Jamin Darcy

Investigations in Ritual Abuse

1614 Lake Lillian Rd
Fountain, FL 32438
T:8502574595
E:jamin.darcy@gmail.com

IN THE SIXTH JUDICIAL DISTRICT COURT

IN AND FOR SANPETE COUNTY, STATE OF UTAH

JAMIN DARCY, Motion for Hearing to Lift and

Expunge Ex Parte Temporary
Petitioner, Stalking Injunction, and Additional
Relief

v.

JOSEPH WOOD BENNION Case No.: 240600056

and
LEE PATRICIA BENNION Judge: Marvin Bagley

Respondents.

Respondent Jamin Darcy requests that the Temporary Civil Stalking Injunction issued via Ex

Parte Order in Case no. 240600056 be lifted and the petition be dismissed.

INTRODUCTION

1. Petitioner Jamin Darcy responds to the Verified Petition for Stalking Injuction with

Motion to Dismiss the Injunction.

2. Petitioner is an independent investigative researcher and journalist covering the

David Lee Hamblin criminal case and its related matters.

3. Petitioner runs Investigations in Ritual Abuse, a subscription based Substack with

subscribers across the United States, including paying subscribers.

4. Investigations in Ritual Abuse is a business, operating legally within the United

States for the purposes of investigative research and journalism where the Hamblin

case and its related matters are concerned.

1
5. Respondents live in Spring City, and operate two businesses, Horseshoe

Mountain Pottery and Mom’s Stuff.

FACTS AND ALLEGATIONS IN SUPPORT OF MOTION

6. Petitioner has never entered Horseshoe Mountain Pottery, nor has he ever

trespassed on the residential property of the Respondents.

7. Petitioner has explicitly warned his subscribers and others to abstain from directly

or personally confronting the Respondents, as the Respondents’ own Petition notes

in Paragraph 40, which explicitly states that the Petitioner “encourag[ed] his acolytes

to never “directly contact or harass any alleged member of the [Church of Satan].”

8. In fact, the Respondents’ own Petition rebuts its own contentions on multiple

occasions:

a) In Paragraph 52, the Respondents directly quote Petitioner: “I am currently

committed to working through the legal process in the hopes that this

process will yield a righteous outcome for David Lee Hamblin’s deeds, adn

for the deeds of his accomplices.” This flies in the face of the Respondents’

attempt to represent Petitioner as one who is resorting to illegal or

extralegal means of obtaining his objective.

b) In Paragraph 53, Respondents quote Petitioner’s contention that ensuring

rapists and child rapists do not continue raping children is righteousness,

either through the law or outside of it when the institutions of the law are

corrupt, and this is hardly a controversial position in our jurisprudence,

given that the credibility of those institutions rests in part on the strict

adherence of their officers to the law itself.

9. The Respondents attempt to characterize such statements as beyond the pale,

when they are in fact consistent with the heritage of our republic, given the reality

2
that our nation was founded in part in response to tyrannical laws perceived as

violating the rights of American colonists.

10. Laws have limits, and those who apply or enforce the law are accordingly bound

within those limits by individual liberty, the breach of which is well-established as the

grounds for rebellion against tyrannical authority or the illegitimate and abusive

application of law and power.

11. Petitioner has never phoned, texted, emailed, or otherwise contacted the

Respondents.

12. Petitioner has never followed, monitored, observed, photographed, surveilled,

threatened, or communicated to the Respondents, nor has he interfered with their

property directy, indirectly, or through a third party by any action, method, device, or

means.

13. Petitioner has never approached or confronted either of the Respondents, and

he has never appeared at their workplace, contacted their employers or coworkers,

nor has he appeared at their residence, nor has he entered property owned, leased,

or occupieed by the Respondents.

14. Petitioner has never sent material by any means to the individual for the purpose

of obtaining or disseminating information about or communicating with the individual

to a member of the individual’s family or household, employer, coworker, friend, or

associate of the individual.

15. Petitioner has never placed an object on or delivered an object to property

owned, leased, or occupied by the Respondents, or to the Respondents’ place of

employment with the intent that the object be delivered to the Respondents.

16. Petitioner never used a computer, the Internet, text messaging or any other

electronic means to commit an act that would fall within the course of conduct of the

the statute as defined by 76-5-106.5.

17. Petitioner did text Respondent’s adult daughter Zina Bennion to inquire about

the Hamblin allegations, in order to ascertain whether or not she would corroborate

the allegations made by the Hamblin sisters or deny those allegations.

3
18. Zina Bennion did not respond to the text, and Petitioner did not attempt to

contact her at any point afterwards.

19. In fact, there was no confirmation to indicate the number Petitioner texted was in

fact Zina Bennion’s number.

20. Writing about criminal allegations against the Respondents does not rise to the

level of stalking under the statute.

21. In fact, writing about the criminal allegations against the Respondents is part of

the legitimate businss purpose of Investigations in Ritual Abuse, and therefore the

Petitioner did not violate the statute, as clearly stated by 76-5-106.5(6)(a)(ii).

22. Reaching out to a potential victim of the Respondents, as Petitioner did when he

attempted to text Zina Bennion, does not rise to the level of violating the statute

either.

