Kabbaj v. Google Inc. et al

Filing 2

COMPLAINT filed Pro Se with Jury Demand against Amazon Inc., Google Inc., John Does 1-10, Yahoo Inc. - filed by Younes Kabbaj. (Attachments: #1 Exhibit 1-4, #2 Exhibit 5-10, #3 Exhibit 11-20, #4 Exhibit 21-23, #5 Exhibit 24-25, #6 Exhibit 26-27, #7 Exhibit 28-29, #8 Exhibit 30-31, #9 Exhibit 32, #10 Exhibit 33-35, #11 Exhibit 36-37, #12 Exhibit 38-41, #13 Civil Cover Sheet)(mdb)

UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
Younes Kabbaj,
Plaintiff
v.
CIVIL ACTION No.
Google Inc. (a Delaware Corporation),
Amazon Inc. (a Delaware Corporation),
Yahoo Inc. (a Delaware Corporation),
John Does 1-10,
Defendants
COMPLAINT AND JURY DEMAND
1. Plaintiff seeks declaratory and injunctive relief, and money damages for defamation,
tortious interference with contract, negligent and intentional infliction of emotional distress,
premised upon diversity of citizenship.
The Parties
2. Younes Kabbaj is US citizen and resident of Morocco, temporarily located in Florida.
3. Google Inc. is a Delaware Corporation, certificate attached as Exhibit 1.
4. Amazon Inc. is a Delaware Corporation, certificate attached as Exhibit 2.
5. Yahoo Inc. is a Delaware Corporation, certificate attached as Exhibit 3.
6. John Does 1-10 are unidentified individuals operating Google, Amazon and Yahoo
internet facilities to author/publish defamation and threats concerning Plaintiff.
Jurisdiction and Venue
7. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1332 because the
amount in controversy exceeds the sum of seventy-five thousand dollars ($75,000.00), exclusive
of interest and costs, and there is diversity of citizenship between Plaintiff and the Defendants.
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This Court also has supplemental jurisdiction over the claim for relief that arises under Delaware
law pursuant to 28 U.S.C. 1367(a) because it forms part of the same controversy and derives
from a common nucleus of operative facts. Venue is proper in this District pursuant to 28 U.S.C.
1391(b)(3) because the Defendants are subject to personal jurisdiction in the District.
The Facts
8. Starting approximately February of 2009, Plaintiff has been subjected to a prolonged
campaign of defamation after accepting a job as IT Technician, Head of IT for the American
School of Tangier and Marrakesh (herein identified as “AST,” also a Delaware Corporation,
certificate attached as Exhibit 4). The subject matter of the defamation is covered in previous
litigation in Morocco, as well as Case no. 10-431-RGA and Case no. 12-1322-RGA (Delaware
District Court), and Case no. 11-23492-MGC (Southern District of Florida).
9. Previous litigation against a suspected John Doe named Mark S. Simpson is captioned
as case no. 12-1322-RGA, yet this litigation failed to yield identifying information concerning
the John Does who authored/published website content hosted by Google Inc., Amazon Inc. and
Yahoo Inc. (herein known as the “ISPs”). This litigation was dismissed on August 28th, 2013.
Plaintiff must serve the John Does and/or ISPs with a summons/complaint concerning this matter
before the statute of limitations expires. Plaintiff also has limited time to acquire evidence
confirming the identities of John Does which authored the defamation published by the ISPs, as
well as the death threat emails sent to Plaintiff. All the defamation described in this Complaint
targeted Plaintiff, his family in Morocco and the United States, and his previous employer AST
which is also intricately tied to Plaintiff’s interests.

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10. The subject of this complaint concerns defamation identical in content to that which
was previously litigated in criminal/civil cases in Morocco and Delaware (10-431,12-1322), and
which has again recently reappeared on the internet facilities of the ISPs complete with
descriptions of Plaintiff’s identity including his name, job titles including ‘IT Technician,’ or
‘Head of IT’ for American School Marrakesh. The defamation accuses Plaintiff of being a
heroin dealer, plotting terrorism, hacking, stalking, fraud, theft, death threats and other crimes, as
well as false allegations that Plaintiff was a ‘closet homosexual.’
11. The defamatory postings cited in this Complaint are also made in violation of a
confidentiality agreement reached between Plaintiff and AST in previous litigation 10-431-RGA,
rendering that previous settlement agreement null and void and giving rise to the tortious
interference claim cited in the instant Complaint. An additional claim for breach of contract will
be filed by Plaintiff once discovery confirms the identity of the John Does which Plaintiff is
certain are parties released in the previous settlement agreement, which requires Plaintiff to get
permission from Delaware District Court before initiating litigation against any of the releases
named in the previous settlement agreement (Case No 10-431, Docket Entry 54).
12. Defamatory and threatening communications concerning Plaintiff recently appeared
in multiple books/articles/web pages hosted by Google and Amazon. Most of the websites have
since been deleted but some still remain active. Several of the websites administered by
Google’s “Blogger” service were located at the following website addresses and corresponding
‘blogger’ and ‘Google+’ profile pages:
A) http://www.draculadancing.com
B) http://www.whitmanandrimbaudkissing.com
C) http://www.whitmankissingrimbaud.com
D) http://www.kerouacandrimbaud.com
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D) http://www.blogger.com/profile/10595979589183199636 (Attached Exhibit 38)
E) http://www.blogger.com/profile/03299136927808961600 (Attached Exhibit 39)
F) http://plus.google.com/102751852946887364961 (Attached Exhibit 40)
Defamation and threats published by Google Inc. internet products and news blogs
13. The following URL’s attached to Complaint are relevant to the instant proceedings:
Exhibit #
05) www.draculadancing.com/2012/07/location-la-localisation-des-evenements.html
06) www.draculadancing.com/2012/07/evil-characters-in-fiction-mal.html
07) www.draculadancing.com/2012/09/mark-fish-pretend-headmaster-of-kew.html
08) www.draculadancing.com/2012/09/the-american-school-of-marrakesh.html
09) www.draculadancing.com/2012/09/the-cause-of-my-traumatic-stress-quest.html
10) www.draculadancing.com
11) www.ilga.org/ilga/en/countries/MOROCCO/Your%20Stories/a8b4f56b-4095-43e5-a3a1-694edbffc5c5
12) www.whitmanandrimbaudkissing.com/2012/11/dan-fingermans-wonderful-gay-play.html
13) www.kerouacandrimbaud.com/2012/11/caveat-emptor-when-it-comes-to-helping.html
14) www.kerouacandrimbaud.com/2012/11/okay-re-introduction-to-you.html
15) www.kerouacandrimbaud.com/2012/11/testing-our-own-limits-of-forgiveness.html
16) www.kerouacandrimbaud.com/2012/11/on-being-writer-few-reflections.html
17) www.kerouacandrimbaud.com/2012/12/advice-from-my-desk.html
18) www.kerouacandrimbaud.com/2012/12/most-homophobic-or-anti-gay-people-are.html
19) www.kerouacandrimbaud.com/2012/12/i-dedicate-this-to-nurse-who-took-her.html
20) www.kerouacandrimbaud.com/2012/12/the-world-beyond-our-control.html
21) www.kerouacandrimbaud.com/2012/12/hypothetical-but-fear-producing.html
22) www.kerouacandrimbaud.com/2012/12/no-personal-emails-please-pas-des.html
23) www.kerouacandrimbaud.com/2012/12/for-gay-man-self-love-take-years-i.html

