman's
son, BERT PITMAN. On or around June 1992 not long after Dr. John Pitman believed
TRACEY RICHTER tried to kill him for the second time, the two separated. Shortly after
their separation, TRACEY RICHTER filed for divorce from Dr. John Pitman. Not long into
their divorce proceedings, TRACEY RICHTER, accused Dr. John Pitman of molesting their
son, BERT PITMAN. Soon after TRACEY RICHTER made this accusation, flyers were
placed on most of the cars at Northwestern Memorial Hospital, the hospital Dr. John Pitman
was working for at the time, which stated that Dr. John Pitman had been found to be a child
molester. TRACEY RICHTER later said she did not place the flyers on the car, but the
person who did was someone with whom she was close.
TRACEY RICHTER and Dr. John Pitman's divorce proceedings lasted close to six years.
During the proceedings, Dr. John Pitman was able to prove, among many other things, that
a signature purporting to be his that was affixed to an insurance policy taken out on his life
3
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
was forged. Later in these proceedings it was proven that TRACEY RICHTER had falsely
accused Dr. John Pitman of molesting BERT PITMAN. Despite the foregoing, when the
divorce I custody matters were finalized, the two stipulated that they would split joint legal
custody, that TRACEY RICHTER would be the primary physical caretaker, and that Dr.
John Pitman would get liberal visitation rights.
TRACEY RICHTER and Michael Roberts were married in Australia in 1996. Michael
Roberts, an Australian, moved to the United States (Chicago, Illinois) after he married
TRACEY RICHTER. Two children, N.R. and M.R., were born to their marriage. N.R. and
M.R. are dual citizens of the United States and Australia.
In 1998, TRACEY RICHTER, Michael Roberts, BERT PITMAN, and N.R. moved from
Chicago, Illinois, to Early, Iowa (Sac County).
In 2000, TRACEY RICHTER again accused Dr. John Pitman of molesting BERT PITMAN.
Dr. John Pitman responded by asking the courts for full custody of BERT PITMAN.
Following a thorough investigation, it was determined that TRACEY RICHTER's new sex
abuse allegation against Dr. John Pitman was unfounded, possibly fabricated.
On December 13, 2001, days before the custody modification proceedings were set to
begin, TRACEY RICHTER shot and killed 20-year-old Dustin Wehde after she was
allegedly attacked in her home by Dustin Wehde and an unknown second intruder who
escaped (although, when law enforcement first arrived at the scene, TRACEY RICHTER
told them there had been three intruders).
The evidence recovered at the scene indicated TRACEY RICHTER, using two different
pistols, fired eleven shots at Dustin Wehde, nine of which struck him. The autopsy of Dustin
Wehde's body revealed three of these nine shots entered through the back of his head in a
tightly grouped pattern. A blood spatter expert would later testify the last of the three shots
fired into the back of Dustin Wehde's head was fired fifteen minutes after the first two while
his head was resting on the ground. Hours after this incident, law enforcement found a pink
spiral notebook in Dustin Wehde's car. The notebook contained what appeared to be a
journal or diary in Dustin Wehde's handwriting, in which Dustin Wehde had written that he
was hired by Dr. John Pitman and Dr. John Pitman's divorce I custody attorney, Stephen
Komie, to stalk, harass, and ultimately murder TRACEY RICHTER, BERT PITMAN, as well
as other bits of information that suggested Dr. John Pitman was ultimately responsible for
this (alleged) home invasion I attempt on TRACEY RICHTER's life. Additionally, notebook
contained a series of numbers.
The few law enforcement officials who knew of the notebook's existence, decided not to
disclose its existence to anyone, including TRACEY RICHTER.
4
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
About two months after she shot and killed Dustin Wehde, TRACEY RICHTER told her
then-friend, Mary Higgins, that law enforcement had told her (TRACEY RICHTER) it found a
notebook in Dustin Wehde's car that proved Dr. John Pitman was behind the attack, and
that Dr. John Pitman was going to be arrested soon.
Dr. John Pitman was never arrested, and law enforcement did not publicly disclose the
notebook's existence until after TRACEY RICHTER was arrested for murdering Dustin
Wehde. However, as discussed below, in the ten years between Dustin Wehde's murder
and TRACEY RICHTER's arrest for his murder, TRACEY RICHTER would openly discuss
the notebook and its contents.
On February 13, 2002, TRACEY RICHTER sent a letter to Lieutenant Dennis Cessford, the
Sac County Sheriffs Deputy ("L T Cessford") assigned to investigate Dustin Wehde's death.
In this letter, TRACEY RICHTER asked the Deputy whether law enforcement had
interviewed Dr. John Pitman, and provided a list of reasons why TRACEY RICHTER
believed Dr. John Pitman and his attorney, Stephen Komie, could be responsible for the
alleged home invasion. TRACEY RICHTER also told the Deputy that she would be able to
identify the alleged second intruder if shown his picture.
On February 15, 2002, TRACEY RICHTER wrote the following in an e-mail to L T Cessford:
[Dr. John Pitman] may be required to come in for a deposition [in their custody proceedings]
in the near future. If we can get him in, we will let you know. If you want to speak in
confidence to my attorney, and give her some questions to ask [Dr. John Pitman], we will. I
doubt he will agree to an interview. [Dr. John Pitman] has not contacted [BERT PITMAN
since the alleged home invasion], which is strange.
On February 21, 2002, TRACEY RICHTER REFUSED to assist investigators in developing
a composite sketch of the second individual she alleged had invaded her home with Dustin
Wehde on December 13, 2011, and attacked her.
On March 20, 2002, TRACEY RICHTER asked L T Cessford where law enforcement had
any information that connected Dr. John Pitman to Dustin Wehde.
On June 9, 2002, TRACEY RICHTER wrote the following in a letter to L T Cessford: "Are
you in a position to reveal to us the nature of the link between Steven Komie and the
Wehde household?
On November 28, 2002, Dustin Wehde's father, Brett Wehde, committed suicide near his
son's (Dustin Wehde) In a note he left behind, Brett Wehde wrote that his "heart was
broken" on [December 13, 2001], the day TRACEY RICHTER shot and killed Dustin
Wehde, and that [he cried] every day since [December 13, 2001 ].
On December 30, 2002, TRACEY RICHTER wrote a letter to Mona Wehde (Dustin
5
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Wehde's mother and Brett Wehde's wife) wherein TRACEY RICHTER accused Mona
Wehde of conspiring with Dr. John Pitman to have Dustin Wehde attack her, and chastised
Mona Wehde for being a horrible wife to her late husband,
On October 13, 2003, Dustin Wehde's Estate filed a wrongful death lawsuit against
TRACEY RICHTER. Wehde Estate v. Tracey [Richter], Sac County District Court, Case No.
LACV018486.
On April 23, 2004, Michael Roberts filed for divorce from TRACEY RICHTER. Michael
Roberts v. Tracey [Roberts], Buena Vista County District Court, Case No. CDCD002755.
TRACEY RICHTER was given temporary custody of their children, N.R. and M.R. Much like
TRACEY RICHTER's divorce with Dr. John Pitman, the custody I divorce proceedings that
followed Michael Roberts and TRACEY RICHTER's separation were contentious and
protracted.
On May 18, 2004, TRACEY RICHTER came into the Sac County Sheriff's Office, and asked
to speak with Sac County Sheriff Ken McClure. The following is Sheriff Ken McClure's
report regarding this incident:
Tracey (Richter] told me she had some information that she felt I needed to know. Tracey
(Richter] told me that her husband, Michael Roberts, talks in his sleep, and while he talks in
his sleep, Tracey is able to ask him questions. TRACEY RICHTER told me that on numerous
occasions, Michael would talk about a journal and how this journal would "cover his ass."
TRACEY RICHTER also said that Michael Roberts told her [in his sleep] that the contents of
this journal concerned Tracey [Richter's] ex-husband John Pittman. When talking about the
Journal, Tracey [Richter] would cry and talk about for short time, and then she would start
talking about something else. Tracey [Richter] said that she asked Michael about where this
journal was because she had never seen it. Tracey [Richter] told me that [Michael Roberts]
told her while he was sleeping that last time he saw the Journal, Dustin had it. On another
occasion, Tracey (Richter] said that [Michael Roberts] was talking in his sleep about how in
case they got caught, [the journal] would cover him. Tracey [Richter] told me that when she
asked who these people were. Michael became coherent and woke up. Tracey [Richter] said
that she had even on one occasion awakened her son BERT [PITMAN], and had him come
into the bedroom and listen to Michael Roberts talking in his sleep about this journal.. Tracey
[Richter] said she had never seen this journal.
On May 19, 2004, TRACEY RICHTER left the following in a voicemail to one of Michael
Roberts's co-workers:
I mean if [Michael Roberts] wants to be with someone else just say he wants to be with
someone else, but don't try to turn me (TRACEY RICHTER) into a monster by saying that
I'm trying to kill him and all of this horrible ridiculous stuff. I am now convinced that he did
have something to do with the attack and I am convinced based on his behavior ... that he
6
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
absolutely refuses to pay any child support ... he refuses to pay the maintenance that he
agreed to pay me ... the fact that he is making up these horrendous, horrible stories about me
trying to kill him ... the fact that he is, you know, doing sneaky stuff with [their business) to
protect his assets ... I don't know who he is and I do now believe, I just met with the sheriff um
last week, I do believe now with all of my heart that he had something to do with the attack
on me, because he has become a complete stranger to me, you know, if he doesn't want to
be with me just say that he's in love with someone else, he wants to start a new life ... but
don't make up these ridiculous stories about me ... and I am now convinced and that is the
tool that I will be using against him because I will use his own actions against him, I don't
have to make stuff up about him, I will make sure that because of everything that he has
done ... that he pays for his crimes ... he pays for the attack on me and that he ultimately will
go to jail and that the rest of his life will be spent in jail as the result of trying to have me
killed ... he has proved himself to be mentally unstable person, he has proved himself to be a
stranger, and I am now convinced that he did have something to do with it and I will make
sure if there is anything in my power that's honest and truthful, you know, to make sure, I'm
not going to lie or anything like that, but to make sure that he does pay for his sins and that
he suffers the consequences of his actions ... you know, unless he were all of a sudden to
have a change of heart and apologize and say that all of this stuff that he has been doing
that he's been behaving and doesn't know what it is ... he's a stranger to me, and that he's a
monster and that. .. he's a danger and a menace to society to have him out there ... that also
means letting everyone in (inaudible) know that he was involved in the attack.
On March 2, 2005, because Dustin Wehde's Estate ran out of money to take the case to
trial, and because TRACEY RICHTER was judgment proof, the Dustin Wehde's Estate
moved to dismiss its wrongful death case against TRACEY RICHTER.
On March 2, 2005, the same day the civil wrongful death lawsuit against her had been
dismissed, TRACEY RICHTER wrote the following in an e-mail to Sac County Sheriff Ken
McClure:
I heard from one of our experts that a notebook of Dustin's was found that contained notes
about me. Is there any chance of my attorney getting a copy. It may be relevant to our
divorce case. If you are worried that confidential information might get released, we can
agree to have the Judge review the item in chambers and decide if it is related.
On March 3, 2005, TRACEY RICHTER wrote the following in an e-mail to Sac County
Sheriff Ken McClure: "I just got of the phone with [my civil attorney] who told me that Dustin
Wehde's notebook contained details about the Dentist in Chicago. I never told anyone
about that."
On March 10, 2005, TRACEY RICHTER wrote the following in an e-mail to Sac County
Sheriff Ken McClure:
My lawyer in Des Moines told me that one of the DCI reports reported a daily log of
7
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Dustin's on an inventory list. When he inquired about it, he was told that it contained
"disturbing personal information about me" he also was told it included "gibberish?" I was
particularity upset that I had not been told about this previously. Was Dustin being paid to
watch me and track my activities? If so, by, whom? Or was Dustin obsessed with me and
watching me tor personal reasons? Forgive m for being upset, but finding out that you
were being stalked and that you were not told about it is kind of weird. Considering the
events of [December 13, 2011], I kind of think that might be related.
On March 11, 2005, TRACEY RICHTER wrote the following in an e-mail to Sheriff Ken
McClure:
I met with Mary Higgins today. She spoke with Robin from Crossroads, who told her that
the notebook was found by [Mona Wehde] in their house NOT in the car as my attorney
stated. She also stated that [Mona Wehde] showed it to Robin and [Michael Roberts] before
turning it in. Supposedly it contained numbers in addition to information relating to my son
[BERT PITMAN] and myself. Is there any evidence to suggest the conspired together and
used Dustin? They would have known Mike would be a suspect, so Dustin would
eventually have to take the fall so Mike would be off the hook. I wouldn't put it past
[Michael Roberts] using both of them so he would be off the hook.
On March 13, 2005, TRACEY RICHTER sent the following in a facsimile to Sheriff Ken
McClure:
I reviewed the report and it clearly states the daily log of Dustin's was found in the car and
taken to DCI. If this is true, how did [Mona Wehde] and Robyn spend days going through
Dustin's notebook that was found in his home??? Are there 2? Did [Mona Wehde] ever turn
hers [in to] the DCI or did she bury it because it incriminated Dustin Wehde?
On March 15, 2005, TRACEY RICHTER wrote the following in an e-mail to Sheriff Ken
McClure: "The second notebook that Mona found contained a bunch of numbers
according to Robin at Crossroads. Could those numbers be bank account numbers?
Passwords? Routing numbers? PIN's?"
On July 18, 2005, TRACEY RICHTER wrote the following in facsimile to Sheriff Ken
McClure and then-Sac County Attorney Earl Hardisty: "I sincerely hope you really don't
believe there wasn't a second man because then you won't look for him and if you won't
look for him you can't find him. You have to find him, he has all the answers."
In 2008, the Court awarded TRACEY RICHTER full custody of N.R. and M.R., and Michael
Roberts was given liberal visitation rights. Immediately following TRACEY RICHTER and
Michael Roberts' separation in 2004, TRACEY RICHTER, her family, and her friends began
a coordinated effort to publicly accuse Michael Roberts of planning the (alleged) home
invasion I being criminally responsible for Dustin Wehde's death, in effort to give TRACEY
RICHTER an advantage over Michael Roberts in the couple's pending divorce I custody
8
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
proceedings.
On December 4, 2007, TRACEY RICHTER and Michael Roberts received an interlocutory
divorce. In 2008, Michael Roberts married Dr. Heidi Johanna Forsbacka (aka Heidi
Roberts).
Michael Roberts has alleged that TRACEY RICHTER attempted to kill him three times in
the four years that followed their separation. In fact, the State of Iowa's victim's
compensation program reimbursed Michael Roberts for damages he sustained as a result
of one of these three alleged attempts.
On or around October 22, 2007, during one of their numerous hearings in Buena Vista
County District Court Case No. CDCD002755, TRACEY RICHTER entered a letter into
evidence which she testified was sent to her by the Consulate General of Finland in Los
Angeles. The letter said that the Consulate General of Finland had forwarded documents
sent to it by TRACEY RICHTER concerning the legality of Michael Roberts' marriage to Dr.
Heidi Forsbacka (citizen of Finland). The letter further stated that "falsifying documents and
committing fraud to obtain a Finnish visa or commit bigamy is a serious criminal offense for
both Mr. Roberts and Dr. Forsbacka." TRACEY RICHTER testified at this hearing that this
letter was genuine and that she received it in the mail or by fax.
On November 8, 2007, the real Consulate General of Finland provided a letter stating that
the above-mentioned letter purporting to be from the Consulate General of Finland, which
TRACEY RICHTER entered into evidence, was fraudulent.
On January 31, 2008, the Court entered its final order in Michael Roberts and TRACEY
RICHTER's custody I child support case (a year or two prior, the Court entered an order
legally divorcing the two). Although the Court awarded TRACEY RICHTER primary custody
of N.R. and M.R., the Court stated the following in its findings:
Tracey is very deviceful; She usually has a plan or scheme to effect a purpose. The following
incidents establish crafty schemes by Tracey: (a) One week after Michael filed the petition for
dissolution of marriage, Tracey filed a petition for relief from domestic abuse. As a result of
the filing of this petition, a temporary protective order was entered. No evidentiary hearing
was ever held to establish that Michael committed domestic abuse assault, as asserted by
Tracey. The timing of the petition for relief from domestic abuse, filed by Tracey, and her
failure to proceed to final hearing on her petition, leads the Court to believe that Tracey used
this process in an attempt to gain advantage over Michael on the custodial issue; (b) Tracey
has made attempts to establish that Michael has committed child abuse. Michael admits that
he had in the past hit Noah on the buttocks with a light stick. He admits that this was
inappropriate. This was reported to DHS and resulted in an unfounded report. At the trial on
the custodial matter, Tracey did not contend that this activity constituted child abuse. In fact,
9
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
she conceded that it was not child abuse. Later, Tracey made vigorous attempts to obtain a
founded report as a result of this incident; (c) All three children were attending St. Mary's
School. Noah had a bruise on his back. Bert went to Noah's teacher and told her about the
bruise on Noah's back. The teacher is a mandatory reporter, and a report was made to the
Department of Human Services. An investigation was conducted. Noah informed both the
teacher and the caseworker for the Department of Human Services that the mark on his back
was the result of a bicycle accident. This resulted in an unfounded report. Tracey, instead of
making a report of child abuse on Noah, as a result of the bruise on his back, involves her
son Bert and has him bring this to the attention of Noah's teacher. Tracey knew this would
result in an investigation being conducted. It is quite apparent Tracey knew all along the
source of Noah's injury; (d) When Tracey was made aware that Michael had a favorable
report regarding custody from Bethany Christian Services, she made complaints to Bethany
personnel to attempt to change the report. The involvement with Bethany was made by
Michael to determine his capabilities of being a custodial parent. It was not his intent that
Tracey be involved in the preparation of the report, but by complaining she convinced other
personnel of Bethany that she should be interviewed as well as her supporters.
On or around July 17, 2008, TRACEY RICHTER alleged there was a website that contained
a nude image of TRACEY RICHTER and that Michael Roberts and or his wife, Dr. Heidi
Forsbacka was responsible. The image was of a nude female with TRACEY RICHTER's
face photo shopped on top of the picture of the nude female. It was later determined that
TRACEY RICHTER used Michael Roberts' checking account to create the website on which
this photo shopped image was published. Although no criminal charges (identity theft) were
filed against TRACEY RICHTER, following a forensic examination of her computer that law
enforcement seized from her apartment in May 2009, pursuant to a search warrant, law
enforcement found the original digital image was used to create the nude photo shopped
image of TRACEY RICHTER that was published on the website she
In the middle of 2008, TRACEY RICHTER and her and Michael Roberts' children, N.R. and
M.R. moved to Omaha, Nebraska. Shortly thereafter, Michael Roberts moved to nearby
Papillion, Nebraska, to be close to his children.
On December 29, 2008, TRACEY RICHTER wrote the following in an e-mail to Iowa
Division of Criminal Investigation (DCI) Special Agent (SA) Trent Vileta (SA Vileta):
"[Michael Roberts] told me about a premonition from God that would solve all our problems.
He said that Mona would find proof that John Pitman tried to kill me and this would allow
both Mona and Mike to sue John Pitman."
On January 27, 2009, Michael Roberts received a temporary restraining order against
TRACEY RICHTER from the Sarpy County District Court. On January 29, 2009, Michael
Roberts was actively participating in the State of Nebraska's Victims of Domestic
10
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Abuse Address Confidentiality Program, which, among other things, provided him with a
State Government mailing address, which allowed him to keep his residential address a
secret.
On February 6, 2009, TRACEY RICHTER wrote the following in an e-mail to DCI SA Vileta:
Once when [Michael Roberts] was working with [Dustin Wehde] and supposedly
"encouraging" him to write, he had him write about being a hitman. Oh, great! That's a really
good idea. We now know that [Michael Roberts] knew [Dustin Wehde] was violent. [Michael
Roberts's admits it. Let's encourage him to fantasize about killing for hire. Yes, let's
glamourize unthinkable behavior.
On April 19, 2010, TRACEY RICHTER was convicted of felony fraud in the Douglas County
District Court, Omaha Nebraska. State v. Richter, Douglas County (Omaha, Nebraska)
District Court Case No. CR 09 13186.
On or around July 27, 2010, TRACEY RICHTER was convicted of felony perjury in the Clay
County District Court in Iowa. State v. Richter, Clay County District Court Case No.
FECR014399
Sometime in 2010, TRACEY RICHTER reported to the FBI that Michael Roberts had once
been a close personal friend and associate of alleged international super cyber criminal
JULIAN ASSANGE, the founder of Wikileaks.org, and that the two had engaged in all sorts
of nefarious conduct.
On June 7, 2011, the FBI interviewed TRACEY RICHTER about her allegations concerning
Michael Roberts' supposed relationship with JULIAN ASSANGE. During the interview,
TRACEY RICHTER began discussing the December 13, 2011, (alleged) home invasion and
shooting death of Dustin Wehde. Specifically, TRACEY RICHTER told the FBI SA that she
had a friend in Early, Iowa, named Mary Higgins. TRACEY RICHTER said that Mary
Higgins and TRACEY RICHTER had a conversation about Dustin Wehde's attack on
TRACEY RICHTER some time after the attack. TRACEY RICHTER said that Mary Higgins
told her somebody involved in the investigation told her (Mary Higgins) that the police found
a "diary or journal" during their investigation, which contained personal information
regarding TRACEY RICHTER. TRACEY RICHTER said Mary Higgins did not say who it
was involved in the investigation who told her (Mary Higgins) this information.
On July 14, 2011, TRACEY RICHTER again told an FBI SA that Mary Higgins was told by
somebody associated with the aforementioned investigation that the police found a journal,
and that the journal contained personal information about TRACEY RICHTER.
On July 27, 2011, TRACEY RICHTER was arrested for the December 13, 2001, murder of
20-year-old Dustin Wehde. State v. Richter, Sac County District Court Case No.
11
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
FECR011900.
The Sac County Sheriffs criminal complaint and arrest warrant alleged TRACEY RICHTER
had knowledge of a piece of evidence that was found in Dustin Wehde's car following the
murder I alleged home invasion, the existence of which was never publicly disclosed by law
enforcement. The complaint further alleged the following:
[TRACEY RICHTER's] communications with law enforcement and other individuals since the
murder strongly indicates [TRACEY RICHTER] not only had knowledge this piece of
evidence existed, but that she manufactured and planted the same in Wehde's vehicle after
the murder to make it appear as if Wehde was a home invader. Specifically, and most
recently, [TRACEY RICHTER] discussed this piece of evidence in detail with the FBI.
Additionally, a witness has recently come forward and has [said that TRACEY RICHTER]
described this piece of evidence to the witness in early 2002.
The day TRACEY RICHTER was arrested, TRACEY RICHTER's mother, ANNA RICHTER,
said the following in a message she left on the Sac County Attorney's Office answering
machine: "You have destroyed a family," and "I have nothing left to lose."
In the days that followed TRACEY RICHTER's arrest for Dustin Wehde's murder on July 27,
2011, while in the Douglas County Jail, TRACEY RICHTER directed her fiance, RUSSELL
SCHERTZ, and mother, ANNA RICHTER, to contact State's witness Mary Higgins.
TRACEY RICHTER told ANNA RICHTER and RUSSELL SCHERTZ that Mary Higgins had
once told her about a journal implicating her first husband, Dr. John Pitman, in the alleged
December 13, 2001, home invasion. ANNA RICHTER repeatedly tried to contact Mary
Higgins in the weeks that followed TRACEY RICHTER's arrest.
On July 28, 2011, while in the Douglas County (Omaha, Nebraska) Jail, TRACEY RICHTER
and ANNA RICHTER had the following conversation:
TRACEY RICHTER: Yeah. I think -- but I do think it's important that you call Mary Higgins
because -- see, and then it says about-- that I discussed the evidence in detail with the FBI.
And I didn't -- I don't think I discussed anything in detail with the FBI -
ANNA RICHTER: It's just really weird. It's just -- I tried calling [Mary Higgins] and nobody
answered. And she has -- she doesn't have an answering service. So I'll try calling tonight.
TRACEY RICHTER: Because the only -- the only evidence that -- like -- the only evidence
that I learned about afterwards from -- Mary Higgins told me that someone she knew close to
the case, um, told her that they found something that Dustin had like -- I don't know -- notes
or a diary or something with information in it about me. That was it.
Then, TRACEY RICHTER's fiance, RUSSELL SCHERTZ, got on the phone, and TRACEY
RICHTER told him the following:
12
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
But when I read [the criminal complaint], I'm like trying to rack my brain to think what it could
be, like what -- the only thing I can talk about -- I mean think about that the FBI guy asked
me about specifically was he asked me about something my girlfriend Mary Higgins told me
about, which was that someone told her close to the case that they had found something,
and but -- and I remember being -- sitting at my mom's when she called me about that. But I
don't remember if it was like -- because after the attack, I spent some time at my mom's
(ANNA RICHTER). But I don't remember if it was then or if it was much later, like sometime
after [Michael Roberts] and I separated and we were like visiting my mom.
Towards the end of the conversation, TRACEY RICHTER again told RUSSELL SCHERTZ
to have her mother, ANNA RICHTER, contact State's witness Mary Higgins:
Yeah. And make sure-- make sure my mom calls Mary Higgins and finds out who told her,
um, about what she had told me about; okay?- Yeah. And tell my mom to tell her it's not a
question of someone getting in trouble. This is --this is a big deal now, you know.
RUSSELL SCHERTZ asked TRACEY RICHTER, "and you want me to ask [Mary Higgins]
what?" And TRACEY RICHTER gave the following answer:
[Mary Higgins needed to tell RUSSELL SCHERTZ and ANNA RICHTER] who told [Mary
Higgins] about what she told [TRACEY RICHTER] about. - And that [ANNA RICHTER]
needs to stress (to Mary Higgins] that it's important, because like if they're going to say I
knew about something that I shouldn't have known about and so then that by default means
that I was involved, I mean Mary needs to come forward and say who said it to her.
In one of the phone calls she made from the Douglas County Jail (Omaha) while awaiting
extradition to Iowa, TRACEY RICHTER tried to get her mother, ANNA RICHTER, to agree
that ANNA RICHTER was present when Mary Higgins told TRACEY RICHTER about the
notebook. Later, during TRACEY RICHTER's murder trial, ANNA RICHTER attempted to
testify to this.
In the week that followed this conversation, ANNA RICHTER called the Higgins' residence
numerous times, but no one answered or returned ANNA RICHTER's calls.
Since this arrest, TRACEY RICHTER has been continuously incarcerated in either the
Douglas County Jail, Sac County Jail, or an Iowa prison.
On August 5, 2011, Sac County Attorney (SCA) Ben Smith filed the Trial Information
against TRACEY RICHTER. State v. Richter, Sac County District Court Case No.
FECR011900. SCA prosecuted and Assistant Attorney General (AAG) from the Iowa
Attorney General's Office, prosecuted the case.
On August 6, 2011, BERT PITMAN said the following to Donna Bistrican in a Facebook
message: I am in Chicago right now. I would love to see you. Is [your home] on the way to
Omaha? In response, Donna Bistrican told BERT PITMAN not to Omaha until TRACEY
13
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
RICHTER's lawyers [told BERT PITMAN it was okay to do so]." Donna Bistrican then told
BERT PITMAN to call her.
Immediately following TRACEY RICHTER's arrest, Michael Roberts took custody of their
children, N.R. and M.R., and moved to California where he was enrolled in the State of
California's victim protection program. Save for a few monitored calls Michael Roberts
allowed TRACEY RICHTER to have with their children, Michael Roberts did not allow
TRACEY RICHTER and her family to have any contact I communication with his children,
mostly because TRACEY RICHTER and her family continued to blame Michael Roberts for
TRACEY RICHTER's plights. In the few instances where he did allow TRACEY RICHTER
to speak to the children over the phone, he had to abruptly end the calls because TRACEY
RICHTER, rather than engage her children in a meaningful, motherly conversation, instead
probed them for information and details as to their current whereabouts.
On November 7, 2011, a Webster County, Iowa, jury convicted TRACEY RICHTER for the
first degree murder of Dustin Wehde. The following non-exhaustive list of persons either
were listed as witnesses in the State's Trial Information and I or testified against TRACEY
RICHTER at her murder trial: Dr. John Pitman, Mary Higgins, Mona Wehde, Ashley Wehde,
Raymond Friedman, Marie Friedman, Michael Roberts, and Jeremy Collins (collectively
"State's witnesses").
As mentioned earlier, during the trial, ANNA RICHTER tried to testify that Mary Higgins was
the one who told TRACEY RICHTER about the existence of the pink spiral notebook (not
the other way around as Mary Higgins had testified). ANNA RICHTER was not able finish
her story because the State made a hearsay objection to the question I her answer, which
the Court sustained.
On December 3, 2011, just days before she was to be sentenced, TRACEY RICHTER and
her mother, ANNA RICHTER, were caught trying to solicit fraudulent testimony from this
convicted child molester in effort to get TRACEY RICHTER a new murder trial. Specifically,
TRACEY RICHTER wrote the following in letters to the convicted child molester:
"I pray for a miracle and [interviewed with] [Dateline NBC] hoping it would cause someone to
come forward with helpful information"; "You need to understand that I am guarded. I used
to ... trust people until they gave me a reason not to trust them. That has changed. Now my
trust must be earned over time and actions speak louder than words"; "I'm not sure whether
your friend was following the [murder case] out of sheer curiosity or he knows something. If
he does [tell him] the statute of limitations has run out on assault and burglary so he has
nothing to lose if something feels bad and wants to come forward [and] wants to do the right
thing"; "there is the possibility there was a 'lookout' person [in addition to the three others
TRACEY RICHTER alleged were responsible for Dustin Wehde's murder], too. My lawyer
has the contact details [for Dateline NBC] if your friend knows anything he wants to share.
14
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
I'm sure God would bless anyone brave enough to come forward."
On December 5, 2011, TRACEY RICHTER was sentenced to life in prison without the
possibility of parole.
As demonstrated below, beginning December 2011 I January 2012, through as recently as
June 23, 2014, DARREN MEADE, TRACEY RICHTER, ED MAGEDSON, ANNA RICHTER,
and others have been publishing defamatory and harassing stories about the State's
witnesses on literally millions of webpages. These defamatory stories and comments
accuse the State's witnesses of theft, perjury, fraud, computer hacking, child molestation,
murder, and terrorism.
DARREN MEADE
DARREN MEADE is a forty-seven-year old resident of Laguna Beach, California. DARREN
MEADE held the position of CEO of Progenex Dairy Bioactives, a Delaware company, from
July 2010 through February 2011. During this period of time, he willfully and
enthusiastically participated in a criminal conspiracy to embezzle in excess of one million
dollars of the company's funds in pursuit of an exclusive license agreement allowing access
to and the use of an illegal structure query language (SQL) injection script capable of
removing online consumer complaint reports from existing "gripe" websites such as
RipOffReport.com, Blogspot.com and others.
On or around November 7, 2007, ADAM ZUCKERMAN was convicted for his role as the
principal organizer in a fraudulent 20-plus million dollar bank leasing scheme, which the US
Department of Justice (USDOJ) named "Operation Lease Fleece." Following his conviction,
while awaiting sentencing for his role as the principal organizer in the aforementioned
leasing scheme, ADAM ZUCKERMAN was on supervised released with U.S. Pretrial
Services. http://www.justice.gov/usao/cac/Pressroom/pr20071141.html
In November 2009, Dr. Scott Connelly, unaware of ADAM ZUCKERMAN's past, entered
into an investment agreement with ADAM ZUCKERMAN's company, VenturePharma, in
order to raise investment capital to fuel a medical research and development venture that
Dr. Scott Connelly's company, Progenex, had developed.
Throughout Dr. Connelly's contact with ADAM ZUCKERMAN, which was between 2009 and
2010, ADAM ZUCKERMAN dropped his surname and used the alias "ADAM STUART" in a
deliberate effort to conceal his status as a convicted felon awaiting sentencing for his role
15
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
as the principal organizer in the 20-plus million dollar fraudulent leasing scheme. When
ADAM ZUCKERMAN's true identity and status as a convicted felon awaiting sentencing
was revealed to Dr. Scott Connelly, which was in April 2010, Dr. Scott Connelly resigned as
CEO of Progenex, moved to rescind the investment deal, and initiated a series of
disclosures concerning ADAM ZUCKERMAN's fraud to the Santa Ana, California branch
offices of the United States Attorney's Office Attorney and the FBI.
In an attempt to prevent his fraudulent actions from becoming known to federal authorities,
ADAM ZUCKERMAN launched a preemptive, vexatious civil action against Dr. Scott
Connelly to deflect his personal culpability in the creation of the investment fraud. When his
expected result of a quick settlement and exhaustive non-disclosure agreement did not
materialize, ADAM ZUCKERMAN instigated a systematic online defamation campaign
against Dr. Scott Connelly in the hopes that the publication of these libelous and untruthful
allegations would coerce Dr. Connelly's acquiescence to ADAM ZUCKERMAN's desired
cover up. ADAM ZUCKERMAN and his felonious cohorts hired DARREN MITCHELL
MEADE as Progenex's CEO to front their group's efforts to harass and intimidate Dr. Scott
Connelly. DARREN MEADE would later admit in a two-day deposition that he was hired by
ADAM ZUCKERMAN solely for the purpose of harassing and intimidating Dr. Scott Connelly
into settling his case civil case with ADAM ZUCKERMAN and ADAM ZUCKERMAN's
criminal organization ("the criminal organization" or "criminal accomplices"). ADAM
ZUCKERMAN and his criminal organization paid DARREN MEADE a salary and agreed to
pay him a $200,000.00 bonus if he was able to coerce and intimidate Dr. Scott Connelly into
settling his civil case against ADAM ZUCKERMAN and his criminal organization.
Throughout his tenure as Progenex CEO, DARREN MEADE was fully aware that ADAM
ZUCKERMAN had recently been convicted of a multi-million dollar bank leasing scheme
and would eventually be incarcerated in a federal prison.
In effort to suppress negative content appearing about them online, which began appearing
after Dr. Scott Connelly exposed them, ADAM ZUCKERMAN and DARREN MEADE, using
company I Progenex funds, hired Michael Roberts' company, Rexxfield, to help fix I bolster
their respective online reputations.
In February 2011, ADAM ZUCKERMAN, DARREN MEADE, and their criminal accomplices
worked to seize control and ownership of Michael Roberts' company, Rexxfield, for the
purpose of usurping the rights to an existing contract Rexxfield had with MATTHEW
COOKE for the use of an illegal SQL technology, which, when deployed, could effectively
remove webpages from the internet.
ADAM ZUCKERMAN and DARREN MEADE sought to monetize this technology by creating
an online reputation management company that would market this illicit technology /SQL
16
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
injection hack as an online "reputation management" service that offered to "repair" an
unsuspecting customer's online reputation by removing whatever webpage(s) the customer
believed was damaging the customer's reputation (or the customer's competitors webpage
for that matter}, using the above-mentioned SOL hack. ADAM ZUCKERMAN and DARREN
MEADE charged up to $5,000.00 per removal.
Progenex funds were used to negotiate and execute a partnership agreement between
ADAM ZUCKERMAN and Rexxfield, and in Feb 2011, Progenex funds were embezzled to
cure an existing default of the Rexxfield-Cooke agreement. Unbeknownst to Rexxfield, this
partnership agreement granted ADAM ZUCKERMAN, DARREN MEADE, and their
accomplices, a sixty-percent (60%) controlling interest in Rexxfield and transferred the
rights to this illicit technology from Rexxfield to an entity wholly owned by ADAM
ZUCKERMAN and his accomplices. Acquiring Michael Roberts' business and deploying an
illegal hacking technology on a mass scale for profit, in addition to being well outside the
scope of Progenex's charter, was patently illegal.
In the latter half of January 2011, DARREN MEADE e-mailed Rexxfield employee Paul
Portelli for the purpose of trying to go behind Michael Roberts' back to discover the contact
information for MATTHEW COOKE (purported inventor and proprietor of this illicit SOL
technology) to solicit I court MATTHEW COOKE and his hacking technology away from
Michael Roberts I Rexxfield and into the folds of DARREN MEADE and ADAM
ZUCKERMAN's ongoing criminal enterprise (i.e., cutting out the middle man, Michael
Roberts)
On February 19, 2011, DARREN MEADE asked ADAM ZUCKERMAN for the address of
Paul Portelli (Michael Roberts' I Rexxfield employee) so that DARREN MEADE could go
over to Paul Portelli's home and intimidate him with a 9mm pistol.
On February 20, 2011, DARREN MEADE suggested that he and ADAM ZUCKERMAN
should begin publicly accusing Michael Roberts of child molestation to pressure Michael
Roberts' into giving DARREN MEADE and ADAM ZUCKERMAN's criminal organization the
exclusive rights to MATTHEW COOKE's illicit SOL technology.
On February 20, 2011, in an e-mail to ADAM ZUCKERMAN with the subject heading
"Conspiracy Theory Gone Wild," DARREN MEADE suggested that he and ADAM
ZUCKERMAN begin publicly accusing Michael Roberts of hiring Dustin Wehde to kill
TRACEY RICHTER (i.e., accuse Michael Roberts of being criminally responsible for Dustin
Wehde's murder) to pressure and leverage Michael Roberts into giving DARREN MEADE
and ADAM ZUCKERMAN's criminal organization the exclusive rights to MATTHEW
COOKE's illicit SOL technology. DARREN MEADE suggested that he and ADAM
ZUCKERMAN have lunch the following day and "devise how to play this card" against
17
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Michael Roberts.
On February 23, 2011, DARREN MEADE told Paul Portelli that DARREN MEADE was
aware of ADAM ZUCKERMAN's criminal history and, despite this, continued to work for
ADAM ZUCKERMAN and their criminal organization because they were his "partners" and
he (DARREN MEADE) wanted to make "millions" removing RIPOFF REPORT complaints
from the internet using MATTHEW COOKE's illicit SOL hack. This is absolute proof
DARREN MEADE was aware of ADAM ZUCKERMAN's criminal behavior, and was quite
content to assist in covering up the same.
DARREN MEADE continued to actively engage in this conspiracy until February 24, 2011,
when he learned that ADAM ZUCKERMAN and his other criminal co-conspirators had
usurped the SOL partnership opportunity for themselves and effectively disenfranchised
DARREN MEADE from their ongoing criminal endeavors, including their planned
development of a reputation management business with MATTHEW COOKE (and his illegal
hacking code), which meant DARREN MEADE would no longer receive his weekly CEO
"paycheck" from Progenex, and was no longer eligible for the bonus that was contingent on
his successfully harassing and defaming witness I litigant Dr. Scott Connelly into
' submission.
On February 24, 2011, DARREN MEADE reached out to Paul Portelli, the Rexxfield
DARREN MEADE sought intimidate with a 9mm pistol just five days prior (February 19,
2011 ), and Michael Roberts, and told them that he (DARREN MEADE) had resigned from
Progenex to protect Rexxfield and their interests in the deal with MATTHEW COOKE. Also
during this conversation, DARREN MEADE told Michael Roberts and Paul Portelli that he
(DARREN MEADE) and ADAM ZUCKERMAN had sold over $50,000 of "RIPOFF REPORT
removals" in just one week. DARREN MEADE told Michael Roberts and Paul Portelli the
following about his experience in removing RIPOFF REPORT complaints from the internet
for mass profit:
Because when you, you know - I cold-called people to see what would happen is you
(inaudible) and we just went on and made phone calls. And you essentially get cussed out
initially because they have been hit up by everybody, and some of the people have paid
money and nothing happened for them. But then they are all willing to go ahead and move
forward and try it out. So if you had it on a larger scale and say you were doing (inaudible)
$500, they could still sell it for 15 to 3,000, you have a lot of revenue. If you did a thousand a
month with one wholesaler, that's $500,000 coming in. What's your overhead on that? A
couple months of beating bushes to pull the wholesalers together, and in the interim, you
could sit and [could continue to make money removing RIPOFF REPORT complaints
yourself].
DARREN MEADE also told the two that the only reason he did not resign sooner was
18
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
because he needed Progenex's resources to help repair his online reputation (i.e., money to
pay professionals to remove derogatory content about him from the internet), which had
been badly damaged after his role in the group's ongoing criminal enterprise had been
exposed by its victims. To support this, DARREN MEADE told Michael Roberts and Paul
Portelli the following:
I mean, you have to --you asked me last night why --why I was still in Progenex, and I said,
did you see what happened to my [online] reputation? So if you Google [my name, DARREN
MEADE] and Progenex and you start clicking on all the links ... and some different websites
they have [up about DARREN MEADE's and ADAM ZUCKERMAN's ongoing criminal
activities] ... they are complete character assassinations. So, for me to be h i ~ e as a
consultant to work for somebody right now, I would never pass a due diligence.
Also during this conversation, DARREN MEADE told Michael Roberts and Paul Portelli that
he (DARREN MEADE) and ADAM ZUCKERMAN planned to "just [remove] RIPOFF
REPORT [complaints] ... and make a lot of money from it." DARREN MEADE told Michael
Roberts and Paul Portelli that he (DARREN MEADE) had a contractual right to MATTHEW
COOKE's illicit hacking technology, and that he had "noticed [ADAM ZUCKERMAN]" that he
planned to exercise this right. Incredibly, DARREN MEADE told Michael Roberts and Paul
Portelli that he was aware ADAM ZUCKERMAN had been using the alias "ADAM STUART"
to conceal his true identity from Progenex's shareholders I investors, because said
individuals would probably not have been so willing to "invest" in ADAM ZUCKERMAN's
new company or Progenex if they knew it was being ran by a convicted felon on pretrial
release and was awaiting sentencing for his principal role in a multi-million fraudulent bank
leasing scheme. DARREN MEADE also told Paul Portelli and Michael Roberts that ADAM
ZUCKERMAN had instructed DARREN MEADE to create "wholesalers that can sell a
couple thousand RIPOFF REPORT [removals] per month," and that "they" would sell these
wholesalers a one-time "franchise [fee] (for access to the illicit SQL hack) for ... $25,000." At
the end of this conversation, DARREN MEADE invited Michael Roberts and Paul Portelli
over to his Laguna Beach to continue their discussion.
On February 27, 2011, in what was clearly an effort to intimidate ADAM ZUCKERMAN and
DARREN MEADE's other (former) criminal co-conspirators from shying away from the deal
with MATTHEW COOKE for the illicit hacking technology, DARREN MEADE, in an
announcement on the free press release distribution service www.PRLOG.com, announced
his resignation as CEO of Progenex, and in doing so, named ADAM ZUCKERMAN as the
company's "major beneficial stakeholder, not "ADAM STUART," the alias DARREN MEADE
and the criminal enterprise had been using to conceal ADAM ZUCKERMAN's true identity.
In this press release, which DARREN MEADE wrote in the third person, DARREN MEADE
said, among other things, that "I cannot in good conscience continue due in part to the
19
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
irreconcilable philosophical differences I have with the major beneficial stakeholder ADAM
ZUCKERMAN who for the most part controls the company and related entities."
The evidence shows, however, that the only irreconcilable philosophical difference
DARREN MEADE had with his former criminal co-conspirators was that DARREN MEADE
believed he was unfairly ousted from the criminal enterprise and that he (DARREN MEADE)
alone should have MATTHEW COOKE's illicit hacking technology .
. On February 28, 2011, in an e-mail, DARREN MEADE informed MATTHEW COOKE, the
inventor I owner of this illicit hacking technology, that he (DARREN MEADE) had a
"unilateral non-circumvention agreement" that gave DARREN MEADE a priority claim to
MATTHEW COOKE's illicit SOL hack over that of ADAM ZUCKERMAN's criminal
organization. DARREN MEADE also informed MATTHEW COOKE that "ALEXANDER
BORJIA" (another ADAM ZUCKERMAN alias) was really convicted felon ADAM
ZUCKERMAN, and that any further dealings related to the illicit SOL hack between
MATTHEW COOKE and ADAM ZUCKERMAN violated DARREN MEADE's contractual
rights to the illicit SOL hack.
Later that same day, MATTHEW COOKE, a man with whom DARREN MEADE had
extensively communicated in the previous two or three months, responded to DARREN
MEADE's above-email as follows: "Dear Mr. Meade, I do know you, nor have I ever been a
party to any agreement with you, and I do not appreciate the continuous calls and emails. I
expect that this communication is the last of our dealings as we have nothing further to
discuss." Shortly after sending this response to DARREN MEADE, MATTHEW COOKE
sent an e-mail to Michael Roberts wherein MATTHEW COOKE admitted that DARREN
MEADE (not "a man named DARREN MEADE" or "a DARREN MEADE") had just sent him
a "confusing" e-mail message and referred to DARREN MEADE by his first name, "Darren."
Following this failed, frenetic attempt to cajole and coerce MATTHEW COOKE and ADAM
ZUCKERMAN into letting him back into the criminal enterprise's SOL licensing I RIPOFF
REPORT removal scheme, DARREN MEADE, forced to confront the realities bearing down
on him (unemployment and being a named defendant in a complex civil fraud proceeding,
neither of which could be mitigated if the truth about his actions while acting as the CEO of
Progenex were revealed) instigated an ever escalating feigned "whistle-blower" campaign to
notify I inform law enforcement and the media of ADAM ZUCKERMAN's (formerly ADAM
ZUCKERMAN and DARREN MEADE's) organization's ongoing criminal activities, all in
effort to obfuscate his responsibility and involvement for the same crimes, which he had
committed alongside them as Progenex's CEO. However, as the foregoing demonstrates,
the ONLY thing responsible for DARREN MEADE's twenty-four hour transformation from
degenerate criminal to whistleblowing white knight, was that he learned ADAM
20
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
ZUCKERMAN and his other former co-conspirators had kicked him out of the "deal" and he
would no longer have access to MATTHEW COOKE's hacking code to make "millions"
removing RIPOFF REPORT complaints.
On March 4, 2011, DARREN MEADE told Michael Roberts that "at the end of the day, [Dr.
Scott Connelly] is a [ADAM ZUCKERMAN's victim] just like you, [Michael Roberts].
On November 21, 2011, DARREN MEADE made a sworn declaration to the Federal Court
in which he had stated he intimate knowledge that his former accomplices and co-
conspirators, ADAM ZUCKERMAN, KIRK MCMAHAN, and others, had effectively
reconstituted their fraudulent BRICKBANC ("Operation Lease Fleece") operations under the
name XBANKER while ADAM ZUCKERMAN and KIRK MCMAHAN were on pretrial
release with the federal government. Below is an excerpt from DARREN MEADE's sworn
declaration:
In late 2010, I was present during a meeting where [ADAM ZUCKERMAN] and KIRK
MCMAHAN became very concerned that if the true nature of the activities taking place at
XBANKER were revealed they would have a negative impact on their pending sentencing in
the BRICKBANC case. As a result they decided to do two things. First, ADAM
ZUCKERMAN's mother, MIRIAM ZUCKERMAN, would be prohibited from entering the
building and communicating with any XBANKER customers out of a fear that the customers
would make a connection between MIRIAM ZUCKERMAN and ADAM ZUCKERMAN and
thus reveal his background. Second, XBANKER's operations would have to be shut down by
January 2011.
Bank records and other information obtained by law enforcement and other information
demonstrates that ADAM ZUCKERMAN, KIRK MCMAHAN, while on pretrial release and
awaiting sentencing, along with DARREN MEADE and a handful of others, essentially
reconstituted the operations of BRICKBANC ("Operation Lease Fleece") under the name
XBANKER.
