DISTRICT COURT, ARAPAHOE COUNTY

DISTRICT COURT, ARAPAHOE COUNTY
Arapahoe County Justice Center
7325 S. Potomac Street
Centennial, Colorado 80112
Plaintiff :
TAMEIRA LEE HOLLANDER, M.D.

v.

Defendants:
JOHN W. BAILEY, BARBARA A.B. BAILEY and
CHRISTINE BAKER

Christine Baker

Case No.: 08CV2229
Division: 407
Defendant Pro Se
Tel: 206-202-4653
Fax: 571-222-1000
Email: [email protected]
DEFENDANT CHRISTINE BAKER’S OBJECTIONS TO PLAINTIFF
DOCTOR TAMEIRA HOLLANDER’S PROPOSED ORDER AND
MOTION FOR PERMISSION TO CONDUCT DISCOVERY

I am the Defendant Christine Baker and I hereby submit my Objections to the
Proposed Order prepared by Plaintiff Tameira Hollander’s attorney Irving Johnson and
my Motion for Permission to Conduct Discovery.

MY OBJECTIONS TO THE PROPOSED ORDER

The proposed order is attached hereto as Exhibit 1 and I object to the proposed
order as stated below.

1) Proposed order paragraph 1

1) The Court finds that Dr. Hollander and Ms. Baker are credible and that
neither party, during the pendency of this action to date, has committed
perjury.

There is absolutely NO evidence to suggest that doctor Hollander’s FALSE
allegations and statements in her VERIFIED 10/17/08 Complaint and Affidavit are in fact
true.

1

On 9/4/09 I submitted my Motion for Summary Judgment including my factual
summary. My perjury complaint to the Arapahoe County district attorney was attached as
Exhibit A. I specifically identified the FALSE statements made by doctor Hollander
under oath.

I do not understand WHY the Court feels that it’s ok to make false allegations
under oath.

WHY did the court rule that doctor Hollander’s FALSE accusations and
statements are NOT perjury?

It appears that the Court RELIED on these false accusations and GRANTED the
temporary restraining order (TRO) on 10/21/08 without ANY exhibits to support doctor
Hollander’s obviously FALSE allegations and statements. The Court ordered my entire
website off-line INSTEAD of merely ordering my LINK to the Baileys’ website
removed.

I almost died due to the subsequent financial problems and the harassment and
abuse by “Mathew Hilton”.

The allegations against me in doctor Hollander’s 10/17/08 Verified Complaint and
Affidavit were FALSE. I have yet to see any document in support of doctor Hollander’s
allegations and statements.

Why is the Court encouraging harassment suits against consumer activists?

Paragraph 2 of the proposed order:

2. Ms. Baker has admitted she has no evidence to connect "Matthew
Hilton" to Dr. Hollander, and Dr. Hollander has testified she does not know
"Matthew Hilton" and he is not an agent of hers, and the Court therefore
finds that "Matthew Hilton" is not Dr. Hollander's agent for any purposes
which might be pertinent to this matter.

Apparently doctor Hollander’s attorney Irving Johnson or someone in his firm
provided the pictures of my home, car, license plate, etc. taken by the process server to
“Mathew Hilton”.

“Hilton” subsequently abused, harassed and threatened me to get me to remove
ALL references to doctor Hollander from my publications – as demanded by her and her
attorneys and to give up like the Baileys.

A few notable quotes from “Mathew Hilton” emails to me:

2

1/17/09: “…You are a criminal and I look forward to posting your mug shot once
you are arrested for contempt of court. …”

1/18/09: “Do you really live in that shithole?”

The pictures taken at my home by the trespassing process server were attached.

1/18/09: “Be careful that you don't have a judgment attached to your property.
Contempt of court sanctions are the same as a judgment.

We are going to get you this time.”

1/19/09: “Watching you have a mental breakdown online is somewhat strange.

On the one hand I am thinking, "It couldn't happen to a more deserving
person."

On the other hand, it is sort of pathetic.

Here is what you really need Christine. A real job.

When was the last time that you actually had a real job?”

My “real” job is working with people with credit or financial problems, which I
was not doing because my entire main website was shut down for TWO MONTHS due to
the Court’s 10/21/08 TRO, based on doctor Hollander’s FALSE allegations.

