Donald Hilton defamation lawsuit against Nicole Prause: Downloadable PDF’s of Hilton lawsuit, exhibits, and affidavits by 9 other Prause victims

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Initial 17-page complaint (May, 2019): Don Hilton defamation lawsuit against Nicole R Prause.

On July 24, 2019 Don Hilton amended his lawsuit to include:

  1. Affidavits from 9 other victims of Prause,
  2. Prause’s malicious complaint to the Texas Board of Medical Examiners containing false and defamatory statements,
  3. Prause’s accusations with two different professional journals in which Dr. Hilton has published, incorrectly accusing Dr. Hilton of falsifying and exaggerating his credentials.

PDF’s of amendments to Hilton’s lawsuit (numbers 4-11 are the 7 original documents found above):

UPDATE (August 9, 2019): Nicole Prause filed a motion to dismiss Donald Hilton’s defamation lawsuit against her. Prause’s motion 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.

Update (September, 2019): September, 2019: Nicole Prause & David Ley commit perjury in Don Hilton defamation lawsuit.

Update (November 26, 2019): Prause’s motion to dismiss Donald Hilton’s defamation lawsuit is denied (the lawsuit will go forward).

Update (December 26, 2019): Prause is trying to limit discovery. Hilton’s opposition to this game-playing:

Update: Prause and presumed aliases target Hilton even AFTER his defamation suit is filed

The tip of the Prause iceberg

As documented in sections of these pages – page 1, page 2, page 3, page 4 – 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, 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.)

Screenshots of a few pages from the original 17-page complaint, describing the key allegations:

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The complaint continues for an additional 12 pages. Below we provide pages 9-12, “Defendant Prause Defamed Dr. Hilton“:

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This section contains screenshots of new documents from Don Hilton’s amended complaint: 7/24/19 (document #3)

Below are screenshots of “1 – Motion for leave to file amended complaint”

 

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Screenshots of 3 – Don Hilton’s new amended complaint, that differ substantially from Hilton’s initial complaint:

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Screenshot of “5 – Exhibit – Notice of malicious Texas Medical Board complaint by Nicole Prause“

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Screenshot of “6 – Exhibit – Email from PNAS to Hilton (Prause falsely claiming Hilton faked credentials on a journal article)”

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Screenshots of “7 – Exhibit – University of Texas confirming that Dr. Hilton is a faculty member”

 

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Screenshots of “10 – Old exhibit – Prause tweets confirming she attended AVN”

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The 9 affidavits are located in subsequent sections.

July, 2019: John Adler, MD affidavit: Donald Hilton defamation lawsuit against Nicole R Prause

PDF of John Adler’s 61-page affidavit: John Adler, MD, founder & senior editor of Cureus (affidavit #1)

We provide screenshots of only the narrative portion of the affidavit (omitting the exhibit portion which are in the full PDF).

For the rest of the affidavit see – John Adler, MD, founder & senior editor of Cureus (affidavit #1). Sections of the Prause pages related to John Adler:

July, 2019: Gary Wilson affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC

PDF of Gary Wilson’s 47-page affidavit (it could have been a 470-page affidavit): Gary Wilson of YBOP (affidavit #2)

We provide screenshots of only the narrative portion of the affidavit (omitting the exhibit portions which are in the full PDF).

You can see the rest of the affidavit here – Gary Wilson of YBOP (affidavit #2). These pagans contain hundreds more of documented incidents involving Prause harassing, defaming or cyberstalking Wilson:

July, 2019: Alexander Rhodes affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.

PDF of Alexander Rhodes’s 67-page affidavit: Alexander Rhodes of NoFap (affidavit #3).

We provide screenshots of only the narrative portion of the Rhodes affidavit (omitting the exhibit portions which are in the full PDF).

You can see the rest of the affidavit here: Alexander Rhodes of NoFap (affidavit #3)

Sections related to Prause’s long history of harrasing, defaming and cyberstalking Alexander Rhodes of NoFap:

Update (October, 2019): On October 23, 2019 Alexander Rhodes (founder of reddit/nofap and NoFap.com) filed a defamation lawsuit against Nicole R Prause and Liberos LLC. See the court docket here. See this page for three primary court documents filed by Rhodes: NoFap founder Alexander Rhodes defamation lawsuit against Nicole Prause / Liberos (see fund-raising page).

July, 2019: Staci Sprout, LICSW affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.

PDF of Staci Sprout’s 21-page affidavit: Staci Sprout, LICSW, CSAT (affidavit #4).

We provide screenshots of only the narrative portion of the affidavit (omitting the exhibit portions which are in the full PDF).

For more see the 21-page affidavit: Staci Sprout, LICSW, CSAT (affidavit #4).

Sections related to the Staci Sprout affidavit:

July, 2019: Linda Hatch, PhD affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.

PDF of Linda Hatch’s 3-page affidavit: Linda Hatch, PhD (affidavit #5)

Prause also sent Linda Hatch a malicious cease & desist letter. Documented here: Ongoing – Prause silencing people with fake “no contact” demands and spurious cease & desist letters

July, 2019: Bradley Green, PhD affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.