In the weeks and months that followed his reluctant departure from ADAM ZUCKERMAN's
organization, DARREN MEADE, on multiple occasions, told Michael Roberts, Dr. Scott
Connelly, the United States Department of Justice, including numerous FBI Special Agents
and Assistant United States Attorneys, and others, that he (DARREN MEADE) was duped
by ADAM ZUCKERMAN (aka ADAM STUART, aka ALEXANDER BORJIA) and his other
former co-conspirators and that Michael Roberts and Dr. Scott Connelly were also victims of
ADAM ZUCKERMAN and his organization (which, from June 2010 through February 24,
2011, included DARREN MEADE).
On June 21, 2011, and September 26, 2011, DARREN MEADE was deposed in Connelly v.
Does, Superior Court Of The State Of California, County Of Orange, Case No. 30-2011-
21
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
00453171. In this deposition, DARREN MEADE testified to the following:
He (DARREN MEADE) was hired by ADAM ZUCKERMAN to use the internet to defame
and harass Dr. Scott Connelly to pressure Dr. Connelly into settling his civil case with
ADAM ZUCKERMAN at al. and ending Dr. Scott Connelly's efforts to have law
enforcement revoke ADAM ZUCKERMAN's and KIRK MCMAHAN's pretrial release (i.e.,
harass and defame a witness to obtain some form of advantage over the witness in
pending litigation).
He (DARREN MEADE) was offered premium incentives, both in cash ($200,000.00) and
equity in Progenex, provided his defamation campaign proved successful in securing a
settlement from Dr. Scott Connelly.
Michael Roberts was ADAM ZUCKERMAN's victim, not his co-conspirator, that it was
ADAM ZUCKERMAN who threatened his life (not Michael Roberts as DARREN MEADE
would later allege).
He and the above-mentioned convicted felons conspired to use stolen Progenex funds to
procure an illicit hacking technology for the purpose of creating a reputation management
service that would charge its customers, victims I subjects of online defamation,
$5,000.00 to remove a RIPOFF REPORT complaint or other defamatory content on the
internet, and would accomplish this by injecting illicit source code (hacking) into RIPOFF
REPORT's servers.
He (DARREN MEADE) and ADAM ZUCKERMAN sold $50,000 worth of [RIPOFF
REPORT removals] in less than a week, maybe spending a total of only three hours on
the phone. DARREN MEADE further testified that he and ADAM ZUCKERMAN did not
need to advertise their services, because all they did was read the RIPOFF REPORT
website and wait for somebody to publish something derogatory about a business and
you would just turn around and call the business an say, "I see that you have this
problem. We can make it go away for $3,000." DARREN MEADE further testified that
"THEIR largest client's were attorneys."
DARREN MEADE further testified that "Ripoff Report never deletes anything written
about somebody. So it's the perfect place to defame somebody because it will always
stay up, and for some reason it winds up ranking on the first page of Google. So if you
want to destroy somebody's reputation, that's a great place to do it."
Michael Roberts was not aware that deploying the SQL code was illegal at the time
Michael Roberts was attempting to purchase it.
A review of both DARREN MEADE's e-mail communications, disclosures he made to
federal law enforcement officials from April 2011 through Nov 2011, as well as admissions
he made in his above-mentioned deposition, leaves no doubt that as of the date he
assumed the role as Progenex CEO, which was in June 2010, as well as throughout his
22
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
entire tenure there, DARREN MEADE knew ADAM ZUCKERMAN was using a number of
aliases to conceal his criminal past. This proves DARREN MEADE was fully aware of the
criminal scheme to steal Progenex funds and defraud its shareholders. In fact, in a
November 15, 2011, e-mail, DARREN MEADE wrote that he "was the CEO of Progenex
[and] knew what was being committed financially."
On August 29, 2011, at KIRK MCMAHAN's sentencing hearing, while sitting alongside a
victim of ADAM ZUCKERMAN's most recent fraudulent operation, XBANKER, DARREN
MEADE told a sitting Federal District Court Judge that ADAM ZUCKERMAN and KIRK
MCMAHAN threatened to explode DARREN MEADE's brain with a .50 caliber bullet if
DARREN MEADE ever threatened to expose them.
On October 24, 2011, TRACEY RICHTER's murder trial started.
On October 25, 2011, in an email to Michael Roberts, DARREN MEADE thanked Michael
Roberts for providing him updates on TRACEY RICHTER's murder trial and told Michael
Roberts that he was praying for him.
On October 28, 2011, DARREN MEADE began making extortive demands of State's
witness Michael Roberts for financial payments, which Michael Roberts refused. As a result
of Michael Roberts' refusal to give DARREN MEADE money, DARREN MEADE's demands
and threats towards Michael Roberts escalated.
In November 2011, flat broke and bereft of any employment, with his history of fraud having
been exposed online, DARREN MEADE, desperate for a source of income, saw an
opportunity to forge a relationship with ED MAGEDSON, the owner, operator, and "EDitor"
of Ripoffreport.com, by providing ED MAGEDSON with information about the ongoing report
removal attacks that he (DARREN MEADE), ADAM ZUCKERMAN, MATTHEW COOKE,
and his other co-conspirators had been executing with the SQL technology. However,
DARREN MEADE (assumedly) failed to tell ED MAGEDSON I RIPOFF REPORT and the
FBI that he actively and enthusiastically participated in this same scheme before he got
booted out of the deal. In fact, DARREN MEADE would later admit that he (DARREN
MEADE) removed derogatory RIPOFF REPORT complaints about himself (DARREN
MEADE) by injecting this illegal source code into RIPOFF REPORT's servers. Furthermore,
during his conversation with Paul Portelli on 23 Feb 2011, DARREN MEADE stated that the
reason for his voluntary continued involvement with convicted felon ADAM ZUCKERMAN
was to "make money off the [RIPOFF REPORT removals]."
On November 5, 2011, two days before TRACEY RICHTER was to be sentenced,
DARREN MEADE launched his first reprisal against Michael Roberts when, in the comment
section below an online news story about TRACEY RICHTER's case, he accused Michael
23
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Roberts of being criminally responsible for Dustin Wehde's murder.
The next day, on November 6, 2011, the jury in TRACEY RICHTER's murder trial handed
down their guilty verdict.
On November 10, 2011, TRACEY RICHTER's good friend DONNA BISTRICAN and
DARREN MEADE had a phone conversation that lasted over one hour.
On November 22, 2011, ANNA RICHTER called DARREN MEADE (one minute).
On November 23, 2011, TRACEY RICHTER wrote the following in a letter to Jim Landa, a
convicted child molester incarcerated in Wisconsin: "Recently a man came forward with
claims my [second] husband, [Michael Roberts] threatened to kill him and befriended a
mentally unstable man and got that man [sic] to break into his [sic] present home."
On November 27, DARREN MEADE called ANNA RICHTER and the two spoke for seven
minutes.
On November 28, 2011, ANNA RICHTER and DARREN MEADE had a phone conversation
that lasted over eighty-three (83) minutes.
On November 29, 2011, ANNA RICHTER and DARREN MEADE had a phone conversation
that lasted about fifty (50) minutes.
On December 1, 2011, DARREN MEADE and RUSSELL SCHERTZ, TRACEY RICHTER's
fiance, spoke on the phone for eighty-seven (87) minutes.
Between December 12 and 15, 2011, DARREN MEADE visited Arizona and stayed in a
hotel on the same road on which RIPOFF REPORT's attorneys are located.
In December 2012, DARREN MEADE began publishing harassing and defamatory stories
on the internet about the State's witnesses, most of which he and others published as
"complaints" on the purported consumer advocacy website www.ripoffreport.com (RIPOFF
REPORT). Among many other things, these "complaints" accuse the State's witnesses of
murder, child molestation, terrorism, perjury, and a myriad of financial crimes, including
fraud.
RIPOFF REPORT
RIPOFF REPORT (www.RipOffReport.com) is incorporated in the State of Delaware as
XCENTRIC VENTURES, LLC ("RIPOFF REPORT). ED MAGEDSON is the owner,
24
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
operator, and "EDitor" of RIPOFF REPORT. RIPOFF REPORT earns money through
advertisements on its website. RIPOFF REPORT is an Arizona based company, but is
incorporated in the State of Delaware. RIPOFF REPORT derives financial benefit and
income by selling advertisement space on its website and through its "Corporate Advocacy
Program" and its RIPOFF REPORT Verified program (collectively "CAP"), both of which
are expensive services provided solely by RIPOFF REPORT, which mitigate, and in some
instances, remove negative, defamatory RIPOFF REPORT complaint for a hefty fee.
The RIPOFF REPORT enterprise markets the CAP programs to the subjects of Reports,
typically after strongly urging them to file rebuttals. By joining CAP or otherwise making
financial arrangements with the RIPOFF REPORT enterprise, a subject can buy the
privilege of essentially writing (or approving) his or her own Google search result. The CAP
member writes or approves between 250 and 350 additional words of positive content that
will be inserted into the body of a Report and also in a known strategic location in the HTML
for the Report. 250 words is just the right amount of text to push the surrounding negative
content so far down in the HTML as to be irrelevant to search engines. Thus, negative
content virtually disappears from the Google search results for CAP members, replaced by
the words approved by the CAP member. Because Google's search algorithms are
generally influenced to select text that "matches," between both a web page and the
corresponding HTML (that is, identical text that is present in both), putting the positive
content in the strategic location in the HTML, along with a matching block of text in the
Report effectively negates the harmful effect of the Report with the Google search engine.
According to RIPOFF REPORT employee I agent SIAMACK YAGHOBI (aka SAM
YOUBANKS), RIPOFF REPORT I XCENTRIC VENTURES is worth more than 35 million
dollars.
On December 10, 2011, DARREN MEADE wrote the following Facebook message to a
friend: "I leave for Arizona on Monday to meet with the FBI and then for a job interview
afterwards ... looks like I might do an interview on Dateline NBC in 2-3 weeks to get the story
out on all of this. The job interview is in [Arizona], but I would still work from Laguna."
Between December 12 and 15, 2011, DARREN MEADE visited Arizona and stayed in a
hotel on the same road on which RIPOFF REPORT's attorneys are located.
On December 21, 2011, DARREN MEADE sent an e-mail, which contained the job proposal
he pitched to ED MAGEDSON I RIPOFF REPORT.
In early January 2012, ED MAGEDSON and RIPOFF REPORT possessed and had
25
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
knowledge of DARREN MEADE's aforementioned deposition.
On or around January 1, 2012, DARREN MEADE told Dr. Scott Connelly he was hired by
TRACEY RICHTER's mother, ANNA RICHTER, and brother to help TRACEY RICHTER get
a new trial.
On January 1, 2012, TRACEY RICHTER told ANNA RICHTER to have BERT PITMAN see
if he could get "[DR. JOHN PITMAN's former girlfriend, Allisan Tucker] to turn on Dr. John
Pitman." TRACEY RICHTER added that [AIIisan Tucker] is looking to further her career and
if she [had] something on [Dr. John Pitman] that could be helpful, know what I mean?"
TRACEY RICHTER told ANNA RICHTER that "it would be heaven" and would "serve [Dr.
John Pitman] right" if he was betrayed by someone he put before his son (BERT PITMAN).
On January 3, 2012, ANNA RICHTER told TRACEY RICHTER that DARREN MEADE was
"going after" Michael Roberts.
On January 20, 2012, TRACEY RICHTER told BERT PITMAN he "[needed] to work magic."
TRACEY RICHTER told BERT PITMAN to talk to Dr. John Pitman's nurses to see if any of
them had information that would prove Dr. John Pitman lied when he testified against
TRACEY RICHTER. BERT PITMAN said he had talked to one of Dr. John Pitman's nurses
and could get more information from that nurse. TRACEY RICHTER told BERT PITMAN to
tell this nurse that the nurse would have the potential to save someone's life (TRACEY
RICHTER's life). BERT PITMAN said this nurse wanted to talk, and another one of Dr. John
Pitman's employees was tired of Dr. John Pitman. BERT PITMAN stated he would talk to
people who work for Dr. John Pitman. BERT PITMAN told TRACEY RICHTER he did not
know the situation with Dr. John Pitman's former girlfriend, Allisan Tucker, and whether she
would tell BERT PITMAN anything. TRACEY RICHTER said she thought "[AIIisan Tucker]
would "f**k Dr. John Pitman over in a heartbeat." BERT PITMAN said the last time he went
out on a limb for TRACEY RICHTER, his father, Dr. John Pitman, cut him off, so he (BERT
PITMAN) needed to be careful, and should hire a lawyer before he talked to Allisan Tucker,
because it could backfire on him (BERT PITMAN). TRACEY RICHTER directed BERT
PITMAN to get Allisan Tucker's contact information and give it to ANNA RICHTER, and
ANNA RICHTER would contact Allisan Tucker so that BERT PITMAN's participation in the
matter would not be known to Dr. John Pitman.
On January 26, 2012, Journalist Glenn Puit, published RIPOFF REPORT complaint No.
article 829020, which is more or less a damning account of the criminal activities of
convicted felons ADAM ZUCKERMAN and KIRK MCMAHAN described earlier herein.
On January 28 and 30, 2012, DARREN MEADE wrote the following to Dr. Scott Connelly
and Dr. Scott Connelly's attorney: "It seems my deposition was sent to a third-party the
26
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
General Counsel for Ripoff Report. Do you have any idea how this happened?"; "I have not
authorized ANY dissemination of the depositions"; "I need to ask for you to keep [your]
promise .... [that you] will not disseminate [DARREN MEADE's deposition to third parties
without clearing it with [me, DARREN MEADE]"; and "going behind my back [and giving my
deposition to] [RIPOFF REPORT] is bad faith; "I explained to you the FBI investigation [into
the RIPOFF REPORT hacking to remove complaints for profit, of which DARREN MEADE
was part] is in it's fragile state. That the boiler room information should funnel through me,
instead you had [your attorney] reach out directly and he offers up my deposition [to
RIPOFF REPORT]?"
On February 3, 2012, TRACEY RICHTER asked ANNA RICHTER whether there was
anything else on RIPOFF REPORT and I or whether RIPOFF REPORT was going after
Michael Roberts, "big time." ANNA RICHTER said RIPOFF REPORT was going after
Michael Roberts, "big time." ANNA RICHTER said DARREN told her RIPOFF REPORT had
Michael Roberts on the run and that Michael Roberts had to be going crazy. ANNA
RICHTER said RIPOFF REPORT had not yet published her "complaint" on RIPOFF
REPORT, even though she had submitted it to RIPOFF REPORT a number of days prior.
TRACEY RICHTER directed her mother to check RIPOFF REPORT every single day.
On February 14, 2012, DARREN MEADE authored I published RIPOFF REPORT complaint
No. 839253, the first version of "Google-Cide Exposed By The Man Who Knew Too Much,
DARREN MEADE threatened and life in danger - SEO (Search Engine Optimization)
Reputation Management dark side," which is an oft updated RIPOFF REPORT complaint
deliberately crafted to deflect and obfuscate DARREN MEADE's knowledge of and
enthusiastic participation in the criminal scheme leading to the executed SQL hack licensing
agreement between ADAM ZUCKERMAN and MATTHEW COOKE. In this original report
(and subsequent updates by DARREN MEADE himself) DARREN MEADE admitted his eye
witness status but purposely omitted critical facts regarding the true nature of his volitional
participation with ADAM ZUCKERMAN's plan from November 2010, continuously up to
February 24, 2011, at which time DARREN MEADE became aware that ADAM
ZUCKERMAN had usurped the SQL licensing opportunity for himself and was proceeding
without DARREN MEADE. To further camouflage his culpability he even included facts
concerning the involvement of Reputation.com in the bidding process for exclusive access
to the license rights to MATTHEW COOKE's SQL code:
I was recruited as the CEO of another [ADAM ZUCKERMAN]-controlled entity, Progenex,
from which he embezzled the funds to acquire both a controlling interest in Rexxfield and the
rights to the SQL injection code. In completely unrelated news, the hacker who wrote it
MATIHEW COOKE was the brain behind RemoveYourName.com. That is, until he sold the
domain (is that all?) to the well-meaning folks at Reputation.com. Draw your own
27
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
conclusions.
The underlined hyperlink (see below) included in the original (and subsequent updates)
provided evidence of the statement by MATTHEW COOKE referring to an offer of
$60,000.00 put forth by Reputation Defender (name changed to Reputation.com in January
2011) for exclusive use rights to the criminal SQL code.
http://www.ripoffreport.com/features/audio/Matthew-Cooke-Caii-With-Michaei-Roberts.mp3
Bank records recovered in the course of the Progenex embezzlement investigation
confirmed that MATTHEW COOKE's online property RemoveYourName.com was acquired
as an "asset purchase" by Reputation Defender (now Reputation.com) in December of 2010
less than 30 days after the execution of the Rexxfield-Cooke SQL license agreement (aka
'Trade Secret Purchase agreement") was executed. Financial transactions and other
records also indicate that during that same time frame (Oct-Dec 2010) MATTHEW COOKE
was operating an "affiliate partner" network in which dozens of existing online reputation
management companies were paying MATTHEW COOKE to remove clients' online
complaint reports by using his SQL code on a fee-for-service basis. The evidence shows
that by late 2010 MATTHEW COOKE had also created an online business model of
"reputation racketeering" in which his online property RipOffRant.com, a website, which
operated the same as RIPOFF REPORT, was used to create defamatory reports about
individuals and businesses alike. Victims of online defamation would then be solicited via
one of MATTHEW COOKE's (or one of his affiliate partner's) reputation management
companies, proffering removal services.
This business model is identical to the organization disclosed by the investigation and
prosecution by California State Attorney Kamala Harris of REVENGE PORN website
operator KEVIN CHRISTOPHER BOLLAERT. Evidence disclosed to the public indicates
KEVIN BOLLAERT was earning tens of thousands of dollars per month by simultaneously
operating dual websites. One website posted nude pictures of female victims while the
other (ChangeMyReputation.com) would solicit these same victims for the removal of the
offending pictures. Many of the offending images were obtained by hacking the victims
email accounts and cell phones.
http://www.omaha.com/news/nation/alleged-revenge-porn-site-operator-heads-to-
triallarticle_Od36d51 c-eb6d-5bb0-884d-2b69beaab1 09.html
DARREN MEADE also said the following in this RIPOFF REPORT complaint (No. 839253):
When I told [ADAM ZUCKERMAN] I would not be involved, I was offered a six-figure bribe
and an equity stake in the venture. I chose option B, tendering my resignation. Shortly
thereafter, I received an audio recording wherein [ADAM ZUCKERMAN] and Rexxfield
operatives describe in great detail the effects a .50 caliber bullet will have on my
28
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
brain should I ever go public with this information. I suppose it's mildly amusing audio if you
can ignore the fact that it's coming from someone with a history of criminal violence THIS IS
A CALL FOR HELP. I am literally putting my life on the line to expose not just another
Internet scam, but a threat against the very fabric of our society: The right to speak the truth
and be heard. I only hope someone hears me before it's too late.
On February 21, 2012, ANNA RICHTER told TRACEY RICHTER that DARREN MEADE
told her that Michael Roberts and his children left the United States using fraudulent
passports. ANNA RICHTER stated TRACEY RICHTER and Michael Roberts' son, N.R., is
still in the United States because Michael Roberts' wife, Dr. Heidi Roberts (aka Heidi
Forsbacka) hated N.R. ANNA RICHTER stated she was going to give TRACEY RICHTER's
fiance, RUSSELL SCHERTZ, information about Michael Roberts and TRACEY RICHTER
and Michael Roberts' children, N.R. and M.R.
On February 21, 2012, TRACEY RICHTER directed her mother to get orders from the U.S.
State Department and Immigrations and Customs Enforcement (ICE) to get a "printout" of
all Michael Roberts' wife's and children's flight activities and then get their credit information
to track their spending to locate Michael Roberts. The two discussed filing kidnaping
charges against Michael Roberts and his wife, Dr. Heidi Roberts. TRACEY RICHTER said
they needed to obtain a court order to give to the Australian Consulate in Chicago, Illinois,
and any other information that would allow them to find N.R., M.R., and Michael Roberts.
TRACEY RICHTER s i ~ she believed Michael Roberts was fraudulently receiving welfare-
type benefits for himself and their children from the Australian government and that they
could get the Australian government to "go after" Michael Roberts. ANNA RICHTER said
that JOHN RICHTER told her that he believed the same about Michael Roberts receiving
welfare benefits. TRACEY RICHTER gave ANNA RICHTER a list of information they
needed to obtain on I about N.R. and M.R. TRACEY RICHTER said they needed to get
Michael Roberts' wife's travel records from ICE because Michael Roberts may have
changed his name, but that Heidi Forsbacka (aka Dr. Heidi Roberts) may not have. ANNA
RICHTER said DARREN MEADE also asked her to get information about Michael Roberts'
wife, Dr. Heidi Forsbacka (aka Dr. Heidi Roberts). TRACEY RICHTER stated that ICE
would not give this information without a court order. TRACEY RICHTER said they needed
to obtain a court order directing Michael Roberts to return to the U.S. with the children within
forty-eight hours, and if he had them in Australia, it would be impossible for him to comply
with the Court's order, which would allow them to have an amber alert issued and have
Michael Roberts held in contempt of court. ANNA RICHTER stated that Michael Roberts is
scared because he knows he is going to be arrested and that Michael Roberts probably
gave the children to his wife, Dr. Heidi Forsbacka (aka Dr. Heidi Roberts}, believing he was
going to be arrested. ANNA RICHTER said she recently sent an e-mail to TRACEY
29
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
RICHTER's fiance, RUSSELL SCHERTZ, concerning the foregoing. TRACEY RICHTER
said she make an affidavit that she did not give Michael Roberts permission to take the kids
out of the country and, "if [she had] to," she would swear that Michael Roberts once
threatened to take the children to Thailand. TRACEY RICHTER said they needed to put up
a website about Michael Roberts's wife, Dr. Heidi Forsbacka (Dr. Heidi Roberts), M.R., and
N.R., to help find the children. ANNA RICHTER said she would get DONNA BISTRICAN to
help her create this website.
On February 23, 2012, TRACEY RICHTER gave her passwords to her two computers to
ANNA RICHTER. TRACEY RICHTER indicated one of her computers was at her fiance,
RUSSELL SCHERTZ's home, and the other was in ANNA RICHTER's possession.
TRACEY RICHTER told ANNA RICHTER to search the computer for files labeled
"Passport" and "Michael Ross Roberts." TRACEY RICHTER indicated that the latter
contained all of Michael Roberts' personal information ANNA RICHTER said she told
RUSSELL SCHERTZ she would get him this information. TRACEY RICHTER said
RUSSELL SCHERTZ had checked to see if her and Michael Roberts' children, N.R. and
M.R, had passports by using their social security numbers and birthdates. ANNA RICHTER
said JOHN RICHTER told her that Michael Roberts obtained fraudulent passports for their
children TRACEY RICHTER said RUSSELL SCHERTZ and I or John Richter was I were in
the process of getting more information from the U.S. State Department and that she
wanted them to get the "guy from the State Department" on the phone. ANNA RICHTER
said she believed a warrant for Michael Roberts' arrest should be issued immediately for
"falsifying legal paperwork." TRACEY RICHTER said the guy at the U.S. State Department
is ready to issue an arrest warrant for Michael Roberts. TRACEY RICHTER said RUSSELL
SCHERTZ gave photographs of N.R. and M.R. to the "guy" at the U.S. State Department for
comparison. TRACEY RICHTER said Michael Roberts could have changed their
appearances.
On February 26, 2012, ANNA RICHTER asked TRACEY RICHTER whether RUSSELL
SCHERTZ talked to TRACEY RICHTER about her children. ANNA RICHTER said JOHN
RICHTER told her (ANNA RICHTER) that "people" who knew Michael Roberts believed he
was still in the U.S., but that DARREN MEADE believed TRACEY RICHTER and Michael
Roberts' daughter, M.R., was no longer in the U.S. ANNA RICHTER said JOHN RICHTER
was going to obtain information concerning Michael Roberts' travels with his children, N.R.
and M.R. ANNA RICHTER said someone authorized to access this information was going
to give it to JOHN RICHTER. TRACEY RICHTER said it was clear Michael Roberts did not
have his car registered in his name otherwise they would have found it. TRACEY
RICHTER told ANNA RICHTER to have DARREN MEADE include in his affidavit that he
heard through "the grapevine" that M.R. was not in the U.S. ANNA RICHTER said they
30
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
should soon learn whether M.R. was still in the U.S. because JOHN RICHTER was going to
use his source to find out whether the kids had traveled. ANNA RICHTER said JOHN
RICHTER can lawfully access certain government databases to see whether passports
have issued for N.R. and M.R., and whether the children had left the U.S. ANNA RICHTER
said JOHN RICHTER could lose his job if he did certain searches, but that the searches he
would be conducting were legal. ANNA RICHTER stated that they have done these
searches before on "someone" to see if that person has traveled out of the country.
On March 2, 2012, pursuant to a subpoena, SCA Smith provided an affidavit in Michael
Roberts and TRACEY RICHTER's custody modification proceedings, which supported
Michael Roberts. Later that day, John Richter sent an affidavit to RUSSELL SCHERTZ's
place of business, ConAgra Foods in Omaha, Nebraska, and RUSSELL SCHERTZ
forwarded the same to TRACEY RICHTER's attorney. In this his affidavit, JOHN RICHTER
referenced a criminal complaint that alleged Michael Roberts had called him on October 29,
2011, and threatened to shoot and kill John Richter with a sniper rifle. Also in his affidavit,
John Richter accused your applicant, SCA Smith, of committing a number of crimes,
including obstructing his police department's investigation into the alleged death made by
Michael Roberts.
Your applicant believes JOHN RICHTER fabricated this complaint against Michael Roberts
to access information that would not otherwise be available to JOHN RICHTER absent a
bona fide criminal investigation.
LOCATING MICHAEL ROBERTS, N.R., AND M.R.
As discussed earlier, immediately following TRACEY RICHTER's arrest, Michael Roberts
took custody of their children, N.R. and M.R., and moved to California where he was
enrolled in the State of California's victim protection program. Save for a few monitored calls
he allowed TRACEY RICHTER to have with their children, Michael Roberts did not allow
her and her family to have any contact with his children, or know their current whereabouts.
On August 6, 2011, TRACEY RICHTER told ANNA RICHTER, that TRACEY RICHTER's
son, N.R., who was three years old when TRACEY RICHTER murdered Dustin Wehde,
"[remembered] some things about the attack" and, therefore, needed to be added as
witness in her criminal case. TRACEY RICHTER told her mother that her criminal defense
attorney was attempting to find a lawyer to get an order prohibiting Michael Roberts from
31
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
leaving the United States with N.R. and M.R.
On August 9, 2011, after TRACEY RICHTER's bond review hearing, TRACEY RICHTER's
criminal defense attorney asked SCA Smith for Michael Roberts' address because they
were trying to find TRACEY RICHTER's children. This attorney also told SCA Smith that
they warned the U.S. State Department that Michael Roberts may be attempting to get U.S.
passports for N.R. and M.R. so he could take them out of the United States.
On August 20, 2011, TRACEY RICHTER told ANNA RICHTER that they checked an
address that they believed was Michael Roberts' primary residence. TRACEY RICHTER
stated that her brother, John Richter, a police detective in another state, had talked on the
phone with TRACEY RICHTER's criminal defense attorney(s) for three hours.
On August 25, 2011, TRACEY RICHTER's fiance, RUSSELL SCHERTZ, told TRACEY
RICHTER that he was thinking about filing kidnapping charges against Michael Roberts.
On August 26, 2011, RUSSELL SCHERTZ read TRACEY RICHTER the contents of an
online article concerning Michael Roberts and DARREN MEADE. TRACEY RICHTER told
RUSSELL SCHERTZ to contact the author of the article, who was I is believed to be
DARREN MEADE, using a "disposable e-mail." RUSSELL SCHERTZ and TRACEY
RICHTER discussed a list RUSSELL SCHERTZ had of past physical addresses for Michael
Roberts, which TRACEY RICHTER had compiled over the years.
On August 28, 2011, TRACEY RICHTER told RUSSELL SCHERTZ he needed to find a
way to have N.R. be made a witness in her murder case so that Michael Roberts would
have to bring him back to the area.
On September 4, 2011, TRACEY RICHTER told ANNA RICHTER, that "this DARREN
MEADE "[knew something about Michael Roberts]."
On September 7, 2011, TRACEY RICHTER's defense attorney's notified your applicant that
they intended to call TRACEY RICHTER's son, N.R., as a witness in TRACEY RICHTER's
murder trial.
On September 9, 2011, RUSSELL SCHERTZ told TRACEY RICHTER that they are trying
to find Michael Roberts' IP addresses and other information in effort to locate him and his
children. Later in this conversation, RUSSELL SCHERTZ and TRACEY RICHTER
conspired to sneak a television producer into TRACEY RICHTER's criminal depositions as
TRACEY RICHTER's "third attorney."
On October 4, 2011, one of TRACEY RICHTER's criminal defense attorney's asked SCA
Smith for Michael Roberts' address so they could serve him with a subpoena to testify in
TRACEY RICHTER's criminal case. SCA Smith told this criminal defense attorney that
32
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
"[p]ersonal service of any out-of-state subpoena for Michael Roberts can be made by
serving [his Iowa attorney]. .. at the below address."
On September 16, 2011, TRACEY RICHTER received a document sent to her by ANNA
RICHTER, which concerned Michael Roberts and DARREN MEADE's business
association. ANNA RICHTER told TRACEY RICHTER she found the document on the
internet. The document was a letter DARREN MEADE sent to the US DOJ on or around
July 22, 2011, wherein DARREN MEADE told the US DOJ that Michael Roberts was ADAM
ZUCKERMAN's victim.
On September 19, 2011, ANNA RICHTER told TRACEY RICHTER that her son, JOHN
RICHTER, had given her documents concerning Michael Roberts. ANNA RICHTER said
she planned to have JOHN RICHTER, a police detective in another state, look up personal
information about Michael Roberts and his associates.
On October 24, 2011, TRACEY RICHTER's murder trial began.
On October 28, 2011, about a week before the jury convicted TRACEY RICHTER of first
degree murder, JOHN RICHTER sent the following Facebook message to his nephew,
TRACEY RICHTER and Michael Roberts' son, N.R.:
Me, [TRACEY RICHTER]. [TRACEY RICHTER's sister], [ANNA RICHTER] and [RUSSELL
SCHERTZ] luve [sic] you guys very much, you should be, home soon. Tell [M.R.] I luve [sic]
her to [sic]." JOHN RICHTER went on to ask N.R. "where [sic] you guys living now?
On October 29, 2011, five days into TRACEY RICHTER's murder trial, JOHN RICHTER
alleged Michael Roberts called him at his police precinct that day and threatened his life.
The following is an excerpt from JOHN RICHTER's report concerning this alleged incident:
SAID VICTIM (DET. [JOHN RICHTER], #20768) WENT TO THE 002ND DIST. DESK TO
REPORT A TELEPHONE THREAT WITH SAID OFFENDER (ROBERTS, MICHAEL).
VICTIM RELATED THAT SAID OFFENDER CALLED HIS PLACE OF EMPLOYMENT[***)
AND STATED "YOU BETTER SHUT YOUR MOUTH ABOUT ME" WHEN THE VICTIM
ASKED THE OFFENDER TO REPEAT HIMSELF, THE OFFENDER STATED "KEEP IT UP,
AND KEEP IN MIND THAT I HAVE A VERY GOOD RIFLE SHOT." VICTIM THEN ASKED
OFFENDER IF HE WAS THREATENING HIM AND OFFENDER THEN STARTED
SCREAMING RELIGIOUS REFERENCE ABOUT REVENGE. THE PHONE CALL WAS
THEN DISCONNECTED AFTER MID SENTENCE. VICTIM RELATED THAT HE HAS
TAKEN SAID OFFENDER'S STATEMENT AS A DIRECT THREAT TO KILL HIM. THE
VICTIM IMMEDIATELY NOTIFIED HIS [SUPERVISING SGT) [OF THE INCIDENT AND
FURTHER INFORMED SGT. [SUPERVISING SGT] THAT SAID OFFENDER HAS A
PREVIOUS DOM. BATTERY CONVICTION AND IS NOT AUTHORIZED TO BE IN
POSSESSION OF ANY FIREARMS. [SUPERVISING SGT INFORMED] VICTIM TO
33
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
'
REPORT INCIDENT TO THE 002ND DIST. DESK. VICTIM GIVEN REPORT FOR
INCIDENT AND ADVISED ON [WRIT]/ORDER OF PROTECTION PROCEDURES.
On .November 7, 2011, TRACEY RICHTER was convicted of murder. TRACEY RICHTER's
crif11inal defense attorneys neither subpoenaed Michael Roberts or called N.R. as witness.
To believe John Richter here, you have to believe that Michael Roberts, on the precipice of
getting full custody of his children and finally being vindicated for any involvement in Dustin
Wehde's murder, after not speaking to JOHN RICHTER in more than a decade, while in
hiding, called JOHN RICHTER at his police precinct while JOHN RICHTER was on duty,
'
made the same death threat (sniper rifle) he allegedly made to DARREN MEADE in 2010,
(according to DARREN MEADE's second or third version of this supposed incident).
On.April 24, 2012, DARREN MEADE, in an e-mail to SCA Smith, knowingly provided false
information to SCA Smith to help TRACEY RICHTER get a new criminal trial and aid her in
her upcoming custody hearing. DARREN MEADE used the following e-mail address to
communicate with SCA Smith: [email protected].
I
DARREN MEADE also told SCA Smith the following:
!
He (DARREN MEADE) had information that TRACEY RICHTER's second ex-
husband, Michael Roberts, was responsible for Dustin Wehde's murder and that
he provided this information to law enforcement in Iowa in December 2010 and
January 2011.
Michael Roberts, not DARREN MEADE, partnered with ADAM ZUCKERMAN
and his criminal organization. In support of this, DARREN MEADE provided links
to his RIPOFF REPORT complaints about Michael .Roberts.
Michael Roberts had threatened to kill DARREN MEADE: "[Michael Roberts] let
me know that he owns a sniper rifle [sic] that he uses .50 caliber bullets 'and that
he is a very good shot."'
He (DARREN MEADE) was aware SCA Smith already provided testimony
favorable to Michael Roberts in Michael Roberts and TRACEY RICHTER's
custody proceedings in Buena Vista County, and, at the upcoming custody
hearing, SCA Smith needed to change his testimony and support TRACEY
34
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
RICHTER'S bid to have custody of N.R. and M.R. transferred to TRACEY
RICHTER's mother, ANNA RICHTER.
In the above-mentioned e-mail, DARREN MEADE provided SCA Smith with a link to
DARREN MEADE's Dropbox account, which account was linked to dmeade@kairos-
meade.com]. [kairos-meade is business entity solely owned and operated by DARREN
MEADE. The web domain for kairos-meade.com is serviced by GoDaddy]
DARREN MEADE sent blind copies of his e-mails to SCA Smith to ANNA RICHTER
([email protected]) and TRACEY RICHTER's fiance, RUSSELL SCHERTZ
([email protected]). Also on or around this same day (April 24, 2012), DARREN MEADE
sent a barrage of like-e-mails to more than ten news media outlets, including the Des
Moines Register.
DARREN MEADE's phone records, which were obtained by SCA Smith shortly after
DARREN MEADE contacted SCA Smith on April 24, 2012, revealed extensive
communications between DARREN MEADE and TRACEY RICHTER's friends and family.
On April 25, 2012, in a letter to Sac County Sheriff Ken McClure, RUSSELL SCHERTZ
wrote, "a man from California called [Sheriff McClure's Office] at least three (3) times in
early 2011 [sic] and left messages saying that he had information about [Michael Roberts]
being involved in a murder plot. .. " but [Sheriff McClure] failed to follow up with this "man
from California." Of course the "man from California" to whom RUSSELL SCHERTZ is
referring is DARREN MEADE. Also in this letter, RUSSELL SCHERTZ alleged the law
enforcement entities that investigated and prosecuted his fiance, TRACEY RICHTER, were
corrupt and I or incompetent, including the Douglas County Sheriffs Office (Omaha,
Nebraska). Many of the same allegations and conspiracies alleged by RUSSELL SCHERTZ
in t ~ s letter appeared later in DARREN MEADE's RIPOFF REPORT complaints concerning
TRACEY RICHTER and the State's witnesses. RUSSELL SCHERTZ sent copies of this
letter to over fifty people, including local and national media correspondents and U.S.
Senators. What is most troubling about the allegations RUSSELL SCHERTZ made in this
letter is that before his fiance was convicted for murder, RUSSELL SCHERTZ and TRACEY
RICHTER were using Michael Roberts' then-amicable relationship with DARREN MEADE
against him (Michael Roberts) in their custody proceedings. Additionally, on August 6, 2011,
RUSSELL SCHERTZ called DARREN MEADE "CRAZY." On August 29, 2011, RUSSELL
SCHERTZ told TRACEY RICHTER that DARREN MEADE was an "UNSTABLE
CHARACTER."
On April 26, 2012, ANNA RICHTER sent an e-mail from her account
[[email protected]] to a local newspaper journalist, which asked the reporter to
look at the RIPOFF REPORT story published by DARREN MEADE and added "[t]here is no
35
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
doubt in my mind that some of the [members of the jury who convicted her daughter,
TRACEY RICHTER, of murder] read the paper and internet that weekend and [TRACEY
RIGHTER's second ex-husband] made sure they were filled with his lies."
On May 16, 2012, pursuant to a subpoena, SCA Smith gave testimony favorable to Michael
Roberts in TRACEY RICHTER and Michael Roberts' custody proceedings. Prior to the
hearing, TRACEY RICHTER asked the Court to transfer custody of their children to their
grandmother, ANNA RICHTER. Among other things, SCA Smith testified he
believed ANNA RICHTER and TRACEY RICHTER conspired and attempted to solicit
fraudulent testimony from convicted child molester Jim Landa to get TRACEY RICHTER a
new murder trial and that TRACEY RICHTER had sent Jim Landa a picture of children
knowing he was a convicted child molester.
SCA Smith testified about thee-mails DARREN MEADE had sent him on April 24, 2012.
SCA Smith testified DARREN MEADE's phone records proved he and ANNA RICHTER
had been communicating and that other evidence obtained by law enforcement proved that
Michael Roberts and DARREN MEADE had an amicable relationship up until around
October 24, 2011, when Michael Roberts refused to give DARREN MEADE money. SCA
Smith testified that he believed that TRACEY RICHTER and I or ANNA RICHTER had
DARREN MEADE manufacture false evidence against Michael Roberts to use against him
in custody proceedings and to get TRACEY RICHTER a new murder trial, much the
same way the two tried to with convicted child molester Jim Landa.
On May 17, 2012, DARREN MEADE sent the following in an e-mail to SCA Smith:
. Being that I have no legal background, nor the ability to retain legal counsel, the testimony
requested would be for the grand jury and the only way you would be willing to investigate
the witness intimidation and alleged jury tampering (by Michael Roberts]? In regards to my
'outreach and phone calls to the tipline for the Dustin Wehde, I did not keep the telephone
number. I left a voice mail and another time I believe I spoke to someone, it was a female. I
did share my concerns about Michael Roberts. This would be to the best of my recollection
December 2010 to January/February 2011. Mr. Smith, I am now terrified that it seems you
have discussed my e-mails with Michael Roberts the person who has conspired to have me
killed, attempted extortion and threatened me with arrest if I stepped forward with what I
know. The appearance of the e-mails seems to indicate you spoke with Michael Roberts
before even responding to myself. Forgive the accusation but it sincerely causes me
hesitancy going forward for both an honest investigation and that my life may now be truly in-
danger.
On:May 17, 2012, at 12:00 p.m. CST, SCA Smith told the following in an e-mail to DARREN
MEADE: I can have a court reporter lined up for depositions anytime in the afternoon next
week. Please tell me when you will be available (via Skype) to provide regarding the
36
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
matters issues you have raised in your previous emails to me.
On May 17, 2012, at 4:27p.m., SCA Smith replied to DARREN MEADE:
Yes, this matter was discussed with Michael Roberts. Let's be clear, I do not care about
Michael Roberts, his ability to hack or whatever matters or dealings you guys have that do
not relate to the investigation of crimes occurring in Sac County or over which Sac County
would otherwise have jurisdiction. I do not care about Rexxfield or whatever business
matters or dealings you and Michael Roberts shared. My question regarding the document I
attached in the previous email required a simple yes or no; they either are yours or they are
not. So, I would appreciate an answer to that question.
Another matter that troubles me is your willingness to provide me, via email, all sorts of
information and make very serious accusations about Michael Roberts; but yet you are
unwilling to swear to the same under penalty of perjury. This causes me concern.
There are some issues that concern me greatly regarding statements you have made, the
following just being a few: neither the Sac County Sheriff nor the Sac City Police Department
have a "tipline." Further, there is no record of anyone calling either one of the two
aforementioned law enforcement entities (at their regular phone lines) from 2008 forward
with information even remotely similar to that which you stated you previously provided. The
:Iowa Division of Criminal Investigation (DCI) has also told me they have no record of the
same. Can you see how this is troubling?
I know you have been in contact I had communication (via phone) with ANNA RICHTER. I
also have a statement provided to me by a former associate of yours that indicates you told
said associate that ANNA RICHTER had told you she (ANNA RICHTER) was working to get
,a new trial for her daughter, TRACEY RICHTER. Can you see how this is troubling? Even
more troubling is the timing of your communications with me and your reference to the
pending custodial matters in Buena Vista County. I also know that before you called my
;office on April 12, 2012, you called a television news organization out of Sioux City. Again,
.this concerns me. You stated you believe your life to be in danger, so I am assuming you
have made law enforcement in your area aware of such. Please provide me with the names
of all such law enforcement entities to which you have made aware of said danger and your
point(s) of contact for the same [to which you have reported these threats]. If you have not
:yet made such a complaint, then I suggest you [hang up the phone], dial 911, and
[immediately report this threat to law enforcement].
You have leveled some very serious charges. As you can see from the above, we do take
these matters seriously and will continue to investigate them accordingly. Please provide me
with answers to all the above questions and please provide me with a yes or no as to
whether you are going to make yourself available for a grand jury investigation.
On, May 17, 2012, 5:35 p.m. COT, in response to SCA Smith's above-mentioned request,
DARREN MEADE wrote SCA Smith the following: "In regards to your request I am
37
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
my previous emails under the penalty of perjury. I trust this will do until we can
get another agency to Investigate matters since you refuse too [sic] and seem very hostile
from your other email." Interestingly, your applicant is not the first law enforcement official
who DARREN MEADE accused of being hostile after calling DARREN MEADE out on his
lies. In his aforementioned declaration, which was filed in a federal court on November 21,
2011, DARREN MEADE stated that during a phone call he had with an FBI SA on
September 8, 2011, "During the call [the FBI SA] was hostile and accusatory towards me.
He called me a liar on facts that he clearly had wrong."
The e-mail referenced immediately above was the last communication SCA Smith has had
with DARREN MEADE.
'
On June 2, 2012, BERT PITMAN told TRACEY RICHTER he planned to give the Virginia
Gazette information about Dr. John Pitman and his association with strippers. TRACEY
RICHTER told BERT PITMAN to reach out to Dr. John Pitman's ex-girlfriend, Allisan
Tucker. TRACEY RICHTER told BERT PITMAN to talk to a former co-worker of Dr. John
Pitman to get dirt on [Dr. John Pitman]. TRACEY RICHTER said Dr. John Pitman
associates with strippers and hookers. BERT PITMAN said the person who told BERT
PITMAN personal, confidential information about one of Dr. John Pitman's patients, which
inf?rmation could be used against Dr. John Pitman, no longer worked for Dr. John Pitman.
TRACEY RICHTER instructed BERT PITMAN to "reach out" to this person. BERT PITMAN
said he planned to do this.
On July 10, 2012, after learning Dr. Scott Connelly had produced DARREN MEADE's
deposition pursuant to SCA Smith's investigatory subpoena, DARREN MEADE, in a series
of e-mails, begged Dr. Scott Connelly to "pull back" the lawfully subpoenaed deposition from
sc:A Smith and advise SCA Smith that the deposition transcripts contained numerous
inaccuracies. DARREN MEADE asked Dr. Scott Connelly why Dr. Scott Connelly again
released DARREN MEADE's deposition with DARREN MEADE's prior approval or
knowledge. Following his refusal to contact SCA Smith and "pull back" DARREN MEADE's
deposition, Dr. Scott Connelly was defamed on RIPOFF REPORT by an anonymous
author.
On June 17, 2012, TRACEY RICHTER told ANNA RICHTER they had the ability to get the
IP addresses of the people who published "complaints" on RIPOFF REPORT. ANNA
RICHTER told TRACEY RICHTER that she was certain the person who put the information
on RIPOFF REPORT about Michael Roberts was one of TRACEY RICHTER's friends.
TRACEY RICHTER said one of the persons responsible for publishing the RIPOFF
REPORT "complaints" about Michael Roberts was the owner of RIPOFF REPORT.
TRACEY RICHTER then told her mother to stop talking about this matter over the phone.
38
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
On June 29, 2012, DARREN MEADE called MATTHEW COOKE and the two spoke for
close to ten minutes. This is the same MATTHEW COOKE who DARREN MEADE and
ADAM ZUCKERMAN partnered with to monetize the aforementioned illicit SQL code by
using it to remove RIPOFF REPORT complaints for profit ($5,000 per complaint removed).
This is the same MATTHEW COOKE who DARREN MEADE told ED MAGEDSON and the
FBI was responsible for deploying the illicit SQL hack into RIPOFF REPORT's servers.
On August 18, 2012, ANNA RICHTER told TRACEY RICHTER that DARREN MEADE
wanted information about Michael Roberts' business. ANNA RICHTER said DARREN
asked her a number of questions. TRACEY RICHTER told ANNA RICHTER that DARREN
MEADE needed to look up certain information about Michael Roberts. ANNA RICHTER
asked TRACEY RICHTER a number of questions about Michael Roberts' business. ANNA
RICHTER said these questions had come directly from DARREN MEADE. TRACEY
RICHTER had ANNA RICHTER write some things down on a piece of paper to give to
DARREN MEADE. ANNA RICHTER said DARREN MEADE told her that State's witness
Raymond Friedman disgusted him. ANNA RICHTER said DARREN MEADE wanted to
know where he could get a copy of the picture of Michael Roberts that TRACEY RICHTER
published on the website deadbeatdad.org. ANNA RICHTER said DARREN MEADE said
Roberts looked crazy in that picture and DARREN MEADE planned to publish the
picture in one of his upcoming RIPOFF REPORT complaints about State's witness Michael
ANNA RICHTER said DARREN MEADE had some really bad pictures of State's
witness Mary Higgins that he also planned to publish on RIPOFF REPORT. ANNA
RICHTER said DARREN MEADE told her that his publishing uncomplimentary pictures of
the. witnesses on RIPOFF REPORT was "childish and immature, but he [was] doing it
anyway." ANNA RICHTER said DARREN MEADE said there was an unbelievable amount
of lying and corruption involved in TRACEY RICHTER's criminal trial. TRACEY RICHTER
dirJcted ANNA RICHTER to have DARREN MEADE somehow obtain Michael Roberts' tax
returns. ANNA RICHTER said she had already given DARREN MEADE a great deal of
information about Michael Roberts. ANNA RICHTER said DARREN MEADE told her State's
witnesses Michael Roberts and Raymond Friedman engaged in shady I crooked business
pradices around the time TRACEY RICHTER murdered Dustin Wehde.
