In The UNITED STATES DISTRICT COURT
For The DISTRICT OF MARYLAND
Southern Division

DAI CHUNG NEWS MEDIA INCORPORATED                      	]
d/b/a DAI CHUNG BIWEEKLY NEWSPAPER		      	]
10515 Summit Avenue                                    			]
Kensington, Maryland   20895,           				]
						     		]
and 								]                                                                     
						     		]
HOAI THANH           						]
2820 Poag Street                                             			]
Alexandria, Virginia 22303                                           		]
as an individual, as the owner of an                 			]
enterprise engaged in Interstate and               				]
foreign commerce, as a member of the           			]
Vietnamese speaking community in America,  			]
on behalf of himself and others similarly         			]
situated,                                                           			]
								]
Plaintiffs,							]
		v.						]	CASE No: AW 05 CV 3420									]
HIEN THI NGO							]
8001 Bradley Boulevard						]            JURY TRIAL 
Bethesda, Maryland 20817,					]            DEMANDED
								]
HUNG NGOC NGO						]
2304 Westmoreland Avenue					]	
Falls Church, Virginia 22096,					]
								]		
VIETNAMESE PUBLIC RADIO, INC.				]
900 S. Washington Street, Suite 302				]
Falls Church, VA 22046,						]
		Serve registered agent Hung Ngo			]
		2304 Westmoreland Street				]
		Falls Church, Virginia 22046,			]
								]
								]			
COMMITTEE FOR RELIGIOUS FREEDOM IN VIETNAM INC	]				
8001 Bradley Boulevard						]	
Bethesda 20817,							]
		Serve registered agent				]
		Ngo Thi Hien at the corporate address,		]
								]				
NGUYEN HONG THAI						]
11525 Dragonfire Way						]
Germantown, Maryland 20876,					]
								]		
THANG DINH NGUYEN 					]                  
6400 Arlington Blvd, Suite 640					]
Falls Church, Virginia 22042,					]
		    						]
BOAT PEOPLE S.O.S., INC.  					]                          
6066 Leesburg Pike			               		]
Falls Church, Virginia  22041,                       	  			]
		Serve Registered agent				]
		Nguyen Dinh Thang				]
		6400 Arlington Boulevard, Suite 640		]
		Arlington, Virginia 22042-2336 			]
		And serve also same registered agent		]
		at above address for corporation;			]
								]
TRAN NGHI HOANG						]			    
8552 Tyrolean Way						]
Springfield, Virginia 22153,					]
								]
LE PHAI, INC.  							]
d/b/a Le Phai Newspaper						]
8552 Tyrolean Way						]
Springfield, Virginia 22153,      					]
                     Serve registered agent					]
	         Tien Van Tran					]
	         at the above address,					]
								]
and 								]
								]
JOHN DOES as follows:						]
								]
JOHN DOE #1							]
  Whose real name is presently unknown, but 	                             ]	
  who, under the pen name LE MINH NGOC,			]
  writes in the Le Phai weekly newspaper				] 
  articles that defame the plaintiffs and cast				]
  the plaintiffs in a false light that are then				]
  broadcast on the programs of defendant VPR,			]
  								]
JOHN DOE #2    							]
  Whose real name is presently unknown, but			]
  who, under the pen name LE TAM writes and			]
  publishes articles on the website internetyahoo/thaoluan		]
  that defame the plaintiffs and cast them in a false light		]
  that are then broadcast on defendant VPR’s programs,
								]
			JOHN DOE #3				]
  Whose real name is presently unknown, but who			]
  broadcasts and hosts on VPR programs under the 			]
  broadcast name HUY DUC matter that defames the 			]
  plaintiffs and casts them in a false light in such 			]
  manner as to stir up members of the audience and			]
  threaten the plaintiffs with threats that include violence,		]
							]
JOHN DOE #4       						]
  Whose real name is presently unknown, but who			]
  broadcasts and hosts on VPR programs under the 			]
  broadcast name HOANG LAN matter that defames the 		]
  plaintiffs and casts them in a false light in such 			]
  manner as to stir up members of the audience and			]
  threaten the plaintiffs with threats that include violence,		]
								]                                                    
JOHN DOE #5							]
  Whose real name is presently unknown, but who			]
  broadcasts and hosts on VPR programs under the 			]
  broadcast name LE THI matter that defames the 			]
  plaintiffs and casts them in a false light in such 			]
  manner as to stir up members of the audience and			]
  threaten the plaintiffs with threats that include violence,		]
								]
JOHN DOE #6							]
  Whose real name is presently unknown, but who			]
  broadcasts and hosts on VPR programs under the 			]
  broadcast name THANH TIN matter that defames the 		]
  plaintiffs and casts them in a false light in such 			]
  manner as to stir up members of the audience and			]
  threaten the plaintiffs with threats that include violence,		]
								]
JOHN DOE #7  							]
  Whose real name is presently unknown, but who			]
  broadcasts and hosts on VPR programs under the 			]
  broadcast name HONG HANH matter that defames the 		]
  plaintiffs and casts them in a false light in such 			]
  manner as to stir up members of the audience and			]
  threaten the plaintiffs with threats that include violence,		]
								]
Defendants.							]

COMPLAINT

Plaintiffs, Hoai Thanh and Dai Chung, Incorporated, allege as follows:
NATURE OF THE ACTION
1)	 For years, and continuing to date, the individual defendants, working through the defendant purported non-profit organizations named above, also as defendants, as instrumentalities, have engaged in a conspiracy to mislead, deceive, and obtain money from the plaintiffs and other things of value, such as public relations from Vietnamese language media such as the plaintiff newspaper, by communicating to the individual plaintiff and others like him in the Vietnamese-speaking community in America, as listeners to the defendant Vietnamese Public Radio, Inc.’s broadcast system who are solicited to wire and mail money and property by U. S. mail or on line communications (all interstate) to the corporate defendants under false pretenses and a pattern of deception and misrepresentation over the wires and airwaves in interstate broadcasts.   This is done through programs put on by the defendant Committee for Religious Freedom in Vietnam, Inc., and also participation in and the conducting of programs by the defendant Boat People S.O.S. Inc., programs over the defendant VPR’s system.  
2)	 The individual defendants and their organizations claim to be raising funds for charitable causes which benefit the victims of floods, disasters and repression in communist Viet Nam and that “almost all” of the funds that they have so raised go for such purposes.  But in fact they have only devoted a small fraction of what they have raised to such purposes and divert the vast bulk of the funds that they thus solicit and raise to purposes other than those which they hold out.  
3)	 The individual defendants and their organizations commingle the funds and use them for their personal inurement and for their personal purposes and for harming those who are so bold as to question their use of funds.  They do this harming also through programs over their radio system into many states and cities which encourage and threaten violence and harm to any who ask for accountability or even question the individual defendants’ and their organizations’ use of funds.  
4)	 Anyone who so questions the individual defendants’ and their organizations’ use of funds, particularly any persons such as the plaintiffs, who have, however small by comparison, any Vietnamese-language media presence, then becomes the target of further deceptions of the Vietnamese community and its members in which the individual defendants and their organizations purport to be using the courts to harm “communists,” which is what they label those who question them through worthy lawsuits which are in fact part of the deception and misrepresentations.  In a continuing pattern which has lasted for years the individual defendants and their organizations solicit funds over the wires and airwaves in broadcasts to be mailed to them or wired to them through credit cards which funds they then transmit in interstate commerce for the purpose of putting on further programs, which include and encourage threats of violence against any who dare to even question the individual defendants and their organizations, the accuracy of their representations in the broadcasts and on their websites or that the motives of the individual defendants are anything other than what the defendants represent or that the individual defendants in any way obtain any inurement, even salaries, from the hundreds of thousands of dollars that they obtain from individuals such as the individual plaintiff in the Vietnamese community. 
5)	 In order to make the intended targets of these interstate wire campaigns to threaten violence seem worthy of this “law of the community” lynching held out as worthy of being above the American law, state and federal, the defendants engage in ruthless campaigns of misrepresentations about those who question them, such as the plaintiffs, in order to cast their intended targets in a “false light,” all funded by the defendants’ solicitation and obtaining of funds through wire and mail fraud campaigns in interstate commerce.  
6)	 As a further part of the campaigns funded by mail and wire fraud which they direct against those who question their use of the solicited and raised funds obtained through the use of these interstate wire programs, the defendants conduct systematic meritless law suits against those such as the plaintiffs who do so question their use of funds.  In order to fund these law suits against their intended targets such as the plaintiffs, the defendants compound their use of mail and wire fraud in interstate commerce by misrepresenting the merit of the law suits over the interstate wire system in order to raise funds to fuel the meritless law suits which they direct.  Defendant members of the associated-in-fact enterprise such as the defendant Nguyen Hong Thai, are lawyers and participants in the management of the associated-in-fact enterprise who conduct the meritless suits for the purpose, which defendants acknowledge in their interstate programs as part of their wire fraud, are intended to economically damage, harm and hurt those who dare to question the defendants’ use of funds without any regard for the merits of the suit.  The intended targets, such as the plaintiffs, are then the object of on-air boasts by defendants such as defendant Thang Dinh Nguyen, that they will be “hurt” and destroyed for offending, in the opinions held out by the defendants, the “Vietnamese community.”
7)	 These misrepresentations, these threats of violence, and this laundering of funds and transporting of goods illegally taken in interstate and even foreign commerce are planned and directed by the individual defendants Thang Dinh Nguyen, Hien Thi Ngo, and Hung Ngoc Ngo and the other individual defendants acting as an enterprise-in-fact which is directed by the three thus named and led particularly by Thang Dinh Nguyen, with the other participants in the structured and continuing enterprise in fact led by those three as they too participate in the pattern of racketeering activity as participants in the associated-in-fact enterprise.
8)	 The defendants have known for years that their broadcast representations to the Vietnamese language public were misleading and deceitful and that they have been misusing and failing to account for the funds which they solicit and obtain through the United States mail or through electronic interstate communications, according to the admissions of the defendant Nguyen Hong Thai.  Yet the defendants continue to enable and stir up threats of violence over the interstate wires and airwaves in broadcasts that they originate against the plaintiffs and any others who dare to question the misrepresentations of the defendants, question the defendants’ misuse of funds, and to ask for accountability from the defendants. They continue to launder funds and use and transport their funds illegally obtained through the mail and wire fraud as set out herein in interstate and foreign commerce for the stated purposes.
9)	 Each year thousands of Vietnamese-speaking Americans like the individual plaintiff are bilked and deceived by the defendants through their fraud in the use of interstate wire, airwaves and mail out of a cumulatively large sum of money which the defendants then use for both their private inurement and invest in their enterprises to stir up and incite threats against those such as the plaintiffs who dare inquire about the defendants and their ways and their use of the funds they solicit from the Vietnamese community in America.  Numbers of small Vietnamese-language media such as the plaintiff bi-weekly newspaper are similarly deceived and give support in their publishing as a result of these deceptions and misrepresentations.  The defendants’ conspiracy and scheme continues and will continue and be ongoing indefinitely unless they are made to answer for their liability to the plaintiffs and others similarly situated in the Vietnamese community in the U.S. 
10)	 Plaintiffs seek both economic damages and injunctive relief for the conduct alleged in this complaint.  Among other things plaintiffs seek temporary and then permanent injunctive relief against the stirring up of and enabling of threats of violence, the filing of the malicious and baseless law suits accompanied by threats (all of which the defendants lose), the use of the airwaves and wires in Interstate Commerce to misrepresent and deceive the Vietnamese-speaking public with false representations of charitable purposes, the use of the airwaves and wires to raise funds pursuant to deceit and misrepresentation for the purpose of bilking the individuals of the Vietnamese community such as the plaintiffs, the laundering of funds and the transporting of the funds illegally obtained in interstate and foreign commerce and for other such relief under pendant state counts. 
THE PARTIES
11)	 Plaintiff Hoai Thanh is a member of the Vietnamese-speaking community in the U.S..  He owns and operates and has owned and operated over the years auto and service station, car-wash and similar businesses, having been trained by U.S. oil companies in retail operations.  He also owned and operated for a number of years the plaintiff Dai Chung Bi-Weekly Newspaper.  He brings this action to obtain declaratory and equitable relief and restitution.  He seeks to recover the property in the form of donations taken from him by the defendants through their fraud and deception and to recover for the damage done to him for years thereafter up until last Christmas by their campaign of threats and intimidation using the wires and mail in a fraudulent and deceptive manner and their attempts to prevent him from going into court and bearing witness against them as well as by their use of interstate and foreign commerce to fund their enterprise with money obtained by fraud and deceit to damage him and destroy his businesses, and for their fraud and deception against all like him and their similar campaigns against the readers of his newspaper who sought to inform and assist him in questioning the fraud and deceit of the defendants and for using their fraud, deceit and intimidation, including threats, to drive away his customers in his auto businesses and his readers, subscribers and advertisers of, in and for his newspaper.
12)	 Plaintiff Dai Chung Incorporated is a corporation duly incorporated in the State of Maryland that did and does business as the Dai Chung Bi-weekly Newspaper.  It also seeks declaratory and equitable relief and restitution for the harm done it by the defendants through their wire and mail fraud, threats, including threats of violence and the use by the defendants of interstate and foreign commerce to damage its business and circulation, drive away and steal its advertisers through fraud, deception and threats of violence and their systematic attempts to prevent it, like the individual plaintiff, from being able to access the courts, including federal courts such as this to obtain redress.
13)	 Together, Hoai Thanh and Dai Chung Incorporated are referred to as “plaintiffs.”
14)	 Defendant Thang Dinh Nguyen is the president and chairman of the defendant Boat People S.O.S., Inc. and his and its offices are in the Commonwealth of Virginia at 6066 Leesburg Pike, in the Tysons Corner area of Fairfax County with a Post Office Address of Falls Church, Virginia.  He is also the principal architect and functions as the CEO or head of the association-in-fact enterprise comprised of himself and the defendants Hien Thi Ngo, Hung Ngoc Ngo as principals and chief operators with the other defendants as knowing and willful participants and lesser operators and participants.  He is on the board also of the defendants Vietnamese Public Radio and Committee for Religious Freedom in Vietnam or functions de facto as a director in a situation where the board is not formally maintained or disclosed.  With the two defendants next listed and alleged he organizes and controls the “command system” of the associated-in-fact enterprise, with its patterns of racketeering activity, some of which, as set out herein, affect the plaintiffs, and others of which, such as illegal immigration schemes and defrauding the government on contracts, do not affect the plaintiffs directly.
15)	 Defendant Hien Thi Ngo is one of the top three operating people and managers of the associated-in-fact enterprise whose actions are complained of and is, or holds herself out as, the president and chairman of the defendant Committee for Religious Freedom in Vietnam, Incorporated.  Her offices are at 8001 Bradley Boulevard, Bethesda, Maryland, where she operates out of her home.  She functions also as a board member or director of the defendant Vietnam Public Radio, Inc. in a situation where the selection of directors, if it exists, is not transparent and the corporations operate as non-stock operations where there are not formal rules or procedures.  She is the sister of defendant Hung Ngoc Ngo and both work closely with defendant Thanh Dinh Nguyen in the operation of his enterprises as well.
16)	 Defendant Hung Ngoc Ngo is one of the top three operating people and managers of the associated-in-fact enterprise whose actions are complained of and is the president and chairman of Vietnamese Public Radio, Inc.  His offices are at 2304 Westmoreland Avenue, Falls Church, Virginia.  He also functions as a director of defendant Committee for Religious Freedom in Vietnam, Inc.
17)	 Defendant Nguyen Hong Thai operates and participates in the associated-in-fact enterprise of the defendants to assure that the campaigns of intimidation and violence that are designed to prevent those such as the plaintiffs from questioning and exposing the fraud and deceit practiced upon them through interstate and foreign wire and mail by taking away their property through baseless law suits which he directs and participates in that are used to deprive those such as the plaintiffs of the resources to combat the campaigns of intimidation which include threats of violence.   He is a director of defendant Committee for Religious Freedom in Vietnam or functions as such de facto, as he does of the associated-in-fact enterprise of the defendants. 
18)	Defendant Tran Nghi Hoang joined and became an operator and participant in the association-in-fact enterprise when it was formed to carry out a campaign of intimidation with threats of violence in interstate and foreign commerce by using his newspaper, the Le Phai (Vietnamese which translates to English: “The Right”) weekly newspaper, of which he is the owner and operator, to publish articles and letters designed to cast the plaintiffs in a “false light” and by doing so to stir up violence against the plaintiffs which articles and/or letters then, under the direction of the heads of the association-in-fact enterprise, would be read on the programs of the defendant Vietnamese Public Radio, Inc., to target the plaintiffs and to inflame the desire on the part of the Vietnamese language listeners and readers to harm the plaintiffs in 22 states and the District of Columbia in order to threaten the plaintiffs and others like them.  He has continually used his newspaper to echo the campaign of the defendants to defame the plaintiffs and cast them in a false light before the public and will continue to do so unless stopped by this action or other legal action. 
19)	 Defendant Le Phai, Inc., is a duly incorporated and registered Virginia corporation that, under the ownership and control of the defendant Tran Nghi Hoang, owns and publishes the Le Phai weekly newspaper.  It participates actively in the pattern of racketeering activity and other torts alleged herein under the direction of the said defendant who in turn reports and is directed by, in matters of the associated-in-fact enterprise complained of, to the defendants Thang Dinh Nguyen, Hung Ngoc Ngo and Hien Thi Ngo.
20)	 Defendant Committee for Religious Freedom in Vietnam Inc. (“CRFV”) is a corporation duly incorporated in Maryland but presently not in good standing for failure to file a required annual form.  It is both a defendant in its own right herein and an instrumentality used by the associated-in-fact enterprise complained of to further its pattern of racketeering activity in interstate and foreign commerce.  The defendant Hien Thi Ngo is the president and chairman of the board of CRFV to the extent that can be determined in non-transparent non-stock corporation.  The defendants Hung Ngoc Ngo, Thai H. Nguyen and Thang Dinh Nguyen are on its Board of Directors and/or are held out to the public as so being on its Board of Directors and/or are directors of CRFV’s affairs de facto. This organization was not founded by the defendants, but rather by one Reverend Nguyen Huu Le, a minister and monk.  He and other religious monks participated in CFRV at its outset, but then the defendants Thanh Dinh Nguyen and Hien Thi Ngo took it over as part of the defendants’ pattern of racketeering activity, in order to use the funds as they wished for their private inurement.  When Reverend Le began to question the use funds, the defendants caused him to have to leave.  He continued his activities on behalf of religious freedom in Vietnam from Tampa, Florida with a new organization, the International Committee for Religious Freedom in Vietnam, whereupon the defendants, lest there be real help for the cause of religious freedom in Vietnam, rather than their ersatz control of the issue, sued the Reverend Le and launched a campaign of intimidation against him.  
21)	 Defendant Boat People S.O.S., Inc. (Boat People) is a corporation incorporated in Virginia. It is both a defendant in its own right herein and an instrumentality used by the associated-in-fact enterprise complained of to further its pattern of racketeering activity in interstate and foreign commerce.  Defendant Thang Dinh Nguyen is the Chairman of the Board and President of this corporate defendant as it is held out to the public and so far as it can be determined.
22)	 Defendant Vietnamese Public Radio, Inc. (VPR) is a corporation incorporated in Virginia. It is both a defendant in its own right herein and an instrumentality used by the associated-in-fact enterprise complained of to further its pattern of racketeering activity in interstate and foreign commerce.  Defendant Hung Ngoc Ngo is the President and Chairman of this corporate defendant. His sister, the defendant Hien Thi Ngo, and the defendant Thanh Dinh Nguyen participate heavily in the operation and planning of VPR’s activities and function as its directors, along with others, such as defendant Nguyen Hong Thai.  VPR is the primary instrumentality of the associated-in-fact enterprise whereby the defendants commit wire and mail fraud, incite and enable interstate threats, including threats of violence, use the funds illegally derived from their racketeering activity to engage in further illegal activity and predicate acts to harm those such as the plaintiffs who dare to question the defendants’ use of the funds that they solicit and to launder funds and otherwise commit illegal acts.
23)	 Defendant John Doe #1 is the individual, real name not presently known to plaintiffs, who, under the pen name Le Minh Ngoc, wrote a letter to defendant Le Phai newspaper dated May 25, 2002 (or so defendants claim) as part of a planned predicate act in which the letter was then used as the basis for a broadcast on defendant VPR to attack and threaten the plaintiffs, whic letter was then reused repeatedly in programs, week after week.  For example, on September 2, 2004, it was used in a broadcast again with different call-ins and embellishments.   And this repeated on or about December 23, 2004.  This particular letter, ostensibly of May 25, 2002, was first sent to plaintiffs, who invited the writer to talk the matter over or meet with them, but the writer did not respond to the plaintiffs’ invitation and refused to meet with the individual plaintiff.  The letter was merely a pretext for the defendants to then use in their fundraising wire and mail fraud with the plaintiffs as target, for their threats in interstate commerce against the plaintiffs as a target and their use of their funds illegally gained to “hurt” and target the plaintiffs.
24)	 Defendant John Doe #2 is the individual, real name presently unknown to the plaintiffs, who, under the pen name Le Tam, writes and publishes articles, as part of the plan of the defendants, on the website internet yahoo/thaoluan that attack and stir up threats against the defendants, defame them and cast them in a false light before the Vietnamese-language audience and public, which articles are then broadcast on VPR as part of the pattern of racketeering activity of the defendants.
25)	 John Doe defendants numbers 3 through 7, under the pen names Huy Duc, Hoang Lan, Le Thi, Thanh Tin, and Hong Hanh, are participants and operators in the associated-in-fact enterprise complained of.  They are the announcers and hosts on the broadcasts of defendant Vietnamese Public Radio who encourage and incite listeners and callers in to participate in intimidation of and threats of violence against the plaintiffs and work with the other defendants as voices and/or guests on the broadcasts to many states and the District of Columbia to that end.
26)	 Defendants Huy Duc, Hoang Anh, Le Thi, Thanh Tin, and Hong Hanh, are principals and operators in the pattern of racketeering and conspiracy complained of as hosts and announcers on VPR programs attacking the plaintiffs who participate in the inciting of threats of violence that are then acted upon against those who question the fraud complained of.
27)	 Together these defendants are referred to collectively as “defendants.”
28)	 As used in this complaint, the term “defendant” includes all predecessor and successor entities to the named defendants.
29)	 Each defendant corporation is sued individually as a primary violator and as an instrumentality participating and operating in the racketeering activities of the associated-in-fact enterprise of the individual defendants.  In so acting and operating as a primary violator and in the racketeering activities of the associated-in-fact enterprise of the individual defendants each defendant acted with an awareness of the fraud and the threats of violence against the plaintiffs and the other wrongful conduct complained of.  Each defendant nonetheless rendered substantial participation in carrying out the operation of the fraud, threats of violence and other wrongful conduct and was aware of its overall contribution to the conspiracy, scheme, and common course of wrongful conduct alleged in this complaint, namely the deceit and misrepresentation in soliciting funds and other things of value from the plaintiffs and others similarly situated among the American Vietnamese community, the threats of violence against the plaintiffs, the illegal use of illegally gained funds to harm the plaintiffs through the instrumentalities of interstate and foreign commerce and the operation and maintenance of their associated-in-fact enterprise to harm the plaintiffs and others similarly situated.  
30)	 Each individual defendant is sued individually as a primary participating and operating in the racketeering activities of the associated-in-fact enterprise of the individual defendants.  In so acting and operating as a primary violator and in the racketeering activities of the associated-in-fact enterprise of the individual defendants each defendant acted with an awareness of the fraud and the threats of violence against the plaintiffs and the other wrongful conduct complained of. Each defendant nonetheless rendered substantial participation in carrying out the operation of the fraud, threats of violence and other wrongful conduct and was aware of its overall contribution to the conspiracy, scheme, and common course of wrongful conduct alleged in this complaint, namely the deceit and misrepresentation in soliciting funds and other things of value from the plaintiffs and others similarly situated among the American Vietnamese community, the threats of violence against the plaintiffs, the illegal use of illegally gained funds to harm the plaintiffs through the instrumentalities of interstate and foreign commerce and the operation and maintenance of their associated-in-fact enterprise to harm the plaintiffs and others similarly situated.
31)	 Each individual defendant is sued as a co-conspirator.  The liability of each individual arises from the fact that each entered into an agreement with the other individual defendants and third parties to pursue, and knowingly pursue, the common course of conduct to commit and participate in the commission of all or part of the unlawful acts, plans, schemes, transactions and artifices to defraud and to intimidate, including the use of violence and threats of violence, the laundering and use of funds alleged in this complaint.
32)	 Defendants did and continue to commit their acts of racketeering against the plaintiffs and the other members of the Vietnamese language community in America and defraud and threaten violence and launder funds in the stream of commerce and pose a continuing threat that they will continue into the indefinite future unless stopped by legal actions such as this.  They have performed such acts as were intended to and did defraud, misuse interstate commerce, stir up and promote violence and threats of violence and improperly and illegally launder funds. They have continually caused tortious injury to the plaintiffs and others similarly situated in a pattern interwoven with such actionable predicate acts. 
JURISDICTION AND VENUE
33)	 This Court has jurisdiction over this subject matter under the Racketeer Influenced and Corrupt Organizations Act (RICO) under 18 U.S.C. §§ 1964 (a) and (c), 1965(a) and the Constitution of the United States.
34)	 This Court has venue because one of the plaintiffs is located in this jurisdiction, and the other was doing business here during pertinent times; a number of the defendants are located in this jurisdiction, many of the acts complained of took place in whole or in part in this jurisdiction, including particularly the baseless law suits against the plaintiffs and others similarly situated, and all of the acts complained of extended into this jurisdiction over the wires and airwaves in the broadcasts complained of.  Many witnesses are located in this jurisdiction and many others are in neighboring jurisdictions.  The scheme and pattern of racketeering activity complained of was devised in major part in this jurisdiction and in substantial part executed in this jurisdiction as one state among the many in which it was executed.  This jurisdiction has, over all more connection with that activity than any other single state.  All defendants have transacted their business and acts complained of in this District for the purposes of the venue provisions of RICO, 18 U.S.C. § 1965(a).
COMPOSITION OF VIETNAMESE LANGUAGE MEDIA MARKET AND INDUSTRY IN THE UNITED STATES

