Mary Cummins of Animal Advocates sues Amanda Lollar, Bat World Sanctuary, Rebecca Dmytryk, Tiffany Krog, Annette Stark, Eric Shupps for libel and defamation per se. Amanda Lollar, Bat World Sanctuary is represented by Dean Rocco of Jackson and Lewis.Case number 2:11-cv-08081-DMG-MANx.

Link to Pacer docket for this case. You may have to sign in to Pacer to view it.

SUMMARY: I reported Amanda Lollar for animal cruelty, animal neglect, violations of the health code, Animal Welfare Act and other things. They were investigated. In retaliation and with malice Amanda Lollar, Bat World Sanctuary and John Does posted libel, libel per se, defamation, defamation per se on the Internet about me. They stated that Mary Cummins was a "convicted criminal," "commits animal cruelty" besides other untrue things. They stated these same things in communications with government agencies. They were sent two cease and desist letters asking them to remove the libel, defamation. They refused. Mary Cummins then filed this suit against the parties to force them to remove false defamatory items and for damages. This page is posted to clear up the libel and defamation made by Amanda Lollar and John Does. I was also forced to sue them for personal injury I suffered at Bat World Sanctuary. That case information is here.

February 16, 2013: Federal District Court no longer has jurisdiction over some defendants because diversity is lost, i.e. Annette Stark, Rebecca Dmytryk and Tiffany Krog. I am moving the case to Los Angeles Superior Court for those defendants. I offered not to file against those defendants if they remove their libel and defamation. They did not respond so I assume that means they refuse. I wonder how they would feel if someone were to post the same type of defamation about them, sent it to their coworkers, neighbors, family, employers...?

Amanda Lollar and her friends like to pose as young women and post online about me on my pages. Mind you they are at least ten years older than me. Then they attack me calling me old, fat and ugly. Pretty ironic that women older than me, who weigh more than me who are not super models would call me old, fat and ugly. What does that make them? Furthermore, what does that say about them? Petty juvenile individuals. You really have to feel sorry for them.

February 8, 2013: I am suing Rebecca Dmytryk as an individual. It seems she got the insurance company that insures Earthways Foundation to represent her. It appears that she told them I was suing WildRescue. I am not suing WildRescue. Her insurance agent told me to give them a call. I just did.

January 31, 2013: Tiffany Krog is now on her third lawyer and this case just started. She has a history or blowing through a few lawyers such as her divorce or when she was sued couple of years ago. Sandra McMullen is her new lawyer.

This case will soon be transferred or dismissed from this court and filed in other courts. We are awaiting Judge Gee's decision. In the meantime it appears that Amanda Lollar continues to defame me. She posted crap about me on Facebook and my Google page. I saved it, advised Google, Facebook legal to retain all identifying documents. I still have subpoenas in to Google and Facebook. It seems that Amanda Lollar is upset that I posted all of my reports against her online. The Judge ruled they were not defamation. They are true fair reports. This is what Amanda Lollar was trying to keep from the public. I'll be adding reports from others and the authorities against her.

January 17, 2013: Eric Shupps continues to spam Amanda Lollar's defamatory links all over the Internet. How much money is Amanda Lollar paying Eric Shupps to spam up the Internet? In other news the last two orders on this case are void and should be vacated. The case will most likely be transferred to different courts. Amanda Lollar's lawyers over looked a mistake I made back in September.

December 14, 2012: Here are Rebecca Dmytryk's bankruptcy documents.

December 4, 2012: I filed a reply to Eric Shupps' motion to strike or dismiss. Eric Shupps should not have lied to his lawyers. He bragged online that he lived and worked in Los Angeles, California for five years. Sure enough, records search shows he lived and worked here. I also included all the cease and desist emails I sent to Shupps. They tried to claim I did not try to mitigate. Yes, I did. They also said I didn't try to serve him. Again, yes I did but he tried to evade service. He has now been legally served though he got a copy of the complaint the day I filed it. They also tried to claim that what he said was freedom of speech. Stating that I was in criminal contempt of court, I set off a Google bomb, stating I wrote a lot of things I did not write, stating that I control a ton of sites ... is not freedom of speech. These are things he said after the trial that he did not say during the trial. He also stated that I posted filth about him and his family. I posted my trial brief stating that he is not an expert and his analysis is seriously flawed. I also posted his bankruptcy documents. In court he said he was a world renown expert with a successful company. In his bankruptcy docs he admits his company is worthless, he barely makes any money, can't pay his bills, got into credit card debt... Not an honest person. Randy Turner, Eric Shupps, Amanda Lollar, birds of a feather. They live in a very different reality where lying is A-okay.

I filed a motion to reconsider order on defendants' Amanda Lollar and Bat World Sanctuary motion for summary judgment. There is new evidence and there was clear error by the court. Motion to reconsider. There most certainly was clear error as you can see by my motion.

November 30, 2012: I filed a request for entry of default against defendants Annette Stark and Rebecca Dmytryk yesterday. Here it is.. I'll get a judgment and injunction but since they have no assets or a job, I won't get a penny. At least I'll get the blogs down. Since I sued Tiffany Krog one blog has now been made private. LA Animal Pals is now private. The libel that was posted in docstoc.com was also removed. I did send them a demand letter a while ago.

November 27, 2012: I filed notice of proof of service of defendants. They have all been served either through their attorneys or directly. Rebecca Dmytryk did not answer. As she has no assets I doubt she will reply. She'll lose by default and I'll get a judgment against her which I'll never be able to collect. Tiffany Krog and Eric Shupps answered the lawsuit. I reply to their filings tomorrow.

I'd like to take this opportunity to let the public know about one of the defendants Tiffany Adell Krog. She is an attorney with Di Julio law firm located at DiJulio Law Group 330 N Brand Blvd Ste 702, Glendale, CA 91203 at Di Julio Law. Tiffany Krog's bar number is 212915. She was admitted to the bar in 2001. She was an English major at UCLA class of 1997, went to Southerwestern University School of Law class of 2000. She was born 12/20/69 and is 42 years old. That means she was 28 when she finally graduated from undergrad and 31 when she graduated from law school. Why did it take so long to graduate from undergrad? It took her an extra six years at least. She had some problems with the law. Here is her criminal rap sheet. This woman has threatened me before which is why I'm posting it. I live in fear of this woman. Tiffany Adell Krog. I'm not the only person Tiffany Krog has viciously attacked. She also went after people who work for the City of Los Angeles besides others. I've been told she has an alcohol problem and is abusive. I've given my neighbors copies of her rap sheet and photos in case she shows up. That is why I'm posting this information.

Here are links to bigger photos. Tiffany Krog mug shot photo and Few more photos of Tiffany Krog aka Tiffany Ramone

. November 24, 2012: Amanda Lollar of Bat World Sanctuary continues to defame me. She posted defamation about me on wikipedia. It was not even related to the topic. I corrected it with facts then I reported her to wikipedia. Then Amanda Lollar reposted the libel against me and added more libel. I copied all of it along with her signature. She received a warning from wikipedia, "Please do not bring your dispute with user:Mary Cummins onto Wikipedia." If she reposts it, she will be booted.

November 11, 2012: All of the new defendants were served within the last few weeks. You would think they'd take down their libel in response but no. They'd rather have to answer to a lawsuit or lose by default.

November 6, 2012: Discovery is over. No more subpoenas from Bat World or Amanda Lollar. Judge signed a protective order on my medical records. Amanda Lollar and Bat World Sanctuary requested all of my medical records including my gynecological records. I filed motion to quash to protect my gyn records which have nothing to do with defamation or emotional distress. Amanda Lollar still insisted on getting my gyn records. Judge over ruled my quash stating her girlfriend tells her gyn everything. Fortunately Defendants' attorneys made some huge mistakes in their discovery requests, subpoenas. Amanda Lollar was present in my deposition when I was asked about my doctors and such. My doctors which were subpoena'd handed over all documents requested. I bet Amanda Lollar wasted $2-$3K trying to get my gynecological records. I believe Bat World Sanctuary is paying for all of that. Do donors know she is wasting Bat World money trying to harass me and get my gynecological records? Perhaps the board of BWS should vote her out as President.

October 25, 2012: Ironically Amanda Lollar is now posting about anti-internet-bullying. Amanda Lollar is cyberstalking, bullying me by posting defamation about me on the Internet, on her websites, YouTube videos... She is making nasty, catty, childish remarks about my looks on the Internet. Pot calling the kettle black.

September 27, 2012: I just filed my second amended complaint against Amanda Lollar, Bat World Sanctuary, Rebecca Dmytryk of WildRescue, Tiffany Krog an attorney with DiJulio Law Group, Annette Stark writer with LA Weekly and wife to Richie Ramone the ex-drummer of the Ramones, and Eric Shupps of BinaryWave and Sharepoint. I sent emails to Rebecca Dmytryk, Tiffany Krog, Annette Stark and Eric Shupps asking them to remove their defamatory blogs. I told them if they did not remove their defamatory blogs about me, I would add them to the lawsuit. They did not remove the blogs. I added them to the lawsuit. If they remove the blogs now, I will not dismiss them. I sent at least two cease and desist letters to each of them.

September 26, 2012: I just won my motion for leave to amend my complaint. I can add the now known Doe Defendants Rebecca Dmytryk, Tiffany Krog, Annette Stark and Eric Shupps. Filing in the morning.

September 25, 2012: "Someone" tried to break into my YouTube account today. I think they saw my birth certificate online and stupidly thought I'd use that information for my security questions. As my birth certificate has always been public, I never use my real info for security questions. This is the fifth time "they" have tried to break into my accounts. It's not happening.

September 21, 2012: Defendants replied to my reply to their motion for summary judgment. It's not really that fair that lawyers can file electronically and pro ses must file via mail or walk-in during business hours only. Defendants filed at 7:30 p.m. and notified me an hour later. I re-read the Judge's order. I could file a motion to strike their response because they were legally late but I doubt the Judge would like it.

September 20, 2012: I'm preparing more discovery docs for Defendants. I am truly shocked by what they posted about me. I just did another quick search. Here are but a few things which are libel per se. These items are attached to their ip addresses. "Mary Cummins assaults animal caregiver again." I have never assaulted anyone in my entire life.

"Repeated and unremorseful animal cruelty by of Animal Advocates."This woman claims to be a skilled caretaker of animals and has been obtaining and rehabilitating animals for years. However, you can make up your own mind how 'careful' she is by looking at these photos! Don't worry you don't need a degree in medicine to see what's really going on and it's disgusting. Apparently she's been arrested several times for cruelty, but she still continues to obtain and 'care' for animals! She's known for scoffing the law/authority/education/humane practices and doing as she pleases. This is crazy!! With just a little digging around on the internet, I also found that she's a professional stalker! She has stalked more than 40 people including the Ramones, their fans, the mayor of LA who also received an email threatening his life (not so smart), other nonprofit wildlife organizations, attorneys, etc.... Anyone dealing with animals KNOWS that you DO NOT have time for stalking when you're looking after animals. She admits, herself, she's also an accomplished Realtor and even managed to become a broker within a year of becoming a Realtor. I'm not a Realtor, myself, but doesn't a broker's license take a little more time to obtain than that? ... all that WHILE looking after animals. This lunatic must be stopped."

I've never been arrested. I've never been charged with cruelty or convicted. I've never been charged with stalking or convicted. I campaigned for the Mayor of LA. I donated, ran ads for him. I sure as heck did not stalk him. I just found out that Defendants have sent even worse items via email to people. I truly believe these people are "apparently" mentally ill. Who even thinks up such disgusting things?

September 19, 2012: Defendants just filed a motion for errata. They made a mistake in their filing and are trying to fix it. I pointed out their mistake here. Defendants' attorneys are pretty sloppy. I don't know who's actually writing the documents, Dean or Sandra or one of their paralegals.

September 13, 2012: I filed my reply to Defendants' Motion for Summary Judgement here. My statement of material facts is here. They must file a reply in seven days then Judge Gee will rule on it.

September 7, 2012: I believe that Dean Rocco, Sandra McMullan of Jackson & Lewis law firm are DEFINITELY working Bat World Sanctuary for every penny they can get in legal fees. They just wrote more huge filings against me when a phone call would have taken care of things. In the last week I bet they charged Bat World Sanctuary $3,500 in legal fees. This doesn't even include their three legal assistants. Times are tough for lawyers. Gotta milk the few clients that they have. None of these filings were necessary. These filings are over 100 pages each.

September 4, 2012: Defendants were supposed to depose Suddenlink today but it was cancelled for some reason. I bet Suddenlink objected. They had good reason to object. Defendants' attorney Dean Rocco should have subpoena'd them earlier. Now it's too late.

September 2, 2012: Just received Defendants' opposition to my motion to quash subpoena for my medical records. I filed my motion August 4. They had ten days to reply. They replied August 28 if not later. It's not yet on Pacer. They wasted a lot of time on this lengthy opposition. I agreed to stipulate. This was unnecessary.

August 29, 2012: I think Defendants' attorneys are trying to ring up a bill for Bat World. They have three lawyers on this case who must read everything. Dean Rocco is a prolific writer. I offered to give them an email in discovery. They insisted they had to write and file a "motion" to order WordPress to give the results of the subpoena to them. Totally unnecessary. After they wasted that time I instructed WordPress to give them the email. Dean Rocco stated in his filing that he spent so many hours writing his opposition to my motion to quash subpoena. That filing was a copy/paste from another lawsuit. He accidentally left the claims of the other lawsuit in the stipulation. He also accidentally noted the discovery Judge as Judge Gee when it is actually Judge Nagle. We had a conference call today with Judge Nagle. They are very different. Dean Rocco also wasted a lot of time with emails when we could have settled things via one short phone call.

Rocco is making me attend a physical hearing 9/5. He stated it'll take him two hours to attend the hearing. It'll take longer with traffic. The hearing is unnecessary as I offered to stipulate to what he wanted and what Judge Nagle suggested. Amanda Lollar has no income to pay for legal fees. People are donating money to Bat World thinking they are helping bats. No. They are helping a woman who defamed, libeled, harassed me. That has nothing to do with bats. She should tell people that their donations are paying for her attorney. She had to hire an attorney because she personally and aka Bat World defamed and libeled me.

Judge Nagle had a phone conference with Defendants' lawyers and myself earlier today. Nagle cancelled my hearing on my motion to quash subpoena of my medical records stating it was outside of the discovery date by one day which it was. I immediately contacted the court coordinator to state that I told the clerk this when I filed my motion which was filed timely. Clerk stated it was okay. I assume because the date fell on a holiday so the next day would be the final day. Anyway Defendants filed an opposition to my motion stating I was outside of the cut off by one day.

Earlier today I filed a motion to quash the subpoena against Suddenlink. I sent a copy to the court via email as well. My motion stated that the subpoena requested a deposition on September 4 which is one day out of the cut off date. The notice of deposition was also too short, distance from person deposed was over 100 miles, no proof of personal service was attached and no check for mileage and such was attached. I didn't have enough notice to arrange for air fare to Texas. They did not give me the option of telephone deposition which I've done before.

Defendants stated in their opposition to my motion to quash the Suddenlink subpoena that they have until 9/4 because 9/3 was a holiday. In their opposition to my motion they state I'm out of time with a hearing on 9/4. Petty legal tricks because I'm a pro se, as usual.

Phone conference went well. Judge Nagle is fair, just, no-nonsense. She stated their request for my medical records was overly broad. They can't ask for ALL records for ALL time. They can only request related records within two years. Rocco blamed Stephen MacPhail for the overly broad request. She asked who set the discovery cut off date and I said I did. Judge Gee would have checked the calendar to make sure it did not fall on a holiday. I just requested two months. That was my fault. I'm not an attorney no less a Judge.

Final result is we will try to stipulate about my medical records. I offered to agree not to offer into evidence medical records or testimony by any medical expert. There are no records about my emotional distress as it is. The Suddenlink depo will happen as long as Suddenlink does not send any objections. They can legally object for quite a few reasons. I cannot object on their behalf based on my objections. I was allowed to be a part of the deposition via phone as I've done before. I requested all documents given by Suddenlink along with a pdf of the transcript.

I just filed a Motion to Quash the Subpoena of Suddenlink. It's way too late. Here it is. Dean Rocco is jerking me around with this too-late subpoena because I'm a pro se. He's also being paid by the hour. That would explain his long emails to me cc'd to his assistants. That would also explain all this unnecessary paper, hours of work on his part. Bat World is sitting on I believe $60,000 in cash with donations pouring in. Donations to help bats are paying for this lawsuit. Amanda Lollar should tell people this.

August 28, 2012: Interesting development. Amanda Lollar got rid of her free attorney from Chubb Insurance. She then hired Dean Rocco and his two associates. She is paying them $260/hour. This is crazy for Lollar to get rid of Stephen MacPhail who was free, very experienced in these exact types of cases, extremely intelligent and has had a lot of cases in Federal court in exchange for Dean Rocco who has a lot less experience, has never had a defamation, libel or personal injury case ever, didn't realize he missed some deadlines, is wasting a lot of time writing lengthy emails cc'd to two other associates who are also on the clock. His proposed filings also include a lot of errors which he has to waste more time to correct. I read an article where clients generally fire lawyers because they don't feel they are mean enough to the other side. I think that is what happened with Lollar. She wanted MacPhail to be meaner, ask for sanctions... Those things wouldn't have helped her case. This is just petty juvenile Lollar. I will start asking for sanctions on my motions. I can't ask for my time as a lawyer because I most certainly am not. But I am wasting my time and costs on these motions which Defendants have forced me to file.

August 27, 2012: Just got the results of WordPress subpoena. The last two John Does are Amanda Lollar and her Internet consultant Eric Shupps. Did Amanda Lollar or Randy Turner pay Eric Shupps to harass and defame me? Did Eric Shupps do it on his own? What's funny is Shupps made the blogs from his home. It's his ip, isp, area code, zip code, weather station.... He didn't even try to hide or else he doesn't know anything about the Internet. Amanda Lollar tried to hide a little. Unfortunately for her it matched the same ip, isp, zip code, area code of her known Google user account. They knew I was sending out subpoenas. They knew I'd get the information. Why did they do it? I have no idea. I think Amanda Lollar got cocky with her Texas court ruling and thought she could get away with lying like she did in trial, deposition, hearings, admissions... These subpoena results go to me. If Defendants' attorney wanted them, they needed to ask for them in discovery. They did not. It's now too late to ask for them. I made the last legal discovery request. I just emailed and called Shupps to see what type of deal he is talking about. He was too afraid to even answer the phone.

August 25, 2012: Just received Amanda Lollar's discovery. Just more lies like the first batch. She states she doesn't have emails between her and certain people because they don't exist. I have copies of some of them. She'll just end up looking like a liar come trial time. I can't believe she is stating that she doesn't control all of those websites attacking me. Even though she paid extra to have the owner's name not be listed on the Internet, it doesn't mean it can't be known. She even states that she owns the websites and copyright on the websites themselves. She also tries to weasel out of answering these questions using semantics and her personal understanding. The only thing she did admit was to being user citizenwatcher1. She knows I'll get that data from WordPress on Monday. She is most definitely working with Eric Shupps on those accounts. His finger prints are all over the files. And again she lies and states she said "it appears she has a criminal record." She never posted that. She admitted to what she posted in her Texas deposition. In her admissions she states she did not say that I was in "criminal contempt of court." She did admit to being Twitter user CitizenWatcher1 which stated "Mary Cummins is charged with criminal contempt of court." She denied things which she previously admitted in court, through her attorney MacPhail, in deposition and in previous discovery. No credibility.

August 24, 2012: Defendants Lollar, Bat World Sanctuary just sent a subpoena notice of deposition to Suddenlink Internet Service Provider. They are too late. As per FRCP you must give 14 days notice of a deposition. As per the Judge's order the end of discovery is September 3, 2012. Do the math. The deposition site is also over 100 miles from Suddenlink. The subpoena was not served in person. Stephen MacPhail of Bragg Kuluva didn't miss deadlines or violate the FRCP.

August 23, 2012: This is tooo funny. I just received this "anonymous" email. "SOMEONE WHO HAS POSTED BAD THINGS ABOUT YOU HAS AGREED TO DISMANTLE ALL THE NEGATIVE STUFF ON-LINE ABOUT YOU IF YOU DO THE SAME FIRST THE BLOGGING HAS RUINED YOUR LIFE FINANCIALLY BUT YOU CAN TAKE THIS STEP TO MUTUALLY GET RID OF ALL THE NEGATIVE STUFF WHEN YOUR NEGATIVE CRAP LEAVES THE WEB SO WILL THEIRS." One, all caps. Trying to hide writing style. Two, intentional bad grammar. Again, trying to hide writing style. Who could this be? How ever will I know what to remove? ;-) I've only posted negative yet totally honest things about Eric Shupps and Amanda Lollar. Those are the two who currently have posted negative things about me. I made this offer to Shupps earlier but he refused. Instead he posted more crap about me. Is this because the Judge signed the court order ordering WordPress to give me the identities of the two WordPress bloggers who are most likely Shupps and Lollar? How extremely childish. At least they admit they caused financial damages.

August 22, 2012: Amanda Lollar continues to defame me on her websites and blogs. Her "anonymous" comments are so childish. She is really obsessed with my looks. I'm starting to feel that Amanda Lollar may be a lesbian because she's so into my looks. She is again having conversations with herself about me to make it appear that a few crazy juvenile people are attacking me. I'm saving all of her websites and blogs as evidence. I'm amazed her lawyers are allowing her to continue to defame and libel me. This is going to be very embarrassing. The comments are moderated so she is viewing and approving them. She is liable for her libel.

August 18, 2012: Everyone has sent me this "Jury orders lawyer to pay $4.5 million to gay University of Michigan alumnus". Thank you! Some great ideas in there which I will be following. The cases are pretty similar.