23. If the Respondents and their counse Caleb Proulx, who is also the boyfriend of

their daughter Zina Bennion, had bothered to read the statute and familiarize

themselves with its plain language, they would have reallized that the Petitioner’s

actions do not fit within the stalking statute.

24. Caleb Proulx did attempt to contact various individuals from the Petitioner’s

family and those individuals immediately informed the Petitioner of his efforts.

25. Those individuals declined to aid Caleb Proulx and the Respondents in their

quest to quash Investigations in Ritual Abuse’s coverage of the Hamblin case and

their alleged roles in the Church of Satan, the group they purportedly belonged to

with David Lee Hamblin and others.

BACKGROUND OF ALLEGATIONS

26. Respondents Joseph Wood Bennion and Lee Patricia Udall Bennion are

allegedly accomplices of David Lee Bennion in “The Group” or “The Church of Satan”

as described by Rachel, Eliza, and Katherine Hamblin in their Victims Statements

4
 from the 2012 to 2014 criminal investigation conducted by the Provo Police

Department.

27. Those Victims Statements and other materials were passed on to the

Department of Homeland Security at the conclusion of the Hamblin criminal case in

2014, when the Utah County Attorney’s Office moved to dismiss the charges without

prejudice due to claimed difficulties in obtaining and turning over discovery items to

the defense.

28. David Lee Hamblin was recorded by the Provo Police Department apologizing to

his daughter for raping her before his arrest.

29. The Victims Statements refer to the Petitioners more that 130 times over the first

four Victims Statements, and there are four other Victims Statements, making eight

in total.

30. Petitioners are, after David Lee Hamblin and his ex-wife Roselle Stevenson, the

second most frequently mentioned alleged perpetrators in the Victims Statements.

31. According to the Victims Statements, Joe Bennion’s name within the Church of

Satan is Solomon.1

32. The Church of Satan is said to be comprised of “different groups who varied in

some practices,” but who “generally followed the High Councils [of the Church of

Satan] or at least had a common desire for secrecy and protection for Satanic

worship.”2

33. Members of the Church of Satan publicly belong to the Church of Jesus Christ of

Latter Day Saints, and worship Lucifer, who they believe to be the rightful heir of

God’s throne.3

34. The membership commonly inverts LDS ordinances and temple rites in order to

worship and glorify Lucifer, and they have evolved a complex methodology of

conditioning their children and members that involves ritualized physical, sexual, and

mental abuse.

1
Victim’s Statement #2, pg. 44; Victim’s Statement #1, pg. 41.
2
Victim’s Statement #2, pg. 1.
3
Victim’s Statement #1, pg. 1.

5
 35. Petitioners are explicitly named as members of the Church of Satan by Rachel,

Eliza, and Katie Hamblin in their Victims Statements.

36. Petitioners are explicitly accused of criminal activity including child rape, sodomy

of a child, battery, and murder. These activities spanned the late Eighties and the

Nineties before David Lee Hamblin and his wife Roselle Stevenson began their

divorce proceedings in 1999.

37. The earliest instance of abuse involving Petitioner Joseph Wood Bennion

recounted in the Hamblin Victims Statements occurs on page 23 of Rachel

Hamblin’s Victim Statement #1, in which she recounted being gagged and

threatened with a knife in a barn on the Hamblin property.4

38. Rachel Hamblin alleged that Joe Bennion was “The Punisher” for the Spring City

Church of Satan Council founded by her father David Lee Hamblin, and in this

capacity he punished and murdered those members who violated the group’s rules.5

39. During this instance of abuse, Joe Bennion forced Rachel to perform oral sex on

him and swallow his semen.6

40. Rachel Hamblin was between seven and nine years of age during the alleged

abuse.

41. During a 1996 instance of abuse, Joe Bennion, along with other members of the

Church of Satan, as well as members of James Dee Harmston’s True and Living

Church of Jesus Christ of Saints of the Last Days (TLC), obtained entry after-hours

to the Manti Temple.7

42. The purpose of accessing the Manti Temple was to conduct marriage sealings to

underaged girls in the Church of Satan and the polygamist TLC group, as well as

Initatory ceremonies and baptisms.8

4
Victim’s Statement #1, pp. 22-23.
5
Victim’s Statement #1, pg. 22; pg. 33; pg. 48;
6
Victim’s Statement #1, pg. 22.
7
Victim’s Statement #2, pp. 43-44.
8
Ibid.

6
 43. During one of the sealings, Respondent Joseph Wood Bennion allegedly was

sealed to one of the underage girls, whose name is redacted in the Victim’s

Statement.9

44. At the conclusion of the sealing ordinance, Joseph Wood Bennion allegedly

raped the girl he was sealed to as she was held down on the altar by Lee Bennion.10

45. Rachel Lee Hamblin was then raped on top of the same altar by unidentified

adults.

46. There are dozens of other instances of alleged abuse against the Respondents,

which Petitioner does not include in this Motion for the purposes of brevity. These

instances are compiled in the Victims Statements, and the Petitioner’s Index of those

Victims Statements, which are attached as Exhibits A-E.

47. Additionally, not a single child of those adults named in the Hamblin Victims

Statement has stepped forward to deny the allegations against their parents.

48. This includes the three daughters of the Respondents, Louisa, Zina, and Adah

Lee Bennion.

