STATE OF WISCONSIN                                      CIRCUIT COURT                                      DANE COUNTY


Case 2018CV003122



v.                                                                                                                                                                                                                      Case No. 18CV3122







Counterclaim Plaintiff James Fetzer hereby alleges a Counterclaim for damages against

Counterclaim Defendant Leonard Pozner and hereby alleges as follows:



1. Counterclaim Plaintiff James Fetzer is a resident of the State of Wisconsin, County of Dane and is a Defendant herein.

2. Counterclaim Defendant Leonard Pozner is a resident of the state of Florida and is a Plaintiff herein.


3. Substantial and not isolated acts giving rise to the cause of action for ABUSE OF PROCESS asserted herein, have occurred in the State of Wisconsin and within this venue.

4, This Court has jurisdiction over both the parties and the subject matter because on information and belief a substantial number of events giving rise to this Counterclaim for Abuse of Process occurred in Dane County. On information and belief and with knowledge of the falsity
of the allegations in his Complaint, Counterclaim Defendant Leonard Pozner has sued Defendant
for having described the death certificate given to Kelley Watt as a “fabrication,” when Plaintiff is
substituting a second death certificate, attached to his Complaint, as though they were the same in
every material respect, when they are obviously different. Just as an unsigned check could be said
to be worthless in comparison to the same check signed, the death certificate Defendant has said
to be a “fabrication” is as different from the copy of the death certificate attached to his Complaint
as a check that is unsigned is to a check that is signed. Defendant has never seen, much less
commented upon, the document attached to the Complaint and therefore cannot possibly be held
responsible for defamation for having characterized it, which they had never before seen, as a
“fabrication”’—though Defendant has observed that, if the death certificate certified by the State
of Connecticut is the same “in every material respect” as the certificate Plaintiff gave to Kelley

Watt, then the State of Connecticut has certified a fabrication, which is itself a crime.


5. On December 14, 2012, in Newtown, Connecticut, agents of the federal, state and
local municipal authorities conspired to stage an elaborate hoax. Counterclaim Defendant Leonard
Pozner was a co-conspirator in the effort to stage the Sandy Hook Elementary School (hereinafter
“SHES”) mass murder by an alleged psychologically disturbed young man by the name of Adam
Lanza, who allegedly stole several guns from his mother, then shot his mother in her bed and then
drove the family car to SHES, where he forcibly entered the school by shooting out the front glass
door, and then entered SHES and murdered 20 students and six administrators and teachers.
Counterclaim Defendant Leonard Pozner maintains that his son, “Noah Pozner,” was killed in this

shooting incident.
Case 2018CV003122 Document 53 Filed 03-21-2019 Page 3 of 11

6. Upon closer examination, investigation, and study by concerned citizens, including
but not limited to the Counterclaim Plaintiff, it was discovered that the alleged SHES mass murder
never actually occurred as it was presented by the mainstream media. This discovery was caused
by the examination of a large body of circumstantial evidence, including but not limited to the


a) Photographs demonstrate that, although a large hole was blown in the plate-glass window
of SHES, it does not appear to have been done by any of the weapons purportedly in the
possession of the alleged shooter, nor did anyone actually enter SHES through that hole,
although at least 10 Connecticut State Police have signed sworn affidavits of having

entered by means of it.

b) Media helicopters taking aerial footage of the event on December 14, 2012, took pictures
of the triage tarps on the ground outside of SHES, but despite that allegations that 26 people
were struck by bullets and killed, not a single human body was photographed being placed

on any of the triage tarps.

c) Federal Emergency Management Agency (FEMA) appears to have managed the event,
including placing Porta-a-Potties and signage at the scene, and directing the participants as

to where they should report to participate in the event.
Case 2018CV003122 Document 53 Filed 03-21-2019 Page 4 of 11





Pizza and bottled water were supplied at the scene, so that the participants could snack and
drink, while awaiting their turn to be filmed and photographed at the alleged emergency

event, much like at a Hollywood location film shoot.

News footage of participant and co-conspirator Robby Parker is seen at first laughing and
smiling, before hyperventilating to “get into character” of the distraught parent who
suffered the loss of a child, before Mr. Parker gives a speech regarding his sorrow at the

alleged loss of his daughter.

Photographs of the scene of the alleged mass murder, reveal at least two photographs were
taken, one showing parents present at the scene, while a uniformed policewoman is

repositioning the schoolchildren being led away from SHES to get “a better shot.”

Investigation later revealed that by December 14, 2012, SHES had actually been closed
since 2008, and the inactive school buildings were being used to “stage” the alleged SHES

mass murder.