14. Below are defamatory excerpts from the above Exhibits, including statements that
identify Plaintiff by name, job title, and terms like ‘Moroccan criminal, felon, wingnut,’ etc:
Exhibit 5
A. “At the moment, I am writing a story about the criminality I found at the American
School of Marrakesh.Do I change the locale or maintain it?Its not as if people don’t know
where I have worked? To inherit a school where a known felon is head of maintenance, a
man formerly incarcerated for heroin trafficking in the United States is in charge of IT”
B. “Especially, considering the lengths to which these characters and others ... strangely
shaped and weirdly behaved Moroccan "aristocrats" threatened me with photos and
emails (of my own) ... went to stop me from revealing anything.”
Exhibit 6
A. “In Morocco, as you know, I encountered a horrible man (Younes Kabbaj), a criminal
with a felony conviction, an animal who sent me photos (now in the hands of the French
authorities) of him and his prison / gang friends with guns, a man who infiltrated all of
my email and other private accounts, twisting things to make me look terrible, all with
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the end of destroying me. As a human being, the experience gave me PTSD (for which
someone is going to pay). However, as a writer, it gave me deep perspective. Why?
Because amoral, evil, unscrupulous, unethical, mean and valueless characters, such as the
Morocco criminal who was the IT Technician at the school where I worked (The
American School of Marrakesh), pose the greatest challenge to writers. They are nearly
impossible for writers to paint with dimension and accuracy, because ... quite frankly ...
most of us don't understand how someone could do such things. Would you read
someone else's most private correspondence? Hand it off to others so they could say, "We
know about the email to Germany." I finally figured out they meant an email I'd sent to a
gay friend who's a tram conductor in Berlin!”
B. “Critics all agree that Vautrin's obvious sexual attraction to Rastignac and Lucien
speaks to his repressed homosexuality; he is bound to them by his hunger for power but
also his hunger for them , which is precisely the case with my own Moroccan criminal.”
Exhibit 7
A. “Not my driver nor the criminal IT Technician named Younes Kabbaj, whom we
were driving to Casablanca for who knows what nefarious activity, cared at all”
B. “I had every possible form of privacy violated: email, general internet, phone, my
own home ... in which spying devices were installed. I saw a holiday dedicated solely to
the slaughter of sheep, in which my own bodyguard (the Head of Security for Alexander
the Great) confessed to being tired after killing so many sheep and cutting them up.
Morocco is filthy, backward, disgusting, corrupt (oh, so corrupt). The police demand
bribes at every roadblock, the government is full of hideous "Royals," who live the
golden life, with jet skis, lavish parties, toy-boys, et al. Do not go to this backward and
disgusting country. Do not patronize their hotels and resorts. Avoid Morocco at all costs.
Boycott it. It is NOT gay-friendly (being gay is, in fact illegal, and you will, as a friend of
mine was, be beaten either to death or nearly), it is hideously sexist, and quite frankly it
makes Tijuana look like Oslo. There ..the truth. As Zola would say, "Do something now."
C. “He is a sham, a fraud, a shopping mall Santa Claus pretending to be something far
beyond his intellect and acumen. I had the misfortune to be recruited by him to go out to
the American School of Marrakesh ... and then he was fired for incompetence by the
board (not coming to school, behaving erratically, sending contradictory instructions,
spending lavishly on his apartment, car, etc.). His departure left me high and dry, with no
instructions, no guidelines, no playbook ... nothing but an unaccredited school, with two
criminals in its employ, and students who couldn't speak English. Ultimately, the
American School of Marrakesh destroyed my career and health, thanks to this total sham
Mark Fish”
D. Comments:
1. “Anonyme 4.8.12 - Amen. The guy is a complete fake. I worked in Tangier
when he was there and we used to call him 'the invisible man,' because you could
never find him. I swear he's mentally ill.”
5. “MarkSutherlandSimpson8.8.12-I know you meant know-nothings .but I agree
utterly. Carney, Sandoe does play favorites and they do NOT do their research of
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candidates properly. It's all a shell-game. The only thing worse is Search
Associates and that homophobic dinosaur John Magagna, who owes me big time”
6. “Mark Sutherland Simpson 8.8.12 - In answer to questions I've received, John
Magagna refused to allow Search Associates to represent me (thus eliminating
hundreds of job opportunities) because of gossip about me having an affair with
my Head of Security (and chaffeur, and the gardener, and ...). To make matters
worse, he repeated the stories, as I have heard directly from others. Yes ... indeed
... he owes me, and big time is an understatement.”
7. “Anonyme 8.8.12 - I work in Tangier, and this man, Mark Fish, was mean for
me. He was yelling at me once, because it is alleged that I did not clean the stairs,
and I did clean the stairs. He is a liar, no one dearer to him in the whole school,
including the Eastman Eliza. Everybody hate him.”
Exhibit 8
A. “Many of you write me every day, and most of you wish to remain anonymous. The
reason seems to be the Islamic component, and fear of Younes Kabbaj, the former IT
technician at the American School in Marrakesh (as well as a former convicted and
imprisoned felon in this country for heroin trafficking). Your fear may be well-founded,
because he might be able to discern your address. I don’t know. You write every day,
asking for my story … and because you worry about me, which I appreciate immensely”
B. “Ultimately,out of sheer fear,I resigned my position with the agreement that would not
talk about what I discovered at the school as long as school didnt talk about me.However,
no sooner had I left for Paris, than I was barraged by threats and death-threat emailing’s
from Younes Kabbaj (including photos of him and his prison chums with guns)”
C. “Of course, he proceeded to infiltrate my life in every way possible, getting on to my
Facebook page and pretending to be me or at one point a woman named Victoria
Olemma (who knew me from a university I never attended. Hmmm). He contacted
former students, made postings in my name … and the same with my blog, snipping bits
and pieces from my computer (to which he had access in Marrakesh, because he was
literally inside of it), email and other correspondence. At one point they claimed I had
affairs with everyone from several of my chauffeurs, my Head of Security, teachers, and
anyone who was male and moved. They claimed to have a Flash Drive with my salacious
writings on it, which could only be the short stories and manuscripts obtained from my
computer ... and altered beyond recognition by now. Again, people who know me, none
of that nonsense would never be true. Yes, I am being treated for PTSD; yes, Younes
Kabbaj, Mark Fish, Steve Eastman, possibly the head of a major search agency, and the
American School of Marrakesh are the cause of it. There ... I'm exhausted, but maybe I
won't need to write a version of this every morning!”
D. Comments:
1. “Anonyme 8.8.12 - You poor guy. That Kabbaj character sounds like other
people I've heard about from that part of the world. They have no values at all,
and no respect for privacy. I hope to heck you plan to sue him and them, and
whoever that Search Agency is. Search Associates? I believe I read about the head
of that organization in one of the comments about Mark Fish.”
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2. “Mark Sutherland Simpson 9.8.12 - Thanks for the support, and thanks
especially for asking that you be printed even if anonymously. Considering the
characters and country we dealing with, that brave of you! Kudos and thanks!”
3. “Anonyme 11.8.12 - Dude, I'm SO, SO sorry for you! But you should have
done year research man, because that place is famous in Marrakesh for being
corrupt. My girlfriend and I lived in Marrakesh for about a year, and
EVERYONE in the city knows that the American School is fool of crooks and
even murderers (or so Cafe de la Poste gossip claims.) My girlfriend is yelling at
me to tell you to keep your chin up and count yourself lucky that you got out of
that hellhole alive! What a screwed up, f-ed up country. You can watch naked
French music videos and listen to the prayer tower things at the same time?!?!
4. “Anonyme 2.9.12-Whoa. I just read this and it totally gave me chills. I've heard
of people having things stolen in Morocco,and of lots of corruption,so this doesn't
surprise me. However, some of these people should be brought before the police,
shouldn't they? Isn't that Mark Fish guy a criminal? What about this Eastman
character? He gave permission for spying on employees? Holy whatever. I'm with
you, Mark, and I'm so sorry this happened to you. But keep the faith. They'll all
get their come-uppance. Evil and stupid people always do. Sean Eastbourne”
Exhibit 9
A. “While there, I encountered an individual named Younes Kabbaj, a man who was at
the time the School's IT Technician and was spying upon everyone's emails, phone calls,
faxes, etc., (teachers, administrators, students, employees), monitoring everyone's
computers, installing listening devices in teachers' homes, and intruding directly into our
computers via modem. He obtained access to all of my accounts and to all of my contact
lists. He managed to intrude into my account at Carney, Sandoe, the Independent School
Placement Agency. You imagine, logging into Facebook or your blog and discovering
that you are ... already logged on, and that this monster has been falsely pretending to be
me. It's hellishly unbelievable and beyond any ethical boundary I have ever encountered
in my life. Rightly or wrongly, I chalk it up to his religion, which seems completely
amoral to me, appearance, sham, ritual, pretense and ... nothing behind it; nothing but
