STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY OF KENT

BEST DRUG REHABILITATION, INC., a Nevada corporation,

Plaintiff,

v

a resident of Louisiana,

MICHAELJ. TOTH PHILLIP B. SLOT

Defendant.

(P36310) (P72960)

Kreis, Enderle, Hudgins & Borsos, P.C. Attorneys for Plaintiff 40 Pearl Street NW, 5th Floor Grand Rapids, Ml 49503

(616) 254-8400

Case No. 13-01093-NZ

Hon. James R. Redford

JEFFREY P. RAY (P31098) Jeffrey P. Ray, P.C. Attorneys for Defendant 2500 Lake Lansing Road, Suite A Lansing, Ml 48912 (517) 372-5700

DEFENDANT'S BRIEF IN SUPPORT OF MOTION FOR SUMMARY DISPOSITION

I. Background and Factual Summary

Plaintiff filed a complaint on February 1, 2013 for alleged defamation per se regarding

an internet posting on the website ripoffreport.com. The statement (Exhibit A) cit ed in the

complaint does not have an actual name attached t o the posting, and the poster has signed

their name as simply "Desperat e M other." In to tal, Plaintiff has filed seven lawsuits against

ano nymou s post e rs t o the w ebsite ripo ffrep ort.com . A ll sev en lawsuits were filed in Kent

County during the month of February 2013.

The st atement, if made by Defendant, is protected speech. Furthermore the

stat ements, if false, are not defamatory because they are clearly opinionated reviews and a

plea for help. Strict liability does not exist for defam ation cases and the statements, if made,

were not made with actual malice or reckless disregard for the facts. Pursuant to M CR 2.116

1

• • (C) {8) and (10) Plaintiff has failed to state a claim upon which relief can be granted and this

frivolous lawsuit is an attempt to quiet public discourse with regards to Plaintiff's business

practices.

This lawsuit is also a means to harass Defendant, who resides in another state and does

not have the means to appear in this court to defend her alleged actions. Plaintiff has filed its

suit in Kent County, even though Best Drug Rehabilitation (BDR) is a Nevada corporation with a

facility in Manistee, Michigan. Defendant- resides in louisiana. Plaintiff claims since the

information was accessible in Kent County, this court should therefore have jurisdiction simply

because it was broadcast there.

A. RipOffReport.com

The website Ripoff Report, where the statements were posted, is a site where any

person can post reviews of a business anonymously. Ripoff claims to have never taken down a

review and they are owned by consumer activist Ed Madgeson. Madgeson's company is for­

profit and he has won several lawsuits in the past, using the Communications Decency Act to

show that third parties who publish information are not responsible for its content. Filing suit

directly against the Ripoff Report has been proven unfruitful. Madgeson's site offers

arbitration services for companies who wish to remove content, but there are no guarantees

that a retraction or modification will be awarded.

B. Ripoff Report and Google m

Plaintiff's lawsuit is nothing more than an attempt to remove negative public opinion

from Google '" search engines. Doing a search for "Best Drug Rehabilitation Manistee" results

in the Ripoff Report postings displayed in the top results. (Exhibit B.)

There are some allegations by business owners that Ripoff Report has had nefarious

behavior in regards to getting reviews in the stop search results. Ripoff Report denies such

accusations, claiming that their site is very active resulting in a higher ranking. Regardless, a

2

• • whole industry has erupted for how to "remove" reviews which have been posted on Ripoff

Reports. It is likely that Plaintiff has visited a website similar to

http:// search e ngi n eland .com/how-to-rem ove-ri poff -reports-from-goo gle-n ot- just-bury-them-

65173 . The website states:

"There is a far lesser-known option that I have found that works wonders (which is

probably why Ripoff Report makes no mention of it on their site). You may not be able

to get the damning listing removed from Ripoff Report, but in my experience,

you can get it removed from Google, which is almost just as good.

Here's what you need to do, in three steps:

First, file a lawsuit against the original author of the report for defamation, business

disparagement, false light, or any other claim that is legally appropriate. The big point

here is that you have to prove your case in a court of law - you have the burden to

prove the report made about you is false.

Be honest with yourself here (otherwise, you're just wasting time and money). If the

report about you is true (or if you can't prove your case), you do not have a valid claim

for defamation, and this option will not work for you. Again, the key here is being

able to prove your case in a court of law. If you can't do that, game over. You're stuck

with one of the other options above.

Also, you should only sue the author of the report-do not sue Google. Your lawsuit

will cost a fortune (Google has plenty of good lawyers), fail very quickly, and you will

only serve to anger the one company that can help you the most.

Second, obtain a court order declaring the offending report to be false and

defamatory (this of course assumes you win your case). The specific content of this

order can take various forms, but you should make sure to seek an order that refers to

the offending report specifically.

Third, present the court order to Google.

In my experience, Google will honor the court order and completely remove the

offending web page from its search index."

3

• • Ultimately, Plaintiff is not interested in removing the report itself. Plaintiff seems solely

interested in obtaining injunctive relief against Defendant and sending the (Order) to Google '"

itself, and having any and all reviews from Ripoff Report de-indexed. Should BDR succeed, a

person doing a search for "Best Drug Rehabilitation Manistee" would not see any of the

negative posts on Ripoff in the search results. In essence, if the reviews disappear from

Google'M they will cease to exist.

C. Scientology-Related Rehabs & the Internet

Given that the owners of these rehabs often own lOO's of website domains, their focal

marketing strategy seems to be finding people searching for drug addiction treatment on

Google 'M. A search for "meth addiction withdrawal," for instance, would take a person to a

website similar to drugfreeworld.org or recoveryconnection.org within the top 5 results. These

are generic sites which list textbook information on the stages of various drugs, a digital

pamphlet of sorts. At the top is listed a 1-800 number which individuals can call and poses as a

seemingly nonprofit informational hotline. This number is, in fact, a link to Narconon or

Narconon affiliates. Instead of a non-profit volunteer, the unknowing caller talks to a

Narconon-staff or contracted salesperson who pitches placing a person in one of their

expensive rehabs around the country.

Narconon is a drug rehabilitation program based solely on the teachings of L. Ron

Hubbard and Scientology. The Church of Scientology's website claims that Narconon's success

rate "is not merely the world's highest, it is four times better than international averages."

(Exhibit C) The program is not accepted by mainstream science, and is based on L. Ron

Hubbard's "purification rundown" where participants undergo sauna, vitamin regimens and

training routines. They tout 70% success rates, even though such claims are unfounded, and

their practices have been seen as nothing more than a scheme to prey upon patients and their

families when they are most in need and charge their insurance companies until the coverage

runs out. It is often a standard practice for individuals to sign a Power of Attorney along with

4

• • their admittance documents so that when charges to insurance are stalled, someone who

works in the facility can contact the insurance company to get such charges reinstated.

