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Q - éo&/-/ /477*/
UNITED STATES DISTRIC'F COURT
SOUTHERN DISTRICT OF FLORIDA
GEORGE R. SIMPSON
VS.
JAM ES RANDI , D. J. GROTH aE PRESIDENT OF
JAMRANDAL JAM ES HAMILTON ZW INGE,
AlG JES RANDI EDUCATIONAL
FOUN DATION, JAM ES RANDI
EDUCATIONAL FOUNDATION
FM UD; M ISREPM SENTATION AND
BREACH OF CONTRACT;IN TEN TIONAL INFLICTION OF
EM OTIONAL DISTRESS;
M ISFEASANCE; M ALFEASANCE;
CONSPIM CY (SECT 1985 AND 1986);ACTIQN FOR DAMAGES; ANDACTION FOR SPECIFIC
PERFORM ANCE
PLAINTIFF'S AM ENDED COM PLAINT
Here comes Plaintiff George R. Sim pson, Prose, and files this Am ended
Complaint against Randal James Hamilton Zwinge (aka James Randi), D. J. Grothe,
President of the James Randi Educational Foundation, and James Randi Educational
Foundation IJllEFI, alleging the following: This Amended Complaint replaces the
Complaint filed on M ay 2, 2012.
Jurisdiction
1. The jurisdiction of this Court is invoked under 28 U.S.C. jj 1331, and 28
U.S.C. jj 1332.
2. Venue is proper pursuant to 28 U.S.C. j1391.
3. Plaintiff George R. Simpson resides in Southampton, New York, and has an
address at PO Box 775, Hampton Bays, New York 1 1946.
4. Defendants 1) Randal James Hamilton Zwinge (aka James Randi) 2) D.J.
Grothe, President of the James Randi Educational Foundation and 3) the Jnmes
Randi Educational Foundation (JREF), according to the website operated by
them, have an address of 201 S.E. 12th Street, Ft Lauderdale, FL 333 16.
5. On infonnation and bèlief, Defendant James Randi Educational Foundation
(JREF) is an organization without limited liability protection for its owner and
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 1 of 29
# à
7.
8.
9.
1 1 .
t
operator, Defendant Randal James Hamilton Zwinge? and Defendant D
.J.Grothe, President of the James Randi Ed
ucational Foundation.Plaintiff George R
. Simpson is an engineer, inventor, writer, and businessman
.Today, he makes his living, primarily, from progrnmming and dat
a publishingbusinesses in the Real Estate field on th
e East End of Long lsland (thelbmptons).
Plaintiff George R. Simpson also owns and operates real estate related
businesses, ''Office Vanagement Systems
, Corp. - wwm hamptonslistings.com ,
www.eastendlistinas.com, and Suffolk Research Service
, lnc. --www.suffolkresearch.com , w w w .eastendcomps.com .
Plaintiff Simpson is a recognized expert on the Hamptons real estate industry
and he is frequently quoted in the eight local East End Long lsland newspapers
,and in other publications such as The W all St
reet Journal, The New YorkTimes, The New York Post
, Newsday, and Bloomburg.
Plaintiff Simpson also owns and operates two websites, wwwtufoetblog.com
and www.etcom gods.com, created to explain and promote the ISET C
ol'n Godslanguage and game''.
Defendants 1) Randal James Hamilton Zwinge (aka James Randi) and 2) the
James Randi Educational Foundation IJREFI, have a website: www .randiaorg.
The www.rmxdi.org website describes the JREF pumose as follow s:
1. Keep up the fight against superstition in the world today2
. Promote critical thinking about the supematural and paranormal3
. Provide scholarships to students who show promise in spreading
critical thinking in their chosen fields4. Challenge those who would deceive the
public for profit orpolitical gainOrganize international meetings that brin
g the critical thinkingcommunity together
6. Maintain vigilanee over media organizations that will sacrifice
the truth for higher ratings
j
l
lh
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 2 of 29
www.randi.org describes the Defendant Jam es Randi Educational Foundation
aS:
''An Educational Resource on the Paranorm al,
Pseudoscientific, and Supernatural''.
13. Defendants James Randi, D. J. Grothe, and Jnmes Randi Educational
Foundation (JREF) present a picture of legitimate and professionally run
activities, where Paranormal, Pseudoscientifsc, and Supernatural topics are
studied in a responsible manner.
Defendant JREF maintains a tçcontest'' called il-l-he One M illion Dollar
Challenge'', whieh the website www.randi.org explains as follows:
''The JREF willpay US$l, 000, 000 (One Million USDollars) (''The Prize ') to anyperson who demonstratesanypsychic, supernatural, orparanormal ability under
satisfactory observation. Such demonstration must takeplace under the rules and limitations described in this
docu'ment. An qpplicant can befrom or in anypart oftheworld Gender, race, and educational background are not
factorsfor acceptance. Applicants must be at least 18years ofage and legally able to enter into bindinga reements. ''g
1 5. George R. Simpson, Plaintiff in the instant lawsuit, applied for the içone Million
Dollar Challenge'', fulflling the requirements for applicants contained on the
website (appended in Exhibit 1, letter dated August 18, 201 l).
16. Seven weeks later (letter dated October 3, 201 1) Plaihtiff was informed that
Plaintiff s Challenge application was missing items.
