1. The respondents are internationally known for instituting groundless and abusive litigation. I was informed that one ex-employee they filed a lawsuit against, faxed the complaint to the new employer with a cover letter that said, "You may want to reconsider your offer."

2. 804 CMR 1.10 (8)(d)

3. The respondents that I was trying to have the MCAD handle have claimed that a "just" an abuse of process claim which does not fall under purview of the MCAD. Their using malicious prosecution to interfere with my rights under MGL c.151B § 4 (4A)(5) brings their actions under the purview of the MCAD.

4. At that point, I did not realize the maliciousness and the abusive litigation practices that is the trademark of the respondents and their attorneys.

5.  If they had done so at that point, my damages would have been minimal. I, through Olenick explained my theories, though he did not completely agree with them then, to Rosen and told Rosen, that if they did not dismiss the counterclaim, I would prosecute this complaint.

6.  This would have prevented me from speaking about this case, aiding anyone else in bring a complaint against Mattel, or Mattel's employment practices. This clearly violates the Astra dicta.

7. To this date, after over three years, respondents still have not provided me with any evidence that any statements of facts on the website are false.

8. unless the respondents propose that a complaint for retaliation must be filed before the retaliation occurs.

9. SUMNER v. U.S. POSTAL SERVICE, 899 F.2d 203 (2nd Cir. 1990) only requires a good faith belief to provide protection.

10. If the respondents did not belief the validity of the case, detailed on the website, they would not have paid over two years salary when I was unemployed for seven months. This is more than "nuisance value."

11. Via the website, I have encouraged others to speak out against discrimination and file their own complaints with the appropriate discrimination agencies.

12.  We had filed the suit in Middlesex Superior Court in September of 1998 to avoid the expiration of time limits.

13.  The respondents strain credibility with this argument, given that they claimed that the counterclaim was not disposed of by the entry of judgment.

14.  Ladd v. Polidoro, 424 Mass. 196 (1997)

15.  Wheatley V. American Telephone & Telegraph CO., 418 Mass. 394 (1994)

16. Respondents are currently is currently litigating a case that includes a Mattel's claim that the plaintiffs brought it "solely for the improper purpose of harassing Mattel, obtaining publicity for themselves and their companies, interfere with Mattel's business operations, and attempting to extort settlement money from Mattel." Mattel, Inc. v. Luce, et al., Case number BC225556, Superior Court of California, County of Los Angeles.

17.  See Carroll v. Gillespie, 14 Mass.App.Ct. 12, 26 (1982), quoting Jones v. Brockton Pub Markets, Inc., 369 Mass. 387, 389 (1975), itself quoting from Quaranto v. Silverman, 345 Mass. 423, 426 (1963). See also Gabriel v. Borowy, 324 Mass. 231, 236 (1949).

18. Mattel v. Luce, IBID.

19. The respondents seem to be quite fond of speaking out both sides of their mouths.

20. Silverstein's opposition to plaintiff discrimination have encourage others to assert their rights at the MCAD.