THIRD CAUSE OF ACTION
                          ({*filter*})
54. Paragraphs 1-53 are re-alleged and incorporated herein by reference.
55. On information and belief, Defendant Hulda Clark is using and promoting the
use of diagnostic devices and treatment methods that lack FDA approval and
would not be legal to market for their intended purposes within the State of
California or in interstate commerce.
56. On information and belief, Defendant Dr. Clark Research Association,
through its Web site and other channels; is marketing devices, herbs, and other
products; lack state or federal government approval for their intended
purposes; and would not be legal to market for their intended purposes within
the State of California or in interstate commerce.
57. On information and belief, Defendant Dr. Clark Research Association,
through its Web site and other channels, is promoting and marketing books
written by Hulda Clark and promoting and collecting payment for Dr. Clark's
services in Mexico. Information about this commercial activity is incorporated
herein as Exhibit "15."
58. At various times, in various combinations, the Defendants conspired with
each other to engage in the acts as alleged in this complaint. The purposes of
this {*filter*} have been to:
(a) Further the commercial interests of Defendants Hulda Clark, David Amrein,
the Dr. Clark Research Association, Tim and Jan Bolen, and JuriMed.
(b) Promote the reputations of each of the Defendants.
(c) Undermine and assassinate the character of their critics, including the
Plaintiffs.
(d) Share information with each other in furtherance of these goals.
WHEREFORE, Plaintiffs pray judgment against Defendants, their "alternate
entities," and each of them as follows:
1. For Plaintiffs' general damages according to proof;
2. For Plaintiffs' loss of income, wages and earning potential according to
proof;
3. For Plaintiffs' cost of suit herein;
4. For exemplary or punitive damages according to proof; and
5. For such other and further relief as the Court may deem just and proper,
including costs as provided in CCP 998, CCP 1032 and related provisions of
law.
DATED: November 3, 2000
LAW OFFICES OF CHRISTOPHER E. GRELL
By_________________________________
Ian P. Dillon
Attorney for Plaintiff(s)
                        LIST OF EXHIBITS
The Most Dangerous Woman in the World - Hulda Clark (press release)
Hulda Clark Campaign in High Gear
A good laugh for all ("Herr quackpot")
Clark Update (May 12)
Clark Update (May 20)
Plaintiffs' response and analysis to #5
Clark Update - Into "Phase Two"
Plaintiffs' response and analysis to #6
Most Dangerous Woman" Feted in Toronto
Canadian Health Freedom Needs Our Help
Plaintiffs' response and analysis to #8
Waterloo Regional Police report on Dr. Terry Polevoy
Correspondence to and from the College of Physicians and Surgeons of Ontario
Newsgroup postings of Ilena Rosenthal (aka "Ilena Rose")
The Last Days of the Quackbusters
Plaintiffs' response and analysis to #12
Health Freedom Wins a Big One
The 'Quackbuster' Debate: Tim Bolen vs. Stephen Barrett, MD
Plaintiffs' response and analysis to #14
Dr. Clark Research Association Web site promotions