Judge Nagle signed my motion to compel WordPress to give me identities of the anonymous bloggers. I believe they will probably be Amanda Lollar and Eric Shupps. Then I amend my complaint to add all teh John Does and other claims as instructed by the Judge.

August 13, 2012: The two missing motions finally found their way to the docket. The hearing is set for August 21, 2012 for my motion to compel WordPress to comply with my subpoena. I'm pretty sure one blog will be Amanda Lollar and the other will be Eric Shupps. Again, they altered the blog dates and keep editing the content.

August 10, 2012: Just got back from Defendants' Motion for Summary Judgment hearing. It was denied today. Judge Gee refused to rule on it because discovery is not over. She will allow me to receive discovery and file a supplemental opposition to Defendants' MSJ. I must file my response by 9/14. Defendants can reply by 9/21. Judge Gee vacated the trial and pre-trial conference dates. She wants us to mediate. Defendants' attorney told the Judge they won't want to settle. I think Mr. Rocco thinks Defendants really won the Texas case. The order has not been signed. It most likely will not be signed if there is any justice in this world. Judge Gee was again polite, professional and fair. Mr. Rocco is not up to date on this case, the issues or his client. Soon he will learn that his client is not honest. She's not even honest with her lawyers. She told MacPhail that the John Does are friends and donors. No, they were not. They were Lollar. She didn't want me to see that she posted all that disgusting crap about me. So juvenile and revolting.

August 9, 2012: Judge just signed substitution of attorney for Defendants Amanda Lollar, Bat World Sanctuary. John Does are still unrepresented as far as I can tell. Some of the Does turned out to be Amanda Lollar. Rebecca Dmytryk is one of the Does, so are a few others.

Related news, my personal injury claim against Amanda Lollar, Bat World Sanctuary and Does 1-10 was not dismissed. Defendants tried to get it dismissed but failed. It was transferred to Federal Court in the Northern District of Texas Case No. 4:12 CV-560. That court has jurisdiction over Palo Pinto County where the initial injury occurred. Judge ruled I can add defamation and harassment related to that case to this case. I will be doing that. At least with Federal court I can appear by phone or filing. No more getting dragged to Texas. I am still suing the entire Board of Directors of Bat World Sanctuary. I will be adding the last two board members soon.

August 6, 2012: UPDATE: Just saw the substitution of attorney filing for this case. The new attorney will be Dean Rocco of Jackson & Lewis. This case may get rolled into the personal injury case I have against Bat World and Amanda Lollar. So far Judge Gee said she didn't want to combine them. They supposedly just need to have the substitution of attorney filings approved by the Judges. I don't know why Defendant would want to get rid of Stephen MacPhail. He did a good job for his client, arguing their side even when they were dead wrong. He only lost those couple of items because I was clearly in the right with a ton of evidence. If it were just his legal ability verses mine, I would have lost every motion. I only have the law, evidence and truth on my side. A blind paralegal in a strait jacket who didn't speak English and had Tourettes could beat me if this case were only about legal ability.

Just looked up the new attorney Dean A. Rocco. He's a newbie. He has only done 14 cases from 2003 to the present. I may have more experience than him? Almost all were civil rights, labor law representing the employer. He was admitted to the bar in 2000 yet didn't do any cases until 2003? I must investigate this more. Can't be true. How can he possibly be a partner in that firm? It is a huge firm. Stephen MacPhail is a lot more experienced attorney than Rocco. I also think he's a lot smarter. MacPhail has been involved in libel, defamation and PI cases for years. Rocco has never been involved in one libel, defamation or PI case ever. Maybe they are giving me to a total newbie because my case is so easy? Like letting the rookies play when their team is way ahead? If that is the case, I'm fine with that. Perhaps MacPhail's boss realized his time is better spent elsewhere. Maybe the new attorney is just plain cheaper?

Hearing on Motion for Summary Judgment and Motion to Dismiss or Transfer Venue are set for the next seven days or so. I believe Defendants will lose those hearings, motions which is why they are trying to roll the cases into one. Stephen MacPhail's MO seems to be he gets cases through discovery then another attorney takes over to settle. The other attorney is a younger guy with little experience. I think he was hoping for an easy dismissal but realizes he can't get one. He stupidly said that my personal injury case could have been rolled into the Texas case. I filed the PI case June 5, 2012. The Texas case went to trial June 11, 2012. It would be impossible to combine them. What, no discovery time? I filed later because I wasn't sure there were assets, money or insurance. Now I know there is. I have a personal injury attorney who may be taking over that case, maybe this one as well now that they know they can get something out of Bat World, Board of Directors, Insurance and Amanda Lollar and her husband Larry Crittenden.

August 5, 2012: Seems Texas attorney Randy Turner may be working with California attorney Stephen MacPhail. MacPhail just made a discovery request which can only help Turner's case. Turner is also now calling me a "sophisticated litigant" which is the same term MacPhail used. I lost the Texas case. How does that show me to be a "sophisticated litigant?"

August 2, 2012: Judge Gee refused to roll my personal injury claim in with this suit. She claims they are different claims for different things with different parties. I didn't ask her to roll the two suits together. Defendants must have asked for that.

July 31, 2012: Here is a sampling of Amanda Lollar talking to herself about me in a few user names on her YouTube channel. Talk about childish. How embarrassing. No wonder she fought the subpoenas. She's since removed quite a few of the comments and blogs she made. I saved copies.

BWSvMC: Repeating what KerryKessler posted: The symptoms of psychopathy include: lack of a conscience or sense of guilt, lack of empathy, egocentricity, pathological lying, repeated violations of social norms, disregard for the law, shallow emotions, and a history of victimizing others. Psychopaths cannot understand the emotional value people attach to certain words, only their​ dictionary definition, thus their attempt​ to use emotional words leads to consequential clumsiness. -Hare, R. (1999). Without Conscience: The Disturbing World of Psychopaths Among Us.

MsJryan72: Mary looks toxic! Wow what an evil human being​ she is. Bottom is a long way down for her!!

Clara24CA: Oh, did I mention that it looks like her hair is doing everything it can to depart her wrinkling head? I've looked better the​ morning after a sorority initiation.(Amanda didn't even finish high school let alone attend college)

Clara24CA: "I've only watched 5 videos so far and I can CLEARLY tell this woman in insane. Who the hell, qualified to scratch their nose in the field, doesn't know that Iso (Isoflurane) is perfectly legal for civilian use almost everywhere EXCEPT California? And beat me with a judge's gavel, but who the hell receives a certificate of being an "expert" in anything? Einstein never received such a document, Dr. Stephen Hawking - to my knowledge - has never received such a document, nor any other individual, scholar or otherwise. I've seen Ms. Scummin's (sorry typo) resume' and if I laughed any harder​ I'd be stuffing organs back up through my privates. She has absolutely NO room to be slapping anyone about education, in my opinion. WHAT A MORON!"

Talk about childish attacks on me personally. Amanda Lollar seems to be very into looks. She really has a chip on her shoulder because she didn't even finish high school. And why is she talking about her privates? Disgusting! On top of this Einstein and Hawking have PhD's. They would mean they are "experts" in their field. Amanda Lollar has not gone past the ninth grade. She is not an expert. Iso can only be used under the order and supervision of a veterinarian. Civilians can't just buy it and use it. Even Lollar admitted she got it from her vet. This law is Federal. California and Texas are treated equally. Perhaps Lollar should have taken a class or two. She really is clueless about these things.

July 30, 2012: The identities of the John Does who've been libeling me are ... Amanda Lollar, Rebecca Dmytryk and a few more. Mainly it's bat lady and her friend Dmytryk. The data also proves they pre-dated the posts to appear to be out of statute of limitations. They aren't. Truly disgusting individuals. Lollar didn't even try to hide. I got supplemental info from Google which PROVES they are these these user names. Lollar got so cocky from her Texas "win" that she felt invisible. She thought she could post anything "anonymously." I really have not met a more despicable, childish, petty, vindictive, nasty individual in my life.

Amanda Lollar pretended to be a 24 year old girl named Clara from California who works with Bat Conservation. She also pretended to be Ms J Ryan born in 1972. Nope, just a 56 year old woman in Mineral Wells, Texas commenting to herself. She sure had some nasty and defamatory things to say about me. Lollar was literally having conversations with herself.

Filed documents for this case this morning. Gave discovery requests in .doc format for MacPhail. Just received court's order, ordering Google to give me the data by tomorrow. Finally.

July 28, 2012: Documents prepared for Monday 10:00 a.m. filing. While preparing these documents I looked at some discovery Amanda Lollar of Bat World Sanctuary had given to me in the Texas case. It looks like she forwarded a fax which I believe Tiffany Krog sent to her about a "Mary Cummins." Proof that they are working in concert.

July 25, 2012: Just filed my response to Defendants' Motion for Summary Judgment. They have no grounds for their motion. It is not even timely because not all of the Defendants are yet known. Response to Defendants' Motion for Summary Judgment. Memorandum of points and authorities Declaration of Mary Cummins

July 24, 2012: Won the hearing on my motion to compel Google to give me identities of John Does. They will be turning over the identifying data. We also took care of my motion to amend that motion to compel. No more hearings with Google. Google never objected to the subpoena. Only MacPhail did. Judge also told me to ask WordPress if they would accept a joint stipulated order signed by the Judge allowing them to give me the data. I already sent that request to them. This way we don't have to have another hearing.

Judge Margaret Nagel was very fair, just and no nonsense which I really appreciated. She said the three "P's" of being a Judge are being punctual, polite and prepared. Turns out Stephen MacPhail's objections to my motion were meritless. I thought so but being a pro se I don't really know.

Minutes from the hearing.

Proceedings: Plaintiff’s Motion To Compel Compliance With Subpoena, Request For Production (“Plaintiff’s Motion”)

The case is called. Mary Cummins, appears pro se. Stephen M. MacPhail, of Bragg & Kuluva, appears on behalf of defendants. Gigi C. Hoang, of Perkins Coie, LLP, appears on behalf of non-party Google, Inc. The Court hears argument regarding Plaintiff’s Motion and GRANTS the same. The Court directs counsel for Google to prepare a proposed Order that Google shall produce certain identifying information, pursuant to subpoenas served upon it by plaintiff, by not later than August 1, 2012. The proposed Order shall be provided to both Ms. Cummins and Mr. MacPhail by 12:00 p.m. on July 25, 2012, for approval as to form. The final version of the proposed Order shall be lodged with the Court by not later than July 27, 2012.

Here is the Google court order.

July 22, 2012: While doing some research just made an amazing discovery. I requested proof that "Mary Cummins" was convicted of credit card fraud in the Texas lawsuit. I received some documents from Lollar. I just read them more carefully. This other "Mary Cummins" was not found guilty of credit card fraud, forgery or anything else. There is no disposition. They pled not guilty. There is no proof that any "Mary Cummins" was found guilty of any criminal acts. Lollar had this document in her possession yet still stated I was found guilty of committing these crimes. No one was found guilty of committing these crimes. Lollar knowingly and maliciously posted that I was convicted of crimes when no one was ever convicted, let alone me. I've never been charged with or convicted of a crime in my life. Rewriting my response to Defendants' motion for summary judgment. This is egregious, malicious defamation.

