August 9, 2019: Don Hilton’s 21-page response to the Nicole Prause motion to dismiss (includes 57 pages of exhibits)

Nicole R. Prause filed a motion to dismiss Donald Hilton’s defamation lawsuit against her. Prause’s motion to dismiss contained false statements and myriad unsupported allegations. Don Hilton responded with a 21-page opposition to dismiss (screenshots below) and 57 pages of supporting exhibits, including his updated declaration (selected excerpts below).

• Downloadable PDF – August 9, 2019: Donald Hilton’s 21-page opposition to Nicole Prause’s motion to dismiss defamation per se case.
• Downloadable PDF – August 9, 2019: 57-pages of exhibits accompanying Donald Hilton’s 21-page opposition to Prause’s motion to dismiss

See these pages for all the gory details related to the defamation lawsuit (and sworn affidavits from other victims of Prause):

• May, 2019: Donald Hilton, MD files a defamation per se lawsuit against Nicole R Prause & Liberos LLC.
• July, 2019: Donald Hilton amends defamation lawsuit to include affidavits from 9 other victims of Prause, Texas Board of Medical Examiners complaint, incorrectly accusing Dr. Hilton of falsifying his credentials.
• July, 2019: John Adler, MD affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.
• July, 2019: Gary Wilson affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.
• July, 2019: Alexander Rhodes affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.
• July, 2019: Staci Sprout, LICSW affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.
• July, 2019: Linda Hatch, PhD affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.
• July, 2019: Bradley Green, PhD affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.
• July, 2019: Stefanie Carnes, PhD affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.
• July, 2019: Geoff Goodman, PhD affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.
• July, 2019: Laila Haddad affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.

The tip of the Prause iceberg

As documented in sections of these pages – page 1, page 2 – Nicole Prause has a history of defaming Donald Hilton MD:

• Fall 2014: Documentation of Prause lying to film producers about Gary Wilson and Donald L. Hilton Jr., MD.
• Prause falsely claimed to have sent cease & desist letters to the 4 panelists on the Mormon Matters podcast.
• Prause falsely accuses Donald Hilton, MD.
• May 20, 2018: Ley & Prause falsely claim that Gary Wilson & Don Hilton gave evidence in a case by Chris Sevier

Don Hilton’s complaint with affidavits from 9 other Prause victims is just the tip of the Prause iceberg. A partial list of her victims includes researchers, medical doctors, therapists, psychologists, a former UCLA colleague, a UK charity, men in recovery, a TIME magazine editor, several professors, IITAP, SASH, Fight The New Drug, Exodus Cry, NoFap.com, RebootNation, YourBrainRebalanced, the academic journal Behavioral Sciences, its parent company MDPI, US Navy medical doctors, the head of the academic journal CUREUS, and the journal Sexual Addiction & Compulsivity.

While spending her waking hours harassing others, Prause cleverly cultivated – with zero verifiable evidence – a myth that she was “the victim” of most anyone who dared to disagree with her assertions surrounding porn’s effects or the current state of porn research. To counter the ongoing harassment and false claims, YBOP was compelled to document some of Prause’s activities. Consider the following pages. (Additional incidents have occurred that we are not at liberty to divulge – as Prause’s victims fear further retaliation against their work/views.)

• Nicole Prause’s Unethical Harassment and Defamation of Gary Wilson & Others
• Nicole Prause’s Unethical Harassment and Defamation of Gary Wilson & Others (page 2)
• Nicole Prause’s Unethical Harassment and Defamation of Gary Wilson & Others (Page 3)
• Victims of Nicole Prause’s Malicious Reporting and Malicious Use of Process.
• Nicole Prause & David Ley libelous claim that Gary Wilson was fired from Southern Oregon University
• Prause’s efforts to have Behavioral Sciences review paper (Park et al., 2016) retracted
• Article by University of Wisconsin student newspaper (The Racquet) posts false police report by Nicole Prause (March, 2019)
• Aggressive Trademark Infringement Waged by Porn Addiction Deniers (www.realyourbrainonporn.com)
• Porn Science Deniers Alliance (AKA: “RealYourBrainOnPorn.com” and “PornographyResearch.com”) (Nicole Prause, Marty Klein, Lynn Comella, David J. Ley, Emily F. Rothman, Samuel Perry, Taylor Kohut, William Fisher, Peter Finn, Janniko Georgiadis, Erick Janssen, Aleksandar Štulhofer, Joshua Grubbs, James Cantor, Michael Seto, Justin Lehmiller, Victoria Hartmann, Julia Velten, Roger Libby, Doug Braun-Harvey, David Hersh, Jennifer Valli, Joe Kort.)

This is shocking – Nicole Prause & David Ley commit perjury in Don Hilton defamation lawsuit.

Screenshots of Donald Hilton’s 21-page opposition to Nicole Prause’s motion to dismiss defamation per se case. (August 9, 2019)

You can follow along with the PDF of Donald Hilton’s exhibits.

The updated Don Hilton declaration (Exhibit A) – which is the first 10 pages of the 57 page PDF of exhibits accompanying Don Hilton’s 21-page opposition to Prause’s motion to dismiss: