2008-10-11

Carrier, a 38-year-old self-employed ancient historian meets Lauren Lane, then a 21-year-old art student and event organizer, at the event retroactively dubbed Skepticon 1 on the campus of Missouri State University. He is one of two speakers, with PZ Myers.

2009-11-20

Start of Skepticon 2. Carrier returns, among other speakers.

2010-02-16

Lane sends a humorous email to Carrier asking for a recommendation letter for graduate school, saying it would be “both hilarious and so FREAKING awesome,” and offering “booze! Drugs! Sex! Surely there must be something you would like in exchange for your good word, sir. If not, then I humbly offer my undying gratitude.” [OH:DEF000583] [No awareness of, or response to, this email by Carrier is recorded.]

2010-04-14

Lane sends a (non-flirtatious) email to Carrier requesting a letter of recommendation for an internship at the Center For Inquiry (CFI). She introduces herself as “My full name is Lauren Lane, although people know me as ‘the girl with the microphone’ from Skepticon.” In response, Carrier initiates emailed flirtation:

• “Silly girl. You are way too cute to forget. You make me pine for my youth.”
• “Lois Lane's hot sister, the one Superman secretly desires.”
• “P.S. as my reward I expect you to dye your hair sexy black for me, er, I mean for Skepticon. (Oh wait, is that sexual harassment? Oh, no, no. I'm sure I can come up with a legitimate reason for it. Just let me think on it a whole weekend with a bottle of Glenlivet.) ;)”
• Carrier’s email leads to mutual flirtation.

[OH:DEF000382]

2010-11-19

Start of Skepticon 3. Carrier returns, among other speakers.

2011-11-18

Start of Skepticon 4. Carrier returns, among other speakers.

2012-07-03

Carrier posts “On Sexual Harassment Policies” arguing in part against the Secular Student Alliance Speaker’s Bureau fraternization policy between speakers and students that:

• It is “overbroad and unrealistic” in that “college kids are not really kids” and that it should obviously not apply to married couples.
• If he wanted to violate it, he would first “just withdraw from the Speaker’s Bureau. But I have no reason to, since I’m married, making it a non-issue for me. But that can be unfair to single or polyamorous speakers, and thus the SSA policy is in my opinion discriminatory”
• “[A] better policy would be: “Speakers are not to solicit sexual behavior from students or staff.” ... That covers what they actually want to prevent (harassment and horndogging, which is unprofessional) …”
• “In sum, as Dave Silverman of American Atheists aptly put it, ‘I want people to have sex at our conferences.’”

2012-11-09

Start of Skepticon 5 -  Carrier returns, among other speakers.

• During the conference, Carrier and Lane begin a consensual sexual relationship [OH#1@24], his fourth of six later-admitted extra-marital affairs. [Private email from Carrier to Skepticon Board]

2013-03-28

Start of American Atheists 50th Annual Convention in Austin, Texas

• Carrier breaks off his relationship with Lane, admitting later that he “didn’t know how to deal with it”, and “realize[s] how badly [he] hurt you.” [OH:DEF000547].

mid-2013

(Exact date unknown) About to be exposed for his sixth affair, Carrier admits them to his wife, and reveals their identities. Makes agreement with her to open their marriage, subject to restrictions.

2013-11-08

One week before Skepticon, Carrier sends out private notice to “several friends and colleagues” to announce that he and his wife have privately agreed to open their marriage. The purpose of the message is to inform them and ask them to keep it quiet. In the private portion of the message sent just to Lane, Carrier proclaims his availability for sex, but requires it to be “girl-girl-guy”.

[OH:DEF000547]

2013-11-09

Lane responds angrily to Carrier, enumerating the ways in which he had pushed past her stated boundaries, and the unfair and undue mental duress she’d been put under because of his actions and “coward[ice]” earlier in the year. She concludes with a direct request to leave her alone. [She really kicked his butt! Maybe someday Lane will let everybody read this masterpiece.]

[OH:DEF000547]

2013-11-11

Carrier respects this last boundary from Lane for two days, then apologizes, calling his behavior the result of “panic”, and concluding “But if you want to cut off all but professional contact, I will understand that, too.”

[OH:DEF000547]

2013-11-15

Start of Skepticon 6 - Carrier speaks at Skepticon for the last time. Lane avoids Carrier as much as possible, (but does speak with him about his behavior).

[LL]

2013-11-17

Lane emails later appreciating the chance “to say fuck you to your face”, that he handled it well, but that friendship is not “something I want right now.”

[OH:DEF000575]

2014-01-04

Start of dispute with Carrier over his books stored by Skepticon. [OH:DEF000314]

2014-03-03

Lane invites Carrier to speak at Skepticon 7. Carrier accepts. [OH:DEF000592]

2014-03-27

Carrier posts in support of a woman in the secular community being sued for writing about her claims of sexual harassment:

• Claims she “has been harassed for years by an ex-boyfriend, who was eventually disciplined by his employer for it (CFI), and she finally wrote about her experience, and apparently to harass her further, he is suing her. It looks like he is counting on the fact that defending herself in court will bankrupt her and has used that to try and intimidate her into issuing a retraction, but she refuses to retract what she says is simply the truth. If you think this is appalling and want to help her, I would very much like you to.”
• “Conspicuously missing from his narrative is any substantive account of their communications in 2011, the actual year in the middle of which his own timeline reports she and her husband told him to stop harassing her. He instead handwaves at vast length about what happened in the year 2010. This is suspicious. Because it means the relevant evidence is in 2011. Yet he tricks you into only focusing on 2010. That looks manipulative. Moreover, his account implies a stock MRA-style women-are-property narrative: that it is impossible to have harassed someone or touched them against there will during a period in which they occasionally have sex with you (I assume then he would have to agree spousal rape is impossible, which maybe even he would concede would be despicable).”
• “Meanwhile, it would only make sense to donate to Radford’s fund if you actually think he is telling the truth. Because he can easily reduce his expenses to zero: don’t file a lawsuit. Stollznow doesn’t have that luxury. Remember, he is the legal aggressor here. He chose to do this. She did not. All she did was exercise her freedom of speech. He could simply match speech with speech and be done with it. Instead, he is trying to use money as a lever of power. She is not. That creates an imbalance. A balanced response would be to simply refute what she said (which, as I noted, he has still not done…so it’s unlikely he can do so in court, so it does not seem likely this case will go well for him).”

2014-05-06

Renewed investigation and attempts at resolving book dispute with Carrier.

[OH:DEF000370]

2014-06-12

Resolution of Skepticon’s book dispute with Carrier

[DEF000378]

2014-06-17

Carrier emails Rebekah and Lane asking if he is invited to speak for Skepticon 7, offering to help fundraise, and pitching an idea for a workshop.

[OH:DEF000598]

2014-06-26

Lane responds to Carrier saying:

“It has been after much consideration that that team and I have decided to not invite you to speak this year. I know that his [sic] may look like a slight or something, but we're really trying to make Skepticon the best it can be and really diversify and give new life to the lineup, which sadly means saying no to some of our returning speakers.

We hope that you understand and will still support Skepticon. You are more than welcome to attend Skepticon as an attendee and host your workshop if you'd like.”

