Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 1 of 44

Marc J. Randazza (pro hac vice) RANDAZZA LEGAL GROUP, PLLC 4035 S. El Capitan Way Las Vegas, Nevada 89147 Tel: (702) 420-2001 [email protected] Jay M. Wolman (pro hac vice) RANDAZZA LEGAL GROUP, PLLC 100 Pearl Street, 14th Floor Hartford, Connecticut 06103 Tel: (702) 420-2001 [email protected] Mathew M. Stevenson, St. Bar # 6876 STEVENSON LAW OFFICE 1120 Kensington, Suite B Missoula, MT 59801 Tel: (406) 721-7000 [email protected]

Attorneys for Defendant, Andrew Anglin

UNITED STATES DISTRICT COURT DISTRICT OF MONTANA MISSOULA DIVISION

) TANYA GERSH, ) Case No. 9:17-cv-50-DLC-JCL ) Plaintiff, ) ) DEFENDANT ANDREW vs. ) ANGLIN’S BRIEF IN SUPPORT ANDREW ANGLIN, ) OF MOTION TO DISMISS ) Defendant. ) ) )

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TABLE OF CONTENTS

TABLE OF AUTHORITIES ...... II

MEMORANDUM OF POINTS AND AUTHORITIES ...... 1

1.0 LEGAL STANDARD ...... 3

2.0 FACTUAL BACKGROUND ...... 5

3.0 PLAINTIFF’S ATTEMPTS AT SERVICE OF PROCESS ...... 11

4.0 ANALYSIS ...... 12

4.1 Plaintiff Failed to Serve Defendant, Timely or Otherwise ...... 12

4.2 This Court lacks Subject Matter Jurisdiction over the Action ...... 16

4.3 Plaintiff Failed to State a Claim Overriding Defendant’s Constitutionally Protected Speech ...... 17

4.3.1 The Articles are Not Fighting Words ...... 18

4.3.2 The Articles are Not True Threats ...... 19

4.3.3 The Articles are Not Incitement ...... 20

4.3.4 No New Category of Unprotected Speech Should be Created ...... 21

4.3.5 Defendant Cannot be Held Liable for the Acts of Third Parties ...... 24

4.4 Plaintiff Fails to State a Viable Cause of Action ...... 25

4.4.1 Defendant is Not Liable for Invasion of Privacy ...... 25

4.4.2 Defendant is Not Liable for Intentional Infliction of Emotional Distress ...... 27

4.4.3 Defendant did not Harass or Intimidate Plaintiff ...... 29

5.0 CONCLUSION ...... 31

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TABLE OF AUTHORITIES

CASES

Argent Mortg. Co. v. Sellers, 2010 Ohio Misc. LEXIS 15636 (Ohio Ct. Com. Pl. Nov. 10, 2010) ...... 15

Ashcroft v. Iqbal, 556 U.S. 662 (2009) ...... 4

Boy Scouts of Am. v. Dale, 530 U.S. 640 (2000) ...... 3

Branch v. Tunnell, 14 F.3d 449 (9th Cir. 1994) ...... 4

Brandenburg v. Ohio, 395 U.S. 444 (1969) ...... 2, 20

Brimm v. Genao-Gomez, 2014 U.S. Dist. LEXIS 152574 (D. Mont. Oct. 28, 2014) ...... 16

Brockmeyer v. May, 383 F.3d 798 (9th Cir. 2004) ...... 4

Butler v. Domin, 2000 MT 312, 302 Mont. 452, 15 P.3d 1189 (2010) ...... 24

Cardan v. N.Y. Life Ins. Co., 2016 U.S. Dist. LEXIS 140731 (D. Mont. Oct. 11, 2016) ...... 4

Collin v. Smith, 578 F.2d 1197 (7th Cir. 1978) ...... 20

Conn v. Zakharov, 667 F.3d 705 (6th Cir. 2012) ...... 14

Fairbank v. Underwood, 986 F. Supp. 2d 1222 (D. Or. 2013) ...... 4

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Gertz v. Robert Welch, 418 U.S. 323 (1974) ...... 29

Goldstein v. Christiansen, 70 Ohio St. 3d 232, 638 N.E.2d 541 (1994) ...... 14

Gooding v. Wilson, 405 U.S. 518 (1972) ...... 18

Haines Pipeline Constr. v. Mont. Power Co., 251 Mont. 422, 830 P.2d 1230 (1991) ...... 11

Hastetter v. Behan, 196 Mont. 280, 639 P.2d 510 (1982) ...... 26

Hustler Magazine v. Falwell, 485 U.S. 46 (1988) ...... 29

In re Estate of NEWCOMB, 192 N.Y. 238, 84 N.E. 950 (1908) ...... 17

Judd v. Burlington N. & Santa Fe Ry., 2008 MT 181, 343 Mont. 416, 186 P.3d 214 (2008) ...... 28

Katzenbach v. Grant, 2005 U.S. Dist. LEXIS 46756 (E.D. Cal. June 7, 2005) ...... 26

Koepplin v. Zortman Mining, 267 Mont. 53, 881 P.2d 1306 (1994) ...... 27

Lew v. Moss, 797 F.2d 747 (9th Cir. 1986) ...... 16, 17

McIntyre v. Ohio Elections Comm’n, 514 U.S. 334 (1995) ...... 3

Miller v. Great Falls Ath. Club, LLC, 2010 MT 171N (2010) ...... 25

Miss. Publ’g Corp. v. Murphree, 326 U.S. 438 (1946) ...... 4

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Mont. Chamber of Commerce v. Argenbright, 28 F. Supp. 2d 593 (D. Mont. 1998) ...... 3

N.Y. Times Co. v. Sullivan, 376 U.S. 254 (1964) ...... 2

NAACP v. Claiborne Hardware Co., 458 U.S. 886 (1982) ...... 2, 25

Newman-Green, Inc. v. Alfonzo-Larrain, 490 U.S. 826 (1989) ...... 16

O’Brien v. Welty, 818 F.3d 920 (9th Cir. 2016) ...... 22, 23

Omni Capital Int’l v. Rudolf Wolff & Co., 484 U.S. 97 (1987) ...... 3, 4

Padgett v. Auburn Univ., 2017 U.S. Dist. LEXIS 74076 (M.D. Ala. Apr. 18, 2017) ...... 1

Peschel v. City of Missoula, 2008 U.S. Dist. LEXIS 98651 (D. Mont. Dec. 5, 2008) ...... 11

Peschel v. City of Missoula, 2009 U.S. Dist. LEXIS 14442 (D. Mont. Jan. 5, 2009) ...... 11

Puente Ariz. v. Arpaio, 821 F.3d 1098 (9th Cir. 2016) ...... 23

Realty Holding Co. v. Donaldson, 268 U.S. 398 (1925) ...... 16

Rodriguez v. Maricopa Cty. Cmty. Coll. Dist., 605 F.3d 703 (9th Cir. 2009) ...... 22

Sacco v. High Country Indep. Press, 271 Mont. 209, 896 P.2d 411 (1995) ...... 27

Saxe v. State Coll. Area Sch. Dist., 240 F.3d 200 (3d Cir. 2001) ...... 22

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Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797 (9th Cir. 2004) ...... 3

Sher v. Johnson, 911 F.2d 1357 (9th Cir. 1990) ...... 3

Shoemaker v. Taylor, 730 F.3d 778 (9th Cir. 2013) ...... 18

Snyder v. Phelps, 562 U.S. 443 (2011) ...... 28

Stamey v. Howell, 2016 U.S. Dist. LEXIS 169318 (D. Mont. Dec. 7, 2016) ...... 4

State ex rel. Copeland v. State Med. Bd., 107 Ohio St. 20, 140 N.E. 660 (1923) ...... 15

State ex rel. Hadley v. Pike, 2014-Ohio-3310 (Ohio Ct. App. 2014) ...... 15

State v. Cooney, 271 Mont. 42, 894 P.2d 303 (1995) ...... 22

State v. Dugan, 2013 MT 38, 369 Mont. 39, 303 P.3d 755 (2013) ...... 19

State v. Lance, 222 Mont. 92, 721 P.2d 1258 (1986) ...... 30

State v. Nye, 283 Mont. 505, 943 P.2d 96 (1997) ...... 22

Stevens v. Sec. Pac. Nat’l Bank, 538 F.2d 1387 (9th Cir. 1976) ...... 4

Strong v. Countrywide Home Loans, Inc., 2017 U.S. App. LEXIS 15559 (9th Cir. Aug. 17, 2017) ...... 3

United States v. Alvarez, 567 U.S. 709 (2012) ...... 18, 21

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United States v. Cassel, 408 F.3d 622 (9th Cir. 2005) ...... 29

United States v. Dahlstrom, 713 F.2d 1423 (9th Cir. 1983) ...... 20

United States v. Orozco-Santillan, 903 F.2d 1262 (9th Cir. 1990) ...... 19

United States v. Poocha, 259 F.3d 1077 (9th Cir. 2001) ...... 18

United States v. Stevens, 559 U.S. 460 (2010) ...... 23

Virginia v. Black, 538 U.S. 343 (2003) ...... 19

Washington County Dep’t of Human Servs. v. Rutter, 100 Ohio App.3d 32, 651 N.E.2d 1360 (4th Dist.1995) ...... 15

Watts v. United States, 394 U.S. 705 (1969) ...... 19

Weible v. United States, 244 F.2d 158 (9th Cir. 1957) ...... 17

West Virginia State Board of Education v. Barnette, 319 U.S. 624 (1943) ...... 32

Widmar v. Vincent, 454 U.S. 263 (1981) ...... 23

Williams v. Moody, 1999 U.S. Dist. LEXIS 527 (E.D. Pa. Jan. 22, 1999) ...... 14

Worrell-Payne v. Gannett Co., 49 F. App’x 105 (9th Cir. 2002) ...... 29

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STATUTES

28 U.S.C. § 1332 ...... 15, 16

Mont. Code Ann. § 31-1-316 ...... 7

Mont. Code Ann. § 27-1-1503 ...... 22, 28, 29

Mont. Code Ann. § 28-10-103 ...... 24

Mont. Code Ann. § 28-10-602 ...... 23

Mont. Code Ann. § 45-5-203 ...... 22, 29

Mont. Code Ann. § 45-7-102 ...... 22, 29

Mont. Code Ann. §27-1-221 ...... 11, 28

Mont. Code Ann. §37-51-313 ...... 7

Ohio Rev. Code Ann. § 2307.382 ...... 14

RULES

Fed. R. Civ. P. 12 ...... 3, 4, 5

Fed. R. Civ. P. 4 ...... 11, 13, 15

OHIO R. CIV. P. 4 ...... 11, 12, 13, 14

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OTHER AUTHORITIES

“The American President,” Aaron Sorkin (1995)...... 1

Admin. R. Mont. 24.210.641 ...... 7

Christine Hauser, “After Neo-Nazi Posting, Police in Whitefish, Mont., Step Up Patrols,” NEW YORK TIMES (Dec. 20, 2016) ...... 8

Joseph Goldstein, “Alt-Right Exults in Donald Trump’s Election with a Salute: ‘Heil Victory’”, NEW YORK TIMES (Nov. 20, 2016) ...... 1

Ohio Gov. Bar R. XII ...... 14

Whitefish City Council Res. No. 14-57 (adopted Dec. 1, 2014) ...... 2

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MEMORANDUM OF POINTS AND AUTHORITIES

“America isn’t easy. America is advanced citizenship. You’ve gotta want it bad, ‘cause it’s gonna put up a fight. It’s gonna say, ‘You want free speech? Let’s see you acknowledge a man whose words make your blood boil, who’s standing center stage and advocating at the top of his lungs that which you would spend a lifetime opposing at the top of yours.’”1

Plaintiff describes Richard Spencer as “an infamous white nationalist.”

Complaint at ¶15. Mr. Spencer has certainly been labeled as such. See Padgett v. Auburn Univ., 2017 U.S. Dist. LEXIS 74076, at *1-2 (M.D. Ala. Apr. 18, 2017)

(“The court takes judicial notice that Richard Spencer is a white nationalist member of the far right who subscribes to what he describes as ‘identitarian’ politics.”) In fact, Mr. Spencer coined the term “alt-right.” Joseph Goldstein,

“Alt-Right Exults in Donald Trump’s Election with a Salute: ‘Heil Victory’”,

NEW YORK TIMES (Nov. 20, 2016). Following the election of President Trump, Mr. Spencer received national attention for a speech in which he stated “Hail

Trump! Hail our people! Hail victory!”. Id. and Complaint at ¶15.

Spencer’s mother lives in Whitefish, Montana – where Plaintiff, Tanya

Gersh lives and has a real estate practice. Because of Spencer’s notoriety, Gersh, injected herself into a public dispute involving Spencer’s mother. Mrs. Spencer claimed, publicly, that Gersh sought to drive her out of her home and business because of Richard. See Exhibit 1.

1 “The American President,” Aaron Sorkin (1995). - 1 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 11 of 44

Plaintiff is affiliated with the Whitefish, Montana organization “Love Lives

Here.” See id. That organization has fought Richard Spencer for years. See

Whitefish City Council Res. No. 14-57 (adopted Dec. 1, 2014); Complaint at ¶¶52-

53. Plaintiff does not deny that she attempted to convince Ms. Spencer to sell her property and issue a public statement denouncing her son. Complaint at ¶21.

Defendant Andrew Anglin is alleged to be the publisher of the Daily

Stormer – a white nationalist website. Complaint at ¶¶ 3 & 9. “White

Nationalism” is irrelevant to these proceedings as its the only purpose to use that term is inflammatory. The First Amendment is blind to viewpoint. Accordingly, the Court should only consider that Mr. Anglin is the publisher of a news website.

In that role, Anglin looked at the public dispute between Gersh and Mrs. Spencer and took an editorial position. This position was “It is clear and obvious extortion.” See Exhibit 2.

Mr. Anglin had every right to do so. If a local business were polluting the environment, any editor could to rally his readers to write to that business in protest. See, e.g., NAACP v. Claiborne Hardware Co., 458 U.S. 886, 909 (1982);

N.Y. Times Co. v. Sullivan, 376 U.S. 254, 266 (1964). If a local business were discriminating against black customers, the NAACP can exhort its members to send correspondence to it. See NAACP v. Claiborne Hardware Co., supra. And, conversely, the KKK can ask its members to send letters of protest to an establishment that treated all races equally. See Brandenburg v. Ohio, 395 U.S.

444 (1969).

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“In order to promote open and informed discussion of public affairs, the

First Amendment seeks to ‘protect unpopular individuals from retaliation – and their ideas from suppression--at the hand of an intolerant society.’” Mont.

Chamber of Commerce v. Argenbright, 28 F. Supp. 2d 593, 600 (D. Mont. 1998) quoting McIntyre v. Ohio Elections Comm’n, 514 U.S. 334 (1995). Every word uttered by Mr. Anglin in this public dispute is protected by the First Amendment, no matter how many people find those views intolerable. See Boy Scouts of Am. v.

Dale, 530 U.S. 640, 660 (2000) (“[T]he fact that an idea may be embraced and advocated by increasing numbers of people is all the more reason to protect the

First Amendment rights of those who wish to voice a different view.”) Thus,

Defendant moves to dismiss Plaintiff’s Complaint pursuant to Fed. R. Civ. P. 12(b)(1), (2), (5), & (6) for lack of subject matter jurisdiction, lack of personal jurisdiction, insufficient process, and failure to state a claim.

1.0 Legal Standard Under Federal Rule of Civil Procedure 12(b)(2), “the plaintiff bears the burden of demonstrating that [personal] jurisdiction is appropriate.”

Schwarzenegger v. Fred Martin Motor Co., 374 F.3d 797, 800 (9th Cir. 2004) citing Sher v. Johnson, 911 F.2d 1357, 1361 (9th Cir. 1990). “Before a federal court may exercise personal jurisdiction over a defendant, the procedural requirement of service of summons must be satisfied.” Omni Capital Int’l v.

Rudolf Wolff & Co., 484 U.S. 97, 104 (1987); see also Strong v. Countrywide

Home Loans, Inc., 2017 U.S. App. LEXIS 15559, at *4 (9th Cir. Aug. 17, 2017)

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citing Miss. Publ’g Corp. v. Murphree, 326 U.S. 438, 444-445 (1946) (“[S]ervice of summons is the procedure by which a court … asserts jurisdiction over the person of the party served.”). A federal court lacks personal jurisdiction over a defendant if service of process is insufficient. See Omni Capital Int’l, supra.

Thus, under Fed. R. Civ. P. 12(b)(5), “[o]nce service is challenged, plaintiffs bear the burden of establishing that service was valid under Rule 4.” Brockmeyer v.

May, 383 F.3d 798, 801 (9th Cir. 2004). “If the plaintiff is unable to satisfy this burden, the Court has the discretion to either dismiss the action or retain the action and quash the service of process.” Stevens v. Sec. Pac. Nat’l Bank, 538 F.2d 1387,

1389 (9th Cir. 1976). “The court may consider evidence outside the pleadings in resolving a Rule 12(b)(5) motion.” Fairbank v. Underwood, 986 F. Supp. 2d 1222, 1228 (D. Or. 2013). Plaintiff failed to effect proper service and the matter must be dismissed for insufficient process and want of personal jurisdiction.

The Complaint otherwise fails to state a claim. “In order to survive a Rule 12(b)(6) motion to dismiss for failure to state a claim, a complaint must ‘contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.’” Cardan v. N.Y. Life Ins. Co., 2016 U.S. Dist. LEXIS 140731, at *5

(D. Mont. Oct. 11, 2016) quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

Further, “if a complaint specifically refers to a document whose authenticity is not questioned by the parties, a court may consider the document when ruling on the motion.” Stamey v. Howell, 2016 U.S. Dist. LEXIS 169318, at *1 (D. Mont. Dec.

7, 2016) citing Branch v. Tunnell, 14 F.3d 449, 454 (9th Cir. 1994). Even in the

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light most favorable to Plaintiff, none of the allegations in the Complaint survive

First Amendment scrutiny or are otherwise sufficient.

2.0 Factual Background

Assuming Ms. Gersh’s recitation is true,2 Plaintiff seeks to hold Mr. Anglin accountable for the speech of third parties. Following the 2016 presidential election, Richard Spencer gave a speech lauding the results. Dkt. No. 1 at ¶¶15-16

& 45. Mr. Spencer’s mother, Sherry Spencer, is a resident of Whitefish, Montana.

Id. at ¶¶15 & 42. Following the speech, members of the Whitefish community planned a protest outside his mother’s property on Lupfer Avenue. Id. at ¶¶17, 46-

48, & 56.

Plaintiff voluntarily participated in the planning meeting to protest and boycott Mrs. Spencer’s tenants’ businesses. Id. at ¶¶56-58. Then, Plaintiff voluntarily contacted Mrs. Spencer’s tenants to “warn them” of the impending protest.3 Id. at ¶¶18 & 58-59. Thereupon, Plaintiff voluntarily agreed to participate in a direct call with Mrs. Spencer. Id. at ¶¶19-20 & 59-60. Plaintiff recommended that Mrs. Spencer “sell the building, make a donation [of the proceeds], and issue a statement disavowing her son’s views.” Id. at ¶21. Plaintiff then alleges she agreed to act as Mrs. Spencer’s real estate agent to sell the building. Id. at ¶¶22 & 62-67. A few weeks later, Mrs. Spencer terminated

Plaintiff’s services. Id. at ¶¶23 & 71.

2 The assumption does not include allegations as to Defendant’s alleged residency or domicile under Rule 12(b)(1), (2), or (5). 3 Plaintiff does not state whether the contact was altruistic or to use the tenants to exert financial pressure on Mrs. Spencer. - 5 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 15 of 44

Approximately two weeks after Mrs. Spencer ended her relationship with

Plaintiff, Mrs. Spencer published an article on the Medium.com blog website describing what happened. Id. at ¶¶ 25 & 74; see also Exhibit 1. Mrs. Spencer wrote: I had no intention of selling . . . until I started receiving terrible threats in the last couple of weeks. These threats came from Tanya Gersh, a local realtor with links to “human rights” organizations Love Lives Here and the Montana Human Rights Network. On November 22, Gersh and I spoke on the phone. She relayed to me that if I did not sell my building, 200 protesters and national media would show up outside — which would drive down the property value — until I complied. Gersh’s other conditions included that I make a public denunciation of my son in a statement written by the Montana Human Rights Network and that I make a donation to this organization from the sale of the property. As Gersh announced on Facebook, she was “spear heading” the campaign. Gersh followed up on her conditions in a number of emails, which I’ve just made public. She even shamelessly suggested that she act as my realtor! In other words, she and the local “human rights” organizations appeared to seek financial benefit from threats of protests and reputation damage. Exhibit 1, and Complaint at ¶¶76-79. As part of her article, Mrs. Spencer published communications, primarily from Ms. Gersh. Exhibit 2.

Mr. Anglin republished Mrs. Spencer’s claims and “call[ed] for a troll storm against” Plaintiff, as the first of thirty articles disapproving Plaintiff’s actions.

Complaint at ¶¶26-27. Mr. Anglin characterized Plaintiff’s actions as extortionate.

Id. at ¶82; see also Exhibit 2. Gersh alleges that the “troll storm” was an invitation for readers to protest Ms. Gersh directly and through her family. Complaint at

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¶¶83-86, 88-89, 91. This is analogous to how the Whitefish residents protested against Mr. Spencer by targeting his mother.

Thereafter, Plaintiff and her family allegedly received hundreds of communications from third parties. Id. at ¶93-124. None of them mentioned

Defendant or his publication,4 though one was directly from Mr. Spencer. Id.

The following day, Defendant published a second article again accusing

Ms. Gersh of extorting Mrs. Spencer. Id. at ¶125; see also Exhibit 4. In it,

Defendant encouraged readers to place calls and send e-mails. Complaint at ¶128. Plaintiff does not allege any reader specifically acted in response thereto.

On December 19, 2016, Mr. Anglin published a third article asking readers to contact Ms. Gersh. Id. at ¶ 130; see also Exhibit 5. Defendant specifically disclaims calling for threats or harassment, but rather for a “campaign of making our voices heard,” which is why he states he purposefully left out home addresses.5

Exhibit 5. No specific response from Defendant’s readers is alleged.

On December 21, 2016, Mr. Anglin encouraged lawful confrontation.

Complaint at ¶¶132-133; see also Exhibit 6. He published a second article that day regarding what he believed to be Ms. Gersh’s unethical practices.6 Complaint at

4 Although Plaintiff uses the expression “[a]s a result of Mr. Anglin’s troll storm,” see, e.g., Complaint at ¶¶110-111, no facts suggest causation. 5 Plaintiff’s contact information was publicly available, as at least one person is alleged to have sent information to her home, despite such address being withheld by Mr. Anglin. See Complaint at ¶105. Plaintiff does not actually claim any of the third parties specifically obtained her contact information from Defendant. 6 As a real estate agent, Ms. Gersh violated her professional obligations to Mrs. Spencer. First, Plaintiff failed to abide Mont. Code Ann. §37-51-313(2)(a), to - 7 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 17 of 44

¶¶134 & 137; see also Exhibit 7. In it, Mr. Anglin encourages the same communications that Ms. Gersh’s supporters encourage, the only difference being the content thereof. See Exhibit 7. He also relayed a New York Times report that the Whitefish Police Department found none of the alleged communications from the third-parties constituted a true threat. See id. quoting Christine Hauser, “After

Neo-Nazi Posting, Police in Whitefish, Mont., Step Up Patrols,” NEW YORK TIMES

(Dec. 20, 2016). No specific response from Defendant’s readers as to either article is alleged. On December 22, 2016, Mr. Anglin encouraged calls and e-mails without threats or suggestions of violence. Complaint at ¶¶138-140; see also Exhibit 8.

He also outlined plans for a lawful protest.7 Complaint at ¶141 and Exhibit 8. No specific response from Defendant’s readers is alleged.

On December 23, 2016, Mr. Anglin reported that an organization with which

Ms. Gersh was affiliated appeared to have repudiated her. Complaint at ¶144; see also Exhibit 9. Again, Defendant allegedly asked readers to contact people by telephone, email, or social media. Complaint at ¶145. That same day, Mr. Anglin expressed schadenfreude regarding a motor vehicle accident, without encouraging

“act solely in the best interests of the seller”, where she was coercing Mrs. Spencer to not only sell the property, but disgorge the proceeds of that sale. Second, in the same way, she failed to “comply with the generally accepted standards of practice.” Admin. R. Mont. 24.210.641(1); see also Mont Code Ann. §31-1- 316(18). This includes Code of Ethics of the National Association of Realtors Art. 1 (“to protect and promote the interests of their client”). 7 Although Ms. Gersh also claims to have received a threatening e-mail from an “AA,” there is no allegation that it came from Defendant. Complaint at ¶142. - 8 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 18 of 44

violence. Id. at ¶¶147-148; see also Exhibit 10. Additionally, another article, bearing the byline of a different author, referenced using Mrs. Spencer to influence her son. Complaint at ¶¶147 & 149; see also Exhibit 11. No specific response from Defendant’s readers is alleged as to any of these articles.

On December 27, 2016, Mr. Anglin recounted his belief on the David Duke

Show that Ms. Gersh extorted Mrs. Spencer.8 Complaint at ¶¶155-156; see also

Exhibit 12. The following day, Mr. Anglin again addressed Ms. Gersh’s conduct, finding it so offensive as to liken it to that of a terrorist group. Complaint at ¶¶157-158; see also Exhibit 13. No specific response from Defendant’s readers is alleged as to either article or the radio show.

The following week, on January 5, 2017, Mr. Anglin described plans for a lawful protest. Complaint at ¶¶159-165; see also Exhibit 14. The protest was not to confront Ms. Gersh. Complaint at ¶161. No specific response from Defendant’s readers is alleged. On January 6, 2017, a different author published a “year in review,” mentioning Ms. Gersh. Complaint at ¶166; see also Exhibit 15. On January 8,

2017, a different author also criticized attacks on Mrs. Spencer. Complaint at

¶169-170; see also Exhibit 16. No specific response from Defendant’s readers is alleged.

8 Plaintiff also alleges encouragement to listen to Mr. Spencer’s appearance on the David Duke Show in which they discuss his mother and Ms. Gersh. Complaint at ¶¶150-154. No specific response from Defendant’s readers is alleged. - 9 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 19 of 44

On January 8, 2017, Mr. Anglin condemned potential governmental interference with the planned protest march based on viewpoint discrimination.

Complaint at ¶171; see also Exhibit 17. Mr. Anglin specifically insisted that it be lawful and peaceful. Complaint at ¶175 and Exhibit 17. No specific response from Defendant’s readers is alleged.

On January 10, 2017, David Duke linked to an interview he had with

Mr. Spencer. Complaint at ¶¶177-184 and Exhibit 18. Plaintiff makes no allegation Mr. Anglin contributed to the interview, only that Mr. Duke and Mr. Spencer also characterized her actions as extortionate. Complaint at ¶¶177-184.

Also, on January 10, 2017, Mr. Anglin complained of what he claimed to be viewpoint discrimination by the City of Whitefish precluding the issuance of the permit for the march. Complaint at ¶¶185-187; see also Exhibit 19. The following day, Mr. Anglin announced the march would be postponed because Whitefish did not issue the permit. Complaint at ¶188; see also Exhibit 20. No specific response from Defendant’s readers is alleged regarding those publications.

On January 18, 2017, a different author reported on supporters of Ms. Gersh coming out in her support on the day the protest march was to have occurred.9

Complaint at ¶¶189-190; see also Exhibit 21. The following day, Mr. Anglin decried an effort to have his publication classified as a terrorist group. Complaint at ¶191; see also Exhibit 22. Although the article states “Hitler was right,” it also calls the Holocaust a hoax and disclaims making any threat. Complaint at ¶¶193-

9 Although Plaintiff credits the article to Mr. Anglin, the byline belongs to Eric Striker. Compare Complaint at ¶189 with Exhibit 21. - 10 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 20 of 44

197 and Exhibit 22. Later that day, Mr. Anglin discussed the merits of peaceful protest. Complaint at ¶198; see also Exhibit 23. A third article of January 19,

2017, by a different author, again spoke out against Ms. Gersh’s extortion of Mrs.

Spencer. Complaint at ¶¶199-200; see also Exhibit 24. No specific response from

Defendant’s readers is alleged regarding those publications.

Finally, in an editor’s note on a February 3, 2017 article, Mr. Anglin deplored the failure of the ACLU to help him obtain a permit. Complaint at ¶¶201-

202; see also Exhibit 25. There is no allegation there was any response from his readers to this publication. Complaint at ¶¶142 & 202-203.

3.0 Plaintiff’s Attempts at Service of Process

On April 18, 2017, Plaintiff filed a Complaint for Invasion of Privacy, Intentional Infliction of Emotional Distress, and Violations of the Anti-

Intimidation Act. 10 (Dkt. No. 1). A Summons and a Preliminary Pretrial

Conference Order were issued. (Dkt. Nos. 2 & 6). Nearly three months later, on July 7, 2017, Plaintiff filed a Motion for

Extension of Time to Effect Service and to Vacate Order Setting Preliminary

Pretrial Conference. (Dkt. No. 13). Plaintiff averred her failure to serve Defendant pursuant to Fed. R. Civ. P. 4(e)(2). (Dkt. No. 13 at p. 3, and Dkt. No. 13-2).

10 Plaintiff also makes a fourth claim for “malice” under Mont. Code Ann. §27-1-221. That is not an independent cause of action, but a measure of damages. See Peschel v. City of Missoula, No. CV-08-79-M-RFC, 2009 U.S. Dist. LEXIS 14442, at *3 (D. Mont. Jan. 5, 2009), adopting 2008 U.S. Dist. LEXIS 98651, at *45 (D. Mont. Dec. 5, 2008); Haines Pipeline Constr. v. Mont. Power Co., 251 Mont. 422, 434, 830 P.2d 1230, 1238 (1991). - 11 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 21 of 44

Thus, she wished to try to serve Defendant under Fed. R. Civ. P. 4(e)(1), following state procedures. (Dkt. No. 13 at pp. 3-4 and Dkt. No. 13-1). She sought an additional 60 days to serve, due to the timing requirements of Ohio R. Civ. P.

4.4(A)(1). (Dkt. No. 13 at p. 6). On July 10, 2017, the Court allowed the motion, setting a deadline of September 15, 2017. (Dkt. No. 14).

The day service was due, Plaintiff filed a second motion for extension of time. (Dkt. No. 15). However, she did not correctly attempt service under Ohio procedures in a timely manner. Id. at p. 3. On September 18, 2017, the Court allowed a second extension to October 27, 2017. (Dkt. No. 17). On October 27,

2017, Plaintiff informed the Court that errors in the publication necessitated completion of the process on November 9, 2017, but no third extension was sought. (Dkt. No. 19)

4.0 Analysis

4.1 Plaintiff Failed to Serve Defendant, Timely or Otherwise Plaintiff failed to make diligent efforts to serve Defendant. According to a review of the online docket in Tanya Gersh v. Andrew Anglin, Case No. 17-MS-

000343 (Franklin Cty., Oh., Comm. Pleas.), it appears that service by certified mail, per Ohio R. Civ. P. 4.1(A)(1)(a), was requested by Plaintiff’s counsel on May

18, 2017, issued on May 19, 2017, and deemed to have failed between June 6 &

14, 2017. See Exhibit 26. Thereupon, on July 6, 2017, just one day before her motion filed in this Court, Plaintiff’s counsel filed a request for service by ordinary

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mail, per Ohio R. Civ. P. 4.6(D).11 See id. The service was issued on July 7, 2017, and it was deemed to have failed between July 26, 2017 and August 21, 2017. See id.