Numerous lawsuits have erupted around the country, and as a result the newest

facilities leave out the Narconon name to disassociate themselves from liability. Each facility

states that there are techniques used from L. Ron Hubbard, but they do not disclose that the

content is derived from teachings used and associated with the Church of Scientology. A

particularly sinister aspect of these facilities is that they rely on an addict's history of not being

trustworthy. When addicts call home to complain about the fraud, their families find the

stories hard to believe and fail to take action until significant funds have been spent.

Utilizing the Internet is an important recruitment tool for these rehab facilities. To get

websites listed in the top results, Narconon and its affiliates utilize Search Engine Optimization

(SEO) companies. SEQ's can help a company's online marketing strategy through the use of

increasing the recognition of certain keywords- resulting in the company's website displayed in

the top results. This is not the paid results listed at the very top of a Google oM search (also a

technique used by Narconon affiliates) but the organic or "natural" results which are listed just

below.

Googleo• search results are incredibly important, and having negative reviews result in a

top search result is catastrophic for such a business model. The newest Narconon-style rehabs

use generic names and common terms so as to have many "hits." "A Forever Recovery,"

"Tranquility Detox" and "Best Drug Rehabilition", all facilities commonly owned in this state,

incorporate widely used words so as to create a cloak of anonymity when doing a Google oM

search, while still displayed in the top results. A person never hears of the facility except for

what a salesperson has told them. Not allowing outsiders to have their experience

communicated to potential clients is a crucial element to their success. Should public discourse

with their facilities be successfully quieted, there is nothing to stop their continued practice of

unsafe drug detoxification, unproven "holistic" techniques based purely on Scientology

teachings and practices and unhappy families who send their loved ones to their rehabs- only to

make their situation worse. This swindling has all been done at a premium cost to the drug­

addicted and their families, often leaving individuals tens of thousands of dollars in debt.

5

• • D. Plaintiff Wants Only Their Own Favorable Reviews Displayed on Google 'M

Plaintiff is intending for its own authored and subjective reviews to be within the first

search results, and not reviews from outside sources such as ripoffreport.com. BDR has set up

several websites with key words designed to get them to display prominently, as demonstrated

in the following:

• bestdrugrehabilitionreviews.com (Exhibit D)

• bestdrugrehabilitatonreviews.net (Exhibit E)

• bestdrugrehabilitationreviews.biz (Exhibit F)

• bestdrugrehabilitationreviews.org (Exhibit G)

• bestdrugrehabilitation.net/reviews (Exhibit H)

• bestdrugrehabilitationreviews.info (Exhibit I)

• drugrehabilitationrankings.com (Exhibit J)

Interestingly enough, these sites from Plaintiff have employed the service "Domains by

Proxy" in order to protect their anonymity as to who owns and authors the websites- but each

one reads as an advertisement for the facility complete with BDR's phone number one can call

for a free consultation. Domains by Proxy have been controversial throughout the years

because of accusations of aiding malicious fake websites. It is plainly obvious that Plaintiff

feels that their opinion should warrant the privilege of anonymity when it is to increase their

own profit margin, but that others should not have this same entitlement and should not be

protected in court.

6

• • The anonymously registered sites are just part of the online campaign that BDR has to

increase their presence on the Internet in a false positive light.

"http:/ /bestdrugrehabilitationreviews.blogspot.com/" is a blog written by Per Wickstrom,

founder and president of Best Drug Rehabilitation. The website drugrehabilitationrankings.com

has each article written by Wickstrom, and the only reviewed rehabs are A Forever Recovery

(Wickstrom's facility in Battle Creek, formerly known as Narconon Stone Hawke) and BDR

(Exhibit K.) There are also multiple youtube channels, face book groups and twitter accounts.

E. SLAPP

Scientologists throughout the years have regularly employed Strategic Lawsuits Against

Public Participation (SLAPP) in order to protect their reputation. A SLAPP lawsuit is an attempt

to censor and I or intimidate a critic by burdening them with the costs of legal defense. A

typical SLAPP lawsuit will be a civil action with charges of defamation, without any evidence as

to the falsity of the statements made. They are sometimes also an attempt to unmask

anonymous or pseudonymous critics.

To protect consumers against a SLAPP lawsuit and to encourage the right of free speech

and public discourse, 28 states have enacted statutory protections against SLAPPs. Even

though Michigan is not among the 28 states, there are thousands of cases which address these

circumstances. Michigan courts have a long history of protecting First Amendment rights and

have placed very high burdens on a litigant alleging "defamation." Not only have the courts

defended the right to public discourse in their various forms, but even untruthful remarks are

protected when they fall into the category of opinion, rhetorical hyperbole and exaggerated

epithet.

F. Lawsuits are Malicious Prosecution

7

The lawsuits filed by Best Drug Rehabilitation against seven individuals in February 2013

all follow a similar pattern. They pray for injunctive relief, claim damages in excess of $25,000,

and list various lines t aken from the users' alleged Ripoff Report reviews for their charges of

defamation. The reviews are not signed by any name and were posted anonymously. The right

of anonymity is a principle the United States Supreme Court has recognized over and over

again; "an author's decision to remain anonymous, like other decisions concerning omissions or

additions to the content of a publication, is an aspect of the freedom of speech protected by

the First Amendment." Mcintyre v. Ohio Elections Comm'n, 514 US 334, 341-42, 115 S Ct 1511,

1516, 131 LEd 2d 426, 436 {1995). In their attempt to unmask each Defendant, BDR has simply

taken each review and guessed whom the poster's identity might be. The reviews they have

chosen to litigate are chosen at random, and are among countless other complaints (about

BDR) posted on Ripoff Report.

These lawsuits are not even filed in the same county that BDR has its place of business­

in Manistee County. Instead they are filed in Kent County, in which is located the office of

Plaintiffs corporate counsel. They have been filed in Kent County because it is convenient for

them. There is no regard whatsoever for the burden these lawsuits place on the individual

Defendants- all of whom reside in other states. These lawsuits were filed with sloppy,

unsubstantiated claims. Charges where even a modicum of research would reveal them to be

clearly frivolous.

It is plainly obvious that they are dependent on each of the Defendants to not have the

means to afford representation or to appear in court. After all, the majority of these

Defendants have had their monetary resources wiped out from the cost of "treatment" at Best

Drug Rehabilitation. A default judgment in their case, or winning any of the cases by default

judgment, would result in the success of de-indexing the reviews from rM searches. Therefore

they would continue to have unsuspecting clients fall into their sham. These law suits are

inundated in greed, abuse of process and harassment.

G. Lawsuit is Also Retaliation

8

• • In the post referred to by Plaintiff, it was clear that a report had been made to the

attorney general's office in a desperate attempt to remove her son from the facility. One

paragraph, as a whole, states:

"Not good enough for me. I called the attorney generals' office, police officers in both

counties, and the [sic] assured me it was a dangerous program to get him out. I called

the county clerks office to find out that all the facilities even Tranquility, the one who

isn't affiliated with the rehabs are all owned and their building licenses are in the

same name. Well that's all it took. The second lie, why lie about this professional

business? I jumped Oma [sic] plane and headed to Ml! I went to the police dept to

protect myself from the thugs I've heard about. So they cold [sic] assist me in getting

him out."

