Cummins uses “Google bombs” - Bat World Sanctuary

Authorship Analysis of Online Content
Related to Cause 352-248169-10 Bat
World and Amanda Lollar versus Mary
Cummins
Summary
Plaintiff alleges that the Defendant posted defamatory content on various Internet sites using various
pseudonyms and aliases to conceal the author’s true identity. Defendant denies these allegations and
asserts in public statements that she is not the author of said material. Furthermore, Defendant claims
that unknown persons copied and distributed content, posting it on various internet sites without her
knowledge. The relevant content includes, but may not be limited to, the following:
Exhibit 1: http://www.indybay.org/newsitems/2011/06/15/18681982.php
Exhibit 2: http://www.indybay.org/newsitems/2011/05/01/18678593.php
Exhibit 3: http://houston.indymedia.org/news/2011/06/73052.php
Exhibit 4: http://houston.indymedia.org/news/2011/05/72813.php
Exhibit 5: http://www.indybay.org/newsitems/2011/05/28/18680622.php
After performing a detailed comparison of this content, using a combination of mathematical and
subjective methods, against material known to be created by the Defendant, a conclusion can be drawn,
with a high degree of certainty, that the material in question was in fact created by the Defendant. It is
also highly unlikely that persons other than the Defendant were responsible for distribution of the
content to various sites.
Background
In recent years, technologies have advanced to such a degree that it is feasible for anyone with a
computer or mobile device and an Internet connection to publish large amounts of content to the world
wide web with relative ease. While much of this content can be directly attributed to the person who
authored it, either contextually within the framework of social networking application or directly via
ownership of a blog or web site, a great deal of the material in cyberspace is anonymous. Many selfproclaimed
“alternative news” sites and blogging platforms exist specifically to enable anonymous
publishing and do not require any form of authentication or identity verification. In situations where
identification of an author is paramount, such as defamation and libel cases, the inherently anonymous
nature of such sites, many of which are located in jurisdictions which do not easily permit evidence of
authorship to be compelled or which do not collect adequate data to make a positive identification,
determining who created the content can be a difficult task.

This challenge is certainly not unique to the Internet. In times past it was common for authors who did
not wish to be identified or directly associated to a particular piece of content to publish articles,
broadsheets, pamphlets, and sometimes entire novels, under false identities: to wit, the famous “Silence
Dogood” letters authored by Benjamin Franklin and the classic American literature penned by Samuel
Langhorne Clemens, better known as Mark Twain. In the latter case, the true authors identity was more
or less generally known to the public as a flagrant nom de guerre but in the case of the former, Franklin
maintained the deception until it was discovered by the publisher.
As technology has progressed over time, tools and techniques have been created to analyze anonymous
publications in order to determine the true author. Known generally as “stylometry”, this field of study
focuses on the linguistic style (or, when applied to art and music, the artistic style) of the author to
identify patterns which can then be compared with other works to determine similarities. While the use
of stylometry is nothing new (it was first described by Wincenty Lutoslawski in 1890 i ) the advent of
computers has improved the ability for researchers to analyze large amounts of data in real-time and led
to continuous improvements in tools, techniques and accuracy.
In 2008 Dr. Patrick Joula of Dequesne University released a paper on authorship attribution which
discussed automation of authorship analysis ii . His work in the field led to the creation of the Java
Graphical Authorship Attribution Program (JGAAP iii ), a software development project funded by the
National Science Foundation. As described on the JGAAP Internet site, the software is designed for:
“…textual analysis, text categorization, and authorship attribution i.e. stylometry / textometry.
JGAAP is intended to tackle two different problems, firstly to allow people unfamiliar with
machine learning and quantitative analysis the ability to use cutting edge techniques on their text
based stylometry / textometry problems, and secondly to act as a framework for testing and
comparing the effectiveness of different analytic techniques' performance on text analysis quickly
and easily.”
JGAAP allows researchers to compare the content of known and unknown texts using a variety of
analysis methods. Based upon the results of each test, the software provides a numerical ranking
indicating the likelihood of authorship for each document based upon source documents from known
authors. It can also be used to identify similar texts when the authors of both are unknown, indicating
which are most likely to have been created by the same author.
In addition to JGAAP, other computer programs such as Signature iv , which has been used to investigate
Barack Obama’s memoir “Dreams from my Father” and to test famous literary works from Shakespeare
to Aristotle, exist to aid in the stylistic analysis of documents. Along with subjective human analysis,
these tools provide an effective means for determining, with varying degrees of accuracy, the creator of
a specific text.

Methodology
In the case of Bat World Sanctuary and Amanda Lollar v. Mary Cummins, the suspected author is not
only known but has also published a great deal of content within a particular field (animal rights) on her
own blog, social-networking site Facebook, and various other Internet sites. The textual content of this
corpus of material, minus any images, formatting or markup, can be used as a known data set for
comparative purposes as the authorship is not in question.
The content chosen for analysis is comprised of various posts selected at random from the Defendant’s
blog (http://animaladvocateswildliferehabilitation.blogspot.com). The titles and URL’s of each
document chosen for comparison are as follows:
Title
Emu rescue
Candle light vigil for Dr Frank Ryan
Sirhan the wolfdog finds a great home
Stingrays being de-barbed at Seal Beach
West Hollywood bans the sale of fur
Link
http://animaladvocateswildliferehabilitation.blogspot.com/
2010/12/emu-rescue-animal-advocates-mary.html
http://animaladvocateswildliferehabilitation.blogspot.com/
2010_08_01_archive.html
http://animaladvocateswildliferehabilitation.blogspot.com/
2010_10_01_archive.html
http://animaladvocateswildliferehabilitation.blogspot.com/
2011/05/stingrays-being-de-barbed-at-seal-beach.html
http://animaladvocateswildliferehabilitation.blogspot.com/
2011/09/west-hollywood-bans-sale-of-fur-mary.html
In addition to the Defendant’s own material, it is necessary to include additional content from other
authors to establish a viable control set. Ideally, the control material should be from a similar genre or
an author publishing within the same field in the same general format (for example, scientific papers
should be compared with other scientific papers and not to a magazine article or romance novel). In this
case, the raw text of random blog postings from authors who publish content related to animal rights,
discovered using a generic web search for the term “animal rights blog”, were selected to comprise the
control set, which was then used along with the Defendant’s known work for comparison against
Exhibits 1 – 5 by the JGAAP software:
Author Title Link
Gillian Lyons
Ban on Domestic Horse
Slaughter Lifted
http://animalblawg.wordpress.com/
2011/11/29/ban-on-domestic-horseslaughter-lifted/
Gillian Lyons Remembering Charlie http://animalblawg.wordpress.com/
2011/11/01/remembering-charlie/
Gillian Lyons
Jury Awards 300k to Family
Whose Dog Was Killed
http://animalblawg.wordpress.com/
2011/09/19/jury-awards-300k-to-familywhose-dog-was-killed/
Gillian Lyons Elephants in the News http://animalblawg.wordpress.com/
2011/08/25/elephants-in-the-news/
Eric Chiamulera Feral cats with Rabies http://animalblawg.wordpress.com/

2011/12/13/feral-cats-with-rabies/
Eric Chiamulera Thoughts on the ethics of pet
ownership
http://animalblawg.wordpress.com/
2011/12/15/thoughts-on-the-ethics-of-petownership/
Gary Francione A Note on Humanlike
Intelligence and Moral Value
http://www.abolitionistapproach.com/a-noteon-humanlike-intelligence-and-moral-value/
Gary Francione Animal Care and Control The
Sad Failure of New York City
Municipal Shelter System
http://www.abolitionistapproach.com/animalcare-and-control-the-sad-failure-of-new-yorkcitys-municipal-shelter-system/
Gary Francione Killing Animals and Making
Animals Suffer
http://www.abolitionistapproach.com/killinganimals-and-making-animals-suffer/
Gary Francione Got Faith in Animal Welfare http://www.abolitionistapproach.com/gotfaith-in-animal-welfare/
Authorship Results
The first battery of tests was performed using the Fisher Linear Discriminant Analysis method against
the described control set. The LDA test was chosen as it is recommended in the Best Practices section of
the JGAAP tutorial as a reliable analysis method. Linear Discriminant Analysis is described as follows:
“Linear discriminant analysis (LDA) and the related Fisher's linear discriminant are methods used in statistics,
pattern recognition and machine learning to find a linear combination of features which characterizes or
separates two or more classes of objects or events. The resulting combination may be used as a linear
classifier, or, more commonly, for dimensionality reduction before later classification.
LDA is closely related to ANOVA (analysis of variance) and regression analysis, which also attempt to
express one dependent variable as a linear combination of other features or measurements.[1][2] In the
other two methods however, the dependent variable is a numerical quantity, while for LDA it is a categorical
variable (i.e. the class label). Logistic regression and probit regression are more similar to LDA, as they also
explain a categorical variable. These other methods are preferable in applications where it is not reasonable
to assume that the independent variables are normally distributed, which is a fundamental assumption of
the LDA method.
LDA is also closely related to principal component analysis (PCA) and factor analysis in that they both look
for linear combinations of variables which best explain the data.[3] LDA explicitly attempts to model the
difference between the classes of data. PCA on the other hand does not take into account any difference in
class, and factor analysis builds the feature combinations based on differences rather than similarities.
Discriminant analysis is also different from factor analysis in that it is not an interdependence technique: a
distinction between independent variables and dependent variables (also called criterion variables) must be
made.” v .
The results of this test indicate a 91.67% probability that the suspect documents were authored by the
Defendant.

Analysis Method:
Control Set:
Conconicizers:
Fisher Linear Discriminant Analysis
Gillian Lyons, Gary Francione, Eric Chiamulera
Normalize Whitespace, Normalize ASCII
Test Type
Target File Word Stems Word Grams Words Character Grams Lexical Frequencies Parts of Speech
1 Cummins Cummins Cummins Cummns Cummns Cummins
2 Cummins Cummins Cummins Cummns Cummns Lyons
3 Cummins Cummins Cummins Cummns Cummns Francione
4 Cummins Cummins Cummins Cummns Cummns Cummns
1 - "ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty"
2 - "Amanda Lollar Animal Cruelty at Bat World TX"
3 - "Amanda Lollar commits animal cruelty at Bat World Sanctuary"
4 - "Rabies filth at Bat World Sanctuary in Mineral Wells Texas"
As JGAPP is primarily a research tool in an emerging field, some of the included analysis methods are
more appropriate than others. As an additional control against the LDA analysis method, a second
battery of tests was run using the Gaussian SVM (Support Vector Machine) analysis method, which
employs a well-known set of techniques for computer-based pattern recognition:
“A support vector machine (SVM) is a concept in statistics and computer science for a set of related
supervised learning methods that analyze data and recognize patterns, used for classification and regression
analysis. The standard SVM takes a set of input data and predicts, for each given input, which of two
possible classes comprises the input, making the SVM a non-probabilistic binary linear classifier. Given a set
of training examples, each marked as belonging to one of two categories, an SVM training algorithm builds
a model that assigns new examples into one category or the other. An SVM model is a representation of the
examples as points in space, mapped so that the examples of the separate categories are divided by a clear
gap that is as wide as possible. New examples are then mapped into that same space and predicted to
belong to a category based on which side of the gap they fall on.” vi
The results of this test demonstrate a 100% probability that the suspect documents were authored by
the Defendant.
Analysis Method:
Control Set:
Conconicizers:
Gaussian SVM
Gillian Lyons, Gary Francione, Eric Chiamulera
Normalize Whitespace, Normalize ASCII
Test Type
Target File Word Stems Word Grams Words Character Grams Lexical Frequencies Parts of Speech
1 Cummins Cummins Cummins Cummins Cummns Cummns
2 Cummins Cummins Cummins Cummins Cummns Cummns
3 Cummins Cummins Cummins Cummins Cummns Cummns
4 Cummins Cummins Cummins Cummns Cummns Cummns
1 - "ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty"
2 - "Amanda Lollar Animal Cruelty at Bat World TX"
3 - "Amanda Lollar commits animal cruelty at Bat World Sanctuary"
4 - "Rabies filth at Bat World Sanctuary in Mineral Wells Texas"

Finally, a combined test battery consisting of fourteen separate analysis methods, including the previous
LDA and Guassian SVM tests, was run in order to provide a broad control set which might counteract
any potentially discriminatory results from the prior tests, with no consideration given to whether or not
the additional tests had any demonstrated track record for accuracy or applicability. The results of the
combined test battery suggest a 71% probability that the suspect documents were authored by the
Defendant. This is highly significant, as most of the tests in the combined battery have no known
validity or reasonable expectation of accuracy in this context; they could very well have indicated a
negative conclusion and been perceived to nullify the two original tests instead of validating them.

