IN THE COURT OF COMMON PLEAS 
OF LAKE COUNTY OHIO
	CIVIL DIVISION

                                                
BRYAN ANTHONY REO, 				)
			Plaintiff,			)
							)
vs.							)	No. 15CV001590
		)	RICHARD L. COLLINS JR
MARTIN LINDSTEDT,  		)	January 6, 2016
                                  Defendant.		)	.

DEFENDANTS AMENDED ANSWER AND COUNTER-CLAIM AS ORDERED
(JURY DEMAND ENDORSED HEREON)

	COMES NOW the current Defendant Pastor Martin Lindstedt along with Lindstedt’s non-profit church corporation in good standing The Church of Jesus Christ Christian / Aryan Nations of Missouri (hereafter in person described as “Pastor Lindstedt” and the Church corporation referred to as “Pastor Lindstedt’s Church”) to timely file this Amended Answer and Counter-Claim against Plaintiff Bryan Reo as ORDERED by this Court on Dec 23, 2015. 

	Defendant(s) intend to Joinder additional Counter-Defendants  (including but not limited to  Anthony D. Reo, Bryan Reo’s father, and William Raymond Finck, “Pastor” Eli James (alias Joseph Kutz or Joseph Putz or Joseph November) and Mark Downey and around a thirty or more counter-defendants and co-conspirators who have worked with Bryan Reo (Plaintiff/Counter-Defendant) to unlawfully interfere under color of law with the First Amendment rights to free speech and practice of religion of Defendant Pastor Martin Lindstedt and his Church.) What should be understood is that Pastor Lindstedt is not a professional licensed attorney, or even a ‘professional’ Plaintiff Pro Se practicing legal practice absent permission from the Ohio State Bar Association on behalf of Bryan Reo’s father, and favored current co-conspirators William Finck and Melissa Epperson, which was admitted to by Bryan Reo and chided by Magistrate Rolls at the Dec. 17th Case Management. Since Pastor Lindstedt’s Church cannot afford an attorney to defend against Bryan Reo’s vexatious and fraudulent litigation, and the Lake County Ohio taxpayers shouldn’t have to provide for an attorney to protect Pastor Lindstedt’s and Lindstedt’s Church Constitutional rights under the U.S. and Ohio Constitutions, the end result is that with all of Pastor Lindstedt’s imperfections in following the Ohio Rules of Civil Procedure, justice and “due process” mandates that this Court will have to make allowances for Pastor Lindstedt’s imperfections in responding to Professional-ish Plaintiff pro-se Bryan Reo’s fraudulent and vexatious unauthorized practice of law for the dozens and hundreds of anticipated flurry of motions to be expected from Bryan Reo seeking summary judgment by any means necessary. Pastor Lindstedt wants this case to go to jury trial and thus ending the criminal career of Bryan Reo, Bryan Reo’s father, William Finck, Melissa Epperson, Eli James / Joseph November and about 20-40 Bryan Reo co-conspirators if by nothing else the posting to the Internet of the never-ending proceedings. What is most likely is that with over 20 or 30 separate parties from various parts around the country and in Canada and Australia, this Court will bail from this frivolous and vexatious litigation just as the federal courts in the Northern District of Ohio and Western District of Missouri did. After all, Bryan Reo has already written a Motion asking for dismissal of Pastor Lindstedt’s Counter-Claim on behalf of William Finck and Melissa Epperson on the basis that this Lake County Court exists solely to destroy the Ohio and United States Constitutional paper guarantees of freedom of speech and religion through tamely giving Bryan Reo everything he wants in the form of getting to practice law without a license and having one law for his enemies like Pastor Martin Lindstedt and Lindstedt’s pre-millennialist Dual-Seedline Christian Identity Church and another for William Finck and Melissa Epperson and their “No Devil” papist-preterist synagogue. 

I.  INTRODUCTION
	Plaintiff Bryan Reo’s fraudulent claim before this Lake County Ohio Court of “tortuous conduct related to Defendant’s campaign of ‘cyber harassment’ against Plaintiff via the World Wide Web” is fraudulent in that Plaintiff Bryan Reo routinely threatened to murder, rape and assault both Pastor Lindstedt and others when Bryan Reo had benefit of Internet anonymity, and then when Bryan Reo was identified, with public social media profiles and Reo’s past history, Bryan Reo and Reo co-conspirators immediately violated the Digital Millennium Copyright Act (hereafter the DMCA)  17 U.S.C. § 512  by taking down a dozen of Pastor Lindstedt’s Church web pages, and those of other parties, committed criminal conspiracies violating 18  U.S.C. § 241 and 242 and violated Pastor Lindstedt and Lindstedt’s civil rights to freedom of speech and religion under color of law, thus civilly liable in the federal jurisdiction under 42 U.S.C. § 1983 and 1984. Upon having his meritless federal case dismissed for failure to state a valid claim despite being given over a month to do so, Bryan Reo decided to file this vexatious and frivolous litigation before this local court. A petty criminal conspirator cannot and will not be able to censor the World Wide Web upon frivolous litigation before a local county court in Ohio. 
	 
II. PARTIES
2.A.  Plaintiff Bryan Reo, who resides with his father, Anthony D. Reo at 7143 Rippling Brook Lane, Mentor Ohio 44060. 
	Admitted: (Civ.R.8B)
	Denied: (Civ. R. 8B) Contrary to Bryan Reo’s assertion that he is a private – not a public – figure, in point of fact Bryan Reo used to have a blog claiming that he was running for an Ohio state assembly seat. But more to the point, Bryan Reo is a notorious Anti-Racist Activist with a public past under a White Nationalist Movement leader named Richard Barrett from 2000-2005 until Richard Barrett declared Reo wasn’t white and that Reo would have to get used to it. Then around 2009, Bryan Reo resurfaced with “Pastor” Eli James to bring in William Raymond Finck as “Dual-Seedline” Christian Identity pastors and claimed to be a pastor and prominent White Nationalist racial activist of sorts himself. Bryan Reo took made fraudulent DMCA complaints and took down around a dozen of Pastor Lindstedt’s Church’s web pages, along with those of others as well. Reo maintains a blog at http://bryanreo.blogspot.com/ and another one on William Finck’s Christogenea web page as well: http://sb.christogenea.org/blog/ where Reo used to reprint Eli James’ claim that Pastor “Lindstedt was a convicted child molester” before taking that libel per se down in order to file his bogus litigation in federal court. Furthermore there was a Bryan Reo Talkshoe podcast channel in which Bryan Reo would claim that Pastor Lindstedt was a convicted child molester and brag – along with Reo’s co-conspirators – about taking down Pastor Lindstedt and Lindstedt’s Church’s forums, blogs, web pages under color of the DMCA and where the DMCA didn’t apply, in Montreal Canada. (By the way, recently Bryan Reo and William Finck took down the Bryan Reo blog in its entirety. 
Bryan Reo also used to display a public Talkshoe podcasting  channel at: 
http://www.talkshoe.com/talkshoe/web/talkCast.jsp?masterId=31407&cmd=tc
Bryan Reo was formerly known as “SwordBrethren” and claimed to be a Teutonic Knight on StormFront and other forums. This Talkshoe Channel is currently “disabled” but can always be re-enabled by Bryan Reo and there are many shows in which Bryan Reo call Pastor Lindstedt a “child molester” and “pedophile” among other malicious things.
	In short, contrary to Bryan Reo’s claims, within White Nationalism in general and Christian Identity in particular, Bryan Reo is a well-known, infamous even, limited purpose public figure . Hence the standard in a libel and defamation lawsuit is Hustler Magazine, Inc., v. Falwell, 485 U.S. 46, (1988) and New York Times v. Sullivan, 376 U.S. 254. All Pastor Lindstedt has done is to point out that Bryan Reo’s public Facebook profile picture, along with other social media pages such as Xuqa.com in which Bryan Reo showed his face, proves that Bryan Reo isn’t even remotely white, hence not a real Christian Identity or White Nationalist leader. The rest of Bryan Reo’s complaint concerns how Lindstedt has allegedly published public records concerning Reo from the federal district court case and soon this case as well. 
	Secondly, in the federal lawsuit, Pastor Lindstedt revealed that Bryan Reo was conspiring with William Finck and others on Finck’s Christogenea forum that Reo was engaging in litigation in order to steal by deceit all of Lindstedt’s “wealth, property, money” because Lindstedt was “the wicked one on Missouri” who was the “enemy of CI”. (Original Answer & Counter-Claim of Oct. 26, 2015, Exhibit #3 Document 9-1, 49-2 of the ongoing federal lawsuit). Thus Reo was conspiring with William Finck and Mark Downey and others to use the courts to defraud and oppress Pastor Lindstedt and Lindstedt’s Church.
	Counter-claim, (Civ. R.13):  Bryan Reo is a public figure within the White Nationalist and Dual-Seedline Christian Identity community who maliciously committed libel per se by publicly stating on his and other Reo co-conspirators’ web pages, blogs, forums, web pages that Pastor Lindstedt was a “convicted child molester” and pedophile. Pastor Lindstedt responded in like manner calling Bryan Reo an Anti-Racist Activist  “mongrel homosexual” which, given Bryan Reo’s appearance and public social media profile pictures confirm the mixed-race ancestry of Bryan Reo. While Pastor Lindstedt and others cannot definitely prove that Bryan Reo is a homosexual, the effeminate mannerisms and the social media profiles certainly lead Pastor Lindstedt and others to assume as much. Therefore, maliciously calling Pastor Lindstedt a “convicted child molester and pedophile” while knowing this is false is far more of a slanderous offense than Pastor Lindstedt is calling Bryan Reo a “homosexual mongrel.” When someone is calling others names, they have no real claim to litigation when others call names right back.  
	This Court, in its Dec. 23, 2015 Order – received Dec. 28, 2015 – told Pastor Lindstedt to make admissions and denials under Civ.R.8(B) or (C) and Counter-Claims under Civ.R.13 and Pastor Lindstedt, no lawyer, or much less pretending to be an attorney practicing “law” for co-conspirators like Bryan Reo, is attempting to obey this Court’s Order as best he can.  
2.B. Anthony D. Reo, father of Bryan Reo, living at 7143 Rippling Brook Lane, Mentor, Ohio, 44060. 
Counter-Claim Civ.R.13.  Anthony D. Reo is a counter-defendant in the federal lawsuit and Pastor Lindstedt seeks a default judgment because of Bryan Reo’s and Anthony D. Reo’s refusal to Answer to Pastor Lindstedt’s counter-suit in federal court in this May 8, 2015 harassing call to Lindstedt’s home:
    http://pastorlindstedt.org/lindstedt/legal/SoredMamzer/2015/May15/050815-133622.mp3
Bryan Reo has claimed that his father, Anthony D. Reo, is one with Bryan Reo’s antics. 
Bryan Reo Unauthorized Practice of Law: At the Dec. 17 Case Management Conference, Bryan Reo gloated that “We stopped Lindstedt’s service” presumably by refusal to sign for the certified letter containing the Lake County Ohio court clerk’s Summons along with Pastor Lindstedt’s Original Answer and Counter-Claim of Oct. 26, 2015 . This Court has itself warned Bryan Reo to “not advocate on behalf of a third party, as he did on behalf of his father, as such would constitute the unauthorized practice of law.” Cf. Order,  Dec. 23, 2015, Paragraph 2, Section VI. However, rather than “caution” semi-professional Plaintiff pro se Bryan Reo for the unauthorized practice of law, this Court, as an Officer of the Judicial System of the State of Ohio, should have immediately dismissed this case against Pastor Lindstedt, and imposed a contempt sanction against Bryan Reo, and immediately reported Bryan Reo to the State Board on the Unauthorized Practice of Law and the Local Bar Association for this crime. The usual fine for this criminal activity is $25,000, hence Pastor Lindstedt immediately makes a claim of $25,000 to be assessed against Bryan Reo and an additional $25,000 to be assessed against Anthony D. Reo. Pastor Lindstedt shall also notify the proper authorities on this matter. This in addition to the claim due on this counter-suit/counter-claim of $25,000 on the merits.  
2.C.(a). William Raymond Finck, Jr., owner/operator of Christogenea.org and numerous other web sites, including www.martinlindstedt.com, address 653 W. 23rd Street, Box 129, Panama City, Florida 32405. 
2.C.(b) Melissa Epperson, concubine / paramour of William Finck, living with Finck, address 653 W. 23rd Street, Box 129, Panama City, Florida 32405. 
Counter-Claim Civ.R.13.  Both William Finck and Melissa Epperson, admittedly in contact still with Bryan Reo, continually call Pastor Lindstedt a “child molester,” a pedophile, a “pecker-puffer”, a sexual predator, and commit libel per se against Pastor Martin Lindstedt until the past month or so when they were served with a summons before this case. William Finck is a Jew who murdered a Puerto Rican sneak-thief in the Jersey City, New Jersey city jail, then “fincked” out his co-murderer and got a reduced prison sentence of 15 years for federal civil rights violations. Finck used to work with Eli James / Joseph November until falling out with November in early 2011. Finck and Eli James and Bryan Reo conspired to fraudulently use the DMCA and Terms of Service complaints to take down “all of Lindstedt’s web pages.”
	Jan. 7, 2011: Eli James with William Finck: “Lindstedt is mad because we (James & Reo) took down all of Lindstedt’s web pages”: http://mamzers.org/useful/audio/EliJames/7Jan11/01_07_11-EJ-long.mp3
	August 13, 2013, Bryan Reo and Bill Finck discuss a conspiracy to take down all of Lindstedt’s web sites using fraudulent DMCA complaints, 1:34:28 to 1:35:46 – 1 min 18 secs:
http://pastorlindstedt.org/lindstedt/legal/SoredMamzer/2013/Aug13/Shills5_10Aug13_13428-13546.mp3
	Bryan Reo was also given a blog on William Finck’s web page where on Nov. 5, 2010, Bryan Reo published the Nov. 1, 2010 article “Rabbi Lindstench – Race Traitor or Jew?”
http://www.anglo-saxonisrael.com/content/rabbi-lindstench  Bryan Reo seems to have taken down not only his reprint of Eli James’ libelous per se article, but sometime within the past few months the entire blog given him by William Finck.
	Therefore, William Finck and Melissa Epperson are accused of defamation, libel and slander and given a counter-claim by Pastor Lindstedt of $25,000 each.
	Bryan Reo’s Unauthorized Practice of Law. Furthermore, at the Case Management Conference of Dec. 17, 2015, while Magistrate Roll was castigating Pastor Lindstedt’s “unreadable” Original Answer and Counter-Claim of Oct. 26, 2015 and praising Bryan Reo’s attendance at law classes, and how Bryan Reo “wrote like an attorney” Pastor Lindstedt commented on how much William Finck’s and Melissa Epperson’s were so much alike. Magistrate Roll commented on how they were so expertly drafted and were word for word the same. Pastor Lindstedt commented that they should be – Bryan Reo had drafted up both Motions to Dismiss for William Finck and Melissa Epperson. Bryan Reo, caught, hastened to say that William Finck asked to see Bryan Reo’s litigation in the federal and Ohio courts. Magistrate Roll then caught onto what was happening and said that Bryan Reo was engaging in the unauthorized practice of law and to “stop it.”
	Again, this Court has itself warned Bryan Reo to “not advocate on behalf of a third party, as he did on behalf of his father, as such would constitute the unauthorized practice of law.” Cf. Order,  Dec. 23, 2015, Paragraph 2, Section VI. However, rather than “caution” semi-professional Plaintiff pro se Bryan Reo for the unauthorized practice of law, this Court, as an Officer of the Judicial System of the State of Ohio, should have immediately dismissed this case against Pastor Lindstedt, and imposed a contempt sanction against Bryan Reo, and immediately reported Bryan Reo to the State Board on the Unauthorized Practice of Law and the Local Bar Association for this crime. The usual fine for this criminal activity is $25,000, hence Pastor Lindstedt immediately makes a claim of twice $25,000 – or $50,000 for drafting up the Finck and Epperson Motions -- to be assessed against Bryan Reo and an additional $25,000 each to be assessed against both William Finck and Melissa Epperson. Pastor Lindstedt shall also notify the proper authorities on this matter. This in addition to the claim due on this counter-suit/counter-claim of $25,000 on the merits.  

