I was sued by a supposed new age healer and his mistress and this was my Answer to their lawsuit.

I have created a new blogspot to commemorate this information to make sure it is available to the public. It can be found at massajadylawsuit.blogspot.com

 

Autumn of 2017, I was served with a lawsuit accusing me of defamation by a supposed new age healer named Mas Sajady and his mistress Fei Xuan ZhouMany former clients have complained about their deceptive business practices. My story in a nutshell can be found here.


We have wondered why the authorities do not care to intervene to protect the public from their targeting of the vulnerable. This curiosity has led me to show that a lot of crime is allowed to flourish under the present rulership. I SHOW the disrespect with which the Law is regarded here on this site, every single day.


Here I also show the real story of Napoleon. Please join us for our Napoleon Memoir Series. I am wondering if Napoleon was the last hero who really had the courage to stand up to the above-the-law oligarchs.


Since I was legally forced to formulate an answer to the Mas Sajady and Fei Xuan Zhou lawsuit, I thought it might benefit our human community to make my legal Answer a matter of public record.


Nothing was heard further from Sajady or Zhou through their lawyer after this answer was sent. I wonder what happened to their lawsuit?


Even though Sajady and Zhou have been throughly exposed and almost all well meaning Truthseekers have fled their midst, Sajady and Zhou still travel the world's most expensive locales completely unabated with his children in tow.

 

Without any discernible source of income, the social media selfies and jetsetting never seem to slow down. Peru, the world's top cocaine exporter, is a favorite destination for this group. I wonder what they're doing that is so magnificently lucrative?


The TRUTH will set you free.

 

I now present my Answer: 


SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF SUFFOLK

---------------------------------------X
MASOOD SAJADY and FEI XUAN ZHOU Index No. 619617/2017

                          Plaintiffs 
                                                                                  VERIFIED ANSWER 
            -against- 

TANA LEE ALVES

                                  Defendant
---------------------------------------X 

Defendant, Tana Lee Alves, as and for her answer to the complaint herein, alleges:


  1. As to Plaintiffs’ Verified Complaint, paragraphs 1 through 8, Ms. Alves acknowledges that Plaintiff Masood Sajady (Sajady) currently identifies himself as a teacher, facilitator and speaker. Sajady has also identified himself under other titles as well, however. Sajady testified that he is a minister of a not-for-profit church incorporated in California, Mas Sajady, Inc.  He has also stated that he is a “quantum healer” and a “medical intuitive” who has the “highest frequencies.”  Sajady’s websites have stated that he has been compared to the greatest healers of all times and also the greatest oracles of all time. Sajady has claimed on multiple occasions that following his second near death experience he entered into a “blood contract” with Jesus Christ.


  1. Additionally, Sajady has stated on multiple occasions that he is a student of Adolf Hitler. He has said that he admires things about Hitler. Sajady has also said that he works with “aliens” and that an “alien” is his guide. Sajady claims that he has powerful remote abilities that can make it seem that he is right there in the room with his listeners. He says that his remote abilities are just as potent as his in-person powers.


  1. Sajady has also claimed to have “access to all knowledge” through his ability to tap into “exponential intelligence.” He has said that he creates “spiritual duplicates” of himself, that he can “project” himself and that he can perform “astral traveling.” He claims that he can “edit time” and “shapeshift” himself. Sajady has also said that he can “edit” the past and the future. He claims he can remove memories from a person’s mind, that he can make dead people ascend to a higher level and medically diagnosis anyone, anywhere even if he is not present with them. He has told some of his customers that they have “alien frequencies” and that they are “aliens.”


  1. Sajady has stated that he puts people into deep, meditative states where he can easily work on their “blueprints” and “edit the files” in their minds. He has described his ability as “level three” while hypnotism and neural linguistic programing are merely “level one.”


  1. Sajady has said on multiple occasions that he also has the power to “read” people and “tap into” people. He claims there is nothing he cannot know about a person. He can look into that person and have all knowledge about him or her. He claimed in a podcast in the Fall of 2016 to have “tapped into” Angelina Jolie. He claimed to have seen that she had been abused and then stated that he could help her with that.


