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COUNTY DEPARTMENT--LAW DIVISION LANDMARK EDUCATION Plaintiff vs. No. nee oe 94111478 business of unknown legal a character, CYNTHIA individually Jury Tr: nded Agent and Executive Director of the CULT AWARENESS NETWORK, JOHN and JANE DOES 1-50 and Unknown aiders, abettors & co-conspirators, ) ) ) ) ) ) } ) ) ) ‘SSER, ) ) ) ) ) ) ) ) ) y Defendants": LANDMARK “EDUCATION” CORPORATION, Now: CoM#s “Pldinti‘e, er referred to as LANDMARK"), by and through its (hereina: ing of Defendant, CULT attorney, WALTER P. MAKSYM, complai: AWARENESS NETWORK, (hereinafter referred to. as “‘CAN*) and/or Defendant, CYNTHIA KISSER, individually and as Agent and Executive Director of the CULT AWARENESS NETWORK (hereinafter referred to as “KISSER") and states as follows: 7 CAUS: x Defamation es relevant hereto LANDMARK was a the laws of the State a IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS offering core program orum and doing business ices located City of c eans, Chicago, Illinois. 2. That on information and belief, at ail times relevant hereto, Defendant CAN was a business of unknown legal character doing business within the City of Chicago, County of Cook, state nois with its “National Office" located at 2421 W. Pratt, ois and Defendant KISSER was a residen| of the County of Cook, State of Illinois and at all times relevant the agent, employee, representative, and Executive times relevant, LANDMARK was known to be a law that enjoyed and was le business untrue, defamatory, slanderous, libelous, scandalous, degrading garding its statements and mis-portrayals, and publici reputation, business and financial interests, corporate charact: and educational endeavors, including its program The Forum. caN and n, could have become knowledgeable o. and. that the ill wrongful conduct undertaken chat such conduct would or could cause great damage to the character, reputation, work, business, profession: educational and financial interests of LANDMARK. information and belief, commencing the twelve (12) months prior to basis with @ intentionally and on reckless disregard , caused to be the County 0 cation and publ and belief Defendant and severally respon and del lars each and said “packet” ne public together with a certain ents designed to disparage LANDMARK more fully described and deciding to cause to be published, the defaming statements therein contained as well as the decision making process as to what material and information to include or exclude from the