Hearing for motion to compel Google is tomorrow.

While finishing up my reply to Defendant's motion for summary judgment I realized that Lollar is predating the new blogs she made. She is predating them over a year. Fortunately I have copies from when she first put them up and today. I also noticed that some of the older blogs are still active. New posts and comments are being added. I've copied them. The email address controlling the blogs is still active.

Just finished up my response to Defendants' motion for summary judgement. MacPhail wrote some mean things in here. He also made a ton of typographical, spelling, grammatical mistakes and included a lot of untrue statements. I don't know if he is just repeating what his client told him or if he decided to lie on his own. His motion is also untimely because discovery is ongoing.

July 20, 2012: Attorney Stephen MacPhail just sent a subpoena to my medical doctors for all of my medical records including my gynecological records. Stephen MacPhail is not the attorney in the personal injury case. My medical records have nothing to do with Amanda Lollar's defamation against me. For the life of me I can't imagine such a crazy request. That would be as ridiculous as me requesting Amanda Lollar's medical records.

Stephen MacPhail sent this, "By claiming mental health and emotional distress damages, Plaintiff's prior mental healthcare records are relevant and discoverable under Rule 26(b)(1), Fed.R.Civ.P. Under the federal rules' broad approach to discovery, district courts have held that 'a simple allegation of emotional distress in a complaint constitutes waiver' of a plaintiff's privacy rights including the psychotherapist-patient privilege recognized in Jaffee Fitzgerald v. Cassil, 216 F.R.D. 632, (N.D.Cal.2003) (citing, among others, Doe v. City of Chula Vista, 196 F.R.D. 562 (S.D.Cal.1999))." Wilkins v. Maricopa County, 2010 WL 2231909 (D.Ariz.,2010)"

It clearly says "Plaintiff's prior mental healthcare records." I don't have a psychologist or psychiatrist. I don't talk to my medical doctor about psychological issues. I believe MacPhail may have sent those subpoenas just to harass me. The subpoenas are void because they are not signed, case number is wrong, they are overly broad, they seek medical records and not mental health records and they are harassment. I will file motion to quash.

I just filed an amended motion to compel Google to reply to subpoena and a motion to compel WordPress to comply. Hearing is August 24, 2012.

July 17, 2012: I was denied my temporary injunction supposedly because I couldn't prove permanent damage would occur if the items were not removed. Lollar's attorney said Lollar removed where it said "criminal contempt." She removed it and has since returned it! MacPhail also said she removed the statement calling me a convicted criminal. I have no way of knowing if she did remove it from that one place. She's since reposted it again all over the internet! Amazing, Lollar gets on the TX stand, lies through her teeth and crocodile-tear cries her eyes out saying she's going broke when she's making more money than before and I posted the truth. I tell the truth on the stand and state true damage and nada. On top of this Lollar reposted the things she said she would take down. I sure hope MacPhail realizes that his client is a con and he just lied for her to the Judge. Maybe lying really is the way to go? Unfortunately my strict catholic granny born in 1899 raised me with old school values. I'm starting to miss the good ole days before laws and courtrooms when we settled our differences by just beating each other over the head with clubs. There will be justice one way or another.

I was going through batworld.org website today looking for evidence. Not only did I find some but Amanda Lollar is upping her lying game. She just went crazy on her CV. I'm amazed she didn't say she invented Al Gore, the Internet and God himself.

Second notice of subpoena was sent along with subpoenas to Google/Blogger/YouTube, Twitter and WordPress. Signed by the clerk, proper time frame, served by a process serve in person, request is clear and detailed. Here it is. I requested the same Google user names, blog owners and added the following Twitter accounts @eshupps, @truthaboutmary, @citizenwatcher1, @batworld and WordPress blogs truthaboutmary and marycumminss. Just sent out second set of discovery requests.

They (Amanda Lollar, Eric Shupps, et al?) continue to libel me. Yes, there was such a thing as Junior Mensa. 30 years ago they didn't want kids under 18 to go to the adult events. They generally serve drinks at those mixers and they were for singles. I was dragged to two Mensa events, two too many if you ask me. There are generally just a bunch of single nerdy men who feel they can't meet someone because they are "too smart." No, they just don't have proper social skills.

July 15, 2012: A few quotes from the bible about lying and dealing falsely with others for thought on a Sunday afternoon. Who's a good Christian? Not someone who lies and cheats. I don't lie and cheat people in my job. I don't lie and cheat people period. Nothing worse than a hypocrite. I generally don't quote the bible but bible thumping hypocrites really bother me.

Leviticus 6:1-4, "And the LORD spake unto Moses, saying, If a soul sin, and commit a trespass against the LORD, and lie unto his neighbour…or hath deceived his neighbour…and lieth concerning it, and sweareth falsely; in any of all these that a man doeth, sinning therein: Then it shall be, because he hath sinned, and is guilty,"

Leviticus 19:11, "Ye shall not steal, neither deal falsely, neither lie one to another."

Psalms 119:29, "Remove from me the way of lying: and grant me thy law graciously."

Psalms 119:163, "I hate and abhor lying: but thy law do I love."

Proverbs 14:25, "A true witness delivereth souls: but a deceitful witness speaketh lies."

July 11, 2012: Finally, some good news. My motion to extend discovery and add defendants was approved. "MINUTES (IN CHAMBERS): ORDER GRANTING PLAINTIFF'S MOTION TO EXTEND DISCOVERY TIME PERIOD AND ADD DEFENDANTS [37] by Judge Dolly M. Gee: Plaintiff's motion to extend the discovery cutoff and add parties is GRANTED as follows: (1) The non-expert discovery cut-off is extended to September 3, 2012 (this includes the hearing of any discovery motions). (2) The deadline for filing motions to amend pleadings and add parties is extended to September 7, 2012. (3) The July 24, 2012 hearing is VACATED. (bp)" I will now add Rebecca Dmytryk and others to this lawsuit. I will resend my subpoenas. The Judge stated that the discovery period was short. Stephen MacPhail wrote the scheduling order.

June 29, 2012: I just received a copy of an email which Amanda Lollar of Bat World Sanctuary sent to members of the public. What she wrote is libel and defamation which I will be adding to my lawsuit against her which I filed in California Federal court. Here is my response.

I did not leave after a few days but after ten days. I was not disgruntled. I was disgusted by what I saw. I saw her possessing and giving rabies vaccinations to bats. I witnessed her trying to perform surgery on bats. I saw bats in pain and agony who later died.

The agencies did NOT find the complaints to be without merit. Health dept gave her instructions to follow which she has not followed. She told the USDA that only her vet would do open cavity surgeries from now on. She had even more problems with the health dept. More complaints were filed so she decided to leave town. She sold her building at 115 N.E. 1st St. January 2012. As per city communication the new owner gutted it and put her personal belongings on the street. As per Lollar in trial someone then reported that to the police.

There were two video cameras in the room during my deposition. The second half of the deposition recorded on the wide angle view camera was destroyed, lost, whatever. I had to file motion to compel. They filed a protective order. Judge Bonnie Sudderth ordered them to give me the video. Instantly Randy Turner said the second half was destroyed, deleted, whatever. They obviously destroyed the evidence intentionally. If there was nothing on the video, why did they destroy it?

I have never Google bombed. It's impossible to do that since 2007. Their expert Eric Shupps has no idea what he is talking about. See Wikipedia for Google bomb.Big difference between that and proper SEO.

Lollar's two vets were trained by her. They don't know any better. Her vets don't have any other bat training with true bat experts. Her one vet did not even know that it's inhumane and illegal to freeze a bat to death. He admitted he hasn't been successful pinning bat wings or using nebulizers with anesthesia. Other true trained bat vets have no problem doing this. Obviously, blind leading the blind. The one intern who testified is not a wildlife rehabilitator. That was her first experience with bats. She also doesn't know any better.

I have no history of victimizing people on the Internet. I go after stock criminals and people who abuse and neglect animals, such as Amanda Lollar. I witnessed animal cruelty. The Texas Veterinary Board told me she committed animal cruelty. I found a dead one winged bat under her desk. It'd been dead for days. That is animal neglect. One of her pallid bats was extremely malnourished and shaking. I saw her giving rabies vaccination which is a violation of the health code. I saw her trying to perform surgery on bats. Bats were dying.

If it is rare for a Judge to read a verdict immediately after the end of trial, I believe it's because the Judge was going to rule against me before I even uttered my first word in court. Judge William Brigham also over saw the temporary injunction hearing May 4, 2011. Randy Turner came up behind me and said paraphrased "I've known this Judge for years. He'll sign whatever I put in front of him." And he did. Judge William Brigham signed an overly broad temporary injunction which was void, unconstitutional, overly broad and included prior restraint. I doubt he even read it before he signed it. I saw him flip through the four pages in less than ten seconds.

At the end of her email Amanda Lollar asks people to spam the search engines. She is asking people to spread her libel and defamation far and wide. The sites she links to include libel and defamation. I am currently suing her for libel and defamation in Federal court in California. I will be adding these items to my suit.

June 21, 2012: In the Texas trial Amanda Lollar stated that I cyberstalked ten people. She said they contacted her. She is now friends with them. In court I asked her who they were. She said Council woman Janice Hahn. Janice Hahn apologized to me for calling me a terrorist. She retracted her false statement and apologized in City Council on TV after I threatened to sue her. She did not contact Lollar. Lollar admitted to talking to a lawyer, real estate person, writer for the Rolling Stones and a rehabber. I'm assuming she is talking about Krog, Stark and Dmytryk. Time for more discovery, interrogatories and admissions. Also time to add the John Does aka Rebecca Dmytryk, Suzy Heck... Lollar now states these people are her friends and donors. That means she's working with them. That means she is liable for their libel as they are a related party.

Amanda Lollar has called me a "cyberstalker." Guess what she is doing? Trying to join all of my online groups. Who is stalking whom? You don't see me joining her group.

I am awaiting a document from MacPhail. In the meantime I prepared my motion to compel Google to give me the identities of the John Does. It is here. I wrote one for Yahoo as well. I will probably have to change it after MacPhail gives me his document and motion to quash. Plaintiffs want to quash my subpoena. Stephen MacPhail is the attorney for Amanda Lollar, Bat World Sanctuary. He is not the attorney for the John Does and can't act on their behalf. Now if he's saying the John Does are Amanda Lollar, then he can act for her. That would mean she posted those disgusting items.

June 8, 2012: Amanda Lollar keeps libeling me. She just posted this, "Bat World Sanctuary. Thank you for your wonderful comments everyone! You are all fantastic. I should add that the claims of our building being "gutted," that my "personal belongings" were "removed", that we were evicted and chased out of town by the health department are completely fabricated by our harasser. The bottom part of the building is being remodeled by a new occupant and what was being carried out were garage sale items that we donated to a church. We were never contacted by the heath department or any city officials. All of the bats (and Norbert) are completely safe and sound just like they always have been. We will keep you posted as the trial progresses, that's a promise!"