Analysis Method:
Control Set:
Conconicizers:
All
Gillian Lyons, Gary Francione, Eric Chiamulera
Normalize Whitespace, Normalize ASCII
Test Type
Method Word Stems Word Grams Words Character Grams Lexical Frequencies Parts of Speech
Burrows Delta Cummins Cummins Cummins Lyons Francione Cummins
Cummins Cummins Cummins Francione Francione Cummins
Cummins Cummins Cummins Francione Francione Cummins
Cummins Cummins Cummins Francione Francione Cummns
Centroid Driver Cummins Francione Cummins Cummns Francione Cummins
Cummins Francione Cummins Cummns Francione Cummins
Cummins Francione Cummins Cummns Francione Cummins
Cummins Francione Cummins Cummns Francione Cummns
Gaussian SVM Cummins Cummins Cummins Cummns Cummns Cummins
Cummins Cummins Cummins Cummns Cummns Cummins
Cummins Cummins Cummins Cummns Cummns Cummins
Linear Discriminant
Analysis
Cummins Cummins Cummins Cummns Cummns Cummns
Cummins Cummins Cummins Cummns Cummns Cummins
Cummins Cummins Cummins Cummns Cummns Lyons
Cummins Cummins Cummins Cummns Cummns Francione
Cummins Cummins Cummins Cummns Cummns Cummns
Linear SVM Cummns Cummns Cummns Cummns Cummns Francione
Cummns Cummns Cummns Cummns Cummns Francione
Cummns Cummns Cummns Cummns Cummns Francione
Cummns Cummns Cummns Cummns Cummns Francione
Markov Chain Francione Lyons Francione Francione Francione Cummns
Cummins Francione Cummins Francione Cummns Cummins
Cummins Francione Cummins Francione Francione Cummins
Naïve Bayes
Classifier
Nearest Neighbor
Driver
WEKA Least
Median Squared
WEKA Linear
Regression
WEKA Multilayer
Perceptron
WEKA Naïve Bayes
Classifier
WEKA Sequential
Minimal
Optimization
WEKA Voted
Perceptron
Result Total: 336
Count "Cummins": 238
Confidence: 70.83%
Cummins Cummins Cummins Francione Cummns Cummns
Francione Francione Cummins Francione Cummins Francione
Francione Francione Francione Francione Francione Francione
Francione Francione Francione Francione Francione Francione
Francione Francione Cummins Francione Cummins Francione
Cummins Chiamulera Cummins Lyons Cummns Lyons
Cummins Francione Cummins Francione Cummns Cummins
Cummins Francione Cummins Francione Francione Cummins
Cummins Cummins Cummins Cummns Cummns Cummns
Cummins Cummins Cummins Cummns Cummns Cummins
Cummins Cummins Cummins Cummns Cummns Cummins
Cummins Cummins Cummins Cummns Cummns Cummins
Cummins Cummins Cummins Cummns Cummns Cummns
Cummins Chiamulera Cummins Lyons Francione Cummins
Cummins Cummins Cummins Lyons Chiamulera Lyons
Cummins Chiamulera Cummins Lyons Chiamulera Cummins
Cummins Cummins Cummins Cummns Lyons Cummns
Cummins Chiamulera Cummins Lyons Francione Cummins
Cummins Cummins Cummins Francione Chiamulera Lyons
Cummins Lyons Cummins Cummns Chiamulera Cummins
Cummins Cummins Cummins Cummns Lyons Cummns
Cummins Cummins Cummins Francione Cummns Cummins
Cummins Francione Cummins Lyons Cummns Cummins
Cummins Francione Cummins Cummns Francione Cummins
Cummins Cummins Cummins Cummns Cummns Cummns
Cummins Chiamulera Cummins Lyons Francione Cummins
Cummins Cummins Cummins Lyons Chiamulera Cummins
Cummins Chiamulera Cummins Cummns Chiamulera Cummins
Cummins Cummins Cummins Francione Lyons Cummns
Cummins Cummins Cummins Lyons Cummns Cummins
Cummins Francione Cummins Cummns Cummns Cummins
Cummins Francione Cummins Cummns Cummns Cummins
Cummins Francione Cummins Cummns Cummns Cummns
1 - "ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty"
2 - "Amanda Lollar Animal Cruelty at Bat World TX"
3 - "Amanda Lollar commits animal cruelty at Bat World Sanctuary"
4 - "Rabies filth at Bat World Sanctuary in Mineral Wells Texas"

Distribution Results
The authorship results demonstrate a very high degree of probability that the Defendant authored the
suspected content in Exhibits 1 – 5. Of these exhibits, the prevailing instance of distribution occurs
between Exhibits 1 and 3. If, as the results of the authorship analysis prove, the Defendant did, in fact,
author the original material, then the obvious question becomes: did the Defendant also distribute the
material to other internet sites
For purposes of this analysis, Exhibit 1, entitled “Rabies, filth at Bat World Sanctuary in Mineral Wells,
Texas”, may be considered the “original” material as it was posted to the www.indybay.org site on June
15, 2011 at 3:09PM while Exhibit 3 was posted several days later to the houston.indymedia.org site on
June 18, 2011 at 9:59AM. Both posts have the same title and are attributed to the same author
(“Desmodus rotundus”, which, incidentally, is the scientific name for the Common Vampire Bat). They
also show the same image, that of a bat in flight against a black background.
It is important to note that both indybay.org and indymedia.org allow any person to post content on
their respective sites without first requiring a login or other form of identity verification; however, both
sites require a spam-prevent technique known as “CAPTCHA” (http://www.captcha.net/) which is
designed to prevent automated routines, such as robots and crawlers, from contributing content. The
CAPTCHA technique is widely used on the Internet and considered to be quite effective in preventing
non-human input; therefore, it is almost certain that a human being and not a computer is responsible
for posting both the original and copied material.
The title and attribution of both posts are identical, including two distinct grammatical errors. The “f” in
the world “filth” is lower case in both titles when it should be capitalized; the same applies to the “r” in
“rotundus” on the attribution line. This indicates that the text was copied directly from the original post
and inserted into the form fields of the copied item (a method known in computer terminology as “cut
and paste” or “copy and paste”). This on its own is not a significant finding – anyone could have simply
copied the title and attribution without bothering to correct the grammatical errors; however, analysis
of the content reveals two highly significant inconsistencies.
First, paragraph 13 of the original text states the following:
“Her wildlife rehabilitation permit does not allow her to keep healthy bats or breed bats.
Assurance colonies are made up of healthy bats that can breed and live unassisted. She
was warned in May 2010 by Texas Parks and Wildlife that she cannot allow her bats to
breed.”
The same paragraph in the copied text is almost identical except the date has been changed from 2010
to 2011 (emphasis added):
“Her wildlife rehabilitation permit does not allow her to keep healthy bats or breed bats.
Assurance colonies are made up of healthy bats that can breed and live unassisted. She
was warned in May 2011 by Texas Parks and Wildlife that she cannot allow her bats to
breed.”

Second, although the image of a flying bat in both posts is identical, the source is entirely different. The
image was first uploaded to the indybay.org site at the following URL:
http://www.indybay.org/uploads/2011/06/15/bat_world_sanctuary.jpg
Instead of referencing the original image location in the copied post, which would be expected if the
content had simply been cut and pasted, the same image, with a slightly different name, was uploaded
separately to the indymedia.org site at the following URL:
http://houston.indymedia.org/uploads/2011/06/bat_world_sanctuary.jpgmid.jpg
In order for this to occur, the original image would have to exist on the author’s computer where the
name could be changed. It would then have to be uploaded via the contribution form and the
embedded link in the content markup changed to point to the new image.
It is simply impossible for any automated routine to have picked up the original post and copied to the
secondary location while simultaneously changing only a single year value in the text and
replacing/renaming the image. Likewise, it is inconceivable that any individual who might have copied
the original post would have done the same, even if they were associated with the original content
author, had a personal or commercial interest in the content, or simply supported the author’s views.
To begin with, they would have to know the actual date of the warning referenced in the post in order
to change it. Secondly, they must have been willing to take the time and effort required to change the
image name, upload it, and modify the page markup – not a likely scenario as simply copying the original
markup would have resulted in a reference to the original image location without any additional effort
required.
Based on the above analysis, the inescapable conclusion is that the author of the original post is also the
author of the copied post. Only the original author would have sufficient knowledge of the incident
referenced in Paragraph 13 to change the only the year in otherwise identical content three days later.
Furthermore, it is unlikely that anyone other than the original author would have gone through the
trouble to manipulate the associated image. As the authorship analysis results in the previous section
prove conclusively that the original author of Exhibit 1 is, in fact, the Defendant, then it logically follows
that Exhibit 3 was also authored by the Defendant, most likely in order to spread the material across
multiple sites, thereby increasing its rank in search results and gaining additional exposure.
Conculsions
The results of the authorship analysis are conclusive and unambiguous. Based upon the results of
stylometric tests, along with examination of duplicate post content and markup, it is clear that the
Defendant not only authored the material in question but also posted a portion of it in more than one
location in order to increase ranking and exposure in various search engines.

Appendix A: JGAAP Raw Result Data
Regularized Linear Discriminant Analysis
Words
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Words as events
1. Mary Cummins 1.1871812575798648E13
2. Gary Francione 1.1871812575798195E13
3. Gillian Lyons 1.1871812575797715E13
4. Eric Chiamulera 1.1871812575793307E13
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Words as events
1. Mary Cummins 8.048282968049015E12
2. Gary Francione 8.048282968048777E12
3. Gillian Lyons 8.048282968046156E12
4. Eric Chiamulera 8.048282968043982E12
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Words as events
1. Mary Cummins 1.1139989937710984E13
2. Gary Francione 1.1139989937710906E13
3. Gillian Lyons 1.1139989937708992E13
4. Eric Chiamulera 1.1139989937705525E13
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Words as events
1. Mary Cummins 1.289344429450714E13
2. Gillian Lyons 1.2893444294507133E13
3. Gary Francione 1.2893444294506172E13
4. Eric Chiamulera 1.2893444294502271E13
Word Stems
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Word stems as events
1. Mary Cummins 1.2276766272439627E13
2. Gillian Lyons 1.2276766272439379E13
3. Gary Francione 1.227676627243896E13
4. Eric Chiamulera 1.2276766272433928E13
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Word stems as events
1. Mary Cummins 7.074735498607778E12
2. Gary Francione 7.074735498607273E12
3. Gillian Lyons 7.074735498605094E12
4. Eric Chiamulera 7.074735498603041E12
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII

Analyzed by LDA using Word stems as events
1. Mary Cummins 9.707104610128525E12
2. Gary Francione 9.707104610128156E12
3. Gillian Lyons 9.707104610126504E12
4. Eric Chiamulera 9.707104610123232E12
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Word stems as events
1. Mary Cummins 1.0355751742709096E13
2. Gillian Lyons 1.0355751742708867E13
3. Gary Francione 1.0355751742708043E13
4. Eric Chiamulera 1.0355751742704209E13
Word Grams
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Word 2Grams as events
1. Mary Cummins 2.930682857744708E12
2. Eric Chiamulera 2.930682857744541E12
3. Gary Francione 2.9306828577442173E12
4. Gillian Lyons 2.930682857743229E12
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Word 2Grams as events
1. Mary Cummins -4.826049202399666E12
2. Gary Francione -4.826049202399727E12
3. Gillian Lyons -4.826049202401523E12
4. Eric Chiamulera -4.826049202402629E12
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Word 2Grams as events
1. Mary Cummins 1.0004754352189697E12
2. Gary Francione 1.0004754352187875E12
3. Gillian Lyons 1.0004754352176781E12
4. Eric Chiamulera 1.0004754352163457E12
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Word 2Grams as events
1. Mary Cummins 5.990256051792382E12
2. Gary Francione 5.990256051792006E12
3. Gillian Lyons 5.990256051789729E12
4. Eric Chiamulera 5.990256051789027E12
Parts of Speech Grams
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using POS 2Grams as events
1. Mary Cummins 1.6187892704452059E13
2. Gillian Lyons 1.6187892704451217E13
3. Gary Francione 1.618789270445119E13
4. Eric Chiamulera 1.618789270445042E13
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt

Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using POS 2Grams as events
1. Gillian Lyons 1.5394684114950666E13
2. Gary Francione 1.5394684114949611E13
3. Mary Cummins 1.5394684114948707E13
4. Eric Chiamulera 1.539468411493728E13
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using POS 2Grams as events
1. Gary Francione 1.6101004742014385E13
2. Mary Cummins 1.6101004742013254E13
3. Gillian Lyons 1.6101004742012791E13
4. Eric Chiamulera 1.6101004742004627E13
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using POS 2Grams as events
1. Mary Cummins 1.5245675618764117E13
2. Gillian Lyons 1.5245675618762936E13
3. Gary Francione 1.5245675618762842E13
4. Eric Chiamulera 1.5245675618759764E13
Character Grams
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Character 2Grams as events
1. Mary Cummins 1.1419478134171932E13
2. Gillian Lyons 1.1419478134171436E13
3. Gary Francione 1.141947813417046E13
4. Eric Chiamulera 1.14194781341689E13
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Character 2Grams as events
1. Mary Cummins 1.1032868961455873E13
2. Gillian Lyons 1.1032868961455459E13
3. Gary Francione 1.1032868961454688E13
4. Eric Chiamulera 1.1032868961451521E13
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Character 2Grams as events
1. Mary Cummins 1.1085021932131709E13
2. Gillian Lyons 1.1085021932131225E13
3. Gary Francione 1.1085021932130492E13
4. Eric Chiamulera 1.1085021932127756E13
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Character 2Grams as events
1. Mary Cummins 1.1682236163627479E13
2. Gary Francione 1.168223616362552E13
3. Gillian Lyons 1.1682236163625033E13
4. Eric Chiamulera 1.1682236163624607E13