Under Ohio R. Civ. P. 4.4(A)(1), service is complete “at the date of the last publication” following six successive weeks. Plaintiff knew this when she filed her motion and she specifically anticipated utilizing this process. (Dkt. No. 13 at p. 6; Dkt. No. 13-1 at ¶15). Thus, Plaintiff was required to ensure publication began by August 11, 2017. Yet, Plaintiff did not even request it until two weeks thereafter. See Exhibit 26. As a result, Plaintiff cannot be deemed to have been diligent and the service, to the extent it is valid, is untimely under this Court’s

Order. Neither is there any justification for the completion of the alleged service on November 9, rather than by this Court’s October 26, 2017 deadline. Thus, the action must be dismissed.

Beyond lack of diligence and untimeliness, the purported service by publication under Ohio R. Civ. P. 4.4(A)(1) and Fed. R. Civ. P. 4(e)(1) was ineffective and insufficient. As Defendant was not served, this Court lacks personal jurisdiction over him.

First, under Rule 4(e)(1) Plaintiff may only serve Defendant in a judicial district of the United States under the state law in “courts of general jurisdiction” where the district is located. Fed. R. Civ. P. 4(e)(1). It is axiomatic that those state courts must have personal jurisdiction over the defendant. Plaintiff alleges that

11 Counsel for Plaintiff stated it was requested on June 27, 2017 (Dkt. No. 13-1 at ¶11), but it was not filed until 9 days later. - 13 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 23 of 44

“Defendant Andrew Anglin is a resident of Ohio.” Complaint at ¶39. He is not and Plaintiff cannot prove as much. In fact, Plaintiff’s counsel admitted that

“Defendant Anglin’s residence is unknown.” Dkt. No. 13-1 at ¶7. Thus, the alleged service in Ohio was ineffective.

There are no allegations in the Complaint that Plaintiff took any action in the state of Ohio, thus there is no specific jurisdiction under the Ohio long-arm statute,

Ohio Rev. Code Ann. § 2307.382.12 Further, unlike many states, “Ohio law does not appear to recognize general jurisdiction over non-resident defendant.” Conn v. Zakharov, 667 F.3d 705, 717 (6th Cir. 2012). As a result, no matter what contacts

Mr. Anglin has with Ohio, he is not subject to the general jurisdiction of the courts therein. Thus, service in Ohio does not comport with Rule 4(e)(1) and this matter should be dismissed for insufficient service.13

Second, the purported service was unlawfully procured, rendering it a nullity, leaving this Court without personal jurisdiction over Defendant. Plaintiff’s counsel, Mr. Dinielli, is the one who made the service requests. Mr. Dinielli is not admitted to practice law in Ohio, and the Ohio docket identifies him as an out of state attorney. See Exhibit 26. Under Ohio Gov. Bar R. XII – Pro Hac Vice

Admission, out of state attorneys must seek permission to practice pro hac vice in a

12 Notably, the Ohio long-arm statute is not extended to the limits of due process. See Goldstein v. Christiansen, 70 Ohio St. 3d 232, 238 n. 1, 638 N.E.2d 541, 545 (1994). 13 In fact, because Defendant is not a resident of Ohio, he should have been served under Rule 4(f), not Rule 4(e)(1). See Williams v. Moody, 1999 U.S. Dist. LEXIS 527, at *3 (E.D. Pa. Jan. 22, 1999). - 14 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 24 of 44

“proceeding.” See Ohio Gov. Bar R. XII at § 2(A). A “proceeding” is an

“adjudicative matter pending before a tribunal,” which includes a “court.” Id. at

§ 1. Although service by certified or ordinary mail may be ministerial—the clerk issues and serves the summons upon request—service by publication is not.

Service by publication only can occur upon the filing of an affidavit. Ohio R. Civ.

P. 4.4(A)(1). The determination by a public official as to whether an affidavit is sufficient is a judicial, not ministerial function. See State ex rel. Copeland v. State

Med. Bd., 107 Ohio St. 20, 140 N.E. 660 (1923). Thus, the judges of Ohio will issue orders for service by publications. See, e.g., Argent Mortg. Co. v. Sellers,

2010 Ohio Misc. LEXIS 15636 (Ohio Ct. Com. Pl. Nov. 10, 2010). Moreover,

“the preparation and filing of a pleading in court is an act of advocacy which must be undertaken by an attorney admitted to the bar and licensed to practice law in this state.” Washington County Dep’t of Human Servs. v. Rutter, 100 Ohio App.3d

32, 36, 651 N.E.2d 1360 (4th Dist.1995). Thus, Plaintiff’s counsel could not act without first moving to appear pro hac vice.

The request for service by publication was invalid and the purported service by publication is a legal nullity. See State ex rel. Hadley v. Pike, 2014-Ohio-3310,

¶¶16-17 (Ohio Ct. App. 2014) (pleading by unlicensed out-of-state attorney deemed “void ab initio”). Plaintiff did not follow state law for serving a summons in Ohio, as required by Fed. R. Civ. P. 4(e)(1). Service was not accomplished, this

Court lacks jurisdiction over Defendant, and the Complaint must be dismissed.

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4.2 This Court lacks Subject Matter Jurisdiction over the Action

Plaintiff alleges subject matter jurisdiction under 28 U.S.C. § 1332, claiming diversity of citizenship. See Complaint at ¶32. Although Plaintiff did not specify which subsection is invoked, the later allegation that Defendant is a “resident of

Ohio” implicates 28 U.S.C. § 1332(a)(1), for actions involving “citizens of different States.” See Complaint at ¶39. Mr. Anglin, however, is not a citizen of the State of Ohio; Plaintiff does not have any basis to suggest as much. See Dkt.

No. 13-1 at ¶7 (“Defendant Anglin’s residence is unknown.”) In Brimm v. Genao-Gomez, this Court observed that “[a] United States citizen who is domiciled abroad is ‘stateless’ for purposes of subject matter jurisdiction and cannot sue or be sued in federal court based on diversity jurisdiction.” 2014 U.S. Dist. LEXIS 152574, at *2 (D. Mont. Oct. 28, 2014)

(Christensen, U.S.D.J.) citing Newman-Green, Inc. v. Alfonzo-Larrain, 490 U.S.

826, 828 (1989). This is because “[t]o be a citizen of a state within the meaning of Title 28 U.S.C. § 1332, a person must be domiciled within the state.” Id. at *3 citing Lew v. Moss, 797 F.2d 747, 749 (9th Cir. 1986). Plaintiff bears the burden of proof in establishing Defendant’s domicile.14 Id.

“An individual’s domicile is the ‘location where he or she has established a fixed habitation or abode in a particular place, and [intends] to remain there permanently or indefinitely.’ Courts evaluate domicile ‘in terms of objective facts,

14 Merely alleging residency is not sufficient to allege citizenship for diversity purposes. See Realty Holding Co. v. Donaldson, 268 U.S. 398, 399 (1925). - 16 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 26 of 44

and statements of intent are entitled to little weight when in conflict with facts.’”15

Id. quoting Lew, supra at 749-750 (internal quotation marks and citations omitted).

Plaintiff participated in a CNN report that highlighted Defendant stating that “he now lives in Lagos, Nigeria.” See Exhibit 27. As Defendant is not a citizen of any

State, this Court lacks subject matter jurisdiction.

4.3 Plaintiff Failed to State a Claim Overriding Defendant’s Constitutionally Protected Speech Notwithstanding this Court’s lack of personal and subject matter jurisdiction, the Plaintiff fails to state a claim. Plaintiff makes claims for invasion of privacy, intentional infliction of emotional distress, and statutory intimidation based on Defendant’s alleged speech. This speech was made on a website to spur others to express their opinions to Plaintiff and her associates, i.e. to contribute more speech to the marketplace of ideas. It did not command compliance. It did not tell the third parties what to say. And none of the statements of the third parties to Plaintiff or her associates are alleged to have been directed by or

15 In Weible v. United States, 244 F.2d 158, 163 (9th Cir. 1957), the Ninth Circuit quoted, with approval, In re Estate of NEWCOMB, 192 N.Y. 238, 250, 84 N.E. 950, 954 (1908), which explained: ‘Residence’ means living in a particular locality, but ‘domicile’ means living in the locality with intent to make it a fixed and permanent home. ‘Residence’ simply requires bodily presence as an inhabitant in a given place, while ‘domicile’ requires bodily presence in that place, and also an intention to make it one’s domicile. Plaintiff cannot show Defendant’s intent to make Ohio his domicile, let alone living or having bodily presence in Ohio necessary to establish residency. - 17 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 27 of 44

otherwise proximately caused by Defendant. Such a complaint cannot pass constitutional muster.

Defendant’s speech does not fall into any category speech of unprotected under the First Amendment. As set forth by the Ninth Circuit Court of Appeals: if speech does not squarely fall within a category of unprotected speech, … the court checks whether the speech falls within any unprotected category and, if so, confines the perimeters of the unprotected category within acceptably narrow limits in an effort to ensure that protected expression will not be inhibited. Shoemaker v. Taylor, 730 F.3d 778, 787 (9th Cir. 2013) (internal citations and quotation marks omitted). “Content-based restrictions on speech have been permitted only for a few historic categories of speech, including incitement, obscenity, defamation, speech integral to criminal conduct, so-called ‘fighting words,’ child pornography, fraud, true threats, and speech presenting some grave and imminent threat the Government has the power to prevent.” United States v.

Alvarez, 567 U.S. 709, 709 (2012). Defendant’s alleged speech does not fit into any of those historic categories. Plaintiff may attempt to shoehorn the speech as incitement, fighting words, or true threats, but such attempts fail.

4.3.1 The Articles are Not Fighting Words

Defendant’s speech does not constitute fighting words. “To characterize speech as actionable ‘fighting words,’ the [plaintiff] must prove that there exist ‘a likelihood that the person addressed would make an immediate violent response.’”

(emphasis added) United States v. Poocha, 259 F.3d 1077, 1080-81 (9th Cir. 2001) quoting Gooding v. Wilson, 405 U.S. 518, 528 (1972). Here, Defendant is not

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alleged to be addressing Plaintiff, but rather addressing third parties. There is no likelihood that Ms. Gersh would make an immediate violent response to

Mr. Anglin, far away, typing on a computer. Accord State v. Dugan, 2013 MT 38,

¶43, 369 Mont. 39, 54, 303 P.3d 755, 767 (2013) (“Words spoken over the telephone are not proscribable under the ‘fighting words’ doctrine because the person listening on the other end of the line is unable to react with imminent violence against the caller.”) Even the speech of the third parties to Ms. Gersh, no matter how offensive, would not provoke an immediate violent response, as all of it was remote, i.e., by telephone, e-mail, and social media.

4.3.2 The Articles are Not True Threats

As determined by law enforcement, Defendant’s speech does not constitute a true threat and Plaintiff does not allege as much. “‘True threats’ encompass those statements where the speaker means to communicate a serious expression of an intent to commit an act of unlawful violence to a particular individual or group of individuals.” Virginia v. Black, 538 U.S. 343, 359 (2003). “A true threat [is] where a reasonable person would foresee that the listener will believe he will be subjected to physical violence upon his person[.]” United States v. Orozco-

Santillan, 903 F.2d 1262, 1265-66 (9th Cir. 1990). None of Defendant’s statements involve an expression, serious or otherwise, of an intent to commit an act of violence. Instead, they all expressly disclaim violence and direct his readers against actual or threatened violence. Political hyperbole is not a true threat. See

Watts v. United States, 394 U.S. 705, 708 (1969) (reversing conviction for

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statement regarding shooting President Johnson if drafted). The third parties’ statements are generally recognized anti-Semitic tropes, without actual harm reasonably to be construed. And, even Nazi expression, no matter the psychic harm on Jewish residents, is nonetheless protected speech. See Collin v. Smith,

578 F.2d 1197, 1205-06 (7th Cir. 1978) (permitting Nazi march on Village of

Skokie). Thus, there was no true threat.

4.3.3 The Articles are Not Incitement

Finally, there is no incitement. “Nothing should be clearer at this stage in the development of first amendment jurisprudence than ‘the principle that the constitutional guarantees of free speech and free press do not permit a State to forbid or proscribe advocacy … of law violation except where such advocacy is directed to inciting or producing imminent lawless action and is likely to incite or produce such action.’” United States v. Dahlstrom, 713 F.2d 1423, 1428 (9th Cir.

1983) quoting Brandenburg v. Ohio, 395 U.S. 444, 447 (1969) (per curiam). As Plaintiff concedes, Defendant specifically implored his readers away from violence, stating: AND AS ALWAYS: ABSOLUTELY NO THREATS OF VIOLENCE, SUGGESTIONS OF VIOLENCE OR ACTS OF VIOLENCE. DON’T DO IT. Complaint at ¶140. Even assuming arguendo that the communications to Ms.

Gersh from the third parties was somehow unlawful, merely giving instruction to an audience as to how to violate the law does not constitute incitement. See

Dahlstrom, supra (instruction as to setting up illegal tax shelter was not

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incitement). As a result, Defendant’s speech does not fit into any historic category of unprotected speech.

4.3.4 No New Category of Unprotected Speech Should be Created The speech at issue is very unpopular, and thus there is an allure to seeking a way to prohibit it. This court should not create a new category of unprotected speech.16 In overturning the Ninth Circuit’s decision that the Stolen Valor Act could constitutionally prohibit false speech, the Supreme Court observed:

While there may exist some categories of speech that have been historically unprotected, but that the Court has not yet specifically identified or discussed, the Government has not demonstrated that false statements should constitute a new category. Alvarez, 567 U.S. at 710 (internal citation and quotation marks omitted). Neither should speech to third parties asking them to make politically motivated speech to another be another new category. If such a new category were created, what hope would there be for any advocacy by any organization? In fact, the Southern

Poverty Law Center, the very organization driving this litigation, would likely be one of the first victims of any such restriction on freedom of expression.17

16 Although many of the cases addressing Freedom of Speech arise in the criminal context, “civil actions … must be limited to the same extent that a state would be limited in imposing criminal sanctions, because ‘fear of damage awards … may be markedly more inhibiting than the fear of prosecution under a criminal statute.’” Sierra Club v. Butz, 349 F. Supp. 934, 937 (N.D. Cal. 1972) quoting New York Times Co., 376 U.S. at 277, 84 S. Ct. at 724. 17 The undersigned attorneys as well as their client would be just as opposed to such a restriction being imposed on the SPLC. - 21 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 31 of 44

The Supreme Court of Montana carved out a new category of unprotected speech, holding “that free speech does not include the right to cause substantial emotional distress by harassment or intimidation.” State v. Cooney, 271 Mont. 42,

894 P.2d 303, 307 (1995); see also State v. Nye, 283 Mont. 505, 513, 943 P.2d 96,

101 (1997) (“Activities which are intended to embarrass, annoy or harass, as was the case here, are not protected by the First Amendment”). The Montana Supreme

Court was wrong to do so. It is, therefore, unsurprising that no Federal court has agreed. This Court should not be the first. In fact, the Ninth Circuit has generally repudiated it, stating it “is axiomatic that the government may not silence speech because the ideas it promotes are thought to be offensive.” Rodriguez v. Maricopa

Cty. Cmty. Coll. Dist., 605 F.3d 703, 708 (9th Cir. 2009). Rather, “[t]here is no categorical ‘harassment exception’ to the First Amendment’s free speech clause.”

Id. quoting Saxe v. State Coll. Area Sch. Dist., 240 F.3d 200, 204 (3d Cir. 2001).

Although the Ninth Circuit recognized that a regulation prohibiting “harassment” and “intimidation” might not be overbroad under the First

Amendment, that regulation required that it “threaten[] or endanger the health or safety of another.” O’Brien v. Welty, 818 F.3d 920, 930 (9th Cir. 2016) (internal citation and quotation marks omitted). In contrast, the Montana Anti-Intimidation

Act, as invoked by Plaintiff (Complaint at ¶228), states:

An individual or organization who is attempting to exercise a legally protected right and who is injured, harassed, or aggrieved by a threat or intimidation has a civil cause of action against the person engaging in the threatening or intimidating behavior. Mont. Code Ann. § 27-1-1503(2). This statute is overbroad.

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In contrast to Mont. Code Ann. § 27-1-1503(1), the language at Mont. Code

Ann. § 27-1-1503(1) does not incorporate the definitions of “intimidation” or

“threaten” set forth at Mont. Code Ann. §§ 45-5-203 & 45-7-102 respectively.

“In the First Amendment context, the Supreme Court recognizes a type of facial challenge in which a statute will be invalidated as overbroad if ‘a substantial number of its applications are unconstitutional, judged in relation to the statute's plainly legitimate sweep.’” Puente Ariz. v. Arpaio, 821 F.3d 1098, 1104 (9th Cir.

2016) quoting United States v. Stevens, 559 U.S. 460, 473 (2010). Under the statute, a pizza-delivery person could be liable for “threatening” a consumer that snow might delay dinner; a professor could be liable for “threatening” a midterm; and siblings could sue each other for “threatening” to tattle. In fact, under the plain language of the statute, Mr. Anglin and Ms. Spencer would have claims against

Ms. Gersh. Due to the scope of anyone “aggrieved” being able to make a claim, the statute is facially unconstitutional. As applied, the internet is a public forum; there is no compelling state interest for Montana to regulate what Defendant might say in Ohio or anywhere else, even if it involves a Montanan. See Widmar v. Vincent, 454 U.S. 263, 269-70

(1981) (requiring narrowly drawn regulation with compelling state interest to justify speech restriction in public forum). Unlike the regulation in O’Brien, there is no requirement of a threat to health or safety. And, as set forth above, there is no

“true threat” involved.

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A new category of unprotected speech is ripe for abuse. Defendant’s speech is political. It arose from a political rally in support of President Trump’s election.

Ms. Gersh voluntarily injected herself into national politics. To permit Defendant to be sued for his political speech because it is “harassment” or “intimidation” means that anyone, Democrat, Republican, or independent, whose speech has political support, could be subject to liability. The First Amendment will not abide such a result, nor should it.

4.3.5 Defendant Cannot be Held Liable for the Acts of Third Parties Although all of the third-parties’ speech is itself protected, even if it were not, Defendant cannot be held liable for it. In Montana, “[a] principal is not responsible for other wrongs committed by the principal’s agent … unless the principal has authorized or ratified the acts, even though they are committed while the agent is engaged in the principal’s service.” Mont. Code Ann. § 28-10-602(2).

However, “[a]ctual agents are statutorily defined as persons who are ‘really employed by the principal.’” Butler v. Domin, 2000 MT 312, ¶28, 302 Mont. 452, 459, 15 P.3d 1189, 1194 (2010) quoting Mont. Code Ann. § 28-10-103. There is no allegation Defendant really employs any of the third parties; in fact, none are identified.

To adjudge Defendant liable for the acts of his readers would similarly violate his First Amendment rights. “Civil liability may not be imposed merely because an individual belonged to a group, some members of which committed acts of violence. For liability to be imposed by reason of association alone, it is

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necessary to establish that the group itself possessed unlawful goals and that the individual held a specific intent to further those illegal aims.” NAACP v.

Claiborne Hardware Co., 458 U.S. 886, 920 (1982). There were no unlawful goals and Defendant had no specific intent to further same. Thus, this action must be dismissed as Defendant has no constitutional liability.

4.4 Plaintiff Fails to State a Viable Cause of Action

Even if Plaintiff’s suit were not constitutionally infirm, there is no merit to it and should be dismissed for failure to state a claim. Defendant did not invade her privacy, intentionally inflict emotional distress, or harass her.

4.4.1 Defendant is Not Liable for Invasion of Privacy

Plaintiff’s first count, for Invasion of Privacy, alleges that Defendant posted stories and contact information about Plaintiff, giving them instruction and encouragement, causing harm thereby. Complaint at ¶¶214-216. The Montana

Supreme Court:

has defined the common law cause of action for invasion of privacy as a wrongful intrusion into one’s private activities in such a manner as to outrage or cause mental suffering, shame or humiliation to a person of ordinary sensibilities. Miller v. Great Falls Ath. Club, LLC, 2010 MT 171N, ¶7 (2010) (internal citations and quotation marks omitted). Defendant did not intrude, he did not do anything wrongful, her activities were not private, and he did not proximately cause her alleged suffering.

Instead, he is alleged to have responded to and republished what

Mrs. Spencer originally provided publicly, which included largely information

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Ms. Gersh provided to Mrs. Spencer. This occurred in the context of a very public planned boycott and protest to harass and intimidate Mrs. Spencer into selling her building, rather than simply involving private activity. All of the information

Defendant allegedly published about Ms. Gersh was publicly available. See

Hastetter v. Behan, 196 Mont. 280, 283, 639 P.2d 510, 513 (1982) (“an individual’s right of privacy protects only matters which can reasonably be considered private.”) Her address and phone number, as well as Twitter account,18 were publicly available and the type of information that appears in a phone book or other directory. There is no reasonable expectation of privacy in such information or her communications with Mrs. Spencer.

Neither did such publication directly or proximately caused harm to Ms. Gersh. First, Plaintiff does not allege any specific third party did so because of Mr. Anglin. Second, Mr. Anglin’s publication itself caused no alleged harm; rather, to the extent that any communications caused harm – these communications were third party communications. If, instead of condemnation, Plaintiff took her side and published her contact information to give her love and support, it would be obvious that mere publication of it cannot cause harm.

Plaintiff seeks to hold Defendant liable not for the act of publication, then, but for the speech of third parties. This is not invasion of privacy. Even if it were, they are not his agents. In the absence of an agency relationship, there is no

18 A Twitter account is, in essence, a website link. “[T]here is no privacy interest in a website link. A reasonable individual would not expect that links to a website are private because the Internet is a public forum.” Katzenbach v. Grant, 2005 U.S. Dist. LEXIS 46756, at *54 (E.D. Cal. June 7, 2005). - 26 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 36 of 44

invasion of privacy proximately caused by Defendant. See Koepplin v. Zortman

Mining, 267 Mont. 53, 62, 881 P.2d 1306, 1311-12 (1994). Thus, this count must be dismissed.

4.4.2 Defendant is Not Liable for Intentional Infliction of Emotional Distress In Plaintiff’s second count, she recites the rote elements of a claim for intentional infliction of emotional distress. In Montana:

[a]n independent cause of action for infliction of emotional distress will arise under circumstances where serious or severe emotional distress to the plaintiff was the reasonably foreseeable consequence of the defendant's negligent or intentional act or omission. Sacco v. High Country Indep. Press, 271 Mont. 209, 896 P.2d 411, 429 (1995).

Although Plaintiff claims that “Mr. Anglin could reasonably foresee the consequences of his conduct” (Complaint at ¶221), such is a legal conclusion; nothing in the Complaint otherwise sets forth a factual basis for such foreseeability. Ms. Gersh was involved with planning a boycott and protest of

Mrs. Spencer’s business. Complaint at ¶18. Thus, Ms. Gersh condones collective action to express a political opinion – so long as that political opinion is one that she favors.

In the face of that, there is no reason to foresee Ms. Gersh would not similarly condone others engaged in collective expression. With the exception of the particular words used, there is no difference between her participation in the collective actions against Mrs. Spencer (i.e. protest and boycott) and Mr. Anglin’s participation in the protest against Plaintiff. Both invoked community outrage. It

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is not reasonably foreseeable that she would not condone it when directed at her.

She may not, in retrospect, like that her political speech gave rise to opposing political speech. But, the same First Amendment that protects her ability to organize a protest against Mrs. Spencer gives Mr. Anglin the right to call upon his readers to share their views about it. Presumably, she would not concede Mrs.

Spencer has a foreseeable IIED claim against her. Thus, similarly, the alleged consequences were not reasonably foreseeable by Defendant.

There is no actionable conduct by Defendant. In Montana, “an actor does not engage in outrageous or extreme conduct simply by exercising a legal right….

[A] privileged action cannot become the basis for such a claim” for intentional infliction of emotional distress. Judd v. Burlington N. & Santa Fe Ry., 2008 MT 181, ¶¶30-31, 343 Mont. 416, 423, 186 P.3d 214, 218 (2008). Plaintiff has not pled that Defendant was not exercising his legal rights (nor could she).

Defendant’s conduct was legal—he was engaged in political speech. Notably, “[t]he Free Speech Clause of the First Amendment — ‘Congress shall make no law

… abridging the freedom of speech’— can serve as a defense in state tort suits, including suits for intentional infliction of emotional distress.” Snyder v. Phelps,

562 U.S. 443, 451 (2011) (citation omitted). That the speech is particularly emotionally hurtful and causes anguish does not strip it of First Amendment protection. See id. at 456. Further, as the Ninth Circuit recognizes:

when the definition of a crime or tort embraces any conduct that causes or might cause a certain harm, and the law is applied to speech whose communicative impact causes the relevant harm, we treat the law as content-based. See, e.g., Hustler Magazine v. Falwell, 485 U.S. - 28 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 38 of 44

46, 99 L. Ed. 2d 41, 108 S. Ct. 876 (1988) (holding that “public figures and public officials” must show actual malice to prevail on a state-law tort claim for intentional infliction of emotional distress based on the defendant's speech). United States v. Cassel, 408 F.3d 622, 626 (9th Cir. 2005). Here, Mr. Anglin’s publications were privileged and he acted without actual malice. Having

“voluntarily inject[ed]” herself into the controversy, she is a limited purpose public figure. Gertz v. Robert Welch, 418 U.S. 323, 351 (1974). Although Plaintiff makes a naked assertion of “actual malice” in her Fourth claim, she fails to assert a false statement of fact made with actual malice. Worrell-Payne v. Gannett Co., 49 F. App’x 105, 109 (9th Cir. 2002); accord Mont. Code Ann. § 27-1-221(2). Thus, this claim (and the Fourth claim) must be dismissed.

4.4.3 Defendant did not Harass or Intimidate Plaintiff As discussed above, to state a claim under Mont. Code Ann. § 27-1-1503(2), as is Plaintiff’s third count, Defendant must have “injured, harassed, or aggrieved” her “by a threat or intimidation,” while she is “attempting to exercise a legally protected right.” The only right Plaintiff asserts she “was attempting to exercise” was, ironically, her right to free speech. Complaint at ¶226. Defendant’s actions related to Ms. Gersh’s past speech. The statute, however, does not speak to past exercise, but rather present attempts to exercise rights. The Complaint identifies no rights Ms. Gersh was attempting to exercise when Defendant allegedly harmed her.

Neither did Defendant commit an actionable threat or act of intimidation.

As discussed above, the statute is overbroad, with those terms undefined. But the

- 29 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 39 of 44

claim fails even if the criminal statutory definitions are incorporated, despite their omission. The so-called “troll storm,” the only allegation of conduct under the anti-intimidation act (Complaint at ¶227), is not actionable thereunder. Defendant did not “threaten” Plaintiff within the meaning of Mont. Code Ann. § 45-7-102, to the extent it is incorporated into section 27-1-1503(2). There was no threat of harm; there was no private address to a public servant; and Ms. Gersh was neither a juror nor public servant.

Similarly, under the definition of “intimidation” in Mont. Code Ann. § 45-5- 203, the claim fails. Defendant did not threaten to inflict physical harm, confine or restrain her, or commit a felony, or report a fire, explosion, or disaster. “Mere advocacy of the use of force or violence to accomplish some end also does not constitute a threat under [45-5-203] since that form of expression is protected by the First Amendment. Rather, only serious expressions of an intention to take a hostage, murder, inflict serious injuries on persons or property, or commit a felony, for the purpose of accomplishing some end constitute a threat punishable under the statute.” State v. Lance, 222 Mont. 92, 104, 721 P.2d 1258, 1266-67 (1986)

(internal citations omitted). In this case, there was no advocacy of the use of force or violence at all. However, even if there were, it would not have been actionable.

Just as Plaintiff would not concede she threatened or intimidated Mrs. Spencer,19

19 The only difference between a protest of Mrs. Spencer and a protest of Plaintiff is the viewpoint. However, unlike the statutory and regulatory duties owed by Plaintiff to Mrs. Spencer, Defendant owed Plaintiff no such duties. - 30 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 40 of 44

she cannot claim Defendant threatened or intimidated her. In the absence of an actionable threat or intimidation, this count must be dismissed.

5.0 Conclusion

There is no subject matter jurisdiction because Mr. Anglin is not a citizen of any state for diversity purposes. He is not a resident of Ohio, thus service

(otherwise invalid due to unauthorized practice of law) was ineffective and there is no personal jurisdiction over him. His speech does not fall into any category of unprotected speech and there is no good cause to carve out a new one. Moreover, none of the actual claims are meritorious. He did not invade Plaintiff’s privacy by publishing already public information. He could not reasonably foresee her distress when she involved herself in a public dispute and endorsed collective action. And he neither threatened nor intimidated Plaintiff. Defendant is not liable for any action of any third party, no matter how much the Plaintiff or her counsel wish.20 In light of the foregoing, the Complaint must be dismissed. The messages Ms. Gersh allegedly received were (in the undersigned’s opinion) mean-spirited, nasty, brutish, and uncalled for, and it is easy to feel sympathy for her. But the undersigned’s opinion is nothing more than a commentary on taste – not law. The messages were allegedly received from a highly-disfavored group – neo-Nazis. And this gives some melody to the siren’s song of censorship – after all, who cares about Nazis? But that is not the test under

20 Counsel for Plaintiff, in fact, specifically disclaim liability for the acts of their supporters. See Exhibit 28 (SPLC President distancing the group from its supporter who allegedly shot Congressman Scalise). - 31 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 41 of 44

our Constitution. If we are to reject speech because it comes from an unorthodox group, we do violence to the very underpinnings of our notions of liberty. Nazis are “unorthodox” in America. Yet the rule of law must govern. “If there is any fixed star in our constitutional constellation, it is that no official, high or petty, can prescribe what shall be orthodox in politics, nationalism, religion, or other matters of opinion or force citizens to confess by word or act their faith therein.” West

Virginia State Board of Education v. Barnette, 319 U.S. 624 (1943).

It is easy to wish to sympathize with Ms. Gersh and against self-avowed Nazis. But, “America isn’t easy” rings true – even in this case. The Court must not look to orthodoxy, or a test of taste, nor even (most likely) into its own heart.

The Court must look to the Constitution – and understand that if we chip away at it because we disfavor a speaker, or his speech, then we do not want free speech at all – much less, do we want it bad.

