At the same time, James Patrick Holding has proven himself to be an unconscionable liar in and out of court (yes, that means I am asserting as fact, not opinion or satire, that he intentionally stated falsehoods in court while he was under oath, so that if I'm lying about this, it would be libel).
Since Mr. Holding's butt-fuck followers are so quick to judge that my third libel lawsuit against him was frivolous, I now offer that Complaint in full.
Doscher v. Apologetics Afield, the third libel lawsuit.
Download here.
my email address is barryjoneswhat@gmail.com
James Patrick Holding's email address is jphold@att.net
UPDATE February 1, 2019:
Mr. Holding says:
Well, I gave Doscher every chance to drop this nonsense and leave me alone. All he had to do was go his way in peace and let me go my way. Instead, he filed a 97 page complaint with 41 charges of libel per se and demanding $450,000 in damages. Fine. As I told him once, I'm not playing any more. Absolutely nothing will be spared this time around. He'll end up dealing with me, even though he thinks he's being clever by suing my dead ministry org. News will be posted here as it occurs.See comment section here
I'm afraid Mr. Holding is mistaken. I had no interest in simply dropping my intended third lawsuit against him. Perhaps someday Holding will stop deluding himself with the lie that I'm in any way "scared" of him.
If you are miffed that I filed a third libel lawsuit against Holding, and you are "sure" that I've falsely accused him therein, do what would normally be expected of somebody capable of arguing in fair fashion: State the pages and paragraphs number in the Complaint for the accusations and legal arguments you think are false, and state your reasons why they are false. Otherwise, if all you are doing is imitating Mr. Holding's irrational juvenile delinquent crying-fest, such as he or one of his followers did (see below), I will have to make a decision on whether a reasonable mature adult would or "should" dignify such childish outburst with any response, and I might decide that because such outburst is trying to "bait" me to say things that can be dishonestly twisted against me in Court, I might decide to avoid responding.
Or if you are too much of a pussy to confront ME with such argument, be sure to email Holding and give him any advice you feel would be useful to his defense. That way, when the jury awards me substantial damages, you will have to live with the fact that when the world's smartest lawyer was sued for libel, and was properly represented by his own chosen lawyer the whole time, and was constantly advised by his various friends around the world, he STILL could not prevail.
Then afterward you can consider making "why juries are always wrong" the 28th book of the NT.
For those who are wondering:
I am quite aware of Mr. Holding's pretending I only sue his dead corporation because I'm "afraid" for him to cross-examine me personally. Mr. Holding is mistaken for several reasons:
a) this contention of his logically implies his fear that his own lawyer will not wish to attack me with all the "dirt" on me that Holding wishes to attack me with. Holding might wish to seriously consider that the reason no actual real lawyer would wish to grill me that much is because the legal system simply doesn't allow, for purposes of justice, what Mr. Holding's entire life-purpose is built around: slinging mud. But if Holding is confident that his lawyer will grill me about every piece of allegedly credibility-impeaching "dirt" Holding wishes to throw at me on the witness-stand...then what is Holding complaining about?
If Holding's own chosen lawyer does NOT grill me on the witness stand with every piece of "dirt" Holding wishes to grill me with, will Holding publicly assert his lawyer's disagreement with him makes that lawyer a "moron", the way he publicly asserts the same about anybody who disagree with him?
I'm guessing "no".
b) I hereby give notice to Mr. Holding that he is advised that while his lawyer prepares notes and evidence to impeach my credibility during trial, Holding should also prepare, starting today, his own notes and evidence so that he can cross-examine me personally, without his lawyer. If after the close of discovery and at any time before trial I decide that most of the libels alleged in the complaint were the work of Mr. Holding personally and not in his capacity as director of Apologetics Afield (very unlikely since the Complaint provides good evidence the libels were legally the work of the corporation) I will file a motion to amend my complaint, seeking to drop "Apologetics Afield" as Defendant and replace with "James Patrick Holding".
That way, when trial date arrives, Holding will not need a lawyer, he can represent himself "pro se", and will therefore be allowed to cross-examine me personally. Gee, I'm really scared of Holding, eh?
I'm not saying I won't be objecting to Mr. Holding's "dirt" on me, ALL parties to a lawsuit routinely file a "motion in limine" just before trial, attempting to persuade the judge that certain evidence the other party is likely to bring up in front of the jury, has greater prejudicial than probative power.