2.D. “Pastor” Eli James, alias Joseph November, Joseph Kutz or Joseph Putz, etc. etc. Address of “Pastor Eli James” (Corporate name since 2005) or Joseph November, (legal name since 1981) at 4901 West Oakdale Avenue, Chicago, Illinois 60641. 
Counter-Claim Civ.R.13 Upon Pastor Lindstedt’s discovery that the anonymous Internet stalker calling itself “SwordBrethren” / SwordMamzer was in fact a well-known within the Movement semi-public figure with a past known as Bryan Reo, and the discovery of a Facebook public profile picture showing that Bryan Reo was obviously of not pure Aryan Israelite racial descent, Eli James and Greg Howard “ex-communicated” Pastor Lindstedt from what they claimed was their special Sanhedrin around noon on Oct. 31, 2010 for finding out about who SwordBrethren / SwordMamzer being Bryan Reo. That very Halloween night Eli James called into Pastor Lindstedt’s Talkshoe Show and called Pastor Lindstedt a pedophile and Federal agent and “White trash” and Lindstedt called Eli James a dirty jew and a ZOG agent provocateur / ZOGbot. The next day Eli James published a claim that Pastor Lindstedt was a federal agent provocateur but also that Pastor Lindstedt was a “convicted child molester” around nine or ten times, while knowing better. Bryan Reo reprinted that slander and defamation by Eli James on Reo’s Wordpress blog hosted on William Finck’s server starting on Nov. 5, 2010. This libel per se was kept up until Reo decided to sue Lindstedt in federal court for libel and defamation. Eli James still has this libel per se article up, while Reo took his libel per se down while suing:
http://www.anglo-saxonisrael.com/content/rabbi-lindstench
From November 1, 2010 until around March 2011 Eli James, William Finck and Bryan Reo got along, with Eli James conspiring with Bryan Reo and William Finck and others to take down Lindstedt’s Church’s forums, blogs, web pages and Internet communications both political and religious. Pastor Lindstedt’s Church is Orthodox Comparetian Dual-Seedline Christian Identity and both Eli James and Bill Finck are jews who practice “papist-preterism” (the belief that the Roman Catholic Church put Satan in the pit for a thousand years from 500-1500 AD where the Devil got out and whispered in Martin Luther’s ear and started the Reformation) and “No Devil” in which Satan isn’t real or if Satan is real Satan died in the pit and now the jews are Satan. Bryan Reo was annoyed with Eli James because Eli James said that up to 15% Edomite Canaanite jews like Eli James could get to heaven even though Bryan Reo isn’t remotely pure Aryan Israelite or maybe only 30% white. However, by late February Pastor Lindstedt and Lindstedt’s Church didn’t have any public Internet presence that Bryan Reo and Eli James working together or separately could take detect/take down, although there were several secret underground private Internet Church servers to which Lindstedt’s Church kept a very low profile. Pastor Lindstedt’s Church even has secret servers located in India to preach the gospel. 
“Eli James” is a made-up corporate name, as the name since 1982 was Joseph November. Reo and Finck found out about Eli James’ family and have been defaming Eli James ever since. Eli James lives in Chicago, and probably will testify against Bryan Reo if subpoenaed. The address for Eli James / Joseph November is 4901 West Oakdale Avenue, Chicago, IL, 60641. Pastor Lindstedt makes a Reo-esque claim against “Eli James” for $25,000.
2.E. “Pastor Mark Downey and Downey’s jewess wife Deborah Badynsky-Downey. 
Counter-Claim Civ.R.13 Another public figure in Christian Identity and White Nationalist Movement, Mark Downey was seen conspiring with Bryan Reo to initiate federal bogus litigation back in late August 2014, after Bryan Reo posted a thread on Finck’s Forum called “Pray for my Success”. (Original Answer & Counter-Claim of Oct. 26, 2015, Exhibit #3, Pray for My Success. Not here reprinted.)
	Mark Downey and his “wife” Deborah Badnysky-Downey used to be pastor of this Washington State Klan in which Debbie was allowed to claim to be the “Klailiff” and Mark Downey, a known FBI informant, was allowed to be the Kludd, or Chaplain. In 2002 Pastor Lindstedt found out that the “Klailiff” was also the sexual mascot of the Klan and so the Kludd ran off with the Klailiff and married her. The Downeys are also “Papist-Preterists” and “No- Devils” but since they can’t get along with most “No-Devils”, have their own congregation along with likeminded others. The Downeys claim that Pastor Lindstedt is a pedophile within the past year as well. 
The Downeys are public figures within Christian Identity and have a web page:
  http://kinsmanredeemer.com/ and acts as a minister in Union Kentucky for Don Elmore’s Church: http://fgcp.org/
	William Finck knows the street address of the Downeys and will be discovered to find it.
2.F. Counter-Claims under Civ.R.13 Other parties to be joindered as conspiring with Bryan Reo and cyber stalking Lindstedt and all of whom Pastor Lindstedt makes a claim of damages:
	Bryan Reo’s Mother – as Bryan Reo claimed in the dismissed federal case her as a witness on his behalf for his fraudulent claims. Bryan Reo knows her street address. 
	Matthew Ott – Bryan Reo’s henchman who threatened to cross state lines to molest Pastor Lindstedt in conjunction with Bryan Reo in Oct. 2010.
	“Victor Switzer”  – alias of a quarter-breed Choctaw Indian who is a fireman around Pine Bluff Arkansas, who conspired with Bryan Reo to take down Lindstedt’s and Lindstedt’s Church’s web pages until the second time Bryan Reo blackmailed him for homosexual favors.
	Greg Howard. Unemployed and divorced henchman of Eli James and formerly Bryan Reo suspected of conspiracy in taking down Lindstedt’s and Lindstedt’s Church’s web pages.
	Dan Johns and Jeremiah Johns. Another so-called Christian Identity minister and his son who worked with Bryan Reo to take down Lindstedt’s Church’s web pages.
	Jeromy John Visser. Sephardic Cherokee Melungeon and so-called Christian Identity pastor who worked at one time with Bryan Reo to take down Lindstedt’s Church’s web pages and who still calls Pastor Lindstedt a pedophile. www.CovenantPeoplesMinistries.com
	Robert Hancock, aka “Obadiah 1:18” aka “Obie-gender-bender-pissers-poofter-possum666” who used to work with Bryan Reo and William Shawn DeClue as well as Jeromy Visser to take down Lindstedt’s Church’s web pages and to interfere with John Britton’s federal civil lawsuit. Visser and Hancock, of Melbourne Australia who maintains a web site in the US, fell out with Visser in 2013. http://www.thechristianidentityforum.net/
	Mike Delaney. Took down in conjunction with Bryan Reo  the first web page, blog and forum under the www.pastorlindstedt.org domain because Lindstedt reprinted an article insinuating that Mike Delaney was a federal agent provocateur. http://www.prothink.org/
William Shawn DeClue – a federal informant and unsuccessful burglar who worked with Bryan Reo to take down Church web pages and who calls Lindstedt a pedophile continuously. Pastor Lindstedt foolishly ordained DeClue upon DeClue’s incessant begging and this lasted 2 days. DeClue had a lengthy criminal record which recently has been expunged. William DeClue has been served with a summons and if this case continues, Pastor Lindstedt will be entitled to a default judgment.
Clifton Emahiser. Pastor Lindstedt knows that Clifton Emahiser has been instrumental in bringing in William Finck into Christian Identity, and thus a conspirator with Reo and Finck. However, the actual damages are problematic. Clifton Emahiser has already been served with a summons and if this case continues, Pastor Lindstedt will be entitled to a default judgment. 
	Martin 41, Allen Rouse, Meggie Butts, “Ezra Pound”, “Sven Longshanks” and John or Jane Does #1-20. Associates and co-conspirators of Bryan Reo, William Finck, Mark Downey who have joined them in taking down Pastor Lindstedt’s and Lindstedt’s Church’s sundry web pages, forums, blogs and Internet teaching and preaching communications and/or keep on calling Pastor Lindstedt a pedophile. William Finck and Bryan Reo knows each of their true identities and street addresses. 
	Howard “Buck” McHugh.  Former stock broker from A.G.Edwards, Buck McHugh operated a Skype chat room, and secretly hated Bryan Reo for working with a jew former partner to cost McHugh over a million dollars. In April 2013 Pastor Lindstedt “braced” McHugh for using Lindstedt as a catspaw against Reo by feeding Lindstedt information against Reo which was only correct 80% of the time. Reo claimed that Buck McHugh is under Reo’s control, however.  Reo would make agreements with both McHugh and John Britton to take down material and photos of Bryan Reo and then Reo would double-cross both McHugh and Britton. Buck McHugh played off Lindstedt and Reo against each other. Any case would have to involve subpoenaing, possibly suing, Buck McHugh.
	John Edward “Johnny Tonto” Britton. Yet another “White Supremacist” and Christian Identist of mixed-race stock, Britton wanted Pastor Lindstedt to support a drunken crack-head named Morris Gulett, who went to prison for conspiring to rob banks in Alabama as Pastor Richard Butler’s successor back in Jan. 2005. For approximately eight years Lindstedt helped Britton and Britton’s extended family with his problems, especially when Bryan Reo interfered with Britton’s federal civil litigation through a mixture of homosexual infatuation and as a means of getting back at Lindstedt. Reo insinuated himself into Britton’s case by filing a sealed affidavit saying that the ongoing federal lawsuit involving a defective gas turbine engine-feed nozzle which was defective and caused a crash was somehow a matter of John Britton being a nephew of Aryan Nations pastor Neumann Britton. Judge Edward M. Lodge, no friend of the Aryan Nations of Idaho, said that the trial could proceed on the merits and not be dismissed because Rolls Royce wanted it dismissed because they had allowed and supported Bryan Reo’s insinuation of himself for malice into the case. Britton wanted to settle for $50,000 and Lindstedt helped Britton get $110,000 of the $330,000 settlement. Britton blew the $110,000 in less than five months. Lives in Emmitt Idaho. 
	In retaliation for Reo’s tortuous interference, John Britton’s lawyer, Stu McCartney, looked up Reo’s information on Lexus-Nexus, and sent the pdf file to Britton. Britton sent this pdf file to five or six others, including Lindstedt, who kept it to himself. An idiot buffoon named Russell Walker, however distributed the Lexus-Nexus printout to his “retard e-mail list” including Bryan Reo and 40 others, including William Finck and Eli James. Reo knew that it wasn’t Lindstedt who published this public information, but rather Russ Walker, yet Reo fraudulently and perjurously in both the federal case, now dismissed, and in the present case claims that Pastor Lindstedt is somehow liable for releasing a public document which because of Reo’s using it as an exhibit is even more of a public document available to anyone with a PACER account when Reo knows the actual source of that public document. 
	John Britton, much like Buck McHugh, is serving Bryan Reo now. Lindstedt found out that Britton wasn’t white, originated from North-East Oklahoma, was the grandson of an Indian Pentecostal preacher, and not descended from King Saul, or of noble ancestry having to do with William the Conqueror or Charlemagne or Frederick the Great.  Furthermore John Britton has three sons and a sixth daughter by three additional women, one of them openly homosexual. John Britton communicated to Pastor Lindstedt a death threat in Feb. 2014. Like Buck McHugh, if this matter ever goes to trial, Britton will have to be subpoenaed.
	This is the list of suspected Bryan Reo co-conspirators and co-counter-defendants as known now by Defendant Pastor Lindstedt. When Pastor Lindstedt filed his counter-claim in the bogus federal lawsuit initiated by Bryan Reo, and then answered all of Reo’s bogus and fraudulent motions, U.S, Magistrate Judge Matthew J. Whitworth finally caught on and figured out that Bryan Reo didn’t have a valid DMCA complaint nor ten million, seven-hundred and fifty thousand dollars in damages because Pastor Lindstedt and Pastor Lindstedt’s Church’s web pages chose to publish this factual information concerning Bryan Reo and Reo’s co-counter-defendants and co-conspirators. John Britton has already been served legal process, and if this case continues Pastor Lindstedt will seek a default judgment unless an agreement is made.
		Daryl Lemont Jenkins of the One People’s Project. An Anti-Racist Activist NGO which Bryan Reo is rightly suspected of working for in the past and possibly in the present. Accused of conspiracy with Bryan Reo to take down Lindstedt’s web pages.
	Mark Potok and the Southern Poverty Law Center. Mark Potok is a jew and a distant relation of William Finck on Finck’s mother’s side. Suspected of using Bryan Reo as one of their Anti-Racist Activists to take down Lindstedt’s Church’s web pages.
	Paul Fromm, Canadian “white nationalist” and poseur for “free speech” in Canada, who appeared on Bryan Reo’s Talkshoe show with William Finck defending Bryan Reo working to get Pastor Lindstedt’s Aryan Nations Church kicked off of iweb-Canada based in Montreal Canada. Bryan Reo admitted to working with the infamous jew lawyer Richard Warman to get Pastor Lindstedt’s Church’s Web page banned in Canada, even though there is no DMCA in Canada and the French Canadian salesman promised that it would take a Montreal magistrate to take down the web page there. Pastor Lindstedt’s web page lasted 15 days from Dec. 13 to Dec 28, 2010. Paul Fromm claims to represent free speech in Canada yet justified Bryan Reo’s and William Finck’s censorship. Thus Pastor Lindstedt wishes to impose a “hypocrite’s tax” by this claim on Fromm the liar and hypocrite. Since both Bryan Reo and Pastor Lindstedt are agreed that this Court really lacks subject matter and personal jurisdiction over out-of-staters, Fromm should be safe in Canada from litigation on this matter.  
	A Note Concerning the Claims Against Numerous Parties. This Court states that under the Ohio Rules of Civil Procedure 13(H) that Pastor Lindstedt doesn’t need the permission of this Court to joinder additional parties but that “there must be an assertion of a counter-claim or cross-claim to justify that joinder of these additional parties.” As recently as a few weeks or days  ago, some of those mentioned as major and secondary parties, like William Shawn DeClue, John Britton, Jeromy Visser, Mark Downey, Meggie Butts, “Ezra Pound” and others were calling Pastor Lindstedt a “child molester” and a pedophile. So under the Bryan Reo theory of “law” then mere Internet name-calling (by parties no longer anonymous is somehow actionable before this Court. Does this Court really wish to spend weeks, months, years in getting to the bottom of how Bryan Reo’s friends called Pastor Lindstedt a “pedophile” and Pastor Lindstedt called them jews and mongrels and homosexuals or all of the above on the Internet? As a result of Bryan Reo’s “fishing expedition” discovery requests, Bryan Reo is bringing up matters that except or Reo’s vexatious and frivolous litigation in this case would have either died a long time ago or simply been written off as mere name-calling. Secondly, as illustrated by the fact that William Finck data-mines the information which comes into his numerous web pages, as witness the fact that Finck found out the real name of a man named “Phil-in-Boaz”to that man’s real name and address, there is no longer any real anonymity on the Internet. Does this Court really want to get involved in refereeing a case involving forty or fifty parties bitching about how they called Pastor Lindstedt a pedophile and Pastor Lindstedt called them jews, mongrels, and homosexuals? This Court asked as much at the Dec. 17th Conference as to whether there really was an actionable case or whether it was nothing more than Bryan Reo and Pastor Lindstedt loathing each other and filing something which is really ridiculous. None of this crap will really stand because the Internet is full of idiots calling each other nasty names and all this case will accomplish before it is flushed by higher courts at the state and federal level is to bring together half a hundred warring litigants from across the country and world who are no longer anonymous and who like to call each other names over the Internet. This Lake County Court of Common Pleas will become a laughing-stock because it allowed a notorious vexatious litigant fraudulently and maliciously practicing law without a license or even a clue to run wild.
	This Court mentioned at the Dec. 17th Conference Pastor Lindstedt and Lindstedt’s Church having an appeal before the 8th Circuit Court of Appeals against Bryan Reo and the likelihood of a win by Pastor Lindstedt. The case by Pastor Lindstedt won’t involve this nonsense before this Court, but rather the unconstitutionality of the Digital Millennium Copyright Act in allowing someone like Bryan Reo and William Finck and Eli James to abuse the DMCA in taking down the Internet web pages of their racial and religious enemies. Is there a First Amendment right to freedom of speech and religion or not? That is the question for a federal court with competent jurisdiction to have asked and answered, NOT this Ohio county court over matters involving petty disputes concerning what happens on an interstate and international venue such as the World Wide Web / Internet

