June 20, 2022
Footnotes: “The Satanic Housewife” videos and legal threat by The Satanic Temple
A former member of The Satanic Temple who goes by the online name “The Satanic HouseWife” made several videos on TikTok explaining that TST’s satanic abortion ritual was not actually a religious loophole preserving people’s access to abortion; she also referenced some other concerns about the Temple and people donating to it.
In response, The Satanic Temple’s primary lawyer Matt Kezhaya and his law firm sent legal threats to her, and other possible email addresses they thought might belong to her, telling her that if she did not publicly recite the apology they gave to her, she would be sued.
Below are those videos with transcripts and the email correspondence between her and the Kezhaya law firm.
Finally, at the bottom of the page is The Satanic Temple’s co-owner and chief speaker Doug Misicko (a.k.a. “Doug Mesner”, “Lucien Greaves”) threatening her on Twitter with the release of the same emails.
Update: Lawsuit filed against Satanic Housewife and reactions to that now included.
Jump to
- First video (criticism of The Satanic Temple)
- Second video (more on TST and abortion rights)
- Third video (“retraction”)
- Fourth video (evidence of legal threat)
- Email exchange
- First email (TST demand letter from Matt Kezhaya)
- Second email (Satanic Housewife reply)
- Third email (Matt Kezhaya)
- Fourth email (Satanic Housewife)
- Fifth email (Sonia Kezhaya)
- Sixth email (Satanic Housewife)
- Seventh email (Matt Kezhaya)
- Last email (Satanic Housewife)
- Tweets (“Lucien Greaves” replying to Satanic Housewife)
- TST legal complaint (Travis County District Court)
- Satanic Europe coverage (articles)
- Hail Satan podcast (interview)
First video (criticism of The Satanic Temple)
Do not give any money to The Satanic Temple to fight for abortion rights. And before you get angry, peep the name: Satanic Housewife. OK? I’ll post in the comments where you can find and verify everything that I’m going to tell you.
In a recent court case for something else TST that is involved in—who can keep up at this point—Lucien openly admitted to taking the money fundraised for court cases and for abortion rights advocacy and using it to pay for his personal bills instead.
Aside from everything else like The Satanic Temple suing former members to make them be quiet about the stuff they experience while in The Temple.
About one of their chapter leaders being accused of sexual assault and TST kicking the victim out of the chapter.
About how their head of Ministry is really good friends with alt right celebrities like Milo Yiannopoulus or however you say that fuck’s name.
Maybe about how some of their suggested reading have STRONG antisemitic themes.
We’re not even going to touch on the “Might Is Right” podcast that Lucien did.
Don’t give them your money.
If you want to help abortion access find a local abortion services provider and donate your time or money to them.
Get involved in local schools, and have sex education kept inside schools.
Stock up on Plan B even if you don’t need it.
Help people find, fund, and secure vasectomies and long-term birth control.
The biggest thing I’m gonna say is don’t try and reinvent the wheel. Whatever it is you’re thinking of creating, I guarantee you that org already exists and they could use your support rather than your accidental competition.
If you have questions about any of this I am very glad to have a conversation.
If you attacked me in the comments I’m very glad just to get rid of you and go on with my day.
Second video (more on TST and abortion rights)
Alright, we have to cover a couple more things about The Satanic Temple.
Many of you are stating that you joined strictly to have your bodily autonomy protected, to have your rights to abortion access continued even if Roe v Wade is overturned.
What I am trying to help everybody understand is that The Satanic Temple has no grounds to help you maintain abortion access.
In fact they’ve tried this previously and failed each time because they don’t have standing.
So while you might not have donated money, your support is convincing others that this is the thing to do to help themselves feel safe.
I know that we all want to feel safe right now and that we are all desperately searching for a safe space. I don’t know what the answer really is. I don’t know what the solution is. But I do know The Satanic Temple isn’t the solution. And the more we’re able to realize that and the more we’re able to help others realize that, the quicker was can figure out what the solution actually is.
Third video (“retraction”)
I don’t even know how to start this video.
I made a good faith effort to give y’all information I thought was valuable for you to know. And now The Satanic Temple is threatening to sue me.
This is one of the hardest things I’ve ever had to do, for reasons I can’t even talk about.