Lexical Frequencies
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Lexical Frequencies as events
1. Mary Cummins 1.2375344835709857E13
2. Gary Francione 1.2375344835709848E13
3. Gillian Lyons 1.237534483570944E13
4. Eric Chiamulera 1.2375344835704555E13
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Lexical Frequencies as events
1. Mary Cummins 1.304491136873906E13
2. Gary Francione 1.3044911368738426E13
3. Gillian Lyons 1.304491136873701E13
4. Eric Chiamulera 1.3044911368735977E13
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Lexical Frequencies as events
1. Mary Cummins 1.3446422408894041E13
2. Gary Francione 1.3446422408893277E13
3. Gillian Lyons 1.3446422408892607E13
4. Eric Chiamulera 1.3446422408890547E13
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by LDA using Lexical Frequencies as events
1. Mary Cummins 1.2161265907166639E13
2. Gillian Lyons 1.2161265907166443E13
3. Gary Francione 1.2161265907165457E13
4. Eric Chiamulera 1.2161265907162062E13
Gaussian Support Vector Machine
Words
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Words as events
1. Mary Cummins 1.0
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Words as events
1. Mary Cummins 1.0
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Words as events
1. Mary Cummins 1.0
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Words as events
1. Mary Cummins 1.0

Word Stems
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Word stems as events
1. Mary Cummins 1.0
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Word stems as events
1. Mary Cummins 1.0
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Word stems as events
1. Mary Cummins 1.0
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Word stems as events
1. Mary Cummins 1.0
Word Grams
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Word 2Grams as events
1. Mary Cummins 1.0
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Word 2Grams as events
1. Mary Cummins 1.0
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Word 2Grams as events
1. Mary Cummins 1.0
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Word 2Grams as events
1. Mary Cummins 1.0
Parts of Speech Grams
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using POS 2Grams as events
1. Mary Cummins 1.0
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using POS 2Grams as events
1. Mary Cummins 1.0

Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using POS 2Grams as events
1. Mary Cummins 1.0
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using POS 2Grams as events
1. Mary Cummins 1.0
Character Grams
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Character 2Grams as events
1. Mary Cummins 1.0
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Character 2Grams as events
1. Mary Cummins 1.0
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Character 2Grams as events
1. Mary Cummins 1.0
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Character 2Grams as events
1. Mary Cummins 1.0
Lexical Frequencies
ACLU tells lawyer Randy Turner that Indybay will not remove article about animal cruelty [Freedom of
Speech].txt C:\Data\Bat World\Mary Cummins\Suspect\ACLU tells lawyer Randy Turner that Indybay will not
remove article about animal cruelty [Freedom of Speech].txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Lexical Frequencies as events
1. Mary Cummins 1.0
Amanda Lollar Animal Cruelty at Bat World TX.txt C:\Data\Bat World\Mary Cummins\Suspect\Amanda Lollar
Animal Cruelty at Bat World TX.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Lexical Frequencies as events
1. Mary Cummins 1.0
Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt C:\Data\Bat World\Mary
Cummins\Suspect\Amanda Lollar commits animal cruelty at Bat World Sanctuary.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Lexical Frequencies as events
1. Mary Cummins 1.0
Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt C:\Data\Bat World\Mary
Cummins\Suspect\Rabies filth at Bat World Sanctuary in Mineral Wells Texas.txt
Canonicizers: Normalize Whitespace Normalize ASCII
Analyzed by Gaussian SVM using Lexical Frequencies as events
1. Mary Cummins 1.0

i http://en.wikipedia.org/wiki/Wincenty_Lutos%C5%82awski
ii http://www.mathcs.duq.edu/~juola/papers.d/fnt-aa.pdf
iii http://evllabs.com/jgaap/w/index.php/Main_Page
iv http://www.philocomp.net/humanities/signature
v http://en.wikipedia.org/wiki/Linear_discriminant_analysis
vi http://en.wikipedia.org/wiki/Support_vector_machine

MARY CUMMINS GOOGLE BOMB FLOW CHART

1
1
2 REPORTER'S RECORD
3 CAUSE NO. 352-248169-10
4 BAT WORLD SANCTUARY, ET AL.* IN THE DISTRICT COURT
*
5 *
VS. * 352ND DISTRICT COURT
6 *
*
7 *
MARY CUMMINS * TARRANT COUNTY, TEXAS
8
9
10 ****************************************
11 EXCERPT ON TRIAL ON MERITS
12 ****************************************
13
14
15
16
17
18 On the 12th day of June, 2012, the following
19 proceedings came on to be heard in the above-entitled
20 and numbered cause before the Honorable William Brigham,
21 Judge Presiding, held in Tarrant County, Texas.
22 Proceedings reported by machine shorthand.
23 CAROLYN H. GAYALDO, CSR
Deputy Official Reporter
24 352nd District Court
Tarrant County, Texas
25
ALLIED REPORTERS * (817) 335-5568 * (800) 562-7055

2
1 A P P E A R A N C E S
2 Attorney for Plaintiffs:
3 Mr. Randal E. Turner
SBOT NO. 20328310
4 TURNER & McKENZIE, PC
1800 Norwood Road, Suite 100
5 Hurst, Texas 76054
(817) 282-3868
6 (817) 282-1563 Fax
7 Attorney for Defendant:
8 Ms. Mary Cummins, Pro Se
9
10
11
12
13
14
15
16
17
18
19
20
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22
23
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25
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3
1 INDEX
2 EXCERPT OF TRIAL ON MERITS
3 June 12, 2012 Page
4 Appearances.................................... 2
5 Beginning of Requested Excerpt................. 4
6 PLAINTIFFS' WITNESS
7 DIRECT CROSS REDIRECT RECROSS
8 Eric Shupps 4 31 -- --
9 End of Requested Excerpt....................... 56
10 Reporter's Certificate......................... 57
11 EXHIBITS
12 PLAINTIFFS EXHIBIT
13 NO. DESCRIPTION OFFERED ADMITTED
14 18 Website Postings 9 10
15
16
17
18
19
20
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22
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25
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1 BEGINNING OF REQUESTED EXCERPT
2 (Tuesday, June 12, 2012, 1:20 p.m.)
3 THE COURT: You may call your next
4 witness, Mr. Turner.
5 MR. TURNER: Call Eric Shupps, and I
6 think he's in the restroom, Your Honor.
7 THE COURT: Go get him.
8 MR. TURNER: I will go get him.
9 THE COURT: Will you raise your right
10 hand to be placed under oath
11 (Witness sworn.)
12 THE COURT: Thank you. Please be seated.
13 ERIC SHUPPS,
14 having been first duly sworn, testified as follows:
15 DIRECT EXAMINATION
16 BY MR. TURNER:
17 Q. State your name for the record, please.
18 A. Eric Shupps.
19 Q. And what is your address -- your work address,
20 Mr. Shupps
21 A. Business address is 611 South Main Street,
22 Suite 400, Grapevine, Texas --
23 THE COURT: Will you please spell your
24 last name for me
25 THE WITNESS: I certainly will.
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5
1 S-h-u-p-p-s.
2 THE COURT: Thank you.
3 Q. (BY MR. TURNER) And what is your profession
4 A. Information technology.
5 Q. What does that mean
6 A. It means I work in the software and Internet
7 industry, primarily in developing computer software, but
8 also in computer networking.
9 Q. And can you describe -- Well, let me back up
10 and ask you: What were you asked to do in this case
11 A. Well, I was asked to perform three tasks.
12 Q. And then I'm going to ask you what your
13 qualifications are to do that. But first, tell us what
14 your -- what you were asked to do.
15 A. Three things. Determine the nature of the
16 content that was posted on the web about Amanda Lollar
17 and Bat World Sanctuary, determine why and what effect
18 that information had, and then determine who posted it.
19 Q. Okay. Would you tell the Court -- describe
20 the education, training, or experience that would
21 qualify you to do these three tasks.
22 A. I have been in information technology for more
23 than 20 years, in all aspects of the business, from
24 low-level computer networking, all the way up through
25 high-level software design, business analysis.
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1 THE COURT: Slow down. Slow down.
2 THE WITNESS: And various other factors
3 of the industry. I primarily spend most of my time
4 writing software for Internet websites, and I'm very
5 familiar with Internet protocols, and have worked in
6 data centers around the world and also for networking
7 companies as well as on the software side.
8 Q. (BY MR. TURNER) And by whom are you currently
9 employed
10 A. I work for my own company, Binary Wave.
11 THE REPORTER: Biner Air Wave
12 THE WITNESS: Binary Wave.
13 THE REPORTER: Thank you.
14 THE WITNESS: Uh-huh.
15 Q. (BY MR. TURNER) Do you have a resume or CV
16 A. I do not have one with me.
17 Q. You gave me one
18 A. I did.
19 Q. I'm going to show you what's been marked as
20 Exhibit 92, and I will ask you: Is that a copy of
21 your --
22 THE COURT: Number what
23 MR. TURNER: 92, Your Honor.
24 THE COURT: 92
25 MR. TURNER: Yes, sir.
ALLIED REPORTERS * (817) 335-5568 * (800) 562-7055

7
1 MS. CUMMINS: Can I get a copy
2 Q. (BY MR. TURNER) Is that a copy of your CV, or
3 curriculum vitae
4 A. Yes, it is.
5 MR. TURNER: You got one in discovery.
6 Q. (BY MR. TURNER) What type of content did you
7 analyze, Mr. Shupps
8 A. Well, the content fell into three categories:
9 News articles, and I'm using that term very loosely,
10 posted to --
11 Q. Can I -- Can I interrupt you
12 A. Certainly.
13 Q. I know this is a very technical field, and I
14 will ask you to use as many nontechnical terms as
15 possible for those of us, like myself, who don't really
16 speak that language very well. In other words, use
17 terms that us laypeople might understand whenever you
18 can. So I'm sorry for interrupting.
19 A. That's fine. News articles, so these are
20 posts made to the web, in this case to independent news
21 organizations, meaning they're not vetted, they are not
22 submitted by reporters, there are no sources or anything
23 quoted. These are just posts that individuals make on a
24 website with no attribution as to who they are or
25 verification of who the author is.
ALLIED REPORTERS * (817) 335-5568 * (800) 562-7055

8
1 There are also blog posts, which are
2 content that people publish typically under their own
3 attribution, or a site that they own or operate.
4 Sometimes they're on network syndicated sites such as
5 those of Google and others.
6 Blog posts are primarily opinion based,
7 sometimes factual, but again, with no vetting or any
8 other type of fact checking on them. And then thirdly,
9 there is a large amount of what we call comments, which
10 are individuals posting their thoughts and opinions in
11 relation to other content that has been previously
12 posted.
13 Q. And did you already tell us where this
14 material was posted
15 A. Well, there is quite a lot of it. There are
16 several primary sources for the material. The majority
17 of it is found on the Indy media sites, so those would
18 be Indybay and its various affiliates along with
19 syndication sites such as Raise The Fist.
20 And what I mean by syndication site is
21 there are news sites where primary content is posted,
22 and then there are other sites that pick up material
23 from those sites and -- and republished them.
24 There are also blogs. Several in
25 particular. The blog that Ms. Cummins owns and
ALLIED REPORTERS * (817) 335-5568 * (800) 562-7055