On' August 20, 2012, TRACEY RICHTER asked ANNA RICHTER whether RUSSELL
SCHERTZ was able to find computer files related to Michael Roberts' business. TRACEY
RICHTER asked which of her computers ANNA RICHTER had in her possession. ANNA
RIGHTER said she had the silver computer. ANNA RICHTER said she just spoke with
DA,RREN MEADE over the phone for one and a half hours. ANNA RICHTER said DARREN
MEADE was getting more information and had asked ANNA RICHTER some questions.
ANNA RICHTER said she had to get answers to these questions from TRACEY RICHTER's
39
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
fiance, RUSSELL SCHERTZ. ANNA RICHTER said she did not want to discuss these
questions over the phone. TRACEY RICHTER asked ANNA RICHTER if she found the
"master file" on TRACEY RICHTER's computer. ANNA RICHTER said RUSSELL
I
SCHERTZ took those (computers or files) to his residence in Omaha, Nebraska, because
RUSSELL SCHERTZ knew better than ANNA RICHTER about such things. ANNA
RICHTER said DARREN MEADE wanted information I documents proving TRACEY
RICHTER had her name legally changed from TRACEY RICHTER to SOPHIA CORRINA
THERESA BARONIN VON RICHTERHAUSEN EDWARDS. ANNA RICHTER said she told
DARREN MEADE that TRACEY RICHTER's name change was real because ANNA
RICHTER helped TRACEY RICHTER get copies of the document used to obtain her legal
narne change.
SOPHIE CORRINA TERESE BARONIN VON RICHTERHAUSEN EDWARDS
On March 11, 2009, Deputies of the Douglas County Sheriff's Office (DCSO) (Omaha,
Nebraska) were dispatched to TRACEY RICHTER's apartment I residence in Omaha,
Nebraska, to meet TRACEY RICHTER. When the DCSO Deputies arrived, TRACEY
RICHTER identified herself as TRACEY RICHTER. TRACEY RICHTER reported that she
believed her second ex-husband, Michael Roberts, had accessed the interior of her car and
planted photographs of Dustin Wehde's dead body in effort to harass her. The DCSO later
concluded Michael Roberts did not break into her car, and that TRACEY RICHTER made
this false report in hopes to use it against Michael Roberts in some upcoming civil custody I
child support proceeding.
On April 4, 2009, furious at the DCSO Detective who refused to believe her, TRACEY
RIGHTER sent the following message to Iowa Division of Criminal Investigation (DCI)
Special Agent (SA) Trent Vileta:
One day [Michael Roberts] is going to hurt someone. When he does, I will have the joy of
:sitting back and saying 'I told you so.' At this point, even if it is me, it will be worth having his
true character exposed. I just pray he never hurts our children. Wouldn't it be lovely if
[Michael Roberts] hurt that asshole's (Douglas County Detective) kids? Fantasizing about
that kind of stuff is about the only thing that gets me through moments like these.
Later that same day, TRACEY RICHTER sent another e-mail to DCI SA Vileta, which stated
that this Douglas County Detective "had just made the list."
e ~ r i n g TRACEY RICHTER was planning to hurt this detective's children and frame
40
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Michael Roberts for it, law enforcement began looking into TRACEY RICHTER's
background.
On or around April 22, 2009, law enforcement learned that on February 19, 2008, TRACEY
RICHTER went to the Iowa Drivers License Station in Spencer, Clay County, Iowa, for a
name change on her Iowa Drivers License. The Iowa Department of Transportation (DOT)
agent said TRACEY RICHTER signed an Iowa DOT form for a name change to SOPHIE
CORRINA TERESE BARONIN VON RICHTERHAUSEN EDWARDS, and that TRACEY
RICHTER provided the Iowa DOT with a copy of a court document filed in Buena Vista
County District Court Case No. CDCD002755, a passport, and social security in the name
"SOPHIE C. EDWARDS" as justification for the name change on her Iowa Drivers License.
Law enforcement next learned that on January 17, 2009, the U.S. State Department issued
U.S. Passport No. #####0483 to SOPHIE EDWARDS. Law enforcement learned that
TRACEY RICHTER provided a social security number for SOPHIE EDWARDS as well as
an affidavit signed and notarized by her ex-sister-in-law, "LISA Roberts (Michael Roberts's
sister)" in regards to TRACEY RICHTER's name change on her U.S. Passport to SOPHIE
EDWARDS. The U.S. State Department advised that SOPHIE EDWARDS' last entry of
travel was February 2009, U.S. Passport #####0483, and that her destination of travel was
Los Cabos, Mexico.
On April17, 2009, law enforcement telephoned LEISA Devine (NOT LISA as the name was
spelled on TRACEY RICHTER's I Sophie Edwards' U.S. Passport change of name form)
(formerly Leisa Roberts) to determine whether or not she filed an affidavit in regards to
TRACEY RICHTER changing the name of her U.S. Passport to SOPHIE EDWARDS.
Michael ROBERTS informed law enforcement he had one sister, Leisa, who
would be TRACEY RICHTER's ex-sister-in-law. Michael Roberts stated that Leisa Devine
last visited the United States around 1999. Law enforcement learned that the U.S. Passport
Affidavit Regarding Change of Name, purportedly signed by "LISA Roberts," was executed
at Boys Town, Omaha, Nebraska, was reviewed and signed by a State of Nebraska Notary
on January 17, 2009. The address provided by "Lisa Roberts" was 1851 N. 115
1
h Plaza No.
3108, which was identified by law enforcement as being TRACEY RICHTER's residence at
the time. Leisa Devine told law enforcement she last traveled to the United States in
September 2000, for a three-week visit. Leisa Devine told law enforcement that she never
signed and swore to an official document or affidavit on behalf of TRACEY RICHTER
regarding a name change or for any reason. Therefore, she said that she never signed off
on an affidavit regarding a name change of TRACEY RICHTER to SOPHIE EDWARDS.
Leisa Devine told law enforcement she did not get along well with TRACEY RICHTER.
Leisa Devine said that around 2003, TRACEY RICHTER and TRACEY RICHTER's mother,
41
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
ANNA RICHTER, attempted to reach Leisa Devine at her place of employment via e-mail.
Sir\ce TRACEY RICHTER and her mother, ANNA RICHTER, were not speaking fondly of
her brother, Michael Roberts, she said that she requested her place of employment to block
all. future incoming e-mails from TRACEY RICHTER and TRACEY RICHTER's mother,
ANNA RICHTER.
On April 21, 2009, in a custody proceeding in Buena Vista County, Iowa, District Court Case
No. CDCD002755, when cross-examined by her ex-husband, Michael Roberts, TRACEY
RICHTER testified she had legally changed her name to SOPHIE EDWARDS, but she did
not know whether or not her "legal" name change included a middle name. TRACEY
RI<;:;HTER further testified she only used her new name, SOPHIE EDWARDS, for
eniployment purposes, and that her vehicle was still registered in the name TRACEY
RICHTER. When RICHTER was questioned as to whether or not she obtained a passport in
her new name (SOPHIE EDWARDS), she responded, "No. I think my passport is still in my
old name." When she was asked if she planned on getting a passport in her new name,
RICHTER testified, "No." TRACEY RICHTER testified that her name change to SOPHIE
EDWARDS was completed by filing an affidavit of name change, then providing the affidavit
to the Iowa Department of Motor Vehicles to obtain a drivers license in her new name,
SOPHIE EDWARDS. TRACEY RICHTER testified she did not file a petition for change of
name in the State of Iowa with the Clerk of Court. She also admitted to the court in this
proceeding that she did not have a Nebraska license, although she currently resided in
I
Nebraska; instead, she admitted she currently had a valid Iowa driver's license utilizing the
name SOPHIE EDWARDS.
On May 7, 2009, law enforcement was told by the Social Security Administration (SSA) that
on December 3, 2009, TRACEY RICHTER requested a name change of her social security
card to the new name, SOPHIE C. EDWARDS, and that TRACEY RICHTER submitted a
divorce decree filed in Buena Vista County District Court Case No. CDCD002755 and Iowa
Drivers License No. #####3673 in the name of SOPHIE EDWARDS in order to obtain I
justify a name change on her social security card.
on May 9, 2009, law enforcement learned that on or around November 21, 2008, for the
purpose of obtaining financing for an automobile under the name SOPHIE EDWARDS,
TRACEY RICHTER gave Lexus of Omaha a copy of what TRACEY RICHTER told Lexus of
Omaha was a court order filed December 4, 2007, in Buena Vista County District Court
a ~ e No. CDCD002755, which, among other things, gave her the choice to RESUME using
her MAIDEN NAME, SOPHIE CORRINA TERESE BARONIN VON RICHTERHAUSEN
EDWARDS. The following is the decretal language contained in the court order TRACEY
RICHTER provided Lexus of Omaha:
42
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED as follows: (1) No further
conciliation procedures shall be required in this action. (2) The marriage of Michael Ross
'
Roberts and TRACEY RICHTER Roberts is hereby, dissolved, and the parties are restored
to the same rights and privileges as unmarried persons. (3) The Respondent, TRACEY
RICHTER Roberts (15 May 1966) may resume use of her maiden name SOPHIE CORRINA
TERESE BARONIN VON RICHTERHAUSEN EDWARDS. (4) The Respondent is granted
authority to obtain U.S. Passports for the minor children, [full name of minor child boy] (26
May 1998) and [full name of minor child girl] (13 FEB 2000) without the permission of the
non-U.S. Citizen Petitioner who resides at an undisclosed address. (5) The Court retains
jurisdiction to enter Findings of Fact, Conclusions of Law and Decree pertaining to all other
issues in this case.
On May 9, 2009, the Buena Vista County Clerk of District Court faxed law enforcement a
certified copy of the only order entered in Case No. CDCD002755 on December 4, 2007.
Said order was identical in all respects to the court order TRACEY RICHTER gave Lexus of
Omaha, except the certified copy contained only the first, second, and fifth numbered
paragraphs, numbered (1) (2}, and (3), respectively, that were present in the copy of the
decree TRACEY RICHTER gave Lexus of Omaha. The following is the how the decretal
language contained in the certified copy of the Order appears:
IT IS THEREFORE ORDERED, ADJUDGED, AND DECREED as follows: (1) No further
conciliation procedures shall be required in this action. (2) The marriage of Michael Ross
Roberts and TRACEY RICHTER Roberts is hereby, dissolved, and the parties are restored
to the same rights and privileges as unmarried persons. (3) The Court retains jurisdiction to
enter Findings of Fact, Conclusions of Law and Decree pertaining to all other issues in this
case.
On May 13, 2009, the Douglas County (Omaha, Nebraska) Sheriffs Office executed a
search warrant at TRACEY RICHTER's apartment in Omaha, Nebraska. During the course
of their search, inside a padlocked closet in TRACEY RICHTER's apartment, law
enforcement found, among other things, the following items: a copy of the December 4,
2007, court order that was identical to the certified copy of the same sent to law
enforcement by the Clerk of Court; a copy of the December 4, 2007, court order which was
identical to that provided by Lexus of Omaha, which as noted above, contained two
additional numbered paragraphs, which allowed TRACEY RICHTER to obtain passports for
her children without their father's permission and resume using her maiden name, SOPHIE
CORRINA TERESE BARONIN VON RICHTERHAUSEN EDWARDS; and a hybrid copy of
the .original order and a piece of paper containing the two additional paragraphs, cut,
copied, and held together with Scotch Tape.
Also found in TRACEY RICHTER's apartment was an unfiled, unsigned, yet completed
Petition for Name change in the District Court of Douglas County, Nebraska, which, if filed
43
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
w i ~ h and approved by the Court, would have legally changed TRACEY RICHTER's name to
Heidi Joanna Forsbacka, which was I is the name of Michael Roberts' wife.
TRACEY RICHTER, her mother, ANNA RICHTER, and her fiance, RUSSELL SCHERTZ,
haye accused law enforcement of planting the forged court decree, its scotched-taped
precursor, and the certified copy of the original in the PADLOCKED closet in TRACEY
RICHTER's Omaha apartment when they executed the search warrant. However, this does
not explain why on July 27, 2010, in her felony perjury trial in Clay County, Iowa (Case No.
FECR014399), TRACEY RICHTER stipulated on the record that these very same
documents were found by law enforcement during its search of her apartment pursuant to
the search warrant issued I executed on or about April 29, 2009. Furthermore, no one in
TRACEY RICHTER's camp can provide a reasonable explanation as to why SOPHIE
EDWARDS listed TRACEY RICHTER as a reference in a job application she submitted to a
prospective employer on January 20, 2009.
On May 18, 2009, TRACEY RICHTER wrote the following in another e-mail to DCI SA
Vi leta:
Yes, they charged me with felony criminal impersonation. In their complaint they state that I
. bought the used Lexus under an assumed name, when in fact all the financing was in [the
\ name TRACEY RICHTER]. I think this is all about the complaints I made against [the
; Douglas County Sheriff's Office Detectives]. They talked about me forging a [document] to
take the kids out of the country which is BS. I have [been] resisting them getting passports as
late as this year. [Michael Roberts] took them to get passport photos whereas I filed passport
alerts with both the Australian consulate and the US State Department. My philosophy was:
no passport, no overseas travel in regard to our kids. Supposedly they found something in
:my house to support this passport claim. I would not put it past them trying to set me up. It
should be easy enough to disprove.
On May 27, 2009, TRACEY RICHTER was charged in Clay County, Iowa, with felony
perjury for falsifying the DOT form. On July 27, 2010, she was convicted by a jury for the
sar;ne crime. State v. Richter, Clay County District Court Case No. FECR014399
On June 9, 2009, TRACEY RICHTER was charged in Douglas County with criminal
impersonation. On April 19, 2010, she pleaded no contest to felony welfare fraud. State v.
Richter, Douglas County (Omaha, Nebraska) District Court Case No. CR 09 1318.
After learning that law enforcement obtained the transcript of her testimony from April 21,
2009, TRACEY RICHTER, made form of threat to the court reporter who reported the
proceedings, alleging the court reporter incorrectly reported the proceedings (assumedly,
the part of her testimony where she lied about her SOPHIE EDWARDS passport). This
threat caused the authorities in Buena Vista County to post flyers containing TRACEY
44
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
RICHTER's Drivers License photograph and the following warning at the Courthouse's
entrances:
This photo is of [TRACEY RICHTER]. She has been arrested and released from Omaha,
[Nebraska]. Due to the criminal charges that were filed against her in [Nebraska], she is
extremely angry and upset not only with the authorities [in Nebraska] but also here in Buena
Vista County. [TRACEY RICHTER] has made threats to an employee in the Clerk's Office as
vyell as [the presiding Judge's] court reporter (who reported the proceedings, and generated
a transcript of the same). All offices in the courthouse have been advised to watch for her,
and if she enters the courthouse, they are to call immediately for law enforcement. [fRACEY
RICHTER] is not banned from entering the courthouse at this time, however, law
enforcement presence will be required anytime she is in the courthouse.
On October 22, 2009, in her Response to Petitioner's Motion for Rule to Show Cause filed
in Bpena Vista County District Court No. CDCD002755, TRACEY RICHTER stated her
name change was "done in an EU country where 'middle names' are not utilized" and that
she did not select a middle name. TRACEY RICHTER further told the Court she did not
have a passport issued under the name of SOPHIE EDWARDS and that her new Social
Security number was issued to TRACEY RICHTER, not SOPHIE EDWARDS. TRACEY
RICHTER also told the Court that she did not travel in February 2009.
In ~ n e 2010, ANNA RICHTER wrote the following in a letter to then-Sac County Attorney
Earl; Hardisty:
After all of these crimes the only person being prosecuted is Tracey and she is the only one
who has done nothing illegal. I am not going away until people are held accountable for their
actions and that is including [the Douglas County Detective who investigated TRACEY
RICHTER].
They tried to bring charges against her for using a fake name until it was proven she had a
LEGAL name change. They supposedly found an altered court document in the search of
Tracey's home. This document had her name change on it and permission to get the children
passports. Needless to say [the Douglas County Detective who investigated TRACEY
RICHTER] is the one who found it after another officer looked through that SAME FOLDER
and didn't find it. First, why would she change a court document regarding her name when it
was already changed legally?
This is just one of many letter's I am sending out. I will not stop until Tracey's name is
cleared and ALL charges are dropped and [Michael Roberts] and [the Douglas County
Detective who investigated TRACEY RICHTER] are held responsible for their actions. I know
first hand how corrupt the Douglas County Sheriff s Dept. is by what they have done to me.
On July 28, 2010, ANNA RICHTER wrote the following in a letter to then-Sac County
Attorney Earl Hardisty:
45
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
! I was with her when she went for her new Driver's license and I know for a fact it was not
:used. Also how could Tracey have committed perjury when the supervisor filled out the part
:of the form that Tracey left blank, after Tracey signed it????? You can tell it is a different
:handwriting and also they should have had Tracey initial it if there were changes made to
it. Don't you agree? This whole thing is fishy to me and you would have to be awful naive
or stupid not see what is going on. I also find it interesting that all of your so called witnesses
[in the Dustin Wehde murder, then-suspicious death case] are proven to be nut cases.
Following her arrest for murder, law enforcement seized, among many, many other things.
two different name change documents TRACEY RICHTER had in a bag in her vehicle.
The first document is titled: "Deed of Change of Name," which purports to be executed on
the, "4
1
h day of July 2006 ("July" and the number "4" are handwritten), and reads as follows:
By SOPHIE CORRINA TERESE BARONIN VON RICHTERHAUSEN EDWARDS of 56,
. Gloucester Road, London in the County of Greater London now or lately known as Tracey
Anne RICHTER a Commonwealth Citizen under section 37(1) of the British Nationality Act
1981, witnesses and it is hereby declared as follows: I absolutely and entirely renounce,
relinquish and abandon the use of my said former name Tracey Anne Richter and assume,
I
adopt and determine to take and use from the date hereof the name of SOPHIE CORRINA
TERESE BARONIN VON RICHTERHAUSEN EDWARDS in substitution for my former name
of Tracey Anne Richter.
TRACEY RICHTER's (and SOPHIE EDWARDS') signatures on the purported "Deed of
Change of Name" document mentioned above, is witnessed by TRACEY RICHTER's son,
BERT PITMAN. The content of the second document is identical to the first, except its titled
"UK Deed Poll Service, Deed of Change of Name (Deed Poll)" and purports to be executed
"this 2nd day of February in the year 2008 "2nd, ("February" and "2008" are handwritten.
TRACEY RICHTER's (and SOPHIE EDWARDS') signatures on this document were also
witnessed by BERT PITMAN.
Sometime after she was arrested for murder, Scotland Yard (Metropolitan Police
Headquarters in London, England) confirmed with law enforcement officials in Iowa that
neither TRACEY RICHTER nor SOPHIE CORRINA TERESE BARONIN VON
RICHTERHAUSEN EDWARDS were British I UK citizens.
On: August 15, 2011, in her response to the State's resistance to Defendant's Motion to
Reduce Bond, TRACEY RICHTER (aka SOPHIE CORRINA TERESE BARONIN VON
I
RICHTERHAUSEN EDWARDS) admitted she did receive a new passport under the name
of SOPHIE EDWARDS and did travel internationally using the same.
On September 12, 2011, less than one month after she was arrested for first degree
murder, and a little over a year after she had been convicted of felony fraud in Nebraska
46
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
and felony perjury in Iowa, the U.S. Department of State filed a criminal complaint against
TRACEY RICHTER for felony passport fraud (18 U.S.C. 1542). Case No. 8:11 MJ195
United States District Court for the District of Nebraska. This complaint was dismissed
following her murder conviction and subsequent life sentence.
As mentioned above, on or around September 9, 2012, DARREN MEADE published
TRACEY RICHTER's second change of name document mentioned above, on RIPOFF
REPORT; however, he conveniently cropped out the top quarter of the document where
one usually finds some official government stamp, seal, or other marking that verifies a
government form /legal document's authenticity.
ANNA RICHTER has been vouching for the legality of TRACEY RICHTER's name change
and has alleged to have witnessed TRACEY RICHTER NOT using I producing certain
documents to facilitate this name change. As mentioned above, ANNA RICHTER was with
TRACEY RICHTER when she went to the Iowa Department of Transportation (DOT) and
witnessed her NOT produce the forged decree. ANNA RICHTER also was with TRACEY
RICHTER when she went to buy the Lexus under the name SOPHIE EDWARDS and
ANNA RICHTER witnessed her NOT produce the forged decree to the dealership to obtain
credit in under the name SOPHIE EDWARDS.
On August 25, 2012, TRACEY RICHTER told ANNA RICHTER that RUSSELL SCHERTZ
was late getting to the prison to visit her because he had been giving documents to
DARREN MEADE. TRACEY RICHTER told ANNA RICHTER that RUSSELL SCHERTZ
had: previously stated he planned to send documents to DARREN MEADE.
On August 29, 2012, ANNA RICHTER told TRACEY RICHTER she had been on the
internet looking at information RUSSELL SCHERTZ sent her. TRACEY RICHTER asked
whether RUSSELL SCHERTZ had found or sent "anything of any value. ANNA RICHTER
said RUSSELL SCHERTZ had sent the information to "you know who," and "you know who"
would be going through this information. ANNA RICHTER said there are other things that
should be "coming out" shortly. ANNA RICHTER said "what's his name" wanted to know if
Michael Roberts was ever deposed or interviewed. TRACEY RICHTER said RUSSELL
SCHERTZ had a copy of Michael Roberts's interview on a disk.
On September 5, 2012, DARREN MEADE ([email protected]) wrote the
following to his friend SIAMACK YAGHOBI ([email protected]):
47
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
:The 'Tracey Story' is the article I have written, read the narrative and when it gets to the links
'of the Dateline episode, watch them in sequence. I have documents and reports which will
also be embedded in the article. The flow charts I asked if you can help me with, will be apart
of the article. In the ["players"] document, you will see one section that [is] the Michael &
I
Tracey outline, that is what needs to be detailed and also a flow chart on the jury tampering
itself. We can work at my house, but it would be a few hours [until] we can, I had some early
!meetings, and need to sleep more [than] pray. What is your schedule like later today? Let me
:know as well if you [are able to] follow the article.
Included in this e-mail, DARREN MEADE attached two MS Word documents. One of these
documents is DARREN MEADE's RIPOFF REPORT complaint No. 938843 (as it appears
on RIPOFF REPORT, but in MS Word format) mentioned and discussed at great lengths
throughout the remainder of this affidavit) The other attached MS Word document contained
DARREN MEADE's notes on all the State's witnesses and law enforcement officials titled
"The Players."
On September 6, 2012, in his response to DARREN MEADE's e-mail above, SIAMACK
YAGHOBI gave DARREN MEADE suggested additions to what ultimately would become
DARREN MEADE's RIPOFF REPORT complaint No. 938843. Most damning in SIAMACK
YAGHOBI's response, however, is SIAMACK YAGHOBI told DARREN MEADE that he
(SIAMACK YAGHOBI) planned to "FILE A REBUTTAL" on the article that would attack
Michael Roberts. The significance of SIAMACK YAGHOBI's statement to DARREN MEADE
here cannot be understated, as it and other information discussed in this affidavit
demonstrates that ED MAGEDSON I RIPOFF REPORT and DARREN MEADE know the
anonymous authors publishing add-on complaints and rebuttals to DARREN MEADE's
RIPOFF REPORT complaints, including RIPOFF REPORT complaint No. 938843.
On September 7, 2012, TRACEY RICHTER asked ANNA RICHTER whether she got the
information she needed from RUSSELL SCHERTZ. TRACEY RICHTER asked whether
RU.SSELL SCHERTZ put a copy of this information on ANNA RICHTER's computer. ANNA
RICHTER said, "supposedly tomorrow or Saturday, all the other stuff is going to be taken
c r ~ of." [In context, this was an obvious reference to DARREN MEADE's forthcoming
RIPOFF REPORT complaint No. 938843) about the State's witnesses)
On September 9, 2012, DARREN MEADE published RIPOFF REPORT complaint No.
938843, which purports to be the results of his investigation into the corruption surrounding
TRACEY RICHTER's criminal prosecution and conviction, but which is nothing more than
DARREN MEADE's and ED MAGEDSON's I RIPOFF REPORT's efforts to harass and
defame the State's witnesses in retaliation for their testimony against TRACEY RICHTER.
Alt1:10ugh DARREN MEADE published the complaint on September 9, 2012 (Sunday), it did
nof appear on RIPOFF REPORT until September 11, 2012 (Tuesday). RIPOFF REPORT
48
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
I
complaint No. 938843 and its progeny (e.g., add-on complaints, rebuttals, and hyperlinks to
other derogatory RIPOFF REPORT complaints about the State's witnesses), among many
I
othe,r things, falsely accuses the State's witnesses and their family members of committing
murder, theft, perjury, child molestation, and having sexually transmitted diseases. RIPOFF
REPORT I ED MAGEDSON and DARREN MEADE published RIPOFF REPORT complaint
No. 938843 as a "featured" RIPOFF REPORT complaint, which is advertised conspicuously
on each of RIPOFF REPORT's approximate 1.8 million complaint pages. By ED
MAGEDSON's and DARREN MEADE's own admissions that www.ripoffreport.com is
I
vie'ed "a couple million times a day," since complaint No. 938843 was published and
featured (September 9, 2012), it is has been viewed over 1.2 BILLION times.
On September 11, 2012, DARREN MEADE sent the following e-mail to ANNA RICHTER, ,
DONNA BISTRICAN, RUSSELL SCHERTZ, and JOHN RICHTER:
Anna and Russ, Thank you for being patient and [sic] during my investigation, [sic] I know it
took longer than expected. If you can promote the article and ask people to offer their
honest opinion, not to compliment me, but to share their own stories of Ben Smith,
~ r y Higgins, Michael Roberts, Vileta, etc. http://www.ripoffreport.com/ben-smith-michael-
roberts-rexxfield/prosecutorial-misconduct/sac-city-sac-county-iowa-B 1 A 77. htm
On September 11, 2012, DARREN MEADE ([email protected]) wrote the
following in an e-mail to a SIAMACK YAGHOBI ([email protected]): "Here is the
link :to the article it posted tonight. This will give you an idea of layout for RIPOFF
REPORT." http://www.ripoffreport.comlben-smith-michael-roberts-rexxfieldlprosecutorial-
misconduct/sac-city-sac-county-iowa-B 1 A 77. htm
On September 12, 2012, DARREN MEADE told private investigator Tina Church, who has
assisted with this investigation, that ED MAGEDSON was the one who suggested to
DARREN MEADE that DARREN MEADE should research I investigate TRACEY
RICHTER's case. DARREN MEADE told private investigator Tina Church that ED
MAGEDSON said he (ED MAGEDSON) would "promote" DARREN MEADE's work on the
case and "get a couple million visitors per day on the site." In discussing his efforts to help
TRACEY RICHTER obtain a new trial, DARREN MEADE told the investigator the following:
The three main witnesses in her trial gave completely different testimony than any of their
depositions, including one month before the trial where they say what they are going to
tbstify to and to let Ben Smith know if they are going to testify to anything different, and they
all completely testified the opposite of what they said they were going to do.
On September 13, 2012, ANNA RICHTER said DARREN MEADE found more information
and jplanned to publish it on RIPOFF REPORT at a later date.
On September 13, 2012, DARREN MEADE told private investigator Tina Church that he
49
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
might be able to get Michael Roberts to leave the U.S. if Michael Roberts believed he was
about to be arrested.
On: September 14, 2012, in a three-way phone conversation between ED MAGEDSON,
DARREN MEADE, and private investigator Tina Church, ED MAGEDSON said the
following:
I do not have people writing for me "per se," but if [the investigator] wanted to publish
articles I complaints on RIPOFF REPORT and wanted to make them searchable .. . AND IF
YOU WANT TO GO TO THE TOP OF THE SEARCH ENGINE, all you need to do is name
.the city, put the name of the attorney, you know, where you want it to be found by the clerk of
the court, whatever you put up [on RIPOFF REPORT] within 20 minutes to an hour or so it
would be at the top of Google.
ED MAGEDSON then told private investigator Tina Church to "search Ben Smith, Sac
County Prosecutor (the title to DARREN MEADE's RIPOFF REPORT complaint No.
938843), see what you get." DARREN MEADE told private investigator Tina Church that ED
MAGEDSON and ED MAGEDSON's attorneys had discussed that SCA Smith was not
acting in the capacity of his official duties, but was acting more like Michael Roberts'
personal attorney. Then, ED MAGEDSON interjected stating "that would be a good title,
Prosecutor - you know, Ben Smith, Sac County Prosecutor. .. acts as [Michael Roberts]
personal attorney." DARREN MEADE then told the investigator "the thing about [ED
MAGEDSON] is if you ever need a title [for a RIPOFF REPORT complaint], he is the one to
ask." Towards the end of the conversation, ED MAGEDSON told DARREN MEADE to link
one of DARREN MEADE's other RIPOFF REPORT "complaints" about Michael Roberts to
DARREN MEADE's September 9, 2012, RIPOFF REPORT complaint (complaint No.
938843)
On September 14, 2012, ANNA RICHTER told private investigator Tina Church the
following:
[DARREN MEADE] got ahold of [DONNA BISTRICAN] and put something on the Internet.
That's a friend of my daughter's. And had put something on the Internet, and I guess
. [DARREN MEADE] read it and he contacted her and then asked if he could talk to me, so
she said, well, I don't want to give you her phone number, let me call her first and see if it's
okay. That's when [DARREN MEADE] contacted me and said he believed in her innocence
. because too many things just were not adding up. And that he was going to help me to prove
her innocence, and I was flabbergasted, because here is this man, doesn't know us at all
and is there wanting to help us.
on September 15, 2012, ANNA RICHTER told TRACEY RICHTER about DARREN
MEADE's September 11, 2012, RIPOFF REPORT complaint No. 938843; specifically,
AN.NA RICHTER said there was new information on RIPOFF REPORT about State's
50
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
w i t n ~ s s s Raymond Friedman, Mary Higgins, and Mona Wehde. ANNA RICHTER also said
DARREN MEADE planned to publish more information on RIPOFF REPORT concerning
the State's witnesses at a later date. ANNA RICHTER further said the "big connection was
money, and that State's witnesses Raymond Friedman and Michael Roberts were each
other's alibi." ANNA RICHTER told TRACEY RICHTER that the pictures of State's witness
Mary Higgins published on RIPOFF REPORT by DARREN MEADE were hysterical. ANNA
RICHTER said DARREN MEADE discovered evidence of Michael Roberts having a sexual
relationship with Dustin Wehde, TRACEY RICHTER's murder victim. TRACEY RICHTER
said she was glad someone was putting the truth out there. TRACEY RICHTER said
DONNA BISTRICAN would help ANNA RICHTER create a Facebook page. TRACEY
RICHTER told ANNA RICHTER to have BERT PITMAN send State's witness (murder
victim's sister) Ashley Wehde a Facebook message with a link to DARREN MEADE's
RIP9FF REPORT complaint No. 938843. ANNA RICHTER said DARREN MEADE
published a short story about State's witness (and murder victim's mother) Mona Wehde in
this RIPOFF REPORT. The RIPOFF REPORT complaint or story to which ANNA RICHTER
is referring alleges that Mona Wehde was also criminally responsible for her son's (Dustin
Wehde) death.
On September 16, 2012, DARREN MEADE told private investigator Tina Church that he
was publishing an update on RIPOFF REPORT about State's witness Raymond Friedman.
DARREN MEADE also told private investigator Tina Church the following:
So what this really is the -- you have - besides (State's witness Mary Higgins's] testimony,
you have two other people's testimony who tied in the prosecution's time line on why
[TRACEY RICHTER] murdered (Dustin Wehde], and those two people are [State's witnesses
Marie Friedman and Ray Friedman]. Now, [State's witness Raymond Friedman and Marie
Friedman] were interviewed the day after the shooting, and their interviews are the exact
opposite of what they testified to in court. But what happened in between that [time] is
[State's witness Raymond Friedman] was paid $25,000 [by State's witness Michael Roberts]
When private investigator Tina Church asked DARREN MEADE about DARREN MEADE's
aforementioned deposition, which apparently had been published somewhere on the
internet, possibly on RIPOFF REPORT, DARREN MEADE said the following:
[Michael Roberts] ... published these fake transcripts from a deposition I gave. And I have
never defended those, but I haven't defended them because I want them all over the Internet
where they can't go and take that stuff down. I want them baked into their position.
When private investigator Tina Church asked DARREN MEADE whether the depositions
were fake, DARREN MEADE said the following:
Not totally fake. What it is ... they changed portions of my answers in there. They also don't
51
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
!have the corrects to the deposition that I gave. So they are miss -- they are altered
,transcripts. They also don't contain the corrections that are supposed to be in there.
Later in their conversation, DARREN MEADE told private investigator Tina Church the
following:
;The [September 9, 2012, RIPOFF REPORT complaint about the State's witnesses (No .
. 938843)], I LAID THAT ALL OUT. NOW, I DID BECAUSE [ED MAGEDSON] OFFERED IT
'TO ME, YOU KNOW, TO HAVE [RIPOFF REPORT] GO IN AND DROP SOME COLOR
'PHOTOS IN THERE, BUT I DID ALL OF THAT ON MYSELF. [ED MAGEDSON] HAS
JUST OFFERED THE PLATFORM, YOU KNOW, of the site because he is passionate about
ending the death penalty. I wrote the article on Tracey just because I am sitting here going
"what the hell is going on," and I was able to get some information and I have some
'information I'm still going to bring out.
On September 18, 2012, an extremely upset I distraught TRACEY RICHTER told ANNA
RICHTER she was angry with SCA Smith, because she believed SCA Smith's testimony in
her custody hearing was the reason she lost the custody case with Michael Roberts. ANNA
RICHTER said she would contact DARREN MEADE because he planned to put something
else out there (assumedly about SCA Smith). ANNA RICHTER said DARREN MEADE
wanted something from ANNA RICHTER and wanted to publish this something on RIPOFF
REPORT that very day. TRACEY RICHTER, still sobbing hysterically, told ANNA RICHTER
she did not know what to do now that she lost custody of her kids, which she again blamed
on SCA Smith. ANNA RICHTER said that is why WE are trying to "get [SCA Smith]" and
t h ~ there was something else going on that she cold not discuss with TRACEY RICHTER
over the phone. TRACEY RICHTER said RUSSELL SCHERTZ told TRACEY RICHTER
about a conversation DARREN MEADE had with "someone." ANNA RICHTER said
"so'meone" is going to be investigating Michael Roberts. TRACEY RICHTER directed ANNA
RICHTER to activate TRACEY RICHTER's Facebook page. ANNA RICHTER said her
dream is to get SCA Smith disbarred. TRACEY RICHTER said the reason she did not get
custody of her kids was because of SCA Smith's testimony at her custody hearing about her
aforementioned correspondence with convicted child molester Jim Landa [Although, I am
fair,ly certain TRACEY RICHTER's murder conviction and life imprisonment played some
role in the Court's decision to give Michael Roberts' full custody of their children]. ANNA
RICHTER said "well, that it is it, I am going to get ahold of [DARREN MEADE] to see if [he
I
can do something]" about SCA Smith. ANNA RICHTER said she talked "to that one
person." TRACEY RICHTER asked whether this was the same person that had previously
spoken with DARREN MEADE, and ANNA RICHTER said it was.
On; September 20, 2012, DARREN MEADE told Dr. Scott Connelly that RIPOFF REPORT
owher I operator ED MAGEDSON planned to spend the night at DARREN MEADE's
52
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Laguna Beach residence. Later, DARREN MEADE said he and ED MAGEDSON traveled
together to San Diego where ED MAGEDSON purchased a boat.
On September 20, 2012, ED MAGEDSON sent the following e-mail to the producer of the
Australian version of the U.S. television newsmagazine 60 Minutes:
Also - You may want to look into this story I I steak [sic] my reputation on this . :-)
http://www.ripoffreport.comlben-smith-michael-roberts-rexxfieldlprosecutorial-
misconducUsac-city-sac-county-iowa-B 1 A 77. htm
Darren, who I copied on this e-mail string could explain more .. but, The guy in this story
(worth a 60 minutes story) in the above LINK is trying to go back to Australia as he is
Australian I Michael Roberts He is also featured in this article here
http://www.ripoffreport.comlorganized-crimelgoogle-cide-exposedlgoogle-cideexposed-by-
the-man-01 cd6.htm
http://www.ripoffreport.com1Search1Michaei%20Roberts.aspx
author of the above Reports [sic] DARREN MEADE [sic] is located in Laguna Beach,
California. Darren testified to FBI on several occasions about Michael Ross Roberts.
RIPOFF REPORT has helped every TV News Magazine with stories over the last 15
years. We will never steer you wrong ! :-)HERE IS [DARREN MEADE's] CONTACT INFO
=
On September 21 2012, TRACEY RICHTER asked ANNA RICHTER what had been going
on with "that guy (DARREN MEADE)" and whether DARREN MEADE had' recently
published anything on RIPOFF REPORT or any other place on the internet. ANNA
RICHTER said DARREN MEADE published an article on RIPOFF REPORT, Google, and
another place online. ANNA RICHTER said ED MAGEDSON I RIPOFF REPORT put up a
disclaimer that DARREN MEADE had been publishing these RIPOFF REPORT complaints
on his own volition. TRACEY RICHTER described the file sharing software I service
Dropbox as an "online briefcases people can open if you send them a link." ANNA
RICHTER said she asked DARREN MEADE whether she (ANNA RICHTER) should
respond to Michael Roberts' comments, and that DARREN MEADE said he would take care
of it. ANNA RICHTER said DARREN MEADE is going to create his own website. TRACEY
RICHTER told ANNA RICHTER to print off RIPOFF REPORT complaint No. 938843 and
send it to her at the prison. ANNA RICHTER said DARREN MEADE said he I RIPOFF
REPORT planned to publish numerous pictures of TRACEY RICHTER with her children in
effort to "humanize" her, which ANNA RICHTER had given to DARREN MEADE. TRACEY
RICHTER said there should be pictures of her and the kids on her (TRACEY RICHTER's)
computer. TRACEY RICHTER said RUSSELL SCHERTZ had the password for this
computer. TRACEY RICHTER said RUSSELL SCHERTZ had like-pictures in boxes in his
53
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
garage.
On September 28, 2012, ANNA RICHTER told TRACEY RICHTER that DARREN MEADE
had asked her and RUSSELL SCHERTZ for permission to put "good stuff' about TRACEY
RICHTER up on RIPOFF REPORT. TRACEY RICHTER said she saw the pictures of Mary
Higgins that DARREN MEADE published on RIPOFF REPORT and that they were horrible.
On October 7, 2012, in an e-mail to Dr. Scott Connelly, DARREN MEADE said the following
about his deposition:
ALL of my corrections were NOT contained within the depositions you provided to [SCA
Smith]. The agreement we had was clear, it would not be disseminated without garnering my
approval. We had signed a mutual release shortly after I resigned from Progenex. This
deposition was done as a favor to you personally before the case was dismissed to help in
your settlement with Progenex. Ben Smith is essentially acting as Michael Roberts personal
attorney in this matter. Why do you think the DA of Sac County Iowa would be requesting a
deposition which was never entered into evidence, and the case, dismissed, between parties
that already executed a Mutual Release? I [had] stated [SCA Smith] is 'essentially acting as
Roberts' attorney', which is true. On April 2, 2012, I filed an update on RIPOFF REPORT
[about Michael Roberts].
On October 10, 2012, DARREN MEADE told Dr. Scott Connelly that the damage caused by
the dissemination of his "fake" depositions had cost DARREN MEADE employment
opportunities and "millions of dollars."
On October 11, 2012, TRACEY RICHTER told her mother that in his September 9, 2012,
RIPOFF REPORT complaint (No. 938843), DARREN MEADE inaccurately stated that
State's witness Dr. John Pitman's medical practice was located in Chicago, Illinois, and that
DARREN MEADE should correct the RIPOFF REPORT complaint to list the correct location
of Dr. John Pitman's medical practice, Williamsburg, Virginia. TRACEY RICHTER directed
her mother to bring this to DARREN MEADE's attention.
On October 19, 2012, ANNA RICHTER told TRACEY RICHTER that DARREN MEADE was
unable to access certain videos and documents on his RIPOFF REPORT complaints and
that he planned to call RIPOFF REPORT to get it fixed.
On November 2, 2012, DARREN MEADE asked his friend SIAMACK YAGHOBI the
following: "Do you know anyone talented with making You Tube videos that might be willing
to make a video for a small amount of money, it would be used to end Google-Cide."
On November 8, 2012, ANNA RICHTER told TRACEY RICHTER that she was worried
about DARREN MEADE as she had not heard from him in two weeks. ANNA RICHTER
said she tried to contact DARREN MEADE by e-mail and telephone numerous times, but he
54
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
had not responded.
On November 22, 2012, DARREN MEADE published an add-on complaint to his RIPOFF
REPORT complaint No. 938843, which he titled "Michael Roberts of Mile2, Lies, and
Audiotapes Causes (Alleged) Perjury of Sac County Attorney Ben Smith Case No.
CDCD002755." The substantive content of this add-on I rebuttal is in keeping with its title.
On November 25, 2012, the anonymous author "VICTIM OF MICHAEL ROBERTS XELLEX
MILE2" posted an add-on I complaint to Ripoffreport.com complaint No. 938843, claimed to
have been groomed by State's witness MICHAEL ROBERTS to kill TRACEY RICHTER.
Said add-on complaint, which purported to be authored by a fifteen-year-old sex abuse
victim of Michael Roberts, alleged Michael Roberts was a drug abuser, homosexual,
pedophile, and rapist. Said author claimed to have first hand knowledge that MICHAEL
ROBERTS chose DUSTIN WEHDE to kill TRACEY RICHTER, and stated, among other
things, the following:
I believed Michael Roberts would kill me if I spoke up. Michael had promised me that we
would run off and have a new beginning as father and son the moment I followed his plan.
He made the same offer to Dustin and promised they would leave town together that
evening.
On November 25, 2012, anonymous author "TIMMY" published RIPOFF REPORT
complaint No. 973523, with the following title: MI.CHAEL R O E R T ~ XELLEX REXXFIELD
VACATION BIBLE SCHOOL VACATION BIBLE SCHOOL MOLESTER, YOUNG BOYS
TRUST BETRAYED, GROOMING FOR ABUSE AND MURDER, INTERNET. The content
of this RIPOFF REPORT complaint is in keeping with its title and is essentially identical to
the content of a comment I rebuttal to RIPOFF REPORT complaint No. 938843.
On November 29, 2012, ANNA RICHTER told TRACEY RICHTER that something
extremely important had to be done by that Monday, but that she could not talk about it with
her over the phone. ANNA RICHTER said she had been exchanging text communications
with DARREN MEADE, and DARREN MEADE had to get a hold of the attorney
representing TRACEY RICHTER on the direct appeal of her murder conviction.
The following demonstrates the extremely important matter DARREN MEADE had to
discuss with the attorney representing TRACEY RICHTER on appeal probably had
something to do with this newly discovered evidence found by DARREN MEADE.
THE PHANTOM JUROR
55
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
As mentioned above, on April 26, 2012, ANNA RICHTER sent an e-mail from her account
[[email protected]] to a local newspaper journalist, asking the journalist to look
at the RIPOFF REPORT story published by DARREN MEADE. ANNA RICHTER told the
journalist: 'There is no doubt in my mind that some of the [members of the jury who
convicted her daughter, TRACEY RICHTER, of murder] read the paper and internet that
weekend and [TRACEY RICHTER's second ex-husband] made sure they were filled with
his lies."
On June 1, 2012, DARREN MEADE posted the following on The Virginia Gazette's website:
"One person purporting to have been a juror in the Richter murder trial claims to have
[googled] TRACEY RICHTER and what they located online made them decide to convict
her."
Coincidentally, this same thing happened to TRACEY RICHTER following her second
felony conviction (perjury), which was on July 27, 2010, in the Clay County District Court
(Iowa), Case No. FECR014399. On August 18, 2010, while her direct appeal of her felony
perjury conviction was being prepared, someone purporting to be one of the Clay County
jurors who convicted her wrote the following on the Storm Lake Pilot Tribune's website:
I was a juror at the 7/12/10 trial. Her lawyer did not even show us a legal name change
and presented no evidence. During lunch break I googled her and learned the truth about
her. There was no way I was going to let her walk.
In another coincidence, around the same time this anonymous juror published the above-
mentioned comment, ANNA RICHTER wrote the following in a letter to then-Sac County
Attorney Earl Hardisty:
I'm sure that you found out that [TRACEY RICHTER] was found guilty of perjury in [Clay
County]. Funny how her attorney refused to put on a defense for her, saying there was
no need to. Naturally we are appealing it.
In her motion for new trial filed October 6, 2010, TRACEY RICHTER offered up this
supposed instance of juror misconduct as grounds for a new criminal trial:
There appeared an internet posting on or about August 18, 2010 on the Storm Lake Pilot
Tribune website in apparent response to a reprint of an article on the 2001 Early shooting
case in which the Dustin Wehde died in the Defendant's home. The internet posting
indicated that 'I was a juror at the 7/12/10 trial. Her lawyer did not even show us a legal
name change and presented no evidence. During lunch break I googled her and learned the
truth about her. There was no way I was going to let her walk.
56
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
On December 10, 2012, ANNA RICHTER told TRACEY RICHTER that RIPOFF REPORT
owner ED MAG EDSON wanted BERT PITMAN to send ED MAG EDSON and DARREN
MEADE certain information.
On December 14, 2012, at TRACEY RICHTER's direction, DARREN MEADE published
RIPOFF REPORT complaints Nos. 982235 and 981918, which are open letters from
TRACEY RICHTER to her and Michael Roberts' children, N.R. and M.R. These "letters"
were clearly intended to reach Michael Roberts' minor children when their names are
entered into a Google.
RIPOFF REPORT complaint No. 982235, which is DARREN MEADE's I TRACEY
RICHTER's open letter to Michael Roberts daughter, M.R. then 12 years old, is titled:
[M.R.] - [M.R.] I MICHAEL ROBERTS REXXFIELD FOUND TO ABUSE CHILDREN AND
WIFE TRACEY RICHTER CONTINUES ABUSE BY REFUSING TO ALLOW MOTHER AND
DAUGHTER TO CONTACT ONE ANOTHER I MILE2 CHILD ABUSE MILE2, DR HEIDI
ROBERTS CONDONES ABUSE OF [M.R.] AND [N.R.] GOOGLE-CIDE, DR SCOTT
CONNELLY INTERNET
RIPOFF REPORT complaint No. 981918, which is DARREN MEADE's I TRACEY
RICHTER's open letter to Michael Roberts son, N.R., is titled:
[N.R.] - Michael Roberts Rexxfield Abusing Children By Refusing Contact His Mother
TRACEY RICHTER \ 60 Minutes Australia \ Mile2 \ Sac County Prosecutor Ben Smith \
[M.R.] \ Google-cide
TRACEY RICHTER and DARREN MEADE's above-mentioned letters to N.R. and M.R.,
and their add-on complaints and the content of the complaints behind the numerous
inserted hyperlinks, are filled with demeaning and defamatory content about their father,
Michael Roberts, which, if taken at face value, would be extremely distressing to a child.
DARREN MEADE and TRACEY RICHTER's "letters" to here to N.R. and M.R. were clearly
intended to reach Michael Roberts' minor children via Google. In fact, as of July 5, 2014,
when "[N.R.'s full name] and [M.R.'s full name]" is searched using Google, DARREN
MEADE and TRACEY RICHTER's letters to N.R. and M.R. appear first and second,
respectively, on the first page of the Google search result.
On January 5, 2013, ED MAGEDSON I RIPOFF REPORT ([email protected]) told
DARREN MEADE [email protected]) that private investigator Tina Church
wanted to help with TRACEY RICHTER's case and directed DARREN MEADE to contact
private investigator Tina Church.