Plaintiff's intent is not only to remove the offending post from Google'M search results,

but to retaliate against Defendant Lewis for reporting improper business practices to

authorities in the state of Michigan. Plaintiff has filed this lawsuit in bad faith and with unclean

hands.

II. Standard of Review

"A motion for summary disposition brought under MCR 2.116(C)(8) tests the legal

sufficiency of the complaint on the basis of the pleadings alone. The purpose of such a motion

is to determine whether the plaintiff has stated a claim upon which relief can be granted."

Beaudrie v Henderson, 465 Mich 124, 129-130; 631 NW2d 308 (2001). "Unless the claim is so

clearly unenforceable as a matter of law that no factual development can possibly justify a right

to recover, the motion under this sub-rule should be denied." Wodoqaza v H & R Terminals,

Inc, 161 Mich App 746, 750; 411 NW2d 848 (1987).

9

• • "A motion for summary disposition under MCR 2.116(C)(10} tests the factual support of

a claim." Amv v MIC General Ins Corp, 258 Mich App 94, 102; 670 NW2d 228 (2003}.

"Summary disposition is proper under MCR 2.116(C)(10} if the documentary evidence shows

that there is no genuine issue of material fact, and the moving party is entitled to judgment as a

matter of law." O'Donnell v Garasic, 259 Mich App 569; 676 NW2d 213 (2003}. "In deciding a

motion brought under this subsection, the trial court must consider affidavits, pleadings,

depositions, admissions, and other evidence submitted by the parties ... in a light most favorable

to the nonmoving party." Kelly-Stehnev & Associates, Inc v MacDonald's Indus Products,

!JJs; 254 Mich App 608, 611-612; 658 NW2d 494 (2003). "The moving party has the initial

burden of supporting its position with documentary evidence, but once the moving party meets

its burden, the burden shifts to the nonmoving party to establish that a genuine issue of

disputed fact exists." /d. "A genuine issue of material fact exists when the record, giving the

benefit of reasonable doubt to the opposing party, leaves open an issue upon which reasonable

minds might differ." Johnson v County o{Jackson, Mich App, Unpublished No. 236622 {Sept. 11,

2003}.

Ill. ARGUMENT

A. The First Amendment and libel

The First Amendment to the United States Constitution guarantees the freedom of

speech. Although it does not grant immunity for false or defamatory statements, there are

10

• • several rules which significantly narrow a Plaintiff's chances for successfully litigating a

defamation action.

The bellwether case, New York Times v Sullivan, 376 US 254; 84 S Ct 710; 11 LEd 2d 686

{1964) reflects the current interpretation of the First Amendment as it relates to charges of

defamation. On March 29, 1960, the New York Times published a full-page advertisement

entitled "Heed Their Rising Voices," in which it stated that students engaging in non-violent civil

rights demonstrations in the south had been "met by an unprecedented wave ofterror." It was

further stated in the ad that truckloads of heavily armed police had surrounded the Alabama

State college campus; that police had padlocked students inside the dining hall to starve them

into submission; that police had arrested Dr. Martin Luther King seven times; and that Dr. King's

protests had been met "with intimidation and violence," including bombing his home,

assaulting him, and charging him with perjury.

Many of these statements were false. Police did not padlock students in the dining hall,

Dr. King was arrested four times, not seven, and the evidence around whether an arresting

officer had assaulted him was conflicting. But the United States Supreme Court rejected an

absolutionist analysis that any false statement could be "libel" and therefore claim "no

talismanic immunity from constitutional limitations." /d. at 269. Like all "other formulae for the

repression of expression," libel "must be measured by standards that satisfy the First

Amendment." /d.

It was recognized that the public discourse would entail engaging in vehement, caustic,

and sometimes unpleasantly sharp attacks on government and public officials. The Court also

observed that "erroneous statement is inevitable in free debate." /d. at 271. Accordingly, some

false statements "must be protected if the freedoms of expression are to have the 'breathing

space' that they 'need ... to survive."' /d. at 272, quoting NAACP v Button, 271 US 415, 433; 83 S

Ct 328; 9 LEd 2d 405 ( 1963).

With this established high standard of libel law, Plaintiff must prove clearly and

convincingly that Defendant intentionally lied or acted recklessly in making the challenged

statements. Proof of negligence does not suffice. The Supreme Court has also extended this

11

• • constitutional privilege to protect defamatory criticism of nonpublic persons who "are

nevertheless intimately involved in the resolution of important public questions or, by reason of

their fame, shape events in areas of concern to society at large." Curtis Publishing Co v Butts,

388 US 164; 87 S Ct 1975; 18 L Ed 2d 1094 (1967). Additionally, it has been extended to cases

where the Plaintiff is a private individual. Gertz v Robert Welch, Inc, 418 US 323; 94 S Ct 2997;

41 LEd 2d 789 (1974.)

B. Michigan Courts Have Upheld New York Times v Sullivan

For decades, the Michigan Supreme Court has vigilantly protected free expression

through strict application of constitutional principles:

For example, In re Chmura, 464 Mich 58; 626 NW2d 876 (2001}, (discussing New York

Times and the actual malice standard in reversing a decision by the Judicial Tenure Commission

that a sitting judge had violated the Code of Judicial Conduct by statements he made in the

course of a campaign); Rouch v Enquirer & News of Battle Creek (Rouch If), 440 Mich 238, 258;

487 NW2d 205 (1992},(reversing a jury verdict in a libel case, discussing the importance of

independent review in such cases, and noting the concern that "juries may give short shrift to

important First Amendment rights"); Locricchio v Evening News Ass'n, 438 Mich 84; 476 NW2d

112 (1991}, cert den, 112 5 Ct 1267 (1992}, (conducting an independent review of the record

and reversing a jury verdict in a libel case); Battaglieri v Mackinac Ctr for Pub Policy, 261 Mich

App 296; 680 NW2d 915 (2004) (discussing the definition of actual malice and reversing the trial

court's decision denying summary disposition in a false-light claim brought by a public figure);

Lakeshore Community Hospital Inc v Perry, 212 Mich App 396; 538 NW2d 24 (1995), (conducting

an independent review, finding insufficient evidence of actual malice and vacating the trial

court) and Garvelink v The Detroit News, 206 Mich App 604; 522 BW2d 883 (1994), (conducting

an independent review of the record and reversing the trial court's decision denying summary

disposition to a defendant in a public official libel case).