[OH:DEF000598]

(Personal recollection, both first- and second-hand) Not wanting to upset Carrier, what goes unsaid is that both his treatment of Lane (and whisper network tales of a few others) and the recent book dispute were the primary factors in the decision. He is not expected by the organizers to attend, since his travel will not be paid, as it would be if he were a speaker. No further action is thought to be warranted unless continuing bad behavior comes to light. [JH]

2014-09-11

Carrier emails Eli (Heina) “A Polyamorous Loveletter (For Want of What Else to Call It)” declaring his heartfelt, undying desire for sex with them (and perhaps a three-way).

[OH:1.27, Affidavit Exhibit 2]

• Eli responds, mocking Carrier for confusing “getting a hall pass after getting caught rampantly cheating” for polyamory, and noting that they must have mistaken him for “someone who’d get the hint from me not acknowledging and/or deflecting the aforementioned hints you’ve been conspicuously dropping”.
• Carrier replies, apologizing, and promising to let it drop.
• Eli replies bluntly, [clearly trying to end the conversation]
• Carrier replies again, saying how much he is “agonizing” over his first email. [Common tactic to pressure the other person to perform the emotional labor needed to comfort you.] And promises again not to “communicate about this again unless you ask.”
• Eli replies [bluntly and without emotion, again]: “Just so we’re clear: You don’t have to agonize over telling me something. It wasn’t sharing your thoughts and feelings that was the problem. It was everything else I mentioned. Nothing was ruined. I’m not of the belief that communication is a wrong thing.”
• Carrier replies again, despite his promise, and Eli not asking, berating himself and complaining about how awful he feels.
• Eli replies that Carrier has been hinting for months, and that they have no desire to make anyone feel awful.
• Carrier replies again[!] that this has made him feel better, and that they matter so much to him, and how he will be “private[ly] pining” for them, still. [This is a deniable way to push on their boundary again.]
• Carrier (30 minutes later) replies again [!!!] “fisk[ing]” Eli’s initial two paragraph email, taking three pages to do it, explaining where they were right and where they were wrong in their reasons for turning him down.
• Eli replies: “You haven’t hurt me, harmed me, or offended me, as I said. I’m annoyed at worst, and now, glad to clear the air, which has felt murky for a while.” [Ouch!]
• Carrier replies the next day: “Annoyed at worst! Noted. Thanks for interacting on it. I appreciate that. If there is any more murk you want to clear, let me know. Otherwise, I’ll just return to normally scheduled programming”
• [Astonishingly, Carrier is oblivious enough to include this exchange in full as an exhibit of his lawsuit to demonstrate that he didn’t hurt or offend Eli, apparently not understanding what the problems were with his behavior.]

2014-11-21

Start of Skepticon 7 - Carrier does not attend.

2015-02-18

Carrier posts “Coming Out Poly + A Change of Life Venue”, announcing publicly that he and his wife are divorcing after attempting an open marriage following his admission to her of several affairs.

• “Had I known several years ago that polyamory was an actual option that works for people, I might have realized this sooner, and dealt with it better.” [Note that he had known of polyamory as an ethical option in his post from 2012-07-03, prior to at least three of his admitted extra-marital affairs.]

2015-04-03

Carrier speaks at the Arizona State University Secular Student Alliance (SSA) meeting where he meets and allegedly touches and harasses Amy Frank, a young neurobiology student.

[OH:1@46 & Exhibit 4]

2015-04-20

Frank’s complaint is forwarded to the SSA in Ohio, alleging repeated sexual harassment, and considering him a threat to future SSA audiences.

[AZ#10 Exhibit 4]

2015-04-21

Carrier is informed by SSA that a student has formally complained about his behavior, including that the “student felt that they had made clear that such advances were unwelcome and felt very uncomfortable”.

2015-04-29

Carrier posts “Looking for a Date Middle of May,” noting an unexpected 48-hour gap in his planned visits to girlfriends in Los Angeles, laying out his sexual preferences (0.5 on Kinsey scale, likes sex workers or women with high sex partner counts), inviting his prospective date to share his hotel room, and clarifying that there will not be any pressure for sex. [No, indeed!] Though it would be welcome.

2015-05-05

Carrier proposes writing “How to Do Wrong Right” and asks SSA to get permission from his accuser, not knowing her identity, and thinking that it was another student who he had propositioned at a different event. Frank explicitly told the SSA that she did not agree with Carrier making this blog post, and told the SSA that she believes that instead, the SSA organization should make an announcement of what happened. [AF] 

2015-06-05

Carrier posts “How to Do Wrong Right,” describing recent interactions from his perspective that he felt he handled badly, cautioning against rushing to judgement, sympathizing with those who are afraid of being falsely reported, and illustrating with examples of the worst “slips near creepy territory” that he has committed.

• Carrier icludes a description of clear sexual harassment and assault of which he alleges he was a victim: “In my case, this escalated into actual sexual assault. A woman I didn’t know and had hardly spoken to became very sexually suggestive around me and over a few hours repeatedly grabbed my ass and touched other parts of my body, not only without permission, but without any reason to think she had any approval at all. I didn’t want to cause trouble or start a scene, so I just tried to avoid her, and very kind conference goers helped cockblock for me (my back to walls, attendees all around me in conversation, so she couldn’t get near me). But that didn’t really work. The behavior continued, because I couldn’t be safely corralled constantly.” Continuing “I feel no need to mention her name, unless I discovered she was still doing such things to people, in which case I probably would.”
• Carrier denies having ever done “anything so egregious as ... just point blank hitting on someone I’ve barely spoken to. Although I think many of those things are correctable, too, in the same way.”

2015-07-04

In response to a blog post about how a supporter of sex work in pornography had changed her mind due to its widespread association of violence with sex, Carrier posts a lengthy comment defending violence in porn as not the problem, instead emphasizing that porn should communicate consent to simulated violence better. He backs this up by graphically describing how several of his girlfriends enjoy being treated violently (with consent) by their other partners, though he himself is uncomfortable in participating, and by noting that in at least one violent porn film he has seen, the actress appears on screen beforehand to assure viewers that this is entirely her idea

In subsequent comments he details his love for semen play.

Responses to this point out that Carrier has trampled commonly-understood boundary expectations in this context by oversharing in ways unnecessary to his point, and centering himself and his needs. The blog author described them as “way too personal and detailed”. Richard replies defensively, implying prudery on everyone else’s part, not-pologises, and exits.

• “Carrier’s comments make me glad I’ve never had sex with him and somewhat sorry to have shaken his hand at a conference.”
• “Speaking of consent and proper boundaries, WTF just happened in this thread? Carrier’s conduct is getting ridiculous. There’s exploring polyamory and then there’s… this. Forcing your sexuality on others. Please learn the difference, people.”

2015-07-05

Carrier registers for Skepticon 8, donating $25.

[OH:DEF000386]

2015-07-05

Lane sends a generic donor thank-you email to Carrier, reading:

“Hey Rick,

Just wanted to send you a quick thanks for supporting Skepticon. It's due to awesome people such as yourself that we are

able make our conference the best it can be.