49. Despite the fact that the Provo Police Department recorded David Lee Hamblin

apologizing to his daughter for raping her, the criminal case against Hamblin was

dismissed in 2014 due to the professed inability of prosecutors to procure discovery

documents and turn those documents over to the defense.11

50. Hamblin was found by clear and convincing evidence to have sexually abused

his two eldest daughters during his custody trial.12

51. Hamblin also admitted to forcing his minor daughters to ingest peyote during

Native American religious ceremonies.13

52. The sufficiency of the allegations and the evidence against David Lee Hamblin

and his alleged accomplices was never put before a criminal jury.

9
Ibid.
10
Ibid.
11
Provo Police Department Police Report 2012000485, pp. 22-24, attached as Exhibit F.
12
Hamblin v. Hamblin, Case No. 994400557 DA, Findings of Fact, Conclusions of Law, and Order
Regarding Custody, Parent-Time, and Related Matters, October 24, 2003, pp. 11-14, Paragraphs 49-
52
13
Hamblin at 6, Paragraphs 16-17.

7
 53. In the years that followed, the Department of Homeland Security and the Utah

County Sheriffs Office continued the investigation into the Church of Satan and

related groups.

54. Two victims, Emily Sheets and Tobias Schroeder, brought allegations and David

Lee Hamblin which are the subject of the current criminal cases against Hamblin in

American Fork and Manti.

55. Schroeder’s father sought recommendations for a clinical psychologist to treat

his son after the son was abused by an older boy.

56. Respondent Joseph Wood Bennion recommended David Lee Hamblin to Tobias

Schroeder’s father, and Tobias was allegedly molested by David Lee Hamblin during

therapy sessions.

57. David Lee Hamblin lost his license to practice psychology after admitting to

engaging in sexual contact with his patients, and attempting to persuade his patients

that the sexual contact was part of their therapy.14

58. Two adult female patients who were sexually abused by David Lee Hamblin

testified against him at his custody hearing.15

59. Respondent Joseph Wood Bennion appears in a documentary, Chasing a Good

Day to Die, which was produced by Terri Holland and Paul Larson, the latter of

whom is named as a member of the Church of Satan and a child rapist.

60. At 16 minutes into the film, Respondent Joseph Wood Bennion says that “Every

time I heard the word shame or guilt spoken, I began to get really sick.”16

61. The ceremonies in Chasing a Good Day to Die utilized peyote, a Schedule I

substance under the Controlled Substances Act, as well as the Utah Controlled

Substance Act.

62. Respondent Joseph Wood Bennion illegally possessed and consumed a

controlled substance during sweat lodge ceremonies, and he appeared in the

documentary discussing his experiences.

14
Hamblin at 9, Paragraphs 38-39, cf. Stipulation and Order, DOPL, October 20, 2000.
15
Hamblin at 10, Paragraph 40.
16
Chasing a Good Day to Die, available at: https://youtu.be/tSMmu_DjKxA?si=UIhH-
J3Vd2TYrZ_M&t=962

8
 63. The Hamblin Victims Statements place Respondents Joseph Wood Bennion and

Lee Bennion in peyote ceremonies with David Lee Hamblin and James Warren

Flaming Eagle Mooney, and the Hamblin sisters allege that the Respondents were

present during ceremonies where they were forced to ingest peyote and submit to

sexual abuse.

64. Katie Hamblin described the peyote ceremonies in the Hamblin residence in

Provo during 1998-1999: “This was a common occurrence—but not just with James

who raped me upwards of 15 times that school year, but with Joe Bennion and

many other friends of David's. Ann Gregerson raped me during these times, as did

Linda Mooney, Lynn Witesides and others. 1 was brought into meetings like this very

often—sometimes daily but at least 2-3x/week while 1 lived in Provo. 1 didn't have

to go to all of them, but they made me go to many. We learned about STDs in school

and it was this time of my life 1 was most terrified of contracting an STD, partly

because Rosie wasn't monitoring me as much as she had when 1 lived with her.”17

65. These allegations and Bennion’s own admission of participation in these

ceremonies constitute sufficient grounds for church discipline up to and including

disfellowship and excommunication, and such behavior is inconsistent with good

standing in the Church of Jesus Christ of Latter Day Saints.18 19 20

66. In order to obtain a temple recommends, Respondents would have lied about

their drug use and their affiliating with an apostate religious group.

67. This would be consistent with the alleged behavior of Respondents as outlined

by the Hamblin sisters, who claimed that members of the Church of Satan publicly

maintained membership in the Church of Jesus Christ of Latter Day Saints while

secretly maintaining membership in the Church of Satan, and lying about their

adherence to Church doctrine in order to maintain membership in good standing.

68. Respondent’s own admission of illicit drug use, and his participation in

ceremonies with a Native American Church led by an excommunicated Latter Day

17
Victim Statement 3, Experience 107, pg. 131.
18
Gordon B. Hinckley, “The Scourge of Illicit Drugs,” Ensign, Nov 1989, 48.
19
Boyd K. Packer, “Revelation in a Changing World,” Ensign, Nov 1989, 14.
20
Russell M. Nelson, “Addiction or Freedom,” New Era, September 1989, 4.

9
 Saint named James Mooney, who had re-styled himself as a Native American

Medicine Man, were the basis of Investigations in Ritual Abuse’s reporting.

