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87 PUBLICATIONS, INC. , MAGAZINE, ADVANCE MAGAZINE — : INC. d/b/a SELF MAGAZINE, “MEMORANDUM OF Law i IN SUPPORT OF DEFENDANTS /_ - MOTION FOR SUMMARY JUDGMENT ~~ NEW YORK. Ny 10188-007: a . TABLE OF CONTENTS PRELIMINARY STATEMENT FACTS ‘The Parties... .... ‘The Article 2.2.2... ee Plaintiff's Complaint... 2.2... DISCUSSION ......-. 5 POINT I AS A MATTER OF LAW, THE STATEMENTS COMPLAINED OF ARE SUBSTANTIALLY TRUE A. THERE CAN BE NO GENUINE DISPUTE THAT THE FORUM HAS BEEN THE SUBJECT OF NUMEROUS COMPLAINTS ABOUT ITS "CULT-LIKE" PRACTICES 1, Leading Cult Awareness Organizations Have Received Complaints About The Forum 2. Plaintiff Has Received Complaints that The Forum Has Engaged in Many of the Practices Detailed in the Sidebar and the Article 3. Complaints About The Forum and its Cult-Like Practices Have Been Widely Reported in the National and International Press . . 4. The Forum Has Been the Subject of Legal Complaints Alleging Cult-Like Practices and Psychological Damage B. THERE CAN BE NO GENUINE DISPUTE THAT THE FORUM HAS: ENGAGED IN MANY OF THE TACTICS LISTED IN THE SIDEBAR ....... + 2. Thought Reform, Mind Control, and Trance Induction 3. Psychological and Emotional Damage Manipulative and Coercive Pressure in Recrtitment 10 - 10 18 - 20 at 26 34 C. OTHER OF PLAINTIFF'S PRACTICES SET FORTH IN DOCUMENTS PRODUCED BY PLAINTIFF ARE ALSO CHARACTERISTIC OF CULTS ... See eee POINT It ‘THE STATEMENTS COMPLAINED OF QUALIFY AS CONSTITUTIONALLY PROTECTED OPINION POINT I THE STATEMENTS COMPLAINED OF ARE NOT "OF AND CONCERNING” PLAINTIFF CONCLUSION ii 35 a7 43 a7