Now for the Defendant / Counter-Claimant parties.
3. A. Pastor Martin Lindstedt, 338 Rabbit Track Road, Granby Missouri, 64844. Tel # 417-472-6901, PastorLindstedt@gmail.com . Owner of several web pages and Talkshoe Radio host of “The Movement Turd” or “Da Dik-Dik Show” in which the goings on of the White Nationalist and Christian Identity Movements – or Bowel Movements – are discussed openly and without censorship. Even Bryan Reo can call into this show – and on Nov. 28, 2010 Reo did so, calling Pastor Lindstedt a child molester and admitting that Reo had no intention of litigating in federal district court his fraudulent Digital Millennium Copyright Act take-down notice for Lindstedt publishing Reo’s public Facebook profile page.
3.B.  The Church of Jesus Christ Christian / Aryan Nations of Missouri under Civ.R. 13(H) and Civ. R. 17(A). Civ.R.19(A), Civ.R.20(A). a public-benefits church corporation incorporated in Missouri since October 2006 and a corporation in good standing with the Missouri Secretary of State until renewal in August 2016. 
This Church non-501(c)(3) corporation is the owner of the web pages, domains, forums, blogs and Internet communications that Bryan Reo and Reo’s co-conspirator co-counter-defendants  fraudulently and maliciously took down under color of law – the DMCA – and is trying to have this Court censor and oppress through fraudulent litigation in this case. Therefore, given that the Church is a party, and that both Plaintiff and Defendants are public figures, this fraudulent and vexatious litigation so violative of the First Amendment will become impossible to sustain. Which is why Bryan Reo lied about this matter to begin with. 