69. No stalking was necessary to obtain this information, because Respondent

Joseph Wood Bennion voluntarily appeared in a documentary discussing his use of

peyote and his involvement with the Oklevueha Native American Church founded by

Mooney, who retained David Lee Hamblin as his spokesperson and protege.

70. The documentary in question is posted on YouTube, and any member of the

public can watch it.

71. The fact that Respondent’s appearance in the video is corroborative of the

allegations made by the Hamblin sisters with regards to the use of peyote in

ceremonies run by James Mooney is the reason Respondent has never filed a

defamation lawsuit against the Petitioner or the Hamblin sisters.

72. During another videotaped documentary interview, Respondent Joseph Wood

Bennion details his childhood arrest for arson, and says that playing with fire is fun.21

73. He also refers to his kiln as a “kill,” which is exactly how the Hamblin sisters

allege he pronounced the word kiln in their Victims Statements.22

74. Again, no illegal stalking was necessary, because Respondent Joseph Wood

Bennion voluntarily disclosed this and other information across several

documentaries.

75. Respondents also divulged numerous other corroborative facts on their social

media accounts, which were public, thereby removing any necessity to engage in

any sort of subterfuge or deceit in order to obtain information through covert means.

IRRELEVANT OR MISLEADING ALLEGATIONS BY RESPONDENTS

76. Respondents, by and through their counsel, Caleb Proulx, included facts which

have no bearing whatsoever on the central allegation of stalking.

21
The Potter’s Meal, Revisited, available at: https://youtu.be/l3Rr0tOyAeo?si=89B-
dRPbp6a40lBV&t=60
22
The Potter’s Meal, Revisited, availabe at: https://youtu.be/l3Rr0tOyAeo?si=A-CnfioknjD_vjRU&t=47

10
77. The obvious motive for doing so was to obtain a stalking injunction by

misleading the court as to Petitioner’s conduct, in order to impede Petitioner’s ability

to write about the Respondent’s on Investigations in Ritual Abuse, or to speak about

the Respondent’s alleged criminal acts during podcast appearances or in private

conversation.

78. Examples of this are found in Exhibit V, which is recounted in Paragraph 49,

where Petitioner’s remarks about possibly moving to Utah and obtaining a piece of

land with clear lines of sight for his rifles is misconstrued, because nowhere in the

quote does Petitioner reference the Respondents, or talk about going to the

Respondents’ property to confront them or threaten them.

79. In Paragraph 50, Respondents use bold face type to highlight Petitioner’s

comment that he is “armed to the teeth and willing to kill and die for this.” They do

not highlight the preceding sentence, which clearly contextualizes the remark as

pertaining to the possiblity that Church of Satan members or their allies might come

after the Petitioner in order to harm him. This takes the highlighted portion from a

threat to a pledge of self-defense, which is legal and reasonable.

80. The more obvious motive for the Respondents’ efforts is to disarm Petitioner, as

the Temporary Civil Stalking Injunction contains the following words within it: “It may

be a federal crime for you to have possess, transport, ship, or receive any firearm or

ammunition, including hunting weapons, while this civil stalking injunction is in

effect.”

81. The obvious implication is clear: the ex parte order, which Petitioner had no

opportunity to respond to at the time, is a means of affording Respondents the

opportunity to potentially make further spurious filings at the federal level regarding

Petitioner’s well-documented ownership and use of firearms.

82. This is despite the fact that the Respondents can show no threats involving

firearms or any other weapons, or any other illegal threats by Petitioner directed at

them personally.

11
83. In Paragraph 53, Respondents again highlight the portions of a quote that they

believe will buttress their contention that Petitioner has somehow threatened them,

while leaving the relevant portion that undermines their claim un-highlighted: “I am

currently committed to working through the legal process in the hopes that this

process will yield a righteous outcome for David Lee Hamblin’s deeds, and for the

deeds of his accomplices...”

84. Additionally, by the Respondent’s own admission in Paragraph 40 of their

petition, Petitioner “encourag[ed] his acolytes to never “directly contact or harass

any alleged member of the [Church of Satan].”

85. Respondents resort to changing the font in their petition, so that they can

highlight the portions that they selectively excerpt to paint the Petitioner in negative

light, while making the portions that rebut their misrepresentations harder to read.

86. Respondents include multiple references to Petitioner’s work with private clients,

even though such facts have nothing to do with the central allegation that Petitioner

engaged in illegal stalking.

87. In Paragraph 74, Respondents allege that Andi Pitcher Davis owns the former

Hamblin residence in Spring City at 95 E 400 S, which is a lie. Davis’s estranged

husband Mark owns the property, and she is not in any position to tell the Petitioner

or anyone else who they can and cannot contact on that property because she is not

the owner, a tenant, or anyone with legal authority over the property in question.

88. Respondents knew or should have known this prior to including a deceptive

allegation in their petition for a stalking injunction, as a simple property search with

the Sanpete County Recorder would have clarified that Andi Pitcher Davis did not

own the property. It would appear that the Respondents instead decided to willfully

deceive the court, or that their counsel did not perform any due diligence beyond

selectively excerpting and bold facing certain quotes in a misleading fashion.