35)	 At all relevant times, the individual defendants Thang Dinh Nguyen, Hien Thi Ngo, and Hung Ngoc Ngo, and those working with them in their associated-in-fact enterprise, have sought to dominate the narrow market for Vietnamese language media in the United States through the use of the instrumentality of the defendant Vietnamese Public Radio, Inc.  
36)	 They operate through their instrumentalities, Committee for Religious Freedom in Vietnam, Inc., headed by defendant Hien Thi Ngo, and Boat People S.O.S., Inc., headed by defendant Thang Dinh Nguyen, as well as Vietnamese Public Radio, Inc. to give a veneer of being solely for the public good, with no profit accruing to themselves, with constant solicitations for donations and funds over the multi-state broadcasting system of VPR to create the impression of being solely for the good of the community from which they receive no profit or remuneration.  In reality they reap large profits from a number of fraudulent schemes of private inurement out of the donations that they solicit and receive through commingling of funds, laundering of funds, diversion of funds from the stated purposes that they use to raise the funds and otherwise use the funds to maintain and operate their enterprises to harm any who dare to seek accountability from them, verification of their claims, or even question what happens to the proceeds of their solicited donations.
37)	 The Vietnamese language media market in the United States is small, perhaps 1.2 million nationwide.  Even in an important metro area such as this Washington, D.C. area, it numbers no more than seventy-five thousand. It is a relatively isolated market for historic reasons: the Vietnamese community here is by and large an émigré community comprised of those who stood with us in the Vietnam War and then had to leave because they did so.  They remember how, starting with the Tet offensive, their and our victories, fighting side by side, were cast by our media as defeats.  The Vietnamese community in America, therefore, looks to its own media for most of its news, not trusting completely our main stream media.  
38)	 Yet there are a large number of Vietnamese language newspapers in every Vietnamese metro area, all of them small, and mostly surviving by paid advertising aimed at the Vietnamese language community.   In this metro area of Washington, D.C., for example, there are 13 Vietnamese language newspapers.
39)	 By reaching into many states through the defendant VPR the defendants are able to dominate in such a narrow market as, in the days of only three major nationwide regular broadcast networks, CBS, NBC, and ABC, the mainstream networks could dominate.  According to VPR’s website, it broadcasts or relays in 20 cities nationwide and reaches at least 24 cities.  It reaches Washington, D.C., Maryland, including Baltimore, Virginia, and has locations in Wichita, KS, Atlanta, GA, Tampa Bay, FL, Austin, TX, St. Louis, MO, Kansas City, KS, Boston, MA, Portland, OR, Philadelphia, PA, New Orleans, LA, Grand Rapids, MI, Denver CO, Oklahoma City, OK, Baton Rouge LA, Louisville, KY, Biloxi, MS, Seattle WA, Dallas TX, and Lincoln NE.  The VPR broadcast system also reaches audiences in Arizona, California, New York, Connecticut, and New Jersey.  No other Vietnamese language media has this kind of coordinated, nationwide reach and it is this reach upon which the defendants impose their command structure.
40)	 This market structure has enabled the defendants, in recent years, and has facilitated them, in the planning, implementation, operation, and funding, of a pattern of racketeering activity and conspiracy to conduct the same, by posing as non-profit, do good entities while in reality reaping large and handsome private inurements for the three principal heads of the defendants’ associated-in-fact enterprise and engaging in the pattern of racketeering complained of in this complaint.
NATURE OF CONSPIRACY AND ASSOCIATED-IN-FACT ENTERPRISE ACTIVITY
41)	 This action claims damages arising out of an ongoing conspiracy by the primary actors and defendants Thang Dinh Nguyen, Hien Thi Ngo and Hung Ngoc Ngo and the other defendants and third parties working with them as well as out of the pattern of racketeering exhibited by their associated-in-fact enterprise.  The goal of the conspiracy is to dominate the market for Vietnamese language media to serve as a vehicle for a massive fraud involving purported fundraising for ostensible charitable and Vietnamese patriotic purposes through a fraudulent plan, scheme, design and effort in which the interstate wire and broadcast capabilities of VPR were used to solicit money, public relations and other valuable items and services by fraud and deceit, the money to be mailed and/or wired to them and their controlled organizations in order that they might, as they have done, commingle it and use it for their personal and other business purposes without accountability.  
42)	 The named individual defendants have pursued a conspiracy of deceit and misrepresentation against the plaintiffs and other Vietnamese-speaking individuals and their businesses in the American Vietnamese-speaking community.  It is a conspiracy designed to deceive the listening audience across America into giving money and other things of value to the defendants and their defendant organizations for the ostensible purpose of expanding religious freedom in Vietnam and contributing to charities targeted at Vietnam in such a manner as to weaken the hold of communism in Vietnam and to suppress those who are sympathetic to communism and pose a threat to anti-communism.  In reality the defendants are almost completely ineffectual in achieving any of these purported goals because they use the funds for other purposes than those they claim to espouse, such as their own personal inurement, the capitalizing of businesses that they own or that are owned by those with whom they are allied, to threaten those who dare to question their use of proceeds or ask for accountability, and for other illicit enterprises, such as fraudulent immigration assistance and counseling, government contracting that does nothing to achieve what it claims to achieve, and the like.
43)	Thus the conspiracy is two-fold.  First they deceive the public into giving them money and other things of value using their unique nationwide status as having a network with reach into all the Vietnamese speaking community in America and the mails, using the funds that they receive for their personal inurement rather than the purposes they pronounce in order to obtain it, then they use threats, including of violence, and knowingly stir up violence against those who question them.  They thus deceive their fellow Vietnamese in America that they are doing something against communism and the hated Vietnamese communist regime from which the Vietnamese in America fled, and then, so strong is anti-communism, as they know, amongst the Vietnamese language community here, that they falsely accuse any who question them of being communist in order to willfully provoke violence and a continuing threat of violence against any who so threaten them.
44)	This constant campaign of misrepresentation on the one hand, and intimidation and the promoting of anti-Communist feelings leading to threats of violence and attempted violence by Vietnamese in America against Vietnamese in America on the other is designed to deceive and confuse the Vietnamese language audience in America and then to intimidate and confuse them further about the use of the moneys which the defendants trick the Vietnamese listening audience into giving by using the money to intimidate those who question what happens to the money under the further deceit and fraud of labeling those who question the use of proceeds as communists.  
45)	The defendants count on the resulting public trust that the create through their fraud and deception against the plaintiffs and those similarly situated to misrepresent, suppress, and confuse accurate information and reporting on who is actually helping the communists and those who are actually seeking to do something to effectively combat the communist government in Vietnam by seeking the truth about who is actually doing something effective to help the people of Vietnam move out from under Communism versus those who are only pretending to do something effective.
46)	These frauds, deceptions, and intimidations have the effect of supplanting effective action and publishing by newspapers such as the plaintiff newspaper and destroying competitive Vietnamese language media such as the plaintiff newspaper by virtue of the fraud and deception taking away readership and driving away the advertising on which most Vietnamese language newspapers and other media depend. 
47)	Thus, the retaliatory campaigns of intimidation, including stirring up anti-Communist motivated violence against those who question the use of funds raised by the fraud and deceit are themselves part of the deceit.  For those retaliated against are as anti-Communist as the rest of the Vietnamese speaking community in America, but they are placed, through the racketeering activities of the defendants, in the false light of being Communist as part of the deception that the defendants are actually doing something to bring about better, non-Communist government in Vietnam and helping their fellow Vietnamese here through charitable efforts.  To the Vietnamese speaking community in America “Communist” is a concrete defamation, not an abstract concept, and being placed in the false light of being “Communist” when you are not is the most harmful thing that can be done to you.
COUNT I

(Federal Racketeer Influenced Corrupt Organizations Act-Pattern of Racketeering Activity)

48)	Plaintiffs restate and incorporate all the preceding paragraphs of this complaint.
49)	This claim for relief is asserted against each of the defendants and arises under 18 U.S.C. § 1962 (c) as to all defendants and also (d) as to the individual defendants among themselves as an associated-in-fact enterprise.
50)	At all relevant times, each of the defendants was a “person” within the meaning of 18 U.S.C. § 1961(3), as each of the defendants was “capable of holding a legal or beneficial interest in property.”
51)	At all relevant times, the defendants Thang Dinh Nguyen, Hien Thi Ngo, and Hung Ngoc Ngo led and directed an associated-in-fact “enterprise” within the meaning of 18 U.S.C. § 1961(4) that was constituted of themselves, the other individual defendants and also the three corporate defendants as their controlled instrumentalities.  This associated-in-fact enterprise is ongoing and it has an ascertainable structure with these three as its directors and Thang Dinh Nguyen functioning as its chairman and the other defendants having assigned and ascertainable roles within it.  The three corporate defendants are also “enterprises” within their own right.  These enterprises are ongoing and have purposes beyond the scope of the predicate acts alleged in this complaint and beyond the conspiracy of the defendants in forming and operating and maintaining this associated-in-fact enterprise.  The purpose and function of the main associated-in-fact enterprise is to maximize the defendants’ control of Vietnamese-language media in the United States and dominate fundraising in interstate and foreign commerce in the Vietnamese language media markets and correspondingly dominate allegedly charitable giving in the Vietnamese language community in America for anti-Communist and purportedly charitable purposes in this country and for Communist-controlled Vietnam and also to dominate contacts between the Vietnamese language community and the wider American community in a public relations sense, especially with members of Congress and the non-Vietnamese language media.   The three corporate defendants as sub-enterprises participate as instrumentalities in this effort.  Each enterprise engages in, and its activities affect, interstate and foreign commerce.  
52)	 Each defendant has been associated with this associated-in-fact enterprise and has conducted or participated in its operations and activities, directly or indirectly, through a pattern of racketeering activity in violation of 18 U.S.C. § 1962(c).  The three defendants Thang Dinh Nguyen, Hien Thi Ngo, and Hung Ngoc Ngo, have directed the associated-in-fact enterprise and the corporate defendants, each of which is headed by one of them in such pattern of racketeering activity.  Defendants’ pattern of racketeering activity dates from at least 1998 and continues to the present and will continue into the indefinite future unless halted as a result of legal action.  Defendants’ multiple predicate acts of racketeering include:
a)	Mail and wire fraud, in violation of 18 U.S.C. §§ 1341 and 1343.  Defendants engaged and are continuing to engage in schemes to deceive and defraud members of the Vietnamese language public in the United States.  These schemes have involved fraudulent misrepresentations and omissions reasonably calculated to deceive the Vietnamese language public that listens to the broadcast system of the defendant VPR in 22 states, deceiving individuals that are persons of ordinary prudence and comprehension.  They also involve “lulling” and the suppression of the truth about the fraudulent activities of the defendants.  They execute these schemes by wire and radio transmission in Interstate Commerce and by the United States mail.
i)	Defendant VPR’s broadcasts of programs by and about the defendant Committee for Religious Freedom’s activities supposedly in assisting the victims of flood relief in Vietnam and in helping religious figures there in such efforts, broadcasts in which the defendant Thang and his company, Boat People SOS, participated, communicated over the VPR broadcast system, were designed to and did solicit funds, which were paid to VPR and CRFV by the use of the U.S. mail and interstate wire communications to transfer credit, pursuant to deceptions about what the defendants had in mind to do with the funds and what they did do with the funds, a deception which they still continue.
ii)	Defendants’ programs directed toward individual Vietnamese-speaking Americans such as the individual plaintiff, and small businesses in the Vietnamese media market, such as the plaintiff bi-weekly newspaper, were designed to solicit funds and favorable public relations and press mention under false pretenses, as alleged, and in doing so to create a dominance by the defendants of Vietnamese public language media on a national basis, in every state where there is a sizeable Vietnamese-speaking population.  These broadcasts containing these deceptions are broadcast every week three or four times and have been so broadcast for many years.
iii)	The plaintiff Hoai Thanh was favorably impressed by these broadcasts and gave donations, writing checks and giving cash in 1997 and then from time to time up through 2000, and to the end of the year 2001 and for a while afterwards and continued to be favorably impressed with what he was led to believe were the good and charitable works of the defendants to which the claimed they devoted “most” of the funds that they solicited and received for the promoted good purposes.  Hoai Thanh’s bi-weekly newspaper, the plaintiff Dai Chung Bi-weekly Newspaper, gave the defendants favorable mention in the writings it contained.  Some of the defendants advertised in the Dai Chung newspaper, advertising their supposed good works as part of the deception, placing ads over the interstate wires and using the mail.
iv)	In the early spring of 2001, however, the plaintiff Hoai Thanh began to wonder about the use of the proceeds that they were raising by the defendants, particularly their claim to have transmitted large sums of money to Vietnam for assistance to flood victims there through the liason of one Father Ly, a well known Catholic priest in Vietnam. In issue number 68 of Dai Chung Bi-weekly Newspaper, published March 1, 2001, plaintiff Hoai Thanh and his plaintiff newspaper raised the question for their Vietnamese language readership in the Washington, D.C. interstate metro area and nationwide in states such as Pennsylvania, of what was happening to the funds that the defendants were raising through the CRFV programs on VPR several times every week in which the defendants Thang Dinh Nguyen and Boat People participated.  They did so merely in a questioning manner and for many months thereafter tried to work with the defendants to try and make the public understand what was going on, still trying to support the defendants’ efforts in the hopes of giving the public a clearer understanding, including accepting documents from the defendants that the defendants claimed would support the defendants’ representations.
v)	As a result of that questioning in the plaintiff Dai Chung newspaper, the defendants began a campaign through the CRFV and Boat People broadcasting over VPR of “lulling” in which they sought to convince the plaintiffs and others similarly situated in the American Vietnamese-speaking population and among the local Vietnamese language publications in the many states to which their broadcasts were transmitted that the defendants could account for their use of funds that they had solicited and obtained by means of wire, radio transmission and mail in interstate commerce.  Plaintiffs tried to cooperate with these efforts and only after a year or more had to reluctantly conclude that these representations were a further implementation of the defendants’ pattern of racketeering activity.  The defendants never did and could not account for their use of the funds for the purposes that they falsely and fraudulently claimed that they were for and the representations made over the interstate wire and radio that the defendants could and had accounted for their use of the funds were a further fraud of deception and omission using interstate wire, radio and mail.  Continuing the deception and omission with this “lulling” against the plaintiffs and others similarly situated in the Vietnamese-speaking community in America, the defendants raised further funds which came in by U. S. mail and wiring of credit to the defendants to, as defendant Thai Hong Nguyen put it, “hurt” those such as the plaintiffs who dared to question the defendants’ use of funds.
vi)	Ultimately the defendants carried this “lulling” to further fool the Vietnamese-speaking community in the United States through their broadcasts to the extent of filing baseless lawsuits against the plaintiffs and others who questioned the defendants’ use of funds and then further fraudulently claiming that they were winning these lawsuits when they were not, misrepresenting what was happening in the courts in order to fraudulently raise further funds by fraudulent misrepresentations and omissions in order to “lull” the audience into believing that their false representations and omissions were being vindicated in the courts.
vii)	Defendants made false and fraudulent statements under oath and penalty of perjury in these law suits and then broadcast these false and fraudulent statements nationwide through the VPR system. The defendants affirmatively denied their fraudulent representations and their failure to use the funds they solicited and raised as they had represented they would use the funds.
b)	Interference with commerce by threats or violence in violation of 18 U.S.C. § 1951.  As the plaintiffs persisted in questioning the use of funds by the defendants contrary to the defendants’ representations in the defendants’ interstate radio programs, the defendants initiated a campaign of threats of violence and intimidation against the plaintiffs in a pattern of racketeering activity that the defendants knew full well would lead to attempts of violence against the plaintiff Hoai Thanh, as it did do. 
1)	Repeatedly, week after week, month after month, year after year and right up to the present, the defendants broadcast through the VPR system indicating that the plaintiffs were communists.  In the context of the Vietnamese language community here in the U.S., this is not an abstraction but a concrete defamation among those who fought communism, bled and died in doing so, saw their country of birth taken over by a brutal communist regime and have witnessed atrocities against their country and its people ever since.  The constant accusation of being a communist can cause intimidation and violence as defendants well know.
i)	In one of a thousand examples, in a broadcast over VPR October 6, 2001, while other defendants were still purporting to be working with the plaintiffs to clarify matters for the Vietnamese public and support their claims, the defendant Huy Duc set a tone, saying: 
 “You will see the communist flag in this newspaper.  As far as we know, it is probably copied from the Communist Quan Doi Nhan Dan newspaper and a communist website.  That’s why there is a Vietnamese communist flag.  Perhaps you will understand where the truth is.  Please read those pages.