YOU ROCK!

Thanks again and see you in November,

-- The Skepticon Team”

[OH:DEF000584] [Carrier later uses this as the example of Lane being welcoming of his attendance, specifically.]

2015-07-10

While attending the SSA student conference in Columbus, OH at Darrel Ray’s workshop, Amy meets Amanda Metskas (Former Camp Quest Executive Director and wife of August Brunsman, Former SSA Executive Director). During the workshop, Metskas mentioned several times that her “boyfriend” Richard Carrier would be in town soon for a Poly Columbus event. [AF]

2015-07-10 - 2015-07-12

While at the SSA conference, Amy sees photos on Twitter of Carrier at the Ohio State campus, where the conference was held. She immediately contacted SSA staff where she was told that he was there unofficially as a “volunteer” to take students to the airport, but was assured by staff that they would find her a different airport driver and that Carrier would be “chaperoned at all times” during the conference. [AF]

2015-07-11

Carrier apologizes on his blog for “being explicit in other people’s spaces”. Generally does so well, but still manages to sneak in insinuations about this being about shaming him for his kinks, and how he has to make a heroic effort to remember in the future that the world is generally prudish. [Carrier positions this as a boundary-pushing exercise of sorts, part of a crusade to make frank and explicit sex talk more of an acceptable norm, but aplogizes for not getting consent first.]

2015-08-01

Approximate date that Carrier is quietly removed from Secular Student Alliance’s Speaker’s Bureau by mutual agreement, due to Frank’s complaint of sexual harassment.

2015-11-13

Start of Skepticon 8 - Carrier attends [OH:DEF000386] and is monitored occasionally by organizers and volunteers. [JH]

2016-04-21

Carrier Patreon: 48 Patrons, $99 / post = $396 / month

2016-06-07

Frank sends a Facebook message to a contact at Florida Institute of Technology introducing herself as the president of the Arizona State SSA chapter and asking if they got SSA funding for an upcoming talk by Carrier, claiming an interest in having Carrier speak. The FIT contact responded that they did not receive SSA funding.

[OH:DEF000612]

2016-06-10

Notice appears on Carrier’s Facebook timeline indicating that he was now an employee of Camp Quest West. [Following a denial by Carrier and Camp Quest after Frank’s post of 2016-06-15, this was quickly recognized as spurious.]

2016-06-13

Carrier Patreon: 57 Patrons, $131 / post = $524 / month

2016-06-15

Frank makes a Facebook post (now made private) criticizing the Secular Student Alliance, and its handling of her complaint against Carrier. It mentioned her complaint about his unwanted touching and sexual harassment to complain about their handling of the case.

[AZ#1@20 & Exhibit 1]

2016-06-15

Carrier publishes a response to Frank’s post,

• Denying any recent or future planned relationship with Camp Quest
• Denying that he touched her
• Denying that he mentioned contacting her again
• Confirming that he expressed sexual interest in her while away from witnesses
• Pointing to other behavior of his in the same time period as worse

2016-06-15

The Secular Student Alliance in a Facebook post:

• Confirms that Carrier was quietly removed from their Speakers’ Bureau in 2015.
• Announces an investigation “into the adequacy of our reporting system, our sexual harassment policies, and any actions that our staff have taken, including our response to the incident when it was originally reported to us.”
• Later reiterates in a comment on the same post that the investigation would only review SSA’s actions, not the claims made by Frank, saying “the scope of the investigation is not focussed on the original harassment claim, although we will look at details surrounding that as well. We are taking a close look at our actions following the original claim and the safeguards we put in place thereafter for their adequacy.”

2016-06-15

Camp Quest in a Facebook comment on SSA’s post, above:

• "To clarify, Dr. Carrier has never been an employee of Camp Quest or any Camp Quest affiliate camp, and there were no plans for him to become one. He volunteered as an activity leader with Camp Quest West in 2007 and again in 2009. That is the extent of Dr. Carrier's involvement with Camp Quest."

2016-06-16

Skepticon organizers begin discussing Carrier’s behavior and possible responses. Discussion continues through 2016-06-20. Additional accounts of troubling behavior emerge privately, and prior accounts of public behavior are reviewed, along with Carrier’s public responses. Lane explicitly states that any decisions need to be made by the organizers as a group, and not by her. [Skepticon internal chat logs, private Facebook posts]

2016-06-20

Skepticon publishes a post (since removed) banning Richard Carrier from attending future conferences. [OH:1@42 & Exhibit 8]

2016-06-20

Stephanie Zvan posts a summary of current public allegations against Carrier, including those by Frank, Skepticon, and Carrier’s own descriptions of misbehavior, as well as alluding to two other private allegations.

2016-06-21

Carrier threatens Skepticon and Lane privately via email with legal action. [OH:DEF000279]

2016-06-21

Myers announces an investigation into allegations of misconduct and suspension of Carrier’s posting privileges while it is ongoing.

2016-06-21

Carrier phone call with Myers. [OH:DEF000538, 541] He ultimately refuses to cooperate with Freethought Blogs’ investigation, citing disagreement with its terms, demands that his blog data be turned over to him [OH:DEF000544] and his blog be removed. He threatens legal action.

2016-06-21

Carrier emails Myers asking him to post a statement on his behalf denying all allegations and saying in part:

• “[FreethoughtBlogs] have every reason to be concerned by prima facie claims of this nature, and I agree with their procedures to date. But they are not equipped to investigate these claims to determine which elements of them are true. I and assigned professionals can. I have decided it’s best for me to move my blog content to another domain where I can operate independently and take all the heat myself, now and in future.”

[OH:DEF000540]

2016-06-24

Carrier posts his statement on his own website, with a few additions.

2016-06-25

Freethought Blogs Ethics Committee posts their statement on Carrier, noting that he has decided not to cooperate, and the investigation therefore cannot be completed.

2016-07-02

Skepticon receives an offer from an individual to investigate, free of charge, the claims made against Carrier, at Carrier’s request. Carrier had received inside information that this individual is the one already running SSA’s investigation, announced June 15th. This investigator bragged about investigating 190 sexual harassment claims in the secular community in the past 4 years. [Having an investigator who was actively leading the SSA’s investigation could cause conflicts of interest. Skepticon’s board decides to make no response to this offer. Neil Carter has an interesting post on the subject from four months later where he talks about this investigator’s interest in keeping things quiet via NDAs .]

[Private email from investigator to Skepticon]

2016-07-06

Carrier’s attorney sends a cease-and-desist (C&D) letter to Frank, demanding a full retraction and public apology.

[OH#1@58 & Exhibit 6]

2016-07-18

Carrier Patreon: 59 Patrons, $131 / post = $524 / month

2016-07-20

Carrier formally requests Myers to remove his blog from the Freethought Blogs network.

[OH:DEF000539]

2016-07-25

Carrier posts “Apology & Going Forward” to his blog, acknowledging that “my actions have made some women in our community uncomfortable” and that those actions have been “contributing to a long­standing climate in which women, especially younger women, may have felt that their value in this community is related to their sexual desirability”, but denying harassment or inappropriate touching. Carrier promises to temporarily refrain from agressively seeking or accepting sex with strangers, especially young students, at future events, at least until his case is settled.