89. The fact that David Lee Hamblin’s former home is across the street from

Respondents’ former home is irrelevant to the stalking statute, in that neither

location constitutes the Respondents’ property, workplace, residence, or location

12
that they occupy for the purposes of defining stalking under the statutory language.

This basic reality seems to elude Respondents and their counsel, who appear to

argue that a visit to a location across the street from a property they formerly owned

constitutes stalking, when the plain language of the statute-as well as a common

sense-rules that out.

90. Tellingly, Respondents make no allegation that Petitioner has ever visited their

current residence or place of business, or any other location that they own, lease, or

occupy. This is because they have no proof that the Petitioner ever engaged in that

course of action, or any other course of action.

91. The inclusion of Respondents’ single text message to Zina Bennion is also

irrelevant, as the statute explicitly stipulates that “immediate family” is restricted to a

child “who regularly resided in the household within the prior six months.” 76-5-

106.5(1)(iii). Zina Bennion is not listed as a Petitioner on the Verified Petition, and a

signle text message to which she did not respond is not grounds for a stalking

injunction.

92. Respondents appear to believe they can vicariously impute a violation of the

statute to any single instance of communication to an adult child who lives outside

of their home, even when that adult child is likely the victim of their abuse if the

Hamblin sisters are telling the truth and therefore a possible source for any

investigative journalist. Respondents make no allegation that Zina Bennion is their

immediate family by virtue of regular residence within their home over the prior six

months, and they offer no evidence to substantiate such a claim.

93. The hagiographic recitation of facts in the section headlined as “Other Relevant

Circumstances, beginning in Paragraph 103 and continuing through Paragraph 122,

has no bearing at all on the central allegation of stalking, or the relevant elements of

the stalking statute. The awards received by the Respondents, and the duration of

their residency in Spring City, have no relevance to the allegation of stalking.

94. Respondents offer no proof to connect Petitioner’s writing to the specific

instances they claim, which include Lee Bennion’s gallerist in Salt Lake City

13
informing her and her husband that the gallery has received phone calls complaining

about the gallery carrying the art of a Church of Satan member, or the egging of

Horseshoe Mountain Pottery in 2024, or the harassing messages.

95. By the Respondents’ own admission, “none of the individuals who have

harassed the Petitioners have explicitly indicated whether they are affiliated with or

taking cues from the Respondent.”

96. The reality is that the Hamblin Victims Statements and police reports naming the

Respondents as perpetrators have been circulating on the Internet for over two years,

and they have been covered by multiple other journalists, bloggers, and podcasters.

97. The Respondents cannot distinguish the coverage of others from that of the

Petitioner for the purpose of showing a nexus between the coverage of

Investigations in Ritual Abuse and the alleged harassment and threatening conduct

they claim to have endured.

98. Respondents offer only their speculation and supposition to draw an inference or

a link between the Petitioner’s writing and podcast appearances and their purported

harassment and emotional distress, the former of which they offer no exhibits in

support of and the latter of which is bereft of a single affidavit or record from a

medical or psychiatric professional.

99. The Respondents simply make bald assertions of a connection between the

Petitioner’s writing and their claimed distress and the instances of harassment,

neither of which they offer any proof or evidence to support.

100. The Petitioner and the Court are left to simply accept the self-interested

assertions and claims of the Respondents, who have every interest in suppressing

the allegations of their involvement in a satanic cult that allegedly trafficked, raped,

and murdered children and adults over at least a twenty year period.

101. The Respondents have every reason to lie, distort, and misrepresent their

alleged suffering, given the public admission of Joseph Wood Bennion that he did in

fact participate in peyote ceremonies at a time when the possession and use of

peyote, even for religious purposes, was illegal in Utah.

14
 102. Additionally, the federal exemption for religious use of peyote only applied to

enrolled members of federally recognized Native American tribes, which Joseph

Wood Bennion holds no membership in and therefore enjoys no legal protection

from the criminal penalties for possessing peyote and belonging to a group,

Oklevueha Native American Church, whose founder James Warren Mooney was

arrested for running a distribution operation involving 20,000 buttons of peyote he

illegally procured and transported across interstate lines.23 24

103. Respondents can show no single instance of behavior by Petitioner that would

constitute stalking under the plain language of the statute, or any instance of

conduct that would not fit under the exemption within 76-5-106.5(6)(a)(ii), which

covers legitimate business purposes, and publishing stories about criminal

allegations on a Substack that is subscription based falls within legitimate business

purposes.

104. The Respondents do not deny the allegations made by the Hamblin sisters or

the allegations covered by Investigations in Ritual Abuse in their petition for a

stalking injunction, just as they do not deny the allegations made by any other

victims. The Respondents have never sought injunctive relief against Rachel, Eliza,

and Katherine Hamblin. The Respondents have never sued Rachel, Eliza, and

Katherine Hamblin for defamation, and they have never sued the Petitioner for

defamation.

105. The Respondents do not accuse the Petitioner of defamation, because doing

so would open the door to civil litigation, where they would be vigorously and

throroughly deposed under oath and subjected to a discovery process.