C. The Statements Cited in Complaint are Rhetorical Hyperbole

12

• • The statements cited by BDR in their complaints were written without actual malice,

because the poster believed them to be true, or they fall into the category of "Rhetorical

Hyperbole" or "Vigorous Epithet." Statements must be viewed in context to establish if they

are capable of defamatory interpretation. Ireland v Edwards, 230 Mich App 607, 584 NW 2d

632 (1998.} Defamatory statements, in order to be actionable, must state actual facts about a

plaintiff, thereby protecting statements that, although factual on their face and provable as

false, could not reasonably be interpreted as stating actual facts about the plaintiff. Ireland,

supra p 617, 584 NW 2d 632, citing Milkovich v Lorain Journal Co., 497 US 1, pp 16-17, 110 5 Ct

2695.

In Ireland, it was concluded that the statement that Ireland "never" spent time with her

child was patently false and an obvious expression of disapproval of the amount of time Ireland

spent with her child, but that no reasonable person would believe the statement stated actual

facts about Ireland. Kevorkian v. American Medical Association, 237 Mich App 1; 602 NW 2d

233, (1999} citing Ireland, supra, p 619, 584 NW 2d 632. Similarly in Kevorkian, the statement

that Plaintiff was a "murderer" was determined to be a strongly worded opinion, and not the

actual accusation of a crime.

D. The Forum Used for the Posts Communicated Clearly That They Were Opinions

Ripoff Report is an opinion website. Indeed, at the top of "Ripoff Report," it is posted

"By consumers, for consumers ... " and "Consumers educating consumers." Any reasonable

individual who reads the reviews would gather that they are not an official source, and that the

statements were expressions by ordinary laypersons meant to show strong disapproval of

business practices.

To surmise that any and all information posted on the Internet is posted as literal fact,

especially a site whose primary purpose is to post opinionated reviews, would deem the vast

majority of the Internet as actionable for defamation. This literal and absolutionist

interpretation of the law has been ruled against time and time again. Should BDR's

13

• • interpretation prevail, then the courts would be flooded with litigation. Something as

innocuous as a facebook'" status update or a product review on a blog could potentially

bankrupt the author. The Internet would be encumbered as a result, reversing the information

and technology revolution of the past few decades. This would stifle users, have a chilling

effect on speech and the flow of legitimate opinion and information due to the fear of lawsuits.

What is more, as demonstrated in Gertz v Robert Welch, Inc, 418 US 323; 94 S Ct 2997;

41 L Ed 2d 789 {1974), strict liability for defamation is unconstitutional in the United States; the

plaintiff must be able to show that the defendant acted with a higher level of mens rea. Simply

claiming that the statements, if submitted by Defendants on ripoffreport.com, were false, is

insufficient. The statements were what was believed to be true and there is no proof that such

statements, if made, were with actual malice. Simply a failure to investigate if the claims are

true does not show blatant disregard for the truth. StAmant v Thompson, 390 US at 731, 733,

88 S Ct 1323 {1968}. Should such a standard exist it would be unreasonable. Individuals posting

on the Internet would be in constant fear of litigation and end up self-censoring to a degree

that would stifle communication and meaningful dissent.

E. Summary Disposition is Suitable for these Lawsuits

Pursuant to MCR 2.116 (C) (8), when the Plaintiff has failed to state a claim upon which

relief can be granted, summary disposition is appropriate. The Supreme Court has ruled that

summary judgment is particularly important in libel cases. See Anderson v Liberty Lobby, 477 US

242; 106 S Ct 2505; 91 LEd 2d 202 (1986} as well as our own state courts, Kevorkian v American

Medical Ass'n, 237 Mich App 1,5; 602 NW2d 233 {1999} where it was observed that "[s]ummary

disposition is an essential tool in the protection of First Amendment rights." Summary relief to

defendants is necessary to avoid the 'chilling effect' on freedom of speech and press Lins v

Evening News Ass'n, 129 Mich App 419, 425; 342 NW2d 573 (1983.)

Furthermore, MCL 600.2911(6) states:

14

• • "An action for libel or slander shall not be brought based upon a communication involving public officials or public figures unless the claim is sustained by clear and convincing proof that the defamatory falsehood was published with knowledge that it was false or with reckless disregard of whether or not it was false".

Our own Michigan Supreme Court, in Smith v Anonymous Joint Enterprise, 487 Mich

102; 793 NW2d 553 {2010} has recognized this high threshold for the actual malice standard.

"[A] plaintiff must present sufficient evidence to justify a conclusion that the defendant made

the allegedly defamatory publication with a 'high degree of awareness' of the publication's

probably falsity, or that the defendant 'entertained serious doubts as to the truth' of the

publication made." Smith, 542, quoting StAmant v Thompson, 390 US 727, 88 S Ct 1323 (1968}.

F. Plaintiff's Frivolous lawsuit Warrants Sanctions

MCR 2.114 and MCR 2.625(A}(2} permits the Court to award of attorney fees to the

prevailing party pursuant to MCL 600.2591 for frivolous suits. BJ's & Sons Constr Ca, Inc v Van

Sickle, 266 Mich App 400, 404; 700 NW2d 432 (2005} "Under Michigan law, a party that

maintains a frivolous suit ... is subject to sanctions under applicable statutes and court rules."

MCL 600.2591 provides:

(1} Upon motion of any party, if a court finds that a civil action or defense to a civil action was frivolous, the court that conducts the civil action shall award to the prevailing party the costs and fees incurred by that party in connection with the civil action by assessing the costs and fees against the nonprevailing party and their attorney.

(2} The amount of costs and fees awarded under this section shall include all reasonable costs actually incurred by the prevailing party and any costs allowed by law or by court rule, including court costs and reasonable attorney fees.

MCL600.2591(3}(a} further reads:

[f]rivolous' means that at least 1 of the following conditions is met: (i} The party's primary purpose in initiating the action or asserting the defense was to harass, embarrass, or injure the prevailing party, (ii} The party had no reasonable basis to believe that the facts underlying that party's legal position were in fact true, (iii} The party's legal position was devoid of arguable legal merit.

15

• • The claims or defenses at issue must be evaluated at the time they were made in order

to determine if sanctions are appropriate pursuant to MCL 600.2591. In re Costs & Attorney

Fees, 250 Mich App 89, 94; 645 NW2d 697 (2002}. The court must examine "the particular facts

and circumstances of the claim involved." /d. at 95. Sanctions are imposed against frivolous

claims '"to deter parties and attorneys from filing documents or asserting claims and defenses

that have not been sufficiently investigated and researched or that are intended to serve an

improper purpose."' Van Sickle, 266 Mich App at 405, quoting FMB-First Michigan Bank v

Bailey, 232 Mich App 711, 722-723; 591 NW2d 676 {1998}.

IV. CONCLUSION

This is a frivolous lawsuit, filed in bad faith without supporting law to defend Plaintiff's

argument. The Internet postings referred to in Plaintiff's complaint were anonymous, and the

statements, if made by Defendant, are protected speech because they are clearly and

unequivocally opinionated by nature. Plaintiff is attempting to sue the legal system to prey

upon persons from out of state making it unlikely they can defend themselves and thus insuring

a high probability of a default judgment and achievement of their goals of de-indexing negative

opinions about their business practices while they, themselves, anonymously control as much

of the internet traffic as they can. This harassment and intimidation comes at a high price to

these individual Defendants and place them at the additional burden of having to defend

themselves in an inconvenient forum.