9
1 operates, the blogs of L.A. Animal Watch and Working to
2 Help Animals Today and Tomorrow, and then various
3 Facebook sites and other social media outlets.
4 Q. Have you been furnished with a copy of the
5 material that was posted to the Internet
6 A. Yes.
7 Q. I'm going to show you, I think, what's been
8 admitted into evidence as Exhibit Number 18. Do you
9 recognize any of the materials in this Exhibit 18
10 A. I do, yes.
11 Q. Do you -- Do these websites -- were these
12 the -- Is Exhibit 18 the -- some of the materials you
13 were asked to look at to make opinions in this case
14 A. Yes, it is.
15 MS. CUMMINS: Can I get a copy of
16 Exhibit 18
17 Q. (BY MR. TURNER) And, Mr. Shupps, do -- does
18 all of the material in Exhibit 18 -- does it today or
19 was it at one time on the Internet
20 A. Yes.
21 Q. Okay.
22 MR. TURNER: We will offer into evidence
23 Plaintiffs' Exhibit 18.
24 MS. CUMMINS: I haven't looked at it yet.
25 No objection.
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10
1 THE COURT: Plaintiffs' 18 is admitted.
2 (Plaintiffs' Exhibit Number 18 was
3 admitted.)
4 Q. (BY MR. TURNER) Mr. Shupps, do these websites
5 that you mentioned have any controls in place to prevent
6 computer-generated posts or to verify the identity of
7 the author
8 A. They do. The primary sites in question, the
9 Indybay sites along with Raise the Fist, all use a
10 technique called CAPTCHA, which requires you to put in a
11 phrase or a couple of phrases or a number that you see
12 displayed on the screen typically, in a chopped up
13 manner or some way, that a computer program couldn't
14 read it that only a human could.
15 So you must input that field before it
16 will accept your post. And CHAPCHA is widely used on
17 the Internet as a means of preventing automated
18 postings.
19 Q. If I understand you correctly, and if certain
20 things appear on the Internet at these sites, a person
21 had to put them there. They weren't put there by a
22 computer-generated program, correct
23 A. That is correct.
24 Q. Were there any indications that the content
25 was created by a single individual as opposed to
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11
1 multiple individuals
2 A. Well, there is a lot of commonality between
3 this information. Some them are fairly obvious that
4 they come from different authors. For example, the
5 Working to Help Animals blog and the L.A. Animal Watch
6 blog and the blog of the defendant all have a very
7 specific voice or manner in which the content is
8 authored and you -- it's very easy to tell that author's
9 style and how they produce content.
10 The difficult ones are the ones that are
11 posted on the independent sites where there is no
12 verification of who the entity is that created that
13 content along with all of the associated comments that
14 go with them. However, in this case, there were a lot
15 of clues which enabled me to establish the identity of
16 the person who posted them.
17 Q. Okay. Now, how can you be certain that the
18 content at these sites was not generated by an automated
19 routine or a robot
20 A. Well, there is a couple of real giveaways.
21 The first is, we've already mentioned it, is the CAPTCHA
22 spam prevention, which stops automated routines from
23 grabbing content from one place and posting it to
24 another. But there are also indications within the
25 content itself that it was copied and pasted by an
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12
1 individual and not done by an automated routine.
2 So, for example, let's take what's in
3 here referred to as Indybay number one and Indybay
4 number three. These are almost virtual identical posts
5 of each other. In fact, for the most part they're a
6 direct cut and paste from one to three.
7 However, there are some real key
8 differences. First of all, a couple of -- one key date
9 was changed in the text. So looking at paragraph 13
10 where it references the investigation by authorities of
11 Amanda Lollar and her permits, there is a date that
12 specifies May, 2010.
13 Q. Can I stop you right there
14 A. Certainly you may.
15 MR. TURNER: Your Honor, it hasn't been
16 admitted, but I would like to publish a report -- a copy
17 of the exhibit that the witness is referring to so that
18 the Court can follow along.
19 MS. CUMMINS: Can I get a copy
20 MR. TURNER: You have a copy.
21 MS. CUMMINS: This one
22 MR. TURNER: Yes, that's it.
23 Q. (BY MR. TURNER) I'm sorry. Go ahead.
24 THE WITNESS: Your Honor, I'm on Indybay
25 number one, page marked 002.
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13
1 In paragraph 13 it states, Her wildlife
2 rehabilitation permit does not allow her, et cetera, et
3 cetera, and then the next sentence it says, She was
4 warned in May, 2010, by the Texas Parks and Wildlife
5 that she cannot allow her bats to breed.
6 When that article was copied to the
7 Houston Indy media site --
8 THE REPORTER: Can you slow down, please
9 THE WITNESS: I'm sorry. When that
10 article was copied and pasted to the Houston Indy media
11 site, that date was changed from 2010 to 2011. An
12 automated routine just picking up content and reposting
13 it wouldn't have changed the date.
14 Secondarily, there is an image. If you
15 look on page 001 on that post, there is an image of a
16 bat in flight against a black background. If I were to
17 copy that source material from the original page to a
18 new one, what would show up is a link back to the
19 original image. The image itself wouldn't get copied,
20 because a copy operation simply takes the markup as text
21 from one place to another.
22 So the image, although it shows up on
23 site number three, would point back to site number one.
24 That didn't happen in this case. This image was
25 directly uploaded by an individual. When you post
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1 content on the Indy media site, there is a form that you
2 have to fill out. That form contains your content along
3 with various other fields, and it also includes a place
4 to post attachments so that it gets copied from the
5 user's computer to the Indy media servers. That's what
6 happened in this case. A human being actually uploaded
7 this image. It was not cut and pasted from the original
8 markup in the Indy number one.
9 Q. (BY MR. TURNER) So this was not a robot, this
10 was a person actually doing this
11 A. Correct.
12 Q. Did you discover any patterns or relationships
13 between the various content sources
14 A. There was a lot of them. What we have here,
15 and I hate to use an industry term, but what we have
16 here is a classic Goggle bomb.
17 Q. Google bomb
18 A. A Google bomb. Here is what happens, as you
19 were discussing earlier about how an image that was
20 posted of you and a skunk, I believe, ended up becoming
21 a number-one hit on the Google search results. The way
22 that that's done is by manipulation of the Google
23 algorithm. It's pretty complex, but it's not that hard
24 to fool.
25 And a lot of people have learned how to
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1 do this. In fact, there are some major retailers, JC
2 Penney and Overstock just in the last few years, who
3 have been investigated by Google and punished for doing
4 this very thing.
5 So let me explain how it works. Let's
6 say that we have two jewelers in town, Bob and Suzy, and
7 they both have a website. They both want to get their
8 search rankings up in Google so that when you search for
9 a jeweler in Fort Worth, you see Bob or Suzy's site
10 first.
11 The way that you can increase your
12 presence on Google is via two distinct things; link
13 density, which is how many other websites link to your
14 content and relevance. How many of the key search terms
15 or phrases are included in your document.
16 The more content you produce that links
17 from external sources back to your own and the more of
18 those key words you put in your document, the higher
19 you're going to get in the search rankings. So Bob and
20 Suzy are competing for search rankings, they each want
21 to produce as much content as possible.
22 But it's not just about the content.
23 It's also who is viewing and linking to the content. So
24 if I want to get that little extra bump and make sure
25 I'm number one instead of number two, I can go to people
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1 I know who run websites, I can stand up blogs under a
2 name that doesn't have anything to do with mine. I can
3 go to Facebook and Twitter and I can post and repost
4 that content.
5 That way it all links back to the
6 original source material. That gives it a higher page
7 rank, moves it up in the Google search results. So
8 that's a positive means of affecting your search
9 results. That's search engine optimization. It's the
10 same thing that the defendant was talking about earlier
11 in performing for clients and helping them to elevate
12 their presence online.
13 But this can also be done maliciously.
14 Let's say that Suzy is not happy with competing with Bob
15 just on the amount of content that she is producing.
16 She really wants to beat Bob. What she can begin doing
17 is publishing negative material about Bob all over the
18 Internet on various anonymous sites like Indybay, for
19 example, Facebook, Twitter, all sorts of other places,
20 get friends to post things on their blog.
21 As that content gets indexed by Google,
22 searches for Bob's jewelry shop are going to start
23 showing the negative content as opposed to his positive
24 content, because she's overwhelmed him with link density
25 and relevance. More people are pointing to the negative
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1 content than are pointing to his positive content.
2 That's exactly what happened in this
3 case. There are three primary articles at the core of
4 this Google bomb. The two Indybay articles identified
5 here as number one and number two and also the Raise the
6 Fist article identified as Raise the Fist number one.
7 Q. And this is what page would the Raise the
8 Fist -- When you say the Indybay number one and
9 number -- and you're referring to the tabs on --
10 A. I'm referring to the tabs in --
11 Q. -- in Exhibit 18
12 A. -- in Exhibit 18. Yes, sir.
13 Q. Okay. Go ahead.
14 A. That content was linked to and syndicated by a
15 number of other sites. Some of them are automatic, some
16 of them pick up links that they're monitoring, these
17 news organizations, and they will embed a title and a
18 short summary and a link back to the original content.
19 Those types of links still show up in
20 search results. They affect link density. But the
21 primary factors in the Google bomb are the other blogs
22 that this content was posted to. It wasn't just that
23 somebody made a comment with a link back to the content.
24 They reposted the majority of the content, and in one
25 case on the Working to Help Animals Today and Tomorrow
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1 blog, the content from one of the articles was posted as
2 a comment to an unrelated blog post. The author of the
3 blog then took and created a blog post with that content
4 in its entirety. So you now have two sources on that
5 blog alone pointing back to that material.
6 This proliferated. A preliminary
7 examination turned up dozens of these sites that link to
8 this content. So what happened was both specifically by
9 reposting the content elsewhere, the author of this
10 content got it to be disseminated on other sites knowing
11 full well that automated crawlers would also pick it up
12 and post summary links back.
13 That created the negative impact on Bat
14 World and caused the negative rankings to come up above
15 the positive rankings, and that's how it affected their
16 online reputation.
17 Q. Can a person's online reputation be harmed by
18 the use of a Google bomb
19 A. Well, of course, it can. You really don't
20 want people seeing about the skunk when they Google
21 Randy Turner. Likewise, Bat World, whether the
22 allegations are true or false, doesn't want people
23 seeing negative information.
24 Nobody here would, any of us who run our
25 own websites, want positive information about us shown
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1 first, not negative information.
2 Q. Mr. Shupps, have -- did you make an effort to
3 determine who authored the negative content that is in
4 Exhibit 18
5 A. I did.
6 Q. And can you tell us how you went about
7 determining who authored all of that content
8 A. Well, I began with looking at the content
9 itself, so one of the things that I spent a great deal
10 of my time doing, which I would rather not do, but I
11 spent a lot of time analyzing other peoples' blogs and
12 Internet postings to see if they are misappropriating
13 the content that I post.
14 So even though what I do for a living
15 isn't all that sexy or interesting to people outside of
16 the industry, I still generate more than 10,000 page
17 views a month on my own blog, and a lot of people
18 looking to get in the industry or make a name for
19 themselves, take that content and repost it on their own
20 blogs.
21 I have to be aware that this is going on,
22 and I have to analyze these blogs and see who is doing
23 what. I not only do it for myself, but there are other
24 individuals, friends and associates, and we all help
25 each other out looking for suspect material that's been
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1 copied from our sites and posted elsewhere.
2 So I have gotten pretty good at being
3 able to read an article and determine is there anything
4 about that author that -- about the person who posted it
5 that gives clues to who may have done it. What I
6 noticed after examining, especially the first three,
7 speaking of -- in the exhibit tab number one, tab number
8 two, and Raise the Fist number one, is that they all had
9 similarities in the way the content was produced.
10 The sentence structure was short, choppy,
11 very direct. The paragraphs were short. They tended to
12 be negative and just bordering on slipping over into
13 name calling and use of derogatory terms, but not quite
14 there yet. So there was still a level of
15 professionalism that told me that the author was someone
16 who writes a lot of content.
17 There were not a lot of grammatical
18 errors and there was pretty tight paragraph structure.
19 So we're dealing with someone who -- who authors content
20 on a regular basis, either a writer, someone who posts
21 on the Internet regularly.
22 Also, by looking at the content, there
23 were various things I discovered that gave clues as to
24 who posted the content. Let's start with the Raise the
25 First article. This is Raise the Fist number one in the
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1 exhibit, page 45. So this particular article was posted
2 on May 6th. It was talking about events that happened
3 in a hearing in this Court on May 4th. So less than 48
4 hours after the hearing ended, this article appeared on
5 Raise the Fist.
6 Now, it's my understanding that the
7 defendant has claimed that the transcript of this
8 hearing was posted by her and picked up by others and
9 released on the Internet to create these posts. The
10 problem is, the transcript wasn't released until
11 May 18th, certified by Monica Willenburg.
12 Whoever posted this content, had
13 firsthand accounts of what happened in the courtroom
14 that day. For example, and I quote, Lollar was asked if
15 she had a Ph.D., master's degree, college degree, or
16 even just a high school diploma. She proudly replied,
17 Nope. When asked where she received her many years of
18 formal training and education, she proudly stated that
19 she had no training and learned everything through trial
20 and error.
21 Nobody reading a transcript is going to
22 have that kind of first-person account information.
23 First of all, the transcript wasn't even available
24 within 48 hours. The only parties who could have posted
25 that content had to have been in the courtroom that day
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1 on May 4th.
2 The plaintiffs certainly didn't post it
3 about themselves, so that leaves the defendant as the
4 only likely party who could have posted it.
5 Q. Before we get off that subject, do you see
6 the -- the picture on page 46, it says, Crazy Bat Lady
7 A. I do.
8 Q. And it's some person wearing a bat costume,
9 sort of an idiotic picture. Is -- Is that Amanda
10 Lollar, by the way
11 A. I don't believe so.
12 Q. Okay.
13 A. It doesn't look like her.
14 Q. Go ahead. You can continue.
15 A. Well, there is something interesting about
16 this article, as well, that came out this morning. The
17 text from this article, specifically paragraphs one and
18 two, were apparently copied and pasted into the e-mail
19 that was sent by the defendant to PETA. So the same
20 content that was posted here, was then copied and sent
21 in an official complaint to PETA. And the only one who
22 could have created this post, is the defendant.
23 Moving on to Indybay number one in the
24 exhibit.
25 Q. What page is that
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1 A. That will be page 001, I believe. This and
2 Indybay number two are the primary nexus of the
3 malicious content, so it was pretty important to
4 determine who had authored this and why. When I was
5 going through the content, I found a PDF that was posted
6 in conjunction with the content that is a copy of the
7 letter sent by Donald Feare, the attorney to the City of
8 Mineral Wells.
9 When that PDF was uploaded, the author --
10 or the person who copied that and created the PDF forgot
11 to clean up the properties on the PDF, and in the author
12 field of that document it plainly says Mary Cummins.
13 Once that content has been posted, the comments are
14 locked. Nobody can go in and change that, take that PDF
15 down and replace it with a different PDF. The person
16 who posted this left their name in the properties of the
17 document.
18 In addition, there is also links by
19 various pseudonyms. Now, we have established -- in
20 fact, we established earlier this morning that the
21 defendant has used pseudonyms to post content,
22 specifically speaking of the articles regarding rabies
23 that were attributed to Bat World that are in, I
24 believe, Indybay number two.
25 Well, in this case, there are additional
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1 comments made. One of them was made just last week on
2 June 6th of 2012, by a user under the pseudonym of
3 Honesty. That pseudonym comes up a lot in these posts.
4 And it speaks about information regarding the sale of
5 the Bat World building. And I quote, The City finally
6 forced them out. They sold their building January,
7 2012. The new owner had to gut the building and dump
8 Amanda Lollar's personal property into the trash.
9 This information is not available on any
10 public forum. It was obtained by a Freedom of
11 Information request by the defendant and subsequently
12 posted as a comment on this article. The only person
13 who had access to any knowledge around that would have
14 been city officials of Mineral Wells, the defendant, and
15 the plaintiff.
16 Moving on to Indybay number two.
17 Q. That's page six of the exhibit
18 A. That is page six, correct.
19 In this particular article, we also have
20 comments by Honesty who shows up again posting a PDF
21 document. In this case the author was not attributed,
22 but the producer of the PDF is the same software or the
23 same operating system platform from the first article to
24 the second, just one revision higher. So it's very
25 likely the same computer was used to produce both of
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1 those PDFs.
2 And this particular article is the one
3 that contains all the links to the YouTube videos and
4 the various Flickr content that subsequently has been
5 removed. Interestingly, the first comment includes a
6 link to the video Amanda Lollar Bat World Sanctuary MP4,
7 which points to a public website for adygil. And I
8 believe, if I'm not mistaken, in the deposition, the