That is not the truth. Amanda Lollar stated that my claims to the health dept caused her to leave town. This is in writing and part of her lawsuit. The health dept has complained about her for YEARS! The City has written up the building numerous times. The building was gutted and cleaned by the new owner. Her personal belongings were removed as per the City Manager. I never said she was evicted. She sold the building January 2012. She was indeed contacted by the health dept and city officials many times. Norbert lives behind the building on Oak, not the one on 1st St. Delusional! The one good thing is that I can now use her Facebook post to "prove" she wasn't(?) "kicked out by the health department." I can't wait for trial.

Here are the emails about Amanda Lollar being forced out of town and her building had to be gutted. Here are the emails. If the building was so bad that it had to be gutted, why didn't Texas Parks and Wildlife Department do something about it? There were 30,000-50,000 bats in there. Seems one of the people who complained was directly next door at 113. She runs an art gallery. I can't imagine how horrible that must have been next to the smelly sanctuary. Plus, that is where the toddler was bitten by a rabid bat. I doubt the gallery owner wants her patrons to get rabies just from visiting her store. Thank you, gallery owner for reporting her.

June 6, 2012: I properly served subpoenas on various parties. I received most of the results already. I am waiting for more. Amanda Lollar's attorney wants to quash the subpoena as it relates to his client Amanda Lollar and possibly her "friends." I know that Amanda Lollar is some of the user names I requested. I'm pretty sure she is some of the others. Is Amanda Lollar embarrassed that she got caught posting disgusting false things about me? Is she telling her lawyer that her "friends" posted those things when she actually did? Is she lying and saying she posted those things when her friends posted them so she can get free legal aide for her friends? Her D&O insurance is paying for legal representation for Amanda Lollar and Bat World. Is she lying to her attorney to avoid her own embarrassment or to get him to help her friends for free? Time will tell. I will fight any motions to quash. This is not freedom of speech. It is libel per se. I believe Amanda Lollar is the author of the blog thecyberstalker. The lone post was made August 11, 2011 yet it talks about things that happened in my depo which was August 25, 2011. It even has a video of my depo that was posted after my depo. Someone predated this blog to make it seem that the false items were on this blog and Amanda Lollar just repeated what she saw. It's word for word what she said in my depo, in her depo, her sites, guidestar, an article she admitted to writing/posting and other sources. I believe she is the author. Soon I will have proof.

June 4, 2012: Docket updated. Judge has taken motion under submission. MINUTES OF Motion Hearing held before Judge Dolly M. Geetaking under submission 30 Motion for TRO; taking under submission 30 Motion for Preliminary Injunction; taking under submission 30 Motion for Permanent Injunction. Written order will issue.Court Reporter: Anne Kielwasser. (rrey) (Entered: 06/04/2012)

June 1, 2012: In Federal court in CA today Judge Dolly M. Gee stated that Defendants' name calling was paraphrased childish, juvenile, something a five year old would do. She looked at Lollar's attorney and said paraphrased "this should be settled in mediation by an adult." I cannot get an injunction on John Does in Federal court. I have to list their names. I will refile on the John Does, aka Rebecca Dmytryk, Amanda Lollar... Lollar's CA attorney stated they have and will remove libelous posts, comments Lollar made. Lollar lied to her attorney. He said I was only at Bat World 4-7 days. I was there ten days. He said the authorities cleared her of all wrong doing. Definitely not true. He said she removed the libel when I first asked. She did not. She still continued to send it around. Judge took it under submission.

May 22, 2012: Waiting for the results of a couple more subpoenas. I will then amend the complaint and add the John Doe defendants. Rebecca Dmytryk of WildRescue and Suzy Heck of Heck Haven are two of the John Does. While I'm pretty sure I know who the other John Does are I need independent third party verification first. I don't want to have to amend the complaint again.

May 18, 2012: Was going through Amanda Lollar of Bat World Sanctuary's deposition April 6 2012 to prepare for my upcoming trial in Texas. I found some gems in there. I'm so shocked that Amanda Lollar has no problem perjuring herself like this. She can't even remember what she said in her last deposition. She completely contradicts herself. Everything she denies in this depo she admitted to her in previous depo.

Here I asked her to read through a post with comments and to circle what comments she made. She starts ranting on and on about defamation against herself instead.

Q I'm only asking you to tell me which comments you made.

A I'm trying to go through it. I have to speak out loud to go through it so I can understand.

Q You can't think without speaking out loud?

A No, I can't.

Normal people can read or think without speaking out loud. Below I asked her why she loaded up videos of my deposition and then put ads on them. That is of course illegal. I signed no model's release or release of any kind.

Q Why do you have ads on the videos?

A Because the money goes into Bat World Sanctuary's account because you defamed us so badly and we lost so much money that we need to make money in any form to stay afloat.

I can now say this the Judge ruled. She made $95K or so in 2010. She made $170K or so in 2011. She's made at least $50K in 2012 minimum so far. She's making more money than ever before. She told me she was about to go under when I first met her. Always the lying sob story. Below she states I did not do any of my duties as an intern. I fed baby bats and cleaned from 7:00 to past midnight ever day. In the end there we started at 6:30 a.m. I sure as hell did my duties and then some.

A. you failed to do any of your duties during the internship

Below I ask her about the things she previously admitted to saying in her November 8, 2011 deposition. She denies it all here.

Q Did you ever post that I was a convicted criminal?

A No.

Q Did you ever tell anyone that I was a convicted criminal?

A No.

Q Do you have any proof that I am a convicted criminal?

A No.

Q Did you ever post or state that I hacked into your website?

A No.

Q Did you ever state that I hacked into your e-mail address book?

A No.

Q Did you post or tell anyone that I'm a cybersquatter?

A No.

Amanda Lollar of Bat World Sanctuary has no credibility whatsoever. She thinks she can just lie under oath, in court, in deposition.

It's possible our filings will be appropriate for decision without oral argument. My motion for temporary injunction and Defendants' objection could be taken under submission and the hearing vacated. I am prepared to physically attend the hearing and present. The Judge should notify us in writing and via Pacer email if she decides to do this. I will call the court coordinator few days before the hearing.

May 16, 2012: Defendant Amanda Lollar and Bat World Sanctuary want this page deleted. They stated it is a violation of their temporary injunction. I just went through the injunction again with a fine tooth comb. I have not reposted the photos or videos. I didn't repost the articles or content of other links. I actually don't even know what was in some of those links as they were taken down before I ever saw them. Judge Bonnie Sudderth has not yet ruled on their motions to amend the temporary injunction to add more links.

Documents just showed up online. That was fast. Here is just the first part of my reply to Defendants' opposition to my temporary injunction.The Exhibits are huge. You can see the beginning of the replies to my subpoenas. Amanda Lollar and Rebecca Dmytryk so far. More to come.

Stephen MacPhail couldn't file the document for me legally. Here it is. I went downtown and filed it along with my reply to Defendants' opposition to my motion for temporary injunction. My reply was only seven pages but there were a ton of exhibits.

May 15, 2012: Amanda Lollar finally admitted that she wrote those articles in houston.indymedia.org She admitted to writing and posting these items. I signed my notice of withdraw of motion to compel. Attorney Stephen MacPhail was kind enough to digitally file it for me. Pro se's can't file digitally. If I were to file it by mail, it wouldn't end up filed until right before the hearing date. MacPhail would have had to just hope that I really sent it in so it's in his best interest to file it for me.

I saw on TMZ that Chubb Insurance settled their lawsuit with Bret Michaels. That means they paid him because they believed he had a true claim. They would have ended up paying more if it went to trial. MacPhail won't be quite as busy now though I'm sure his boss will probably give him a ton more work. He will have a ton more work once he receives my latest response to his opposition to my motion for temporary injunction. Motion is short but exhibits are about 150 pages.

May 12, 2012: Defendants have filed an opposition to my motion for temporary injunction. I have just written a response. I will confer with Stephen MacPhail before I file it. He may want to retract his affidavit and edit his opposition. I will give him time to do this.

While I was writing this document I went looking for more evidence. In Amanda Lollar's April 6, 2012 deposition she stated she did not write that I was a "convicted criminal." Of course in her November 8, 2011 deposition she admitted that she did write that post. Lying under oath is perjury. Anyway I just found more proof that she did indeed post that to her group. A robot reposted the post here, Board reader post. Obviously a robot is not going to lie or edit the post. Big deal Amanda Lollar supposedly removed the post and made her group private. Her statement is still on the Internet. I will be adding this website to the injunction order. UPDATE: Just got this removed by contacting boardreader. It will take me a few days to remove her other posts.

Just did even more research. Fortunately I have been saving copies of Defendants' blogs and websites every few months. I just compared their current blogs and websites to older ones. My printer prints out a time/date stamp on the upper right hand corner of the document. I save a pdf which also has a digital date of when the file was made. Defendants know they are libeling and defaming me. They have changed the dates of the blogs and posts to make it seem they were made over five to six years ago. They were actually made within the last year. The dates of the blog posts have been altered. They did this after I sued them because they know that defamation has a one year statute of limitations. They are trying to be sneaky. One can't tell when a blog post was actually made by looking at the date on the blog. My print-outs with time/date stamp tell the correct date.

May 8, 2012: Just received the results of some of my subpoenas. The John Does are Rebecca Dmytryk of WildRescue and Amanda Lollar of Bat World Sanctuary. More John Does to be unveiled soon. You write a false and totally defamatory review on GreatNonProfits.org and Guidestar and you will be sued.

I will file a notice to withdraw my motion to compel after I have made sure that Defendants gave me the documents I requested. I'm busy with the Texas case so it'll have to wait until I get back. I did ready the notice. Here it is.

May 2, 2012: Just filed a motion for temporary and permanent injunction against Defendants here. I also filed a six page memorandum in support of my TRO with 11 exhibits of their horrible defamation and libel per se. Defendants have posted the most outrageous, false and deplorable things about me and admitted to same under oath. Hearing is set for June 1, 2012 at 9:30 a.m. in court room 7. Judge Dolly M. Gee will be presiding.

I have prepared a notice to withdraw my motion to compel discovery but will not be filing it until I get the requested documents.

April 24, 2012: Good news! Bat World Sanctuary has $1,000,000 in liability insurance. Attorney finally gave me the insurance page. He said he was just out of town. I will withdraw my motion to compel when he hands over the other items.

My motion to compel just showed up online. Here it is.

In other news I was able to get Rebecca Dmytryk and Amanda Lollar's defamation and libel removed from my Guidestar account for Animal Advocates.

Seems Stephen MacPhail is representing the Tony Awards as a defendant in the lawsuit Bret Michaels vs Tony Awards. I think this has to do with Bret being hit on the head with the curtain. The case was filed in NY in Federal Court due to diversity. As far as I can tell this is the only case he is currently handling that is out of state. It's a pretty big case so I could see how he could be busy. After watching the video of Bret being hit on the head by the curtain I think the insurance company should just settle. I will say that Bret's cowboy hat is the reason he could not see the curtain coming down above him. That is how I hit my head at Bat World. I was wearing a hair net with a head lamp. It's like wearing a baseball or cowboy hat. You can't see above you. The other two people left the stage earlier and weren't wearing hats. Bret likes to pull his hat way down low in the front. Then you really can't see above you or even in front of you that well. Still.