These comments and others in the broadcast elicited comments from callers in in the Vietnamese language such as: “To tell you the truth, if those people [plaintiff Hoai Thanh and his newspaper personnel] lived next to my house, I might have stabbed them to death.”  Another comment was: “If I were you they would not get out of my house.  After their being knocked out in my house, I would have police pull their body out.”  Defendant Hung Ngic Ngo and defendant Hien Thi Ngo participated in this broadcast as the hosts also, prompting and eliciting these threats of violence.  A caller suggested not going after the plaintiff newspaper, to which a host responded: “Do you think we should surrender or defeat communism?”
ii)	These representations were all false and known to defendants to be false.  In fact the plaintiff Hoai Thanh served in the Vietnam War against the communists in the army of the late, lamented Republic of South Vietnam.  He was an intelligence officer working closely with the American military as a liaison.  The plaintiff newspaper, by any objective standard, has been anti-Communist in its content throughout its existence.
iii)	The aim of the defendants is to supplant and displace those like the plaintiffs who are publishing and working against communism in their work in the Vietnamese community with a fraudulent version of anti-communist activities that is a cover for their personal power and inurement. 
2)	In a further attempt to stir up threats against the plaintiff Hoai Thanh, the defendants also broadcast week after week, month after month, year after year, purported documents setting out fraudulent misrepresentations and omissions about the plaintiff Hoai Thanh in his personal businesses other than the defendant newspaper.  On September 2, 2004, for example, the defendants broadcast a purported letter saying that plaintiff Thanh had defrauded and cheated innocent Vietnamese business people in America of tens of thousands of dollars.  The representations were false, known to be false and were deliberately misleading.  They repeated this broadcast on or around December 23, 2005 and again shortly after Christmas.
3)	Here is an actual broadcast transcript from some broadcasts:
Operator: Good evening, Vietnam Radio Overseas listeners. My name is Ngo Ngoc Hung. [Defendant Hung Ngoc Ngo] Today we would like to provide you with the correspondence response program, Sunday, October 21, 2001. Tonight we have a lot of important things to share with you. Please stay tuned. First of all, we sincerely thank audience members who have been donating to the station and who offer continued support by sending us their comments. You will be receiving a thank you letter from us this week.

UM1: About this daily newspaper, I think you already know that there is only 1 part that we would like you take a look at: page 27, Print No. 71. There is the list of the formal delegates visiting Vietnam with Mr. Nguyen Tuan. You will see the communist flag in this newspaper. As far as we know, it is probably copied from the Communist Quan Doi Nhan Dan newspaper and a Communist website. That’s why there is a Vietnamese communist flag. Perhaps you will understand where the truth is. Please read those pages.

Sorry, please wait for a second.

The reason why we had some trouble responding to you is the amount of money for flood relief in central Vietnam. Almost the whole amount has been sent to the current leaders in Vietnam, who perform excellent social activities as well as a very high merit of fighting. They are listed as follows: First, farther Nguyen van Ly, Superior monk Thich Thai Hoa, farther Giai, farther Loi and the sisters and the Buddhist charity groups. As you know, even though people like farther Ly and farther Giai experienced some difficulties at that time, they were still able to perform social activities. However, up till now, their fighting has not been strong enough. Therefore, we also expected some suspects in the flood relief issue. This was what we did wrong during the period of flood relief. If you have the flood relief document, you will see page No. T16. When opening this page, you will see the posted date of March 27, 2000. The Committee of Freedom Religious (CFR) has sent to farther Ly (You will see: Nguyen Van Ly, Hue, Vietnam and the account number) the amount of $31,000 (please open the document), which was wire-transferred from the bank of the CRFV to farher. Ly’s bank account, which is Vietcombank, 46 Hung vuong, Hue, Viet nam, and the account of farther Nguyen Van Ly as well. That was our mistake, because in the United States of America when you sign an over-$10,000 check, the check will be investigated. The reason for this law is that they want people of notorious background, especially “money launderers”, which means that they send their money from one bank to another. Therefore any amount of over $10,000 must be sent through this system. That was the mistake of the CRFV.

UF1: Hello.

UM2: Yes, I’m listening.

UF1: Hello, I have a comment. I live in Boston. I turned 70 this year. I have heard what you said on the radio about sabotage and I have a question about the amount. It is said that “don’t let your left hand know the charity done by the right hand” [a Vietnamese idiom]. How much did those people donate while they keep sabotaging? Mrs. Ngo Thi Hien works for the community . . . It is said not to share the same language. Most of the times they call the radio station to ask for help in everything. I think those people could have been sent here by Viet Cong to commit sabotage. “Receive benefit from the state but worship the communism” [fixed expression]. You should not be dependent on them. Vietnamese people living here are all anti-communists, not just a few individuals. Therefore you don’t have to hold talks with them to be truthful and upright. Being truthful and upright is a matter for hundreds or thousands of people, not just for them. Put them aside. To tell you the truth, if those people lived next to my house, I might have stabbed them to death.

Operator: Thank you very much.

UM2: My name is Minh. Good evening Ms. Ngo Thi Hien. [defendant Hien Thi Ngo] I have been with the station for quite a long time and I know that you have made a great contribution. I would like to make a suggestion about bringing an action against Dai Chung newspaper. I think you shouldn’t do that because what we did is for justice and Dai Chung newspaper is the unfounded saboter, supported by the domestic Communists.

Mrs. Ngo Thi Hien: Mr. Minh, pardon me for interrupting you here. Do you think we should surrender or defeat communism? In Vietnam, we can surrender to communism because there is no law but the law of the jungle, but here we need money. I don’t think it will become the second O.J. Simpson.

Mrs. Ngo Thi Hien: October 6, 2001.
What can we do while South of Vietnam is getting worse and worse? Two difficult years have resulted in extreme poverty amoung the poor, taking the lives of many innocent citizens, especially of ill-fated children. In the spirit of “blood is thicker than water” [Literally, means “if the blood is split, the gut turns soft”], we appeal to your charitable hearts, who wish to mollify some of the poverty, misery and calamity descending to our consanguineous people. You may wish to send a check to: Vietnamese Committee of Free Religion, P.O Box 342111. MD 20827. All donations for flood relief to Committee of Free Religion are tax exempted.
We really appreciate it.
Best regards,

UF3: Mr. Banh, from Maryland.

Mr. Banh: Good evening Ms. Hien, Ms. Hoang Lan and the audience of the Vietnam Radio Overseas. Dai Chung newspaper has criticized the donation of relief and has sabotaged the Radio of the Free Vietnamese behind the radio announcer’s back, such as Ms. Ngo Thi Hien, has barred our voice and jobs. I have told Dai Chung newspaper...this is an application of the law of the jungle like that of the Viet Cong. Many people complainted that Mrs. Hien is as gentle in her character as her name [Hien means “Gentle” in Vietnamese]. What a pity that you are so courteous. If I were you, they would not get out of my house. After their being knocked out in my house, I would have police pull their body out. And this sabotage is to stifle our voice and bar our relief fund in the future. From this, our fellow-citizens can see the purpose of Dai Chung newspaper. I think the fellow countrymen and the audiences will support the words of anti-communists. 

Mrs. Ngo Thi Hien: Good evening. 

Now Mr. Hien, please. Good evening, Mr. Hien.

Mr. Hien: Yes. Good evening Mrs. Ngo Thi Hien, Ms. Minh and others at the station. I think that what Mr. Sinh just said was unfounded. Since we are in Tesla, we don’t know what rag Dai Chung newspaper is. Honestly, we did not know anything until we heard from the radio. Do you know which state that newspaper is based in? The way they combat is quite a sabotage. According to your station, they have strong support. perhaps they have a lot of money to hire an attorney, as in Kim Xuan’s case. I would also like it if audiences would support the station so that it can have an attorney bring an action against/sue them. Otherwise they represent a group of people. It means that we fight against communism and they are against us, so it means they are some force. We also expect that the audience will support our legislation fund to bring them to court. Bye.

Mrs. Ngo Thi Hien: Thank you very much. We think that if we give our hands, we must believe that we will win. 

Ms. Nam, please.

Ms. Nam: I’m Nam in Boston. Good evening, Mrs. Hien. Good evening, everyone and all...

Mrs. Ngo Thi Hien: 

Ms. Nam, turn off the radio please!

Ms. Nam: I think that Dai Chung newspaper did that one purpose. It means that they have a strong support. That’s why they have done it. If we sue them, will we win? What if they have a huge financial support from a nation? They could prove black is white. We still don’t know their real ability. What Mrs. Hien has done is right. But when black is proven to be white, it will be clear who gave that amount to them. They are against the radio station, meaning that they are against all Vietnamese nationals, but not only Mrs. Hien, Mr.Ngo Ngoc  Hung or anyone working at the station. That’s all I have to say.

Mrs. Ngo Thi Hien: Thank you Ms. Nam. Ladies and gentlemen, honestly the comments sent to us are right. We believe that we have to contend with a force, which is stronger than us. We have lost our country. If we want to get it back, we must have resistance. Do not think that we can lose, just let it be. We will try and we promise you that if you agree and support us, we will bring glorious victory to stamp out the old shame. If we let them win, not only will this committee of religion be wiped out but also hundreds of other people. Then what will be our nationals’ voice? Next will be Mr. Minh.

Mrs. Ngo Thi Hien: My name is Minh. Good evening Mrs. Ngo Thi Hien. I have been with the station for quite a long time and I know that you have made a great contribution. I would like to make a suggestion about bringing an action against Dai Chung newspaper. I think you shouldn’t do that because what we did is for justice and Dai Chung newspaper is the unfounded saboteur, supported by the domestic Communists.

Mrs. Ngo Thi Hien: Mr. Minh, pardon me for interrupting you here. Do you think we should surrender or defeat communism? In Vietnam, we can surrender to communism because there is no law but the law of the jungle, but here we need money. I don’t think it will become the second O.J. Simpson. We don’t think so. O.J. Simpson has been supported by those who have the same color skin as them. But here, we must know that we are Vietnamese nationals. Communism was lucky or indebted to some miscreants who took over our Vietnam. But someday we must defeat them. We must defeat them completely. In the meantime we say that we will lose, then, if we don’t take action, when we could get our country back.

Mr. Banh: Good evening, Mrs. Hien, Ms. Hoang Lan and the audience of the Vietnamese Public Radio. I’m Banh, from Maryland State. Dai Chung newspaper, criticizing the donation of relief and sabotaging the Radio of Free Vietnamese behind the radio station’s back has barred our voice and our jobs. I have told Mr. Hoai Thanh’s Dai Chung newspaper that this is an application of the law of the jungle like the Viet Cong did. Many people complained that Mrs. Hien is so gentle in her character as her name [Hien means “Gentle” in Vietnamese].  What a pity that you are so courteous. If I were you, they could not get out of my house. After their being knocked out in my house, I would have police pull their body out. And this sabotage is to stifle our voice and bar out relief fund in the future. From this, our fellow-citizens can see the purpose of Dai Chung newspaper. I think the fellow countrymen and the audiences will support the words of anti-communists. And Ms. Hien should help our fellow citizens to fight for our future and for our unhappy people in Vietnam. We should do something and Dai Chung Newspaper’s reporters should do something for our unhappy Vietnamese in the home land. We have seen clearly what Dai Chung Newspaper has done. That’s all.

Mrs. Ngo Thi Hien: Thank you Mr. Banh very much. Thank you to all of you who want to express your comments. But it is getting late now. We really appreciate those who called in to convey their accurate opinions and comments. Though some of you thought that they were so strong while we are weak, we should not bring them to court. We will leave this for you to comment. We are in a weak position, so we must do something to improve our position...so that we can win, do you agree? We have here some of you who can support, but those who still have other issues to be concerned about, please spiritually support us. To that extent we feel happy to continue our job in the future. See you again. Once again, the address of the Vietnam Committee of Free Religion is: P.O Box 342111. MD 20827. Thank you very much.

...it was so shameless to bang his fist on the table and ask for the records. When we wrote a press release requesting you not to get close to our house, you responded by writing an article with the title “Madam President of the Vietnam Committee of Free Religion needs to study American laws”. At that time, you adduced a law. Since we are not aware of the legislation system, we had to consult with some attorneys. It seems that none of them know about your so called [...] law. We found that you are so aware of laws. So we had to ask our attorney to bring actions against you and request the court order you not to come near our house and office. We hope that you have a chance to talk to the judge about your [Sunshine?] law.

Ladies and gentlemen, Mr. Hoai Thanh forgot his law book at home, so as soon as he got into the court, he asked the attorney to inform us that he had surrendered and would comply with our requirements and never come to our office.

Ladies and Gentlemen, let me raise a question: Is there anything worthy of complaint in a case of having got what was wanted without spending a minute in court? Our attorney still hadn’t agreed while Mr. Hoai Thanh had stated conditions. Do you know what were the conditions? They were that the Committee of Free Religion has to promise not to broadcast on air that he lost this time. Yes, you did not hear by mistake. Mr. Thanh surrendered and promised likely not to come to our house and office with the condition that we have to keep this case confidential and not to talk on the radio so that people can know that he surrendered.

UF5: Mrs. Hien, you have talked about Mr. Hoai Thanh so far. I was wondering when you saw Mr. Hoai Thanh, were you afraid?

Mrs. Ngo Thi Hien: My impression was that he came here without an appointment. My house is located in a relatively large area. The distance between houses is wide, so an appointment needs to be arranged. Only the postman or a ticket deliveryman do not need appointments. So the image of him giving me a pile of documents and banging on my table to ask me to give him this and that makes us feel scared everytime the doorbell is rung. This morning when we met him at court, we did not dare to look at him. This fear can be compared to Nam Anh’s fear of a caterpillar or a snake. For example, we are scared of being bitten by a tiger, but a tiger is bigger and stronger than us, we must say. In case we find that a caterpillar is so descpicable, but we are still scared of it and we don’t want to get close to it. That’s what I am really afraid of from now until the court date and when I see Mr. Hoai Thanh. This fear will never be forgotten for the rest of my life. So to answer Nam Anh’s question: I am really scared. But have you ever seen a caterpillar on your skin?