mumbo jumbo. Religion or not, Mr. Kabbaj is an evil man, a criminal, who spent three
years in an American Federal Penitentiary for Heroin trafficking”
B. “Toward that end, I have taken the advice of authorities and worked to shake him off.
I have turned over to them his emails to me, in which in threatened with me death and
included photos of himself and his prison friends with guns, including Kalashnikovs.
Think doesn't scare the Hell out of you? Think again, my friends ... you ought to read
them or see them. You'd be beyond shocked. Even the French authorities passed them
around in horror, shocked that anyone would be so foolish as to send out such
incriminating emails, which were ... of course, traced by the French DGSE immediately
back to the originating ISP”
C. “He has been after me because, incorrectly, he believes I fired him and then wrote a
letter to the parent body about him. I did neither. The Board of Trustees fired him
(against my advice, by the way) for gross misbehavior and violation of the school charter,
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and the letter to parents was written and distributed while I was in New York, and not
even in Morocco. So, his entire campaign of destruction of my life has, as has so much in
his life, been based on nonsense.”
D. “I moved locations continuously on advice of French and American authorities, I cut
off contact with anyone from my past including friends from childhood and unfortunately
witnessed death and mayhem …something I had never or could ever have anticipated.”
E. “I ask Younes Kabbaj, directly, to please leave me the Hell alone. I never fired you, I
never sent out a letter about you (Moulay Omar and Madison Cox orchestrated that, using
my digital signature, obtained from my office), I never offered you a hint of the calumny,
libel and disgrace that you have shoveled upon me. Yes, I am gay. Being gay does not
make you a pedophile, a pervert, or any of your other silly. salacious, and defamatory
concoctions. In my country, it's an ordinary thing to be gay; it is not ordinary to destroy
someone's life in order to achieve some vague personal revenge. That's called criminality,
lack of ethics, and abnormal personality type. You're a wingnut on speed, Kabbaj (or is it
Cabbage?), a total and complete demon. To the rest of you here, and the thousands of you
who have already started reading this blog, thank you for your support. Thank you for
reading my blog. Thank you for buying my books ...it keeps me going in the face of evil.”
Exhibit 10
“Mark lives in a world of silence, unable to communicate with more than two or three
people. We go to extreme precautions when speaking with him, and security is strong at
all events. His life has been completely invaded electronically and in other fashions, by a
criminal of Moroccan origin with a profound psychological problem of some religious/
sexual sort. He has written letters to Mark's friends and associates, asserting the most
astounding nonsense, co-opted Mark's accounts, faked accounts, tricked, deceived,
distorted and ultimately threatened him with death. Mark lives in a shadow world and
always will. Our hearts go out to him each and every day. We work closely with the
Australian, French and American authorities, all of whom are documenting this criminal's
violations of laws regarding invasions of privacy, defamation of character, libel,
harassment, cyber-bullying, stalking and infliction of mental distress.”
“Because Mark lives in a world of silence, unable to communicate with more than two or
three people. We go to extreme precautions when speaking with him, and security is
strong at all events.”
Exhibit 11
“The major event that occurred; and for which I had no participation - a dual national
(American and Moroccan) person was fired by the Board of Directors. Sadly for me, this
religious fanatic and true homophobe, decided to focus his intense revenge on me - for
three years now. He sent communications to schools I applied to; contacted the agency
that represented me and put out terrible lies; most notably that I was a pedophile.
Needless to say, in the world of education, even a lie about that issue ends your career.
He didn’t stop there. He stalked me on email, Facebook and my blogs; he had infiltrated
my computer in Morocco and obtained my contact lists and has also written 30 page
diatribes about me; or in some cases pretended to be me – writing to former students
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saying I was sexually interested in them. I have continuously relocated around the world,
concerned about my personal safety.”
Exhibit 12
“Unfortunately, one thing that occurred; and for which I had no participation - a person
was fired by the Board of Directors. Sadly for me, this person focused his homophobic
revenge on me. He sent communications to schools I applied to; contacted the agency
that represented me and put out terrible lies; most notably that I was a pedophile.
Needless to say, in the world of education, even a lie about that issue ends your career.
He didn’t stop there. He stalked me on facebook and my blogs; he had infiltrated my
computer in Morocco and obtained my contact lists and has written 30 page diatribes
about me; or in some cases pretended to be me – writing to former students saying I was
sexually interested in them. I have continuously relocated around the world in order for
him not to find me, as I am concerned about my personal safety.”
Exhibit 13
A. “However, in the course of my last job, I was targeted by a sociopathic IT technician
who, after being dismissed from the school for very, very good reasons, became my
stalker, harasser and career-destroyer.”
B. “This is my author page on Amazon, of which I am also proud. My stalker/harasser
posts the bad reviews, and I am sorry about that. They are embarrassingly transparent,
grammatically flawed and clearly harassment (they've been documented). It's just another
attempt to intimidate me.”
C. “I think he thinks I slandered him through my various police reports (In France you
have to write things down, beginning with "J'atteste sur mon honneur) or on my blog, but
since he was inside my blog (he is a hacker, as well, a former IT Technician) I'm not sure
who could believe anything from my previous blogs. This one is safe ... and well
monitored. Anyway ... final word, be careful about playing with matches.”
D. “To any former student, colleague or friend that was either directly or indirectly
harmed by this homophobic villain– you have my most sincere and heartfelt apology. The
pain I have felt; the suffering I have endured; and the toll I have paid for this person’s
incredibly cruel acts should never have burdened your lives. I miss staying in touch with
all of you – however, your well-being is paramount to me. I think of each of you
everyday, and I hold you close in my heart and in my prayers.”
Exhibit 14
“Unfortunately, in the course of my career I ran afoul of a sociopathic individual who,
after being dismissed from school employment, destroyed my career and my life. He
invaded every inch of my privacy: email accounts private AND professional, bank
accounts, Facebook, every single account I had, and he even invaded the Trinity School
server, without their knowledge. From my contact lists and his infiltration into the
website of Carney, Sandoe, a placement agency, he sent out the most disgusting and
repugnant long (VERY long) emails, about me being a pedophile (HARDLY, since I've
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never glanced at a man younger than thirty-five and hairy chested ... well, okay, an
exception or two on the hairy chest)”
Exhibit 15
“There is only one person in the world for whom I might use the word hate, though I
would more accurately say detest. This is a person who willfully and with full knowledge
of his actions, violated my private email, banking, Facebook, and other accounts, wrote
long letters filled with lies as well as with information he obtained through violation of
my privacy ... and who has harassed and stalked me for three years. However, I am not at
ease with feelings such as I have for this scoundrel, amoral and criminal though he is.
To have violated my privacy, something everyone holds sacred, then to manipulate and
use it to interfere with my employment is a criminal offense in the United States. I pray
for the strength to see this criminal face justice here or upstairs, when he comes face-toface with the big guy.”
Exhibit 16
“Then, after my Amazon page was infiltrated and my reviews tainted by my stalker /
harasser, I lost out on a film option ... the friend working with me on that got scared away
by my stalker / harasser's apparent religion and the photos I'd shown her. SO ... no film
option at the moment, which is too bad, because we were talking big bucks. But people
are afraid of my stalker / harasser. As my shrink said, "You've been blackballed." No one
wants to touch the "thing" connected to a particular religion. I'm a relatively unknown
Salman Rushdie. Really. I should be on Katie Couric's show, which was also my shrink's
advice ... to go public in every way about being stalked and harassed, TV and newspaper,
the works. However, I've moved on ... trust me, after the Hell of the last three years,
caused by an internet stalker / harasser who was fired for good reason from the school of
which I was Headmaster, invaded all of my accounts, email and otherwise, including
Facebook, and then having violated my privacy used some of that information to interfere
with my employment (he also had access to my referees and the my site on the placement
agency web), well ... I can weather storms (and illegal criminal mischief).”
15. Defendants continue to defame Plaintiff with additional Google articles attached as
the following exhibits:
A. ”Advice from my desk ..” attached as Exhibit 17
B. “Most homophobic or anti-gay people are gay ... true” attached as Exhibit 18
C. “I dedicate this to the nurse who took her life in London ...” attached as Exhibit 19
D. “The world beyond our control ...” attached as Exhibit 20
E. “Hypothetical, but fear-producing” attached as Exhibit 21
G. “No personal emails, please …” attached as Exhibit 22
H. “For a gay man … self-love takes years” attached as Exhibit 23