PDF of Bradley Green PhD 39-page affidavit: Bradley Green, PhD (affidavit #6)

We provide screenshots of only the narrative portion of the affidavit (omitting the exhibit portions which are in the full PDF).

For more see the 39-page affidavit: Bradley Green, PhD (affidavit #6)

July, 2019: Stefanie Carnes, PhD affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.

PDF of Stefanie Carnes 12-page affidavit: Stephanie Carnes, PhD (affidavit #7)

We provide screenshots of only the narrative portion of the affidavit (omitting the exhibit portions which are in the full PDF).

For more see the 12-page affidavit: Stephanie Carnes, PhD (affidavit #7)

Sections related to the Stefanie Carnes affidavit:

July, 2019: Geoff Goodman, PhD affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.

PDF of Geoff Goodman, PhD 3-page affidavit: Geoff Goodman, PhD (affidavit #8)

PDF of Geoff Goodman’s 3-page affidavit: Geoff Goodman, PhD (affidavit #8)

In addition to trying to destroy Goodman’s career, Prause attacked Goodman in the comments section under her and David Ley’s disgusting Psychology Today blog post:

As usual, Prause is lying: Geoff Goodman is still on the AASECT listserve, posting whenever he pleases. His university ultimately dismissed Prause’s malicious attempt to punish Goodman for challenging one of Prause’s minions.

July, 2019: Laila Haddad affidavit: Donald Hilton defamation lawsuit against Nicole R Prause & Liberos LLC.

PDF of Laila’s 6-page affidavit: Laila Haddad of Exodus Cry (affidavit #9)

We provide screenshots of only the narrative portion of the affidavit (omitting the exhibit portions which are in the full PDF).

For the remainder of the 6-page affidavit, see: Laila Haddad of Exodus Cry (affidavit #9)

Section related to this affidavit: February, 2019: Prause falsely accuses Exodus Cry of fraud. Asks twitter followers to report the non-profit to the Missouri attorney general (for spurious reasons), Appears to have edited the CEO’s Wikipedia page.

Prause and presumed aliases (@BrainOnPorn, etc.) target Hilton even AFTER his defamation suit is filed

This section documents the attacks of Prause and her presumed aliases (@BrainOnPorn, Truth ShallSetYouFree) on Hilton after his defamation lawsuit was filed. Attorneys of individuals embroiled in defamation lawsuits usually instruct their clients to avoid discussing the case. It goes without saying that a person being sued for defamation would be wise to refrain from further defamation and targeted harassment. Nicole Prause is no ordinary defendant…or harasser. More than reckless, the following items demonstrate Prause’s malice toward Hilton.

June 3, 2019: David Ley and Prause alias (RealYBOP) team up to disparage Hilton with Rory Reid’s unpersuasive commentary:

June 22, 2019: Prause’s closest ally, David Ley tweets about Hilton. Note: (1) David Ley filed a lie-filled affidavit on the behalf of Prause in this case, and (2) PornHub was the first to retweet Ley’s tweet:

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July 5, 2019: David Ley’s tweet borders on defamation itself.

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July 15, 2019: While she doesn’t mention Hilton by name, Prause has tweeted much the same about Hilton in the past:

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August 13, 2019: Prause/RealYBOP ally disparages Hilton with untrue statements:

RealYBOP likes the tweet:

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September 20, 2019: On the day of a very important hearing in her case, Prause tweets about a major issue in the suit: Kinsey collaborating with pedophiles, as is clear from Table 34 in his famous treatise Sexual Behavior in the Human Male (1948). This was a major point of discussion in the only conversation between Prause and Hilton. Prause later mischaracterizes the discussion as Hilton calling her a child molester (he never did).

While not overt, it’s still targeting Hilton.

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November 14, 2019: three tweets directly referring to Hilton and the lawsuit (tweet 1, tweet 2, tweet 3), and containing false or defamatory statements:

November 14, 2019: On the same day, Prause alias @BrainOnPorn tweets about Hilton’s appearance on a CBS show about pornography:

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November 19, 2019: RealYBOP disparages Don Hilton, MD. (He was the so-called “religious physician” in the CBS segment about porn, but he sticks to the science and never makes religiosity part of his public talks. Only his critics do.)

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November 22, 2019: UCLA law tweets about the Diana Davison article discussing Hilton and Rhodes lawsuits. Specifically mentions Volokh’s July article about Hilton v. Prause. Prause immediately threatens UCLA law!

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November 24, 2019: In response to Diana Davison exposing Prause as lying about attending porn awards, Prause tweets a Chad Sokol email mentioning Don Hilton:

The email:

Chad Sokol & my email: This brings us to reporter Chad Sokol and his biased article about a February 23, 2019 conference on the risks of porn use held at Gonzaga University. In interviewing some of the presenters (such as Don Hilton) it became apparent that Sokol had already spoken with David Ley and Nicole Prause (and Prause co-author Cameron Staley). Sokol was clearly biased, having been prepared with Prause-generated materials and talking points.

In conversations with Hilton, Sokol parroted Prause, suggesting that Hilton’s religious faith skewed his views, making him biased. If bias (not the research) was Sokol’s primary concern, Hilton wondered if Sokol might be willing to examine evidence of Prause’s and Ley’s biases.