9 defendant admits to giving content to adygil to post,
10 and I believe it was in specific reference to that
11 video. We find that here as the very first comment,
12 also, again, under a pseudonym.
13 In addition, more related material
14 number -- what I have as number eight, which would be in
15 here. It's the one with all the static images. That
16 would be Indybay number four.
17 Q. Which is page 22
18 A. I believe it -- I have page 12.
19 Q. Oh, okay.
20 MS. CUMMINS: Indybay four
21 THE WITNESS: I'm sorry. Indybay number
22 three. That's Indybay number three.
23 Q. (BY MR. TURNER) So page 12
24 A. Page 12, correct. So here we have comments by
25 someone calling themselves Animal Advocate with an
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1 e-mail address of mmmaryinla@hotmail.com. And
2 subsequently, the Honesty person shows up again talking
3 specifically about you, Mr. Turner, and offering you
4 search engine advice on how not to affect your own
5 search results. So whoever did that, obviously, knows a
6 little bit about search engine techniques.
7 Now, that was all part of my subjective
8 analysis. I was pretty convinced by the time I got to
9 this point that I knew who the author of the material
10 was. First of all, the PDF in 18, that alone just gives
11 it straightaway. However, I also wanted to apply some
12 more analytics to this problem and see if we couldn't
13 put some statistics against this to determine if there
14 was a way to figure out from the text itself who
15 authored the documents.
16 This is a specific discipline called
17 stylometry. And what it does -- or the purpose of it is
18 to take a body of text and break it into a bunch of
19 mathematical data points, things like word length,
20 length of sentences, number of paragraphs, number and
21 types of words used, capitalization and punctuation.
22 There is all sorts of data points that you can create
23 out of the document just from the raw text.
24 And then various statistical analysis
25 routines are run against those data points to determine
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1 similar or difference between those particular
2 documents. So in this case, we had a set of -- of
3 target or suspect material, which are the primary
4 blog -- or the Indybay, Raise the Fist articles that are
5 here, 18. I believe they are one through Raise the Fist
6 number one. So Indybay number one through Raise the
7 Fist number one.
8 So we had a set of target suspect content
9 that we were looking at. We also needed known content,
10 so content that we know a suspected author has produced.
11 To get that content I went to the Animal Advocates blog
12 and took random postings of roughly similar length and
13 content type to the suspect material.
14 But that by itself isn't sufficient.
15 Just comparing two sets of authors against the other
16 without any additional controls, doesn't give you much
17 of a test. There is no control set. So in addition, I
18 went out randomly on the web and found additional
19 authors who are known to post about animal rights. It
20 doesn't do any good to have a control set of a totally
21 different topic and genre.
22 You can't, for example, compare a
23 scientific paper against someone's personal blog post.
24 They're too different. It's apples and oranges. So I
25 needed to find content that was roughly similar. I did
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1 this randomly off several different blogs. The next
2 step is to clean up the content so that it can be
3 analyzed.
4 You have to take out things like links,
5 quotations that are known to be attributed to other
6 individuals, random white space, random punctuation,
7 those sorts of things.
8 Once all the material was cleaned up, I
9 then ran it through a computer program called JGAAP,
10 which stands for the Java Graphical Author Attribution
11 Program. This was created by Dr. Juola of Ducanes
12 University specifically to allow people who don't have
13 advanced statistical analysis experience to use
14 statistical analysis techniques to analyze and determine
15 authorship of documents.
16 The first two tests that I ran were
17 specifically recommended by the authors of the software.
18 And were, in fact, the two tests that were used in the
19 2004 authorship attribution contest to win the
20 competition. That contest was organized by Dr. Juola,
21 by the way.
22 These two tests both the -- and I'm sorry
23 for using long technical terms, but the linear
24 discriminate analysis test and the support vector
25 machine test indicated a 92 percent and 100 percent
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1 probabilty respectively that the author of the content
2 on the Indybay and Raise the Fist sites was the same
3 author of the content on the Animal Advocates website.
4 As an additional control, I also ran
5 numerous other tests. Some of which aren't known to
6 have any specific validity to the authorship analysis,
7 whereas, the linear discriminate and the support vector
8 are known to be very, or at least, as accurate as
9 possible within this discipline. Some of the other test
10 methods aren't. Some have very little validity at all,
11 and many have been primarily discarded as authorship
12 attribution techniques.
13 But as a control, I went ahead and ran 14
14 additional test batteries for a total of 84 individual
15 tests. And that produced a 71 percent probabilty that
16 the author of the content -- of the content was, in
17 fact, the defendant.
18 Q. Mr. Shupps, in your opinion, do you have an
19 opinion as to whether or not Mary Cummins authored the
20 content in Exhibit 18
21 A. I'm convinced from my analysis that Indybay
22 number one in Exhibit 18, Indybay number two, Indybay
23 number three, Indybay number five, and Raise the Fist
24 number one were all authored by the defendant.
25 Q. Okay. Is there anything else that you think
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1 would be helpful to the Court in understanding the
2 analysis you did in this case
3 A. I think the important factor to remember here
4 is not just who did it, but why and the manner in which
5 they did it. The individual responsible is very
6 familiar with how to influence search rank results.
7 They knew that by posting this content in specific
8 places, it would get distributed elsewhere and have an
9 impact on the negative result rankings of Bat World.
10 There was no question about that or that that was the
11 intent of the content.
12 Normally, if you're -- two of us are
13 having a dispute in -- on the Internet, typically known
14 as a flame war, between each other, we will keep our
15 content to our respective known and owned sites. So for
16 example, if you and I are arguing about a particular
17 topic, you will post information on your blog, I will
18 post it on my blog. We might also post it on our social
19 sites. But that's typically kept between two known
20 parties.
21 The only purpose of posting this content
22 outside of the known parties in this case was to affect
23 search results and increase link density for the number
24 of articles pointing -- that were pointed to from these
25 various sources and pointing back to this content and
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1 the search relevance for those content. It was a
2 malicious campaign to affect the online reputation of
3 Bat World.
4 MR. TURNER: Thank you. Pass the
5 witness.
6 CROSS-EXAMINATION
7 BY MS. CUMMINS:
8 Q. I took a look at your resume, and it states
9 that you are basically an expert in Share Point software
10 also in fine whiskey and beer. I did not see --
11 THE REPORTER: And also what --
12 Q. (BY MS. CUMMINS) Fine whiskey and beer.
13 I did not see in your resume that you
14 have been an expert witness when it comes to authorship
15 analysis. Have you ever given expert witness testimony
16 in a court of law
17 A. First of all, it doesn't say beer or whiskey
18 on my resume any where. That was picked up from a
19 social media site. Second of all, no, I have not
20 testified as an expert witness.
21 Q. Do you believe that you are an expert witness
22 when it comes to the analysis of authorship
23 A. Oh, in this case, I certainly do. I spent a
24 lot of time looking for material on other websites
25 that's been picked up from my own and from my
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1 associates.
2 Q. Have you ever been an expert witness in
3 deposition for authorship
4 A. No.
5 Q. Have you ever been an expert witness for
6 authorship before
7 A. No.
8 Q. So this is your first time
9 A. Yes.
10 Q. Okay. Now, you stated that you took articles
11 from my blogs and used them as my own articles
12 A. That is correct.
13 Q. So you believe every word that is written in
14 my blogs I wrote it personally
15 A. The materials on blog sites, first of all, had
16 your name appended to it and it appeared on your
17 websites, so you're responsible for it in one fashion or
18 another. In addition a number of your articles that I
19 took, mentioned where you were at specific events in Los
20 Angeles, and there is no question that you were the
21 individual that wrote the content.
22 Q. You don't think it's possible that there are a
23 few people who take care of my blog and we all write
24 articles
25 A. Of course, it's possible, but they weren't at
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1 the events that you claim to be at in Los Angeles. If
2 you claim to be at an event, and then you wrote on your
3 blog that you were at that event and you published it,
4 you wrote it.
5 Q. Which article are you talking about
6 A. So, in specific, in the control material were
7 you or were you not involved in the West Holiday ban on
8 the sale of fur
9 Q. Yes, I was one of many people.
10 A. Okay. And then was subsequently written on
11 your blog post, whom else from Animal Advocates was
12 at --
13 THE WITNESS: I'm sorry, Your Honor. I
14 don't know if I'm allowed to ask questions.
15 THE COURT: You're not. You're to
16 respond to the questions Ms. Cummins asks you.
17 Q. (BY MS. CUMMINS) So you don't feel that --
18 What is the name of the blog where you took the
19 articles
20 A. That is your
21 animaladvocateswildliferehabilitation.blogspot.com.
22 Q. Okay. It doesn't say Mary Cummins' blog, does
23 it
24 A. It says Mary Cummins all over the blog.
25 Q. But it doesn't say this is Mary Cummins' blog
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1 A. It -- On nearly every post it says Mary
2 Cummins Animal Advocates.
3 Q. Isn't the blog Animal Advocates
4 A. Yes.
5 Q. Okay. Do I have any personal blogs
6 A. I believe you do. I believe you have several.
7 Q. Why didn't you use the articles from Mary
8 Cummins' blog
9 A. These were selected just simply at random
10 based on length of content and type of material. I
11 certainly could have used those.
12 Q. But you didn't, why not
13 A. Because it was random.
14 Q. You randomly used only articles from Animal
15 Advocates blog
16 A. They were of similar length and content type
17 to the questionable material, therefore, they matched in
18 terms of what we would want to use for a subjective
19 analysis. If, for example, I looked on the Mary
20 Cummins' blog and the postings were very short with lots
21 of video and image content, that's not a subjective
22 textual analysis. It's not useful in this scenario.
23 Q. Is it -- Are you 100 percent positive that I
24 wrote every single word and every single article that
25 you used in the control as my articles
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1 A. No.
2 Q. Okay. So you're not positive that I actually
3 wrote those articles
4 A. I am convinced that the majority of the
5 content came from you.
6 Q. In the articles, aren't other people quoted in
7 the articles
8 A. Indeed. And those quotes were removed before
9 the analysis was performed.
10 Q. Is it possible that other information was
11 taken and copied and pasted from somewhere else and just
12 put in there
13 A. In -- Of course, it's possible. In these
14 particular posts, there is very little cutting --
15 apparent cutting and pasting in these posts. The
16 majority appears to be firsthand accounts, part of the
17 reason they were selected.
18 Q. In the -- In the article, Stingray Being
19 Debarbed at Seal Beach, wasn't there was a long e-mail
20 from a Fish and Game biologist included in it
21 A. There was. It was removed.
22 Q. Did you download this software from the
23 Internet
24 A. I did.
25 Q. Where did you download it from
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1 A. From the JGAAP wiki site.
2 Q. Did you take a look at the frequently asked
3 questions list
4 A. I did.
5 Q. Do you believe that --
6 MS. CUMMINS: Well, I would like to
7 submit into evidence Defendant's Exhibit 1.
8 Oops. And this is the copy from the
9 Internet of the frequently asked questions list from the
10 website where the software is downloaded.
11 Q. (BY MS. CUMMINS) Now, I want you to go to
12 page two.
13 THE COURT: Ms. Cummins, you have handed
14 me Defendant's Exhibit Number 1.
15 MS. CUMMINS: Yes.
16 THE COURT: What was your purpose for
17 handing this to me
18 MS. CUMMINS: Because I wanted to show it
19 to him. I thought I had to submit it to show it to him.
20 Q. (BY MS. CUMMINS) If you could please go to
21 page two and the question that says -- I mean, the
22 paragraph that goes, Hang on. It just said that
23 Christopher Marlowe wrote in my address book. I know
24 that's wrong.
25 Have you read that paragraph
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1 A. I have, yes.
2 Q. So you -- you realize that JGAAP only does
3 close class attributions, correct
4 A. That is correct.
5 Q. So that means if you didn't give them my name
6 as a possible author, it wouldn't have chosen me,
7 correct
8 A. It would have chosen the most likely match
9 based on the control set. The control set included not
10 only your material, but also material from others. So
11 out of the selected material, which included animal
12 rights blogs of a similar vein to the suspect content,
13 out of four authors, it selected you.
14 Q. I would like you to read right under where it
15 says, Hang on. It just said that Christopher Marlowe
16 wrote in my address book. I would like you to read --
17 can you read the paragraph under that
18 A. The one that begins, Yeah
19 Q. Yeah.
20 A. Yeah.
21 MR. TURNER: Well, Your Honor, I'm going
22 to object. This is hearsay. It's somebody saying
23 something about software. That person is not here for
24 me to cross-examine.
25 THE COURT: Sustained.
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1 Q. (BY MS. CUMMINS) Well, then let me ask you a
2 question: If you were to give this software program the
3 possible authors of Groucho, Chico, and Harpo Marx and
4 then you gave it a copy of Moby Dick, and asked them
5 which Marx Brothers wrote it, would it have to pick one
6 of the Marx Brothers
7 A. Yes, it would. That's what close class
8 attribution is all about.
9 Q. So this isn't a way to positively I.D. who
10 truly wrote something, because we know that the Marx
11 Brothers didn't write Moby Dick
12 A. We do. It's only as good as the valid control
13 set. If the valid control set contains no documents
14 that are anywhere close or have sufficient similarities
15 to the target document, it's going to pick the most
16 likely match and give it a confidence level.
17 In this case the two primary algorithms,
18 which have been shown to be very, very efficient at
19 identity authorship, LVA and SVM, both selected one with
20 92 percent confidence, the other with a hundred percent
21 confidence the author of the material.
22 Q. Is there anyway that you can know for certain
23 that the articles which were placed on the Animal
24 Advocates blog were written only by one person
25 A. I believe you have already asked me that
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1 question. The articles were selected primarily because
2 they appeared to come from one individual.
3 Q. Isn't it possible that theoretically I could
4 have written an article and then I gave it to a friend
5 to review it and they checked it out, and then I gave it
6 to another friend to look at it and they added something
7 else, and then I gave it another person and they cut
8 something else out. You would then have four people who
9 would have contributed to that article, correct
10 A. Correct.
11 Q. So wouldn't it be possible if I were to have
12 written an article, that four other people could have
13 coauthored it
14 A. Oh, it's certainly possible. And it also
15 would have resulted in a lower confidence score on the
16 attribution of the content.
17 Q. But what -- Well, anyway.
18 Now, isn't this software not supposed to
19 be used when there are multiple authors
20 A. The software makes no determination about the
21 number of contributing authors to a document. The
22 example given by the authors of the software themselves
23 is the Federalist papers. A number of them -- Hear me
24 out.
25 A number of them were known to have been
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1 created by individuals, some of them were known to have
2 been created by multiple individuals. For example, when
3 Jefferson and Madison were collaborating in those cases,
4 LVA and SVM were able to identify the most prominent
5 author in the document.
6 So, yes, it can handle multiple author
7 scenarios, however, it is most effective when your
8 target and your control set both consist of specific
9 authors.
10 Q. Have you read all the guidelines and the --
11 the legal release on this software program when it can
12 be used, when it can't be used, can it be used in a
13 court of law
14 A. There is no determination made as to whether
15 it can or cannot be used in a court of law. There is
16 instances where it may be more appropriate than another,
17 and I understand that Dr. Juola is not a big fan of
18 using JGAAP for court cases, but other analysts,
19 especially those who won the competition in 2004, are
20 known expert witnesses who use these same techniques.
21 Q. So you're just saying that the person who
22 wrote this software doesn't recommend it for --
23 A. Actually, Dr. Juola did not write the
24 software, he chaired the team that wrote the software.
25 Dr. Juola is a known expert in stylometry.
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1 Q. Okay. So a known expert in stylometry just
2 stated that he doesn't believe this should be used in
3 court cases
4 A. The same expert that came in number four in
5 his own competition, yes.
6 Q. My question -- Okay. So he did -- An expert
7 stated that this should not be used in court cases
8 A. No. He stated that it is not his preference
9 to use software. He uses his on subjective analysis
10 techniques. Let's clarify something. All the software
11 does is make it easy for those who of us who don't live
12 within statistical analysis day by day to use those same
13 statistic analysis techniques on our own computers.
14 It doesn't make us experts, nor does it
15 bring the expert into our computer, but it does allow us
16 to use the same means that they use on a day-to-day
17 basis.
18 Q. So you just stated that you're not an expert
19 A. I believe I have maintained that all along.
20 Yes.
21 Q. Okay. And also, you stated that this software
22 is for people who are not experts in statistics
23 A. Correct.
24 Q. Okay.
25 A. That doesn't invalidate the statistical
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1 techniques.
2 Q. Do you realize that this software is a beta
3 software
4 A. Of course, yes.
5 Q. Has anyone -- Have you read any where that
6 JGAAP is not intended as a final product to be used in
7 court cases
8 A. I'm sure that's likely been published as an
9 opinion.
10 Q. You stated earlier that someone posted one
11 article in Indybay and then someone else reposted it on
12 Raise the Fist. Did you state that
13 A. There -- There are incidents of that. Yes.
14 Q. Do you have any knowledge that Raise the Fist
15 has its own robot where it pulls content from Indybay
16 A. Correct.
17 Q. Okay. So if someone were to post something on
18 Indybay, the Raise the Fist robot would take it and