17. By letter dated November 30, 201 1, Plaintiff Simpson supplied missing
introduction letters from two professors, ther' eby completing the application.
18. The following link shows Plaintiffs application for the challenge:
http://ufoetblog.com /'?p=44l 0.
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 3 of 29
@il
1
19. The application is also copied in Exhibit 1 of this Complaint: Letter from
Plaintiff George R . Simpson dated August 18, 201 1 to James Randi Educational
Foundation, enclosing the ltApplication''.
Facts
20. Plaintiff George R. Simpson, for 27 years
, has been performing the scientific
investigation and discovery of a hidden language, embedded in the English
language.
Plaintiff Geprge R. Simpson has documented thousands of examples of words
which contain hidden 'meanings. The existence of these hidden meanings is
proof, contrary to common belief, that the English language did not ûtevolve''
Language, rather, was planned (designed) so that these hidden meanings could
be revealed by using the decoding nlles discovered by Plaintiff
Subliminal communication with the paranormal presence confirmed Plaintiff s
course of study and discovery. In addition, his hundreds of thousands of trial
and error translations gave feedback as to the correctness and suitability of the
translation methods and decoding rules.
23. The existence of thousands of word decodings is proof of the btparanormal''.
24. The hidden language and decoding structurq to uncover hidden meanings was
named the ::ET Corn Gods language and game''.
25. One objective of Plaintiff s ET Col'n Gods language/game discovery and
documentatipn (for many years) has been to apply for, and to win the JREF The
One Million Dollar Càallenge.
The following link shows Plaintiff s application for the challenge:
http://ut-oetbloc.eom/?p=44lo.
27. The application is also copied in Exhibit 1 of this Complaint: Letter from
Plaintiff George R . Simpson dated August 18, 201 1 to James Randi Educational
Foundation, enclosing the çlApplication''.talso included in Exhibit 1)
28. In his applieation, Plaintiff Simpson proposed as a tejt protocol (to test whether
the claims are étparanormal''), the following:
li1
4
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 4 of 29
k
é'Ipropose a d#erent set ofdecoding criteria, e.g. someother base number other than 66,. a dterent list ofBiblebooks, bookpositions and book abbreviations
..
dp rentchart ofelemehts. ''
Exhibits IV and V provide snmples of randomly selected Bible Books and
Elements that could be used in the Challenge.
Seven we'eks later, Plaintiff received a letter, dated October 3, 201 1 from
President of JREF, Defendant D.J. Grothe. His letter said that applicant
Simpson had omitted one requirement of the Application, that om ission is
covered in the following statement options to submit from the www.randi.org
website:
a. ad signed letter ofreferenceh'om a medical doctor, afaculty memberat an accredited university or college, or a professional researchscientist (i.e., employed by an industry or government agency)stating that the person should be considered a serious Applicant andthat the claim merits testing.
ad copy ofqny article, book television appearance (other than thosepublished solely on the Interneo, or other recognized independentmedia in which the Applicant and the relevant claim arefeaturedSelf-promotional or self-published accounts do not qual#.
c.. W video (made available electronically or delivered onphysicalmedia) in which the Applicant clearly demonstrates the claimedability Self-produced videos are permitted Such video becomes theproperty ofthe JREF and the Applicant grants the JREF anirrevocable license to publish or otherwise use the video in any wtz
-p.
Submitting a video is the lowest standard ofthese three options, andApplicants who choose to provide a video instead ofa letter ofrejèrence or media sample are not automatically cxonsideredfor aPreliminary Test and are not entitled to a written explanation oftheir rejection. The selection ofvideo Applicantsfor PreliminaryTests may be done by any method, at the JREF'S sole discretion.
Plaintiff applicant Simpson fulfilled the missing application requirement by
supplying ûçsigned letters of introduction'' from two separate professors from
accredited universities. (Letter dated November 30, 201 1)
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 5 of 29
4*
Months passed with Plaintiff Simpson waiting for Defendant JREF to respond.
33. Then, Plaintiff got an email from Defendant JREF (months after the corrected
application was mailed to JREF). The email said that JREF needed two or three
weeks more to evaluate Plaintiff s applieation.
34. M onths passed, again, with no answer from Defendant JREF. Plaintiff had been
romised a response in tûtwo or tllree weeks''.p
35. Plaintiff Simpson made numerous emails and phone calls (a1l the JREF phone
lines are answered by machine) to Defendant JREF. None were answered.
Plaintiff also inquired to people named on www.randi.org, known to be working
with Defendants Jnmes Randi and JREF, asking: ûéW hy don't they return phone
calls? W hy don't they return emails? Is Randi afraid of my winning his
$1Mil1ion?''
37. Someone set up a discussion thread at www .randi.org concerning the George R .
Simpson (titled çreorge Russel Simpson'') application, which was not being
followed up by Defendant JREF. The thread stayed on the internet for three
days, was made inactive, and then several weeks later, it was taken off the
Internet. The thread was started on M arch 3, 2012, 09:42 AM by poster
dtpaulmark''. The last post appeared on M arch 6, 2012, 1 1 :14 PM by poster
llwardenclyffe''. JREF advertises that it is the place for free and open discussion
of the ûtparanormal'' and tlskeptical'' except when it comes to discussing One
Villion Dollar Challenger, George R. Simpson.
38. Plaintiff was able to get two of the Randi.org associates to commtmicate with
him. One of the JREF'S içsenior Fellows'' said that Randi.org was not
answering Plaintiffs phone calls and emails, because Plaintiff Simpson had
previously sued Jam es Randi and JREF. Plaintiff Simpson's response was:
''Ifyour SlMillion Challenge is not being offered to thosewht? hadpreviouslyhled suits against James Randi/lRkythen your SMillion written tpf/'cr should say so ''.
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 6 of 29
39. Plaintiff Simpson was also able to start a içFacebook'' dialog with Tyler
Measom, one of the two filmmakers of a documentary about James Randi called
itAn Honest Liar''. Mr. M easom told Plaintiff Simpson that Defendant James
Randi didn't have time to get back to a1l those who applied for the SlM illion
Challenge, because he gets 100 applications a month. That statem ent is not
trtle.
40. Finally, on April 03, 2012, Plaintiff received the appended email (Exhibit 1I)
from ûtBanachek JREF <[email protected]'. The email asked four
questions of Simpson about his Challenge. The email (and the JREF questions)
was answered by Plaintiff Simpson's Exhibit II1 email, requesting that
Defendant JREFget back to him within a wcck
Defendants did not respond within the requested one week time period.
Defendants, at the tslihg of the instant Complaint, have not responded at all.
42. Defendants have therefore violated a contractual relationship with Plaintiff
George R. Simpson.
43. There was an offer made by Defendant JREF on the website Randi.org The
same or slightly changed SlM illion Challenge offer had been accepted,
according to Defendant James Randi, ûçover one hundred times'' with other
people who wished to have their tdparanormal claims'' tested.
44. The Exhibit 1 challenge acceptance and subsequent correspondence from
Defendants to Plaintiff is evidence of the three elements of a contract: The 1)
offer, 2) acceptance and 3) contract compensation.
45. But when Plaintiff George R. Simpson filed an application for the $ lM illion
Challenge, he was treated in a fraudulent way. Defendants did not return calls
or emails.
46. When Defendant JRE/ finally answered by email on April 03, 2012, the answer
evidenced total lack of understanding of Plaintiffs proposed Stprotocol''.
47. Note: çiprotocol'' is the word used in the JREF SlM illion Challenge to define
the testing scheme for each Challenge.
7
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 7 of 29
48. Defendants claim to be the defender of scientific and critical thinking methods,
yet they exhibited the scientifc/math sophistication of a grade school student.
49. Because of the stonewalling and inactivity of Defendants, Plaintiff has been
fprced to sue to compel Defendants to perform as they have promised in their
advertised Gûone Million Dollar Challenge''.
50. Defendants have treatçd Plaintiff in a fraudulent manner and have
misrepresented their offer.
51 . Because Defendants know that Plaintiff Simpson will win the $ lMillion
Challenge, Defendants are stonewalling, trying to avoid the contest.
W hv is The ET Corn Gods Lanzuaze and Game
Evidence of the Gparanorm ar.
52. W e are taught that Language evolved. For language to be organized in a pattern
which cannot be explained by evolution would be evidence of. divine
intervention or the tlparanorm al'' W e are taught that words were created by
circumstances over a long period of years. As words were coined in use, they
became a part of the English Language. Al1 words, including recently coined
words such as Stcar'' tftoaster'' tçcomputer'' are thought to evolve, one word at a5 5
tim e.
53. But, in fact, the ET Corn Gods language/game discovery is evidence that GOD
preplnnned the English Language so that words and groups of words were
linked together within words giving meaning to the words, using the rules
contained on the website www.etcorngods.com
The websites www.ufoetblog and www.etcorngods.com provide thousands of
exnmples of the hidden pre-plalmed linked language within words.
55. For instance, the word çtcom puter'' decodes to the key components of a
ikc tejz, lOm Pu .
1 C ter'ompu .
C is c+66+66 = tlm e''
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 8 of 29
Drop oTherefore'.
Com = ûlM em''
Add 0+66+66 ...' = 1:Or''.
R is 18, 180, 180 = 1 eighty. (Sdd ç10'')Therefore'.
Com = içM em ory''
Therefore'.
Computer = ûtM em ory puter''
Pu is up, backwards. .
1.1-66-66 .. = 4, book backwards is 40, book Mt, mt-66-66 . .. = ççHar''.R is 18, 14+4, 14+44. (add 40, 40 is book Mt, 1m-66-66 ... = (û0'')Therefore'. '
Computer = tûM emory Hardd d ter''.
D is 500. 5+33, 38, 108, 18, IûR'' (drop 110'5)Add 0+66+66 .... = çtor'' backwards is tçro'' book 45, lûive''5 ' *
Therefore'.
Computer = t'M em ory Hard Drive Ter''.
Ter:
T is 20 book 1Tr''7 *
E1+66+66 . ... = ç$In''
Add 0+66+66 ... = 1$Sn'' Sç-l-in'' 111-66-66 . .. = tder''5 5 *
Therefore;
Computer = çlM emory Hard Drive Printer''.Add o, 15, 13+2, tçMb''5
Add o,
Add 0+66+66 .. = ltther''.B is Boron,
Ron = rn, rad. (drop t$o'')Ra is 1 8 1 , backwards is 18 1, ûçAr''.Therefore:
Boron = ûlBoard''
Computer = ûtM emory Hard Drive Printer M other Board''Add 0+66+66 . .. = 1ESn'' :l-l-in''5 ,
T'.