  1. Sajady also claims that he has performed numerous exorcisms. He has said that he can break contracts with demons easily and that demons are “not that bad.” Sajady has said that he works with “dark sources” and that he is protected by “dark sources.” He has claimed that he infuses his listeners with “dark energy.”


  1. Sajady has also said that he communicates with dead people. After the death of pop musician Prince in 2016, Sajady posted a podcast claiming that Prince had made a contract with dark sources for fame and success. Sajady further claimed that he helped free Prince from this contract and ascend to a higher plane. This podcast was reported on in the City Pages periodical in Minneapolis. That article is currently available on the website citypages.com.


  1. On his web site, Sajady sells various products. These include podcasts and tickets to see him speak publically and privately. Sajady also charges money for individuals to be touched by him. Additionally, he sells items and tchotchkes infused with spiritual power. He also sells podcasts that can “recharge” items that have been bought from him. His podcasts include “21 Day Medihealing,” “50 Shades of Great Sex,” “Global Healing,” “Opening to Romance,” “Love, Sex, Twin Flames and Soul Mates,” and “Getting High With Mas.” Sajady also sells “Frequency Clinics” that address specific medical diagnoses. Recurring topics of his podcasts include “twin flames,” healing and obtaining “higher frequencies” associated with “pure source.”


  1. His program claims to offer “360 degrees of rapid abundance” in all areas of a person’s life including relationships, work, money, family and sex. He says following his program of “rapid transformation” can lead to youth, beauty and wealth. One of his slogans is “See what I can do in 5 minutes.”


  1. Sajady testified in a court of law on May 23, 2017 in Carver County, Minnesota that he has the number one podcast or fastest growing podcast on iTunes. He also testified that he gets 100,000 new followers a week. He said he gets up to 20 new testimonials a day. He testified that all of his growth is “organic.” As of this writing, he has over 1.4 million followers on his Facebook page. As of October, 2016, he had only about 8,000 followers on Facebook. He said recently on a podcast that he has received messages from thousands of people claiming to be “twin flames” with him.


  1. On Sajady’s home page, Mas-Sajady.com, a testimonial page is provided to the public. The fourth testimonial is by Mat Shaffer who states that Sajady changed his life with a single touch. Mat Shaffer is a paid employee of Sajady however his testimonial does not identify himself as such.


  1. In the Plaintiffs’ Verified Complaint, Fei Zhou is identified as the person who manages Sajady’s business and that she is his “Chief Financial Officer.” He has also called her his executive director, business manager, business partner and director of operations. He testified in a court proceeding that Zhou runs his business. On various company documents, her first name has been spelled Fay, Fei and Feix. Her Facebook page is under the name Fay MIA.


  1. The defendant, Ms. Alves, has suffered from certain medical conditions for decades. These conditions have resulted in various surgeries without any long term success. Consequently she has tried alternate medicines to resolve her issues, including acupuncture and yoga, also without success. Ms. Alves was an abused child which left her with Complex Post Traumatic Stress Disorder.


  1. Around November, 2015, Ms. Alves viewed a video of Sajady on YouTube. In his video interview with Shefali Burns, Sajady claimed that someone could be healed just by listening to his YouTube broadcasts because of his “high frequencies.” Hopeful, Ms. Alves then went to see him on December 13, 2015 at a live event in Weston, Connecticut. There, Sajady told her that she had been an abuse victim. Sajady then touched Ms. Alves on her very lower back. He rubbed her there for several minutes and then whispered to her “I can help you.”


  1. On January 2, 2016, Sajady sent a public comment to Ms. Alves via the social app Twitter, “We can change the world together.”


  1. In March 2016 at another personal appearance, Sajady, while rubbing Ms. Alves’  lower belly, said, “Very nice.” 


  1. During 2016, Ms. Alves followed Sajady’s program. Her purchases of his various products totaled around $4,000. Some of her payments for Sajady products were made to a California company called “XPDreamTeam.” At the time, the California Secretary of State listed this corporation as “inactive.” A judicial subpeona will determine the relationship between Mas Sajady, Inc. and XPDreamTeam, Inc.. 