III  JURISDICTION AND VENUE

4. Bryan Reo –This Court enjoys subject matter jurisdiction over the instant civil action because the amount in controversy exceeds five hundred dollars. ($500) R.C. § 2305.01.
Affirmative Defenses Civ.R.8(C)  This Court doesn’t have subject matter jurisdiction over name-calling over the Internet; because the Statute of Limitations of Ohio Revised Code § 2305.03 and 2305.11 forbids this lawsuit, and because Bryan Reo can’t prove that he suffered any damages whatsoever, much less for over $500.  Also, Bryan Reo can’t explain how Pastor Lindstedt calling Bryan Reo a mongrel homosexual is actionable given that Bryan Reo and Bryan Reo’s numerous co-conspirators have been and continue to call Pastor Lindstedt a convicted child molester and pedophile while demanding Pastor Lindstedt’s Church’s web pages be censored and gagged because Bryan Reo’s feelings are hurt. 
5. Bryan Reo – This Court enjoys personal jurisdiction over Defendant because Defendant caused tortious injury to Plaintiff in the State of Ohio by an act outside the State of Ohio that was committed by Defendant with the purpose of injuring Plaintiff when the Defendant might reasonably have expected that Plaintiff would be injured in the State of Ohio. R.C.  § 2307.382 (A)(6); Civ. R. 4.3(A)(9); Kauffman Racing Equip., L.L.C., v. Roberts, 126 Ohio St. 3d 81, (Ohio 2010) (holding that a non-commercial website intentionally used to defame an Ohio resident provides Ohio courts personal jurisdiction over foreign tortfeasors.)
	Affirmative Defenses Civ.R.8(C)  Res Judicata.  Plaintiff Bryan Reo didn’t initially seek out this Ohio Court in order to file against Defendant Pastor Lindstedt and Lindstedt’s Church a bogus and fraudulent civil action for a mere $25,000 but rather before the US District Court in Cleveland Ohio for $10.75 million by acting through fraud and perjury to not only render Defendant “penniless and destitute” (Exhibit 3, Original Answer and Counter-claim of Oct. 26, 2015) but also to get Defendant Pastor Lindstedt gunned down by U.S. Marshalls, or put into a psychiatric prison and censored forever. (See Exhibit #1, Original Answer and Counter-claim of Oct. 26, 2015)  Now that Reo’s and Reo’s co-conspirators lost that fraudulent effort in the U.S. District Court, (See Exhibit #2, Original Answer and Counter-Claim of Oct. 26, 201 5) Reo has brought this action to his native Ohio court in Ohio, and not stated a single thing differently that lost before the U.S. District Court. Therefore, having already lost in federal court as Bryan Reo’s initial court of jurisdiction, Bryan Reo can’t forum-shop to this local venue, especially given that now professional pro se Plaintiff Bryan Reo has admittedly written two Motions for Reo co-conspirators William Finck and Melissa Epperson about this Court NOT having personal jurisdiction over them because both the Ohio and federal court of appeals recognize the possibility of oppression and injustice given that they live so far away from a local state court in which a professional plaintiff pro se like Bryan Reo practicing law without a license or a clue or decency could file vexatious and frivolous motion after motion and then like Bryan Reo, claim to have served them while buying postage from stamps.com and avoiding postmarks proving fraud. While Pastor Lindstedt hasn’t acted like Bryan Reo in filing motion after motion seeking summary judgment for violations of delusional and fraudulent interpretation of law, still both the federal and Ohio courts must recognize that there is no personal jurisdiction by this local Court over Pastor Lindstedt and Lindstedt’s Church. Even more to the point, Bryan Reo’s own unauthorized practice of law motions drafted for the benefit of Reo co-conspirators William Finck and Melissa Epperson admit that this Court lacks personal, as well as subject matter jurisdiction. Finck and Epperson live much the same distance as Pastor Lindstedt from Bryan Reo. So Bryan Reo argues that yes, this Court has personal jurisdiction over Pastor Lindstedt and Lindstedt’s Church, but NOT over Reo’s friends William Finck and Melissa Epperson. 
	Statute of Limitations of Ohio Revised Code § 2305.03 and 2305.11 forbids this lawsuit, even though Bryan Reo claims that because U.S. Magistrate Judge Matthew Whitworth dismissed Reo’s litigation without prejudice, the fact that Reo failed at the federal level doesn’t allow anything before Reo filed on April 15, 2014 in the Northern District of Ohio federal district court to suddenly become relevant because of that failure. Bryan Reo could have filed this action for alleged defamation happening in 2010, 2011, 2012, 2013 and before April 2014 in this Lake County Court, but rather since $10.75 million is more than $25,000 chose not to do so. U.S. Magistrate Judge Matthew Whitworth told Bryan Reo when Reo begged to bring his case down to Lake County Ohio too be mindful of Ohio Statute of Limitations, and while not knowing Ohio law, figured out that whining about what was allegedly said over five years ago wouldn’t cut it. The federal system isn’t some cryogenic freezer unit in which claims over a half decade are made, brought up, and then when failed, to be thawed out and processed like rotten chicken before a state court somewhere when the state law sets limits for the cases to be processed locally. Practically all the events complained about by Bryan Reo occurred in 2010 to 2013, and Reo already tried and lost his litigation attempts in federal court, which dismissed as spurious and fraudulent Reo’s claims. Res judicata applies, unless Reo wants to actually spend the $400 to re-file in federal court, in which case the Northern District of Ohio shall kick it back to the Western District of Missouri for much the same result. The only timely thing Reo claims is that Pastor Lindstedt published the motions from the federal court proceedings on his Church’s web page, and as a public record they are not actionable in any case, especially given that Lindstedt’s motions informed the federal judge that Reo’s claims before that court were baseless and fraudulent. Since Pastor Lindstedt has brought up this matter, this case must be dismissed forthwith with prejudice.
	Civ.R.8(B) Denial. Bryan Reo is claiming that Pastor Lindstedt had the malicious purpose of somehow injuring Bryan Reo even when Lindstedt didn’t know who Bryan Reo was in the first place, other than that some mongrel of dubious heterosexuality was pretending to be a White Supremacist and Dual-Seedline Christian Identity pastor and threatening to murder old women in wheelchairs for questioning William Finck’s supposed Greek scholarship and later calling Pastor Lindstedt a child molester and pedophile. Given this denial by Pastor Lindstedt that there was at that time no personal animus but rather a determination to remove that which didn’t belong, according to religious duty and principles, how is Bryan Reo going to prevail via trial by jury on the merits? It is Bryan Reo who has demonstrated vindictiveness and malice, especially given that Pastor Lindstedt has spent most of the past six years trying to protect the Aryan Christian Israelite Congregation and Church web pages from Bryan Reo viciousness, often by hiding and then when detected by Reo removing anything from Church web pages that Bryan Reo complained about. Bad faith was always two-thirds Reo and one-third Lindstedt. 
Civ. R.13 Counter-claim. If, as Bryan Reo claims, this Court has personal and subject matter over Pastor Lindstedt and Lindstedt’s Church, then this Court has personal and subject matter not only Bryan Reo, but William Finck, Melissa Epperson, and thirty or forty or fifty of Bryan Reo supporters and co-conspirators calling Pastor Lindstedt a convicted child molester and pedophile and destroying Church intellectual property by filing fraudulent DMCA and Terms of Service Complaints.  The end result will be chaos as there are forty parties, each clawing and scratching, most who hate both Reo and Lindstedt by now, with Bryan Reo practicing unauthorized reo-law for those Reo likes, all over stupid crap about who called someone else what over the Internet. Not only does this Court lack jurisdiction, this Court will learn soon enough that it don’t want jurisdiction over this foolishness and find some excuse to flush it down like U.S. Magistrate Matthew Whitworth eventually did.  
6. Bryan Reo – Venue is proper with this Court because Plaintiff resides in Lake County, State of Ohio, and the Court’s personal jurisdiction exists via Civ.R.4.3 Civ.R.3(B)(7).
	Civ.R.8(B)(C) Denial. Bryan Reo in Item #6 merely re-states the exact same claims as in Item #5, whereupon Pastor Lindstedt, in the interests of brevity, proffers the exact same defenses and counter-claims. However, it does raise the question of what sort of state court allows thirty-five fraudulent and vexatious lawsuits by some hard-core unemployable over federal issues such as the DMCA or the TCPA (Telephone Consumer Protection Act) which now are raised by these corporate telemarketers to the U.S. District Court in Cleveland. In short, this Lake County Court is being used as a sort of racket enforcement arm by Bryan Reo not wanting to spend the $400 docket fee before the federal district court in Cleveland so Reo files for less than half-price plus cheap service before this Court so that the telemarketing companies will remove these Bryan Reo fraudulent shake-downs to the federal level and they pay the $400 docket fee, remain as defendants, and then negotiate with Bryan Reo as to how it will be much, much, much cheaper to settle rather than to litigate with Professional pro se Plaintiff . As “Plaintiff” Bryan Reo can always voluntarily move to dismiss his lawsuit if things get out of control. Then what are the telemarketing companies to do? File for an appeal and pay thousands of dollars more for the hollow victory.  And Bryan Reo knows how to practice vexatious litigation, filing motion after motion to strike, demanding unnecessary discovery about irrelevant items, pretending that what it claims is the law is the real law when it is not, and on occasion feeding the Lake County Bar Association.  Even the National Rifle Association and Arbitron  had to settle with Bryan Reo. There is a purpose to these seemingly random endless petty lawsuits filed by Bryan Reo. The purpose is a legal shakedown of interstate  merchants and telemarketers as they face, like a moose or deer attacked by a vexatious tick with nothing to lose and no other purpose in life other than parasitism, and so they simply feed the tick a few thousand to settle. There is one telemarketing company which has already been sued before by Bryan Reo amongst the four new lawsuits filed the week of Dec. 23-30, 2015, with three filed in one day alone. 
	But there is a price for acceding to this corruption from about this, the most twisted Satanic mongrel abomination spawned ever. Talking to the Lake County court clerks who know what is going on but dare not mention it Pastor Lindstedt can feel their frustration at being harnessed to serving an evil court system which encourages this parasitic viciousness. It really must be frustrating to be a well-educated middle-class woman or single-mom trying to feed a family and having to be a part of such abuse of process. All they can do is to just do their job and stick to answering questions about docketing papers, and whether the judge has ruled on a motion. They cannot answer questions which might be construed as giving legal advice.
	Looking at the Ohio Code of Ethics and Judicial Responsibility, the Number One Rule is to do nothing which will reflect adversely upon the necessity of enhancing respect for the Judicial System. Because if people lose respect for the judiciary, then they will lose their power, and once they lose their power, countless revolutions and civil wars show that they will lose their lives. Any court or judge who forgets this fact of life will hear from the others.
	On Dec. 17, 2015, Pastor Lindstedt listened with amazement as it seemed that Magistrate Roll – who both Lindstedt and Lindstedt’s domestic partner Roxie F. thought was a woman – was ovulating to Bryan Reo. Magistrate Roll denied that Bryan Reo was a public figure in the racial nationalist movement and Christian Identity. Roll condemned Pastor Lindstedt’s  answer and motions, saying that they were “unreadable.” Roll repeated Bryan Reo talking points. Roll complimented Bryan Reo on going to law school classes and how Bryan Reo’s writing was “like that of a professional lawyer.” Pastor Lindstedt mentioned how well William Finck’s and Melissa Epperson’s Motions to Dismiss were written. Magistrate Roll talked about how they were literally word for word. Pastor Lindstedt accused Bryan Reo of drafting them. Bryan Reo, caught out, came up with a lie, saying that William Finck asked Bryan Reo to “keep him in touch” with Reo’s litigation against Pastor Lindstedt. Magistrate Roll then told Reo that this was verging on the unauthorized practice of law and to “stop it.” A trial date was set for August 2, 2016. Pastor Lindstedt listened with amazement as Bryan Reo was telling Magistrate Kenneth Roll that Reo would go down to Granby Missouri and force Lindstedt to give a deposition but not allow Lindstedt to ask questions of Reo. Magistrate Roll said that Lindstedt got to ask questions of Reo at a deposition. By this time Pastor Lindstedt is thinking that this Magistrate Kenneth Roll is a tranny and has gone all Caitlyn Jenner – Caitlyn/Kennethene Roll. It sounded like listening to a homosexual couple fighting, with Bryan Reo being the pitcher and Roll the catcher. However, since Magistrate Roll was taking up for Pastor Lindstedt and Lindstedt’s Church having some rights against a salivating Bryan -- who was the bull and with Caitlyn being the cuck – it seemed best to listen and say nothing. However, when Pastor Lindstedt started referring to Magistrate Roll as “Ma’am” then Roll said that he wasn’t a “Ma’am.” “So how do you wish to be addressed? As Magistrate Roll? “You can call me Sir!!!” Well, okaaay, then.
	At the end of the conference, Bryan Reo referred to Pastor Lindstedt having a web page which defamed Bryan Reo no end and referred to the link. Bryan Reo said that Lindstedt would end up defaming Magistrate Roll no end. Pastor Lindstedt said nothing and the Conference ended. Afterwards while calling about the Journal Entry the next day (Dec. 18th), the court clerks confirmed that Magistrate Kenneth Roll’s gender was male, and Pastor Lindstedt did an Internet search and found out that Roll was the Secretary of the Ohio Magistrates thingamabob and got an award for Magistrate of the Year and is thought of highly. Who’d of thunk it?
	That said, Pastor Lindstedt has absolutely no confidence in getting due process of law or a fair trial for himself or his Church in Lake County Court system. Already Bryan Reo is writing up Motions for Summary Judgment because Bryan Reo insists on using Discovery as a weapon against Pastor Lindstedt and Lindstedt’s Church. Bryan Reo certified that he mailed off a Motion for Summary Judgment on Dec. 23d and somehow it didn’t get delivered until Jan. 2, 2016, along with a Lake County Court document postmarked December 29, 2015. Bryan Reo is printing up stamps and thus avoiding a postmark. Not that it matters upon appeal to the higher Ohio Appellate or federal courts. The System isn’t going to let a litigious professional plaintiff pro se working some county court to shut down the Internet. So we let events unfold.
	However, the Ohio Attorney General’s Office, The Ohio Supreme Court Board for the Unauthorized Practice of Law, the U.S. Attorney’s Office, and a number of Bryan Reo victims shall be notified, and sooner or later be forced to clean up this mess. .