Dated: November 30, 2017. Respectfully submitted, /s/ Marc J. Randazza Marc J. Randazza (pro hac vice) RANDAZZA LEGAL GROUP, PLLC 4035 S. El Capitan Way Las Vegas, Nevada 89147 /s/ Jay M. Wolman Jay M. Wolman (pro hac vice) RANDAZZA LEGAL GROUP, PLLC 100 Pearl Street, 14th Floor Hartford, Connecticut 06103

- 32 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 42 of 44

/s/ Mathew M. Stevenson Mathew M. Stevenson STEVENSON LAW OFFICE 1120 Kensington, Suite B Missoula, MT 59801 Attorneys for Defendant, Andrew Anglin

Case No. 9:17-cv-50-DLC-JCL

CERTIFICATE OF COMPLIANCE

Pursuant to D. Mont. L.R. 7.1(d)(2)(E), undersigned counsel hereby certifies compliance with the said Rule and states that the number of words in this brief, as per the count of Microsoft Word, is 8,667.

/s/ Marc J. Randazza Marc J. Randazza

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on November 30, 2017, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I further certify that a true and correct copy of the foregoing document being served via transmission of Notices of Electronic Filing generated by CM/ECF.

/s/ Marc J. Randazza Marc J. Randazza

- 33 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 43 of 44

INDEX OF EXHIBITS

Exh. Exhibit Description No. 1 Sherry Spencer post on Medium dated Dec. 15, 2016 2 Andrew Anglin post on Daily Stormer dated Dec. 6, 2016 3 Gersh communications published by Sherry Spencer 4 Andrew Anglin post on Daily Stormer dated Dec. 17, 2016 5 Andrew Anglin post on Daily Stormer dated Dec. 19, 2016 6 Eric Striker post on Daily Stormer dated Dec. 21, 2016 7 Andrew Anglin post on Daily Stormer dated Dec. 21, 2016 8 Andrew Anglin post on Daily Stormer dated Dec. 22, 2016 9 Andrew Anglin post on Daily Stormer dated Dec. 23, 2016 10 Andrew Anglin post on Daily Stormer dated Dec. 23, 2016 11 Jez Turner post on Daily Stormer dated Dec. 23, 2016 12 Andrew Anglin post on Daily Stormer dated Dec. 27, 2016 13 Andrew Anglin post on Daily Stormer dated Dec. 28, 2016 14 Andrew Anglin post on Daily Stormer dated Jan 5, 2017 15 Lawrence Murray post on Daily Stormer dated Jan. 6, 2017 16 Ben Richards post on Daily Stormer dated Jan. 8, 2017 17 Andrew Anglin post on Daily Stormer dated Jan. 8, 2017 18 David Duke post on Daily Stormer dated Jan. 10, 2017 19 Andrew Anglin post on Daily Stormer dated Jan. 10, 2017 20 Andrew Anglin post on Daily Stormer dated Jan. 11, 2017 21 Andrew Anglin post on Daily Stormer dated Jan. 18, 2017 22 Andrew Anglin post on Daily Stormer dated Jan. 19, 2017 23 Andrew Anglin post on Daily Stormer dated Jan. 19, 2017 24 Eric Striker post on Daily Stormer dated Jan. 19, 2017 25 Eric Striker post on Daily Stormer dated Feb. 3, 2017

- 34 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32 Filed 11/30/17 Page 44 of 44

Exh. Exhibit Description No. 26 Docket – Franklin County, Ohio – Case No. 17 MS 000343 Mallory Simon and Sara Sidner, “An avalanche of hate: How a 27 Montana mom became the target of a neo-Nazi troll storm”, CNN (Jul. 11, 2017) Richard Cohen, “Attack on GOP Congressman is Assault on 28 Democracy,” SPLC (Jun. 14, 2017) 29 Declaration of Jay M. Wolman

- 35 - Brief in Support of Motion to Dismiss 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32-1 Filed 11/30/17 Page 1 of 6

EXHIBIT 1

Sherry Spencer post on Medium dated Dec. 15, 2016

5/12/2017 Does Love Really Live Here? – Responsible Business Case 9:17-cv-00050-DLC-JCL Document 32-1 Filed 11/30/17 Page 2 of 6

Sherry Spencer Follow Dec 15, 2016 · 3 min read

https://medium.com/@recnepss/does-love-really-live-here-fff159563ba3 1/5 5/12/2017 Does Love Really Live Here? – Responsible Business Case 9:17-cv-00050-DLC-JCL Document 32-1 Filed 11/30/17 Page 3 of 6

https://medium.com/@recnepss/does-love-really-live-here-fff159563ba3 2/5 5/12/2017 Does Love Really Live Here? – Responsible Business Case 9:17-cv-00050-DLC-JCL Document 32-1 Filed 11/30/17 Page 4 of 6

https://medium.com/@recnepss/does-love-really-live-here-fff159563ba3 3/5 5/12/2017 Does Love Really Live Here? – Responsible Business Case 9:17-cv-00050-DLC-JCL Document 32-1 Filed 11/30/17 Page 5 of 6

https://medium.com/@recnepss/does-love-really-live-here-fff159563ba3 4/5 5/12/2017 Does Love Really Live Here? – Responsible Business Case 9:17-cv-00050-DLC-JCL Document 32-1 Filed 11/30/17 Page 6 of 6

https://medium.com/@recnepss/does-love-really-live-here-fff159563ba3 5/5 Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 1 of 12

EXHIBIT 2

Andrew Anglin post on Daily Stormer dated Dec. 6, 2016

Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 2 of 12

Jews Targeting Richard Spencer’s Mother for Harassment and Extortion – TAKE ACTION!

Andrew Anglin Daily Stormer December 16, 2016

Richard Spencer did nothing wrong.

This is the Jews for you, people.

They are a vicious, evil race of hate-filled psychopaths.

When you do something they don’t like, they will use the power of the media to come down on you, assassinate your character. They will call you names and accuse you of all sorts of things. They will go after your money.

If all of that fails, they will attack your mother.

This is a people without shame.

Daily Mail:

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 1 of 11 Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 3 of 12 The mother of white supremacist Richard Spencer claims she is suffering financially due to the backlash against her son’s controversial views.

Sherry Spencer, who lives in Whitefish, Montana, said she is being forced to sell a building she owns in the small town because residents are rebelling against her son.

Richard Spencer shot to prominence last month when footage emerged of him delivering a ‘hateful speech’ at a white nationalist meeting held to celebrate Donald Trump’s election win.

A video by The Atlantic taken inside the Ronald Reagan building showed Spencer, leader of the National Policy Institute, shouting, ‘Hail Trump, hail our people, hail victory!’ as some of the people in attendance lifted their hands in a Nazi salute.

…

The speech drew intense criticism from the US Holocaust Memorial Museum, which said in a statement Spencer made: ‘several direct and indirect references to Jews and other minorities, often alluding to Nazism.’

…

And according to Sherry Spencer, the criticism has been echoed by people in her hometown – where he son also has a business registered and visits regularly.

Sherry Spencer told KTMF she is selling a building she owns at 22 Lupfer Avenue, which she currently sublets. It houses a beauty salon and vacation rentals. She also runs a real estate business from the building.

‘As painful as this is, I am exploring a potential sale of the building,’ she said.

She also took aim at a local human rights group, Love Lives Here, and accused it of damaging her family.

‘We are stunned by the actions of Love Lives Here, an organization claiming to advocate tolerance and equal treatment of all citizens, yet coursing financial harm to many innocent parties,’ she said.

One of the strongest opponents to Sherry is local real estate agent Tanya Gersh, who said Spencer has backed her son and allowed him to spread his views.

‘She is profiting off of the people of the local community, all the while having facilitated Richard’s work spreading hate by letting him live and use her home address for his organization,’ Gersh told the network.

Love Lives Here also responded to Sherry’s remarks, saying it ‘did not know what she (was) talking about’.

‘We don’t cause financial harm to anybody,’ co-founder Ina Albert said, before going on to say the group does not have a specific problem with the Spencers.

‘I don’t know what (Richard) does when he comes here. But that is not our problem with Richard Spencer.

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 2 of 11 Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 4 of 12 ‘It is the National Policy Institute and what that stands for and our town being smeared by his philosophy.’

The National Policy Institute was established in 2005 by Spencer, and it is described by the Southern Poverty Law Center as ‘hate group’.

Gersh went on to call for Sherry to sell the building immediately, and then use the money to help human rights causes.

‘(She) Could address this by selling the building, making a donation to human rights efforts, and making a statement in opposition to white supremacist ideas spread by Richard,’ Gersh said.

A donation, they say.

This is what they do. It is clear and obvious extortion. They are saying “give us money, or we are going to continue this campaign of terror against you and your family.” It couldn’t be any more clear. All of these Jew organizations engage in this transparent extortion racket with impunity.

This is Tanya Gersh:

Tanya Gersh, vice president of Bet Harim, the main Jewish organization in the area, says that the community was “super excited” at the news that Barnett and his friends were coming to celebrate Purim with them. “We don’t have a rabbi and we don’t have a synagogue, but we do have a kosher Torah and we try to get together for all the Jewish holidays,” Gersh says. “We feel that he (Barnett) is a product of this community,” she says. “We’re extremely proud.”

She also posts slut pics on the internet.

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 3 of 11 Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 5 of 12 tanya-gersh

Tanya Gersh

The Jew hate group Love Lives Here is led by Francine Green Roston, a confirmed super-Jew. She is a female Rabbi and a “community activist.”

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 4 of 11 Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 6 of 12 francine-roston

Francine Roston

The organization’s co-founder, Ina Albert, is also an extreme Jew, married to a rabbi.

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 5 of 11 Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 7 of 12 ina-albert-whitefish

Ina Albert

As the Forward tells us in their report on the attacks on Spencer’s mom:

“We certainly don’t want his ideology considered part of the Whitefish community,” said Ina Albert, an 81-year- old activist who describes herself as “very Jewish.” She was raised in Philadelphia and moved to Montana with her husband, the retired rabbi. “This is one of the most beautiful places on earth.”

There are only 6,000 Jews in the entire state of Montana, yet they’re 100% of the people trying to trying to silence Richard Spencer by harassing his mother. So Then – Let’s Hit Em Up Are y’all ready for an old fashioned Troll Storm?

Because AYO – it’s that time, fam.

And as always: NO VIOLENCE OR THREATS OF VIOLENCE OR ANYTHING EVEN CLOSE TO THAT.

Just make your opinions known. Tell them you are sickened by their Jew agenda to attack and harm the

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 6 of 11 Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 8 of 12

mother of someone whom they disagree with.

First things first: the Jew terrorist group Love Lives Here.

Please call them

Phone: 406-309-5678 (international callers add 001 to the beginning)

They also have a form you can fill with your complaints.

Ina Albert has an Amazon page.

Twitter: @inaalbert

Email: [email protected]

Phone: 406-863-2333 (international callers add 001 to the beginning)

We also have some contact information for her husband, Rabbi Allen Secher – who goes by Pizzagatey handle “The Naked Rabbi.”

Email: [email protected]

Twitter: @thenakedrabbi

Next: Tanya Gersh

Please call her and tell her what you think. And hey – if you’re in the area, maybe you should stop by and tell her in person what you think of her actions,.

Address: 121 Wisconsin Ave, Whitefish, MT 59937

Phone: (406) 261-4830 (international callers add 001 to the beginning)

You can also leave a review of her business on Google, and perhaps note that it is front for an extortion racket.

Her Twitter (@gershtanya) doesn’t appear to be active – but her son has active accounts. You can hit him up, tell them what you think of his whore mother’s vicious attack on the community of Whitefish.

Jacob Gersh’s twitter: @Jacob135Gersh

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 7 of 11 Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 9 of 12 _wy6qjgi

Jacob Gersh – what a creepy little faggot!

The scamming little kike has 12 followers – presumably all “friends” that he knows IRL – and he’s pushing advertising scams on them!

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 8 of 11 Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 10 of 12

Jews: they are definitely born this way.

Her Jew husband, Judah Gersh, is a kike attorney.

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 9 of 11 Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 11 of 12 33847_443223362383_209976_n

The Gersh family – what a bunch of creepy weirdo kikes!

You can give him a call or stop by his office and let him know what you think of his wife’s behavior, advise him to get a leash on that hoe.

VISCOMI & GERSH, PLLP ATTORNEYS AT LAW

121 Wisconsin Avenue Whitefish, MT 59937

Phone: 406-862-7800 (international callers add 001 to the beginning) Fax: 406-862-7820 (international faxers add 001 to the beginning)

You can also send him an email: [email protected]

He is on Google.

So – get to it!

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 10 of 11 Jews Targeting Richard Spencerʼs Mother for Harassment and Extortion – TAKE ACTION! – Daily Stormer 11/30/17, 4)52 PM Case 9:17-cv-00050-DLC-JCL Document 32-2 Filed 11/30/17 Page 12 of 12

Let these people know what you think!

Again – as always – don’t make any threats of violence and certainly don’t do anything violent. Don’t ever do anything illegal, ever. It is well within your rights to tell these people what you think of their actions, trying to extort Richard Spencer’s family.

This is very important. Calling these people up and/or sending them a quick message is very easy. It is very important that we make them feel the kind of pressure they are making us feel.

There hasn’t ever been a more important campaign than this.

So do it!

Hail Victory!

Eric Striker contributed research to this report.

https://dailystormer.red/jews-targeting-richard-spencers-mother-for-harassment-and-extortion-take-action/ Page 11 of 11 Case 9:17-cv-00050-DLC-JCL Document 32-3 Filed 11/30/17 Page 1 of 8

EXHIBIT 3

Gersh communications published by Sherry Spencer

Case 9:17-cv-00050-DLC-JCL Document 32-3 Filed 11/30/17 Page 2 of 8 Case 9:17-cv-00050-DLC-JCL Document 32-3 Filed 11/30/17 Page 3 of 8 Case 9:17-cv-00050-DLC-JCL Document 32-3 Filed 11/30/17 Page 4 of 8 Case 9:17-cv-00050-DLC-JCL Document 32-3 Filed 11/30/17 Page 5 of 8 Case 9:17-cv-00050-DLC-JCL Document 32-3 Filed 11/30/17 Page 6 of 8 Case 9:17-cv-00050-DLC-JCL Document 32-3 Filed 11/30/17 Page 7 of 8 Case 9:17-cv-00050-DLC-JCL Document 32-3 Filed 11/30/17 Page 8 of 8 Case 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 Page 1 of 11

EXHIBIT 4

Andrew Anglin post on Daily Stormer dated Dec. 17, 2016

11/29/2017 Neo-Nazis Demand Tanya Gersh Sell Her Home, Give the Money to NPI – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 Page 2 of 11

Andrew Anglin Daily Stormer December 17, 2016

Richard Spencer’s mother has written an essay on Medium outlying the abuses she has suffered at the hands of the Jews of Montana.

My name is Sherry Spencer, and I am Richard Spencer’s mom. I’m a resident of Whitefish, Montana, and am the proud owner of a beautiful mixed­use facility in town.

…

Richard does not own the building, nor has he ever used it for his writing or publishing. Put simply, the building has nothing to do with politics — and it has everything to do with tourism and local businesses.

I had no intention of selling . . . until I started receiving terrible threats in the last couple of weeks.

These threats came from Tanya Gersh, a local realtor with links to “human rights” organizations Love Lives Here and the Montana Human Rights Network.

On November 22, Gersh and I spoke on the phone. She relayed to me that if I did not sell my building, 200 protesters and national media would show up outside — which would drive down the property value — until I complied. Gersh’s other conditions included that I make a public denunciation of my son in a statement written by the Montana Human Rights Network and that I make a donation to this organization from the sale of the property. As Gersh announced on Facebook, she was “spear heading” the campaign.

https://dailystormer.red/neo-nazis-demand-tanya-gersh-sell-her-home-give-the-money-to-npi/ 1/10 11/29/2017 Neo-Nazis Demand Tanya Gersh Sell Her Home, Give the Money to NPI – Daily Stormer Gersh followed up on her conditions in a number of emails, which I’ve just made public. Case 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 She even shamelessly Page 3 of 11 suggested that she act as my realtor! In other words, she and the local “human rights” organizations appeared to seek financial benefit from threats of protests and reputation damage. The same day Gersh first contacted me, I received a sales offer, even though I had not expressed any intention to sell, nor had anything been publicized.

One renter reported to me that Gersh threatened her business with boycotts unless she moved. This renter also alleged that Gersh called her “collateral damage.” As the manager of the property, I employ a number of local maids and other maintenance personnel, who would lose their jobs if I were to sell. More “collateral damage,” I guess.

I never wanted to go public with this story. However, the fact that so many news outlets have reported on it forces my hand.

Whatever you think about my son’s ideas — they are, after all, ideas — in what moral universe is it right for the “sins” of the son to be visited upon the mother?

All I wanted to do with the building was help Whitefish.

The people attacking me claim that “loves lives here.” Now it’s time for them to show it.

Here are the emails she’s published.

https://dailystormer.red/neo-nazis-demand-tanya-gersh-sell-her-home-give-the-money-to-npi/ 2/10 11/29/2017 Neo-Nazis Demand Tanya Gersh Sell Her Home, Give the Money to NPI – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 Page 4 of 11

https://dailystormer.red/neo-nazis-demand-tanya-gersh-sell-her-home-give-the-money-to-npi/ 3/10 11/29/2017 Neo-Nazis Demand Tanya Gersh Sell Her Home, Give the Money to NPI – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 Page 5 of 11

https://dailystormer.red/neo-nazis-demand-tanya-gersh-sell-her-home-give-the-money-to-npi/ 4/10 11/29/2017 Neo-Nazis Demand Tanya Gersh Sell Her Home, Give the Money to NPI – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 Page 6 of 11

https://dailystormer.red/neo-nazis-demand-tanya-gersh-sell-her-home-give-the-money-to-npi/ 5/10 11/29/2017 Neo-Nazis Demand Tanya Gersh Sell Her Home, Give the Money to NPI – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 Page 7 of 11

This is straight-up extortion. No other way to frame it.

I mean – threatening a protest to run out tenants?

I think it’s going to come back on her. In a big way. Jews have operated with impunity for so, so long that they just can’t imagine goyim standing up and saying “no.”

But that is what is happening here.

The local media published an article about my article from yesterday – and the Jews are backtracking,

saying they never threatened a protest.

Montana Standard:

https://dailystormer.red/neo-nazis-demand-tanya-gersh-sell-her-home-give-the-money-to-npi/ 6/10 11/29/2017 Neo-Nazis Demand Tanya Gersh Sell Her Home, Give the Money to NPI – Daily Stormer An anti­Semitic website called The Daily Stormer has posted a call to “TAKE ACTION” against Jewish people inCase 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 Page 8 of 11 Whitefish, providing personal contact information and urging a “troll storm” against them.

The story claims the “vicious, evil race” has harmed the Whitefish business of Richard Spencer’s mother. It quotes a story from the British newspaper Daily Mail that said Sherry Spencer “said she is being forced to sell a building she owns in the small town because residents are rebelling against her son.”

The site posted phone numbers, email addresses, and Twitter handles for the Whitefish residents it alleges are harassing Sherry Spencer, along with a disclaimer that it opposes violence.

…

Some of those targeted by Thursday’s post are involved in Love Lives Here, a group that fights discrimination – racial, ethnic, religious and gender – in the Flathead. It was founded in 2009 in response to screenings of pro­ Hitler films by a white separatist group called Kalispell Pioneer Little Europe. Daily Stormer calls Love Lives Here a “Jew terrorist group.”

Earlier this month, Whitefish Mayor John Muhlfeld signed a proclamation that declared, among other things, “The City of Whitefish repudiates the ideas and ideology of the white nationalist and so called alt­right as a direct affront to our community’s core values and principles.”

“Love Lives Here has never promoted the idea of a protest of a boycott of a building,” Will Randall, the organization’s chairman, said Friday. One of the people targeted by the Daily Stormer post “is a beloved member of our community who entered into this conversation trying to help.”

The Stormer posted pictures of several Whitefish residents, including a child, with a yellow Star of David with the word “Jude” – German for Jew – added to each photo. During World War II, Jews in Germany and Nazi­ occupied territories were forced to wear such stars on their clothing.

Randall said that his research into neo­Nazi groups has accustomed him to such images.

“But when your own personal friends are affected, it’s gut­wrenching,” he said. “These are some of the best people around, and to see them attacked because they’re Jewish or have a Jewish­sounding name is disgusting.”

If they are the best people around, why are they viciously threatening the mother of a person whose politics they disagree with, Randall?

That doesn’t seem like something the best people around would do. It sounds like something a criminal gang would do.

Absolutely disgusting that they now just come out and say “oh no we never did that” as soon as evidence is released. Of course, it was Tanya Gersh who did it, who is not necessarily a representative of Jew terror group Love Lives Here in a direct sense, but she is working directly with this group – and demanding the extortion money go to them.

This whole situation really throws the mask off the Jew. They do this to literally everyone who cross them (or their family members, in special cases like this where the individual who crossed them doesn’t care). https://dailystormer.red/neo-nazis-demand-tanya-gersh-sell-her-home-give-the-money-to-npi/ 7/10 11/29/2017 Neo-Nazis Demand Tanya Gersh Sell Her Home, Give the Money to NPI – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 Page 9 of 11 They come to you and say “you’re going to do exactly as we tell you to, or we are going to make you suffer.”

The pre-written apology is especially interesting. All of those apologies you hear people read to Jews were written by Jews.

This people are a disease.

Her lawyer husband also appears to be involved in some dirty dealings. We are investigating that.

Tanya Gersh Must Sell Her Home, Issue an Apology for Jewry and Give Money to NPI

On behalf of global Nazism, I am hereby demanding that the Jew Tanya Gersh sell her property in Whitefish and donate the money to NPI, issue an apology to the community, the white race and goyim everywhere, and immediately move to Israel.

I assure that when you get to Israel, there will be no white people there trying to extort you because your son believes Jews have a right to exist – even though this is exactly what you’ve done to us in our country. Your ancestors ensured that you have a place to go where this doesn’t happen to you, and that is what we are trying to build for our children.

So you have to go back, Tanya. You simply are not welcome in this country.

We’ve had enough, Tanya.

This is the goylash.

You remember the last goylash, don’t you Tanya?

https://dailystormer.red/neo-nazis-demand-tanya-gersh-sell-her-home-give-the-money-to-npi/ 8/10 11/29/2017 Neo-Nazis Demand Tanya Gersh Sell Her Home, Give the Money to NPI – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 Page 10 of 11

Yeah.

You’re gonna wanna dip out before this thing really gets started.

Because I’ll tell you want, Tanya.

This fire is already rising.

There’s only one place this road ends.

Keep Up the Pressure

Keep calling these people. Keep emailing them.

Make it known to them that the jig is officially up.

We aren’t playing this game anymore.

The entire list of contact information is in my last post.

https://dailystormer.red/neo-nazis-demand-tanya-gersh-sell-her-home-give-the-money-to-npi/ 9/10 11/29/2017 Neo-Nazis Demand Tanya Gersh Sell Her Home, Give the Money to NPI – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-4 Filed 11/30/17 Page 11 of 11 Go do it.

Hail Victory.

https://dailystormer.red/neo-nazis-demand-tanya-gersh-sell-her-home-give-the-money-to-npi/ 10/10 Case 9:17-cv-00050-DLC-JCL Document 32-5 Filed 11/30/17 Page 1 of 6

EXHIBIT 5

Andrew Anglin post on Daily Stormer dated Dec. 19, 2016

11/29/2017 Lying Jew Media Says Daily Stormer “Threatened” Jewish Racketeers Extorting the Spencer Family – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-5 Filed 11/30/17 Page 2 of 6

Andrew Anglin Daily Stormer December 19, 2016

The lying Jew media is claiming that we here at the Daily Stormer – this writer specifically – “threatened” a Jewish racketeering cabal in Whitefish, Montana after we called for a non-violent campaign of public outcry against these terrorist Jews after they attempted to extort the family of Richard Spencer as revenge for his political beliefs.

Think Progress:

A white­supremacist call to action to “troll” Jewish people in Whitefish, Montana — home of white nationalist Richard Spencer’s mother — is gaining support on social media and putting lives in danger.

On Friday, Andrew Anglin of the Daily Stormer published an inflammatory article about Jews “targeting Richard Spencer’s mother,” Sherry Spencer, claiming that her real estate business is failing because of public backlash against her son, a white supremacist and prominent member of the National Policy Institute (NPI) who coined the term “alt­right.” https://dailystormer.red/lying-jew-media-says-daily-stormer-threatened-jewish-racketeers-extorting-the-spencer-family/ 1/5 11/29/2017 Lying Jew Media Says Daily Stormer “Threatened” Jewish Racketeers Extorting the Spencer Family – Daily Stormer Anglin falsely claimed that Jewish people in Montana are “harasCase 9:17-cv-00050-DLC-JCL Document 32-5 Filedsing” Sherry, attempting to 11/30/17 Page 3 of 6 extort money from her, and forcing her to sell a building she owns — all because they disagree with her son. He cites a Daily Mail article in which Sherry complains that her sons’ views are damaging her business. The article does not mention any particular religion. But Anglin called on his readers to harass Jews, describing them as a “vicious, evil race of hate­filled psychopaths” and “a people without shame.”

Jezebel:

On Friday, The Daily Stormer founder Andrew Anglin published an incendiary bit of propaganda that called on white supremacists to harass Jewish people in the town of Whitefish, Montana, claiming that they have caused Richard Spencer’s mother’s real estate business to fail (of course, this is not true), Think Progress reports.

…

Anglin’s screed claims falsely and malicious that Jewish people in Montana are harassing and attempting to extort money from Sherry, citing a Daily Mail article published Thursday that cites the ABC article, which just so happens not to mention Jews at all.

Anglin’s post becomes potentially dangerous when he lists the personal information of members of Love Lives Here, including photos, email addresses, phone numbers, and social media accounts.

The Independent:

A white supremacist website has endangered people’s lives by posting contact details and photos of Jewish residents in a small Montana town – where the mother of white supremacist Richard Spencer lives – and has urged readers to “take action”.

The Daily Stormer, a racist website that describes Jews as a “people without shame”, cites a Daily Mail article which alleges that Sherry Spencer was considering selling her business in Whitefish, as she claimed she was suffering backlash against her son’s views. Richard Spencer is a member of white supremacist think tank the National Policy Institute, which coined the term alt­right.

The attacks focus on a group called Love Lives Here, which Ms Spencer accused of damaging her family.

The peace organisation, which is “committed to co­creating a caring, open, accepting and diverse community, free from discrimination and dedicated to equal treatment”, denied any wrongdoing.

Uproxx:

A scary “call to action” in white supremacist outlet The Daily Stormer has resulted in Jewish residents of Whitefish, Montana being targeted and harassed by followers of Alt­Right leader Richard Spencer. Stemming from an article in the Daily Mail in which Spencer’s mother said that the business she owns is being damaged by her son’s views, author Andrew Anglin falsely took her comments and provided his own context and perspective in order to blame Jews for the issues — even though Sherry Spencer never specified that she was being bothered by a certain group or religion.

Certain passages of the article are unfortunately pretty standard these days when it comes to anti­Semetic sentiments being made public. However, some pieces of the post are downright unsettling in the ways he calls out innocent residents of the town. He describes Jews as “vicious, evil race of hate­filled psychopaths” and not

https://dailystormer.red/lying-jew-media-says-daily-stormer-threatened-jewish-racketeers-extorting-the-spencer-family/ 2/5 11/29/2017 Lying Jew Media Says Daily Stormer “Threatened” Jewish Racketeers Extorting the Spencer Family – Daily Stormer only notes which people Spencer’s supporters should target and troll but even includes photos of each person withCase 9:17-cv-00050-DLC-JCL Document 32-5 Filed 11/30/17 Page 4 of 6 an all­too­familiar yellow Star of David Photoshopped onto their clothing as if they were in Nazi­era Germany.

Despite Anglin’s insistence that there should be no violent action taken against the innocent people he identifies, he also includes their phone numbers, home addresses, and emails if available.

“Home addresses” is yet another Jewish lie. I purposefully left out home addresses.

This demonstrates just how utterly depraved the Jew media is.

It is the Jewish racketeering cabal of Whitefish that is making the threats. Emails published by Richard Spencer’s mother show the cabal’s ringleader, Tanya Gersh, threatening her with protests if she doesn’t sell her property. Gersh also threatened tenants in the building she is pushing for her to sell. At the same time, she was demanding money be given to the Jew terrorist group “Love Lives Here,” and that an apology be issued.

This is an open and public harassment campaign against Spencer’s mother because these Jews dislike her sons political views.

I called for people to express their feelings about these threats and this harassment and extortion to the people responsible – and somehow I’m the threatener and harasser!

They just claim “oh no, no one threatened her” – even while admitting to have read the Medium piece where she posted the emails showing the threats!

These Jews live in a sick mirror-world where everything is the opposite of what it actually is.

Meanwhile, in Reality…

I have made it explicitly clear that I am not calling for threats or harassment or anything else against the people who are threatening and harassing (and extorting) the Spencers. I have called for a campaign of making our voices heard, making it clear to these people that we see what they are doing and that we do not agree with it. That we are sickened by it.

https://dailystormer.red/lying-jew-media-says-daily-stormer-threatened-jewish-racketeers-extorting-the-spencer-family/ 3/5 11/29/2017 Lying Jew Media Says Daily Stormer “Threatened” Jewish Racketeers Extorting the Spencer Family – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-5 Filed 11/30/17 Page 5 of 6

The main goal, besides making it clear to the individuals involved with the harassment campaign that we know what they are doing and are tracking their actions, was to bring light to the issue. And that is working. The media is covering it.

Of course, they are covering it from the angle of “the people against threats and harassment are the real threateners and harassers,” but that is inconsequential. The people looking at the situation can see it for what it is. The facts are all there and people can make a decision as to whether it is okay for Jewish groups to threaten and extort the mothers of people they disagree with politically.

None of these articles even describe the situation, basically trying to claim that I just randomly began posting the contact info for Jews in this town in Montana for no reason. In other words, their articles don’t make any sense, and anyone reading them with half a mind will go look further and find what it is we are so upset about.

Operation Continues

We will keep putting pressure on these Jews, Tanya Gersh in particular, until they stop harassing the Spencers and issue an apology for this brutal Jewish racketeering.

Tanya has already taken down her website, and removed her business from Google. I’m not sure what this is if not an admission of guilt.

We are presently working to uncover the dirty dealings of Gersh’s husband, the Jew lawyer Judah Gersh.

So please, if you haven’t contacted these people to let them know what you think of their deranged

actions, do so. The contacts are all in this article.

https://dailystormer.red/lying-jew-media-says-daily-stormer-threatened-jewish-racketeers-extorting-the-spencer-family/ 4/5 11/29/2017 Lying Jew Media Says Daily Stormer “Threatened” Jewish Racketeers Extorting the Spencer Family – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-5 Filed 11/30/17 Page 6 of 6 We will soon be releasing an extended contacts list, where you will be able to tell the business associates of these people what you think of their actions, and ask that they cut their business ties with the Jews engaged in this campaign of harassment and extortion against the Spencers.

It has been scientifically proven that Richard Spencer did nothing wrong.

This goes far, far beyond Richard Spencer or his family.

It is absolutely time that we make it clear to these people that we have the ability to do to them the same thing they do to us. They have operated with impunity for decades, getting us fired from our jobs, targeting our businesses, making our lives hell because we dared to stand up to them.

As Tanya Gersh has the tables turned on her, with a backlash against her criminal actions (even local media admits she’s experiencing a “backlash”), as she frets about whether she may be facing a civil or even criminal lawsuit for extortion, I’m quite certain she is thinking “maybe I shouldn’t have messed with these particular goyim?”

https://dailystormer.red/lying-jew-media-says-daily-stormer-threatened-jewish-racketeers-extorting-the-spencer-family/ 5/5 Case 9:17-cv-00050-DLC-JCL Document 32-6 Filed 11/30/17 Page 1 of 8

EXHIBIT 6

Eric Striker post on Daily Stormer dated Dec. 21, 2016

11/29/2017 Daily Stormer Exposes Montana Jew Racketeers – Jew Criminals Claim They’re the Victims and Call the Feds – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-6 Filed 11/30/17 Page 2 of 8

Eric Striker Daily Stormer December 21, 2016

A quick look at what’s going on in Whitefish, Montana, and you’ll understand why Hitler was so mad.

The Daily Stormer has recently embarked on a campaign to call attention to a Jewish racketeering operation targeting the family of Richard Spencer – the FBI has responded by “investigating” outraged citizens instead.

The Jewish paramilitary organization “Love Lives Here” has been working with real estate speculator (((Tanya Gersh))) in a direct push to use mafia-style intimidation tactics to get Spencer’s mother to sell her lucrative Whitefish, Montana property as a payoff to call off the piranhas in the payots.

As noted previously, the Daily Stormer went the extra mile to keep our report well-within the confines of the law, but this current commotion based on nothing shows just how the Talmud has become the law of the land.

New York Times:

The police in Whitefish, Mont., said Tuesday that they have stepped up patrols and are working with the F.B.I. after a neo­Nazi and white supremacist website listed the names and contacts of local Jews, calling on readers to “take action” against them. https://dailystormer.red/daily-stormer-exposes-montana-jew-racketeers-jew-criminals-claim-theyre-the-victims-and-call-the-feds/ 1/7 11/29/2017 Daily Stormer Exposes Montana Jew Racketeers – Jew Criminals Claim They’re the Victims and Call the Feds – Daily Stormer Lt. Bridger Kelch of the Police Department in the town in northwestern Montana said that the force was takingCase 9:17-cv-00050-DLC-JCL Document 32-6 Filed 11/30/17 Page 3 of 8 the measures after the website, The Daily Stormer, on Friday published phone numbers, work locations, email addresses, and photographs of six Flathead County residents. Several of those targeted were from Whitefish where Sherry Spencer, the mother of the white nationalist leader Richard B. Spencer, lives and owns a building that has been the subject of protests.

…

Reached by telephone, Lt. Kelch said Tuesday morning that the department was reviewing social media posts and emails directed at the six people, but that none had risen to death threats. He said the department was conducting patrols, but there had been no reported confrontations in person or by telephone. “We have been looking at any communications,” he said.

The FBI and the Whitefish Donut Club are teaming up to do what exactly? Shield Jewish underworld parasites from criticism and exposure? Their presence has no legal grounds to it, the only thing they can do (for now) is use their presence to try and scare people who are critical of Jews.

Our civil liberties are mangled and the respect for the right to free speech is under perpetual assault, but they can’t lock people for defending ourselves from outlandish acts of aggression from the Jewish community, its press, and its proxies…yet.

Apparently Spencer’s family has let these terrorists win, and are selling their property out of fear for their safety and the safety of the businesses inside from the circling Zionist jackals outside. As with all terrorism, whenever you pay the ransom, they keep doing it, the only thing that will stop this madness is through direct (and fully within the confines of the law) confrontation.

We’re going to keep doing this no matter what, not only because it’s the right thing to do, but it also exposes who really runs America to the world. If you put your arms up to shield your head during a Jewish hate-attack and the Jew attacker breaks his nail in the process, suddenly you are featured in every single major publication as an accomplice to a Holocaust, and the FBI is ordered to come down to look all professional, even as the agents laugh among themselves at yet another false alarm.

Yet, when people threaten Trump with assassination, openly call for the murder of foreign diplomats, or Montana Jewish organizations coming together to terrorize a Gentile family into selling them their property – the police and FBI are nowhere in sight.

Behold what happens when the Jew barrages you, and you simply cry “STOP!”

Judenpresse? Ain’t no such thing! Just a conspiracy theory, goy.

https://dailystormer.red/daily-stormer-exposes-montana-jew-racketeers-jew-criminals-claim-theyre-the-victims-and-call-the-feds/ 2/7 11/29/2017 Daily Stormer Exposes Montana Jew Racketeers – Jew Criminals Claim They’re the Victims and Call the Feds – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-6 Filed 11/30/17 Page 4 of 8

https://dailystormer.red/daily-stormer-exposes-montana-jew-racketeers-jew-criminals-claim-theyre-the-victims-and-call-the-feds/ 3/7 11/29/2017 Daily Stormer Exposes Montana Jew Racketeers – Jew Criminals Claim They’re the Victims and Call the Feds – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-6 Filed 11/30/17 Page 5 of 8

https://dailystormer.red/daily-stormer-exposes-montana-jew-racketeers-jew-criminals-claim-theyre-the-victims-and-call-the-feds/ 4/7 11/29/2017 Daily Stormer Exposes Montana Jew Racketeers – Jew Criminals Claim They’re the Victims and Call the Feds – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-6 Filed 11/30/17 Page 6 of 8

https://dailystormer.red/daily-stormer-exposes-montana-jew-racketeers-jew-criminals-claim-theyre-the-victims-and-call-the-feds/ 5/7 11/29/2017 Daily Stormer Exposes Montana Jew Racketeers – Jew Criminals Claim They’re the Victims and Call the Feds – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-6 Filed 11/30/17 Page 7 of 8

Spencer’s comparatively more nuanced and forgiving view on Jews doesn’t appear to be softening any of the blows Slimy Hymie is trying to dish out against him. So great is their growing character assassination campaign, that the Judenpresse has even freeze framed a few out of context pictures from his videos to use as prejudicing stock photos, or “hit pics.” These pictures are put in shared Jewish media databases, meant to be used whenever there are reports about individuals they want to defame, and I already have seen two that have been featured consistently accompanying articles on these fake news websites.

Here’s one – Darth Spencer:

https://dailystormer.red/daily-stormer-exposes-montana-jew-racketeers-jew-criminals-claim-theyre-the-victims-and-call-the-feds/ 6/7 11/29/2017 Daily Stormer Exposes Montana Jew Racketeers – Jew Criminals Claim They’re the Victims and Call the Feds – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-6 Filed 11/30/17 Page 8 of 8

Here’s the second one, where Spencer is meant to look like a cross between the anti-white trope of “Angry White Man” and an exasperated orating Adolf Hitler:

Keep memeing Spencer like this, Jews. He may just become the nightmare you’ve been dreaming of.

https://dailystormer.red/daily-stormer-exposes-montana-jew-racketeers-jew-criminals-claim-theyre-the-victims-and-call-the-feds/ 7/7 Case 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 1 of 12

EXHIBIT 7

Andrew Anglin post on Daily Stormer dated Dec. 21, 2016

11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 2 of 12

Andrew Anglin Daily Stormer December 21, 2016

Bad news, Jews: The goyim know. And they appear to be extremely pissed off.

The situation in Whitefish, Montana is continuing to heat up!

Here’s the timeline so far:

Richard Spencer gave a speech in Washington, DC which got widespread media coverage because some people threw up straight-armed salutes at the end of it.

The Jew realtor Tanya Gersh, working with the Jewish terror group “Love Lives Here” contacted Richard Spencer’s mother in Whitefish and told her if she didn’t sell her commericial building in the center of Whitefish, they would bring 200 protesters to the building and drive down property value. She also demanded that after selling the building, Mrs. Spencer give a portion of the proceeds to Love Lives Here.

She went so far as to offer to be the realtor dealing with the sale.

https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 1/11 11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 3 of 12 The Jew Gersh threatened tenants in Madam Spencer’s building, telling them their businesses would be boycotted because they are renting from a racist (Richard’s mother has said repeatedly that she does not agree with Richard’s beliefs, but Jews don’t care).

Mrs. Spencer published a piece on Medium, explaining her side of the story, and published her email exchanges with Gersh, which contained threats and demands she apologize for the beliefs of her son.

The Daily Stormer posted a protest article, pointing out that this is blatant, open extortion against a man’s mother because of his political beliefs, and urging readers to contact the Jews involved and let them know that they see their Jew behavior and they do not approve. Contact information was posted, including social media contacts, email addresses, phone numbers and business addresses (no home addresses were posted, despite the initial claims of the lying kike media – they have now stopped saying that).

A media storm ensued, with the Jew-run media claiming that the Jews of Whitefish were victims, and I was “targeting them for harassment” and “threatening” them for no reason.

World Jewry rallied to defend the Jews of Montana.

The Jew Gersh took down all her social media accounts, turned off her phone and contacted the police.

And now…

As we reported earlier today, the sickening Jew filth is attempting to send the FBI after me for telling people to send messages of protest to the Jews!

https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 2/11 11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 4 of 12 Well Jews – sorry! I don’t ever do anything illegal! I don’t even do cocaine or drive past the speed limit, let alone threaten to murder people on the internet!

What happened was the local police told the Jews that I had done nothing wrong, and the Jews kept on pushing the issue, to the point that it was referred to the FBI.

The New York Times has admitted that there were no death threats:

Lt. Bridger Kelch of the Police Department in the town in northwestern Montana said that the force was taking the measures after the website, The Daily Stormer, on Friday published phone numbers, work locations, email addresses, and photographs of six Flathead County residents.

…

The matter has been the topic of national news media articles after a local report in The Missoulian drew widespread attention on social media.

Reached by telephone, Lt. Kelch said Tuesday morning that the department was reviewing social media posts and emails directed at the six people, but that none had risen to death threats. He said the department was conducting patrols, but there had been no reported confrontations in person or by telephone. “We have been looking at any communications,” he said.

He added that some of the material had been shared with the F.B.I.

Sandra Barker, the spokeswoman for the agency’s Salt Lake City office, whose jurisdiction includes Montana, said in an emailed statement on Tuesday: “The F.B.I. is aware of the issue and is reviewing to determine if there is a violation of federal law.”

What federal law could be violated?

Is there a federal law against emailing the Jews????

Not yet!

I can also photoshop pictures of your face and that of your scamming spammer rat son onto Nazi propaganda posters from the 1930s!

https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 3/11 11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 5 of 12

No one can stop me from doing this, Tanya!

It’s in the Constitution!

https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 4/11 11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 6 of 12

Anyway, the whole media was reporting that there were “death threats” – even while none were presented. Of course, even if there were death threats, I wouldn’t be responsible for that – whoever sent them would be. But you all understand that we don’t want to give these people any ground to stand on, and they get that if there are actual death threats.

The Jews have now demanded that the police drive around their neighborhoods 24 hours a day, making sure that there are no Nazis waiting in the bushes, ready to pop out and turn them into lampshades.

https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 5/11 11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 7 of 12 Basically, the Jews are shocked that goyim such as we are legally allowed to disagree with them. They apparently just assume it is illegal.

[Jewing Intensifies]

International Jewry is rallying around the Jews of Montana.

A very telling article by the mousy New York Jewess Phoebe Maltz Bovy (Twitter: @tweetertation, email: [email protected]) was published in the Jewish Daily Forward.

Bovy writes that it is unethical to target a man’s mother because of his beliefs, but that it doesn’t matter, because Jews suffer more than whites. She references Mrs. Spencer’s Medium article, where she talks about how this has affected her life, and says she just isn’t showing enough sympathy for the plight of Jews.

I think we, the outside observers, need to be careful not to conflate the financial setback his mother says she’s experiencing with the horror it would be right now to be a Jew in Whitefish, Montana, at a time when neo­Nazis are threatening the town’s few Jews, including children. She’s in a bad spot, yes, but not quite at the level of the young child being referred to (this is from the cached link in the Tablet post) as both “a creepy little faggot” and a “scamming little kike.”

Let me be clear: The chance fact of having an adult child who’s a white nationalist leader doesn’t make Sherry Spencer (or Rand, whose building it isn’t, and who therefore seems to be a bit less wrapped up in this) obligated to become White Gentile Ally of the Year, or otherwise engage in https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 6/11 11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer anti­racist activism.Case 9:17-cv-00050-DLC-JCL But she’d be let’s say a more likable protagonist if she spent a little less time holding forth Document 32-7 Filed 11/30/17 Page 8 of 12 on how attentively she’d decorated her “mixed­use building” and devoted, I don’t know, a sentence to acknowledging why her son has marginalized people, Jews especially in this case, so riled up. Or if she seemed even remotely aware of the comments from unabashed anti­Semites who have come out in her defense. “The apartments even include my original artwork, and the rooftop garden features my ceramic mural, which celebrates the Whitefish Winter Carnival,” writes Sherry Spencer on Medium, as if this were the issue.

Does Sherry Spencer’s apparent (that is, in these public statements) indifference to bigotry, apart from how it inconveniences her personally that her son is a high­profile bigot, make her, too, A Bigot, despite protests to the contrary? No. I think that’s the wrong way to look at it. Her public reaction is both understandable and emblematic of how racism and anti­Semitism operate.

And it’s not the end of the world if would­be white supremacists restrain themselves upon realizing that it would bring shame on their families if they did so. Yes, in a perfect world, shame would not extend to the relatives of the terrible, and we should strive to live in that world, and aim protests at white supremacists, not those who share their DNA. But we do not live in that world; let the silver lining of this be an “alt­right” sort or two thinking of his family and stopping before he gets in too deep.

This is a truly incredible look into the mind of the kike.

The Forward is, of course, a Jew publication meant for Jew consumption, so she’s able to be more frank.

But just look at what she’s saying:

Mrs. Spencer is obligated to show sympathy for the Jews attacking her, because people are angry that the Jews attacked her.

The Jews who attacked her are necessarily bigger victims than she, who was attacked, because people responded to their attacks with words of protest.

It is unethical that she’s being attacked for her son’s political beliefs, but actually it’s good because it will make others who share these beliefs scared to go public for fear that their families will be targeted by Jews.

This is pure “we are the chosen ones, we simply matter more than you goyim.”

It’s difficult to wrap your head around.

We would not be having this conversation if the Jews of Whitefish had not organized to extort Mrs. Spencer as revenge for the political beliefs of her son.

Another very interesting Jew response comes from the other coast – Berkeley rabbi Menacham Creditor

(Twitter: @rabbicreditor, email: [email protected]).

https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 7/11 11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 9 of 12

He posted this to his Facebook page:

Good morning friends –

A brief update about the responses to the cyber­hate attacks on members of the Jewish community and the community at large in Whitefish, MT (see: https://thinkprogress.org/white­nationalists­target­jews­in…). The families there are deeply appreciative of the support from around the country. There will be an update for the local Jewish community whose members and leadership have been most specifically under attack. There will be a need for fundraising and other ongoing support for them and because of the threats they have the greatest challenges right now. As channels are identified to offer them support without further exposing them those will be shared and everyone is asked to please be ready to put out an appeal at that time, so if you are thinking of next steps, that will be coming in the next 24­48 hours from 12/20.

There are two local organizations who have now had the time to come together and begin to identify their most specific needs and ways to support their community right now.

1. Love Lives Here : This is a local organization who has worked tirelessly in the Flathead Valley and is, as their website states, “committed to co­creating a caring, open, accepting and diverse community, free from discrimination and dedicated to equal treatment for all our citizens.”

You can find their materials on their facebook page: https://www.facebook.com/LoveLivesHereFlathead/

Here are specific actions they suggest:

• Write a postcard with a positive, loving message and send it to Love Lives Here at P.O. Box 204, Whitefish, MT 59937. We will deliver these messages in person. • Buy or borrow a copy of “The Christmas Menorahs” and host a story hour for your neighborhood kids. Share the story of what happened in Billings, MT in the ’90s when they rallied around a Jewish family in their community. • Get a Menorah for your window (window cling or candle holder) to show solidarity with your Jewish brothers and sisters during the Hanukkah holiday (Dec 24th – Jan 1st). • print off a pdf of the Love Lives Here logo and post it in your car or home or business. • Email [email protected] if you can go door to door and ask your neighbors to put up Love Lives Here flyers and The Proclamation in local businesses. https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 8/11 11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer • Write a Letter to the Editor supporting Love Lives Here and send it to ALL of the local papers. Please keepCase 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 10 of 12 letters to about 100 words, max 250 and keep your responses brief and to the point

2. Montana Human Rights Network – MHRN: They have historically focused on combatting bigotry in MT. Their website states that they work, “To promote democratic values such as pluralism, equality and justice; challenge bigotry and intolerance; and organize communities to speak out in support of democratic principles and institutions.”

You can find their facebook page here: https://www.facebook.com/MTHumanRights/…

Their website: http://www.mhrn.org/index.html

Here are specific actions they suggest:

Here’s 5 ways you can help right now:

1) Use #lovetheresisters when posting about this situation 2) Write a post about standing with the people of Whitefish and the Flathead Valley who are facing serious harassment and threats. 3)Tag Love Lives Here in the Flathead Valley. 4) Write a short letter to your local paper and the Daily Interlake dissolving these tactics, white supremacy & supporting Love Lives Here and the Jewish Community. 5) Make the connection with opposition to the anti­Semitic leafleting that continues in Missoula and make this picture your profile picture and print and hang in your work/home window during Hanukkah Dec 24­Jan 1st. (go to https://www.facebook.com/MTHumanRights/… for the photo)

So again: the Jews who viciously attacked and attempted to extort Mrs. Spencer are the victims. They need you to give them money, and help them to fight the goyim through various other means.

Well, I’m calling on my people to do things as well.

1. Love Lives Here:

Write a postcard with a negative, hateful message and send it to Love Lives Here at P.O. Box 204, Whitefish, MT 59937. [The mailman will deliver these]

Buy or borrow a copy of “Mein Kampf” and host a story hour for your neighborhood kids. Share the story of what happened in Billings, MT in the ’90s when they rallied around a Jewish family to harass goyim.

Get a Nazi flag for your window (window cling or candle holder) to show solidarity with your Aryan brothers and sisters during the Hanukkah holiday (Dec 24th – Jan 1st).

print off a pdf of the Nazi swastika logo and post it in your car or home or business.

Email [email protected] and tell them you’re well aware of their plans to kike the goyim.

Write a Letter to the Editor condemning Love Lives Here and send it to ALL of the local papers. Please

keep letters to about 100 words, max 250 and keep your responses brief and to the point

2. The Montana Human Rights Network https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 9/11 11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 11 of 12 1. Use #lovetheresisters when posting about this situation

2. Write a post about standing with the white people of Whitefish and the Flathead Valley who are facing serious harassment and threats [from the Jews].

3. Tag Daily Stormer in the Flathead Valley.

4. Write a short letter to your local paper and the Daily Interlake dissolving these tactics, Jewish supremacy & supporting Daily Stormer and the Spencer family.

5. Make the connection with support for the anti-Semitic leafleting that continues in Missoula and make this picture your profile picture and print and hang in your work/home window during Hanukkah Dec 24- Jan 1st. (go to /… for the photo)

In short: we need to do everything they are doing to us, exactly how they do it to us.

And that is what we are doing, which is what is making these Jews so enraged. They just can’t imagine that we would use their same tactics of protest – that they have used against us for decades – against them. They assume it is illegal. They are trying to get us up on federal charges for… complaining about their behavior.

Well, tomorrow we’re kicking it up a notch – so get ready.

I am going to post an entire list of business associates for the Gershs and others associated with Love Lives Here for you to contact and demand they cut their business ties with these individuals due to their unethical practices of threats, harassment and extortion of family members of people they disagree with.

Be ready to be very professional. We want results here, so nasty speech or name-calling is a big no-no. We simply want to make it clear to those who associate with this criminal Jewish racket that we are aware of their associations, and we think they should cut these ties.

So be prepared for that.

We have already pretty much won this round. The Jews are making a huge media storm pointing to their own abhorrent criminal behavior. Gersh has basically admitted guilt by shutting down her social media accounts, removing her profile from the realty site and turning off her phone. But when you’re winning, there is no reason not to keep going.

Hail Victory.

https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 10/11 11/29/2017 (((Neverending Story))): Jews Respond to Chaos! in Whitefish Montana – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-7 Filed 11/30/17 Page 12 of 12

https://dailystormer.red/neverending-story-jews-respond-to-chaos-in-whitefish-montana/ 11/11 Case 9:17-cv-00050-DLC-JCL Document 32-8 Filed 11/30/17 Page 1 of 10

EXHIBIT 8

Andrew Anglin post on Daily Stormer dated Dec. 22, 2016

11/29/2017 Operation Whitefish: New List of Collaborators with Jew Racketeers – TAKE ACTION – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-8 Filed 11/30/17 Page 2 of 10

Andrew Anglin Daily Stormer December 22, 2016

“Hello, Jews. Yes, this is the Daily Stormer calling. It’d like to file a complaint.”

We’re wining big in Whitefish, in our battle against the sickening Jew racket running the town.

For anyone who doesn’t know what’s going down, I wrote a big article on it Wednesday, and did a podcast. You’d better catchup quickly, and join this MEGA TROLLSTORM.

Today, the governor canceled his planned press conference to address the Daily Stormer, presumably because he found out just want kind of twisted skulduggery these vicious Jews are up to.

There is total radio silence from Tanya Gersh, according to Haaretz. She has shut down her social media

sites and has turned off her phone. She is not even communicating with the Jew media itself. Most importantly, the realty company she is employed by has removed her profile from the site, suggesting that

they fear an incoming lawsuit.

As the old gambler’s adage goes: never quit while you’re ahead. https://dailystormer.red/operation-whitefish-new-list-of-collaborators-with-jew-racketeers-take-action/ 1/9 11/29/2017 Operation Whitefish: New List of Collaborators with Jew Racketeers – TAKE ACTION – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-8 Filed 11/30/17 Page 3 of 10

We are continuing our barrage against the criminal Jews of Whitefish and their racketeering cartel.

Now, we contact associated business connections and ask them to withdraw support.

You want to be polite here. Simply tell them that you are disgusted by the racketeering and will be boycotting any business that supports the criminals involved, which includes Tanya Gersh and the members of the terror group Love Lives Here.

You may also tell them that the governor canceled his press conference in support of Gersh and LLH,

indicating that they may soon face criminal charges for their racketeering scam, and people want to be aware that they may suffer for these connections to a known criminal gang.

Today’s List

https://dailystormer.red/operation-whitefish-new-list-of-collaborators-with-jew-racketeers-take-action/ 2/9 11/29/2017 Operation Whitefish: New List of Collaborators with Jew Racketeers – TAKE ACTION – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-8 Filed 11/30/17 Page 4 of 10 We’re going to start today with a solid list. We’ll be releasing more numbers/contact information on Monday.

All our international callers need to add 001 or +1 before dialing these numbers. And we do need our international support.

Tanya Gersh’s Employers

As I said, Gersh may have already been fired. But we still need to put pressure on her (potentially former) employer.

When you call/write, urge them to make a public statement distancing themselves from the Gersh extortion racket.

Purewest Real Estate

Main office phone: (406) 751­5600

Whitefish office phone: (406) 862­4900

Email: [email protected]

You can also use this list to randomly call other realtors and ask what it is they are doing about the Gersh situation.

Christie’s International Real Estate (Purewest’s parent company)

New York, New York Tel: +1 212 468 7182 Email: [email protected]

London, England Tel: +44 (0)20 7389 2551 Email: [email protected]

Beverly Hills, California Tel: +1 310 385 2600 Email: [email protected]

Chicago, Illinois Tel: +1 312 618 3325 Email: [email protected]

You can send out a single email to all those addressed, complaining about the Gersh racketeering/extortion situation, and ask them what they’re doing to solve it.

Twitter: @ChristiesHomes https://dailystormer.red/operation-whitefish-new-list-of-collaborators-with-jew-racketeers-take-action/ 3/9 11/29/2017 Operation Whitefish: New List of Collaborators with Jew Racketeers – TAKE ACTION – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-8 Filed 11/30/17 Page 5 of 10 Associations Purewest Belongs To

Tell these people about the unethical behavior Purewest is engaged in, which includes – but is to limited to – racketeering and extortion.

Billings Association of REALTORS: (406) 248­7145

Gallatin Association of REALTORS, Steve Candler CEO (406) 585­0033, (406) 587­8824 (fax), [email protected]

Missoula Organization of REALTORS: (406) 728­0560, file ethics complaint here,

Northwest Montana Association of Realtors (406) 752­4313

Associated Terror Groups

Montana Human Rights Network

This is the parent organization of Love Lives Here. We have already contacted LLH, but we need to reach out to these people as well, and ask them why they are threatening protests against the mothers of political dissidents, and voice our disapproval.

Phone: (406) 442­5506

Email: [email protected], [email protected]

Twitter: @MTHumanRights

Terror-Supporting Businesses

Tree Hugger Soap

This business has been aggressively assisting the Jewish extortion racket in Whitefish, offering them moral and perhaps even material support. Make it clear that this is intolerable.

Email: [email protected]

Twitter: @treehuggersoap

Facebook (Report for supporting terrorism)

Website

The Walking Man Frame Shop & Gallery

https://dailystormer.red/operation-whitefish-new-list-of-collaborators-with-jew-racketeers-take-action/ 4/9 11/29/2017 Operation Whitefish: New List of Collaborators with Jew Racketeers – TAKE ACTION – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-8 Filed 11/30/17 Page 6 of 10

Run by Michelle Saurey and her husband Peter Edland, this frame shop has been providing support for the terror group Love Lives Here since before all of this began, and we need to make it known that this is sickening.

Address: 305 Baker Avenue Whitefish, MT 59937

Phone number: 406­863­2787

Email: [email protected]

Facebook

Website

Google reviews

DO NOT target The Buffalo Cafe, as they appear to be innocent in all of this and have been getting calls. The owner is apparently a non-Jew, and has not voiced support for Jewish terrorism.

Husband’s Business Associates

Tanya Gersh’s Jew husband is certainly responsible for providing material support to the terroristic actions of his wife. As such, it is important to make it clear to his business associates that we are outraged.

We are looking into the dirty dealings of VISCOMI & GERSH, but if you’ve had a bad experience with them,

feel free to write a review.

Google Reviews

https://dailystormer.red/operation-whitefish-new-list-of-collaborators-with-jew-racketeers-take-action/ 5/9 11/29/2017 Operation Whitefish: New List of Collaborators with Jew Racketeers – TAKE ACTION – Daily Stormer Yelp Case 9:17-cv-00050-DLC-JCL Document 32-8 Filed 11/30/17 Page 7 of 10

Jonah Gersh Clients

Call these people and demand they cut ties to Jonah Gersh, due to his wife’s terrorist activities.

The Lodge at Whitefish

Address: 1380 Wisconsin Avenue, Whitefish, MT 59937

Phone number: (406) 863­4000

Toll Free: (877) 887­4026

Fax: (406) 863­2750

Email: [email protected]

Google reviews

The Firebrand Hotel

Phone: (406) 863­1900

Toll Free: (844) 863­1900

Email: [email protected], [email protected]

Google reviews

Government Officials

Contact these people and demand that they denounce the terroristic extortion racket of Tanya Gersh.

Whitefish Chamber of Commerce

Contact these people and report the dirty dealings of Tanya Gersh and Love Lives Here, as well as the business associations.

Address: 307 Spokane Ave, Ste 103 PO Box 1120 Whitefish, MT 59937

Phone number: (406) 862­3501

Fax number: (406) 862­9494

email: [email protected]

State Officials

https://dailystormer.red/operation-whitefish-new-list-of-collaborators-with-jew-racketeers-take-action/ 6/9 11/29/2017 Operation Whitefish: New List of Collaborators with Jew Racketeers – TAKE ACTION – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-8 Filed 11/30/17 Page 8 of 10 Ask them to denounce the Whitefish extortion racket.

Governor Steve Bullock

Bullock canceled his press conference defending Gersh and LLH, but he did write a vague op-ed saying he’s against hate, and thereby apparently supporting Gersh.

Phone number: (406) 422­0115, (406) 444­3111

Email: [email protected]

Twitter: @GovernorBullock

Senator Steve Daines

Phone number: (202) 224­2651

Contact form

Twitter: @SteveDaines

Senator Jon Tester

Phone number: (202) 224­2644

Contact form

Twitter: @SenatorTester

GET TO IT!

If you are a true warrior for the cause, you will make time to contact all of these people.

I’m serious.

We are all busy. Trust me, I know about busy. But this is so, so important. We have to stand up to these people, and we have to force an apology from Tanya Gersh and Love Lives Here. This will be an absolutely massive victory for our cause. We have never done this before.

There has never been a more important call to action on this site.

This is the revolution.

When we win this, every single one of these Jews will think twice before coming after us and our families.

We are setting a precedent here. I simply cannot stress the importance of this action.

So, if you don’t have time: make time. Call and email all of these people. Do it right now.

https://dailystormer.red/operation-whitefish-new-list-of-collaborators-with-jew-racketeers-take-action/ 7/9 11/29/2017 Operation Whitefish: New List of Collaborators with Jew Racketeers – TAKE ACTION – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-8 Filed 11/30/17 Page 9 of 10 AND AS ALWAYS: ABSOLUTELY NO THREATS OF VIOLENCE, SUGGESTIONS OF VIOLENCE OR ACTS OF VIOLENCE. DON’T DO IT. IT JUST GIVES THEM POWER. THEY ARE ALREADY CLAIMING THEY ARE GETTING DEATH THREATS, WHILE THE LOCAL POLICE AND THE FBI ARE DENYING IT AND THIS MAKES THEM LOOK STUPID. KEEP EVERYTHING ON THE LEVEL.

Next Step For the next phase of our plan against Jew Gersh and Jew Love Lives Here, we are planning an armed protest in Whitefish.

Montana has extremely liberal open carry laws, so my lawyer is telling me we can easily march through the center of the town carrying high-powered rifles.

I myself am planning on being there to lead the protest, which has been dubbed “March on Whitefish.”

Currently, my guys say we are going to be able to put together about 200 people to participate in the march, which will be against Jews, Jewish businesses and everyone who supports either. We will be busing in skinheads from the Bay Area.

I have already worked out most of the details with the leaders of the local groups. Several of our top supporters from Silicon Valley have offered to provide significant support for the march, but we may need to solicit donations to pay for gas/food for the skinheads. I will keep you informed on that.

We’re shooting for the second week of January – just before the inauguration.

https://dailystormer.red/operation-whitefish-new-list-of-collaborators-with-jew-racketeers-take-action/ 8/9 11/29/2017 Operation Whitefish: New List of Collaborators with Jew Racketeers – TAKE ACTION – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-8 Filed 11/30/17 Page 10 of 10

Stay tuned.