2016-07-26

Carrier’s attorney sends C&D letters to all other defendants demanding full retractions and attorney’s fees.

[OH#1@58 & Exhibits 7-9]

2016-07-30

A friend of Frank creates a GoFundMe fundraiser for Frank’s legal costs. It includes an image of part of the C&D, and a lengthy quote from what is later revealed to be Frank’s original complaint to the SSA.

[AZ#10 Exhibit 4]

2016-07-30

Carrier posts “The Details of my Defamation Case,” claiming:

• “The Secular Student Alliance retained a professional investigator who consulted documents and interviewed witnesses pertaining to this. He did not conclude any sexual harassment or assault had occurred.” [The SSA has stated that it did not investigate Frank’s claims as part of its investigations.]
• “multiple eyewitnesses do not corroborate Frank’s new claims, and that harassment and physical contact were not part of her original complaint to the SSA last year“ [As revealed by Frank’s Answer in the Arizona case (AZ#10), Frank’s original complaints included repeated sexual harassment, and Carrier later (AZ#15) admitted to non-sexual physical contact in a car, and to not being able to confirm or deny a second contact to the inside of her arm.]
• “Both [other complaints] involve long-term friends of mine at the time, each of whom I sent a single electronic message expressing my interest, years ago. They said no. I apologized. And I never renewed any expression of interest in them. That is literally all that this is about.” [Compare this description with Lane’s response of 2013-11-09, and Eli’s (Heina’s) email chain of 2014-09-11]
• “I have not been subject to that policy for a year. I have been a speaker for many SSA campus affiliates in that time, without incident.“ [In the year prior to being removed from the Speaker’s Bureau, Carrier spoke at 10 SSA-sponsored events. In the year after his removal, (but before Frank’s post), he spoke at 4 SSA events, plus 2 where the local SSA was a co-host.]
• “I even directed their way a highly-experienced professional investigator who does this for free and has conducted dozens of investigations for a large number of secular organizations over many years, and who is independent and wholly unaccountable to me.“ [One who seemed a lot more interested and qualified in keeping investigations quiet. See 2016-07-02.]
• “In actual fact, the ‘Skepticon staffer’ in question is Lauren Lane, an ex-lover of mine, who has indicated a strong dislike of me for breaking up with her, and who has harassed me in the past.” [Compare with interactions starting 2013-11-08]
• “After some months I started to feel conflicted about cheating on my wife and told Lane we couldn’t continue, but we could remain friends.” [Carrier has elsewhere described Lane as the fourth of six affairs. (Private email to Skepticon)]
• “Months later I had confessed my cheating to my wife and my wife and I began an open marriage arrangement.” [Seeking a change of rules only after “getting caught” (Eli’s words). Might be a pattern here. One that organizers might find unacceptable, perhaps?]
• “I merely sent [Eli] one letter expressing my interest in them. It was a letter sent to a longtime friend. It wasn’t vulgar. It was polite and not presumptive. [Eli] refused me. I accepted their refusal and apologized.” [Compare with the actual email exchange detailed at 2014-09-11]

2016-07-30

Zvan privately posts a status update to Facebook, reading in part:

• “I fully stand by my original blog post about the allegations against Richard Carrier. It was and is conservative in its presentation of facts and opinions. I have also since heard from a sixth person, who was subject to his advances after taking actions that should have made it crystal clear to him that she was not interested.”
• “That he adopts tactics in that post that he decried when they were used against Karen Stollznow speaks to his integrity in a way that anyone dealing with him should pay close attention to.”

2016-08-02

Skepticon board votes to remove post from its website on advice from its attorney.

[Internal Skepticon discussion]

2016-08-03

SSA announces the conclusion of their internal investigation, finding that the removal of Carrier from the Speakers’ Bureau was proper, but not releasing any other findings. It did not examine Frank’s claims and so could not clear Carrier nor confirm further wrongdoing.

2016-08-15

Carrier Patreon: 62 Patrons, $144 / post = $576 / month

2016-09-01

An attorney graciously working pro bono for Skepticon and Lane responds to the C&D denying his claims and any liability.

[Private attorney letter to Carrier][OH#1 Exhibit 19]

2016-09-19

Carrier Patreon: 64 Patrons, $168 / post = $672 / month

2016-09-20

Carrier files lawsuit in Federal Court in the Southern District of Ohio against all seven defendants, demanding a total of $2.1M in damages.

• Claims that his move to Ohio in June centers his reputation there despite living in California almost all of his life. [Purely a coincidence that California has a strong anti-SLAPP law, while Ohio has none.]
• Relies heavily on Google Trends data to bolster the case that Ohio is the center of Carrier’s popularity. [Note: Trends does not compare absolute search volume. Instead it compares search intensity. It shows the relative number of searches as a percentage of the searches in each state, not the total number of searches. Assuming that the number of searches per capita is the same, the number for California would need to be multiplied by about 3, making California by far the largest source of searches for Carrier, as expected.]
• Claims that the story in the GoFundMe benefitting Frank bears no resemblance to Frank’s original complaint. [Spoiler: it is a quote from her original complaint]
• Denies sexually harassing or touching Frank.
• Admits in his affidavit to expressing his wish to touch Frank in a sexual way, in front of witnesses.
• Claims (indirectly) that SSA conducted an investigation into Frank’s claims and did not conclude that he had sexually harassed her. [No evidence of this investigation has yet emerged. SSA has stated clearly that the investigation it did conduct did not involve Frank’s claims.]
• Includes his cringeworthy exchange of emails with Eli from 2014-09-11 in his own exhibits. [Example of his pattern of boundary pushing behavior, in this instance captured in written form. This level of obliviousness, combined with a strong drive for sex with young students is a recipe for causing harm.]

[OH#1]

2016-09-24

[Multiple defendants find out about the lawsuit not from being served, but from a blog post by Hemant Mehta. None of them had alerted Mehta about the suit. It’s Zvan’s birthday.]

2016-10-21

Defendants decide to band together in a common defense, and hire prominent First Amendment attorney Marc Randazza at the recommendation of Ken White (Popehat). Randazza offers a generous discount on his rates, but they are still steep. Defendants agree to a joint defense and sharing the costs.

[Private emails and chats among defendants.]

2016-11-07

Invoice #1 from attorney: $4,712.50

2016-12-01

Defendants file motion to dismiss lawsuit on jurisdictional grounds, pointing out that none of the defendants have any connection to Ohio, and all knew him only as a Californian.

[OH#10]

2016-12-01

Invoice #2 from attorney: $11,837.50 - Running total: $16,550.00

2016-12-09

Invoice #3 from attorney: $2,882.50 - Running total: $19,432.50

2016-12-19

Carrier Patreon: 73 Patrons, $216 / post = $864 / month

2016-12-23

Carrier files response to defendants’ motion, claiming under penalty of perjury and based “on personal knowledge” that each of the defendants knew of his residence in Ohio at the time they published their posts. [But providing only possibilities and suppositions as evidence.]

[OH#17]

2017-01-05

Invoice #4 from attorney: $5,370.20 - Running total: $24,802.70

2017-01-06

Defendants’ ask for Carrier to voluntarily be deposed to give basis for his claims that defendants knew of his move to Ohio prior to June 20th, and related claims. Carrier’s attorney responds positively, but Carrier refuses.

[Attorney email]

2017-01-23

Defendants file a motion for limited discovery to allow Carrier to give any evidence he has for his claims to jurisdiction, which have not met even the low bar required.

[OH#23]

2017-02-02

Carrier objects to providing jurisdictional evidence claiming that he has already given enough to satisfy legal requirements.

[OH#27]

2017-02-06

Invoice #5 from attorney: $4,617.50 - Running total: $29,420.20

2017-02-09

Defendants reply that Carrier’s claims amount only to his say-so against sworn affidavits from each of the defendants, and that this raises Carrier’s burden of proof.

[OH#29]

2017-02-13

Carrier Patreon: 78 Patrons, $300 / post = $1,200 / month

2017-03-02

Invoice #6 from attorney: $5,471.56 - Running total: $34,891.76

2017-04-04

Invoice #7 from attorney: $112.50 - Running total: $35,004.26

2017-05-10

Invoice #8 from attorney: $1,988.00 - Running total: $36,992.26

2017-06-13

Concerned that he might lose the jurisdiction fight, Carrier asks the Ohio court to order any future court in other states to extend their statutes of limitations clocks by a year.

[OH#31]

2017-07-05

Defendants reply that Carrier acted in bad faith by filing in Ohio, that Ohio can’t tell other courts what to do, and that if the court dismisses the suit on jurisdiction, any ruling it makes on time limits won’t count.

[OH#32]

2017-07-10

Invoice #9 from attorney: $3,502.50 - Running total: $40,494.76

2017-08-14

Court grants defendants’ motion for limited discovery, and ends their motion to dismiss until after the limited discovery is completed.

[OH#33]

2017-08-14

Carrier Patreon: 88 Patrons, $403 / post = $1,612 / month

2017-08-17

Invoice #10 from attorney: $287.50 - Running total: $40,782.26

2017-09-19

Invoice #11 from attorney: $1,965.00 - Running total: $42,747.26

2017-10-05

Carrier submits his list of discovery questions for the defendants, including:

• Requiring the names and contact information for anyone who communicated about his harassing behavior privately.
• Obsessing over and badly misrepresenting a presentation by Ken White on how to handle harassment claims, and demanding defendants admit to having seen this presentation.
• Insisting that defendants conspired with each other in making their statements.

[Attorney email to defendants]

2017-10-06

Invoice #12 from attorney: $1,203.10 - Running total: $43,950.36

2017-10-16

Carrier Patreon: 106 Patrons, $454 / post = $1,816 / month

2017-10-18

Defendants submit their responses to Carrier’s discovery requests, refusing to answer the many items with no connection to the subject of jurisdiction, since these were outside the scope of what the court ordered.

[Attorney email]

2017-11-13

Invoice #13 from attorney: $13,574.64 - Running total: $57,525.00

2017-11-17

Court denies Carrier’s motion to extend the statute of limitations as moot (pointless) as the defendants had argued. The court said that if the defendants refiled their motion to dismiss, Carrier could resubmit his motion with the Ohio court, but would have to answer the defendants’ objections. [Carrier misreads this badly, later.] [OH#37]

2017-12-12

Invoice #14 from attorney: $302.50 - Running total: $57,827.50

2017-12-15

Carrier responds to defendants’ discovery requests. Notable responses include:

• Again unable to substantiate claims that defendants knew of his move to Ohio prior to publication, citing only his two blog posts, and telling two other bloggers at The Orbit.
• Claims that while he was never an employee of SSA or Camp Quest, he had “had on many occasions been hired as a contractor” by both organizations. [If true, Carrier is admitting to being rather deceptive in his original response to Frank’s claims, and showing both SSA and Camp Quest’s leadership at the time to be just as deceptive.]
• Submitted spreadsheets with data showing less than 12% of his 2015 income from SSA events, 0% from Camp Quest. California income was almost 2.5x Ohio income, despite this being his biggest Ohio income year. Ohio was not his “principal source of speaking and direct sales income” as he had claimed.
• Carrier’s 2016 income dropped in both California (by $5200) and Ohio (by $1700). Contract income increased slightly. Overall income dropped a bit less than 16%. His biggest expense was paying $28,000 in attorney’s fees.
• Carrier’s 2017 income was incomplete, but projecting for December, gross income was within 14% of 2016’s, and saw an increase in Patreon income of over $9000.
• [These figures come from spreadsheets provided by Carrier, but do not include any documents to back them up.]

[Attorney email]

2018-01-03

Invoice #15 from attorney: $5,474.33 - Running total: $63,301.83

2018-01-23

Carrier is deposed regarding jurisdiction.

• Flatly denies harassing or touching Frank. Discusses the Venn relationship of sex and dating.
• Cannot produce or even name any evidence of any defendant knowing that he had moved to Ohio before their posts, just supposition and speculation.
• Admits that he has no evidence that Skepticon or Lane knew he had moved at the time of publishing their post.
• Admits that Myers believed that Carrier lived in California at the time he published his post.
• Can name only one potential business opportunity he was negotiating in Ohio, with Camp Quest. [CQ and Carrier had denied they had any current or planned relationship in posts dated on the day of Frank’s post.]
• Claims that his speaking engagements dried up following the defendants posts in mid 2016. [They started a steep decline following his expulsion from the speakers’ bureau in mid 2015.]
• Revealed that he was receiving inside information while SSA was conducting its investigation into the handling of Frank’s complaint.
• Estimates FreethoughtBlogs readership at 1.4M and The Orbit at 200-400k people per month.
• Admits that his efforts at cultivating business in Ohio only began in 2015.

[OH#41]

2018-02-02

Invoice #16 from attorney: $20,096.19 - Running total: $83,398.02

2018-03-14

Invoice #17 from attorney: $1,776.12 - Running total: $85,174.14

2018-04-16

Carrier Patreon: 122 Patrons, $667 / post = $2,668 / month

2018-04-12

Invoice #18 from attorney: $55.00 - Running total: $85,229.14

2018-05-05

Invoice #19 from attorney: $165.00 - Running total: $85,394.14

2018-05-29

Carrier files a brief giving his arguments against dismissal:

• Carrier has already met his obligation to prove jurisdiction.
• Defendants refusal to turn over evidence, [unrelated to jurisdiction], in a discovery that is limited to the question of jurisdiction is evidence that they have none.
• By law, Carrier’s allegations have to be assumed true, and defendants’ evidence ignored.

[OH#40]

2018-05-30

Defendants file a brief giving their arguments for dismissal:

• It is Carrier’s burden to produce some minimal basis for his claims that the defendants knew he had moved to Ohio prior to publishing their posts. Carrier admitted to having no such evidence.
• Carrier’s use of Google Trends data is at best junk science.
• None of the defendants have ever had any substantial contact with Ohio.
• Carrier described his reasons for moving to Ohio as reduced cost of living and proximity to girlfriends, not business opportunity.