April 19, 2012: Spoke with the Judge's court coordinator. She instructed me to file my motion to compel. Editing it now. Will drive it down shortly. Here it is.

Just filed my motion to compel. We have a hearing date for May 22, 2012 at 10:00 a.m. in room 580. Hopefully Amanda Lollar will just give me the documents before then. If Stephen MacPhail was indeed going to give me the docs in just a few days, filing this motion was a big waste. Of course maybe they had no intention of giving me the docs without my filing this motion.

Guess how many times Amanda Lollar said "I don't recall" in her deposition? 94 times. Guess how many times she said "I don't remember?" 34 times. Amanda Lollar said "I don't recall" or "I don't remember" 128 times in her deposition. Not a reliable witness at all.

Received Amanda Lollar's deposition transcript last night. I will start posting her perjury and other info here. First I will post what Amanda Lollar said about her memory. I asked her "This is a legitimate question. Do you have any physical reason that would affect your ability to recall?" to which she responded "I can't remember every post I made two months ago or even last week much less six months ago or a year or two years ago." Mind you I was asking her about very recent posts she made about me within the last two weeks. "I don't recall" was her most common answer. She doesn't seem to recall anything. I tried to ask this same question in her Texas depo but Randy Turner would not let me ask it. Amanda Lollar has basically admitted under oath that she is not a credible witness.

More perjury during Amanda Lollar's deposition. It was mind boggling. She lied about making a libelous review about me on Guide Star then finally admitted to it. She then lied about making the post calling me a "criminal." Here are a few pages from the transcript. I guess because she's getting away with lying in the Texas case she feels she can just continue to lie like crazy in California.

April 18, 2012: Two days later and still no docs. Time to call the Judge.

April 16, 2012: Stephen MacPhail did indeed call and again promised to give me the documents within the next couple of days. Seems he's been sick, busy and is now out of state. We shall see if I get these docs. If not, I call the Judge then file the motion to compel.

This is ironic! During Amanda Lollar's deposition she refused to touch a pen I handed to her. She refused to touch the exhibits I handed to her except with the tip of her finger. She did this just to be snotty. *** I'm the one who should have been worried. Anyway she ended up having a cold which she gave to a volunteer and probably her attorney. Had she touched my pen and exhibits I might have also gotten it. Reverse karma!

Lots of activity in the Texas lawsuit. Her Texas attorney Randy Turner started papering me to death again. Motion after motion to which I am replying and filing my own motions. I bet the Judge will call him on it after her warning.

April 13, 2012: I requested discovery documents February 14, 2012. March 22 defendants belatedly responded to my discovery requests with objections and only a handful of documents. I had a "meet and confer" with Stephen MacPhail. He promised to give me the items but did not. At Amanda Lollar's deposition I again asked for the items and he stated he would give them to me but didn't. He stated he was extremely busy which he is. I asked twice more in email and again, no documents. I give up. I'm filing a motion to compel Monday morning. Here it is. I sent Stephen MacPhail an email with the motion and also left a phone message. I will also call the discovery Judge and see if she can work this out for us. I also had to file a motion for contempt against Amanda Lollar in the Texas case because she refused to turn over her financials properly. I believe she has no financial damages which is why she is refusing to turn over these documents.

During Amanda Lollar's deposition I asked Lollar if she requested certain documents. She said "no." I then asked her attorney if he is the one who requested them. He said "yes." I was asked some crazy things in admissions. Here are defendants' admissions. Seems like a waste of a document. Of course I will answer "no" to all which I did. Crazy admissions. Here are two of the admissions. "REQUEST NO. 36: Admit that YOU have pornographic photographs of YOURSELF. REQUEST NO. 37: Admit that YOU have posted pornographic photographs of YOURSELF on the Internet." Why would Amanda Lollar ask for this? Why is she interested in pornographic photographs of me? Did she ask about nudie pics of me or did her attorney? I find it hard to believe he'd make that request. What would nudie pics of me have to do with her libeling and defaming me? Not unless someone took pics of me naked when I was asleep, there are no nudie pics of me.

April 11, 2012: I'm reviewing Amanda Lollar's deposition video. I put a little star next to her statements which are lies. My notes are full of stars. I swear if her deposition were a drinking game and I had to drink a shot every time she lied, I'd die of alcohol poisoning within the first few minutes of her testimony. She keeps contradicting her own discovery, admissions and interrogatories besides the evidence. I asked her if she ever posted on the Facebook page "Animal Advocates and the Truth." She said "no." I then showed her a page which shows that both her user names "Lorraine Kurtz" and "Bat World Sanctuary" posted on the page. Then she finally admits to it. I re-read her admissions, interrogatories and discovery responses. She swore to them under oath. She perjured herself in her own documents and in her deposition. I am 100% positive that her attorney instructed her to tell the truth. For the life of me I don't understand why she would not follow her attorney's orders. They are for her own good. I would not ask her questions if I didn't already know the correct answer.

Amanda Lollar admits to receiving my May 11, 2011 email to Randy Turner telling her to cease and desist from posting libel about me. I copy/pasted the exact post in the email. Amanda Lollar claimed the email stated "it appears she has a criminal record." It does not say "it appears she also has a criminal record." It says "Re: Mary Cummins Yes, she also has a criminal record." In the email I even attached a pdf copy of the exact post. The print is dated May 10, 2011. How can she deny this in her deposition and discovery responses?

Amanda Lollar stated "I never posted a review of your organization or about you on Guidestar in any way shape or form. I have never posted to guidestar about you or your organization." I asked again "Have you ever made any review or comment on guidestar?" She said "no." I then showed her a comment posted on Guidestar by user "sanctuary." She finally admits that she made that post, "this comment was made in reference to a horrible review you wrote, you posted false and malicious, defamatory, so, yes I posted a defense." First she said she never posted about me on Guidestar, had never posted on Guidestar then finally she "recalls" she did post about me on Guidestar. Here is her review which she finally admitted she posted which is defamatory, "sanctuary wrote: March 20, 2012 Ms. Cummins left our internship as a disgruntled intern, has been harassing our organization for two years, and was recently charged with criminal contempt of court. Please see the following link for more information on our case, including videos of her court ordered deposition, where she admits to being involved in over 20 lawsuits and being sued four times for defamation. http://www.bat*** http://www.bat*** http://www.you****" I haven't even known her group for twy years, was NEVER charged with criminal contempt of court. My depo was not "court ordered." I did not admit to being involve din over 20 lawsuits in my depo. Her depo is littered with these contradictions.

Here is the post that she was responding to on Guidestar. There is nothing defamatory or horrible in here at all. "I was an intern at Bat World Sanctuary in 2010. I witnessed animal cruelty and neglect. Bats died. I reported Amanda Lollar to the authorities. My reports included photographic evidence besides videos. In retaliation Amanda Lollar sued me for defamation. Since then she has libeled and defamed me and my organization. I was forced to sue her in Federal court. http://www.prweb.com/releases/2011/10/prweb8891635.htm I would advise anyone considering donating to search Amanda Lollar and Bat World Sanctuary on the internet. If I knew then what I know now, I never would have interned at Bat World Sanctuary. She has not gone past the ninth grade, has never taken a class in animal care, is not a veterinarian yet performs surgery on bats. More information about the litigation go here http://www.animaladvocates.us/batWorldLawsuit "

April 10, 2012: My index page has now gone down six times in the last two days. I thought perhaps it was my cat but no, not this time. I will now save a copy to my desktop every time I update. Fortunately I saved items earlier. I will upload tomorrow.

Amanda Lollar of Bat World Sanctuary commits perjury in her deposition. Page 10 of her Texas deposition lines 3-9

Q. What is the last year of schooling that you actually finished? 

A. Tenth grade.

Q. Why didn't you finish 11th and 12th? 

A. Because I wanted to go onto other things. 

Q. Such as? 

A. Such as, just life.

From her April 6, 2012 CA deposition.

47:00 minutes into deposition video.

Q. What is the last grade of school that you finished?

A. Ninth.

Q. (Pause as I sit there in disbelief) Do you remember in your November 8th deposition that you stated the last grade you finished was the tenth?

A. I said the last grade I "attended" was the tenth.

Q. I believe it was "finished" but i'll look at the…

A. As I stated I have a GED which is the same thing as a high school diploma. I had family issues and other things that I needed to deal with.

Q. Do you remember you stated you just wanted to "get on with life?"

A. Ya, I do. (Selective memory)

From her TX deposition.

Page 91 of the same deposition. She ADMITS to writing that post stating that I'm a criminal. Pg 91 lines 13-25. Pg 94 lines 

Q. (BY MS. CUMMINS) This is Exhibit 22. Can you tell me what that is? 

A. It is a post made to my list serve.

Q. Did you make that post?

A. I can't tell who made it.  Yeah, it says Bat World Sanctuary, so, yes, I made it. 

Q. Could you please read that? 

A. It says: Yes, she also has a criminal record. Other lawsuits involve cyber squatting, And it lists case number and several different legal -- Court 1484EA, PC PTY theft, ACQ credit card W/O cons. Another one says forged name on credit card, another one says theft by forgery, invalid credit card. Another one that says theft of property which she lost via default judgment. And then it says FA Beverly Hills, Incorporated versus Mary Cummins, ET, neighbor dispute which she promptly settled, and defamation, which plaintiff abandoned because they were able to get rid of her defamation. She also goes by Mary Cummins, Mary Cummins Cobb, and Mary Katherine Cummins, and sometimes her name shows up as Mary Cummings. She has used the same e-mail for years. She has hundreds of aliases she uses, as well. Right now she's encouraging her Facebook friends to repost the videos and defamation I've managed to get removed. These are the same items she was ordered to remove by the court, so she is now in contempt. She either thinks she's above the law or that she will never -- or that it will never catch up to her. She typically bullies and harasses her victims into giving up, but that's not going to work for her this time around. Thank you, Debbie, for your words of encouragement on our blog. That really means a lot to us.

Q. Can you hand that back to me. 

A. (Witness complies.) 

In her CA depo she stated she did not write that. I handed her the exact same document. No credibility whatsoever. She committed perjury. I handed Lollar items from the discovery she provided to me. Right in front of her I ripped the papers out of the small stapled stack that her attorney gave to me the previous morning. I handed them to her and asked her if she wrote, posted those. She said "no." I then told her they were her own discovery items. She said they were not. She said I must have "fabricated them over night." Her attorney seemed shocked. Under oath she denied admitting to writing items she gave me in discovery. There is nothing her attorney can do if she wants to dig a hole for herself. He did try to cover for her with a story about documents referencing posts. I clearly asked for all posts or comments she made about me in my request number seven. I asked Amanda Lollar why she wanted the emails between me and Randy Turner and me and Stephen MacPhail. Her attorney again tried to cover for her by saying he made the discovery request. I asked him why he'd want his own emails. He said in case he deleted some. Again, trying to cover for her. Why would he want the emails between me and Randy Turner? Obviously Lollar requested them. At least her attorney was polite and professional.