19 repost it
20 A. In the article that you're referring to is the
21 one that was made on May 6th before the transcript of
22 the hearing was released.
23 Q. Isn't it possible that I wrote my own
24 transcript from notes at the hearing and I posted that
25 on my own website and someone else picked that up
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1 A. The article doesn't appear on your website
2 before May 6th.
3 Q. The article is not on my website. I'm talking
4 about --
5 A. So it -- I feel I should point out that she
6 just asked me if it was possible it was posted to her
7 own website first and then syndicated, and then said it
8 was not posted her own website first.
9 Q. That is not what I stated. I'm talking about
10 you stated that it would be impossible for someone to
11 have the transcript because it wasn't printed yet,
12 correct
13 A. Correct.
14 Q. Isn't it possible that I'm taking notes here
15 and I go home and I write down what was said today, and
16 I load that up to my Animal Advocates website and
17 someone else picks it up from there and adds it to an
18 article somewhere else
19 A. It's possible, but that didn't happen in this
20 case. The article wasn't posted on the Animal Advocates
21 website first, number one. Number two, just because it
22 gets picked by another website doesn't make you --
23 doesn't resolve -- absolve responsibility for the
24 original content. It's all part of the Google bomb
25 strategy. In fact, that plays into exactly what was
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1 trying to be achieved here.
2 Q. Let me ask a question. This is my question
3 specifically: Is it possible that I went to a hearing
4 and I went home and I wrote some notes which were my
5 personal notes of what happened and I loaded that up
6 onto my Animal Advocates website Isn't it possible
7 someone else that I don't even know went to my Animal
8 Advocates website, saw the transcript that I wrote
9 myself, they then took that and wrote an article and
10 posted it somewhere else
11 A. It's possible. It didn't happen in this case,
12 but, yes, it's possible.
13 Q. How can you prove that didn't happen
14 A. Because the content did not appear on the
15 Animal Advocates website before May 6th. The only --
16 Q. The transcript
17 A. The content that we're speaking of that came
18 from first-person accounts within this courtroom during
19 the hearing did not appear on the Animal Advocates
20 website before May 6th.
21 Q. Do you have proof
22 A. Its first appearance is on -- It's not there.
23 It's not dated there. I would like to see proof that it
24 was posted there first and not to Indybay or Raise the
25 Fist.
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1 Q. You don't -- Okay. Do you have absolute proof
2 right now with you that I did not post the minutes -- my
3 own minutes from the hearing after the hearing myself on
4 my Animal Advocates blog
5 A. No.
6 Q. Okay. Earlier you stated that if you search
7 for Google -- I mean, Randy Turner you get a photo of
8 the skunk butt. Number one, is that true
9 A. That was stated by others in the courtroom
10 this morning, not by myself. I simply referred to the
11 earlier testimony.
12 Q. So who said that if you search for Randy
13 Turner on Google, your number one hit would be a skunk
14 butt
15 A. I believe that was mentioned earlier, by -- it
16 may have been mentioned by either yourself or
17 Mr. Turner.
18 Q. Were you here -- Were you here
19 A. I was here.
20 Q. So didn't I say that if you searched for Randy
21 Turner Texas attorney you will see a photo of my skunk's
22 butt on the seventh page, which is 70 items deep
23 A. That may be true now. At one time it may have
24 been the very first hit, especially right after it was
25 first posted.
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1 Q. Do you --
2 A. And in any event, those are just Google
3 results. What about Bing and Yahoo and the other search
4 engines The search rank isn't going to be the same
5 between those. It may show up higher on others than it
6 does on one.
7 Q. I'm only asking you about Google. Are you
8 telling me right now if you search for Randy Turner on
9 Google, you're going to get a photo of my skunk's
10 butt --
11 A. First of all, my analysis was not on a picture
12 of a skunk's rear end. My analysis was on the content
13 that was posted to Indybay, Raise the Fist, and the
14 other blog sites as we have been speaking about.
15 Q. Okay. You stated earlier that Facebook and
16 Twitter are anonymous; is that true
17 A. I did not state any such thing.
18 Q. You didn't state that
19 A. No. You can, however, be anonymous on both
20 sites. Neither Facebook nor Twitter has any
21 authentication to verify your identity when you create
22 an account.
23 Q. Earlier you stated that there are auto
24 crawlers, which are robots which pick up content and
25 repost it, correct
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1 A. Of course.
2 Q. So, isn't it possible if anyone were to post
3 any article, even about gardening on a blog or other
4 website, then an auto crawler robot would pick it up and
5 repost it
6 A. That's the point. That's how you create a
7 Google bomb by creating negative content that you know
8 is going to be picked up by the crawlers and the other
9 engines and distributed around the Internet. That's the
10 entire purpose.
11 Q. Okay. Back to -- earlier you said that there
12 was a PDF of a letter from attorney Donald Feare
13 A. Uh-huh.
14 Q. And the authorship had my name
15 A. Uh-huh.
16 Q. Correct
17 A. I am looking at it right here.
18 Q. Okay. Now, didn't I load the PDF of the
19 letter from Donald Feare into my website
20 A. I don't know. This particular PDF was on the
21 Indybay number one article under a pseudonym.
22 Q. Okay. Let me ask you a question: I loaded up
23 a PDF of an -- of an attorney's letter from Donald Feare
24 to my website and it has me as the author, isn't it
25 possible for someone else to go there, download that
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1 PDF, and load it up somewhere else The author stays
2 the same
3 A. Within 40 minutes of the original post, I
4 seriously doubt it.
5 Q. And how do you know when I posted the original
6 letter from Donald Feare on my Animal Advocates site
7 A. I'm not concerned about whether or not it was
8 posted on your Animal Advocates site. I'm talking about
9 the Indybay article that includes a PDF that is -- that
10 you have claimed you did not produce this article and
11 yet the PDF has your name in the properties. It's still
12 there today.
13 Q. Yes. I loaded up a PDF of the letter. It has
14 me as the author. I didn't change it. I put it up on
15 my website. Okay. Can't someone go and download my
16 file and still have my name in it and then they can post
17 it somewhere else, it doesn't necessarily -- doesn't
18 mean that I posted it somewhere else
19 A. And the odds of that happening within 40
20 minutes of the original production of this article on
21 the uploading of the PDF and it not be you or someone
22 related to you are almost nil.
23 Q. Okay. Well, that doesn't make any sense. But
24 let's say someone went to my website and they downloaded
25 a PDF and they downloaded some JPEGS and they downloaded
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1 some text and then they went and they posted an article
2 on Indybay and they instantly posted all these other
3 things. Isn't that possible
4 A. Certainly possible.
5 Q. So it doesn't mean that I definitely, 100
6 percent posted that
7 A. Possible and probably are two entirely
8 different things.
9 Q. Can you prove -- do you have proof that I --
10 In fact, didn't you state earlier that there is no way
11 to prove who wrote the articles on Indybay or Raise the
12 Fist
13 A. There is enough evidence within the articles
14 themselves and after the statistical analysis to give me
15 a high level of confidence as to who the author is.
16 Q. Again, do you have some physical proof or
17 evidence that can prove beyond a shadow of a doubt that
18 I absolutely wrote and posted those articles on Indybay
19 A. There is no evidence that would exist to that.
20 It could have been done from any Starbucks. You can't
21 trace it back to an IP because of the nature of these
22 sites, they don't verify identity.
23 In order to arrive at the author, you
24 have to perform the type of analysis that I performed.
25 Is it a hundred percent guaranteed Absolutely not. Do
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1 I have a high level of confidence that I know who the
2 author of this material is Yes, I do.
3 Q. Okay. Earlier you stated that someone posted
4 on -- I don't know if it was Indybay or Raise the Fist,
5 paraphrase, that the City forced Amanda out and they
6 threw away her stuff
7 A. That was a comment made on Indybay article
8 number two -- Indybay article number one made last week
9 on June 6th.
10 Q. Isn't it possible that I posted on my Animal
11 Advocates site a copy of the e-mail from the City and to
12 the City stating these things, someone went to my
13 website, they saw what I posted, they copied it and they
14 posted it somewhere else
15 A. So the -- the question, if I understand it is:
16 Is there a shadowy person out there who happens to be
17 monitoring your site, the Indybay site, the Raise the
18 Fist site, the L.A. Animal Watch blog site, the Working
19 to Help Animals Today and Tomorrow site, who is
20 monitoring all of these sites and then who's going and
21 taking material that is always negative to Bat World and
22 always positive to Animal Advocates and Mary Cummins and
23 going and posting all this material The likelihood
24 that there is an individual like that out there other
25 than yourself, nil.
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1 Q. You don't believe that it's possible that
2 there are quite a few people that don't like Ms. Lollar
3 or Bat World Sanctuary
4 A. As near as I can find, the only primary
5 negative content about Bat World Sanctuary comes from
6 yourself and those who are affiliated with you.
7 Q. So do you absolutely have proof that there is
8 no one else out there who dislikes Amanda Lollar or Bat
9 World
10 A. I don't -- I don't believe that I'm here to
11 provide 100 percent conclusive truth. I'm testifying as
12 an expert witness that it is my opinion based on the
13 evidence in front of me that I know who the author of
14 this content is.
15 Q. You posted -- You stated that someone made a
16 post and then they signed it with mmmary@hotmail.com,
17 correct
18 A. Correct.
19 Q. And you state that that meant that I posted
20 that
21 A. No. It doesn't mean that you posted it. It's
22 a bit of circumstantial evidence that all leads back to
23 determining who the author is. If -- They're all
24 pseudonyms.
25 Q. Is that my e-mail address
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1 A. I have no idea, but if I recall during the
2 deposition, wasn't there an e-mail address given of --
3 of mmmaryinla@aol.com, or something similar that is
4 attributed to you
5 Q. Do you know for certain that this is my e-mail
6 address
7 A. No. And I'm not claiming that by itself -- in
8 and of itself claims that you were the author of that
9 content. In fact, here is what I can say about that
10 particular post. It appears to be by the same author of
11 the Working to Help Animals Today and Tomorrow blog.
12 This is the most vicious content that is posted online
13 about Amanda Lollar. It always includes swear words and
14 very derogatory remarks. It's very similar in content.
15 Q. Isn't the How to Help Animals Today -- Working
16 to Help Animals Today -- whatever the rest of it is,
17 isn't the author's name right on the front page of that
18 blog
19 A. No, it's not.
20 Q. Isn't there an author's name
21 A. No, it's not. The author specifically states
22 that they had to go, quote, unquote, underground to
23 escape persecution.
24 Q. Do you believe I am the author of that blog
25 A. I don't have -- First of all, I have not
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1 investigated that. I don't have any proof, and I'm not
2 claiming that you're the author of that blog. What I do
3 know is that the material that I'm convinced that you
4 authored was distributed to that blog as a way of
5 increasing link density and effecting the results
6 against Bat World.
7 Q. Let me ask you specifically. Do you believe I
8 posted on Working to Help Animals blog
9 A. Oh, I do. In fact, I believe you made a
10 comment on that blog on May 8th of 2011, that was then
11 elevated into a full blog post using material copied
12 from Indybay -- it would have been Indybay number one or
13 number two.
14 Q. A few last questions. You stated earlier that
15 this is the first time you've been an expert witness in
16 a court of law, correct
17 A. Correct.
18 Q. How many other times have you done authorship
19 analysis of online content How many other reports have
20 you done for clients for pay
21 A. For clients for pay. None.
22 Q. So this is the first time you've done one of
23 these for a client, and it's the first time you've been
24 an expert witness in court, correct
25 A. That is correct. That does not mean it's the
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1 first analysis that I have performed, it simply happens
2 to be the first one I've performed specifically for
3 another party in a legal context.
4 Q. And just so we're clear, are you 100 percent
5 certain that I wrote all of the blogs in Animal
6 Advocates that you used that you attributed to me
7 A. No.
8 Q. Okay. So you -- have you ever heard of the
9 term garbage in, garbage out
10 A. I'm very familiar with that term.
11 Q. So let's say all of the blog posts in Animals
12 Advocates that you used were not written by me, they
13 were written by my colleagues and other people who
14 control the blogs, and then you then compared that to
15 the other Indybay articles and Raise the Fist. Would
16 you be able to ascertain that I was the author based on
17 that
18 A. So I believe that the inference is that very
19 little of the material on the Animal Advocates blog was
20 written by yourself and that most of it is written by
21 somebody else I don't believe that to be the case,
22 number one. Number two, that was only part of the
23 analysis, analyzing that material against the suspect
24 material in an analytical context. I was convinced who
25 the author -- who had authored those posts before I
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1 fired up JGAAP and started doing the statistical
2 analysis.
3 Q. So before you even used any software, your gut
4 feeling was that I wrote those articles
5 A. It's not a gut feeling. It's based on my
6 years of experience in analyzing content and determining
7 authorship specifically of blog related content.
8 Q. Have you looked at quite a few of my posts on
9 Animal Advocates blog
10 A. I have. I can't say that I've done an
11 exhaustive reading of your site.
12 Q. Have you noticed that I repost all of
13 California Fish and Game's press releases
14 A. Okay.
15 Q. And I repost other peoples' articles and other
16 press releases. Have you seen that
17 A. Yes. Those are fairly obvious when they
18 happen.
19 Q. Okay. So you're telling me that you're not
20 100 percent positive that I write everything on Animal
21 Advocates
22 A. What I'm telling you is that I selected
23 material for comparison that was, number one, very
24 obviously written by a single individual. Number two,
25 that was similar in tone and context to the suspect
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1 material. And, number three, that had a source of
2 attribution, in this case the Animal Advocates website.
3 MS. CUMMINS: No further -- I will pass
4 the -- No further questions.
5 MR. TURNER: I have no further questions.
6 May this witness be excused
7 THE COURT: Mr. Shupps, give me
8 Defendant's Number 1.
9 THE WITNESS: There.
10 THE COURT: You may be excused,
11 Mr. Shupps.
12 THE WITNESS: Thank you.
13 (End of requested excerpt.)
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1
2 STATE OF TEXAS )
3 COUNTY OF TARRANT )
4
5 I, Carolyn Hawks-Gayaldo, Deputy Official Reporter
6 in and for the 352nd District Court of Tarrant County,
7 State of Texas, do hereby certify that the above and
8 foregoing contains a true and correct transcription of
9 all portions of evidence and other proceedings requested
10 in writing by counsel for the parties to be included in
11 this volume of the Reporter's Record in the above-styled
12 and numbered cause, all of which occurred in open court
13 or in chambers and were reported by me.
14 I further certify that this Reporter's Record of
15 the proceedings truly and correctly reflects the
16 exhibits, if any, admitted by the respective parties.
17 I further certify that the total cost for the
18 preparation of this Reporter's Record is $478.50 and
19 has been paid by Plaintiffs.
20
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1
2 WITNESS MY OFFICIAL HAND on this the 19th day of
3 June, 2012.
4 /s/Carolyn H. Gayaldo
CAROLYN H. GAYALDO CSR 7181
5 EXPIRATION DATE 12/31/13
Deputy Official Court Reporter
6 352nd District Court
Tarrant County, Texas
7 Allied Court Reporters
5208 Airport Freeway, Suite 105
8 Fort Worth, Texas 76117
(817) 335-5568
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1
2 REPORTER'S RECORD
3 CAUSE NO. 352-248169-10
4 BAT WORLD SANCTUARY, ET AL.* IN THE DISTRICT COURT
*
5 *
VS. * 352ND DISTRICT COURT
6 *
*
7 *
MARY CUMMINS * TARRANT COUNTY, TEXAS
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10 ****************************************
11 EXCERPT ON TRIAL ON MERITS
12 ****************************************
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18 On the 14th day of June, 2012, the following
19 proceedings came on to be heard in the above-entitled
20 and numbered cause before the Honorable William Brigham,
21 Judge Presiding, held in Tarrant County, Texas.
22 Proceedings reported by machine shorthand.
23 CAROLYN H. GAYALDO, CSR
Deputy Official Reporter
24 352nd District Court
Tarrant County, Texas
25
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1
2 A P P E A R A N C E S
3 Attorney for Plaintiffs:
4 Mr. Randal E. Turner
SBOT NO. 20328310
5 TURNER & McKENZIE, PC
1800 Norwood Road, Suite 100
6 Hurst, Texas 76054
(817) 282-3868
7 (817) 282-1563 Fax
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8 Attorney for Defendant:
9 Ms. Mary Cummins, Pro Se
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1
2 INDEX
3 EXCERPT OF TRIAL ON MERITS
4 June 14, 2012 Page
5 Appearances.................................... 2
6 Beginning of Requested Excerpt................. 4
7 Order of Court................................. 4
8 End of Requested Excerpt....................... 5
9 Reporter's Certificate......................... 6
10 EXHIBITS
11 EXHIBIT
12 NO. DESCRIPTION OFFERED ADMITTED
13 None
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1 BEGINNING OF REQUESTED EXCERPT
2 (June 14, 2012, 10:35 a.m.)
3 THE COURT: The evidence is complete.
4 The summation is complete. There will be no more
5 evidence and no more summation. The Court is about to
6 rule.
7 In this case, the Court is of the opinion
8 that plaintiff is entitled to recover. I think the
9 plaintiff has clearly proven that a defamation in this
10 case was egregious as well as malicious as well as
11 intentional. I think that Amanda Lollar, the plaintiff
12 in this case, had a worldwide reputation in the proper
13 care of bats similar to that of Jan Goodall in the care
14 of primates. Jan Goodall went to Africa to find
15 primates.
16 Amanda Lollar in Palo Pinto County,
17 Texas, where it probably has maybe one of largest
18 concentration of bats in Texas, at least, maybe Austin
19 has a few more. I don't know. The concentration of
20 bats in the old Crazy Well Hotel, now known as the Baker
21 Hotel that shut the Crazy Well Hotel down years ago, the
22 bats have been there forever. The Court finds that the
23 defendant did, in fact, sign the contract proven by
24 excellent expert testimony point after point after
25 point.
ALLIED REPORTERS * (817) 335-5568 * (800) 562-7055

