Myrl Carlene Jeffcoat's Declaration under Penalty of Perjury, July 30, 2000
She was one of two people from the support system from whom I requested a declaration.
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ILENA ROSENTHAL in Pro Per Plaintiff,
CORPORATION, INAMED CORPORATION; PATRICK J. O'LEARY, SUSAN SCHAEZLER, ETC. INFORMATION SERVICES; and
DOES 1 to 20, inclusive
CASE NO. GIC739307
SUPPLEMENTAL DECLARATION OF MYRL JEFFCOAT IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANT'S MOTION TO STRIKE AND REQUEST FOR ATTORNEY'S FEES
NO APPEARANCE REQUIRED
Date: August 11, 2000
Time: 2:00 p.m.
Judge: Honorable William C. Pate
Complaint Filed: Nov. 24, 1999
I, MYRL JEFFCOAT, declare as follows:
- I am submitting this declaration in support of the Plaintiffs Opposition to Defendants Motion to Strike and Request for Attorneys Fees. I have personal knowledge of the facts set forth below. If called upon to testify, I could and would competently testify to the facts set forth herein.
- The purpose of this letter is to document certain experiences I have had on-line with defendants Susan Schaezler, "Mplnt" (OLEARY) and other entities.
- In late 1995 I went into the internet actively seeking information about the status of breast implant litigation.
- I noted from the very beginning on the AOL Breast Implant Forum that Susan Schaezler and the entity known as "Mplnt" were present, as well as others that appeared to be very disruptive and insulting to implant victims. I had complained to Susan Schaezler, I didn't understand why a breast implant victim would be siding with an obvious pro-implant person to berate other victims. Susan Schaezler and I talked for a brief time (few days) about beginning a newslist, to create privacy for genuine implant victims, to give them safe harbor from the AOL board disruption created by "mplnt" and other disruptive entitities.
- While we were discussing it, she went ahead on her own and set it up, and instituted strenuous rules, regulations, and absolute control over membership. I was one of the "charter" members of BIS, and was there from the very beginning. Imagine my dismay when I discovered that "Mplnt" (one of the major disrupters of the AOL board) was also there, as a Susan Schaezler invited member. Shortly after Susan Schaezler began BIS, she solicited from the membership an invitiation for us to all openly share our real names, addresses, phone numbers, etc. The suggestion from her, was that we ought to all feel comfortable enough with each other, and could do that.
- I was one of the implant victims who did share my personal information openly on that list, and "Mplnt" was on the newslist and in the e-mail address when it occurred. Susan had always boasted that she knew the true identity of "Mplnt" and he was definitely not manufacturer related. She always suggested that he was a doctor knowledgeable about silicone issues, but did not believe our illnesses were caused by silicone. A brief amount of time went by (a few months), when an altercation arose on the BIS newslist. It involved the presenting of a theory presented by "Mplnt" that was very controversial to one of our more knowledgeable implant victim members. Ultimately this member was kicked off of BIS because of a negative response to "Mplnt" on BIS, while he remained.
- It was puzzling to many of us, that she chose to align herself with this disruptive influence, instead of the women for whom she claimed to have created her "private list."
- We on the support groups, were aware of Judge Pointers Order #8 protecting plaintiffs by prohibiting manufacturers from personally contacting implanted victims.
- "Mplnt" has been in our midst (breast implant forums, etc.) for many years. Susan Schaezler and he have always appeared to be joined at the hip. Imagine my distress, when some 4 years later, I learned that "Mplnt" was none other than Patrick O'Leary (President of McGhan Ireland. Evenmore distressing was the fact that I am a McGhan/3M victim.
I declare under penalty of perjury under the laws of the State of California on this 31st day of July, 2000, that the foregoing is true and correct.
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