57
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
On January 6, 2013, DARREN MEADE [email protected]) sent the following in
an e-mail to private investigator Tina Church, which he copied to ED MAGEDSON I
RIPOFF REPORT ([email protected]) and ANNA RICHTER
([email protected]):
I enjoyed our previous conversations, and was hopeful we might be able to utilize your name
and know-how, to what I had uncovered in regards to the 'abuse of process', 'prosecutorial
misconduct', 'witness intimidation' and wrongful prosecution of TRACEY RICHTER. We had
spoken about working together to not only help TRACEY RICHTER but others suffering the
same travesty of justice. In good faith I put you in touch with both ED MAGEDSON of Ripoff
Report and ANNA RICHTER the mother of TRACEY RICHTER. Tina, is it possible to
authenticate that you are in fact the known private investigator Tina Church, whom worked
often with Innocent Project? I've come across multiple electronic artifacts that have linked
you to Michael Roberts I Rexxfield. Michael Roberts is the master mind whom has placed
TRACEY RICHTER in prison for life without the possibility of parole, conspired to have me
killed (which is on audio tape) and 4 months ago began offering $2,500 for anyone woman to
come forward and provide testimony that I raped them. TRACEY RICHTER is innocent, if
you can help her family, then they certainly need your help. Equally, you can take the work I
have done, and call it your own.
On January 6, 2013, ED MAGEDSON I RIPOFF REPORT wrote the following in an e-mail
to private investigator Tina Church, which he copied to DARREN MEADE (dmeade@kairos-
meade.com) and ANNA RICHTER ([email protected]):
When you called me the other night you made a comment to me that was very disturbing to
me. You stated to me, DARREN MEADE told you that he worked for me .. Darren would
never lie. He never has and will not be working for Ripoff Report. This is a well-known claim
by Michael Roberts. AGAIN, I HAVE NEVER EVER KNOWN DARREN TO TELL A LIE, OR
EVEN SWAY FROM THE TRUTH IN THE SLIGHTEST BIT. IF HE IS NOT SURE OF
SOMETHING, HE WILL NOT SAY IT. DARREN IS THE REAL DEAL. If Darren is wrong, or
I am wrong - I hope you will understand our concern here.
On January 8, 2013, RIPOFF REPORT owner ED MAGEDSON ([email protected])
wrote the following in an e-mail to private investigator Tina Church:
I am not sure if you are who you say you are, .. and if you could be somehow not a double
agent ... For all I know, you think Michael Roberts' is not guilty and you want to try and save
him .. I have no idea what is going on- but, something is not right. ALL I WANT .. I WANT
TO DO ANYTHING THAT HELPS FREE TRACEY-- I want to do anything that helps those
that are not guilty - after rescuing dogs from being euthanized every day, and my website
helping consumers - the only other thing on my wish list is to help those you are sitting on
death row and those that got life wrongfully. Again, if I am wrong - and you are smart, ..
you can see why I feel the way I do. I AM WILLING TO FEATURING ARTICLES AND
58
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
PLACE ADVERTISEMENTS FOR THE CAUSE ON MY WEBSITE.
On January 9, 2013, the Iowa court of appeals affirmed TRACEY RICHTER's murder
conviction.
On January 9, 2013, ANNA RICHTER told TRACEY RICHTER she lost her appeal. ANNA
RICHTER said she published a comment on RIPOFF REPORT that TRACEY RICHTER
was not able to bring up new information on her direct appeal. ANNA RICHTER said
DARREN MEADE wanted TRACEY RICHTER's attorney to serve him with a subpoena.
concerning threats he alleged SCA Smith made to him. ANNA RICHTER said she had
things that she needed to discuss with DARREN MEADE. TRACEY RICHTER said they
needed to subpoena this information from DARREN MEADE to "keep him out of the
middle."
On January 9, 2012, DARREN MEADE published an add-on complaint to his September 9,
2012, RIPOFF REPORT complaint No. 938843, which he titled: THE EVIDENCE OF
PROSECUTORIAL MISCONDUCT AND WITNESS TAMPERING CANNOT BE
INTRODUCED UNTIL AFTER THE "DIRECT APPEAL" (WHICH MEAN ONLY EVIDENCE
FROM THE TRIAL) IS EXHAUSTED. In this comment I add-on complaint, DARREN
MEADE published the following statements TRACEY RICHTER's fiance, RUSSELL
SCHERTZ, made about the Court's decision:
[RUSSELL SCHERTZ] admits the decision will cost Richter, and her family, "years that they
cannot get back." Richter's appeal was what's called a "direct appeal," which means it could
only include evidence in the court record from the trial. But, Schertz says he's uncovering
new information about "prosecutorial misconduct and witness tampering" that he thinks
should allow for a new trial in the future. For now, Schertz says the family will file an appeal
with the Iowa Supreme Court in the next 20 days.
On January 10, 2013, ANNA RICHTER told TRACEY RICHTER that DARREN MEADE was
upset that TRACEY RICHTER lost her direct appeal of her murder conviction. ANNA
RICHTER and TRACEY RICHTER discussed the post-conviction relief (PCR) process
versus that of the direct appeal; specifically, that new evidence can be considered in a PCR
action. ANNA RICHTER said DARREN MEADE told her he discovered information that
proved Michael Roberts had motive to frame Dr. John Pitman for TRACEY RICHTER's
murder. ANNA RICHTER said they needed to attack the testimony of the State's witnesses.
ANNA RICHTER said she and high school graduate DARREN MEADE discussed trial
strategy, specifically, putting doubts in the jurors' minds. ANNA RICHTER said DARREN
MEADE planned to publish a RIPOFF REPORT complaint about the horrible job he
believed TRACEY RICHTER's criminal defense attorneys did in representing her. Later, the
two discussed why they believed Michael Roberts was homosexual.
59
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
On January 11, 2013, DARREN MEADE ([email protected]), in an e-mail to
ANNA RICHTER ([email protected]), RUSSELL SCHERTZ
([email protected]), and DONNA BISTRICAN ([email protected]) said he created the
website TraceyRichter.com, and asked the group to have their friends and family to spend a
couple hours per week creating additional links to the site. The website
www.TraceyRichter.com is replete with links to all the RIPOFF REPORT complaints
concerning the State's witnesses that are referenced in this affidavit. It also provides links to
the following active social media accounts purporting to be owned, controlled, and authored
by TRACEY RICHTER: Facebook.com, YouTube.com, Twitter.com, AboutMe.com, and
others, all of which contain recent (as recently as June 10, 2014) posts, comments, and
other content that link to the RIPOFF REPORT articles about the State's witnesses.
DARREN MEADE also told them the content up on TraceyRichter.com should be more from
their voices, not his, and that creating these additional profiles and links to the website
would make them all more visible on Google-type search results (thus making the RIPOFF
REPORT complaints more visible). Also in this e-mail, DARREN MEADE provided the
above-named recipients with the login, password, and e-mail ([email protected])
for the website.
On January 12, 2013, ANNA RICHTER told TRACEY RICHTER that ANNA RICHTER's
son, JOHN RICHTER, a police detective from another state, obtained information about Dr.
John Pitman's arrest and had given it to her. ANNA RICHTER said BERT PITMAN told her
that Dr. John Pitman spends all his money on prostitutes. Dr. John Pitman had been
arrested pursuant to a bench warrant for failing to appear for court in a civil matter, and the
contempt charge was never adjudicated.
On January 13, 2013, ED MAGEDSON directed DARREN MEADE to contact private
investigator Tina Church to discus their "strategy."
On January 13, 2013, ANNA RICHTER ([email protected]) sent the following
e-mail to BERT PITMAN ([email protected]):
Contact [reporter's name]@vagazette.com, [a reporter from the Virginia Gazette]. I told him
about [Dr. John Pitman's] arrest and other things regarding his taking money from you and
not paying for your college and his girlfriend from Canada. I told him you have more info on
her then I do. Sorry but after what your dad did to Tracey I want him to know how it feels to
have his name in the paper and not in a good way. Once we get the mugshot of him Darren
is going to do a piece on him. I also gave this Carter the Ben Smith Website and the new one
on your mom which I sent you. I hope we can get him interested. Don't put it off. This is
important.
On January 14, 2012, DARREN MEADE published yet another add-on complaint to his
60
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
September 9, 2012, RIPOFF REPORT complaint (No. 938843), in which high school
graduate DARREN MEADE explained to readers that difference between a direct appeal
and a habeas corpus action (Post Conviction Relief). Specifically, that newly discovered
evidenced, such as "prosecutorial misconduct" and "witness tampering" can be introduced
in the latter to obtain a new trial, and not in the former.
On January 14, 2013, TRACEY RICHTER asked ANNA RICHTER ifthere was a "mug shot"
of Dr. John Pitman. ANNA RICHTER told TRACEY RICHTER that Dr. John Pitman is
pushing his surgery practice into the ground. TRACEY RICHTER stated she hoped to get
more information on Dr. John Pitman and that she wanted to see Dr. John Pitman's mug
shot. ANNA RICHTER said she e-mailed ED MAGEDSON, the owner I operator of RIPOFF
REPORT, and "that one attorney," which the two had discussed earlier. ANNA RICHTER
said she e-mailed ED MAGEDSON and DARREN MEADE about ED MAGEDSON
something believed to be related to TRACEY RICHTER's case and RIPOFF REPORT.
ANNA RICHTER said BERT PITMAN posted a lot of this content on Facebook. TRACEY
RICHTER said they needed to get sworn statements from people but that she did not want
to mention any names over the phone.
On January 14, 2013, ANNA RICHTER told TRACEY RICHTER that DARREN MEADE
asked her for documents from the wrongful death lawsuit brought against TRACEY
RICHTER by Dustin Wehde's estate.
On January 21 , 2013, author "BRETT COLLINS" published RIPOFF REPORT complaint
No. 1000888, titled "DR. JOHN PITTMAN THE THIRD, MEDICAL DOCTOR PLASTIC
SURGERY CENTER NAME, PITTMAN SURGICAL ASSOCIATES, A STRANGE EX-
HUSBAND KEY WITNESS ARRESTED BY SIX ARMED OFFICERS PLASTIC SURGERY
PRACTICE, UNITED STATES ARMY COL." Among other things, this RIPOFF REPORT
complaint accuses Dr. John Pitman of committing perjury, compounding felonies, ongoing
illicit drug use I abuse, and associating with strippers and hookers. The article continues,
alleging that Dr. John Pitman is driving his practice into the ground with "shabby work."
[During one of their phone conversations, ANNA RICHTER told TRACEY RICHTER that Dr.
John Pitman "was driving his practice into the ground"]. Also in this complaint are links to
other RIPOFF REPORT complaints concerning Dr. John Pitman.
On January 22, 2013, BERT PITMAN sent the following e-mail message to the Virginia
Gazette; shortly thereafter, he forwarded the message to ANNA RICHTER as proof he
completed the task which she had given him:
To whom it may concern, My grandmother, ANNA RICHTER, had informed me about a week
ago that she had e-mailed you about my father John Pitman and mother TRACEY
RICHTER. I would like to speak with you about very important recent and past occurrences.
61
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Including his recent arrest, his possession of the police report on the house invasion/
"murder", his relationship with Allisan "lachesis" tucker, and many other important and case
breaking actions committed by my father. John Pitman has painted a picture of himself and
his life that is nothing other than a facade. Sorry it took a little while to contact you, I have
been very busy moving to Richmond, working and obviously this has been a extremely tough
situation for a son to be in. My number is 7575855037, please call me at your convenience.
BERT PITMAN.
On January 25, 2013, add-on complaint (rebuttal) to RIPOFF REPORT complaint No.
1000888, titled "DR. JOHN PITMAN AND MICHAEL ROBERTS REXXFIELD CAUGHT
RED-HANDED," was published on RIPOFF REPORT. In this add-on complaint, anonymous
author, "2 DEADBEAT DADS" alleged, among other things, that Michael Roberts and Dr.
John Pitman were responsible for Dustin Wehde's murder. The following excerpt was
contained in the body of the complaint: "[Michael Roberts] told Dateline NBC of wanting to
kill John Pittman prior to 2001, and that Roberts claimed he had more money than Pittman
and would outspend him in the custody hearings over his stepson." [TRACEY RICHTER
and ANNA RICHTER discussed this same subject matter (Michael Roberts wanting to kill
Dr. John Pitman) - in one of their prison phone conversations right before "2 DEADBEAT
DADS" published this RIPOFF REPORT complaint, which concerned the very same subject
matter]
On January 25, 2013, an add-on complaint (rebuttal) to RIPOFF REPORT complaint No.
1000888, titled "DR. JOHN PITTMAN AND MICHAEL ROBERTS VEGAS ORGIES,
SHE/HE AND HE/HE TWISTER, DR. PRESCRIBING PAIN PILLS FOR SEX FUELED
NIGHTS," was published on RIPOFF REPORT. The substantive content of this add-on
complaint, which was authored by anonymous author "SHARED VICTIMS," is in keeping
with the subject matter described in its title. This add-on complaint, like most, if not all the
other RIPOFF REPORT complaints concerning the State's witnesses, contains numerous
hyperlinks that redirect viewers I readers to other RIPOFF REPORT complaints about the
State's witnesses.
On January 25, 2013, an add-on complaint (rebuttal) to RIPOFF REPORT complaint No.
1005913 was published on RIPOFF REPORT with the following title:
DR. JOHN PITTMAN CHEATS ON WIFE LISA PITTMAN WITH RAPPER. DR. JOHN
PITTMAN BROKE WITH MULTIPLE TAX IRS TAX LIENS, FINANCES VIDEO FOR
RAPPER WHICH HAS A BRUTAL HOME INVASION MURDER SIMILAR TO THE
HUSBAND CHEATS ON DEAD FISH WIFE LISA PITMAN, ALLISON TUCKER, TRACEY
RICHTER MURDER TRIAL, SAC COUNTY IOWA WILLIAMSBURG, VIRGINIA
On January 30, 2013, author "LACHESIS" published RIPOFF REPORT complaint No.
1005913, the content of which is in line with its title:
62
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
DR. JOHN PITMAN CHEATS ON WIFE LISA PITMAN WITH RAPPER LACHESIS. DR
JOHN PITMAN BROKE WITH MULTIPLE TAX IRS TAX LIENS, FINANCES VIDEO FOR
LACHESIS WHICH HAS A BRUTAL HOME INVASION MURDER SIMILAR TO THE
HUSBAND CHEATS ON DEAD FISH WIFE LISA PITMAN, ALLISAN TUCKER, TRACEY
RICHTER MURDER TRIAL, SAC COUNTY IOWA WILLIAMSBURG, VIRGINIA."
On January 31, 2013, ANNA RICHTER told TRACEY RICHTER she was unable to locate
certain information concerning the CHILDREN of one of the State's witnesses. TRACEY
RICHTER asked if there was any new news on Dr. John Pitman. ANNA RICHTER said
there was a story on the internet concerning Dr. John Pitman, but ANNA RICHTER thought.
it was authored by someone else. ANNA RICHTER said the RIPOFF REPORT article on
Dr. John Pitman was crazy, because it was about Dr. John Pitman having orgies and being
fat. ANNA RICHTER then said something to the following effect: DR. JOHN PITMAN IS
NOT GOING TO HAVE ANY MONEY BECAUSE OF THESE RIPOFF REPORT
ARTICLES. TRACEY RICHTER said BERT PITMAN had once said Dr. John Pitman had
orgies. ANNA RICHTER said she was debating whether to publish an add-on complaint I
comment on the RIPOFF REPORT complaints concerning Dr. John Pitman. TRACEY
RICHTER said it would be better if "WE" do not have any personal connection to the
negative stories. ANNA RICHTER claimed she did not know who wrote the "crazy stuff'
about Dr. John Pitman.
On February 5, 2013, DARREN MEADE published RIPOFF REPORT complaint No.
1009000, the subject matter of which is in keeping with its title:
MILE2 MICHAEL ROBERTS REXXFIELD RAYMOND FRIEDMAN" WRITES MILE2
MICHAEL ROBERTS REXXFIELD RAYMOND FRIEDMAN MARIE FRIEDMAN GRAPHIC
DEPICTIONS OF CHILD MOLESTATION, CHILD TORTURE, EXACT RECIPES OF LIQUID
EXPLOSIVES, TYPE BOMBS ILLICIT RECORDINGS, INTERNET.
On February 6, 2013, anonymous author "RAID" published an add-on complaint (rebuttal) to
RIPOFF REPORT complaint No. 1009000, the subject matter of which is in keeping with its
title: MICHAEL ROBERTSON RAYMOND FRIEDMAN MADE MILE2 CEASE TO EXIST
OUT OF FEAR OF THE CHILD TORTURE PORN ON YOUR FREE MIGHT PUT US OUT
OF BUSINESS.
On February 7, 2013, TRACEY RICHTER relayed a phone number to ANNA RICHTER
using a code the two developed. The coded message, which was later deciphered, was the
phone number of a school TRACEY RICHTER and RUSSELL SCHERTZ believed one of
her and Michael Roberts' child M.R. was currently attending. TRACEY RICHTER said
RUSSELL SCHERTZ had called the school, but that it would not give him any information
because he was not immediate family. TRACEY RICHTER directed ANNA RICHTER to call
63
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
the school. ANNA RICHTER said DARREN MEADE told her the copy of his deposition that
was given to SCA Smith by Dr. Scott Connelly was fake.
On February 14, 2013, ANNA RICHTER told TRACEY RICHTER that DONNA BISTRICAN
posted something on Facebook about TRACEY RICHTER's case. TRACEY RICHTER
directed ANNA RICHTER to have BERT PITMAN post something similar on Facebook.
ANNA RICHTER said DARREN MEADE and ED MAGEDSON I RIPOFF REPORT planned
to publish another RIPOFF REPORT complaint [presumably concerning the State's
witnesses]. TRACEY RICHTER said "stuff is coming out about Dr. John Pitman." Then,
just as ANNA RICHTER mentioned DARREN MEADE's name, TRACEY RICHTER directed
her to stop talking about [DARREN MEADE, Dr. John Pitman, and RIPOFF REPORT] over
the phone, and that the two would talk about it in person during ANNA RICHTER's next visit
to the prison. ANNA RICHTER said she had information to pass along to TRACEY
RICHTER from DARREN MEADE, but that she would wait and tell it to TRACEY RICHTER
during her next visit with her at the prison TRACEY RICHTER at the prison. Later during
their conversation, ANNA RICHTER said she stored e-mails from RIPOFF REPORT on her
computer.
On February 17, 2013, TRACEY RICHTER sent a letter to DONNA BISTRICAN asking her
to manage her e-mail, social media, and other online accounts. In this same letter, TRACEY
RICHTER wrote she believed SCA Smith or DCI SA Vileta were linked to her prison
counselor and that her prison counselor had been in contact with someone connected to
[Michael Roberts], but TRACEY RICHTER did not know which one (either SCA Smith or
DCI SA Vileta) because "the FBI [would not] give [her and her family I friends] a name at
this point."
On March 6, 2013, in an add-on complaint (rebuttal) published in RIPOFF REPORT No.
938843, anonymous I fictitious author "BETHANY" made comments generally defaming
MICHAEL ROBERTS. Interestingly, at the bottom of this rebuttal I comment, author
"BETHANY" just so happened to include a link to DARREN MEADE's website
www.cyberbountyhuntersblog.com.
On March 7, 2013, DARREN MEADE published State's witness Michael Roberts' wife's
(Heidi Forsbacka) bank account information on his website cyberbountyhunger.com. The
manner in which this information appeared or was displayed on DARREN MEADE's website
and other circumstances strongly suggest Ms. Forsbacka's banking information was
obtained illegally (i.e., computer hacking). Later, on April 8, 2013, DARREN MEADE sent
an e-mail message wherein he freely admitted possessing and publishing Michael Roberts'
wife's banking information.
On March 22, 2013, BERT PITMAN told TRACEY RICHTER that he planned to give "the
64
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
addresses to the group."
On April 2, 2013, ANNA RICHTER told TRACEY RICHTER that she called BERT PITMAN
about an internet article I news story concerning TRACEY RICHTER, which ANNA
RICHTER believed Dr. John Pitman published and I or authored. ANNA RICHTER said
DARREN MEADE had "all kinds of stuff up" in response to this article. ANNA RICHTER
further told TRACEY RICHTER that "this is the last straw" as for Dr. John Pitman, and that
she planned to "fight back." TRACEY RICHTER directed ANNA RICHTER to get DARREN
MEADE to put "all these things together."
On April 2, 2013, ANNA RICHTER and TRACEY RICHTER cryptically discussed State's
witness Mary Higgins. ANNA RICHTER said her and DONNA BISTRICAN recently had a
discussion about State's witness Mary Higgins. The following demonstrates that TRACEY
RICHTER and ANNA RICHTER have been using DONNA BISTRICAN to intimidate State's
witness Mary Higgins since before TRACEY RICHTER's murder trial started.
DONNA BISTRICAN
On September 21, 2011, TRACEY RICHTER wrote the following letter to ANNA RICHTER
from the Sac County Jail:
[State's witness Mary Higgins] is crazy, no wonder [Mary Higgins] didn't have any friends.
[Mary Higgins] needs to get her [medication] adjusted and go to church. Our talk last night
helped me a great deal. Please send my best to [DONNA BISTRICAN]. I miss her. I was also
upset over [Mary Higgins'] comments about [DONNA BISTRICAN]. It was mean spirited and
unnecessary. [DONNA BISTRICAN] doesn't have a mean or dishonest bone in her body.
She never did anything to warrant [Mary Higgins'] cruelness.
In late September 2011 or early October 2011, about three weeks before TRACEY
RICHTER's murder trial started, Mary Higgins was jogging not far from her rural Early, Iowa,
farmstead on the gravel roads on which she always jogged, when she saw a larger than
normal rock lying near the middle of the gravel road. Underneath the rock, Mary Higgins
found a note which said, "DEMON BE GONE." The note also had numbers on it. Mary
Higgins reluctantly provided the above-information to law enforcement out of concern for
her and her family's safety on October 4, 2011.
A Des Moines, Iowa resident since 2010, DONNA BISTRICAN had previously been
neighbors in Early, Iowa. DONNA BISTRICAN is one of TRACEY RICHTER's most loyal,
65
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
dedicated followers. Information provided to law enforcement suggests DONNA
BISTRICAN was in the Early, Iowa area around the time State's witness Mary Higgins found
this note.
Shortly after Michael Roberts filed for divorce from TRACEY RICHTER, which was on or
around May 7, 2004, DONNA BISTRICAN sent Michael Roberts the following in an e-mail,
which served as an electronic exorcism or "e-exorcism" of Michael Roberts: "In Jesus name
I bind Satan and his DEMONS TO COME OUT OF YOU (Michael Roberts) now and get
away from you (Michael Roberts) now." In a communication to JOHN RICHTER in February
2012, DONNA BISTRICAN admitted to sending this e-mail to Michael Roberts.
Mary Higgins and her family have reported that their farmstead residence has been
burglarized at least five times since TRACEY RICHTER was convicted of murder
(November 7, 2011 ). Following one of these break-ins, the lock from the home's front door
had been removed, reassembled, and placed in the center of their kitchen floor. Another
time they returned home to find their kitchen chairs turned upside-down.
On April 11, 2013, TRACEY RICHTER and ANNA RICHTER discussed getting Dr. John
Pitman to sign an affidavit swearing the information I statements attributed to him in an
online article in the online UK newspaper "The Daily Mirror" were false. TRACEY RICHTER
told ANNA RICHTER to have BERT PITMAN get Dr. John Pitman to retract these
statements. TRACEY RICHTER told ANNA RICHTER to have BERT PITMAN get certain
information about Michael Roberts and Dr. John Pitman, and give it to either DARREN
MEADE or ED MAGEDSON I RIPOFF REPORT. ANNA RICHTER said more and more
people "from out there" believed Dr. John Pitman hired Dustin Wehde to attack I kill
TRACEY RICHTER, and that she would discuss it more in detail during her next visit to the
prison. TRACEY RICHTER told ANNA RICHTER to get the password for the laptop in
ANNA RICHTER's possession from her fiance, RUSSELL SCHERTZ.
On April 15, 2013, SCA Smith moved to quash a subpoena issued to the Sac County Sheriff
by TRACEY RICHTER in the contempt action she filed in the Buena Vista County, Iowa,
District Court against Michael Roberts for non-payment of child support. In said motion, to
address another like-subpoena TRACEY RICHTER's custody I child support attorney
issued to DARREN MEADE for the "names and individuals that you know have been
threatened by [SCA Smith]," SCA Smith discussed DARREN MEADE's aforementioned
deposition, wherein DARREN MEADE testified he knowingly consorted and conspired with
66
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
convicted felons to harass and defame a witness in a civil matter. Also included in SCA
Smith's motion was a reference to DARREN MEADE's deposition testimony concerning
RIPOFF REPORT:
RIPOFF REPORT never deletes anything written about somebody. So it's the perfect place
to defame somebody because it will always stay up, and for some reason it winds up ranking
on the first page of Google. So if you want to destroy somebody's reputation, that's a great
place to do it.
On April 17, 2013, ANNA RICHTER told TRACEY RICHTER that she had just gotten off the
phone with an FBI agent. Then the two discussed what TRACEY RICHTER's attorney
needed to subpoena, but agreed they should not talk about it over the phone. ANNA
RICHTER said that "a certain person" would be calling TRACEY RICHTER's child support I
custody attorney, but did not want to tell TRACEY RICHTER who the "someone" was or talk
about the matter over the phone any further.
On or around April 18, 2013, ANNA RICHTER sent DARREN MEADE a Western Union
Money Gram in the amount of $400.00, which he deposited into his Bank of America
account.
On April 18, 2013, DARREN MEADE asked a friend whether the friend knew "someone who
had time to "make one to two videos for [DARREN MEADE] per week." DARREN MEADE
told this person that he had written "two of the scripts and wish to find someone whom could
make the videos have the look and feel of a breaking news story such as CNN did with the
recent bombings in Boston."
On April 25, 2013, ANNA RICHTER told TRACEY RICHTER she wanted to go after Dr.
John Pitman (or SCA Smith) with a vengeance. TRACEY RICHTER asked ANNA RICHTER
whether "they" are putting certain information into the video [presumably a video about the
State's witnesses]. ANNA RICHTER responded that they should making this video because
she, ANNA RICHTER, had given "them" the information.
On April 30, 2013, an e-mail containing a "non-indexed" link accessing a copy of SCA
Smith's aforementioned Motion to Quash (MTQ) was sent to ED MAGEDSON's e-mail
address ([email protected]), which ED MAGEDSON accessed and viewed, then
forwarded to DARREN MEADE, who also accessed and viewed the same. ED
MAGEDSON's viewing SCA Smith's MTQ was at least the second time ED MAGEDSON I
RIPOFF REPORT was made of aware of DARREN MEADE's deposition (SCA Smith's
MTQ referenced and cited DARREN MEADE's deposition)- the same deposition in which
DARREN MEADE testified that RIPOFF REPORT was a "great place to destroy someone's
reputation" and that he was hired by convicted felons to harass and defame a witness via
the internet.
67
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
"Non-indexed" links (or URL's uniform resource locators") host content which is
intentionally hidden from search engine results pages thus restricting access to the link from
anyone using common search engine tools to discover online content. In this case, the
links could only be accessed (or opened) by directly clicking on the link contained in the
body of an e-mail delivered to a targeted individual. Accessing or clicking the link is
recorded on the server hosting the URL and the server's log files automatically records the
date and time (in GMT) as well as the Geolocation of the IP address of the recipient's
computer used to access their e-mail account. Any such IP recovery data can only be
recorded by those directly receiving the e-mail from the originating sender or those
individuals who are forwarded the e-mail from the intended "target" (or "recipient zero") of
the e-mail. Therefore, the first IP recorded in this instance was traced to ED MAGEDSON,
who then forwarded it to an individual who opened it disclosing an IP address linked to
DARREN MEADE's computer.
On May 5, 2013, TRACEY RICHTER and ANNA RICHTER discussed the letter TRACEY
RICHTER's child support I custody attorney wrote to the Sac County Board of Supervisors,
wherein said attorney accused SCA Smith of committing a crime and violating an ethical
rule. TRACEY RICHTER told ANNA RICHTER to "feel free to give a copy of the letter to
'someone' if they wanted one." Later, TRACEY RICHTER expressly told ANNA RICHTER
to have DARREN MEADE published the letter on the internet and give a copy of it to
DONNA BISTRICAN.
On May 6, 2013, an e-mail containing a "non-indexed" link to a YouTube video described
below in "The Glenn Puit Disappearing RIPOFF REPORT Complaint" was sent to ED
MAGEDSON's e-mail address ([email protected]), which, like the non-indexed link
mentioned above, ED MAGEDSON accessed and viewed, then forwarded to DARREN
MEADE, who accessed and viewed it.
GLENN PUIT'S DISAPPEARING RIPOFF REPORT COMPLAINT
Back in January 2012, ED MAGEDSON and DARREN MEADE solicited the services of
investigative journalist Glenn Puit to create what would become RIPOFF REPORT
complaints Nos. 828918 and 829020. The following factual assertions can be taken from
DARREN MEADE's e-mail and other communications to and from ED MAGEDSON and
others between December 2011 through February 2012: ED MAGEDSON paid DARREN
MEADE to work directly with investigative journalist, Glenn Puit. ED MAGEDSON
68
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
personally directed content edits and changes to Glenn Puit's work. ED MAGEDSON I
RIPOFF REPORT's attorneys reviewed Glenn Puit's complaint before it was published on
RIPOFF REPORT's website. ED MAGEDSON asked that Glenn Puit address specific
issues and allegations against certain individuals in his article. ED MAGEDSON directed
DARREN MEADE to create other RIPOFF REPORT complaints. ED MAGEDSON had
DARREN MEADE edit various RIPOFF REPORT complaints to include certain content so
that these complaints would be more visible and rank higher on internet search results. ED
MAGEDSON suggested that DARREN MEADE format DARREN MEADE's complaints in a
way that would make them more viewer friendly. DARREN MEADE told investigative
journalist Glenn Puit the only way ED MAGEDSON would allow certain audio I visual
content to appear in journalist's complaint is through DARREN MEADE and if the articles
were beneficial to RIPOFF REPORT's interests. ED MAGEDSON directed DARREN
MEADE to "create new titles for the preexisting derogatory RIPOFF REPORT complaints
about DARREN MEADE. ED MAGEDSON promised to "optimize" them so that existing
unfavorable RIPOFF REPORT complaint(s) about DARREN MEADE would be effectively
removed from the internet.
On January 11, 2012, ED MAGEDSON I RIPOFF REPORT paid DARREN MEADE
$2,500.00 (check No. 002498) with the memo "[Public Relations] thru Feb 15
1
h 2012."
On January 23, 2012, when asked whether Glenn Puit's anticipated RIPOFF REPORT
complaint would be a "featured" RIPOFF REPORT complaint, DARREN MEADE said: "I
don't believe the first article will be linked on every page, [because there was] no benefit to
ROR."
As mentioned earlier, on January 26, 2012, Journalist Glenn Puit, published RIPOFF
REPORT complaint No. 829020. The original report's headline was simply "COMPLAINT
REVIEW: GOOGLE-CIDE: THE FULL STORY PROGENEX LEADERS ADAM
ZUCKERMAN, RYAN PAGE," and the title's first sentence read: "PROGENEX MANAGERS
ADAM STUART ZUCKERMAN AND RYAN PAGE NEGOTIATE CONTRACT WITH
REXXFIELD ONLINE REPUTATION MANAGEMENT MICHAEL ROBERTS IN ATTEMPT
TO COMMERCIALIZE INJECTION SOURCE CODE." The article was a damning account
of the criminal activities of convicted felons ADAM ZUCKERMAN and KIRK MCMAHAN
described earlier herein.
Glenn Puit's original RIPOFF REPORT complaint here was originally published and was
located at the following URL address: http://www.ripoffreport.comlbusiness-
consultantslgoogle-cide-the-fulllgoogle-cide-the-full-story-b3660.htm
Sometime on or after March 13, 2012 but before April30, 2013, ED MAGEDSON or another
RIPOFF REPORT agent created an unauthorized duplicate copy of Glenn Puit's article and
69
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
therein effected subtle changes with the clear intent of increasing harm done to Michael
Roberts. The following is the new URL for the duplicated I edited RIPOFF REPORT
com plaint: http :I lwww. ripoffreport.comlriM ichaei-Roberts-Rexxfie ld-Goog le-cide-The-F u 11-
Story-Progenex-leaders-Adam-Stuart-Zuckerman-Ryan-PageiCosta-Mesa-California-
926261Michaei-Roberts-Rexxfield-Progenex-Managers-Adam-Zuckerman-and-Ryan-Page-
negotiate-contr-829020
On May 27, 2014, ED MAGEDSON or another RIPOFF REPORT agent made substantive
changes to the article in that he changed both the heading and sub-heading to draw more
attention to Michael Roberts and his business, Rexxfield. The headline was changed to
following: "COMPLAINT REVIEW: MICHAEL ROBERTS, REXXFIELD, GOOGLE-CIDE:
THE FULL STORY PROGENEX LEADERS ADAM STUART ZUCKERMAN, RYAN PAGE";
and the first sentence of the title was changed to: "MICHAEL ROBERTS, REXXFIELD,
PROGENEX MANAGERS ADAM ZUCKERMAN AND RYAN PAGE NEGOTIATE
CONTRACT WITH REXXFIELD ONLINE REPUTATION MANAGEMENT MICHAEL
ROBERTS IN ATTEMPT TO COMMERCIALIZE INJECTION SOURCE CODE."
The changes made by RIPOFF REPORT administrators to the duplicated article's sub-
heading I title and URL serve no purpose except to increase the damage done to Michael
Roberts. The extra emphasis on Michael Roberts' personal name and business name in
both the sub-heading I title and more conspicuously, in the URL, is clearly an attempt by
RIPOFF REPORT to use generally accepted "Search Engine Optimization" techniques in
order to persuade Google and other search engines to elevate this RIPOFF REPORT
complaint in search results for Michael Roberts' name.
On or about April 30, 2013 SCA Smith discovered the unauthorized derivative of Glenn
Puit's original article. Thereafter, journalist Glenn Puit was notified about the change. After
learning of the change, Glenn Puit contacted ED MAG EDSON directly to protest the issue.
Shortly thereafter, ED MAGEDSON or an agent of RIPOFF REPORT deleted the new URL.
These facts were memorialized by Michael Roberts in the form of a YouTube "screen cast"
video, which clearly establishes both the existence of the unauthorized article and its
subsequent deletion.
The evidence suggests that when ED MAGEDSON learned of this YouTube video, he or
one of RIPOFF REPORT's agents restored the deleted page so that it would not result in an
error message displaying the phrase "The resource you are looking for has been removed,
had its name changed, or is temporarily unavailable," which is what was displayed after ED
MAGEDSON deleted the original article and had the original URL redirect to the new
unauthorized version.
This change of URL and redirection provision is evidenced by Glenn Puit's RIPOFF
70
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
REPORT complaint No. 828918, which still references the old URL with the following quote:
'To read my second story on this matter that delves into allegations of computer hacking,
please go to http://www.ripoffreport.com/business-consultants/google-cide-the-full/google-
cide-the-full-story-b3660.htm"
The aforementioned changes to Glenn Puit's initial RIPOFF REPORT effectively thrust
Michael Roberts into the role DARREN MEADE played in his and ADAM ZUCKERMAN's
organization's ongoing.criminal enterprise discussed earlier.
On May 7, 2013, one day after ED MAGEDSON and DARREN MEADE accessed and
viewed the link to Michael Roberts' YouTube screencast, which proved ED MAGEDSON or
another RIPOFF REPORT agent removed and republished an amended RIPOFF REPORT
complaint, ANNA RICHTER told TRACEY RICHTER that SCA Smith was attempting to
intimidate DARREN MEADE by going through ED MAGEDSON. TRACEY RICHTER told
ANNA RICHTER that DARREN MEADE needed to send "stuff."
On May 17, 2013, an e-mail containing a "non-indexed" link accessing a copy of DARREN
MEADE's February 28, 2011, e-mail to MATTHEW COOKE, in which DARREN MEADE
sought to enforce his purported right to acquire the exclusive rights to the highly illegal
hacking technology that he and ADAM ZUCKERMAN used to remove RIPOFF REPORT
complaints for profit. ED MAGEDSON accessed and viewed this e-mail and then forwarded
the same to DARREN MEADE who also accessed and viewed it. This e-mail
communication provided ED MAGEDSON unimpeachable evidence that in 2011 his I
RIPOFF REPORT employee and BFF, DARREN MEADE, tried to purchase the very
hacking technology DARREN MEADE told ED MAGEDSON and the FBI was used to hack
RIPOFF REPORT's servers and remove RIPOFF REPORT complaints.
On May 28, 2013, an e-mail containing a "non-indexed" link accessing a copy of a February
20, 2011, e-mail message from DARREN MEADE to convicted felon ADAM ZUCKERMAN
was sent to ED MAGEDSON, who accessed and viewed it and then forwarded the same to
DARREN MEADE, who also accessed and viewed it. In this e-mail, which DARREN
MEADE gave the subject heading, "Conspiracy Theory Gone Wild," DARREN MEADE
suggested he and ADAM ZUCKERMAN's organization begin publicly accusing Michael
Roberts of being criminally responsible for Dustin Wehde's murder (i.e., Michael Roberts
hired Dustin Wehde to murder TRACEY RICHTER, which resulted in TRACEY RICHTER
defending herself by shooting Dustin Wehde nine times and killing him) to "pressure" and
intimidate Michael Roberts into handing his business over to DARREN MEADE and ADAM
71
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
ZUCKERMAN. Towards the end of his e-mail to convicted felon ADAM ZUCKERMAN,
DARREN MEADE suggested that he and ADAM ZUCKERMAN get together to devise how
to "play this card" against Michael Roberts. DARREN MEADE sent this e-mail to ADAM
ZUCKERMAN around the same time DARREN MEADE, TRACEY RICHTER, ANNA
RICHTER, and RUSSELL SCHERTZ alleged DARREN MEADE provided Iowa law
enforcement with information implicating Michael Roberts in Dustin Wehde's murder. The
information contained in this e-mail, which computer forensics proved was viewed by ED
MAGEDSON, is contrary to that contained in almost all of ED MAGEDSON's, DARREN
MEADE's, and the anonymous authors' RIPOFF REPORT complaints about Michael
Roberts and the State's witnesses, and also contrary to DARREN MEADE's deposition,
which, as discussed above, ED MAGEDSON I RIPOFF REPORT and at least one of
RIPOFF REPORT's attorney were well aware of as early as January 2012.
On June 6, 2013, ANNA RICHTER told TRACEY RICHTER that DARREN MEADE wanted
TRACEY RICHTER to provide him with the location of sensitive, embarrassing information
concerning a family member of one of Michael Roberts' former employees. DARREN
MEADE subsequently posted this information on RIPOFF REPORT. ANNA RICHTER also
said DARREN MEADE had sent her (ANNA RICHTER) some information I documents, but
that she would discuss it with TRACEY RICHTER in person during their next prison visit.
ANNA RICHTER also told TRACEY RICHTER that in his Motion to Quash, SCA Smith was
"moaning" that "they" had given information I documents to DARREN MEADE. TRACEY
RICHTER said most of the information ANNA RICHTER had given to DARREN MEADE
was given to her (TRACEY RICHTER) during her murder prosecution. ANNA RICHTER
said most of the information DARREN MEADE obtained was from the internet, and
sometimes DARREN MEADE asked her for information about which she knew nothing.
On July 4, 2013, DARREN MEADE published a video titled "Michael Roberts Rexxfield
RIPOFF REPORT Google 60 Minutes Australia". Therein, DARREN MEADE asserted
Michael Roberts' custody battle was a hoax, that Michael Roberts orchestrated the "home
invasion," which resulted in Dustin Wehde's murder, and that Michael Roberts "confessed
the real motive" of the home invasion to DARREN MEADE once upon a time.
On June 13, 2013 (or June 6, 2013), ANNA RICHTER told TRACEY RICHTER that ED
MAGEDSON received a copy of SCA Smith's Motion to Quash, and that ED MAGEDSON
forwarded the same to DARREN MEADE. TRACEY RICHTER told ANNA RICHTER "they"
had proof SCA Smith obtained the transcripts from DARREN MEADE's aforementioned
deposition, and that SCA Smith cannot use the power of his office to do this. TRACEY
RICHTER continued, stating neither "they" nor DARREN MEADE had done anything
criminal, and SCA Smith was attacking DARREN MEADE for merely exercising his First
72
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Amendment rights. Amazingly, however, TRACEY RICHTER then said SCA Smith could
have an actionable civil defamation claim against ED MAGEDSON I RIPOFF REPORT and
I or DARREN MEADE, but neither of ED MAGEDSON I RIPOFF REPORT and I or
DARREN MEADE had done anything actionable in the criminal sense.
On June 29, 2013, DARREN MEADE sent the following e-mail to ANNA RICHTER:
Everyone, I have had enough of all the threats from Michael Roberts and Ben Smith. Every
three-four days I will be releasing video's showing the true character of Michael and
Benjamin. I hope the tone of the first video is not offensive to anyone. I plan to release one
on Ben by Monday morning. I never made a video presentation in my life therefore I know
the video maybe lacking a bit. Here is a link to the first video:
http://www. screencast. com/UAqlqBnF cl
On July 2, 2013, TRACEY RICHTER told ANNA RICHTER to give certain documents to
"you know who." ANNA RICHTER stated she already had given them to him. [The context
of this conversation suggests DARREN MEADE is the unnamed individual] ANNA
RICHTER then stated she located documents about Mona Wehde, the murder victim's
mother, and Dr. John Pitman, both of whom were State's witnesses. TRACEY RICHTER
directed ANNA RICHTER to give the information to this unnamed individual.
On July 11, 2013, after receiving the transcript of SCA Smith's testimony from her and
Michael Roberts' custody proceedings, which, much to their dismay, proved SCA Smith did
not commit perjury as TRACEY RICHTER, ANNA RICHTER, DARREN MEADE and ED
MAGEDSON I RIPOFF REPORT had been alleging on RIPOFF REPORT, TRACEY
RICHTER told ANNA RICHTER that the she still believed SCA Smith committed perjury.
ANNA RICHTER told TRACEY RICHTER that the court reporter who reported the
proceedings was "dirty."
On July 18, 2013, ANNA RICHTER played DARREN MEADE's July 4, 2013, video
presentation, which is mentioned above, over the phone for TRACEY RICHTER. After
listening to the video, TRACEY RICHTER commented that DARREN MEADE did not do a
bad job with the video presentation and that he would get better.
On July 25, 2013, TRACEY RICHTER asked ANNA RICHTER whether there was any new
information, documents, or material [on RIPOFF REPORT]. ANNA RICHTER stated there
was one thing online that was new, but that she wanted to wait and discuss it with TRACEY
RICHTER during their next visit at the prison because "they" might be listening to TRACEY
RICHTER's phone calls.
On July 27, 2013, TRACEY RICHTER told BERT PITMAN to create a YouTube channel for
ANNA RICHTER. TRACEY RICHTER said that YouTube shows up pretty high in internet
73
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
search results. BERT PITMAN told TRACEY RICHTER he wanted nothing to do with Dr.
John Pitman. TRACEY RICHTER told BERT PITMAN to "keep his eye on the prize."
On July 30, 2013, ANNA RICHTER told TRACEY RICHTER that she got a preview of
"another thing" that DARREN MEADE told ANNA RICHTER was going to published on the
internet. ANNA RICHTER said she wrote [DARREN MEADE] back and told him the
proposed video content was good. TRACEY RICHTER said some of the State's witnesses
lied when they testified against her. ANNA RICHTER said they need to go after the State's
witnesses because they lied on the witness stand. ANNA RICHTER said they were going to
prove State's witnesses Mary Higgins and Mona Wehde committed perjury when they
testified against TRACEY RICHTER. TRACEY RICHTER told ANNA RICHTER they
needed an affidavit from "the woman" who alleged Dr. John Pitman lied on the witness
stand.
On August 11, 2013 at 12:18 p.m. PST, DARREN MEADE left the following voicemail for
Daniel Danino (dba OC PC Services):
Hi Daniel, my name is Darren, I'm in Huntington Beach, I have a laptop that is not working
and I needed to get it fixed today, Sunday. Can you please let me know if you have anytime
today to work on a laptop. Again, I'm in Huntington Beach. My cellphone number is (949)
357-6193 again. That's (949) 357-6193. Thank you.
After this, DARREN MEADE paid OC PC Services $90.00 to for computer maintenance
services. DARREN MEADE gave Daniel Danino the address of 711 Pacific Coast Hwy,
Huntington Beach, California, to attend to the repairs. The repairs needed more work,
Daniel Danino took the laptop back to his office. DARREN MEADE did not pick up his
computer.
On August 22, 2013, ANNA RICHTER told TRACEY RICHTER she believed that Michael
Roberts lied on his immigration paperwork from 1996. TRACEY RICHTER asked ANNA
RICHTER whether she had sent this information to "somebody else." ANNA RICHTER
stated she was not sure, but that she would fax it over to "that person." TRACEY RICHTER
asked whether she sent that document to "that someone else." ANNA RICHTER stated
"they never checked on the alibi of you know who."
On August 28, 2013, Ripoffreport.com complaint No. 1079952 was published about Daniel
Isaac Danino (dba OC PC Services), and his mother Roberta Danino. Said complaint
accuses them of crimes, mental health issues, and other derogatory I criminal conduct.
Additional demeaning comments and photos of these victims were added to this RIPOFF
REPORT complaint on August 29, 2013, September 3, 2013, September 05, 2013, and
September 7, 2013
74
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
On August 29, 2013, Dr. John Pitman's office received a call from a male who identified
himself as Ryan. Ryan informed Dr. John Pitman's administrative assistant, Tina Allen, that
he worked for RIPOFF REPORT and, for $10,000, could remove all the derogatory
complaints on RIPOFF REPORT about Dr. John Pitman, including the RIPOFF REPORT
complaints DARREN MEADE has admitted to authoring and publishing on RIPOFF
REPORT. On May 19, 2014, RIPOFF REPORT I XCENTRIC VENTURES wrote a check to
a RYAN DUCA. Tina Allen memorialized the substance of this conversation in an affidavit
and provided the same to SCA Smith.
On September 4, 2013, ANNA RICHTER told TRACEY RICHTER that Dr. John Pitman
would rather spend money on a prostitute I stripper than care for [his son, BERT PITMAN]."
On September 4, 2013, another RIPOFF REPORT complaint about Daniel Danino and
Roberta Danino (dba OC PC Services) was published. This complaint alleged Daniel
Danino committed various crimes. The report was later augmented with additional
comments, photos of the victims, and criminal allegations on September 13, 2013,
September 21, 2013 and October 17, 2013.
Between September 5, 2013, and September 13, 2013, DARREN MEADE transmitted
hundreds of phone calls and text messages to Daniel Danino's mobile phone.
On September 5, 2013 (9:39 a.m.), SIAMACK YAGHOBI ([email protected])
pitched the following in a RIPOFF REPORT CAP I VP sales e-mail to a prospective
RIPOFF REPORT CAP customer (RIPOFF REPORT victim I subject), and copied in ED
MAGEDSON I RIPOFF REPORT ([email protected]) on the e-mail as well:
We see you have complaints on [www.pissedconsumer.com]. if, [sic] for some reason they
come before Ripoff Report on a search ... [sic] and the business (like yours) is a member of
one of our programs, at our request, they should be removing it at our request. Why? .. this
[sic] was part of an out of courrt [sic] settlement when Ripoff Report caught them stealing
thousands of Reports.