But here goes:
The TikTok post I made contained many statements that are provably untrue. I regret having made the post and the harm it has unfairly and unjustly caused The Satanic Temple.
I know of no credible claims that The Satanic Temple has ever misappropriated funds.
The Satanic Temple’s lawsuit against the Johnson defendants who call themselves ‘QueerSatanic’ is over Facebook pages they admitted they stole from The Satanic Temple.
I know of no credible claims that The Satanic Temple condones sexual assault or punishes victims of assault.
I know of no credible claims that The Satanic Temple has alt right ties.
I sincerely apologize for my hurtful, misleading, and dishonest statements.
Fourth video (evidence of legal threat)
I don’t blame you for not believing it or for asking for evidence because that’s what you should do, about everything. So here you go.
Here is the first page of the demand letter sent to me by a lawyer representing TST.
I have of course blacked out my full legal name at the top, my mailing address.
This whole bit in the middle here that’s all blacked out? That is a list of any possible email address that they felt might be connected to me that they sent this demand letter to.
This letter — that has my full legal name, my full home address, also talks about Satanism — he sent it to complete strangers on the Internet. People not related to me at all.
When I wrote a response and said, “Hey, I feel really unsafe because you sent my home address where my family lives to a bunch of strangers,” he told me basically, “Too bad, we don’t use screen names in court.” Didn’t acknowledge it at all.
Here’s page two. You’re going to have to screenshot and read it later. I don’t want to run down the clock on this.
And finally, page three, telling me what to do with the new video.
There are several emails that happened after this going point-by-point, me providing evidence for what I said, such and such.
I really hope that you read thoroughly this demand letter. Moreso, I hope you notice what’s not there.
My original video focused on making sure you understood that being a member of The Satanic Temple does not protect your rights to abortion access. Nowhere in this demand letter did they want me to take that statement back.
My focus then and my focus still now is to make sure that you are protected in the event that you need abortion access. I want to make sure you know what is available to you and what isn’t.
Thank you for your kind words, for your messages. It’s gotten me through an incredibly rough week, personally. Aside from just this.
To those that have messaged me with your own stories, my inbox is always open. Please reach out to me if you need help, if you need to vent, if you want to share your story. I’m available.
Email exchange (between second and third videos)
[Kezhaya Law PLC header]
[The Satanic Housewife’s government name and home address]
a/k/a @satanichousewife on TikTok
[redacted]
Sent via email to [emails possibly related to The Satanic Housewife].
Re: The Satanic Temple v. [The Satanic Housewife] Demand Letter and Request for Correction, Clarification, or Retraction
Ms. [The Satanic Housewife]:
If you have representation in this matter, please forward this letter to your attorney and request that they contact me. I serve as general counsel for The Satanic Temple, Inc. (“TST”). I have been made aware of a recent TikTok video of yours,1 in which you make certain provably-false statements of fact about my client which have a tendency to harm my client’s reputation. The purpose of my letter is to inform you that these statements you have made are actionable, and that litigation will ensue unless you publish a correction, clarification, or retraction of the defamatory statements on TikTok, and any other platform on which you have shared the video, within three days.
In your video, beginning at about 0:20, you state: “In a recent court case … Lucien openly admitted to taking the money fundraised for court cases and for abortion rights advocacy and using it to pay his personal bills instead.” Your statement is false. Lucien has never made any statement to the effect of an admission to “taking money fundraised for court cases and for abortion rights advocacy and using it to pay his personal bills instead.” Your false statement is defamatory because it charges TST (a public charity) with allowing for embezzlement, which is a serious charge of fraud.
Next, beginning at about 0:41, you claim that TST is “suing former members to make them be quiet about the stuff they experienced while in the Temple.” Your statement is false. TST is suing those former members because they stole TST’s property and, using that stolen property, channeled provably-false and harmful statements directly at TST’s audience, which statements were made for the wrongful purpose of diverting TST’s donation base to the former members’ new competitor organization. Your false statement is defamatory because it wrongly paints TST as being abusive against its former members, which tends to diminish the public trust in TST as a religious organization.