These practices and the Complaints they spawn are as close to abuse of process as any

claim may ever be.

Defendants are entitled to summary disposition and should receive this Court's serious

review of sanctions in the form of an order for reimbursement of their actual costs and

attorney fees incurred in the defense of such claims.

16

• • The claims or defenses at issue must be evaluated at the time they were made in order

to determine if sanctions are appropriate pursuant to MCL 600.2591. In re Costs & Attorney

Fees, 250 Mich App 89, 94; 645 NW2d 697 {2002}. The court must examine "the particular facts

and circumstances of the claim involved." ld. at 95. Sanctions are imposed against frivolous

claims '"to deter parties and attorneys from filing documents or asserting claims and defenses

that have not been sufficiently investigated and researched or that are intended to serve an

improper purpose."' Van Sickle, 266 Mich App at 405, quoting FMB-First Michigan Bank v

Bailey, 232 Mich App 711, 722-723; 591 NW2d 676 {1998}.

IV. CONCLUSION

This is a frivolous lawsuit, filed in bad faith without supporting law to defend Plaintiff's

argument. The Internet postings referred to in Plaintiff's complaint were anonymous, and the

statements, if made by Defendant, are protected speech because they are clearly and

unequivocally opinionated by nature. Plaintiff is attempting to use the legal system to prey

upon persons from out of state making it unlikely they can defend themselves and thus insuring

a high probability of a default judgment and achievement of their goals of de-indexing negative

opinions about their business practices while they, themselves, anonymously control as much

of the internet traffic as they can. This harassment and intimidation comes at a high price to

these individual Defendants and place them at the additional burden of having to defend

themselves in an inconvenient forum.

These practices and the Complaints they spawn are as close to abuse of process as any

claim may ever be.

Defendants are entitled to summary disposition and should receive this Court's serious

review of sanctions in the form of an order for reimbursement of their actual costs and

attorney fees incurred in the defense of such claims.

16

• Dated: March 28, 2013

17

• Respectfully submitted,

Lansing, Ml 48912 (517) 372-5700

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Please help us get our aon out of this Scientology/ narconon rehabilitation center. This place Is a scam and a wry dangerous place for anyone.

My son, 19ls an addict who suffers from ADHD and ODD. He Hnally decided he wanted to get clean and stay clean arlee and for all. He truly wants to get his life straight after years of battling these diseases.

Of course that was the basi news of my life. I went straight to the J..pad and searched desperately to find the best help possible. I called a man In Florida, who Is a recruiter for rehabilitation centers (so I thought). So I haw great Ins. But a wry high deductible so I was told 1 needed 10 grand. I dldn1 haw that money just sl11lng there ya know. So guess what, Florida guy

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on the Internet abo •. • So my son Illes away to Manistee, Ml, to a place called ~Best Drug Rehabilitation", so 1 thought. I started looking at the weather there just to see how cold it was compared to what he's used to and to my surprise, I found hell ...

I couldn't bellew what I as reading aOOut these facility's. Scientology/ Narconon?? 1 read aOOut deaths, brainwashing, extortion, d11.1g trafficking, human trafficking, insurance fraud, and the list goes on. This is the biggest money making scam. It made me sick and scared because I sent my child here for help and he might die?

I decided right or wrong I just wanted him to come home and get help Elsewhere. called the intake officer In Manistee and asked that all rehabilitation stop Immediately and to gi-.e my son his cell phone back so I could talk to him. They refused to let me speak to him or haw anyone call me back. Finally someone called me from BattleCreek Ml, at Tranquility Oetox. What? Who are he's people? Detox? More drugs? He is four hours away from the place I sent him. Still alter getting wry Irate they said he was going through withdrawals so bad he couldn't get out of bed. He needed grubs to take the edge off. If I remm.e him I wold kill him. I was confused be less than twelw hours before this he was able to fty and awn catch a connections Hight and had nB\ef ftown before. How could this be? This particular place assured me they aren't affiliated with the rehab centers 1\e read aOOut that hey are just contracted by them. They promised me he wold n8\Eir sea anyone from the rehab. That they are behind looked doors and he Vv'Ould be safe. So I relaxed for a split second when I heard his \Qice say mom I'm okay.

Not good enough for me. I called the attorney gooerals office, police officers in both counties, and the assured me It was a dangerous program to get him out. I called the county clerks office to find out that all the facilities e\00 Tranquility, the one who isn't affiliated with the rehabs are all owned and their building licenses are in the same name. Well that's all it took. The second He, why lie about this professional business? I jumped Oma plane and headed to Ml! I went to the police dept to protect my self from the thugs 1\e heard about. So they cold assist me in getting him out.

He won't gall He refuses to leaw with me. He wrote me a latter while standing there. H statod he's happy and finally fits in and they low him and all they want to do is help him. He is hea\-ily medicated and looked completely high when I saw him. The letter was coached because I know my son. I had to leaw be I became Irate and distraught. just can't beliew hey haw brainwashed him already.

1\e tried e-.erything I can to get him. I hire an attorney who has a case against hem already. I found out that hey don't haw a license to practice medicine in the facility. Wher did the d11.1gs come from. Who's administering these drugs be no licensed medical professional can practice in a facility that doesn't haw a state license. All the staff they haw were once a student themselws, some just months before. There Is no one with any type of certifications other than~ L Ron Hubbard's~. Videos. YES!, Scientology! E-.er time I speak to my son I scream these thing to him before he gets a chance to hang up hoping that something will click when he gets to the treatment facility. The new facility that they're sending him to is Forewr Recm.ery?. !terminated our son from our insurance and they will not get a dime. They still will not let him go. Who's paying and why? Why did they change rehabs?

Now here I sit back at home. What can I do? I want him out! I hope someone knows something 1\e owr1ooked. I need help people before my child and others children lose their li-.es.

Thts rcporl was posted on on 1113/2012 8.34.05 J1v1 and 1s a perm:ment record locatecd ~IHIIJ /lforPVPF-f!li~Overylcultlhilt\lt---creek-rridug'"'-f>hd90.hhn n,e posting lorn:, lndicilt .. d i~ AJl(OFlH lll<;fll lila: Ad70ilo:J d~'~S not ob5erv<· dnyliphl 5<n'Fng~ ,;o th<J poc;t tinr may• tFO M:ountnin or P;Jcd•c doiJO!ldlt!\) on the t•n-e of yeor

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#1 Consumer Comment

Best bet AUTHOR: Stacey- Dalla& (U.S.A.)

SUBMITTED Saturday. November 03. 2012

Once they cannot squeeze anymore money out of you then they will kick him out -

these people only care about the almighty dollar period. Since your son Is of age

getting him committed through a court order may be hard but I suggest you seek

that a-.enue if you can. I am not an Atty but if he is a danger to himself or others

than that may be an a\eflue you can seek

Good luck and God Speed- these people are ruthloss and unethical in all stages!