When Chad Sokol said “these kinds of attacks,” he is referring to my email to Don Hilton, which was forwarded to Chad Sokol, who forwarded it to Prause. Everything in my email is true and accurate and proves that Prause attended porn industry awards shows.

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December 16, 2019: Prause tweeted links to PDFs of defamatory documents she filed in her unsuccessful September, 2019 Motion to Dismiss in the Hilton defamation suit. She had them re-published on www.reason.com, an online magazine. At the time of her tweets, her Motion to Dismiss had already been denied, which she failed to mention. In a desperate attempt to veil her defeat, she made it her pinned tweet, and appeared to pay for fake Twitter accounts to retweet and like her tweet(!).

Prause’s tweet was once up past 100 retweets (it’s now down to 70). Almost all were fake accounts. A few screenshots supporting this assertion:

Her Motion to Dismiss was, in large part, an extensive rant defaming me, Alex Rhodes, Don Hilton, Stefanie Carnes and others. She perjured herself throughout. More importantly, her decision to publicize her court documents brings with it numerous legal implications, supplying further evidence of defaming her targets anew, including both Hilton and Alex Rhodes, and the possibility of additional lawsuits by others defamed in her now publicized/published documents.

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December 21, 2019: Prause once again tweets her defamatory, already denied, Motion to Dismiss court documents:

The above was in Pascal Gobry’s thread where he tweeted his extensive article: A Science-Based Case for Ending the Porn Epidemic. RealYBOP and Nicole Prause responded with 90 rambling tweets in Gobry’s thread, consisting of personal attacks, ad hominem, and false accusations (but never addressing the substance of his article).

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December 19, 2019: In an utterly shocking turn of events Prause creates and posts a YouTube video attacking Don Hilton, titles “Donald Hilton Bigotry.” It’s 5 minutes of spliced together out-of-context snippets. A good portion of the video is Hilton reading an article by someone else. Prause is attempting to make the viewers believe they are Hilton’s words, when it clearly they were not.

It was posted on the newly created YouTube channel “Truth ShallSetYouFree.” We know this is Prause’s YouTube channel because (1) it was named “RealYourBrainOnPorn” in the first few days of its existence, (2) it commented under the Rebecca Watson video outing Prause as a defamer and harasser, (3) the comment is Prause talking in the first person about the California Psychology Board complaints and the WIPO complaint (involving her). Again, she publicized her defamatory documents related to her failed Motion to Dismiss.

A screenshot of the above comment when it was named “Real YourBrainOnPorn” (before Prause changed the name of the YouTube channel to “Truth ShallSetYouFree”):

Others recognize “Truth ShallSetYouFree” as a Prause alias:

That’s not all. It appears that Prause, or her agent, hired internet marketing service Bosmol to tweet and spread the misleading Hilton video. A tweet from December 19, 2019:

Bosmol tagged The University of Texas (where Hilton teaches), the UT Dean, the Texas Civil Rights Project, and The Daily Texan. Is this Prause once again trying to get Hilton fired from his teaching position at University of Texas? Can anyone say “undeniable malice?”

I discovered the Bosmol tweet because it was retweeted by two RealYourBrainOnPorn “experts” and close Prause allies, David Ley and Victoria Hartmann:

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The Bosmol tweet was also “liked” by Prause’s apparent Twitter alias @BrainOnPorn:

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December 31, 2019: Out of nowhere, RealYBOP misrepresents a 10-year old commentary by Don Hilton. Hilton & Watts commentary: Pornography addiction: A neuroscience perspective

December 31, 2019: Cyberstalking Gabe Deem (who has blocked RealYBOP) on New Years Eve, RealYBOP tweets defamation and PDFs of her defamatory Motion to Dismiss documents:

December 31, 2019: RealYBOP trolls under Gary Wilson (even though I blocked her and she blocked me), tweeting about Hilton & Watts, 2011 – again, and completely out of context:

December 31, 2019: In a truly bizarre event, @BrainOnPorn Twitter (apparently managed Prause) changed its home page to superimpose Rory Reid’s unpersuasive commentary on Hilton & Watts, 2011:

Huh?

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February, 29, 2020: Prause & Luke Adams team up to disparage so-called frivolous lawsuits:

Prause is the ruling monarch of frivolous legal actions and bogus C&D letters.

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March 4, 2020: Ley tweets screenshots likely supplied by Prause (Ley doesn’t capture and store these type of screenshots). I do hope that Hilton’s lawyers request discovery on Ley and Prause emails, as I suspect Prause supplied the screenshots and suggested the tweet’s content.

Prause alias account RealYBOP liked Ley’s tweet:

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March 5, 2020: Implying the 2 defamation lawsuits against her are moving in a favorable direction:

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March 7, 2020: She threatens yet another person with a defamation suit, then falsely implies that she has “won” all sorts of lawsuits. In reality, the 2 defamation suits against her are the only actual lawsuits on record – and both are moving towards trial.

Extensive page exposing Prause’s lies and fabrications: Nicole Prause & David Ley commit perjury in defamation lawsuit (September, 2019).

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