Hail Victory.

https://dailystormer.red/operation-whitefish-new-list-of-collaborators-with-jew-racketeers-take-action/ 9/9 Case 9:17-cv-00050-DLC-JCL Document 32-9 Filed 11/30/17 Page 1 of 6

EXHIBIT 9

Andrew Anglin post on Daily Stormer dated Dec. 23, 2016

WHITEFISH GAME-CHANGER: Love Lives Here Throws Tanya Gersh Under the Bus! – Daily Stormer 11/30/17, 11(36 AM Case 9:17-cv-00050-DLC-JCL Document 32-9 Filed 11/30/17 Page 2 of 6

WHITEFISH GAME-CHANGER: Love Lives Here Throws Tanya Gersh Under the Bus!

Andrew Anglin Daily Stormer December 23, 2016

Rabbi Allen Secher

We’ve had a monumental breakthrough in Whitefish.

Top figures within Love Lives Here are throwing Tanya Gersh under the bus, saying they had no idea she was extorting Mrs. Spencer.

Rabbi Allen Sacher, husband of LLH founder Ina Albert, has claimed the organization had nothing to do with Gersh’s actions.

Jewish Journal:

Secher unequivocally rejected the claim that Love Lives Here approached Spencer, saying that Gersh was not speaking on the group’s behalf. Gersh didn’t respond to an emailed request for comment.

“Nothing was further from the truth,” Secher said of the allegation that his group pressured Spencer. “Love Lives Here never contacted her.” https://dailystormer.red/whitefish-game-changer-love-lives-here-throws-tanya-gersh-under-the-bus/ Page 1 of 5 WHITEFISH GAME-CHANGER: Love Lives Here Throws Tanya Gersh Under the Bus! – Daily Stormer 11/30/17, 11(36 AM Case 9:17-cv-00050-DLC-JCL Document 32-9 Filed 11/30/17 Page 3 of 6

Tanya Gersh herself referred to the Montana Human Rights Network in the emails posted by Mrs. Spencer, which LLH is “an affiliate of” according to their Facebook page and the Montana Human Rights Network website (basically, LLH is the Whitefish branch of the Montana Human Rights Network), claiming she was working with them, and that they had planned to protest the building. She also mentioned LLH by name, saying they gave an “incredible response” to the prospect of a sale.

https://dailystormer.red/whitefish-game-changer-love-lives-here-throws-tanya-gersh-under-the-bus/ Page 2 of 5 WHITEFISH GAME-CHANGER: Love Lives Here Throws Tanya Gersh Under the Bus! – Daily Stormer 11/30/17, 11(36 AM Case 9:17-cv-00050-DLC-JCL Document 32-9 Filed 11/30/17 Page 4 of 6

But sure, okay – if LLC wants to claim they had nothing to do with it, and Gersh was lying and actually acted alone, that’s fine. I’ll take that.

What’s more – the current head of the organization itself, Will Randall, has told the Associated Press that he never tried to force the sale of the building and Gersh doesn’t represent the group – she was acting as an individual, he says.

AP:

Randall said his organization is not trying to force the Spencers out of Whitefish, and said the real-estate agent acted as an individual, not as a representative of Love Lives Here.

“I think the Spencers could resolve this by picking up the phone, calling their son and telling him to tell his followers to stop harassing people online and to take those actions down from the internet,” Randall said. “That’s how it can end and we can move on.”

Look, Randall – you couldn’t end this by coercing Richard Spencer.

Richard Spencer didn’t declare this protest. I did.

And I decide when it ends.

I don’t even know Richard Spencer. I have talked to him on the phone like one time. This isn’t about Richard Spencer. It is about justice.

Vicious Jews have attacked, slandered, threatened and attempted to extort an innocent woman because they dislike her son’s politics. And me and my people are not going to end this until justice is served.

So, Here’s the Deal, Randall.

What I need is very simple. If these things are done, I will call off the protest and we will cancel the march.

This is what I need from Love Lives Here:

A repudiation of what Tanya Gersh did in trying to extort Richard Spencer’s mother (you’ve already done basically this with your statement to AP, but I want a clear statement in writing from your organization).

A clear statement that you do not believe that family members of political figures are responsible for the actions of their relatives.

https://dailystormer.red/whitefish-game-changer-love-lives-here-throws-tanya-gersh-under-the-bus/ Page 3 of 5 WHITEFISH GAME-CHANGER: Love Lives Here Throws Tanya Gersh Under the Bus! – Daily Stormer 11/30/17, 11(36 AM Case 9:17-cv-00050-DLC-JCL Document 32-9 Filed 11/30/17 Page 5 of 6

A promise that any protest actions you take in the future against Richard Spencer will not involve his family members.

And from Tanya Gersh, I need:

A public, written apology to Richard Spencer’s mother, an admission of wrongdoing and a statement that she hopes Mrs. Spencer’s business will succeed.

A vow to never again try to harm Mrs. Spencer’s business, or to take any other actions against her.

I think that’s reasonable enough, no?

You see, we are reasonable people.

If we get these things, I will call off the protest now. The calls and emails will stop. The march will be canceled.

If we don’t get these things, then I promise you, this is going to last a very long time. We are going to march. And before that, we are going to protest all of the businesses supporting Love Lives Here, as well as other business connections of those involved in this extortion racket.

Until Then

As of right now, Love Lives Here is still being treated as 100% guilty – until they fully denounce Gersh, we’re pushing forward against them.

Earlier today, I made a huge post with contact information for business contacts of the racketeers and their supporters.

GO CONTACT THESE PEOPLE NOW! If they don’t answer the phone, email them or contact them through Twitter (some of them have already deleted accounts, but some have not).

Also, make it very clear that all we are asking for is an end to the harassment of Mrs. Spencer and a public apology from Gersh. Tell these people that, so that they understand we are reasonable, and we are not just aimlessly lashing out in the way the Jewish media is claiming.

https://dailystormer.red/whitefish-game-changer-love-lives-here-throws-tanya-gersh-under-the-bus/ Page 4 of 5 WHITEFISH GAME-CHANGER: Love Lives Here Throws Tanya Gersh Under the Bus! – Daily Stormer 11/30/17, 11(36 AM Case 9:17-cv-00050-DLC-JCL Document 32-9 Filed 11/30/17 Page 6 of 6

As far as all of you wanting to attend the planned March on Whitefish in January – we’re going to have a pretty stringent RSVP process. Because many protesters will be armed, we have to make sure we weed-out any potential nutjobs. This needs to be extremely professional, which is why we’re mainly relying on pre- vetted skinhead groups.

Anyway, I will keep everyone posted on the details of that.

The bus-throwing of Gersh by LLH is a monumental victory for our cause. A true cause for celebration.

Again, I don’t think it is true that they had nothing to do with it. But that is completely irrelevant. We have no proof that Gersh wasn’t lying when she claimed to be working with them, and that they were planning a protest. So they have a clear way out of this.

We have already won.

And we’re going to keep on winning.

Hail Victory.

https://dailystormer.red/whitefish-game-changer-love-lives-here-throws-tanya-gersh-under-the-bus/ Page 5 of 5 Case 9:17-cv-00050-DLC-JCL Document 32-10 Filed 11/30/17 Page 1 of 3

EXHIBIT 10

Andrew Anglin post on Daily Stormer dated Dec. 23, 2016

11/29/2017 Kek Strikes: School Bus Falls Over in Whitefish! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-10 Filed 11/30/17 Page 2 of 3

Andrew Anglin Daily Stormer December 23, 2016

When was the last time you heard of a school bus falling over?

It is a weird thing which happens virtually never.

But it just happened in Whitefish, Montana, where certain members of the community are coddling Jew terrorists.

It is clear that the frog god is responsible.

KPAX:

The Whitefish School District said they have been notified of a school bus accident near KM Ranch Road Wednesday afternoon, but that no students appeared to have suffered any serious injuries.

Trooper Andrew Horton with the Montana Highway Patrol told MTN News that the bus was traveling on a snow­packed gravel roadway when the bus driver tried to negotiate a right curve. The right­side tires of the bus then went over an embankment causing the bus to tip over onto its side.

Students were able to get out of the bus through the rear exit door. Horton says about 35 students were on board. The Whitefish School District says one student was transported by ambulance as a precaution and was accompanied by a family member.

The frog god does not have mercy or feelings, save for lulz and hatred of Jews and other non-whites.

He is a totally merciless frog. https://dailystormer.red/kek-strikes-school-bus-falls-over-in-whitefish/ 1/2 11/29/2017 Kek Strikes: School Bus Falls Over in Whitefish! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-10 Filed 11/30/17 Page 3 of 3 This is serious business.

https://dailystormer.red/kek-strikes-school-bus-falls-over-in-whitefish/ 2/2 Case 9:17-cv-00050-DLC-JCL Document 32-11 Filed 11/30/17 Page 1 of 5

EXHIBIT 11

Jez Turner post on Daily Stormer dated Dec. 23, 2016

11/29/2017 Hope Not Hate Threatens to Sue Nigel Farage: Another Jewish Anti-Gentile Charity Rattles the Collecting Tin – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-11 Filed 11/30/17 Page 2 of 5

Jez Turner Daily Stormer December 23, 2016

Immediately after the Berlin Terror attack on the Christmas Market Nigel Farage said “Terrible news from Berlin but no surprise. Events like these will be the Merkel legacy.’’ The silent majority nodded in agreement, but the Jewish Elite and their liberal lackeys were outraged; for to them speaking the truth is the worst crime of all. Because of course the truth inevitably leads people to look at the not-so-secret anti- white agenda of our so-called Elite, thence to question it, usually to deeply dislike it, then severely criticise it and finally, when ignored or even punished for complaining, to perhaps even get rather angry about it. They don’t want us getting angry. Brendan Cox, husband of assassinated MP Jo Cox, tweeted in response to Farage’s comments “@NigelFarage blaming politicians for the actions of extremists? That’s a slippery slope Nigel.” (The truth must be shut down or it will lead to more angry white men assassinating more puppet politicians – so goes the reasoning.)

The Guardian:

In an interview with LBC radio Farage hit back saying the widower of the murdered Labour MP Jo Cox was himself tainted by extremism for supporting Hope Not Hate, which Farage called “violent and undemocratic”. Asked about the exchange on LBC soon afterwards, Farage accused Cox of links to extremism via Hope Not Hate, one of three charities supported by a foundation set up in the name of his late wife. Farage said: “Well, of course, he would know more about extremists than me, Mr Cox. He backs organisations like Hope Not Hate, who masquerade as being lovely and peaceful, but actually pursue violent and undemocratic means.”

Ouch! Oy vey! Nigel just took on the Jews!

https://dailystormer.red/hope-not-hate-threatens-to-sue-nigel-farage-another-jewish-anti-gentile-charity-rattles-the-collecting-tin/ 1/4 11/29/2017 Hope Not Hate Threatens to Sue Nigel Farage: Another Jewish Anti-Gentile Charity Rattles the Collecting Tin – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-11 Filed 11/30/17 Page 3 of 5

Hope Not Hate (HnH) run by (((Nick Lowles))) devotes in common with other such shady (((charities))) such as Searchlight, The Community Security Trust, and The Campaign Against Anti-Semitism, a sizable chunk of their time and their considerable wealth, (partly government funded – no surprises there), to distorting and shutting down the truth. In perhaps a sign of the times The Economist magazine a fervid supporter of (((the Globalist Agenda))) has recently even criticised HnH.

https://dailystormer.red/hope-not-hate-threatens-to-sue-nigel-farage-another-jewish-anti-gentile-charity-rattles-the-collecting-tin/ 2/4 11/29/2017 Hope Not Hate Threatens to Sue Nigel Farage: Another Jewish Anti-Gentile Charity Rattles the Collecting Tin – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-11 Filed 11/30/17 Page 4 of 5 Hope Not Hate also organise largescale distributions of scurrilous leaflets aimed against patriotic candidates standing in target wards, in an effort to tip the scales against them. They put out 3.5 million leaflets nationally in the 2009 Euro Elections and 350,000 in the Barking & Dagenham parliamentary seat when Nick Griffin stood there in 2010.

Criticism from of HnH is also coming from the left.

However, because the organisation itself does not stand in elections, such leafletting is actually illegal under British Law. But, as always, it is one law for (((them))) and one law for everyone else.

What, they and other similar groups are really notorious for, and primarily concerned with, be it noted, is following Saul Alinsky’s ‘Rules for Radicals’ to the letter, doing the sort of thing the Jews in Montana, Whitefish are doing to Richard Spencer’s mother – persecuting anyone who dares to speak out by tracking

down and publishing photos and details of them and their relatives, their workplaces and their homes. Information naturally lapped up by the wannabe Mossad types of (((Antifa))). Fear, intimidation and violence ensue for which Hope Not Hate refuse to take responsibility.

Hope Not Hate, in short could be said to specialise in fomenting Hate against those whose politics they disagree with, i.e. anyone who Hopes to start a discussion about Jewish power and the agenda that such power serves. Hope Not Hate – its not hypocrisy, its being creative with words – were described by Nigel Farage as extreme, violent and undemocratic, and there he hit the bullseye. Award the guy a medal!

On the wider theme of responsibility, referring to mad Merkel’s efforts to exterminate Germany through mass non-white immigration, Farage added: “And I’m sorry, Mr Cox, but it is time people started to take responsibility for what’s happened.”

Indeed. But responsibility? Liberals take responsibility? The whole point of Liberalism is that it does NOT take responsibility. Facts, consequences and reality are such horrid things, so un-pc, so illiberal!

Hope Not Fate have issued a statement on their website:

Statement: Nigel Farage LBC comments

We are aware of a serious and potentially libellous statement made about HOPE not hate by Nigel Farage on LBC radio this morning. We have no idea on what Mr Farage bases his outrageous comments. HOPE not hate has a proud history of campaigning against extremism and hatred.

We will not be making any further comment until we have had the opportunity to consult with our lawyers.

That’s what must be known as ‘chutzpah’. And never missing a chance to raise some shekels, the group

has launched a widely reported financial appeal to ‘’Help us to take Nigel Farage to court’, which ‘Time Out’ https://dailystormer.red/hope-not-hate-threatens-to-sue-nigel-farage-another-jewish-anti-gentile-charity-rattles-the-collecting-tin/ 3/4 11/29/2017 Hope Not Hate Threatens to Sue Nigel Farage: Another Jewish Anti-Gentile Charity Rattles the Collecting Tin – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-11 Filed 11/30/17 Page 5 of 5 – the online London events listing magazine – is backing.

Why is a supposedly non-political events listing magazine getting involved in politics? Well if you weren’t Daily Stormer readers I could say that it was another example of the metropolitan, metrosexual liberal elite ramming their own consensus and values down the hapless public’s throat and calling it ‘fashion’. But as you are Daily Stormer readers I’ll just say, as Edouard Drumont used to, ‘cherchez le juif’.

So what’s going to happen next? Not a lot. Except that Hope Not Hate will raise quite a bit of money. In this they are quite similar to ‘The Southern Loverty Not-So Poor Centre’ in the USA and hundreds of thousands of other con-men and con-artist organisations worldwide. You see it is all a bit of a scam. Hope Not Hate are an incorporated association, a shadowy trust fund type organisation supposedly registered in some tax haven in the Caribbean, very hard to follow the money in this case. And the truth is that an incorporated association cannot sue for libel; only individuals can do that. The vast sums of money they are no doubt now raising will not be used to sue Nigel Farage. They know that. But whenever have (((they))) bothered about the truth, let alone letting the truth get in the way of a good fund raising racket? The truth is such a horrid thing after all.

Twitter: @hopenothate

https://dailystormer.red/hope-not-hate-threatens-to-sue-nigel-farage-another-jewish-anti-gentile-charity-rattles-the-collecting-tin/ 4/4 Case 9:17-cv-00050-DLC-JCL Document 32-12 Filed 11/30/17 Page 1 of 4

EXHIBIT 12

Andrew Anglin post on Daily Stormer dated Dec. 27, 2016

David Duke and Andrew Anglin: The Jewish Attack on the White Race and the Coming Whitefish March – Daily Stormer 11/30/17, 11(36 AM Case 9:17-cv-00050-DLC-JCL Document 32-12 Filed 11/30/17 Page 2 of 4

David Duke and Andrew Anglin: The Jewish Attack on the White Race and the Coming Whitefish March

Andrew Anglin Daily Stormer December 27, 2016

I appeared this morning with Dr. David Duke, and we discussed the ongoing situation in Whitefish, Montana, where we see very clearly the microcosm of the global Jewish war on the white race. https://dailystormer.red/david-duke-and-andrew-anglin-the-jewish-attack-on-the-white-race-and-the-coming-whitefish-march/ Page 1 of 3 David Duke and Andrew Anglin: The Jewish Attack on the White Race and the Coming Whitefish March – Daily Stormer 11/30/17, 11(36 AM Case 9:17-cv-00050-DLC-JCL Document 32-12 Filed 11/30/17 Page 3 of 4

We discussed the fact that the Jews are the ones who initiated this attack on Richard Spencer’s mother, but they have then flipped it around that the people who caught them and complained about it are the aggressive attackers. We also discussed the fact that the Jews threatened a protest against Richard Spencer’s mother when they were extorting her, and this was simply “political activism” – yet when I plan a march with the sole purpose of drawing attention to Jewish criminality, the Jewish media calls me a “terrorist.”

The double standards are slapstick comedy levels of ridiculous.

Look at these stories.

Montana officials denounce planned neo-Nazi march – Politico

Montana Pols Condemn Neo-Nazis’ Threats Of Armed March On Ski Town – Talking Points Memo

Montana Lawmakers Repudiate Anti-Semitic Slurs – Roll Call

Neo-Nazis Are Planning an Armed March Against Jews in Richard Spencer’s Hometown – Slate

American Nazis Rising as Trump’s Armed Brownshirts to Target Jews – Politics USA

Neo-Nazis Organizing Armed March In Montana – IBT

Neo-Nazis plan armed protest in Montana against Jewish businesses – The Blaze

Montana faith leaders speak out in support of beleaguered Jewish community – The Times of Israel

Neo-nazi assholes seek to chase Jews from Whitefish, Montana – Boing Boing

Neo-Nazi website calls for armed march against Jews in Montana – Jerusalem Post

All of these publications and many, many more make me out to be the bad guy simply for standing up for an innocent woman attacked over the political beliefs of her son by an organized criminal cartel.

They aren’t even talking about Tanya Gersh anymore. She’s disappeared from the discussion. Now they are just acting like we are “harassing” Jews for no reason at all. It is patently absurd.

We have stated our reasons for opposing the Jewish “human rights” groups in Montana, and we have said that all we want is for Jewish groups to agree to stop harassing Richard Spencer’s mother and trying to interfere with her businesses as revenge against her son.

https://dailystormer.red/david-duke-and-andrew-anglin-the-jewish-attack-on-the-white-race-and-the-coming-whitefish-march/ Page 2 of 3 David Duke and Andrew Anglin: The Jewish Attack on the White Race and the Coming Whitefish March – Daily Stormer 11/30/17, 11(36 AM Case 9:17-cv-00050-DLC-JCL Document 32-12 Filed 11/30/17 Page 4 of 4

That’s all we want.

Period.

And yet, this isn’t even being discussed. It’s just “vicious evil Nazis attacking Jews for no reason.”

Who can possibly even imagine at this point that the media is anything other than an arm of Jewish terrorism?

Anyway, it was a great show today and I’d advise you to give it a listen.

We also talked about other issues involved in the Jewish agenda, including the war on Christmas and the war on our women.

Good stuff.

00:00 00:00

Download

By the way – businesses are back open today, so why not go give the supporters of Love Lives Here a call?

You have a duty, White Man!

Get to it!

Here is the current list of contacts we are protesting.

https://dailystormer.red/david-duke-and-andrew-anglin-the-jewish-attack-on-the-white-race-and-the-coming-whitefish-march/ Page 3 of 3 Case 9:17-cv-00050-DLC-JCL Document 32-13 Filed 11/30/17 Page 1 of 5

EXHIBIT 13

Andrew Anglin post on Daily Stormer dated Dec. 28, 2016

11/29/2017 Montana Officials Sign Letter Backing Jewish Racketeers Extorting Local Woman (ヘブライ犯罪陰謀) – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-13 Filed 11/30/17 Page 2 of 5

Andrew Anglin Daily Stormer December 28, 2016

Sen. Jon Tester has also recently denounced a proposed tax increase on cheeseburgers.

State lawmakers in Montana have released a statement backing a Jewish racketeering cartel in Whitefish involved in an extortion operation against a local woman.

https://dailystormer.red/montana-officials-sign-letter-backing-jewish-racketeers-extorting-local-woman-%E3%83%98%E3%83%96%E3%83%A9%E3%82%A4%E7… 1/4 11/29/2017 Montana Officials Sign Letter Backing Jewish Racketeers Extorting Local Woman (ヘブライ犯罪陰謀) – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-13 Filed 11/30/17 Page 3 of 5 Montana Sens. Jon Tester, a Democrat, and Steve Daines, a Republican, came together with Democratic Gov. Steve Bullock and GOP Rep. Ryan Zinke in an open letter to “fellow Americans” voicing support for Love Lives Here and attacking those who have voiced opposition to the group’s gangsterism as racist haters.

The lawmakers did not make specific reference to the group or realtor Tanya Gersh, who was serving as operating “street boss” running an extortion conspiracy targeting the mother of a perceived political opponent of international Jewry. Gersh threatened Sherry Spencer, mother of Richard Spencer, with a protest that she claimed would drive down the value of her property in Whitefish if she did not sell the property, denounce her son and make a “donation” to local human rights groups.

Gersh had provided Spencer with a pre-written apology/confession, which they asked her to read to the community. This practice is also popular among ISIS, which usually requires public execution victims to read aloud a scripted apology/confession before death.

https://dailystormer.red/montana-officials-sign-letter-backing-jewish-racketeers-extorting-local-woman-%E3%83%98%E3%83%96%E3%83%A9%E3%82%A4%E7… 2/4 11/29/2017 Montana Officials Sign Letter Backing Jewish Racketeers Extorting Local Woman (ヘブライ犯罪陰謀) – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-13 Filed 11/30/17 Page 4 of 5

It is believed that the officials failed to name Love Lives Here, their parent organization the Montana Human Rights Network or Tanya Gersh by name in the letter due to pending litigation against them. However, this raises questions about why state officials in Montana are voicing public support for a criminal operation, leading to accusations of endemic corruption in the state of Montana, where Jewish organized crime gangs are often perceived as having a stranglehold on the levers of power.

The letter comes after this website, The Daily Stormer, protested against the extortion operations of Love Lives Here against the family of Richard Spencer. When they were caught, and called out on their behavior, the Jews claimed that the people who were protesting against them were “threatening” them. https://dailystormer.red/montana-officials-sign-letter-backing-jewish-racketeers-extorting-local-woman-%E3%83%98%E3%83%96%E3%83%A9%E3%82%A4%E7… 3/4 11/29/2017 Montana Officials Sign Letter Backing Jewish Racketeers Extorting Local Woman (ヘブライ犯罪陰謀) – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-13 Filed 11/30/17 Page 5 of 5 The Daily Stormer’s planned protest through the streets of Whitefish, scheduled for mid-January, has garnered international attention over the past 24 hours, with the media claiming that we are the bad guys for standing up against this racketeering operation. I am happy with this, as we are not only exposing the local Jews in Montana, but exposing the Jewish control of the international media.

Tanya Gersh has already apparently been fired for carrying out the conspiracy against Mrs. Spencer, and she presumably will be sued and perhaps even criminally prosecuted for extortion. And yet somehow, we are the ones in the wrong, for simply demanding that the local Jewish groups vow to stop harassing family members of political dissidents.

I have gone so far as to offer to call off the march if we are issued an apology and a promise that moving forward, Sherry Spencer will not be targeted for the beliefs of her son. Instead of apologizing for wrongdoing, however, the crime syndicate has claimed that we are in the wrong, and has called the police.

In a related development, while the international Jewish media has taken interest in our Whitefish march – dubbed the “March on Whitefish” – so have nationalist groups across the country. So far, it looks like we will have representatives from at least three European nations marching with us in January, a sign of increasing global white racial solidarity against the international Jewish agenda to exterminate the white race through programs of mass immigration, feminism and the promotion of homosexuality.

https://dailystormer.red/montana-officials-sign-letter-backing-jewish-racketeers-extorting-local-woman-%E3%83%98%E3%83%96%E3%83%A9%E3%82%A4%E7… 4/4 Case 9:17-cv-00050-DLC-JCL Document 32-14 Filed 11/30/17 Page 1 of 5

EXHIBIT 14

Andrew Anglin post on Daily Stormer dated Jan 5, 2017

11/29/2017 March on Whitefish Moves Forward – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-14 Filed 11/30/17 Page 2 of 5

Andrew Anglin Daily Stormer January 5, 2016

As promised, we have filed our paperwork for the March on Whitefish, which is scheduled for January 16th, and carries the official title of the “James Earl Ray Day Extravaganza.”

We were initially planning to march to Tanya Gersh’s home, but we decided it would be too cold. We will instead simply march through the center of town, ending at a Memorial Park where several speakers will https://dailystormer.red/march-on-whitefish-moves-forward/ 1/4 11/29/2017 March on Whitefish Moves Forward – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-14 Filed 11/30/17 Page 3 of 5 speak.

I am also proud to announce that we have representatives from the nationalist groups from the UK, Sweden, France and Greece that will be attending.

I can also confirm that a representative of Hamas will be in attendance, and will give a speech about the international threat of the Jews.

Where is the ACLU?

During the barrage of media coverage, one thing which is notably absent is any comment from the ACLU. There was a time they would have been rushing out there to defend our rights in this situation – this has

https://dailystormer.red/march-on-whitefish-moves-forward/ 2/4 11/29/2017 March on Whitefish Moves Forward – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-14 Filed 11/30/17 Page 4 of 5 gotten very high-profile, with the governor and all of Montana’s congressmen denouncing our right to peacefully demonstrate.

And yet, the media doesn’t appear to be talking to the ACLU, and the ACLU has not contacted me to offer support.

Even ten years ago, the ACLU would have been all up on this. And the Jewish media is so ridiculous, they haven’t even bothered to call them up.

Sad!

Still No Apology or Denouncement from Gersh or Love Lives Here

All I have asked for is an apology and a vow to stop harassing Richard Spencer’s mother in the future. And

both Tanya Gersh and Love Lives Here have refused to do this.

This is absolutely insane, and shows the mentality of Jews. What Gersh did was in all likelihood criminal. She has been fired from her job for it, she will lose her real estate license and she is presumably going to be sued.

So this was objectively wrong, in the eyes of her employer, the real estate board and the state.

And yet, both she and Love Lives Here refuse to say it was wrong.

Instead, they brought the Jew ADL in to send me a bunch of copyright claims on photographs of the perpetrators.

So the march will go forward as planned.

Lion King Be Prepared 1080p HD

https://dailystormer.red/march-on-whitefish-moves-forward/ 3/4 11/29/2017 March on Whitefish Moves Forward – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-14 Filed 11/30/17 Page 5 of 5

And they will rue the day, as they see two hundred skinhead Alt-Right Nazis marching with a guy from Hamas carrying machine guns through the center of their town!

Hail Victory.

https://dailystormer.red/march-on-whitefish-moves-forward/ 4/4 Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 1 of 19

EXHIBIT 15

Lawrence Murray post on Daily Stormer dated Jan. 6, 2017

11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 2 of 19

Lawrence Murray Atlantic Centurion January 6, 2017

The current year is dead. Long live the current year.

2016 was the year the Alt-Right went big league. We became a household name to anyone following the election closely, spread our memes further than ever before, and witnessed the ascent of Donald J. Trump as the next president of the United States. We memed a shitlord billionaire into the White House and triggered millions of people worldwide. There was a dizzying amount of media coverage and habbenings in 2016, almost to the point where it became exhausting to stay involved. You’re going to get tired of winning, folks.

First though, some general trends over 2016:

In a display of impressive ineptitude, Hillary Clinton fails to move past her deleted emails scandal over the course of nine months.

The world sees a marked increase in integrity among video game journalists.

The plague of frogs crashes upon the shores of the Potomac.

Sam Hyde is reportedly sighted at a number of violent crime scenes.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 1/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 3 of 19 Semi-cucked commentators including Paul Joseph Watson and Steven Crowder label themselves “Alt- Right” but then drop the label as our brand recognition grows stronger.

Twitter bans a lot of people.

National Review Online discontinues Disqus comments in an attempt to stop Alt-Right raids on their site. Sad!

Thanks to the media’s mass coverage of the Alt-Right, The Right Stuff gets a permanent Wikipedia page with dozens of citations. Ditto the Alt-Right itself and the Triple Parentheses. We’re officially over the notability threshold now.

The Democratic Party succumbs to racism and xenophobia as it blames “the Russians” for costing them the election.

Many pool parties are held.

The Current Year Revisted:

Jan6 – Jeb Bush explains to a young New Hampshire resident that he keeps plastic turtles in his pockets.

“I give them out to kids. Slow, steady progress — that’s what that means,” he told reporters, as he pulled out more turtles from his pocket. “I have a bunch of turtles. I got the little baby Jesus, I got my rosary beads and I got three turtles.” (CNN)

Jan19 – Cuckservative “strategist” Rick Wilson denounces the Alt-Right as “childless single men who masturbate to anime.” But we president now.

Feb13– Supreme Court Justice Antonin Scalia passes away. The left expresses glee at the death of a conservative judge; Trump vows to appoint judges “in the mold of Scalia,” if when elected.

Mar5 – Lawrence Murray’s “seven pillars” of the Alt-Right article is published. No, I don’t regret including “autism” and a reference to Lothrop Stoddard in the title.

Mar16 – Aids Skrillex and Carl the Cuck confront a reporter with The Alex Jones Channel in St. Louis.

Mar23 – Microsoft launches their @TayAI chatbot on Twitter. Her tagline was, “Microsoft’s AI fam from the internet that’s got zero chill.” Tay was designed to learn, with Microsoft claiming, “the more you chat with Tay the smarter she gets, so the experience can be more personalized for you.”

Mar24 – TayAI is shoahed by Microsoft for becoming a /pol/ack.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 2/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 4 of 19

Mar24 – National socialist in exile weev sends a bunch of friendly fliers to university printers and fax machines. Hilarity ensues.

April – The Houston Goylers have their karaoke hall putsch.

May26 – The Daily Beast‘s Olivia Nuzzi publishes “How Pepe the Frog Became a Nazi Trump Supporter and Alt-Right Symbol,” taking everything @JaredTSwift and @PaulTown_ told her at face value:

“In a sense, we’ve managed to push white nationalism into a very mainstream position,” he said. “Trump’s online support has been crucial to his success, I believe, and the fact is that his biggest and most devoted online supporters are white nationalists. Now, we’ve pushed the Overton window. People have adopted our rhetoric, sometimes without even realizing it. We’re setting up for a massive cultural shift.”

May30 – Rodrigo Duterte is elected president of the Philippines, memeing right-wing death squads into reality. Helicopter rides for degenerates are also memed into reality.