What Mr. Holding also failed to note is that Florida law allows juries on libel cases to awared punitive damages even if they award no actual damages. If therefore I decide to amend my complaint and remove all claims for actual damages, I'd STILL be able to ask the jury for substantial damages.
In Miami Herald Publishing Company v. Brown, 66 So.2d 679, 680-81 (Fla.1953), the court made clear that general damages for defamation per se are "those which the law presumes must naturally, proximately, and necessarily result from the publication of the libelous matter. They arise by inference of law, and are not required to be proved by evidence." Campbell v. Jacksonville Kennel Club, 66 So.2d 495 (Fla.1953), agreed that damages are presumed to result from defamation per se and need not be proved. The singular protection afforded by Florida law to personal reputation in actions for defamations per se is further seen by the fact that punitive damages may be the primary relief in a cause of action for defamation per se. Jones v. Greeley, 25 Fla. 629, 6 So. 448, 450 (1889), held that malice is an intrinsic part of actions for defamation per se in order that the jury may consider punitive damages. In Nodar v. Galbreath, 462 So.2d 803 (Fla.1984), the court added that the express malice for punitive damages under Florida law is present where the evidence shows that an intention to injure the plaintiff was the primary motive for statements defamatory per se.[26]
Lawnwood Medical Center Inc. v. Sadow, 43 So. 3d 710, 727 (Fla: DCA 4th Dist. 2010)
UPDATE February 1, 2019: The stupidity of Holding and his followers:
The "reply" function here does not allow more than about 4,000 words, so I'm "updating" this post to provide a point by point critique of yet another dumbshit who is either Mr. Holding himself or one of his "zeal without knowledge" juvenile delinquent followers:
You are rather stupid, given that your below-cited comments support my contention in this lawsuit that Mr. Holding's libels really do cause third-parties to view me with hatred, contempt, disgrace, distrust, etc (i.e., the social opprobrium Florida identifies as libel per se and allowing damages even absent any actual proof of damages, see Lawnwood, supra)..AnonymousFebruary 1, 2019 at 7:16 AMLmao!
The latest lawsuit against Holding is a 97-page complaint asserting 41 separate counts of libel per se. What are the odds that
a) you are educated in Florida libel law, and
b) your "Lmao" results from your educated opinion that this lawsuit is legally and factually frivolous?
not good, obviously.
Sure, you are angry that Holding is tied up in another lawsuit, but honesty would counsel that you first determine for yourself whether the slander-charges are true, not whether I'm getting in the way your Savior's uploading of entertaining cartoon videos to YouTube. I have charged your savior with slandering me. If those charges are true, his culpability is great: it isn't rocket science or post-Nicene trinitarianism...its basic biblical ethics:
...And he who spreads slander is a fool. (Prov. 10:18 NAU)
21 "For from within, out of the heart of men, proceed the evil thoughts, fornications, thefts, murders, adulteries,
22 deeds of coveting and wickedness, as well as deceit, sensuality, envy, slander, pride and foolishness.
23 "All these evil things proceed from within and defile the man."
(Mk. 7:21-23 NAU)
He who goes about as a slanderer reveals secrets, Therefore do not associate with a gossip. (Prov. 20:19 NAU)
19. Gossips are treacherous; cf. Instruction of Amen-em-ope: “Spread not thy words to the common people, nor associate to thyself one too outgoing of heart” (ANET 424a).20.
9 I wrote you in my letter not to associate with immoral people;"Reviler" in the Greek is λοίδορος---loidoros, and several lexicons make clear it is talking about the person who goes around insulting and slandering others. From TDNT:
10 I did not at all mean with the immoral people of this world, or with the covetous and swindlers, or with idolaters, for then you would have to go out of the world.
11 But actually, I wrote to you not to associate with any so-called brother if he is an immoral person, or covetous, or an idolater, or a reviler, or a drunkard, or a swindler-- not even to eat with such a one.
12 For what have I to do with judging outsiders? Do you not judge those who are within the church?
13 But those who are outside, God judges. REMOVE THE WICKED MAN FROM AMONG YOURSELVES. (1 Cor. 5:9-13 NAU)
449Danker:
λοιδορέω loidoreÃoÒ [to revile, abuse],
λοιδορία loidoriÃa [abuse],
λοίδορος loiÃdoros [reviler],
ἀντιλοιδορέω antiloidoreÃoÒ [to revile in return]
This common word group has the secular sense of reproach, insult, calumny, and even blasphemy. In the LXX it carries the nuance of wrangling, angry remonstrance, or chiding as well as the more usual calumny. Philo has it for mockery or invective. In the NT the verb occurs four times and the noun and adjective twice each.
