lawsuit against 12/23/13 1:'1.-me IN THE UNITED STATES DISTRICT COURT FOR THE MIDDL A DISTRICT OF TENNESSEE AT NASHVILLE . ZMBUECZ3 PH h-k5 . . Li? or Chris Sevier MIDDLE. Li.) I -UV - Plaintiff V. ARTS AND ENTERTAINMENT NETWORK GLAAD, CASE Honorable Judge Campbell TELEVISION GROUP, WILSON CRUZ, Barack Obama COMPLAINT FOR IIWNCTIVE RELIEF AND DECLARATION (Making God's Ways Priority) Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 1 of 92 Page|D 1 Page 1 N91 lawsuit against 12/23/13 1:52 PM NOW COMES 1, Chris Sevier, under the equal protection clause, due process clause, first amendment of the United States Constitution filing this complaint for damages against et. al. pursuant to Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. 2000e, et seq. ("Title and 42 U.S.C. 1983. I guess you could say, "Hey, I with Phil;" I too would rather go hunting than interview with Barbra Walters. This action is brought in response to the Defendant's unconstitutional and inexcusable discrimination against members of my church, which I am a member of, because of our position that the Bible is correct when it classifies homosexuality unambiguously as both a "sin" and abonination for good cause. It is what Mr. Roberson represents and the political climate of our country that servers to establish "quasi-state actions" for the purposes of the Constitution claim under the totality of the circumstance test. The Defendants were trying to send Christians a message by targeting my brother in Christ, andI have a message for them embodied in this Federal action brought before the United States Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 2 of 92 Page|D 2 page 2 M91 lawsuit against 12/23/13 1:52 PM District Court. Like Mr. Roberson, I have a continuing economic expectation with the Defendants, and I now because of their reckless decision without due process, I myself directly have the reasonable apprehension of being discriminated against under the "chilling effect doctrine." This fear of inevitable discrimination for being a Christian, who ardently opposes something as despicable as homosexual conduct gives rise to a claim under 28 U.S.C. 2201 against the Defendants, who are obviously furthering the "pro- gay" agenda through their "symbolic" and "joint" relationship with the Obama administration, which has reduced itself to the poster child of poor leadership. It was not by accident that President Obama felt "compelled" to inject himself in this controversy after the fact to try to reverse the damage caused by his backfiring social agenda that blatantly affronts the will of God. [For opposing counsel and the Court to note, I am going to provide pictures and write this complaint in layman's terms to assist the public in understanding the legal concepts involved in order to deflate some of the tension in this matter that provokes passion for good reason. Many of my friends believe have bought into the argument that gay people were born that way - I don't buy that whatsoever - but I ask for leeway in that regard]. od's Laws Are ucx stars aw -YTPI 4 Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 3 of 92 Page|D 3 page 3 01:91 lawsuit against 12/23/13 1:52 PM 1. HATED, BIGOTRY, MISDIRECTION, DISHONESTY, RED HERRING: It is not hate speech for Christians to condemn with extreme language activity, which the God of the Bible expressly opposes. In fact, it is scriptural to "hate the things that God hates." That is, Christians have not only the right but the duty to openly hold a life style of prostitution, rape, homosexuality, murder, theft in extreme contempt without the fear of being wrongfully classified as a "bigot" or "hate mongers." The Christian church to include the one that Mr. Roberson and I belong to consists of broken people, who have committed a verity of sins, who seek restoration, redemption, and healing through a relationship with the God of the Bible through his son Jesus Christ. We repent of these sins and make best efforts to live our lives in conformity with the way that our Lord and Savior Jesus Christ and God instructs us through the Bible. All of us are in need of The Great Physician, its simply that the people in the local church have come to realize this, and tumed their hearts to God. It is not by accident that a litany of christian organizations, like Healing Place which is also in Louisiana, Joyce Meyer Ministries, and thousands of other local churches, take such a huge role in prison ministries in a deliberate effort to show God's love to people who have lived life styles that are both criminal and worthy of extreme contempt to the point of literal imprisonment to protect themselves and society from harm. [The local churches Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 4 of 92 Page|D 4 Page 4 01191 lawsuit against 12/23/13 1:52 PM need to be doing more to help our brothers and sisters at CCA and the Department of Corrections help rehabilitate inmates by introducing them to God our transformative healer]. To mischaracterize a Christian as a "bigot" because he vehemently opposes self-evident destructive activity is both a red herring and act of dishonesty that warrants extreme scrutiny and contempt. Such a tactic impeaches the integrity of the pro-gay-activity plight to begin with, further undermining its legitimacy that has been absent since the inception of mankind. What is truly hate mongering is for one to check their brain at the door and join this "insane gay-rights bandwagon" that elevates man's ways above God's. To dress up, people engaging in gay behavior as a class for the purposes of equal protection analysis is flagrantly racists and sanctionable hate speech. The lies to which the pro--gay proponents go through to spread their gospel of spiritual death is astounding. What our Nation and the world desperately needs is more role models on T.V., like Mr. Robertson, who embody what it looks like to make best efforts to live out the Christian life in a culture that has lost its way. 2. WE LIVE IN A CHRISTIAN NATION We live in America, where the idea of Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 5 of 92 Page|D 5 Page 5 om lawsuit against 12/23/13 1:52 PM persecuting Christians is intolerable under the Civil Rights Act of 1964 and for law under res ipsa loquitar. We do not live in Egypt, Iran, Syria, or Iraq where persecutions of Christians is a way of life and their are literally Christians being killed daily throughout the globe for making God the priority in their life instead, of placing their own selfish desires on the throne of their hearts like those living the gay life style do with disastrous results. It was not by accident that Nation" in Church of the Holy Trinity 12. United States, 143 U.S. 457 (1892). A vast majority of our laws stem directly from the Bible. The concepts in the Bible have always constituted a yard- stick of sanity in a Universe that was self-evidently designed by the Creator referenced in the Bill of rights, Whose impression can be readily identified in the hearts of our founding Fathers. Put simply, doing things God's way Works, and everything outside of that plan does not, and produces disaster and wrath because history has demonstrated that God is justice. Whether we like it or not, Benevolent God, who is full of mercy and grace, will bring forth justice on a culture that turns its back on Him. Its just a fact jack that remains fixed in time whether we believe it or not in the same way that the laws of gravity are at work whether we believe it or can see it. Case 3:13--cv-01450 Document 1' Filed 12/23/13 Page 6 of 92 Page|D 6 Page 5 01:91 lawsuit against 12/23/L51 DUCK DYNASTY 55 - 3. 3. There are currently 2 billion Christians on the earth and 45 0,000 churches in North American alone. decision against Mr. Robertson was a deliberately calculated and symbolic injury to all of them, to include myself. The adverse administrative action was part of a concerted effort to create a chilling effect by targeting a public figure like Mr. Robertson in a political climate where "same sex" marriage is at the forefront of social politics. The fact that nearly everyone in this Country is talking about this matter, the fact that gay marriage is the most "white hot" Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 7 of 92 Page|D 7 Page 7 Om lawsuit against 12/23/13 1:52 PM political issue of our time, the fact that We are spiritual beings, the fact that President Obama has chimed into this affair directly, and the fact that clearly intended to create a chilling effect to advance a political social agenda of President Obama establishes more than enough to assert "quasi state action" to support a cause of action under the Civil Rights Act and Constitutional Free Speech. Therefore, this Honorable Court has subject matter jurisdiction over these affairs. 4. BLESSED ARE THE PEACEMAKERS, BLESSED ARE THOSE WHO ARE PERSECUTED FOR RIGHTEOUGNESS SAKE, LOVE YOUR AND PRAY FOR THOSE WHO PERSECUTE YOU, TURN THE QTHER CHEEK But I tell you, love your enemies and pray for those who persecute you. Matthew 5:44 5. To be clear, I by no means am directly representing White Ferry Road Church (WFR) or Phil Robertson. As a Court Officer you could suggest that I am designed to be what amounts to a symbolic avenging angel. I plan on keeping them out of this litigation, as much as it is possible, in reigning down accountability on these deplorable conduct of the defendants in my resolve to rectify this flagrant injustice. I did not seek nor ask for WFR or Mr. Robertson's permission to Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 8 of 92 Page|D 8 Page 8 0,91 lawsuit against 12/23/13 1:52 PM file this lawsuit because under the circumstance, I have personal standing to vigorously pursue the Defendants under the fullest extent of Federal and state law at my election. Subject matter jurisdiction is present here to support this cause of action through a trial on the merits. The expected position of my church, White Ferry Road and Mr. Robertson, is that they are praying for the salvation of those who are persecuting us, imploring God that our persecutors come to having the same life giving relationship with Jesus Christ that we have. Our paramount fight is not against any individual, to include the Defendants named here, but against the ideas and lies that made the Defendants act the Way they did here. (See Ephesians 6:12). Under these circumstances, an injury to Mr. Robertson, is a direct injury to all of the members of WFR, along with all Jews and Christians who Bible come into agreement with the Bible instead of their the gospel of pop culture. I am one of those members who is being discriminated against vicariously as a result of the Defendant's discriminatory actions that were crafted to serve a political purpose, as ratified by President Obama's direct involvement here by his own admissions. Besides being a missionary and former combat officer I am a Court Officer, and as all Court Officers, it is our duty to stand up for those who are being wrongfully oppressed, under the transferred right of self-defense, when they feel so convicted to be responsive in order to put a stop to the flood gate problem of persecution that exists in countries around the globe that can be ignited by a single act of discrimination. As this Court has seen in other actions lodged before it, I disfavor the misconduct of adult bullies, especially those who masquerade, as being one thing but are really another. That kind of parallel abuse is present here. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 9 of 92 Page|D 9 Page 9 Om lawsuit against 12/23/13 1:52 PM CARE Condemned Iranian Pastor Refuses to Renounce His Religious Beliefs ll Ill EGYPT VICARIOUS INJURY AND TRANSFERRED RIGHT OF SELF-DEFENSE FOR THE PURPOSE OF STANDING: 6. History has taught us that the persecution of Christians begins with seemingly minor discriminatory actions. By way of analogy, my intervention here is symbolically no different than Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 10 of 92 Page|D 10 Page 1001.91 lawsuit against 12/23/13 1:52 PM what a Soldier serving in Iraq or Afghanistan would do to protect a member of his unit or a citizen in that country, who was being attacked by an adversary with the heart of Al Qeda. Such responsiveness would be in keeping with the rules of engagement and a Soldiers duty in following escalation of force measures to protect the innocent from being harmed under the transferred right of self-defense. I am here to indirectly stand in the gap for Mr Robertson, myself, and other Christians to stop dishonest tyrants from persecuting Christians for putting God's way above their own because the misconduct of the Defendants has generated a vicarious and direct injury. knowingly took a course of conduct, in bad faith, to send a message to Christians to not oppose the same-sex agenda in hopes of advancing a counter-productive-social initiative championed by the Obama administration. But in standing up for Mr. Robertson indirectly here, I as a Christian Court Officer am intending to send the message of my own that persecution of Christians will not stand in this one Nation under God. I also intend to communicate the message that we Christians, who are vested with government powers, will loudly oppose all forms of evil out of an over flow and abundance of love, and those who do not have a relationship with the God of the Bible will never silence our voice, even if they have to crucify us through various self-help measures. We will unapologetically stand against homosexuality in the same way that we oppose murder, heroine use, adultery, pride, fomication, sex greed, unforgiveness, and so forth. Yet, we will invite our adversaries to come to know the same transforrnative God of the Bible that we have a relationship with. Thankfully, we live in a Christian nation where we can reign in our Nation back towards God ways as was unequivocally intended by our founding fathers when they created the United States Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 11 of 92 Page|D 11 page 11 0191 lawsuit against 12/23/13 1:52 PM Constitution from the Bible itself. CHILLING EFFECT, FRUIT OF THE SPIRIT, CONFLICT THAT HAS BE PRESENT SINCE THE INCEPTION OF MANKIND THAT IS REMEDIED THROUGH INCLUSIVEE ESS 7. What makes Duck Dynasty the number television show in the County is the authentic fruit produced by the actors, who are not really acting, but are being themselves. The evidence shows that when the networks commissioned the show, they did not expect the Robersons to maintain their Christian values, but to conform to the values of the world. See seconds/the-robertsons/) Besides perhaps being "a low tech family, in a high tech world," who the Robertson's are at their very core are authentic Christians, who make best efforts to place the God of the Universe at the center of their lives. This is why they insist on closing every show with a prayer to our Lord and Savior Jesus Christ, which uplifts believers and provokes the shame in those who believe in themselves, not God. The Roberson's paint a the picture of what submission to God looks like and the results that follow from dying to oneself and living for Christ our Lord. The Robertson's abundant prosperity is direct evidence of their compliance with the moral will of God, as often talked about by Pastors like Joel Olsteen. After several series, no one can deny, to apparently include the President, that the Robertsons are an excellent example Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 12 of 92 Page|D 12 page 120f91 lawsuit against 12/23/13 1:52 PM of a family that has been blessed financially, spiritually, emotionally, and in countless other ways, as a direct result of their conformity to God's ways and not the worlds. The Robertson's bear fruit by being in relationship with God and doing things His way, which makes their show so attractive Americans to the point that even President Obama stated, "There are no bigger fans of Duck Dynasty than Michele and me." (Hollywood has still yet to figure out that the world is groaning for television programing that sets a good example. Americans are fed up with programming that promotes self-destructive values that leave us in spiritual and personal ruin. [Although Rick Santorum did not become President, he has started a Christian television network that is designed to release more uplighting Christian programming to help believers with their walk with God that warrants support]. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 13 of 92 Page|D 13 page 130,=91 lawsuit against 12/23/13 1:Fruit of the spirit richly blessed 9. It has been my personal experience from having gone on overseas mission trips that those who place anything other than the God of the Bible as the head of their life will naturally be opposed to those who do. Those who put themselves first and not God will be at odds. But in a country where the rule of law controls, discriminating against Christians offends the very fabric of our Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 14 of 92 Page|D 14 page 140-I591 lawsuit against 12/23/13 1:52 PM laws is entirely unacceptable under an assortment of causes of actions, as this law suit demonstrates. However, the conflict that exists between Non-Christians and Christians does not need to exist because Christianity is inclusive. It invites all people to come to know the same God of love, through Jesus. The prayer here is that all other people would come to know this God and abandon life styles that place their their ways not God's, at the center. That is the paramount message that Mr. Robertson puts forth, regardless of whether doing so makes him popular with people who are currently living in self--absorption. seam/1' 10. What Mr. Roberson was strongly condemning in his interview with GQ magazine was destructive conduct, not any individual person. But of course proponent of homosexual life style attempt to mischaracterize this because their hearts and minds are evidently depraved, as they prove continuously with convincing clarity. The things of God will always be foolishness through the lens of man, and the ways of man will always be foolishness to the Godly. natural man does not accept the things of the Spirit of God, for they are foolishness to him; and he cannot understand them, because they are spiritually appraised." I Corinthians 2:14. Although we are spiritually and emotionally at different places, this divergence will remain true until the end of time. My friend Bill Maher, for example, thinks Christians are crazy for not subscribing to mans ways, but we would respectfully submit that to trust in ones own mind opposed to the Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 15 of 92 Page|D 15 Page 15 0,91 lawsuit against 12/23/13 1:52 PM God's way is flagrant insanity. In general the worlds way of doing things is to live ones life to gamer the praise of men; whereas Christians do not care about Winning some kind of intergalactic popularity contest. Christians are concerned with making our loving God happy because we have come to know the Creator and want to make Him happy, happy, happy in response to His grace. (We were not looking for praise from people, notfrom you or anyone else. 1 Thessalonians in 13 L. I VICARIOUS LIABILITY AND PERSONAL STANDING IN CONNECTION TO BLATANT RELIGIOUS DISCRIMINATION AGAINST A RELIGIOUS ORGANIZATION THAT I AM A MEMBER OF BY A QUASI-S TATE ACTOR ACTING UNDER THE COLOR OF STATE ACTION IN TARGETING A PUBLIC INVOLVING THE MOST HIGHLY POLITICIZED CONTROVERSY OF OUR TIME THAT IS BEING CHANIPIONED BY THE NETWORK IN DIRECT CONJUNCTION WITH THE OBJECTIVES OF THE OBAMA ADMINISTRATION: 11. Phil Roberson andl are both members of White Ferry Road Church (WFR) located at 3201 7th St.West Monroe, LA, 71291. Ibring this vicarious pro se action as a Court Officer, from my own personal interpretation of our organizations values that Mr. Roberson and I are members of. I have sustained a Vicarious injury here, as well as a direct injury through the "chilling effect" that has taken place, given my continuing business relationship with and the other Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 16 of 92 Page|D 16 Page 160,91 lawsuit against 12/23/13 1:52 PM defendants. I participate in the organization, WFR, as a member of the online campus that assembles at these locations and on the world-wide-web. I attend these meetings from my residence in Davidson County, Nashville, Tennessee. I joined this Christian organization that Mr. Roberson and others belong to, while living in the state of Tennessee. I pay tax deductible tithes to WF from my residence in Tennessee through their website and through my bank account located in Middle District of Tennessee. I am one of only 191 member who was accepted on the WFR private Facebook group because I am in fact member of this Christian organization that Mr. Robertson was speaking on behalf of to GQ magazine with the actual, implied, and ratified authority, as he explained our church's endorsement of the Bible. '1'/ze Ferry Rd. F0771-'ll-jl a Chuch - -- Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 17 of 92 Page|D 17 Page 170,91 lawsuit against 12/23/13 1 :52 PM A44 - '|'ll'SO0IlEll Ell i 1' 12. THE PLAIN LANGUAGE OF THE BIBLE VEHEMENTLY OPPOSES HOMOSEXUAL ACTIVITY VVITHOUT ANY AMBIGUITY: As members of WFR, We unapologetically believe the Bible to be the divine word of God, transcribed by men allowing themselves to be used as vessels of the Almighty. We endorse the plain meaning of the text in Lev. 18:22, Lev. 20:13, 1 Cor. 6:9-10, Rom. 1:26-28, which clearly explains that "homosexuality" is sin that is destructive for (1) society, (2) those who practice the life style, and (3) third parties, who are influenced by it. The Creator referred to in our Bill of Rights, whose allegiance by Christians supersedes state boundaries finds homosexual conduct to be a deplorable abomination state in the Bible: 'Do not have sexual relations with a man as one does with a woman; that is detestable; Lev 18:22; 'Ifa man has sexual relations with a man as one does with a woman, both of them have done what is detestable. "Lev. 20:13; Do not be deceived.' neither the sexually immoral, nor idolaters, nor adulterers, nor men who practice homosexuality, nor thieves, nor the greedy, nor drunkards, nor revilers, nor swindlers will inherit the kingdom of God; 1 Corinthians Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 18 of 92 Page|D 18 Page 18 0,91 lawsuit against 12/23/13 1:52 PM Because of this, God gave them over to shameful lusts. Even their women exchanged natural sexual relations for unnatural ones. In the same way the men also abandoned natural relations with women and were inflamed with lust for one another Men committed shameful acts with other men, and received in themselves the due penalty for their error Romans 13. Like Billy Graham believe in faith that Bible is the word of God. In the Bible, the evidence shows that God did not explain that homosexuality was a sin because he was merely trying to be a "kill joy." Instead, homosexuality is a sin because it is a grossly inferior life style choice that leaves its participants spiritually and emotionally dead ultimately. The God of the Bible classifies homosexuality as "detestable" because he loves us and wants what is best for us. He does not want us choosing a life style that causes us to settle for less. Each of us Christians at WFR can attest first hand of the realities of God and our relationship with him that compels us to come into agreement with His sovereign word that continues to stand the test of time. After all, politics and the culture cannot save our souls, only God can do that through having a relationship with His son Jesus. One of the ways that God speaks to us is through the Bible. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 19 of 92 Page|D 19 Page 19 01.91 lawsuit against 12/23/13 1:52 PM 14. DUE PROCESS REQUIREMENT NOT MET: Mr. Roberson explained Views that stem from the organization I am a member of in an interview with GQ magazine on December 18, 2013. These views were in step with the Bible and views of the church. They are also support by logic and science. In response, took adverse administration action against him without due process, discriminating against him, and members of our organization for beliefs that we hold as sacred and self-evident knowing that Mr. Robertson legally classifies as a "public figure." took these measures in step to further a political initiative acting under the color of a state actor to send a chilling effect to Christians to further a "hot button" political matter. It was not by accident that President Obama involved himself directly in this matter, speaking out against after the fact that engaged in per se discrimination and "hypocrisy." There is more than a symbolic relationship here for purposes of an action arising under the Civil Rights Act of 1964 in a "joint enterprise" between the networks and the Obama Administration. It is a matter of public record that Duck Dynasty the number one watched show on television currently. set out to send a message to Christians in furtherance of a political agenda by taking adverse administrative action against Mr. Roberson to encourage the passing of same sex marriage in our states. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 20 of 92 Page|D 20 Page 20 0,91 lawsuit against 12/23/13 1:52 PM Discrimination here if allowed to stand not only stifles Mr. Roberson's freedom of speech, freedom on expression, and freedom of religion, it unduly infringes upon the speech of all of the members of our Christian organization to include myself (as well as the other 2 billion Christians around the globe who make up the body of Christ and the congregational members in the 450,000 churches in North America). The prosperity for the Defendants to discriminate on the basis of religion in taking adverse administrative action without due process of law is patently un--American. 15. As a former Solider of the United States military and a member of WFR, I should not be required to stand for such blatant vicarious persecution, when I have the reasonable apprehension that will now discriminate against me, given my continuing business relationship with them because I too opposely the Obama pro-gay-activity agenda that offends the commands of the religious beliefs that our Nation was founded upon directly. Combat Veterans like myself and Uncle Si did not risk our lives overseas during a time of war only to see the rule of law be discarded by those foolish enough to believe that their ways supersede God's. That goes for the networks and the President. An injury to one of the members of our organization is an injury to all of us under the straight forward principles of vicarious liability and the guarantees of religious Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 21 of 92 Page|D 21 Page 21 0.91 lawsuit against 12/23/13 1:52 PM freedoms found in the Civil Rights act of 1964. I have standing to pursue accountability of the defendants in this matter in my individual capacity in the jurisdiction under which the injury was personally felt under the straight forward principles of agency law and vicarious transference of damages, given my connection to Mr. Roberson's church. 16. The evidence shows that discrimination took place in Hollywood, California. The Defendants acted in concert to carry out this injurious activity in Hollywood, but I felt the injury in my home state of Tennessee, where I first established a continuing business relationship with the Defendants. When I conducted business dealings in the past with these Defendants, I did so from my residence in the state of Tennessee. The musical content they exploited was created in Tennessee, establishing more than enough grounds for the minimal contact test. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 22 of 92 Page|D 22 Page 22 0,91 lawsuit against 12/23/13 1:52 PM 17. UASI-STATE ACTOR OF PARTNERSHIPS GIVEN THE FACTS OF CONCERTED EFFORT BETWEEN PRIVATE AND GOVERNMENT ACTORS TO PROMOTE THE PARAMOUNT SOCIAL AGENDA OF THE CURRENT ADMINISTRATION: The Defendants, ARTS AND ENTERTAINMENT NETWORK DBA GLAAD, Hearst Corporation, Walt Disney Corp, Obama Administration are partners, agents, and assignees of one another, who acted collectively and individually to bring about an injury that is complained of in this action. The Defendants are jointly and severally liable for the damages they inflict on private citizens and members of other organizations, as they arrogantly facilitate an objective that offends common sense, and is against best interest of our Nation, elevating their ways above God's. In United States, a state actor is a person who is acting on behalf of a governmental body, and is therefore subject to regulation under the United States Bill of Rights, including the First, Fifth and Fourteenth Amendments, which prohibit the federal and state governments from violating certain rights and freedoms. Although at first blush the term would seem to include only persons who are directly employed by the state, the United States Supreme Court has interpreted these amendments and laws passed pursuant to them to cover many persons who have only an indirect relationship with the government. Controversies have arisen, for example, over whether private companies that run towns (the "company-town") and Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 23 of 92 Page|D 23 Page 23 0,91 lawsuit against 12/23/13 1 :52 PM prisons (traditionally a state function) can be held liable as state actors when they violate fundamental civil rights. This question remains unresolved, but the Supreme Court has held private citizens to be liable as state actors when they conspire with government officials to deprive people of their rights. [One does not have to look further than Facebook page to see evidence of that conspiracy, since they openly campion Obama's social agenda and admit to having strong ties to the gay and lesbian community. Additionally, it was not by accident that President Obama was "compelled" to involve himself in this matter, further establishing the connection of a symbolic concerted effort and a joint enterprise (see EXhibits)]. In a handful of states, notably Califomia, state constitutional protections and certain common law rights have been extended to limit private actors. California allows the peaceful exercise of free speech in certain spheres See Pruneyard Shopping Center V. Robins, 447 U.S. 74 (1980); and requires certain types of private actors to afford current or potential members a rudimentary version of procedural due process called fair procedure. Upon information and belief, California law would apply here because the Defendants were acting under their law when they committed the discriminatory act. the nav Agenda C-mphlam Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 24 of 92 Page|D 24 Page 24 0,91 lawsuit against 12/23/13 1:52 PM ICE KICK BIITT 9 (J 18. AND There are a number of situations where the United States Supreme Court has recognized the conduct of individuals or private organizations to be "state action," and therefore subject to provisions of the Constitution such as Equal Protection, Due Process, or the First Amendment. The Supreme Court has held the following: (1) If the government and the private party enter into a "joint enterprise" or a "symbiotic relationship" with each other it is state action (Burton v. Wilmington Parking Authority, 365 U.S. 715 (1961); (2) if the government coerces, influences, or encourages the performance of the act, it is state action (Rendall-Baker V. Kohn, 457 U.S. 830 (1982)); (3) the performance of a "public function" (a function that has been traditionally and exclusively performed by the state) is state action (Marsh v. Alabama, 326 U.S. 501 (1946)); and (4) if government agencies are simply members of a private organization, the actions of the organization are not state action, but if the government is "pervasively entwined" with the leadership of the private organization, the acts of the organization are state action (Brentwood Academy v. Tennessee Secondary School Athletic Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 25 of 92 Page|D 25 page 25 N91 lawsuit against 12/23/13 1 :52 PM Association, 535 U.S. 971 (2002)). I . 1 G, JACK up is on . '0 19. CALIFORNIA LAW MAKES A STATE ACTOR IN THIS CASE GIVEN THE TOTALITY OF THE CIRCUMSTANCES: Here, and the other defendant's principle place of business is in California. The decision to take adverse action against a member of a fellow member of my organization for our shared beliefs took place in Califomia. The defendants were subjected to the state laws that encourage a heightened protection of speech in such a manner that was acting at the minimum as a quasi-state actor, when it violated our organization's free speech. The Defendants should remember that it was the liberals in California who established the low burden classification of what constitutes a "state actor" in order to protected their sacred liberal speech. Just because the applicability of that low standard for applies here in an matter that opposes their traditional liberalize agenda does not negate state actor qualification for purposes of Constitutional actionability. (See Genesis 5 0:20.' You intended to harm me, but God intended it all for good). 