https://github.com/Enegnei/JacobAppelbaumLeavesTor/blob/master/JacobAppelbau... Some elements are now in court, there are a number of people filing statements, here is one of them... https://www.courtlistener.com/recap/gov.uscourts.cand.340308/gov.uscourts.ca... For Exhibits A through P, run the 0.pdf from 1.pdf through 16.pdf . UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION PETER TODD, an individual, Case No. 4:19-cv-01751-DMR Plaintiff, DECLARATION OF JACOB APPELBAUM v. IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANT'S SPECIAL SARAH MICHELLE REICHWEIN aka MOTION TO STRIKE PLAINTIFF'S ISIS AGORA LOVECRUFT, an COMPLAINT (ANTI-SLAPP MOTION) individual, Date: August 22, 2019 Defendant. Time: 1:00 p.m. Location: Courtroom 4 Complaint Filed: April 3, 2019 I, Jacob Appelbaum, do hereby declare: 1. I am a US citizen and a legal resident of Germany for the last six years. I executed this declaration in Germany. I am not a party to this lawsuit. Unless otherwise stated, I have personal knowledge of the facts set forth in this declaration. 2. I am an investigative journalist and an academic researcher in the fourth year of my doctoral studies in mathematics at the Eindhoven University of Technology (TU/e) in Eindhoven, Netherlands. I was a contractor and an employee for approximately eight years with The Tor Project non-profit, a primarily U.S. and European government funded free software project designed to provide online anonymity. 3. I met the Defendant Sarah Michelle Reichwein a/k/a Isis Agora Lovecruft ("Defendant" or "Lovecruft") through a mutual acquaintance in a non-work context, they later joined the Tor Project as a contractor. 4. I have been a target of Defendant's pattern of malicious behavior, in a manner mirroring that described by Plaintiff Peter Todd ("Plaintiff" or "Todd"). Lovecruft's malicious behavior has included Lovecruft's publication of a number of public statements falsely claiming that I had sexually assaulted and raped Lovecruft and others. 5. For example, on June 3, 2016, the website <jacobappelbaum.net> was published. The website as originally launched was written as an impersonation of me, and then rewritten to pretend that the authors were concerned about my well-being after it received extremely negative feedback. A true and correct copy of an incomplete, archived version of the <jacobappelbaum.net> website as it originally appeared is attached hereto as Exhibit A. 6. As later modified, the website displayed several false and primarily pseudonymous stories by a "victims collective" alleging that I had "harassed, plagiarized, humiliated, and abused -- sexually, emotionally, and physically." True and correct copies of complete pages from this website are attached hereto as Exhibit B. 7. A true and correct copy of one of the false claims of sexual assault against me, which was initially published under the pseudonym "Forest" on <jacobappelbaum.net>, is attached hereto as Exhibit C. 8. On June 13, 2016, Lovecruft stated on their personal blog located at <blog.patternsinthevoid.net>, that Lovecruft was Forest in Forest's claim of sexual assault on <jacobappelbaum.net>. A true and correct copy of Lovecruft's June 13, 2016 blog post is attached hereto as Exhibit D. Further, Lovecruft stated that they had spent two years "seeking out other victims, in order to develop the collective capacity to defend ourselves and to have the simple ability to speak out in a manner which would be heard and not discarded." 9. Lovecruft later escalated their allegations against me to include claims of rape. A true and correct copy of an August 15, 2016 Tweet by Lovecruft falsely accusing me of rape is attached hereto as Exhibit E. Based on my prior personal and professional relationship with Lovecruft, I am familiar with Lovecruft's Twitter account and handle. 10. Lovecruft also falsely claimed that I had harassed them, threatened them, and sought to retaliate against them. A true and correct copy of a chain of Tweets that Lovecruft posted on October 11, 2016 containing a sampling of these false claims against me is attached hereto as Exhibit F. 11. Lovecruft's statements accusing me of rape and sexual assault are absolutely false. 12. Further, Lovecruft's statements accusing me of retaliation in any form, including harassment and threats, are also absolutely false. 13. Following Lovecruft's publication of false claims against me, I repeatedly and publicly expressed my commitment to working to resolve any conflict or misunderstanding arising from my personal and professional conduct through mediation or other means. A true and correct copy of one such public statement (comprising a Twitter chain and linked blog post) is attached hereto as Exhibit G. 14. As stated in Exhibit G and reiterated here: "Inevitably, there may have been moments in my professional or private life when I may have inadvertently hurt or offended others' feelings. Whenever I was aware of these instances, I have, and will continue to, apologize to the friends and colleagues in question and to continually learn how to be a better person." 15. Despite my efforts to resolve Lovecruft's false accusations against me, Lovecruft has refused any and all attempts at mediation. A true and correct copy of a May 12, 2017 Tweet by Lovecruft, publicly refusing to attempt to resolve this conflict, is attached hereto as Exhibit H. 16. While Lovecruft has repeatedly and falsely accused me of multiple crimes (including rape, sexual assault, threats, and harassment), Lovecruft never pursued civil or legal recourse against me either in Germany or any other country, thereby denying me the opportunity to clear my name through due process in a court of law. 17. As discussed above, Lovecruft has claimed that I perpetrated crimes against Lovecruft in Germany. However, Lovecruft has publicly rejected the use of the German legal system (see Declaration of Isis Lovecruft) and additionally, reportedly stated their intention to commit perjury in the event of court proceedings. Attached hereto as Exhibit I is a publication on 18 Oct 2016 by my former university colleague Kit, who uses the handle @SchrodingersK1t, discussing Lovecruft's intent to prevaricate in legal proceedings. 