1. loiÃdoros occurs in lists of vices in 1 Cor. 5:11 and 6:10. In Acts 23:4 Paul is asked why he reviles the high priest, and in his reply he recognizes a religious duty not to do so. In Mart. Pol. 9.3 the aged Polycarp cannot revile Christ; to do so would be blasphemy.
2. Christians should try to avoid calumny (1 Tim. 5:14), but when exposed to it (cf. Mt. 5:11) they should follow Christ's example (1 Pet. 2:23; cf. Mt. 26:63; Jn. 18:23), repaying railing with blessing (1 Pet. 3:9). This is the apostolic way of 1 Cor. 4:12: “When reviled, we bless” (cf. Diog. 5.15). By this answer to calumny the reality of the new creation is manifested. [H. HANSE, IV, 293-94]---------Source: here.
4004 λοίδοροςDon't know what "insolent" means?
λοίδορος,ου,ὁ [fr. a source shared by Lat. ludus ‘game’] insolent person 1 Cor 5:11; 6:10.
Source: here.
Gee, since you cannot think of any evidence that Holding has ever been "insultingly contemptuous in speech or conduct", you are sure he isn't the kind of "reviler" Paul required you to disfellowship, amen?1 : insultingly contemptuous in speech or conduct : overbearing
What's next? The standard lexicons are lying to us about what biblical words mean? FUCK YOU.
If you bother your brain long enough to remember that Holding's achieving dismissal of the prior two lawsuits I filed against him had nothing to do with determining the merits of my accusations, you might hold off showing the world just how far your zeal exceeds your knowledge. Holding may have died for your sins, but that doesn't mean he can walk on water, he's imperfect, I don't really give a fuck if you see it differently.
Mr. Anonymous continues:
Incorrect. You appear to be under the delusion that if you cannot find it on Google, then it didn't happen to me. Such ignorance is consistent with your inflammatory and baseless zeal. If you were talking about my prior two libel lawsuits against Holding, then apparently you are under the delusion that Jesus approves of the way lawyers exploit technicalities and thereby avoid justice. You'd be wrong:Aside from all your previous lawsuits that failed,
23 "Woe to you, scribes and Pharisees, hypocrites! For you tithe mint and dill and cummin, and have neglected the weightier provisions of the law: justice and mercy and faithfulness; but these are the things you should have done without neglecting the others. (Matt. 23:23 NAU)And since you apparently have more mouth than brain, I filed this Complaint "in forma pauperis" asking for the filing fee to be waived. So if the Complaint was indeed "filed", it was only after a judge reviewed it to make sure the factual allegations, if true, would state a legally valid cause of action for libel:
From Murray v. Collins, Dist. Court, MD Florida 2019
"A claim is frivolous if it is without arguable merit either in law or fact." Bilal v. Driver, 251 F.3d 1346, 1349 (11th Cir. 2001) (citing Battle v. Central State Hosp., 898 F.2d 126, 129 (11th Cir. 1990)).More specifically, the Florida Middle District (which approved of my IFP request) has previously refused to dismiss Complaints for libel where the alleged libels looked far less egregious than the libels Mr. Holding engaged in:
A complaint filed in forma pauperis which fails to state a claim under Federal Rule of Civil Procedure 12(b)(6) is not automatically frivolous. Neitzke v. Williams, 490 U.S. 319, 328 (1989).
Section 1915(e)(2)(B)(i) dismissals should only be ordered when the legal theories are "indisputably meritless," id. at 327, or when the claims rely on factual allegations which are "clearly baseless." Denton v. Hernandez, 504 U.S. 25, 32 (1992).
"Frivolous claims include claims `describing fantastic or delusional scenarios, claims with which federal district judges are all too familiar.'" Bilal, 251 F.3d at 1349 (quoting Neitzke, 490 U.S. at 328).
Additionally, a claim may be dismissed as frivolous when it appears that a plaintiff has little or no chance of success. Id.
With respect to whether a complaint "fails to state a claim on which relief may be granted," § 1915(e)(2)(B)(ii) mirrors the language of Federal Rule of Civil Procedure 12(b)(6), so courts apply the same standard in both contexts. Mitchell v. Farcass, 112 F.3d 1483, 1490 (11th Cir. 1997); see also Alba v. Montford, 517 F.3d 1249, 1252 (11th Cir. 2008).