20. regularly champions the Obama administration on its' social media pages because it Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 26 of 92 Page|D 26 Page 26 Om lawsuit against 12/23/13 1:52 PM has both a "symbolic" and "joint enterprise" with the Obama Administration to promote the legalization of gay marriage in the states that has been the paramount "white hot" social political issue in our Country for past few years. Therefore, the networks failed to give Mr. Roberson the requisite due process by willfully Violating his civil rights and the rights of an organization and religion that I belong to without a compelling justifiable basis to promote a Presidential agenda. -r 21. THE CURRENT POLITICAL CLIMATE AND GOVERNMENT Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 27 of 92 Page|D 27 P819927 Om lawsuit against 12/23/13 1:52 PM ENCOURAGEMENT FROM THE OBAMA ADMINISTRATION MAKES A STATE ACTOR UNDER THESE PARTICULAR CIRCUMSTANCES: There is no question that the "white hot" political issue currently in our country centers around the gay communities backfiring quest to legalize same sex marriage. The amount of effort mounted by the gay rights proponents in both Hollywood and in the Obama Administration to achieve this unoriginal objective that is grounded in "insanity" is unprecedented. This quest has been around since the dawn of time, but it is the Obama administration that has been maneuvering to make Gay marriage a part of our civilized society, despite the fact that is a clear step backwards towards savagery. To suggest this is no "hate speech" because it is the activity that is hated, not a group of people who are trying to squeeze themselves into a protected class in keeping with a pattern of depraved heart 22. It is also been the Obama administrations overt policies to persecution Christians. As a combat Army Officer and member of the United States Judge Advocate Core, who served in an 06 capacity (Full Bird Colonel) during operation Iraqi Freedom, I can personally attest to seeing Obaina's pro-gay-self-justification activity play out first-hand. The repeal of "don't ask don't tell" and making "proselytizing illegal" in the military were just the first steps in the quest to convert America from a "Christian nation" into a "gay one," elevating mans Ways over God's. The Presidents policies have done more than just weaken our Armed Forces. It has invited disfavor. The President Obama may hold himself out as a man of faith, but his political initiatives are patently against the Bible. He is constantly engaging in misdirection. The fact that the President may say one thing but does not make this any less true. Given the current political climate, there is no doubt that and the defendants were encouraged, influenced, and Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 28 of 92 Page|D 28 Page 28 0,91 lawsuit against 12/23/13 1 :52 PM coerced to take adverse action against a member of my religious organization in such a manner that they could be classified as having acted under the color of the government authority to promote the priority social agenda of the current administration. This is true despite the fact that President Obama thrust himself directly in this controversy and defended Mr. Roberson to his fellow codefendants after the fact. and its partners boldness in punishing Mr. Roberson along with all of the members of our church was the result of their having been embolden to ride the political wave started by their coconspirator the abominable Obama administration to persecute Christians and those who oppose same sex marriages. Riding the Wave VS. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 29 of 92 Page|D 29 Page 29 of 91 lawsuit against 12/23/13 1:52 PM Napping the Wave 23. CHRISTIANS SHOULD BE HAPPY, HAPPY, HAPPY THAT WE ARE ONE LY, ONE BODY IN CHRIST Mr. Roberson and I are part of a church organization that is part of a body of Christ that unites all Christians around the World. We have a saying, "we are one body, one body in Christ, and we do not stand alone." Although I am not acting on behalf of Mr. Robertson or WFR, I have the right to pursue a Vicarious pro se action to curb this bullying that recklessly stifles my speech without just cause. I have a fundamental right as an injured party here to do everything in my power to push our nation back to the principles that not only our Country was founded on, but that create prosperity when followed. Our Nation needs God's favor to maintain super power status. It is the leadership examples set by men of Honor like Mr. Roberson that can help push the hearts of our citizenry towards God. Deep down, President Obama must knows this to be true and that is why him and Michelle are allegedly the biggest fans of Duck Dynasty out there. One Body in Christ, We do not stand alone: Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 30 of 92 Page|D 30 Page 30 0,9, lawsuit against 12/23/13 1:52 PM Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 31 of 92 Page|D 31 Page 31 of 91 lawsuit against 12/23/13 1:52 PM 24. WHAT THE POSTAL AND SELF-INHERE.NT REALITY HAVE IN COMMON: Let's just leave the church aside for a moment, to eradicate any notion that "check your brain at the door Christianity is at play'' because in 2013 it is not. There are a lot of people who have been burned by certain churches in the past who we.re marked with a pharisees spirit, because after all the church is full of people, and we know What people are like, and these matters are undoubtedly sensitive. So, in tuming to a secular rock band other than ZZ top, Death Cab's side project, The Postal Service, release a single "Such Great Heights." The lyrics read, "God himself did make us into corresponding shapes, like puzzel pieces from the clay." One does not have to have much in the way of common sense to use their own two eyes and see that a males body parts correspond with a females. As these lyrics indicate, God obvious created "the Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 32 of 92 Page|D 32 Page 32 0,91 lawsuit against 12/23/13 1:52 PM round peg to go into the round hole" so to speak. When these corresponding shapes are put together, such a union has the potential to be life giving, not only metaphysically, nerochemically, emotionally, socially, but literally. Who would deny that children are amongst our most precious gifts, as the by product of traditional marriage. In a world where the greatest commodity is love and intimacy the act of protecting such an obviously sacred sexual unions within the context of marriage between members of the opposite sex comports with the essence of logic, common sense, and the best interest of the nation. If those traditional marriage unions did not exist, then neither would any of us, since after all artificial insemination is a recent phenomenon. [The evidence suggests that artificial insemination is an inferior form of procreation. See MTV Generation Cryo]. The United States has always been a nation that promotes life, not death (see our position on human rights that stem from the Bible). Accordingly, outspokenness against the self--justifying gay agenda continues to be plausible now, as it has been since the inception of mankind. The weight of the historical record conclusively shows that when a society puts mans ways over God's ways, that society ends in disaster, accomplishing spiritual and physical death. That is because God is perfectly justice. And I am asking that the Court here be His instrument of Justice in fixing these wrongs. [It is disturbing that President Obama pays lips service to being a Christian but he ignores that a central theme of the old testament is that when a Nation turns its back on God, disaster happens until the nation repents of its arrogance and retums to doing things God's way.That is why we have elections]. 25. THE POPE IS DOPE BUT THE SELF JUSTIFYING GAY ACTIVITY PROPONENTS DISHONEST MISCHARACTERIZATION OF HIS POSITION Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 33 of 92 Page|D 33 Page 33 0,91 lawsuit against 12/23/13 1:52 PM IMPEACHES THEIR SHAMEFUL AGENDA TO THE POINT OF WARRANTWG SAN CTIONS UNDER THE FEDERAL RULES OF CIVIL PROCEDURE: Gay Magazine voted the Pope as "the man of the year," which was not done in good faith. Pope Francis encouraged local churches to welcome and embrace homosexuals, which is a message that the church needs to hear. The Pope encouraged the body of Christ to welcome homosexuals into the church in the same Way that the church is expressly commanded in the Bible to embrace prisoners, prostitutes, drug addicts, thieves, rabble rousers, adulterers, skate boarders, EDM singers, porn addicts, rednecks, and all other types. "Hey," WFR has even arduous burden to embrace certified rascal, Uncle Si, tea glass and all, into our ranks. The Pope, like all other pastors to include those at WF and the other 450,000 churches in North America, desire that the church look more like a hospital for the sick than a museum for the righteous. (From the outset, our Lord and Savior, Jesus Christ, recruited prostitutes, tax collectors, and other undesirables to make up his church, who abandoned their life style to adopt His). Christ was more confrontational with the self-righteousness than he was with those categorized as "the sinners"). However, what the proponents of gay-activity intentionally fails to understand to serve their purpose is that neither the pope nor any other church that is part of the body of Christ supports and condones the homosexual lifestyle whatsoever. That is, Christians find homosexual activity to be flagrantly detestable, deplorable, wrecked, foul, unnatural, contemptuous, vile and disgusting, since it is categorically sin under a plain reading of the controlling Biblical text. This nation would be better off if Congress had the courage to passed a Federal law that banded gay marriage across the board. The pro-gay-activity types such wake themselves from their delusions long enough to come to terms with the fact that the Pope has previously called gay Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 34 of 92 Page|D 34 Page 34 0,91 lawsuit against 12/23/13 1:52 PM marriage the work of the devil and "a total rejection of God's law engraved on our hearts." 26. Of course, the pro-gay-activity types will use any form of misdirection available to distortion of the truth to promote their backwards agenda that has always been grounded in shame and dishonesty to accomplish ends that have always been unjustifiable. The fact that those on the pro-gay bandwagon have to misconstrue the Pope's position impeaches their validity and exposes them as acting as abusive fraud mongers that they truly are. The fact that I am hauling GLAAD into court, for their involvement in the injury here it is important to identity that nearly everything that GLAAD does is predicated on dishonesty. However, before this Honorable Court, GLAAD should be aware that they are subjected to perjury liability in the event that they attempt to inflict their patterns of dishonesty that marks their lives on this Honorable Court of record. THE MISCHARACTERIZATION OF THEIR PLIGHT TO ONE OF EQUAL PROTECTION IS PATENTLY RACISTS AND WARRANTS SANCTIONS: 27. Probably one of the most hateful strategies put forth by the proponents of gay-behavior is their vile attempt to mischaracterize their self-justification initative, as an equal protection matter Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 35 of 92 Page|D 35 Page 35 0,91 lawsuit against 12/23/13 1:52 PM that mirrors the race plight. The evidence shows that people were not bom gay any more so than they were born to live any other life style, such as the life style of a meth addict. [There are hundreds testimonials of individuals who became "gay" only to then become "straight," which the gay community does not want to face because they need to live in a persistent state of delusion to perpetuate their own self-gratifying deception]. However, all of us can see with our eyes that people were born with inconsequential pigment variations beyond the realm of their control. "Skin tone" has nothing to do with behavior and is inconsequential for the purposes of human rights determination. For the proponents of gay behavior to misconstrue their agenda as one arising under the equal protection clause in asserting that their choice-based-activity is as uncontrollable as skin tone is patently racists because those things are not equal. Such wicked deceptive practices is per se "hate speech" and offends the civil rights movement and the accomplishment of the 13th amendment, disrespecting all of the millions of people who suffered under our Country's darkest history of actual racism. Sexual origination is not part of the Civil Rights Act of 1964, but freedom to practice religion is most certainly part of that statutory law. The very law that the pro-gay behavior activist attempt to twist to promote their agenda is the very one that defeats them here on the face of the statute. The Civil Rights Act should send the pro-gay activist back under the rock from which they came with nothing to show except an award of sanctions for maliciously attempting to classify their behavior as a race matter. For their willfully perpetrating such fraud on our Honorable Courts in dressing up their plight on the level of race issue to justify their shameful behavior, severe sanctions should be imposed in the face of