Next, at approximately 0:51, you claim that “one of their chapter leaders being accused of sexual assault and TST kicking the victim out of the chapter.” This statement is patently false. It is defamatory because it suggests that TST supported a person in a leadership position within the organization who was accused of sexual assault by removing the accuser. This is in direct contrast to TST’s actual conduct, and it harms the reputation of TST with its current membership, with potential members, and with the public at large. As you have first hand knowledge, TST investigated this matter and found (based on eyewitness interviews) that the “victim” falsified the allegation.
Last, at about 0:57, you claim that TST’s “head of ministry is really good friends with alt-right celebrities like Milo Yiannopoulos.” Your statement is false. TST’s head of ministry was friends with Yiannopoulos, long ago, but they have not been friends for many years. Without necessary context, the statement is false. Your false statement is defamatory in the overall context of the video because the kinds of people who are likely to donate to TST in support of the Religious Reproductive Rights campaign are politically averse to Yiannopoulos and will therefore be deterred from donating to TST by a misbelief that there are secret ties between TST and him.
Because litigation may become necessary, you are obligated to refrain from destroying or deleting any social media accounts, any media storage devices (e.g., phones or laptops), and any communication you may have had with third parties about TST or the matters in your video. If information relevant to a known potential lawsuit is missing, it may be presumed to be harmful to the person who failed to preserve the information. See Brookshire Bros., Ltd. v. Aldridge, 438 S.W.3d 9 (Tex. 2014).
As noted above, we intend to file suit unless you publish a sufficient correction, clarification, or retraction of the defamatory statements on TikTok, and any other platform on which you have shared the video (such as Facebook, Insta gram, Twitter, Discord, Reddit, or any other platform), within three days, including a link to the original video so that it is likely to be seen by those who have viewed the original video. TST reserves the right to file suit to the extent that the correction, clarification, or retraction is deemed insufficient under the Texas Defamation Mitigation Act.
Please notify me if you intend to acquiesce to this letter. If I do not hear from you by the deadline, I will assume that you intend to defend your video in court.
Sincerely,
Matthew A. Kezhaya
—
1available at: https://www.tiktok.com/@thesatanichousewife
/video/7093692392297041194 (last visited June 8, 2022) originally published on or about May 3, 2022.
From: [The Satanic Housewife]
Date: Sun, Jun 12, 2022 at 1:37 PM
Subject: Re: The Satanic Temple v. [The Satanic Housewife] — demand letter; for correction clarification or retraction
To: Matthew A. Kezhaya matt@kezhaya.lawHello,
Please use this email address ([redacted]) if you need to contact me. I am appalled you sent communications to numerous random email addresses with my full legal name and physical address. Considering the general public’s heated reaction to things viewed as “Satanic”: just last night someone set fire to TSTs headquarters: I now have to worry for my and my family’s safety as you published my home address.
I noticed in the list of who received this communications you listed that you “Sent via ; Instagram to satanichousewife; Facebook Messenger to “The Satanic HouseWife” a/k/a @roasmind; Twitter to “The Satanic Housewife” a/k/a @satanxhousewife” however I do not have any messages in regard to this demand letter on any of the mentioned platforms (inbox or spam), and on one of those platforms my settings expressly disallow anyone I am not connected with to message me; please provide me with a dated copy of these messages.
To the demand letter:
Claim 0:20:
I am willing to amend my statement to “The Satanic Temple/Reason Alliance paid Lucien $4000 from funds raised for a veterans monument”. According to the deposition given in Satanic Temple, The v. Belle Plaine, City Of, along with Exhibit 9 found on page 93, this is not a false statement as $4,000 was used from the funds raised to pay Douglas Mesner/Lucien. For your ease, I have attached a screenshot of pages 80, 82, 83 where this is directly discussed during deposition.
Claim 0:41:
I am willing to amend my statement to “Currently The Satanic Temple is threatening legal action against me, as well as suing former members, and the publication Newsweek”. This is evidenced by the demand letter I received on June 9th 2022, along with the lawsuit against Queer Satanic, and how TST is also suing Newsweek.
Claim 0:51:
I have to acquiesce to this as everything I know would be considered hearsay. I am willing to make that statement in the retraction/clarification video.
Claim 0:57:
I will gladly make an updated statement/video that The Satanic Temple wants me to correct my earlier video to reflect that Greg Stevens (the Head of Ministry mentioned) WAS friends with Milo Yiannopoulos.
“TST reserves the right to file suit to the extent that the correction, clarification, or retraction is deemed insufficient”; before I post the amended statements laid out above, that I will say verbatim to what is laid out above, I require a statement from you on behalf of TST that my correction, clarification, or retraction is sufficient and that this matter will not be pursued further. Once this statement is received I will post the clarification video within 24 hours.
-End.
From: Matthew A. Kezhaya <matt@kezhaya.law>
Date: Mon, Jun 13, 2022 at 6:21 PM
Subject: Re: The Satanic Temple v. [The Satanic Housewife] — demand letter; for correction clarification or retraction
To: [The Satanic Housewife]
CC: Sonia A. Kezhaya <sonia@kezhaya.law>, Brad Ryynanen <brad@bdrlegal.com>
Ms. [The Satanic Housewife]We appreciate your willingness to work with us to undo some of the harm you have done. TST prefers that you post a retraction and correction video over having to litigate this matter. Based on your response, it looks like you also share that preference. This email is to ensure clear expectations for what will suffice as a true retraction and correction.
Claim at 0:20
At issue is this statement: “In a recent court case … Lucien openly admitted to taking the money fundraised for court cases and for abortion rights advocacy and using it to pay his personal bills instead.” We objected because
(1) Lucien has never made any statement to the effect of an admission of the underlying claim;
(2) the underlying claim is false; and
(3) it charges TST (a public charity) with allowing for embezzlement.
You propose amending the statement to an assertion that Greaves received $4,000 for funds raised for a veterans monument. But it is inadequate to simply amend your statement, you also need to retract your prior statement (i.e., you need to explicitly withdraw the claims and say that they were false). Additionally, your proposed amendment does not correct the original charge of embezzlement. Your proposed amendment continues to falsely imply that Lucien being paid money by TST is improper. The law is the opposite. Lucien is entitled to derive a reasonable income for personal services rendered to the church. IRS Pub. 1828 at 5. Greaves’s services to TST are much more than a full-time job. No part of the law expects him to do that job for free. As for the Veteran’s Memorial, the funds paid to Greaves were for services related to overseeing the development of the monument. Jarry Depo. at 80:15-19 (Satanic Temple v. Belle Plaine, 0:19-cv-1122 doc. 84-1 at 32).
Based on the above, an agreeable retraction and correction requires all of the following:
(1) withdraw the claim that “Greaves takes income from money raised for court cases and for abortion rights advocacy and using it to pay his personal bills instead;”
(2) state that the claim was false in its entirety;
(3) state that Greaves may lawfully accept reasonable compensation in return for personal services; and
(4) cite your viewership to IRS Pub. 1828 at 5 for any questions they have about lawful compensation of church officials.
(5) state that Greaves has not accepted any “income raised for court cases and for abortion rights advocacy and using it to pay his personal bills instead;”
(6) state that you have no credible basis to believe that TST ever improperly provided compensation to Greaves; and
(7) state that you have no credible basis to believe that TST ever misrepresented to the public what it was fundraising for or what was done with the funds.If you insist on addressing the $4,000 payment from TST to Greaves in relation to the Belle Plaine veterans monument, your video must also include the following:
(8) state that Greaves provided TST personal services related to the Display, particularly, he: oversaw development, design, construction, logistics, and transport of the Display for TST;
(9) state that TST paid Greaves $4,000 for those personal services; and
(10) state that you have no credible basis to believe that TST ever misrepresented to the public what it was fundraising for or what was done with the funds.
Claim at 0:41
At issue is this statement: TST is “suing former members to make them be quiet about the stuff they experienced while in the Temple.”We objected because TST is suing those former members because they stole TST’s Facebook page.
You propose amending the statement to “Currently The Satanic Temple is threatening legal action against me, as well as suing former members, and the publication Newsweek.” Again, it is not sufficient to simply amend your statement, you have to retract it and then correct it. Your proposed amendment still does not correct the false claim. TST is suing the Johnson defendants because they stole TST’s Facebook pages. We survived their motion to dismiss because the law entitles TST to sue the Johnson defendants for stealing TST’s Facebook pages.
Based on the above, an agreeable retraction and correction requires the following:
(1) withdraw the claim that TST is “suing former members to make them be quiet about the stuff they experienced while in the Temple;”
(2) state that the claim was false in its entirety;
(3) state that TST is suing the Johnson defendants for stealing TST’s Facebook pages;
(4) state that TST’s lawsuit against the Johnson defendants is proceeding toward a trial for
(a) tortious interference with a business relationship and
(b) conversion, or trespass to chattels; and
(5) state that you have no credible basis to believe that TST sues former members “to make them be quiet about stuff they experienced while in the Temple.”
If you insist on also addressing TST’s threatened litigation against you or the ongoing litigation against Newsweek, your video must also include the following:
(6) it is actionable defamation to make a false claim with a requisite ill-intent if the false claim causes harm to another;
(7) you made the false claims which are detailed in our demand letter;
(8) in response, TST sent you a letter which specified the objectionable claims and demanded a retraction and correction;
(9) the contemplated video is published in response to TST’s letter;
(10) Newsweek published an article which TST asserts is defamatory;(11) Newsweek failed to acquiesce to TST’s demand for a retraction and correction; and
(12) TST is suing Newsweek for defamation.
Claim at 0:51
At issue is this statement: “one of their chapter leaders being accused of sexual assault and TST kicking the victim out of the chapter.”We objected because TST investigated this matter and found (based on eyewitness interviews) that the “victim” falsified the allegation.
You responded that you are willing to retract the statement.Based on the above, an agreeable retraction and correction requires the following:
(1) withdraw the claim that one of TST’s chapter leaders was accused of sexual assault and TST kicked the victim out of the chapter;
(2) state that the claim was false;
(3) state that TST investigated this matter and found (based on eyewitness interviews) that the “victim” falsified the allegation;
(4) state that your claim was based entirely on hearsay; and
(5) state that you have no credible basis to believe that TST ever kicked a sexual assault victim out of a chapter for claiming sex assault by a chapter leader.Claim at 0:57
At issue is this statement: TST’s “head of ministry is really good friends with alt-right celebrities like Milo Yiannopoulos.” We objected because TST’s head of ministry was friends with Yiannopoulos, long ago, but they have not been friends for many years. You responded that you are willing to retract the statement.
Based on the above, an agreeable retraction and correction requires the following:
(1) withdraw the claim that TST’s “head of ministry is really good friends with alt-right celebrities like Milo Yiannopoulos.”
(2) state that the claim was false;
(3) state that you have no credible basis to believe that TST’s head of ministry has ever been friends with any alt-right celebrities, other than Milo Yiannopoulos;
(4) state that TST’s head of ministry was friends with Yiannopoulos, long ago, but they have not been friends for many years; and
(5) state that you otherwise have no credible basis to believe that TST’s head of ministry has any relationship with the alt-right.
Objection to personal information
You objected to my use of your legal name and your mailing address in my demand letter. We don’t use screen names in the courts, we use legal names.
Objection to the form of service
You also objected to my failure to send the demand letter via your various social media accounts in addition to sending it by email. Your objection is irrelevant. What matters is that you received fair notice of the request for correction, clarification, or retraction and grounds for the request.
No waiver
Finally, you asked TST to waive its right to file suit before you will issue the contemplated “correction, clarification, or retraction” video. Without seeing the actual statement, TST is unable to analyze whether it will correct the harm caused by the subject video. Therefore, TST declines to waive its right to sue.
But, as I mentioned at the top of this email, TST does not want to sue you. TST wants the actionable statements retracted and corrected. So, you should have no concern that TST will bring suit, provided that you act with sincerity and in good faith when creating and publishing the “correction, clarification, or retraction” video.
Matthew A. Kezhaya
From: [The Satanic Housewife]
Date: Mon, Jun 13, 2022 at 8:50 PM
Subject: Re: The Satanic Temple v. [The Satanic Housewife] — demand letter; for correction clarification or retraction
To: Matthew A. Kezhaya matt@kezhaya.lawHello,
Forgive my lack of professional email niceties; I’ve spent all day at various Dr’s offices with my autistic toddler seeing if he broke his leg or not, and I have no energy left. I do feel this is important though so I wanted to respond to you asap.
Claim at 0:20
“(6) state that you have no credible basis to believe that TST ever improperly provided compensation to Greaves; and
(7) state that you have no credible basis to believe that TST ever misrepresented to the public what it was fundraising for or what was done with the funds.
(10) state that you have no credible basis to believe that TST ever misrepresented to the public what it was fundraising for or what was done with the funds.”Apologies , and I am sincerely not trying to be difficult, but I cannot speak these statements. What I have learned, read, experienced, heard, etc leaves me in a position to not be able to say those sentences in good faith. I am not looking to state the opposite or anything else on the matter. However, I cannot sincerely say those sentences considering everything mentioned earlier, as well as in Cave v Thurston Lucien spoke of “staying afloat” with TST funds to the tune of $2,000 at times. Yes, he has the right to do this and no, TST is not transparent with the public about this – I had to read court transcripts to learn it.
I am agreeable to reading aloud all the other statements provided regarding this claim.
Claim 0:41
“(3) state that TST is suing the Johnson defendants for stealing TST’s Facebook pages”
The case is not settled and the right to add “allegedly” still stands. I am agreeable to stating “TST is suing the Johnson defendants for allegedly stealing TST’s Facebook pages”
I am agreeable to reading aloud all the other statements provided regarding this claim.Claim 0:51
“(1) withdraw the claim that one of TST’s chapter leaders was accused of sexual assault and TST kicked the victim out of the chapter;”
This might be where things go south for our communication, but I will not say this. Which leads to
“(5) state that you have no credible basis to believe that TST ever kicked a sexual assault victim out of a chapter for claiming sex assault by a chapter leader.”
I cannot say this either.
I am agreeable to reading aloud all the other statements provided regarding this claim.
Claim 0:57
“(3) state that you have no credible basis to believe that TST’s head of ministry has ever been friends with any alt-right celebrities, other than Milo Yiannopoulos;”
I cannot say this. His tenure with Brietbart and his relationship with Milo Y do give me enough credible basis to believe that he may have ever been friends with other alt-right celebrities/personalities in the past. I understand if I were to speak that belief I would most likely receive another letter from y’all, and I have no intentions of repeating this interaction.
“(5) state that you otherwise have no credible basis to believe that TST’s head of ministry has any relationship with the alt-right.”
Adding the word “currently” at the end of this statement is agreeable to me.
I am agreeable to reading aloud all the other statements provided regarding this claim.
Objection to personal information
“You objected to my use of your legal name and your mailing address in my demand letter. We don’t use screen names in the courts, we use legal names.”
To clarify; I objected to you sending my personal information to multiple email addresses that were in no way associated with me. That action has left me feeling very unsafe in my own home.
No waiver
“Finally, you asked TST to waive its right to file suit before you will issue the contemplated ‘correction, clarification, or retraction’ video. Without seeing the actual statement, TST is unable to analyze whether it will correct the harm caused by the subject video. Therefore, TST declines to waive its right to sue.”
That is completely understandable, and I do not have any other option at this point.
I will read what you wrote in your email to me, on video, linked to the original video which caused this action, with the current (possible) exceptions to those statements listed above in this email. Is this agreeable?
From: Sonia A. Kezhaya <sonia@kezhaya.law>
Date: Tue, Jun 14, 2022 at 11:05 AM
Subject: Fwd: The Satanic Temple v. [The Satanic Housewife] — demand letter; for correction clarification or retraction
To: [The Satanic Housewife]
CC: Matthew A. Kezhaya <matt@kezhaya.law>, Brad Ryynanen <brad@bdrlegal.com>Ms. [The Satanic Housewife]:
We appreciate your prompt response and hope all is well with your toddler. Perhaps a phone call could help the parties reach an agreement. Are you amenable to having a phone conversation? If so, I can get that scheduled.
Thank you,
Sonia
From: [The Satanic Housewife]
Date: Tue, Jun 14, 2022 at 1:23 PM
Subject: Re: The Satanic Temple v. [The Satanic Housewife] — demand letter; for correction clarification or retraction
To: Sonia A. Kezhaya <sonia@kezhaya.law>
CC: Brad Ryynanen <brad@bdrlegal.com>, Matthew A. Kezhaya <matt@kezhaya.law>Hello,
I think a phone call would be best.