Respond to this report! Ae a POOutlal

#2 Consumer Comment

Invitation AUTHOR Narconor,::cS<:Ientology. (USA)

SUBMITTED Monday. Novembbr 05.2012

You may find additional help on Reaching for the Tipping Point. The forum is run by

\Oiunteers that help \-ictims of Narcooon.

http://forum.reachingfortheti ppingpoint.neUindex. php

There is information about Best Drug Rehab and A Fore-.er Rocowry on the forum.

Someone posted your complaint in this thread·

http://forum.reachlngforthetlppingpoint.neUindex.php?

action -=post;topic-= 1 0 723. 60;num _replies -=o66

Respond to this report! Ae a Robtlttat

#3 Consumer Comment

worst place ever AUTHOR krl&ten- pleaaant hope (United State& of America)

SUBMITTED_ Monday. F"ebi\Jal)' 04. 2013

I was wanting to get help for a drinking problem I was ha..tng. The place I was going

to required you to go here first to do the program. I was not 'Nithdrawaling from

anything when I got here. They tried to make me take diazepam which is va!ium 5 times a day. I refused so they told me I was being del"yont an that I would just ha-.e

to stay there longer if I didn't. There was no structure or order to anything they did. 1 strongly ad'-.tse if you ha-.e a daughter here go get hor now!!! The men an womon are

not separated except klr rooms. Giris were walking around an in hot tubs with the

men I bikinis. I was so scared an uncomfortable an was asking to go home for 3 days tell I finally had to for real jump the fence to got out! I could go on an on I hope I can atleast holp people know what that place is like.

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Author Topic: Best Drug Rehabilitation- Reaching For the lipping Point forum.reachingforthetippingpoint.neUindex.php?topic-10723 .. 20 posts - 6 authors - Jun 26, 2012 Best Drug Rehabilitation .... After 10 days at detox I was taken to Manistee, Michigan, which is where BDR is located. It was a rundown building ... Ynu'VP visited this page :l time~ last IAsit· 2"(17.'1:\

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NARC ON ON AN INTERNATIONAL DRUG REHABILITATION PROGRAM SAVING LIVES Global drug abuse has led to what can inarguably be described as a world awash in

blood and human misery.

In reply stands Narconon (meaning "no drugs"), the drug rehabilitation and

prevention program founded in 1966 and based on the discoveries of

L. Ron Hubbard.

The Narconon program not only addresses the mental and physical debilitation

precipitated by drug abuse, but also the reasons why an individual turns to drugs

in the first place.

Global drug abuse has led to what can inarguably be described as a world awash in

blood and human misery.

In reply stands Narconon (meaning "no drugs"), the drug rehabilitation and

prevention program founded in 1966 and based on the discoveries of

L. Ron Hubbard.

The Narconon program not only addresses the mental and physical debilitation

precipitated by drug abuse, but also the reasons why an individual turns to drugs

in the first place.

As a result, the Narconon success rate is not merely the world's highest, it is four

times better than international averages.

But with drug abuse now ruining 200 million lives worldwide, the battle to

eradicate abuse must also include prevention. To that end, Narconon graduates

and volunteers conduct one of the most effective drug awareness programs on

Earth. To date, it has provided more than 17 million young people with the facts

about drug abuse.

Scientologists helped sponsor the creation of Narconon Arrowhead. Established in

2001, this is the premier facility of the Narconon network. It stands amidst 216

acres of woodland on the shores of Lake Eufaula in southeastern Oklahoma. In

addition to bemg the ww·s largest residential tacillty 0

Arrowhead also serves as the international training cen

kind, Narconon

r for drug rehabilitation

specialists. Since opening its doors, it has provided on-site internships for

professionals from 13 nations and 43 US states.

Today, the worldwide Narconon drug rehabilitation and prevention network

comprises more than 180 centers and groups across 47 nations-double the

number of a decade ago.

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By providing supervised detoxification and a comprehensive rehabilitation program, Best Dmg Rehabilitation's centers have saved lives. The success rates are impressive, and testimonials from recently recovered addicts prove that our methods !Or treating drug addiction are fur more successful than those archaic practices of the past.

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The best source of client reviews for Best Drug Rehabilitation is stmight from the clients, becatL~e it allows one to hear about the healing occurring in their lives. At Best Drug Rehabilitation, the goal is to create a positive environment appropriate for healing a person's spirit, mind, and body. Treatment options can be customized to best suit the individual needs and wants of every client who walks through the doors. Getting Addiction Treatment Many who fight the battle with an addiction problem continue to sulfur because they reel there is no hope fur the happiness they once fult. [Read More ... ]

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Cocaine Addiction

Cocaine addiction is becoming a growing trend. Cocaine is a hydrochloride salt which can be snorted, smoked or injected. [t also can be applied to vagina~ oral or rectal rrrucus membranes and can be mixed with liquor. Cocaine is normally not taken by mouth fur recreational purposes because it has toxic reactions such as death. Usually, the only time cocaine is taken orally is when a person tries to hide the cocaine from the law or border patrol Regardless of the method of ingestion, repeated usc will result in addiction and serious side clfucts to the user's health and lifustyle. Getting "Slammed" The white cocaine powder can be melted in water and used intravenously, known as getting slammed. Cocaine has a high melting point so it cannot be smoked and using intravenously is the most popular way to do the drug. When frcebasing occurs it converts the hydrochloride into sulfute and is free of additives. It's not water soluble and the melting point is very low and now it can be smoked. It is very dangerous to frcebasc cocaine. Addiction to Crack Cocaine Crack is the most popular drug on the street and is sold in vials and easy to smoke. It is smoked in crack pipes, in cigarettes and in marijuana joints. The toxic dose of cocaine is not known because everyone is dilfurent and some people can handle more than others. Usually cocaine is used among yotmg kids, along with alcohol and marijuana use, and this can become a deadly practice. Contact Us Today To Speak With A Counselor About Our Programs and ...

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!Jest Drug Rehabilitation has one goal That goal is to provide the best care that an individual can receive at an addiction treatment mcility. Drug or alcohol addiction has negative cffucts, not only on the addict, but on the~ loved ones as weD. Addiction affucts every aspect of an individuars lifu, relationships, 6nances, work or sehoo~ physical health, as well as mental health. We arc a residential treatment center with a highly skilled profussional staff on hand 24 hours a day, seven

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November 14, 2012 By l!llmin Leave a Conunent

If you or a loved one are sulfuring from drug or alcohol addiction and are looking lOr help from an addiction treatment fucility, perhaps you have read sorne Ucst Drug Rehabilitation reviews. If you have read the reviews, you know of the success rate we have with addiction trcat:rrent. Uest Drug Rehabilitation fu.cilitics ofiCr many program; fur ak;ohol and drug addiction.