1/19/09: “… The other issue you face is potential jail time for contempt of court due
to the violations of your restraining order.”

On 1/19/09 I requested that doctor Hollander’s attorneys control their minion
“Mathew Hilton” and I requested that they identify the person(s) who they provided with
the pictures of my home.

The 1/19/09 terse response by attorney Lauren Dorweiler:

Ms. Baker,

I am in receipt of your email. We have neither hired nor directed anyone to
harass you.

On 1/29/09 attorney Irving Johnson filed his Contempt Motion:

13. Ms. Baker is deliberately harassing Plaintiff and her counsel. On
information and belief, Ms. Baker has a history of harassing people over the

3

internet. Other victims of Ms. Baker's deliberate harassment have been
in contact with Plaintiff.

24. Plaintiff respectfully requests that this Court enter and Order a Citation
of Contempt against Ms. Baker. Concomitant with the entry of this Order
and Citation, the Court should issue a bench warrant for the arrest of
Ms. Baker, which warrant shall direct the Sheriff to apprehend Ms.
Baker and bring her immediately before the Court for the imposition
of punitive and/or remedial sanctions. Because Ms. Baker is a resident of
Arizona, undersigned counsel has filed a proposed Letter Rogatory
contemporaneously with this Motion for the Court's consideration.
[Emphasis added.]

I cried when I read this Contempt Motion. I was devastated. In hindsight, it was
a good thing that I hadn’t actually bought a gun yet.

I envisioned my dog killed at the pound because I didn’t have the money to pay
for boarding while I was IMPRISONED.

I’m very grateful for judge Weishaupl’s quick denial of the Contempt Motion and
she may well have saved my life.

To my surprise, doctor Hollander denied knowing who “Mathew Hilton” is when I
questioned her and I believe she stated that she never received the pictures taken by the
process server.

I APOLOGIZED to doctor Hollander right then and there.

That’s what “normal” people do when they realize that they made a mistake.
Notably, doctor Hollander has yet to apologize to me.

Doctor Hollander’s ATTORNEYS acted on doctor Hollander’s behalf and I
incorrectly concluded that she had instigated the harassment because I didn’t think that an
ATTORNEY would resort to such horrendous tactics.

Doctor Hollander’s attorneys NEVER denied providing the pictures of my home,
taken by their process server while trespassing on my property, to “Mathew Hilton.”

On 12/17/09, I asked attorney Johnson again to identify all persons who
received the process server’s pictures, attached as Exhibit 3:

On 12/18/09 attorney Johnson replied:

4

“ … Although I can't answer your questions now, I can suggest two things:
first, if the problem ceased last January, move on with your life. Second, do
your best to clean up the internet. …

Apparently, doctor Hollander’s attorney Johnson provided the pictures to
“Mathew Hilton” and he continues to cover for that thug.

In fact, “the problem” did not cease last January. Since summer, I have been
subjected to multiple instances of identity theft. And a user identified as
“DieChristineDie” posted at RateMDs.com comments so threatening or defamatory that
the postings were deleted by the RateMDs.com administration.

Since 1994 I have published my fraud investigations.

Over the years, I have received death and rape threats from some of the subjects of
my investigations. The “CHRISTINE BAKER THE NIGGER WHORE” web page is
posted at http://doctor-tameira-hollander-litigation.info/5-2000-nigger-whore.htm. Law
enforcement agencies FAILED to actually investigate and pursue this criminal.

Darrel Uselton threatened to sue me for defamation unless I deleted my posts
about his illegal stock manipulations. I refused. A reader sent me the link to his arrest
video and thanked me for my work. The video and the TX AG’s press release are posted
at http://pennystock-
fraud.info/news.php/stock/comments/the_texas_ag_arrest_video_of_penny_stock_pump_
and_dumper_darrel_uselton/

More recently, I exposed the fraud by Mark Cella and his company Federal Debt
Relief System after the California AG failed to stop this scam DESPITE numerous
complaints by defrauded consumers. My PUBLICATION of the fraud at my websites
forced him out of business: http://fdrs-debt-elimination-scam.info Unfortunately, I
cannot help the many consumers pleading for help. I can’t even afford attorneys to
represent me, all I could do was PUBLISH the scam. Had they done just a little
research, they would have found my websites and they could have saved thousands of
dollars.