On September 5, 2013 (7:25 p.m.), ED MAGEDSON ([email protected]) sent the
following reply to SIAMACK YAGHOBI ([email protected]): "You need to
REMOVE the paragraph I have in Yellow [sic] highlight if there are no Reports on them on
[www.pissedconsumer.com]!!!"
RIPOFF REPORT sued Opinion Corp (dba Pissed Consumer I www.pisssedconsumer) on
October 7, 2008, In the United States District Court of Arizona (Case No. 2:08-CV-01841-
JAT). In its complaint, RIPOFF REPORT referred to Pissed Consumer as its direct
competitor). It appears that on or around December 8, 2008, the parties (RIPOFF REPORT
and Pissed Consumer) entered into a settlement agreement, which enjoined Pissed
Consumer from stealing or "scraping" and publishing RIPOFF REPORT complaints on
75
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Pissed Consumer's website (www.pissedconsumer.com) and dismissed RIPOFF
REPORT's complaint, which asked for hundreds of thousands of dollars in damages and
attorneys' fees, with prejudice.
Evidence obtained by law enforcement demonstrates that Pissed Consumer complaints
concerning RIPOFF REPORT employees and I or individuals who were I are not RIPOFF
REPORT CAP or VP members, were removed by Pissed Consumer (again, RIPOFF
REPORT's direct competitor) at ED MAGEDSON's I RIPOFF REPORT's direction,
assumedly pursuant to this settlement agreement.
On September 12, 2013, another RIPOFF REPORT complaint about Daniel Danino and
Roberta Danino (dba OC PC Services), was published. This complaint I article accuses
Daniel Danino, the company's owner, and his family of sex offenses, scams, lewd behavior,
robbery, and the rape of a female student. Subsequent to this RIPOFF REPORT complaint,
Daniel Danino demanded that DARREN MEADE remove the aforementioned
Ripoffreport.com complaints. DARREN MEADE responded by demanding a fee of
$7,000.00 for the removal of the Ripoffreport.com pages, and for compensation for
DARREN MEADE's laptop, which DARREN MEADE had never retrieved. Daniel Danino
agreed only to a refund DARREN MEADE's $90.00 and return the laptop, which he would
hold until DARREN MEADE deleted the aforementioned defamatory RIPOFF REPORT
complaints.
On September 17, 2013, SIAMACK YAGHOBI wrote the following in an email to a
prospective RIPOFF REPORT customer (victim), which he blind copied to ED MAGEDSON
I RIPOFF REPORT: "We work extremely closely with Google and occasionally our list of
links don't work because Google consistently changes their 'search links."' Minutes later, ED
MAGEDSON wrote the following to SIAMACK YAGHOBI in response:
We don't work closely with Google!!!! Don't ever say that!!!!!!. See, what that is, is, ...
GOOGLE CHANGES THEIR ALGORITHMS ALL THE TIME .. BUT, RIPOFF REPORT
STILL STAYS AT THE TOP OF THE SEARCH ENGINES. Never say we are in good with
Google. Search engines know us for over 16 years now- and consider us a good source of
information for consumers.
SIAMACK YAGHOBI wrote the following in response to ED MAGEDSON's admonishment:
"1 0-4 boss."
On September 25, 2013, RIPOFF REPORT filed a lawsuit against Michael Roberts and his
business entities. The case was filed in the Superior Court of Arizona, County of Maricopa
[Case No. CV2013-012936]. In its complaint, RIPOFF REPORT alleged Michael Roberts
had wrongfully I tortuously interfered with RIPOFF REPORT business' interests.
Specifically, RIPOFF REPORT alleged that the boycott of RIPOFF REPORT lead and
76
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
organized by Michael Roberts through Michael Roberts' websites authorizedstatement.org
and badforpeople.com, which efforts Michael Roberts has asserted were in response to the
defamatory attacks against himself and others. Later, on or around November 18, 2013,
following the hearing on RIPOFF REPORT's request to enjoin Michael Roberts' boycott, the
Court found that everything in AuthorizedStatement.org and BadForPeople.com was
protected speech" and denied RIPOFF REPORT's request for a preliminary injunction. Your
applicant was informed that RIPOFF REPORT introduced evidence in these proceedings
that demonstrated Michael Roberts' boycott negatively impacted RIPOFF REPORT's
advertising revenue.
On September 26, 2013, ANNA RICHTER told TRACEY RICHTER that ED MAGEDSON
filed a lawsuit against Michael Roberts. TRACEY RICHTER "stated she cannot imagine ED
MAGEDSON would be intimidated by Michael Roberts. ANNA RICHTER said Michael
Roberts had made ED MAGEDSON angry.
On September 30, 2013, ANNA RICHTER told TRACEY RICHTER she was waiting for
information and I or documents from DARREN MEADE, but that DARREN MEADE had
been busy the last couple days helping RIPOFF REPORT owner ED MAGEDSON prepare
for his civil action against Michael Roberts. ANNA RICHTER said ED MAGEDSON is going
after Michael Roberts for extortion, and is taking out a protective order against Michael
Roberts and SCA Smith because the two were harassing him (ED MAGEDSON). ANNA
RICHTER said she found a document TRACEY RICHTER had asked her to find while she
was searching for documents I information for ED MAGEDSON. TRACEY RICHTER said
she had something to tell ANNA RICHTER about ED MAGEDSON, and that ED
MAGEDSON had a bunch of stuff on Michael Roberts. ANNA RICHTER said she was
supposed to get information to ED MAGEDSON and DARREN MEADE about Michael
Roberts. ANNA RICHTER said DARREN MEADE told her he had to work on ED
MAGEDSON's case first, but when he finished with that, he would go back to working for
TRACEY RICHTER and ANNA RICHTER's cause. ANNA RICHTER said that when "WE"
put stuff on RIPOFF REPORT "WE" provide documentation.
On September 30, 2013, TRACEY RICHTER directed ANNA RICHTER to perform certain
tasks on TRACEY RICHTER's or ANNA RICHTER's computer in real-time. ANNA
RICHTER said ED MAGEDSON and I or DARREN MEADE wanted her to ask TRACEY
RICHTER whether she (TRACEY RICHTER) was familiar with an individual ANNA
RICHTER named. ANNA RICHTER and TRACEY RICHTER both stated that Mona Wehde,
the mother of the boy Tracey murdered, was once involved with Michael Roberts and drug
dealers from Sioux City, Iowa.
On October 1, 2013, DARREN MEADE published RIPOFF REPORT complaint No.
77
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
1088535, which contained defamatory statements about State's witness Michael Roberts
and his wife Dr. Heidi Roberts (aka Heidi Forsbacka). The title of DARREN MEADE's
RIPOFF REPORT complaint here is as follows:
AUTHORIZED STATEMENT, BAD FOR PEOPLE, MICHAEL ROBERTS REXXFIELD,
SCAM GROUP, RIPOFF SCAM TO ED MAGEDSON RIPOFF REPORT, SAC COUNTY
ATTORNEY BEN SMITH, 60 MINUTES AUSTRALIA, HEIDI ROBERTS, JANICE DUFFY
CHECK BOOK JOURNALISM, DIGITAL ASSASSINS, RIPOFF, CHECKBOOK
JOURNALISM, PROSECUTORIAL MISCONDUCT, NINEMSN FRAUD, GOLD COAST
On October 3, 2013, ANNA RICHTER told TRACEY RICHTER she (or they) had obtained
e-mail communications between Michael Roberts and his wife, Heidi Forsbacka. Michael
Roberts told law enforcement that no one other than he or his wife should have copies of
correspondence between him and his wife.
On October 10, 2013, ANNA RICHTER told TRACEY RICHTER that DARREN MEADE had
recently sent her information. TRACEY RICHTER told ANNA RICHTER "thank God
[DARREN MEADE] is involved." ANNA RICHTER relayed a question from DARREN
MEADE to TRACEY RICHTER about State's witness Mona Wehde.
On October 13, 2013, ANNA RICHTER told TRACEY RICHTER that ED MAGEDSON
asked ANNA RICHTER to tell TRACEY RICHTER to report the results of her custody I child
support proceeding with Michael Roberts, back to ANNA RICHTER, so that ANNA
RICHTER could relay the same to ED MAGEDSON. TRACEY RICHTER asked ANNA
RICHTER whether "there was anyone else who wanted her lawyer to ask a specific
question of Michael Roberts while he was under oath." ANNA RICHTER said she had
already discussed this possibility with TRACEY RICHTER's fiance, RUSSELL SCHERTZ.
On October 15, 2013, SIAMACK YAGHOBI ([email protected]) wrote the
following in an e-mail to his "boss," ED MAGEDSON I RIPOFF REPORT
([email protected]): "Would you consider creating a [email protected] email
address? Do u agree it to enhance professionalism, and [great] results on hearing back
from prospects?"
On October 17, 2013, ANNA RICHTER told TRACEY RICHTER she found out that Michael
Roberts had never been an FBI informant. TRACEY RICHTER asked whether they could
get tangible proof that Michael Roberts had never been an FBI informant. ANNA RICHTER
said the information was from a "very reliable source," and she would get more information
about this once "she [got] some other stuff back." Later, ANNA RICHTER said the
information came from an FBI SA. ANNA RICHTER said ED MAGEDSON wanted TRACEY
RICHTER to report the outcome of her custody hearing to ANNA RICHTER, so that ANNA
RICHTER could relay the same to ED MAGEDSON. ANNA RICHTER said ED
78
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
MAGEDSON had given her documents to give to TRACEY RICHTER, and that she would
be sending them to TRACEY RICHTER. TRACEY RICHTER said "someone" had been
trying to contact ANNA RICHTER, but that this "someone" must not have ANNA RICHTER's
correct e-mail address. TRACEY RICHTER said she would have her fiance, RUSSELL
SCHERTZ, check with this "someone" tomorrow to see if the "someone" had ANNA
RICHTER's correct contact information. TRACEY RICHTER said ANNA RICHTER knew
this "someone."
On October 18, 2013, TRACEY RICHTER told ANNA RICHTER to tell ED MAGEDSON
that Michael Roberts was served with that "thing" (ED MAGEDSON's I RIPOFF REPORT
lawsuit against Michael Roberts) when he appeared at the Buena Vista County Courthouse
for their hearing on the contempt I child support matters.
On October 19, 2013, ED MAGEDSON I RIPOFF REPORT issued SIAMACK YAGHOBI
the following e-mail address: [email protected]
On Sunday, October 20, 2013, 9:15 p.m. PST, SIAMACK YAGHOBI sent an e-mail from
[email protected] to ED MAGEDSON's e-mail addres [email protected],
with the subject heading "OC PC contact#" and message body that simply read: "Daniel
Danino 714-869-####" Approximately 10 minutes later, (9:26 p.m. PST), ED MAGEDSON
replied from [email protected]: "You would text this to me once you are maybe on
your way in that area- if you $aid, ED< I am about 1 or 2 hours away- check to see if he
will be there.. I will do that." ED MAGEDSON's above-reply proves he was an active
principal in this scheme to extort Danino. Ten minutes later, SIAMACK YAGHOBI
acknowledged Magedson's e-mail instructions with a simple e-mail reply: "Ok sounds good"
On October 21, 2013, at 1:19:15 p.m. PST, SIAMACK YAGHOBI initiated a call from cell
phone number (949) 600-0673 to Daniel Danino's mobile phone, which is (714) 869-1660.
According to Daniel Danino, the pretext for this call was that SAM YOUBANKS, needed to
give multiple laptops to Daniel Danino for repair. Daniel Danino did not know at the time
SIAMACK YAGHOBI was associated with DARREN MEADE. This same day, sometime
after 1:00 p.m. PST, SIAMACK YAGHOBI arrived at Daniel Danino's gated estate without
any computers for repair and identified himself to Daniel Danino as "SAM YOUBANKS."
SIAMACK YAGHOBI revealed that he was a business partner of DARREN MEADE and
was there to collect DARREN MEADE's laptop. Daniel Danino told SIAMACK YAGHOBI he
needed the three above-mentioned RIPOFF REPORT complaints I articles concerning
Danino's family and business removed. SIAMACK YAGHOBI then made a call to an
unknown person. After that, SIAMACK YAGHOBI told Daniel Danino that the three RIPOFF
REPORT complaints about Daniel Danino, his family, and business had been removed.
Daniel Danino checked RIPOFF REPORT for these three complaints, and after observing
79
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
they had in fact been removed, Daniel Danino gave SIAMACK YAGHOBI DARREN
MEADE's laptop computer.
On October 21, 2013 at 2:00:15 P.M. PST, SIAMACK YAGHOBI initiated a call from cell
phone number (949) 600-0673 to (714) 869-1660 which belongs to Daniel Danino, the call
lasted 29 seconds. On October 21, 2013 at 2:00:56 P.M. PST, SIAMACK YAGHOBI
initiated a call from cell phone number (949) 600-0673 to (602) 518-4357 which belongs to
ED MAGEDSON, the call lasted 24 seconds.
On October 21, 2013 at 2:04:57 P.M. PST, SIAMACK YAGHOBI initiated a call from cell
phone number (949) 600-0673 to 714-869-1660 which belongs to Daniel Danino, the call
lasted 28 seconds.
On October 21, 2013 at 2:04:57 P.M. PST, ED MAGEDSON initiated a call from his Leap
Wireless cell phone number (602) 518-4357 to SIAMACK YAGHOBI's Metro PCS cell
phone number, (949) 600-0673. This call lasted 4 minutes 45 seconds.
On October 21, 2013 at 2:28:29 P.M. PST, SIAMACK YAGHOBI initiated a call from his
Metro PCS cell phone number (949) 600-0673 to (602) 518-4357, which belongs to ED
MAGEDSON. This call lasted 39 seconds.
On October 21, 2013 at 2:36:50 P.M. PST, SIAMACK YAGHOBI initiated a call from his
Metro PCS cell phone number (949) 600-0673 to ED MAGEDSON's phone, (602) 518-
4357. This call lasted 1:57 minutes.
On October 21, 2013 at 3:02:15 P.M. PST, ED MAGEDSON initiated a call from his Leap
Wireless cell phone number 6025184357 to (949) 600-0673 which belongs to SIAMACK
YAGHOBI, the call lasted 6 minutes 38 seconds.
On October 21, 2013, RIPOFF REPORT deleted the three defamatory pages (complaints
Nos. 1079952, 1081741 and 1084023). The removal of these complaints were carried out,
presumably, at the direction of ED MAGEDSON in an attempt to coerce Daniel Danino into
complying with DARREN MEADE's extortion demands.
On October 21, 2013, there were seven calls and eight text messages between DARREN
MEADE's cell phone (949) 357-6193 and ED MAGEDSON's cell phone (602) 518-4357
Later, on Oct 21 2013, after SIAMACK YAGHOBI retrieved DARREN MEADE's computer
from Danino, and after SIAMACK YAGHOBI and ED MAGEDSON had exchanged phone
calls, the three aforementioned RIPOFF REPORT complaints concerning Daniel Danino
and his family were republished as follows: complaints No. 1084023 at 04:42 P.M. (UTC-
07:00), complaints No. 1081741 at 07:25 P.M. (UTC-07:00) and complaints No. 1079952 at
10:40 P.M. (UTC-07:00)
80
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
On October 24, 2013, ANNA RICHTER told TRACEY RICHTER she was not certain
whether anything came out during the contempt proceedings that would be helpful to ED
MAGEDSON. ANNA RICHTER said TRACEY RICHTER's custody I child support attorney
gave ANNA RICHTER permission for ED MAGEDSON to call the attorney on his mobile
phone. TRACEY RICHTER directed ANNA RICHTER to get certain information from ED
MAGEDSON about Michael Roberts.
On October 25, 2013, ED MAGEDSON ([email protected]) directed SIAMACK
YAGHOBI to make a "sales" call to (757) 232-5580, which is the phone number of Dr. John
Pitman's plastic surgery practice in Virginia.
On October 28, 2013, in response to SIAMACK YAGHOBI's request for ED MAGEDSON to
pay SIAMACK YAGHOBI's cell phone bill, ED MAGEDSON wrote him the following:
"[SIAMACK YAGHOBI], Just pay it - I will reimburse you with the $200 - this week. IF I
PAY [YOUR CELL PHONE BILL], IT THEN CONNECTS WITH MEl DON'T WANT
THAT!"
On October 31, 2013, ANNA RICHTER told TRACEY RICHTER she had scanned a
number of documents, which she planned to send to "someone." ANNA RICHTER told
TRACEY RICHTER she learned Dr. John Pitman was back with a stripper and that Dr. John
Pitman lied under oath when he testified in his deposition in TRACEY RICHTER's murder
case. ANNA RICHTER said she finally got contact information "on a certain person" form
"someone." ANNA RICHTER said she printed off documents concerning another case
involving ED MAGEDSON, and that ED MAGEDSON had to remove "something" from
RIPOFF REPORT, but that "something" did not have anything to do with TRACEY
RICHTER's case and I or DARREN MEADE's and the other RIPOFF REPORT complaint's
concerning the State's witnesses.
On November 3, 2013, SIAMACK YAGHOBI wrote the following in an e-mail to a Sarah (1
[email protected]), which he copied to DARREN MEADE: "Hi Sarah, So grateful we met
as well as being able to introduce you to [DARREN MEADE]. I'm looking forward to the
great fruitfulness to this relationship between all of us, especially in support of and for
justice for [TRACEY RICHTER]. Wishing you two a great weekend."
It is important to note that DARREN MEADE testified in his aforementioned deposition that
he and Adam Zuckerman hired I recruited freelance writers or bloggers from fiverr.com and
other places to "back-link" or "push" defamatory internet stories about Dr. Scott Connelly
onto different article directories, which would effectively turn one defamatory article I post
about Dr. Scott Connelly, into hundreds. DARREN MEADE also testified that he and Adam
Zuckerman hired a number of people to dig up and publish defamatory information about
Dr. Scott Connelly and another individual adverse to their criminal organization, with the
81
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
intent to "destroy [their businesses and reputations] and make it so [they] were unable to
have gainful employment." The information contained in this affidavit clearly demonstrates
that DARREN MEADE and ED MAGEDSON I RIPOFF REPORT are doing the same thing
to the State's witnesses that DARREN MEADE and his and Adam Zuckerman's criminal
organization did to Dr. Scott Connelly in 2010.
On or around November 5, 2013, pursuant to their ongoing divorce proceedings, Dr. John
Pitman was served with a request for production of documents by his estranged wife, Lisa
Pitman. Numbered paragraph twenty-one of the request asked Dr. John Pitman to produce
"each and every letter, e-mail communication, or any other written correspondence of any
nature between [Dr. John Pitman] and Michael Roberts from the date of [Dr. John Pitman's
marriage Lisa Pitman] to the current date, omitting nothing." Dr. John Pitman told SCA
Smith he did not have any such evidence to produce, and that neither he nor his attorney
could think of any reason why the information described in this interrogatory would be
relevant in any way to his and Lisa Pitman's divorce I custody proceedings.
The information contained in this affidavit demonstrates that TRACEY RICHTER and her
friends and family routinely hijack other people's civil discovery processes to fit her I their
own ends and needs. Question No. 21 from the request for production served on Dr. John
Pitman appears to be just another example of this. As discussed earlier, TRACEY
RICHTER had ANNA RICHTER asked ED MAGEDSON whether ED MAGEDSON had any
questions TRACEY RICHTER's custody I child support attorney should ask Michael
Roberts. At the time TRACEY RICHTER offered this to ED MAGEDSON, ED MAGEDSON
was suing Michael Roberts in Arizona. On February 8, 2014, during a prison visit, ANNA
RICHTER told TRACEY RICHTER that ED MAGEDSON had been after ANNA RICHTER
to do something, and that ED MAGEDSON (or his attorney) had e-mailed TRACEY
RICHTER's attorney to see if there was a way TRACEY RICHTER's attorney could obtain
Michael Roberts's mental health therapist's confidential notes I reports made during I
following Michael Roberts' therapy session from 2003 and 2004. TRACEY RICHTER told
ANNA RICHTER to have her custody I child support attorney to subpoena Michael Roberts'
confidential therapy notes and tell said attorney it is related to the custody stuff. ANNA
RICHTER told TRACEY RICHTER that getting Michael Roberts' confidential therapy notes I
reports to ED MAGEDSON would "really help [ED MAGEDSON] in his lawsuit against
Michael Roberts." Later, during a prison visit between TRACEY RICHTER and ANNA
RICHTER on February 28, 2014, ANNA RICHTER said ED MAGEDSON's attorney and
one of TRACEY RICHTER's PCR attorneys were communicating for the purpose of sharing
I obtaining information about Michael Roberts. Another example, as discussed above, on
March 9, 2014, TRACEY RICHTER directed ANNA RICHTER to give ED MAGEDSON a list
of the information ED MAGEDSON should request of Michael Roberts in their civil case in
82
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Arizona about Michael Roberts's wife, Heidi Forsbacka (aka Heidi Roberts). TRACEY
RICHTER told ANNA RICHTER that Michael Roberts might "back off' if ED MAGEDSON
requested certain information from Michael Roberts about his wife. In fact, Darren Meade's
2012 and 2013 bank records are chock-full of payments to www.fiverr.com.
On November 11, 2013, Dr. John Pitman's administrative assistant, Tina Allen, received a
call at Dr. John Pitman's medical practice from a male who identified himself as RIPOFF
REPORT employee "SAM YOUBANKS." Tina Allen said SAM YOUBANKS advised that [Dr.
John Pitman] could get the derogatory information published about him on RIPOFF
REPORT removed with an initial down payment and the remaining amount billed after it
was taken down. Tina Allen said SAM YOUBANKS advised there would also be a monthly
fee to continue to monitor RIPOFF REPORT for any new additional derogatory information
published on it concerning Dr. John Pitman. SAM YOUBANKS provided Tina Allen the
following contact information: e-mail: [email protected] and mobile phone No. (949)
600-0673 (Metro PCS), which is (disposable) sold I serviced by Metro PCS. As noted
earlier, ED MAGEDSON I RIPOFF REPORT issued the e-mail [email protected] to
SIAMACK Y AGHOBI.
On November 21, 2013, ANNA RICHTER told TRACEY RICHTER to remind her to tell
TRACEY RICHTER something the next time she visited the prison, because she did not
want to discuss it over the phone. ANNA RICHTER discussed giving information to ED
MAGEDSON and I or DARREN MEADE.
On November 30, 2013, an individual posing as Dr. John Pitman (with Dr. John Pitman's
knowledge and permission) using [email protected], sent SAM YOUBANKS the
following e-mail to the e-mail address SAM YOUBANKS provided Tina Allen,
[email protected]:
Sam; About 2 weeks ago you spoke with my office manager Tina Allen regarding a proposal
to remove the untruthful posts about myself and my former wife that have been placed on the
RIPOFF REPORT for quite some time. She was expecting to hear back from you by e-mail
regarding the specifics of your proposal and provided you her e-mail address but as of last
Weds she has not heard back from you. Would you please e-mail me the details of the
service or provide a convenient time and phone number to reach out to you directly. Your
response would be appreciated. Thank you JM Pitman, M.D.
On November 30, 2013, SAM YOUBANKS ([email protected]) replied to
[email protected]):
First and foremost, we do not and have not removed reports for our entire tenure of over 16
years in business ... and I have never stated such a 'proposal' what so ever ... what I told Tina
is that what we do within our Corporate Advocacy Program is much better and if the report
83
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
writer cannot provide legitimate proof of the written allegations then we will go about
exposing and redacting false statemenUs. First watch this quick video that goes into detail
about the services we offer within our program:
On December 1, 2013, [email protected]) responded to SAM YOU BANKS
([email protected]):
Thank you for your reply and clarification. I am going to discuss this with Tina when she
returns to the office this week. I could be mistaken but I am quite sure that she said that the
reports could be removed for a fee of $10,000.00 paid in 2 installments, one initial payment
and then final payment when the reports were removed. I will get back to you afterwards.
On December 1, 2013, SAM YOU BANKS ([email protected]) responded to
[email protected]) and copied in ED MAGEDSON ([email protected]):
Your welcome, Dr., I am glad to have cleared things up for you. There's nothing worse than
miscommunication errors in business, especially when fellow professionals misquote another
professional. I'm sure Tina is just been busy and/or juggling a lot of thoughts and that could
have been the premise to leading her to share such a ridiculous statement that would never
come from any of our companies' representatives and I'm sorry for the confusion. This is
truly the ultimate opportunity for you to repair and restore your reputation the right way, Dr.
and show consumers that you are a business they can trust because you have made a
commitment to customer satisfaction unto us. I hope you have taken the time to review the
information I sent to you and learn about the invaluable services we are offering members of
the Corporate Advocacy Business Remediation and Customer Satisfaction Program.
On December 5, 2013, [email protected]) e-mailed the following message to SAM
YOUBANKS ([email protected]):
I have reviewed the materials you sent to me and have asked Tina to follow up by filling out
the application so that this process can be completed as soon as possible. The slander
contained in these reports has had a significant negative financial impact on my practice and
I would be most appreciative if your process could be expedited. Tina has told me that she
has some questions regarding portions of the application and would like to speak with you to
resolve these items so that the application need not be corrected due to any errors or
omissions. She will be in the office tomorrow from 10 am-3 pm EST. Could you give her a
call at 757-229-5200 so that she can get the application completed and off to you before the
weekend.
On December 6, 2013, SAM YOUBANKS called Dr. John Pitman's medical practice and
spoke with Dr. John Pitman's administrative assistant, Tina Allen. The conversation was
recorded. SAM YOUBANKS told Tina Allen once Dr. John Pitman paid RIPOFF REPORT,
RIPOFF REPORT would give Dr. John Pitman the true identities of the individuals who
authored the anonymous defamatory RIPOFF REPORT complaints about him. Specifically,
84
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
SAM YOUBANKS told Tina Allen that once a RIPOFF REPORT victim pays RIPOFF
REPORT for its Corporate Advocacy Program's (CAP) services, RIPOFF REPORT sends
out a letter to the original author, and if the original author does not respond to the letter,
then RIPOFF REPORT gives the author's IP address to the victim. SAM YOUBANKS told
Tina Allen that his Metro PCS phone was a "separate phone solely dedicated to our
members."
On December 7, 2013, [email protected]) e-mailed SAM YOUBANKS
([email protected]) the following:
I have been reviewing the application Tina has prepared after your conversation yesterday
and I remain somewhat confused about the requirement for a monthly fee over a 3 year time
frame. Can you explain in more detail why this monthly charge is necessary if in fact your
methods are so effective in off setting the slander? I have been continuously receiving
unsolicited proposals from a variety of companies (see example below) claiming that they
can actually remove the negative reports from the RipOffReport.com. This company even
states that they will guarantee the result. Are you aware of these e-mail campaigns? How are
these companies getting my personal e-mail contacts? I am going to contact this company
on Monday and see if I can get "Hector'' to e-mail me a written proposal (stating the
guarantee). I will forward you any response that I receive back from him.
On December 7, 2013, SAM YOUBANKS responded to the above-e-mail from
[email protected]):
You need to first fill out the application. NOT every business is accepted to the CAP
program. Once you've filled that information out, I will be forwarding it to RIPOFF REPORT's
main office. Then you can pose those questions to RIPOFF REPORT. I am just an
independent sales person selling the CAP program part time while I go to school. Once
you've filled out the application, I will forward that to the main office.
On December 13, 2013, RIPOFF REPORT announced that it had offered a $25,000 reward
for information leading to the exoneration of TRACEY RICHTER.
On February 1, 2014, during a prison visit between TRACEY RICHTER and her fiance,
RUSSELL SCHERTZ, said "there is some other thing about BERT PITMAN [your mom,
ANNA RICHTER] didn't want to tell you over the phone." RUSSELL SCHERTZ said
"[JOHN RICHTER] thinks that [Lisa Pitman] put the stuff on RIPOFF REPORT." TRACEY
RICHTER replied, "Probably. Well, did she or was it [DARREN MEADE]? Because I asked
my mom (ANNA RICHTER) if it was [DARREN MEADE]. She (ANNA RICHTER) said, well,
[DARREN MEADE] said no, it (was or wasn't him). And she (ANNA RICHTER) said
DARREN MEADE admitted to other things to her before." RUSSELL SCHERTZ whispered
the name of the person he believed was responsible for the anonymous derogatory I
defamatory postings on RIPOFF REPORT about Dr. John Pitman, but, because he lowered
85
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
his voice, it is impossible to hear what he said. Then RUSSELL SCHERTZ added "we don't
know [for sure]" who published the RIPOFF REPORT complaints about Dr. John Pitman.
TRACEY RICHTER then told RUSSELL SCHERTZ "it will be interesting if it comes up in his
[divorce proceedings with Lisa Pitman] about him fooling around with hookers and call girls,
because that will be- we will be using that in my post-conviction relief." TRACEY RICHTER
added "BERT PITMAN informed them that "[Dr. John Pitman] is back together with [the
hooker I stripper], but [Dr. John Pitman's] neighbor - I want to say a neighbor told [BERT
PITMAN] or was it Courtney told them?" .RUSSELL SCHERTZ said "We need to get some
information from the secretary or the ... business manager before she leaves." TRACEY
RICHTER then said " Well, who knows. Maybe we can get information from [Lisa Pitman],
because [Lisa Pitman] and [Dr. John Pitman] were together [at the time TRACEY RICHTER
has alleged Dr. John Pitman saw pictures I photographs of pink spiral notebook], and if she
saw the photos and she knows he had the photos, maybe we can trade something with her
that she needs." RUSSELL SCHERTZ said they needed to get information from Dr. John
Pitman's secretary and from Lisa Pitman. RUSSELL SCHERTZ and TRACEY RICHTER
agreed they needed help and assistance from Lisa Pitman and Dr. John Pitman's secretary
to obtain sensitive I personal information about Dr. John Pitman. TRACEY RICHTER said
DARREN MEADE admitted to ANNA RICHTER that he had authored I published many of
the RIPOFF REPORT complaints about the State's witnesses, but had said he did not
author I publish the outrageous RIPOFF REPORT complaints about Dr. John Pitman.
TRACEY RICHTER told her mother that "maybe this stuff with Dr. John Pitman could
develop into something for our benefit [in the PCR context]." RUSSELL SCHERTZ told
TRACEY RICHTER he had stored a great deal of information (based on the information in
this affidavit, presumably about TRACEY RICHTER's case I State's witnesses) on his work
computer but he recently had it removed from that computer because his employer's
(ConAgra Foods, Omaha) IT department forced him to remove it. TRACEY RICHTER told
RUSSELL SCHERTZ she had a portable hard drive in a box that was in RUSSELL
SCHERTZ's possession he could use to store this information. TRACEY RICHTER told
RUSSELL SCHERTZ that "they" were going to go after the juror who had an ankle injury
before the trial and wanted off the jury, and that they are going to attack jury members.
RUSSELL SCHERTZ said that one of TRACEY RICHTER's new attorneys, Matthew
Shimanovsky, said SCA Smith is an idiot.
On February 2, 2014, ANNA RICHTER visited TRACEY RICHTER at the prison. TRACEY
RICHTER asked ANNA RICHTER to tell her more about Dr. John Pitman. TRACEY
RICHTER told ANNA RICHTER that Dr. John Pitman needed to come clean and tell the
truth. TRACEY RICHTER told ANNA RICHTER they already had [witnesses in TRACEY
RICHTER's case] come forward and said they were pressured to lie, so Dr. John Pitman did
86
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
not need to worry about getting in trouble (for committing perjury). TRACEY RICHTER told
ANNA RICHTER to tell BERT PITMAN the following:
[Dr. John Pitman] needs to come clean about everything. I'm not- there's things we do know
about, and unless he tells us things we don't know about, I don't trust him. Otherwise [Lisa
Pitman] is going to find out everything she needs to know about [Dr. John Pitman's former
girlfriend, Allisan Tucker], whore.
ANNA RICHTER said the following in reply:
And then [BERT PITMAN] should tell [Dr. John Pitman] you better come clean, because
everything will come out about the stuff we don't know, what they told you ... to say, then the
information that I got, I don't want to give to [Lisa Pitman].
TRACEY RICHTER then told ANNA RICHTER to have BERT PITMAN tell Dr. John Pitman
the following:
And we know you (Dr. John Pitman) were helping [your former girlfriend, Allisan Tucker]. We
have got receipts for you (Dr. John Pitman) paying for her dental. We know where here bank
accounts are in Florida. We know how you (Dr. John Pitman) were using your business and
paying for all her (AIIisan Tucker) stuff. Paying for her (AIIisan Tucker) airfare, paying for all
her video production and everything else. Talk to [BERT PITMAN] let [BERT PITMAN] know
that this could be our huge blessing. Because if [Dr. John Pitman] comes forward and admits
[law enforcement] pressured him to [lie about not having knowledge of key pieces of
evidence] ...
A while later, TRACEY RICHTER and ANNA RICHTER had the following discussion:
TRACEY RICHTER: Talk to [BERT PITMAN] because this could be a huge blessing in
disguise. That could be a Godsend, Mom (ANNA RICHTER). Sometimes God puts things
into play so that we have to seize the opportunity.
ANNA RICHTER: Yeah, but [BERT PITMAN cannot say] anything over the phone to you.
And make sure it's all done in person. [BERT PITMAN] can't [talk about this plan] over the
phone [because] they listen to your phone calls.
TRACEY RICHTER then directed ANNA RICHTER to have BERT PITMAN give Dr. John
Pitman TRACEY RICHTER's word that she "will not get involved" if he (Dr. John Pitman) did
the "right thing." ANNA RICHTER said that she would tell BERT PITMAN not to talk about
their plan over the phone with TRACEY RICHTER. TRACEY RICHTER added "[BERT
PITMAN can tell me over the phone what he knows about Dr. John Pitman] but not about
our plan."
Towards the end of their visit, TRACEY RICHTER said her fiance, RUSSELL SCHERTZ,
told her that "[Dr. John Pitman] thinks [Lisa Pitman] posted that stuff about [him on RIPOFF
REPORT]. ANNA RICHTER replied "That's what [BERT PITMAN] told me, that [Dr. John
87
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Pitman] asked [BERT PITMAN] if he thinks that [Lisa Pitman] had been posting all that stuff
on RIPOFF REPORT." TRACEY RICHTER said RUSSELL SCHERTZ told her that ANNA
RICHTER would tell TRACEY RICHTER more about this during their visit the following day.
Then TRACEY RICHTER asked ANNA RICHTER what BERT PITMAN told Dr. John
Pitman in response to Dr. John Pitman's question about whether BERT PITMAN knew who
was responsible for the RIPOFF REPORT complaints about him. ANNA RICHTER replied
"Oh, I don't know. [BERT PITMAN] didn't say. I'm sure he would have said no. Hopefully
[BERT PITMAN] has the smarts to say [he did not know who did it]." TRACEY RICHTER
then said the following:
You know what, [BERT PITMAN] could- he could tell [Dr. John Pitman], "you know what, we
could probably get proof from the people who own RIPOFF REPORT as to who posted it,
and you (Dr. John Pitman) will be able to use it in court, but that we are going to need your
cooperation on things.
ANNA RICHTER said she believed their "other plan," giving personal, sensitive information
about Dr. John Pitman to Lisa Pitman unless Dr. John Pitman "[cooperated]," was a better
plan.
DR. JOHN PITMAN'S DEPOSITION
As mentioned earlier, TRACEY RICHTER's first husband, Dr. John Pitman, was listed as a
State's witness in the State's Trial Information charging TRACEY RICHTER with the first
degree murder of Dustin Wehde, which was filed in Sac County District Court Case No.
FECR011900 on August 5, 2011.
On October 23, 2011, JOHN RICHTER sent the following Facebook message to BERT
PITMAN (his nephew): "once again your [sic] not answering, [sic] call me." Later that same
day, JOHN RICHTER sent the following Facebook message to BERT PITMAN: "call me!"
On October 24, 2011, the State provided defense counsel with a list of its witnesses in the
order in which it intended to call them throughout the week. Later that day, around 11:30
p.m., BERT PITMAN sent the following Facebook message to JOHN RICHTER: "took a
long time to down load all of them. I'm sending it to ur [sic] e-mail in the next hour."
On October 25, 2011, at 4:45a.m., JOHN RICHTER sent the following Facebook message
to BERT PITMAN: "I just checked my e-mail [and] they are not there yet,
[email protected]."
88
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
TRACEY RICHTER's murder trial started later that same morning (October 25, 2011 ). That
evening, at 8:14 p.m., BERT PITMAN sent the following Facebook message to JOHN
RICHTER: "I sent them to inkedtilldeath on accident. Sending them now." October 25, 2011,
BERT PITMAN e-mailed around fifty (50) images of documents that contained personal,
sensitive information about Dr. John Pitman and his then-girlfriend, aspiring musician
Allisan Tucker, whose stage name was I is Lachesis, to his uncle, JOHN RICHTER. Dr.
John Pitman recently told law enforcement the documents shown in these images had to
have been removed from Allisan Tucker's handbag without her permission when she was at
Dr. John Pitman's residence. The information contained in the documents shown in these
images BERT PITMAN sent to JOHN RICHTER is identical to the information TRACEY
RICHTER and ANNA RICHTER conspired to give to Dr. John Pitman's wife, Lisa Pitman, if
Dr. John Pitman did not "play ball."
On October 27, 2011, Dr. John Pitman took the witness stand and gave testimony against
TRACEY RICHTER. Midway through the State's direct examination of Dr. John Pitman,
TRACEY RICHTER's criminal defense attorneys made an evidentiary objection, which was
overruled. The Court, at the request of TRACEY RICHTER's defense attorneys, gave them
permission to depose Dr. John Pitman before he testified any further, adjourned for the day.
Around 7:00 p.m. that evening, TRACEY RICHTER's criminal defense attorneys deposed
Dr. John Pitman. During the deposition, which lasted only about forty-five (45) minutes,
TRACEY RICHTER's criminal defense attorneys questioned Dr. John Pitman about his
relationship with Allisan Tucker, his former girlfriend, and asked Dr. John Pitman on multiple
occasions throughout the deposition whether Allisan Tucker was a stripper or a prostitute.
TRACEY RICHTER's criminal defense attorneys then asked Dr. John Pitman for Allisan
Tucker's phone number so they could call her that evening to confirm whether or not she
was or had been a stripper I hooker. The next morning, Dr. John Pitman took the witness
stand, and finished testifying without ever being asked about Allisan Tucker or whether
Allisan Tucker was a stripper or a hooker. TRACEY RICHTER's criminal defense attorneys
never spoke with Allisan Tucker.
Information obtained by law enforcement suggests JOHN RICHTER communicated
extensively with TRACEY RICHTER's criminal defense attorneys before TRACEY
RICHTER's trial started. On August 20, 2011, ANNA RICHTER told TRACEY RICHTER
that JOHN RICHTER spoke with her criminal defense attorneys for three hours the day
before (August 19, 2011 ).
On February 3, 2014, TRACEY RICHTER directed BERT PITMAN to find out what was
89
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
going on with Dr. John Pitman and Lisa Pitman's divorce. BERT PITMAN told TRACEY
RICHTER that Dr. John Pitman asked him whether Lisa Pitman was responsible for the
derogatory postings about him on RIPOFF REPORT. BERT PITMAN told TRACEY
RICHTER that he did not tell Dr. John Pitman who was responsible for publishing the
complaints. Also during this conversation, TRACEY RICHTER told BERT PITMAN he
should have taken her computer.
On February 8, 2014, during a prison visit between TRACEY RICHTER and ANNA
RICHTER, TRACEY RICHTER and ANNA RICHTER mentioned, by full name, and
discussed the DOT employee who processed TRACEY RICHTER's change of name form in
2010, and who later told law enforcement that TRACEY RICHTER had presented the
forged court decree as proof her name had been legally changed. Then, ANNA RICH,TER
told TRACEY RICHTER that ED MAGEDSON wanted her (TRACEY RICHTER) to give him
certain information about Michael Roberts. ANNA RICHTER said ED MAGEDSON had
been after her (ANNA RICHTER) [to do or get something]. ANNA RICHTER also said ED
MAGEDSON e-mailed his (or TRACEY RICHTER's other attorney), Victoria Ames, about
something having to do with TRACEY RICHTER's case. ANNA RICHTER asked TRACEY
RICHTER whether TRACEY RICHTER's attorney could compel Michael Roberts's therapist
to produce the reports from Michael Roberts' therapy session. ANNA RICHTER or
TRACEY RICHTER stated that they would have to tell the doctor I therapist that the
report(s) are needed for TRACEY RICHTER's pending civil litigation with Michael Roberts
(child support contempt action) [when really they planned to give it to ED MAGEDSON I
RIPOFF REPORT for the purposes of publishing it in a RIPOFF REPORT complaint and I
or for RIPOFF REPORT to use in its pending litigation against Michael Roberts]. TRACEY
RICHTER said they would ask one of TRACEY RICHTER's attorney to subpoena the
confidential reports from Michael Roberts's therapist. ANNA RICHTER said getting this
report would really help ED MAGEDSON in his lawsuit against Michael Roberts. Later in
this conversation, TRACEY RICHTER told her mother to ask DARREN MEADE how to
make a website more visible on an internet search (e.g., Google, Bing, Yahoo!, etc.) results.
Attorney Victoria Ames is believed to be a faculty member at Arizona State University
College of Law. The school's website indicates that Victoria Ames was an attorney with
Jaburg and Wilk before joining the College of Law. Jaburg and Wilk represents Xcentric
Ventures (DBA RIPOFF REPORT) and ED MAGEDSON, the owner I operator of RIPOFF
REPORT. In January 2014, ED MAGEDSON I RIPOFF REPORT paid Victoria Ames
$1 ,025. The memo line of this check reads, "December invoice."
On February 16, 2014, during a prison visit between TRACEY RICHTER and DONNA
BISTRICAN, TRACEY RICHTER directed DONNA BISTRICAN to give BERT PITMAN
90
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
information about RIPOFF REPORT's $25,000 reward that it issued for information leading
to TRACEY RICHTER's exoneration, so BERT PITMAN could forward I publish the same
on www.traceyrichter.com and I or the Facebook page "Free TRACEY RICHTER." TRACEY
RICHTER also told DONNA BISTRICAN to use TRACEY RICHTER's credit card to
purchase I create a website. TRACEY RICHTER told DONNA BISTRICAN that both ANNA
RICHTER and Russ Schertz had copies of this credit card. Later during this conversation,
Donna Bistrican told TRACEY RICHTER that Donna Bistrican had seen something on Iowa
Courts Online that indicated Michael Roberts made a $20,000 payment towards an
outstanding accrued support balance owed to TRACEY RICHTER. Panicked, TRACEY
RICHTER directed Donna Bistrican to quickly contact RUSSELL SCHERTZ and ANNA
RICHTER and have them immediately take TRACEY RICHTER's credit I debit card (where
her child support payments were deposited) to her lawyer and dump all the money from the
card into the attorney's trust account as a retainer, so she could "try and lock it up before
[SCA Smith] [garnished it]" to pay TRACEY RICHTER's almost $300,000 in restitution she
owed Dustin Wehde's family and the State of Iowa.
On February 23, 2014, during a prison visit between TRACEY RICHTER and ANNA
RICHTER, the two again discussed having BERT PITMAN pressure his father, Dr. John
Pitman, into recanting I changing the testimony he gave in TRACEY RICHTER's murder
trial, by having BERT PITMAN tell Dr. John Pitman that "stuff is going to come out unless
you play ball." TRACEY RICHTER said if this information came out about Dr .. John
Pitman, he would lose custody of his children to Lisa Pitman and his business would
be ruined. TRACEY RICHTER said BERT PITMAN should approach Dr. John Pitman
under the false premise that "[they knew] Ben Smith told [Dr. John Pitman] not to talk to
Tracey's lawyers, [and we just want to know what else Ben Smith said to you]." One of the
two then said that BERT PITMAN should tell Dr. John Pitman that if Dr. John Pitman did not
"come clean" that it would really hurt their (BERT PITMAN and Dr. John Pitman)
relationship and that BERT PITMAN should tell Dr. John Pitman "Enough is enough, Daddy.
You need to come clean." ANNA RICHTER said it would be great if BERT PITMAN were to
record this conversation. ANNA RICHTER told TRACEY RICHTER she would contact
BERT PITMAN and discuss their plan with him. Later, TRACEY RICHTER asked whether
her PCR attorneys had scheduled the deposition of her criminal defense attorney(s). ANNA
RICHTER said DARREN MEADE wanted to attack TRACEY RICHTER's criminal defense
attorney(s) on RIPOFF REPORT, but ANNA RICHTER told DARREN MEADE "Don't you
dare. We need [him I her]." ANNA RICHTER said TRACEY RICHTER's PCR attorney was
a friend of one of TRACEY RICHTER's criminal defense attorneys and that this criminal
defense attorney confided with TRACEY RICHTER's PCR attorney that he I she made a
number of mistakes representing TRACEY RICHTER in her murder trial. ANNA RICHTER
91
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
added that ED MAGEDSON also directed DARREN MEADE not to publish anything on
RIPOFF REPORT about TRACEY RICHTER's criminal defense attorneys.
On February 28, 2014, during a prison visit between TRACEY RICHTER and ANNA
RICHTER, ANNA RICHTER said DARREN MEADE planned to publish complaints on
RIPOFF REPORT attacking the competence I effectiveness of TRACEY RICHTER's
criminal defense attorney(s), but that she instructed DARREN MEADE not to "bother
[TRACEY RICHTER's criminal defense attorney] right now because [in TRACEY
RICHTER's PCR case, TRACEY RICHTER's criminal defense attorney] is going to admit
that he was ineffective [in his representation of TRACEY RICHTER in her murder case I
trial]" and they "needed" him I her. TRACEY RICHTER said DARREN MEADE needed to
wait to publish a complaint on RIPOFF REPORT about her criminal defense attorney until
after the attorney testified in TRACEY RICHTER's Post Conviction Relief case, because
then DARREN MEADE can publish the transcript of the attorney's own under oath
admissions about the attorney's ineffective representation of TRACEY RICHTER.
It is important to note that the crux of TRACEY RICHTER's Post Conviction Relief Petition
filed in Sac County District Court Case No. PCCVO 19511 on April 16, 2014, is that her
criminal defense attorneys were ineffective in representing her. Obviously, such an
admission by TRACEY RICHTER's criminal defense attorney(s) would aid TRACEY
RICHTER in her PCR efforts. ANNA RICHTER told TRACEY RICHTER that complaints that
are published on RIPOFF REPORT are never taken down. Later, ANNA RICHTER told
TRACEY RICHTER she discussed the $25,000 reward RIPOFF REPORT I ED
MAGEDSON had offered for information leading to TRACEY RICHTER's exoneration;
specifically, ANNA RICHTER told ED MAGEDSON they needed to advertise the reward in
and around Sac County, Iowa.
