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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW MEXICO


BENJAMIN RADFORD,
Plaintiff,
vs. No. 1:14-CV-334-SMV/KBM
KAREN STOLLZNOW,
Respondent.
DECLARATION OF BENJAMIN RADFORD
I, Ben Radford, declare as follows:
1. I am the plaintiff in this proceeding, and I provide the information in this declaration
on the basis of my personal knowledge.
2. I am 43 years old. I was born in New York City and moved to New Mexico at the age
of seven. I have lived in New Mexico most of my adult life, principally in Corrales and Rio
Rancho. My father is the editor and publisher of the Corrales Comment, a small, independent
community newspaper, and my mother served as a municipal judge in Corrales. Our family is
well-known in Corrales and environs and I believe I and the rest of my family have always
enjoyed a good reputation in our community. I come from a long line of journalists, for whom
personal reputation and credibility are essential.
3. I attended and graduated from the University of New Mexico and have for many years
made a career writing, investigating, debunking, and speaking about claims for which there is not
good scientific evidence, including pseudoscience, unproven alternative medicine, and
"unexplained" phenomena such as miracles, psychic powers, ghosts, etc., from a science-based
point of view. As a result, I have become a prominent member of the "skeptical" community or
"skeptical movement" of which the defendant, Karen Stollznow, is also a member. The skeptical
movement is centered on the philosophy that nothing should be accepted as fact without valid
supporting evidence; as Carl Sagan said, "Extraordinary claims require extraordinary evidence."
4. I have been employed for 16 years by the Center For Inquiry (CFI), a non-profit
educational organization whose mission "is to promote scientific inquiry, critical investigation,
and the use of reason in examining controversial and extraordinary claims." Although CFI is
based in Buffalo, New York, I have for the past six years performed my work for CFI from my
home in Rio Rancho, New Mexico, and receive my pay here in New Mexico. I also engage in
EXHIBIT
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freelance activities as a writer and speaker and travel to conventions and speaking engagements
around the country, as do other members of the skeptical community, including the defendant,
Karen Stollznow. I do virtually all of my writing (for CFI's magazine The Skeptical Inquirer
and for other publications and on-line sites such as Discovery News and LiveScience.com) at my
home office in New Mexico. I have frequently written for the Albuquerque newspaper The
Weekly Alibi, and I have made numerous appearances on both AM and FM Albuquerque radio
talk shows (including the 94 Rock Morning Show with TJ Trout and "Swami Rob"). I have also
appeared many times on local Albuquerque television stations to comment on a wide variety of
claims and my related investigations including the KiMo Theater Ghost, urban legends,
mysterious giant birds in New Mexico skies, chupacabra reports, and radiation fears in the wake
of the Fukushima nuclear disaster. I have also appeared on cable TV shows dozens of times
(including the Discovery Channel, the Learning Channel, the History Channel, National
Geographic, and CNN) and made national news because of my investigation into a famous New
Mexico mystery, the "Santa Fe Courthouse Ghost."
5. In the course of my career, I had occasion to meet and come to know Karen Stollznow
as both a lover and professional colleague. She has always been aware that I live and work in
New Mexico and, as I explain below, visited me here during our romantic relationship, has
engaged in several ongoing professional activities here, as I also explain below. She has
socialized with my parents and friends here, as well as during visits to her then-hometown of San
Francisco. She has sent me more than 1,000 emails here (along with a book manuscript she
wrote and asked me to review) and has sent me letters, cards, birthday cards and presents, to my
address in New Mexico. Many of her communications to me, and mine to her, involve
professional and collegial matters, such as ideas for articles, professional collaboration, advising
and commenting on each other's work, and the like. I provide the following as very limited
examples of the types of interactions and communications Stollznow had with me while I was
domiciled in New Mexico and, in the vast majority of cases, while I was physically present in
New Mexico:
a. January 28,2009: Stollznow and I discussed my continued contributions to the
magazine that Stollzow edited, The Skeptic. She wrote to me "I did ask you about
some articles you'd sent to [previous editor] Barry .... I would very much
appreciate anything you would like to submit, especially an article with piccies
[Australian slang for pictures]. But the remote viewing one sounds interesting too.
