The Nizkor Project: Remembering the Holocaust (Shoah)

Shofar FTP Archive File: people/b/bradbury.scott/Edeiken-v-Bradbury-RA.01


Archive/File: people/b/bradbury.scott/Edeiken-v-Bradbury-RA.01
Last-Modified: 2001/02/14

                   REQUESTS FOR ADMISSION

   NOW COMES Plaintiff Yale F. Edeiken and demands that, pursuant to Rule
4014, Pennsylvania Rules of Civil Procedure, Defendant Scott Bradbury
admit or deny the truth of the following within thirty (30) days of service
or, by failing to do so, admit the truth of the matters asserted:

     1.   Defendant Scott Bradbury publishes material on the Internet under
the pseudonym "Doc Tavish."

      2.  Defendant Scott Bradbury has in the past and continues in the
present to use various services to publish his material in a manner in
which it cannot be traced back to its source.

      3.  Defendant Scott Bradbury has published material on the Internet
under the pseudonym "Nazihunter."

      4.  Defendant Scott Bradbury has created and published on the
Internet under the  name of "Nazihunter" a website which gives his own
address and telephone number.

      5.  Defendant Scott Bradbury has thereafter falsely claimed that said
website was created by others in an attempt to harass him.

      6.  Defendant Scott Bradbury has, at various times, published his own
address and telephone number under the name of "Nazihunter" together with
various threats of violence.

      7.  Defendant Scott Bradbury has thereafter made the false claim,
based upon such publications, that he is being harassed and threatened by
others.

      8.  Defendant Scott Bradbury has at various times contacted various
internet service providers and, using the false pretense that he was the
author, cancelled the published work of others.

      9.  Defendant Scott Bradbury has participated in campaigns of
threats, defamation, forgery, and harassment in order to intimidate and
harass his opponent and prevent them from exercising their rights of free
speech.

      10. Defendant Scott Bradbury has assisted and/or obtained the
assistance of others in said campaigns, including but not limited to David
E. Michael, Donald Ellis, and "Pat Blakely."

      11. That Donald Ellis has published material under the pseudonyms
"Mike Kalvatis," "Pat Blakely," "RevWhite" and "Rabbi Brimstone."

      12. That at all times relevant hereto Defendant Scott Bradbury was
aware of the use of those pseudonyms by Donald Ellis.

      13. The targets of said campaigns of harassment have included, inter
alia, Plaintiff, Sara Salzman, Jeffrey G. Brown, Ken McVey,   Scott Murphy,
David Gehrig, Andrew Skolnick, Steven Wolk, Mike Curtis, Andrew Mathis, and
all others named in "The Nizkor Phonebook."

      14. Defendant Scott Bradbury has forged material which he claimed
originated from Jeffrey G. Brown and published said material on the
Internet falsely claiming that it originated from Jeffrey G. Brown.

      15. Defendant Scott Bradbury has forged material which he claimed
originated from Andrew Skolnick and published said material on the Internet
falsely claiming that it originated from Andrew Skolnick.

      16. Defendant Scott Bradbury has forged material which he claimed
originated from Plaintiff and published said material on the Internet
falsely claiming that it originated from Plaintiff.

      17. Said forgeries have included forgeries making unwanted sexual
advances to Defendant Scott Bradbury.

      18. That no such unwanted sexual advances were ever made.

      19. That notwithstanding the fact that said communications were
forgeries and known to be such by Defendant Scott Bradbury, Defendant Scott
Bradbury forwarded them to third persons claiming that they were true and
accurate.

      20. That the purpose of Defendant Scott Bradbury in distributing said
forgeries was to injure the reputation of Plaintiff and to induce others to
terminate a business contract with Plaintiff.

      21. Defendant Scott Bradbury has published the statement that he has
been threatened with homosexual rape by Plaintiff, Jeffrey G. Brown and
Kenneth McVay.

      22. Said claim was published despite the fact that no such threat had
ever been made to Defendant Scott Bradbury.

      23. Defendant Scott Bradbury has published the claim that Andrew
Mathis, Ph. D., had solicited minor boys by offering them alcoholic
beverages.

      24. Said claim was made despite the fact that Defendant Scott
Bradbury knew that no such offer or solicitation had ever been made.