[OH#42]

2018-06-07

Invoice #20 from attorney: $10,062.50 - Running total: $95,456.64

2018-06-12

Carrier publishes on his web site a series of pages titled “Help Me Get a Fair Trial”

• Claims that defendants “pose a significant threat to the atheist, skeptic, and humanist communities” and “a future threat to you, or those you care about”.
• Claims “all I am being accused of is asking for consent, and respecting the answer”.
• Claims defendants have “endless funds”.
• Claims that Carrier offered defendants court-facilitated arbitration and that the defendants refused. [None of the defendants have memory or record of this offer getting to them. The closest thing that any can remember is that the court automatically schedules a mediation for just prior to trial, and when the jurisdiction hearing fight pushed out the expected court schedule for a year, that mediation was canceled. The defendants were also opposed to settlement offers from Carrierin part because he insisted on getting the identities of people who came forward privately to complain of harassment.]
• Insisted he only listened to Frank sympathetically, and then said he’d be interested in dating her, nothing else. Characterized this as “one polite remark, and immediately we parted.”
• Claims that SSA had an investigation into Frank’s claims.
• Misreads Frank’s claim that Carrier offered to involve her husband in the sex he proposed as the opposite, and claims this as evidence that she did not know his personal “favorite kink”.
• Misreads Frank’s “martyring” comment as being sympathetic to him.
• Claims that he is pursuing his legal action to try to get the defendants to talk. [But legal action and threats of legal action only shut down conversation, and that is the first piece of advice from any lawyer. It certainly worked here. Carrier can’t possibly not know that.]

2018-07-14

Invoice #21 from attorney: $1,746.56 - Running total: $97,203.20

2018-08-01

Invoice #22 from attorney: $405.00 - Running total: $97,608.20

2018-08-01

Invoice #23 from attorney: $1,710.00 - Running total: $99,318.20

2018-08-13

Carrier Patreon: 132 Patrons, $678 / post = $2,712 / month

2018-09-05

Invoice #23 from attorney: $5,660.00 - Running total: $104,978.20

2018-09-16

Carrier posts “Would You Like to Be My Date for MythCon?”, offering “access to the event, if you don’t already have tickets; and a share of a bed (platonically even), if you haven’t already booked your own room. I’ll also cover drinks.”

2018-10-03

Invoice #24 from attorney: $4,885.50 - Running total: $109,863.70

2018-11-14

Court dismisses Ohio case for lack of personal jurisdiction, arguing:

• Carrier was living in Ohio for at most a few weeks.
• Carrier could not produce any evidence that defendants knew he had moved to Ohio at the time of publishing.
• Carrier could not produce any evidence that the posts were targeted at Ohio.
• Carrier himself had minimized his association with the Ohio organizations he pointed to as his business interests in Ohio.
• Carrier could not even establish the necessary minimal contact between any defendant and Ohio.

[OH#43]

2018-11-15

Invoice #25 from attorney: $82.50 - Running total: $109,976.20

2018-11-15

Invoice #26 from attorney: $92.50 - Running total: $110,038.70

2018-12-04

Invoice #27 from attorney: $1,655.00 - Running total: $111,693.70

2018-12-04

Invoice #28 from attorney: $2,977.50 - Running total: $114,671.20

2018-12-14

[Time expires on Carrier’s ability to file a notice of appeal of the decision.]

2018-12-17

Carrier Patreon: 121 Patrons, $655 / post = $2,620 / month

2018-12-31

Invoice #29 from attorney: $280.00 - Running total: $114,951.20

2018-12-31

Invoice #30 from attorney: $1,342.50 - Running total: $116,293.70

2019-02-01

Invoice #31 from attorney: $232.50 - Running total: $116,526.20

2019-04-15

Carrier Patreon: 129 Patrons, $635 / post = $2,540 / month

2019-04-29

Carrier files new lawsuits, acting as his own attorney and shortly before the deadline to file in Arizona, against Frank in Arizona, Myers in Minnesota, and Lane and Skepticon in Missouri:

• Misreads the Ohio judge’s instruction from 2017-11-17 as “...instructing Plaintiff to re-file later in an appropriate jurisdiction and address therein the objections to tolling the statute...”, rather than if he were to refile his motion in Ohio he needs to counter the defendants’ arguments.
• Denied he touched or sexually harassed Frank.
• Claims that Frank’s original complaint was only regarding fraternization, not sexual harassment.
• Claimed that Frank’s original claim “bears no factual resemblance” to the quote from her on the GoFundMe page set up for her benefit. [Spoiler: it’s a quote from the original complaint]
• Claimed that SSA had conducted an investigation into Frank’s “new claims”.
• Claims that Myers’s investigation announcement somehow declared Carrier to be guilty.
• Claims that he was defamed by statements in the private response letter from Skepticon’s attorney to Carrier’s attorney.
• Uses Google’s meaningless “About 48,500,000 results” as serious evidence. [Actual number of results returned, including duplicates, for “Richard Carrier” is 336]
• Argues for a statute of limitations extension based on Ohio law.
• Demands $1.3M in damages, plus interest and costs.
• Affidavit in Arizona denies touching Frank in any way, denies any further “intimate communication” after that night, and claims that Frank published the original GoFundMe.
• Affidavit in Minnesota claims that Myers ordered the investigation only after Carrier complained.
• Affidavit in Missouri claims that Lane was Carrier’s employer.

[AZ#1, MN#1, MO#1]

2019-05-24

Frank files an answer to Carrier’s complaint and includes counter-claims:

• Denies all substantive allegations against her.
• Argues that the suit is barred because it was filed after the statute of limitations had run.
• Argues that Carrier acted in bad faith by suing in Ohio, and does not qualify for an extension on the time limit.
• Argues that Carrier’s reputation regarding sexual behavior had already been injured by prior, greater public claims against him.
• Argues that Carrier cannot demonstrate damages because he is making more money than before, and is now more popular among groups such as mens’ rights activists.
• Points out that the GoFundMe was not published by Frank.
• Claims that Carrier sexually fixated on another student at the bar and Frank overheard his comments.
• Claims that this student appeared to be made uncomfortable by Carrier’s behavior.
• Claims that the gathering at the house was related to a friend’s birthday party, not specifically to accompany Carrier there.
• Claims that in a ride-share from bar to house Carrier put his hand on Frank’s leg without consent.
• Claims that at the house, Carrier bragged about having sex with other secular leaders.
• Claims that Carrier explicitly asked her for sex, which she explicitly refused multiple times.
• Claims that Carrier then proposed involving Frank’s husband, which she also refused.
• Claims Carrier said he would send Frank something “inappropriate”, which she rejected.
• Claims Carrier caressed the inside of Frank’s arm without consent, and commented on her tattoo, and that Frank made it clear to Carrier that his touch was inappropriate.
• Claims Carrier said he wanted a girlfriend in Arizona.
• Claims that despite asking him not to do so, Carrier sent Frank a Facebook message the next day repeating his interest in a future relationship. Exhibits included a screenshot of this message.
• Included, as an exhibit, the original complaint made by the outgoing president of the ASU SSA, saying that two women had complained about Carrier’s behavior that night, but only Frank chose to report to the SSA formally. Provides the full complaint, which was only excerpted on the original GoFundMe for Frank.
• Claims Carrier defamed her with a series of web pages published on or about 2018-06-12, calling her a liar repeatedly despite knowing his claims were false.

