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Opposition to Motion to Dismiss MSNBC/Maddow Suit

Opposition to Motion to Dismiss MSNBC/Maddow Suit

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Published by Heather MacAulay

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Published by: Heather MacAulay on May 03, 2012
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01/26/2013

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIABRADLEE DEAN, et. al.,
 Plaintiffs,v.
NBC UNIVERSAL, et. al.,
efendants.Civil Action No: 1:12-cv-00283 (RJL)
PLAINTIFFS'
OPPOSITION TO DEFENDANTS’ SPECIAL MOTION TO DISMISS
AND MOTION TO DISMISSI. INTRODUCTION
Defendants, MSNBC, NBC and Rachel Maddow, broadcast nationwide andinternationally that Plaintiffs Bradlee Dean and You Can Run But You Cannot HideInternational are, like their congresswoman, former Presidential Candidate Michele Bachmann,
bloodthirsty
” evil religious right bigots that call for the killi
ng of gays and lesbians. Plaintiffshave filed a complaint for false light and defamation against them. Compl. ¶ 10
. Defendants’
outrageous and maliciously-published statements have severely harmed not only Plaintiffs'reputations, but also their financial well-being. Defendants, who are anti-conservative andsecular, if not anti-religious
 – 
indeed their network marketing is geared to the left of the politicalspectrum
 – 
maliciously used Plaintiffs as a means to tie them to Presidential candidate MicheleBachmann
 – 
also an avowed Christian conservative --in an attempt to destroy her campaign aswell. Compl. ¶11
. This “clever” but outrageous strategy, designed also to boost viewership, must
be held to account legally. As a result of these malicious ad hominem attacks, Plaintiff Bradlee
 
2
Dean’s life has been threatened by radical politicized homosexuals who even vowed to
firstsodomize and then kill him. Compl. ¶11.The damage having already been done, Defendants now disingenuously seek to dismissthe complain
t under the District of Columbia’s (D.C.) newly enacted anti
-SLAPP act as well asunder Super. Ct. Civ. R. 12(B)(6). However, in their desperate attempt to summarily dismiss thecomplaint and deny Plaintiffs their day in court, much less discovery, Defendants not onlymisrepresent facts but also intentionally distort well-established law. Their motions must bedenied.
II. THE FACTS
Plaintiff Bradlee Dean is an accomplished hard metal rocker who found Jesus Christ aftera difficult sinful youth, resulting in part to an absent father who was imprisoned and an absentmother. Compl. ¶ 2. After overcoming the obstacles in his own life, Plaintiff sought to positivelyinfluence youth and others through restoring Judeo-Christian and family values. Compl. ¶ 2. In2001, he founded a non-
 profit foundation, You Can Run But You Cannot Hide (“YCR”), as a
means to instill such morals. Compl. ¶ 2. In order to further his message, he also broadcasts these
 principles through the radio show “Sons of Liberty.” Compl. ¶ 1. I
n addition to discussing issuesrelated to alcoholism, abortion and drug use, Dean has addressed the issue of homosexuality.Dean's mission has recently been the subject of a N.Y. Times profile, which spoke highly of hiswork. Exhibit 1.
On May 15, 2010, Plaintiff discussed the issue of homosexuality on “Sons of Liberty.” In
this radio broadcast, Dean sought to encourage Christians to take a stronger stance with regard tothe radical gay agenda promoting homosexuality in the schools. Dean specifically rejects, asChristians do, the Islamic doctrine and actual practice of executing homosexuals.
 
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(youcanruninter
national.com). Rather, Dean’s intent was to focus attention to the dangers of 
promoting homosexuality to young, vulnerable, and susceptible children, not to advocate harm toanyone. More inclined to experiment with the same sex, given the susceptibility of children,promoting homosexuality in school is setting children on a path ridden with emotional distress,depression, and suicidal tendencies. In fact, studies do suggest that severe emotional distress ismore common among gay teenagers than straight ones
. See “Mental Health Disorders,
Psychological Distress, and Suicidality in a Diverse Sample of Lesbian, Gay, Bisexual, and 
Transgender Youths,”
 
 by Brian S. Mustanski, PhD, stating “LGBT youths had higher prevalence
of mental disorder diagnoses than youths in national sa
mples.”
See also
New York Times Article(http://www.nytimes.com/2011/01/04/health/04brody.html). Dean, seeking to draw attention tothe issue, merely advocated that Christians recognize the problems associated with advocatinghomosexuality to the young and to take a firmer stance against the radical gay agenda and lobby.In this regard, to prod Christians to take the issue mo
re seriously, “tongue in cheek”
hereferenced even radical Muslims taking the issue seriously, but never condoned their practices of killing homosexuals under Shariah law. (youcanruninternational.com).On May 11, 2011 Defendants Maddow, MSNBC, and NBC broadcasted a segment on"The Rachel Maddow Show," blatantly, maliciously and falsely asserting that Plaintiffsadvocated
the killing of homosexuals. Even more false and outrageous were Maddow’s
published statements that Plaintiffs are
"part of social conservatism that is that radical andthat bloodthirsty" and that Plaintiff Bradlee Dean, YCR, and Michele Bachman were
calling for the “upping of the bloodshed in America’s culture wars” and that
Plaintiffs"advocated using foreign enemies
against America because Christians aren’t doing the job
by killing gays and lesbians,
beliefs and actions that have never been condoned, advocated, or

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