T is 20, book Pr. .
P is l6, 6 is vi, 229, 2+29 = 1$Ca''.Therefore:
PF = VVM RI'''
Ar is a1--66-66 . .. = td52'' book ûlAth''5 *
UIT == Vilsl Ettll''
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 9 of 29
Computer = HM emory H ard Drive Priùter M other
Board M ath Internet Program ''
56. Note the logic to create the incredible string.of words common to a computer
use the number 66, Roman Numbers, the elements Sn (Tin), Boron, and the
àooks of the Bible, 1çPr''.
57. Here are som e exnmples of simple translations.
58. Take the word çtDiscovery''. (The word suggests some triscovery'').
Discovery:
D is letter 4. (a,b,c,d)C is Roman Num eral 100.
In :Add 0+66+66 .. = 1$Sn'' ût-l-in'' 1n-66-66 = 'çer''5 9 *
Add 0+66+66 .. = tiNet''
Therefore;
ln = ûllnternet''Therefore'. .
Computer = lûMemory Hard Drive Printer M other Board M ath Internet''Add 0+66+66 . = û1Sn'' Sû-l-in'' 1n-66-66 = û'er''5 5 *
T is Pr, Pro. (add 105)R is l8, 18+40 = 58, 58+66+66 ... = 1ûGr''.
Therefore'.
Ter = Etprogr r''
R is r+66+66 .. = 1:Al'' L+66+66 = ûtnd'' n+d = R 1+66+66 .. = ç1Al''5 5 5 *
Therefore:
Ter = ûlprograal''
AL backwards is La, 121, backards is 121, La.La = l+a $ûM '', *
Ter = ttprogrnm''
Computer = itMemory Hard Drive Printer M other Board Math lnternet Program''.
Add 0+66+66 .. = t1Net''.
N is ad, Add. (D is 3, add 40, book Mt, Mt-66-66 ... = tû0'')Add 0+66, book Rev. v is 22, book tCSS''.
Et+66+66 .. . = ûtip''Therefore:
Computer = 'çM emory Hard Drive Printer Mother Board M ath lnternçt Program
Address IP''
10
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 10 of 29
Y is letter 25.
Therefore:
Discovery = $ç4 is 100 over 25''. (D is C over Y)
59. Take the word liFormula''. , The word says: CûF or MULA''. The word
tiFormula'' has two im portant translations.
Formula: (meaning 1)IIM '' is letter 13.
u1a = A1. (letter IIU'' turns adjacent letterts) bqckwards e.g.: U La = Al)Therefore:
Form ula = fiFor 13, AL''.Note: 13 is the atom ic number of ûtA1''.
Formula: (meaning 2)U and L cancel.
(Letter 21 and letter 12 cancel each other in accordance with therules)
Therefore:
Form ula = diF or M A''@
Note: F = M a is a most famous physics formula.
60. W hen Plaintiff Simpson was given the assignment of deciphering the English
Language to find the keys to the lll-lidden Language'', it took two or three years
of trial and error to get the tsrst clues of the decoding rules. Then it took over
25 years to develop a working knowledge - all trial and error.
61. lt was like being brought into a cave where there were strange writings in an
unknown language on the wall of the cave. The job is to decipher the language,
find the keys, which convert the cave wall Fritings to English.
62. An analogous situation was the discovery of the EtRosetta Stone''. W hen the
stone was found, there were years of trial and error cycles to discover/decipher
what was N itten on the stone. It fnally turned out that there was the same
message repeated thre'e times, each of the three is a different language.
63. lt took a long time of trial and enor to decipher the three languages, as it took
years to decipher the ET Colm Gods language/gam e translations.
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 11 of 29
W hy does the ET Corn Gods Ianguage/game work?
64. Astounding as it might seem, words in the English language were pre-
programmed with hidden meanings within words, which are revealed using the
translation decoding structure of the ET Corn Gods language/game.
65. And, the language decoding very cleverly uses a combination of Bible Books
(abbreviations), Chemical Elements (Names', Atomic Numbers, and Atomic
Symbols) and the other tools/rules to discover hidden meanings. The decoding
process is not easy, but it can be taught to anyone with a high IQ.
The word lûW ord'' decodes to çtook Hard''.
67. Deaths, births, national disasters, etc. are pre-programmed into the words which
describe them, as if someone has been here (now) before. There is the
suggestion that everything is pre-plnnned - predestined by GOD .
68. ln summary, the ET Corn Gods language/game works because GOD designed it
to work, and GOD is the greatest (ultimate) engineer/programmer in the
Universe.
