I, Sara Salzman, being duly sworn, state as follows:
1. That Deponent has personal knowledge of the testimony given below.
2. That Deponent is an adult woman who is a computer professional who
uses the Internet in her work.
3. That Deponent has engaged in various activities related to the
study of the Holocaust and the presentation of the historic reality of the
Holocaust on the Internet. Said activities have included, inter alia, the
preparation of materials about the Nuremberg trials and the trial of Adolf
Eichmann for availability on the Internet.
4. That as the result if those and similar activities, Deponent has
attracted the attention of various anti-Semitic activists and has become a
target for harassment by said activists.
5. That someone using the alias of “Doc Tavish” is one of the
anti-Semitic activists who have harassed Deponent, and Deponent believes
that “Doc Tavish” is Scott Bradbury of Bellville, Texas, the Defendant
6. That the harassment by the anti-Semitic activists, including “Doc
Tavish,” has taken the form of, among other things, threats of violence,
including threatening to sexually molest Deponent, threatening to torture
Deponent to death, and threatening to use her skin for “lampshades.”
7. That other forms of harassment by the anti-Semitic activists have
included, among other things, threats against Deponent’s children and
family; publication of her home address and of the telephone numbers of
Deponent and her father; publication of the addresses and phone numbers of
Deponent’s neighbors; publication of a photograph purported to be
Deponent’s house; publication of a map and directions to Deponent’s house;
publication of untrue statements about Deponent, including statement that
Deponent abuses her children, that Deponent abuses drugs, and that Deponent
8. That in addition to such public statements about Deponent,
Defendant Bradbury and/or his accomplices have filed false accusations with
child protection authorities in Deponent’s community and have encouraged
others to do the same. Death threats to Defendant Bradbury and his
accomplices have been forged in Deponent’s name, and Deponent believes that
these forgeries were made by these anti-Semitic activists. A death threat
to then-President Clinton was e-mailed to the White House forged in
Deponent’s name, and Deponent believes that the forgery was committed by
these anti-Semitic activists. Defendant Bradbury and/or his accomplices
have also forged Deponent’s 9-year-old daughter in Internet posts
soliciting sex and accusing Deponent of forcing said daughter to have sex
9. That in addition to the harassment directed at her, Deponent has
witnessed the harassment of others, including the Plaintiff herein, by
Defendant Bradbury and the anti-Semitic activists using methods similar to
those that were directed against Deponent with the announced intention of
“driving” their opponents “off the Internet.”
10. That Deponent was asked to testify against Defendant Bradbury in
the pending matter and agreed to do so.
11. That as a result of her decision to testify in this matter,
Deponent has been
subjected to an intense campaign of harassment and intimidation by
Defendant Bradbury and his accomplices.
12. That as a result of this campaign of harassment, Deponent fears that she
will be subject to physical attack if she testifies in open court in this
matter because such attack has been threatened by Defendant Bradbury and
his accomplices. Deponent has been told she had “better not” testify.
13. That this campaign of harassment and intimidation has intensified
since December 1, 2000, and presently consists of a daily barrage of
threats and abuse on the Internet by Defendant Bradbury and his
accomplices, including threats to sue Deponent’s father and threats to
14. That in an attempt to stop the campaign of harassment and
intimidation being conducted against her by Defendant Bradbury and his
accomplices, Deponent contacted Daylin Leach who, she was informed,
represented Defendant Bradbury in the instant matter.
15. That Daylin Leach refused to act to halt the campaign of harassment
and stated that if Deponent wished to avoid such harassment, that she
should “stop bothering” Defendant Bradbury, and stop taking any other
action to combat the violent anti-Semitic agenda of Defendant Bradbury and
his accomplices. Deponent took these statements to mean she should not
“get involved” or testify as requested by the Plaintiff. Daylin Leach also
stated that Jews and other activists should take similar actions.
16. That in response to her complaint and concerns for the safety of
her immediate and extended family, Daylin Leach informed Deponent that she
was a “crackpot” and that the activities of Deponent and other Jews on the
Internet was a “big joke.”
17. That Daylin Leach referred to the harassment Deponent has endured as a
“stupid war of words.”
FURTHER AFFIANT SAYETH NOT.