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16. Defendants also describe their motive for wanting to harm Plaintiff as derived from
discriminatory hatred of Arabs/Muslims, attached as additional posts:
Exhibit 24) www.draculadancing.com/2012/07/lets-talk-about-hypocrisy-allez-y-et-de.html
Exhibit 25) www.draculadancing.com/2012/08/the-new-dangers-of-writing-les-nouveaux.html
Exhibit 26) www.draculadancing.com/2012/08/i-support-israel-completely-je-soutiens.html
Exhibit 27) www.kerouacandrimbaud.com/2012/11/israel-shares-our-values-we-are-family.html

Defamation and threats published by Amazon Inc. internet products and books
17. Defendants created several Amazon.com accounts whereby they published/sold
defamatory novels about Plaintiff using a variety of different titles and author names, as follows:
A) www.amazon.com/M.S.-Simpson/e/B0056TK2XU
E) www.amazon.com/author/marksutherlandsimpson
B) www.amazon.com/Campbell-George-Cardeston/e/B0088NNPZ8
C) www.amazon.com/C.-Alcuin-Becket/e/B009V1BYMW
18. Defendants published a 146 page novel originally titled “Satan in a Donkey Cart”
and then renamed “Mythical Sex in Marrakesh,” “Drink Fire of the Sunshine” and “Core of a
Sinking Flame,” all of which contain excerpts and references to Plaintiff that defame him with
allegations identical to those appearing on the Google sites referenced previously, including the
following excerpts from various versions of these books:
Exhibit 28
Page 10: “Nine months of hell in bestial, backward, barbaric Marrakesh (forget the
tourist brochures, the place is grotesque) ended with her reputation destroyed. This was
not hyperbole, it really had been destroyed, not sullied, but shattered beyond recognition,
after her nemesis - the kook, as he came to be known - copied and sent out, using her own
address book (which included friends, foes, former employers, colleagues, parents,
nieces, grandparents, Banana Republic, Air France, literary agents, etc.), emails and
phone call transcripts (yes, he monitored and recorded her phone - it's doable), along with
his sadistic sexual mythologies about her love life and excerpts from the short stories he
(from his point of view) fortuitously found on her computer desktop. He gained access
via a proxy server in Spain (that's doable too) and the router in her living room, which
apparently he had programmed and thus controlled. Her internet router was the kook's
best friend. Worst of all, her public humiliation continued, despite her precipitous
departure from Morocco. The flabby, sex-obsessed computer technician hadn't stopped.
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There had been another barrage last night. He still haunted her - he might always haunt
her. Ophelia knew she'd never had sex with a one-eyed Egyptian pilot named Omar, who
tied her up with her own bra and took her in ways she'd never heard of (though some did
sound interesting, she had to admit); she knew she never picked up three rough Berber
men in the Medina and brought them home for a searingly sleazy four-way - but her
grandmother didn't. Her mentally ill nemesis still managed to get access to her personal
codes and bombard people with his garbage, changing his own account names frequently
enough that people didn't delete them unopened or have them slithered directly into spam
folders. He was as clever as Satan, the kook- no, he was Saran. And nothing and no one
in hideous Marrakesh had either been able or prepared to stop him, not lawyers, not the
apparently well-equipped Gendarmerie Royale - nothing. For all she knew, he worked
for them or was related to the Wali- or someone else
Page 16: “Though she had sampled more of the danger than the deliciousness, thanks to
the obsessive desires of the school's computer technician, whose name in Arabic sounded
both feminine and vintage, as if he were a female character from an I Love Lucy episode
- though she never repeated his name, not even to people who already knew it (even if it
could evoke laughs), and his last name also rhymed with a humorous vegetable, but that
too was best left unspoken. Certain things just shouldn't be said aloud and, really, he was
Satan. At first, she'd thought he was merely a pot-bellied kook (well, he was a kook and
he did have a potbelly) with his scraggly beard and drug-glazed eyes, who asked her out
ten times in three days and turned up twice at her apartment. But he turned out to be more
than that - much more.”
19. Excerpts from alternative versions of the above-referenced book can be found in the
“Mythical Sex in Marrakesh” novel sold on Amazon.com, where the John Doe defendants are
clearly referencing Plaintiff by name as attached as Exhibit 29:
Exhibit 29
Page 20: “… episode - though she never repeated his name (Eunice), not even to people
who already knew it even if it could evoke laughs, and his last name also rhymed with a
humorous vegetable, but that too was best left unspoken (Cabbage). Certain things just
shouldn't be said aloud and, really, he was Satan.”
20. Defendant Simpson clearly intends “Eunice Cabbage” to be interchangeable with
“Younes Kabbaj.” The authors of this defamation also mock Plaintiff’s name in similar fashion
in other defamatory postings where they claim to own a cat named “Cabbage,” attached as
Exhibit 30. Reviews of Mythical Sex in Marrakesh are attached as Exhibit 31.

12

21. Defendants also maintain their Google blog feeds on the various Amazon and
Google profiles, where the original defamatory exhibits attached to this Complaint are also
republished on Amazon Author pages and Google+ Profile feeds, and redistributed to various
different mass communication email lists including RSS feeds. Attached as Exhibit 32 are
assortments of the various snapshots taken of these various Amazon author pages and biography
pages over the time period starting approximately June of 2012, where it is clear that the
Defendants constant changing of identities is so prolific, it could not serve to improve book sales
but only to evade detection for activity that the authors are aware is clearly illegal.
22. Attached as Exhibit 33 is another recent (August 2013) snapshot taken of the
Defendants Amazon author page and biography which changes almost daily. Again the
Defendants are illegally accusing the Plaintiff of the same false allegations including:
“predatory internet attacks, including identity theft, impersonation, scandalous slander,
libel and assault, watching himself caricatured on obscene and dishonest web pages, enduring
co-option and hijacking of every personal account, seeing his blogs inundated with embarrassing
hacked postings either made up or purloined from Simpson's private emails, having his social
media compromised and people contacted under false pretenses, having his contact lists used to
send out scurrilous, libelous and slanderous mass mailings, and watching helplessly as his
computers were pirated.”
These posts appear just for a day or two before being deleted and republished and
deleted, countless times over the course of years, without Plaintiff ever being able to properly
ascertain the source of the John Does behind the defamatory publications, although they are
being facilitated by Google, Amazon and Yahoo consistently for years.
Additional relevant content
23. The postings made to these blog sites are too voluminous to add as exhibits to the
Complaint, as many of the postings were edited multiple times and during certain periods the
13