Please let me know what time works for you and I will make myself available.
From: Matthew A. Kezhaya matt@kezhaya.law
Date: Thu, Jun 16, 2022 at 4:23 PM
Subject: Re: The Satanic Temple v. [The Satanic Housewife] — demand letter; for correction clarification or retraction
To: [The Satanic Housewife]
CC: Sonia A. Kezhaya sonia@kezhaya.law, Brad Ryynanen brad@bdrlegal.comMs. [The Satanic Housewife]:
On review of our correspondence, I don’t think a phone call will be productive. I’ve come to the conclusion that an ultimatum is the only way we can resolve the impasse. I summarize why below.
Claim at 0:20
You have shifted your claim three times. First, you accused TST of allowing Lucien to embezzle money raised for the limited purpose of court cases and abortion rights advocacy. Then, you accused TST of allowing Lucien to embezzle money raised for the limited purpose of the Belle Plaine Display. Now, you accuse Lucien of embezzling money to “keep afloat.” All three of these claims are rooted in the provably-false premise that Lucien accepting compensation from TST is improper. In fact, TST is entitled to pay Lucien reasonable compensation in return for personal services. You have stated a subjective understanding that this is the law. Thus, any claim to the contrary is a knowingly-false statement which causes harm to TST.Any permutation of a claim that it is improper for Lucien to accept compensation from TST is actionable defamation. “Any permutation” includes veiled statements, innuendo, implication, and any other statement that would cause a reasonable person to believe that TST improperly compensates Lucien. Your objection to transparency is irrelevant. Churches have neither a social obligation nor a legal obligation to be transparent about their payroll. What is prohibited is paying an unreasonable rate, and “$2,000 here and there” is unimpeachably reasonable for a more-than-full-time job.
Based on the foregoing, you need to make the correction as demanded or I will have to sue you to vindicate TST’s rights.
Claim at 0:41
The “allegedly” modifier fails to retract the original provably-false claim that TST is suing the Johnson Defendants to “keep them quiet.” It is provably-false for you to claim that TST is suing the Johnson Defendants because the Defendants “allegedly” stole TST’s Facebook page. That is because there is nothing “alleged” about the theft. The Johnson Defendants publicly bragged that they “stole” TST’s Allies page. Exhibit 5 at 3; see also Exhibit 6 (ADJ also admitted to sealing the Chapter page). Facebook publishes all former names of its pages. Exhibit 3. The Allies page, which is indisputably in the possession of the Johnson Defendants, began as “South Side Satanists: Friends of TST.” Id. TST is suing to recover the website and for all compensable damages arising out of the interference with TST’s exclusive rights to the two pages. Second Amended Complaint at p. 23 (prayer for relief); see also id. at Counts 2-4. The Court denied their motion to dismiss for failure to state a claim as to the interferences and the theft. Order at 32.
By failing to include the above necessary context, your proposed correction does not remediate the harm. It is just a veiled restatement of the same actionable claim.Based on the foregoing, you will make the correction as demanded or I will have to sue you to vindicate TST’s rights.
Claim at 0:51
You already stated that your sole basis for your understanding that TST kicked out a sex assault victim is rooted solely in unreliable hearsay. That was an admission to defamation liability. It is too late to retract your prior admission. I am prepared to prove that TST has never kicked a sexual assault victim out of a chapter for claiming sex assault by a chapter leader. I am also prepared to prove that you know that you have flatly zero credible basis to believe that TST has ever kicked a sexual assault victim out of a chapter for claiming sex assault by a chapter leader.
Based on the foregoing, you need to make the correction as demanded or I will have to sue you to vindicate TST’s rights.
Claim at 0:57
You now accuse Penemue of having “tenure” at Brietbart. “Tenure” connotes a permanent employment. I am prepared to prove that Penemue’s affiliation with Brietbart consists of precisely one article, seven years ago, for which he received no compensation. I am also prepared to prove that you have no basis to you prepared to prove to a jury of your peers that Penemue ever had a permanent employment at Brietbart.
I am also prepared to prove that you have no basis to believe that Penemue had a friendship with any other alt-right celebrities. Your response suggests that you drew an inference to make that claim based on (1) Penemue posted one article on Brietbart; and (2) years ago, Penemue was friends with Yiannopoulos. I am prepared to prove to a jury of your peers that this is not a credible ground to make that claim.