  1. Ms. Alves was a content creator on social media during this period. Prior to following Sajady, Ms. Alves used her social media to promote a year long charity art project she ran in conjunction with the Coalition for Women’s Cancers of Southampton Hospital. Once she began following Sajady, most of her posts concerned his program. Sajady often criticized cancer charities. Sajady frequently told his customers to listen to his broadcasts “on a loop” 24 hours a day “if they really wanted to heal.”


  1. During the course of her posting about Sajady and his program, including her reporting her belief that she was having telepathic communications with Sajady and that she was “twin flames” with Sajady, Ms. Alves would receive regular feedback from “Mas Sajady.” Her posts on various social media, including those about being “twin flames,” would be liked by “Mas Sajady,” commented on by “Mas Sajady” or shared on “Mas Sajady’s” various social media accounts. In September, 2016, on both the Sajady public figure Facebook page and in his newsletter, Ms. Alves was listed as the “Featured Testimonial.” Her picture was included with the Mas Sajady insignia added next to her face. Sajady also used a painting by Ms. Alves as the avatar on his Instagram account regularly for several months around that time. 


  1. A few weeks after Ms. Alves was Sajady’s featured testimonial, she was sent a direct message from Sajady’s “Exponential Intelligence” Facebook account consisting of nothing but a red heart emoji. Once again, Ms. Alves’ painting was the avatar on that message.


  1. In October, 2016, Ms. Alves went on the “Cruise Into Spirit” seven day cruise with Sajady and Zhou. While on the cruise, Ms. Alves observed Zhou crouch on a chair and dance seductively in front of Sajady. Ms. Alves also witnessed Sajady and Zhou having frequent intimate contacts. Ms. Alves was shocked by their behavior as on his social media, Sajady identifies himself as “a loving husband” and “the ultimate father” who was an “expert on spiritual relationships.” During the course of the cruise, Ms. Alves was alarmed that Sajady kept returning to the topic of “human sacrifice” rituals which were the killing of humans to satisfy demonic spirits. Ms. Alves also witnessed Sajady tell one woman, in front of an entire crowd, while he was touching her that in a past life she had been an “illuminati orgy sex slave.” When the woman appeared to be shocked and humiliated by this, Sajady told her that she was “dark” and he asked the audience to agree with this.  


  1. In November, 2016, Sajady sent Ms. Alves an email. Sajady stated that she was “delusional” and that her posts were not of “pure source.” He said that she was living in a “fantasy world” and that she was “distorted.” 


  1. Then, in January 2017, Zhou sent Ms. Alves several e-mails stating that it was not, in fact, Mas Sajady who was liking, commenting and sharing her posts on his social media. Zhou claimed that the name “Mas Sajady” was used by their staff and that it was company policy to like everything their customers said on social media. She also claimed that Sajady did not know who she was. 


  1. Another employee of Sajady’s, Kaille Padgett, sent an email that called Ms. Alves a “slave bitch.” Padgett said that she wanted to “annihilate” her and others who were complaining about their experiences with Sajady. Padgett also stated that she wanted to come after them “like a goddess.”


  1. Ms. Alves came to Sajady for physical healing and spiritual growth. She feels that the regular likes, comments and shares of her posts by “Mas Sajady” about Sajady and the psychic connection they were having were intentionally deceptive. According to Zhou, it was the regular business practice of Mas Sajady, Inc. to support posts about Sajady regardless of content. By “Mas Sajady” liking, making positive comments and resharing on their own social media Ms. Alves’s posts, the business encouraged and supported her content. When Sajady then claimed after a year of this behavior that Ms. Alves was “delusional” and “distorted,” she was understandably devastated. Following this cruel rejection after so much apparent affirmation, Ms. Alves experienced suicidal ideation. As a result, she spent thirteen months in psychotherapy with a licensed treatment provider in Southampton, NY.


  1. Though Ms. Alves has made public posts about her experiences with Sajady and Zhou and concerns she has about some of things he has said, she has never knowingly made a false statement about him. Ms. Alves maintains her social media both to tell her story and to provide information to people about certain things Sajady has said so that they can make an informed decision as to whether to become a customer of his. None of Ms. Alves’ posts or communications are done maliciously. Her only purpose is to provide information to the public.