June1 – The Coincidence Detector is taken down from Google Chrome’s addon library after clickbait site Policy Mic draws attention to it. The addon, which was made by a TRS goy, placed triple parenthesis brackets around Jewish names found on websites. Mic ran several articles on it where they quoted our troll response to their emails, in which one of our goys described how each set of brackets represented a different layer of semitic subversion. As a result, the (((ADL))) added our punctuation to their hate symbol database. Also, Jews and other leftists began to bracket their names on social media as a sign of solidarity against nazis or something. So now if you go on Twitter, you’ve got all these Jewish and philosemitic accounts now marking themselves with parentheses, as a way of doing what they think is “taking back” the symbol from evil internet trolls. We’ve gotten them to wear yellow stars and they think they’ve won. You know who had the parentheses on his account before he took the whole thing down? Disgraced New York congressman and degenerate pervert Anthony Weiner. What a fine representative of what we’re trying to highlight. And he did it for us.

June10 – Lawrence Murray is quoted in the New York Times on how the Alt-Right is “winning the meme war.”

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 3/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 5 of 19 June12 – The Orlando nightclub shooting claims the lives of 100, 120 guys. Two or three troll a Brazilian newspaper in the morning:

Thanks to 504rum user Featherman for translating the huehue-speak:

“I was on the dance floor, with 100 or 120 guys, when we heard gunshots. My reaction was to shout ‘Oh my god! It’s happening!’ I threw myself on the floor and crawled to the backdoor. I didn’t see the shooter”, told John Eden to the Correio, 26 years old. “I saw two or three guys wounded in the corner, and tried to crawl outside the fastest I could. I heard around 14 gunshots. It was a very loud noise and my adrenaline was pumping”, added the Orlando resident, who suffered a lesion on the shoulder.

More memes:

A cook in a restaurant of the Applebee’s network, Marlon Lincoln Patterson, 26, had just left the nightclub momentarily when he hard a “loud clack”. “I couldn’t see the shooter because he was far away. But I heard someone shout many times ‘Only one solution here to be honest’. I saw people running toward the exit,” he told our reporter.

Survivor’s testimonials:

John Eden 26 years old, accountant

“There were many gunshots. It was a really loud noise, louder than the music. I remember only wanting to get out of there. When I arrived home, first thing I did was call my rabbi. Now I know how my grandparents felt. They survived the war, the Holocaust and the nazis. It’s terrible.”

Marlon Lincoln Patterson 26 years old, cook

“I went to the nightclub by my own initiative, I wasn’t familiar with the place. I was outside, hugging someone, when the assassin entered. Everything seemed to be going well, until I heard a loud snap. People seemed very confused at first moment, and things got heavy quickly.” https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 4/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 6 of 19 June15 – Intersectional Alt-Right starts podcasting as Alt-Right Fights and grows to be the number one TRS show on the sound clouds after Fash the Nation and The Daily Shoah (again) were shoahed.

June18 – Chad nationalism is born in Arizona when a Trump supporter demands a Trump protestor make him a burrito.

June19 – A britcuck attempts to assassinate Donald Trump in Chicago.

June23 – #Brexit referendum takes place with a slim Leave majority, as Britain votes to separate from the European Union.

July7 – The 2016 Ramadan Bombathon comes to a close with hundreds of deaths.

July7 – Dindu terrorism in Dallas.

July14 – An angry North African man goes for the high score in France… using a cargo truck. 86 are killed and 434 injured. The French prime minister tells his country they must “live with terrorism.”

July18 – A Trump supporter wears a “Cuck Hunt” t-shirt while open-carrying at the RNC.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 5/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 7 of 19

July19 – Richard Spencer shows up in Cleveland for the RNC with a cheeky sign and talks to reporters:

As he told one of his incredulous interlocutors in the Public Square, he believes that race “is the foundation of culture, society, politics, and identity.” He dreams of a white ethno­state, which will allow white people “to unlock our potential. And that is the exploration of the universe. That is the unlocking of our Faustian will.”

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 6/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 8 of 19

July20 – Breitbart News executive Steve Bannon describes his site as “the platform for the Alt-Right.”He is now White House chief strategist for President Trump.

July21 – Alex Jones trolls ‘The Young Turks’ into apoplectic rage on camera.

July21 – Trump accepts the nomination of the Republican party and gives a speech portraying himself as the redeemer.

July25 – Wikileaks goy Julian Assange tweets about “establishment climbers” with thick rimmed glasses and parentheses around their names. He quickly realizes what he’s done and delets this:

“Tribalist symbol for establishment climbers?” said a Wikileaks tweet on Saturday. “Most of our critics have 3 (((brackets around their names))) & have black­rimmed glasses. Bizarre.”

July26– r/altright does its first AMA with American Renaissance‘s Jared Taylor.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 7/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 9 of 19 July26 – The Battle of Sacramento takes place between antifa and skinhead groups affiliated with the Traditionalist Workers Party.

July28 – Clinton accepts the nomination of the Democratic party ,which she had been yugely favored to win all along, and gives a cucked speech that amounts to putting lipstick on the Weimerican pig:

We have the most dynamic and diverse people in the world. We have the most tolerant and generous young people we’ve ever had. We have the most powerful military. The most innovative entrepreneurs. The most enduring values. Freedom and equality, justice and opportunity. We should be so proud that these words are associated with us. I have to tell you, as your Secretary of State, I went to 112 countries, and when people hear those words – they hear America.

Aug5 – First episode of Million Dollar Extreme’s World Peace airs.

Aug14 – “Esoteric Kekism, or Kek as a Bodhisattva of Racial Enlightenment” is published. The mimesis of Savitri Devi’s The Lightning and the Sun proves to be the year’s most read article on Atlantic Centurion.

Aug22 – Shitlib clickbait website Gawker is shoahed due to bankruptcy wrought by wrestler Hulk Hogan’s

lawsuit, which was bankrolled by Silicon Valley billionaire and anti-hero Peter Thiel.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 8/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 10 of 19 Aug23 – A reporter from The Guardian quotes TRS’s Mike Enoch without spin and portrays the Alt-Right as a movement with “a sense that White identity is under attack.” Probably one of the best mainstream media pieces on the Alt-Right.

Aug24 – A screenshot of TRS is shown on CNN, with a tharrupost on the homepage.

Aug25 – Clinton dedicates an entire campaign speech to denouncing the Alt-Right. Alas we are lumped with a certain water filter salesman. During the speech, an audience member shouts “Pepe!” and is promptly removed. Clinton also used the phrase “White genocide.” I don’t know about you, but I was never expecting the Democratic party to be the one to pick up on the Alt-Right. Or their nominee to dedicate a half hour speech to hand-wringing about us.

Sept1 – Donald Trump gives an excellent immigration policy speech in Arizona.

We’ve admitted 59 million immigrants to the United States between 1965 and 2015. Many of these arrivals have greatly enriched our country. So true. But we now have an obligation to them and to their children to

control future immigration as we are following, if you think, previous immigration waves.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 9/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 11 of 19 We’ve had some big waves. And tremendously positive things have happened. Incredible things have happened. To ensure assimilation we want to ensure that it works. Assimilation, an important word. Integration and upward mobility.

Within just a few years immigration as a share of national population is set to break all historical records. The time has come for a new immigration commission to develop a new set of reforms to our legal immigration system in order to achieve the following goals.

To keep immigration levels measured by population share within historical norms. To select immigrants based on their likelihood of success in U.S. society and their ability to be financially self- sufficient.

We take anybody. Come on in, anybody. Just come on in. Not anymore.

Sept5 – Claremont publishes the Flight 93 election article, a widely read “conservative” case of sorts for voting Trump that went above and beyond ordinary punditry.

Sept7 – Fash the Nation co-host Jazzhands McFeels does an AMA on r/altright.

Sept9 – Hillary Clinton gives the “basket of deplorables” speech to a bunch of wealthy Manhattanite donors. Chattering classes agree that everyone they don’t like is an evil racist sexist. Normie conservatives are outraged at her denouncing a fourth of the country as irredeemable un-American bigots. The Alt-Right can barely conceal their shit-eating grins.

Sept11 – Meme fuel melts muscle beams. Hillary Clinton has to leave a memorial service at Ground Zero because of “heat exhaustion,” and is caught on video collapsing into her footprint.

Sept14 – Hillary Clinton’s campaign website puts up an explainer about how “sinister” Pepe the Frog is.

Sept14 – The Right Stuff‘s Mike Enoch does an AMA on r/altright.

Sept17 – Three bombs go off and several explosives are found in New York and New Jersey, planted by an Afghan refugee.

Sept21 – Ricky Vaughn does an AMA on r/altright.

Sept27 – Pepe the Frog is labeled a “hate symbol” by the (((ADL))), placing him in the company of the swastika, runes, and the numbers 14 and 88. Yeah, a cartoon frog. Can you imagine leftists sitting around trying to explain to one another or to normies that frogs are symbols of so-called White supremacy and

neo-nazism? Isn’t that just the stupidest thing you’ve ever heard?

Sept28 – Kevin MacDonald, editor of The Occidental Observer does an AMA on r/altright. https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 10/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 12 of 19 Sept30 – (((Elie Wiesel))), Holocaust evangelist and author, dies. The French and Hebrew editions of the book read by millions of American highschoolers, Night, omits passages where escaped camp inmates rape female German civilians.

Sept30 – CNN makes their own Pepe.

Oct5 – The Alt-Right’s Ricky Vaughn, an MIT-cited election influencer, is banned from Twitter.

Oct6 – After “racist” flyers appear on the University of Michigan’s campus, the administration blows $85 million on a diversity initiative. Affirmative action is currently banned in public universities in the state.

Oct10 – The second presidential debate is held and Bill Clinton is mortified by Trump’s references to rape accusations against him.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 11/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 13 of 19

Oct14 – Matt Furie, the cartoonist who created Pepe, teams up with the (((ADL))) to denounce the use of Pepe as a “hate symbol,” in a failed Twitter campaign called #SavePepe.

Oct14 – Fash the Nation, no. 1 Republican podcast on the sound clouds, is shoahed from the platform.

Oct15 – Lawrence Murray’s article “Why Donald Trump is the Anti-War Candidate” is reposted at ZeroHedge, Lew Rockwell, etc., and Stefan Molyneux reads excerpts in a video.

Oct25 – Abki baar Trump sarkar

Oct26 – Alex Jones finally acknowledges a Jewish mafia exists.

Nov6 – The 40s-and-weed-at-the-polls troll is an Alinskyite success. Politico reports it in full:

Neo­Nazi leader Andrew Anglin plans to muster thousands of poll watchers across all 50 states. His partners at the alt­right website “the Right Stuff” are touting plans to set up hidden cameras at polling places in Philadelphia and hand out liquor and marijuana in the city’s “ghetto” on Election Day to induce residents to stay home.

A “representative” of TRS was quoted:

“We also have some teams going in to the ghettos in Philly with 40s and weed to give out to the local residents, which we think will lead to more of them staying home. We have had success with this in the past,” wrote the representative of TheRightStuff.biz, who said four teams of two employed this tactic in Detroit during the Democratic primary in an effort to help Bernie Sanders. “40s” are 40­ounce bottles of malt liquor. POLITICO could not independently verify his claims.

Nov8 – Donald J. Trump is elected President of the United States.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 12/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 14 of 19

Nov14 – Murdoch Murdoch releases their video, The Great Meme War.

See also, Encyclopedia Dramatica‘s take:

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 13/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 15 of 19 Nov14 – Sam Hyde bullies a Jewish Buzzfeed “journalist” who made a point of trying to get World Peace cancelled. His life’s greatest literary achievement was to write a hit piece no one will even remember in a year. [Reupload]

Nov16 – Lawrence Murray does an AMA on r/altright.

Nov19 – Salutegate: A cheer of “Hail Trump, Hail our people, Hail Victory” and a friendly wave at the NPI conference spark a minor flurry of counter-signaling, only to lead to more press coverage and no harm done at all.

Nov21 – The sister of Facebook co-founder and CEO (((Mark Zuckerberg))) writes an article expressing concern that the Alt-Right likes classical civilization. In her view, interpreting Greece and Rome as the foundations of Western civilization is “a slippery slope to White supremacy,” and students of the classics should be discouraged from thinking in those terms. I wonder why an overseas Israeli is so interested in deconstructing White history and identity…

Nov25 – Communist dictator Fidel Castro dies.

Nov26 – Sam Hyde responds to the charge that secret Nazi symbols were in World Peace.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 14/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 16 of 19 Dec3 – “Anomie, Anime, and the Alt-Right” is published, combing weapons-grade autism with cutting social commentary. Commended by the neo-reactionary movement as article of the week. Your author has also heard a reading of it done by a friend’s mother.

Dec5 – Jason Reza Jorjani, editor in chief of Arktos, is targeted for academic purging based on his involvement with NPI. An article is published by Inside Higher Ed exposing many people to the novel idea that the first “white genocide” took place in Persia.

Dec5 – Shitlords, family, and friends raise nearly $15,000 to help victims of wildfires in the Appalachia region. #AmericaFirst

Dec5 – MDE’s World Peace is cancelled by Adult Swim‘s skype management.

Dec6 – Richard Spencer bullies fat people and rabbis at a speaking event held at Texas A&M University. Here Spencer embraces the Chad mindset and takes on the form most terrifying to our enemies: the preppy White male with illiberal views. (Forward article) (NY Times responds)

Dec7 – Emily Youcis, YouTube animator and Philadelphia’s “Pistachio girl,” is terminated from her job

because of her involvement with NPI.

Dec8 – Opening of 504rum registrations. https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 15/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 17 of 19 Dec8 – Paul Nehlen, a congressional candidate who lost to incumbent cuck Paul Ryan, does an AMA on r/altright.

Dec9 – Jared Wyand is shoahed off Twitter after going full JQ on his feed.

Dec15 – Closing of 504rum registrations.

Dec15 – Supposedly, “@jew_goldstein” causes (((Kurt Eichenwald))) to have a seizure on Twitter and his wife reports it to the police.

Dec16 – Harassment and extortion of Richard Spencer’s mother by Jewish activists. Proving that there is always a profit to be made, Montana realtor (((Tanya Gersh))) had the gall to suggest Richard’s mother do

the following:

1. Denounce her son (as opposed to just disavowing his beliefs, which she did)

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 16/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 18 of 19 2. Sell the building and make “a donation to human rights efforts” (after threatening to organize protests outside the property, which would lower its value)

Dec19 – Trump wins the formal electoral college vote by a margin of 77 with 304 votes in total (3+4=7), due to 7 faithless electors. He will also be 70 years, 7 months, and 7 days old on his first full day in office:

Donald Trump was born on June 14, 1946. If you move ahead 70 years from that date, that brings you to June 14, 2016. Moving forward another seven months brings you to Jan. 14, 2017, and moving forward another seven days brings you to Jan. 21, 2017.

Dec22 – Syrian president Bashar al-Assad reconquers all of Aleppo, in time for Christmas. Jingocucks are outraged and call for more blood to be spilled in the name of dead terrorists.

Dec23 – Upstate NY Republican Carl Paladino makes these off-color comments about people of color in an interview about what he would like to see in 2017:

“Obama catches mad cow disease after being caught having relations with a Herford. He dies before his trial and is buried in a cow pasture next to Valerie Jarret, who died weeks prior, after being convicted of sedition and treason, when a Jihady cell mate mistook her for being a nice person and decapitated her.”

“Michelle Obama. I’d like her to return to being a male and let loose in the outback of Zimbabwe where she lives comfortably in a cave with Maxie, the gorilla.”

He knows about Michael Obama? I guess Paladino listens to Knock Off.

Dec25 – People are saying Merry Christmas again.

Dec26 – Alt-Liter Baked Alaska graduates to the Alt-Right and embraces the JQ, leading health

supplements retailer GNCernovich to birch him from a pro-Trump event. Does an AMA on r/altright.

Dec31 – The age of cucks is over, the time of the shitlord has come. We now enter the Kali Yuge.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 17/18 11/29/2017 Alt-Right 2016: The Current Year in Review – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-15 Filed 11/30/17 Page 19 of 19

Thanks to Tharru, Jayoh, WaterFilterMerchant, Eric Patton, charles martel, Karl North, Bigly Hail Victory!, Christine Marat, SecretSantaSkippy, Producer Kenny, Cat Larp’ as Tiger, Berlusconi Fever, Caerulus Rex, Don’t Step Snek, Featherman, Ignis Faatus, the TRS 504rum, Daily Stormer, Encyclopedia Dramatica, and other deplorable sources for help in assembling this Current Year in Review.

https://dailystormer.red/alt-right-2016-the-current-year-in-review/ 18/18 Case 9:17-cv-00050-DLC-JCL Document 32-16 Filed 11/30/17 Page 1 of 3

EXHIBIT 16

Ben Richards post on Daily Stormer dated Jan. 8, 2017

11/29/2017 JDL Kike Terrorist Meir Weinstein Threatens to Kick Richard Spencer’s Head In – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-16 Filed 11/30/17 Page 2 of 3

Ben Richards Daily Stormer January 8, 2017

This fat Jew terrorist Meir Weinstein has threatened physical harm to Richard Spencer!

The Jew Meir Weinstein representing the Jewish terrorist organization known as the Jewish Defense League, has threatened physical violence against NPI’s Richard Spencer. The threat comes in light of a planned march in Whitefish, Montana to support Spencer after his mother was illegally harassed by Jewish racketeers.

Jewish Daily Forward:

The Canadian branch of the Jewish Defense League is prepared to mobilize in Whitefish, Montana, where neo­ Nazis are planning an anti­Jewish march on Martin Luther King Jr. Day — and do whatever it takes to “smash the Nazis.”

“We would be more than wiling to help in any way,” said Meir Weinstein, national director of Canada’s JDL. The FBI has designated the U.S. branch of the movement a terrorist organization.

Weinstein, who calls himself a “loyal disciple” of the JDL’s founder, the firebrand Jewish nationalist Meir Kahane, called “alt­right” figurehead Richard Spencer a Nazi.

“That guy’s going to get his head kicked in. He’s a Nazi, this guy’s a Nazi,” Weinstein said of Spencer in a phone interview.

Canadian authorities should immediately investigate these terrorist threats from this Jew. I would go so far as to say that he should be arrested for inciting violence and terrorism. If for some reason Canadian https://dailystormer.red/jdl-kike-terrorist-meir-weinstein-threatens-to-kick-richard-spencers-head-in/ 1/2 11/29/2017 JDL Kike Terrorist Meir Weinstein Threatens to Kick Richard Spencer’s Head In – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-16 Filed 11/30/17 Page 3 of 3 law enforcement doesn’t do anything about this, I would encourage American immigration personnel to ban this Jew from entering the United States. He has announced his intention to visit the country just to kick someone’s head in. If that isn’t terrorism, than I don’t know what is.

Meir Weinstein is the Jewish version of Jabba the Hut! lol

Even if he somehow manages to cross the border and gets to Whitefish, he won’t be kicking anyone’s head in. Just look at the pictures of this obese Jewish rat. He’d probably collapse of a heart attack if he spent more than 30 seconds on a treadmill.

This whole situation is hilarious. These Jews can’t even admit that what their people did to Spencer’s mother was wrong. They are biologically incapable of admitting that their people could ever be at fault for something. If these Jews actually do end up visiting Whitefish to stir up trouble, it will only further highlight the disgusting and degenerate behavior of the Jew that much more.

https://dailystormer.red/jdl-kike-terrorist-meir-weinstein-threatens-to-kick-richard-spencers-head-in/ 2/2 Case 9:17-cv-00050-DLC-JCL Document 32-17 Filed 11/30/17 Page 1 of 7

EXHIBIT 17

Andrew Anglin post on Daily Stormer dated Jan. 8, 2017

11/29/2017 World Jewish Congress President Demands Montana Shut Down Stormer Nazi March on Whitefish! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-17 Filed 11/30/17 Page 2 of 7

Andrew Anglin Daily Stormer January 8, 2017

“Extravaganza” is not a word I use lightly.

The stinking rat Jews of the World Jewish Congress have demanded that the state of Montana act to crush the free speech of the white race, who they fear is standing up to their evil shenanigans!

Ronald Lauder, top Jewish weasel, released the following press statement on our planned march on Whitefish against the Jews, which is to take place on January 16th, a day internationally recognized as a celebration of the life of James Earl Ray.

WJC:

World Jewish Congress President Ronald S. Lauder is demanding that authorities in Montana immediately put a stop to an armed march being planned by neo­Nazis in the town of Whitefish on January 15, calling it “a dangerous and life­threatening rally that puts all of America at risk.”

“When notorious and self­professed neo­Nazis announce that they are planning to march through a town carrying ‘high­profiled rifles’ in an action targeting ‘Jews, Jewish business, and everyone who supports either,’ the local authorities must respond with quick alarm and vigilance.

“This rally crosses the line between freedom of expression and incitement to hatred. The intention of these neo­ Nazis is not just to send a political message – they are organizing a dangerous and life­threatening rally that puts all of America, including the local Jewish community, at risk. There has been an upturn of late in public expressions of anti­Semitism and hatred of the other. It is unacceptable, and unfathomable, that such incidents could happen in America. https://dailystormer.red/world-jewish-congress-president-demands-montana-shut-down-stormer-nazi-march-on-whitefish/ 1/6 11/29/2017 World Jewish Congress President Demands Montana Shut Down Stormer Nazi March on Whitefish! – Daily Stormer “When neo­Nazis planned their march through Skokie in 1977, to spit in the face of Holocaust survivors, theCase 9:17-cv-00050-DLC-JCL Document 32-17 Filed 11/30/17 Page 3 of 7 Illinois Supreme Court ruled after months of debate that it would be unconstitutional to stop them. The counter­ response was deafening: Only a few dozen Nazis came out to protest, met by hundreds of Jews and their supporters.

“But the circumstances in Montana, and in the America of today, are different. In Montana today, it is legal to openly carry a weapon. And the America of today has seen far too many mass and targeted shootings of innocent people, far too many expressions of violent bigotry and lethal hatred, to sit by quietly and debate the constitutional right of armed militants to march against the Jewish people and ‘anyone that supports’ them.

“All around the world, from the Jobbik Party in Hungary to the Golden Dawn in Greece, fascism is on the rise. Anti­Jewish, anti­Muslim, and anti­Black incidents are jumping at alarming rates.

“Inflammatory rhetoric on the part of White Supremacists, whether targeting Jews, Blacks, Muslims or any other minority, can all too easily turn into incitement to violence and worse. ‘Constitutional’ hate speech can far too easily turn into unspeakable atrocities.

“We cannot allow the horrific massacres that occurred just recently – nine murdered in cold blood at a Charleston church, 49 lives ruthlessly wiped out at an Orlando night club – to replicate themselves in Whitefish. We must stop this rally from taking place and prevent a hate crime from happening before it even becomes a possibility. When we send the message that anti­Semitism is acceptable, it becomes acceptable. America is a beacon of tolerance – it cannot let itself become a beacon of hatred.”

The rally is being organized by The Daily Stormer, a neo­Nazi website, and is set to coincide with Martin Luther King Day. The World Jewish Congress, American Section, has sent a letter to Montana Governor Steve Bullock demanding that the rally be stopped.

So far, TOP CUCK Bullock has issued no such order. Presumably, because it is impossible.

We are well within our rights to march against these kikes – and march we shall!

Because, as of yet, we have been given no apology for the targeting of Richard Spencer’s mother by organized global Jewry.

But hey – if you had any question as to the whole “organized global Jewry” concept, then I guess that’s gone, huh?

Here you have the head of the preeminent global Zionist-Jew group, Ronald S. Lauder, rushing to defend a random Jewish extortion artist, Tanya Gersh, who has already been fired and has pending litigation against her for her racketeering activities!

https://dailystormer.red/world-jewish-congress-president-demands-montana-shut-down-stormer-nazi-march-on-whitefish/ 2/6 11/29/2017 World Jewish Congress President Demands Montana Shut Down Stormer Nazi March on Whitefish! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-17 Filed 11/30/17 Page 4 of 7

tfw the goyim know

In response to this outrageous, stupid demand from the Jews, we here at the Daily Stormer are making the extremely reasonable demand that Montana ban Jews.

There is absolutely no logical or even close to logical reason for allowing Jews in a city, state or nation. In fact, there is no real reason to allow Jews on the planet earth.

I have been speaking with our anti-Jew comrades in Hamas, as we prepare to join hands in Whitefish and march against the Jews, and you just can’t even believe what these poor bastards are dealing with over there.

These Jews in Israel are just running around killing babies left and right!

They took their land!

Just went ahead and straight jacked it! https://dailystormer.red/world-jewish-congress-president-demands-montana-shut-down-stormer-nazi-march-on-whitefish/ 3/6 11/29/2017 World Jewish Congress President Demands Montana Shut Down Stormer Nazi March on Whitefish! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-17 Filed 11/30/17 Page 5 of 7 Can you believe it???

No wonder they’re so angry!

And if the Jews of Love Lives Here and The Montana Human Rights Network get a chance, they’re going to do to the people of Montana the same thing the Jews of Israel are doing to the Palestinians: slaughter them like dogs!

Montanans best wise up and get rid of these Jews before the hammer comes down and they end up getting their hospitals and markets destroyed by Jewish airstrikes!

Today, Gaza – Tomorrow, Montana???

Listen up, Montana: Jews will also use white phosphorous and other chemical weapons banned under

international law against you, as soon as they get a chance!

Time to wise up! https://dailystormer.red/world-jewish-congress-president-demands-montana-shut-down-stormer-nazi-march-on-whitefish/ 4/6 11/29/2017 World Jewish Congress President Demands Montana Shut Down Stormer Nazi March on Whitefish! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-17 Filed 11/30/17 Page 6 of 7 Montana Standard:

In fact, the police chief said the city can place a condition that no loaded weapons be part of the event.

Thursday, The Daily Stormer posted a copy on its website of an “application for special event” permit signed and dated Jan. 2, 2017. The event was proposed for Jan. 16, Martin Luther King Jr. Day, and titled with the name of King’s assassin, the “James Earl Ray Day Extravaganza.”

“You gotta give the guy credit for having a little bit of creativity, as vile as it might be,” Chief Dial said.

Thanks, Chief.

Dial seems like a pretty cool guy, and I don’t think he’s going to block us from keeping our weapons LOADED.

Along with the stated representative of Hamas, and representatives from France, UK, Germany and Greece, we are also proud to announce that the march will feature a member of the Iranian Revolutionary Guard, who will be giving a speech updating American Alt-Right Nazis on how the country plans to thwart Israel and liberate the Palestinian people.

Currently, we have 178 skinheads being bussed in from the Bay Area on 6 large buses. Including international representatives, we will have a total of around 225 people marching through the city, though only about a third will be armed with machine guns. Others may carry baseball bats or swords, we haven’t decided yet.

I want to note that I have still not been contacted by the ACLU, indicating that this organization is now

100% a lapdog of the international Zionist hate machine.

We’re kicking 2017 off with a BANG!

https://dailystormer.red/world-jewish-congress-president-demands-montana-shut-down-stormer-nazi-march-on-whitefish/ 5/6 11/29/2017 World Jewish Congress President Demands Montana Shut Down Stormer Nazi March on Whitefish! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-17 Filed 11/30/17 Page 7 of 7 And no, Jews, not the bang of guns. This is a 100% peaceful march. To insure that, we’re only allowing EXTREMELY VETTED skinheads and others to attend. We recognize the seriousness of all that could go wrong, but unlike the insane Jews who just run around doing anything to get money and Jew the goyim, we are responsible people.

This is the BANG of the goyim waking up and taking a stand against our RATFACED overlords!

The BANG of JUSTICE arisen!

Hail Victory.

https://dailystormer.red/world-jewish-congress-president-demands-montana-shut-down-stormer-nazi-march-on-whitefish/ 6/6 Case 9:17-cv-00050-DLC-JCL Document 32-18 Filed 11/30/17 Page 1 of 2

EXHIBIT 18

David Duke post on Daily Stormer dated Jan. 10, 2017

11/29/2017 The David Duke Show: Exposing Jewish Supremacism with Richard Spencer – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-18 Filed 11/30/17 Page 2 of 2

David Duke January 10, 2016

Today Dr. Duke had National Policy Institute Director Richard Spencer has his guest for the hour. They talked about the aspect of Judaism as being a monotheistic, yet tribalistic religion that reserves to Jews alone a direct relationship with God. They talked about the hypocrisy of universal Jewish support for the ethno-state of Israel, while at the same time Jewish organizations leading non-white and non-Christian immigration into every nook and cranny of America and other traditionally white Christian country.

Richard Spencer also updated listeners on the efforts by Jewish extremists to wreck and extort money from his mother’s business in Whitefish, Montana as a means of silencing Richard’s own voice.

This is another great show that will fascinate you. Please share it widely.

00:00 00:00

Download

https://dailystormer.red/the-david-duke-show-exposing-jewish-supremacism-with-richard-spencer/ 1/1 Case 9:17-cv-00050-DLC-JCL Document 32-19 Filed 11/30/17 Page 1 of 4

EXHIBIT 19

Andrew Anglin post on Daily Stormer dated Jan. 10, 2017

11/29/2017 Whitefish Local Government Attempting to Cockblock Stormer March! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-19 Filed 11/30/17 Page 2 of 4

Andrew Anglin Daily Stormer January 10, 2017

The local government of Whitefish, Montana, where we have been planning to have an armed Neo-Nazi march against local Jewish terrorists, have attempted to cockblock us by denying our permit based on some alleged technicality.

In response to our permit request, Whitefish City Manager Chuck Stearns sent us a letter demanding all

sorts of outrageous things must be done before we are issued our permit.

I will not be calling that number (406-863-1582), and instead have contacted the ACLU and asked them to

do it. You can also try calling him if you want, just to see what’s up.

https://dailystormer.red/whitefish-local-government-attempting-to-cockblock-stormer-march/ 1/3 11/29/2017 Whitefish Local Government Attempting to Cockblock Stormer March! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-19 Filed 11/30/17 Page 3 of 4 The fact that they are denying the permit at all shows that they are not serious people, and are attempting to jerk us around.

As to his points:

1. We did include a map.

2. This is petty, but if they want an extra $65, that’s fine. I could just as easily give them the cash on Monday.

3. Demanding insurance is a crazy new requirement. That was not part of the deal, and I don’t believe they are allowed to force this obscure thing on us.

4. This is also a new requirement. We were never told we would have to notify any businesses.

We will fight this. We will have our march.

Regrettably, as I don’t want to see mass arrests and chaos on the streets, it looks like we may have to reschedule the event for sometime in February, as we work with our lawyers and the lawyers of the ACLU (I hope) to ensure our rights are not violated, and that we are allowed to march.

Clearly, a Neo-Nazi march involving hundreds of armed skinheads is something that has to be dealt with carefully, and I’m not going to try and have the march until my permit is issued. Or, at least until my lawyers have assured me it can be done legally and without incident with no permit.

Whitefish authorities purposefully waited until the last minute before sending these weird extra requirements so we wouldn’t have the time to figure it out. I am going to try to figure it out and do as planned on Monday, but this is going to be difficult and it is likely we will have to reschedule.

I will be making the decision about rescheduling by tomorrow morning. I have contacted the company through which I am chartering the buses to transport the skinheads from the Bay Area, and they have assured me that for a relatively small fee I can reschedule the trip if need be, but I need to let them know by Wednesday.

This really throws a wrench in the works, as we also have people flying in from all over the world to take part in the march, and their flights will have to be rescheduled.

But we shall prevail.

Nothing can stop us.

We will have our march, whether it is on James Earl Ray Day, or sometime later this year. https://dailystormer.red/whitefish-local-government-attempting-to-cockblock-stormer-march/ 2/3 11/29/2017 Whitefish Local Government Attempting to Cockblock Stormer March! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-19 Filed 11/30/17 Page 4 of 4

Hail Victory.

https://dailystormer.red/whitefish-local-government-attempting-to-cockblock-stormer-march/ 3/3 Case 9:17-cv-00050-DLC-JCL Document 32-20 Filed 11/30/17 Page 1 of 3

EXHIBIT 20

Andrew Anglin post on Daily Stormer dated Jan. 11, 2017

11/29/2017 March on Whitefish to be Postponed After Jewish Trickery – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-20 Filed 11/30/17 Page 2 of 3

Andrew Anglin Daily Stormer January 11, 2017

I have spoken at length with my lawyers – though the ACLU has yet to respond to my inquiry – and we’ve decided that due to the permit refusal by the city of Whitefish, we will need to postpone the planned march.

We will of course be rescheduling, probably for some time in February, and the march will be bigger and have more guns and special guests than we originally planned.

If we have to, we will march without a permit, but to do that on short notice is problematic.

It also appears that we probably have a lawsuit, given that their demand that we seek approval from every business on the march route violates our Constitutional rights.

Winning a federal lawsuit against the city would be an even bigger victory than the march itself.

I was greatly looking forward to confronting the state-sponsored “resistance.”

Look at these faggots.

https://dailystormer.red/march-on-whitefish-to-be-postponed-after-jewish-trickery/ 1/2 11/29/2017 March on Whitefish to be Postponed After Jewish Trickery – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-20 Filed 11/30/17 Page 3 of 3 (Official) Whitefish, MT Armed Fascist March. Jan. 16.

[deleted]

r/socialism • [deleted] • 10m ago 152 points • 28 comments

Can you believe they have the nerve to pretend they are rebels, as they come out to support the state and the most powerful people in the world against a people’s populist movement?

Are they not ashamed of being such complete tools?

If they want to defend the Jews, they should go join the IDF.

https://dailystormer.red/march-on-whitefish-to-be-postponed-after-jewish-trickery/ 2/2 Case 9:17-cv-00050-DLC-JCL Document 32-21 Filed 11/30/17 Page 1 of 4

EXHIBIT 21

Andrew Anglin post on Daily Stormer dated Jan. 18, 2017

11/29/2017 Communists and Anarchists Converge on Whitefish to Defend World’s Richest Ethnic Group – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-21 Filed 11/30/17 Page 2 of 4

Eric Striker Daily Stormer January 18, 2017

The Industrial Workers of the World (IWW) at one point in history had some interesting ideas and figures (Eugene Debs, Bill Haywood), but their ceiling for growth was low due to the many Jews who used it as a front to push for unbridled immigration – something no genuine working man will ever really agree with.

Today, the IWW counts capitalist-approved millionaire Tom Morello (Rage Against the Machine guitarist), college professors and upper-middle class students who think stretching out your ears and dying your hair blue makes you an oppressed minority. Because their message has failed to gain traction with actual working people, they have gone from leading miner strikes while under fire from Pinkerton busters to inciting unemployed black gang members against random working class whites (because it’s easy).

On Monday, they went to march in solidarity with Whitefish’s Jewish oligarchs. So brave!

Flathead Beacon:

WHITEFISH – About 50 self­proclaimed anti­fascists gathered in downtown on Monday to show solidarity with the community on the day a neo­Nazi group had been planning an armed march through town that was later postponed.

https://dailystormer.red/communists-and-anarchists-converge-on-whitefish-to-defend-worlds-richest-ethnic-group/ 1/3 11/29/2017 Communists and Anarchists Converge on Whitefish to Defend World’s Richest Ethnic Group – Daily Stormer The peaceful demonstration on Martin Luther King Jr. Day came a week after a white supremacist website, TheCase 9:17-cv-00050-DLC-JCL Document 32-21 Filed 11/30/17 Page 3 of 4 Daily Stormer, sent an incomplete application for a special event permit to the city of Whitefish. The website’s founder, Andrew Anglin, had announced plans to hold an armed march on Jan. 16 dubbed the “James Earl Ray Day Extravaganza,” referring to the assassin who shot and killed the civil rights icon.

City officials said they could not act on an incomplete permit, and Anglin announced on his website soon after that the march would be postponed until sometime in February.

…

Despite the cancellation of the Jan. 16 event, anti­fascists and others gathered in Whitefish in case neo­Nazis did move forward with their plan to march down Second Street from Memorial Park to City Hall.

Many of the protestors came from out of the area and were organized by a coalition of groups, including the Missoula chapter of the Industrial Workers of the World and the Queer Insurrection Unit. Some were masked and dressed in all back with pink armbands. One man, who asked not to be identified, said organizers chose to wear black to show the neo­Nazis that they were “militant” and would not be deterred by their weapons.

To clarify, this small black bloc/Bolshevik fragile alliance came out to defend real estate speculator (((Tanya Gersh))), who sought to use Richard Spencer’s status to mobilize Whitefish Jewry into intimidating his mother into selling her property to Gersh and leaving the town. There was a racial incident, but it was Jew-on-white. It’s possible the wealthy Jews of Whitefish paid to bus in these faux-socialists in a show of force meant to dissuade any other whites thinking about fighting back.

Last but not least, the narcissism of these “Antifa” silver spoon dykes and eunuchs was put on full display. They knew the march on Whitefish was postponed due to the government making bizarre and almost impossible demands for a permit, and yet, they showed up anyway just to scratch their “Look At Me, Mommy!” itch.

The IWW and today’s Left have always prioritized fighting identity “-isms” over actually battling the system.

Because the elites of the world agree with them on this front, they often wind up with the awkward optics

of forming human chains around filthy rich Jewish mafia bullies like Tanya Gersh.

https://dailystormer.red/communists-and-anarchists-converge-on-whitefish-to-defend-worlds-richest-ethnic-group/ 2/3 11/29/2017 Communists and Anarchists Converge on Whitefish to Defend World’s Richest Ethnic Group – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-21 Filed 11/30/17 Page 4 of 4 What Anti-Fascists don’t understand is that they’re on the wrong side of history. The concept of nationalism and the awakening to the reality of race is simply an idea whose time has come. If anyone thinks their blue hair, flabby muffin top and obsolete way of thought can halt our speeding train, they will be swept aside – perhaps even crushed.

https://dailystormer.red/communists-and-anarchists-converge-on-whitefish-to-defend-worlds-richest-ethnic-group/ 3/3 Case 9:17-cv-00050-DLC-JCL Document 32-22 Filed 11/30/17 Page 1 of 6

EXHIBIT 22

Andrew Anglin post on Daily Stormer dated Jan. 19, 2017

11/29/2017 Whitefish: Christ-Killing Kikes Trying to Have Daily Stormer Classified as a Terrorist Group…! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-22 Filed 11/30/17 Page 2 of 6

Andrew Anglin Daily Stormer January 19, 2017

The nerve of these Jews.

Shaking my damn head.

It never ceases to amaze.

Israel News Agency:

Following Neo Nazi, White Supremacy threats of planning an armed march through the streets of Whitefish, Montana, Jews Against Hate are preparing a petition for Congress that would designate all Nazi groups as terror organizations.

The British Parliament recently passed into law designating a neo­Nazi group to be labelled a terror organization and banned in a landmark first for the UK.

The order proscribing fascist group National Action was submitted before Parliament three weeks ago. It was the first time membership of a far­right group has been outlawed in the UK.

Here is the full text of their petition:

As you read this petition, American Nazis are terrorizing Jewish families and their friends in Whitefish, Montana. They have threatened to bring automatic weapons to a planned march sometime in January or February.

https://dailystormer.red/whitefish-christ-killing-kikes-trying-to-have-daily-stormer-classified-as-a-terrorist-group/ 1/5 11/29/2017 Whitefish: Christ-Killing Kikes Trying to Have Daily Stormer Classified as a Terrorist Group…! – Daily Stormer The city of Whitefish argues that they will have to allow theseCase 9:17-cv-00050-DLC-JCL Document 32-22 Filed racist Nazi thugs into their town 11/30/17 Page 3 of 6 based on “free speech”.

Incitement to murder and or harm Jews and other minorities is not free speech.

The Jewish families of Whitefish and the businesses that they are associated with have all been targeted online with death threats. Why do we allow these death threats and criminal harassment to go unpunished?

Nazi terrorism is not limited to Montana. On January 18, 2017, more than 20 Jewish Centers across the country were targeted with bomb threats.

Have we not learned anything about Nazis?

Have we forgotten the brutal history of the Nazi Party – 11 million murdered in World War Two as the result of racist hate?

The Nazis of 2017 have the same agenda as the Nazis of 1938.

In addition, the Nazis of 2017 have aligned themselves with the Hamas Islamic terror organization (Jihad) to achieve their global and domestic goals.

We recognize that many did not live through nor experience the original Nazi genocidal era. So we ask you to think of the evil of ISIS and the efforts that modern Nazis are making to associate with them and Hamas.

We are taking this action as the United Kingdom has recently declared the Neo­Nazi, anti­semitic group “National Action” as a terror organization under the Terrorism Act 2000. It is now a criminal offense to recruit for, be a member of or in any way support a Neo­Nazi group including displaying Nazi or Nazi supporting flags, posters or banners.

We kindly request of the United States House of Representatives and the United States Senate to designate the American Nazi Party AKA National Socialist White People’s Party as terror organizations.

This present and clear danger to the welfare, protection and safety of American citizens needs to be addressed without delay.

Obviously, I did not ever threaten anyone with anything – if I did, I would be in jail or at least facing criminal prosecution.

They just lie, because they are filthy lying Jews.

It’s shocking, really, to watch these kikes react in real time to simply being questioned.

https://dailystormer.red/whitefish-christ-killing-kikes-trying-to-have-daily-stormer-classified-as-a-terrorist-group/ 2/5 11/29/2017 Whitefish: Christ-Killing Kikes Trying to Have Daily Stormer Classified as a Terrorist Group…! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-22 Filed 11/30/17 Page 4 of 6

It was the Jew Tanya Gersh who threatened Richard Spencer’s mother. It was the Jewish community of Montana – including the group “Love Lives Here” – which backed up Gersh in her campaign of extortion.

We simply responded.

And yet, somehow, we are the bad guys.

And the Jews are the victims.

Just think about how insane this is: they are claiming that we hate them for no reason, and simply

randomly decided to protest them. They claim they have absolutely no idea what is going on. It’s all a big mystery – except that we are pure evil for ever saying anything negative about them, or taking any issue whatsoever with their behavior.

https://dailystormer.red/whitefish-christ-killing-kikes-trying-to-have-daily-stormer-classified-as-a-terrorist-group/ 3/5 11/29/2017 Whitefish: Christ-Killing Kikes Trying to Have Daily Stormer Classified as a Terrorist Group…! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-22 Filed 11/30/17 Page 5 of 6 This is just like another Holocaust – a hoax created to defame good and well-meaning people who are trying to protect themselves and their kinfolk from the international Jewish terror network.

The Jews are a vicious, diseased race of evil monsters, and it is they who deserve to be banned as a terrorist group. Their entire existence, going back all through their recorded history, has been a series of terrorist incidents.

But they always project that evil onto their enemies.

The problem that they have at this point is that their projection is becoming ever more obvious. This “oh no – we’re the real victims!” routine is wearing extremely thin, as they tear through like an ancient monster from another dimension, destroying everything good and wholesome in the universe.

And so it is that they are calling for the Constitution of the United States to be disregarded, and for all of us to simply be forcibly silenced.

Well – not on my watch, Jews.

I will continue to oppose you until my dying breath.

https://dailystormer.red/whitefish-christ-killing-kikes-trying-to-have-daily-stormer-classified-as-a-terrorist-group/ 4/5 11/29/2017 Whitefish: Christ-Killing Kikes Trying to Have Daily Stormer Classified as a Terrorist Group…! – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-22 Filed 11/30/17 Page 6 of 6

Hitler was right.

Hail Victory.

https://dailystormer.red/whitefish-christ-killing-kikes-trying-to-have-daily-stormer-classified-as-a-terrorist-group/ 5/5 Case 9:17-cv-00050-DLC-JCL Document 32-23 Filed 11/30/17 Page 1 of 4

EXHIBIT 23

Andrew Anglin post on Daily Stormer dated Jan. 19, 2017

11/29/2017 Washington Prepares for Full-On Assault During Inauguration – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-23 Filed 11/30/17 Page 2 of 4

Andrew Anglin Daily Stormer January 19, 2017

It really shows the mentality of the left-wing.

These faggots lost. Straight-up.

Now their just throwing a tantrum.

Why don’t they just move to Canada like they promised?

Reuters:

Washington will turn into a virtual fortress ahead of Donald Trump’s presidential inauguration on Friday as the U.S. capital braces for more than a quarter­million protesters expected during the Republican’s swearing­in.

Police have forecast that some 900,000 people, both supporters and opponents, will flood Washington for the inauguration ceremony, which includes the swearing­in on the steps of the U.S. Capitol and a parade to the White House along streets thronged with spectators.

Many of those attending will be protesters irate about the New York real estate developer’s demeaning comments about women, immigrants and Muslims, a vow to repeal the sweeping healthcare reform law known as Obamacare and plans to build a wall along the U.S.­Mexico border.

“Irate.”

I’m always shocked when an MSM source uses the appropriate adjective. https://dailystormer.red/washington-prepares-for-full-on-assault-during-inauguration/ 1/3 11/29/2017 Washington Prepares for Full-On Assault During Inauguration – Daily Stormer Outgoing U.S. Department of Homeland Security Secretary Jeh JohCase 9:17-cv-00050-DLC-JCL Document 32-23 Filed 11/30/17nson said police aim to Page 3 of 4 separate groups to diffuse tensions, similar to last­year’s political conventions.

“The concern is some of these groups are pro­Trump, some of them are con­Trump, and they may not play well together in the same space,” Johnson said on MSNBC on Thursday.

Jeh Johnson, lel.

I don’t think even liberals are going to miss hearing elected officials use niggerisms like “con-Trump.”

About 28,000 security personnel, miles (kilometers) of fencing, roadblocks, street barricades and dump trucks laden with sand will be part of the security cordon around 3 square miles (almost 8 square km) of central Washington.

About 30 groups that organizers claim will draw about 270,000 protesters or Trump backers have received permits for rallies or marches before, during and after the swearing­in. More protests are expected without permits.

A protest group known as Disrupt J20 has vowed to stage demonstrations at each of 12 security checkpoints and block access to the festivities on the grassy National Mall.

…

By far the biggest protest will be the Women’s March on Washington on Saturday, which organizers expect to draw 250,000 people. Hundreds of Women’s March­related protests are scheduled across the United States and around the world as well.

What the hell do these women expect?

Trump is a busy man. He can’t possibly be expected to grab a quarter million pussies.

There will be an anti­Trump protest in New York on Thursday evening when Mayor Bill de Blasio, filmmaker Michael Moore and actors Mark Ruffalo and Alec Baldwin, who portrays Trump on “Saturday Night Live,” take part in a rally outside the Trump International Hotel and Tower. https://dailystormer.red/washington-prepares-for-full-on-assault-during-inauguration/ 2/3 11/29/2017 Washington Prepares for Full-On Assault During Inauguration – Daily Stormer One Washington protest will come amid a haze of pot smoke as pro­marijuana activists show their opposition toCase 9:17-cv-00050-DLC-JCL Document 32-23 Filed 11/30/17 Page 4 of 4 Trump’s choice for attorney general, Alabama Republican Senator Jeff Sessions, a critic of pot legalization.

The group plans to distribute 4,200 joints at the inauguration and urge attendees to light up. Possession of small amounts of marijuana is legal in Washington but public consumption is not.

Interim Police Chief Peter Newsham said officers were prepared for mass arrests, although authorities hoped that would be unnecessary.

“If we do have a mass arrest, we’ll be able to get people processed very quickly,” he told Washington’s NBC 4 television station.

Police and security officials have pledged to guarantee protesters’ constitutional rights to free speech and peaceable assembly.

This is not a peaceful assembly.

The Daily Stormer was attempting peaceful assembly in Whitefish, Montana when we were shut down by kikes.

These people are terrorists. At least most of them are. Paid rioters, Jews and other psychopaths.

I’m hoping for mass arrests and possibly some kind of Kent State incident.

https://dailystormer.red/washington-prepares-for-full-on-assault-during-inauguration/ 3/3 Case 9:17-cv-00050-DLC-JCL Document 32-24 Filed 11/30/17 Page 1 of 5

EXHIBIT 24

Eric Striker post on Daily Stormer dated Jan. 19, 2017

11/29/2017 Rabbinical Council Gathers in Whitefish Montana To Fight Daily Stormer – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-24 Filed 11/30/17 Page 2 of 5

Eric Striker Daily Stormer January 19, 2017

Jewish power is so ferocious it even leaves me in awe at times.

Every week, Daily Stormer undergoes massive, professional DDOS attacks presumably by state actors (guess who), is blocked by every credit card processor and advertisement company in the world, is blacklisted by numerous ISPs world wide, and attempts are constantly being made to attack and

intimidate the extended families of its journalists. It’s not hard to see how the Jews were even able to cow a man with the vast fortune and connections of Henry Ford.

https://dailystormer.red/rabbinical-council-gathers-in-whitefish-montana-to-fight-daily-stormer/ 1/4 11/29/2017 Rabbinical Council Gathers in Whitefish Montana To Fight Daily Stormer – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-24 Filed 11/30/17 Page 3 of 5 The editorial line of the Daily Stormer is mild compared to the Talmud, or even a (((Noel Ignatiev))) lecture, yet world Jewry is constantly breaking every law imaginable to silence political dissidents and nobody dares say anything about it. We bend over backwards to stay within all legal paradigms when engaging in our First Amendment rights, but this corrupt system uses everything from agent provocateurs to libel to violent threats make it as difficult as possible.

But our flag is going forward anyway. No matter what it costs, we have to win!

Now the procurers of hate and baby-fellatio are flying in from all over the place to Whitefish, Montana – not for any just or noble cause, but to provide cover for a member of the Kosher Nostra, Tanya Gersh, who was trying to extort the mother of Richard Spencer (who doesn’t even say much about Jews to begin with).

No other religion or ethnic group would behave in this manner. Every time you read a typical one-sided account about a historical dispute between a Jew and a Gentile, keep this ongoing feud in mind.

AP:

Orthodox Jewish rabbis said Wednesday they will counter white supremacists’ harassment of the Jewish community in the Montana town of Whitefish by sending students to visit the Auschwitz concentration camp and by mailing a Torah to every Jewish family in the state.

The delegation of rabbis from Canada and across the U.S. presented Montana Gov. Steve Bullock with a copy of the holy text and thanking him for defending the state’s Jewish residents.

“We hope to inspire you to be a source of strength in the future for the Jewish community and that these horrible threats and terrible words of bullying and intimidation never come to a reality,” said Shmuel Herzfeld, rabbi of the prominent Ohev Sholom congregation in Washington, D.C.

Whitefish became a focal point for white supremacist anger late last year after the mother of white nationalist leader Richard Spencer said a local real estate agent pressured her to sell her property in town. https://dailystormer.red/rabbinical-council-gathers-in-whitefish-montana-to-fight-daily-stormer/ 2/4 11/29/2017 Rabbinical Council Gathers in Whitefish Montana To Fight Daily Stormer – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-24 Filed 11/30/17 Page 4 of 5 She didn’t just say it – she also released the emails proving it.

The authenticity of these emails has never been in question, yet the Associated Press, along with the rest of the Jewish-controlled media, continue to refer to this extortion racket as if it were a conspiracy theory.

The delegation of rabbis arrived in Montana from Washington, D.C.; Montreal; Sacramento, California; and San Antonio, Texas. They were hosted by Orthodox rabbis from Bozeman and Missoula.

The group said they have raised enough money so far to send Torahs to 350 of the estimated 1,500 Jewish families in Montana. They also plan to raise money through their congregations to send four non­ Jewish students from Whitefish to the Auschwitz­Birkenau Memorial and Museum in Poland. After the trip, the students would then travel the state and tell other students what they learned.

…

The delegation also met with legislative leaders and representatives from northwestern Montana before they headed to Whitefish to meet with Jewish community members.

Governor Steve Bullock gets most of his political donations/bribes from lawyers, lobbyists and real estate speculators, which is precisely why white victims of Jewish bigotry have no representatives in Montana.

Pulling out the Holocaust card does nothing but highlight the intersectionality of all these seemingly unrelated events and narrative threads. That is, the issue is that no individual Jew, no matter how secular or religious or evil or criminal, acts in isolation; he is part of a network – World Jewry – and the only reasonable defense is to ape their collectivism and oppose them as a collective political entity.

The problem is that these Jews are fighting against an earthquake that no amount of criminal activity or

lying can contain. It’s the zeitgeist, and no Tay-Sachsoid can will himself over this emerging historic spirit.

https://dailystormer.red/rabbinical-council-gathers-in-whitefish-montana-to-fight-daily-stormer/ 3/4 11/29/2017 Rabbinical Council Gathers in Whitefish Montana To Fight Daily Stormer – Daily Stormer Case 9:17-cv-00050-DLC-JCL Document 32-24 Filed 11/30/17 Page 5 of 5 Their tricks aren’t working anymore.

https://dailystormer.red/rabbinical-council-gathers-in-whitefish-montana-to-fight-daily-stormer/ 4/4 Case 9:17-cv-00050-DLC-JCL Document 32-25 Filed 11/30/17 Page 1 of 5

EXHIBIT 25

Eric Striker post on Daily Stormer dated Feb. 3, 2017

Jews, Capitalists and Catladies Pour Money Into ACLU to Keep Invaders in America – Daily Stormer 11/30/17, 11(54 AM Case 9:17-cv-00050-DLC-JCL Document 32-25 Filed 11/30/17 Page 2 of 5

Jews, Capitalists and Catladies Pour Money Into ACLU to Keep Invaders in America

Eric Striker Daily Stormer February 3, 2017

The American Civil Liberties Union, an organization stuffed to the brim with Jews, purports to be an organization dedicated to defended Constitutional rights, but actually exists exclusively to browbeat Christians and normal people out of the public space and into submission.

The ACLU has taken up a couple of genuine free speech cases in its history (Frank Colin’s Skokie march – Colin was later exposed to be a Jew himself and this was probably an internal Jewish theatrical escapade), but overall, they are more concerned in employing petty judicial tyranny to do stuff like force religious people to cater queer marriage-fetish events. When it comes to real free speech issues, e.g. on the American college campus, the ACLU is deafeningly silent on events like Wednesday’s Berkeley mob beating Trump supporters unconscious in the street. [Editor’s Note: When the publisher of this website emailed the ACLU about our proposed march on Whitefish, they never replied. -AA]

https://dailystormer.red/jews-capitalists-and-catladies-pour-money-into-aclu-to-keep-invaders-in-america-all-in-vain/ Page 1 of 4 Jews, Capitalists and Catladies Pour Money Into ACLU to Keep Invaders in America – Daily Stormer 11/30/17, 11(54 AM Case 9:17-cv-00050-DLC-JCL Document 32-25 Filed 11/30/17 Page 3 of 5

According to Yids and Silicon Valley billionaires, Trump’s ban on visas for Yemenis and Somalians will collapse the American economy. A coalition of wealthy Jews and capitalists have come together in a fundraising effort led by (((Judd Apatow))) to finance the unelected ACLU in its quest to legally obstruct the fulfillment of promises by the duly elected President of the United States.

CNN:

The American Civil Liberties Union said it received $24.1 million in online donations over the weekend.

In a normal year, the activist group makes about $4 million in online donations. In one weekend, it raised six times as much money.

Officials at the ACLU said they were stunned and gratified by the surge in financial support.

It came on the same weekend that the ACLU and its allies successfully challenged portions of President Trump’s travel ban in court.

Many celebrities and Silicon Valley luminaries encouraged their social media followers to support the group, and some even pledged to match some donations.

“The ACLU took Trump to court. Let’s stand with them. Reply with donation receipts from today and I’ll match to $25,000,” venture capitalist Chris Sacca tweeted on Saturday. As replies poured in, Sacca doubled and tripled his match offer, then said he was “matching my own match and giving $150,000.”

Rosie O’Donnell, Sia and Judd Apatow are some of the entertainers who joined in.

By Sunday evening, the ACLU said it had received $19.4 million in donations. At the end of the night, the group ran “one last set of numbers” for the weekend, according to a spokesman, and ended up at $24,164,691.

Silicon Valley (Twitter, Apple, Reddit, etc.), which supports “comprehensive immigration reform” in order to have permanent access to mediocre programmers who undercut American white collar workers, is

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throwing a lot of money away on the ACLU or taking independent legal recourse. Jewish celebrities like music producer Jack Antonoff, the pearl-diving pig Rosie O’Donnell, and childless catlady “Sia,” have also given substantial amounts.

Unkempt ghetto Jew Judd Apatow was one of the famous people who led the push for the ACLU money- bomb. Just a few days later, Apatow celebrated the political violence intended to silence speech Jews don’t like at (((Berkeley))), where young girls were beaten over the head with weapons and pepper sprayed for wearing a Donald Trump hat.

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This $24 million over a weekend for the ACLU can certainly be conceded as a small victory for the corporate Left, but the “venture capitalists” and Silicon Valley’s evil NWO nerds are about to get wet-willied by the new bully in town. A bill is being introduced in the House of Representatives that will neutralize the economic advantages these anti-American companies get from gaming the H1-b visa system. If the cucks in Congress don’t block it, the not-so-humanitarian motives of big business in browning and third- worldizing America will be revealed as they begin to drop their whining and lawsuits about travel bans being “un-American.”

As for the Jews, they’ll keep at their game, because their racial mission is driven by a white exterminationist fantasy, not necessarily just profit. But as Trump’s game of musical chairs continues, Jews beware, you may just be the only one’s left standing.

https://dailystormer.red/jews-capitalists-and-catladies-pour-money-into-aclu-to-keep-invaders-in-america-all-in-vain/ Page 4 of 4 Case 9:17-cv-00050-DLC-JCL Document 32-26 Filed 11/30/17 Page 1 of 9

EXHIBIT 26

Docket Franklin County, Ohio Case No. 17 MS 000343

11/29/2017 Civil Case Detail Case 9:17-cv-00050-DLC-JCL Document 32-26 Filed 11/30/17 Page 2 of 9

Home Case Information Online Court Schedule Last Name: First Name: Middle Init: Court: Case: Advanced Search Email Updates CIVIL CASE DETAIL

CASE NUMBER TYPE of CASE STATUS DATE FILED 17 MS 000343 MISC ACTIVE 05/18/2017 JUDGE COURTROOM DAVID E CAIN COURTROOM 7F 345 SOUTH HIGH STREET 7TH FLOOR COLUMBUS, OH 43215 PLAINTIFF(S) Name Attorney TANYA GERSH DAVID C DINIELLI C/O DAVID DINIELLI SOUTHERN POVERTY LAW CNTR SOUTHERN POVERTY LA W CNTR 400 WASHINGTON AVE 400 WASHINGTON AVE MONTGOMERY, AL 36104 MONTOGOMERY, AL 36104 DEFENDANT(S) Name Attorney ANDREW ANGLIN PBLR NO ATTORNEY ON RECORD 915 N HIGH ST COLUMBUS, OH 43201