      25. Since the filing of this lawsuit Defendant Scott Bradbury
increased his efforts to harass and threaten Plaintiff and to distribute
false and defamatory information about him in an effort to intimidate
Plaintiff.

      26. Defendant has been assisted in this effort by David E. Michael
and Donald Ellis publishing material either under their own names,
pseudonyms, or anonymously.

      27. Defendant Scott Bradbury, either personally and/or acting through
others who were, then and there, acting with his knowledge assistance and
consent have attempted to disrupt Plaintiff's internet service by
"mailbombing" him by sending gigantic files to him as electronic
communications.

      28. Defendant Scott Bradbury, either personally and/or acting through
others who were, then and there, acting with his knowledge assistance and
consent have attempted to disrupt Plaintiff's internet service by asking
various commercial services to send him electronic communications thereby
overwhelming his service provider with "spam."

      29. Defendant Scott Bradbury, either personally and/or acting through
others who were, then and there, acting with his knowledge assistance and
consent have attempted to disrupt the internet service of others by send
them "mailbombs" in Plaintiff's name and using Plaintiff's name to spam
such persons.

      30. On or about July 2, 2000, Defendant Scott Bradbury either
personally or acting through his associates acting  then and there with the
knowledge, consent, approval and assistance of Defendant Scott Bradbury
published personal information about Plaintiff's family including his
father, mother, sister and brother including their names addresses,
telephone numbers with instructions to call and harass them.  Said
publication is attached hereto and made part hereof as "Exhibit "A."

      31. The purpose of said publication was to threaten, harass, and/or
intimidate Plaintiff and to encourage others to commit acts of violence
against him and his family.

      32. Said purpose  was at all times known to Defendant Scott Bradbury.

      33. On or about July 7, 2000,  Defendant Scott Bradbury either
personally or acting through his associates a ting then and there with the
knowledge, consent, approval and assistance of Defendant Scott Bradbury
published four threats of violence against Defendant Scott Bradbury.  One
such publication is attached hereto and made part hereof as Exhibit "B."

      34. The purpose of such forgeries was to harass Plaintiff with false
charges.

      35. Notwithstanding that he was aware said publications were
forgeries, Defendant Scott Bradbury forwarded copies of said publications
to Plaintiff's internet provider claiming that Plaintiff had published said
material.

      36. That Donald Ellis a/k/a "Pat Blakely" a/k/a "RevWhite" forwarded
said publications to the law firm of Todd S. Miller & Associates
notwithstanding the fact that said publications were known to him to be
forgeries.

      37. The purpose of said action was to adversely affect the
professional standing of Plaintiff.

      38. That such distribution was done with the approval, consent, and
knowledge of Defendant Scott Bradbury who was at all times aware of the
forgery.

      39. Said publication was made with the consent, approval, and
knowledge of Defendant Scott Bradbury who had, at that time, a full
understanding of the purpose and intent of that publication.

      40. That Donald Ellis a/k/a "Pat Blakely" a/k/a "RevWhite" forwarded
said publications to Plaintiff's internet service provider and to various
law enforcement agencies notwithstanding the fact that said publications
were known to him to be forgeries.

      41. The purpose of said action was to adversely affect the
professional standing of Plaintiff and to have fraudulent criminal charges
brought against him.

      42. That such distribution was done with the approval, consent, and
knowledge of Defendant Scott Bradbury who was at all times aware of the
forgery.

      43. On or about July 10, 2000, a forgery was published under the name
of Plaintiff making a death threat against the Woman's Center of Allentown.
Said publication  is attached hereto and made part hereof as Exhibit " C."

      44. Said publication was made by Donald Ellis a/k/a "Pat Blakely"
a/k/a "RevWhite" a/k/a "Rabbi Brimstone" with the purpose of harassing,
threatening, and intimidating the persons named on said list.

      45. Said publication was made with the assistance, consent, approval,
and knowledge of Defendant Scott Bradbury who had, at that time, a full
understanding of the purpose and intent of that publication.

      46. On or about July 14, 2000, a forgery was published under the name
of "Wendy Edeiken" making a death threat against Plaintiff.  Said
publication is attached hereto and made part hereof as Exhibit " D."

      47. Said publication was made by Donald Ellis a/k/a "Pat Blakely"
a/k/a 'RevWhite" a/k/a 'Rabbi Brimstone" with the purpose of harassing,
threatening, and intimidating the persons named on said list.