H. Wayne Carver II, M.D., then-chief state medical examiner, stated that the parents of the
deceased children were identified by photographs, as opposed to direct observation and
identification of the bodies of the children, which appears to have been done because the
children only existed in the form of photographs, as subsequent research has shown, some
of which appears in “Sandy Hook Truth: A Sandy Hook Collected Memorandum for the

President of the United States” (2018), edited by Robert David Steele and available online.
Case 2018CV003122 Document 53 Filed 03-21-2019 Page 5 of 11

i) Other and further circumstantial evidence of this staged event exists and will be developed
in discovery, including “The FEMA Manual for Sandy Hook,” published as Appendix A
to Nobody Died At Sandy Hook: It was a FEMA Drill to Promote Gun Control, which is
confirmed by the presence of the sign, refreshments and restrooms, and participants
wearing name-tags on lanyards, which are standard practices for conducting FEMA drills,
and by the absence of a surge of EMTs into the building, the lack of a string of ambulances
to rush the bodies off to hospitals where they could be declared to be dead or alive, the
failure to call a Med-Evac chopper, which is normally done even for drills, and a host of

other indications, many of which appear in the publications cited above and elsewhere.

7. This elaborate staged mass-media event was “produced” to advance an agenda to

deprive U.S. citizens of their rights pursuant to the Second Amendment of the U.S. Constitution.

8. As concerned citizens continued to investigate the alleged SHES mass murder,
including the Counterclaim Plaintiff, numerous persons coordinated their investigations to reveal
and uncover the “Sandy Hook Hoax,” Counterclaim Defendant Leonard Pozner contacted Kelley

Watt in 2015, followed by numerous telephone conversations and email exchanges.

9. During the course of conversations and correspondence between Leonard Pozner
and Kelley Watt, Leonard Pozner provided her with a “death certificate” alleged to be that of his
son “Noah Pozner,” which death certificate has, on its face, several material differences and
inconsistencies from the alleged death certificate, which Defendant Fetzer has introduced into the

records of this case.
Case 2018CV003122 Document 53 Filed 03-21-2019 Page 6 of 11

10… The death certificate that Plaintiff Pozner attached to his Complaint differs
substantially from the death certificate Plaintiff previously sent to Kelley Watt, insofar as, unlike
that version, it has a (handwritten) file number, does not have a bottom two-thirds darker in texture
than the top one-third, and the box for decedent’s Social Security number is blank, while the same
box in the copy sent to Kelley Watt was blacked out in an apparent effort to conceal that decedent
does not have (or was never assigned) a Social Security number. Additionally, the document
attached to Plaintiff’s Complaint shows several changes attributed to “father Leonard Pozner,”
even though the name of the father on the certificate proper is “Lenny Pozner.” They are not the


11. After having investigated the alleged SHES mass murder of December 14, 2012,
Defendants James Fetzer and Mike Palecek, published in 2015 a book entitled Nobody Died At
Sandy Hook: It was a FEMA Drill to Promote Gun Control (with 13 contributors, including six
current or retired Ph.D. professors), establishing that the school had been closed by 2008, that there
were no students there, and that it was a FEMA drill to promote gun control in which nobody died.
A second edition of the book was published in 2016 by James Fetzer, Mike Palecek and Wrongs

Without Wremedies, LLC.

12. ‘Plaintiff Leonard Pozner claims to have been defamed by the publication of the
books Nobody Died At Sandy Hook: It was a FEMA Drill to Promote Gun Control, specifically
for Defendant Fetzer having described the death certificate given to Kelley Watt as a “fabrication,”
and filed this lawsuit for defamation, when in truth and in fact, Leonard Pozner knows that the

SHES shooting was an elaborate staged event, wherein no one was killed on December 14, 2012.
Case 2018CV003122 Document 53 Filed 03-21-2019 Page 7 of 11


13. Counterclaim Plaintiff incorporates by this reference all allegations contained
within this Counterclaim into this cause of action for Abuse of Process as though said allegations

have been set out fully and at length herein, and further alleges as follows:

14. On or about November 27, 2018, Leonard Pozner initiated litigation in this Court
against James Fetzer, Mike Palecek and Wrongs Without Wremedies, LLC, with alleged causes
of action for defamation and conspiracy against the Defendants. Plaintiff Leonard Pozner
intentionally filed and served said lawsuit for defamation and conspiracy on said Defendants,
despite his knowledge that his son “Noah Pozner” was not killed in the SHES shooting on

December 14, 2012.

15. | Leonard Pozner’s acts, by filing and serving a lawsuit which he knows contains
false allegations regarding the alleged killing of his son “Noah Pozner” and the alleged issuance
of a death certificate, was performed and accomplished for the improper purpose of sustaining the
false belief by citizens of the State of Wisconsin and of the U.S. that a child massacre had been
perpetrated by a mentally disturbed individual on December 14, 2012, who allegedly took

possession of his mother’s legally obtained firearms and then went on a killing spree at SHES.

16. The improper purpose of the filing and service of Leonard Pozner’s lawsuit against
the Defendants arises from the continuing intent of Leonard Pozner and his co-conspirators in the
federal, state and local municipal governments (aided and abetted by the mainstream media) to

continue to mislead and deceive the U.S. population, to deprive its citizens of their rights pursuant
Case 2018CV003122 Document 53 Filed 03-21-2019 Page 8 of 11

to the Second Amendment of the U.S. Constitution, including the use of social media giants
(Google, YouTube, Facebook and Twitter) to suppress exposure of the facts of the matter to the

American people and subvert the First Amendment.