18. Since initially making these allegations against me, Lovecruft's accusations have been inconsistent in their severity. For example, in Lovecruft's Declaration, they represent their allegations as "sexual harassment" and "assault." However, in other fora, including a number of Tweets, Lovecruft accuses me of "rape" and specifically of raping her. A true and correct copy of a February 6, 2017 Tweet by Lovecruft falsely accusing me of rape is attached hereto as Exhibit J. 19. Lovecruft's accusations have also since escalated from "rape" to "serial rapist" and "gang rape" in different contexts. Attached hereto as Exhibit K are: a) a true and correct copy of an earlier, archived version of a blog post by Lovecruft, obtained from <https://archive.fo/qRvDF>, in which Lovecruft made accusations of "gang rape"; and b) a true and correct copy of a February 20, 2019 Tweet by Lovecruft, in which Lovecruft accused me of being a "serial rapist." 20. In mid-2016, as a result of Lovecruft's false statements and refusal to mediate with me regarding their false claims, I had no choice but to retain legal counsel. My legal counsel proactively reached out to the relevant authorities in Germany and offered my full cooperation with any investigation which might arise from Lovecruft's false allegations. The German authorities did not pursue any charges against me. True and correct copies of two articles originally published in German and English in the German news publication Zeit Online, as well as an article published by the Guardian on October 11, 2016, entitled Power, secrecy and cypherpunks: how Jacob Appelbaum ripped Tor apart, are attached hereto as Exhibit L. 21. Since initially making false claims against me in June 2016, Lovecruft has repeatedly courted the press to repeat their false claims against me. In these instances, journalists subsequently contacted me for comment, and I have categorically denied Lovecruft's false accusations. See Exhibit L. 22. I have otherwise striven to remain silent about Lovecruft's false accusations against me to avoid inciting or provoking further false publications by Lovecruft. I have proactively withdrawn from any event where I understood there was a chance of inflaming this or any related conflicts. When I am required to attend professional events for my doctoral research, I coordinate with the relevant parties in advance to explain that I am willing to accommodate others relating to this or any other conflict. The simplest accommodation is the easiest: I commit to follow the rules of their conference and additionally offer to leave if my presence is a problem. 23. Lovecruft's pattern of malicious behavior has included, but is not limited to, defamation, threats, and persistent harassment of myself, my romantic partners, my family, my friends, and my professional colleagues, as well as defamation of my character to uninvolved third parties. These third parties include community and professional conference organizers, employers, potential employers, and academic collaborators. 24. Lovecruft has sought to exclude me from any event they want to attend as well as other events, and Lovecruft has reportedly stated that they would like me to be removed from all countries where they might want to live. This would appear to include the country of my residence, Germany. See Exhibit I. 25. Lovecruft has encouraged others to target and exclude me in a similar manner. A true and correct copy of a June 7, 2016 Tweet by Lovecruft encouraging others to exclude me from the professional community is attached hereto as Exhibit M. 26. Lovecruft has targeted my doctoral research advisors, Professor Daniel J. Bernstein and Professor Tanja Lange. True and correct copies of Tweets posted by Lovecruft from October 2016 and October 2017, threatening and disparaging Professor Bernstein and Professor Lange are attached hereto as Exhibit N. 27. Lovecruft's pattern of malicious behavior and false allegations in the above- captioned case is consistent with their pattern of malicious behavior and false allegations against me and a number of individuals I know. 28. Lovecruft has frequently bragged about their reputation and ability to bully, assault, threaten, and lie to and about individuals. True and correct copies of Tweets posted by Lovecruft evidencing this behavior are attached hereto as Exhibit O. 29. Several individuals have told me that they are afraid of speaking against Lovecruft, lest they be targeted or further targeted by Lovecruft's pattern of malicious behavior. This reflects my state of mind as well. However, I could not live with myself if I had remained silent while Plaintiff was seriously harmed by the same malicious behavior that I have experienced and continue to experience. 30. Lovecruft's false statements have significantly harmed me and others and continue to harm me to this day. 31. Lovecruft's false statements and malicious behavior have resulted in my departure from a rewarding and remunerative position, my exclusion from professional conferences, and damage to my economic prospects. A true and correct copy of a GitHub article detailing the effects of Lovecruft's false statements and malicious behavior is attached hereto as Exhibit P. 32. I am of sound mind and body, though I am injured. I have relied on years of therapy sessions with medical professionals to cope with the trauma caused by Defendant's actions. 33. I consider Lovecruft's inclusion of their previously disputed and defamatory claims about me in this case to be another instance of the pattern of their malicious behavior toward me and toward other people whom Lovecruft perceives as supporting me. 34. That they will continue to mention me in this case is all but assured. I ask the Court to note my experience of that behavior as ongoing harassment and that I request it to stop immediately. 35. This declaration is not a full enumeration of the harms caused to me and others by Lovecruft. 36. I have requested that Lovecruft cease their malicious campaign of defamation and harassment. I reiterate this request and my offer to engage in good-faith professional mediation with whomever should desire it. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on July 26th, 2019. By: Jacob Appelbaum