  1. As to Plaintiff’s Complaint paragraph 9, Ms, Alves denies posting on social media or transmitting email under the alias “James Bernet.”


  1. As to Plaintiff’s Complaint paragraphs 13 through 43, Ms. Alves denies the allegations that her posts were knowingly false. As stated in Plaintiff’s Complaint paragraph 28, she made it clear to everyone that these were not face to face, real world communications she was having Sajady. She believed that these telepathic communications were really happening and related them as such without any misrepresentation. Whether these telepathic communications actually occurred are not facts that can be proven or disproven and are therefore merely opinions and not defamatory.


  1. As to Plaintiff’s Complaint paragraph 44, Ms. Alves acknowledges that after months of “Mas Sajady” liking, commenting and sharing on his media her public posts which included statements of her belief that she was “twin flames” with Sajady and that she was having telepathic communications with him, he coldly told her in an email that she was “ignorant,” “petty,” “delusional” and “distorted.” Additionally, in an article in the City Pages article published in March of 2017 in Minneapolis, Minnesota, Sajady stated that Ms. Alves “fell in love with him and got jealous when he refused to be seduced.” This article is still available on the citypages.com website. Ms. Alves was devastated by this total fabrication. She never attempted to “seduce” Sajady and she was deeply offended to see in the print media that she would attempt to seduce a married man. This is an outrageous and false accusation. Ms. Alves was never alone with Sajady and never had any private contact with him.


  1. As to Plaintiff’s Complaint paragraph 45, Ms. Alves denies offering herself romantically to Sajady. However, after being informed that she had been deceived for a year by “Mas Sajady,” she did feel it incumbent on herself to correct all the positive and supportive posts she had made about Sajady’s programs. Her purpose was not to malign or disparage but rather to inform.


  1. As to Plaintiff’s Complaint paragraph 46 and 47, Ms. Alves denies making any false statements to Liphe Balance Center. 


  1. As to Plaintiff’s Complaint paragraph 48, upon information and belief the event at Liphe Balance Center was not cancelled and did, in fact, occur. Whether the host of the event declined to book any further appearances with Sajady is the host’s own decision.


  1. As to Plaintiff’s Complaint paragraph 49, Ms. Alves never posted any knowingly false statements about the plaintiffs. It is her belief for the reasons stated above that the plaintiffs knowingly and intentionally perpetrated a fraud against her with their deceptive business practices. She also believes that when Sajady states that he works with “dark sources” and is protected by them, he means demons. She never stated that Sajady is, in fact, a prostitute or that he has sex in exchange for money. As a result of learning of the fraud perpetrated against her, Ms. Alves experienced suicidal ideation. At least one other customer of Sajady’s that she is aware of committed suicide after following his program.


  1. As to Plaintiff’s Complaint paragraphs 50 through 61, Ms. Alves acknowledges reposting photographs uploaded to the internet by Zhou depicting a party that Ms. Alves characterized as an orgy. The Merriam-Webster dictionary defines, in part, an orgy as “drunken revelry.” The 50 or so pictures posted by Zhou under the name “Mistress Fei - Public” depict a wild party with copious amounts of alcohol and several scantily clad young women interacting provocatively with the male guests. These women are often in their underwear. There are pictures of women laying in bed cuddling with each other. One women in a red bustier, red garters and red stockings is dancing for a crowd. She then crawls towards a man and is seen kneeling between his legs. Other photographs depict several young women in wet t-shirts with the words “Pierre’s Bitches” written on them. Their nipples are visible. They are surrounding Pierre Huguet and his face is covered with lipstick. Whether these pictures fairly depict “drunken revelry” will be for a jury to decide.


  1. As to Plaintiff’s Complaint paragraphs 62, 63 and 64, Ms. Alves denies that her statement is defamatory. In the quoted post, she specifically states “I believe” meaning that she is expressing her opinion, as is her right under the First Amendment of the US Constitution. 


  1. As to Plaintiff’s Complaint paragraphs 65 and 66, Ms. Alves denies ever stating that Sajady or Zhou use cocaine or are involved in cocaine distribution. Sajady did post periodically about his trips to Peru. The plaintiffs’ claim that Ms. Alves’ questions as to why Sajady made these frequent trips is defamatory is disingenuous on their part. Paragraph 65 quotes her post. Nowhere in the post is Ms. Alves making any statements of facts. She is merely asking questions of a public figure. That is not defamatory.


  1. As to Plaintiff’s Complaint paragraphs 67, 68 and 69, plaintiff’s claims that Ms. Alves’ post are defamatory are likewise disingenuous. The post quoted in paragraph 67 specifically says “It is my contention” and “it is my belief.” Ms. Alves is expressly stating her opinion as to aspects of Sajady’s business. Everyone is entitled to their own opinion. Only the relating of intentionally false facts can be defamatory. This action cannot be sustained merely because Ms. Alves expressed her opinion.


  1. As to Plaintiff’s Complaint paragraphs 70, 71 and 72, Ms. Alves restates her position in Verified Answer paragraph 31.


  1. As to Plaintiff’s Complaint paragraphs 73, 74 and 75, Ms. Alves denies making these statements.


  1. As to Plaintiff’s Complaint paragraphs 76 and 77, Ms. Alves denies making a defamatory statement. During a published interview with Jane Sibbett, Sajady claimed that as a person achieves higher frequencies, the rules of society no longer apply. He said that these people can then partake in activities like group sex without judgment or becoming spiritually compromised. Ms. Alves had never stated Sajady frequents prostitutes. Likewise, she never said that Sajady has sexually abused children. Sajady did post a picture on his social media of his five year daughter’s face pressed against his crotch. Sajady has also posted other, similar pictures. Ms. Alves has expressed concern these might be examples of “grooming behavior.” Sajady has also broadcast media of himself touching children during his live appearance programs. 


  1. What is more, during his sworn testimony on May 23, 2017, Sajady stated that he was distressed children from his area were not coming by his house anymore. He said that he would work on his children’s friends’ suicidal ideation. This is despite the fact that Sajady has no training or education in working with suicidal people and no permission from the children’s parents to treat them. Sajady testified that the children might kill themselves because he was not working on them.


  1. As to Plaintiff’s Complaint paragraphs 78 and 79, Ms. Alves denies making any false statements. In Sajady’s podcast #14, available on iTunes, he states that a person died in front of him. Sajady said, “It was one of the most beautiful things I’ve ever seen.” Sajady also said this year in an interview with Jill Dahne that abusive, rough sex is healthy. In her posts, Ms. Alves merely repeats and comments on statements that Sajady has made or pictures that he has posted online.


  1. As to Plaintiff’s Complaint paragraphs 80 through 97, Ms. Alves denies ever making any posts or communications under the alias “James Bernet.”


  1. As to Plaintiff’s Complaint paragraphs 85 and 86, though Ms. Alves did not make any communications under the alias “James Bernet,” she does refute Sajady’s claim that he is not under investigation of any governmental body. Over this past year multiple investigations have been initiated against Sajady and his business by the California, Minnesota and Federal governments. These investigations were originated by complaints from multiple parties. Documentary evidence from various agencies proves this. An article published in the Star Tribune in Minnesota in March of 2017 also states that Sajady was being investigated by a Minnesota government agency. Additionally, upon information and belief, as of this writing, Sajady is currently being investigated by the Minnesota Medical Board for his role in the recent suicide of one of his followers, Matthew Kurtz. This investigation was purportedly initiated by a complaint by the Kurtz family.


  1. As to Plaintiff’s Complaint paragraphs 98 through 102, though it is irrelevant to this action, Ms. Alves denies making any posts or communications on behalf of Theresa Nygard.