IV. STATEMENT OF FACTS
7. Bryan Reo --  Plaintiff first came into contact with Defendant in early 2010 when Defendant was invited into a lively Internet ,chat room discussion in which the topics that were discussed 
involved hunting, camping, target shooting, outdoor activities, and politics. A dispute arose  between Plaintiff and Defendant during the discussion at which time Defendant promised to 
ascertain the real-life identity of Plaintiff-which was then not known to Defendant-to destroy 
Plaintiff s reputation. 
	Civ.R.8(C) – Bryan Reo fails to state a complaint upon which any relief can be granted. Nobody has any inherent right to anonymity on the Internet, especially when engaged in nefarious or unlawful activity. Bryan Reo is making a claim that it has some “right” to remain anonymous while committing over the Internet acts of terrorism, slander, libel per se, fraud, defamation, extortion, solicitation to murder, rape, assault, battery, and other illegal and immoral acts. The only benefit to Bryan Reo’s attempted anonymous cowardice is that at least then Bryan Reo didn’t engage in fraudulent DMCA complaints or litigation.
	Civ.R.8(B) – Denial and partial admissions. The owner of the chat-room, Howard “Buck” McHugh invited Pastor Lindstedt to attend precisely to deflate and to fight with these other attendees who were mainly idiots and frauds. At the time, Buck McHugh hated Bryan Reo because McHugh blamed Reo for viciously working with a former partner in the securities profession of costing McHugh millions of dollars in profits from those McHugh had pressured to invest with at A.G. Edwards. 
http://www.boston.com/business/articles/2008/11/22/retirees_to_recoup_their_losses/
	Pastor Lindstedt had the reputation of digging into things in order to find out the truth about people coming into Christian Identity since 1995. McHugh assured Lindstedt that this creepy-sounding effeminate who was in the chatroom calling itself “SwordBrethren” was not remotely white, much less Aryan Christian Israelite, but rather was the Deuteronomy 23:2 forbidden miscegenated mongrel bastard called in Ancient Hebrew a “mamzer.” So Lindstedt took to giving it the name of “SwordMamzer.” This creature worshipped William Finck and was rumored to be a former Anti-Racist Activist. McHugh insisted on giving Lindstedt the details of how it lived in the Cleveland area, went to John Carroll University, and pretty much that it preyed on elderly women in insurance scams and was into Mixed Martial Arts, and a whole lot more. Everything except “SwordMamzer’s” real name and where it lived. 
	Later in April 2013, Buck McHugh revealed that he had used Pastor Lindstedt for his own purposes as a catspaw. Said that Lindstedt had promised to sue Bryan Reo under the DMCA for fraudulently taking down Lindstedt’s Church’s web pages – and so Lindstedt had, but it seemed best then to simply let Bryan Reo as a known mongrel and William Finck and Eli James as jews simply let their deeds be made manifest. Pastor Lindstedt told Buck McHugh that he ought to sue Bryan Reo and John Britton ought to do his own dirty work. This was the last time Lindstedt spoke to Buck McHugh. However, Buck McHugh is believed to snitch out what Bryan Reo is up to on these and other cases. Buck McHugh was correct about Bryan Reo 80% of the time, which is pretty good. Bryan Reo also thinks that he controls Buck McHugh. 
	This entire paragraph by Plaintiff Bryan Reo is telling. Bryan Reo actually thinks as a parasite and predator and sly sniveling monster that it has a right to remain anonymous so that it can destroy the lives of others like a rat in ambush. Hence the calls to U.S. Magistrate Matthew Whitworth for a protective “gag order” against Pastor Lindstedt publishing the facts and evidence of the Reo federal lawsuit. Whitworth said that he wouldn’t issue any prior injunction restraining the publication of Plaintiff and Defendant court documents at the Scheduling Conference on Feb. 13, 2015. In fact, the only new thing in this latest lawsuit by Bryan Reo is the complaint that Lindstedt has published the PACER public records of the filings of Reo’s federal case, which was dismissed as frivolous. Since a U.S. Magistrate Judge refused to issue a “protective order” or “gag order” enjoining Pastor Lindstedt, a mere county judge in Ohio will not have any such power to do likewise. Bryan Reo is still butt-hurt over this and wants one still. 
	As Pastor Lindstedt recollects the myriad conversations between “SwordMamzer” and himself in Buck McHugh’s Skype call-in room, some of the time Reo was trying to get Lindstedt to relent on the Deuteronomy 23:2  rule, but Lindstedt said that yes, sooner or later he would find out who the anonymous mongrel coward was that did threaten and cause trouble for those who were in that on-line racial and religious community and that this would most certainly be revealed to everyone who wanted to know and that “SwordMamzer” would have to behave itself. 
9. Bryan Reo -- Towards the later part of 2010, Defendant succeeded in ascertaining Plaintiffs identity and began a relentless campaign of harassment that continues to the present day whereby (1) Defendant posted photographs of Plaintiff and Plaintiff s personal phone number onto pornographic websites; (2) Defendant impersonated Plaintiff on the World Wide Web to purport to third-parties that Plaintiff supports child molestation; and (3) Defendant published statements on the World Wide Web that state that Plaintiff is a homosexual, a drug dealer, a con-man, a murderer, a pawn store owner, a "Jewish pimp," engages in insurance fraud, and has syphilis and other venereal diseases. Defendant further defamed Plaintiff by claiming that Plaintiff had threatened to murder an elderly woman and rape another woman.
Civ.R.8(C) – Affirmative Defenses. Again, Bryan Reo’s claims of Defamation from 2010 are banned by the Ohio one-year Statute of Limitations. Bryan Reo neglects to mention that Bryan Reo  and Reo’s co-conspirators were calling Pastor Lindstedt a convicted child molester and pedophile at this time.
Civ.R.8(B) Denials and Admissions:   
	Item (1) is a knowing lie by Reo. Bryan Reo had taken down the web pages of some Internet trolls named “NIM-Busters” and it was likely a NIM-Buster who posted any posting of Reo’s pictures on any pornographic web sites, not Pastor Lindstedt who in any case NEVER posts anything on pornographic web sites, much less homosexual pornographic web sites. Item #2 is another knowing lie by Bryan Reo as Lindstedt hasn’t claimed that Reo is a child molester, although Reo and Reo’s co-conspirators claim back then and now that Lindstedt is a child molester all the time. Items #3 are a mixed bag. Pastor Lindstedt believes Reo is indeed a homosexual as do most Movement activists. Lindstedt has not claimed that Reo is a drug dealer. Buck McHugh claimed that Bryan Reo was indeed a con man, a murderer, and engages in insurance fraud. In the summer of 2013 Lindstedt found out that it was another Bryan Reo who drives the exact same year and model of  SUV that killed a Catherine Williams in South Carolina. Pastor Lindstedt and John Britton speculated that Bryan Reo’s father operated a pawn-brokerage due to the numerous guns Bryan Reo had, but Buck McHugh said that Reo’s father was a janitor for GE. Bryan Reo claimed the rest already on Reo’s dismissed federal lawsuit against Lindstedt, who doesn’t know where Reo came up with that nonsense. 
	Insofar as Reo threatening to murder an 86-year-old woman named Athena living in Michigan confined to a wheelchair by shoving a spear in her head for YHWH, Pastor Lindstedt heard that from Russ Walker, the retard who published Bryan Reo’s Lexus-Nexus profile far and wide. However, Lindstedt did hear Reo and Finck on one of their podcasts together getting all mad at Athena because she was born in Macedonia and speaks Greek making fun of Finck’s pretend ability to speak and read Greek when Finck can’t speak English. There never has existed any native Greek speaker or writer who fails to ridicule Finck’s pretend Greek scholarship that Finck supposedly acquired while in prison for murdering a Puerto Rican sneak-thief in jail.  
	Bryan Reo did threaten, sometime after Oct. 13, 2010 and before November 28, 2010 to rape John Britton’s wife and daughters. This probably was in a Talkshoe chat room. Lindstedt and Britton were in communication by phone, and Lindstedt assured Britton that Reo didn’t rape women but that Britton needed to watch his own corn hole. This was before we found out about “Victor Switzer” who Reo had a man-crush on and blackmailed like Reo did with Britton. Anyways, Reo goaded Britton when he called into Lindstedt’s “Movement Turd #46”  of November 28, 2010 to where Britton threatened to shoot Reo if Reo showed up in Britton’s town in Idaho. Reo made a complaint to Talkshoe and got that show pulled. On March 7, 2011 Bryan Reo made an unsigned complaint to the Lake County Sheriff’s Department that John Britton had threatened to murder Reo, that Lindstedt defamed Reo, and that Russ Walker sicced some vinyl siding salesmen on Bryan Reo and Reo’s father. Pastor Lindstedt has asked for a second copy of  that police report from the Lake County Sheriff’s Department and presented a copy of this as an .Affidavit of Reo perjury. 
	On the Nov. 28, 2010 show, Bryan Reo called Pastor Lindstedt a child molester numerous times and admitted that he didn’t have any intentions of filing suit under the DMCA given that Lindstedt had filed a Counter-Notice  on Nov. 18th to Reo’s Take-Down Notice Nov. 15, 2010. A recording of this call by Reo to Lindstedt’s show proved that Reo simply abused the DMCA in order to take down the web pages of Lindstedt and others as censorship. Since there was no DMCA jurisdiction, the federal judge had no choice but to dismiss Reo’s bogus federal lawsuit when Reo couldn’t even remotely prove that Reo suffered $10,750,000 in damages.
The hour-long segment in which Bryan Reo called in of the entire six-hour program is one of the classic Movement Turd shows  on this Talkshoe show operated by a NIM-Buster:
http://www.talkshoe.com/talkshoe/web/talkCast.jsp?masterId=113209&cmd=tc  Show
http://recordings.talkshoe.com/TC-113209/TS-631318.mp3  -- Episode recording
Civ.R.13 – Counter-Claim.  Bryan Reo and Reo’s co-conspirators back then and to this very day claim the libel per se that Pastor Lindstedt is a child molester and pedophile and Pastor Lindstedt repeats the truth that Bryan Reo isn’t white, but rather is a mixed-race mongrel and the wide-spread speculation that Bryan Reo is likely s homosexual. 
9. Bryan Reo -- Plaintiff does not support child molestation and Plaintiff is not a homosexual, a drug dealer, a con-man, a murderer, a pawn store owner, or a "Jewish pimp," Plaintiff does not engage in insurance fraud, and Plaintiff does not have syphilis or any other venereal disease. Plaintiff has never threatened to murder any elderly women nor rape any women.
Civ.R.8(B) Denial / Partial Admission. Bryan Reo in Item #9 merely re-states the exact same claims as in Item #8, whereupon Pastor Lindstedt, in the interests of brevity, proffers the exact same defenses and counter-claims. Item #9 is Bryan Reo simply denying the same lies that Bryan Reo made up in Item #8. These same items were made by Bryan Reo in Reo’s federal complaint which were not believed or deemed relevant in that dismissed case, and they date from 2010 and 2011 which is beyond the Ohio Statute of Limitations even though they are mainly Bryan Reo’s lies that Reo lies that Pastor Lindstedt made up. 
Civ.R.13 – Counter-claim. As in Counter-Claim #8 & #9 above.