[AZ#10]

2019-06-04

Invoice #32 from attorney: $19,522.50 - Running total: $136,048.70

2019-06-07

Carrier files an answer to Frank’s cross-complaint:

• Claims that student at the bar had previously arranged to discuss polyamory with Carrier.
• Claims that the small group followed him to the home where he was staying, not for other reasons.
• Admits that Carrier touched other people in the ride-share but blames tight quarters and denies it was sexual.
• Claims Carrier cannot recall claiming he had sex with leaders of the secular community, and so cannot admit or deny it.
• Again admits he openly verbally sexually harassed Frank (by declaring his wish to touch her in a manner he considered sexual.) Denies he said it more than once.
• Claims Carrier cannot now recall whether he discussed having sex with Frank.
• Denies that Frank told Carrier that she did not want sex with him.
• Claims that Carrier cannot now recall whether he suggested a three-way encounter with Frank and her husband. Somehow misreads again that Frank is claiming the opposite and that this shows that she made it up, because MFM is his favorite kink. Admits that her case would be much stronger if she had known his kink. [Which she did, so…]
• Admits that Carrier said he wanted to send her something “inappropriate”.
• Claims that Carrier cannot now recall whether he touched Frank’s arm, but that it doesn’t sound like him.
• Admits that Carrier told Frank that he wanted a girlfriend in Arizona.
• Admits that Carrier sent the Facebook message to Frank the next day “that if you’re ever free or can convince [husband] to go for it, I’d love to.” in contrast to his earlier sworn statement that he did not communicate with Frank following the previous night.
• Claims that Frank sent Carrier a second Facebook message after responding politely [but does not provide it here]. On his website, Carrier has posted an image of this exchange.
• Admits that Carrier’s reason for resigning from the SSA Speakers’ Bureau was to be free from the restriction on approaching students for sex. Clarifies that he also wanted to be free to accept when students approached him for sex.

[AZ#15]

2019-06-16

Mario Quadracci writes a letter to defendants’ attorney, Marc Randazza, claiming that he will “fully fund” Carrier’s lawsuit against all defendants unless Randazza provides him with sufficient facts to “dissuade” him.

[Attorney email]

2019-06-17

Carrier Patreon: 131 Patrons, $683 / post = $2,732 / month

2019-06-18

Frank files motion to dismiss based on lack of subject-matter jurisdiction

• Argues that Carrier has now admitted that he would settle the case in exchange for a retraction only, and that considering his annual income, the value of the retraction could not exceed the $75,000 minimum for federal court.

[AZ#24]

2019-06-28

Carrier files response to the motion to dismiss

• Argues that the proper time to argue over subject jurisdiction is after discovery.
• Claims that his offer to settle was an offer of “forgiveness” and “mercy” toward Frank in exchange for retraction, which is worth $1.3M to him.
• Carrier estimates that the damage to his income over the past three years has been $30,000 in total.
• Carrier notes that this does not account for emotional damages.

[AZ#29]

2019-07-01

Frank files a reply to Carrier’s response

• Argues that the law says the court has a duty to rule on subject jurisdiction whenever it comes into question.
• Argues that at most, Carrier has been able to support claims for $30,000 in damages that, by law, count toward the amount in controversy.
• Argues that even that figure should not fall on Frank individually, as Carrier has claimed that all seven original defendants contributed to the damage.

[AZ#35]

2019-07-02

Invoice #33 from attorney: $29,865.00 - Running total: $165,913.70

2019-07-03

Carrier files a motion to allow him to make a sur-reply to Frank’s reply

• Argues that if damages are to be divided, the divisor should be four (or maybe three).
• Argues that over the course of twenty years, divided by four, and taking what he feels is a low number for punitive damages, that has to be at least $100,000.

[AZ#36]

2019-07-03

Court denies Frank’s motion to dismiss on subject jurisdiction

• Argues that the amount claimed in the complaint can only be challenged if “to a legal certainty,” the “plaintiff cannot recover the amount claimed”, and that Frank has not met that burden.
• Court is not convinced that Carrier acted in bad faith in setting the claim amount.

[AZ#46]

2019-07-08

Myers files a motion to dismiss as lacking in merit and time-barred by the statute of limitations, arguing that:

• The claim against Myers is for saying that he received and read complaints, and that Carrier has admitted that Myers had done so for at least two public complaints.
• Minnesota law controls the statute of limitations, that its time has expired, and that the Minnesota saving statute does not apply to this case.
• Applying Ohio law to a defendant, when an Ohio court had just ruled he had too little contact with Ohio to apply Ohio law, is incoherent.
• Carrier was not prevented from filing in Minnesota during the limitations period, and had been fully warned of this by defendants’ motion in December 2016 that jurisdiction in Ohio was not valid.

[MN#6, 9]

2019-07-08

Skepticon and Lane file a motion to dismiss as lacking in merit and time-barred by the statute of limitations, arguing that:

• Carrier has already publicly admitted that he has engaged what could reasonably be described as boundary-pushing behavior.
• What is unacceptable risk is an opinion, and expressing it is protected by the federal Constitution.
• Carrier admits that the statute of limitations has already passed.
• Missouri law controls this case, and the Missouri saving statute does not apply to cases originally filed outside of Missouri.
• Applying Ohio law to the defendants, when an Ohio court had just ruled that they had too little contact with Ohio to apply Ohio law, is incoherent.
• Carrier was not prevented from filing in Missouri during the limitations period, and had been fully warned of this by defendants’ motion in December 2016 that jurisdiction in Ohio was not valid.
• Carrier’s complaints about the letter from Skepticon’s lawyer cannot be a cause for action because such an attorney’s letter is absolutely privileged, and because it was not published.

[MO#6]

2019-07-15

Carrier files a response to Skepticon’s motion to dismiss, arguing that:

• If the binding legal precedents are ignored, Missouri’s saving statute reads as if it should apply.
• Skepticon’s use of the word “repeated” indicated that Carrier had persisted after receiving a no, rather than as having multiple occasions of the behavior.
• He can prove that his behavior was not one of the reasons why Skepticon organizers stopped inviting him because it was not in the email he received, and because the organizers, including Lane, continued to treat him in a friendly manner.
• His behavior did not pose any “unacceptable risk” in his opinion.
• His filing in Ohio was a “correctable error” made in good faith, that should not prevent him from suing now in Missouri.
• Precedent regarding out-of-state action is not binding on this case because the case used as precedent had a negligent plaintiff.
• If an action does not violate Skepticon’s written policy, it cannot cause harm to the well-being or comfort of attendees.