      48. Said publication was made with the assistance, consent, approval,
and knowledge of Defendant Scott Bradbury who had, at that time, a full
understanding of the purpose and intent of that publication.

      49. On or about July 22, 2000, Defendant Scott Bradbury published a
direct threat of violence against Plaintiff.  Saud threat is attached
hereto and made part hereof as Exhibit 'E."

      50. Defendant Scott Bradbury has contributed to, participated in
and/or cooperated with the establishment on the Internet of a site known as
"The Nizkor Phonebook."

      51. The purpose of "The Nizkor Phonebook" is to threaten, harass,
and/or intimidate Jews and others who disagree with Defendant Scott
Bradbury and his accomplices.

      52. The purpose of 'The Nizkor Phonebook" was at all times known to
Defendant Scott Bradbury.

      53. On or about July 24, 2000, "The Nizkor Phonebook" was edited to
display a picture of an automatic pistol above personal information about
Plaintiff and his wife including their names addresses, telephone numbers,
and a map whereby they could be located.

      54. The purpose of said publication was to threaten, harass, and/or
intimidate Plaintiff and to encourage others to commit acts of violence
against him.

      55. Said purpose  was at all times known to Defendant Scott Bradbury.

      56. On or about July 25, 2000, "The Nizkor Phonebook" was edited to
display personal information about Plaintiff and his wife including their
names addresses, telephone numbers, and a map whereby they could be located
surrounded by images of dripping blood.

      57. The purpose of said publication was to threaten, harass, and/or
intimidate Plaintiff and to encourage others to commit acts of violence
against him.

      58. Said purpose  was at all times known to Defendant Scott Bradbury.

      59. On or about July 29, 2000, "The Nizkor Phonebook" was edited to
display personal information about Plaintiff's father, mother, sister, and
brother including their names addresses, telephone numbers, and a map
whereby they could be located surrounded by images of dripping blood.

      60. The purpose of said publication was to threaten, harass, and/or
intimidate Plaintiff and to encourage others to commit acts of violence
against them.

      61. Said purpose  was at all times known to Defendant Scott Bradbury.

      62. On or about July 14, 2000, a publication called "The Dead Pool"
was made by Donald Ellis under the pseudonym "Rabbi Brimstone" which named
various opponents of Defendant Scott Bradbury and his associates asking for
wagers as to which would die first.  Said publication is attached hereto
and made
part hereof as Exhibit "F."

      63. Said publication was made by Donald Ellis a/k/a "Pat Blakely,"
a/k/a "RevWhite" a/k/a "Rabbi Brimstone" with the purpose of harassing,
threatening, and intimidating the persons named on said list.

      64. The title of said publication was intended as a reference to a
list  of death threats in a motion picture of the same title, and in said
motion picture members of the "Dead Pool" list were murdered.

      65.  In subsequent publications on the topic, Donald Ellis a/k/a "Pat
Blakely" demonstrated that he was familiar with this significance of the
title, and therefore the "Dead Pool" post can reasonably be construed as a
series of death threats against the individuals listed therein.

      66. Defendant Scott Bradbury was aware of the threatening nature of
the publication at the time that it was made.

      67. Defendant Scott Bradbury advocates that Jews be deprived of the
civil, political, and human rights in the United States.

      68. Defendant Scott Bradbury endorses the stereotype of Jews as
depicted in the propaganda of Adolf Hitler and the Nazis as true and
accurate.

      69. Defendant Scott Bradbury has claimed that the Holocaust 
did not occur.

      70. Defendant Scott Bradbury has endorsed the positions of William
Pierce and the National Alliance, a neo-Nazi and violently anti-Semitic
organization which teaches that Jews are "mud people" who should be
murdered in a nationwide pogrom.


Home ·  Site Map ·  What's New? ·  Search Nizkor

© The Nizkor Project, 1991-2012

This site is intended for educational purposes to teach about the Holocaust and to combat hatred. Any statements or excerpts found on this site are for educational purposes only.

As part of these educational purposes, Nizkor may include on this website materials, such as excerpts from the writings of racists and antisemites. Far from approving these writings, Nizkor condemns them and provides them so that its readers can learn the nature and extent of hate and antisemitic discourse. Nizkor urges the readers of these pages to condemn racist and hate speech in all of its forms and manifestations.