10. Bryan Reo -- At the time Defendant published the false and defamatory statements about Plaintiff as detailed in Paragraph 8 of this Complaint, Defendant had actual or constructive knowledge to believe that Plaintiff does not support child molestation and Plaintiff is not a homosexual, a drug dealer, a con-man, a murderer, a pawn store owner, or a "Jewish pimp," Plaintiff does not engage in insurance fraud, and Plaintiff does not have syphilis or any other venereal disease.
Civ.R.8(B) Denial / Partial Admission. Bryan Reo in Item #10 merely re-states the exact same claims as in Item #8 and 9 , whereupon Pastor Lindstedt, in the interests of brevity, proffers the exact same defenses and counter-claims. Pastor Lindstedt had ample reason to actually believe that what was said back in 2010 was true then and is still substantially true today. 
11. Bryan Reo -- In March of 2011, Defendant acquired via a LexisNexis report Plaintiffs voter 
registration, political party affiliation, vehicle registration, vehicle license plate number, and social security number and publicly disseminated this confidential information via the medium of 
the World Wide Web to a significant number of third-parties.
	Civ. R. 8(B) Denial. In February 2011 Bryan Reo, out of sheer maliciousness, insinuated himself to get John Britton’s eight-year civil litigation from an August 2003 helicopter crash from a defective engine part made by a Rolls-Royce subsidiary dismissed. Reo notified Ray Mariani of Nixon-Peabody and Reo made a sealed complaint about a number of things, all of them irrelevant, particularly that John Britton was a nephew of Aryan Nations member Neumann Britton. Reo also went onto a homosexual pornographic web forum called Upstandingf*ckingcitizens.com to impersonate John Britton in order to add perjurous grist to his fraudulent affidavit. John Britton and Pastor Lindstedt and some NIM-Busters who were all mad that Bryan Reo had taken down NIM-Busters as a result of Reo’s endless fraudulent DMCA complaints immediately counter-trolled the Reo account pretending to be John Britton. In order to cover his tracks, Bryan Reo then filed a bogus and fraudulent DMCA Take-Down Notice against UpstandingF*ckingCitizens.com and claimed that their nasty homosexual porn was child porn and and scared the Upstanding Citizens into shutting down permanently. Which is why Pastor Lindstedt can’t keep track of which Bryan Reo homosexual porn was made by Bryan Reo as a source of criminal fraud and which Bryan Reo homosexual porn was created by other homosexual pornsters mad at Bryan Reo for shutting down their homosexual porn sites that Bryan Reo infests and impersonates for purposes of fraud. 
	After senior US District Court Judge for Idaho Edward M. Lodge ruled that the Britton federal civil case would proceed to trial on the merits and not on whom John Britton’s uncle was, John Britton’s lawyer Stuart McCarty gave Britton a .pdf Lexus-Nexus printout on Bryan Reo to use as Britton saw fit. Britton sent Pastor Lindstedt and four or five others a copy, including this tedious buffoon named Russell Walker. Russ Walker sent his copy to around 40 other idiots, some claiming to be CI on his retard e-mail list, especially Bryan Reo, who threatened to sue Russ Walker. Russ Walker went to law school and doesn’t have any money, and told Bryan Reo to sue. Reo then decided to wait three years from March 2011 until April 2014 and then knowingly fraudulently claim that Pastor Lindstedt was the one who released the public record Lexus-Nexus printout on Reo available at any public library with a Lexus-Nexus subscription. 
Civ. R. 8(C) – Affirmative Defenses. Bryan Reo fails to state a claim upon which can be granted. It is not unlawful for Pastor Lindstedt to post on his Church’s web pages a public Lexus-Nexus report, even Pastor Lindstedt had done so – which Pastor Lindstedt didn’t do. Rather one Russ Walker posted it on his own public e-mail list, including to Bryan Reo. The Lexus-Nexus Report was heavily redacted and didn’t show anything really confidential. In fact, Bryan Reo himself  keeps on posting this Lexis-Nexis report that Russ Walker posted in his federal and state litigation.  Also, this report dates from March 2011, well beyond the Ohio Statute of Limitations.
Civ.R.13 Counter-Claims. Bryan Reo knowingly commits perjury in making the exact same thing perjurous claim when Bryan Reo knows better, cf. Affidavit of Bryan Reo perjury from Nov. 13, 2015. 
  	Civ.R.13 – Counter-Claim. Bryan Reo knowingly commits perjury by claiming that Pastor Lindstedt, as opposed to Russell Walker, had much, if anything to do with the publication of this public-document Lexus-Nexus Report with practically ALL of the sensitive private information deleted or redacted. Bryan Reo knowingly made a falsified police report to the Lake County Sheriff’s Department and then refused to sign it because Reo knew that it would get in trouble. This perjury by Bryan Reo has lead to all manner of trouble for Pastor Lindstedt and Lindstedt’s Church in the form of allowing Bryan Reo to portray fraudulently itself as a victim of Pastor Lindstedt’s racist Aryan Nations Church, which is actually dedicated – far more than the imposters and ZOG agents provocateur – to actual Orthodox Comparetian Dual-Seedline Christian Identity in which Anti-Racist Activist mongrels like Bryan Reo and Bryan Reo’s fellow jew and mongrel and pervert co-conspirators cannot find any purchase into the small one and two and three family congregations which make up the real blood, body and bone of YHWH’s Servant Nation of Aryan Christian Israel. None of the literal Spawn of Satan can get inside because of Pastor Lindstedt’s revelations concerning Bryan Reo and Reo’s co-conspirators. All Bryan Reo and William Finck and Eli James are is Internet and it drives them into a Genesis 3:15 antipathetical rage and despair that they cannot enter the Congregation. 
12. Bryan Reo --   Between March and July of 2015 Defendant published defamatory remarks, in print format, online, declaring that Plaintiff had committed perjury, wire fraud, and mail fraud, and was engaged in fraudulent conduct in a then ongoing court proceeding.
Civ.R.8(B). Denial & Partial Admission. Actually, this is the first new thing which isn’t over a year old and thus not dismissible under the Ohio statutory time-limit bar for libel and slander actions. However, Bryan Reo is admitting that after the Feb. 13 2015 Scheduling Conference in which Judge Whitworth said that there would be no gag order on discussion about the federal case, Reo refused to  tender the initial disclosures which would have proven that Reo had made numerous fraudulent DMCA complaints under penalty of perjury along with Reo’s co-conspirators acting to censor Lindstedt and Lindstedt’s Church’s web pages, which carries with it some mighty stiff ten-year prison sentences for conspiracy. So Bryan Reo made bogus motion after motion concerning what he thought the discovery process should be. Pastor Lindstedt answered the motions quite satisfied to let Bryan Reo lie to a U.S. Magistrate Judge who used to be the U.S. Attorney for the Western District of Missouri and hoping that Judge Whitworth would grow tired of being lied to by Bryan Reo. This lying and fraud by Bryan Reo occurred between March and July 7, 2015 after a F.R Civ.P Scheduling Conference regarding trial dates and discovery. On July 7, 2015, after Motion after Motion to strike, for Summary Judgment, etc. asked for by Bryan Reo and answered by Pastor Lindstedt, Judge Whitworth ordered Reo to show cause why the federal case shouldn’t be dismissed. Knowing that Bryan Reo had lost the case because of an inability to show cause for Reo’s fraudulent DMCA complaint and claims of $10.5 million in punitive or even any damages, Lindstedt brought up some of the case documentation up from an “Admin-eyes only” sub-forum to where the general public could see this public documentation already available on PACER.gov at ten cents per pdf page. Until September, when the federal case was dismissed, Pastor Lindstedt didn’t put up anything concerning the Reo case up on his Church’s forum so that Reo would fly blind. In the federal system, professional pro se plaintiffs engaged in the unauthorized practice of law without a clue are not allowed to make fraudulent motion after motion in futile hope of winning a default judgment. Thus Reo is lying to this state court even more than Reo lied to the federal court. 
Court proceedings are a matter of public record. Reo is whining that Pastor Lindstedt is publishing on his Church’s web pages and elsewhere these public records. If Reo is so worried that publication of public records will make Reo look to be a fool and a criminal the smartest thing to do would be to stop filing fraudulent litigation – certainly against someone who will publish it openly on his Church’s web pages for everyone to see.
http://christian-identity.net/forum/showthread.php?t=892  Bryan Reo’s DMCA claims that Bryan Reo was whining about to Magistrate Roll at the Dec. 17th Case Management.
Civ.R.8(C) Affirmative Defenses. Bryan Reo has no reasonable expectation that public records and documents from the now thirty-five and counting, three new ones filed on Dec. 30th 2015 alone and one filed on Dec. 23, 2015 for a total of four that week Lake County Ohio Court won’t be revealed. How does anyone or anything other than a professional plaintiff pro se practicing law without a license or a clue rack up so many lawsuits if it isn’t for mere vexation and hope of unjust enrichment through abuse of legal process? At the Dec. 17 Case Management Conference alone, Bryan Reo admitted to the unauthorized practice of law to benefit Reo co-conspirators Anthony D. Reo, William Finck and Melissa Epperson. Rather than merely chiding Bryan Reo after complimenting Reo for Reo’s professional vexatious abilities to gin up massive amounts of legal-sounding perjurous and fraudulent drivel and chiding Defendant Pastor Lindstedt from over 850 miles away for not being able to write fraudulent abuse of process in his and his Church’s defense, and Lindstedt’s Church’s being unable or unwilling to pay for a Satans-spawn attorney, this Court should have summarily dismissed Reo’s fraudulent case against Pastor Lindstedt and Pastor Lindstedt’s Church, held Bryan Reo in criminal contempt and jailed, and made out a civil and criminal complaint to the Lake County prosecuting attorney, the Ohio Attorney General, and the state and local bar association for Bryan Reo’s admitted unauthorized practice of law. 
Civ.R. 13 – Counter-claim. Pastor Martin Lindstedt and Lindstedt’s Church hereby makes a counter-claim of three times $25,000 for a total of $75,000 against professional Plaintiff pro se Bryan Reo under Ohio Revised Code Section 4705.7 – Unauthorized practice of law, and for $25,000 apiece from Anthony D. Reo, William Finck and Melissa Epperson for asking for and receiving the “benefits” of this criminal and tortuous unlawful and abusive misconduct by Bryan Reo. Also, an additional $25,000 each from the thirty or forty Reo co-conspirators who have asked for and received Bryan Reo professional pro se unauthorized practice of law “services.” This sort of abuse of legal process needs to be put an end to  by this Court, rather than encouraged & enabled. Thirty-five vexatious and frivolous Bryan Reo civil lawsuits are enough!  
13. Bryan Reo -- Plaintiff has never committed perjury, wire fraud, or mail fraud and was never engaged in fraudulent conduct at any time during the relevant court proceeding.
	Civ.R.8(B) – Denial. Bryan Reo has engaged in nothing but fraudulent and perjurous conduct against Pastor Lindstedt and Lindstedt’s Church for malicious and evil motives.
	For example, in Defendant’s Original Answer and Counter-Notice of October 26, 2015 Defendant’s Exhibit 3 (Document 9-1 filed Nov 20, 2014 in the previously dismissed federal lawsuit) of SwordBrethren / Bryan Reo to Reo’s co-counter-defendants and co-conspirators entitled “Pray for My Success” dated Monday, August 25, 2014 7:40 pm:

. . . I am presently seeking to make a covenant with God on a very specific matter. I have some ongoing issues against various foes. . . If Yahweh God will deliver their money, their estates, their property, their assets into my hands, I will properly tithe 15% [rather than the usual 10%] to my kin and those who work for our people. . . 
. . . I have a particular enemy in Missouri who has a stake in a cattle ranch in South Dakota, I am asking that God deliver all of his property, all of his wealth, all of his land, all of his assets, all of his money to me, and leave him desolate and penniless . . . 
. . . Basically when it is boiled down, I am asking Yahweh for approximately $240,000 in the next four months [from various foes] along with the entire estate, wealth, property, money of the wicked one in Missouri [ the ranch in South Dakota might be worth $500,000 just by itself. . . 

 At the time this greedy mongrel was also suing Arbitron and the National Rifle Association for the $240,000 but Pastor Lindstedt and Lindstedt’s Church were the ones to be rendered destitute by Bryan Reo’s perjury, wire fraud, criminal conspiracy, and fraudulent conduct. Pastor Lindstedt has another several dozen of like forum posts to demonstrate Bryan Reo’s motivations to a federal or state jury, grand or petit, along with the sundry sheriff’s, U.S. Attorneys, etc. 
	Civ.R.13 – Counter-claim. Pastor Lindstedt and Lindstedt’s Church hereby makes a counter-claim against Bryan Reo and Bryan Reo’s co-conspirators and their families and their satanic fraudulent churches and synagogues sufficient to – as Bryan Reo’s own scheming words puts it – “ . . . deliver all of their property, all of their wealth, all of their land, all of their assets, all of their money to Pastor Lindstedt and Lindstedt’s Church, and leave them all desolate and penniless . . .” Turnabout is indeed fair play.
15. Bryan Reo -- Defendant has caused injury to Plaintiff in excess of twenty-five thousand dollars ($25,000.00).
	Civ. R. 8(B) – Denial. Bryan Reo hasn’t even remotely plausibly claimed any rational legal basis for a rightful injury for twenty-five cents, much less twenty-five thousand dollars. 
Civ.R.8(C) -- Affirmative Defenses. Due to fraud, perjury, Statute of Limitations, Unauthorized Practice of Law, abuse of legal process, etc. Bryan Reo cannot sustain any claim for damages.
Civ.R.13 – Counter-claim. Pastor Lindstedt and Lindstedt’s Church hereby makes a counter-claim against Bryan Reo and Bryan Reo’s co-conspirators and their families and their satanic fraudulent churches and synagogues sufficient to – as Bryan Reo’s own scheming words puts it – “ . . . deliver all of their property, all of their wealth, all of their land, all of their assets, all of their money to Pastor Lindstedt and Lindstedt’s Church, and leave them all desolate and penniless . . .” Turnabout is indeed fair play. Additionally, this Court might wish to consider a civil protective castration and radical gelding of Bryan Reo so that elderly Greek women confined to wheelchairs, John Britton’s wives and daughters and sons and “Victor Switzer” cannot fear – or anticipate – the threat of anal sodomistic assault and rape from Bryan Reo.
16. Bryan Reo -- Plaintiff previously sued Defendant in federal court over the controversy at issue in the instant civil action, but said civil action was dismissed without prejudice within the past year for lack of subject matter jurisdiction due to diversity jurisdiction not being properly shown by Plaintiff. Plaintiff hereby invokes R.C. § 2305.19(A), which pertinently provides that "In any action that is commenced * * *, if the plaintiff fails otherwise than upon the merits, * * * the plaintiff's representative may commence a new action within one year after the date of * * * the plaintiff's failure otherwise than upon the merits[.]" Menno v. Salem Hunting Club, 7th Dist. 
Columbiana No. 11C02, 2012-0hio-4553, ~ 13 ("When a complaint is refiled under the saving statute, the case relates back to the date of the original complaint for purposes of satisfying any 
statute of limitations problems.")
Civ.R.8(B) – Denial. Plaintiff Bryan Reo sued Pastor Lindstedt under color of the Digital Millennium Copyright Act (DMCA) for $10,750,000. After a year of Reo’s lying to the federal court judge the federal judge flushed the toilet and dismissed the case on Sept. 10, 2015, whereupon Bryan Reo scurried to the Lake County Court of Common Pleas and is now asking for only $25,000 in damages for . . . something upon which not any valid claim can be made. Bryan Reo didn’t lose in federal court on the merits because there never was any merit to the case as U.S. Magistrate Judge Whitworth stated in the ORDER to Dismiss after giving Bryan Reo an additional month to come up with some rational for keeping the case alive. Then like the demons asking Christ when Christ was purging Legion to let them go into some swine, who promptly ran into the Sea of Galilee and drowned, so too does Bryan Reo run to this local state court to ask for $25,000 in mythical damages and for this Court to censor and place a gag order upon Pastor Lindstedt posting public information on Lindstedt’s Church’s web pages. The federal court reminded Reo that he would have to obey the Ohio rules regarding statutes of limitation, which in Ohio is one year for slander and libel. This swill that Reo claims is actionable dates in some cases from March 2010 and has already been rejected by the federal court. The only new thing under a year is Bryan Reo bellyaching about how Pastor Lindstedt posted public federal court records from March to July 2015 when Reo’s fraudulent and bogus federal case imploded. Ohio Revised Code § 2305.03 and 2305.11 absolutely bar Bryan Reo’s litigation after losing its ancient claims in federal court. That these claims have been already ruled invalid means that res judicata holds that they cannot be raised anew in a state court of limited jurisdiction.
 Civ.R.8(C) -- Affirmative Defenses. Due to fraud, perjury, Statute of Limitations, Unauthorized Practice of Law, abuse of legal process, etc. Bryan Reo cannot sustain any claim for damages.
Civ.R.13 – Counter-claim. As in Counter-Claim #15 above.

V. TRIAL BY JURY DEMANDED
17. Bryan Reo -- Plaintiff respectfully demands a trial by jury on all of the issues set forth herein that are triable by right. Civ.R. 38.
	There is agreement on the part of the Defense that a jury trial August 2, 2016 @ 8:30 am is in order.
	However, Defendant observes that Bryan Reo has never really wanted a jury trial given all of Reo’s fraudulent and vexatious Motions to strike and for Summary Judgment and refusal to participate in Discovery by accepting Defendant’s own Discovery papers which are nothing more than Bryan Reo’s own discovery devices turned about to ask of Bryan Reo what Reo asked of Pastor Lindstedt. Right now Pastor Lindstedt is working on filing his “admissions” while Bryan Reo plays games in accepting Pastor Lindstedt’s discovery processes. 
 
VI. CAUSES OF ACTION
COUNT I – COMMON LAW DEFAMATION
18. Bryan Reo -- The foregoing paragraphs of this Complaint are incorporated by reference as if fully set forth herein.
19. Bryan Reo --  Defendant published false and defamatory statements about Plaintiff to third-parties via the medium of the World Wide Web.
20. Bryan Reo -- Defendant's false and defamatory statements about Plaintiff were made by Defendant without privilege.
21. Bryan Reo -- Defendant acted with at least negligence in making false and defamatory statements about Plaintiff.
22. Bryan Reo -- Defendant failed to act reasonably in attempting to discover the truth or falsity or defamatory character of Defendant's publication about Plaintiff.
23. Bryan Reo -- Defendant's false and defamatory statements about Plaintiff are defamatory per se insofar as said statements reflect upon the character of Plaintiff by bringing him into ridicule, hatred, or contempt, and affects Plaintiff injuriously in his future trade or profession.
24. Bryan Reo -- Defendant committed against Plaintiff the common law tort of libel per se.
Civ. R. 8(B) Denial. Insofar as Bryan Reo states a cause of action of all of above items, as opposed to merely stating what Bryan Reo wishes the law was against Pastor Lindstedt and Lindstedt’s Church, Pastor Lindstedt denies all the above allegations.
Civ.R.8(C) -- Affirmative Defenses. Due to fraud, perjury, Statute of Limitations, Unauthorized Practice of Law, abuse of legal process, res judicata, lack of subject matter and personal jurisdiction, etc. Bryan Reo cannot sustain any of the claims made in Reo’s boilerplate Items #18-24 in Count I -- Defamation. Bryan Reo called Pastor Lindstedt a child molester and pedophile and Pastor Lindstedt has called Bryan Reo a mongrel homosexual. Internet name-calling cannot sustain a course of action. 
Civ.R. 13—Counter-claims. Pastor Lindstedt and Lindstedt’s Church ask that Bryan Reo and Bryan Reo’s co-conspirators suffer the same penalties that they would assess or claim against the Defendants in this frivolous and vexatious litigation. 

COUNT II – COMMON LAW INVASION OF PRIVACY – FALSE LIGHT
25.  Bryan Reo -- The foregoing paragraphs of this Complaint are incorporated by reference as if fully set forth herein.
	26. Bryan Reo -- Defendant made false and derogatory statements about Plaintiff that Defendant publicized via the medium of the World Wide Web.
	27. Bryan Reo -- The false and derogatory statements made by Defendant about Plaintiff placed Plaintiff before the public in a false light.
28. Bryan Reo -- The false and derogatory statements made by Defendant about Plaintiff are highly offensive to a reasonable person.
	29. Bryan Reo -- Defendant is at fault and knew or acted with recklessness as to the truth of the statements made by Defendant that concern Plaintiff.
30. Bryan Reo -- As a direct and proximate result of Defendant's statements about Plaintiff, Plaintiff has been and will continue to suffer damages in the form of mental anguish and reputational injury.
	31. Bryan Reo -- Defendant committed against Plaintiff the tort of invasion of privacy - false light.
Civ. R. 8(B) Denial. Insofar as Bryan Reo states a cause of action of all of above items, as opposed to merely stating what Bryan Reo wishes the law was selectively applied against Pastor Lindstedt and Lindstedt’s Church, Pastor Lindstedt denies all the above allegations. Additionally, Bryan Reo has never respected the privacy of Defendants or of others. 
Civ.R.8(C) -- Affirmative Defenses. Due to fraud, perjury, Statute of Limitations, Unauthorized Practice of Law, abuse of legal process, res judicata, lack of subject matter and personal jurisdiction, etc. Bryan Reo cannot sustain any of the claims made in Reo’s boilerplate Items #25-31 of “False Light” which doesn’t exist in Ohio Statute or Constitution.
Civ.R. 13—Counter-claims. Pastor Lindstedt and Lindstedt’s Church ask that Bryan Reo and Bryan Reo’s co-conspirators suffer the same penalties that they would assess against the Defendants in this frivolous and vexatious litigation. Bryan Reo and Reo’s co-conspirators keep on calling Pastor Lindstedt a “convicted child molester” and pedophile, negating this claim.