postings reached approximately 20+ postings a day. Many of the postings also provided clues to
the identities of the John Does. For example, in one post made in a book sold on Amazon, the
John Does make reference to an individual named Pierre Berge, a former Board Member of AST
(and releasee named in previous settlement agreement) who Plaintiff is informed and believes is
one of the suspected John Does responsible for the recent defamation campaign. This post
concerning a eulogy given by Pierre Berge at Yvess Saint Laurent’s funeral is described below:
Exhibit 34: "Yes. Somewhere. I only have virus-ridden flash drives now. I had to throw
away my laptop, it was so infiltrated by the straggly-bearded kook that it was basically
his ... and half the world. Anyway, the eulogy and probably a Trojan horse virus are on
one of the flash drives, I think." "Find it for me, if you can, Phee. It was so beautifully
written, like Pierre Berge lamenting Yves St. Laurent ... though between us Pierre Berge
has completely lost his marbles of late, if he ever really had any that mattered. Your
eulogy was the most moving Moment in Vanessa's funeral."
24. Another article published by the John Does make reference to another individual
named Madison Cox, who is a current Board Member of AST (and releasee from the previous
settlement agreement) who Plaintiff is informed and believes is another suspect John Doe
defendant in this case. This article is attached as Exhibit 35 at URL:
www.kerouacandrimbaud.com/2012/12/madison-cox-gay-landscape-architect.html
25. Upon information and belief, the Defendants also engaged substantial email, internet
and telephone correspondence with numerous third parties that they corresponded with through
the Google, Amazon and Yahoo platforms, wherein the sole purpose was to defame and incite
violence against Plaintiff and his family, for which they have succeeded as Plaintiff’s family
received death threats regularly as a result of this criminal incitement, Plaintiff’s cousin was
illegally kidnapped/detained/tortured by the Moroccan military for 6 months in a Marrakesh
prison due to matters related to this litigation. Two of Plaintiff’s second-cousins have also been
14

kidnapped by the Moroccan military and are still in their custody as a result of this conflict
which is being manipulated on these defamatory blogs. It is necessary to identify the sources of
these communications because these John Does are also responsible for a host of other criminal
actions that have been taken against Plaintiffs family in the US and Morocco since 2009.
26. As is clearly shown in the comments section of Exhibit 7 and 8 and other posts, this
defamation was also deliberately targeted to reach individuals associated with AST (a Delaware
Corporation) with whom Plaintiff has a previous settlement agreement concerning previous
identical defamation that was litigated in case no. 10-431-RGA. This new round of defamation
is clearly targeted to reach AST affiliates in both America and Morocco. In Exhibit 7, two
comments submitted to the offending blogs which were then posted in the comments section are
alleged to have been written by employees of AST, confirming that the Defendants are clearly
reaching AST employees and affiliates around the world with this targeted activity.
27. The attempts by John Doe defendants to target AST (a Delaware Corporation) and
their affiliates all over the world is deliberate because the offenders are clearly aware this type of
threat against Plaintiff via AST causes direct physical harm to Plaintiff’s family in Morocco by
forcing his family into continued and sustained conflict with the Moroccan military officials
implicated in misconduct concerning these matters. The kidnapping and torture of Plaintiff’s
cousin was covered by numerous media organizations in Morocco, as his abduction and unlawful
incarceration came about after numerous unsuccessful attempts to settle a multitude of
criminal/civil cases related to these matters.
28. Defendants also targeted their defamation of Plaintiff at specific internet forums
intended to reach Moroccans and other individuals associated with AST, such as this entry they
15

posted on yet another internet site targeting readers specifically located in Morocco, attached as
Exhibit 11. Defendants also post messages on the Google blogs specifically targeting students
at AST, as is shown in other posts attached as Exhibit 12, despite the fact that the blog authors
are aware these sites are not appropriate viewing for children.
29. Defendants also falsely accuse Plaintiff of suffering from repressed homosexual
dysfunction, manifesting in some obsession with stalking homosexuals. All these false claims
published by the Defendants are also defamatory because they assert Plaintiff is committing
infidelity against his female companions by cheating on them with members of the same sex.
Women clearly have a right to know if their significant other is experiencing same-sex
attractions, especially if such proclivities factor into providing consent to engage in sexual
relations. The type of women that Plaintiff has had relationships with would never engage
sexual relations with a bi-sexual or homosexual man, so malicious allegations by the Defendants
accusing Plaintiff of being homosexual are akin to accusing Plaintiff of committing infidelity
against his significant others, or of having some loathsome disease (as many women see
homosexuality as a type of loathsome psychological disease like necrophilia or pedophilia).
30. Defendants also openly states that the religion of Islam completely disgusts them
(disregarding that Plaintiff is inclusively Jewish/Christian/Muslim), and they provide hundreds
of pages of literary content that give clear insight into the minds of the John Does regarding their
motivation for wanting to harm the Plaintiff based upon a false claim that he is some type of
Islamic super-militant radical on a mission to kill all gays. It was already established in previous
litigation that Plaintiff will only consider assassinations of individual gay rapists/pedophiles that

16

specifically attempt to commit sexual-themed crimes directly against him. Several posts by
Defendants admit bias against Plaintiff because of his religion attached as Exhibit 36 by stating:
Exhibit 36
A. “I'm a normal person, in that I amnot free of certain prejudices or biases. I admit this
upfront. I believe everyone is biased. For me, my chief problem is with Islam, which I
cannot abide. I'm working on it.”
31. Defendants publish large amounts of soft-core pornography (that they declare to be
art) depicting young men in various stages of nudity with private parts visible, and videos of
sexual groping and kissing between men, including another blog titled kabukiandshirtless.com
(which has subsequently been removed), and others similar in content. Defendants also author
graphic depictions of sex under the guise of ‘literature’ in numerous hardcover books and
internet products, and some drafts of the material include under-age sex, sex between teachers
and students, rape and other indecent acts.
32. Defendants also operate RSS feeds of their Google/Amazon products where
subscribers can receive their products and posts via email and other means, in real time as they
are posted. This technical ability of Google/Amazon to disseminate the defamatory content
thereby allows for mass distribution of these products to thousands of people. Subscriptions
surpassed over 50,000 for some of the blogs before they were eventually deleted.
Defamation and threats published via Yahoo! Inc. internet products and/or email facilities
33. Plaintiff also documented numerous emails hosted by Yahoo Inc. that purport to be
owned by the authors/publishers of the content appearing on Google and Amazon, including
‘[e-mail],’ ‘[e-mail],’ ‘[e-mail]’ and
others. After litigation was filed against a defamation suspect, Plaintiff began to receive
additional threatening emails from Yahoo accounts linked to the Google/Amazon sites.
17