such flagrant hate under rule 16(t) of the Federal Rules of Civil Procedure Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 36 of 92 Page|D 36 Page 3601,91 lawsuit against 12/23/13 1:52 PM Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 37 of 92 Page|D 37 Page 37 01.91 lawsuit against 12/23/13 1:52 PM . . I0 28. TACTICS SMELL OF METHODOLOGY AND THE SLIPPERY The evidentiary from World War II demonstrates that not only did Himmler want to eradicate the ews, he planned to eventually persecute Christianity into extinction next. [For example, to symbolize that agenda, around Christmas time the Nazi's performed a litany of bizarre ceremonies to establish a slow progression of traditions that they planned would one day replace Christmas]. Christianity is merely the extension of the jewish religion. It picks up "where the Jewish story left off' so to speak, and Christianity was birthed from Judaism. Christianity was started by Jews and continues to beg Jewish people to be a part of the new covenant and stop living for dead tradition. The new testament story is that God has sent His only begotten Son to die for the sins of the world so that all men could come to know the Father, Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 38 of 92 Page|D 38 Page 38 0,91 lawsuit against 12/23/13 1 :52 PM not just the Jews. Himmler was not only aware of that direct connection to Judism but of Christianity's unsurpassed influence, which condemns evil activity, which includes includes mass murder, gay behavior, sex trafficking, persecution of the innocent, and the like. Unlike all of the other world religions, Christianity is centered on being in relationship with God through Jesus Christ. Christianity is not founded on "works based righteousness," like all of the other oppressive religions that literally ultimately enslave their members through insufferable obligation through the use of fear tactics, which leaves their members void of fruit, stripped of peace, joy, and life. 29. Furthermore, the grace based faith distinction makes Christianity so powerful and threatening because we Christians are literally plugged into a material power source that gives birth to love, joy, peace, patience, kindness, gentleness, self-control, ect. That is, we Christians are connected to the Creator that our Bill of Rights understandably refers to for good cause, which makes us different. The only way to stop the Christians is to persecute and them suppress them into silence. That is what Himmler planned to do and that is precisely what did when it took unilateral adverse action against brother Robertson. This is also exactly What the Obama Administration's agenda has set out to accomplish in a direct and round about way, which explains the lack of God's favor over his administration and our Nation that is losing sight of the value system that mades America the super power that has always was. Yet, none of this should be considered to be "shocking" because all of this is laid out in the Bible so clearly: when a nation's policies cause it turn its back on God's ways there are terrible consequences for the people in that nation, until that nation repents and returns to doing things God's Way. This is not a story that Christians just made up. It is a reflective pattern that marks history, since the beginning Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 39 of 92 Page|D 39 Page 39 0,9, lawsuit against 12/23/13 1:52 PM of man's existence. Cruz shares the same characteristics as the Networks Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 40 of 92 Page|D 40 P619940 Om lawsuit against 12/23/13 1:52 PM Real Life. Drama; As a Elder in my church, Mr. Roberson tells GQ that he does not like these characteristics beouse it is against the Bible Neither should the 2 Billion Christians on the earth to include those believers who are shareholders in the networks. 30. INTOLERANCE OF THE TOLERANT IS INTOLERABLE IN A COUNTRY THAT Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 41 of 92 Page|D 41 Page 41 01:91 lawsuit against 12/23/13 1:52 PM PROTECTS RELIGIOUS AND FREE SPEECH UNDER THE CIVIL RIGHTS ACT OF 1964: In terms of having zero credibility whatsoever, proponents of the gay life style advocate a position of "tolerance;" however, when anyone disagrees with them to include members of a Christian organization I belong to, they find such activity to be "intolerable" and lash out through reprisal measures that make a mockery out of due process and the very rights they alleged protect them. Their only remedy is to persecute their opponents into silence so they can left alone feel less guilty about a destructive life styles that produces adverse consequences for others. The gay behavior debate has been going on since the inception of mankind. It was indirectly address by Aristotle in his discourse on "the old speech verses the new speech." (The end result of the fruit of establishing a pro-gay society can be found in Genesis 19 in Sodom and Gomorrah. It has always ended disastrously for the nation that rejected the ways of the Bible and turned its back on God, suggesting that mans ways are better). Proponents of gay activity have been attempting to convince others around them to see their activity as acceptable since the beginning of humanity. Of course, gay activity will never and has never been seen as anything other than offensive as a contemptuous life style that is marked by inherent shame, delusional reasoning, and a litany of distortions that Warrants contempt by everyone because we should have a reverence for God's commands, which parallels the universal law that was discussed at Nuremberg and found in the hearts of our founding fathers. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 42 of 92 Page|D 42 page 42 om lawsuit against 12/23/13 1:52 PM GOD 1: Donotworship any other gods 2: Do not make MAN 5: Honouryour father 8. mother 6: Do not murder any idols 3: Do notmisuse the name of God 4: Keepthe Sabbath holy 7: Do notcommit adultery 8: Do notsteal 9: Donotlie 10: Do not covet 31. OVER PLAYED HAND EVIDENCE OF STATE ACTOR THANKS TO WILSON BIGOTRY TOWARDS CHRISTIAN S: The church has a saying, "the devil always over plays his hand." Wilson Cruz of GLAAD, who upon information and belief, has established a partnership with and has more than just tangential ties to the Obama administration, retorted to Mr. Roberson's position in GQ: "Phil and his family claim to be Christian, but Phil is lies about an entire community fly in the face of what true Christians believe. He clearly knows nothing about gay people or the majority of Louisianans -- and Americans -- who support legal recognition for loving and committed gay and lesbian couples. Phil 's decision to push vile and extreme stereotypes is a stain on and his sponsors who now need to reexamine their ties to someone with such public disdain for LGBT people and families. 32. Mr. Cruz spoke on behalf of his codefendant's with actual, implied, and ratified authority, making them all vicariously liable, while imposing a chilling effect on my speech, as he articulated threats in underscoring the prospective adverse economic consequences of Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 43 of 92 Page|D 43 Page 43 0,91 lawsuit against 12/23/13 1:52 PM championing the Christian discourse. Due to Mr. Cruz's self-evident poisoned heart, what he threatened on behalf of GLAAD and constitutes interference of contractual relations, which is an actionable tort. Those threats on the basis of religion interfere with my contractual relations with the Defendants. Additionally, Mr. Cruz's reckless statements were clearly made in furtherance of the Obama administrations herculean effort to have the counterproductive gay marriage laws by the states and ratified by the Courts. We Christians do not condoned the gay behavior because the kind of dark-heart Mr. Cruz that the activity produces as demonstrated with convincing clarity in Mr. Cruz's intemperate response to stifle Christian speech, which amounts to a violation under Tort law. 33. Cruz/Obama/A&E VS. Si/The Christian Community/proponents of family values Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 44 of 92 Page|D 44 Page 440,91 lawsuit against 12/23/13 1:52 PM 34. IF A MAN LOVES A IF A WOMAN LOVES A WOMAN THEY WILL PREPARE THEM TO BE A BETTER SPOUSE FOR THE MEMBER OF THE OPPOSITE SEX: To suggest that those who are proponents of gay activity are blind and self- deceived is a gross understatement. It is self evident that if a man loves a man, he will encourage the man to be a better man, helping his brother develop his character in part so that he may potentially someday be a better prospective mate for his female counter part. If a woman loves a woman, she will help her sister become a more virtuous woman in part so that she someday can be a better prospective spouse for her male counter part. This does not leave room for the idea that members of the same sex should be molesting each other, which serves to not only deplete oxytosen levels but causes them to miss out on a prospective life giving relationship that with the potential of being marked with God's favor. In stepping away from Christianity, even Aristotle spoke of two types of friends, friends of virtue and friends of pleasure. A true friend acts in love to help the member of the same sex to become more virtuous. A friend of pleasure involve two individuals who help each other experience pleasure even if the long term consequences are terrible. The pro-gay-activity types fall into this second type "friends of pleasure", and these two forms of "love/friendship" are by no means equal. As Mr. Robertson stated, "this is a matter of Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 45 of 92 Page|D 45 Page 45 0,9, lawsuit against 12/23/13 1:52 PM logic." [For the record, fornication falls into the "friends of pleasure" category and is equally opposed as homosexuality]. um: DUQK on!" 35. There are many drug users who believe that their drug dealer loves them because their products make them feel a certain way, but they have a consumer relationship that pushes one another towards spiritual and physical death, while exposing them to criminal liability. Emotional feelings do not necessarily legitimize reality. The same can be said of same sex couples, who deceive themselves into believing that what they are doing is "love" because it feels a certain way, when they are settling for less and poisoning their hearts and minds through a dysfunctional reinforced reward cycle. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 46 of 92 Page|D 46 Page 4601.91 lawsuit against 12/23/13 1:5., run-vi Ky?" oi' 36. DOS AND FIRE BRIMESTONE MISCHARACTERIZATION: What pro-gay-bully types, like Defendant Cruz, really hope is that this lawsuit is a hell-fire-brimstone one. But to suggest that would be just another one of their dishonest misdirections to garner support for an unjustifiable plight that distorts love, falsely packing the matter up as an equal protection matter. This action is brought forth out of love. What members of our organization suggest is that the paramount focus of Christianity is not a list of "dos and don'ts," to include "don't be gay," "don't be a liar," "do not fornicate," "do not look at porn online,'' and so forth. (Religions like Hinduism, Buddism, and Islam are centered on "works based righteousness," religions based on degrees salivation by degrees of works do not make any sense, and man will never be good enough to earn God's love through actions). What Christianity emphases is relationship. One of the primary points of our Lord and Savior Jesus Christ is that none of us will ever be good enough to earn our way to God. Christianity focuses on salvation by grace, through accepting Jesus Christ as Lord and accepting his sacrifice as atonement for one's sins, and then building a relationship with God through Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 47 of 92 Page|D 47 page 47 om lawsuit against 12/23/13 1:52 PM Christ. By working on that relationship, the "dos and don'ts" begin to care of themselves following commands such as "don't commit gay acts," "don't stifle speech," "don't commit murder in your heart," and so forth become easy. The evidentiary historic record tends to show that God's way works, and everything counter to that simply doesn't. At first glance, the greatest ding on the Christian faith is that it is exclusive, but that exclusivity is offset by the fact that it is entirely inclusive, inviting all of us to take part in the same life giving relationship that causes the Roberson family to have the number one television show in the Nation. As Pope Francis identified, all are welcome to join our Church family and build a relationship with God through Jesus Christ. Unlike Islam, Christianity is not a cultural religion that amounts to a half baked derivative stemming from egoistical View that man can work his way into God's good graces by "trying hard to follow rules." Christians are commanded to hate the things that God hates. And God hates homosexual acts so Christians are commanded to hate homosexual action, despite the pro-activity--proponents that "if it feels right it must be love." Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 48 of 92 Page|D 48 Page 48 0,91 lawsuit against 12/23/13 1:52 PM Have Your Buddy's Back JESUS IS EXCLUSIVE {mun 37. BANDWAGONING OF DISHONESTY: I am not sure why it is so difficult for my friends, living in New York City and Hollywood, two cities that I live in as well, to comprehend that the majority of world does not live like them or share their values? The vast majority of the World, to include those living in America, are proponents of traditional family values. There are billions of parents out there trying their best to raise a family, and what we do not need is Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 49 of 92 Page|D 49 page 49 om lawsuit against 12/23/13 1:52 PM Hollywood getting rid of roll models like Mr. Roberson because the gay community is still trying to convince everybody that their self-evidently unnatural behavior is appropriate. decision sent the message that it is ok for employers to discrimination against their employees on the basis of religion, which should have this Court concerned). From the dawn of time, those trying to get others to come into agreement with them that their gay behavior is proper have merely been dressing up the same argument in different ways. Society does not need to be afraid of these liberals who are trying to convince the rest of us of that insane agenda is legitimate, simply because they say that their "love is real because they say it is." 38. Through shows like Glee and shows on the logo network, Hollywood has gone to unimaginable links to silence the voices who have the courage to call "a spade a spade," identifying that which is harmful as exactly that, only to promote conduct that produces a dysfunctional and shattered life. Hollywood has done an outstanding job of making the case to our Nation that the purpose of life is to win some universal popularity contest, when in fact trying to make everyone happy through appeasement was patently Anti-American from the start, when our founding father's established our Nation. 38. Those who are influenced by Hollywood Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 50 of 92 Page|D 50 Page 50 om lawsuit against 12/23/13 1:52 PM VS. E. 40. ACCORDING TO THE BUSINE SS JUDGMENT RULE NETWORKS NEED TO REALIZE THE JERESY SHORE T-SHIRTS SELL BUT THE DUCK DYNASTY MERCHANDISE BE KEPT ON THE SHELVES FOR GOOD REASON WAKE UP CALL FOR THE SHARE HOLDERS - f92 e|D 51 Case 3:13--cv--O145O Document 1 Filed 12/23/13 Page 51 0 a9 Page 5101.91 lawsuit against 12/23/13 1:52 PM The Defendants needs to take note of the fact that nobody wants to buy an American Hoggers T-shirt. Upon information and belief, there is not a single person in the Universe wearing the "Kardasian family" t-shirt. But the merchandise in stores like Walmart that associate with the Roberson family continues to fly off the selves. This is because we are spiritual beings, and millions of Americans connect with the Roberson family and what they represent. What the Television has become at this point is an evidentiary case study on human nature and spirituality. To suspend Mr. Roberson from a reality T.V. makes the show less real. 42. Yet, allow me to pick on my friend KeSha, who I have interacted with and is from our city of Nashville. I like Ke$ha unconditionally, but I deplore her life style that sets a terrible example for young girls. Ke$ha has a show on MTV called, "My Beautiful Crazy life." The show amounts to nothing less than a documentary of a what a disturbed person, who is suffering the consequences of being raised in a broken, looks like. What Ke$ha promotes whether she knows it or not is "stimulation addiction" and "thrill seeking" in an effort to fill the God shaped void inside of her. Those who subscribe to her example end up getting hurt in a variety of ways. The Gospel she is preaching leads to harm, but the one that Mr. Robertson preaches leads to life abundantly. 43. What we need we need more of is shows like Duck Dynasty that set a good example of what living the Christian life looks like in todays society. We need characters like Mr. Roberson on Television, who set an example of what the end result of submitting oneself to Jesus Christ has the potential to look like. I can honestly say that Duck Dynasty is one of the first TV shows I have been able to actually enjoy, since the HBO series, "Band of Brothers" was released. Not only did the Robertson's achieve finical prosperity they enjoyed spiritual and emotional Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 52 of 92 Page|D 52 Page 52 0,91 lawsuit against 12/23/13 1:52 PM prosperity ever since Mr. Roberson decided that his house would put God first. It is as if program directors in Hollywood cannot allow itself to promote these examples because it would confirm what their hearts have denied - that the God of the Bible and Jesus are real, and the Christian way of living was right all along. 44. LEMONHEADS, LADY GAGA, LAWYERS, GAY GENE, SPIRITUAL BEINGS CIRCULAR REASONING, SILENCING CHRISTIANS: After the firing of Mr. Roberson took place, I elected to engage in a debate with fellow lawyers in Nashville who I respect, who are proponents of gay activity. This debate took place on Facebook. I selected John Strohm, who is the former bass player of the Lemonheads to be my opponent, not only because he is a skilled attorney but because we are friends who disagree with one another on this matter. 42. After a continuing debate on this matter, we concluded that the misclassified "gay rights" matter hinged on whether their was a gay "trait" or "gay gene" that made people act gay beyond their control. (See brilliant philosophers like Lady GaGa, who capitalize on that pathetic self- justify position with ditties like "Born this way.") The evidence would show that mankind is bom Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 53 of 92 Page|D 53 Page 53 0,91 lawsuit against 12/23/13 1:52 PM with a fallen nature. However, the evidence demonstrates that there is not a gay gene, a murder gene, a drug use gene, a thievery gene, nor any other gene that would make someone engage in an activity beyond their control that is contrary to the will of God. However, what is inextricably evident is that we are spiritual beings with a God shaped void. We are all looking for a source of life. All of us to differing degrees have been guilty of trying to fill the God shaped void by engaging in different activity in hopes of experiencing escapism. VS. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 54 of 92 Page|D 54 Page 54 01391 lawsuit against 12/23/13 1:52 PM /3 nlairna A BIIMAIER 45. After much debate, Mr. Strohm, who is not only a law professor and a bright legal mind, final reaction was to argue that he is right because he says he is right. He then ordered me to be quiet, which is the same reaction that had with Mr. Roberson. This reaction from a law professor is frightening because it shows that pro-gay activity proponents will mislabel things as hatred and bigotry and when that approach fails, their only recourse is to demand the oppositions Voice be silence. This pattern has played itself out in a more extreme Way in Egypt, China, Iran, Pakistan, North Korea, and elsewhere. There is something inherently wrong with allowing a slippery slope of persecution to become established in America. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 55 of 92 Page|D 55 Page 55 om lawsuit against 12/23/13 1:52 PM 46. INJURY, CHILLING EFFECT, RIPENESS, DUBSTEP, ELETRO, HOUSE, HARD STEP, COPYRIGHT EXPLOITATION: Annie #1 Iolts. uunmmsamma. On . .. ~-Bommriunn I myself am merely nothing more than a lowly song writer and recording artist of electronic music: soundcloudcom/ghostwars. (Sorry liberals, the songs are for free so this action is not about economic angles). I have had songs placed on myriad of T.V. networks to include songs on Disney, and ABC stations owned and controlled by the defendants. I regularly have my Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 56 of 92 Page|D 56 Page 55 0,91 lawsuit against 12/23/13 1:52 PM copyrighted works of arts placed on their TV programs and have earned royalties, paid out from the PROS headquartered in Nashville as a direct result of these exploitations. These networks have licensed the right to use my songs. Therefore, I have an continuing economic expectation with the Defendants in the same way that Mr. Roberson does, but to a lesser extent. Equally to Mr. Roberson, I am opposed to the destructive agenda of the abusive gay proponents like those put forth by depraved--hearted zealots, like Wilson Cruz, and the employes at who thought wise to persecute a man as wholesome as Mr. Robertson. Like Mr. Roberson, I am openly opposed to the gay life style and ardently opposed to gay marriage because I sincerely care about people and do not want to encourage anyone to live a life style that causes them to miss out on life's best. Gay-marriage-lifestyle will never be seen by the vast majority of people in world as acceptable, no matter if certain states have unwisely adopted it and no matter how much effort Hollywood puts forth to attempt to persuade the public that such a union is valid because logic is being defied. have plenty of friends, to include some lesbian ones, who live life styles that I vehemently despise and do not condone. But that does not mean that I nor the church care deeply for those individuals; we long for them to come to know the same Jesus that we do and believe that if they were to do that the lifestyle problem would take care of itself. We are not interested in guilting anyone, as we are in pointing them towards Christdistributing a new batch of songs to music supervisors, who are employed by the defendants and who licensed my material in the past. However, I am worried that I too will be persecuted and discriminated against because I not only subscribe to Mr. Roberson's beliefs, I am a member of his church's online campus, and fully support every single thing that the Roberson's family represents (too include Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 57 of 92 Page|D 57 Page 5-, 01591 lawsuit against 12/23/13 1 :52 PM gigging frogs from the Country Club pond in the dark of night). Exhibit A: 48. Mr. Roberson is one of our nations best role models, and country is in dire need of men of faith, men of character, men of principle, who center their families on God's way to be on T.V.. Young males especially are in need of heroes. (If the networks were to discriminate against the ''real house wives of Texas" for their self-invented values created from their own minds, I doubt you would see anyone in an uproar, since the civil rights act of 1964 would likely not apply to the religion of "self--absorption." So, if is discriminating against Mr. Roberson for his Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 58 of 92 Page|D 58 page 53 01:91 lawsuit against 12/23/13 1:52 PM beliefs, I am distress over the high probability they will do the same to me, which has created the apprehension of discrimination on the basis of religion and established a chilling effect on my speech to the point that I am sustaining injury that establishes subject matter jurisdiction for purposes of an Article case and controversy. 