Also during this prison visit, TRACEY RICHTER directed ANNA RICHTER to have BERT
PITMAN and DARREN MEADE to tell Brandon Wehde (murder victim's first cousin) about
the aforementioned $25,000 reward, and also give him (Brandon Wehde) certain derogatory
information concerning his aunt Mona Wehde's alleged acts of disloyalty to the Wehde
family. TRACEY RICHTER said that someone needed to tell Brandon Wehde "you need to
know the truth about what [Mona Wehde] had been up to." TRACEY RICHTER said
Brandon Wehde should be given a copy of Brett Wehde's (Mona Wehde's husband, Dustin
Wehde's father) suicide note, and he should be told that Mona Wehde (allegedly) planned
to leave her family. ANNA RICHTER said DARREN MEADE already had published Dustin
Wehde's father's suicide note on RIPOFF REPORT. TRACEY RICHTER directed ANNA
RICHTER to also have DONNA BISTRICAN contact Brandon Wehde using her Facebook
account. ANNA RICHTER said she was going to contact BERT PITMAN to discuss the
92
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
foregoing. TRACEY RICHTER told ANNA RICHTER to work with DARREN MEADE to
create a highly visible website with content that would expose Michael Roberts to hatred,
ridicule, and contempt. TRACEY RICHTER and ANNA RICHTER again went over their plan
to have BERT PITMAN pressure Dr. John Pitman into changing his testimony. ANNA
RICHTER told TRACEY RICHTER she exchanged documents with DARREN MEADE, and
that she stores the same in her Dropbox account. TRACEY RICHTER directed ANNA
RICHTER to send documents to "Marko" via Dropbox. ANNA RICHTER said she talked to
ED MAGEDSON, and ED MAGEDSON had talked to attorney Victoria Ames. ANNA
RICHTER said ED MAGEDSON told her that her attorney Matthew Shimanovsky is
supposed to contact Victoria Ames about getting Michael Roberts' confidential therapy
reports I notes from Dr. Rumberger. TRACEY RICHTER told ANNA RICHTER that her PCR
attorneys needed to talk to one of the jurors who convicted her, as well as all the other
jurors, but that they needed to start with this particular juror, because he I she was the
WEAKEST one Ouror). ANNA RICHTER said Julia Ofenbakh said she (Julia Ofenbakh)
would like to see SCA Smith in jail. ANNA RICHTER said Julia Ofenbakh also said "that just
listening to things that [SCA Smith] has done, he (SCA Smith) should be in jail." TRACEY
RICHTER told ANNA RICHTER that someone should register the website
www.BenSmithSucks.com. TRACEY RICHTER asked whether DARREN MEADE had
anything up on RIPOFF REPORT about Mary Higgins and Anna said that Darren is
concentrating on Ben Smith. ANNA RICHTER said she wanted to completely destroy SCA
Smith. ANNA RICHTER said she told this to TRACEY RICHTER's new. attorney Julia
Ofenbakh. ANNA RICHTER said that TRACEY RICHTER's new attorney Julia Ofenbakh
said the jurors in TRACEY RICHTER's criminal case were idiots. ANNA RICHTER said "I
will be damned if my daughter is going to sit here eighteen years before they declare her
innocent." ANNA RICHTER said they need to get this fund going because this is going to
cost money.
On March 2, 2014, during a prison visit between ANNA RICHTER and TRACEY RICHTER,
ANNA RICHTER said she had. recently talked to ED MAGEDSON. TRACEY RICHTER
directed ANNA RICHTER to send and I or receive digital copies (of something inaudible).
TRACEY RICHTER said something about people giving money to TRACEY RICHTER via
PayPal and that "[little bits of money add] up." The context of this conversation suggests
that ED MAGEDSON had or was creating this PayPal account. ANNA RICHTER said she
recently spoke with BERT PITMAN. TRACEY RICHTER said there had to be "something
somewhere" about Dr. John Pitman. ANNA RICHTER said something to TRACEY
RICHTER about having BERT PITMAN talk to Dr. John Pitman. ANNA RICHTER further
stated she just wanted "them to be truthful." TRACEY RICHTER told ANNA RICHTER to
(do something) with any information on State's witness Michael Roberts' wife, Dr. Heidi
93
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Forsbacka, that ANNA RICHTER obtained. ANNA RICHTER told TRACEY RICHTER that
Dr. Heidi Forsbacka hung up the phone when ANNA RICHTER tried to call her (Heidi
Forsbacka). TRACEY RICHTER told ANNA RICHTER to have someone create the website
www.MichaeiRoberts.Biogger.com.eu and publish defamatory I derogatory content on it
about State's witness Michael Roberts "so nobody will ever want to do business with
him again."
On March 7, 2014, during a prison visit between ANNA RICHTER and TRACEY RICHTER,
TRACEY RICHTER told ANNA RICHTER to have BERT PITMAN take photographs of Dr.
John Pitman's prescriptions, although the recording was difficult to hear at this point. Later,
although still barely audible, it is believed the two discussed getting sensitive I embarrassing
information about Dr. John Pitman for the purpose of blackmailing I extorting him into
recanting I changing his testimony. ANNA RICHTER and TRACEY RICHTER discussed Dr.
John Pitman's personal finances. TRACEY RICHTER said something about ED
MAGEDSON and DARREN MEADE, and that "how someone found where he was living."
TRACEY RICHTER told ANNA RICHTER to create the website "JeremyCollins.com."
Jeremy Collins is another State's witness. TRACEY RICHTER said Jeremy Collins might
"freak out" after the website about him goes up and just want the stuff online about
him to go away and "that's all [we] would need" [for TRACEY RICHTER to be granted
a new trial through the PCR action]. TRACEY RICHTER told her mother that after
www.JeremyCollins.com goes up that someone would need to approach Jeremy Collins.
TRACEY RICHTER is heard telling ANNA RICHTER "they" needed to put something online
about "another" one of the State's witnesses. TRACEY RICHTER and ANNA RICHTER
then discussed putting up a website with information about Michael Roberts that would
make "no women with half a brain want to get involved with him (ANNA RICHTER and
TRACEY RICHTER believed Michael Roberts and his wife, Heidi Forsbacka (aka Heidi
Roberts) were separated I divorced). TRACEY RICHTER added the following:
Well then if [Michael Roberts] wants that [derogatory website about him taken] down ... you
know what the cost of taking down that website on Michael Roberts is? I want all the
dirt on [SCA Smith] and what he did and I want the kids returned to you (ANNA
RICHTER). And then he can have that website taken down and he can do whatever he
wants. He can run off and live where he wants. He can have whatever job -- he can scam
whoever he wants in Australia. I don't care. Just go away --go away and live in Australia.
ANNA RICHTER said Michael Roberts would not be able to get the derogatory information
removed from RIPOFf REPORT because RIPOFF REPORT does not remove its
complaints. ANNA RICHTER said she had to go home and scan certain documents into her
computer, which the two had previously discussed, and to give them to DARREN MEADE.
ANNA RICHTER listed off the derogatory information about Michael Roberts she planned to
94
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
publish on the internet.
On March 8, 2014, during a prison visit between TRACEY RICHTER and her mother, ANNA
RICHTER, the two discussed creating a website about Heidi Forsbacka, wife of State's
witness Michael Roberts.
It is important to note that TRACEY RICHTER has created similar websites in past to
defame and harass those adverse to her in litigation or just adverse to her in general.
TRACEY RICHTER's GoDaddy.com account records show that during her divorce I custody
proceedings with Michael Roberts, TRACEY RICHTER created the website
RyanKolpinSucks.com (Michael Roberts' custody I divorce attorney at one point during their
divorce I custody proceedings}, MichaeiRobertsSucks.com (obvious reference to Michael
Roberts), Mile2Sucks.com (a reference to Michael Roberts' business}, and
HeidiForsbackaSucks.org (Michael Roberts' wife). TRACEY RICHTER later purchased the
rights to and I or created the website RichdaleGroupSucks.com (name of her apartment
complex owners I management, which did not hire Sophie Edwards for a management
position (despite having TRACEY RICHTER as a reference).
On March 9, 2014, during a prison visit between ANNA RICHTER told TRACEY RICHTER,
ANNA RICHTER said something to TRACEY RICHTER about something ED MAGEDSON
and I or DARREN MEADE had recently said. ANNA RICHTER said ED MAGEDSON gave
her transcripts of the testimony Michael Roberts' gave in a deposition in Michael Roberts
and ED MAGEDSON's civil case in Arizona. ANNA RICHTER stated she received other
items from DARREN MEADE about Michael Roberts. ANNA RICHTER stated she e-mailed
ED MAGEDSON and talked to DARREN MEADE about proving the location of IP
addresses belonging to Michael Roberts (assumedly, the IP addresses from which Michael
Roberts posted comments on RIPOFF REPORT). Towards the end of the visit, TRACEY
RICHTER said something to ANNA RICHTER about destroying Michael Roberts socially
and professionally. Later, the two discussed finding another way to reach Michael Roberts'
wife, Dr. Heidi Forsbacka, and publishing defamatory I derogatory information about her on
the internet. TRACEY RICHTER directed ANNA RICHTER to give ED MAGEDSON a list of
the information ED MAGEDSON should request of Michael Roberts through the civil
discovery process to get information about Michael Roberts's wife, Heidi Forsbacka (aka
Heidi Roberts) (Michael Roberts and ED MAGEDSON were I are currently engaged in civil
litigation). TRACEY RICHTER told ANNA RICHTER that Michael Roberts might "back off' if
ED MAGEDSON requested certain information from I about Michael Roberts's wife. ANNA
RICHTER stated that State's witnesses committed perjury when they testified against
TRACEY RICHTER.
On March 14, 2014, during a prison visit between ANNA RICHTER and TRACEY
95
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
RICHTER, ANNA RICHTER said BERT PITMAN told her Dr. John Pitman denied being
responsible for a derogatory news article about TRACEY RICHTER.
On March 15, 2014, ANNA RICHTER told TRACEY RICHTER she e-mailed ED
MAGEDSON the other day about something having to do with Michael Roberts. ANNA
RICHTER said something about ED MAGEDSON emailing DARREN MEADE about
something having to do with Michael Roberts.
On March 16, 2014, ANNA RICHTER mentioned something having to do with ED
MAGEDSON. ANNA RICHTER told TRACEY RICHTER how certain online articles I
websites "get moved to the top [of an internet search result]." ANNA RICHTER stated she
had to give something to DARREN MEADE.
On March 20, 2014, BERT PITMAN sent the following e-mail message to ANNA RICHTER
and JOHN RICHTER:
This is my letter to [his father, Dr. John Pitman]. I will be sending you another e-mail in the
next day or two with my detailed conversation I will have with [Dr. John Pitman] if he agrees
to meet with a psychologist. Send me any changes you might have on this letter, but the next
one will definitely need more input from everyone. Since it will detail prior occurrences and
what will need to be done by him to make things right Thank you for your time Lil' Bert
Richter
The following is BERT PITMAN's (aka Bert Richter) aforementioned letter to his father, Dr.
John Pitman:
Dear John Pitman Ill, I appreciate you reaching out and trying to speak with me, but
unfortunately, the divide between us is too great to just have a casual conversation. Even
though I would love to have a father to talk to about sports and such, I cannot do so because
you have failed to be one for the vast majority of my life. The times you should have given,
you took. The times you should have helped me grow, you did set a good example. The
times when you could have been a man, you were deceitful and showed poor character.
Your actions have cause me an immense amount of pain, however, I have made it through it
all and have come out the other side as a strong and enlightened man. As a man, it is on me
to clearly state what you need to do to make amends. If and when, you fulfill my requests,
then we can be on speaking terms and start to repair our relationship. I would like to meet
with you with Dr. Coe (we can split the costs), so we can discuss the reasons for our tattered
relationship and what needs to be done to fix it. Until then, communication between you and I
will be solely professional, monetary, or concerning the scheduling of this meeting. BERT
PITMAN
On March 21, 2014, during a prison visit between ANNA RICHTER and TRACEY
RICHTER, ANNA RICHTER said BERT PITMAN planned to write Dr. John Pitman two
letters. The first letter BERT PITMAN planned to write to Dr. John Pitman would be short
96
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
and to the point, and the second one would tell Dr. John Pitman that if he is to have a
relationship with him (BERT PITMAN) "there are things that have to be done." ANNA
RICHTER said BERT PITMAN planned to tell Dr. John Pitman that he had to make right
what he had done to TRACEY RICHTER, be accountable, and come forward with the truth.
TRACEY RICHTER said Dr. John Pitman needed to "step up." ANNA RICHTER said BERT
PITMAN told her Dr. John Pitman was going to come forward with the truth. Then, TRACEY
RICHTER and ANNA RICHTER begin to whisper, but you can hear TRACEY RICHTER say
BERT PITMAN needed to get Dr. John Pitman to say that law enforcement and Michael
Roberts told Dr. John Pitman what to say. TRACEY RICHTER then said Dr. John Pitman
needed to swear out an affidavit that TRACEY RICHTER never tried to kill Dr. John Pitman.
TRACEY RICHTER directed ANNA RICHTER to have BERT PITMAN find out whether
Michael Roberts tried to intimidate Dr. John Pitman. Later in this visit, ANNA RICHTER told
TRACEY RICHTER that BERT PITMAN stated he was going to make Dr. John Pitman
come forward with the truth and correct this mistakes.
Dr. John Pitman recently told law enforcement that BERT PITMAN hand delivered Dr. John
Pitman with a copy of his aforementioned letter on or around April 7, 2014, and that they
discussed going to therapy I counseling, but never did. Dr. John Pitman also said BERT
PITMAN had never asked Dr. John Pitman to retract or change his testimony or to swear
out an affidavit.
Dr. John Pitman stated his medical practice has lost an estimated $600,000 since these
defamatory I derogatory articles about him first appeared on RIPOFF REPORT. Similarly,
State's witness Raymond Friedman and Michael Roberts also informed SCA Smith that
their respective businesses had suffered greatly as a result of DARREN MEADE's RIPOFF
REPORT complaints I articles.
In late April 2014 I early May 2014, DARREN MEADE and ED MAGEDSON had a falling-
out. Apparently, DARREN MEADE quit working, ED MAGEDSON stopped paying DARREN
MEADE because DARREN MEADE quit working, and DARREN MEADE believed he
should be paid for doing nothing. When ED MAGEDSON refused to pay DARREN MEADE,
DARREN MEADE threatened ED MAGEDSON I RIPOFF REPORT that if ED MAGEDSON
I RIPOFF REPORT did not pay DARREN MEADE money and fulfill other demands,
DARREN MEADE would expose RIPOFF REPORT to civil, maybe even criminal liability.
On May 15, 2014, DARREN MEADE ([email protected]) wrote the following e-
mail to ED MAGEDSON ([email protected]): "I can document with log files, screen
recordings and search histories the thousands of hours I spent researching to help ED
MAGEDSON and TRACEY RICHTER."
In another May 15 e-mail between DARREN MEADE, ED MAGEDSON, SIAMACK
97
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
YAGHOBI, ANNA RICHTER ([email protected]), and
([email protected]) [Adam Kunz General Counsel for XCENTRIC VENTURES, LLC],
DARREN MEADE alleged that ED MAGEDSON directed and demanded DARREN MEADE
to make changes to a video and that DARREN MEADE took down the "posts". DARREN
MEADE further stated in this e-mail that he had no animosity towards Michael Roberts and
that he worked at ED MAGEDSON's direction. DARREN MEADE also told ED MAGEDSON
the following:
"ANNA RICHTER, TRACEY RICHTER's mother, called and begged me to come testify at
the murder trial. I could not walk at the time, and was threatened with arrest if I set foot in
Iowa. When TRACEY RICHTER was convicted I felt responsible, I allowed myself to be
intimidated and ignored Anna's pleas for help ... that is why [sic] drove me ... not hatred."
DARREN MEADE's above-assertions, by his own prior admissions and all available
evidence I information, are patently false. In fact, DARREN MEADE did not even know
ANNA RICHTER until after TRACEY RICHTER had been convicted of murder.
In a May 16, 2014, e-mail, ED MAGEDSON sent the following e-mail to MEADE:
I am sick about what you seem to be trying to claim! We have never had a contract for you
to work for my company. We specifically documented that we would have no contracts
unless in writing. You are certainly not an employee of me or my company. I have been your
friend. WE HAVE HAD A MUTUAL CAUSE, TO FREE TRACY RICHTER, AND TO
EXPOSE MICHAEL ROBERTS TO THE WORLD FOR HIS HYPOCRITICAL AND
DISHONEST DEALINGS. I have supported your living expenses to allow you to continue
with YOUR work towards those goals. I certainly never had a direction or control over the
work. In fact, many of the things that you stated you would do have never happened. And,
now you are telling me that you lost your research. What a disappointment. What a
blunder. Darren, some of the things you write about make it seem like you feel entitled to get
certain things at my expense, like rent and a car and food. I don't help you with those things
because I am obligated. I [GAVE YOU MONEY] BECAUSE I WANTED TO HELP YOU, MY
FRIEND, AND I WANTED TO SUPPORT YOUR CRUSADE TO SEE JUSTICE IN THE
TRACY RICHTER CASE.
In another May 16, 2014, e-mail from ED MAGEDSON to DARREN MEADE, ED
MAGEDSON admitted paying DARREN MEADE to help I do work associated with TRACEY
RICHTER at ED MAGEDSON's direction.
On May 17, 2014, MEADE sent the following e-mail to ANNA RICHTER, ED MAGEDSON,
and SIAMACK YAGHOBI:
Anna, the video's I made on behalf of Tracey and exposing Michael Roberts and Ben Smith
have were disabled for some reason on RIPOFF REPORT. I was hopeful my issues with Ed
would not affect my advocacy work on Tracey's behalf, but ever video I had made has been
98
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
disabled. The majority of the video's I had also placed onto a website I made for Tracey
located at http://traceyrichter.com had many of the same video's which I published on
RIPOFF REPORT. Those video's are operational, I pay for that site every 3 months ( $39.95
) and will send you the billing information so you can continue the website. It would seem
that my ability to post video's on Tracey's behalf no longer exists on RIPOFF REPORT. I will
post a new video on http://traceyrichter.com it will not have the viewership of RIPOFF
REPORT, but given my video's were disabled I believe this is the best course of action. I've
copied Ed and Michael's friend [SIAMACK YAGHOBI] on this e-mail for transparency. I
wanted to alert you to what had taken place on RIPOFF REPORT and assure you it was
nothing that I participated in, and again, the website I control still has the video's active ::
perhaps, I am wrong and there is another reason the video's are disabled on RIPOFF
REPORT but active on other websites?
In a May 17, 2014, e-mail from ED MAGEDSON ([email protected]) to DARREN
MEADE ([email protected]), ED MAGEDSON said the following: "Anyone that
knows you knows you've had an obsession to go after [Michael Roberts] for your own, and
[TRACEY RICHTER] just got some of the benefits." Later on in the above-e-mail (or another
one sent on this same date) ED MAGEDSON admitted he paid DARREN MEADE to work
on matters involving TRACEY RICHTER and RIPOFF REPORT.
Just some of RIPOFF REPORT's bank records show that between December 2011 and
May 2014, RIPOFF REPORT paid DARREN MEADE approximately $90,000 from its Bank
of America account. ED MAGEDSON has also discussed paying DARREN MEADE from
other sources, such as prepaid credit cards. Most telling in all this, however, is ED
MAGEDSON paid DARREN MEADE $3,000.00 just days after DARREN MEADE began
extorting RIPOFF REPORT I ED MAGEDSON. As indicated above, throughout May 2014,
DARREN MEADE told ED MAGEDSON I RIPOFF REPORT he was prepared to make
public the fact that he worked at ED MAGEDSON's direction in their joint efforts to "help"
TRACEY RICHTER and published RIPOFF REPORT complaints about the State's
witnesses. Rather than alert the authorities to DARREN MEADE's extortionist efforts, ED
MAGEDSON I RIPOFF REPORT instead asked DARREN MEADE for a list of his demands,
which DARREN MEADE provided, and ED MAGEDSON I RIPOFF REPORT at least
partially met.
On May 28, 2014, DARREN MEADE contacted a plaintiff adverse to RIPOFF REPORT in
pending civil litigation. DARREN MEADE informed the plaintiff he (DARREN MEADE) had
worked for XCENTRIC VENTURES from January 2012 to May 2014, and that he was now
adverse to ED MAGEDSON I RIPOFF REPORT, and he was willing provide evidence to
this plaintiff on certain conditions.
On June 19, 2014, DARREN MEADE published the following "Tweet" on his Twitter
99
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
account: "Attention: Alleged RIPOFF REPORT Victims! Please know I am available for
depositions June 23-2ih in Laguna Beach, CA" @darrenmeade (DARREN MEADE's
Twitter account "handle").
On June 25, 2014, at 4:22 pm CST, one of ED MAGEDSON's I RIPOFF REPORT's
attorneys was sent an e-mail, which asked whether said attorney planned to attend
DARREN MEADE's depositions (as advertised on DARREN MEADE's Twitter account) and
provided a link to DARREN MEADE's above-Tweet. Interestingly, also on June 25 and on
26, 2014, ED MAGEDSON I RIPOFF REPORT allowed DARREN MEADE to publish add-
on complaints I comments to existing RIPOFF REPORT complaints Nos. 970019 and
938843, which condemned SCA Smith for garnishing TRACEY RICHTER's prison funds. It
is not know at this time whether DARREN MEADE published these comments before or
after ED MAGEDSON's I RIPOFF REPORT's attorney was sent the e-mail described
above.
. ...................... -................ .
CONCLUSION
Based on my training and experience, and the facts as set forth in this affidavit, there is
probable cause to believe TRACEY RICHTER (aka SOPHIE EDWARDS), DONNA
BISTRICAN, ANNA RICHTER, DARREN MEADE, BERT PITMAN (aka BERT RICHTER),
ED MAGEDSON, SIAMACK YAGHOBI (aka SAM YOUBANKS) and XCENTRIC
VENTURES I RIPOFF REPORT have committed the crimes set forth below, either directly,
or by aiding and abetting another in and with the same crimes, and the property and
information described in Attachments A and B to this Search Warrant is property I
information used or possessed with the intent to be used as the means of committing a
public offense or concealed to prevent an offense from being discovered and I or is property
relevant to the crimes discussed below and material as evidence in a criminal prosecution
for the same or any related offenses.
WITNESS TAMPERING
"A person who, in retaliation for anything lawfully done by any witness ... in any case,
harasses such witness, or conspires to do the same ... commits an aggravated
misdemeanor. IowA CODE 720.4, 706.1 (2013). In Iowa, an aggravated misdemeanor is
an indictable offense. Iowa Const. Art. 1 11; IowA CODE 903.1 (2) (2013); Iowa Rule of
100
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Criminal Procedure 2.4(2) (2013) Here, the harassment was done by communicating with a
State's witness in a criminal matter filed in the Sac County District Court, by electronic
communication, without legitimate purpose, in a manner likely to cause the witness
annoyance or harm and with the specific intent to intimidate, annoy or alarm the witness
and, with the intent to produce detrimental effects within Iowa, and the subject's actions did
produce detrimental effects within Iowa. Witness Tampering in Iowa is an indictable offense.
IOWA CODE 708.7(1) (2013); IOWA CODE 720.4 (2013); I.A. Const. art. I, 11; IOWA CODE
903.1 (2) (2013); Iowa R. Crim. P. 2.4(2); IOWA CODE 803.1 (2013)
Based on the evidence I information contained in this application, there is probable cause to
believe that beginning in 2012, TRACEY RICHTER, DARREN MEADE, ED MAGEDSON,
ANNA RICHTER, RUSSELL SCHERTZ, DONNA BISTRICAN, and I or BERT PITMAN
have been engaged in a systematic and ongoing campaign of cyber I internet harassment
and defamation aimed directly at the State's witnesses, in retaliation for their cooperation
with law enforcement and testimony against TRACEY RICHTER in State v. Richter, Sac
County District Court Case No. FECR011900.
The available evidence strongly suggests DARREN MEADE, ANNA RICHTER, TRACEY
RICHTER, ED MAGEDSON I RIPOFF REPORT, BERT PITMAN, RUSSELL SCHERTZ,
knew most of the demeaning, derogatory content they published about the State's
witnesses on the RIPOFF REPORT and other sites was I is per se defamatory.
The available evidence shows that in January 2012, ED MAGEDSON I RIPOFF REPORT
and at least one of ED MAGEDSON's I RIPOFF REPORT's attorneys was aware of
DARREN MEADE's aforementioned deposition wherein DARREN MEADE, among many
other damning admissions, testified to the following: that DARREN MEADE was hired by
convicted felons to defame a witness for the purpose of harassing and intimidating the
witness into settling his civil case with these convicted felons (i.e., that DARREN MEADE
was once a "liar for hire"); that Michael Roberts' was ADAM ZUCKERMAN's victim, not his
partner, the latter of which DARREN MEADE alleged in seventy-five (75%) or more of all his
RIPOFF REPORT complaints he published about the State's witnesses; that DARREN
MEADE, when he was working for and with these convicted felons, had actually removed
RIPOFF REPORT complaints from the internet by injecting the above-describe illicit SQL
source code into RIPOFF REPORT's servers; and that "RIPOFF REPORT never deletes
anything written about somebody. So it's the perfect place to defame somebody because it
will always stay up, and for some reason it winds up ranking on the first page of Google. So
if you want to destroy somebody's reputation, that's a great place to do it." Additionally,
DARREN MEADE and ED MAGEDSON I RIPOFF REPORT have alleged the testimony
given by the State's witnesses against TRACEY RICHTER during her trial were in direct
101
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
conflict with the testimony they gave in their depositions, which is patently false. TRACEY
RICHTER, ANNA RICHTER, and RUSSELL SCHERTZ provided DARREN MEADE and ED
MAGEDSON I RIPOFF REPORT with copies of the discovery in TRACEY RICHTER's
criminal trial, including the transcripts from the depositions of the State's witnesses.
As discussed earlier, in April 2013, TRACEY RICHTER and ANNA RICHTER learned of
DARREN MEADE's deposition, as SCA Smith referenced it in his Motion to Quash
TRACEY RICHTER's subpoena duces tecum to the Sac County Sheriff, and even included
DARREN MEADE's quote about how RIPOFF REPORT is a "great place" to destroy
someone's reputation. As discussed earlier, on July 20, 2012, after learning SCA Smith had
received DARREN MEADE's deposition pursuant to a court order subpoena, DARREN
MEADE pleaded with the subpoenaed party, Dr. Scott Connelly, to "pull back" the
deposition from SCA Smith and tell SCA Smith the transcript was inaccurate. Also in April
2013, ED MAGEDSON I RIPOFF REPORT received a copy of SCA Smith's Motion to
Quash. Additionally, in May 2013, ED MAGEDSON I RIPOFF REPORT learned of the 2011
e-mail DARREN MEADE sent to convicted felon ADAM ZUCKERMAN wherein DARREN
MEADE suggested that for the purpose of furthering DARREN MEADE and ADAM
ZUCKERMAN's felonious enterprises, they should begin publicly accusing Michael Roberts
of Dustin Wehde's murder (i.e., that Michael Roberts sent Dustin Wehde into he and
TRACEY RICHTER's home to attack TRACEY RICHTER, which resulted in TRACEY
RICHTER shooting (nine times) and killing Dustin Wehde).
Despite having unimpeachable evidence as early as January 2012, that DARREN MEADE
had previously been hired I paid by convicted felons to defame witnesses online and that
most of the content in DARREN MEADE's RIPOFF REPORT complaints were patently
false, ED MAGEDSON I RIPOFF REPORT paid DARREN MEADE to create defamatory,
harassing RIPOFF REPORT complaints about the State's witnesses, and provided him with
unfettered access to RIPOFF REPORT, a "great place to destroy someone's reputation,"
which by DARREN MEADE's own admissions, had the ability to attract up to two million
viewers per day. In addition to paying DARREN MEADE over at least $80,000.00 to create
RIPOFF REPORT complaints about the State's witnesses and publicize the same, ED
MAGEDSON I RIPOFF REPORT, aware of the factual, under oath assertions contained in
DARREN MEADE's deposition, sought out major news media to advertise and vouch for the
credibility of DARREN MEADE's work on RIPOFF REPORT, specifically, DARREN
MEADE's RIPOFF REPORT complaint No. 938843.
Another example of ED MAGEDSON I RIPOFF REPORT protecting and vouching for
DARREN MEADE is on or around September 14, 2012, when Michael Roberts made a
102
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
comment I rebuttal to DARREN MEADE's September 9, 2012, RIPOFF REPORT complaint
(No. 938843) about the State's witnesses, which he titled:
[DARREN MEADE] OF KAIROS-MEADE IN LAGUNA BEACH CALIFORNIA. [DARREN
MEADE] IS A PAID REPUTATION-HITMAN WORKING FOR ED MAGEDSON OF RIPOFF
REPORT THESE POSTINGS ARE IN RESPONSE TO MY REFUSING TO SUBMIT TO
DARREN MEADE'S EXTORTION DEMANDS IN OCTOBER 2011, AND MY EXPOSES ON
ED MAGEDSON'S APPALLING BUSINESS PRACTICES.
In this comment I rebuttal, Michael Roberts provided hyperlinks to information that poked
holes in DARREN MEADE's credibility and the substantive content of his RIPOFF REPORT
complaint about the State's witnesses and corroborated Michael Roberts' comment.
However, sometime after Michael Roberts' posted this comment, ED MAGEDSON 1
RIPOFF REPORT removed or "redacted" Michael Roberts's hyperlinks and amended the
above-title of his rebuttal to the following: "*UPDATE .. FROM [ED MAGEDSON] -
NEITHER RIPOFF REPORT, NOR ED MAGEDSON ENGAGED, HIRED OR REQUESTED
DARREN MEADE TO WRITE THIS STORY."
Also, it is important to note that the original URL for DARREN MEADE's November 9, 2012
(published on November 11, 2012), RIPOFF REPORT complaint No. 938843 was
http://www.ripoffreport.comlben-smith-michael-roberts-rexxfieldlprosecutorial-misconducUsac-city-
sac-county-iowa-B1A77.htm However, the URL for the same RIPOFF REPORT complaint is now
http://www.ripoffreport.comlriBen-Smith-Sac-County-lowa-Prosecutor-Prosecutoriai-Misconduct-
Tracey-Richter-Falsely-Convicted-Overwhelining-Evidence-Michaei-Roberts-RexxfieldiSac-City-
lowa-IBen-Smith-Sac-County-lowa-Attorney-prosecutorial-misconduct-improper-relationship-with-st-
938843
It is not difficult to understand why this change was made, considering the following e-mail
ED MAGEDSON I RIPOFF REPORT sent to SIAMACK YAGHOBI on September 18, 2013:
I put [the reviews] at the beginning for a reason. Look- the ONLY f reason why [RIPOFF
REPORT customers I victims] are talking to you (SIAMACK YAGHOBI aka SAM
YOUBANKS, RIPOFF REPORT CAP and Verified salesman) is, because, they are listed on
Google and they want that f ing listing to change!!! Once [the RIPOFF REPORT customer I
victim sees] that- that the title is changed out! And we inject over 500 to over 1,000 words
before the [RIPOFF REPORT customer's I victim's defamatory RIPOFF REPORT complaint]
with new titles that reflect [the RIPOFF REPORT customer's I victim's commitment to
satisfaction etc .. that is all they will care about - they will listen to anything you have to say
my Aladdin.
As discussed earlier, on September 9, 2012, DARREN MEADE and ED MAGEDSON
published RIPOFF REPORT complaint No. 938843, which, among other things, accuses
the State's witnesses of perjury and theft, and contains comments and a myriad of
103
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
hyperlinks (which, unlike those hyperlinks published by Michael Roberts that are mentioned
above) to other salacious, defamatory stories concerning the State's witnesses. ED
MAGEDSON and DARREN MEADE have placed this RIPOFF REPORT complaint, on each
of RIPOFF REPORT's approximate 1.8 million webpages (No. 938843). ED MAGEDSON
and DARREN MEADE have bragged about RIPOFF REPORT's visibility on the internet. By
DARREN MEADE's own admission, RIPOFF REPORT complaint No. 938843 has been
viewed 1.2 BILLION times. RIPOFF REPORT complaint No. 938843 contains a myriad of
hyperlinks and "rebuttal" or add-on complaints, which redirects readers I viewers to other
salacious I defamatory RIPOFF REPORT "complaints" about the State's witnesses made by
DARREN MEADE and other anonymous authors.
As noted above, DARREN MEADE has admitted to authoring some of the other RIPOFF
REPORT complaints about the State's witnesses. The evidence shows DARREN MEADE
was I is an agent of RIPOFF REPORT I ED MAGEDSON. ED MAGEDSON has paid
DARREN MEADE over one hundred thousand dollars (either directly or indirectly) to create
the content published in the RIPOFF REPORT complaints about the State's witnesses, all
in effort to "help" TRACEY RICHTER and ANNA RICHTER. Since December 2012, ED
MAGEDSON I RIPOFF REPORT, from just one of ED MAGEDSON's I RIPOFF REPORT'
bank accounts, has paid DARREN MEADE over $80,000.00 either directly or indirectly.
Evidence demonstrates that DARREN MEADE received additional compensation from ED
MAGEDSON I RIPOFF REPORT from other sources in this same timeframe. Additionally,
phone records show that from April 2012 and December 2013, DARREN MEADE's mobile
phone called ED MAGEDSON's mobile phone 336 times for a total of 50 hours, and sent
ED MAGEDSON's mobile phone 854 text messages. In this same timeframe, ED
MAGEDSON's mobile phone called DARREN MEADE's mobile phone 1503 times for a total
of 279 hours, and sent DARREN MEADE's mobile phone 954 text messages.
DARREN MEADE's SPRINT PCS mobile phone records for number (949) 357-6193 shows
that through April 2012 and December 2013, DARREN MEADE called (602) 518-4357,
which is a Leap Wireless (dba Cricket Wireless) believed to be ED MAGEDSON's phone,
366 times for a total of approximately 50 hours. ED MAGEDSON is the owner I operator of
ROR. In this same timeframe DARREN MEADE sent Magedson 854 text messages. Also in
this same timeframe, Magedson called DARREN MEADE 1 ,503 times for a total of 279
hours. In this same time, ED MAGEDSON sent DARREN MEADE 954 text messages.
In addition to knowing the defamatory, harassing complaints, were patently false, DARREN
MEADE and ED MAGEDSON I RIPOFF REPORT, crafted said complaints so the same
would be highly visible in legitimate Google-type search results for the State's witnesses
and I or their businesses.
104
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
The most salacious, defamatory RIPOFF REPORT complaints about the State's witnesses,
however, are made by anonymous and I or fictitious persons. The information contained in
this application, however, demonstrates DARREN MEADE, ED MAGEDSON I RIPOFF
REPORT, TRACEY RICHTER, and her family and friends are or know the identities of
these anonymous authors and I or have colluded with them on some level. Example 1:
RIPOFF REPORT complaints No. 1049232 and 1000888 contain the same photograph of
State's witness Dr. John Pitman; the first was published by DARREN MEADE, and the latter
by a "BRETT COLLINS." Example 2: The titles of all the RIPOFF REPORT complaints
concerning the State's witnesses, although they appear nonsensical and choppy, are
worded to maximize their visibility in results of legitimate internet searches for the same
people I businesses. As noted earlier, this is the same method of labeling I titling RIPOFF
REPORT complaints ED MAGEDSON and DARREN MEADE suggested private
investigator Tina Church use to maximize the visibility of any RIPOFF REPORT complaints
she may publish on their behalf. A cursory examination of the titles used in just a sampling
of RIPOFF REPORT complaints demonstrates most are about consumer issues, not events
not related to consumers and businesses, such as murder cases, and that the titles to most
of these complaints read something like the following title pulled from a recently published
RIPOFF REPORT complaint: "[COMPANY I BUSINESS NAME] DOES NOT BACK
PRODUCT AND HAS NO VIABLE SUPPORT MECHANISM NATIONWIDE." Whereas the
title of DARREN MEADE's RIPOFF REPORT complaint No. 1009000, published on
February 7, 2013 is as follows:
MILE2 MICHAEL ROBERTS REXXFIELD RAYMOND FRIEDMAN MARIE FRIEDMAN
GRAPHIC DEPICTIONS OF CHILD MOLESTATION, CHILD TORTURE, EXACT RECIPES
OF LIQUID EXPLOSIVES, PIPE BOMBS ILLICIT RECORDINGS, INTERNET
Comparing the above-title with the one below for RIPOFF REPORT complaint No. 990368,
which published by anonymous author "LOST BOY" leaves no doubt DARREN MEADE and
"LOST BOY" are somehow connected, if not the same:
MIKE ROBERTS MILE2 REXXFIELD.COM CHILD TORTURE AND CHILD
PORNOGRAPHY, EXACT RECIPES FOR THE MANUFACTURE OF LIQUID EXPLOSIVES
AND PIPE BOMBS, INTERNET
Example 3: Communications between the above-named individuals obtained by law
enforcement show that some of the personal I sensitive information contained in some of
the RIPOFF REPORT complaints authored by these anonymous I fictitious persons, was
given to DARREN MEADE by TRACEY RICHTER's friends I family. Example 4: The subject
matter of these anonymous RIPOFF REPORT complaints closely follow TRACEY
RICHTER's conversations about the same subject matter with ANNA RICHTER and her
fiance, RUSSELL SCHERTZ.
105
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
The evidence clearly shows that DARREN MEADE ED MAGEDSON I RIPOFF REPORT,
and the anonymous authors (who the evidence demonstrates most likely are, or have some
close association with DARREN MEADE and ED MAGEDSON I RIPOFF REPORT}, have
titled their harassing, defamatory RIPOFF REPORT complaints and their respective add-on
comments I rebuttals to reach not only the "two million viewers per day" they bragged about,
but more importantly, to friends love interests, prospective employers I customers, etc. who
I which after conducting a legitimate I benign search result for one of the witnesses, would
almost certainly find one of these RIPOFF REPORT complaints at the very top of the first
page of the search result. Example: Today, June 26, 2014, SCA Smith searched "Marie
and Raymond Friedman" using Google. Again, Marie and Raymond Friedman were two key
State's witnesses. The first three search results for "Marie and Raymond Friedman" (the
parentheses were not part of the search terms entered in Google) return links to RIPOFF
REPORT complaints with the following titles:
MILE2 MICHAEL ROBERTS REXXFIELD RAYMOND FRIEDMAN MARIE FRIEDMAN
GRAPHIC DEPICTIONS OF CHILD MOLESTATION, CHILD TORTURE, EXACT
RECIPES OF LIQUID EXPLOSIVES, PIPE BOMBS ILLICIT RECORDINGS, INTERNET
(RIPOFF REPORT No. 1009000)
MILE2 MICHAEL ROBERTS RAY FRIEDMAN CONSPIRE TO DEFRAUD MAJORITY
PARTNER TRACEY RICHTER IN ORDER TO USE MILE2 TO STEAL GOVERNMENT
[SIC] SECRETS VIA SOCIAL ENGINEERING AMAN BHAR, MATTHEW RAIKES, NICK
DUMITRU, PAUL PORTELLI, WIKI LEAKS SOURCE, SOCIAL ENGINEERING
UTILIZED AGAINST U.S. MILITARY, MARIE FRIEDMAN, HACKING OF MILITARY
SECRETS, LIJIT NETWORKS TAMPA, FLORIDA (RIPOFF REPORT No. 980023)
The third result was a link to the search result within RIPOFF REPORT to the first of the
three RIPOFF REPORT complaints listed here (No. 1009000)
As mentioned earlier, on January 1, 2012 ED MAGEDSON wrote check No. 2498 for
$2,500 to DARREN MEADE from the XCENTRIC VENTURES (dba RIPOFF REPORT},
LLC bank account. The memo line of the check stated "[Public Relations) thru Feb 15,
2012". Evidently, the so-called public relations affected by DARREN MEADE since his
engagement by ED MAGEDSON can only be described as a scorched-earth campaign
against each and every State's witnesses. This includes literally hundreds of webpages,
images, videos, or comments on websites that are not RIPOFF REPORT, that are
conspicuously search-engine-optimized so as draw the viewer I reader back to defamatory,
harassing RIPOFF REPORT complaints, to cause maximum damage to each State's
Witness when the names or businesses are searched in Google or other search engines. In
short, the reader I viewer of legitimate internet content, is almost always one click away
from landing on one of the many RIPOFF REPORT complaints about the State's witnesses.
106
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Most telling, however, is the crux of the defamatory, harassing RIPOFF REPORT
complaints published on RIPOFF REPORT by DARREN MEADE and ED MAGEDSON I
RIPOFF REPORT center on the personal and professional lives of the four State's
witnesses DARREN MEADE identified as being most responsible for TRACEY RICHTER's
conviction (i.e., Dr. John Pitman, Mary Higgins, Marie Friedman, and Raymond Friedman)
and thoughtful alternative theories of the TRACEY RICHTER's case. In fact, Jeremy Collins,
the war (Iraq) wounded combat veteran, whose alleged involvement as the mysterious
"second intruder" in the imagined home invasion, was the heart and soul of TRACEY
RICHTER's defense theory. In fact, TRACEY RICHTER flopped around defense counsel's
table, feigning terror, as the "second intruder," as Jeremy Collins entered the courtroom
and made his way to the witness stand, which looking back, explains why TRACEY
RICHTER's criminal defense attorneys covered TRACEY RICHTER's eyes when SCA
Smith displayed a photograph of Jeremy Collins during a deposition, just a few weeks
before her trial started. Regardless, in a recorded conversation between TRACEY
RICHTER and one of the investigators back in 2002, TRACEY RICHTER (unknowingly)
positively excluded Jeremy Collins as the second intruder. In the hundred-plus hours of
audio recorded phone conversations and visits, SCA Smith only recalls TRACEY RICHTER
mentioning I discussing Jeremy Collins one time, which was she told her mother to create
the website www.JeremyCollins.com, in the hopes that Jeremy Collins would "freak out" and
"just want things to go away." In the ten years that followed Dustin Wehde's murder,
TRACEY RICHTER described the alleged second intruder as being Caucasian, Hispanic I
Caucasian, and Middle Eastern. One time TRACEY RICHTER said the second intruder had
worn a ski throughout the entire alleged home invasion. TRACEY RICHTER also described
second intruder's height as being anywhere from 5'7" to 6'2". One time she described the
alleged second intruder's build as being slender, but later described him as having a
heavier physique. TRACEY RICHTER once told law enforcement that the second intruder
was not strong enough to pick her up off the ground, another time she said he picked held
her up off the ground to the point her feet were dangling.
The fact that this narrative (Jeremy Collins as the second intruder) is largely ignored in
DARREN MEADE's "investigation" and subsequent RIPOFF REPORT complaints and
comments, which just so happen to target, on an unfathomable scale (1 .8 million webpages
viewed over a billion times), the professional and personal lives of the four State's
witnesses DARREN MEADE identified as being most responsible for TRACEY RICHTER's
conviction, is just one of many examples proving the RIPOFF REPORT complaints
concerning the State's witnesses were created and published to harass and defame the
State's witnesses for cooperating and testifying against TRACEY RICHTER, and not for any
legitimate purpose.
107
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
As for TRACEY RICHTER and ANNA RICHTER, the information contained in this affidavit
demonstrates that, on multiple occasions, TRACEY RICHTER and ANNA RICHTER
discussed creating derogatory websites about some of the State's witnesses to cause them
"freak out" and "just want it all to go away" (Jeremy Collins). Additionally, the evidence
shows that TRACEY RICHTER, ANNA RICHTER, and their friends and family provided
DARREN MEADE and I ED MAGEDSON RIPOFF REPORT with the information (e.g.,
reports, photographs, and other sensitive information knowing DARREN MEADE and ED
MAGEDSON I RIPOFF REPORT, they knew would be used in RIPOFF REPORT
complaints concerning the State's witnesses.
What the evidence also makes clear is that ANNA RICHTER has control over what
DARREN MEADE and ED MAGEDSON publish on RIPOFF REPORT. As discussed
earlier, ANNA RICHTER told TRACEY RICHTER that DARREN MEADE intended to
publish a derogatory RIPOFF REPORT complaint concerning the poor legal defense he
(DARREN MEADE) believed they provided TRACEY RICHTER, but that ANNA RICHTER
stopped him from doing such because, according to ANNA RICHTER, TRACEY
RICHTER's criminal defense attorney(s) planned to admit to some level of ineffectiveness in
TRACEY RICHTER's Post Conviction Relief proceedings. Also, in addition to paying
DARREN MEADE, phone records show that from between April2012 and December 2013,
there were 120 phone calls made between DARREN MEADE's Sprint PCS mobile phone
and ANNA RICHTER's Verizon Wireless phone No. (515) 401-8926, totaling approximately
43 hours of total talk time.
Furthermore, your applicant cannot think of any reason why information about any of the
State's witnesses CHILDREN (not referring to N.R. or M.R.) would be needed for any
legitimate purpose having to do with TRACEY RICHTER's legal defense.
EXTORTION
A person commits extortion if the person does any of the following with the purpose of
obtaining for oneself or another anything of VC!Iue, tangible or intangible, including labor or
services, or conspires to do the same: threatens to inflict physical injury on some person, or
to commit any public offense; threatens to accuse another of a public offense; threatens to
expose any person to hatred, contempt, or ridicule; threatens to harm the credit or business
or professional reputation of any person; threatens to take or withhold action as a public
officer or employee, or to cause some public official or employee to take or withhold action;
threatens to testify or provide information or to withhold testimony or information with
respect to another's legal claim or defense; threatens to wrongfully injure the property of
another. Extortion is a Class "D" Felony. IowA CODE 711.4 (2013)
lOB
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
During at least two prison visits between TRACEY RICHTER and ANNA RICHTER at the
Iowa women's prison in Mitchellville, the two conspired to use BERT PITMAN to threaten to
expose State's witness Dr. John Pitman to hatred, ridicule and contempt. Specifically, the
two plotted to have BERT PITMAN tell Dr. John Pitman that unless Dr. John Pitman
recanted and I or changed the testimony he gave in TRACEY RICHTER's murder trial (or in
TRACEY RICHTER's own words "play ball"), TRACEY RICHTER, ANNA RICHTER, and I
or BERT PITMAN would give Dr. John Pitman's wife, Lisa Pitman, personal, confidential,
and sensitive information about Dr. John Pitman and his former girlfriend, Allisan Tucker, for
Lisa Pitman to use against Dr. John Pitman in their pending divorce proceedings.
The statements made by TRACEY RICHTER and ANNA RICHTER concerning their plan to
extort Dr. John Pitman were not cherry-picked from a years worth of prison visits. The
twenty or so prison visits that were recorded, occurred between February and March 2014.
The recordings for half of the visits are not audible. TRACEY RICHTER and ANNA
RICHTER discussed their "plan" to extort and harass Dr. John Pitman in four or five of the
ten recordings that were audible.
It is clear from ANNA RICHTER's and BERT PITMAN's e-mail communications with ANNA
RICHTER, specifically, his e-mail containing the letter he had ANNA RICHTER review
before he personally handed the same to Dr. John Pitman, that ANNA RICHTER relayed
TRACEY RICHTER's orders to BERT PITMAN, which would be an v ~ r t act in furtherance
of the conspiracy ..
Also, ED MAGEDSON I RIPOFF REPORT agents I employees DARREN MEADE and I or
YAGHOBI contacted Dr. John Pitman and offered to remove all RIPOFF REPORT
complaints about him for $10,000, which were created and published by DARREN MEADE
and ED MAGEDSON I RIPOFF REPORT, DARREN MEADE, ED MAGEDSON I RIPOFF
extorted Dr. John Pitman.