34. On December 4th, 2012, Plaintiff received an email from ‘[e-mail]’
purporting to be from the author of the defamation using an email signature bearing the name
Mark S. Simpson. In this email, the John Doe author going by the name of Mark S. Simpson
taunts Plaintiff and sends him a second email to stating he/she didn’t send the first email, but that
his/her account had been ‘hacked’ by Plaintiff. Because this second email reply was cc’d to
attorneys and Board member of AST, this email stands as an act of defamation on its own, as it
falsely accused Plaintiff of illegally accessing email accounts operated by these John Does. This
is similar to the posts made on Google/Amazon that claim the authors did not publish the
defamatory content appearing on the sites, but that their accounts at Google/Amazon were
‘hacked’ and that some unidentified third party (or Plaintiff himself) posted the content.
35. On April 7th, 2013, Plaintiff received an email death threat from
‘[e-mail]’ referring to matters consistent with the theme of the defamation.
This email is threatening Plaintiff with everything from death to false imprisonment. This email
also threatens Plaintiff with financial ruin and includes a threat against Plaintiff’s mother, who
the Defendants had illegally stalked and conducted surveillance against while she worked at a
local strip mall. After Plaintiff’s mother resigned her position at the mall as a result of the threat,
Defendants then left another death threat atop Plaintiff’s mother’s car. Defendants had been
conducted similar death threats against Plaintiff and his family for years since 2009.
36. On April 20th, 2013, Plaintiff received another death threat email from
‘[e-mail]’ referring to matters related to their defamation campaign. The email
references a threat that Plaintiff is on a ‘hit list’ of people that are being targeted by the
Defendants with illegal subversive activities. The existence of this list is verified as since the
18

moment Plaintiff had come into conflict with Defendants in 1987 (after reporting their leader for
illegal molestation activity), these Defendants and their Hollywood supporters have thereby
shadowed Plaintiff throughout his life for decades and launched many bizarre attacks against him
for over 26 years since the conflict began.
37. The Defendants have registered dozens of Yahoo email addresses showing a clear
preference for this email platform and the sophistication/security it provides to engage these
‘anonymous’ illegal threats and defamation against Plaintiff. All these death threats have been
forwarded to FBI without response due to the fact that the suspected John Doe defendants are
clearly politically-connected as they claim in their blogs. The Defendants have shown ability to
suppress any federal investigation into their conduct confirming they have co-conspirators inside
the US government helping them evade arrest by obstructing Plaintiff’s attempts to report them.
The previously described emails are attached as Exhibit 41.
Conclusion
38. ISP Defendants and John Does wielded sophisticated internet news/media/email
products to facilitate the spreading of defamatory communications about Plaintiff to millions of
people. By reason of the per se defamation engaged against Plaintiff by Defendants, Plaintiff has
been forced to suffer impairment of his good name, public embarrassment, humiliation,
impairment to his professional reputation, public impairment of his abilities and integrity,
anxiety, public ridicule, loss of past and future employment, mental pain and anguish, and
additional damages. An affidavit concerning the Defamation is attached as Exhibit 37.
AS AND FOR A FIRST CLAIM
Declaratory and Injunctive Relief
19

39. Plaintiff repeats the averments of paragraph 1 through 38 as if fully set forth herein.
40. By reason of the foregoing, the John Doe Defendants malicious defamation and
threatening communications, which they caused to be published via the ISP Defendants internet
facilities, constitute libel per se for which all Defendants are answerable for damages under
Delaware State law.
41. That this Court order ISP Defendants, Google Inc., Amazon Inc. and Yahoo Inc. to
immediately provide to Plaintiff all evidence in their possession that will help identify the John
Does defaming and threatening Plaintiff via their facilities. Plaintiff also asks this Court to order
the ISPs to provide the IP/Mac Address used to publish each defamatory communication cited in
this complaint. If an IP/Mac Address address used by a John Doe to publish a defamatory article
cited in this Complaint is not sufficient to identify the John Doe, then the Court should order the
ISPs to also provide any information given to register the accounts with the ISPs, or any other
information that could help identify the publisher of each individual communication, as
preliminary investigation by Plaintiff concerning possible IP addresses involved in the
defamation indicate that there are multiple Defendants spread out over several countries. The
Court should also order the ISPs to provide Plaintiff any statistical information gathered by them
concerning each defamatory communication, including the number of hits for each webpage,
locations (but not identities) of viewers, number of defamatory books sold and income generated.
42. In the event that the ISPs are not in possession of any records that could help to
identify the John Does that operated these accounts, that this Court immediately order ISPs to
disclose to Plaintiff all external entities that had access to their equipment to be able to
intercept/record data related to the accounts identified in this Complaint, and to disclose any
20

cooperation between ISPs and external entities, including but not limited to government
agencies, where the cooperation allows these external entities the ability to also capture data
streams passing through the ISPs that could identify John Doe defendants which are defaming
and making threats against Plaintiff.
AS AND FOR A SECOND CLAIM
Tortious Interference with Contract
43. Plaintiff repeats the averments of paragraph 1 through 38 as if fully set forth herein.
44. By reason of the foregoing, John Does are tortuously interfering with a previous
settlement contract reached between Plaintiff and AST in case number 10-431-RGA by
attempting to induce both parties into violating the Contract which cannot sustain under
Plaintiff’s inability to obtain information concerning the identity of the John Does defaming and
threatening him. ISP Defendants are also engaging tortious interference with the contract if they
do not immediately act to provide all information necessary to identify the John Doe Defendants.
45. Plaintiff is requesting $1,000,000 from the John Doe Defendants for tortuously
interfering with this previous settlement agreement, which has cause Plaintiff to incur substantial
damages to his ability to return to Morocco due to the collapse of the settlement causing Plaintiff
to once again fall into conflict with the Moroccan military due to matters related to this litigation.
46. In the event that the ISP Defendants are unable to provide identifying information
concerning the John Does that operated accounts they hosted which are the subject of this
Complaint, or if the ISPs are found to be negligent in their obligation to maintain records of
individuals that use their facilities to publish material onto the internet, Plaintiff is thereby
requesting an additional $1,000,000 from the ISPs for tortious interference with Plaintiff’s
21

settlement contract due to the fact that their products are defective by virtue of being designed in
any way that does not take every reasonable step to minimize the ability of anonymous
individuals being able to use these advanced internet media publication products to post
anonymous defamation.
AS AND FOR A THIRD CLAIM
Negligent and Intentional Infliction of Emotional Distress
47. Plaintiff repeats the averments of paragraph 1 through 38 as if fully set forth herein.
48. By reason of the foregoing, the actions of the ISP Defendants in failing to secure
their facilities to prevent John Does from publishing false and defamatory communications
concerning Plaintiff constitute negligent infliction of emotional distress. The ISP Defendants
should not allow any individuals the ability to publish articles using their facilities, without first
verifying that the content of the published material is not defamatory. In the event that the ISP
Defendants are also found to be negligent in their duty to verify, to a reasonable standard, the
identity of users of their advanced blog products, the actions of the ISP Defendants would also
be negligent in allowing users the ability to operate a blog in such a manner whereby a user
cannot be directly identified for service of process in the event such a user publishes defamatory
content that the ISP Defendants are not capable of screening before final publication is made via
the ISP’s facilities. Plaintiff is willing to forgo any financial compensation from the ISP
Defendants in the event they are able to produce evidence that can identify the John Doe
Defendants, but in the event that they are found unable to produce any evidence concerning the
identities of the John Doe defendants because they failed to implement procedures (such as
telephone verification), before allowing users to register accounts such as the ones cited in this
22

Complaint, then Plaintiff is requesting $1,000,000 from the ISP Defendants as compensation for
Negligent Infliction of Emotional Distress.
49. Plaintiff is also requesting $1,000,000 in damages for Intentional Infliction of
Emotional Distress from the John Doe Defendants, because it is clear that their actions are
deliberate, intentional and designed to harm the defendant with violence if possible.
AS AND FOR A FOURTH CLAIM
Damages for Libel per se
50. Plaintiff repeats the averments of paragraph 1 through 38 as if fully set forth herein.
51. By reason of the foregoing, John Doe Defendant’s malicious and willful defamatory
published statements have damaged the Plaintiff and are actionable for damages under the law of
the State of Delaware.
52. Accordingly John Doe Defendants should be held liable for damages to the Plaintiff
in a sum exceeding $75,000 and yet to be determined by a jury.
53. In the event that the ISP Defendants are unable to provide Plaintiff any information
concerning the proper identities of the John Doe Defendants, Plaintiff is also asserting that the
ISP Defendants are additionally liable for damages to the Plaintiff for libel in a sum exceeding
$75,000 and yet to be determined by a jury.
PRAYER FOR RELIEF
WHEREFORE Plaintiff respectfully demands this court enter judgment in its favor and
against Defendant Simpson as follows:
1. Ordering the ISP Defendants to immediately provide all evidence in their possession
that will identify the John Doe Defendants, and enjoining the ISP Defendants from allowing the
23