49. N0 STRANGER TO PERSECUTION FOR MY RELIGIOUS BELIEFS: It should be abundantly clear to this Court by now given other controversies I have been involved in that I am both a whistle blower and no strange to persecution for my religious beliefs. [As the Court has seen in pre-existing lawsuits, I have received actual death threats, after demanding that Apple and Hewlett-Packard comply with the laws that prohibit the selling of obscene pornography to minors.] As a Court Officer, I am a whistle blower because I possess faith in the rule of law and because I believe that our County has the sense to shift back towards Judeo-Christian values, in the same way the Israelities returned to God after turning their back on Him and facing the consequence of their pride. (Our nation is groaning for a retum towards God). I am no stranger to being persecuted for my subscription to judeo/christian values and my belief in the rule of law. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 59 of 92 Page|D 59 Page 59 0,91 lawsuit against 12/23/13 1:52 PM As this Court saw in a matter brought before the Honorable Judge Trauger, I was grossly persecuted by the United States military when serving as a Judge Advocate during the Obama Administration for acting in accordance to my religious beliefs in attempting to report a state Congressman to the Inspector General for violations. I have been mercilessly persecuted by the Tennessee Supreme Court for requiring that their agents at the Board of Professional Responsibility, like Nancy Jones and Krisann Hodges, not interfere elevate themselves above the United States Constitution to derail valid civil litigation to prevent me from holding self-rightous adult bullies, like Celebrity Apprentice victor, John Rich, accountable for trampling on the rights of the defenseless members of our community because it suits his political and economic interests. I have had powerful rich bullies use their economic resources to compel the District Attorneys offices in multiple states to viciously harass me for initiating causes that stemmed directly from my religious beliefs. I should not be required to stand by and watch these pro-gay demonstrate bigotry towards the members of my church, simply because of our beliefs. Our laws do not allow for quasi-state actors, who are acting in conjunction and collusion with the current administration, to take adverse action against a person for their religious beliefs without due process. Here there was a taking against myself and Mr. Robertson. 50. It is time that we Christians come forward and speak out against these unacceptable affronts to our families, taking our Country back from those who would otherwise lead us into ruin spiritual, economic, and social backwardness. But of course, this should be carried out in love because we are commanded to "hate the sin but love the sinner." Our nation did not achieve super power status because of the human strength put forth by the populace. Our Nation was made great due to the hearts of our citizens who bathed themselves in the truths of the Bible and Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 60 of 92 Page|D 60 Page 50 Om lawsuit against 12/23/13 1 :52 PM brought forth God's favor on our lands51. SCIENCE, DOPMINE RECEPTORS, PALOVS DOGS, CLASSICAL CONDITIONING AND THE CONNECTION TO THE APPLE HEWLETT-PACKARD LAWSUIT: Contemporaneously pending before this Court is my lawsuit against Apple and Hewlett-Packard, in which I am demanding that the device makers in our Country heed the call of the British Prime Minister to selling their products in a safe condition that complies with the laws that prohibit the selling of smut to minors. The goal of the law suit as well as the laws that are not being enforced by the U.S. Department of Justice is to to protect women, children, and marriages. More importantly, my proposed solution found in the suggested rule 68 offer of settlement is designed to reduce the demand side of sex trafficking and child pornography. Put simply, the burden should be on those who want to see porn to have to take the extra step to remove the filter, instead of placing the burden on those, who do not want to be poisoned by it to have to block it. As Prime Minister David Cameron stated shortly after I filed my first lawsuit against Apple and HP, "What a minor cannot get in the store, they should not be able to get online." Pom is not harmless speech, and there needs to be more limitation on that kind of speech Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 61 of 92 Page|D 61 Page 51 01.91 lawsuit against 12/23/13 1:52 PM for good cause. We need laws that protect us from us, or we will become so misguided that we will believe crazy things, like allowing same sex marriage should be encouraged and that "gay love is actual love because someone's feelings tell them that it is ok." Evidently We need filters in place that safe guard our hearts so that We will have fewer people that have the heart of the Defendants, who have been reduced to a place where they believed that Mr. Roberson's speech is harmful to society, when what they ought to be concerned about is how their outrageous conduct has violated the business judgment rule.] What secular studies from the Witherspoon Institute and Patrick Carnes prove conclusively is that people become addicted to porn through classic conditioning that plays off of our hardwiring. Us guys are attracted by sight, and what we set before our eyes impacts our hearts and minds. "Getting off" to porn hij acks dopamine receptors and there are nero-chemical shifts that have the capacity to impact one sexually in a variety of averse ways. The reward cycle is interfered with. Similarly, the something has gone awry in the reward cycle of people who engage in gay activity or heroine use. This is what all of the studies are finding. Its seems that the gay proponents not only want to live in denial of the religious implications of their actions, it is too painful for them to face the scientific implications that gay people are merely people who have been lying to themselves and asking that others join in their delusions to support their life style that is rife with adverse consequence and dysfunction. There is no "gay gene," but their is classic conditioning involved as the end result of a poisoned heart and the depraved mind. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 62 of 92 Page|D 62 Page 62 Om lawsuit against 12/23/13 1:52 PM 52. Homosexual men and Women can become conditioned to desire members of the opposite sex because of classic conditioning that is reinforced by orgasm through sexual encounter with the member of the same sex. This principle could apply to beastiality as well, if one were to use 21 animal as a sex object. [There are studies cases of men who prefer a blow up dolls to a real woman because they get conditioned to having intercourse with a blow up doll - causing them to miss out on a superior prospective life giving relationship with a tangible member of the opposite sex. Few things have the potential to be more beautiful than the intimacy based sex between members of the opposite sex in the confines of a convent that can produce life and superior forms of love. The couples on Duck Dynasty are a perfect example of that. Who is this country does not Want to have a marriage that parallels those displayed on Duck Dynasty? Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 63 of 92 Page|D 63 page 53 01391 lawsuit against 12/23/13 1:52 PM 53. What homosexuality, beastiality, blow up doll lovers, and internet porn addicts all have in common is that (1) they are engaging inherently shameful activity; (2) they are settling for less in life style that causes them to miss out on a better life; (3) they are not a class that warrants protection under the equal protection clause because their actions are activity based; (4) their is no chance that their sexual exploits can produce a direct life from the relationship; (5) they set a bad example, encouraging an inferior life style choice for the young generation. What makes homosexual practice particularly bad in this comparison to the other forms is that two people are reinforcing soul poisoning conduct, instead of just one. Fornication between members of the opposite sex is equally contemptuous as homosexual activity, but at least, their is a possibility that the fornicators could form a sacred marriage covenant. (See Senator Fred Thompson, who had a child out of wedlock, married the mother, and remains happily married). FOR LADIES ONLY NOW Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 64 of 92 Page|D 64 page 54 01591 lawsuit against 12/23/13 1:52 PM 54. In the states that gay marriage is allowed, citizens in that state should be able to marry their pets, if they like. Theoretically one could just as easily be conditioned to their pet, computer, blow up doll, ect. The states can't have it both ways. Once marriage is defined as anything other than a covenant between a man and woman, the flood gates should be open for more insanity to follow. The end result is that a society can never flourish in a country where the citizens do things their own way instead of the way God commands. History has shown us that God is patient, but eventually he will pour out his judgment on a nation because he loves humanity too much to see it living a life that affronts his natural design. This position is more than just "nay saying" its a reflection of the historical record. If anything, God prefers mercy over justice. Accordingly, Mr. Robertson's outspokenness against gay living is well founded and not actionable by and the codefendants and more than my speech should be stifled for entirely agreeing with him. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 65 of 92 Page|D 65 Page 55 M91 lawsuit against 12/23/13 1:52 PM 55. REASONABLE APPREHENSION OF PERSONAL DISCRIMINATION ON THE BASIS OF RELIGION: I license my songs to Disney, and other defendants in the past. I am in the process of licensing additional songs with them. However, because I have an actual apprehension that I might likely be discriminated against because I am a member at the same Church that Mr. Robertson attends because I, and all other 2 billion Christians in the world, believe that homosexuality is a "sin," I have the reasonable apprehension of being discriminated against. I am thereby injured economically at this instant moment as a direct result of this undeserved credible fear. That is, the undeserved chilling effect unduly imposed upon me has produced and actionable injury that warrants remedy in a situation that calls into the authenticity of the very laws upon which our nation was founded. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 66 of 92 Page|D 66 Page 55 M91 lawsuit against 12/23/13 1:52 PM - >5 . soundcloudcom/ghostwars THE SIGNIFICANCE OF PRESIDENT DIRECT INVOLVEMENT IN THIS MATTER IN REGARDS TO STATE ACTOR QUALIFICATION 56. On December 19, 2013, Calling suspension of 'Duck Dynasty' patriarch Phil Robertson "a chilling crackdown on free speech in an artistic community that should value individual expression," President Barack Obama urged the Arts Entertainment network to reinstate Robertson immediately, and to apologize for its "hypocrisy." (see exhibit) 57. President Obama stated: "There are no bigger fans of Duck Dynasty than Michele and me. . . .and while I have my disagreements with Mr. Robertson's Views on homosexuality, as expressed in GQ magazine, I'll defend with my last breath Robertson's right to express those Views." 58. The White House acknowledged that the private company has the right to fire Robertson for expressing his opinion, based on the Bible, that homosexuality is one kind of sin among many. Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 67 of 92 Page|D 67 Page 67 0,91 lawsuit against 12/23/13 1:52 PM 5 9. "But the president felt compelled to speak out," said press secretary Jay Carney, "because his silence might be perceived as assent among his many entertainment industry supporters who hold freedom of expression in the highest esteem." 60. By his own omission President Obama demonstrates more than enough evidence that and its partners were acting under the color of state law in discriminating against Mr. Roberson and the members of our church. The President felt "compelled" to speech out. The President "disagrees" with Mr. Robertson's views on sexuality. The President indicates that he watches Duck Dynasty more than anyone else, apparently keeping a watchful on the Robertsons. The President perceived by private networks that a symbolic relationship exists to advance his political pro-gay agenda. 61. The significance of President Obama's involvement in this controversy shows that under the current political climate in this country was acting under the color of state action when it took adverse administrative action against Mr. Roberson without due process. 61. The fact that (1) champions President Obama on their social media sight, the fact that (2) "same sex marriage" is a white hot political issue in America, the fact that (3) President Obama felt the need to contact and involve himself directly in this matter and contact about this matter, the fact that (4) was acting under California state law in Hollywood when it made the decision to fire Mr. Roberson for his religious beliefs, the fact that (5) believed that it was entitled to further the initiatives of the pro-gay-activity set forth by Obama Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 68 of 92 Page|D 68 Page 58 01.91 lawsuit against 12/23/13 1:52 PM administration establishes more than enough evidence of a "symbolic relationship" and "joint enterprise" as referenced in: (Burton V. Wilmington Parking Authority, 365 U.S. 715 (1961); Wolotsky V. Huhn, 960 F.2d 1331 (6th Cir.1992); Kerr V. Holsinger, March 25, 2004 Not Reported in F. Supp.2d. Accordingly, was acting in a way to further a national objective of the current administration that involved the President of his own volition, which establishes that they were acting under the color of a state actor, which establishes subject matter jurisdiction. I CALL UPON PRESIDENT OBAMA TO DO HIS JOB TO ENFORCE CHILD OBSCENITY LAWS, PROVIDING HIM WITH A REAL LEADERSHIP OPPORTUNITY, AND PROVIDING AN EXAMPLE OF THE KIND OF SPEECH THAT NEEDS TO BE LIMITED TO PROTECT WOMEN, CHILDREN, AND FAMILIES Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 69 of 92 Page|D 69 Page 69 0,91 lawsuit against 12/23/13 1:52 PM 62. I do not want to come across as hypocritical myself. Some forms of speech should be limited. This includes the distribution of pornography to minors on devises that connect to the internet, giving them access to pornographic content that poisons the soul. I am asking the President to be responsive to this major social problem that has developed under his watch. Imploring him to do his job as the executive to enforce the law. 63. I want to make it abundantly clear that upon information and belief that both I and the church at large support any President of the United States once they are elected, to include Barack Obama. There are hundreds of thousands of prayers lifted up for our government officials daily by the very church that he has encouraged discrimination against by his programs that affront the will of God in the Bible. In the military we have a saying, "we respect the rank, not the man, for good reason." The only reason his administration is being added to this lawsuit is because of his involvement here and his connection to the Defendants the that establishes state actor classification to support claim under 1983. The purpose of his presence is by no means to harass or embarrass our President nor to unnecessarily divert executive legal resources on a matter lesser importance. We are on the same team. On a positive side note, there are countless things that the Obama administration has done that has been plausible and worthy of respect. My personal favorite was when the President "green lighted" "Operation Neptune Spear," during which the President demonstrated his capacity for real leadership. 64. Since I have the President's administrations attention, I would ask that he do two things. First, to continue to mitigate the damage he caused by pushing this disastrously counterproductive pro-gay-activity agenda, which never has and never will be an equal Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 70 of 92 Page|D 70 Page 70 01591 lawsuit against 12/23/13 1:52 PM protection matter, no matter how badly a group wants to justify a certain behavior. Although the President would like to assert his ways above God'merely a man. Like me, he is merely a lawyer. And from one lawyer to another, I ask him to employ his legal skills to settle this matter as a mediator between the network and Mr. Roberson for the betterment of the Nation. There is no question that his pro-gay agenda is the superseding cause that created this existing controversy. If he was not in office, this complaint would not exist. 65. Second, I would ask that the President take on the leadership opportunity presented in my lawsuit again Apple and Hewlett-Packard. In June of 2013, I filed a lawsuit against Hewlett Packard and Apple to make them comply with the laws that prohibit retailers from selling smut to minors that can be found on the books of every state in our union for good cause. That lawsuit made international news for good reason. The evidence shows that partly in response to the discussion that I started, the British Prime Minister began championing my proposed solutions to make it harder to access pornography online, which would push our world back towards innocence. The evidence demonstrates through studies, like those released by the Withspoon Institute, that online pornography is proliferating the demand side of sex trafficking, child pornography, and reaping havoc on intimacy, marriages, and the quality of life for millions of Americans. 66. The British Prime Minister has called upon our nation to enter a joint task force with the United Kingdom to require device makers and search engineers to shift the burden onto those who want to see porn to have to take the additional steps to access it instead of putting the burden on those who want to encounter porn to have to take the extra steps to avoid doing so. In Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 71 of 92 Page|D 71 Page 71 0,91 lawsuit against 12/23/13 1:52 PM the United States, Google is already being responsive the British Prime Minister's demands, attempting to make it more difficult for porn to pop up in search engines. Google has also responded by deleting thousands of images that could be considered to be child pornography. While that is a step in the right direct to limit this harmful speech, more needs to be done. I need an a Chief Executive who will implement the proposed plan to enforce the law that bars the distribution of online pornography to minors. The Department of Justice is all but ignoring this growing sex trafficking problem, as if it does not exist. The best Way to fight sex crimes is to begin by attacking the vehicle which proliferates the demand side without crossing the line into violating freedom of speech. 67. I am asking the President push Congress and the FCC to promulgate legislation that requires all device makers, like Apple and HP, that enable connection to the intemet to sell pre-installed filters on their products that set those devices to "safe mode." If the purchaser of the product is over 18 and wants to have those filters removed, the purchaser should be able to acquire a password from device maker to disable the filter upon showing proof that they are of age. Requiring this extra step of intentionality will make it establish the requisite accountability that will have a major impact on reducing sex crimes against children, sex trafficking, and the devastating divorce rate. I have created an opportunity for the President to demonstrate real leadership on a nonpartisan issue that will improve his ratings by acting in a manner that protects Women and children. I am asking the President to show the kind of leadership that his hero Mr. Roberson does and carry the fight on this issue in our Country. It is embarrassing the the British Prime Minister is doing more for us on this issue than our President. Congress has the ability to regulate this issue under the commerce clause because the devices are crossing state lines and the Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 72 of 92 Page|D 72 page 72 0,91 lawsuit against 12/23/13 1:52 PM device makers are violating the laws by distributing smut to minors. 68. I am by no means for legislating morality nor am I a proponent of making constitutionally protect pornography illegal. But I am for making it harder to access pornography online because we are spiritual beings, and viewing porn, just like engaging in gay activity, poisons the soul and promotes a lesser form of sex and high jacked capacity for intimacy. Everyone deserves to have the opportunity to be in a marriage relationship like those displayed for us on Duck Dynasty between all of the couples on the show. Pastor Tim Keller, in his book the Meaning of Marriage, was entirely correct, when he said that all forms of sex outside of a covenant marriage between a man a woman are lesser forms that poison the soul and leave us spiritually dead. This would include gay sex, beastiality, self-sex, masturbation, and fornication. [You want to see the case for abstinence - look at Jase Robertson's marriage; you want to see the case against fornication, watch 16 and pregnant]. The heart is the "well spring of life" and we need laws in place that protect it. Proverbs 4:23. Somehow, we have manage to put a man in office who completely ignores this reality to the point of contempt. If the President hopes to turn his administration around, he would be wise to stop elevating his plans above God's and start pushing policies that squarely conform with the sovereign will of the God of the Bible, which is an acronym for "basic instruction before leaving earth" for good reason. Capacity for Leadership -- Geronimo Case 3:13--cv-01450 Document 1 Filed 12/23/13 Page 73 of 92 Page|D 73 page 73 01:91 lawsuit against 12/23/13 1 :52 PM F. David Camieon - Alliesea-ciing the fight aganst seiit trafficl-