I did one on that topic once for Aust. Science. Thank you. I want to submit some
stuff to SI [Skeptical Inquirer magazine] soon too."
b. February 2,2009: Stollznow contacted me in New Mexico thanking me for
contributing material for her magazine: "I'm pleased you'll be a part of my first
issue," Stollznow wrote.
c. July 21, 2009: Stollznow e-mailed me to say, "Ben, let's go away together
somewhere. Let's do an investigation somewhere bizarre and have a crazy couple
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of days tackling local lore and our evenings tangled in each other. I miss your
touch, and your smell, and your taste, and the sound of your voice in my ear. I
miss you. Maybe in October if our schedules permit?"
d. October 2,2010: I got a birthday card and gift from Stollznow with a note signed,
"Lots of love, Karen, xxx/ooo."
e. January 10, 2011: I informed Stollznow that I had referenced her research in my
article for Skeptical Inquirer magazine: "I worked in a mention of your recent
Naked Skeptic column in the next issue of SI." Stollznow replied, "Nice. Thank
you, baby!"
f. April 26, 2011: I e-mailed a photograph taken of the two of us outside our hotel in
San Francisco, the morning after the night we spent together. She replied,
"Thanks for the pic. We really do look cute in it! Karen."
g. January 4,2012: Stollznow e-mailed to thank me for the Christmas gift I sent her:
"Hi there, I've been working on my book and usual articles, columns, etc. Thank
you for the framed SI cover - I didn't really contribute to that issue much
though!"
h. March 28, 2012: Ie-mailed Stollznow to offer assistance on indexing her book:
"Hi Karen If you end up doing your own book indexing, let me know and I'll be
happy to offer advice on how I do it. Ben." She replies, "Hey Ben, Thanks for the
offer. I'll see how I go. Much appreciated."
1. August 11, 2012: Stollznow e-mailed me to thank me for a birthday card I sent:
"Hi Ben, I just received your birthday card. Thanks for that, it certainly made me
laugh! Have a great weekend. Karen."
6. As set forth in my lawsuit against her, after our relationship soured in 2010, Stollznow
maliciously and falsely defamed me with the transparent intent to ruin my reputation (which she
has largely accomplished) and to get me fired from my job (which she nearly accomplished),
which I perform in New Mexico.
7. This case arises from, and in the context of, our business and personal relationships.
8. In September 2008, I met Stollznow at a convention in Atlanta, at which time she and
I became romantically, professionally, and sexually involved. After the convention, on
September 2 and 4, she contacted me suggesting that she visit me in New Mexico and that she
"would be amenable to any future opportunities that may arise." We agreed on a four-day, long
weekend visit when she would come to stay with me in New Mexico, which she did. Before she
came, I told her that I could arrange a radio interview for her, on a New Mexico radio station,
while she was in New Mexico, which I did, and she in turn conducted a radio show interview
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with me for her podcast, "The Skeptic Zone." During her visit, I showed her around where I
grew up; took her to my mother's house and she and my mother became friendly with each other.
9. During the days she spent with me in New Mexico, I introduced her to Ken Frazier,
who also lives in New Mexico. Frazier was and is an editor of The Skeptical Inquirer, CFI's
magazine and a mainstay of the skeptical movement in which both Stollznow and I make our
livings. I made dinner for both Frazier and Stollznow while she was here and, as a result of my
introduction and my promotion of Stollznow to Frazier, she began a successful relationship with
the Center for Inquiry and The Skeptical Inquirer, through her continuing contact with him and
with me. She wrote for the magazine on a number of occasions thereafter and was also hired to
become a writer for the Skeptical Inquirer website. She was paid by CFI to work on its podcast,
Point of Inquiry, and later elected to an honorary position in the organization. After Frazier and
Stollznow met through my intercession in New Mexico, Frazier emailed Stollznow on February
4, 2009: "That was a very enjoyable evening at Ben's. Afterward I sent a note about it and you
to Barry Karr (CSI exec director) and Paul Kurtz (chairman) in Amherst to bring you to their
attention as a young rising force in the skeptical movement. I'm going to share your new contact
info with Barry as well. Ben and I have talked recently about encouraging the next generation of
young skeptics, you prominently among them, to begin to move into leadership roles. I'm glad to
see that already happening in your case."