[MO#7]

2019-07-19

Skepticon and Lane file a reply to Carrier’s response on their motion to dismiss, arguing that:

• Each state gets to interpret its own laws.
• Ohio law has already been ruled by Ohio courts as inapplicable to the defendants.
• Missouri’s saving statute references its effect only on Missouri law and courts.
• Carrier had the option of re-filing in California where jurisdiction would not be contested, but persisted in Ohio, meeting the legal standard for unclean hands and bad faith.
• Carrier is adding his interpretation to the plain words of Skepticon’s blog post, which is impermissible in defamation analysis.
• Carrier admits to repeated sexual behavior at Skepticon, and what is boundary-pushing is protected opinion.
• The fact that Carrier was told one reason for being disinvited does not mean that there were not others that were concealed from him.
• What Skepticon considers an unacceptable risk is by law a protected opinion.

[MO#8]

2019-07-29

Carrier files a response to Myers’ motion to dismiss, arguing that:

• Myers has not sufficiently established that the amount in question is insufficient.
• Carrier’s original filing in Ohio was reasonable.
• Precedent cited by Myers is inapplicable because a new law was passed since then, which would allow Ohio law to apply.
• Extending the statute of limitations is permitted when extraordinary circumstances intervene. Carrier’s stated extraordinary circumstance is that he “could not foresee losing”.
• [It’s all so unfair that he was not permitted to sue in a manner convenient for him regardless of the rights of those he sued.]
• Myers reset the statute-of-limitations clock by publicly talking about the case. [Also Carrier: Oh why won’t the defendants talk about the cases?]
• Admitting to a habit of sexually propositioning young students is a “trivial observation”. The objectionable claim is that he violated consent by persisting in unwanted behavior.

[MN#27]

2019-08-08

Invoice #34 from attorney: $45,626.50 - Running total: $211,540.20

2019-08-12

Myers files a reply to Carrier’s response to Myers’ motion to dismiss, arguing that:

• The new law that Carrier cites does not apply to this case because the other state’s statute of limitations does not apply, as explicitly required by the new law.
• Carrier filed in Ohio for his own convenience, not out of legal necessity.
• Carrier did, in fact, foresee losing in Ohio, filing a motion asking the Ohio court to extend other states’ statutes of limitation prior to one year after the alleged defamation.
• Any additional statements by Myers in his video are not a subject of Carrier’s complaint in this case and can’t be used to reset the statute of limitations. Any repetitions of earlier statements fall under the single-publication rule.
• Myers’ claim was that he “received reports”, not that he could prove that the reports were true.
• Carrier’s claim that Myers said Frank’s claims were not believable, in context, was a statement that one complaint on its own is less believable than when combined with the “rising number of women” now complaining to him.
• Myers asked for and received a statement from Carrier giving his defense against the known accusations.

[MN#30]

2019-08-12

Carrier Patreon: 140 Patrons, $855 / post = $3,420 / month

2019-09-03

Invoice #35 from attorney: $16,292.68 - Running total: $227,832.88

2019-09-24

Carrier and Randazza give oral arguments on motion to dismiss the case against Myers in Minnesota. Arguments on both sides generally follow those previously submitted in writing.

[Transcript not available, so this is based on attendee notes.]

• Carrier argues for a right to have his day in court, that justice would not be served otherwise. [Seems to be an argument about how the law should be, rather than how the law is.]
• Randazza points out that Ohio law was found by an Ohio court to be inapplicable against Myers.
• Randazza also argues that the facts as put forward by Carrier demonstrate that the case should be thrown out on its merits, that Carrier’s pleadings contain proof that Myers’s claims are true, and admit that Myers had access to more than one claim from an accuser fitting his factual claims about them. By law, this cannot meet the standard for defamation of a public figure.
• Carrier agrees to drop the claims for emotional distress as not meeting Minnesota’s standards.
• Carrier claims that defendants were lying about not knowing of his move to Ohio prior to publishing the alleged defamation.
• Carrier argues that “in defiance of requests that he stop” was not previously publicly claimed, plus he claims Myers refused to investigate, and this is why he is suing Myers.
• Carrier offers to amend his suit to include claims against Myers’s video if that will save his claim from being time-barred. (Judge says he will take that under consideration. [Seemed skeptical, to defense observer.])

2019-09-30

Court in Missouri dismisses the case against Skepticon and Lane with prejudice as time-barred, but making no ruling on the merits.

[MO#10]

2019-10-01

Carrier files 63-pages of requests for discovery for Frank, described by Randazza as “hilarious”, “bulshittery”, and said that Frank was in for a “ride on the crazy train”. Among the requests were some for Randazza to conduct specific procedures to log in to Frank’s social media, unblock Carrier, and search for specific results. Questions included returning to insinuations of Frank lying about being unaware of his move to Ohio, which had nothing to do with this case, and long series of slight variations of questions asking her to speculate what a “reasonable person” would think, [indicating his poor grasp on the purpose and rules for the discovery process. Answers are only to be based on personal knowledge.]

[Internal defendants’ chat, and attorney email]

2019-10-02

Invoice #36 from attorney: $9,610.00 - Running total: $237,442.88

2019-10-08

Plans for Frank’s deposition by Carrier begin. [The idea that Frank will be questioned by Carrier, her accused harasser, rather than by a professional, is emotionally daunting. Plans begin among defendants to support her through the ordeal.]

[Internal defendants’ chat and attorney emails]

2019-11-06

Invoice #37 from attorney: $11,165.00 - Running total: $248,607.88

2019-11-20

Carrier contacts Randazza offering a walk-away agreement, with no restrictions on any party discussing terms or the case. Frank and Myers agree.

[At this point, Carrier has had his cases dismissed in Ohio and Missouri on technical grounds, is facing very likely dismissal in Minnesota, possibly on merits as well as technical grounds, and has counter-claims from Frank that may cost him a great deal of money should he lose. In addition, the internal SSA documents regarding the handling and investigation of Frank’s case would certainly be subpoenaed. Carrier losing seemed very likely to the defendants, considering how much of Frank’s claims he had already admitted to in his response, and how much his story about that night had changed over time. Even so, bringing the case to trial would cost hundreds of thousands of dollars more, and significant judgements against Carrier seemed unlikely to ever be paid.]

[Internal defendants’ chat and attorney emails]

2019-11-25

Settlement agreement is signed by Carrier, Myers, and Frank. Agreement includes dismissal of remaining suits with prejudice, releases of all parties to the original suit, plus the GoFundMe authors from all liability for any actions or statements prior to the agreement or regarding the claims involved in the cases, a covenant not to sue for released items, and arbitration for any disputes.

[Attorney emails.]

2019-11-25

Carrier files stipulations of dismissal in the AZ and MN cases.

[AZ#50, MN#33]

2019-11-26

Judge formally dismisses AZ case against Frank.

[AZ#51]

2019-11-27

Carrier announces on his Patreon page that “In the spirit of the coming holidays, I'm dismissing my lawsuits, after getting from the defendants all the evidence they had” and falsely claiming once again that he had obtained proof that Frank lied. [Such holiday spirit! Fails to note that none of the suits ever reached the point where the defense was to argue its case or present its evidence.]

2019-12-02

Judge formally dismisses MN case against Myers.

[MN#34]

2019-12-05

Invoice #38 from attorney: $16,670.00 - Running total: $265,277.88

2019-12-16

Carrier Patreon: 134 Patrons, $834 / post = $3,336 / month

2019-12-30

Invoice #39 from attorney: $175.00 - Running total: $265,452.88