The Etlects of Addiction

Drug and alcohol addiction affucts nany fiunilies in the United States today. 1bis can cause a breakdown in corrnrrunication within a fumily. When this happens an individual can sink deeper and deeper into depression and thus, into drug abuse. Many people have fiunily problclll5 or situations which they fuel are impossible. 1herefbre, they drink or take drug5 such as tranquilizers to mask their fCc lings of hopelessness and insecurity. After a while this no

lon!:,Jt!r works, so they either drink rmre or take a larger dosage of pills. All this leads to fi.dl blown dmg or alcohol addiction. At this titne the individual has a physical addiction to the dmgs or alcohol When this happens, they can no loll!,JCr quit on their own. lbey must have protbssional help in stoppit1g

the abuse.

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If you check Best Drug Rehabilitation reviews, you will see that we have highly skilled profussionals to help with a sate detoxification, or detox, fur each of our clients. At our residential treatm::nt fucilities there is a compassionate and caring staff on duty 24 hours a day seven days a week. They can help wi1h any issues, physical or ermtiona~ which may arise during detox. If a client just needs someone to hold the~ hand during this process, they will have ~. Many members of our staff are recovered addicts; they know exactly what the client is going through and can have an understanding like no one else ofthcir fueling.<; and sulfuring.<;.

1he detoxification process is the hardest part of their addiction recovery. Once this is over, the client will be well on their way to complete recovery

fium the~ alcohol or drug addiction.

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Best Drug Rehabilitation Michigan Reviews

Addiction can be a devastating force in one's life and the best choice for overcoming an addiction is through treatment at a professional rehab center according to many positive Best Drug Rehabilitation reviews.

Best Drug Rehabilitation Treatment Programs

Alcohol and substance abuse can tead to loss of employment, alienation from friends and family and coutd possibly result in death. After a while, as an addict reviews their experience with addiction, they feel as if they are powerless over the situation. Best Drug Rehabilitation Michigan helps clients understand the under1ying forces that contributed to their addiction and teaches them the skills they need to overcome these obstacles.

Now I am a different person. I have restored my sanity. Best Drug Rehab gave me a second chance at life.

Best Drug Rehabilitation reviews reveal that the key to recovery is set up to provide the support structure needed to help addicts beat their addictions. The ultimate goat is to provide the individual with the tools necessary to abstain from substance abuse in the long·run. The treatment provided at Best Drug Rehabilitation establishes a foundation for the addict to overcome the cravings and triggers that are present on a day-to-day basis.

The program offered by Best Drug Rehabilitation Michigan is designed to work in conjunction with detox in order to provide the client with long·term results. The program addresses the physical and emotional needs of the client and seeks to improve their daily living skills with relapse prevention as the main objective. Nutritional guidance and healthy activities are availab~, including counseling designed to help the client build interpersonal relationships.

The type of treatment at a rehab center is targeted to the particular needs of each client. Certified addictlon specialists and supportive staff provide regular evaluations and reviews to design treatment programs based on the client's individual progress throughout the program.

At Best Drug Rehabilitation, there are a wide range of therapies offered that focus on aU facets of addiction recovery. CaU us to learn more information about the Best Drug Rehabilitation Michigan reviews and about our program.

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Best Drug Rehabilitation Reviews

We welcome all reviews at Best Drug Rehabilitation. If you read some of our reviews, you will see that we have a high success rate with our clients. We encourage our clients to take part in selecting a treatment program which suits their individual needs and prererences. No two addicts have the same issues, just as no two programs should be the very same. We reel this is why we have such good reviews about our programs and treatments. About Our Program at Best Drug Rehabilitation Best Drug Rehabilitation takes a holistic approach to drug and alcohol treatment We reel that you shouldn't replace a drug or alcohol addiction with another drug. We treat our clients with vitamins, nutrients, and healthy nourishing meals. Best Drug Rehab offurs things such as yoga, meditation, acupuncture, and massages !Dr a natural approach to healing. We have an exercise and weight room

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Prescription drugs only suppress the symptoms of your disease and cause disruption in the normal body cell fimctions. This why prescription drug users are subject to getting a disease, because prescription drugs can cause malfimction of cells. Recent studies have showed having over 2 million Americans were admitted to the hospital for serious effects of prescription drugs with over 100,000 resulting in death. Prescription Drugs Arc Just As

Serious As Illegal Drugs Other dangers of prescription drugs occur with those who are abusing a prescnbed a medication, or one not prcscnbcd to them Teens arc more likely to be turning to prescription drugs rather than street drugs these days, because they are easier to get. Many prescription drug abusers reel their drug of usc is not as dangerous ... [Read More ... ]

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Fact or Fiction: Addiction is hereditary

by Per Wickstrom

Addiction and Heredity

There is not one single cause !Or addiction factors are at work simuhaneously. One reason addicts relapse

is that a rehabilitation may address one factor relating to their addiction, but not the rest. They could go through seveml rehab progmtm and still not have ef!Cctively covered all the elements at work. The question regarding the role that heredity plays in addiction is often asked. Is addictive behavior handed down from genemtion to genemtion? If the great-grandfather was an opium addict, the gmndfuther a tmrphine addict, and the lather a heroin addict, will the son or daughter become a methadone or prescription pill addict? Does the child of an alcoholic possess an involuntary inclination to become alcohol

dependent?

Researchers have been looking fur genetic factors related to a propensity fur addiction One study in the United Kingdom points to brain cell abnormalities present in siblings of drug addicts. The study analy7-ed brain scans of 50 cocaine addicts and their non-addicted brothers and sisters, as well as 50 mndom healthy vohmteers. The researchers reported finding detects in brain fibers in a certain part of the brain in both the addicts and their siblings, but not present in the other volunteers. They believe this discovery coukl indicate a common thread in addictive behavior tmced to brain abnormalities. What the study is not able to answer is the question as to why some of the siblings became drug addicts and the others did not. Based on such research, it is possible there could be a comtmn neurological or cellular thread that could lead to addiction IdentifYing such factors could potentially help people in isolating and averting addictive behavior. But these factors are tmrc of an unknown than a known quantity at this tim.!. Certain familial, environmental and personal factors, however, have been found to he present in countless cases of drug addiction:

Familiallntlue nces

A child looks up to the parents andAler siblingi, and the example they set .nely plays a large role in the behavior and attitudes of that cbild. '~boy will o fren want to be like the filthe~ut it goes fwiher: The boy will ­to one degree or another - take on the identity and rnannerisrm of the father. A girl will take on the identity of the rrother. Or any combination can be present - the sister who looks up to the big brother, and so on. When one or rrore in the household arc drug-addicted or alcoholic, it can rub off on others in the family to a rmrked degree. 'They seek to emulate other members of the same family. This factor alone plays a large role in the story of addiction.