10. During the period 2008-2012, I continued to assist Karen Stollznow in gaining
recognition in the "skeptical" movement and was able to do so on many occasions. As noted
above, when she came to Albuquerque in 2008 to visit me, I arranged for her to appear on a local
talk show radio show. The show was "Science Watch" on Clear Channel's AM 1350 station.
The show aired November 15, advertised as '''Skeptics Down Under' with special guests Dr.
Karen Stollznow (Australian skeptic/investigator) and Albuquerque's own Ben Radford of
Skeptical Inquirer." On the show, she promoted herself, her podcast, and her work. Thereafter, I
always looked for ways when I was writing a book or article to refer or cite her articles, in order
to promote her. For example, in April 2010 when I wrote a high-profile Discovery News article
on xenoglossia (speaking in an unknown language, or speaking in tongues while "possessed" or
during religious fervor), I referred readers to Karen's work. The result was an April 23 article
titled "Demonic Possession, Reincarnation, and Xenoglossia," which prominently promoted and
quoted Stollznow over two paragraphs.
11. In Skeptical Inquirer magazine, while I was either Deputy or Managing Editor, we
regularly included a section in the magazine that highlighted articles online and I would select
them. On numerous occasions, when an article by Stollznow was relevant to our topic or topics, I
would refer the reader to her articles in order to promote her career. When I promoted her in this
fashion, she would call or email to thank me and express the hope that I would continue to
"plug" her articles or talks. I always tried to act on her requests, out of friendship and an effort
to promote her worthy work. For the most part I undertook all of these efforts on her behalf, as
well as my work in general, from my home/office in New Mexico, with which Stollznow was
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quite familiar. We were in regular communication regarding all of these matters, most often
while I was in my home/office in New Mexico. For her part, Stollznow moved several times
during the three years of our relationship romantic relationship and the five years of our
professional relationship, including in Australia; Berkeley, California; and Denver, Colorado.
12. In 2010 I authored a book titled Scientific Paranormal Investigation: How to Solve
Unexplained Mysteries. I asked Stollznow to contribute a portion of one chapter, and she
submitted a piece entitled "Busting Ghost Busters with the Historical Method." My book, with
her contribution (to the best of my knowledge, her first chapter section in a published book) was
published in New Mexico, by a New Mexico-based publishing company, Rhombus Books.
13. In October 2008, Stollznowalso sent a book she was writing to New Mexico and
asked me to review it and offer suggestions, which I did.
14. My efforts to promote her to Frazier, and the many other efforts I made on her
behalf, provided, I believe, significant boosts to Stollznow's career. I made these efforts freely
because I thought she was a good researcher and writer and because we were involved together
in a romantic relationship.
15. After Stollznow's 2008 visit to New Mexico, and over the next two or three years,
Stollznow sent me numerous letters, cards, birthday cards and presents, to my home in New
Mexico, apparently to reflect the affection she claimed to have for me and, I assume, as a way of
thanking me for my efforts on her behalf. I reciprocated by sending her occasional cards and
holiday/birthday presents where she lived, including in September 2008, December 2009, March
2010, August 2010, December 2011, and January 2012. Stollznow also telephoned me on a
number of occasions to my home in New Mexico, and sent me more than 1,000 emails regarding
professional and personal matters.
16. In the course of our relationship, we met for sex and companionship in Georgia and
New Mexico in 2008, and in California in 2010. When we met in San Francisco in 2010, it was
at Stollznow's request and she communicated that request to me while I was in New Mexico.