Most of Christmas Day 2009 I spent DELETING my 2004-2006 investigation of
Wellstone Filters because they also obtained a court order. Doctor Hollander’s suit
cleared the way for these harassment suits requiring the deletion of TRUE statements and
I expect to receive MANY more orders requiring me to delete my work.

Instead of “moving on” with my life, I will submit my complaint about doctor
Hollander’s attorneys to the Colorado State Bar Association. If the attorneys’
misconduct in this case is not in violation of the Bar’s Code of Ethics and Rules, the
public needs to know that.

5

I certainly had no idea that an attorney representing a doctor would sink so low
and share private and personal information with low-life thugs and criminals to harass,
abuse and threaten a pro se defendant into giving in to his ridiculous demands.

• As the record shows, this was a HARASSMENT suit.

• Attorney Johnson sought deletion of all REFERENCES to doctor Hollander
through intimidation, harassment and false claims.

I request permission to conduct DISCOVERY to find out what REALLY
happened and to obtain the identities of all persons who received the pictures taken by the
process server of my home.

Paragraph 3 of the proposed order:

3. The Plaintiff Dr. Hollander acted reasonably in not informing Ms. Baker
who she was in their communications because she reasonably believed that
revealing her identity could lead to further internet defamation.

This is truly perplexing.

Of course anyone can contact me anonymously, but it is very unlikely that I will
respond to any future ANONYMOUS communications. Liars, thieves and criminals of
all sorts act anonymously.

Due to the Baileys’ assistance I was able to send my offer to update / correct my
publications to doctor Hollander’s CORRECT email address as she had provided a false
email address.

Is the Court finding that I should have DELETED all references to the Baileys’
website because of some ANONYMOUS notice without ANY documentation?

Paragraph 5 of the proposed order:

5. Based on everything before the Court, Ms. Baker has never done
anything to determine whether or not Dr. Hollander's evaluation, care and
treatment of her patient, Ms. Bailey, was reasonable and appropriate, and
the Court finds there are no bases for Ms. Baker's negative comments about
how Dr. Ho!lander took care of Mrs. Bai!ey, and how she takes care of her
other patients, and therefore the Court finds that Ms. Baker published
several posts, blogs and comments which were negative about Dr.
Hollander without verifying the accuracy of her statements.

What exactly is before the Court to substantiate this finding?

6

Didn’t the Court review my Exhibit 1 for the 9/16/09 hearing?

I emailed AND I published my offer to the then-ANONYMOUS doctor
Hollander:

Providing the URL(s), the EXACT quotes that are libelous and the
documentation will result in corrections and/or updates.

Doctor Hollander’s ONLY response was to serve me with the Summons and
Complaint.

I read the Baileys’ entire web site before I linked to it and highly recommended it
to my readers.

The Baileys documented their claims extremely well.

Even after over a YEAR of litigation and despite my NUMEROUS requests for
documentation I haven’t received a single document to support the notion that the
Baileys’ allegations were false.

To the contrary, John Bailey even advised on 11/1/08 that CHANGES were made
to the medical practice due to his complaints, attached as Exhibit 2, and I quoted his
email in its entirety in my 10/9/09 Reply in Support of my Motion for Summary
Judgment:

… At the hearing, the Plaintiff provided us with a notebook with new info
on what had happened during my wife’s botched treatment. Some of the
documents implicate the medical practice and the procedures in place
at the time of my wife’s issue. It is apparent that the practice has
instituted changes in their procedures as a result of complaints that I
filed with both the state medical board and our insurance company.
While it’s very sad that the matter had to get this far before we received this
info, we were happy to see that at least some of our complaints had
been validated by an agency and addressed by the practice. Upon
seeing the new info, we also understood why the practice and its primary
owner were not party to the lawsuit. Of course, none of the new info
changes the truthfulness of the information we published online. We still
had an absolute right to say what we said. … [emphasis added]

I have not seen the documents provided to the Baileys.