UF5: (Smile)

Operator:
Now, for the rest of our time, we would like to tell you briefly about this morning in court. As we have said earlier, Mr. Hoai Thanh’s attorney came to negotiate before the hearing had started that Mr. Hoai Thanh had surrendered and agreed that he would never come to our house. Then Mr. Hoai Thanh suggested that he surrendered with only one condition: that we had to keep this morning’s hearing a secret and not to say on the radio that he had lost at the hearing. Actually, as you see, for the past few months, the radio station has appreciated the time for us to open our heart about what needs to be done rather than talking about things that may be important to our life but not as important as what we need to do for our country. Thus, we probably realize that in the past few months we haven’t mentioned about the issue of Dai Chung newspaper. So we also think that it’s not important. The matter of who’s right and who’s wrong has been known, so we don’t view it as an issue needing to be talked about on the air. But when Mr. Hoai Thanh, though he had surrendered, set this condition for us, we found it unacceptable. For us, the winner is the decider, not Mr. Hoai Thanh, who told us what to do. For us, we just say the truth. And we think that no one has the right to force us to act against our working concept and methodology, just because of their honor or embarrassment. Our answer was no, because we had come to appear in court. If you don’t want to appear in court, you must agree that you would not come to our house and office. About broadcasting on our radio, our right to do so is not subject to your wish/command. Finally, Mr. Hoai Thanh knew that if he entered the court the same result/judgement was waiting for him. Why did he come to our house and, in his anger, risk doing something he might have regretted later on? So he knows that if he raised his hand in defense he would still lose the case. Eventually, he let his attorney talk to the judge. Mr. Hoai Thanh’s attorney and our attorney standing in front of the judge said iut was fine and I would write it in the report. So, we didn’t stay long because without entering the court Mr. Hoai Thanh had agreed to comply with our requirements. In his article “Madam president of the Vietnam Committee of Free Religion needs to study American laws”, Mr. Hoai Thanh wrote “an incomparable visit in my life is satisfaction enough.” Ladies and gentlemen, he visited our house asking for documents. We did not give them to him but because he felt so satisfied that this morning he had to agree to surrender and promise from now on he would never come near our house! And even though he is SO good at law, he still will be chastised by laws. In fact, we did not want to make a big fuss out of the case, but it is so ridiculous to give conditions upon losing the case. When he slandered us, I wondered whether he would ask our permission in order now to ask us to hide what he doesn’t want to be seen. Well, we don’t want to talk about anything more about this for sure. But if we have a chance, our Committee of Free Religion will be on the radio to tell you about what’s going on in this stressful and profitless dispute so that you can understand and sympathize with us. We think that what Mr. Hoai Thanh wrote in his articles was to gag the committee because the committee has done something which encountered his idea or offended his boss. To answer Nam Anh’s question of whether Mr. Hoai Thanh is scared, for the past few weeks we did not hear anything from his newspaper that we misappropriated the money.

In fact the defendants had filed a completely baseless lawsuit, which they ultimately lost on the merits in both the Circuit Court of Montgomery County, Maryland, and the Maryland Special Court of Appeals.  During that case, the attorney representing the defendants, defendant Nguyen Hong Thai, boasted to his opposing counsel and those assisting them that he and his colleagues knew that the suit was baseless, but, as they boasted in their programs, they could wear the plaintiffs down financially and hurt them.  Defendant Nguyen Hong Thai also admitted that, as part of this effort, he was not paid an hourly or other substantial fee and that plaintiffs would have to pay heavy legal fees (eventually over $100,000.00, see malicious prosecution count below.)
As a result of this broadcast, and others substantially similar in which the same letters and other pretextual provocations would be used by defendants to elicit other calls and threats, plaintiff Hoai Thanh found himself threatened in other ways.  In late 2002 he reported to the police that as he was exiting on a ramp from the Washington Beltway, Interstate 95, two cars traveling very fast engaged in a maneuver that was coordinated to try and force him off the road into an accident.  One car had Pennsylvania license plates and the other New York license plates.  By stopping quickly he was able to avoid being forced off the road into an accident.  The cars were moving too fast for him to get their license plate numbers.  Other incidents have occurred as the defamatory, attacking, false broadcasts have continued.  In the last two years, when VPR has, in late November, its anniversary celebration, which is attended by many listeners from many states, there have been particularly ominous threats.  In 2003 at the time of the annual VPR celebration, he found that his car in front of his business, had been entered into and a ninja uniform covered with dog and cat hairs had been placed so as to cover the car’s steering wheel.  In Vietnamese culture this is a message to threaten one’s life and that of his family.  This year, just a few weeks ago, he found hanging in front of the door of his auto business as he went to work, a large skeleton with flashing red eyes.  Bones and skeletons have a particular significance in Vietnamese culture as a threat to kill and send one to join the dead.

c)	Engaging in interstate or foreign travel in aid of racketeering activities in violation of 18 U.S.C. § 1953.  Routinely, the defendants traveled between Maryland, Virginia and the District of Columbia, as well as other states and overseas in pursuit of their racketeering activities.
53)	The acts form a “pattern” of racketeering activity.  These acts have been related in their common objectives of defrauding the Vietnamese language community in America with false representations about soliciting money, public relations exposure and other things of value in order to help free Vietnam and fight communism, establish free religion in Vietnam and other laudable goals which the defendants use to further their domination of such efforts and the Vietnamese language media to shut out those such as the plaintiffs who really do do something about these issues and in “hurting” through threats and intimidations any who question the defendants and their use of proceeds while “lulling” the Vietnamese language community into believing that the defendants can account for their use of funds when they cannot do so.  These acts have had the same or similar purposes, results, participants, victims, and methods of commission.  The acts have been consistently repeated and show no sign of being discontinued and are capable of being repeated indefinitely.
54)	Each defendant also conspired to violate 18 U.S.C. § 1962(c), the individual defendants all with each other, and the corporate defendants all with each other.
55)	 Plaintiff Hoai Thanh has been injured in his business and property, and in his health, emotional well-being and ability to work within his Vietnamese language community by the defendants’ violations of 18 U.S.C. § 1962 (c) and (d), his wife has been greatly harmed and intimidated, her emotional health so damaged that she has had to seek medical help, and his children have been affected.  His businesses other than the plaintiff newspaper have been so severely damaged by the driving away of customers from the Vietnamese language community that he has had to sell his Maryland business and start over in Virginia with a business that is struggling to make it without customers from the Vietnamese language community.  The plaintiff newspaper has had its advertisers from the Vietnamese business community intimidated and driven away and its growth reversed and circulation destroyed while its ability to publish has been virtually eliminated.  The defendants have boasted of this on the air and stated that they will do so to anyone who dares to question their use of proceeds.  In the absence of the defendants’ violations of 18 U.S.C. § 1964(c) and (d), none of this harm and damage would have occurred.  Under the provisions of 18 U.S.C. 1964(c), plaintiffs are entitled to bring this action and to have immediate, temporary and permanent injunctive relief, and to recover treble damages, all the costs of bringing this suit, and reasonable attorney fees. 
COUNT II

(Federal Racketeering Influenced and Corrupt Organizations Act - Investment of Proceeds of Racketeering Activity)

56)	 Plaintiffs restate and incorporate all the preceding paragraphs of this complaint.
57)	 This claim for relief is asserted against each of the defendants, and arises under 18 U.S.C. § 1962 (a) and (d) of RICO.
58)	 At all relevant times, each defendant was a “person” within the meaning of 18 U.S.C. § 1961, as each defendant was capable of “holding a legal or beneficial interest in property.”
59)	 At all relevant times, the defendants have constituted an associated-in-fact “enterprise” within the meaning of 18 U.S.C. § 1961(4), or, in the alternative, each defendant has constituted such an enterprise.  Each enterprise and its activities have an effect on interstate commerce, in that the enterprise is engaged in broadcasting and transmitting commercially subscribed to programs, supported by advertising and subscriptions, in interstate commerce, and in obtaining funds from listeners in interstate commerce and in competing in interstate Vietnamese language media markets for the purpose of dominating such markets and “hurting” through the use of interstate commerce any who question the defendants’ fundraising or drive for such market dominance.
60)	 Defendants have engaged in a pattern of racketeering activity which dates from 1999 through the present and is ongoing and threatens to continue indefinitely into the future.  Defendants multiple acts of racketeering are set out in Count I above.  These racketeering acts generated income for the defendants from the funds raised through their fraudulent and deceptive false representations and omissions and from their threats and actions that “hurt” those who tried to question their activities so as to enable them to compete illegally against those such as the plaintiffs, including starting a newspaper directly competitive with the plaintiff newspaper and taking away its advertisers.
61)	 Defendants have used or invested their illicit proceeds, generated through the pattern of racketeering activity, directly or indirectly, in the acquisition of an interest in, or the establishment or operation of, each enterprise in violation of 18 U.S.C. § 1962(a).  Defendants’ use and investment of these illicit proceeds in each enterprise is for the specific purpose of obtaining further funds through their fraudulent misrepresentations and omissions in interstate commerce through wire and transmission and gaining additional funds through the mail and for “hurting” through an interstate campaign and their travel interstate, with threats and intimidation, those such as the plaintiffs who question their use of their funds that they raise and solicit in the broadcasts.
62)	 Each defendant also conspired to violate 18 U.S.C. § 1962(a) in violation of 18 U.S.C. § 1962(d), the individual defendants among themselves and the corporate defendants among themselves.
63)	 Plaintiff Hoai Thanh has been injured in his business and property, and in his health, emotional well-being and ability to work within his Vietnamese language community by the defendants’ violations of 18 U.S.C. § 1962 (c) and (d), his wife has been greatly harmed and intimidated, her emotional health so damaged that she has had to seek medical help, and his children have been affected.  His businesses other than the plaintiff newspaper have been so severely damaged by the driving away of customers from the Vietnamese language community that he has had to sell his Maryland business and start over in Virginia with a business that is struggling to make it without customers from the Vietnamese language community.  The plaintiff newspaper has had its advertisers from the Vietnamese business community intimidated and driven away and its growth reversed and circulation destroyed while its ability to publish has been virtually eliminated.  The defendants have boasted of this on the air and stated that they will do so to anyone who dares to question their use of proceeds.  In the absence of the defendants’ violations of 18 U.S.C. § 1964(c) and (d), none of this harm and damage would have occurred.  Under the provisions of 18 U.S.C. 1964(c), plaintiffs are entitled to bring this action and to have immediate, temporary and permanent injunctive relief, and to recover treble damages, all the costs of bringing this suit, and reasonable attorney fees. 
COUNT III: FALSE LIGHT
64)	 Plaintiffs restate and incorporate all the preceding paragraphs of this complaint.
65)	 The individual defendants, working through and with their respective organizations, (the organization defendants, VPR, BPSOS and CRFV), decided to “hurt”, as they put it in their broadcasts, the plaintiffs for questioning the fundraising, ostensibly for Vietnamese flood victim relief, which the defendants VPR and CRFV, with the participation of BPSOS, were conducting through the radio publishing system of the defendant VPR.
66)	 At all relevant times in this action, defendant program hosts such as Huy Duc and Thanh Tin and the other host and broadcaster defendants were acting within the scope of their employment and work with the organization defendants and pursuant to the direction of the individual defendants Nguyen Dinh Thang, Hung Ngoc Ngo, Hien Thi Ngo, and Thai Hong Nguyen.
67)	 From at least in October of 2002, in a series of repetitive programs published over and over again and disseminated through their radio system in multiple states and reaching over 1 million Vietnamese speaking citizens and residents of the United States, the defendants published false and misrepresentative matter concerning the individual plaintiff Hoai Thanh and his activities in private business apart from his publishing activity with the plaintiff Dai Chung newspaper and invaded his privacy by undertaking to cast a completely false light on him with the wider Vietnamese-language public.
68)	 From this point in time forward, the defendants, no longer content to just “hurt” the plaintiff Hoai Thanh, set out to destroy him and his business and life apart from his role in the plaintiff newspaper.  They conspired together to destroy his business in the plaintiff newspaper beyond just criticizing the content of his articles questioning the defendants’ fundraising and his automobile repair business, in the former by taking away readers and advertisers and the latter by driving Vietnamese-speaking customers away from the business through the power of their broadcast dominance.  Vietnamese language newspapers are particularly dependent upon advertisers, as defendants well knew.  Defendants conspired to do this.
69)	 The defendants repeated this publishing of false and misrepresentative statements and material through the multi-state publishing and dissemination system of VPR from time to time, (scores of times all told) up until the present time and continue to publish them.
70)	 As recently as September 2, 2004, and then again on or about December 23, 2004, the defendants repeated the publishing and dissemination of the false and misrepresentative statements and material through the VPR multi-state radio system.  On September 2, 2004, from 9 PM until 9:27 PM EDST the defendants broadcast again anew a purported letter saying that plaintiff Hoai Thanh had defrauded and cheated innocent Vietnamese business people in America of tens of thousands of dollars.  The representations were false, known to be false and were deliberately misleading.  They did this again on or about December 23, 2004.
71)	 The radio programs mentioned above, as disseminated and published in multiple  states, included falsehoods and misrepresentations about the plaintiff Hoai Thanh and his non-publishing business activities and personal history including:
a)	That the plaintiff Hoai Thanh did not own a valuable Sunoco gas station franchise which he did in fact own on Pennsylvania Avenue Southeast in the District of Columbia, but was merely a “manager” for Sunoco.
b)	That the plaintiff Hoai Thanh deceived one “Mr. Thanh” (Thanh Van Vo) about the plaintiff Hoai Thanh’s ownership of this valuable gas station franchise.
c)	That Mr. Thanh Van Vo was a “victim” of Mr. Hoai Thanh when in fact the opposite was the case.
d)	That Mr. Thanh Van Vo bought the gas station from Mr. Hoai Thanh for “$70,000.00” when such was not the case.  Mr. Thanh did not legitimately buy the gas station for any amount of money, did not have “$70,000”, but was instead an extortionate con artist, part of a would be Vietnamese “mafia,” that attempted to use the gas stations own income to illegally take over the gas station accompanied by threats of violence, including murder and physical harm to the family of Mr. Hoai.
e)	That Thanh Van Vo personally “invested hundred thousand of dollars” in the gas station and built many improvements with such funds.  Thanh never invested any of “his” funds in the gas station, but only illegally took funds from the revenues of Mr. Hoai’s Sunoco franchise after he illegally took it over and used those funds to operate a business that was not his and that he had not any legal ownership of.  Thanh Van Vo did not make improvements but he did operate businesses out of the gas station in violation of the franchise agreement.
f)	That Thanh Van Vo brought the Sunoco gas station franchise business, in contrast to its operation by the present plaintiff Hoai Thanh, to a “prosperity.”  In fact Thanh Van Vo knew nothing about, and had no experience in operating, a gas station whereas Hoai Thanh, the present plaintiff, had successfully operated and supervised many stations as a manager within major oil companies, including Sunoco, and had successfully operated other major oil company franchises.  Thanh Van Vo, by contrast, didn’t even know, when he illegally intruded into the franchise, how to change oil, and knew nothing about auto mechanics.  He repeatedly bounced checks, he attempted to rape an employee, allowed his employees, who were inexperienced in the business and were menacing, violence prone young men, to joy ride customer’s cars and he failed to give decent service up to the standards of the trade.
g)	That Hoai Thanh, the present plaintiff, was a “conner” in the sense of a criminal “con artist” and untruthful and deceiving person when in fact he was not and Thanh Van Vo was.  Thanh Van Vo was bluffing and deceiving about everything connected with his past, his purported skills and experience, his business background, and his finances, and was part of a group that was engaged in a conspiracy of “bluffing,” lying and deceiving.
h)	That Hoai Thanh, as a result of business arrangements that he had with one Khuong, “dispersed his property and filed bankruptcy.”  This is false and a misrepresentation.
i)	That Hoai Thanh, the present plaintiff, committed “crime” in his dealings with Khuong.
j)	That Hoai Thanh was able to prevail in a number of lawsuits stemming from business relationships only by “cheating and deceiving.”  In fact Hoai prevailed in court on the merit of his case in each instance where he prevailed.
k)	That Hoai Thanh only prevailed in the cases where he prevailed because of trickery and of lawyers he hired who went along with his deceit and trickery and enabled it and whom he paid a lot of money which he tricked out of people by illegal means.  In fact there were no tricks, the cases were won because Hoai was honest and not “tricky,” and the lawyers were not paid very much for the amount of work that they did and were not paid with any money except money that was honestly earned and come by.
l)	That a woman, Mrs. Minh, had loaned $100,000.00 to Hoai Thanh without a receipt and had never been repaid because Hoai Thanh had tricked and cheated her.  In reality Mrs. Minh had invested in a business with Hoai Thanh and she purported to invest $60,000.00 not $100,000.00 and at that one check of the amount she purported to invest, for $10,000.00, was returned for insufficient funds and never made good.  In addition she received in payments, $34,880.35, for which Hoai Thanh has the returned checks, and also received back valuable inventory and other items.  Hoai Thanh has the signed document in which Mrs. Minh acknowledges repayment of her investment over and above money received in the form of “tools, equipment, supplies, inventory and office furniture,” and releases Hoai Thanh from any further obligation.  To the release is attached a list of the inventory received by Mrs. Minh.  It alone shows a value of $43,230.00.  In short Mrs. Minh got back what she invested and more and acknowledged the same, despite the fact that the business venture ultimately failed.
m)	In connection with this episode the broadcast claims that Mrs. Minh went to Hoai Thanh’s home to get furniture to pay back part of her “loan” and Hoai Thanh called the police on her for trespassing.  This never happened.  Hoai Thanh never called the police and Mrs. Minh did in fact take a good bit of furniture from Hoai Thanh’s home, getting even more back on her investment.  To represent that she was a “victim” as the broadcast does, who “lost $100,000.00,” is untrue and a misrepresentation.
72)	 These examples and others are used in this and the other, like, broadcasts, to supposedly illustrate that the plaintiff Hoai Thanh is a “crook” and a “big liar,” who “deceive[s]” the “VN refugees…”
73) These assertions are false and misrepresentative of the truth, and known by the defendants to be so when they direct and publish them.  The purported examples are false and known by the defendants who direct and publish them to be so.  They constitute a willful campaign to misrepresent the truth about and harm the life of the plaintiff Hoai Thanh and to discredit and place in a false light both plaintiffs.
74) In these programs also the defendants had the host defendants indicate that Hoai was a “communist.”  By this they meant, within the context of the Vietnamese exile and expatriate community in the U.S., not that Hoai was a philosophical believer in the theory of communism but that he was an active collaborator with the dictatorial communist regime that rules Vietnam and against which we and the South Vietnamese fought.  This also is false and known to the defendants to be false and is used by the defendants to place the plaintiffs in a false light.
75) This is a serious misrepresentation and is completely false. In fact plaintiff Hoai fought against the communists in the armed forces of the late lamented Republic of South Vietnam and has remained active in working against communism in this country and against the dictatorial communist regime that now rules Vietnam.  There is no greater slander or disparagement in the Vietnamese ethnic community in this country than this accusation.
76) The defendants not only perpetrated these false representations about the plaintiff Hoai and his newspaper, but also actively condoned and enabled “callers in” to their programs from all over the U.S. Vietnamese speaking community in multiple states to embellish and amplify these false representations, calling plaintiff Hoai a “communist” and even threatening violence against plaintiff Hoai, such as killing him, or wishing in public utterances on the program that someone would do the plaintiff Hoai harm and violence.  Defendants did his repeatedly on every show.
77) These repeated publications of false statements and misrepresentations over a period of years were intended to place the plaintiffs in a false light before the ethnically Vietnamese and Vietnamese-speaking community in the United States and did so, holding out the plaintiff Hoai, and, as a consequence, his newspaper and the writings under his pen name as to be despised based on a completely false picture and representation. 
78) Defendants did these acts and made these misrepresentations to place plaintiffs in a false light with malice aforethought, maliciously, wantonly, recklessly, intentionally with complete disregard for the rights of the plaintiffs and did so in order to destroy, displace and replace the plaintiff newspaper and destroy financially the plaintiff Hoai in all his business, when combined with the pattern of racketeering activity engaged in by the defendants, and to destroy the reputation and viability of plaintiff Hoai’s pen name.
79) They acted in this way and engaged in this illegal behavior in order to discourage the plaintiffs from exercising their First Amendment Freedom to investigate and report on the defendants and their activities and to prevent the plaintiff newspaper and the plaintiff Hoai as its owner and publisher from existing and publishing in competition and rivalry with the newspaper which the defendants started to displace and replace the plaintiff newspaper.
80) In so doing the defendants, jointly and severally, caused great financial harm to the plaintiffs, caused great emotional suffering to the plaintiff Hoai, destroyed and are destroying his businesses, both his newspaper and his other businesses and have made clear their intent to keep on damaging and harming the plaintiffs unless and until they are stopped.
WHEREFORE, plaintiffs pray, jointly and severally, for compensatory damages in the amount of one million dollars ($1,000,000.00) and punitive damages in the amount of five million dollars ($10,000,000.00), for temporary and permanent injunctions to prohibit the defendants from ever again invading the privacy of the plaintiff Hoai in order to cast him a false light, from engaging in further misrepresentations about the defendants and ro such other relief as to the Court shall seem just and meet in law or equity and to order them to publish corrective statements accurately representing the plaintiffs and the falsehood of their misrepresentations and acknowledging that falsehood to the same Vietnamese public to whom they addressed their efforts to place the plaintiffs in a false light over a period of three months and, the plaintiffs also pray, because of the particularly egregious and outrageous nature of the defendants conduct, and the viciousness and wantonness of their malice as exhibited by it, that the plaintiffs be awarded all of their costs, including reasonable counsel fees.
COUNT IV: CONSPIRACY TO COMMIT “FALSE LIGHT”
81)	Plaintiffs restate and incorporate all the preceding paragraphs of this complaint.
82)	The individual defendants, and all of them, conspired together as set out in the previous counts in order to perpetrate the tort of false lights by which the plaintiffs were cast in a false light before the Vietnamese language public by the misrepresentations and falsehoods alleged.
WHEREFORE, plaintiffs pray, jointly and severally, for compensatory damages in the amount of one million dollars ($1,000,000.00) and punitive damages in the amount of five million dollars ($10,000,000.00), for temporary and permanent injunctions to prohibit the defendants from ever again invading the privacy of the plaintiff Hoai in order to cast him a false light, from engaging in further misrepresentations about the defendants and ro such other relief as to the Court shall seem just and meet in law or equity and to order them to publish corrective statements accurately representing the plaintiffs and the falsehood of their misrepresentations and acknowledging that falsehood to the same Vietnamese public to whom they addressed their efforts to place the plaintiffs in a false light over a period of three months and, the plaintiffs also pray, because of the particularly egregious and outrageous nature of the defendants conduct, and the viciousness and wantonness of their malice as exhibited by it, that the plaintiffs be awarded all of their costs, including reasonable counsel fees against all of the individual plaintiffs, jointly and severally. 
COUNT V: DEFAMATION
83)	Plaintiffs restate and incorporate all the preceding paragraphs of this complaint.
84)	Plaintiff Hoai Thanh resides in Northern Virginia, in the Washington D.C. Metropolitan area and did so at all times pertinent hereto.  At the relevant times in this complaint to its counts above he operated an auto business in suburban Maryland at the address given above for the plaintiff Dai Chung Bi-weekly Newspaper, of which he is president and publisher, a business which he was compelled to sell because of the harm done to it by the defendants in the actions complained of herein.
85)	The plaintiff Dai Chung Bi-weekly Newspaper at all relevant times operated out of offices in Suburban Maryland at the above address.
86)	The defendant Committee for Religious Freedom in Vietnam (CRFV) was a corporation incorporated in Maryland which operated out of headquarters in Maryland at the address given in the style of this complaint above.
87)	The defendant Hien Thi Ngo resided in suburban Maryland at the above address at all relevant times and still resides there.  She operates out of the address of CRFV which she heads as president and principal.
88)	All the other defendants reside and operate in the Washington, D.C. metro area and did so at all relevant times, some also in Maryland.
89)	The campaign of false light and the pattern of racketeering activity focused on the plaintiffs in broadcasts by the defendant CRFV over the system of the defendant VPR under the direction of the defendants in their associated-in-fact enterprise originating in the D.C. metro area and reaching an audience of over a million in this D.C. area and many other states.
90)	It was focused particularly in Maryland because it was coordinated there with the defendants’ campaign of malicious prosecution against the defendants, the details of which are set out and alleged in Count VII below, and it was those maliciously prosecuted law suits in the Montgomery County, Maryland, Circuit Court that were the recipient, ultimately, of a substantial portion of the funds that the defendants raised by their fraudulent representations over intestate wire and airwaves and received by wire nd mail and where much of their interstate travel and transportation was involved along with their use of proceeds to fund interstate operations to harm the plaintiffs there and destroy them and their business.
91)	The particularly publishing of defamatory material against and concerning the plaintiffs complained of in this count, one of many that have gone on for years and threaten to continue into the future, took place in a broadcast by CRFV over the VPR system on September 2, 2004.  The broadcast was one of many similar broadcasts, which the defendants have made over a span of more than three years, since they began a systematic campaign of defamation against the plaintiffs.  They repeated this broadcast again or or about December 23, 2004 and again during the Christmas holiday season of  2004.
92)	Defendants, on that September 2, 2004 date, maliciously published over the defendant Vietnamese Public Radio system, under the sponsorship of the defendant CRFV and under the direction and planning of their associated-in-fact enterprise, reaching an audience in many states of approximately one million people who speak and understand and are conversant in the Vietnamese language, the following words concerning the plaintiff Hoai Thanh in the original Vietnamese, which they then repeated on or about December 23, 2004: 
NHỜ ƠNG HOAI THANH TÌM TÊN ÐẠI BỊP 