Based on the foregoing, you need to make the correction as demanded or I will have to sue you to vindicate TST’s rights.
Objection to personal information
I apologize for making you feel unsafe. I am sensitive to the stigma attached to being a publicly identifiable Satanist. However, you caused my client an actionable harm and it is my job to rectify that harm. Part of my efforts to rectify that harm required me to communicate the original demand letter to you. To communicate the demand letter required (in relevant part) an email address. My best available means to procure your email address was to perform a public records search and send emails to all addresses reflected on the search results. Hopefully, it will resolve your safety concerns to learn that I received bounceback errors from all email addresses other than [redacted].
Ultimatum
This is the last email I intend to send on this matter before filing a complaint. At that point, I foresee that this will become an irresolvable problem without a judgment. The prior email included all necessary elements that will rectify the harm to TST, while strictly keeping to the actionable facts and claims at issue in the objected-to first statement. I strongly prefer to avoid litigation in this matter. But if you do not rectify the actionable harm you caused, I will have no choice but to initiate litigation. I have already retained local counsel on this matter and am prepared to swiftly open the proceedings.If the itemized matters from the prior email are still an issue, here is a shorter statement that will serve TST’s purposes:
The TikTok post I made contained many statements that are provably untrue. I regret having made the post and the harm it has unfairly and unjustly caused The Satanic Temple. I know of no credible claims that The Satanic Temple has ever misappropriated funds. The Satanic Temple’s lawsuit against the Johnson defendants who call themselves “Queer Satanic” is over Facebook pages they admitted they stole from The Satanic Temple. I know of no credible claims that The Satanic Temple condones sexual assault or punishes victims of assault. I know of no credible claims that The Satanic Temple has alt-right ties. I sincerely apologize for my hurtful, misleading, and dishonest statements.
Matthew A. Kezhaya
From: [The Satanic Housewife]
Date: Fri, Jun 17, 2022 at 2:03 PM
Subject: Re: The Satanic Temple v. [The Satanic Housewife] — demand letter; for correction clarification or retraction
To: Matthew A. Kezhaya matt@kezhaya.law
CC: Brad Ryynanen brad@bdrlegal.com, Sonia A. Kezhaya sonia@kezhaya.lawI have made the video requested and used the script provided.
It has been published on my personal TikTok. As requested I have attached it to the original video, as well as attached it to the original video on my Twitter, Facebook, and Instagram. For good faith I have also posted it as its own separate video on those platforms as well.I am hopeful that by fulfilling the demands we can resolve this matter.
Thank you.
Tweets in response to Jezebel article
The Satanic Housewife @satanxhousewife
Congrats to @Jezebel & @sueonthetown. I’m sure you’ll join the ranks of us who have been threatened with litigation or outright sued by TST! We should start a club. Maybe print tshirts.
Lucien Greaves @LucienGreaves
Or maybe don’t accuse people of actual crimes they haven’t committed, admit that you had no basis for claiming so to begin with, and then continue to make the same claim. That’s not “criticism,” that’s defamation.
The Satanic Housewife @satanxhousewife
I don’t understand why you say it’s defamation when I say that you do indeed get paid, but then you can tweet that you do get paid and it’s suddenly OK ?
Lucien Greaves @LucienGreaves
That’s not what you said. You are now lying.
The Satanic Housewife @satanxhousewife
Character limit, that’s the summation of what I said for ease. But just to clarify, I can say that you do indeed get paid right? And this money you get paid, would that come from the donations?
Lucien Greaves @LucienGreaves
I can post your emails where you admitted to making claims based on hearsay, if that would be easier?
The Satanic Housewife @satanxhousewife
This one? The one where I say that I have to acquiesce because I understand I did not have enough evidence for court and even though I’ve talk to the victim it would still be considered hearsay. That’s not a lie, that’s me understanding how proof and evidence works.
TST legal complaint (Travis County District Court)
Satanic Europe coverage (articles)
Hail Satan podcast (interview)
The Satanic Temple's Boogeyman
Queer Satanic
The Satanic Temple has been suing us since April 2020, and we are still here.