I just had to file this. I swear to god. also, memes.
PURPOSE OF PLAINTIFF’S WEBSITE AND CLARIFICATION OF
MISREPRESENTATIONS
10. Plaintiff submits this section to clarify the lawful purpose, function, and content of her
website, RapeIsRape.org, in response to Defendant’s repeated and misleading assertions
that the website is directed at him, created to monitor him, or intended as harassment.
These claims are factually incorrect, legally unsustainable, and contradicted by the
structure, content, and privacy protections built into the site. The website is not about the
Defendant, but rather the Plaintiff. It is not a tracking system targeting him, nor does it
contain identifying information about him. Defendant’s presence on the site is voluntary
and self‑initiated. If he wishes not to appear in analytics, the remedy is simple: he should
not visit the website.
a. THE WEBSITE DOES NOT TRACK DEFENDANT OR HIS COMPUTER
11. RapeIsRape.org uses standard, universally available website analytics—the same type
used by blogs, nonprofits, small businesses, and nearly every modern webpage. These
analytics track only Plaintiff’s website. They do not access or interact with any visitor’s
files, settings, personal data, or hardware. A visitor appears in analytics solely because
they choose to load the webpage. Defendant appears in Plaintiff’s analytics because he
and members of his household and extended family voluntarily visit the site, often
multiple times in one day. Plaintiff would have no knowledge of these visits if they did
not make the conscious decision to access the website. Any suggestion that Plaintiff is
“monitoring” Defendant or his computer is false and misleading.
12. Plaintiff has never accessed, attempted to access, or claimed to access Defendant’s
devices, accounts, or data. She monitors only her own website, which she lawfully owns
and is fully entitled to track.
b. THE WEBSITE IS NOT ABOUT DEFENDANT; IT IS ABOUT PLAINTIFF’S
EXPERIENCE
13. RapeIsRape.org is a survivor‑narrative and advocacy platform documenting Plaintiff’s
own story, trauma, and experiences navigating institutional failures. It includes her
real‑time reflections as she processes trauma and the aftermath of her assault. It also
contains a brief list of online resources that Plaintiff personally found helpful in her own
recovery. The site further functions as a transparent documentation archive, organizing
filings, timelines, and records necessary for state, federal, and administrative complaints
following multiple record‑handling failures by Nevada agencies. There are numerous
academic style articles about relationship rape as well as PSA videos to support women
in similar situations. The website’s purpose is rooted in healing, transparency, and
self‑protection, not harassment or retaliation.
c. PRIV ACY PROTECTIONS SHOW THE WEBSITE IS NOT TARGETED AT DEFENDANT
14. Plaintiff has taken deliberate steps to ensure that Defendant is not personally identifiable
on the website. He is referred to only as “{D}.” Plaintiff does not publish Defendant’s
address, phone number, email, or any personal information. Any images that include
Defendant have his face obscured. Only government‑issued documents released
unredacted by the State of Nevada contain his name. These measures demonstrate that the
website is not directed at Defendant and does not exist to expose or target him.
d. SURVIVOR NARRATIVES ARE NORMAL, NECESSARY , AND HEALTH‑PROTECTIVE
15. Survivor narratives are a longstanding and essential part of trauma recovery.
Survivors often read such narratives to find validation, to understand their own reactions,
and to reduce the isolation common among trauma victims. Narratives help survivors
recognize coercive dynamics, institutional betrayal, and patterns of abuse they may have
previously minimized or lacked language to describe. Plaintiff’s website functions within
this tradition, providing a space where she can reclaim her voice and document her
experience. It is a coping mechanism, a resource, and an act of survival—not a weapon.
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