69. Here are a few of the hundreds of translations on wwk.ufoetblox.com which
convert to events/people/dates. (more summarized here:
http://ufoetblog.coln/?p=s6z3)
Myron L eon Wallace = 'Jew Rich, New Canaan CT(in),April 7, 2012, age 93, dea4 M ay 9, 1918 on date born, C7#5'60 Minutes Ace (A1l talk show) ''.See '' httn://ufoetblog.com/?p=s7s4
Whitney Elizabeth Houston = ''Record Star, Hit Singer,
Black Woman, 2012 AD, February 11 Die, ofœ erdose inHotel Room, Christian Faith, Home (US) New Jersey, BornOn Date August 9, 1963 AD ''
See.. http://ufoetbloa.com/?p=s46g
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 12 of 29
Trayvon Martin = (kvbhot At Close Range by Gun 2012 AD
on February 26''
See: http://ufoetblog.com/?p=s6so
Taylàr ks'wf/i = ''CMA Awards Winner, November 9, AD2011 Fr ''
See: lAttp://ut-oetblog.com/?p=soz3
70. Does the ET Corn Gods language/game work like this for all words? The
answer i: tçNo''. Plaintiff is uncertain as to whether there is no meaningful
hidden translations for some words or whether Plaintiff Simpson is simply not
able to identify the decoding routine necessary to uncover the hidden meaning.
The revelations of the ET Corn Gods language/game have W orld changing
implications. The proof of the existence of an all-controlling t.çGOD'' will
virtually end the ûûbelief ' of atheists and agnostics. Since the results of ET Corn
Gods translations are critical of organized religions like Christianity and
Judaism, those Religions will end or be greatly changed.
The ET Corn Gods language/game is an indictment against those who claim to
know/represent GOD (the Pope, Priests, Ministers, Rabbis, etc), or, in the
extreme claim , that there is no GOD, as Defendant James Randi and his
followers claim.
73. This ET Col'n Gods language/game (the basis of Plaintiff Simpson's application
for Defelidants' SlMillion Challenge) is evidence of the Paranormal.
74. This evidence will meet the challenge for the One M illion Dollars.
The ET Corn Gods Language/Gam e Reveals Translation Results Contain Jam es
Randi as a Central Them e.
75. It was discovered, after the Com plaint for the instant lawsuit was originally
filed, that the filing of the lawsuit was predestined - down to the date of the
tiling (tiled May 2, 2012 AD), by many word translations using the ET Corn
Gods language.
13
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 13 of 29
One of the purposes of GOD's ET Corn Gods language/game is to criticize
(condemn) religion. Religion at its worst, according to the translations, is
people who gather together to disbelieve that GOD exists.
Jnmes Randi makes a living out his belief that there is no GOD, that there are no
miracles, and the Paranorm al doesn't exist.
78. Some of the translations uncovered by the ET Corn Gods language about James
Randi are' tsinsulting'', and certainly not ftpolitically correcf'. GOD is very
blunt, and his hidden meanings show his disdain for itpolitical Correctness'':
Exnmples:
Disgusting = içRandi, James, Atheist Jew James Randi Gay Tiny, Joke,
GRS Gam e Corn Gods, Sexy''
lnsulting = (sGag, Atheist Jew James Randi Gay Tiny, Joke, GR S G ame
Corn Gods, Gay Jew''
Rosetta Stone = ççRandi James, ET Corn Gods 2012 AD , D are Fun Fun
Fun Fun ...''.
Note.. The Rosetta Stone (which wJx pre-coded asis the Englîsh Language), and the Pyramids,ET/UFO/Aliens, Crop Circles and the events of9l 1 2001AD, are a1I acts ofGOD, which could not have beencreated by humans. The E T Corn Gods Ianguage/gam e,
Iikewise, could not have been created by humans.
COUNT ONE
Fraud
79. Plaintiff re-alleges paragraph 1 tllrough 78, and incorporates tize same by
reference.
80. Defendants misrepresented the SlM illion Challenge. Even though Plaintiff
Simpson fulfilled his part of the first stage of the Challenge, Defendants refused
to go forward.
14
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 14 of 29
81. Defendants' fraudulent actions greatly dnmaged the Plaintiff, and prevented him
from earning the SlM illion prize.
COUNT TW O
M isrepresentation and Breach of Contract
82. Plaintiff re-alleges paragraph 1 through 8 1, and incorporates the same by
reference.
83. Defendants deliberately, fraudulently, and with malicious intent misrepresented
the slM illiolA Challenge.
84. Under the mistaken belief that Defendants' SlMillion Challenge offer would be
adhered to, Plaintiff invested many man days of work, and the Defendants'
misrepresentations caused Plaintiff to have to sue in the instant lawsuit to get
Defendants to perform under the contract.
COUNT THREE
M isfeasance
85. Plaintiff re-alleges paragraph 1 through 84, and incorporates the sam e by
reference.
86. Defendants managed the JREF Randi.org tione M illion Dollar Challenge''
business with errors and unfortunate results, greatly dam aging Plaintiff
Simpson.
87. Defendants' errors and unfortunate results damaged Plaintiff's reputation and his
financial well being, and it prevented Plaintiff from realizing the SlMillion
Challenge.
CO UNT FOUR
M alfeasance
88. Plaintiff re-alleges paragraph 1 through 87, and incom orates the sam e by
reference.
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 15 of 29
89. Defendants deliberately failed to honor their commitment to Plaintiff Simpson.
They made it impossible for Simpson to continue with the terms of the
SlMillion Challenge.
90. Defendants damaged Simpson by their Malfeasance actions.
COUNT FIVE
Action for Damazes
91. Plaintiff re-alleges paragraphs 1 through 90, and incorporates the sam e by
reference.
92. Due to the aforementioned reasons, Plaintiff has been greatly damaged,
financially and emotionally by Defendants.