I asked Amanda Lollar in discovery if she had a Blogger user name. She said no. I asked her again in her depo and she said no. I asked her if she was Blogger user "A. Lollar." She said no. She said she may have had a Blogger user name a long time ago when she made a post about a friend. I then showed her an item from her discovery which she admitted to posting. It was a comment by Blogger user A. Lollar. After hemming and hawing she finally admitted that she posted that but she said "it's not a Blogger user name. I didn't post on a blog." It most certainly is a Blogger user name. She posted on a blog and admitted to it in discovery. Then she said it is an old account which is no longer active. The account was started May 2011 and is still active. Here is the blog in question. You can see her post there. Lollar's lies are truly amazing. I pity her attorney. I can only imagine the lies she's told her attorney about me and her.

Amanda Lollar had a nasty attitude during her deposition. She would roll her eyes, make "mean girl" faces, refused to touch my pen which I handed to her, did not want to hand documents back to me. I would hand the exhibit first to her attorney then he'd hand it to her. Then I'd ask her to hand it back to me. She would sometimes barely flick the paper back to me. One time she only moved it an inch toward me leaving it out of reach. I said "come on!" then fortunately her attorney slid it toward me. Lollar is lacking in basic social skills. Quite a few members of Bat World have told me the same. I'm sure dropping out of high school is probably one of the causes or perhaps her social awkwardness is the reason she dropped out of high school.

April 5, 2012: I was deposed. It was videotaped. I did not give permission for the video to be publicly shared or posted. It can only be used for legal reasons in this case. Lollar's attorney Stephen MacPhail was polite and professional. He thankfully did not ask any harassing questions. I would have objected. He did ask about my injury. I objected because it's not related to this case. He asked if I was going to sue for that claim in this case. I said no. I am under the assumption I must sue in TX. If I can sue here in CA, then I'd much rather do that. I will look into this.

March 26, 2012: Summary of our telephonic hearing was just posted. I love Federal court. Here it is. I was trying to figure out how to order the actual hearing minutes but couldn't figure it out yet. I think my computer is not compatible with the court's website. This summary is good enough. I was the one who asked for the telephonic hearing. The only mistake I see is that the minutes say Stephen MacPhail represents "defendants." He only represents Amanda Lollar, Bat World Sanctuary and he clearly stated this in the hearing. When I add Rebecca Dmytryk of California, Suzy Heck of Louisiana and the rest they will all be on their own. They will need to hire their own lawyers. A normal retainer would be $10,000. They will probably go through that within two months. It will cost them $100,000 to go to trial. The Judge has stated that Lollar will be deposed April 6. I will be deposed April 5.

March 25, 2012: Amanda Lollar has been busy making more defamatory and libelous websites about me. I saved copies of all. She refers to me as the "individual" then links the word "individual" to my website. Legally she is still referring to me. I wish her lawyer Stephen MacPhail would teach her a little bit about the law and tell her to knock it off. He obviously has absolutely no control over his client. I'm amazed that uneducated Amanda Lollar is telling her educated, experienced lawyers what to do. I wonder if her Los Angeles lawyer Stephen MacPhail will ask me ridiculous, unrelated, harassing questions in my upcoming depo like her Texas attorney did.

March 23, 2012: How many documents did I give to Defendants in their discovery requests? 578 items. How many documents did they give to me? 0, zero, zilch, nada. Our requests were almost identical yet I got zero documents.

Just read through Amanda Lollar and Bat World Sanctuary's discovery responses again. They made some mistakes. I also think Amanda Lollar wrote some of it. She pretended not to understand a question. She responded that she and others have info about defamation I posted about them. This case is about defamation she posted about me. I phrased the question property. A few sentences just cut off mid-sentence. I'm sure Stephen MacPhail was perhaps in a rush and tired.

Amanda Lollar did admit to posting in raisethefish, indymedia, indybay, care2, amandalollar, batworld...about me. She still had the nerve to say she never posted that I was a "convicted criminal." She posted, reposted, shared, emailed that to others. She admitted that she posted it in her deposition. I'll post more of her ridiculous discovery later. She requested tons of documents from me which I spent days preparing and I gave to her. I requested almost identical documents. She objected saying it would be too much work and there's nothing discoverable in there. This is what makes me so pissed. She and her attorney have a lot of nerve to reply in this manner after they requested similar documents which I then gave to them. I should have waited for her discovery response before I even sent mine out. I would have used the same objections then we both could have wasted time filing motions to compel. I can ask for more discovery until July.

Received "discovery" later last night. I basically got a list of objections and lies. Here we go again. Glad I started on my motion to compel. Amanda Lollar is now denying that she wrote/posted some things about me which she admitted to under oath at her own deposition. I don't know if she's lying to her attorney or if her attorney is instructing her to lie to me. She repeated this same statement a few times in writing. There is no denying it.

I realized last night what attorney Stephen MacPhail may have meant by an address being confidential. In my notice of deposition of Amanda Lollar I included her address. That is of course public as it's on her website. Perhaps he did not know that. I think attorney Stephen MacPhail may think all documents in this case are confidential. That is not true. He asked me to sign a confidentiality agreement February 2, 2012. There was a place for me to sign it, Stephen MacPhail and the Judge. I told Stephen MacPhail that I would not sign an agreement between me and him. Amanda Lollar would have to sign it. Big deal Stephen MacPhail signs it. He has no control over his client. Amanda Lollar would not have to abide by something signed by someone else. I told him he'd have to change it. He never did. I never signed any confidentiality agreement.

March 22, 2012: I gave Stephen MacPhail and his client Amanda Lollar of Bat World Sanctuary an extra week for discovery. I didn't have to give them extra time. They still have not given me discovery. I can only hope it's because they gave me all the documents I requested. If they spent the last 37 days writing objections, I will not be happy. I gave them everything they asked for except things they already had or could get elsewhere. I will need to give them a supplement to discovery as items come in. I will start writing my motion to compel right now.

March 20, 2012: UPDATE: Amanda Lollar really believes she is better than everyone. She had the nerve to ask me to inconvenience myself to convenience her schedule. I remember asking her and her attorney to change a hearing and depo time/date. They said NO! Her TX attorney asked me to change a hearing date. I stupidly said yes thinking he'd pay back the favor later. I later asked him to change a hearing date and he said NO! Why would I inconvenience myself to convenience Amanda Lollar? She has to play by the rules just like the rest of us.

Stephen MacPhail misquoted the law again. He said I can only depose Amanda Lollar for seven hours then he quoted Federal Rules of Civil Procedure (FRCP). It clearly states that I can depose for seven hours or longer if stipulated. I stipulated in my request. My request is almost an exact copy of his request so he should have realized that. I believe he is misquoting the law intentionally just like Turner did. This is why we did not get along. It is not very nice for an attorney to try to take advantage of a pro se by misquoting the law. Thank god for the Internet.

I love Federal court. If you have an issue with the other side, you don't have to file a motion, schedule a hearing, appear in person and wait for a written order which generally takes six weeks. You call up the Judge. She puts you on a conference call. One side speaks, the other speaks, she tells you what to do. Magistrate Judge Margaret Nagle is very no nonsense. She also explained how phone conference hearings work to me even though I already knew. Nice and efficient. That is how courts should be run.

Attorney Stephen MacPhail previously cancelled my deposition and Lollar's. He wanted to depose me and his client in May which is two months off. He had the nerve to say legally I must depose her in Texas or fly her out at my expenses. Not true! Misquoting the law just like attorney Randy Turner. I can't wait two months to depose her as I have a lot of discovery to do and subpoenas to send. I also thought it was a stalling technique so I'd miss a deadline or something. I called the Judge and she sorted things out. She asked me when I noticed Lollar of her March 21 depo. That would be February 14. Judge said that I gave her plenty of notice to be deposed. I will be deposed April 5. Amanda Lollar will be deposed April 6. That took about five minutes. Amanda Lollar's airfare went from $179 to $400 because she didn't feel like showing up tomorrow. Hotel rooms are a lot more expensive in Los Angeles than Fort Worth, Texas. I doubt she even bought the original plane ticket. I doubt she ever intended to show. I wonder if her insurance will pay for her travel expenses? Then she wouldn't care how much it costs. In fact if she doesn't bother to be deposed it wouldn't affect Amanda Lollar or Bat World. She would lose the case but her insurance would have to pay for everything. She truly believes she is above the law.

In the hearing Stephen MacPhail stated that his client cares for "endangered" bats. Her dad is very sick. She basically runs the sanctuary by herself. Then he said he had three short trials in April. He added that I am posting "vitriol" on "blogs." I am posting the truth on my website. It is criticism but it is not "cruel" or "bitter." If Lollar does not want me to criticize her, she should give me no reason to criticize her. Lollar should start by removing her libel and defamation instead of posting new defamation per se.

Stephen MacPhail also told the Judge that I posted "confidential" items such as the location of Lollar's deposition. I posted a notice of deposition which had the address of my p.o. box. I did not post the location of her deposition. Even if I had it's an office building in downtown LA. Big deal. MacPhail's address is public. That is where I will be deposed. Who cares.

I don't know if Stephen MacPhail was lying to the Judge or if Amanda Lollar was lying to Stephen MacPhail who just repeated it to the Judge. I later emailed Stephen MacPhail and cleared up his misconceptions. She does not have any endangered or even protected bats as she has no Fish & Wildlife permit which she admitted in her TX deposition. She has volunteers who help her for free. I never posted the location of Lollar's deposition. I posted my p.o. box address.

I just noticed that Lollar's Los Angeles attorney is playing out just like Randy Turner did in Texas. I remember the first hearing when Randy Turner stated his client had "the largest bat sanctuary in the world!" I told the judge that Lollar has 300 bats. The largest bat sanctuary in the world has 1.8 - 2.2 MILLION bats. Turner also said that Lollar was as "world renown expert." If you mention the name Amanda Lollar among true bat experts you get half of an eye roll. She cites their books and papers. They don't cite her at all. Amanda Lollar did not go past the tenth grade. She's never had a class in animal care. She doesn't know what she's doing. She recommended freezing bats to death which is inhumane. I sure hope MacPhail learns from Turner's mistakes and doesn't end up looking like a total fool like Turner.

Amanda Lollar of Bat World Sanctuary continues to libel me. She just posted this, "Ms. Cummins left our internship as a disgruntled intern, has been harassing our organization for two years, and was recently charged with criminal contempt of court. Please see the following link for more information on our case, including videos of her court ordered deposition, where she admits to being involved in over 20 lawsuits and being sued four times for defamation." I was not a "disgruntled intern." I reported her for animal cruelty and neglect. I have not been "harassing" Bat World. I haven't even known Bat World for two years. I interned there June 19, 2012. I was not "charged with criminal contempt of court." My deposition was not "court ordered." It was mutually agreed upon. It clearly states this in the depo request. I never admitted to being "involved in over 20 lawsuits." She made up all of these defamatory accusations. She also continues to lie about me in her website batworld.org Her attorney has absolutely no control over her.