John Doe Defendants any future access to their facilities, and ordering the ISP Defendants and
the John Doe Defendants to immediately remove any remaining defamatory statements still
contained on the offending products, and ordering the ISP Defendants and/or the John Doe
Defendants to print retractions of their Defamatory publications, and to remove from sale any
novels containing defamatory allegations attributable to the Plaintiff.
2. Awarding on the Second and Third Claim for such compensatory and punitive
damages for the Defendants tortious interference with the 2012 Contract in the sum of at least
$1,000,000.
3. Awarding on the Fourth Claim, such compensatory and punitive damages, inter alia
for emotional distress and loss of reputation of at least $1,000,000, or any sum as the jury may
impose.
4. Granting such other and further relief as the Court deems just and proper, including
the costs of this action and investigative costs associated with gathering evidence in this case.
JURY DEMAND
Pursuant to Federal Rule of Civil Procedure 38(b) Plaintiff hereby respectfully demands a
trial by jury of all issues triable of right by a jury.
Respectfully submitted this 28th day of August, 2013

/s/ Younes Kabbaj_____
Younes Kabbaj PRO SE
1844 N Nob Hill Rd #222
Plantation, FL 33322
[e-mail]
561-223-9777

24

Exhibit 38

25

Mark Simpson - Google+

+You

Search

Images

Maps

Play

YouTube

News

Gmail

Drive

Calendar

More
Sign in

Mark Simpson

Posts

About

Add to circles

Photos

Videos

Tagline
I'm a nice guy, first and foremost: gentle, loving, kind to animals, especially
hunky ones in jeans! I like to laugh and have fun, and equally I like to be
quiet and work on my writing. / Je suis un gars très sympa: douce,
aimante, gentil aux animaux, en particulier ceux poilu qui porte le jeans !
J'aime rire et s'amuser, et aussi je voudrais être calme et travail sur mon
écriture.

Worked at Moi-meme (self)

Attended University of Leeds

1,020 IN HIS CIRCLES

Introduction

Radhika Sharma

My favorite color is blue, I like strong and masculine men who are also
kind; I'm a family-oriented person, and definitely a one-man dog! / Ma
couleur préférée est le bleu, j'aime les hommes forts et masculins qui sont
aussi gentils ; Je suis une personne axée sur la famille et certainement
quelqu’un que sois fidèle et dévote uniquement à un homme

Federico Wiem…
Luis Guto

Bragging rights
I am a total egghead on the surface, good grades in school, Ph.D. with
Distinction, many, many awards from Phi Beta Kappa to being one of only
fifty Fellows of the Library of Congress. However, I'm a simple boy at heart
and proudest of little things in my life, like raising my cat, my plants, my
view over rooftops./Je suis un intello totale sur la surface, de bonnes
qualités à l'école, Ph.D., avec Distinction, prix beaucoup, comme de Phi
Beta Kappa à l'un des seuls cinquante Fellows de la Library of Congress,
etc. Cependant, je suis un garçon simple au cœur et fiers des petites
choses dans ma vie, comme élever ma chatte, mes plantes, ma vue sur
toits. !

Alexei Genova
Paolo Gav
Aaron Haas

261 HAVE HIM IN CIRCLES

Occupation
I'm a writer / je suis un ecrivain

Employment
Moi-meme (self)
L'écrivain (writer)

Education
University of Leeds
University of California, Riverside
Report / block Mark

Gender
Male
Settings

· Help · Send feedback

©2012 Google - Terms - Map data © 2012 : Terms of Use - Content Policy - Privacy - English (United States) / Set region

https://plus.google.com/102751852946887364961#102751852946887364961/about

Exhibit 39

26

Blogger: User Profile: Mark Sutherland Simpson

Mark Sutherland Simpson

My blogs
Eliza's Orange
Mark Sutherland Simpson

About me
Gender
Industry

Publishing

Occupation

Writer

Location

Paris, Ile de France, France

Introduction

First and foremost I love literature; I live for my writing, and reading two or
sometimes three books a week. No kindle allowed in this home! I travel a
fair amount, and am anxious to settle in one place. New York will always
be home. However, I love Paris, Melbourne, San Francisco, Portland,
Quebec City and Mexico City. Also, I like being gay ... sometimes I watch
a man just doing something, like feeding the parking meter, and I'll think, "I
really like men, the way they move, stand, behave. It's a good thing I'm
gay." I'm a normal person, in that I am not free of certain prejudices or
biases. I admit this upfront. I believe everyone is biased. For me, my chief
problem is with Islam, which I cannot abide. I'm working on it.

Favorite Books

View Full Size

Male

I love The Shooting Party (Isabel Colgate), Madame Bovary (Flaubert),
Brideshead Revisted (except for the anti-semitic part, by Evelyn Waugh),
Annam (Christophe Bataille), and finally On The Water (H.M. van den
Brink)

On Blogger since
May 2012
Profile views - 77

Help Center | Terms of Service | Privacy | Content Policy | Developers
Copyright © 1999 – 2012 Google

http://www.blogger.com/profile/10595979589183199636

Exhibit 40

27

Blogger: User Profile: Mark S. Simpson

Mark S. Simpson

My blogs
.If Kerouac and Rimbaud were lovers: The modern gay man's blog

About me
Gender

Male

Industry

Publishing

Occupation

Writer

Location

New York / Paris

Introduction

I'm a cool guy, nice and rather shy, who has been bashed around a little
by life. So, I can't say that I've lived out the American dream. That said,
I'm generally chipper, upbeat and (at least to myself) witty.

Interests

Music, especially French contemporary.

View Full Size

On Blogger since
October 2012
Profile views - 19

Favorite Movies Les parapluies de Cherbourg
Favorite Books

To the Lighthouse, Past Imperfect, Eleven, High Fidelity

Why does the taste of pennies remind you of losing a tooth?
I can't remember ever tasting a penny, which makes sense ... I'm not keen on putting things
like coins and other bacteria-ridden objects in my mouth. I do remember losing my teeth as
a boy, and being skeptical (I was always a tad precocious) about the tooth fairy, since he or
she gave me less than my friend Dennis for the same size tooth!

Help Center | Terms of Service | Privacy | Content Policy | Developers
Copyright © 1999 – 2012 Google

http://www.blogger.com/profile/03299136927808961600

Exhibit 41

28

[e-mail]
From:
Sent:
To:
Cc:
Subject:

Identité particulière / Private <[e-mail]>
Tuesday, December 04, 2012 4:53 PM
[e-mail]
[e-mail]; [e-mail]
Re: I'm in New York ... and you know it.

How dare you write to me. How did you get this address and why are you sending such a lengthy diatribe to
me?
You make up fake emails from me and then answer them??? Good grief.

__________________________
Mark S. Simpson
The link ed image cannot be display ed. The file may hav e been mov ed, renamed, or deleted. Verify that the link points to the correct file and location.

You cannot find peace by avoiding life.
-

Virginia Woolf –

Vous ne trouvez tranquillité en évitant la vie.
De : "[e-mail]" <[e-mail]>
À : 'Identité particulière / Private' <[e-mail]>
Cc : [e-mail]; [e-mail]
Envoyé le : Mardi 4 décembre 2012 16h45
Objet : RE: I'm in New York ... and you know it.

Mark Simpson,
1

I do not wish to have this conflict with you outside of a courtroom.  From Morocco until today I have consistently sought 
to have a court mitigate this issues that have developed between us because of your discriminatory hatred of me, but at 
every turn you have chosen to flee the court proceedings you provoked with your unlawful activities against me.