Gởi Ong Hoai Thanh 

Mừng Ơng Thắng Lớn 
Ðúng là con người co số phải khơng ơng? 
Biết bao lần người ta thưa ơng về lường gạt, giựt nợ v.v..mà hình như vụ nào ơng cũng thốt. 
Ơng biết là mình co ngơi sao may mắn tại tịa án, thành ra cái gì ơng cũng dám làm; bàng dân thiên hạ chắc chắn khơng ai được làm bị cáo nhiều như ơng đâu. Mừng ơng lần nữa. 

Tiện đây xin nhắc đến lá thư "Tìm Tên Ðại Bịp" mà tơi đã nhiều lần gởi cho ơng từ tháng 5, 2002. Nhưng ơng khơng hề lên tiếng trả lời. 

Sau do, lá thư được đăng trên tờ Lẽ Phải vùng Hoa Thịnh Ðốn, độc giả đã mĩa mai cười khiến ơng tức giận lên tiếng dọa nạt thưa gởi các vị thương gia. Dù vậy ơng đã khơng nhắc gì đến lá thư cũng như trả lời cho Lê Minh Ngọc tơi. 
Tiện dịp ơng đang hồ hởi lên diễn đàn, tơi xin một lần nữa gởi ơng lá thư. Hy vọng quí vị trên diễn đàn khuyến khích để ơng Hồi Thanh can đãm lên tiếng đưa tên thằng Ðại Bịp thế gian cho mọi người biết. 

Và sau đây là lá thư gởi ơng Hoai Thanh: 
Ngày 25 tháng 5 năm 2002 

Kính gởi Ơng Hoai Thanh, 
Chủ nhiệm, chủ bút báo Ðại Chúng. 

Thưa ông, 
Trước hết, tôi xin tự giới thiệu tôi tên là Lê Minh Ngọc, một độc giả trung thành của quí báo trên Website. Xin ông cho phép tôi được nói lời ngưỡng mộ về tấm lòng và công sức của ông đã đổ ra để làm sạch cộng đồng như ông đã viết trên báo. Nếu làng báo mà có được nhiều người như ông thì chắc cộng đồng VN sẽ hoàn hảo hơn nhiều. 
Thời gian này, đồng bào tha thiết xin ông hãy cho đăng báo lá thư, và điều tra dung mạo một tên lưu manh, chuyên đi lừa gạt những đồng bào tị nạn đã đặt trọn niềm tin vào người đồng hương là nó. Thằng lưu manh Ðại bịp này nó sống quanh quẩn trong khu vực của ông ở chứ không xa. Tên này có những đặc điểm là rất thích khoe khoang cho mọi người biết: ta là dân cầm bút, chưa bao giờ cầm kềm, mỏ lết, cầm bình sơn xe. Thích ăn nói lộng ngôn bạt mạng, vô liêm sỉ, lật lọng lời hứa như trở bàn tay ông ạ. Sau đây là cụ thể những nạn nhân của nó: 

1	Nạn nhân thứ nhất: là Bà Minh, chủ tiệm Hair Cuttery tại Arlington, Virginia. Bà Minh đã vì chổ thân tình, tin tưởng cho thằng Ðại Bịp thế gian, mà bà lầm là tử tế mượn 100,000 dollars (một trăm ngàn đô la) mà không bắt viết giấy nợ. Khi Bà Minh đòi lại tiền thì thằng gian manh này nói, nó làm ăn thua lỗ, năn nỉ bà đến nhà nó xiết đồ trừ bớt nợ. Bà Minh vốn dĩ có tính thật thà, thương người nên cũng chấp nhận giải pháp xiết đồ trừ bớt nợ cho nó. Bà Minh nghĩ của đổ thì ráng hốt lại, được chút nào hay chút đó. Nhưng khi bà đến nhà thằng lưu manh này, thì nó đã tẩu tán hết những vật quí giá mà bà biết rõ nó có. Bà vì tức giận đã lớn tiếng chửi nó. Không bỏ lỡ cơ hội sự hiểu biết luật pháp Hoa Kỳ, nó bấm phone gọi cảnh sát, vu khống bà Minh tội xâm phạm gia cư bất hợp pháp.Nó không nhận là: chính nó đã mời bà Minh đến nhà nó. Thế là bà Minh tình ngay, nhưng gặp lý gian nên đã mất toi 100 ngàn, còn bị nhốt hết một ngày ở sở cảnh sát , ông Hoài Thanh ạ. Ông đoán coi thằng lừa bịp thế gian này, nếu nó tuyên bố muốn làm sạch cộng đồng, liệu có ai tin nó không, thưa ông Hoài Thanh 
2	Nạn nhân thứ hai: là builder Lê Công Thiên tại Virginia. Ông Thiên mất toi $30.000 (ba mươi ngàn) cũng vì cái tính cố hữu của người Việt Nam: tiền bạc đưa bằng tay, nói bằng lời là đủ tin nhau. Và kết quả là ông Lê Công Thiên đã mua được kinh nghiệm sống và làm việc với kẻ bất lương giá hơn 30,000 đô la. Giá mua này còn hời hơn bà Minh nhiều, phải không ông Hoài Thanh? 
3	 Nạn nhân thứ ba: là ông Thanh có bán xe Hotdog ở Washington DC. Ông Thanh Hotdog bị thằng Ðại bịp này, bán cho một cây xăng giá $70,000 đô la là tài sản của hảng Sunoco, chứ không phải là tài sản riêng của nó. Nó chỉ được hảng Sunoco cho nó làm quản lý mà thôi. Vì vậy, khi bán cây xăng của hãng Sunoco cho ông Thanh Hotdog, nó ngon ngọt với ông Thanh Hotdog là chỉ nên viết giấy tay thôi. Ðưa ra công chứng làm gì cho mất thì giờ, mất thêm tiền lệ phí v.v... Nộp 70,000 đôla cho thằng đồng hương Ðại bịp rồi, ông Thanh Hotdog đổ thêm và cây xăng cả trăm ngàn đô la nữa để nới rộng cơ sở. Làm thêm chổ thay vỏ xe, bán nước giải khát, bánh kẹo v.v...Khi cơ sở này làm ăn đang phát triển thịnh vượng thì ôngThanh Hotdog bị cảnh sát đuổi ra. Lý do cây xăng mà ông mua từ thằng Ðại bịp với giá 70,000 đôla và bỏ thêm vào đấy hàng trăm ngàn đôla nữa, vẫn chưa phải là tài sản của ông. Tới lúc đó, ông Thanh Hotdog mới biết được một điều rất quan trọng là: Ai đứng làm chủ cây xăng cũng chỉ là người quản lý. Mọi sự mua bán sau khi đã thỏa thuận giá cả riêng với nhau, phải nộp hồ sơ mua bán lên hảng trung ương để phê chuẩn đồng ý thì mới hợp pháp. Ông Thanh Hotdog đã không biết điều đó. Nhưng thằng Ðại bịp thì biết rất rõ, nên nó đã đóng vai tuồng người đồng hương VN tử tế thật xuất sắc. Sau khi té ngửa, ông Thanh Hotdog chỉ còn biết cầm mảnh giấy mua bán viết tay đem đến tòa kiện gỡ gạc. 
4	Nạn nhân thứ tư: là ông Khư7ng, chủ tiệm vải Mỹ An ở Virginia. Ông Khương là một thương gia tài giỏi, đã có kinh nghiệm nhiều với chợ đời. Vậy mà khi gặp thằng Ðại bịp thế gian này, ông Khương đã lầm tưởng là nó có đạo đức vì nó luôn kể chuyện ơn nghĩa vì tình thương đồng bào, ông Hoài Thanh ạ. Khi thằng Ðại bịp này hỏi mượn 10,000 đôla, ông cũng cho nó mượn, nhưng ông bắt nó phải viết giấy nợ. Cẩn thận là thế mà ông Khương có thoát khỏi tính tham tiền của nó đâu. Vì đã quen thói lừa đảo, ăn quịt tiền của đồng bào tị nạn, nên nó không chịu trả nợ cho ông Khương. Ông Khương rất giàu có. Số tiền 10 ngàn đôla đối với ông chỉ là ba cái lẻ tẻ thôi. Nhưng ông Khương nhất quyết không cho thằng Ðại bịp khốn nạn này một xu, chứ đừng nói chi tới 10 ngàn. Và để đòi được 10,000 đôla này, ông Khương phải đem nó ra tòa. 
5	Ông Hoài Thanh biết không? Thằng này quỉ quyệt gian ma, nó dùng tiền ăn cướp được của đồng hương. Thoải mái mướn 3 luật sư Mỹ tài giỏi để chạy tội cho nó dưới ánh sánh sáng luật pháp Hoa Kỳ. Thằng vô liêm sỉ, chuyên gia Ðại bịp thế gian này có nhiều mưu kế lắm. Nó hy vọng thắng vụ kiện này. Nó sẽ cho đăng lên báo để là bẽ mặt ông Khương và tạo thêm uy tín, dễ dàng đi lường gạt tiếp những đồng bào tị nạn chưa biết thành tích lường gạt của nó. Trước tòa, nó đã ma mãnh khai với tòa rằng: ông Khương hùn vốn với nó để làm ăn. Cuộc làm ăn đã thất bại. Nó không có bổn phận trả lại 10 ngàn đôla đó. Nhưng với tờ giấy nợ làm bằng chứng hiển nhiên, không thể lật lọng được như những vụ trước. Quan tòa đã bắt thằng Ðại bịp thế gian này trả lai cho ông Khương cả vốn lẫn lời. Khi không thể chạy tội được, nó tẩu tán tài sản rồi khai vở nợ (bankruptcy) để xóa nợ. Nhưng ông Khương cao tay ấn hơn, nên nó đành phải trả lại tiền trong tiếc nuối. Và như vậy, trong vô số nạn nhân, nó chỉ bị thua có mỗi một mình ông Khương, còn lại là nó đã ẩm trọn được những số tiền vay mượn, hùn hạp lớn nhỏ của các nạn nhân qua lường gạt, lật lọng hoặc là khai vở nợ. 

Thưa ông, danh sách nạn nhân còn dài, tôi sẽ viết tiếp kỳ tới. Ðể cuộc điều tra chóng kết thúc và có kết quả mỹ mãn. Ông Hoài Thanh cần đến gặp những đồng hương có tên dưới đây họ rất sẳn sàng cung cấp thêm những chi tiết các vụ lường gạt và tên tuổi thằng Ðại bịp đó. Bởi vì chinh họ đã là nạn nhân, hoặc đã biết rõ những hành động lường gạt bỉ ổi của nó ông ạ. 

Ông có thể đến hỏi các thương gia sau đây: 

Tiệm Vàng Bạch Tuyết - Tiệm Vàng Kim Long - Ông Hoàng Nuôi nhà hàng Queen Bee - Ông Khương tiệm vải Mỹ An ở Virginia - Ông Thanh có bán xe Hotdog ở Washington DC - Ông Lê Công Thiên ở Virginia - Bà Minh chủ tiệm Hair Cuttery tại Arlington, Virginia - nhà hàng Ðại Nam cũ - Bà MêKong và các thương gia có cơ sở thương mại trong khu Wilson / Clarendon Virginia ... 

Thưa ông Hoài Thanh, tôi luôn nhớ câu tâm huyết của ông đã đăng trên bìa báo Xuân Nhâm Ngọ: vì tình thương đồng bào và muốn cho cộng đồng được trong sạch và vững mạnh ...nên tôi tin tưởng rằng ông sẽ quyết tâm đem thằng lưu manh này ra ánh sáng bằng sự thông thái của ông. Vậy kính xin ông cho đăng lá thư này của tôi trên báo Ðại Chúng, để đồng bào được biết nội dung các kiểu lường gạt của tên Ðại Bịp này mà tránh. Cũng như qua tờ báo của ông, đồng bào sẽ biết để mà cung cấp thêm dữ kiện cho quí báo làm tin sốt dẻo, cống hiến cho đồng bào vì tình thương đồng bào như ông đã khẳng định. 
Chúc ông luôn tâm bình và thành đạt. 
Kính chào ông 
Lê Minh Ngọc 