"To survive a motion to dismiss, a complaint must contain sufficient factual matter accepted as true, to `state a claim to relief that is plausible on its face.'" Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)).
"Labels and conclusions" or "a formulaic recitation of the elements of a cause of action" that amount to "naked assertions" will not do. Id. (quotations, alteration, and citation omitted).
Moreover, a complaint must "contain either direct or inferential allegations respecting all the material elements necessary to sustain a recovery under some viable legal theory." Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 683 (11th Cir. 2001) (quotations and citations omitted).
From Dibble v. AVRICH, Dist. Court, SD Florida 2014
What in Tarnation is a Surrogate Dibble, No way this can be a real human beings name, low class redneck pig excrement, redneck asshole, PATHETIC, LOWCLASS, INBRED REDNECK SCUMBAG, venom-spewing, mud-sucking, LOW-CLASS REDNECK, REDNECK LOSERS, SON OF A BITCH, SCUMBAG DRIBBLE, Now do us all a big favor and go play some Russian Roulette with SIX rounds in the chamberWHAT IN TARNATION IS A SURROGATE DIBBLE, This low-class, inbred, half-witted, redneck, idiot, horse's ass, bully, CHEAPSKATE AND ASSHOLE, venom-spewing, mud-sucking clown, NON-CUSTOMER, pig-farmer, miserable redneck loser, Surrogate Dibble yo-yo, son of a bitch, SCUMBAG DRIBBLE
Defendants contend that Avrich's offending statements amount to nothing more than rhetorical name-calling or expressions of opinion which cannot be construed as statements of fact. Therefore, they argue, the statements cannot constitute actionable defamation. Defendant's comments stem from his apparently strongly-held convictions about Plaintiff's name. This may turn out to be a case about literal name calling. But, Defendant's publications also contain statements about Plaintiff's intelligence, class, ancestry and business-relevant qualities. As examples of the latter, Defendant allegedly stated that Plaintiff might not be a real person, is a cheapskate, a "non-customer," and lacks any credibility. Compl. ¶ 10.
...Construing the allegations in the Complaint in the light most favorable to Plaintiff, the Court cannot conclude at this stage that Defendant's comments are mere rhetoric and cannot constitute defamatory publications. See, e.g., Presley v. Graham, 936 F. Supp. 2d 1316, 1325-26 (M.D. Ala. 2013) (finding, at pleading stage, that statement that plaintiff was "a supervisor's nightmare," even if opinion, could be interpreted by a reasonable reader as a fact-based summation). In our age of anonymous internet trolls and the often-uninformed echo-chamber of the blogosphere, maybe no reasonable reader would take Defendant's statements as asserting facts rather than just one more outspewing of thoughtless rhetoric. But the Court is not willing to say, as a matter of law, that Defendant's insults are incapable of being interpreted as false facts. Visitors of transportreviews.com may understand Defendant to be stating that Plaintiff is in fact inbred, or not a real person, or, at the very least, someone you wouldn't want to do business with. The Complaint fairly and plausibly alleges as much. Whether it is true requires the Court to consider a factual context for the parties to address and develop in discovery. Plaintiff's allegations of defamation will survive Defendant's Motion to Dismiss.You'll excuse me if I note that your anger appears to arise from the fact that Florida law favors me. If you want Florida to adopt a more narrow definition of libel, and require courts to dismiss any IFP lawsuits where the proof of tort is something less than high-definition videos provided by 10 police officers, direct your concerns to the Legislature. Until that day, you appear to be in need of the following education: Under Florida law, libel occurs where a false statement of fact is published to third parties in such a way as to possibly motivate such third parties to avoid Plaintiff. Instead of whining like a baby, try reading the actual Complaint, which sets forth my best case that Holding violated Florida's civil law against libel.
------(Update April 11, 2019: I did not realize until a few days ago that Florida distinguishes between filing and filing. PACER indicated the Complaint was "filed" within a few days after I sent it. But a few days ago I received in the mail a frivolous "Order" from a Magistrate judge threatening to file a Report and Recommendation asking the Court to dismiss the Complaint, for perceived "pleading defects". So apparently the fact that the Complaint got "filed", didn't mean it got filed "all the way". I would have figured that the Clerk would do nothing with the Complaint except forward it to the judge, and the Complaint would not be "filed" until the judge approved of the in forma pauperis application. Regardless, I reacted to the interlocutor Order threatening dismissal, with a "motion for reconsideration" highlighting the judge's legal and factual errors, and, in case he didn't find this compelling, I also filed a 1st Amended Complaint, as the Order invited me to do. See my blog post to that effect, with links to those documents, here.)