106. In short, the Respondents and their counsel misled the court at every turn in

their Verified Petition in an attempt to utilize the stalking statute to quash journalistic

coverage and free speech they did not like, while never once denying the following:

23
Nick Nelson, Medicine Man, Daily Herald, May 22, 2005, available at:
https://www.heraldextra.com/news/2005/may/22/medicine-man/
24
Mooney eventually entered into a Settlement Agreement with the U.S. Attorneys Office in which he
agreed that he would not possess or use peyote in any form, or distribute or facilitate the distribution of
peyote to others, or seek to acquire peyote from any authorized or unauthorized source. Settlement
Agreement, Case No. 2:05 CR 410 TS, February 22, 2006.

15
 a) That they were members of the group described by Rachel, Eliza, and

Katherine Hamblin;

b) that they engaged in the criminal conduct alleged by Rachel, Eliza, and

Katherine Hamblin;

c) that they were involved in the abuse of Rachel, Eliza, and Katherine

Hamblin and others;

d) and that they were and are members of a group that designated itself as

the Church of Satan, a.k.a. the Group.

107. The mischaracterizations of Petitioner’s conduct are myriad in the Verified

Petition of the Respondents, and they are listed in the next section.

MISCHARACTERIZATIONS AND LIES IN THE VERIFIED PETITION

108. In Paragraph 29 of their Verified Petition, the Respondents alleged that the

Petitioner’s “conduct goes beyond mere “investigation” and he seeks to harass and

ultimately destroy the “CS” and its members.”

109. The Respondents then list specific quotes that they contend support their

position, but which in fact are entirely legal and appropriate:

a) Documenting criminal acts and offenses committed by the membership of

the Church of Satan;

b) Compiling useful information or evidence on those offenses and acts, as

well as the accused and their victims;

c) Utilizing prior accrued evidence and information to obtain additional

information;

d) Packaging the information into media packets, criminal complaints to be

utilized at various levels, and civil complaints.

16
 110. Not a single listed item would constitute stalking or any other criminal form of

behavior. Respondents do not deny the voluminous allegations against them, they

do not dispute the veracity of those allegations in their Verified Petitions; instead,

they apparently argue that any further examination of those allegations constitutes

stalking and the infliction of emotional distress.

111. The Respondents apparently identify themselves as offenders, as Paragraph

30’s inclusion of “We want to make the offenders uncomfortable. They’ll make

mistakes when they’re uncomfortable would indicate.” The Respondents’ inclusion

of this quote makes it clear that they see themselves as offenders for the purpose of

this quote’s inclusion in their Verified Petition. Again, they never deny the

substantive allegations against them; nor do they specify which, if any, of the

allegations against them are false.

112. Respondents appear to believe that Petitioner’s stated goal of seeing “as many

of the named perpetrators as possible go to prison and suffer significant financial

losses” is stalking, when in fact, the general goal of any reasonable person is to see

an organized group of child traffickers, child rapists, and child murderers go to

prison for their criminal activities and suffer civil penalties for their abuse and murder

of children.25

113. In Paragraph 32, Respondents cite Petitioner’s invitation for people interested

in taking part in the investigative effort to contact him as evidence of an act in

furtherance of stalking the Respondents, when the specific quote does not reference

the Respondents nor does it invite anyone to contact, approach, confront, send

material to, place or deliver an object to, or directly or indirectly follow, monitor,

surveil, threaten, or communicate about the Respondents or interfere with their

property.

114. In short, the Respondents and their counsels selective excerpt and quote the

Petitioner throughout their Verified Petition without ever drawing any connection

25
Verified Petition, Paragraph 31.

17
between the specific conduct cited as stalking as defined by the statute and their

own alleged plight.

115. The Respondents cite the efforts of Petitioner to train laymen in investigative

research and journalism techniques as evidence that he is somehow stalking them,

when the specific instances cited do not reference Respondents Joseph Wood

Bennion and Lee Patricia Udall Bennion.

116. The Respondents remove the context of certain quotes, including in Paragraph

38, when they say that the Petitioner “states his belief that the members of the CS

“have to reaffirm their commitment to Satan via ordinances”; this means that “the

members could theoretically be surveilled in a manner that would document their

activities.”

117. Petitioner does not instruct the readers to go conduct surveillance, or to engage

in any course of activity that would bring them into proximity with Respondents or

the other alleged members of the Church of Satan, precisely because Petitioner

believes the Respondents to be dangerous, likely guilty of multiple homicides and

rapes, and potentially still part of an organized criminal group.

118. Respondents’ own Petition notes this in Paragraph 40, which explicitly states

that the Petitioner “encourag[ed] his acolytes to never “directly contact or harass any

alleged member of the [Church of Satan].”

119. The methods of identifying, documenting, and disrupting the activities of

criminal groups such as the Church of Satan were outlined to assist in building

evidence for criminal and civil cases, the former of which would require such

information to determine where crimes occurred, and the latter of which would

require such information in order to collect assets to satisfy civil judgments against

those who rape and murder children and adults as part of an organized criminal

enterprise.

120. The Petitioner’s contention that “the simplest way to exert pressure on CS

members is for them to be aware that they are under scrutiny” is removed from its

context of scrutinizing criminal actors in order to deter them from committing further

18
criminal acts, and the scrutiny involved never once involved monitoring, observing,

photographing, surveilling, threatening, or communicating with the Respondents or

any other alleged CS member, which is why the Respondents’ Verified Petition is

bereft of a single cited instance where Petitioner instructed his trainees to engage in

such behavior.