Environmental Factors

The family is itself an environment, but one's surroundings extend to the street outside, one's friends, neighborhood, club, gang, schoo~ etc. TI1ese play a large part in the addiction equation. Kids get offured drugs at a very young age. That age seem; to get younger and younger each year. Children can be offured pills or dope at 7 or 8 years old. lfthe family drinks and srrokes pot in front of the child, they are setting the stage fur drug use tor tbat child. At school or arrongst peers, whether or not a child or teenager does drug; can determine their social status, how "coo r• they appear, and what kinds of friends they get to hang out with. Drug use at a young age builds up tolerance and fuels a desire tor rrore potent substances tor the purpose of getting high.

Nowadays, the legal status of certain drugs is also a big influence. [n Colorado and Washington State, where marijuana bas been legalized, kids assurre, '1t's legal It must be OK." Police and drivers' education professionals in those states are pulling their hair out as they bave no roadside tests (unlike alcohol) to determine if someone is driving while high. The scourge of quasi-legal synthetic drugs - "Bath Salts" and synthetic cannabis l.br example - arc now a nationwide epidemic. Prescription drugs, such as those round in people's medicine cabinets, also offur ways tor youth to get high on "legaf' substances.

Drugs as Esca~

A person does not usually set out with the goal in mind of becoming a drug addict It is a roore gradual process. All too often the scenario goes a little something like this: A young person bas some personal problcrrn, fumiliaL troubles, relationship difficulties, or any number of stresses. They cannot study well; they're very withdrawn in social situations; they don't know what they want out oflire; or they could have experienced sorre sort of trauma - the death of a close fiiend or a loved one. Sheer boredom or having no goals in lire will also trigger drug use. As a "solution" they turn to what you could term "chemical escape." Drug; or alcohol .rnakc them rorget about their problerm. Alcoho~ pills and weed lead to cocaine, speed or opiates. The cycle of addiction takes a 1irm grip in the person's lite. These days, prescription pill abuse and heroin addiction reed off each other. A $50 per day pill babit can be replaced by a $15 per day heroin habit, as heroin is now rrrucb cheaper in Lmny locatiorn ­particularly along the Interstate 5 corridor where heroin from Mexico is channeled into Arrerican cities. Not everyone winds up addicted, but fur the ones that do, it can happen without them even realizing what is going on. One morning they awake, Look in the mirror and discover a drug addict staring back at them.

Combination of Causes

Drugs abuse is fueled by any of the above causes. Normally it is a combinatiofl of multiple factors. After a while, the drug abuse becomes the chief problem., and the personal problems that instigated the original drug use either Jade into the background or increasingly affect the person's life.

Drug education offers a way to intercept the influences that can Lead one to tum to drugs. Elelping

people to solve their problems a.ormulate goals also goes a long .n preventing drug abuse.

Holistic rehabilitation offers a way to address the multiple factors involved in drug addiction that have already taken hold.

{ 0 connnents }

What characteristics in kids make them likely to do drugs?

by Per Wickstrom

Research and patient experience have revealed certain characteristics that make kids more likely to do drugs.

These characteristics range from the psychological to the environmental They are essential in lUlderstanding what leads to drug use - and, ultimately, in preventing it.

Here we discuss several characteristics that often lead children to use drugs.

Low self-esteem and self-doubt

The decision to abstain from drugs requires a strong degree of self-confidence: the belief that drugs arc harmful, the confidence to say no, and the conviction to choose more productive behaviors. Children who are less sctt: assured often find it harder to resist drugs. They also tend not to have the same confidence in a drug- free lifu.

Because drugs arc also a way to escape fuelings of self-doubt and temporarily boost self: confidence, those with lower self-esteem often gravitate to drugs as a way to compensate fur the deficiency. Drugs become a compelling "therapy" fur low self'. esteem.

That is why instilling self.confidcnc.ISt be a priority among parents. It is .fthe greatest antidotes to drug

use later in lite.

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{ I comment}

What's the best way to stay sober and not relapse?

by Per Wickstrom

Sobriety shouldn't fuel like punishrrent or purgatory- it should be celebrated as the wonderful gift you've given yourseiE In finding the clarity to bccorre sober, you've given up old rears and negative ways of thinking. That is an accomplishrrent that should give you a great deal of pride and comfOrt that you are living[ ... ]

Read the full artie le ->

Facts About Marijuana

by Drug Rehabilitation

What is marijuana? Marijuana (grass, pot, weed) is the common narre lOr a crude drug made from the plant Canrrabis satiVd. 'lbe main mind-altering (psychoactive) ingredient in marijuana is THC (dclta-9-tetrahydrocannabinoO, but trme than 400 other chemicals also are in the plant. A marijuana ')oint" (cigdrcltc) is made from the dried particles ofthe plant. [ ... ]

Read the full artie 1e ->

How Does Marijuana Affect the Brain?

by Drug Rehabilitation

Pot, weed, grass, ganja and skunk, arc sorre ofthe common words used to descnbc the dried leaves drug known as marijuana. Marijuana is a cannabis plant that is "usually smoked or eaten to entice euphoria." (I). Throughout the years, there has been research on the negative and positive clfucts of marijuana on the human

body[ ... ]

Read the full artie le ->

What are the Affects of Marijuana

by Drug Rehabilitation

Ellcets on the Brain As Tl IC enters the bmin, it catiSes the user to fuel cuphoric--{)r high-- -by acting on the brain's reward system, which is made up of regions that govern the response to pleasurable things like sex and chocolate, as well as to most dmgs ofabtiSe. TIIC activates the reward system in the( ... ]

Read the full artie le ---> • • Cocaine in the Brain

by Drug Rehabilitation

"Cocaine delivers an intensity of pleasure-- and despair- beyond the botu1ds ofnonnal htunan experience." During the 1980s, Partnership tOr a Drug Free America began airing commercials that seem to either frighten or educate people about the use of illegal drugs. One of these commercials avowed, "No one ever says, 'I want to [ ... ]

Read the full artie le --->

What are the Affects of Cocaine?

by Drug Rehabilitation

Cocaine is a powerfully addictive stimulant drug. '!be powdered hydrochloride sah fOrm of cocaine can be snorted or dissolved in water and then injected. Crack is the street name given to the fOrm of cocaine that has been processed to make a rock crystal, which, when heated, produces vapors that arc smoked. '!be term "crack" [ ... ]

Read the fit!! article --->

How Does Cocaine Affect the Brain?

by Drug Rehabilitation

A highly addictive substance, Cocaine is usually seen as a powdered hydrochloride salt which is most commonly snorted, although it is also dissolved and injected. Crack is another fOrm of cocaine. 1bis is a crystalline limn of cocaine which has not been treated with acids to produce the fumiliar powdered fDnn Crack cocaine is heated [ ... ]

Read the full artie le --->

How to Tell if You're Kids are Using Drugs

by Drug Rehabilitation

·n1e first line of dcfunsc today to help chiklren combat the war on drugs arc their parents. Today's parents arc in the best position to sec drug LL~e in the family as well as to stop it. It is a hard process to overcome but there have been many fumilics who have dedicated themselves with[ ... ]

Read the full artie le -->

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