17. Plaintiff has perpetrated a fraud upon this Court and the public by presenting
himself as the grieving father of a child whom, he claims, died at Sandy Hook, when Plaintiff has
acted in full knowledge this was a FEMA mass casualty exercise involving children in which
nobody—no adult and no child—was shot and killed. It has been reported that the fake families of
the alleged 26 victims have received from $27 million to $130 million in donations from
sympathetic but gullible Americans, which divided equally between the 26 fake families works
out at over $1 million to $5 million apiece for the pretense of having lost a child at Sandy Hook.
Plaintiff and others who participated in this fraud upon the public are therefore also guilty of theft

by deception, which is a crime under Wis. Stat. § 943.20.



18. Counterclaim Plaintiff reaffirm that Counterclaim Defendant appears to be
perpetrating a fraud upon the Court. See Schultz v. Sykes and Jones v. Courtyard Apartments, LLP.
Aoude v. Mobil Oil Corp., 892 F.2d 1115 (1st Cir. 1989), states: “A ‘fraud on the court’ occurs

where it can be demonstrated, clearly and convincingly, that a party has sentiently set in motion

some unconscionable scheme calculated to interfere with the judicial system’s ability impartially
to adjudicate a matter by improperly influencing the trier or unfairly hampering the presentation
of the opposing party’s claim or defense.” See, e.g., Alexander v. Robertson, 882 F.2d 421, 424
(9th Cir.1989); Pfizer, Inc. v. International Rectifier Corp., 538 F.2d 180, 195 (8th Cir.1976);
England v. Doyle, 281 F.2d 304, 309 (9th Cir.1960); United Business Communications, Inc. v.
Racal-Milgo, Inc., 591 F.Supp. 1172, 1186-87 (D.Kan.1984); United States v. ITT Corp., 349

F.Supp. 22, 29 (D.Conn.1972), aff’d mem., 410 U.S. 919, 93 S.Ct. 1363, 35 L.Ed.2d 582 (1973).”

19. On the basis of multiple lines of research, including national searches using two
widely relied upon search engines, which have failed to locate any party by the name of “Leonard
Pozner” in the U.S., Counterclaim Plaintiff has concluded Counterclaim Defendant has filed this
case under a false name and that “Lenny Pozner” appears to be as much of a fiction as his alleged
son “Noah Pozner,” who appears to be a fiction made up out of photographs of older children when
they were young. Specifically, subject to further investigation, Counterclaim Plaintiff believes
“Noah Pozner” is a fiction made up out of photographs of his “older step-brother” Michael Vabner,
and that, to the best of Counterclaim Plaintiff’ s knowledge and belief, “Leonard Pozner” is actually
Reuben Vabner, the father of Michael Vabner, which explains why there are so many photographs
of “Lenny and Noah” together, where Counterclaim Plaintiff is engaged in ongoing research to
confirm or disconfirm their findings about the true identity of the Counterclaim Defendant in this

case, who does not appear to be a person with the real name of “Leonard Pozner.”

20. Further proof derives from evidence that the U.S. passport for “Noah Samuel
Pozner” appears to be another fabrication, where the photograph used to create the document does

not conform to State Department requirements with regard to type of photograph (snapshot rather

than formal), with the subject looking to the side (rather than fully-facing the camera). In addition,
the image is of the wrong size and violates the placement requirements imposed by the government
(which is obvious from inspection). Counterclaim Plaintiff believes that faking a U.S. passport
represents a far more serious (federal) offense than faking a (state) death certificate. This discovery
reinforces Counterclaim Plaintiff’s belief that Counterclaim Defendant has committed perpetrated

a fraud upon the Court.


Counterclaim Plaintiff reaffirms his belief that Counterclaim Defendant Complaint has
been filed for the illicit purpose of intimidation to prevent public knowledge of the truth concerning
the events at SHES, and not for genuine legal relief for actionable harm done and is therefore an
actionable abuse of process. Counterclaim Plaintiff requests the Court reserve for Counterclaim
Plaintiff the options to Counterclaim for Abuse OF Process, for fraud and theft by deception, and
for perpetrating a fraud upon this Court and/or to seek relief under Section 802.05 and/or under

Section 895.044 of Wisconsin Statutes.


         Counterclaim Plaintiff prays as follows:

A) For declaratory relief, determining that the death certificate circulated by Leonard Pozner

in 2015 is not the same as the death certificate Plaintiff attached to his Complaint and, as

such, Defendant cannot be guilty of defamation for a document they have in fact never addressed.

B) For damages and attorney fees incurred by Counterclaim Plaintiff made necessary by

the defense of the within action.

C) For costs of suit herein.

D) For such other and further relief as this Court deems just and proper.


Dated: March 21, 2019


James Fetzer, pro se