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).

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

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:

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,, 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.)

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:



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