She asked me if I would agree to meet her in San Francisco during a conference at which I was
to speak. She offered to arrange a hotel room for us, and did arrange for a hotel room for us,
where we continued our sexual relationship.
17. In January 2009 Stollznow expressed her disappointment that I seemed not to be
interested in a long term relationship with her, writing in an e-mail to me that "I like you more
than I've liked any man in a very long time, which doesn't serve me well, given our distance,
and your relationship preferences. I have accepted this, the old 'He's just not that into you'
understanding, and I would rather move on completely than hold onto some vain, pathetic hope
for a future with you ... " In a March 1,2010, e-mail to me Stollznow again stated her
disappointment that our relationship had not blossomed as she'd expected, writing that she "was
pretty upfront about [her feelings for me] until the point where I [Stollznow] realized my feelings
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weren't reciprocated." Some months later, she informed me, or I learned from acquaintances,
that she had become engaged to (following a year-long, rocky on-and-off relationship with)
Matthew Baxter, who both she and I had known for some time, who was also a member of the
skeptical movement.
18. After she entered into her relationship with Baxter, Stollznow placed a call to me on
my cell phone in September 2010, to solicit my sympathy and advice, claiming that Baxter had
broken her wrist during an argument. Because I had some knowledge of abusive relationships as
a result of volunteer work in a battered women's shelter, I advised her to get out of any
relationship that was abusive. She suggested, and I agreed, that she might get away from the
situation and come to visit me in New Mexico for a week in mid-October 2010. Although she
suggested dates for her visit, the visit never materialized.
19. In September 2010 I rebuffed Stollznow's request that we continue our affair even
though she had married Baxter. She seemed upset.
20. Although I was certainly attracted to Stollznow throughout the years 2008-2010, she,
more than I, solicited sexual encounters, and I willingly responded to her solicitations.
21. In June 2011 Stollznow called me in New Mexico, with Baxter on the line, and
suddenly (and for the first time in our by-then four year relationship) stated that I needed to stop
"harassing her" and warned me that she might raise the issue with my employer. I told her,
accurately, that I had no idea what she was talking about, and asked for examples of my
harassing behavior, none of which were forthcoming. In retrospect, I can only assume that she
said this either for the benefit of her husband, who was on the line, or as an opening salvo in
what became her effort to destroy my reputation. After that, she became angry at me again for
accusing her of not doing her fair share of the work in producing a podcast, "Monster Talk," that
she and I and a third colleague worked on.
22. Soon after-and after trying to have me banned from two conferences where I often
speak-Stollznow contacted my employer, CFI, to attempt to get me fired for my supposed
misconduct toward her. To my employer, she escalated her allegation from "harassment" to
"sexual harassment." I know this because CFI informed me that she had, and it launched an
investigation into whether what she had accused me of was true.
23. Although CFI found most of her allegations against me to be unsubstantiated, their
investigator found that I had sent Stollznow "inappropriate" emails in 2012, after she and I had
ended our relationship and she had married Baxter. I realized later, when I examined one of the
documents she had provided CFI's investigator, that Stollznow had falsified the dates of my
emails to her, changing their years to 2012. By doing so, she made it falsely appear that I had
somehow been romantically pestering her after her marriage to Baxter. But I had actually sent
her the emails in 2009 and 2010, when she and I were romantically and sexually involved. In
other words, she falsified the dates of the emails to make it appear that I had sent them 2012,
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after our relationship was over and she was married to Baxter. It was the falsified dates that made
the emails appear "inappropriate." It requires no speculation to understand that her purpose in
doing this was to attempt to get me fired by CFT. I still have my emails, with the correct dates,
and have had their dates independently verified by a computer forensics firm for purposes of this
litigation. In the course of my efforts to get Stollznow to retract her allegations to avoid
litigation, I have learned that Stollznow now claims to have "deleted" the original emails whose
dates she falsified in a cut-and-paste- job that she used to mislead CFI in an effort to cost me my
job.
24. After CFI had largely rejected her allegations against me, Stollznow posted a guest
blog on the prominent Scientific American Mind web site to not only use me as an example of a
"predator" who had for years sexually harassed (and even sexually assaulted) her, but also to
attack CFI for not having done more than suspend me for two weeks without pay. Although she
didn't named me in the blog post, she soon contacted mutual colleagues in the skeptical
community (including several prominent bloggers such as PZ Myers) to tell them that the alleged
malefactor was me. A few hours after Stollznow's August 6 blog, a man named Ian Murphy
revealed my name in connection with Stollznow's blog, via Twitter: "FYI, Karen Stollznow's
sexual harasser is Ben Radford. Someone had to say it" and included a link to Stollznow's blog.
This was retweeted 32 times to nearly 50,000 people. In other words, Stollznow kept my name
out of her posting, but took steps to make sure that the people in the skeptics movement, through
whom I make my living, would be sure to know that she was talking about me. In her posting,
she also accused CFI of shirking its duty to discipline me more severely, accusing them of
having "a track record of disciplining these harassers lightly, and then closing ranks like good 01'
boys." In my opinion, the inference to draw from her attack on CFI was that she hoped to
pressure CFI into firing me. As a consequence of her communications to CFI, her "guest blog"
posting on Scientific American, and her communications to our mutual colleagues to make sure
they knew I was the one she was accusing, her false accusations against me spread throughout
the Internet, including by prominent Slate.com blogger Amanda Marcotte. In this way,
Stollznow was able to turn me into a pariah among many in our field. I was even listed as a
"sexual predator" on the social networking site Twitter, and typical responses to this include:
"Radford has now pretty much proven himself to be irredeemable scum and someone who, I
hope, is no longer called to be a face of the movement"; "I've heard him on many a podcast, but
now glad I've never bought any of his books"; and "The thing is, no matter how good
[Radford's] work is, these actions are impossible to condone. I shall continue to think highly of
Karen, perhaps even more so now for her courage on this issue but also for all the great work she
has done ... and continues to do, but I'll never be able to see Radford in the same light again no
matter what he does." This has all happened to me even though her statements about me were
made knowingly and maliciously and were untrue, as she certainly knew.
25. After my experience with Stollznow's attacks on me, I learned that at least three
other people, including her current husband, have had similar experiences with Stollznow
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making false accusations against them, including of a sexual nature. What I list below are only
the instances that I have learned about (more examples can be found in statements made by
Baxter to police during Stollznow's September 7, 2010, arrest on domestic violence charges). I
include these instances in this declaration because I want to demonstrate that she has deliberately
tried to harm me, as she has others. I believe it likely that there are more instances like these,
simply because it is unlikely that I would happen to learn of all of them:
a. On April 22, 2014, radio podcaster Daniel "Reap" Paden wrote a detailed blog
describing his personal experience with Stollznow, including her falsely accusing
him of making sexual advances towards her, and also of falsely accusing him of
physical abuse. Paden's blog read in part: "I have seen Karen claiming to have
been a [sic] innocent victim but from my experience Karen is not the type to be a
victim. She will do/say anything needed to keep from taking responsibility and
she is vindictive ... Personally I would question anything that Karen Stollznow
says. She obviously has the ability to fabricate whatever story she needs to in
order to avoid taking responsibility for her actions ... .I think it is safe to assume it
was not the first time she has acted out in such a way. In my opinion I find it hard
to believe that Karen is an innocent victim of Ben Radford's. I would find it more
likely the other way around." Paden's account of the false accusations against him
was corroborated by a statement from Beth Hedrick, who was Paden's girlfriend
at the time and had first-hand experience with Stollznow. In a comment posted on
Paden's blog Hedrick wrote, "I remember her [Karen Stollznow] talking about her
boyfriend's fetish, and it seemed personal but I considered it was the alcohol
talking. She became more vocal and agitated about her boyfriend, she is the one
that told Reap that he [Reap] was the person her boyfriend wanted her to be with.