121. At the risk of being redundant, Respondents’ own Petition notes this in

Paragraph 40, which explicitly states that the Petitioner “encourag[ed] his acolytes to

never “directly contact or harass any alleged member of the [Church of Satan].”

122. The Petitioner’s encouragement of trainees utilizing what they can use “to

identify patterns of behavior, geographical locations of activity, and the participants

in such activity” was always in this context of “never directly contact[ing] or

harass[ing] any alleged member of the [Church of Satan].”

123. When Petitioner texted Zina Bennion via text message, for example, he

contacted her as a possible victim of her parents, the Respondents, because Zina

Bennion is not listed in the Hamblin Victims Statements as a perpetrator of abuse or

as a willing member of the Church of Satan.

124. The Verified Petition’s inclusion of Petitioner’s awareness of the Respondents’

and their alleged accomplices awareness of his Substack stems from sources who

told him that Respondent Joseph Wood Bennion claimed he knew who the

Respondent was in 2022 and 2023, while also falsely claiming that Petitioner had

been excommunicated from the Church of Jesus Christ of Latter Day Saints.

125. Additionally, one source alleged that Respondent Joseph Wood Bennion had

walked into a local coffee shop, bragging that he had a gun and anyone who

threatened his family would end up dead. If anyone threatened Respondent’s family

with imminent physical harm, he would be well within his rights to defend himself

and his family with lethal force, but the Petitioner never threatened Respondent

Joseph Wood Bennion or his wife Lee Bennion with anything other than criminal and

civil culpability for their alleged conduct, and Petitioner did not do so through any

direct contact with either of the Respondents, or indirectly through third parties.

19
 126. In fact, Petitioner has never met or talked to or communicated with the

Respondents in any way, a fact that their Verified Petition fails to explicitly stipulate

as it insinuates and alleges that Petitioner’s legal acts within a journalistic and

business context somehow constitute a violation of the stalking statute, when as a

matter of law and fact those actions do not constitute of violation of any criminal or

civil statute, which is why the Respondents resorted to an ex parte order instead of

suing Petitioner for defamation or filing a police report against Petitioner.

127. The context in which Petitioner noted Respondent Joseph Wood Bennion’s

birthday stems directly from the Hamblin Victims Statements, where Rachel, Eliza,

and Katherine Hamblin allege that members of the Church of Satan are required to

re-commit themselves on an annual basis to Lucifer:

“In the Church〔CS), you must re-commit yourself yearly to Lucifer

in a very serious ceremony. It was usually sometime around our

birthday and a very traumatic event. You are challenged to make

a great sacrifice to him. Our Redacted, especially Redacted (the

Paterfamilias), would assign us something they said was “inspired”

(often killing a pet or human). If we did not follow through, huge

punishments awaited us. The elders made a big deal about having

a "happy" birthday - "happy" meaning we were obedient in the

ceremony and not tortured for our resistance. As a "reward”

for adults, friends would hold these parties for each other and

honor the important person with a ceremony and special

sexual favors of their choice. Redacted hosted many at

Redacted home in Provo and at "the House,” as they and their

friends called it (Redacted house in Spring City) and we attended

others.”26

26
Victim Statement #2, pg. 29.

20
128. This context provides an adequate justification for Respondents’ neighbors in

Spring City to keep an eye out for unusally large gatherings or activities around the

birthdays of alleged Church of Satan members.

129. The locations publicized on Substack were the locations of alleged crimes, and

as criminal organizations often tend to re-utilize locations for additional criminal

activities, those addresses were relevant. Again, the Respondents make no effort to

deny the veracity of the allegations against them, either with a blanket denial and an

assertion of defamation, or with any specific rebuttal of the claims made by their

accusers.

130. At no point do Respondents cite a single instance where the Petitioner instructs

anyone to go to the present addresses or past addresses of the Respondents or any

other alleged perpetrator, but they do cite Petitioner’s admonishment that his

readers and trainees should “never directly contact or harass any alleged member of

the [Church of Satan].”

131. In essence, the Respondents’ own Verified Petition undercuts the central

contention that the Petitioner engaged in stalking with the actual words of the

Petitioner that explicitly state that his readers and trainees should not contact or

harass the Respondents or any other alleged member of the Church of Satan.

132. Only by selectively excerpting quotes by the Petitioner, misleading the Court as

the context of those quotes, and through outright deceit do the Respondents

manage to make their case that they have been stalked or harassed, but by their

own admission they cannot connect a single harassing phone call to their gallerist or

their residence and business to the Petitioner or his supporters.

133. As a matter of law and fact, the Verified Petition utterly fails to establish that the

Petitioner engaged in any course of action that could reasonably be construed as

stalking, harassment, or defamation. In fact, the Respondents do not allege that the

Petitioner ever defamed them at all. They do not deny their alleged membership in

the Church of Satan, their commission of alleged criminal acts, or their alleged

beliefs and practices consistent with the allegations made by Rachel, Eliza, and

21
Katherine Hamblin, nor do they submit any affidavits in support of their position from

their adult children denying the allegations of their membership, and their

participation in criminal physical and sexual abuse of children and adults, up to and

including murder.