Tờ Báo Ðại Chúng và Ong Hoai Thanh (Chủ Nhậm kiêm Chủ...Pút-Kềm-Búa) con thậm thụt mấy lần nửa? 
Tơi đã định khơng viết, vì thấy ơng Lê Minh Ngọc đã đưa hình ảnh tên Ðại Bịp cho mọi người rồi. Nhưng hơm nay, trước việc Hoai Thanh và tờ Ðại Chúng thậm thụt trên diễn đàn Thảo Luận đến 3 lần trong vong 5 ngày chỉ với một bài duy nhất: "Vụ kiện báo Ðại Chúng của Ủy Ban Tự Do Tơn Giáo cho Việt Nam..." Tơi thấy mình khơng im tiếng được nửa và xin đưa vài ý kiến mạo muội như sau: 
Khơng phải chỉ ở Việt Nam mới co những vu khống "Lm Nguyễn Văn Lý co năm vợ mười con" hay " MS Nguyễn Hồng Quang dụ dỗ gái vị thành niên", mà tại Hoa Kỳ cũng co những người noi khơng cần sự thật. 
Tơi sống tại vùng Hoa Thịnh Ðốn, đã từng dại đưa xe cho ơng Hoai Thanh sơn lại; từng gây lộn vì tiền mất mà tật mang. Sau do, tơi từng nghe nhiều người nêu "thành tích lẫy lừng" của ơng; cũng như từng đọc loạt bài "Quần chúng muốn biết số tiền cứu trợ nạn nhân bão lụt" vu khống UBTDTG một cách thật hạ cấp.(Quí vị nào muốn xem loạt bài này co thể vào website của tờ Ðại Chúng: www.daichung.com <http://www.daichung.com/> (bắt đầu từ số 68 hay 70 gì do). 
Cơng nhận Hoai Thanh tuy dốt (điều này thì ai đã gặp HT đều biết) nhưng rất gian manh (diều này thì các nạn nhân của HT đều đồng ý). Hồi Thanh rất biết cách chửi. Tuy nhiên,"credit" kỳ này chưa chắc là của HT mà co thể là của ơng "chủ bự vơ hình" chi tiền. Thật vậy, những bài "quần chúng muốn biết .."theo tơi đoan là do một "du sinh" (noi theo kiểu XHCN) viết. Ai cũng biết ơng HT đâu co khả năng viết lách, dù chỉ viết bài dởm. Nếu ơng HT muốn phản bác điều này, tơi thách thức ơng do. Ơng sẽ ngồi trong phong kín trong 2 giờ, giám khảo cho ơng một đề tài, tơi cam đoan ơng khơng viết được 3 câu cho ra câu chứ đừng noi 
là viết được một bài và nhất là theo văn phong của Vân Nam.
Nếu HT đồng ý nhân lời thách thức, tơi sẽ mời ba vị trưởng thượng trong vùng Hoa Thịnh Ðốn làm giám thị và quí vị trên diễn đàn sẽ làm giám khảo. Nếu HT viết được một bài dù chỉ "hay" bằng loạt bài "Quần chúng muốn biết..." tơi sẽ chịu thua $US 10,000, giúp HT co tiền trả luật sư cho vụ kiện của UBTDTG sắp tới. Con nếu HT khơng viết được, bị thua cuộc thì phải bỏ ra tương đương số tiền trên, tức là $US10,000 cho Ban Ðại Diện Cộng Ðồng vùng Hoa Thịnh Ðốn làm những việc cơng ích. 
HT co cam đảm nhận lời khơng? Nhờ ơng lên tiếng trên diễn đàn dùm. Mong lắm thay. 
Ðọc loạt bài "Quần chúng muốn biết..." của Vân Nam (mà ơng HT luơn nở mũi, ưỡn ngực nhận mình là tác giả) ai cũng thấy đây là văn phong của một "du sinh" Hà Nội. 
Hoai Thanh co mướn một "du sinh" Hà Nội lo việc laid-out và website. Khơng biết cậu này và Vân Nam là hai hay một. Nhưng điều chắc chắn là loạt bài "Quần chúng..." của Vân Nam luơn chất chứa những danh từ đặc biệt Hà Nội Ðỏ. Như chữ "bàu chửa" mà quí vị thấy trong bài vừa rồi. Tơi nhớ hồi một câu trong loạt bài chửi như tát nước vào mặt UBTDTG mà anh "du sinh Vân Nam" phun ra theo thoi quen, đại khái như sau: "Nếu chính quyền CSVN cho phép những tin tức liên quan đến Nguyệt Biều được phép loan tải trên báo chí, thì tuần báo Ðại Chúng sẽ đăng tải một cách cơng khai những tin tức này trong tương lai". (Sanh ra dưới sự kềm kẹp của bác và đảng, cái gì cũng chờ phép là đúng quá rồi), hoặc quan điểm sặc mùi vu khống các vị lãnh đạo tinh thần trong nước: "Tiền cứu lụt từ nước ngồi gởi về cả triệu đơ, nhưng số tiền này khơng đến tay các nạn nhân bão lụt, vì số tiền này đã bị cháu của Hoa Thượng Thích Quảng Ðộ là Hoa Thượng Thanh Minh tri hơ là bị ăn cướp. Nhưng thật ra Hoa Thượng Thanh Minh giử lại số tiền này để cất chùa". Những doan tương tự như trên đã đăng trên Ðại Chúng số 75. (Tơi nhớ chắc số này như tên phở 75). 
Nếu ơng Hoai Thanh là một người bình thường, co tư cách thì chắc cả vùng Hoa Thịnh Ðốn này đã tin ơng ta và tẩy chay UBTDTG và đài Tiếng Noi VNHN lâu rồi!. Tuy vậy, ít ra ơng HT cũng thành cơng với những người nhẹ dạ ở xa. Lên website Ðại Chúng đọc vài bài, khơng tìm hiểu sâu xa, chỉ mặc nhiên nghĩ rằng "khơng co lửa sao co khoi". Nhưng đối với người co kiến thức sâu sắc đàng hoang, họ phải tìm hiểu những nguyên nhân tiềm ẩn. Một tờ báo tố cáo một tổ chức thâm lạm tiền cứu trợ thơng thường chỉ cần viết một hai bài báo, lời lẻ đúng đắn đàng hoang là đủ rồi, đâu cần phải viết liên tục mấy chục bài, chửi xa rồi lại chửi gần; như vậy theo tơi ơng HT muốn đập chết UBTDTG và đài phát thanh TNVNHN để họ khơng con tiếng noi chống lại "ơng chủ lớn" của HT; chứ đâu phải HT muốn đứng về phía dân lành "làm sạch cộng đồng" như lời ơng tuyên bố. 
"Làm sạch cộng đồng". Ơi sứ mạng của ơng HT sao mà cao cả thế! Trong khi cái body-shop nhỏ xíu của ơng, khách gà mờ kiểu tơi đút đầu làm nạn nhân bất mản gây lộn với ơng hàng ngày, sao ơng khơng làm sạch? Ơng quên bài học sơ đẳng là phải tu thân trước rồi mới làm thầy thiên hạ sao? 
Ơng đã giựt lương bao người thợ phụ, nay lại "anh hùng thấy chuyện bất bình" để "phẫn nộ" tiền cứu lụt của bá tánh thì thật là quá trơ trẽn đĩ nghe. 
Tơi biết Bà Hiền khơng ngu. Tiền bạc thu chi về cứu trợ nạn lụt chắc chắn phải phân minh đàng hoang. Bà ấy mới dám kiện Ðại Chúng và Hoai Thanh ra toa: Co ai dại "lạy ơng tơi ở bụi này" đưa hồ sơ cho ơng luật sư của HT "vạch lá tìm sâu" để nếu hồ sơ khơng đúng, vào tù ngồi xé lịch! Chắc chắn bà Hiền khơng dại đến độ này đâu. Co dại là chính HT, tưởng mình ranh ma, co thể lường gạt những người dại như mình, tuyên bố mình thắng kiện để chứng minh Bà Hiền gian dối, sai trái. Hoai Thanh ngồi ghế bị cáo thì co gì để thắng. Khơng bị quan toa xử đã dùng những lời lẻ vu khống, chụp mủ là mừng thấu trời rồi. 
Hiện nay, bàng dân thiên hạ đang chờ HT đưa Bà Hiền ra toa vì bà ta tuyên bố HT noi láo, mạ ly, vu khống ..., trong khi HT toan noi sự thật trong mấy mươi bài báo "Quần chúng ...". Khi nào HT dám đưa Bà Hiền ra toa với các tội trên hay bất cứ tội gì, thì dù toa chưa xử, cộng đồng cũng khen HT là anh hùng. Hoai Thanh thấy cộng đồng thiên vị HT chưa? Hảy thừa thắng xơng...vơ, kiện Bà Hiền đi, cho thiên hạ nễ chút mặt mốc. Lúc do mới là "thắng" thật. Rán lên! 
Hoai Thanh hùng hổ co hai người (của HT) về VN đến gặp TT Thích Khơng Tánh và được Thương Tọa cho biết Bà Hiền khơng hề gởi 15,800 đơla cứu lụt cho GHPGVNTN. 
Hoai Thanh ngoa mà ngu. TT Thích Khơng Tánh cùng toan thể GHPGVNTN đang bị quản chế, thì dễ gì người của HT co thể vào gặp, trừ khi người do co "lai-sân" hoặc "mác" Hà Nội. Mà dù co gặp đi nữa, TT Khơng Tánh đâu co ngu như HT, trong thời buổi này, trước mặt một "đệ tử bá vơ, phản thầy nọ kia", mà dám "thưa ơng Việt-Kiều, thưa ơng VC, chúng tơi đã cải lệnh ơng, đã đi cứu trợ và đã nhận của Bà Hiền 15,800 đơla" !! 
Về tư cách 2 người của HT, ơng bà ta co câu "ngưu tầm ngưu, mã tầm mã". Bạn bè của ơng mà noi miệng thì cho no tin. Giấy tờ ơng con làm giả thì co kho gì noi co thành khơng, noi khơng thành co. Nếu 2 người này quang minh chính đại thì hảy cơng khai đưa địa chỉ, số điện thoại để mọi người tham khảo, tại sao phải qua địa chỉ của báo Ðại Chúng để được anh "du sinh Vân Nam" kiểm soat và báo cáo về Trung Ương Hà Nội hoặc cái Sứ-Quán tại Washington !! Và chắc là anh "du sinh" sẽ trả lời dùm? Cơ Kim Huê là nhân vật giả hay thật thì tơi khơng biết. Con ơng Nguyễn Văn Thắng(thân phụ LS Nguyễn Thái) thì tơi quá biết ơng này. Ơng "Nọ-Kia" này khơng đến nổi gian hùng như HT, nhưng tư cách cũng chẳng ra gì. Ơng Nguyên Thái Nguyễn Văn Thắng, chuyên viên thư rơi dạo nào, giờ tứ cố vơ thân, lảnh tiền SSI, luơn kiếm cơm chực. (cam đoan đây là sự thật 100%) nên chỉ cần 100 đơla là ơng hăng hái nĩi đủ thứ, khơng chỉ giới hạn chuyện Thầy Thích khơng Tánh đâu. Khơng nhận những bửa cơm thí mà con được HT đưa lên Ðại Chúng với danh xưng giáo sư này, nhà phát minh nọ. "Ơ Mê Ly" như vậy thì sai biểu gì mà "giáo sư" chả làm!! 
Viết tới đây, tơi thật tơi nghiệp cho Luật Sư Nguyễn Thái (con ơng Thắng). Ðây là trường hợp "cha cú đẻ con tiên". Chắc ơng luật sư giống mẹ, khơng bị giống một điểm tồi bại nào của người cha khơng tư cách. Co lẻ nhờ LS xa cha từ thuở nhỏ. Tơi biết LS Thái rất đau long khơng nhìn người cha vơ tư cách này. Nhưng cũng thành thật xin lỗi LS. Tơi khơng biết phải dùng chữ chính xác hơn đối với ơng Thắng, người đang bị HT lợi dụng tối đa. Bỏ đao xuống sẽ thành Phật, ơng "Nọ-Kia" ơi! 
Tơi viết những dong chữ này khơng với tư cách một nạn nhân của HT. Sự thiệt hại của tơi quá nhỏ so với những nạn nhân khác của ơng ta. Nhưng thấy ơng Hoai Thanh thường tưởng mọi người như con nít noi nhăng cuội gì cũng co người tin nên tơi đành tốn chút thì giờ, mở mắt cho HT làm phước. 
Cái mặt mốc HT trơ trẽn lắm. Ðể quí vị xem, noi vậy mà thằng chả chưa chịu câm miệng đâu. Nhưng thơi khơng sao, coi như cái nghiệp. Cứ "du-sinh-Vân-Nam" mà viết ngu, thì mổ tơi cứ đè đầu HT ra tế (HT muốn vậy mà). 
Tơi sẽ mất chút thì giờ, chứ chẳng co gì đề mất thêm, mình cũng chẳng làm cứu lụt, cứu bão gì hết, nên cũng chả sợ bị "khơng vú" là ăn tiền của đồng bào nạn nhân! 
Cũng chẳng sợ bị kiện, mình chỉ noi sự thật thơi, chứng cớ đàng hoanh, sức mấy mà HT đám để những nạn nhân của hắn ra tịa làm chứng. Vả lại chắc gì HT con tiền để kiện, trừ khi ơng thành cơng cho những vụ lường gạt mới; vì chắc chắn mấy vụ kiện của UBTDTG làm HT ngất ngư con tàu đi rồi. Tội nghiệp ! 
Lê Tâm 

Hoai Thanh: người đạo văn "du sinh HàNội-Vân Nam"

Thưa ơng Hoai Thanh, 

"Chúng cháu" đọc chữ "Bọn Mày" của "chúng ơng" mà nổ đơm đốm con mắt. Sau cải cách ruộng đất 54, đây là lần đầu "chúng cháu" được đọc loại văn chương này tại hải ngoại. Cám ơn bác và đảng đã cho "du sinh Vân Nam" xuất cảng lao-động-chữ-nghĩa. 
Chuyện "Ơng Ðại Bịp" thì đã co ơng Lê Minh Ngọc "xử lý" với ơng. Tơi chỉ xin "động viên" ơng vài điều nho nhỏ sau đây: 
Ơng cho rằng tơi "khơng xứng đáng để thách thức với Vân Nam và Hoai Thanh". Thách thức thi viết và gian hùng như ơng Hoai Thanh thì đúng là tơi khơng xứng đáng. Tơi đâu "co chức" chủ nhậm (mắt) kiêm chủ pút-kềm-búa đâu mà dám lớn lối. Nhưng ơng phải nhìn thấy thiện chí tơi đang tìm cách kiếm tiền cho ơng đây. Ơng HT chỉ cần ngồi trong một phong kiếng. Trong 2 giờ (để bảo đảm khơng co ai nhắc tuồng, quăng "bùa", hoặc email bài viết sẳn) viết một đề tài do ban giám khảo đưa ra. Bài viết khơng cần xuất sắc, văn phong tầm cở Vân Nam trừ gian diệt bạo (nhưng chứa chấp thằng lưu manh) là đủ rồi. Ơng HT sẽ lãnh trọn 10,000 đơla. Vị chi mỗi giờ làm được 5,000 đơla. Ơng coi co văn sĩ nào được income như vậy đâu. 
Hảy đem so sánh với nghề làm đồng sơn xe của ơng, kiếm năm ba trăm đổ mồ hơi hột; đã vậy khách hàng khơng biết mang ơn ơng, mà con "com pờ len" doi tiền lại vì ơng sơn khơng giống màu "o-ri-gin"! sửa xe thấy chổ vá. Ðời thật đen bạc phải khơng ơng? 
Ơng co giận tơi thì cứ giận, nhưng khuyên ơng nên nhận lời đi, mười ngàn chứ đâu phải ít. Ơng co nhớ 10,000 đơ oan nghiệt mà Ơng Khương, tiệm vải Mỹ An, đã đưa ơng ra toa, ơng tốn bao tiền luật sư mà tức thay, cuối cùng, phải trả cho ơng Khương tổng cộng vốn lời đến ba mươi mấy ngàn đơ. Con kỳ này ơng ăn trọn ngon ơ. Ðã vậy con chứng minh mình là cây bút thứ thiệt làm ê mặt những đứa tố ơng chỉ cầm kềm búa, khơng biết cầm bút; "bọn mày" khơng con dám chửi hỗn nửa đâu. 
Ðừng bỏ cơ hội ngàn vàng này, uổng lắm, ơng HT ơi. 
Ơng HT co biết khơng, thiên hạ đồn rằng dạo này ơng "xuống cấp" lắm. Một hai tháng mới ra báo một lần vì khơng cotiền in. Lại nữa chuyện ơng điều tra tiền cứu lụt của Ủy Ban Tự Do Tơn Giáo trước đây cứ mỗi nửa tháng co một hai bài chửi rủa vơ địch. Lúc này, cả năm rồi, co thấy ơng viết gì đâu. 
Rồi mới đây, ơng tuyên bố thắng thế, mà chỉ viết mấy câu yếu xìu chẳng khí thế một ly ơng cụ nào hết, khiến thiên hạ đồn ơng như con cho ghẻ, vùng vẫy rên rỉ tru lên chút đỉnh trước khi ...ngủm! 
Hay ơng thua mà ơng noi xạo là thắng đĩ cha nội.. Ðã thắng thì với tài viết lách như ơng, ơng nên viết thêm, chửi cho Bà Hiền, ơng Hùng phải dọn nhà đi tiểu bang khác ở; giống như hồi ơng ở Oklahoma, khai bankrupcy dọn qua Cali; rồi từ Cali dọn về Virginia "quậy" cho tới bây giờ. Chứ ơng chỉ noi vong vong, mờ mờ ảo ảo thật chán mớ đời. Do do co mấy thằng xấu mồm loan ầm là ơng thua nặng phải bán miếng đất và bán cái body-shop ở Maryland và dọn về Alexandria chữa-thương để nghĩ mưu mơ "quậy" tiếp. 
Chúc ơng sớm kiếm đủ tiền để ra số báo kế. Ðộc giả Lê Tâm đang trơng đợi để đọc bài của Vân Nam và thấy bản lãnh ngon lành của "thủ lãnh" tờ Ðại Chúng! 
Con một chuyện nửa, sáng nay tơi vào website Ðại Chúng để tìm cảm hứng. Nhưng khơng biết tại mơ mà 9 số báo sau đây ơng khơng đăng tải trên trang web (từ số 124 đến số 133). Phải chăng những số báo này co đăng bài của tổ sư của ơng là Chủ Tịt VB Ðặng Văn Nhâm đã chửi bới, vu khống các bậc Thầy trong Giáo Hội Phật Giáo Thống Nhất? Chửi đã, bây giờ thấy rét, nên dẹp chăng? Hay ơng sắp sửa cầu xin chuyện gì đến quý Thầy, nên dấu biến để nịnh nọt cho dễ. 
Ơng Vân Nam ơi, viết trả lời dùm Hoai Thanh đi. Viết thật độc kiểu như: mày tao, ăn cắp, ăn trộm, hiếp dâm, chuột chun đầu ống "kống" v.v...càng tốt. Tuy nhiên cũng nhớ trả lời các câu hỏi trên. Ðừng giả bộ giận dử rồi quên trả lời. Dù ơng Hoai Thanh khơng biết viết, nhưng cũng đừng để người ta tưởng là ơng khơng biết đọc thì quê lắm do. 
Lê Tâm 

93)	 These broadcasts on VPR by the defendants were willful and malicious and done with the intent to injure plaintiff Hoai Thanh and to expose Hoai Thanh to hatred within the Vietnamese audience and community, and to expose Hoai Thanh to ridicule, contempt, scorn and obloquy, and to cause Hoai Thanh to be shunned and avoided and to injure his standing and that of the plaintiff newspaper in the Vietnamese audience and community, to injure him in his profession as a publisher and author and as a businessman.  Such words and the depiction they gave were intended to mean and did mean and were understand by the listeners in Vietnamese to the program as follows when translated into English:
ARTICLE REQUESTED TO BE PUBLISHED WITH PAYMENT BY LE MINH NGOC

TO: Le Phai Weekly Newspaper.

     Dear Sir,

     In the 98th issue of Dai Chung Magazine, Mr. Van Nam cited my name - Le Minh Ngoc-and blamed me for sending an anonymous letter. While the letter written by myself was sent directly to Dai Chung Magazine to be pubshied, therefore it could not be charged as anonymous as Mr. H.T. proclaimed in the Spring Magazine Issue. I was myself completely independent to write this article with a desire to support you. Mr. Hoai Thanh, to “purify” the community as you proclaimed in the Spring Issue. Mr. Editor of Le Phai! Could you please make any necessary correction in order to clarify the content of the article which Mr. Hoai Thanh had concluded as anonymous. That may cause suspicion in the public and readers who easily accuse the writer and the others.

     I, the undersigned Le Minh Ngoc requested the favor from Le Phai Newspaper to public two letters that had been sent to Dai Chung Magazine previously in the section of “Pay Advertisement” .

     Le Minh Ngoc (Email of LMN sent to Le Phai on May 25/02

     Mr. Editor in Chief for “Le Phai Newspaper”:

     Yesterday, I sent an article and requested it to be posted on your newspaper with payment but I forgot to ask about the cost to sent you a check. Could you please tell me how much is the fee that I pay for.
     Thank you and wish you safe and happy always.
     Sincerely yours,
     Le Minh Ngoc

Mr. Hoai Thanh
Chief Editor of Dai Chung Magazine

     Dear Sir:

     First, I would like to introduce myself as Le Minh Ngoc, a faithful reader of your magazine Website. May I express my admiration for your concern and work to clear all the conflicts among the Vietnamese Community as you wrote in the magazine. If the journalist circle had many people like you, the VN community would have been a lot better.