Reap said he wanted no part in it. She became more belligerent and wanting to
end the discussion persuaded her to step outside. She never spoke of Reap having
any sexual conversations with her at any time. She then announced he was an
asshole, and left with another party." Soon afterward, according to Paden, Karen
falsely accused him of making sexual advances toward her. Though alcohol was
involved in this incident, Stollznow's behavior cannot be excused by drinking
because she never retracted her statements.
b. Stollznow called me on September 26,2010, and told me that Matthew Baxter,
the man she had been dating on and off (and who is now her husband), had
assaulted her and broken her wrist. From my experience as a volunteer at a local
domestic violence shelter, I was concerned about her safety. I told her that she
should not stay with an abusive partner, and Karen asked if she might come visit
me for a week at my home in New Mexico to get away from Baxter and clear her
head. Karen e-mailed me later that evening, thanking me for consoling her and
trying to help her: "Hi Ben, Thanks for the chat tonight. You made a lot of sense.
Should your calendar be free, the dates around Tue. Oct 12 to the following Tue.
are reasonably priced for me, although I understand if this is too long a period of
time. Please think on it when you can! Have a great trip in KY, and thanks again
for being so sweet to me."
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I later learned, after Karen accused me of sexual harassment and assault, that
Karen's accusation against Baxter was false. Though she had slightly injured her
wrist during a fight with Baxter, it turns out from the police report that Stollznow
was the aggressor and had been arrested for domestic violence. She had become
jealous because she discovered that there was a photo of a former girlfriend of
Baxter's on his Facebook page. As a consequence, Stollznow, according to the
police report, smashed Baxter's camera with a hammer, clawed his face, arms and
torso, and dumped a container of protein powder on his head. As to her claim to
me that Baxter had broken her wrist, the arresting officer stated in his police
report that Stollznow was examined at "St. Anthony Central Hospital, where they
did medically clear her to be able to go to Jefferson County Jail. It should be
noted that Stollznow's wrist was fine and not fractured." Thus Stollznow had
known since September 8 that her wrist was fine, yet three weeks later when she
called me seeking help, she told me that Baxter had broken it and that she had
been the victim of his domestic violence.
c. Before Baxter and Stollznow got married, Baxter emailed me in 2010 to seek
relationship advice and complained that "My relationship with Karen has been a
rocky one. She is the most enchanting, wonderful, spiteful, insecure, grudge-
harboring woman I have ever met. The thing that worries me is the signs that she
is either a huge liar or delusional." Baxter gave several examples of Stollznow
making false accusations against him, and stated, "So much of Karen's time seems
to be spent finding ways to incriminate me. This has been from the beginning. I
have done everything I can to put her fears to rest and show her how much I love
her. Now I think I am seeing that it has never been about fears. She and I don't
seem to live in the same reality. Her mood swings are violent and she admits that
she doesn't like to let go of anger."
26. Both my mother and father, who live in Corrales not far from Rio Rancho where I
reside, were surprised and worried by Stollznow's accusations against me. The accusations
caused enormous upset and concern on their parts, leaving me in the position of having to
carefully explain to them, in a very emotional family meeting, that Stollznow's accusations were
demonstrably false. Although I have made no effort to find out how many people in New
Mexico, Rio Rancho, or Corrales know about Stollznow's false accusations against me, I have
no doubt that many have been exposed to them. If one does a Google search for my name, after
the introductory entries that are biographical (such as Wikipedia), one of the first articles that
appears about me is under the title "Ben Radford Accused of Sexual Harassment."
http:// skepchick. org/20 13/0 8/ben -radford -accused -of-sexual-harassmentl. The first sentence in
the article states: "Karen Stollznow, paranormal investigator and former Skepchick writer, has
written a post over on SciAm alleging that she suffered years of sexual harassment and even
sexual assault at the hands of an unnamed colleague who has since been revealed to be Ben
Radford." Certainly many of my friends and family in New Mexico have read this.
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27. As a consequence of Stollznow having communicated her false accusations to my
friends, colleagues, potential employers, those who run conferences at which I previously spoke,
and most importantly my employer, I had to borrow many thousands of dollars from my parents
to pay my attorney to respond to Stollznow's false allegations in the course of communicating
with my employer, and in a failed attempt to persuade Stollznow to retract her allegations so that
we could avoid litigation.