The Court does not allow me to access the filings online because I’m not an
attorney, I had not been served yet and I therefore did not attend this hearing. As I live

7

almost 900 miles from the court, I can’t afford to personally check the records. I don’t
even know whether the documents the Baileys received are filed.

Clearly, I have to conduct DISCOVERY to find out what REALLY happened
and whether John Bailey’s statements of CHANGES due to their complaints are
TRUE.

I also would like to be able to state publicly that due to doctor Hollander’s FALSE
allegations against me, her anonymous deletion demand, her providing a false email
address and her failure to provide any documentation to support her claims, I’d have to be
very close to death before letting doctor Hollander touch me or write a prescription for
me.

Do I still have the right to voice my OPINION?

I’ll greatly appreciate the Court’s identification of the statements it finds to be
defamatory.

Since this is a PUBLISHED lawsuit, it is EXTREMELY important that my
readers know what we can NOT publicly state.

Paragraph 6 of the proposed order:

6. Several of Ms. Baker's posts, blogs and/or comments were thereafter
republished by other users of the web site, for example "John," and these
were done with knowledge of this litigation and of this Court's previous
Temporary Restraining Order.

I am NOT aware of “John” republishing MY posts. He did however post HIS
OPINION of doctor Hollander due to her litigation. Is that now illegal?

Is a restraining order against me enforceable against everybody who knows about
it?

Don’t we have the RIGHT to publicize the litigation of doctors who SUE patients
who dare to publish their experiences and opinions of their doctors?

I certainly will AVOID doctors who SUE their patients and I am grateful to every
person who still dares to warn the general public. It is an undisputed fact that BAD
doctors KILL people!

Are doctors now elevated to the status of GOD during the Inquisition and any
criticism and negative opinion in a public forum is no longer allowed?

8

What exactly is objectionable in John’s posting?

Paragraph 8 of the proposed order:

8. The negative statements Ms. Baker has made about Dr. Hollander's
abilities as a physician and the quality of her care provided to her patients
and Ms. Bailey are defamatory.

Again, I request that the Court IDENTIFY all defamatory statements.

The TRUTH and my OPINION are not defamatory.

CONCLUSION

I really have no idea what’s going on. My Motion for Summary Judgment has
been IGNORED by the Court.

It is undisputed that I enjoy immunity for my LINK to the Baileys’ site.

Doctor Hollander failed to identify any other allegedly defamatory statement
made by me prior to the filing of her Complaint and Affidavit and the Court
ordering my entire website removed on 10/21/08.

From the 10/17/08 Hollander Motion for Temporary Restraining Order:

10. Colorado Rule of Civil Procedure 65(c) states in pertinent part:

(c) Security. No restraining order or preliminary injunction shall issue
except upon the giving of security by the applicant, in such sum as the court
deems proper, for the payment of such costs and damages as may be
incurred or suffered by any party who is found to have been wrongfully
enjoined or restrained.

Did doctor Hollander post a $1 bond? Notably absent is the Court’s finding
regarding this issue.

Is this the green light for all who can afford to hire an attorney to have entire
websites removed and to have ALL REFERENCES to the plaintiffs DELETED?

For the reasons explained in detail above, I would finally like to conduct
discovery.

Attached hereto is Exhibit 4, my 3/9/09 email to attorney Dorweiler:

9

… Been meaning to contact you to see when we can work on the case
management plan, as I would like to submit my written discovery ASAP.
…
I did not receive a response to this request and I hope that the Court will allow me
to finally conduct discovery.
Respectfully submitted, December 28, 2009.

__________________
Christine Baker
Defendant Pro Se
Tel: 206-202-4653
Fax: 571-222-1000
Email: [email protected]

10

Certificate of Service
Tameira Hollander v. Barbary Bailey, John Bailey and Christine Baker
Case No.: 08CV2229

I certify that on 12/28/09 I mailed a copy of my Objection to the Proposed Order
and Motion for Permission to Conduct Discovery to:
Lauren Dorweiler
Irving G. Johnson
Pryor Johnson Carney Karr Nixon, P.C.
5619 DTC Pkwy Ste 1200
Greenwood Village, CO 80111-3061
ATTORNEYS FOR DOCTOR TAMEIRA HOLLANDER
______________
Christine Baker

11