5
1 So, Mr. Turner, if you will prepare a
2 final judgment in this case and mail a copy of it to the
3 defendant, Mary Cummins, at
4 Los Angeles, California , and
5 in that final judgment compensatory damages of
6 $3 million; exemplary damages of an additional
7 $3 million; a permanent injunction on items Plaintiffs'
8 17 and 18; liquidated damages and then attorney fees of
9 $176,700.
10 Mail it to her for her review. Her
11 signature is not necessary. Upon proper submission, it
12 will be signed by the Court. Thank you. We will stand
13 in recess.
14 MR. TURNER: Thank you, Your Honor.
15 (End of requested excerpt.)
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ALLIED REPORTERS * (817) 335-5568 * (800) 562-7055

6
1 STATE OF TEXAS )
2 COUNTY OF TARRANT )
3
4 I, Carolyn Hawks-Gayaldo, Deputy Official Reporter
5 in and for the 352nd District Court of Tarrant County,
6 State of Texas, do hereby certify that the above and
7 foregoing contains a true and correct transcription of
8 all portions of evidence and other proceedings requested
9 in writing by counsel for the parties to be included in
10 this volume of the Reporter's Record in the above-styled
11 and numbered cause, all of which occurred in open court
12 or in chambers and were reported by me.
13 I further certify that this Reporter's Record of
14 the proceedings truly and correctly reflects the
15 exhibits, if any, admitted by the respective parties.
16 I further certify that the total cost for the
17 preparation of this Reporter's Record is $50.00 and has
18 been paid by Plaintiffs.
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ALLIED REPORTERS * (817) 335-5568 * (800) 562-7055