That fearless spiritual "warrior" known as "anonymous barking child" continues:
No, maybe this time Mr. Holding will do something he didn't have to do in the last two lawsuits: answer the charges on the merits.maybe this time you'll get lucky!
Quit worrying about my brain and get a second job, your savior needs help with his legal fees.Oh Doscher, that big brain of yours just isn't clicking big man.
If the 2015 lawsuit has anything to do with it, it is because the Court unlawfully dismissed that case "without cost to either party", then violated that Order by granting Holding's post-dismissal petition for attorney fees. Lest you stupidly speculate that maybe 'costs' are different than 'fees', the Washington state case law, which was binding on that Court in 2015, said:Don't you get it? There's a reason why you never win in court,
Attorneys for both parties signed a stipulation that "all causes herein, as between Roberts and Bechtel, have been fully settled and compromised and that this matter should be dismissed with prejudice and without costs." …Ms. Bechtel contends the award of expenses is precluded by the terms of the release and settlement. We agree....It is undisputed Ms. Roberts, through her counsel, stipulated the matter should be dismissed without costs. Attorney fees are considered costs of litigation. Detonics ".45" Assocs. v. Bank of Cal., 97 Wn.2d 351, 644 P.2d 1170 (1982). The court was bound by the stipulation precluding an award of costs. Roberts v. Bechtel, 74 Wn. App. 685, 687 (Wash: Court of Appeals, 3rd Div. 1994)Mr. Anonymous continues on like a toddler whose toy was taken away:
You might want to consult with Mr. Holding. Since the subject of that meeting will be "what is a John Doe Subpoena and how does it relate to Doscher's ability to unmask my true identity and have a process server come knocking on my door?", you might schedule that appointment so Holding can confer with you for several hours.there's a reason why your own father stabbed you in the back a few years ago
Google the relevant topics beforehand, here's a starter: Matthew Mazzotta, Balancing Act: Finding Consensus on Standards for Unmasking Anonymous Internet Speakers, 51 B.C. L. REV. 833 (May 2010) (addressing the various standards formulated by courts in determining whether to issue subpoenas "unmasking" anonymous internet posters, including the balancing of First Amendment rights of the anonymous speakers against the strength of the plaintiff's claim and the need for unmasking, and collecting cases); Ashley I. Kissinger and Katharine Larsen, Untangling the Legal Labyrinth: Protections for Anonymous Online Speech, 13 No. 9 J. INTERNET L. 1 (March 2010)(same); Stephanie Barclay, Defamation and John Does: Increased Protections and Relaxed Standing Requirements for Anonymous Internet Speech, 2010 B.Y.U. L. REV. 1309 (2010)(same); Charles Doskow, Peek-A-Boo I See You: The Constitution, Defamation Plaintiffs, and Pseudonymous Internet Defendants, 5 FLA. A&M U. L. REV. 197 (Spring 2010) (same); Nathaniel Gleicher, John Doe Subpoenas: Toward a Consistent Legal Standard, 118 YALE L. J. 320 (November 2008); and Victoria Smith Ekstrand, Unmasking Jane and John Doe: Online Anonymity and the First Amendment, 8 COMM. L. & POL'Y 405 (Autumn 2001) (same).
Persuasive authority would be TRAWINSKI v. Doe, NJ: Appellate Div. 2014
Mr. Anonymous continues:
I'm not alone. But apparently there are stupid people in the world who base arguments from silence upon the fact that they couldn't find something through Google.and there's a reason why you're alone.
No worries, my latest lawsuit draws the Court's attention to those prior lawsuits on multiple pages.Don't worry, Holding is going to show everything next time in court including all your previous lawsuits.
Unlike stupid boistrious juvenile delinquents such as you, the people who created and maintain America's court system have recognized for many decades there is a great danger that allowing one party to confront the other with every possible bit of "dirt" they can find, might cause the jury to decide the case not on the merits, but solely upon the "dirt":
Rule 403 – Excluding Relevant Evidence for Prejudice, Confusion, Waste of Time, or Other ReasonsFrom Moore v. GEICO GENERAL INSURANCE COMPANY, Court of Appeals, 11th Circuit 2018
The court may exclude relevant evidence if its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence.