CASE SCHEDULE No Case Schedule On File Date Description

DOCKET Show All Descriptions Select Docket Category Date Description Image Fiche Frame Pages 11/09/17 APPLIED ­ DAILY REPORTER PUBLICATION 00 AMOUNT ­ PAID: 303.00 HOW PAID IND: N/A RECEIPT 6161933 NUMBER: PLNTIF/DEFNDT N IND: 11/09/17 PROOF OF PUBLICATION 0D893 Q63 1 AMOUNT: 303.00 10/19/17 APPLIED ­ DAILY REPORTER PUBLICATION 00 AMOUNT ­ PAID: 289.00 HOW PAID IND: N/A RECEIPT 6157288 NUMBER: PLNTIF/DEFNDT N IND: 10/18/17 PROOF OF PUBLICATION 0D861 C02 1 AMOUNT: 289.00 09/20/17 SECURITY DEPOSIT RECEIVED 00 AMOUNT ­ PAID: 500.00 HOW PAID IND: CHECK/MONEY ORDER RECEIPT NUMBER: 6151383 PLNTIF/DEFNDT IND: P NAME: TANYA GERSH OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 09/20/17 APPLIED ­ DEPOSIT FOR COSTS 00 https://fcdcfcjs.co.franklin.oh.us/CaseInformationOnline/caseSearch?QEFFS7NCuLTWhntQWvJo 1/8 11/29/2017 Civil Case Detail AMOUNT ­ DEPOSITCase: 500.00 9:17-cv-00050-DLC-JCL Document 32-26 Filed 11/30/17 Page 3 of 9 HOW PAID IND: CHECK/MONEY ORDER INTRST BEARNG IND: N RECEIPT NUMBER: 6151383 PLNTIF/DEFNDT IND: P NAME: TANYA GERSH OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 09/20/17 REQUEST FOR SERVICE BY PUBLICATION WITH AFFIDAVIT E2784 X10 6 09/05/17 ORIGINAL COPY OF FAILURE OF SERVICE NOTICE FILED OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 09/08/17 NOTICE MAIL DATE: 09/05/17 09/05/17 SERVICE FAILED ­ ORDINARY MAIL E2778 E19 1 TIE FILING DATE: 07/07/17 REASON FAIL DESC: FORWARDING ORDER EXPIRED ADDRESS: SUITE 121 6827 N HIGH ST WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINTED ON 09/08/17 08/25/17 REQUEST FOR SERVICE BY PUBLICATION WITH AFFIDAVIT E2776 F85 68 08/25/17 SECURITY DEPOSIT RECEIVED 00 AMOUNT ­ PAID: 500.00 HOW PAID IND: CHECK/MONEY ORDER RECEIPT NUMBER: 6146256 PLNTIF/DEFNDT IND: P NAME: TANYA GERSH OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 08/25/17 APPLIED ­ DEPOSIT FOR COSTS 00 AMOUNT ­ DEPOSIT: 500.00 HOW PAID IND: CHECK/MONEY ORDER INTRST BEARNG IND: N RECEIPT NUMBER: 6146256 PLNTIF/DEFNDT IND: P NAME: TANYA GERSH OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 08/21/17 ORIGINAL COPY OF FAILURE OF SERVICE NOTICE FILED OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 08/29/17 NOTICE MAIL DATE: 08/21/17 08/21/17 SERVICE FAILED ­ ORDINARY MAIL E2773 G01 1 TIE FILING DATE: 07/07/17 REASON FAIL DESC: NO SUCH NUMBER ADDRESS: SUITE 121 3827 N HIGH ST WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR https://fcdcfcjs.co.franklin.oh.us/CaseInformationOnline/caseSearch?QEFFS7NCuLTWhntQWvJo 2/8 11/29/2017 Civil Case Detail Case400 W 9:17-cv-00050-DLC-JCLASHINGTON AVE Document 32-26 Filed 11/30/17 Page 4 of 9 MONTGOMERY, AL 36104 NOTICE PRINTED ON 08/29/17 08/09/17 ORIGINAL COPY OF FAILURE OF SERVICE NOTICE FILED OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 08/15/17 NOTICE MAIL DATE: 08/09/17 08/09/17 SERVICE FAILED ­ ORDINARY MAIL E2768 V52 1 TIE FILING DATE: 07/07/17 REASON FAIL DESC: INSUFFICIENT ADDRESS ADDRESS: APT B 7407 BRANDSHIRE LN DUBLIN, OH 43017 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINTED ON 08/15/17 07/26/17 ORIGINAL COPY OF FAILURE OF SERVICE NOTICE FILED OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 07/31/17 NOTICE MAIL DATE: 07/26/17 07/26/17 SERVICE FAILED ­ ORDINARY MAIL E2762 N02 1 TIE FILING DATE: 07/07/17 REASON FAIL DESC: NOT DELIVERABLE AS ADDRESSED ADDRESS: 915 N HIGH ST COLUMBUS, OH 43201 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 WASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINTED ON 07/31/17 07/07/17 PROOF OF SERVICE ISSUED ­ ORDINARY MAIL E2754 F29 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: 915 N HIGH ST COLUMBUS, OH 43201 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 TIE FILING DATE: 07/06/17 RETURNED ­ NOT SERVED 07/07/17 PROOF OF SERVICE ISSUED ­ ORDINARY MAIL E2754 F28 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: APT B 7407 BRANDSHIRE LN DUBLIN, OH 43017 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 TIE FILING DATE: 07/06/17 RETURNED ­ NOT SERVED 07/07/17 PROOF OF SERVICE ISSUED ­ ORDINARY MAIL E2754 F27 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: SUITE 121 https://fcdcfcjs.co.franklin.oh.us/CaseInformationOnline/caseSearch?QEFFS7NCuLTWhntQWvJo 3/8 11/29/2017 Civil Case Detail Case3827 N HIGH ST 9:17-cv-00050-DLC-JCL Document 32-26 Filed 11/30/17 Page 5 of 9 WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 TIE FILING DATE: 07/06/17 RETURNED ­ NOT SERVED 07/07/17 PROOF OF SERVICE ISSUED ­ ORDINARY MAIL E2754 F26 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: SUITE 121 6827 N HIGH ST WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 TIE FILING DATE: 07/06/17 RETURNED ­ NOT SERVED 07/06/17 REQUEST FOR SERVICE ­ ORDINARY MAIL 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: SUITE 121 6827 N HIGH ST WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 07/06/17 NOTICE MAIL DATE: 07/06/17 07/06/17 REQUEST FOR SERVICE ­ ORDINARY MAIL 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: SUITE 121 3827 N HIGH ST WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 07/06/17 NOTICE MAIL DATE: 07/06/17 07/06/17 REQUEST FOR SERVICE ­ ORDINARY MAIL 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: APT B 7407 BRANDSHIRE LN DUBLIN, OH 43017 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 07/06/17 NOTICE MAIL DATE: 07/06/17 07/06/17 REQUEST FOR SERVICE ­ ORDINARY MAIL 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: 915 N HIGH ST COLUMBUS, OH 43201 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW https://fcdcfcjs.co.franklin.oh.us/CaseInformationOnline/caseSearch?QEFFS7NCuLTWhntQWvJo 4/8 11/29/2017 Civil Case Detail CaseCNTR 9:17-cv-00050-DLC-JCL Document 32-26 Filed 11/30/17 Page 6 of 9 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 07/06/17 NOTICE MAIL DATE: 07/06/17 07/06/17 INSTRUCTIONS FOR SERVICE E2755 D82 1 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 06/14/17 ORIGINAL COPY OF FAILURE OF SERVICE NOTICE FILED OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 06/15/17 NOTICE MAIL DATE: 06/14/17 06/14/17 SERVICE FAILED ­ CERTIFIED E2745 B06 1 TIE FILING DATE: 05/19/17 REASON FAIL DESC: ATTEMPTED ­ UNKNOWN ADDRESS: SUITE 121 6827 N HIGH ST WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINTED ON 06/15/17 06/09/17 ORIGINAL COPY OF FAILURE OF SERVICE NOTICE FILED OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 06/12/17 NOTICE MAIL DATE: 06/09/17 06/09/17 SERVICE FAILED ­ CERTIFIED E2743 L13 1 TIE FILING DATE: 05/19/17 REASON FAIL DESC: NO SUCH NUMBER ADDRESS: SUITE 121 3827 N HIGH ST WORTHINGTON, OH 43085 DATE ­ SERVICE: 06/09/17 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINTED ON 06/12/17 06/06/17 ORIGINAL COPY OF FAILURE OF SERVICE NOTICE FILED OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 06/15/17 NOTICE MAIL DATE: 06/06/17 06/06/17 ORIGINAL COPY OF FAILURE OF SERVICE NOTICE FILED OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 06/15/17 NOTICE MAIL DATE: 06/06/17 06/06/17 SERVICE FAILED ­ CERTIFIED E2747 D32 1 TIE FILING DATE: 05/19/17 REASON FAIL DESC: NO SUCH NUMBER ADDRESS: 915 N HIGH ST COLUMBUS, OH 43201 OOS NAME: DAVID C DINIELLI https://fcdcfcjs.co.franklin.oh.us/CaseInformationOnline/caseSearch?QEFFS7NCuLTWhntQWvJo 5/8 11/29/2017 Civil Case Detail OOS ADDRESS: CaseSOUTHERN POVER 9:17-cv-00050-DLC-JCLTY LAW Document 32-26 Filed 11/30/17 Page 7 of 9 CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINTED ON 06/15/17 06/06/17 SERVICE FAILED ­ CERTIFIED E2747 D31 1 TIE FILING DATE: 05/19/17 REASON FAIL DESC: MOVED ­ LEFT NO ADDRESS ADDRESS: APT B 7407 BRANDSHIRE LN DUBLIN, OH 43017 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINTED ON 06/15/17 05/19/17 PROOF OF SERVICE ISSUED ­ CERTIFIED MAIL E2737 H15 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING CERTIFIED MAIL NO: 522802374274 ADDRESS: 915 N HIGH ST COLUMBUS, OH 43201 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 TIE FILING DATE: 05/18/17 RETURNED ­ NOT SERVED 05/19/17 PROOF OF SERVICE ISSUED ­ CERTIFIED MAIL E2737 H14 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING CERTIFIED MAIL NO: 522802374281 ADDRESS: APT B 7407 BRANDSHIRE LN DUBLIN, OH 43017 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 TIE FILING DATE: 05/18/17 RETURNED ­ NOT SERVED 05/19/17 PROOF OF SERVICE ISSUED ­ CERTIFIED MAIL E2737 H13 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING CERTIFIED MAIL NO: 522802374298 ADDRESS: SUITE 121 3827 N HIGH ST WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 TIE FILING DATE: 05/18/17 RETURNED ­ NOT SERVED ON 06/09/17 05/19/17 PROOF OF SERVICE ISSUED ­ CERTIFIED MAIL E2737 H12 1 NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING CERTIFIED MAIL NO: 522802374304 ADDRESS: SUITE 121 6827 N HIGH ST WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 https://fcdcfcjs.co.franklin.oh.us/CaseInformationOnline/caseSearch?QEFFS7NCuLTWhntQWvJo 6/8 11/29/2017 Civil Case Detail TIE FILING DATE:Case05/18/17 9:17-cv-00050-DLC-JCL Document 32-26 Filed 11/30/17 Page 8 of 9 RETURNED ­ NOT SERVED 05/18/17 SECURITY DEPOSIT RECEIVED 00 AMOUNT ­ PAID: 35.00 HOW PAID IND: CHECK/MONEY ORDER RECEIPT NUMBER: 6124303 PLNTIF/DEFNDT IND: P NAME: TANYA GERSH OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 05/18/17 APPLIED ­ CLERK 00 AMOUNT ­ DEPOSIT: 35.00 HOW PAID IND: CHECK/MONEY ORDER INTRST BEARNG IND: N RECEIPT NUMBER: 6124303 PLNTIF/DEFNDT IND: P NAME: TANYA GERSH OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 05/18/17 MISCELLANEOUS PAPER E2736 F58 1 US DIST COURT DIST MT SUMMONS ANDREW ANGLIN 915 N HIGH ST COLUMBUS OH 43201 05/18/17 MISCELLANEOUS PAPER E2736 F57 1 US DIST COURT DIST MT SUMMONS ANDREW ANGLIN 7407 BRANDSHIRE LN APT B DUBLIN OH 43017 05/18/17 MISCELLANEOUS PAPER E2736 F56 1 US DIST COURT DIST MT SUMMONS ANDREW ANGLIN 3827 N HIGH ST STE 121 WORTHINGTON OH 43085 05/18/17 MISCELLANEOUS PAPER E2736 F55 1 US DIST COURT DIST MT SUMMONS ANDREW ANGLIN 6827 N HIGH ST STE 121 WORTHINGTON OH 43085 05/18/17 PETITION FILED E2736 F59 63 05/18/17 JUDGE ASSIGNED ­ ORIGINAL JUDGE: DAVID E CAIN 05/18/17 APPEARANCE FILED ­ OUT OF STATE E2736 F59 63 NAME: TANYA GERSH PLNTIF/DEFNDT IND: P OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 05/18/17 REQUEST FOR SERVICE ­ CERTIFIED MAIL NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: 915 N HIGH ST COLUMBUS, OH 43201 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 05/18/17 NOTICE MAIL DATE: 05/18/17 05/18/17 REQUEST FOR SERVICE ­ CERTIFIED MAIL NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: APT B 7407 BRANDSHIRE LN DUBLIN, OH 43017 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 05/18/17 NOTICE MAIL DATE: 05/18/17 05/18/17 REQUEST FOR SERVICE ­ CERTIFIED MAIL https://fcdcfcjs.co.franklin.oh.us/CaseInformationOnline/caseSearch?QEFFS7NCuLTWhntQWvJo 7/8 11/29/2017 Civil Case Detail NAME: CaseANDREW ANGLIN PBLR 9:17-cv-00050-DLC-JCL Document 32-26 Filed 11/30/17 Page 9 of 9 PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: SUITE 121 3827 N HIGH ST WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 05/18/17 NOTICE MAIL DATE: 05/18/17 05/18/17 REQUEST FOR SERVICE ­ CERTIFIED MAIL NAME: ANDREW ANGLIN PBLR PLNTIF/DEFNDT IND: D SERVICE ITEM DESC: PLEADING ADDRESS: SUITE 121 6827 N HIGH ST WORTHINGTON, OH 43085 OOS NAME: DAVID C DINIELLI OOS ADDRESS: SOUTHERN POVERTY LAW CNTR 400 W ASHINGTON AVE MONTGOMERY, AL 36104 NOTICE PRINT DATE: 05/18/17 NOTICE MAIL DATE: 05/18/17

https://fcdcfcjs.co.franklin.oh.us/CaseInformationOnline/caseSearch?QEFFS7NCuLTWhntQWvJo 8/8 Case 9:17-cv-00050-DLC-JCL Document 32-27 Filed 11/30/17 Page 1 of 10

EXHIBIT 27

Mallory Simon and Sara Sidner, “An avalanche of hate: How a Montana mom became the target of a neo-Nazi troll storm”, CNN (Jul. 11, 2017)

11/29/2017 How a Montana mom became the target of a neo-Nazi troll storm - CNN Case 9:17-cv-00050-DLC-JCL Document 32-27 Filed 11/30/17 Page 2 of 10

Living with an 'army' of hate 04:52

An avalanche of hate: How a Montana mom became the target of a neo-Nazi troll storm By Mallory Simon and Sara Sidner, CNN

Updated 12:37 PM ET, Tue July 11, 2017

Editor's Note: This story addresses hate speech and contains oensive language that may be disturbing to readers.

Whitefish, Montana (CNN) — Once the calls began, they did not stop. Swiping to decline a call just led to the phone ringing again. Blocked number after blocked number filled up the voice mail.

Deleting one message just created space for another to take its place.

Then came the tweets and the email messages.

The volume was overwhelming. The content: vile and terrifying.

https://www.cnn.com/2017/07/10/us/avalanche-of-hate-daily-stormer-lawsuit/index.html 1/9 11/29/2017 How a Montana mom became the target of a neo-Nazi troll storm - CNN Case 9:17-cv-00050-DLC-JCL Document 32-27 Filed 11/30/17 Page 3 of 10

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Gunshots rang out from voice mails. Emails and texts read: "I hope you die," "Kill yourself," "We will take pleasure in your pain."

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Tanya Gersh found herself buried in an avalanche of hate, one she had not seen coming and one that focused on one fact: She's Jewish.

Gersh was called a "bitch," "a worthless c**t," and told countless times she was nothing more than a filthy "k**e." The vile and ugly words were spelled out in full when sent to Gersh.

The messages began late at night and continued into the early hours, keeping her family awake. Or there was a night of silence, broken by an onslaught at 4 a.m., jolting the family from sleep.

https://www.cnn.com/2017/07/10/us/avalanche-of-hate-daily-stormer-lawsuit/index.html 2/9 11/29/2017 How a Montana mom became the target of a neo-Nazi troll storm - CNN One voice mCaseail -- " Y9:17-cv-00050-DLC-JCLou are surprisingly easy to fi n dDocument on the Inte r32-27net. A n d Filed in rea 11/30/17l life" -- en d ePaged Ger s4h of's li10felong practice of leaving her home and car unlocked in her little Montana town, nestled by a lake in the Rocky Mountains.

It became unbearable, Gersh said. She described panic attacks, vomiting, shaking and sweating. And then the times she could not even catch her breath.

Now, she was in fear of almost anyone she met. Her old way of life had been washed away. She was now in an America full of hate. It was an America where racism and bigotry have powerful online platforms.

Gersh learned that one blog post could lead to an anonymous online assault by a group of hateful people hell bent on destroying her life. All it took was a few keystrokes, amplified by a social media megaphone, to send the deluge of repulsive messages her way and heighten tensions in this quaint ski resort town.

All because of what started, Gersh says, as a "mother-to-mother" chat.

Gersh appears to have become a target for hate after contacting tenants of a local building. Gersh says she was then called by the building's owner, Sherry Spencer, the mother of white supremacist Richard Spencer.

This mixed-use property was at the center of a dispute between Sherry Spencer and Tanya Gersh.

Gersh says she warned Sherry Spencer about looming protests at the building in Whitefish, a Montana town of 7,300 where both women live.

Gersh says she advised Spencer to disavow the views of her son, including that the United States is a country for white people. She says she oered to sell Spencer's property as a way of defusing tensions in town. Gersh suggested Spencer donate money to a human rights group.

Sherry Spencer refused to speak to CNN when we reached her on the phone. Earlier, she wrote in a blog post that Gersh, a Realtor, had threatened her, saying protesters and media would turn up and drive down the building's value if she didn't sell. https://www.cnn.com/2017/07/10/us/avalanche-of-hate-daily-stormer-lawsuit/index.html 3/9 11/29/2017 How a Montana mom became the target of a neo-Nazi troll storm - CNN Whitefish PolCaseice Ch 9:17-cv-00050-DLC-JCLief Bill Dial said Sherry Spen c eDocumentr did not file 32-27 a com p lFiledaint w 11/30/17ith police, t h Pageough h 5e rof so 10n Richard Spencer accused Gersh of extortion in interviews and a video diary. No law enforcement agency has filed any charges relating to the dispute.

There was comment aplenty, though, on DailyStormer.com, which spews neo-Nazi propaganda.

Are y'all ready for an old-fashioned Troll Storm? Andrew Anglin, the site's founder, accused Gersh of extortion in a blog post. And he Andrew Anglin, founder of DailyStormer.com exhorted readers to send Gersh -- whom he also identified as Jewish -- enough messages to make a point.

"Let's hit 'em up," he posted. "Are y'all ready for an old-fashioned Troll Storm?"

He then told them: "(I)t's that time." 'These are not trolls. They are terrorists'

Tanya Gersh says harassing messages reached her in every corner of her life.

For three months, packed luggage sat on the floor of Gersh's home.

She debated fleeing, to escape what felt like an army of online hate coming after her.

"We were scared that they were going to show up," Gersh says. "It got worse and worse and worse and worse. They just kept perpetuating it."

https://www.cnn.com/2017/07/10/us/avalanche-of-hate-daily-stormer-lawsuit/index.html 4/9 11/29/2017 How a Montana mom became the target of a neo-Nazi troll storm - CNN Anyone who Caseread D 9:17-cv-00050-DLC-JCLaily Stormer had access to a llDocument Gersh's info 32-27rmatio n aFiledfter A 11/30/17nglin post e dPage it tim e6 a ofnd 10 again. He put up photos and personal details: phone number, address, workplace and social media profiles -- including one used by her 12-year-old son. Each contained instructions to tell Gersh how they felt.

"Listen here you fucking Jew. You had better back o and leave Richard Spencer's mom alone, you dirty scumbag," one caller said on Gersh's voice mail. "You fucking Jew. You had better back o of Richard Spencer's mom. Everybody is watching you."

The Daily Stormer published more about Gersh and her "Jew agenda," once with a doctored photo showing her and her tween son on the gates of the Nazi concentration camp at Auschwitz.

A tweet was sent to Gersh showing her surrounded by gas, with the message: "Hickory dickory dock, the kike ran up the clock. The clock struck three and Internet Nazis trolls gassed the rest of them."

More messages referenced crematoriums and said she should have died in the Holocaust.

A tweet to her 12-year-old son had an image of an oven with the message: "PSsst kid there is a free X-box inside this oven."

Gersh thinks she will always be haunted by those images, and by the family talks she was forced to have. They had known the horrors of the Holocaust, but to them it had been something foreign and distant. No longer.

She hangs her head, remembering the conversation.

I'm going to make sure it doesn't happen to anybody else. "I never imagined that I would have to teach my children that Tanya Gersh, Whitefish resident they might be hated because they are Jewish," she says.

For Gersh, these threats were personal and real, not to be confused with generic if vile ramblings on an online comments board.

"These are not trolls. They are terrorists," Gersh says. "They are very harmful, they are very malicious and they are dangerous."

And Gersh decided to take a stand. She didn't know who had threatened her -- they hid behind withheld numbers and untraceable email addresses -- but knew who she believed had sent them into her life.

"Andrew Anglin has done this to so many people. I'm going to make sure it doesn't happen to anybody else," Gersh says defiantly.

Encouraged by the Southern Poverty Law Center, an Alabama-based organization that monitors hate crimes across the country, she decided to sue Anglin, accusing him of intentional infliction of emotional distress, invasion of privacy and violation of Montana's anti-intimidation statue. Protected speech ... or hate?

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Andrew Anglin is the founder of The Daily Stormer website.

On DailyStormer.com Anglin wrote he has hired a First Amendment lawyer to fight the lawsuit; he says he was simply "blogging." A prominent fundraising post declares: "The Daily Stormer is being sued by Jewish terrorists. In order to survive, we need shekels." It is paired with another doctored photo of Tanya Gersh, her head on a dragon's body being slain by a knight on a white horse with the face of Anglin. So far there have been around 2,000 donations, totaling in excess of $150,000.

Still, Anglin did ask readers to leave the Gersh family alone, allow the case to proceed and be simply about protected speech.

"(T)hough this is going to get a lot of publicity, I am asking all of you, genuinely, that you don't attempt to contact the Gershes during this process," Anglin wrote on the site. "This has escalated from jokes on the Internet to something which could potentially lead to a big step towards the hellish, Orwellian world that the enemies of freedom wish to bring down on this country."

Lawyers for Gersh say it is ironic that they cannot find Anglin -- a man apparently proud of what he's done -- to serve him to compel him to appear in court. But they expect the case to proceed.

"I hope the result is that we get fair compensation for the Gersh family, that we punish Andrew Anglin and the people who are associated with him in this circle of terror," SPLC co- counsel John Morrison says. "And beyond that, my hope is that we wind up convincing him to stop."

Morrison says they have a strong case.

"This is not free speech, this is nothing protected by the First Amendment, this is not the expression of political opinion," he https://www.cnn.com/2017/07/10/us/avalanche-of-hate-daily-stormer-lawsuit/index.html 6/9 11/29/2017 How a Montana mom became the target of a neo-Nazi troll storm - CNN Case 9:17-cv-00050-DLC-JCL Document 32-27 Filed 11/30/17 Page 8 of 10 Anglin's has raised $150,000 online says. "The purpose of this is to damage these people, the purpose of this is to cause them fear and emotional harm, and after he asked for supporters to that's illegal." donate alongside an image of himself CNN reached out to Anglin, who told us he now lives in Lagos, on a horse with a spear through Gersh. Nigeria, where he says his rights to say what he wants are not limited. He declined to comment to us on the Gersh case.

Read the lawsuit (PDF)

Morrison and Gersh believe Anglin is not the whole problem, as he has followers ready to be encouraged to act. Morrison describes them as an "army" that carries out "vicious attacks that are done in a concerted way at the beck and call of a commander who puts out the orders on this website."

Robert Ray, who writes features for The Daily Stormer under the name "Azzmador," told CNN he was "absolutely" OK with what was written on the site about Gersh. He called her a "Jewish terrorist" for allegedly threatening Richard Spencer's mother.

"I want anyone who thinks that they can exert this terroristic activist style political pressure on family members of people whose political views they don't like, I want them all terrified to do that," Ray says.

Robert Ray, a Daily Stormer writer, supports Anglin's call to action.

But he adds that messages to Gersh were not threats, but expressions of opinion.

"There's no evidence that anyone from, who was influenced by Daily Stormer, made any death threats or anything," he says.

Gersh says she does not expect to change the beliefs of Anglin or his followers. But she does have a message for them. https://www.cnn.com/2017/07/10/us/avalanche-of-hate-daily-stormer-lawsuit/index.html 7/9 11/29/2017 How a Montana mom became the target of a neo-Nazi troll storm - CNN "You are allowCaseed to 9:17-cv-00050-DLC-JCL believe whatever you want t o Documentbelieve but y32-27ou abs o Filedlutely c11/30/17annot tak e Pageyour b e9l ieoffs 10and use it to terrorize," Gersh says.

Words do matter, she and her legal team argue. The SPLC tracks instances of hatred from all groups. It says the unapologetic hatred on the Daily Stormer -- which also takes aim at African-Americans and opponents of President Donald Trump, for example -- is a catalyst for division. Among its readers were Charleston, South Carolina, church mass killer Dylann Roof and the murderer of Jo Cox, a British legislator.

For Gersh, this is a new reality. She had never never heard jokes about Jews or been subject to anything anti- Semitic before this. Now she is consumed by fighting a battle she had thought was over. She talks about the Nazis -- with their swastikas, concentration camps and genocide -- being defeated decades ago. And how the world stood up then to say "Never again."

But now she finds it is her turn to stand up to another group of people who are adamant in their hatred of Jews. She says she must take on the people who told her she should have died long ago and those who told her they hope she kills herself now.

So Gersh hopes her voice is clear when she echoes those words of warning again to those who have threatened her.

"What we are saying is never again."

Correction: An earlier version of this story misstated who initiated the contact between Tanya Gersh and Sherry Spencer.

Illustrations by Will Mullery, CNN

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https://www.cnn.com/2017/07/10/us/avalanche-of-hate-daily-stormer-lawsuit/index.html 9/9 Case 9:17-cv-00050-DLC-JCL Document 32-28 Filed 11/30/17 Page 1 of 2

EXHIBIT 28

Richard Cohen, “Attack on GOP Congressman is Assault on Democracy,” SPLC (Jun. 14, 2017)

11/29/2017 Attack on GOP congressmen is assault on democracy | Southern Poverty Law Center Case 9:17-cv-00050-DLC-JCL Document 32-28 Filed 11/30/17 Page 2 of 2

https://www.splcenter.org/news/2017/06/14/attack-gop-congressmen-assault-democracy 1/1 Case 9:17-cv-00050-DLC-JCL Document 32-29 Filed 11/30/17 Page 1 of 10

EXHIBIT 29

Declaration of Jay M. Wolman

Case 9:17-cv-00050-DLC-JCL Document 32-29 Filed 11/30/17 Page 2 of 10

Marc J. Randazza (pro hac vice) RANDAZZA LEGAL GROUP, PLLC 4035 S. El Capitan Way Las Vegas, Nevada 89147 Tel: (702) 420-2001 [email protected] Jay M. Wolman (pro hac vice) RANDAZZA LEGAL GROUP, PLLC 100 Pearl Street, 14th Floor Hartford, Connecticut 06103 Tel: (702) 420-2001 [email protected] Mathew M. Stevenson, St. Bar # 6876 STEVENSON LAW OFFICE 1120 Kensington, Suite B Missoula, MT 59801 Tel: (406) 721-7000 [email protected]

Attorneys for Defendant, Andrew Anglin

UNITED STATES DISTRICT COURT DISTRICT OF MONTANA MISSOULA DIVISION

) TANYA GERSH, ) Case No. 9:17-cv-50-DLC-JCL ) Plaintiff, ) ) DECLARATION OF vs. ) JAY M. WOLMAN IN SUPPORT ) OF MOTION TO DISMISS ANDREW ANGLIN, ) ) Defendant. ) )

Case 9:17-cv-00050-DLC-JCL Document 32-29 Filed 11/30/17 Page 3 of 10

I, Jay M. Wolman, declare:

1. I am over 18 years of age and have first-hand knowledge of the facts set forth herein, and if called as a witness could and would testify competently thereto.

2. I am an attorney permitted to practice in this case pro hac vice.

3. I am an attorney of record for Defendant Andrew Anglin in this matter, and I submit this Declaration in support of Mr. Anglin’s Motion to

Dismiss, filed herewith. 4. Upon information and belief, due to third-party acts, the Daily

Stormer no longer utilizes the .com Top Level Domain (“TLD”), but rather the .red

TLD. Upon further information and belief, a change in domain name does not alter the content of a website, but rather the path a web browser takes to access that content. Thus, upon further information and belief, all of the Daily Stormer articles described herein and retrieved from the .red TLD were those originally accessible from the .com TLD set forth in Plaintiff's complaint.

5. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 1 is a true and correct copy of Sherry Spencer’s post on Medium titled

“Does Love Really Live Here”, dated December 15, 2016, as retrieved from the

URL on May 12, 2017.

6. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 2 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated December 16, 2016, as retrieved from the URL - 1 - Declaration of Jay M. Wolman 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32-29 Filed 11/30/17 Page 4 of 10

on November 30, 2017.

7. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 3 is a true and correct copy of communications posted by Sherry Spencer on Scribd, as retrieved from the URL

17863435/Emails> on November 29, 2017.

8. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 4 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated December 17, 2016, as retrieved from the URL

on November 29, 2017. 9. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 5 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated December 19, 2016, as retrieved from the URL on November 29, 2017.

10. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 6 is a true and correct copy of a post by Eric Striker on The Daily Stormer dated December 21, 2016, as retrieved from the URL

on November 29, 2017.

11. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 7 is a true and correct copy of a post by Andrew Anglin on The Daily - 2 - Declaration of Jay M. Wolman 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32-29 Filed 11/30/17 Page 5 of 10

Stormer dated December 21, 2016, as retrieved from the URL

on November 29, 2017.

12. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 8 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated December 22, 2016, as retrieved from the URL

on November 29, 2017. 13. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 9 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated December 23, 2016, as retrieved from the URL on November 30, 2017.

14. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as Exhibit 10 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated December 23, 2016, as retrieved from the URL

on

November 29, 2017.

15. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 11 is a true and correct copy of a post by Jez Turner on The Daily Stormer dated December 23, 2016, as retrieved from the URL

on November 29, 2017. - 3 - Declaration of Jay M. Wolman 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32-29 Filed 11/30/17 Page 6 of 10

16. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 12 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated December 27, 2016, as retrieved from the URL

on November 30, 2017.

17. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 13 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated December 28, 2016, as retrieved from the URL

%E3%83%98%E3%83%96%E3%83%A9%E3%82%A4%E7%8A%AF%E7%BD %AA%E9%99%B0%E8%AC%80/> on November 29, 2017.

18. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 14 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated January 5, 2017, as retrieved from the URL

on November 29,

2017.

19. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 15 is a true and correct copy of a post by Lawrence Murray on The Daily

Stormer dated January 6, 2017, as retrieved from the URL

on November

29, 2017.

- 4 - Declaration of Jay M. Wolman 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32-29 Filed 11/30/17 Page 7 of 10

20. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 16 is a true and correct copy of a post by Ben Richards on The Daily

Stormer dated January 8, 2017, as retrieved from the URL

on November 29, 2017.

21. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 17 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated January 8, 2017, as retrieved from the URL on November 29, 2017.

22. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as Exhibit 18 is a true and correct copy of a post by David Duke on The Daily

Stormer dated January 10, 2017, as retrieved from the URL

on November 29, 2017.

23. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 19 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated January 10, 2017, as retrieved from the URL

on November 29, 2017.

24. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 20 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated January 11, 2017, as retrieved from the URL - 5 - Declaration of Jay M. Wolman 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32-29 Filed 11/30/17 Page 8 of 10

on November 29, 2017.

25. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 21 is a true and correct copy of a post by Eric Striker on The Daily Stormer dated January 18, 2017, as retrieved from the URL

on November 29, 2017.

26. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as Exhibit 22 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated January 19, 2017, as retrieved from the URL

on November 29, 2017.

27. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 23 is a true and correct copy of a post by Andrew Anglin on The Daily

Stormer dated January 19, 2017, as retrieved from the URL

on November 29, 2017.

28. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 24 is a true and correct copy of a post by Eric Striker on The Daily Stormer dated January 19, 2017, as retrieved from the URL

on November 29, 2017.

- 6 - Declaration of Jay M. Wolman 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32-29 Filed 11/30/17 Page 9 of 10

29. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 25 is a true and correct copy of a post by Eric Striker on The Daily Stormer dated February 3, 2017, as retrieved from the URL on November 30, 2017.

30. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 26 is a true and correct copy of the Franklin County, Ohio, Court docket in the matter of case number 17 MS 000343, as retrieved from the URL on November 29, 2017.

31. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as Exhibit 27 is a true and correct copy of a CNN article by Mallory Simon and Sara

Snider dated July 11, 2017, as retrieved from the URL

on November 29, 2017.

32. Attached to Mr. Anglin’s Brief in Support of Motion to Dismiss as

Exhibit 28 is a true and correct copy of a post by Richard Cohen on the Southern

Poverty Law Center’s website dated June 14, 2017, as retrieved from the URL

on November 29, 2017.

. . .

. . .

. . . - 7 - Declaration of Jay M. Wolman 9:17-cv-50-DLC-JCL Case 9:17-cv-00050-DLC-JCL Document 32-29 Filed 11/30/17 Page 10 of 10

I declare under penalty of perjury that the foregoing is true and correct.

Executed on November 30, 2017.

JayM. Wolman

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- 8 - Declaration of Jay M. Wolman 9:17-cv-50-DLC-JCL