RIPOFF REPORT I XCENTRIC VENTURES' conduct bears a reasonable relation to a
legitimate state interest, which is letting potential I future witnesses in Iowa feel they can
come forward and give full (complete) and accurate testimony without fear of having their
personal and professional lives destroyed by out-of-state cyber hitmen hired by, and 1 or
working at the direction of the person against whom they are testifying. IowA CODE 803.1
(2014)
Furthermore, ED MAGEDSON I RIPOFF REPORT provided free advertising space on over
1.8 Million pages of his website to the TRACEY RICHTER and ANNA RICHTER who are
Iowa residents, as consideration for their efforts in the conspiracy. Regardless, as
discussed below, DARREN MEADE's and ED MAGEDSON's I RIPOFF REPORT's
extortion of Dr. John Pitman can be used to prove it or its agents have engaged in Ongoing
109
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Criminal Conduct I Specified Unlawful Activity, which is "any act, including any preparatory
or completed offense, committed for financial gain on a continuing basis, that is punishable
as an indictable offense under the laws of the state in which it occurred and under the laws
of this state." IOWA CODE 706A.1 (5) (2013)
Additionally, as discussed earlier, the evidence strongly suggests RIPOFF REPORT and I
or its agents or employees created defamatory RIPOFF REPORT complaints concerning
Dr. Richard Weiss, Global Legal Resources, LLP, Westlake Financial Services, Payment
Systems Corp, Dr. Gary Motykie, and Dr. Payam John Kahen, and then reached out to help
them mitigate I correct the damage it appears RIPOFF REPORT and I or its agents or
employees caused.
OBSTRUCTING PROSECUTION
"A person who, with intent to prevent the apprehension or obstruct the prosecution or
defense of any person, knowingly ... makes available false evidence or furnishes false
information with the intent that it be used in the trial of that case, or conspires to do the
same, commits an aggravated misdemeanor. IowA CODE 719.3, 706.1 (2013) In Iowa, an
aggravated misdemeanor is an indictable offense. Iowa Const. Art. 1 11; IowA CoDE
903.1 (2) (2013); Iowa Rule of Criminal Procedure 2.4(2) (2013)
DARREN MEADE knowingly made available false evidence and I or furnished false
information with the intent that said evidence I information be used in the proceedings
following TRACEY RICHTER's murder conviction (e.g., direct appeal and Post Conviction
Relief), when DARREN MEADE contacted SCA Smith in April 2012, and alleged he
provided information to law enforcement in Iowa proving TRACEY RICHTER's second ex-
husband, Michael Roberts, not TRACEY RICHTER, was responsible for Dustin Wehde's
death. Because around the same time DARREN MEADE supposedly contacted law
enforcement in Iowa, DARREN MEADE was conspiring with two convicted felons to publicly
accuse Michael Roberts of attacking his wife, TRACEY RICHTER, to "pressure" and coerce
Michael Roberts into handing his business, Rexxfield, over to DARREN MEADE and his
felonious "partners." Despite this, after DARREN MEADE learned the convicted felons had
cut him out of their criminal enterprise and began his frenzied whistleblowing campaign, he
and Michael Roberts, for a brief time, enjoyed amicable relationship, which lasted up until
October 28, 2011 (five days into TRACEY RICHTER's murder trial), when Michael Roberts
refused to give DARREN MEADE money.
DARREN MEADE has told law enforcement and news media that back in 2010, Michael
Roberts provided DARREN MEADE information that implicated him in Dustin Wehde's
110
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
murder and I or would serve to exonerate TRACEY RICHTER. For example, in his
September 9, 2012, RIPOFF REPORT complaint No. 938843, DARREN MEADE claimed
Michael Roberts showed DARREN MEADE the crime scene photographs back in 2010.
However, as discussed earlier, according to e-mail communications between DARREN
MEADE and his convicted felon partner, ADAM ZUCKERMAN, shows that DARREN
MEADE did not even know about Dustin Wehde's murder until 2011.
TRACEY RICHTER's mother, ANNA RICHTER, and TRACEY RICHTER's fiance,
RUSSELL SCHERTZ, were aware of DARREN MEADE's aforementioned efforts, as
DARREN MEADE copied them both in on his (DARREN MEADE's) e-mails to SCA Smith.
Phone records show that both ANNA RICHTER and RUSSELL SCHERTZ communicated
with DARREN MEADE before he (DARREN MEADE) provided the false information I
evidence about Michael Roberts to SCA Smith. Most telling, however, is that in August
2011, RUSSELL SCHERTZ, and possibly ANNA RICHTER, believed DARREN MEADE to
be "unstable" and crazy, and planned to use Michael Roberts's then-amicable association
with DARREN MEADE against Michael Roberts in TRACEY RICHTER's custody
proceedings. In fact, on or around August 26, 2011, RUSSELL SCHERTZ and TRACEY
RICHTER discussed DARREN MEADE's February 2011 e-mails to convicted felon ADAM
ZUCKERMAN, in which DARREN MEADE threatened to use a 9mm to intimidate Michael
Roberts' employee with a 9mm pistol and suggested that he and his other felonious
partners should publicly accuse Michael Roberts of child molestation and attempting to kill
TRACEY RICHTER all for the purpose of pressuring and intimidating Michael Roberts into
surrendering his company. Despite knowing where DARREN MEADE had been and what
he was capable of doing, RUSSELL SCHERTZ, ANNA RICHTER, TRACEY RICHTER, and
others provided DARREN MEADE with information and documents knowing he planned to
use the same to attack the State's witnesses on RIPOFF REPORT.
There is only one reason why DARREN MEADE would provide false exculpatory evidence
to the prosecutor responsible for convicting TRACEY RICHTER is that it be used in
TRACEY RICHTER's then-pending direct appeal, and subsequent PCR to obtain a new
trial. The specific allegations DARREN MEADE made against Michael Roberts in his
communications to SCA Smith, if not pure fiction, would I could undermine the I a juries'
decision to convict TRACEY RICHTER for murder.
SOLICITATION
A person solicits another person to commit a felony or aggravated misdemeanor when the
person commands, entreats, or otherwise attempts to persuade the other person to commit
a particular felony or aggravated misdemeanor, with the intent that such act be done and
111
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
under circumstances which corroborates that intent by clear and convincing evidence. A
person who solicits another person to commit a felony of any class commits a class "D"
felony. A person who solicits another person to commit an aggravated misdemeanor
commits an aggravated misdemeanor. IOWA CODE 705.1 (2013)
It would be easier to list the phone and prison conversations between TRACEY RICHTER
and ANNA RICHTER in which TRACEY RICHTER did not solicit ANNA RICHTER and
others to commit and I or aid and abet an indictable offense and I or conspire to do the
same in some way or another.
ONGOING CRIMINAL CONDUCT
It is unlawful for a person to commit, or conspire to commit specified unlawful activity as
defined in section 706A.1. IOWA CODE 706A.2(4) (2013). "Specified unlawful activity"
means any act, including any preparatory or completed offense, committed for financial gain
on a continuing basis, that is punishable as an indictable offense under the laws of the state
in which it occurred and under the laws of this state. IOWA CODE 706A.1 (5) A person who
engages in "Specified unlawful activity" commits a class "B" felony. IOWA CODE 706A.4
(2013). The maximum sentence for any person convicted of a class "B" felony shall be
confinement in prison for no more than twenty-five years. IOWA CODE 703.1 (2013)
All the above-mentioned crimes are indictable offenses. The following demonstrates said
crimes were committed for financial gain on a continuing basis:
DARREN MEADE has been obstructing the State's prosecution of TRACEY RICHTER and
has been tampering with the State's witness beginning as early as January 2012, through
as recently as June 2014, and has been paid by ED MAGEDSON I RIPOFF REPORT and
ANNA RICHTER to do such. '
DARREN MEADE, along with others, from June 2010, through February 2011, embezzled
over one million dollars from Progenex. Embezzlement or theft is punishable as an
indictable offense under the laws of the state of California and Iowa. IowA CODE 714.1
(2013)
Information obtained by law enforcement coupled with DARREN MEADE's own admissions,
including DARREN MEADE's May 9, 2012, e-mail to SCA Smith in which he wrote that he
was receiving Supplemental Security Income (SSI) (proving he had a medical and financial
obstacles preventing him from testifying before the Sac County Grand Jury), demonstrates
that DARREN MEADE has been I is using the California Department of Healthcare Services
(DHCS) (California Medicaid), which means he probable never disclosed the $80,000-plus
112
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
paid to him by RIPOFF REPORT from December 2011 through April 2014, or the
thousands of dollars paid to him by convicted felon ADAM ZUCKERMAN to harass and
defame a witness online back in 2010. In a February 2, 2011, e-mail to one of his felonious
partners, DARREN MEADE wrote the following: "An FYI, the reason I keep my pay and
things under raps is that I lost health insurance when everything happened. In order to keep
it I can never have more than $800.00 in any bank account."
ED MAGEDSON I RIPOFF REPORT, as noted earlier in this affidavit, derive financial
benefit and income by selling advertisement space on RIPOFF REPORT and through its
"Corporate Advocacy Program" and its "Verified" program, both of which are expensive
I
services provided solely by RIPOFF REPORT. An analysis of Ripoffreport.com revenue and
bank records since 2011, suggests that between $5,000 to $10,000 per month worth of
advertising is being provided by ED MAGEDSON I RIPOFF REPORT and DARREN
MEADE to TRACEY RICHTER, ANNA RICHTER, and TRACEY RICHTER's followers. The
real value of this advertising space could be considerably higher, but, absent a
comprehensive accounting, only a baseline estimate can be provided.
As mentioned above, on January 8, 2013, ED MAGEDSON told private investigator Tina
Church, "Alii want.. I want to do is anything that helps free Tracey- I am willing to featuring
articles and place advertisements for the cause on my website (www.RipOffReport.com).
Since September 9, 2012, ED MAGEDSON I RIPOFF REPORT inserted DARREN
MEADE's RIPOFF REPORT complaint No. NUMBER as a "featured report" on all its 1.8
million webpages I complaints. While creating the above-mentioned RIPOFF REPORT
complaint with journalist Glenn Puit, ED MAGEDSON told DARREN MEADE that Glenn
Puit's complaint would not be published on RIPOFF REPORT as a featured report because
it provided "NO BENEFIT TO RIPOFF REPORT." Thus, by negative implication, DARREN
MEADE's September 9, 2012, RIPOFF REPORT complaint (No. 938843), and its rebuttals I
add-on complaints, which has been a featured report on RIPOFF REPORT since
September 9, 2012, benefit ED MAGEDSON I RIPOFF REPORT.
Additionally, information obtained by law enforcement shows that ED MAGEDSON I
RIPOFF REPORT is using the buzz generated by his and DARREN MEADE RIPOFF
REPORT complaints about the State's witnesses to raise money for TRACEY RICHTER's
legal defense. Specifically, on February 28, 2014, during a prison visit, ANNA RICHTER
told TRACEY RICHTER that one of her two new attorneys said TRACEY RICHTER and
ANNA RICHTER needed to create a trust fund for the money donated to TRACEY
RICHTER for her legal defense I Post Conviction Relief (PCR) proceedings, because the
attorney did not want SCA Smith to garnish these funds. ANNA RICHTER said TRACEY
RICHTER's attorney said she did not want SCA Smith to garnish these funds. Furthermore,
113
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
the evidence suggests that ED MAGEDSON hired a former RIPOFF REPORT attorney to
help TRACEY RICHTER and ANNA RICHTER.
In Iowa "a public or private corporation, partnership, or other voluntary association shall
have the same level of culpability as an individual committing the crime when any of the
following is true: The conduct constituting the offense consists of an omission to discharge a
specific duty or an affirmative performance imposed on the accused by law. The conduct or
act constituting the offense is committed by an agent, officer, director, or employee of the
accused while acting within the scope of the authority of the agent, officer, director or
employee and in behalf of the accused and when said act or conduct is authorized,
requested, or tolerated by the board of directors or by a high managerial agent. "High
managerial agent" means an officer of the corporation, partner, or other agent in a position
of comparable authority with respect to the formulation of policy or the supervision in a
managerial capacity of subordinate employees." IowA CODE 703.5 (2013)
The above-listed crimes were committed with the intent to produce detrimental effects within
Iowa, and the subject(s) actions did produce detrimental effects within Iowa. Witness
Tampering is an indictable offense. Iowa Code 708. 7(1) (2013); Iowa Code 720.4
(2013); I.A. Const. art. I, 11; IOWA CODE 903.1(2) (2013); Iowa R. Grim. P. 2.4(2); IOWA
CODE 803.1 (2013)
After ED MAGEDSON I RIPOFF REPORT and DARREN MEADE learned that SCA Smith
had their mobile phone records and DARREN MEADE's deposition, which would have been
around July 2012, and was actively investigating them for witness tampering, rather than
cease and desist from their defamatory publications, a little over a month after learning of
SCA Smith's investigation, ED MAGEDSON I RIPOFF REPORT and DARREN MEADE
intensified their criminal actions by publishing false information about the State's witnesses
and SCA Smith, with a photograph of SCA Smith on each of the 1.8 million RIPOFF
REPORT pages as one of its "featured reports (which, according to ED MAGEDSON and
DARREN MEADE, benefits RIPOFF REPORT)," which was done to intimidate SCA Smith
into ending his investigation of RIPOFF REPORT employee I agent DARREN MEADE's
aforementioned ongoing criminal conduct and to manufacture a preemptive legal defense
(i.e., that SCA Smith's investigation of ED MAGEDSON I RIPOFF REPORT and DARREN
MEADE was retaliatory in nature and in violation of their civil rights). Ironically, the
continuance and escalation of these deliberate actions created an undeniable duty
compelling SCA Smith - the chief law enforcement officer of Sac County -to take decisive
steps to terminate the malignant precedent that will be created by allowing the actions of not
only these individuals, but potential imitators as well, to forever impair the efficient pursuit of
criminal justice in Sac County. Ignoring the obvious potential injury to our criminal justice
114
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
system would be a breach of SCA Smith's duties to the State's witnesses and the citizens of
Sac County.
No greater threat to our criminal justice system exists than allowing convicted, incarcerated
murderers (criminals), and their friends and family, to destroy the livelihoods and personal
reputations of the people brave enough to testify against them in open court. Considering
the foregoing, specifically, the extent to which these witnesses have been damaged socially
and professionally by TRACEY RICHTER, ANNA RICHTER, DARREN MEADE, ED
MAGEDSON and others, your applicant doubts few, if any of the State's witnesses, if given
the option to do it again, would come forward and give full, accurate testimony against
TRACEY RICHTER. In fact, many have expressed as much.
The information contained herein gives your applicant reason to believe that as TRACEY
RICHTER's chances for a new trial decrease, the more drastic her and her family's and
friends' actions will become. As mentioned above, TRACEY RICHTER and ANNA
RICHTER have already identified the WEAKEST juror. Your applicant fears it is only a
matter of time before the jurors who convicted TRACEY RICHTER will join the State's
witnesses on RIPOFF REPORT or will face other like-retaliation.
SUMMARY OF RELEVANT TECHNOLOGY
Information contained in the electronic storage devices ("electronic files"), such as
computers, iPads, smartphones, etc. can be recovered months or even years after it has
been downloaded, deleted or viewed via the internet. Such information may include
computer applications, images, text, programs, encryption routines and algorithms, or other
data that may be decoded, reconstituted, or otherwise manipulated to produce, utilize,
transmit, receive, encrypt, encode, or display such images, text, programs, encryption
routines, and algorithms.
Electronic files downloaded to a hard drive I electronic storage device can be stored for
years at little or no cost. Even when files have been deleted, they can be recovered months
or years later using readily available forensics tools. This is so because when a person
"deletes" a file on most electronic storage devices, the data contained in the file does not
actually disappear; rather, that data remains until it is overwritten by new data. Therefore,
deleted files, or remnants of deleted files, may reside in free space or slack space-that is, in
space on the hard drive I digital storage device that is not currently being used by an active
file-for long periods of time before they are overwritten. In addition, in many instances the
operating system for a computer I digital storage device may also keep a record of deleted
data in a "swap" or "recovery" file.
115
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
The Internet is a global network of computers and other electronic devices that
communicate with each other. Files that have been viewed via the Internet are typically
automatically downloaded into a temporary Internet directory or "cache." The internet
browser often maintains a fixed amount of hard drive space devoted to these files, and the
files are only overwritten as they are replaced with more recently viewed Internet pages or if
a user takes steps to delete them.
An Internet Protocol address (or simply "IP address") is a unique numeric address used by
computers on the Internet. An IP address looks like a series of four numbers, each in the
range 0-255, separated by periods (e.g., 121.56.97. 178). Every computer attached to the
Internet computer must be assigned an IP address so that Internet traffic sent from and
directed to that computer may be directed properly from its source to its destination. Most
Internet service providers control a range of IP addresses. Some computers have static-that
is, long-term-IP addresses, while other computers have dynamic-that is, frequently
changed-IP addresses. Law enforcement can often find out a particular ISP using an IP
address, and given the date and lime the IP address was used;the ISP typically can identify
the account holder by name and physical address.
Peer to peer file sharing ("P2P") is a method of communication available to Internet users
through the use of special software. P2P software allows users to trade digital files through
worldwide networks of computers. Several different software applications can be used to
access these networks, but these applications operate in a similar manner. To access the
P2P networks, a user first obtains the P2P software, which can be downloaded from the
Internet. This software is used exclusively for the purpose of sharing digital files. When the
P2P software is installed on a computer, the user is directed to specify a folder that will
contain files available to anyone on the world wide network for download ("shared folder").
A user obtains files by conducting keyword searches of the P2P network. When a user
initially logs onto the P2P network, a list of the files that the user is sharing is transmitted to
the network. The P2P software then matches files in these file lists to keyword search
requests from other users. A user looking to download files simply conducts a keyword
search, and the results of the keyword search are displayed. The user then selects file(s)
which he or she wants to download. The download of a file is achieved through a direct
connection between the computer requesting the file and the computer(s) hosting the file.
Once a file has been downloaded, it is stored in the area previously designated by the user
and will remain there until moved or deleted. Most P2P software applications keep logs of
each download event. A P2P file transfer is assisted by reference to an Internet Protocol
(IP) address, which is a unique numeric address used by computers on the Internet.
Searching for information stored in computers often requires agents to seize most or all
116
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
electronic storage devices to be searched later by a qualified computer expert in a
laboratory or other controlled environment. This is often necessary to ensure the accuracy
and completeness of such data, and to prevent the loss of the data either from accidental or
intentional destruction. Additionally, computers and other electronic storage devices can
store the equivalent of millions of pages of information. Also, a suspect may try to conceal
criminal evidence; he or she might store it in random order with deceptive file names. This
may require searching authorities to peruse all the stored data to determine which particular
files are evidence or instrumentalities of crime. This sorting process can take weeks or
months, depending on the volume of data stored, and it would be impractical and invasive
to attempt this kind of data search on-site. For all the reasons discussed in this numbered
paragraph, your applicant requests permission to copy the hard drive(s) or its equivalent for
each of the electronic storage devices seized from ANNA RICHTER's residence.
Searching computer systems for criminal evidence sometimes requires highly technical
processes requiring expert skill and properly controlled environment. The vast array of
computer hardware and software available requires even computer experts to specialize in
some systems and applications, so it is difficult to know before a search which expert is
qualified to analyze the system and its data. In any event, however, data search processes
are exacting scientific procedures designed to protect the integrity of the evidence and to
recover even "hidden," erased, compressed, password- protected, or encrypted files.
Because computer evidence is vulnerable to inadvertent or intentional modification or
destruction (both from external sources or from destructive code imbedded in the system as
a "booby trap"), making copies of the hard drives of the electronic storage devices may be
necessary to safeguard against any loss (inadvertent or otherwise) as a result of the
foregoing.
Searching computer systems for the evidence described below may require a range of data
analysis techniques. In some cases, it is possible for agents and analysts to conduct
carefully targeted searches that can locate evidence without requiring a time-consuming
manual search through unrelated materials that may be commingled with criminal evidence.
In other cases, however, such techniques may not yield the evidence described in the
warrant. Criminals can mislabel or hide files and directories, encode communications to
avoid using key words, attempt to delete files to evade detection, or take other steps
designed to frustrate law enforcement searches for information, such as deleting web
browser history. These steps may require agents and law enforcement or other analysts
with appropriate expertise to conduct more extensive searches, such as scanning areas of
the disk not allocated to listed files, or peruse every file briefly to determine whether it falls
within the scope of the warrant In light of these difficulties, the DCI intends to use whatever
data analysis techniques appear necessary to locate and retrieve the evidence described
117
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
below.
Dropbox is a file hosting service operated by Dropbox, Inc., headquartered in San
Francisco, California, that offers cloud storage, file synchronization, and client software.
Dropbox allows users to create a special folder on each of their computers, which Dropbox
then synchronizes so that it appears to be the same folder (with the same contents)
regardless of which computer is used to view it. Files placed in this folder also are
accessible through a website and mobile phone applications.
The Dropbox client enables users to drop any file into a designated folder that is then
synchronized with Dropbox's Internet service and to any other of the user's computers and
devices with the Dropbox client. Users may also upload files manually through a web
browser.
Dropbox client supports synchronization and sharing along with personal storage. It
supports revision history, so files deleted from the Dropbox folder may be recovered from
any of the synced computers. Dropbox supports multi-user version control, enabling several
users to edit and re-post files without overwriting versions. The version history is paired
with the use of delta encoding technology. When a file in a user's Dropbox folder is
changed, Dropbox only uploads the pieces of the file that are changed when synchronizing,
when possible.
Your affiant has been a Dropbox account holder for over 2 years and knows that registering
and using the Dropbox is facilitated almost by the Dropbox Inc. account holder's email
account. Your affiant is aware of only one email account used by ANNA RICHTER, which is
the YAHOO! Inc. email address identified above.
In my research and experience, I have learned that YAHOO! INC. provides a variety of on-
line services, including electronic mail ("email") access, instant messaging, and other
electronic communication services to the general public. Subscribers obtain an account by
registering with YAHOO! INC .. During the registration process, YAHOO! INC. asks
subscribers to provide basic personal information. Therefore, the computers of YAHOO!
INC. are likely to contain stored electronic communications (including retrieved and non-
retrieved email for YAHOO! INC. subscribers) and information concerning subscribers and
their use of YAHOO! INC. services, such as account access information, email transaction
information, and account application information.
As discussed earlier, ANNA RICHTER has I had a YAHOO! INC. e-mail account
([email protected]), which she had used as recently as May 17, 2014, and
that search warrant for all e-mails in the account issued to YAHOO! INC. returned nothing.
In general, an email that is sent to a YAHOO! INC. subscriber is stored in the subscriber's
118
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
"mail box" on YAHOO! INC. servers until the subscriber deletes the email. If the subscriber
does not delete the message, the message can remain on YAHOO! INC. servers
indefinitely. When the subscriber sends an email, it is initiated at the user's computer,
transferred via the Internet to YAHOO! INC.'s servers, and then transmitted to its end
destination. YAHOO! INC. often saves a copy of the email sent. Unless the sender of the
email specifically deletes the email from the YAHOO! INC. server, the email can remain on
the system indefinitely.
Instant messaging (IM) is a type of online chat which offers real-time text transmission over
the Internet where short messages are typically transmitted bi-directionally between two
parties, when each user chooses to complete a thought and select "send."
A YAHOO! INC. subscriber can also store files, including emails, address books, contact or
buddy lists, pictures, and other files, on servers maintained and I or owned by YAHOO!
INC .. As per YAHOO! INC. policy, chat history including IP address information (logging) is
stored on YAHOO! INC. servers.
Subscribers to YAHOO! INC. might not store on their home computers copies of the emails
stored in their YAHOO! INC. account. This is particularly true when they access their
YAHOO! INC. account through the web, or if they do not wish to maintain particular emails
or files in their residence.
In general, email providers like YAHOO! INC. ask each of their subscribers to provide
certain personal identifying information when registering for an email account. This
information can include the subscriber's full name, physical address, telephone numbers
and other identifiers, alternative email addresses, and, for paying subscribers, means and
source of payment (including any credit or bank account number).
Email providers typically retain certain transactional information about the creation and use
of each account on their systems. This information can include the date on which the
account was created, the length of service, records of log-in (i.e., session) times and
durations, the types of service utilized, the status of the account (including whether the
account is inactive or closed), the methods used to connect to the account (such as logging
into the account via YAHOO! INC.'s website), and other log files that reflect usage of the
account.
In addition to the foregoing, email providers often have records of the Internet Protocol
address ("IP address") used to register the account and the IP addresses associated with
particular logins to the account. Because every device that connects to the Internet must
use an IP address, IP address information can help to identify which computers or other
devices were used to access the email account.
119
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
Further, in some cases, email account users will communicate directly with an email service
provider about issues relating to the account, such as technical problems, billing inquiries,
or complaints from other users. Email providers typically retain records about such
communications, including records of contacts between the user and the provider's support
services, as well records of any actions taken by the provider or user as a result of the
communications.
A search warrant issued to YAHOO! INC. on May 23, 2013, for e-mails in ANNA
RICHTER's yahoo e-mail account returned nothing (i.e., as of May 23, 2013, there were no
e-mails for [email protected] stored on YAHOO! INC. servers), which
suggests she has downloaded them from Yahoo! Inc.'s servers, onto her computer.
SIGNED and DATED July ~ 2014.
~ : :
BEN SMITH
SAC COUNTY ATTORNEY
120
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
IN THE IOWA DISTRICT COURT IN AND FOR SAC COUNTY
(Magistrate Division)
IN THE MATTER OF AN APPLICATION
FOR A SEARCH WARRANT FOR THE
RESIDENCE AT 4221 155TH STREET,
URBANDALE, IOWA 50323
SEARCH WARRANT APPLICATION:
ATTACHMENT A
PLACES AND THINGS TO BE SEARCHED BY THE GOVERNMENT
This warrant applies to information associated with the following items and their (digital)
contents located at ANNA RICHTER's residence at 4221 155TH STREET, URBANDALE,
IOWA 50323, all computers, portable hard drives, data DVDs, USB flash drives (NOT TO
INCLUDE mobile phones I smartphones) and the digital files, folders, and other digital
documents I information contained in said items.
121
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
IN THE IOWA DISTRICT COURT IN AND FOR SAC COUNTY
(Magistrate Division)
IN THE MATTER OF AN APPLICATION
FOR A SEARCH WARRANT FOR THE
RESIDENCE AT 4221 155TH STREET,
URBANDALE, IOWA 50323
SEARCH WARRANT APPLICATION:
ATTACHMENT B
'
ITEMS AND INFORMATION TO BE SEIZED BY THE GOVERNMENT
All information contained on the electronic storage devices, computers (laptops or towers),
flash drives (USB drives), data DVDs, described in Attachment A and to seize information
contained in said electronic storage devices that constitute fruits, evidence, and
instrumentalities of the criminal violations outlined in the Affidavit to the Search Warrant
Application ("Affidavit"), which is attached hereto and is incorporated herein by reference.
Specifically, and among other things, law enforcement shall seize any and all
communications to or from the individuals identified in the Affidavit that concern or relate to
the crimes alleged in the Affidavit, and all documents, records, communications,
correspondence, notes, e-mails, addresses or contacts, text messages, instant messages,
chats, Internet history, records of internet activity, time indicators, text message logs, instant
message logs, other logs, user profiles for social media, visual depictions, audio files, and
all other data relating to the crimes and conduct alleged in the Affidavit, including but NOT
limited to the information listed below, as well as and all evidence capable of demonstrating
or leading to further discovery of the same information:
1. All files and information contained in any and all of the electronic storage devices
that were discussed I mentioned by ANNA RICHTER and the other individuals or that
relate to the crimes and conduct alleged in the Affidavit, including any such files located
in a Dropbox or similar program I file on any of the electronic storage devices, used to
transfer I store documents and other information between ANNA RICHTER and ED
MAGEDSON I RIPOFF REPORT, DARREN MEADE and the others named I described
in the Affidavit.
2. All e-mail communications between ANNA RICHTER and the individuals
identified in the Affidavit, which relate to and I or corroborate the facts contained in the
Affidavit and I or that are described or specifically identified in the Affidavit. Said e-mail
122
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
communications shall include those mentioned in the Affidavit and I or those which
relate to the crimes and conduct alleged in the Affidavit.
123
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
DISTRICT COUin OF IOWi".
SAC COUNTY
FILED
ZOI4 JUL -9 AM 8: 09
IN THE IOWA DISTRICT COURT IN AND FOR SAC COUNTY
(Magistrate Division)
IN THE MATTER OF AN APPLICATION
FOR A SEARCH WARRANT FOR THE
RESIDENCE AT 4221 155TH STREET,
URBANDALE, IOWA 50323
ENDORSEMENT ON SEARCH WARRANT
APPLICATION
This matter came before the Court on the government's search warrant application. In
issuing the search warrant, the undersigned relied upon the sworn testimony of Sac County
Attorney Ben Smith, together with the statements and information contained in the
application and any attachments thereto, and finds such information demonstrates probable
cause, and therefore, I do issue the warrant.
124
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
EXHIBIT 4
E-FILED 2014 SEP 19 6:45 PM SAC - CLERK OF DISTRICT COURT
VIDEO FILE TO BE FILED WITH THE COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
X-FriendScore: -0.7 sd=-0.7 -11.8(X-SpamContent:clean) -3.0(X-
Phrase:clean) 0.9(X-myrbl:Color=blue) -0.2(dnswl_none) O.O(X-
LangGuess:English) O.O(X-Verify-SMTP present) [sig=3) [nnot=2,nis=O,O.O)
X-NotAscii: charset=utf-8
X-SpamContent: Clean
X-LangGuess: English
X-Probe: +OK skipped, from friend
X-Phrase: Clean score=O.OO
X-Avast: Message is clean
X-MyRbl: Color=Blue Age=O Spam=O Notspam=O Stars=O Good=O Friend=l Surbl=O
Catch=O r=O ip=208.109.78.210
X-IP-stats: GreyPassed Incoming Last 0, First 1100, in=640, out=O, spam=O
ip=208.109.78.210
I ( ' t
[ l.foj,we Nationai_Pteseoe
i u;
[1[
. 1-1
(e) Google Maps'" l.) Windows live Maps'" () Yahoo Maps" .. ! I Two Maps Overview Map
'" j
/
Cily
.
Ptescoll
(')
ino
L.
Cibafa Nationt
\!j
(
Kofa National
I
j \
1
< WM!tfe Refuge
'
Mex1cah
r \iJ '!:/
il @ ro--.___
Mesa, Uniled
I i>hcien\. I
Avonda!h_;' cL, !'({,)
, f Mesa
\ \
\San Tan
'yal'.ey
'I __ Colorado ()
c;) Cabeza Priei(!_Nalicnal
Wildlife Refuge
IP Address
65.122.15.1690 0
Provider
City Of Phoenhc G
tlostMme
avnsmtp01.phoenlx.gov 0 0
Timelone
America/Phoenix\\'
<IY
Mesa W
State (Code)
Arizona (AZ) \\'
Country
United States W
Continent
America\\'
X
($)
Gila national Forest
''
ij;l '<Deming
lkpO!I a U1Jjl Cf/01
Country flag DNA Code
753
latitude Area Code
33,4223 480
longitude Postal Code
-111.8226 nfa
TLO GMT Offset
us\\' -7
)
)
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
)
)
)
--- Original message ---
Subject: (none)
From: Darren M. Meade <[email protected]>
To: scott conneiiy <[email protected]>
Date: Wednesday, 21/12/2011 9:55PM
Darren M. Meade
Direct: (949) 715-1521
Fax: (800) 657-5660
Visit me on Unkedln
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages
attached to It, may contain confidential information that is legally privileged. If you are not the Intended recipient,
or a person responsible for delivering It to the Intended recipient, you are hereby notified that any disclosure,
copying, distribution or use of any of the Information contained In or attached to this message Is STRICTLY
PROHIBITED. If you have received this transmission In error, please Immediately notify us by reply e-mail at
[email protected] or by telephone at (949) 715-1521, and destroy the original transmission and Its
attachments without reading them or saving them to disk. Thank you.
"}:
R...0_8.Jki!Jn?_to_r_m,_p_dL($_Q_K___ll)
EXHIBIT
5
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
PROPOSAL
What follows is a high-level analysis of areas of opportunity for ROR to build brand eq-
uity, expand consumer awareness, increase revenue, and help position the Company for
a favorable acquisition or public offering within the next 12-24 months. These strategic
recommendations are based on a limited understanding of certain aspects of ROR op-
erations and are subject to change as our relationship deepens. Tactical implementa-
tion would be covered in a next-level business plan engagement.
In consideration of ROR's success to date, we have identified six strategic initiatives that
could substantially impact the future of the business:
EVOLVE THE BRAND
Just because you deal with dirty laundry doesn't mean you need to smell/ike it. The ROR
brand needs to be elevated beyond its black hat status as the Web's premier vendetta en-
gine to become synonymous with it's underlying virtue: unflinching consumer advocacy.
To repackage ROR as consumer champion it actually is, action items would include: 1) reas-
sessing brand positioning, 2) redesigning the logo, and 3) rewriting the tag line
ESTABLISH THE VOICE
Every worthy cause has a champion. As an extension to the brand evolution outlined above,
ROR needs a develop a voice-a personification of its purpose. Whether it's the Founder
or someone else, that someone needs to wear the white hat and get out in front of ROR to
make an offensive push into the market, rather than a defensive stand against detractors.
STREAMLINE THE MESSAGE
Humans need water to live, but who wants to drink from a firehose? ROR has an answer to
virtually every question when it comes to its principles and its practices-IF you're commit-
ted enough to read all the info. Most people aren't. The result is a lot of knee-jerk reactivity
that could be mitigated if ROR can streamline its messaging in conjunction with the brand
repositioning recommended above.
ENHANCE THE EXPERIENCE
Even angry people expect a user-friendly website. There are a number of things that could
be done from a user interface standpoint to enhance the ROR user experience and increase
brand perception. Some are relatively simple-like slowing down the report teaser on the
homepage and fixing the search function so it says something even if no results are found.
Other improvements would be more involved and require a better understanding of the
ROR platform and how easy it is to work with from a site architecture standpoint.
)
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
)
MEET THE PRESS
No publicity is bad publicity. We will create a series of investigative news stories by repu-
table journalist that will serve to help reposition ROR as the best alternative consumers
have to voice their opinions when they've been wronged by a powerful corporation or are
simply unable to secure justice through the civil or criminal courts. That said, ROR has itself
been victimized by white collar criminals and "vulture capital"-backed reputation manage-
ment firms, resulting in a wave of costly chaos and negativity. ROR will need to rethink its
identity and direction to turn the tide.
Action items would include internet & print articles, well-placed news stories and viral vid-
eos. The goal will be to create a groundswell of "free" PR and high-impact impressions that
wold cost tens of millions to create through conventional advertising.
MOBILIZE THE MASSES
Do something worth talking about! Word of mouth marketing is the most valuable cur-
rency in today's advertising-saturated world. Ultimately, word of mouth marketing comes
down to being good to people-consistently telling the truth and doing what you say you'll
do (or not do). Happy customers grow your brand for you. The word of mouth that they
create is far more powerful than all the advertising in the world. We can build on the suc-
cess of the Corporate Advocacy Program and create a word of mouth marketing campaign
amplified by the strategies introduced above.
These strategic recommendations will take time and money to implement. While sub-
stantial questions remain with respect to certain aspects of ROR operations yet to be
disclosed, we are nonetheless convinced the approach outlined here is the key to build-
ing real value and positioning ROR for acquisition or !PO within 12-24 months.
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
BankofAmerlca
Capture Date: 01/05/2012 Sequence 41:9492798648
)
I .,
Bank H Endrs Type TRN
123000220 -1
y
775000092 Undetermined N
123000220 Undetermined N
41202582 Undeter.,ined N
91000022 Undetermined N
121103886 Pay Bank N
)
Page 12 of 340 Print Req:#20140521003145
..
,.
RRC
. .
... :.
Bank Nrune
002479
U.S, DANK NATIONAL A
U.S. BANK NATIONAL A
U.S. BANK NATIONAL A
U.S. BANK NATIONAL A
U.S, BANK NATIONAL A
BANK OF AMERICA, NA
EXHIBIT
6
Tim May 22 17:10:19 COT 2014
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
)
BankofAmorlca i!S>..
~
Capture Dote: 02/21/2012 Sequen<e #: 9392255435
)
)
0
I
~ ...
Electronic Endorsements
Oate Sequence
02/17/2012 7477600255
02/17/2012 009792604791
02/17/2012 009792604791
02/21/2012 009596003680
02/21/2012 009596003680
02/21/2012 009392255435
No Payee Endorsements Found
Page 56 of 340
Bank I
123000220
91000022
123000220
41202582
91000022
121103886
Endrs Type TRN
-1 y
Undetermined N
Undetermined N
Undetermined N
Undetermined N
Pay Bank N
Print Req:#2014052l003145
DATE '2. - I y- \ )_
RRC Bank Name
U.s. BANK NATIONAL A
U.s. BANK NATIONAL A
U.S. BANK NATIONAL A
U.S. BANK NATIONAL A
U.S. BANK NATIONAL A
BANK OF AMERICA, NA
Thu May 2
2527
tl111llllln
HU
~ ::
.. . ., : ~ ;
_E_X_H..,;
7
-IB_I_T_ ~
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
)
)
)
From:
Sent time:
To:
Subject:
Darren M. Meade <[email protected]>
0111312012 12:21:04 AM
[email protected]
= Hacking Code)
Can you send rne Maria's email please?
-------- Original Message --------
Subject: Re: HACK- michael fertlk connection detailed Multi
Jurisdictional Investigation & Tim Reynolds Is the other 'custodian of
the secret' = Hacking Code]
From: [email protected]
Date: Thu, January 12, 2012 10:17 pm
To: [email protected]
Cc: [email protected]
1
[email protected]
Darren ...
you are successfull sending them ONLY to my AOL account.
I tried to forward them to Maria [email protected],
can you do that directly .. send her what you just sent to us? I dont think David or Adam can forward them either.
Keep Maria copied on eveything you send about HACK reaited evidence.
EXHIBIT
8
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
)
)
)
From: Darren M. Meade <[email protected]>
Subject: RE: Deposition Transcripts
To: Erik Syverson <ll.Y.VersonCI!lMillerbarondess.com>, erik syverson <[email protected]>, scott connelly <Scoll@Q_qdvrx.corn>, ... ;;:j_
moro
Cc:
Date: Monday, 30/01/2012 10:41 PM Show: raw 111m!
Erik,
It seems my deposition was sent to a third-party the General Counsel for Ripoff Report.
Do you have any idea how this happened?
Darren M. Meade
Direct: (949) 715-1521
Fax: (800) 657-5660
Visit me on linkedin
EXHIBIT
9
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
)
)
)
From: Darren M. Meade <[email protected]>
Sent time: 0113112012 04:30:28 AM
To: [email protected]
SubJect: RE: Recordings Explaining The Plot to Kill Me and Also Planning By Rexxfield and Adam Zuckerman On The Need To Lie to Me
Understood,
Do you have a preferred format on how to itemize the tapes?
I thought by attaching 4 tape snippets and then numbering 1-4 with a narrative would be easily understood
1
obviously I missed the mark.
Let's get an approved format tomorrow.
Rill- Bit.
-------- Original Message --------
Subject: Re: Recordings Explaining The Plot to Kill Me and Also
Planning By Rexxfleld and Adam Zuckerman On The Need To Lie to Me
From: [email protected]
Date: Tue, January 31, 2012 12:54 am
To: [email protected]
when you send tapes like these, you need to itemize each tape
tape 139389mps - Darren is getting the screws to him I Zuckerman Is talking and threatening world peace.
tape -304-045uu9- Suckerman plots to blow up north america. I Roberts says he will take care of Mexico
Froggie, OK ? I dent undersland the importance of these other than the first one where (whoever is talking cause you dent
say) " ??? Is saying that you neeed to lie but not too much,
-----Original Message-----
From: Darren M. Meade <[email protected]>
To: westerned <[email protected]>
Sent: Men, Jan 30, 2012 6:44pm
Subject; Recordings Explaining The Plot to Kill Me and Also Planning By Rexxfield and Adam Zuckerman On The Need To
Lie to Me
This is a small sampling of audio tapes that will detail not only Adam Zuckerman and Rexxfield plans to have
me shot in the event that I went public, but also a sampling of the on-going plan to lie to me about the new
Reputation Management company based on silencing the voice of victims, extortion and fear mongering to
parents about their children.
Prior to the FOX Los Angeles interview with Rexxfield airing, I called Dan and Heidi Cuta. They were the
producers of the piece. The reason I called, is I began to distrust Roberts and wanted to cancel the FOX
piece because it was to kick off the new 'Rexxfield' as devised by Adam Zuckerman and Michael Roberts.
Roberts was made aware of my phone call and he spun a story to Dan and Heidi.
L Adam Zuckerman is admonishing Michael Roberts and Paul Portelli to be careful when lying to me
because if I catch them in one lie, the whole plan goes to helL
2. Michael Roberts, Adam Zuckerman, Paul Portelli discussing how to 'Bluff me about the deal coming
together because I do not trust them.
3. Adam Zuckerman explaining to Michael Roberts and Paul Portelli how he had to He and manipulate me
from resigning and issuing a press release
4. Roberts, Zuckerrnan, Portelli discuss how to keep my guard down and at 4:12 begin to discuss having
me shot. Roberts agrees with Zuckerman that a 50 caliber hollow point bullet would makejpllbldl.,!,lll!li..,. ___ ""
explode,
Roberts
1
Zuckerman and Portelli continually discussed how not only to defraud and have me kil
event I went public
1
but how to maximize profits based on fear to parents and silencing the v
EXHIBIT
10
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
This is why Zuckerman and Roberts each need to discredit me, because of their sinister plan to censor the
internet to people whom would pay the highest ransom fee,
The Goog!e-Cide as quoted in the FOX piece was only the beginning,
As quoted In the FOX news piece called Gooqle-Cide In a meeting with Rexxfield, Michael Roberts and career
criminal Adam Zuckerman a fear based marketing campaign was discussed saying :"I would love to run an
underground campaign that says, 'Google Is trying to destroy your reputation(" an executive on the call Is
heard saying. "I like the Idea of, 'the more popular you are, the more dangerous It Is( and giving people the
scare tactic of, 'the more exposure you have ... the Faster It Is For your enemies to attack you.'" "I think
there's a whole other campaign where we can break the parents," the Adam Zuckerman continued. "Send
them a picture of their kid with a gun In his mouth -- Google did it. 'Little Johnny Is going to commit Google-
clde. Can you stop It?"'
Darren M. Meade
Direct: (949) 715-1521
Fax: (800) 657-5660
Visit me on linked In
)
)
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
2
m
w
D
m
s
0
<(
a
w
w
"'
t'
$"
'-
q:
cr
"'
Feb 1112 07:09p Kairos-Meade (949) 315-3358 p.1
)
CONFIDENTI<\.LIT.Y f NON-DISCLOSURE AGREEME::";T
THIS CONJllDENTIALITYf NON-DISCLOSURE AGREEMENT (the "Agreement") is
entered into this . 11 ill day of January, 2012, (the "Effective Date"), between XCENTRIC
Vl:lNTURES, LLC., an Arizona corporation ('Xcentric") end DARREN MEADE
Xcentric and Recipient are refened to herein individually as a "Party"
c<Jllectively the ''Parti<::$."
RECITALS
A. Xccntrlc will share, or has shared, with Recipient certain confidential information
regarding Xcentric's business and desires to take all reasonable stepB to safeguard and protect all
s\lch co1rlide1Hial informatiou from any unauthorized use or disclosure; nnd
J3. The Purties desire to continue such discussions and exchange l'urlher
and
C. The Parties desire to tnke all steps to safeguard and protect all
Confidential Information (as defined below) from any unauthorized use <Jr
AGREEMENT
THERE.FORE, in consideration of the mutual agreements of the Patties and other. good
and the receipt and sufficiency of which are acknowledged, und
intending to be legally bouncl, it is agn,ed <1s follows:
I. Confidential l_nformmion. As used herein, "Xcentric's Confidential
Information" shuU consist of all information, whether in written, graphic, oral, electronic or other
fbnu, furnished or disclosed on or after the Efl:"ectivc Date, or previously ftunished m disclosed.
by Xccntric to Recipient Hnd speuitically includes, but is not limited to information related to
Xcentric's strategies, business and llnancial inl'urmatiun, and methods and marketing
and strategic plans. !
2. Non"CrmlideHhtllnformution. The term "Xccntric's Coniidential.
ltlfOJmation" shall not include any:
2.1 Information rightfully in the possession of, or already known to, the
Recipient it wus disclosed to Recipient by Xccntrlc;
2,2 Info1mation in the pnblic domain at the time of disclosure, or which, after
such disclosmc, enters into thu public domain through no breach of this Agreement by th6
Recipient;
2.3 lu!onnution lawfully furnished or disclosed to the Recipient a 11011-
l'arty without any obligation of C(>ntidentiality and through no breach of thi.5 Agre u nt
Recipient; or f/7WIa-......... '\
I Ql9111MC'i/MCII957>05_ v l
EX::BIT j
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
Feb 1112 07:09p Kairos-Meade (949) 315-3358 p.2
2.4 J n fornmlion independently developed by Recipient wi thont the of any
Conl\thmlial lnlormulton.
3. Ownership of Confidcntiallnforma!ion. Xcenlric shull remuin the sole owner
of Xcentric's Con!\dentiul Information. Nothing in this Agre"'ment shull be construed
as granting or conferring any right or lic<;onse in the Xoontric Confidential information or in uuy
patents, copyrights or otllet technology, trade secrets or other intellectual property, either
expNssly or by implication to the Recipient.
4. Limits on Use Hml of Contidentiallnfonnation. The 'Parties covenant
uud ugreG that:
4.1 Confidential Information received by Recipient shall not be used by
Recipient for any unless Xcc11lriu licully consents to its use;
4.2 the Confidential Information may not be used by Recipient to drcmnvent,
compete with, or to the detriment oi'Xcentric;
4.3 Recipient shall take all reflsonablc steps to safeguard and protect
Confidential fnfOI'Illntion by Xcentric from any theft, loss, llllauthorizcd access,
unauthorized usc or discloswe and accord it at leust the same deg:re<> of confidential and
proprietary treatment as it gives its OWl\ confidential and proprietary information;
4.4 Recipient shall not, without the priOl' written cons\lnt u:f Xcentric, disclose
nny ofXcentric's Confidential information to any third party;
5. Agreement Not to Record. Recipient ngree-s that he wi!J not make any audio
recording of any conversations between hlm and any agent ol' X centric.
6. No verbal Contracts. TI1e Parties agree that neither is bound by any verbal
agreement between them. All C011trncts must be in writing, which writing muy be by email
communication if such communication Jogally conslitules a contractunl ugrecmcnt.
7. Return ofConfldentinl lntonnation. A\ any time upon written request of
Xcentric, :Recipient shall promptly return or as directed by Xcentric all Confidential
Tnfonnution received from Xccntric. Upon the request of Xcenhic, R\lcipient shall furnish to
Xcentric a "igned ufliduvit providing assmanccs as to the relum O\" of the
Confidential Information. which is held in electronic form shall be <.kemed
d.,.,;troyed when deleted from local hnl'd dt'lves, back-up tapes, sel'Vers or other electronic sources.
8. Disclosure Under Legal Process. In the event that Recipient is requested or
required pursuant to legal process to disclose any Conlldentinl ln1ormation, it is agreed that
Hecipient will provide Xccntric with prompt wrinen notice of such request or rcquirement,_so
Xcentric 11\ay, at its OJ1lion and own expense, seck an appropriate pmtective ordep;'V.ritten
waiver in respect of compliance with this Agreemem, or other remedy to >\SS 1j\t. the
Confidential Information will be accorded COiltldentinl treatment.
.....
/
2
)
)
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
"
m
D
m
s
0
"'
0
w
<o
01
t'
ro
"
'
"
;
cr
"'
Feb 1112 07:10p Kairos-Meade (949) 315-3358 p.3
)
)
)
9. No Ohligalinn. oft he agrees that unless tmd until a sub seq ucnt
agreement or agreements between the Pnrties with respect to a business transaction has or h&ve
been executed and delivered t<l the other Pur:ty, neither Pnrty will be under any legal to
the other Party of any kind whatsoever with respect to such transaction, except for the matters
specifically agreed to herein.