You need to obtain an attorney and respond to the most recent complaint, originally filed against you in Southern 
District of New York, which was thereby transferred to Delaware District Court due to the terms of the settlement 
agreement I reached with AST which required me to go through Delaware to sue you for any new violations of the 
settlement agreement.  You can find all the case information on the marksutherlandsimpson.com website, and you can 
download extra copies of the complaint to compliment the two that were already served upon you in Portland and New 
York (for which your deadline to answer is just a few days away).

Don’t think for one moment that you can evade this court process, or otherwise prevent me from obtaining a legitimate 
judgment against you in a court of law since it is clear that you have not yet overcome your obsession to harm me.   I am 
well versed on technology matters and am conducting a world‐class internet investigation to preserve, maintain and 
obtain evidence regarding your new round of crimes.  I am using a professional third party forensic investigator to 
collect and document all the web postings you have made and deleted in the past several months, and you are causing 
me to incur substantial costs to maintain this investigation of you, and these investigative costs have already run into the 
thousands.  I just hope you know that it doesn’t matter that you delete your posts, I have 24/7 monitoring on all your 
sites and the second something goes up, it gets archived into an evidence locker.  In fact, if you change just one word on 
any of your posts and repost them, I will get an alert telling me that a post has changed.  I am fully aware of every single 
thing you have posted up about me on any of the sites you controlled since the day I was again alerted to your most 
recent activity.  

All this evidence is being collected by a third party computer forensics litigation support specialist and the evidence is 
being held in a digital evidence locker (which I am now forced to pay monthly storage fees to maintain) just to ensure 
you cannot attempt to claim in Court that I have tampered with evidence, as you constantly have been claiming from 
afar.  Don’t think that the technicalities and complexities related to an internet case will prevent me from bringing you 
to justice.  I will be able to lay a foundation for all evidence I seek to submit to the courts and should you show up to 
court seeking to deny the defamation, you will very quickly sabotage yourself even worse than all the self‐sabotage you 
have forced upon yourself by continuing to pursue me in an unlawful manner.  I have not even started with my 
subpoenas and other discovery tools that I will utilize to further document these matters.  I even have leads on your 
activities through my website, and have acquired additional information from people responding to the website from all 
over the world including Ireland, France, California and to New York.  I also had process servers attempt to serve you at 
your “book readings” in Australia (before I finally located you), and they told me that the book readings were all fake 
and that there were no such events occurring at the universities you listed in your fictitious book tour.

Please don’t make me start approaching your friends and family to ask them for help in getting your cooperation with 
this court process.  I understand that you are claiming to have mental disorders.  If this is the case then I don’t mind 
settling my claims against you in a fair way, but you must print retractions on all your websites exonerating me of your 
allegations so that your readers are apprised of it, and you must perform other acts to ensure that I am no longer 
subjected to unlawful activity due to your mental issues.  Since you are refusing to appear in court, you are risking me 
sending certified mail to everyone else you know (including sister, brother, friends from California and others that I have 
been able to track down) just to continue to gather a record of your refusal to respond to the court process.  If you think 
that the best strategy is to just evade the court process and perhaps show up to a court several years later after I finally 
start to lien your property, hoping that by that time evidence is no longer available or the case is harder to pursue, you 
are wrong.  I am going to meticulously close every possible back‐door you could use to evade being held to account for 
your crimes, and I am diligently doing this as we speak.

Mark, I really don’t care what you want to do with your life.  I am not to blame for your inability to pursue a career in 
education.  You are entirely to blame for that and quite deservedly so.  If you want to now reinvent yourself as a soft‐
porn gay blog author, I could care less.  What you cannot do, however, is defame me on your websites and in your 
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books.  You are lucky you are not in jail for all what you did, and to then pop up again defaming me after I finally allowed 
you to walk away in one piece just earlier this year (at the behest of the school), is like adding insult to injury and it will 
not be tolerated.

Younes Kabbaj

From: Identité particulière / Private [mailto:[e-mail]]
Sent: Tuesday, December 04, 2012 3:16 PM
To: [e-mail]
Subject: I'm in New York ... and you know it.

So, do I get the money for turning myself in?
I'd be careful about posting things at the moment. You know the old rule about these things ... for once thing,
you have incorrect books there, and you have a book published by Slavica Press, not self-published ... and my
master's thesis, which was never published. I'd love to see it published. Also, a book published by a registered
company may or may not be self-published, it's a gray area.
Enough with the silly website, don't you think? Really? It's a bit weird.

__________________________
Mark S. Simpson
The link ed image cannot be display ed. The file may hav e been mov ed, renamed, or deleted. Verify that the link points to the correct file and location.

You cannot find peace by avoiding life.
-

Virginia Woolf –

Vous ne trouvez tranquillité en évitant la vie.

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[e-mail]
From:
Sent:
To:
Subject:

Message to Younes <[e-mail]>
Sunday, April 07, 2013 9:56 AM
My Man <[e-mail]>
Message

We are former colleagues, staff, students and current friends of Dr. Simpson. We have been watching all the
needless pain and suffering that you have caused Dr. Simpson through your complete lies, fabrications and
bogus exhibits. We have faith in the judicial system and we know that Dr. Simpson will prevail.
However, be clear about a few things:
1. Though he does not yet know it, we have started a trust fund for Dr. Simpson's defense. It is growing by the
day. We will make sure that he can successfully defeat you in all 50 states, in any district court or any other
venue that you bring legal action against him. Our trust funds will assure that he has the best possible defense
team against all of your lies from now until hell freezes over;
2. We are setting up a separate trust fund for your former employer, AST.
3. We will soon reach out to Dr. Simpson and AST to encourage them to begin proceedings against you to
recoup every ill gotten gain you have ever received. Yes, we can and we will do everything in our power to see
that you live out your life either penniless, or the run from the authorities (or both).
4. The single MOST important item for you to note: Under the best circumstances, you will do us all a favour
and simply drop dead. However, we will be happy enough if you just get thrown back in prison and they throw
away the key.
Let us be clear: Stopping you in Delaware is only the first step. We will make sure that the full breadth of legal
action is taken against you. There is nowhere to hide from legal justice.
Never, has the been a more useless or poor excuse for a human being on this planet. Do humanity a favour - go
play on the freeway.
Thanks for providing your email (what a wanker) on the NY complaint you attached to
http://www.marksutherlandsimpson.com/. It is refreshing that a lowlife like you know that we are on to you.
We are everywhere - maybe even at the strip-mall. Talk with you soon.

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[e-mail]
From:
Sent:
To:
Subject:

[e-mail]
Saturday, April 20, 2013 3:37 PM
[e-mail]; [e-mail]
So ...

it can't be stalking and evading at the same time. Oh dear. You seem to have painted yourself into a corner with
that one, as well as violated the persons' with disabilities act. Poor thing. It just gets worse and worse.
Don't you think it's time to just be quiet and ... you know ... go away and just be a check-out clerk at Walmart or
something?
So many fundamental contradictions are befuddling. People taking medication that prevents an erection don't
have sex ... so why would they need a prostitute? And what would they do with that prostitute? Very weird ...
well, that part is not surprising, you define weirdness. I imagine your life has been sad and that you have been
constantly teased and tormented because of your strange and peculiar ways. Certainly everyone who has met
you thinks you're weird ... so either everyone is wrong or ...
You are such a worthless human being, which I know you know. Worthlessness stares you in the face every
morning.. Can't you find some way to do something productive to do with your life? Or is preying upon peoples'
and instutional resources your only sense of how to make a living? Sad, so sad.
According to the Moroccan Consulate in New York there are no arrest warrants for any crimes in Morocco for
the people you mention ... you, however, are on what is described as "the list." You don't suppose you're lying
do you? My G-d ... that wouldn't be like you at all, would it ??? In any event, the Consul General is most
gracious, and one is quite reassured by him that the welcome mat is out in Morocco for all and sundry EXCEPT
you ... so, going there for a vacation sounds like fun !
You know you're mentally ill, I hope. Because you are mentally ill ... seriously and utterly.

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