93. Plaintiff seeks recovery of the dnmages by Defendants.
COUNT SIX
Action for Specific Performance
94. Plaintiff re-alleges paragraphs 1 through 93, and incorporates the sam e by
reference.
95. Plaintiffs right to compete for the SlM illion Challenge is unique and carmot be
satisfied with money alone. Therefore, Plaintiff seeks the Court's Order to
compel Defendants to complete the SlMillion Challenge specitkally as it is
promised on the Defendants' website, www.randi.org.
COUNT SEVEN
Conspiracv Section (1985 & 1986)
96. Plaintiff re-alleges paragraphs 1 through 95, and incorporates the sam e by
reference.
97. All of the named Defendants were parties to this vicious conspiracy, shown
herein by evidence of Defendants' stone-walling, delay and avoidance of
responsibility of Defendants to continue their responsibility under the Contract
with Plaintiff Simpson.
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 16 of 29
#
Relief Requested
W HEREFORE, the Plaintiff prays for the following relief:
1. An Order for Specific Performance, com pelling Defendants to perfonu the
Paranormal test prescribed by the SlM illion Challenge Offer displayed upon the
Defendant JREF website: wwm randi.org.
An Order for compensatory damages and general damages in an amount determined
by the Court to be paid to Plaintiff by Defendants.
3. An Order for punitive damages in the nmount determined by the Courq to be paid
by Defendants to Plaintiff
A1l awarded dnmages to be Jointly and Severally liable by Defendants, so that a
judgement against any Defendant can be enforced against any Defendant.
JURY TRIAL REOUESTED
DATED: June 4, 2012 GEORGE R. SIM PSON , PROSE
By:
George R. Sim pson
PO Box 775Hampton Bays, N Y 1 1946
631-357-9502
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 17 of 29
CERTIFICATE OF SERVICE
The undersigned hereby certifes that a true and exact copy of the foregoing
pleading was served by mailing the same, postage prepaid, by hand delivery or byth d f June 2012.facsimile on the 4 ay o ,
JAMES RAND ,1 D. J. GROTHEnPRESIDENT OF JAM RANDAL JAM ESHAM ILTON ZW INGEqAIQA JES RANDI EDUCATIONAL FOUN DATION,
JAMES RANDI EDUCATIONAL FOUNDATION
To: Hamilton Zwinge, AKA James Randi,
AndJames Randi Educational Foundation
12000 NW 8 Street
Plantation, FL 33325
Via: Mail gxxxj Fax ( 1 Hand g 1
To: J. D. Grothe,
1724 Highland Ave 525
Los Angeles, CA 90028
Via: Mail (xxx) Fax ( q Hand g )
Xtlv-
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 18 of 29
Exhibit I
The srst, absolutely for etzre, intellectual corllac/ with ET's.
see: www.Etc-o-rpGods-com
August 18, 201 1
Jam es Rahdi rduc tional Foundation
Mlllim Dcllar Challenge7965 Hollywood Boulevar :d # 666bos Angelx , CA 90028-6:35
Gentiemen
Ptea/ 5nd my *nclo:e Apjllcatlon fèf llla Milllor Dollar Chall@nge. A1K entlo:od @r: Oples dtwu al:ce e efe my wœrk * pqblished - fulfllllng lh'e rêqqiYment of yopr rulK .
l lx k fofward to Iearing frorrl you ard winnkn: the 51,0ûG,Qû0.
Sln- : youa;
0*0%e R SimpAPO Rm* 775Hampton Bap , NY 11948631-357-9502
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 19 of 29
*
I was vpsited W exedprrestnal presenc: ty/eflty-glxyeareago l he'#8 teen in contactwithU presence on 8 delly basiq ,slnceth. erl l yv'as tclt thet tlngre @a! .# hidden languageln tln. Englishlâncua; .: end thgt itwes rw jcb to decpde It and tell it to tl): wirtd.I tloe dosume v'ntêd S:tflends Qf trapslet--lon .s i'ierer w- ':étçcrngpdikcem, D t Illare:
kmw çifrmttlejqom 'T'he f99o14d -lcrtls r'ent4in Erlglich ye.r -sl 'ons 9:f'tho lhiddpqlmeaildgs E ilh ôtst ij .a mlratb (lrocf éf tt'e, pàrântmla# ), C4rtalrilktheusendé t?fyalhsiateà v rdi 'wnuld quellfv,tö win the $M' i'lllcn challeng.T)* encw tlon (tonslation) rklos at* 'zosainvd here'.hp'x/e ,etcp*gpds.c,ûe tàhslMon.bsn) 4ni here'http'.//- zëfr.om,i' pdskem/sàf:rkhtéth>Th: translajôtj rttles i'nvckë 1) Thi besê ntprùber 6,' ntlmbem càn bextbnverted tolettel's and hijeàversl 2) $$ bocks cf the Blbb (blxk pïxitcn, bcok name, end bockabbrcviptipnl; A) The P4ri9,1iç .C' hac '3f Elpmifds. (Atpmit Number, Atcmi'c Skmb. :l,Atèmic Nétn4)', 4) Arabic @iid koMan Numèrals'.
.