COUNT III -- COMMON LAW INVASION OF PRIVACY
PUBLIC DISCLOSURE OF PRIVATE FACTS
32. Bryan Reo -- The foregoing paragraphs of this Complaint are incorporated by reference as if fully set forth herein.
	33. Bryan Reo -- Defendant publicly disclosed private facts about Plaintiff to third-parties via the medium of the World Wide Web.
	34. Bryan Reo --  Defendant's disclosure about private facts about Plaintiff would be highly offensive and objectionable to a reasonable person of ordinary sensibilities.
	35. Bryan Reo -- Defendant's disclosure of private facts about Plaintiff was done intentionally.
	36. Bryan Reo -- Defendant's disclosure of private facts about Plaintiff are not of legitimate concern to the public.
	37. Bryan Reo -- Defendant committed against Plaintiff the tort of invasion of privacy - public disclosure of private facts.
Civ. R. 8(B) Denial. Insofar as Bryan Reo states a cause of action of all of above items, as opposed to merely stating what Bryan Reo wishes the law was selectively enforced against Pastor Lindstedt and Lindstedt’s Church, Pastor Lindstedt denies all the above allegations. Additionally, Bryan Reo would publish the street address and telephone number of Pastor Lindstedt and others even before Pastor Lindstedt found out Reo’s real name and past history. Bryan Reo whining about violating the privacy of others is ridiculous and hypocritical. 
Civ.R.8(C) -- Affirmative Defenses. Due to fraud, perjury, Statute of Limitations, Unauthorized Practice of Law, abuse of legal process, res judicata, lack of subject matter and personal jurisdiction, etc. Bryan Reo cannot sustain any of the claims made in Reo’s boilerplate Items #32-37 in “Count III.” There is no such tort as “public disclosure” of something which doesn’t exist such as “private facts” in Ohio Statute or the Ohio Constitution. Even if there was, then Bryan Reo and Reo’s co-conspirators would be guilty of libel per se in calling Pastor Lindstedt a “convicted child molester” and thus invading Pastor Lindstedt’s privacy. 
Civ.R. 13—Counter-claims. Pastor Lindstedt and Lindstedt’s Church ask that Bryan Reo and Bryan Reo’s co-conspirators suffer the same penalties that they would assess against the Defendants in this frivolous and vexatious litigation. 

COUNT IV - COMMON LAW INVASION OF PRIVACY – INVASION OF SECLUSION
38. Bryan Reo -- The foregoing paragraphs of this Complaint are incorporated by reference as if fully set forth herein.
39. Bryan Reo -- Defendant intentionally intruded upon Plaintiff's seclusion, solitude, and/or private concerns or affairs by making public disclosures of information about Plaintiff that are of no legitimate concern to the public.
40. Bryan Reo -- Plaintiff has a reasonable expectation of privacy in his solitude, seclusion, and/or private concerns or affairs.
41. Bryan Reo -- The unreasonable intrusions and invasions by Defendant occurred in a way that would be highly offensive to a reasonable person.
42. Bryan Reo -- As a direct and proximate result of Defendant's intrusions upon Plaintiff's seclusion or solitude, Plaintiff has suffered damages.
43. Bryan Reo -- Defendant committed against Plaintiff the tort of invasion of privacy - invasion of seclusion.
Civ. R. 8(B) Denial. Insofar as Bryan Reo states a cause of action of all of above items, as opposed to merely stating what Bryan Reo wishes the law was selectively enforced against Pastor Lindstedt and Lindstedt’s Church, Pastor Lindstedt denies all the above allegations. 
Civ.R.8(C) -- Affirmative Defenses. Due to fraud, perjury, Statute of Limitations, Unauthorized Practice of Law, abuse of legal process, res judicata, lack of subject matter and personal jurisdiction, etc. Bryan Reo cannot sustain any of the claims made in Reo’s boilerplate Items #38-43 in “Count IV.” There is no such tort as “invasion of seclusion” of something which doesn’t exist  in Ohio Statute or the Ohio Constitution. Even if there was, then Bryan Reo and Reo’s co-conspirators have been the ones invading Pastor Lindstedt’s and Lindstedt’s privacy and seclusion rights by their fraudulent and vexatious pursuit of Defendants and not the other way around. 
Civ.R. 13—Counter-claims. Pastor Lindstedt and Lindstedt’s Church ask that Bryan Reo and Bryan Reo’s co-conspirators suffer the same penalties that they would assess against the Defendants in this frivolous and vexatious litigation. Additionally, Bryan Reo would publish the street address and telephone number of Pastor Lindstedt and others even before Pastor Lindstedt found out Reo’s real name and past history. Bryan Reo whining about violating the privacy of others is ridiculous and hypocritical.

COUNT V – PUNATIVE DAMAGES
44. Bryan Reo -- The foregoing paragraphs of this Complaint are incorporated by reference as if fully set forth herein.
45. Bryan Reo -- Defendant's conduct was conscious, deliberate, intentional, and/or reckless in nature.
46. Bryan Reo -- Defendant's conduct was undertaken with hatred, ill will, and/or vexation.
47. Bryan Reo -- Defendant's conduct was done with a conscious disregard for the rights of Plaintiff and has a great probability of causing Plaintiff substantial harm for many years.
48. Bryan Reo -- Plaintiff is entitled to punitive damages from Defendant.
Civ. R. 8(B) Denial. Insofar as Bryan Reo states a cause of action of all of above items, as opposed to merely stating what Bryan Reo wishes the law was selectively enforced against Pastor Lindstedt and Lindstedt’s Church, Pastor Lindstedt denies all the above allegations. Bryan Reo cannot prove that there were any damages against Bryan Reo whatsoever, much less claim punitive damages – especially given that Reo has been stalking Pastor Lindstedt. 
Civ.R.8(C) -- Affirmative Defenses. Due to fraud, perjury, Statute of Limitations, Unauthorized Practice of Law, abuse of legal process, res judicata, lack of subject matter and personal jurisdiction, etc. Bryan Reo cannot sustain any of the claims made in Reo’s boilerplate Items #44-48 in “Count V –Punitive Damages.” Plaintiff and Plaintiff’s co-conspirator co-counter-defendants’ have not only violated Ohio law, but 17 U.S.C. § 512(f) and 42 U.S.C. § 1983, 1985 as well. There are also criminal violations of federal law by Plaintiff and Plaintiff’s co-conspirator co-counter-defendants as well. Therefore any claims before this local court absent subject matter and personal jurisdiction (And Bryan Reo has argued on behalf of William Finck and Melissa Epperson that this Court lacks personal jurisdiction against parties residing out of the Ohio state limits.) should be summarily dismissed.
Civ.R. 13—Counter-claims. Pastor Lindstedt and Lindstedt’s Church ask that Bryan Reo and Bryan Reo’s co-conspirators suffer the same penalties – especially punitive ones -- that they would assess against the Defendants in this frivolous and vexatious litigation. 

COUNT VI – PERMANENT INJUNCTION
49. Bryan Reo -- The foregoing paragraphs of this Complaint are incorporated by reference as if fully set forth herein.
50. Bryan Reo -- Some or all of the improper and unlawful conduct of Defendant is continuing and will continue in the future absent injunctive relief from the Court, and Plaintiff will continued to be damaged by the same.
	51. Bryan Reo -- In the absence of the entry of a permanent injunction by the Court, Plaintiff will suffer serious and irreparable harm and injury, including but not limited to damage to Plaintiffs reputation.
53. Bryan Reo --  Public policy favors the entry of a permanent injunction because such relief will prevent unlawful conduct and will preserve and protect Plaintiffs reputation from further injury.
	54. Bryan Reo --  Plaintiff is entitled to a permanent injunction in which Defendant is compelled to remove from the World Wide Web and not republish thereto any and all derogatory materials Defendant or Defendant's agents published there about Plaintiff.  
Civ. R. 8(B) Denial. Insofar as Bryan Reo states a cause of action of all of above items, as opposed to merely stating what Bryan Reo wishes the law was selectively enforced against Pastor Lindstedt and Lindstedt’s Church, Pastor Lindstedt denies all the above allegations. Bryan Reo cannot be given any injunction to take down Pastor Lindstedt’s Church’s web pages in any case, and proves malicious intent in so asking.
Additionally, this explains Bryan Reo’s entire motives. Bryan Reo wants Pastor Lindstedt and Pastor Lindstedt’s Church’s critical public inquiry concerning Bryan Reo and Bryan Reo’s friends silenced by this Lake County Court. This is a solicitation for the violation of the First Amendment of Freedom of Speech and Religion and a violation of the Ohio Constitution as well. 
Civ.R.8(C) -- Affirmative Defenses. Due to fraud, perjury, Statute of Limitations, Unauthorized Practice of Law, abuse of legal process, res judicata, lack of subject matter and personal jurisdiction, etc. Bryan Reo cannot sustain any of the claims made in Reo’s boilerplate Items #49-53 in “Count VI –Request for Permanent Injunction.” 
There can be no such preliminary or permanent “prior restraint” restraining order issued by this Ohio Court. Near v. Minnesota, 427 U.S. 539, 559. In 1931 it involved a racist, anti-jew anti-negro publisher named Near who was writing articles against jew and negro and mongrel criminals who used a Minnesota law to shut down Near’s newspaper. After losing several times before the Minnesota Supreme Court, the U.S. Supreme Court ruled that such “gag orders” were unconstitutional per se. This admission by Bryan Reo that Reo wants the complete violation of the U.S. and Ohio Constitutions regarding Freedom of Speech and Religion negates absolutely Bryan Reo’s entire case as it proves that a slander, libel, and defamation pretext is being used to justify the destruction of the religious and intellectual property of Pastor Lindstedt’s Church and the silencing under color of law of Pastor Lindstedt.
Civ.R. 13—Counter-claims. Pastor Lindstedt and Lindstedt’s Church ask that Bryan Reo and Bryan Reo’s co-conspirators suffer the same penalties – especially punitive ones -- that they would assess against the Defendants in this frivolous and vexatious litigation. 

VII. PRAYER FOR RELIEF
FINALLY – BRYAN REO -- WHEREFORE, Plaintiff prays that this Court will enter judgment against Defendant in Plaintiff’s favor in an amount of money that exceeds twenty-five thousand dollars ($25,000.00) for general and special damages, award Plaintiff punitive damages against Defendant in an amount the Court deems just and proper, award Plaintiff all costs associated with maintaining the instant civil action, award Plaintiff all pretrial and post-trial interest on any and all monetary relief awarded to Plaintiff, award Plaintiff injunctive relief by ordering Defendant to remove from the World Wide Web and not republish thereto derogatory or' invasive materials about Plaintiff that Defendant or Defendant's agents published about Plaintiff, and will award Plaintiff all other relief to which Plaintiff is entitled as a matter of law or equity.

	WHEREFORE, in this thorough and correct and true and genuine Amended Answer and  Counter-Complaint to the best of their Humble Abilities Pastor Martin Lindstedt, and Pastor Lindstedt’s Church Corporation  in good standing in the State of Missouri, The Church of Jesus Christ Christian / Aryan Nations of Missouri do to the best of their limited abilities submit this Court-ORDERED Amended Answer and Counter-Complaint. 
	Bryan Reo has demonstrated that he is a vexatious and frivolous litigator practicing the unauthorized practice of law. There are no merits whatsoever to this case and Bryan Reo should be punished and prosecuted and this case should be summarily dismissed with Defendants reimbursed for their costs and trouble.
	Or, in the alternative, having this bogus and fraudulent and silly case proceed to jury trial  while having Bryan Reo and thirty or forty of Bryan Reo’s co-counter-conspirator co-counter-defendants each pursuing their own self-interest means is a disaster in the making.	Hopefully this Court decides is necessary and proper but which will likely generate endless appeals if this case is not put down quickly.

Hail Victory !!!

______________________________________
Pastor Martin Luther Dzerzhinsky Lindstedt, ArchBishop
The Church of Jesus Christ Christian / Aryan Nations of Missouri
338 Rabbit Track Road
Granby Missouri 64844
(Tel #) 417-472-6901
(E-mail address): pastorlindstedt@gmail.com
(E-mail address for Reo who has threatened to terminate above e-mail address): johnreltney@gmail.com
Defendant(s) / Counter-Claimant(s)

CC: (Not printed but mentioned in passing as belonging with the Original Answer & Counter-Complaint of Oct. 26, 2015 in this Court-Ordered Amended Answer and Counter-Complaint.) 
Exhibit #1, Civil Complaint, Reo v. Lindstedt, NDOH, Case # 1:14-CV-816
Exhibit #2, Docket Sheet to Oct. 16, 2015 of above federal case transferred to Missouri
Exhibit #3, Bryan Reo’s post “Pray For My Success” from Aug. 25, 2014, Exhibit 9-1 Document 9, Pastor Lindstedt’s Initial Answer to Reo’s federal Civil Complaint showing that Reo’s purpose for litigation against Lindstedt and Lindstedt’s Church is for purposes of vindictive theft.