  1. As to Plaintiff’s Complaint paragraphs 103 to 110, Ms. Alves denies making any knowingly false or malicious statements regarding Sajady or Zhou. As such, she has not defamed either plaintiff. As to the plaintiff’s claim that his business has been damaged, this is also apparently false based on the plaintiffs’ own media postings. The number of followers on Mas Sajady’s public figure Facebook page has risen from around 8,000 in October of 2016 to over 1.4 million as of this writing. Additionally, pictures have regularly been posted on Sajady’s social media showing large crowds listening attentively to his words at various events throughout the year 2017. During his testimony in the trial Sajady initiated against Theresa Nygard referenced in Plaintiff’s Complaint paragraph 100, Sajady swore that all his customer growth was “organic.” He has gained almost one and half million followers over the past year while Ms. Alves related her experiences and concerns on her social media. Based on Sajady’s own, sworn testimony, Ms. Alves has not had much impact on his business. Indeed, no justification for the outlandish amount of damages sought has been provided. That would suggest the true purpose of this lawsuit is not to seek compensatory damages, but rather to intimidate Ms. Alves into not using her First Amendment rights to freedom of speech, freedom of press and freedom of religion. 


  1. As to Plaintiff’s Complaint paragraphs 111 to 120, Ms. Alves likewise asserts that she never knowingly made any false statements about Sajady or Zhou. Likewise her motivations were never malicious. Her primary concern is that Sajady does not readily disclose to potential customers statements that he has made regarding his admiration for Adolf Hitler, his use of “dark energy,” the fact that he says he works with and is protected by “dark sources,” and the myriad statements he had made that contradict the teachings of Jesus Christ with whom Sajady claims to have a “blood contract.”


  1. As to Plaintiff’s Complaint paragraph 114, Ms. Alves denies making the statements alleged. 


  1. As to Plaintiff’s Complaint paragraph 116 wherein the plaintiffs allege Ms. Alves claimed that Sajady uses “mind control,” Sajady himself has repeatedly stated that he puts people into “deep meditative states” where he can alter their “blueprints” and “erase” their unwanted memories. He said he “breaks people down like the Navy Seals.” Sajady claims that there is no way for people to resist his “programming” of them, with or without their consent. Is there a difference between this and hypnosis or mind control? A jury can decide that.


  1. As to Plaintiff’s Complaint paragraphs 122, plaintiff’s claims that Ms. Alves has interfered with their business relationship with the Lake Harriet Spiritual Center is disingenuous. Based on the event calendar currently on their business website, Sajady has an upcoming appearance at Lake Harriet. Ms. Alves denies making any false statements to the Temple of Light. Ms. Alves also denies making any false statements to the Liphe Balance Center. Whether any vendor has chosen to discontinue their association with the plaintiffs is not due to any defamatory statements made by Ms. Alves.


  1. As to Plaintiff’s Complaint paragraphs 123, 124 and 125, Ms. Alves categorically denies making any knowingly false or malicious statements about the plaintiffs to any party. As such, she refutes their claim for damages.


  1. As to Plaintiff’s Complaint paragraphs 126 through 129, Ms. Alves denies making any false statements about the plaintiffs, she denies any malice towards them and she denies employing any unfair methods. She strongly opposes any injunctive relief, either permanent or temporary. Ms. Alves is empowered by the Constitution of the United States of America to speak freely as to her experiences with the plaintiffs and her concerns about their business practices. She is entitled to post her opinions on social media and to contact any individuals or businesses to express her concern. It is her opinion that the plaintiffs are employing deceptive business practices and that they are endangering lives. Additionally, the contents of her social media are at issue in this case. Deleting those social media pages would destroy the evidence needed to resolve this action. Ms. Alves therefore also strenuously objects to any injunction requiring the removal of her social media postings.


  1. In Plaintiff’s Complaint paragraph 12 the plaintiffs acknowledge that some of Sajady’s followers believe telepathy is real. Sajady has also claimed on multiple occasions that he has vast “remote” communication powers. Sajady also speaks regularly about “twin flames.” Ms. Alves learned of the “twin flame” concept from him. Ms. Alves accepted what Sajady was teaching as true and now he is calling her “delusional” for it. 


  1. This is the second lawsuit initiated by Sajady in an attempt to silence the free speech rights of a former customer who has voiced her complaints about her experiences with the plaintiffs. Sajady lost that court action.


  1. Sajady claims in Plaintiff’s Complaint paragraph 1 that he is a teacher. He has no education, training or license to teach. Likewise his entire program is based around the promise of healing and abundance. He sells a wide variety of podcasts regarding specific medical issues. Sajady has no education, training or license to give medical advice. He also charges people to be touched by him and he puts his hands on children. If Ms. Alves believes that the claims Sajady has made about his various powers are fraudulent, then she has the right to say that.