I preptxe a èrdcc:l tô i4st *# claim bf a di#èrept s8t ct decoding.critdtfe, q.g someother base numberthan 66., ta ti#erent llsto? Sibb books. , bcek positlôrts, ânt b. cukatkreviptipns; iiffp*Atchart 'lfèlemkntj. lt is' pfojected th'et stteh dlffer:nt translationrtile: w'lll h:t pràdlatè mèanipjful trahsletlcn .s Ccpi'es rg:ethed cïf ië trénslflpnjpublibhad Iijë 14:.,/4 . trti'r lrtle qnnétMt,com/z' 01 I.Qà' 1 1 html
sv . r.: .
oa-: . Rl 1 7 / J /4/8.111:k1.4:-1.:112 -.----
20
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 20 of 29
*
. zlr ::. '.jrigjy1 je x*'#
'
. .
#4'I i'è'Eile Kdlt ï
'
iew Iools Yessage # p
p . : . .s .. . îj
.)j è ..V .. E,,jjReply Reply AII Forward Prlnt Delete Prevlous Next Addresses jiy/f
aem: irio
Date: Tuesday, il 0% 2012 7232 PMT'o: Banaclnek IREF; D,J , Grothe; Thomas Donnelly ; Brian T pson; [email protected]
subject: Re: Hey
T0: George slmpson; D.J. Grothe; Thomas Dnnnelly; brian Thompson
s tlb (lec- t : R e ) H e y
Exhibit 11
M r Simpson,
l have been giving your applications some serious thought as it is a hard one to really
set a scientific test with the information you have provided with your application.1 would like to proceed, however, 1 need some clarifcation since l see no real method,
no hidden language but rather coding if anything, and a 1ot of subjective answers. Forinstance in many of the coding you have done in the past, you reveal information about
people but it seems very subjective in the answers.lf your coding does reveal to you characteristics about people via their names. W e
could have you do a coding on people's names (as you have done in the past), and havethe people match the interpretations with themselves. That would be pn easy test. Butagains not clear on what you can and can not do other than find hidden words via what
looks like a tlexible code. l could be wrong and that is why I need clarification please.
So if you can answer the following questions for us, we may be able to proceed at a
better rate in putting some sort of protocol together.Please answer with short concise answers so we can understand better.
l . Please explain your claim in one sentence.2. Please explain how your ability is ''paranormal''.3. If your ''decoded words'' are ''English versions'', what is the language of the ''hidden
language''?
4. How is the language an objectively collected ''hidden language'', rather than asubjective interpretation?5. How do you propose your claim be tested?
Tharlk you. .
BanachekJREF Million Dollar Challenge Desk
Exhibit llI
21
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 21 of 29
# *
Answers to your questions -1. Please explain your claim in one sentence.
Something worth lsMillion shouldn't have to be answered in ''one sentence'' Thehidden Ianguage is used to translate hidden meanings contained in normal words
(Names, places, events, etc.). The translation method is defined by the decoding matrixdetailed upon www.etcorncods.com: (Books of the Bible, the number 66, RomanNumerals,' and the Periodic Chad of Elements) which allow the decoding of words with
astounding (paranormal) results.2. Please explain how your ability is ''paranormal''Read 1. The translation system is paranormal. I discovered it.3. If your ''decoded words'' are ''English versions'', what is the Ianguage of the ''hidden
Ianguage''?Read 1English words are deciphered to expose a family of hidden meanings inEnglish. The discovery is not unlike the discovery and deciphering of ancient
îanguages. Re: Rosetta Stone.4. How is the Ianguage an objectively collected ''hidden language'', rather than a subjective
interpretation?Don't have 1any ldea what you mean. And my guess5. How do you propose your claim be tested?
W hat have you been doing for the months, since your email told me you would need afew weeks before getting back to me7 My guess is, you are not up to the testing of my
paranormal demonstration.Read my application. 1 have suggested comparing the ET Corn Gods/language/gamein competition with an alternative-coding matrix of the same complexity. Rather than
coming up with rich translations (as with the ET Corn Gods language/game) the use ofthe alternative will come up with little to nothing. Read httn://ufoetbloc.com/?n=44lo
I have provided a sample randomly selected matrixes.Your questions indicate that you have no idea what my clajm is. You guys claim to be thechampions of Science and Critical thinking. The hidden language is Science - perhaps themost unusual science ever. The content of your email suggests the scientific/math
sophistication of a grade school student.Time is of the essence. You have refused to return my telephone calls, refused to return my
emails. I'm not used to dealing with such insulting indifference.You have used up my time. You are not operating in good faith. You have been fraudulent in
your dealings with me.You have a SlMillion challenge, but, under Florida law, your exposure is far greater than
is, you don't either.Read
SlMillion.Please get back to me in a week.
George Simpson
- inal M essage ---------- Clrlg
From : Banachek JREF
To: George Sim pson ; D.J. Grothe ; 'rhomas Donnelly ; Brian 'rhom pson
Sent: Tuesday, April 03, 2012 3:30 PM
Subject: Re: Hey
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 22 of 29
*
i
i1l
11
M r Simpson,
I have been giving your applications some serious thought as it is a hard one to
really set a scientifc test with the information you have provided with yourapplication
.
1 would like to proceed, however, I need some claritkation since 1 see no real
method, no hidden language but rather coding if anything, and a 1ot of
subjedive answers. For instance in many of the coding you have done in thepast, you reveal information about people but it seems very subjective in theanSW CCS.