7
1
2 WITNESS MY OFFICIAL HAND on this the 14th day of
3 June, 2012.
4 /s/Carolyn H. Gayaldo
CAROLYN H. GAYALDO CSR 7181
5 EXPIRATION DATE 12/31/13
Deputy Official Court Reporter
6 352nd District Court
Tarrant County, Texas
7 Allied Court Reporters
5208 Airport Freeway, Suite 105
8 Fort Worth, Texas 76117
(817) 335-5568
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ALLIED REPORTERS * (817) 335-5568 * (800) 562-7055

..
Fm:Balley & Galyen Attorneys To:Bat J.lorld sanctuary and lUanda Lollar v. Mary c (18178502328) 16:01 07/11/12 EST Pg 4-9
CAUSE NO. 352-248169-10
BAT WORLD SANCTUARY and
AMANDA LOLLAR
Plaintiffs,
v.
MARY CUMMINS,
Defendant
§
§
§
§
§
§
§
§
IN THE DISTRICT COURT
OF TARRANT COUNTY, TEXAS
352Nn JUDICIAL DISTRICT
JUDGMENT
ON the 11 1 h day of June this cause came on to be heard. Amanda Lollar, Plaintiff whose last
three digits of her Texas driver's license number are 000, appeared in person and by her attorney
and announced ready for trial. Bat World Sanctuary, Plaintiff, appeared by and through its
attorney and announced ready for trial. Mary Cummins, Defendant whose last three digits of her
California driver's license number are 781 appeared pro se and armounced ready for trial. No
jury having been demanded, all questions of fact were submitted to the Court.
After hearing the evidence and arguments of counsel and the defendant the Court finds that
the plaintiffs, Amanda Lollar and Bat World Sanctuary, are entitled to recover from the
defendant, Mary Cummins.
IT IS THEREFORE ORDERED that Amanda Lollar recover from Mary Cummins actual
damages in the amount of THREE MILLION DOLLARS ($3,000,000.00).
IT IS FURTHER ORDERED that Amanda Lollar recover from Mary Cummins exemplary
damages in the amount of THREE MILLION DOLLARS ($3,000,000.00).
IT IS FURTHER ORDERED that Bat World Sanctuary recover from Mary Cummins actual
damages in the amount ofTEN THOUSAND DOLLARS ($10,000.00).
I'J' IS FURTHER ORDERED that Bat World Sanctuary recover from Mary Cummins
attorney's fees in the amount of ONE HUNDRED SEVENTY SIX THOUSAND SEVEN
HUNDRED DOLLARS ($176,700.00).
IT IS ORDERED that Mary Cummins be permanently enjoined and she is ORDERED to
immediately and permanently r~zove from the internet the following statement~ which currently
appear at http://www.animalad{ocates.us/batWorldLawsuit/:
l. They breed animals in tl~e facility.
4 of 9 711112012 2:59:34 PM [Central Daylight Time]
\
~ \ ~ i{fj~
Court's ~iin~es
TransactiOn·'--""--

fi:Bailey & Galyen Attorneys To:Bat llorld Sanctuary and linanda Lollar v. Mary c (18178502928) 16:02 07/11/12 EST Pg 5-9
2. Pretty ironic for this group to certify Bat World Sanctuary when the health department
told her to leave town and they had to gut the building and remove her belongings.
3. Vet recommended blood and stool tests. Lollar declined. She just wants empirical
therapy. It that doesn't work, she wants to euth the dog. She refused treatment. When I
was at Bat World June 19, 2010 to June 28,2010 I saw her use her fingers to pull out one
of the dog's teeth, i.e. oral surgery on dogs.
4. The current method she suggests is also inhumane. The bats die of suffocation. She also
forgets to mention that the drugs she suggests must be used under the direction of a
veterinarian. She doesn't even administer the gas legaiJy, humanely, or safely.
5. He should not be working for free for someone who commits animal cruelty.
6. I doubt he'll be speaking about this embarrassing little case where he is actually
representing someone who commits animal cruelty and neglect.
7. She took the money that came from the dissolution of Bonnie Bradshaw's group and
bought a new silver Honda Eclipse. That money was supposed to go for animals. This is
what Lollar does with money that is given to Bat World.
8. Lollar never even washed her hands before surgery, you can see dirty finger nails in the
photos, no surgical garments, no mask, hat, nothing. Night and day.
9. Just confirmed that Amanda Lollar of Bat World Sanctuary is illegally obtaining human
and animal rabies vaccinations ... .Again, breaking the law. rm amazed she admitted to
having the vaccine and buying it when she is doing it illegally.
10. She does not state that it died from neglect of care. She also chose to euth it instead of
treating it as her vet suggested. She'd previously turned down care which her vet
suggested.
11. When I was at Bat World she told me the place where she buys her rabies vaccine thinks
she's a doctor.
12. Earlier in the year the vet noted the dog had major dental issues yet she didn't have the
vet treat them. You know how painful it would be to have a mouth full of rotten teeth
That's animal neglect.
13. BREAKING NEWS!!! Amanda Lollar of Bat World Sanctuary admits in writing that she
and Bat World Sanctuary are being forced to leave Mineral Wells because of all the
complaints to the City and Health Department.
14. The dogs rear claws are super long. There is no way she could stand .... She has to drag
herself on cement.
15. She tells people to use lsoflurane illegally, inhumanely and unsafely in her book.
5 or 9 7/1112012 2:59:34 PM [Central Daylight Time)

F1:Bailey & Galyen Rttorneys To:Bat IJorld Sanctuary and JDanda Lollar v. Mary c (18178502928) 16:02 07/11/12 EST Pg 6-9
16. He didn't care that she admitted to illegally having the human rabies vaccination,
admitted to using drugs not according to the label or that she "proudly" admitted to
performing surgery.
17. In the video Lollar takes tweezers and just pulls out the molars of a conscious bat that is
fighting and biting her while it bleeds. Lollar is proud of this and posted this video in her
book and online. Bat experts know that bats must be unconscious and intubated to
remove molars. Can you imagine the pain that bat felt
18. Pulling molars out of conscious bats is not "cutting-edge" though cutting open conscious
bats might fall into that "category." Operating on bats using the drop anesthesia technique
or amputating wings instead of pinning them is also not cutting edge but cave man
veterinary practice.
19. Lollar is exposing people to rabies by not checking their cards.
20. Her recent story about the episiotomy at the depo was that, that was not the bat's vagina
and uterus being pulled out. It was the "placenta separating." It clearly was not.
21. She'd already yanked out the placenta which is what helped cause the prolapse, besides
cutting way too much and pulling too hard. She really needs to get her vision checked.
Someone with very bad vision is the last person who should be slicing into micro bats.
22. Yeah, I look like crap in the videos but at least there are no videos of me hacking an
animal to death.
23. She's been breeding her bats illegally. She's committing fraud asking for money for a
project she cannot and will not do.
24. She said she would use the bag for the trip then return it to Walmart for a refund. She
admitted to me with an evil laugh that she does this frequently.
25. Rabies complaint against Bat World Sanctuary. General sanitation laws, harboring high
risk rabies animals, allowing them in downtown.
26. Amanda Lollar and her buildings have been written up so many times for building
violations, safety issues, rabies, histoplasmosis, no address, unsightly building, build up
of guano 6-8 feet. .. People have been reporting her smelly building and rabid bats for
over 15 years.
27. She's basically experimenting on bats. The bats are dying because she doesn't take them
to the vet. That's okay because she can just go get more bats.
28. Amanda Lollar of Bat World Sanctuary found guilty of illegally breeding bats at her
facility. It is a violation of her permit
0 of9 7/11/2012 2:59;34 PM [Central Daylight Time)

fi:Balley & Galyen Attorneys To:Bat IJorld Sanctuary and ~Banda Lollar v. Mary c (18178502928) 16:03 07/11/12 EST Pg 7-9
29. Amanda Lollar of Bat World Sanctuary is now sending threats of extortion from Mineral
Wells, Texas. Because she's sending it over the computer it's a Federal crime,
30. She has violated the following regulations listed on her permit. "15 a. Permit holder is
prohibited from a. Propagating, selling or bartering animals or animal remains received or
held under authority of this permit." She is allowing the bats to breed.
31. The complaints going back 18 years were about alleged animal cruelty, animal neglect,
violations of the health code and building and safety regulations.
32. The complaints stretching back 18 years were about animal cruelty, animal neglect,
violations of the health code, violations of Texas Parks & Wildlife regulations, violations
of the Animal Welfare Act, building violations and a report about a rabid bat biting a
toddler directly next door to Bat World Sanctuary.
33. Here is the disgusting photo of my face which they photoshoooed semen onto. They then
added the caption "Yep, screw you too, Mmmary!" They named the file "mmmm." This
is how disgusting and childish these people are.
IT IS FURTHER ORDERED that Mary Cummins be permanently enjoined and she is
ordered to immediately and permanently remove from the following URL's in their entirety:
1. http://www.animaladvoeates.us/batWorldLawsuit/ Amanda_Lollar_Bat_ World _San
ctuary _Breeding_Bats.pdf
2. http://www.animaladvocates. uslbatWorldLawsuit/amanda _Iollar _1994_ manual_ ori
gina!. pdf
3. http://www.animaladvocates.uslbatWorldLawsuit/mmmm.jpg
IT IS FURTHER ORDERED that Mary Cummins be pem1anently enjoined and she is
ORDERED to immediately and permanently remove from the internet the following statements
which currently appear at
http:f/www.animaladvocatcs.us/mary cummins sues amanda Iollar bat world sanctuary
1. She's the one who handles rabid bats with her bare hands.
IT IS FUR1HER ORDERED that Mary Cummins be permanently enjoined and she is
ORDERED to immediately and permanently remove from the internet the following statements
which currently appear at https://www.facebook.com/marycummins:
1. Update: Health Dept. forced Bat World Sanctuary to leave town. In January they gutted
the building, cleaned it and removed her property.
7 or 9 7/11/2D12 2:59:34 PM [Central Daylight Time)

Fm:Bailey & Galyen Attorneys To:Bat llorld Sanctuary and Ananda Lollar v. Mary c (18178502928) 16:04 07/11/12 EST Pg 8-9
2. Amanda who runs bat sanctuary just uses her bare hands. The rabid bats even bite her.
IT IS FURTHER ORDERED that Mary Cummins be permanently enjoined and she is
ORDERED to immediately and permanently remove from the internet the following statements
which currently appear at https:/lwww.facebook.com/AnimaJAdvocatesUSA:
1. Update: Health Dept. forced Bat World Sanctuary to leave town. In January they gutted
the building, cleaned it and removed her property.
IT IS FURTHER ORDERED that Mary Cummins be permanently enjoined and she is
ORDERED to immediately and permanently remove from the internet the following statements
which currently appear at https://plus.google.com/107575973456452472889:
1. Bat World Sanctuary admits in writing they are being forced to leave the City because of
all the complaints to the City and Health Dept.
IT IS FURTHER ORDERED that Mary Cummins be permanently enjoined and she is
ORDERED to immediately and permanently remove from the internet the following statements
which currently appear at http://twitter.com/MMMARYinLA:
I. Bat World Sanctuary admits in writing that they are being forced to leave the City
because of all the compluints to the City and Health Dept.
2. Update: Health Dept. forced Bat World Sanctuary to leave town. They gutted her
building, cleaned it and removed her property.
3. Amanda Lollar commits animal cruelty at Bat World Sanctuary http://goo.gl/fb/tfv4x
IT IS FURTHER ORDERED that Mary Cummins be permanently enjoined and she is
ORDERED to immediately and permanently remove from the internet the following statements
which currently appear at http://www.myspace.com/mmmaryinla:
I. Health Dept. forced Bat World Sanctuary to leave town. They gutted her building,
cleaned it and removed her property.
2. Bat World Sanctuary admits in writing they are being forced to leave the City because of
all the complaints to the City and Health Dept.
IT IS FURTHER ORDERED that Mary Cummins be permanently enjoined and prohibited
from posting on the internet or publishing to any person any video recording of any episiotomy
that was recorded or made at Bat World Sanctuary.
IT IS FURTHER ORDERED that the total amount of the judgment here rendered will bear
interest at the rate of five percent (5o/o) per year from the date of this judgment until paid.
All costs of court spent or incurred in this cause are adjudged against Mary Cummins,
defendant.
8 or9 7/11/2012 2:59:34 PM (Central Daylight Time]

fi:Bailey & Galyen Attorneys To:Bat J.lorld Sanctuary and fDanda Lollar v. Mary c (18178502928) 16:04 07/ll/12 EST Pg 9-9
All writs and processes for the enforcement and collection of this judgment or the costs of
court may issue as necessary.
All other relief not expressly granted in this judgment is denied.
SIGNEDthis ~~ dayof&,u6r- ,2012.
JUDGE ~~
PRESIDING
9 of 9 7/1112012 2:59:34 PM [Central Daylight Time]

Fm:Bailey & Galyen Attorneys To:Bat llorld Sanctuary and Allanda Lollar Y. Mary C (18178502928) 16:00 07/11112 EST Pg 2-9
9/l3/20ll lC:26:3~ AM PAGE 2/002 F~~ Server
THOMAS A. WILDER - TARRANT COUNTY DISTRICT CLERK
f_,ru~_l'~ANSMO"fTAl FORM Cover Sifseet
Attorncy:Ja crJa.lf..e:.JM1'12eC._ Bar m # __ p..J)_3.2__8_3JQ ___ _
FirmName&J leAr 1 c~a.(\ft.
Fax# ~l1~~lJf.:l_d-q,_0--+-
Subsclib~r Number ~-QD-~q;.:;:.O....~tf ______ Telephone# i11:-2~1.:J_Q~L
Repr.Jsenting: _6r.lntiti"IPetitioner __ Defendant/Respondent Otber
Autbilrizatio~: l authorize the filing of tbe below named documenl{s) and I 'lJ!t!!er.at•.thc-r~:~ my checking
account to be debited L"l accordance with my subscriber· s agi:eemdt. -
------------------------~-S_i~g~~--'~·~~~~~~-----------------
This .iccmnent should be filed in:
X Civil {for Civil or Criminal please send your fax to: 817-850-2928)
Crimi:d
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_.
---- Family (l 1 ,1r Family pleMe send your fax to: _t17-85il-2927) :::r: ::;;: ---1
_!..;;u_v~_n_ile;._.____ ~(F.,..a.,..r..;.Ju_v..;e,r.ile pl~e se,'ld your fax t~)l!Z;~Q-23l!~----r1i-""7...___,·_- - - 00 -·1~ -v
If yo".! ever have a probk•1, please call817·2l2-70111or Civil, 817-Zl2-75:>3 for Fara! ·
or 817-SJS-%45 for Juw:ll!le.
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Total munber of Pases