  1. Ms. Alves denies each and every allegation not previously or specifically admitted or denied.


FIRST DEFENSE

  1. Plaintiffs have failed to state a sustainable cause of action against Ms. Alves.


SECOND DEFENSE

  1. Any statements made by Ms. Alves regarding the plaintiffs in any form are expressions of her opinions or her direct experiences with the plaintiffs. As such none of her statements are defamatory or defamatory per se.


THIRD DEFENSE

  1. Any statement that cannot be proven true or false is an opinion. Statements made regarding paranormal experiences with Sajady or her description of aspects of his program as being “demonic” are not statements that can be proven true or false and therefore are opinions. As such, these allegations should be dismissed.


FOURTH DEFENSE

  1. None of Ms. Alves’ statements regarding the plaintiffs contain knowingly false information. As such, none of her statements are defamatory or defamatory per se.


FIFTH DEFENSE

  1. The damages claimed by the plaintiffs cannot be verified or attributed to Ms. Alves. As such, the plaintiffs cannot maintain this cause of action.


SIXTH DEEFENSE

  1. The Plaintiff’s Complaint contains knowingly false information and as such should be dismissed.


SEVENTH DEFENSE

  1. Multiple former customers are complaining on social media about the plaintiffs’ business. As such, any alleged damages sustained by the plaintiffs cannot be attributed to Ms. Alves and this complaint should be dismissed. 

 

EIGHTH DEFENSE

  1. Any communications Ms. Alves may have had with third parties or vendors were for the purpose of making them aware of various aspects of Sajady’s program so that they could make an informed decision about whether to host him. As such, her actions cannot constitute tortious interference with a trade or business and this cause of action should be dismissed.


NINTH DEFENSE

  1. The plaintiffs employed intentionally deceptive business practices in their dealings with Ms. Alves. This will serve as the base for the counterclaim of fraud that Ms. Alves intends to file.


TENTH DEFENSE

  1. The plaintiffs deceptive and misleading business practices and their communications with Ms. Alves constitute the intentional infliction of emotional distress which will also be a cause of action in Ms. Alves’ counterclaim.


ELEVENTH DEFENSE

  1. Sajady’s false statements about Ms. Alves published in the City Pages periodical claiming that Ms. Alves attempted to “seduce” him, a married man, constitute defamation per se. This cause of action will also be included in Ms. Alves’ counterclaim.


TWELFTH DEFENSE

  1. The plaintiffs’ communications and those of their employees with Ms. Alves, their posts on their social media and this lawsuit constitute harassment. This cause of action will also be included in Ms. Alves’ counterclaim.


THIRTEENTH DEFENSE

  1. Sajady’s statements published in the press and the social media postings of his staff constitute defamation and will be included in Ms. Alves’ counterclaim.


FOURTEENTH DEFENSE

  1. Sajady claimed repeatedly that if Ms. Alves wanted to heal, she had to follow his program and listen to his broadcasts 24 hours a day. She followed his program diligently, paid him money, and she did not heal. This constitutes breach of contract and will be included in Ms. Alves’ counterclaim.


PRAYER


WHEREFORE, Defendant demands judgment as follows:

(i) dismissing the complaint; and 

(ii) for such other and further relief as this Court may deem appropriate and just, together with Defendant’s costs and disbursements and reasonable attorneys’ fees for the defense of this action.



By: ___________________________       Dated: December 5, 2017 
           TERRY WOODARD, ESQ.

Attorney for Defendant

Courthouse Corporate Center

320 Carleton Ave., Ste. 1000

Central Islip, NY  11722

Office: (631)582-5757

Fax: (631)234-0058


COUNTY OF SUFFOLK
STATE OF NEW YORK

Tana Lee Alves, being duly sworn, deposes and says: that she is the defendant in this action; that she has read the foregoing answer and knows the contents thereof and that the same is true to her own knowledge, except as to matters therein stated to be alleged upon information and belief, and as to those matters she believes it to be true.



_________________________________
     TANA LEE ALVES



Sworn to before me this
____ day of December, 2017


____________________________
Notary Public