If your coding does reveal to you characteristics about people via their names.W e could have you d
o a coding on people's names (as you have done in thepast), and have the people match the interpretations with themselves
. Thatwould be an easy test. But again
, not clear on what you can and can not do otherthan find hidden words via what looks like a flexible code
. l could be wrong andthat is why I need claritkation please.
So if you can answer the following questions for us, we may be able to proceed
at a better rate in putting some so14 of protocol together.
Please answer with short concise answers so we can understand better.
1. Please explain your claim in one sentence.
2. Please explain how your ability is ''paranormal''.
3. If your ''decoded words'' are ''English versions'', what is the language of the
''hidden language''?
4. How is the language an objectively collected ''hidden language'', rather than a
subjective interpretation?
5. How do you propose yotlr claim be tested?
Thank you.
Banachek
JRF,F M illion Dollar Challenge Desk
ww w.randi.org
No virus found in this message.
1
1
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 23 of 29
Checked by AVG - www.avg.comVersion: 2012.0.1913 / Virus Database: 21 14/491 1 - Release Date: 04/02/12
24
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 24 of 29
# #
Exhibit IV, Random ly Selected Bible Books
ndom lly Gelleratêd BlbI9 ! Oi.s:
Elii : : :'i.:!.!IIE!II!!iIt.E(: :;: . . ., .jk.:r;L2 2..EL!i(E:1ïL,E..yj, g .:;... . '' .r . i , , .:;: ,,
' '' i,1!8ê ..E ((
mk-xdzn 4 zyimosvx, j x: (ay
> > M t.'rwfaam 4 a1 kyùrx..a 4 :12 ut,trmv= t é: àcA p @ ài :%W 8 X Y1 > pt : % !. r #: 47 ïi F> 1 i àe 1tèly.... it *..j y #yé j j jjj' jjbje --rxjq ji 4,j jKai Sj Q WQ VW b 1 6 17 : # itq j .4,4 k'r 1 vp:I i t; t.à ketx#v.- ## 1 wjj1 .,.-.-,..sr ;, jj j()f, jj tjBi 2j 4z R.iri- xêd4iglè 16 k: 1
x: azaa...ydWXX Q@ > WUtttxtN 24' : 51 'Xtutilàqdi/ 2*o kE.z. utw''li:: ;6' :# 111
aj xj jxky yjywe Irlrli ;;2!: . :
, , (::,,1, , , ,., , .g w y r : j g y. < . .* vpuu aj #; abq ti #à7 bqN .Fe b: 13 mhp:> - 3i é/ J.'
: jj < :z--Y/'NJ , ë . , ,w j w
YG Ae ài * Wheakcw zé 41 ?jkd&zii ake e Iii* dq Y i tv.: 4 1 2 j j rfer ktz à #?
' . . . . . . .. . . . . . . .
K4a 4: i kuiVi :i, d?:F<
Papv t
25
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 25 of 29
4
x ,tE 6 a :na1 N i q .46, ' *. 1A 4% y >$< : >
m/Ye 42.:' 92 : 4: 1c zr: n= u 6, p 1 1 N
i'hd $1 12' 1.:. . k ' k .' ,4y t 't1 blov Q2 1.3 W
g j j &4 .# Nq 54 1! tg g i y g gg jy ajgrq .rqmls A k $'r Tg: p. ,1T' 1: k:ux. .r y .. jg y jjrNll 8* r gé â) <.1 nr 3* 11 1; y @j @@ 9Q >1 Qm ' : '62' 2 ! 12 4, ,4 zq.z q 4 21 3. . . , x. . ..., . ., . . . . . 2. ' ox .. '< E .*. ' 'X XN 6 bè ' œ . Ro é':z j,:u ,,,i:E:. '
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XO 6 1
26
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 26 of 29
4
Exhibit V, Random ly Selected Elem ents
Random Num ber G enerated
Atom ic Elem ents
i EE : ë jë ;r k ! E L##jj4# : !( p;4.o .(t, jj/lj! j#a, u, k yyj jjj; j gal :)!,
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. 3 Trkmiyjpjcq k krkkxf 5 x- 9?F. -. -xzawj'q * 1tblkop 7 Hx:tkktkq j ài,tanyivl j ra$ j j :i, IX @lbsNrj 1 i Ibq ùksjyéj j g tjydq- kk db tytlasyjouf i4 J,pgsxmskrtx ià ,>qttll?l9 16 iif, jj jy rijjk:p'ct ?trii;à i b Li.tqmmgzmy i4 lqcdidgkf 20 dd
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SXrkyiir 37 Ltiiéor- tjèj tji1Jaà ' 39 tj1?N, 9
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Pajti' 1
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 27 of 29
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Xvibb d4 *àigxùr ii éit'àèèiiji, tt t'JN/jdkkiùu ài N:kikxlk àt kftlékkjtaidlrq 5rj étbùiifikhika tt bu' . . . .
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Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 28 of 29
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tikiq/iù.. tlà, . ic.i k9Wik/swr 1t8 WhS'/fkieo'vn $ Yylzùhrtxuo 107 Mudkftmtù 1* ùktùGitikkhub idi tuI 9 -u si q 1 ' -H#' 'P V . ! 1 t 2 wYqYaybf wtiw 1 11 Y!q
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29
Case 0:12-cv-60817-KMW Document 9 Entered on FLSD Docket 06/06/2012 Page 29 of 29