1. Of my six alleged accusers, all relevant activity with M, C, and Dadabhoy occurred in private circumstances outside the context of any event or policy, and were not governed by any policy. This is also true of O, as our encounter took place at a pub in unofficial circumstances after any event; and did not constitute a violation even of that event's policy (which was governed by the CFI Conduct Policy, which only prohibits unwanted advances, and I heeded any indication of what was unwanted). She has not accused me of anything anyway (officially or unofficially). Defense cannot truthfully be alleging any of these encounters violated a sexual harassment policy.

2. You can examine the evidence pertaining to what Amy Frank has insinuated. But of relevance to the present point, Amy Frank never filed a complaint against me for sexual harassment with the SSA. And still has not. And the defendants have not presented to the court any SSA-related sexual harassment policy I violated. Nor have they presented any complaint filed by Frank.

Per my Complaint, Pars. 51 and 52, the SSA formally investigated my behavior and did not find that I violated their sexual harassment policy, only a separate and distinct policy against fraternization, that only applied to members of their Speaker's Bureau, not other speakers at SSA events. I am, for example, no longer subject to that policy at SSA events; I am instead subject to the new SSA Conduct Policy, which is now worded differently, but my actual conduct with Frank would not have violated even their new policy, nor would any conduct she initially reported to the SSA.

Hence the email I received (which will be submitted to the court when required) from the Affiliate Program Manager of the SSA, sent 19 August of 2015, that rescinded my Speaker's Bureau status for violating only its fraternization policy, a decision I agreed with, concluded, "You are free, of course, to continue to work independently with students on events." This official correspondence, relating a considered decision of the board of directors, demonstrates I cannot have been deemed to have violated their sexual harassment policy, as such would have entailed my being asked not to work with SSA affiliates at all.

These essential facts were publicly stated by the SSA (in "SSA Will Update Sexual Harassment Policy," third paragraph; this being the conclusion of their investigation announced previously). Which reveals they only received from Frank a claim of violating the fraternization policy, and never any formal complaint from her that I violated their sexual harassment policy (her sudden public announcement of such a claim taking them by surprise). The Defendants have never reported this truthfully even after being asked to (e.g. Desist Letter to Zvan, page 3, demand (3)(b) and (g)).

3. That leaves the accusation of Lauren Lane. She published an official Skepticon announcement alleging I had violated the sexual harassment policy at Skepticon, and that I had been disinvited from speaking at Skepticon partly for that reason. Both claims are demonstrably false.

In legal correspondence both Lane and Skepticon, through counsel, admitted they did not mean I had violated their policy with multiple women, but only one woman: Lane (though neither she nor Skepticon has ever publicly corrected their implication otherwise). There, page 2, under "'Sexual Harassment' Statements Are True," second paragraph, they formally stated that my claim:

...that [Skepticon's announcement] accused Dr. Carrier of having sexually harassed "multiple women," and that he continued such behavior after he was told it was unwanted, is inaccurate. These allegations are neither contained nor suggested in the [announcement], which at most mentions "someone involved in Skepticon."

They therefore admit they never even intended to claim that I had continued any behavior I was told was unwanted, or that I had harassed multiple women.

They go on in the next paragraph to admit the only person accusing me of violating the harassment policy at Skepticon is Lauren Lane herself, admitting that the "someone involved in Skepticon" meant her, and claiming that:

Ms. Lane will testify about the many occasions on which Dr. Carrier made unwanted sexual advances towards her, including but not limited to touching her knees and hugging her without permission; leering at her; asking her inappropriate questions; and making harassing and sexually-charged comments about and towards her.

This is, of course, all false. Lane pursued me (not the other way around), as both eyewitness affidavits and email correspondence demonstrates (shown in my survey of evidence pertaining to Lane). Those documents show I never touched Lane outside of our consensual relationships, and all our sexual banter was likewise demonstrably consensual, and often initiated by her (as again, witnesses and correspondence demonstrate). No violations of policy at Skepticon occurred (unless you deem a conference leader initiating sexual banter and activity with a contracted speaker to be harassment, in which case, all evidence would prove Lane is the violator).

The only action I took with Lane that was at all inappropriate was a very insensitive message I sent her in an attempt to renew our relationship after I had broken it off (as discussed in my account regarding Lane). But that did not occur at Skepticon. It was therefore not subject to any policy there. I also apologized for the gaffe, and never renewed any such banter with or interest in her, nor initiated any kind of physical contact, completely respecting all her stated wishes.

That same letter from their lawyer concludes with the claim that:

Evidence in the case will also consist of statements from third parties involved with Skepticon, including Skepticon speakers and attendees, who have also been sexually harassed by Mr. Carrier.

No such evidence has been presented. As one can ascertain by this point, there is none. Of course, they insinuate here again that I harassed "multiple women" at Skepticon, after having just admitted they intended to claim no such thing. But they've presented no evidence I harassed anyone, anywhere. Much less anyone connected with Skepticon; even less at Skepticon. Two years of litigation. No evidence.

To the contrary, as I show in my account regarding Lane, this assertion has to be impossible, as a complete collection of the internal correspondence mentioning me, among Skepticon's staff and board of directors, including Lane, up to the date they published their statement, has now been provided by the defense upon court-ordered discovery. It lacks any mention of anyone having any idea I had ever been accused of anything by anyone—so conspicuously, in fact, as to establish no one had accused me of anything. Which means this claim that there were any at all is now demonstrably false. There is no record in that correspondence even of Lauren Lane issuing a complaint against me, nor of any official discussion of or knowledge of such a complaint (much less investigation of it). Which means their claim that she did make a complaint, and I was disinvited for that reason, is also demonstrably false.

That collection of correspondence not only demonstrates all these claims are false, but that Lane and Skepticon knew they were false when they made them. And one should not trust anyone proven to have been dishonest in the matter.