28. Having come to New Mexico to stay with me for four days in 2008, Stollznow was
well aware that I and my mother and father all lived here. Indeed, Stollznow met them and
appeared to me to go out of her way to establish rapport and a good relationship with my mother
(in fact when my mother and our extended family visited Stollznow in San Francisco in June
2009, my mother mentioned in passing to Stollznow that she'd make a good daughter-in-law.)
29. Stollznow's false and defamatory statements to my employer, CFI, caused me to lose
two weeks' pay and receive a letter of reprimand. I have always received and deposited my pay
in the bank in New Mexico, and check stubs are also mailed here in New Mexico. Her false
statements substantially destabilized my relationship with my employer. Although'CFI is
located in Buffalo, New York I have performed my work for CFI from my office in New Mexico
for the past six years. In addition to depriving me of two weeks' salary, her false accusations
caused me to spend well over $25,000 in attorneys' fees when I felt compelled to seek legal
assistance in addressing my employer, CFI, regarding Stollznow's accusations, which CFI had
taken seriously, not knowing that her accusations were false and the dates of critical emails
falsified.
30. In the aftermath of her blog post on Scientific American, and her efforts to be sure
that my colleagues and acquaintances knew that she had been referring to me, I remained silent
for a period of months. But because she made an effort to identify me as the person who had
supposedly sexually harassed and assaulted her, I became a target of venom and ridicule
throughout the "skeptics" movement, and numerous other articles and blog posts appeared in
which I was identified and reviled as a serial sexual harasser and even sexual predator. Typical
examples of these follow-up posts are:
a. August 7,2013: Stollznow provided blogger Carrie Poppy with correspondence
between Stollznow and the president of a prominent skeptical organization, the JREF.
The piece reads in part "Dr. Stollznow says that she was assaulted at the James Randi
Educational Foundation's (JREF) annual conference, The Amazing Meeting (TAM)
on three separate occasions. Dr. Stollznow is a research fellow for the JREF, and is a
respected speaker at TAM. The person who she says assaulted her is Ben Radford,
another speaker at TAM ... "
b. August 7, 2013: Brian Thompson, Carrie Poppy's boyfriend, tweets "I know enough
women who have been harassed by @BTRadford and @michaelshermerto know it's
not' gossip'. These men are garbage people." This was retweeted 18 times to nearly
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120,000 people. I have never sexually harassed any women at all but Stollznow has
been able to brand me a sexual predator.
c. August 7, 2013: Prominent skeptical blogger and podcaster Rebecca Watson widely
disseminates a post titled, "Ben Radford Accused of Sexual Harassment," including
on Facebook, Twitter, and web sites such as www.ScienceSeeker.org. She states,
"I'm very glad that Radford's name was leaked, because it's extraordinarily important
that women know who to watch out for and for conference organizers to know who
they're putting on stage .... The harasser will face social repercussions, other women
will be better able to keep themselves safe, and perhaps most importantly, other
women will feel comfortable speaking out about their experiences and being stronger
for it."
d. August 8, 2013: Kenneth Downey and Robert Gross, under the name Blind
Labyrinth, wrote a song about Radford's accusations and posted the video to
YouTube. Titled "Sick of Talking About Sexual Harassment," the three minute,
seven-second video begins with a prominent photo of Mr. Radford above the caption
"I'm sick of guys like Benjamin Radford." It was eventually viewed nearly 1,000
times and as of January 2014 was online as a private video.
e. August 12,2013: Joe Anderson, a close friend of Stollznow's, writes a blog titled
"Shame on you Ben," in which he states that he fully supports Stollznow in part
because she shared several of Radford's allegedly harassing communication with
him. These e-mails, which were written in 2009 and 2010, were offered as evidence
that Radford had sent harassing emails to her in 2012, after she was married.
f. October 16,2013: Radford's name and twitter handle, @BTRadford, is placed on a
public list of "Predators: A public list by Kim Hanfelt"
g. March 3, 2014: Blogger PZ Myers, in a blog attacking Radford, states that
Radford "is guilty of sexually harassing Karen Stollznow for years."