     Some of your articles criticizing fiercely the Freedom Religion Committee and the VN Overseas Radio that I have read, have been brought to court and the result will be turned out clearly either black or white.

     According to me, you would rather not wast paper and ink to argue with them. The court will justify the facts as you have thought about. For the time being, our fellow countrymen eagerly request you to publish the letter and featuring the crook who used to deceive the VN refugees that wholeheartedly trust him as a good compatriot.

     This big liar lives not far away, just around your neighborhood. His unique characteristic is boasting himself as a penholder and never holds hammers, wrenches and screwdrivers, etc...He like to use big words and talks irrelevently, shamelessly and unconsistantly like we turn up and down our hand.

     The following people are his victims:

     The first one was Mrs. Minh, the owner of a hair cuttery shop in Arlington, VA. who considered him as a closed good acquaintance and let him borrow $100,000.00 without requesting him to write a receipt. When Mrs. Minh claimed back her money, this dishonest guy said he lost in the business and asked her to come to his house to take all furniture and household facilities instead. Mrs. Minh, a born honest and generous woman accepted his proposal to set off part of the debt by taking things from his home. But on  the day she came to the house, the debter had evacuated all his valuable items that she already knew he had possessed them previously. She got very angry and could not help cursing him in loud voice. Taking advantage of knowing the american law, he called the police and charged her of illegal invading his house and denied his inviting her to come in. Mrs. Minh with her frank nature but reacting illegally had lost $100,000.00 and was detained one day at police station. That was the story, Mr. Hoai Thanh. Guess if anyone dared to trust him, Mr. Hoai Thanh? When this bad guy always said he wanted to purify the community!.

     The second victim was Mr. Le Cong Thien, a builder in Virginia who lost $30,000.00 resulting from his Vietnamese born-possessed characteristic of money transaction hands on hands, without writing any receipt, they verbally trusted each other. Therefore Mr. Le Cong Thien had paid $30,000.00 for this live experience. And the price was much cheaper than that of Mrs. Minh, was it right, Mr. Hoai Thanh?

     The third victim was Mr. Thanh, who was the owner of a hot dog van in Washington DC.. Mr. Thanh bought a gas station from him and paid $70,000.00. But it turned out that the gas station was not his own property but it belonged to Sunoco. He was only hired by Sunoco as a manager. In the transaction with Mr. Thanh Hot Dog, he convinced him that a hand writing deed was enough; had it publicly notorized was only one time consuming and money wasting. Beside paying $70,000.00 to this bluffing fellow countrymen, Mr. Thanh Hot Dog also invested hundred thousand of dollars to expand the services such as adding tire change section, and building soda and candy stand etc... When the business came to its full swing, Mr. Thanh Hot Dog was evicted by the police because this gas station has not been completely his own property. One important thing that Mr. Thanh Hot Dog learn by this time was that whoever managed this gas station was only a manager, but not owner. All kind of agreed transaction must be filed at the central office for being verified to be legalized. Mr. Thanh Hot Dog did not know that process except his big bluffer who played very well his role as a good VN compatriot. Awaking from the bad dream, what Mr. Thanh Hot Dog had to do was sueing him at court to claim back part of his losses..

     The fourth victim was Mr. Khuong, the owner of My An Fabrics. He is a very talented businessman with very many experiences in business field but when coming up with this Big bluffer, he also mistook him as a honest man because he always talked about offering charitable services and cpmpassion toward his fellow countryman, Mr. Hoai Thanh! When this bluffer insisted Mr. Khuong to loan him $10,000.00 the latter agreed but carefully insisted him to write a receipt. Even though Mr. Khuong could not get out of his deceptive practice. Being familiar with cheating, he did not pay Mr. Khuong the debt.

     Mr. Khuong was very rich. To him ten thousand dollars meant nothing but he determined not to give him a cent and tried to bring him to the court.

     What do you know, Mr. Hoai Thanh? He was very cunning, he used money cheated from his fellow countrymen to hire three talented American lawyers to defend for his crime. Under the light of American law, this cunning, shameless big bluffer armed with myriad of plots and tricks hoped to win this case. He will manipulate newspapers and makes Mr. Khuong loose face and at the same time created the credit for himself to easily continue his cheating the refugees. At the court he cunningly delared that Mr. Khuong pooled his capital as a joint venture to do the business. The business was going down and he was not responsible to refund that ten thousand dollars but the receipt of the loan was the blatant proof, he could not cheat like the previous cases. The judge had ordered him to reimburse Mr. Khuong the loan amount plus interest. Not being able to avoid the crime, he dispersed his property and filed bankruptcy to wipe out the loan. But in this case, Mr. Khuong was more high handed therefore he sorrily had to pay him back the amount of money.

     In short, among numerous victims, he was only defeated by Mr. Khuong but victorious over the others by means of cheating and deceiving to collect the other’s money in the title of loan or joint venture.

     Sir the list of victims is still long, I will continue to write in the next issue in order to get the investigation ending fast and satisfied result. Mr. Hoai Thanh should meet your fellow countrymen listed below. They are readily availiable to provide you the details regarding the cheatings and bluffings mentioned above and the name and background of this villainous bluffer: 

     Bach Tuyet Jewelry, Kim Long Jewelry, Mr. Hoang Nuoi Restaurant QueenBee, Mr. Khuong VA. Fabrics shop, Mr. Thanh Hot Dog in Washington D.C., Mr. Le Cong Thien VA., Mrs. Minh Hair Cuttery in Arlington VA., Dai Nam Restaurant, Mr. Mekong and businessmen in the Wilson/Clarendon areas.

     Mr. Hoai Thanh, I always remember your wholehearted saying appearing on the Nham Ngo Spring Magazine: “In compassion with the compatriots and with desire to build up strong community...” therefore I believe, with your wisdom, you would definitely expose this crook to light. I eagerly request you to publish this letter on Dai Chung Magazine to let the people know all kind of cheatings and deceiving to spare them from being a victim. Also through reading your magazine, our people will provide you more information and events for publishing as hot news to the public. That seems to match with your words. I sincerely wish you always safe and successful.

     Good bye,
     Le Minh Ngoc

To: Dai Chung Magazine and Mr. Hoai Thanh ( Editor and Senior writer), how many times did you  sneak in and out?

I did not intend to write any more, because Le Minh Ngoc has shown the photo of the big con artist  to the public. But today, Hoai Thanh and Dai Chung Magazine “sneak in and out “ on the Thao Luan Magazine three times in a row of five days simply to talk about the article “Dai Chung Magazine sued by the Religion Freedom Committee”. I find myself not being able to be silent any more and I want to present some ideas as follows:

Not only in Vietnam do the calumnies exist as “Priest Nguyen Van Ly has a wife and ten children”  or  “Minister Nguyen Hong Quang seduces a teenager”; but in the USA also, are there many people who speak out  without any proofs.

I have been living in the suburb of Washington, stupidly having my car repainted at Mr. Hoai Thanh’s body shop; I involved in an argument with him and consequently I lost money for nothing. Afterward I have heard many people complain about his “bad achievements” and I have read a series of articles under the title: ” The public wants to know the relief fund for the flood and storm victims” slandering the Religion Freedom Committee sordidly ( those who want to read these articles can surf the Dai Chung website : www.daichung.com ( starting from the issue 68 -70 or so).

Though Hoai Thanh is illiterate (everyone who has met him has known that) but very crooked  (all Hoai Thanh’ s victims agreed on this). Hoai Thanh knows how to criticize very well. Even though “this credit” does not surely belong to him but it likely belongs to ”an invisible big boss” who paid for. Truly, a series of articles “The Public wants to know” as I guess, were written by ”an overseas student” (using the term of Socialism). Everybody knows that Hoai Thanh does not have enough ability to write, even a bad essay. If Mr. Hoai Thanh wants to deny this weakness, I bet you sit in a closed room for two hours and a proctor gives you a subject, I guarantee you cannot complete three correct sentences, but not an article in the same style of Van Nam.

If Hoai Thanh accepts the challenge, I will invite three respectable seniors in the Washington metropolitan area to be proctors and the gentlemen in the editing staff act as examiners. If Hoai Thanh is able to write an article that is as good as that in “ The public wants to know”, I will lose $10.000 which will help Hoai Thanh to pay for the attorney fee in the law suit of the Religion Freedom Committee; and if Hoai Thanh cannot write, you will lose the bet and must hand over the same amount of money of $10.000 to the Community Representative Committee in the Washington area to spend on the public services.

Are you courageous enough to accept the bet. I hope to hear your answer soon on the newspaper. 

Reading the series of articles “The public wants to know”, of Van Nam (that made Mr. Hoai Thanh proud of, with your nose inflated, and chest thrown up to the front to claim that you are the author), everyone see this is the style of “ the overseas student” from Hanoi.

Hoai Thanh has hired one Hanoi overseas student to take care of the “lay out on the web site”. I do not know if this guy and Van Nam are two individuals or just one? But surely the series of articles “ The public wants to know”, of Van Nam always consisted of the special terms used in  Hanoi Red such as the word “ baøu chöûa” that was read in the recent essay. I always remember a sentence in a severe criticism that was like a splash of water to the face of the Religion Freedom Committee, and that the overseas student Van Nam used to spit out roughly as follows “the Vietnamese Communist government authorizes the newspapers to publish the news related to Nguyet Bieu, then Dai Chung Magazine will reproduce it publicly in the future”, -(Being born in the suppressive regime of uncle Ho and the Communist Party, everything must be waited the permission, that is quite right!) -or the calumnious opinion against the spirit leaders in the country:” The relief fund for Flood  reliefs accounted to millions of dollars from overseas did not reach to the hands of the flood victims, because this fund was robbed ,as said in the report, by Venerable Thanh Minh, -a nephew of Venerable Thich Quang Do -, but in reality, Venerable Thanh Minh has kept this fund to build the pagoda”. The similar news as mentioned above was published on Dai Chung, the issue 75. I remember this number, as it is the same name of Pho 75).

If Mr. Hoai Thanh was a normal person, with good personality then surely all the people in the Washington area would believe him and boycott the Religion Freedom Committee and the Overseas VN Radio long time ago.

Although, at least Mr. Hoai Thanh is also successful with some who are naive and live far away and Read Dai Chung on the Website, if not understanding thoroughly, but simply thinking  of  ”there is no smoke without fire”. But to the wise and intellectual, they tend to look for the hidden causes. A newspaper denouncing the corruption and embezzlement of the relief fund for flood victims in an organization, normally needs only one or two commentaries with appropriate languages.  That is enough; writing score of articles is not necessary. Mr. Hoai Thanh, in this case, found fault with and blamed them directly and indirectly in the way because he wanted to beat to death the Religion Freedom Committee and the Overseas VN Radio so that they do not have voices to stand against ” the Big Boss” of his; not because he wants to be on the side of the people to purify community as he said. 

“Purify the community” how sublime is the mission of Mr. Hoai Thanh! In the meantime why do you not clean your tiny body shop?  Only the naiïve client like me gets into your business and was dissatisfied after involving in an argument with you everyday, why do you not clear it up? You forget an elementary lesson which teaches us to perfect ourselves before preaching to others?

You have robbed the salaries of so many apprentices, but now playing the role of a hero to interfere in and get angry against the relief fund raised by the community is blatantly shameless.

I know Mrs. Hien is not stupid. The money received and spent for the flood victims was so surely accounted with care that she dared sue Dai Chung and Hoai Thanh in the court. No criminal is so naïive to report to the police that he is hidding in this bush or hand over the files to Hoai Thanh’s attorney to collect the mistakes in order to be put into the jail if any sign of fraud or embezzlement have been found! Surely Mrs Hien is not such a stupid .It is yourself, a dump who think yourself malicious, being able to deceive the others, and proclaim to be the winner in the law suit in order to prove Mrs Hien “s wrongdoing and cheating.

Hoai Thanh on the chair of defendant has nothing to be victorious. Not being charged for calumny and slander, that must be your big happiness.

For the time being, people are waiting Hoai Thanh to bring Mrs. Hien to the court because she charged you as a liar, a slanderer and a culumnier… while you exposed the whole truth in dozen of articles on “ Quan Chung”. When you dare sue Mrs Hien to the court for the mentioned above crime or for any crime, then the public will praise Hoai Thanh as a hero, even if, the court does not set up the trial. Do you notice that the community favors you, Mr. Hoai Thanh! Just move forward and sue Mrs. Hien then the people admire your mossy face. Only that time is your real “victory”. Try harder man!

Hoai Thanh proudly said he sent his two men back to Viet Nam to see Venerable Thich Khong Tanh and he was told that Mrs. Hien never sent $15.800 of the flood relief fund to the VN United Buddist Committee.

Hoai Thanh was boastering but idiot, Venerable Thich Khong Tanh and the whole VN United Buddist Committee were put under the surveillance of the police, therefore it was not easy for any member of this group to meet anyone except that person carried a permission or a mark of Hanoi.  Even if they met each other, Venerable Thich Khong Tanh was not stupid as Hoai Thanh used to be, because in this era, meeting with an unknown, betrayal believer- is like to to say” hey Mr. Viet Cong and Mr. overseas Vietnamese, we challenged your order to receive $15.000 of the reliefs fund from Mrs. Hien to distribute to the flood victims”!

About the personality of the two individuals of Mr. Hoai Thanh, our ancestors have thought us “ Birds of the feather flock together”. Your friends talk, only dogs believe. You can falsifiy the documents and also convert from yes to no easily. If these two persons were honest they could publicly show their addresses and telephone numbers for people to make a survey. Why they had to hide behind Dai Chung Magazine in order that the overseas student Van Nam could check and report to Hanoi or to the VN Embassy in Washington! And probably this overseas student could answer in the place of you.  I do not know if Ms. Kim Hue is a real or fake character. But I know exactly that Mr. Nguyen van Thang, (the father of lawyer Nguyen Thai). This Mr. “ No Kia “ is not as scoundrel as Hoai Thanh, but his personality is also mediocre. Mr. Nguyen Thai, Nguyen van Thang specialized in writing anonymous letters sometime ago, due to not having any relative supports, he collects the SSI, gets free meals (Guarantee this is 100% true), therefore only $100 can make him talk about everything, not limiting to the story of Venerable Thich Khong Tanh.

Not having a free meal but still have Hoai Thanh put his name on Dai Chung as the title Professor and Journalist. “Such an ectasy “ makes the professor carry out every kind of orders!

Writing to this point, I feel pity to the lawyer Nguyen Thai (Mr. Thang”s son). This is the circumstance of ” an owl father gives birth to an angel”. Perhaps the lawyer resembles his mother, not taking any bad feature of the father. But I sincerely apologize to the lawyer, I do not know how to use the more accurate word for Mr. Thang, he was the most exploited by Hoai Thanh. Throw away the spear you will be a Buddha, Mr.” No Kia “!

I am writing these lines of words not on behalf of the victim of Hoai Thanh. The disadvantage of mine is too small compare to the others. But Hoai Thanh thought that other people were children, who believed every thing he said, therefore I must spend time to help him open his eyes. 

His mossy face is thick skin.  Let’s see, that guy has not been subdued and shut up his mouth. But it is O.K I consider this as a fate. Keep using the name ”Overseas Student Van Nam “ to write stupid thing then I crush his head for the celebration (Hoai Thanh wants this action).

I will lose a little time, but nothing else to lose more, I also did not involve in helping flood or storm victims, therefore I am not afraid to be charged for taking money from the fellow countryman!

Also not afraid of being sued, I only tell the truth, with available proofs, how come Hoai Thanh be able to let his victims go to the court as witness, moreover nothing to be sure that Hoai Thanh still has enough money to follow the law suit, except he is successful in new cheats; because the litigations of the Religion Freedom Commitee certainly made him like a boat staggering in a rough sea. It ‘s a pity!

Mr. Hoai Thanh: the plagiarist “Overseas student- Van Nam”

Dear Mr. Hoai Thanh,

“We” read the words “Your group” of “our”* that made my eyes dazzled with glares: after the land reform in 1954, this is the first time “we”* read this literature style in overseas.  Thank you, Uncle and Party*, for having “overseas student Van Nam” “exported language labor.”

The story “Con Artist” has had Mr. Le Minh Ngoc to deal with you.  I only suggest to you some trifling things as follows:

You think that I do not deserve to challenge Van Nam and Hoai Thanh.  Challenging to test the ability of writing and cheating as you are; it is true that I am not deserving.  I do not hold the position of an editor and “senior pincers and hammer handling”*; therefore, I dare not boast.  But you must see my good will is to look for ways to make money for you.  Mr. Hoai Thanh, you only need to sit in a glass room for two hours (to guarantee no one prompt you and pass the ready made text or email the article to you) to write an essay given by a board of examiners.  The writing need not be necessarily outstanding; the style should be of the same caliber as Van Nam’s, aiming at eliminating fraudulent and exterminating brutality (but supporting the scoundrel), and that is enough.  You will receive US $10,000.  That means $5000 per hour of work.  You see, there is no other writer who can earn such high income.

Compare this to your auto body career-to gain a few hundred dollars, you must perspire plus the customer’s complaint about a job not well done and the request for a refund instead of thanks.  Life is so treacherous, isn’t it?

If you get angry with me, just go ahead, but I advise you to accept the bet.  $10,000 is not a small amount of money.  Do you remember when Mr. Khuong, the owner of My An Fabrics, sued you in court for $10,000?  You paid a lot of money to the lawyer but at the least you had to refund to Mr. Khuong the total of US $30,000 including interest.  No one can earn this amount easily.  Besides, you could demonstrate that you are the real writer and cause shame to those who undermined you as a pincers and hammer holder but not a writer.  This group dare not curse you with bad language.

Do not let this golden opportunity pass you by-that would be very wasteful, Mr. Hoai Thanh!
Did you know that recently a rumor has been saying that you are “degrading” substantially?  Your magazine publishes only once every one or two months because of money shortage, due to your involvement in investigating the relief fund for the flood victims of the Religion Freedom Committee.  Previously, every fortnight you wrote one or two criticisms but recently maybe for a year, no one has seen any of your compositions.

And all of a sudden you proclaimed you won in a few sentences in a soft style, and not as ardent as before, that people called you a scabious dog that was wagging its tail and groaning for a while before dying!

Or you lost the case and you lied about being a winner, Man!  If you had won, an expert writer like you, you should write more, and curse Mrs. Hien and Mr. Hung so that they have to move to another state.  Similar to the time when you lived in Oklahoma, you filed bankruptcy and moved to California and from California to Virginia to “stir up” until now.  You only talk irrelevantly and vaguely-how boring it is!  Therefore, some bad-mouthed guys spread noisily that your loss was so serious that you had to sell the piece of land and the body shop in Maryland and move to Alexandria to treat the “injury,” then continue to “stir” again.

I wish you would earn enough money soon in order to publish the next issue.  Reader Le Tam is waiting to read the composition of Van Nam and to see the firm characteristic of the “leader” of Dai Chung.

One more story, this morning I surfed the website of Dai Chung to search for inspiration, but I do not know why you did not place 9 issues (from #124 to #133) on the website.

Is it because in these issues there are essays of your ancestor teacher Dang Van Nham who cursed and slandered the Venerables in the United Buddhism Religion?  After the bad-mouthed criticism, you felt cold and stopped?  Or you are going to ask something from the Venerables, so you hide these writings in order to be successful in your request.
Hey, Mr. Van Nam, go ahead and write for Mr. Hoai Thanh!  Write in as brutal a style as in the story of robbery, rape, or rats getting into the “sewer,” etc. …the better.  Anyway, remember to respond to the above-mentioned questions.  Don’t pretend to be upset and forget to answer.  Though Mr. Hoai Thanh did not know how to write, but do not let people think that you cannot read.  If so, what a shame!

Le Tam

94)	 The excerpt from the September 2, 2004, program over VPR by CRFV set out above was broadcast and published by the defendants with malice and evil intent in that the defendants knew of the falsity of what they were broadcasting to the Vietnamese listening audience and/or stated, broadcast and published what they said as set out above with a reckless and wanton disregard for the truth.  All of the allegations, about lawsuits, about bankruptcy, about business dealngs of the individual plaintiff, were false and known to be false by the defendants when they wrote and broadcast them. The same was true when the program was repeated on  or about December 23  2004.
95)	The program as a whole, like the excerpt above, was malicious and wanton and per se defamatory and meant to be so by the defendants, misrepresenting on purpose everything that was purported about the plaintiff Hoai Thanh.  
96)	The excerpt itself was malicious and wanton and per se defamatory and meant by the defendants to be so, and it was false, as the defendants well knew.
97)	The excerpt contains many specific per se defamatory words and phrases.
98)	The Vietnamese word (Thang dai bip) is translated in the excerpt as the “conning” or, in the plural “connings.”  In the ninth paragraph, beginning, in English, “The third victim…,” for example the word is used in the singular, and in the fourteenth paragraph, beginning, in English, “Sir, the list of victims is still long,” it is used in the plural.  This word thus means criminally deceiving as in a criminal “conning” a victim as a “con artist” in the English phrase.
99)	The related forms of the word, in Vietnamese (Thang dai bip) is the equivalent of, and can be translated into, in English, “con artist” and is repetitive of the per se defamation.  It is used in paragraphs nine, ten, twelve, and fourteen and even augmented in Vietnamese, as the phrase (Thang dai bip the gian) which makes even clearer that the plaintiff Hoai Thanh is accused of a criminal act.
100)	In paragraph twelve there is a further augmentation, in Vietnamese, (Thang vo liem si) where the plaintiff Hoai Thanh is called a “shameless big con artist.”  This is to make it clear that the plaintiff Hoai Than is accused of being a criminal who is guilty of punishable crimes.
101)	In paragraph fourteen there is even further augmentation in that the plaintiff Hoai Thanh is called in Vietnamese a (Nhung hanh dong lua gat bi oi), which translates into English as “villainous big con artist.”
102)	None of these accusations is true and are all defamatory per se and meant to be so.
103)	The excerpt uses variations on the Vietnamese word, in verb form, which in English is “to steal by trickery” in the sense of an actionable crime.  The Vietnamese equivalent, (luong gat) is used in the past tense, in English “cheated,” and the Vietnamese (lua dao) for the English participle form “cheating” and, in the plural, “cheatings.”
104)	This term luong gat too is, and its variations are, defamatory per se and the accusations made by use of the word are false and known to be false to the defendants when they decided to use the word and its variations and specifically applied them too the plaintiff Hoai Thanh.
105)	In the same way the defendants used in this broadcast program the quoted words (Thang nay quy quyet gian ma) and (ma manh) in Vietnamese meaning in English “cunning” and “cunningly” in the sense of a dishonest man who deceives and tricks in a criminally dishonest manner.
106)	The following terms were also used:

a)	(Thằng lưu manh) in Vietnamese, meaning in English “crook.”

b)	(Thằng lưu manh đại bịp) in Vietnamese, meaning in English “big liar.”
c)	(Tội trạng của nó) in Vietnamese, meaning in English “crime”
d)	(Nhiều mưu kế) in Vietnamese, meaning in English “plots and tricks.”
e)	(Thang lua bip the gian nay) in Vietnamese, meaning in English “bad guy.”
107)	All of these terms as used in the context of the broadcast were per se defamatory and known to the defendants to be false and were used with recklessness and malice.
108)	The broadcast stated that the plaintiff Hoai Thanh had filed “bankruptcy” in the course of dealing with one Khuong.  This accusation was false and known to be false to the defendants when they decided to use it.
109)	This last defamatory false statement was intended maliciously to harm the business reputation and credit of both plaintiffs.
110)	The accounts of judicial proceedings in the United States District Court for the District of Columbia, in the Superior Court of the District of Columbia, in the Circuit Court of Montgomery County, Maryland and in the Circuit Court of Arlington County, Virginia are unfair, false and malicious. The assertions of those accounts in the above excerpt from the VPR/CRFV broadcast are slanderous and defamatory, designed and intended to falsely lead the Vietnamese listening public to believe that the plaintiff Hoai Thanh lied and deceived to, and committed fraud upon, the courts, when he did not do so but proceeded fairly in accord with the rules of the courts and the law.  Defendants designed and intended these false representations to expose the plaintiff Hoai Thanh upt to the wrath, hatred, contempt and ridicule of the Vietnamese speaking American public and, by reflection, his newspaper, the plaintiff Dai Chung BiWeekly newspaper, also.  They have deprived the plaintiff of business customers and readership and of the benefits of public confidence and social intercourse, and, as such, are slanderous and defamatory per se.  
111)	 All of the above slander, libel, and defamation aimed by the defendants at the plaintiff Hoai Thanh was designed to deprive him of business in his newspaper and auto businesses and to deprive the plaintiff Dai Chung BiWeekly Newspaper of its readers and advertisers and did so, the general defamation of the program, and the specific defamation of the particular words and phrases in the above broadcasts in a campaign of similar broadcasts repeated again and again over literally years up to the present time with an intent on the part of the defendants to continue such broadcasts into the future unless prevented from further defamation against the plaintiffs.
112)	The plaintiff Hoai Thanh lost most of the Vietnamese business in his Maryland auto business as a direct result and had to sell the business.
113)	The plaintiff Dai Chung BiWeekly Newspaper lost its readers and advertisers as a direct result to the point where it has had to repeatedly miss issues and now suspend publication in hard copy indefinitely.  Contributors and subscribers have been driven away as a direct result.
114)	The defendants with this defamation and the large number of similar defamations over a period of years have directly, maliciously and unlawfully caused the plaintiff Hoai Thanh to become vexed, harassed, intimidated, threatened physically, to receive threatening phone calls and curses and insults in the street and public places, to become injured and suffer great mental and nervous strain and emotional stress and trauma, and to cause the same to occur to his wife and children and other relatives,   He and his family have been unable to rest and sleep well, have been unable to work with their usual effectiveness and efficiency, and to have had to have medical treatment for conditions directly resulting from the attacks, to suffer scorn, contempt, ridicule, and obloquy from the Vietnamese community in all the states where VPR programs are heard and to suffer  a loss of public confidence and social relationships.  The plaintiff Hoai Thanh, for example, is a veteran of the Army of the late, lamented, Republic of South Vietnam and a member for many years of the organization in this country of such veterans.  Now he is shunned by members of that group as a direct result of the defamation by the defendants.  
115)	Before this campaign of defamation as part of the defendants’ campaign of false light began and before the defendants began to employ their pattern of racketeering activity directly against the plaintiff Hoai Thanh, Hoai Thanh had a good reputation in the Vietnamese community and was considered fair and honest, a leader among his peers.  Defendants have willfully and maliciously destroyed that.
116)	The plaintiff newspaper has likewise, by this defamation against its princii-pal and also against itself, had its former good reputation damaged and destroyed and its personnel and associates have received a treatment similar to that of the plaintiff Hoai Thanh.
WHEREFORE, the plaintiffs pray in this count for defamation, for:
1)	General Damages in the amount of at least five million dollars.
2)	Special Damages in the amount of one million dollars.
3)	Punitive and exemplary damages in the amount of ten million dollars.
4)	Injunctive relief to command repeated publication in broadcasts in all 22 states of acknowledgement of the falsity of the defamations against the plaintiffs, and for injunctive relief on a temporary and then permanent basis to prohibit any further such defamation, and
5)	Any and other further relief as to the Court shall seem meet and proper at law or in equity.
COUNT VI: CONSPIRACY TO DEFAME  
117)	Plaintiffs restate and incorporate all the preceding paragraphs of this complaint.
118)	The individual defendants, and all of them, conspired together as set out in the previous counts in order to perpetrate the torts of slander and libel and defamation to damage the plaintiffs and destroy the plaintiff Hoai Thanh’s business, livelihood and life, his standing in the community, his ability to socialize and to torment and cause emotional suffering and harm to him, his wife, and his family.  
119)	The corporate defendants conspired together to the same end, and were used by the individual defendants as instrumentalities to that end.
WHEREFORE, the plaintiffs pray in this count for conspiracy to defame against all defendants, jointly and severally, for:
6)	General Damages in the amount of at least five million dollars.
7)	Special Damages in the amount of one million dollars.
8)	Punitive and exemplary damages in the amount of ten million dollars.
9)	Injunctive relief to command repeated publication in broadcasts in all 22 states of acknowledgement of the falsity of the defamations against the plaintiffs, and for injunctive relief on a temporary and then permanent basis to prohibit any further such defamation, and
10)	Any and other further relief as to the Court shall seem meet and proper at law or in equity.
COUNT VII: MALICIOUS PROSECUTION

120)	Plaintiffs restate and incorporate all the preceding paragraphs of this complaint.
121)	For six and one half years the plaintiff Hoai Thanh has operated the plaintiff Dai Chung Biweekly Newspaper at the above address, and also in Virginia.
122)	The plaintiff Dai Chung Biweekly Newspaper has during its time of operation circulated and had readership in the entire Washington, D.C. metropolitan area, including Maryland, Northern Virginia and the District of Columbia.
123)	Also at the above address in Maryland for the Dai Chung Biweekly Newspaper, the plaintiff Hoai Thanh operated an auto body shop, Duramax Auto Body, Incorporated, doing business as Duramax Auto Service Center.
124)	On August 30, 2001, the four above-named defendants, VIETNAMESE PUBLIC RADIO, INC., COMMITTEE FOR RELIGIOUS FREEDOM IN VIETNAM, INC., HUNG NGOC GO, and HIEN THI NGO, filed and commenced a civil action against the plaintiffs Hoai Thanh and Dai Chung Biweekly Newspaper a civil action and also against the pen name of the plaintiff Hoai Thanh that he used to write columns in the Dai Chung Biweekly Newspaper, “Van Nam,” in the Circuit Court for Montgomery County, Maryland.  It was assigned the civil number 224653v.
125)	This suit was for defamation in four counts (I, III, V, VII) and intentional interference with “prosective” [sic] advantage in four counts (II, IV, VI, VI).
126)	The defendant THAI H. NGUYEN, ESQUIRE was the attorney who filed the suit in question and was counsel of record throughout its prosecution until it ultimately failed for lack of merit.
127)	The defendant THAI H. NGUYEN, ESQUIRE was also an officer and director of the defendant Committee for Religious Freedom in Vietnam, Incorporated (CRFV)                              at all times pertinent hereto.
128)	The suit sought $25,000.00 in compensatory damages and $300,000.00 in punitive damages on each of the eight counts.
129)	Plaintiffs were served with the complaint, answered, and the action was joined.
130)	The mentioned action was commenced and prosecuted by the defendants to this suit maliciously and without probable cause in that the defendants knew, with regard to their counts and allegations as to interference with prosective [sic] advantage, that there was no such “prosective” or prospective advantage that the defendants had or possessed, much less any with which the plaintiffs, or any of them, had interfered.
131)	The mentioned action was commenced and prosecuted by the defendants to this suit maliciously and without probable cause in that the defendants knew, with regard to their counts and allegations as to defamation, that they alleged that the plaintiffs had stated through the plaintiff biweekly newspaper that the defendants had engaged in “embezzling” funds when, in fact, no such statements had ever been made in the plaintiff publication.
132)	In fact, the opposite was true, as the defendants herein well knew.
133)	The defendants conspired and concerted together to launch the meritless law suit in question for the purpose of interfering with and damaging the business advantages and business of the plaintiffs.
134)	They did this for the purpose of launching their own newspaper to rival the plaintiff newspaper, take away its advertisers and business and prevent the individual plaintiff from continuing in the newspaper business once they had interfered with and damaged the business of the plaintiffs.
135)	They did this through the defendant attorney, who was not paid very much for his efforts, but functioned as a participant in the associated-in-fact enterprise in order that they might financially drain the plaintiffs so as to destroy the business advantages and prospects and business of the plaintiffs, because they knew that the plaintiffs would have to hire expensive representation and be tied up in the law suit with time and resources even though the defendants knew full well that their law suit had no sound basis in fact and no legal merit.
136)	The mentioned action was commenced and prosecuted by the defendants maliciously and without probable cause in that the defendants knew, with regard to their counts and allegations as to defamation, that the plaintiffs herein had only questioned what the defendants had done with funds that the defendants raised through radio shows.
137)	The defendants filed the lawsuit complained of in order to stop the plaintiffs from questioning and looking into the defendants’ fundraising activities in connection with solicitations for funds that defendants claimed were to be used to give relief to flood victims in Vietnam because they knew that the plaintiffs’ exercise of free speech in this regard would help the plaintiffs’ business advantage and correspondingly diminish their own.
138)	These solicitations were published on a radio system to the public in 22 states.
139)	The defendants knew that the plaintiff newspaper was smaller and had no radio outlet that worked with it.
140)	So the defendants launched a campaign of, among other things, accusing the defendants of charging them with “embezzlement” and interfering with the defendants’ opportunities, even as the defendants set out to use their law suit to interfere with the business of the plaintiff newspaper and supplant it with a newspaper controlled by the defendants.
141)	The defendants well knew that to question what happened with funds raised by the defendants’ publishing activities and to ask for accountability to the public of the the Vietnamese-American communities in 22 states was not the same as accusing the defendants of “embezzlement,” but, nonetheless, the defendants pursued their baseless lawsuit against the plaintiffs, even raising funds through the radio publishing activities of the defendants for the purported purpose of funding the meritless lawsuit against the plaintiffs.
142)	The defendants knew, and are charged with knowing, that such questions as the plaintiffs raised were legitimately raised under the First Amendment protections of Freedom of the press and speech.
143)	The mentioned action was commenced and prosecuted by the defendants cynically and maliciously for the purpose of destroying the plaintiff biweekly newspaper’s business and the other businesses and livelihood of the plaintiff Hoai Thanh by exhausting his resources in causing him to have to spend over $150,000.00 in counsel fees while the defendant attorney received a mere $500.00 or so, according to statements made by the attorney defendant.
144)	The defendants compounded this reckless and wanton malice by using their radio broadcasting to destroy the plaintiff Hoai Thanh’s businesses and business reputation, broadcasting continually and incessantly attacks on his character and business reputation and capability in which they continually defamed and slandered him and the plaintiff Newspaper by direct calumny and attack as well as constantly encouraging callers in to the radio shows to slander, defame and even physically threaten the plaintiff Hoai Thanh with bodily harm, including murder, and his biweekly newspaper with physical destruction of its property and facilities.
145)	In a further show of wanton and reckless malice in their filing of and prosecution of the law suit complained of, the defendants started their own Vietnamese language newspaper to compete directly with and supplant the plaintiff biweekly newspaper in the Washington D.C. Metropolitan Area by use of the device of the frivolous and meritless law suit complained of.
146)	By reason of defendants’ actions complained of, plaintiffs suffered injury to their business, business reputation, credit, plaintiff Hoai Thanh’s personal credit, business reputation, mental state, emotional state, health, family relationships, economic loss and pain and suffering in the amount of $3,000,000.00.
147)	By reason of defendants’ actions complained of plaintiffs incurred reasonable legal fees and expenses to defend and defeat the frivolous lawsuit in the amount of $150,000.00.
148)	Because the defendants initiated and conducted the malicious prosecution complained of recklessly, wantonly, and with malice and a total disregard for the rights of the plaintiffs, the plaintiffs are, therefore, entitled to exemplary and punitive damages in the amount of $9,000,000.00.
149)	The defendants launched not just one such law suits, but a series of them, additional numbers of such suits in Montgomery County being ccivil numbers 242835 V and 240210 V.  All of these lawsuits have been essentially the same, and all equally baseless.  None have been won and all have been either dismissed and/or lost on the merits within the last three years. 
150)	The defendants have launched many other such baseless lawsuits against other victims who dare to question their use of funds.  In the action in the Montgomery County Circuit Court mentioned in 147 above, number 242835 V, the four named defendants herein sued, in addition to the plaintiffs in this case, the following:
a)	Khai Tan Le of Olney, MD
b)	Tang Huu Nghia of Tigard OR
c)	Tam Minh Ngo of Salem OR
d)	Dong Phuong News, Inc. of Seattle WA
e)	Saigon Radio Broadcasting System, Inc. of Seatlle WA
f)	Quoc Nam of Seatlle WA
g)	Chinh Nghia News, Inc. of Chamblee GA
h)	Son sVan Ha of Chamblee GA
i)	Kim Au of Chamblee GA
151)	All of these parties, like the plaintiffs herein, dared to question the use of funds by the defendants herein that they raised in the defendant VPR’s programs after initially being deceived by the present defendants and supporting their efforts through their own Vietnamese language local media.
152)	This activity of malicious prosecution with baseless law suits is part of a pre-planned concerted effort that is part of the pattern of racketeering activity engaged in by the defendants.
WHEREFORE, plaintiffs pray in this count for over $150,000.00 in actual and compensatory damages in legal fees and costs, an additional $300,000.00 for emotional distress, pain and suffering, an additional $500,000.00 for damages to their businesses and business reputations from the “hurt” caused by the lawsuits combined with the broadcasts, and $9,000,000,000.00 in punitive damages.
COUNT VIII: CONSPIRACY TO MALICIOUSLY PROSECUTE  
153)	Plaintiffs restate and incorporate all the preceding paragraphs of this complaint.
154)	The individual defendants, and all of them, conspired together as set out in the previous counts in order to perpetrate the tort of malicious prosecution to “hurt” the plaintiffs and destroy the plaintiff Hoai Thanh’s business, livelihood and life, his standing in the community, his ability to socialize and to torment and cause emotional suffering and harm to him, his wife, and his family and to destroy the plaintiff newspaper as a competitor in the Vietnamese language media market.
WHEREFORE, plaintiffs pray in this count for over $150,000.00 in actual and compensatory damages in legal fees and costs, an additional $300,000.00 for emotional distress, pain and suffering, an additional $500,000.00 for damages to their businesses and business reputations from the “hurt” caused by the lawsuits combined with the broadcasts, and $9,000,000,000.00 in punitive damages.

PLAINTIFFS DEMAND A TRIAL BY JURY ON ALL ISSUES SO TRIABLE UNDER THE CONSTITUTION AND LAWS OF THE UNITED STATES.

Respectfully submitted,

______________________________
Laurence A. Elgin      USDC-MD # 13609
Suite 900 South Building
601 Pennsylvania Avenue, NW
Washington, DC 20004-3615
(202) 628-1114
(202) 628-6798 - fax
lawnet@earthlink.net

VERIFICATION UNDER PENALTY OF PERJURY 

I, Hoai Thanh, individually and as the President and owner of Dai Chung News Media Incorporated, hereby swear and affirm under penalty of perjury this 21st day of December, 2005, that the foregoing complaint, and all it’s allegations, are known by me to personally be true to the extent that they can be known and to the extent that they cannot be so known they are based upon my best information and belief.

					____________________________   
					Hoai Thanh