Rule 403 provides that "[t]he court may exclude relevant evidence if its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence." A Rule 403 determination is committed to the district court's discretion. See United States v. Dixon, 901 F.3d 1322, 1345 (11th Cir. 2018), petition for cert. filed, No. 18-6917 (U.S. Nov. 29, 2018).Mr. Anonymous continues:
Evidence of claimants' settlement with Peak certainly had some probative value...
On the other hand, the probative value of this evidence was diminished because the claim Peak settled was not identical nor even substantially similar to the claim GEICO was handling.
...Continuing then to the balancing of probative value against unfair prejudice, required by Rule 403, the district court did not abuse its discretion in determining that the probative value of Peak's settlement was outweighed by "the danger of . . . unfair prejudice" to GEICO and of "confusing the issues [and] misleading the jury." Fed. R. Evid. 403.
But alas, it's my social ineptness that causes me to find bible study more fun than socializing with friends. This is good because it ensures that I continue to smack down idiot Christian claims with that level of scholarly biblical acumen that a more socially active atheist probably wouldn't have. Between friends and bible study, I choose bible study.Maybe this time you'll get your mind out of the gutter you socially inept freak.
I have no idea what the fuck you are talking about just now.Pull it out, it's error free, so I have nothing to give.
Same answer, however, your intentional violation of NT ethics is noted:This is up to you, whistle dick. I'll get the treats ready.
3 But immorality or any impurity or greed must not even be named among you, as is proper among saints;
4 and there must be no filthiness and silly talk, or coarse jesting, which are not fitting, but rather giving of thanks.
5 For this you know with certainty, that no immoral or impure person or covetous man, who is an idolater, has an inheritance in the kingdom of Christ and God. (Eph. 5:3-5 NAU)
5 Therefore consider the members of your earthly body as dead to immorality, impurity, passion, evil desire, and greed, which amounts to idolatry.Gee, maybe the Context Group can prove that "whistle dick" wasn't considered "filthy" speech by 1st century Christians?
6 For it is because of these things that the wrath of God will come upon the sons of disobedience,
7 and in them you also once walked, when you were living in them.
8 But now you also, put them all aside: anger, wrath, malice, slander, and abusive speech from your mouth.
9 Do not lie to one another, since you laid aside the old self with its evil practices,
10 and have put on the new self who is being renewed to a true knowledge according to the image of the One who created him-- (Col. 3:5-10 NAU)
UPDATE: February 5, 2019, 11:05 a.m. Pacific Standard Time:
Since Mr. Holding has falsely asserted that I only sue his Apologetics Afield Corporation because I'm "scared" for him to cross-examine me personally, I notified him today that if I am satisfied, before trial, that the libels he committed, as recounted in the 2019 lawsuit, were posted in his individual capacity, then I might be changing the Defendant to "James Patrick Holding, in his personal capacity", so that he is no longer forced by law to hire a lawyer, and he can then cross-examine me personally at trial:
If the screenshot is unclear, here's the text:
I hereby give notice to Mr. Holding that he is advised that while his lawyer prepares notes and evidence to impeach my credibility during trial, Holding should also prepare, starting today, his own notes and evidence so that he can cross-examine me personally, without his lawyer. If after the close of discovery and at any time before trial I decide that most of the libels alleged in the complaint were the work of Mr. Holding personally and not in his capacity as director of Apologetics Afield (very unlikely since the Complaint provides good evidence the libels were legally the work of the corporation) I will file a motion to amend my complaint, seeking to drop "Apologetics Afield" as Defendant and replace with "James Patrick Holding". If the corporation is no longer the defendant, Holding will no longer be forced to have a lawyer represent him, and he can then cross-examine me for himself at trial. But like the 2019 Complaint says, Holding' committed the libels alleged therein while acting within the course and scope of his capacity as "director" of the Apologetics Afield corporation. I told Mr. Holding years ago to back the fuck off and quit smearing me, or I would react with more legal force than the average person might be expected to...but no, this belligerent pathologically obsessed asshole just doesn't have the requisite genetic hard-wiring to appreciate the trouble his mouth gets him into, he only cares about impressing his few babies with his infallible intellect, so FUCK HIM, iIf anybody deserved to reap the consequences of their own thoughtless uncharitable hateful spiteful actions, it is the director of Apologetics Afield, Inc. Apparently, when I tell Holding he picked the wrong victim when he picked on me, he conveniently forgets how to communicate in English.