31. I have no connections with the State of Colorado or Denver, Colorado, except the
following: About twenty years ago, I traveled to Colorado for a Pink Floyd concert. Other than
that, I've never been to Denver. About three years ago, I had a phone conversation with a
Colorado glass blower in connection with a book I was writing at the time. Other than these two
contacts, I have had none with Colorado.
32. The witnesses whose testimony will or may be required in the course of discovery
andlor trial include the following. After each name, I have listed the witness's place of
residence:
a. Plaintiff Ben Radford (Rio Rancho, New Mexico)
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b. Ken Frazier (Albuquerque, New Mexico), Editor of Skeptical Inquirer and Executive
Council member of Center For Inquiry, Radford's employer. Frazier has knowledge
of Stollznow's trip to New Mexico and solicitation of business here; the impact of
Stollznow's accusations regarding Radford on Radford's reputation and standing at the
Center For Inquiry and Skeptical Inquirer.
c. Parents of Ben Radford (Corrales, New Mexico), who will testify as to impact on
Radford of Stollznow's false accusations.
d. Daniel "Reap" Paden (Fremont, California). Paden has knowledge of other false
accusations by Stollznow regarding supposed sexual misconduct.
e. Heidi Anderson (Greenville, South Carolina). Has knowledge of the relationship
between Radford and Stollznow in 2009 when Stollznow claimed Radford's
harassment occurred.
f. Jenna Griffith (Buffalo, New York). Has knowledge of Radford and Stollznow's
relationship as well as Stollznow's history of false accusations.
g. Blake Smith (Atlanta, Georgia). Third member, with Stollznow and Radford, of.
"Monster Talk" podcast. Has knowledge of absence of prior allegations of
"harassment" or the like.
h. Ron Lindsay (Washington, D.C.). Lindsay is CEO ofCFI, Radford's employer.
Lindsay imposed suspension of Radford based on false statements by Stollznow and
documents falsified by Stollznow.
1. Ann Rogers, Esq. (Albuquerque, New Mexico). Has lmowledge regarding impact of
Stollznow's allegations on Radford and his parents.
J. Beth Gramigna (Short Hills, New Jersey). Gramigna was the investigator, hired by
CFI to investigate Stollznow's allegations against Radford. Gramigna received the
falsified emailsfromStollznowthatStollznowused, along with other fabrications, to
persuade CFI that Radford had behaved "inappropriately" and merited a suspension.
k. Dave Thomas (Peralta, New Mexico). Thomas is a physicist and head of the local
skeptics group. It was his radio talk show on which Stollznow appeared in late 2008.
1. PZ Myers (Morris, Minnesota). Meyers is a prominent blogger whom Stollznow
communicated her false and defamatory statements about Radford to, and who then
disseminated them on the web.
m. Carrie Poppy (Los Angeles, California). Poppy is another blogger who disseminated
Stollznow's false and defamatory statements about Radford after Stollznow directly
communicated them to her, and in fact spread them with Stollznow's "blessing."
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33. The documents that relate to Stollznow's conduct and this litigation are virtually all
emails or other documents that are "online" or are readily available electronically_ In. addition to
emails, the documents related to this case include blogposts, Twitter and Facebook posts,
electronic recordings and other documents that can be exchanged easily by electronic means. To
my knowledge, the only substantial volume of physical documents that may exist would be the
file in the possession of Beth Gralnigna, the investigator that my elnployer, CFI, hired to conduct
an investigation into Stollznow's accusations against me, and to whom Stollznow provided the
emails whose dates she had falsified. Although I have 110t seen her report, on infonnation and
belief her file and her report will contain other falsehoods from Stollzno\v.
I declare under penalty of perjury under the laws of the United States of America that, to
the best of my knovvledge, the foregoing is true and correct.
Dated: May 1,2014
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