Was going through old emails and saw this in one, "Cummins v. Lollar PDF copy: Caption CLAIMS REF NO. 268950 CLAIMS EXAMINER Marissa G. Arnold." Her attorney is being paid for by insurance. My case is a claim. Marissa Arnold is a claims examiner insurance adjuster at Chubb insurance in South Windsor, Connecticut 860-408-2210. marnold@chubb.com

March 17, 2012: Amanda Lollar now doesn't want to show up for her deposition. She claims her dad is sick. If her dad is sick, why is she going to the construction site? Why is she taking in more bats? Why is she on FB all day long? I just sent her another notice of deposition. Legally I must give ten days notice to her attorney . I gave 11 days notice. She can be deposed this Wednesday March 21, 2012 as scheduled or March 28, 2012, same time, same place. Notice of taking of deposition of Amanda Lollar to attorney Stephen MacPhail.

I just figured out what type of law firm Bragg & Kuluva really is. They are counsel for Chubb Insurance which processes insurance claims and such for many insurance companies. This means Stephen MacPhail is on salary. He isn't pro bono and is not being paid the usual $350-$550/hour rate. I am assuming that Amanda Lollar and/or Bat World Sanctuary had some sort of insurance which is covering her legal fees and Bat World's. I am suing her personally and as Bat World. I assume it'd also cover any settlement to me. That would also mean that they had insurance for my injury at Bat World Sanctuary. Legally Bat World Sanctuary must tell me who is their insurance company. Amanda Lollar has refused to tell me. My PI attorney will find out soon enough though I'm assuming the underlying carrier is Chubb Insurance. I just checked attorney Stephen MacPhail's email source and the logs from this page. The emails and hits are indeed coming from domain chubb.com out of their main office.

A little background on attorney lawyer Stephen M. MacPhail. He's a very bright man who graduated with honors from both undergraduate and graduate schools. His speciality is labor and employment law. He has even taught classes on labor law and written articles. Here is his resume.

March 7, 2012: The Judge in my Federal case against Amanda Lollar and Bat World Sanctuary was able to resolve our depo video issue. Only a professional videographer will video the depo. I will not also video the depo. If anything improper were to happen, I will let the record reflect that, end the depo and file an emergency protective order. I doubt anything will happen as this lawyer is so far polite and professional though he has one bad habit. Amanda Lollar, Bat World Sanctuary has to pay for the videographer, court reporter, attorney's fees from yesterday. There are minimum costs because there was indeed a very short depo.

March 6, 2012: I was supposed to be deposed today in my Federal case against Amanda Lollar. Her attorney Stephen MacPhail would not allow me to videotape even though I am entitled under Federal Rules of Civil Procedure FRCP 30(b)(3)(B) "(b) NOTICE OF THE DEPOSITION; OTHER FORMAL REQUIREMENTS. (3) Method of Recording. (A) Method Stated in the Notice. The party who notices the deposition must state in the notice the method for record- ing the testimony. Unless the court orders otherwise, tes- timony may be recorded by audio, audiovisual, or steno- graphic means. The noticing party bears the recording costs. Any party may arrange to transcribe a deposition. (B) Additional Method. With prior notice to the deponent and other parties, any party may designate another meth- od for recording the testimony in addition to that speci- fied in the original notice. That party bears the expense of the additional record or transcript unless the court orders otherwise."

Stephen MacPhail objected on the record then I objected to his objection. The Judge will figure this out for us. No matter what Amanda Lollar will have to pay for the videographer and court reporter today not to mention her attorney's time. Her attorney Stephen MacPhail has so far acted ethically and professionally. Stephen MacPhail really had no real reason to fear being videotaped. I doubt he would nod off on me like Randy Turner did. I even promised not to post the video. I just need some independent record as I will be deposed by myself.

February 28, 2012: Response to admissions, interrogatories and discovery were due tomorrow. They were sent in today. A few items in my response to interrogatories were confidential so I won't be posting the document.

Cummins response to admissions

Cummins response to discovery

February 23, 2012: Judge approved our scheduling order. Judge has ordered us to appear before a magistrate judge for a settlement hearing. This is standard protocol. Here is the document. Our trial by jury is scheduled for November 6, 2012 before Judge Dolly M. Gee.

February 14, 2012: I just sent off discovery documents to defendants Amanda Lollar aka Bat World Sanctuary an individual and Bat World Sanctuary an unknown business entity. I also sent a cover letter and request for deposition of Amanda Lollar here in Los Angeles, California to her attorney Stephen MacPhail.

Discovery cover letter

Deposition of Amanda Lollar

Discovery admissions Amanda Lollar

Discovery admissions Bat World Sanctuary

Discovery interrogatories Amanda Lollar

Discovery interrogatories Bat World Sanctuary

Discovery production documents Amanda Lollar

Discovery production documents Bat World Sanctuary

In the mean time Amanda Lollar continues to libel and defame me. She's also signing me up for spam.

January 17, 2012: I just happened to look at Pacer and see the Judge's order for a scheduling meeting. I don't know why I wasn't emailed. I signed up for auto-email when anything is filed. Anyway this means the case will not be dismissed. Amanda Lollar, Bat World Sanctuary, John Does 1-10 lose on their motion to dismiss. I'm filling out this form right now.

January 7, 2012: The court fixed the scanning error in my first amended complaint. Here is a good copy. While they were in there they fixed all the little mistakes like my address and the dollar amount I am asking for in the lawsuit.

January 6, 2012: Defendants Amanda Lollar and Bat World Sanctuary answer the lawsuit. It's a standard answer. They deny everything and use every affirmative defense. These filings are very neat and tidy. Either it's a standard copy/paste or the lawyer Stephen MacPhail is making his filings more professional because he knows they're going on the internet.

Answer by Amanda Lollar, attorney Stephen MacPhail

Answer by Bat World Sanctuary, attorney Stephen MacPhail

December 25, 2011: A friend just noticed that pages 10-11 and the proof of service are missing from the Pacer record. I did indeed file them. Here is a copy of what I filed which was sent to Defendants. I just sent it to the court to make sure the Judge has it.

December 22, 2011: Just filed an amended complaint here. I updated the docket above. I did not delete John Does party. It looks like originally they wrote Defendants "Does." They deleted "Does" and added "John Does." I am still suing John Does 1-10.

December 20, 2011: Defendant Amanda Lollar, Bat World Sanctuary sent in a request for clarification. It was denied as it was untimely. The order stands. Here it is

December 15, 2011: Good news! Defendant's motion to dismiss due to improper venue was denied. Their motion to transfer venue was also denied. Little bit of bad news is that I didn't include an exact date of libel in the body of my complaint. They were granted a motion to dismiss for failure to state a claim. The Judge is giving me 15 days to replead. I just rewrote the corrected pleading and will file in the morning. That means they lost their motions to dismiss or transfer. California Central District Federal court is the proper jurisdiction.

December 9, 2011: I called the court to confirm the December 12 hearing at 9:30 am. I saw it on calendar. They called me back and said the judge took the documents under submission. She will rule on the documents alone then mail us her order. Neither side needs to appear at the hearing. I thought Federal court ruled on documents and not testimony at hearings. Glad I made two written replies to their motion to dismiss or transfer.

December 8, 2011: I filed proof of service and my opposition to defendants' motion to dismiss or transfer November 30. It just showed up on Pacer eight days later. This court does not allow pro se parties to file digitally. I hand deliver my filings to the court. The defendants' attorney files digitally and the documents show up next day. We have a hearing set for Monday to hear the motion.

December 2, 2011: Defendant filed a reply to my opposition. The lawyer Stephen MacPhail did not notify me that he filed the document. Fortunately I just happened to be looking at Pacer. His reply was much more professional than his original motion to dismiss/transfer. Perhaps Stephen MacPhail had a law student or legal assistant write the original motion. Few mistakes in his most recent reply. Again, venue is Federal District Court in California because I was damaged here in this venue, jurisdiction, district. Defendants are in Texas and other states such as New York and Pennsylvania for starters. Diversity.

November 30, 2011: I just filed my opposition to defendants' motion to dismiss or transfer here. Here is a more legible unsigned copy. Venue is most definitely in California.

November 8, 2011: Defendants file motion to dismiss or transfer case. I took off the exhibits because they were lengthy. Look at all the typographical, spelling and grammatical mistakes in this filing. I've never seen such sloppy work. Attorney Stephen M. MacPhail of Bragg & Kuluva is the lawyer. His typographical errors are so bad that he accidentally put numbers in words. How does one even do that? He also made three mistakes in the actual filings of the digital documents.

Here is the official complaint with time stamps.

Here is a more legible copy.

November 1, 2011: Amanda Lollar of Bat World Sanctuary has just deleted some of the libel and defamation per se, but not all of it.

October 20, 2011: What is Amanda Lollar of Bat World Sanctuary's response to my lawsuit? She is posting even more libel and defamation. I'm of course saving all of it.

Mary Cummins sues Amanda Lollar and Bat World Sanctuary

October 19, 2011: (PRWEB) Los Angeles: Animal activist and rescuer Mary Cummins President of Animal Advocates filed suit against Amanda Lollar, Bat World Sanctuary and John Does 1-10 for defamation per se and interference with business relations, Case # CV11-08081 in California Federal Court on September 29, 2011.

The complaint states that Amanda Lollar falsely posted on the Internet that Cummins "has a criminal record," "was convicted" of "theft of property, forged name on credit card," and "hacked into" Lollar's "email address" among other things. The complaint also states that Defendants emailed some of these same false allegations of criminal activity to government agencies such as the United States Department of Agriculture and the California Department of Fish & Game which control Cummins' permits.

Mary Cummins said "While I am a major proponent of freedom of speech, I am appalled that someone would try to destroy my reputation by falsely posting on the Internet that I am a 'convicted criminal.' I have never been charged with or convicted of any crime in my entire life."

The complaint states that defendants also posted on the Internet that Cummins commits "animal cruelty" and "tortures" animals. Mary Cummins said "I am very passionate about providing the absolute best care for animals. I went through the police and humane academy to become a Humane Officer so I could protect animals from abusers. For these people to make such false claims on the Internet is outrageous."

The comments were posted in Yahoo, Facebook, Google Blogs, Indymedia and other websites. Mary Cummins is President of Animal Advocates a non-profit animal rescue organization in Los Angeles, California. Animal Advocates rescues ill, injured and orphaned native wildlife (coyotes, bobcats, foxes, raccoons, opossums, skunks, squirrels...bats) for release back to the wild.

http://www.prweb.com/releases/2011/10/prweb8891635.htm

Mary Cummins of Animal Advocates sues Amanda Lollar, Bat World Sanctuary for libel, defamation

Animal Advocates

October 18, 2011: Amanda Lollar and Bat World Sanctuary were served today in Mineral Wells, Texas. Proof of Service

September 29, 2011: Mary Cummins files suit against Amanda Lollar, Bat World Sanctuary and John Does 1-10 for defamation/libel per se, tortious interference, emotional distress.