I 0. Expenr.cr.. Exce11t as may be specifically agreed to in writing, oach of the
Parties shall bear it.s own costs 1md expenses associated with the furnishing, und
retum of Confidential Information and involving any S\tbscqncnt discussion and
conceming a potentia.! transnction.
11. Equitable lt is ngreed tbut mony damages would not bo a sufficient
remedy for any breach of this Agreement by Recipient. Accordingly, Xcentric shall be entitled
w seek perfonmuwe, relief, or any other forms of equitable relief as a remedy
f(lr tuly breach of this AgreerneJJI by Recipient; provided, however, that such remedies shall not
be deemed to be the cxclw.ivo romedios lhr a breach of tllis Agreement, b11t shall be in addition
to ftll other remedies nvatlablc at lmv or in equity.
12. General Provisions.
12,1 Notices, All notices required or permitted to be given must be
in writing, and shall be elleclive upon if delivered personally (which includes notices
delivered by messenger, e-mail, facsimile or overnight <Xlurier) M, if given hy muil, three ........... \
(J) c.htys utter mailing, by certifted mail, return receipt requested, postage prepaid, to 916 ,-
m their as set forth below, or at such other addresses as they may designutltby . /
l\Qtice given in with this Section:
If to Xccntric:
Ed
Xccntric V en lie
P.O. Box 310
Tempe, A7. S52SO
[email protected]
With a c(>py to:
Maria Crimi Speth
3
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
Feb111207:10p Kairos-Meade (949)315-3358 p.4
12.2 Consent or Waiver. No dteration, consent, waiver, amendment, change
or hereto shall be binding or effective the same is set forth in a writing signed
by of the PUJ1ies. No failure or delay of oil her Party in enforcing its rights hereunder shall
act as a waiver thereof, nor shall any single or partial exercise precludll <my other or further
exercise of any other right set forth herein.
12.3 Binding Effect. Except as otherwise set forth herein, this Agreement is
personal to the Parties and none of the Parti.es will have the right or power to aqslgn or delegate
any of such Party's rights or lwreu.nder. Subject to the foregoing, this Agreement und
all of the provisions thereof will be binding upon and imu-e to the benefit of the Parties, their
respective heirs, representatives, successors and assigns.
12.4 Counterparts. This Agreeme:lt may be executed in any munber of
cotulterparts, each of which one and the same instrument, and any Party may
execute this Agreement by signing any counterpa1t.
12.5 Captions. Captions and section headings t1sed herein are for convcnlonce
only and ore not a part of this Agreement, and not oo deenwd to limit or alter any provision
hereof
12.6 Constructi011 of Agreement. Each of the Pa1ties had an equal degree ol'
contr<.>l as 10 the drafting of this Agreement and the various provisions set forth herein; the mle
of construction that an ambiguous document is to be construed against its drafter is accordingly
inapplicable to this Agreement. All of ihe provisions of this Agreement shall be cons!med in
accordance with thalr plain meaning and without pmtlality to any of the Parties. To the extent
permitted by the context in which used words in the singular number shall include the plural,
words iu the masculine gender shall include the feminine and neuter, and vice versa.
12.7 Entire Agreement. Agreement und the Exhibits, Schedules and other
attacluncnts referred to heroin (all ot' which ure incorporated by this reference), if any,
collectively set forth the entire agreement between the Parties as to the subject matter of this
Agreement, and me subject to no promise, warranty or representation not expressly set forth or
referred tc\ herein. This Agreement mny not be modified except by an insti'Ument h1 writing
signed by the Pm'ly to be bound.
12.8 Severability. ln the event a comt of competent jurisdiction determines
that llny term or provision hereof is invalid or UttenJbrceable: (i) the remaining terms and
provisions herein sllall be tmimpaired and remain in full force ru1d effect, and (ii) the
invalid or unenforceable term or provision shall be replaced by a term or that is valid
and enforceable and that comes closest to expressing the intention of such invalid or
unenforceable tcrru or provision.
12.9 Survival of Representations. Warranties. Covenants and Oblieations. ;}..1! ... ,
c<>vcnunts and obligations of the Parties contained in this .. :
-::
.
shall survive the cxpimtioll or termination of Agreement. () . . / /:
. /j/}
Jv
1 4
I 0Z97 liM(: vI
)
)
)
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
"'
0
"'
0
s
0
<{
0
w
w
V1
ro
c
L
,._
u
"
Feb 11 12 07:11 p Kairos-Meade (949) 315-3358 p.5
)
)
)
12.10 Attorneys Petg;, In the event of litigation brought by ru1y Pmty to enforce
the terms of this Agreement or otherwise relating directly or indirectly to the transactions aiJd
agreements r<;fleoted herein, the prevailing Party, in addition to any and all other rights and
remedies, will be entitled to recover all of its costs of litigation or arbitration, including but nol
limited to all nttorneys' fee and taxable costs. Attorneys fees claimed undel' this
Section shall be awarded without relerence to A.R.S. 12-341.01.
Date ?. , /0 --12_
s
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
Feb 1112 07:11p Kairos-Meade (949) 315-3358 p.6
MUTUAL CONFIDEI\TIALITY AGREEJ.\'lENT
In order to pursue a potential business transaction, XCENTRIC VENTURES, LLC., an Arizona
corporation ("Xccntric") and DARREN MEADE {"Meade") recognize tlwt there is a need to disclose to
each other certain confidential information and to provide for mutual agreements to protect such
confidential information. In consideration of the mutual promises contained herein, X CENTRIC and
MEADE agree as follows:
I. XCENTRIC and MEADE mutually agree to hold each other's Contidentiallnformation in
strict confidence, to usc it only for the purpose of pursuing a potential business transaction between them
and not to disclose such Confidential Information to any third party, except as provided herein.
XCENTRIC and MEADE each agree to use all reasonable best eftorts to protect such Confidential
Infbrnuttion.
2. X CENTRIC and MEADE mutually agree not to disclose to one anothe1 competitively sensitive
information except to the extent reasonably required to evaluate the potential business transaction under
consideration. To the extent competitively sensitive infonnation is disclosed, each party agrees, in
addition to all Ute other protections provided in this Agreement, to limit disc.losurc of such information to
those members of its senior management team and those Representatives whose evaluation or knowledge
of the infOrmation is reasonably required with respect to the potential business tmnsaclion,
3. XCENTRIC or MEADE or any of their respective Representatives is required by law to
disclose any oflhe other party's Confidential Information, the party required to make such disclosure will
promptly notify the other party of such requirement prior to making the disclosure. X CENTRIC and
MEADE shall then confer and use reasonable, good faith cffo11s to agree on a form and terms of
disclosure reasonably acceptable to both XCENTIUC and MEADE in light of the circumstances under
which the diselosum is required to be made, provided that if following such notice and conferring
X CENTRIC and MEADE arc unable to agree on a mutually acceptable form and terms of disclosure, then
the party making the disclosure shall have no liability to the other party to the extent such disclosure is
required by law, provided such party makes reasonable effoJ1s to obtain an appropriate proh::divc- order or
other reliable assurance that confidential treatment will be accorded the other patty's Confidential
Information by the govcmmentnl agency, autltority or tribunal requiring disclosure.
IN \\fiTNESS WHEREOF, each of the purtics hereto has caused this Agreement to be executed
by a duly authorized officer as an agreement under seal.
X CENTRIC VENTURES, LLC
By: _________ _
RREJ;r-MEA:pE t/2_
B -/ ~ I <-2.({:(-
Name: Ed Magedson N uen M. M e ~ d e
Its: Manager Its: Self
)
)
)
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
)
)
)
Byronsumers, for oonsumern ...
Repon"
Don't let them get awayv.ith it letlhe lruil be knoY.nl rn
Ripoff Report Business Directory'"
=
() l!!lroft RDDOII
lll.verUiedu'sale
a Home " Help Register to Ale a Report a Login
Td:al Visits since 1008: 8,886,567,351 111 Estimated m:ney O::flslJTiefS sao.ed since 1900: $15,551,492,863.62 Repcrts filed: 1,864,149
BUILT FOR SPEED WITH
FAST ACTING
ADVIL ION CORE'"TECHNOLOGY
SAVE$3
ADVIL' FILM-COATED
Report #839253
Complaint Review: *NOTICE: July 13,2014:
RIPOFF REPORT LAUNCHES FULL
INVESTIGATIONIII Sac County Iowa Prosecutor's
Allegations Warrant Unprecedented Action from
Ripoffreport.com regarding Darren Meade
Posts .... Google-Cide Exposed By The Man Who
Knew Too Much, Darren Meade threatened and life
in danger -SEQ Reputation Management dark side
ted Reports !
Ripoff Reports
' John Brewington,
Paladin Investigations
, Arizona-based private
Investigator, cnm!nal
; record, who brags about
his knowledge of the
Into met and his ability to
help antifree speech
plaintiffs (always
. unsuccesSful) win their
lawsuits. Mr. Brewington
has a long history of his
own legal problems, a
crimina:! record and may
' be hiding from his
creditors Including tha
IRS, Chandler Arizona
II Submitted: Tue, February 14,2012 Jl Updated: wro,A.Jgust 13,2014
111
Reported By: DaTen M f.l.eade- Laguna Beach Callromla Uited States of
America
11 *NJTiceJuly 13,2014: RPOTIB'CRT l.AI..tOfB RLL
ltNESTlGATla'.!U Sac County Iowa Prosecutor's Allegations
Wlrraot U\pfeoeden!edActlon from Rpoffreportoom regarding
lll"ren Meade Posts" .. G;)og1e-Cide &posed Bilhe Mao Wlo twilw
Too Much, lll"ren Meade Unal.ened and life In danger 58)
Blputatlon Management dark slde
31ffl B Aip:rt. Lo::p Dive
,_,.,
Uited Sales d' Armica
11
Phone:
11Web:
B Category:
*NOTICE: July 13, 2014: Ripoff Report
Launches Fulllnvestigationll! Sac County
Iowa Prosecutor'sAIIegations Warrant
Unprecedented Action from
Ripoffreport.com regarding Darren Meade
Posts ...... Google-Cide Exposed By The Man
Who Knew Too Much, Darren Meade. Adam
Stuart Zuckerman, Michael Roberts, Paul
Portelli of Rexxfield & Matthew Cooke of
RemoveYourName.com censored the
Internet to silence the voice of victims
world-wide by removing personal blogs
and functionality of the Internet controlled
BLOCKER TV
PRESENTS
Quickly File a legal
Name Change
Ei.'9 hiM1 mi. ar
w lfflJinft fqb#m !"f!"drt
12
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
Paladin Pl John F
Bre'.' ..ington Paladin
lnVJStigalions: RiJX'f Report
Rejected EXT0Rl10\!A1E
, 0\:,inand from .klhn F.
Bre,.inqtoo- Ripon Report
rejectea attempted
blackmail refuSing to Pay
Bret.ing!m $100,COO.OO for
SJ!ence, Olanc:ller Arizona
Tile New "D:gital Extortion"
Is lhe a
Reputation Management
SEQ WARNING!
might contactYO<J next!
Ripoff
by hackers disguised as Online Reputation
Management and SEQ companies,
censorship of the Internet (google-cide)
available for hire, victims lose voice on
cons, First Amendment Rights Costa Mesa,
Nationwide Internet
*REBUTTAL Owner of company: MASS CLEANSING
*Consumer Comment: Desperate mom exploiled and traumatized
*UPDATE EX-employee responds: Here is what happens if you
word for Mjchae! Roberts and Rexxfield.com
*Consumer Comment And yet
EX-employee responds Rexxfield. Nathan Shrewsburv
bus!nessreputationrepafr com and Pmtl Portelli
*Consumer Comment: Wow
*Consumer Suggestion: Victim of FOX Slas Veqas ,The Cyber
Terrorism Grew Worse After We Contacted Rexxfie!d
*General Comment: j think this Is ridiculous. there are more
important issues such as frauds who say they are experst in their
field when there js no viable filed and they sound so stuojd
*Consumer Comment Fox 5las Vegas Rexxfield I Suicide
Because of Michael Roberts
*Consumer Suggestion: Fox 5las Fox 11 Los Angeles-
Causing Suicide By Promoting Rexxfield
*Author of original report Rexxfield Fraud Evjdence
Manufactured by Michael Roberts Adam Zuckerman. Paul PorteHI
and Ryan Page. False Police Report filed with Costa Mesa Police.
Google.Cide shakedown next.
*Consumer Comment: FOX NEWS SCAM TWENTIETH CENTURY
FOX CORPORATION IS PARI OF THE FEDERAL RESERVE
*Consumer Comment: Fraud Factorv- Matthew G. Cooke and
Reputation Defender::: Rexxfield Ryan Steygn Page. Aaron
Thomas. Adam Stuart Zuckerman. Paul Anthony Portelli Mjchae!
Ross Roberts. Reputation Management
*Consumer Comment: LOL@ YOU SILLY INTERNET THUGS!
*Author of original report: Rexxfield: 'Masters of Spin' Adam Stuart
Zuckerman. Michael Ross Roberts and Paul Portelli conspire to
ayo!d crjmlnal prosecution I Roberts wjll claim he was setting up
Zuckerman and therefore his words are not indjcatiye of his intent
Then he will claim it was Matthew Cooke whom did the hacking, I
Paul Portelli will claim he was boasting on the tapes and his words
are not !ndjcative of his intent
*UPDATE EX-employee responds: Harassment and threats by
Adam Stuart Zuckennan
[QJ 31
Add Rebuttal to thls Report CD
me rew Report
Aribitrate &. Set Record
straight
Repair Your Reputation
BLOCKER TV
PRESENTS
lEAR CAPITAl IS "A GOOD
HONEST BUSINf'SS"
COMMITTED TO
"100% CUSTOMER
SATISFACTION"
# BLOCKERTV
PRESENTS
\\VI
Buslness'sUU
lawyers and Law Finns <53121
Mljnislmfi\elawl11l
Mrira!ty&MaritimelawfW
Mricd!JI'Bila,y !2)
.AJternatiw asrue Resdution om
Antitrust & TI<Xie Re;xJalim l1l
Appeila!e Practice Cl2l
A\!a{ion & Aerospa;e (11)
Barl!:ioo law <90>
Bad!:n dey l38Ql
Business I fiN 1'232\
0\il RidJts (55)
aass Ac!icns cyn
Cprrrnerclal Law (13)
Conmn!ca!ioos 1 awm
Constitttjona! !.?.y (1)
Constntion Law (83l
Cootmcts m
Coox:rata !.?.y Q5)
OioiM Law ffi68l
OOoc& Oedtocf51l
Edtr.aJ!oo Law <141
Elder law@
ElectiooCarrwJoo & Pditical <Ol
Errineri [);m;in (5)
Errrloyee Beootjts m
Entertarvnent & Sports tm
Emii"Ormnla! I fffl l43l
family la,y (131
Aoaoce <Ol
)
)
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
)
)
r/>211.hant
Ser,iCs
VJ1oleso"1le
r..erchan!
Sei\iCs- to
ruotorref-;;:-iiPiO:{:;! ___ _
SJtis'adion In prv.idoo uedrt
s;grd!lm0S'ii10._fmXUtanl
rei\iro::1'Lf'[\c\TE R"<:o:miZ<Yi
bv Aoolf Rf.oort
s:JIB
\'J\o!('S'!.!e
r-/.e:ch'Ont Se,">i!hsrrffiBSFN&rv
attf:mQI
IS3.Jc..,snuidk VJ"Jdcffife
r-.'hc:hant Semwsrr:soonlz._'CI by
R[.{)ff Rer.o<t as a SJre
()',r1
ID1.m
0J1(rll8'
SaHadion
O::>rnnitrr<:nt
ffii'.1nq
r:wnenlr.,"'CBillno merd1anl
e-xount needs of sm!l to
Sze btJ,jn8=s. 019Pat
toa.Bc;mw f'l
j'ernoloyw
Rew.:miz.;.d b'fHoolf l9._,"'.ffii1
0::>'l!Q@'e N.v.:Bw Proor<lm as a
:{e bu'i n;os; s::t.!)im -
aii'.8\SfB3J!I'El OO:i
j_,'WBs. fe-B! %'1: &
.:F.-illffii'J1Ecn cf9inq
Ole Pa-t rr.o:>q,Yz!Cd !;r{_B'22
&!:;Q,rt Veiifrt-d'" as a ffi'"!
br.Einessrer,foo.
' I" ''''''" _. . ' t!do<c,Uy.
ID1ill
Evo!\:g
1,\_-.\orr.\Ues
lh---di cate.;J to
tvlal wson1ElrSl'i9'adion_ No:.v
lnncrt<>iiw techooloJf_ Evolve
es dc,d;mlul to aea:?ng
h,peref!ici0l! lonoranon
c;:'fonl;#e rrdott)-des& s:oole;s
E-.'011--e <?'ions & rnarlUI2ctlJCB!l
frec--1!1c & h'br1d oelc;<:tic vehides
E\Qive
F'<cmeQ.!i]_Jon Bnd OdoflB'
U1al ts the
@'eslhem
\',1-r...Q
l-..EiflC"S Evlli:,}J __}.!ij __
fL"O..:qnize.;!__b:lf;)__QQ:_'I_!fl:.9_,j
S'l'eMnes;
ir>ioo
/v',eade Posts.
NOTICE July 13, 2014: Ripoff
Report Launches Full
lnvestlgationll! Sac County lo.va
W.?.rrant
Unprecedented Action from
Ripoffrep:xt.com regarding Darren
R'jX)fiRepcrl.can Wtt Jrr.estigate ategatioos
p-eseoted In a 124 page aflida\it by Q::uj;y Prosectta
Ben Snith of Sac omy -- Snith .,eged"""'
penalty of peojuy that l>mn Meade- mJ jXJStOO
tase rep:rts oo R'fXI!ReJxlrt.can ab:xt at least b.r
spedfic lfRifXI!ReJxlrt.can's l!MSUgatioo reo.eas
that IDf ol the Slegatioos ll'IErle In arJ PJSI ab::llA: those
Yritnesses cortcin false olfact. the tase kts
Yrltt be redacted tom tOO posti()JS. 'We W!l get to the
OOI.tcm of Ben Smith's allegalkns ard the
e.ldell:e m:1 coo:::tusloos: states R'JX)II' Rep:xt Edt ex
mJ FOUlde< Ed Magedsoo. lcooUrued bei<Mj ....
Report Attachments:
<-Is this
Ripoff Report
About you?
Ripoff Report
A business' first
line of defense
on the Internet.
If your business Is
wiUing to make a
commitment to
customer satisfaction
_C]Qs_hf:LO now ..
O:les b.JS'Ile$haw a bad
_,
Axltlhed{tltW<rJ.
Coroorate @oeacy Proqam.v
Authci O:rn:o Mea:ie's \'>filings (some ofv.Hch a-e In Uls !irk lisO
Proo Meade) chaleoge the fairness and credibility of the honickle lmestigalioo, trial,
rruder C<Xl'Jctioo, ao:l slbseq.Jeflt lreatrllEflt d lo.\a rrd.her Trncy Retter at tOO hands
d O::u-ty Prosecutor Ben Srrith m:l Mchael R::.tts (Rexxfield), Tracy R'chtel's
former tusbaOO. The Prmfcos o:xnty Prosecutor had declined to prosectte RichtE",
v.ho dams to ha\e beoo acting In derense of herself and her child'en against
attack en; v.heo she shot at ll.Jstin Whede d.riOJ a hane lmasloo In Deceoi:let" of
2001. Ed Magedsoo had been carJnced by Meade that the shcding was m::rally ao:l
legally justified and that M lmxent 'M:liT'I<Y1 was irrprlsooed
Wlile Comty Prosecut Snith's affida\tt conl.<ins certain locarect assertloos ao:l
many material orrissloos, It a so raises sane shocking facts, sutlicienl to justify a fi.JI
lrr.estigation by Ripoffi'ep:rllnto Meade's assertioos and rncii\otioos.
R'p:>lfRep:xt's lnwsUgaUon Is an actloo b"the ccost..mefwebsite.
Ripolf Rep:xt accepts reports Iran aJth<n< v.ro C<l<tlfy the hooesty of the cooteot of
their rep:rts, ao:l eocou-ages rOOI.itais to JXO.fde readers vJth bd.h sides of a disp.rted
stocy. Geoernlly, R'JX)II' Rep:xt ailoM> the p..tiic, the ccuts or an lndepeOOent f:rbitrntcx
to JOOJe the tnth aOO OOes m 00 an lmestigatioo to stppemerl a chal!erge p:lSiirgs.
Gathering e.Jdell:e ao:l passing Judgnertl. oo tOO statements d cots ide auth:xs depcns
fiom Its stao::Jard JXQCUce.
Comty Prosecutor Sttith's aooressOO actions justify extraon:finary meast.res. Srrith
oot oriy states that Meade's fach.B allegatioos &"e tase, he asserls that thE;y
\!date kwa's crlnind la.w ao:t that Ed Ma;;Jedsoo kn'J.Mf\lly coosj)red Wth Meade ao:l
ct.hers. Ed Magedsoo did no soch thing.
Comty Prosecutor Snith has used the ldl JX1Mlf of tis elected dfice In altefTllts to
crush criticism cltis prosea..tioo aOO he has relied hea\liy oo acMce, lnfoonatioo and
g.JidMce fran Michael Roberts, a kOOMlliar and extatiorisl. Roberts was IOO'.d
In a scheme to megary hack the RSX'lf Rep:rt v.ebsite Md ROOerts atlerJl)ted to sell
lcloonatloo regaro;rg the hack to Ripolf Rep:xt for 105,000.
As a 'M!bsite dedcated to pu.idrg a \Oice to the oorrm:xl persoo lh'to;jl open
lnformatloo and free speech rights, R]Xllf Rej::at asserts its O'M1 \dee oo trose matt em
ct p..tiic lnlerest and cax::em, and flEdges lUI lrr-.estlgat!oo of the Issues.
/1$ progress is made v.flh ourirr-mtigalion, it \\\!1 be posted hem as an UPDATE to this
G:Mmmeo! (14)
Go.emmeo! Cortracts l2l
!rrrrimJljoo 1482\
lrdaro & l'!:!tr.e poo,ljilloos m
kwM:;.e tool
!liliiiC!u.:i Prt::fflrtY !5261
ln!Arrnti<ffl taw (33)
lrtanati<x\31 Trade <Ol
!olflf!'let LaNm
fmeslmerts l1l
L.aOOr & Errd(MJ)AQ!; 02\
Legal Womctfce 92\
Utigatim 20\
Meda Law C1l
Medical MaOO!C{ica (131
Mergers & /l.mjsitlons ffil
M!i!!Wl.au(5)
tflt!IBI Rffi9! rces om
Qxpetj@ Safety & Hedth {Q)
Persooa! lrilKY (8421
Pn:xh;ts U:Dtitv f21l
Pfess!ooo! uoomty em
Rea Estste t361 l
Seruit!es 0001
Taxatioo 11421
T!rlv'dooy & Scleo:e (Q)
Toxic Torts (Q)
rrrosrotatioo <2)
Trusts & Estales 13681
'Mjte ())liar Dime rn
Wills & prota!e m
Wqkers r..c:.rneosatioo (242)
Zorioo Pfaocioo & Lard Use l1Q)
leaal Servlcesf32)
ArtltmtorsJMedatqs m
Autorrdiw Expect INjtnesses (Q)
Ball Brods (Q)
Qut Rerq1em (1)
EIEctmric J:B!:a llsoo.ecy l1l
Expert INitnesses m
forensic Experts m
m Selection m>
L'ga! Assls!a.js (8)
!.ega! 5sx:akem f2l
U!irlfll!oo S! qxxt (2)
Medical Expert Wrtnesses m
Q!IDW
Pata!eqa! 151
PIDB!e Jmesliqa1Qf5 f6l
Process Smers m
I rros!atqsllntemretem (Q)
Miscellaneous Busfness Services l19)
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
.B-1rtf..ve
Bl8flton fl_,
34203(9411
75%9721202
GJr<Avfl BIEi).!Qrl FL
!Lnall
th!efsi W.!llhisoomoOOYJn
lv&nltor;.Q(i_datohe1Q
tlisoorwam and they
rlooinq oooole off md the'fHCNer
[>:'I'd JTl';! ororoave the people
ITl\'Jfl\l'l they M t?OE<} off pi eaOIJ do
the right th!no do
tlle'/
f'"e vr:ldorthem and 1
fnewit I%SI'lU<l9 Ell&n!oo
Rorlda
ln!Bmatiooal
Founda:ion
M!mal 8udd1
&-,,NY.odoameat llB!/ t/;chele
&v.'.n. John Wllian-m<l A<Jlber
Ctw..:;choo Omiti Jean
l.'<d:ie l-t'll>"e'tAIInlBndiQili,1.
K!!CBn O:lle Lorraine Pike .9.1\ill
E;OC-0;.1:= Calos IY!!XO
Fr:Jud Pla...][adj;ed
""""
>loo'}{ira..'BTJeflt
J'.bn.!ch
!o.'ctcr..-l!lli,!ll
&tinson Sole
QQ_uipment
[romm1
!:Chid a ar.d LftliTlroid It /0(__2100
his fix and
ooth!oh ToooY<> 1<8nSJs
nl9 in octler\o deal duoe to
S 1 00 000 in WITllllisoionsAuSi n
GAIJiN
entutalnment
O!J1erol
o-'lmeo!;\.'Jr
CbnAictWN3S
OF PREYAPAO-E: A!R
N3S!>U Tand mamoth<:1S.. I WJS
lBnn<1 for nanhl rr.:>nq rot
rofunded Lordm LK Jn:eme!
l,\'fltf$ld
fr:l-___6-o!OF
QJ'Nllli,n
1-.l.._<;q::l_I
Qio.ifed
statement.
NY.v to the original report that v:as pc<Sied ...
MY NA.ME IS DARREN MEADE, MD I Nil A DEAD MAN. Q so I oos tdd v.hen l
refused to go dex'9 Wlh a so.cd!ed rep.taticrt management plan to use
v.eapons.gOOe hacking lechrdogy to hap frao::lslers, q;ocks, and ether sct.I!Tb:lgs
ao.dd being expoo,ed OOina.
DmnA-t>ede,
Imagine: Yocire a successfli cosmetic suyeon ao:l a patleot des In ycucae. It's a
temble tragedy, blt yCJ.hJ g:i to llXl'.e oo. Tw yeas later, c::c:mparts ab:::Ji.A. yeo begin
to sllface oo the constmef ad\ocacy 'Mlbsites, c:tages that yCJ.hJ ne\f l::'eefl
accredited as a pastic suyeon, J-dd oo sU'jjcal designation, ao::l ha\e no OC.Sj)tal
pi\lfeges all ofYA11ch a-a true, CI.Aminatingln the State medcal OO<rofindng yeo
"irlcoo"pel.ent, dsJ)'aying "dsgrnceU, cr t.f'llrdesslooci. coodx:t In ycu
care of fiw dffereot p:stierts, lnclOOing the 32-yea--ci'd rrxXher yoo left dyifl:l In ycu
reco.ay rtXm \'kite yeo v.ent oU. to dime:r. The cb.wMm:i spiro! accelerates v.hen the
lnfcmlatioo tits ao::l consequertly, page 1 cl Gc.oge.
Whafs a quack to do? If yOOre Behnaz Yazdanfatthe red-life Tcxorto
tturb nailed aba.e you cootract v.ilh Micha4 ROOerts and the rep.rtation rnooagement
specialists" at Raxxfie!d & llink Basis v.hoolferyouaYMf to net just ruy bad JXe55
oo the search erg!oes, lxA make it dsawea- COI"Jlietely. As In abracadabra. Presto.
1-bw do I know this? Well get to that later. The bigger question Is, tx:mls it eo.eo
p:>SSible? In geek-speak, it's cd!Ed a SO..Irjectloo hack. ll'is s:ertictlor\eriety oos
created to 00 a rtJfl"ber rlttirgs, lnchxing the de--lrxfexing (Ndng) cl specffic pages
from seach engines.
So v.ith the click rJ a bAton,
the meddlesome
f?.e!:OOs D'. Yazdanfar blaned
fcr a ffi% drop In rEl'.EO.Je v.ere
gooe. At a pice tag d
S1B,roJ, the rnaJ!c sOON cfidn\
come cheap, rut the tn.Ah oos
far m:xe expensOO. Fa
COOSLJ"'OfS, It's oo frootal
assaUt oo rut Rrnt
Amoo:lment rl{tt to speak the
truth; f cocrparies like
Raxxfiekl, It's a \efitable gdd
nine. A b'eosic audt rJ
coofinned
lh::lusands d lrd\ld.BI rep:xts
v.ere S<X.If1eclloo
attacks. Were a!l d them
cn:d<s v.ilh deep p:x;kets fr.
Yazdanfal? Perh3ps net, 1M
6\eO the C()OS!(\Sti\e math Is
staooering.
NJ matter hoN yoo slice lt,
there Is a lorg line of pecpe
v.hov.!ll pay hardsomely fcr
their VMl prOOte kill-sv.l!ch on
Internet free soeedJ E\ell so,
Jhls Is a (ilo cl 'JfXIf19 mxher M1 wife Krista SU;fand ...00
di&d a1 thiJ hand cl O; Behn.u Yamarlarcl Tcrorto O:ts<ro1ic
Oinlc. Krista rraslelltodeast>; Ya.Wadw\Wft lodmer.
0x1s:arots and patients began to W&1l othf::ls \fa Rpcif Fepott
and It caused a 5/J'/o drop In teYenUe to herself M"ilhe Tam/o
Q\srwtic D: Yal!ianfarhlreda 11-t>b"n>sterfmnThlnk
)
)
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
)
)
I
I
JJn Buckakl
Vocal P.\laJ.a
ilocalradio a\a
Jb'sPiaoo Bar
ll=hin;<::ltJ'I
l&,_fi\2'2.l:\.lQ_QXno! 2__g,rYce
J:>ollo/Mt;',i.1
f:.:Lf-Rl00
1
LED 24H{ MCBILE
PESt;;t. &
TO'.'NX324f-R MW!LE DESEL
REPAIR> & TONNG Sle-roo
lmo"?rc;!o P00cille. Q-,Ms
!@J:j_QD_
'fi.WI?A___t-B\KBII..E CO'___A\Y,',\12.1!_
Arneiym Qr_-&d Fraud $c'?.rn
&even
.<':LH31Jillll.!OJJJ;ro.
&
..
rnr.sooherrriller1007\2.'il:nrnail Q
Ci
dviotoohem"iller-\351 on
lhlf!h.<r:>ld frullQ
tb'..ada ln\emet
RepOrt in the Pkdia
E
&oofff-\&oortoo
CBS 19
.
.
fJ..ety go::x:l mns deaer krlcN.-3 Ba9s8t'ldp<id S18,00JtoFex:&eldlnM!ertoptltil&e the
If 1M fl'lM<et lsnl t:ig erxxJ{f1
(aod it re.er Is), you M.e to hacXlrio800deleteCCf'11ialntsfitedooRpotfR?pat
create rvmooes. RexxlieM
has a plan kY that, atAomated teclvldcgy to generate defamatay <Xrlent ab:xJt
100\fd.tals and oxporaticos that \Blue their repc.A:aticos the llooer the tetter. We're
tdkirg at:oot a v.tde OON stran ciVfl.IDs d mass defanatioo. ltiri< atnA it:
INhat If al!egatiors cl ped::lfh!Ja v.ere to J:q) up the next time you C3oog'e yocr name?
ex cbsceoe stories alxxJt "ycu dalJJH:er? 'Nhm we'mtalklrg aOOut the
p:Xertlal ruin c:A yotr ca-eer, yocr mooiage, "yotr cli!ds fU:ure, m:xle'f Is oo ct4ect
ood these predators kro.vlt. Wheo the time Is rlg-.1, you'll get an email and it11 be
Rexxleklto the rescue Mtid::te in coo hao::t, artiYax in the other.
WHch l:rlrgs us bock to the qJeSUoo, hem 00 I koo.v all c:A !tis? It's slmpe: I was in the
rron \'Ji!e the Pot was tang hatched I oo.v koo.v and cal proo.ethat RexxfiE4d isn,
Just anctOOr repU.atlco at C<XJllOOY: It's a bonafide crimina eoteq:rlse
fin<n::ed ao::l cortfl.1ied IJt a oorrJcted felon IJt the mood Adam Sl!m ZJJCkemm_ a
ttl.lg rureotJy w.aitirg seoteoclqJ fcr tis rde as mastemind-tl..JtOed.srltch in
ni!!joo ro rmeot leas!oo scam.
I was recMted as theCEOofao:::thet ZOO<errnao-o::rirdledentity, Progeoox, tom
vkkh he errOOzzled the txxfs to acqUre both a iniElSI in Rexxfield and the
rlgtis to the SQI.. irjeciJoo cede. h IJI'Yelated rehS, the Mckerv.h:>v.rol.e it
Matthew Ccd<e was the b'aln b3Hnd Rernq.e)'ooNama.com That Is, urtil he sold the
d:.xr'an Qs tOOt all?) to the Voel-mearirg kllks at Repttatloo.ccm (Jawwr OM'!
coocJuslons
'v\'"heo I tdd Zockerman I y,ajd nd be lmol\ed, I was offered a slx-figxe tribe and an
eqlity stake In the \eflture. I ctose q:.tloo B, lenderlrg my reslgnatlco. Shortly
thereafter, 1 recffied an arlo recon:foo v.hereln luck.emm and Rexxfie!d cpemti\es
describe !n rreat de! a! tOO efix;!s a BJ cdi!xJr W!et wlt ba\e oo my txa1o should I
\el" !P p.iiic v.!th ttis ln!O.matiort I suwooe it's nildy arrusing arlo if yoo cal
lgue the fact that it's cooing from somecoe v.ith a tistO!V ofglrrioal \ldeoce
too<, I ko::m I coo, yoo to take my w.xd br all ttis, j:Miy because Ztclerman
a1d the Rexxfield garg hme d<eady made good oo their fiffit !hoot to destroy rrr;
repU.aUoo cOine. Go ahead C3oog'e my name. It's m.Jd If you <kln, alreadf ko::m me.
But lilfaturetely b" these 'PfS, their death t/Yeats wen, the OOy tling I ha\e oo tape.
I ha\e the t\'.o-hcu" Rexxfield strategy session v.hem dlckennan proposes OO.V they
can ext crt parents a.er their kids' futures. Here's a taste r.l 1001; sempn. I also ha\e (N<:t
20 ai:lltionallu.rs d I"E!CQI"((I"lJS all cooseosuallhat tie the ertire cperntion t()JE!ther.
They're OON hosted offshore, beycnd the reach of Zlx:kerman's gxflaltomeys, t:a::ked
v.!th detailed lnstnx;tions In the e\efll. of my 1.11timely demise.
nus IS A CALL FOR HB.P.I am litetaly plAting my life on the line to expose net just
another lrtemet scam, !xA. a tiYeat agc:jnst the 'Bf fabric of OU" society: The rlgit to
speak the truth and be heard. I crly hq:le scmeooe hears me befoo3 it's too late.
The Art! de Above & Cooynents Below Am My farsona! Opinion and News
Copyright Notice
/JJI audio and Images used here In are In accordance with TIUe 17, U.S. Code
section 107.
Purpose: CRITICISM, COMMENT, NEWS, REPORTING.
The fUI Goo:J!e-Ode serrrpn Is <Milatle hero llis ooosensW reoordrg was made oo
1-28-2011/n Costa Mesa, Califorria. Michael Pllberts fd!oMng Uls rooeting sold 60%
c:A and li!fils to the hackirg cOOe to hi<rn Stuart Zuckemnl and Rym
Ste.en Page.
The \dces In oo:1er of aweaa'lC8:
1st \Oiee AdM1 Stua1 Zock1"1000 (oo super.ised release kt Q::Erotion Lease Reece}
2nd \dee Ryan Ste>.e1 Page
3cd \Oiee Kirk Mcf.Jahao (on supeNsed release b" Operation lease Reece)
4th \Oiee PaJ Portelli (Rexxlie!d
ffil \dee Michael Ross ROOerts (RexxfieM CEO and FOll'der)
In oo:ler to end the ceosastip of the Internet and rettm the \Oiee to \lctims y,ajd..y,!de
affected 1Jf this tack exj)icit det<i!s locludng coosflSw!ly recmled au:io d pamirg
sessions, ernai!s, slg-lfXI o::rtra::ts and the hacking cOOe itself Is 8\Bi!ab!e to Mf
\erifiab!e reportef".
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
Sec more videos f
l
Special Features i
f
ThM'Jf
I 'I"'"
'
SlV8S ili()(G
Ths rEp:l't was m Rp::lf 02/141201207:48 FM<n:l is aperrrmertn::o::rd b::a!OO
We: ltl.pJ,\w;W .rif;off rep:rt
N/ffiTG>. n:::N-Sa::-O::uJ.'y-bN
sOO'reLooukB "1VOCE-JJ';-13-2014-Rf-Rrat-1..8tl"'clo9s-fu'-111est'ga:.ffiSa::-O::o-..'y-bu a-Ro-
Tt.eros!OJ liTein.:k<l!OO isArizcm Ariz em deBs rot 00selveda'fi'j1 sai"-'P so
tJ-e JXlSI fue ll1l'/ be Mui..<inor FOOfPCdeper.dngoo trefua ri yea-.
RIXff Ro,xrt Ius a1 exclusive kense !ott-is rep.:rll rmy rxt bacqjOO witt.a1 !00writ1oopcnliss:OO
ri R!Xif Rop::rt
Oick Hem to read o!her RooiJ Recqts oo *OO]CE .Uy 13 2014 R!fqf REPCff[
LAI..t>O-ES FLU Sac Co.rty leMa Prosecutoc's Al!egatioos
Wa7oot tiP'ocfdfyfedActloofrrm Bpdfreror! cqnrtWJioo men Meade
Posts ... Gme-Qde Exm<i.fd By The Mao WOO KnEw Too Mu::h PFen Meade
ttrealeoed rod life In darqec - SEQ Reo! -atioo Mamgemool dark s!OO
Search for additional reports
r yru wo.jj &a 1o see m:re Rp-df A:lp:rts oo tis cmpa-l'ffn:ivklel, sedJ he.-e:
Report & Rebuttal
Respond to this Also a victim?
report!
Rea Rebuttal Q) Fie a Report (1)
Arbitrate
Remove Reports?
th! Better yeti Arbitrate to set the record straoti!
Repair Your
Reputation!
Get started Q)
FHl.JTTALS & RRE5:
Updates & Rebuttals
9.2 (:)_Q 9i1
AJ.Ji'a Onsmer hPote&'ONOO'
#1 REBUlTAL OMlor d ocmpany
MASS CLEANSING
Aurn:R II
That Is v.hat Uls oo..rty and ttl's ca.nty alcoa neEds. Fock tb'th Korea and Dina
It seems to me and my igloolot nilld that this v.tde time they 00\e it <bMl cocrect.
NJ teeoom a religion. NJ fieedom a speECh. Let alone ha\.e the chance to spi*lk
bady Qf exjX'eSS a negati..e oprioo alxliJ. !heir goo.emmeot.
U.S.A= Freedxn a .... ANYTHNG? I call BLUSHT. Money mll Wj yoo ITJI'Xe
roooey, PQMlfbiA rll'JS! lrrp:xtartly respect lcxlks tikewe\e sdd 00. dJrrb.ed
doMl arrl sdd otr diglity arrl roorn!s \'kite at it.
EVERYCX\E tBs a plica tag and the lich kn:mit. E\ef]'cne is ttngy ..... no,
they're PARO-EDarrl dyinglxrrore mooey arrliTJI'Xe mooey orly tosperd it at
oo lhe next iPixloe Qf internet us:grade to speed q> their OOYiection. case, it
looks like they're tllrsty to dear their name. dear their l:us!ness Qf peffiaps sa..e
their fanily member rom ine\oitatie sliclde OOe to their bad decisioos and rrisacMse
g<Jdaoce.
Where ND v.h:> lhe fuck are the pecpe Ytith gcx::d heais ..... ? Gco:::l m:::ti\eS still
left In their dyifYJ hearts. I mean really there's a lot a peq:ieYtith money cut them
sitting back and erjoyirg thernsehes Yohile lhe ....OOd they li..e In, Is lhe SM"Ie vilere
these atrocities ae goiiYJ on
rm cmare that life Is mfust l:x4 lhls Internet "thing" is really gettifYJ out of hald. llis
Is looking as lflhe U.S. stx::uld be lhe next l'bth Ka-ea aoo cc::olrd lhe rnedajust a
bit JID"a. Control us just a bit mere. Cootrol the roo:t we consume just a bit more
andleaw us toha\e a peaceM death, AT LEAST.
Can you /00\e us that m.JCh??
A peaceU death.
Report Attachments:
Respond to this report! File a Rebuttal (D
)
)
)
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
)
)
)
Desperate mom exploited and traumatized
Aurn::RAshleytbrwood 0
lrrajne krmfrg yaxcoe rod crly soo vas ge(lirg seo.erely t:Ulied a1d finally
bel!e.lng you bJOO the sdlA!cn I v.es desperate like 001 cther room, the Wlyirg
almost sOO:Jeriy stowed after me aOO my farrily begal to pay ttis repltatioo
mar<lg001enl """l"f'l'. m my"" w"" ramJy """""' u-.n gateU tor ,.po!f
Pep:xt because v.e VIOOd 1'\3\e ne\ef 1<ncMn V.OO these peq:ia rea1y 'M:m We
fioolly C<.Ylimted tt'is repltatloo mar<lg001enl mafia v.ho tdd us they co1d slq> so
much ard I let them kno.Y v.e were gdrg to the pjice M:t they y,ajd stU OOt.n
treir PJ1 fNMYW> bel-loom. \\hEre they bela'() ..-.1 rellsit al thalr
clierts.
Wltl"oJt Risxif Repcd v.e v.Wd be cOO.If'l.Biy Ell"'tanjed In tHs cyrical, nttiess
ard absdliely hoo'eOOcos 1harl< you b" exp::lSing them a1d c:iding true
jwlice, I YIO!Jd !le\ef \'ta'( M:Xhef rrdhEt to go tm:oj1 Wlat me a1d my family
v.ert tkol.gh egan
Respondtothlsreportl neaReb\lttal 0
#3 l.PO'.lE respoods
Here is what happens if you word for
Michael Roberts and Rexxfield.com
Aum::R p)'ihrlas (lhited Stales of America)
8U:::'.'IIIED :qC>J. 2)13
I Mchael Rcterls, and used tov.ak fa' tim lean tell
yoo b' a fact that he v.as neo.er an frwstigatcr v.lth the ASIO, ard has ro degees,
orsctroirg In his area offcmlslcs. And e\ellv.ase, the mao has
mertal dsorders crlrriool cyber hackirg, arxf he \l'ctirrizes AU. his v.akem bf
makirg txg premises, falir.g to keep them, arxl then tlanirg it all oo them to stat a
fi!#. E\edually they aU p:yt oo bad terms v.ith him.
There's lots d proof d this <rline . ..kJsl go to Go::l9'e Md type In "Mchael Rcterts
Ripdf' cr "Rexxfield.com reJ.rms" and yoo Mil see the f'lJl'T'I9fOOS tnror stories and
abcot ttis ITBl, as v.eU as d tis Illegal cyber hackirg acWties
and frrp:nonatloos d others. l-2re Is one, if this site Wll Slo.v me to post It:
h!to:lfwml foxoem cqrVtecti2Q12101f2!Yoocx1e-c!de-ojjne-rgxAat!wmooaoors-
c;nyjpe-fnxn-y.Eb'
l-2re Is \\hat trawans v.heo yoo \\Ofk br him:
Ha \'All dfefyoo a wry generoJS salc:wy and eqUty In the begmlrg dyCU'
errpoyment, v.hlch he NEVER AOO there we sane BIG catches yoo \'All iird
ot.t later on that \'All til yoo nx:ieiy:
1. Arsl, yoo ace OOTaiiCMed to ask him MJ questions abcot }'Ollfw::xk In his
rrird, yoo shoUd knON\\hal toOO\'Jtlu.t beirg asked, v.tich Is absdtA.ely
In his eyes, tis fal!ts ace dw<rfs YCXJRSI That makes w:xf<irg fa'
him a rx>\'Jn situation g..aaanteOO to get v.a-se, because if anythirg ha
vJII use yoo as lis scapegcat and JXIrlirg OOg, pi rUng tha blame oo you. As this
goes on, he \'All amass hatred yoo v.tich v.ill crly get v.oo;e and v.oo>e U1Ul
it reaches a breaklrg pdnt. That's Ykrf EVERYClf'>E v.ho has e.er \\aked fcf tim
has left v.ilh bitterness, arger and reseotmed for the wey they v.ere \lctirrized l7f
him UYoog1 rx> faUt d their OMt 1\e seen lh!s t.awen many limes.
2. EWI)' HtUe Uing yoodov.ill beinftatedand used against yru Yoov.illlileraly be
'\\a king oo eggshells" so to speak. It v.ill make yoo t.nCOr11krlal:ie and nEf\OOS,
v.h!ch v.i!l oriy rMke tlings v.oo>e and jj\e him m:xe reasm> to spte you. At scme
pdnt, he v.m be filled v.ilh cdd 001Smlrg tatred for you. Yoo v.i!l see It In lis eyes.
Then he vJII treat yoo like stit, kick yoo MX.JOO, break tis prorrises, be
dsrespectful and nxJe to yoo, or jusligue yoo and wake coo:iticns l.rlbeaable b"
yoo so that you \\ill be forced to qtil. Ole W<rf or aocther this breakirg pcint \\ill be
reached. Ewn if yoo ae a rice Innocent aoJe1 v.ro Is reliable, res!X'OSitle and OOes
oov.rong, this v.ill t.awen to yru It's g.a'<MlleOO. N:.> cne has e.er been exerfl'(
frcm tHs nasty ootcome. 1\0 eN: I N:::t e\00 a catboo Wi'f d Rt:berts Hmself
\Wiid be exet'Jl)l, and thai. shotld tell yoo a lol.ijust ask tis son v.OOm he placed In
an lnstiMion) 1\e seen it h3ppeo rrooy limes.
Basedoothese catches" aOO.e, vkich ae m:re like a Trqan Hctse In his
pronisirg generrus dfas to you, there Is oo questioo thai M". Rlberts roost be
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:11 AM SAC - CLERK OF DISTRICT COURT
IN THE IOWA DISTRICT COURT IN AND FOR SAC COUNTY
STATE OF IOWA,
Plaintiff,
v.
XCENTRIC VENTURES (DBA
WWW.RIPOFFREPORT.COM),
Defendant.
Case No. CVCV019540
STATES RESPONSE TO
DEFENDANTS MOTION TO
DISQUALIFY COUNTY ATTORNEY:
ATTACHMENT B EXHIBITS 39-102
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:22 AM SAC - CLERK OF DISTRICT COURT
IN THE IOWA DISTRICT COURT IN AND FOR SAC COUNTY
STATE OF IOWA,
Plaintiff,
v.
XCENTRIC VENTURES (DBA
WWW.RIPOFFREPORT.COM),
Defendant.
Case No. CVCV019540
STATES RESPONSE TO
DEFENDANTS MOTION TO
DISQUALIFY COUNTY ATTORNEY:
ATTACHMENT C EXHIBITS 105-178
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT
E-FILED 2014 OCT 01 10:33 AM SAC - CLERK OF DISTRICT COURT