134. The reason an allegation of defamation would be relevant to the allegation of

stalking is simple enough: if the allegations made by Rachel, Eliza, and Katherine

Hamblin and covered by Investigations in Ritual Abuse are false, the Respondents

might have a basis for their purported emotional distress commensurate with the

reasonable person standard of the statute.

135. If the allegations are true, and the Respondents are instead concerned with the

potential criminal and civil culpability they face if the Petitioner and his supporters

are successful in uncovering evidence to substantiate the allegations against the

Respondents, and there is no unwarranted emotional distress.

136. Petitioner recognizes that murderers and child rapists suffer a great deal of

emotional distress at the prospect of facing exposure, including civil and criminal

culpability, but murderers and rapists are not the class of individual-the reasonable

person engaged in legal conduct-the stalking statute was written to protect.

137. Petitioner also recognizes that the Respondents are free to worship Lucifer or

any other god of their choosing due to the guarantees of religious freedom enshrined

in the First Amendment, but there is no interpretation of religious liberty that extends

to beliefs that lead to the practice of ritualized child rape, torture, and murder.

138. Any reasonable person would agree with the position that religious liberty does

not encompass ritualized abuse and murder, and any reasonable person would

agree that those who perpetrate such acts are not immune from the emotional

distress of exposure or journalistic reporting, or the private opinions expressed by

private individuals.

139. Additionally, the Petitioner is well within his religious liberties as a member of

the Church of Jesus Christ of Latter Day Saints in opposing the continued

22
membership of those individuals who advocate for apostate positions on sexual

morality, or who engage in criminal conduct including child rape, torture, and murder.

140. Petitioner has every right to advise his Church leaders of the allegations against

the Respondents, and the available corroborating evidence which demonstrates

their likely violation of any number of Church doctrines and commandments for

members. No reasonable person would construe this as stalking; if such activity

were stalking, the Church would be unable to engage in any former of discipline

against members who violate its rules.

141. The Respondents have had two years to make their case against the Hamblin

sisters by rebutting the specific allegations made with facts and evidence to show

that the sisters are lying about timelines, locations, dates, specific details, and any

other items. In those two years, the Respondents have offered not a scintilla of

evidence to rebut the allegations against them. In their Verified Petition, they offer

nothing in the way of a rebuttal to those allegations, or even a denial of the veracity

of the allegations.

142. Instead, they have resorted to filing a 35 page Verified Petition For Stalking

Injunction, the contents of which debunk the Respondents’ claims that the Petitioner

ever engaged in a course of action that would constitute stalking as defined by 76-5-

106.5, and their own cited examples of Petitioner’s Substack writing not only refute

the allegation of stalking, but also fit within the exception of 76-5-106.5(6)(ii), which

clearly delineates a legitimate business purpose as an exception to the stalking

statute. Petitioner operates a Substack that is a subscription based business in

which he covers allegations contained with police reports and victims statements

from the Hamblin criminal case in 2012 to 2014, and on the Substack and in

subsequent podcast appearances he has explicitly discouraged readers and

supporters from contacting or harassing any alleged member of the Church of Satan.

143. In fact, the Petitioner has explicitly stated that he does not contact or harass or

confront the alleged perpetrators of sex crimes precisely because doing so would be

23
unsafe, given the violent nature of many perpetrators, despite the fact that the

Petitioner is the legal owner of a firearm and proficient in self-defense.

144. The context of Petitioner’s so-called “extreme” statements pertaining to the use

of force have always been in the context of self-defense, such a hypothetical

situation where the Church of Satan’s members attempt to confront, threaten, or

attack him on his land or in his day to day life, or if they attempted to harm his family

or his property. This is entirely legal, and not at all inappropriate to express.

Respondents offered no examples of Petitioner stating that he would come to their

business, their residence, or any other location for the purpose of confronting them

or engaging in illegal conduct, and the reason is simple: the Petitioner never made

such a statement.

145. The Respondents filed a frivolous Petition seeking relief for a non-existent

threat, and to protect themselves against a course of behavior that never happened,

likely for the purpose of deterring and intimidating Petitioner from engaging in

constitutionally protected speech on his Substack.

146. Their inept understanding of the plain language of the stalking statute is

obvious, as is their dishonest characterization of Petitioner’s actions. Their inept

execution of the Verified Petition, which contains within it exculpatory quotes that

clearly establish the Petitioner never stalked the Respondents and explicitly

discouraged others from stalking the Respondents, is consistent with their

reputation as individuals who leveraged their membership in their Church and their

connections to the institutions of their community to camoflauge themselves in order

to evade culpability or exposure.

147. It is not that the Respondents are particularly competent or adroit at evading

culpability; instead, it is that the Respondents are adroit at compromising others by

persuading them to participate in illicit activity via peyote ceremonies and other acts,

which are illegal under criminal code and prohibited by the clear doctrine of their

Church, which the Respondents clearly disagree with on a fundamental level based

on their endorsement of same sex marriage, the use of illicit drugs, and their

24
association with apostate religious groups, even as they remain members in order to

avail themselves of the penumbral covering of status as active Latter Day Saints in

order to avoid the consequences of their publicly documented actions and

convictions, to say nothing of the extraordinary criminal allegations against them.

148. No reasonable person would look at the Verified Petition for a Stalking

Injunction and see as anything other than an attempt to mislead the Court, by

misrepresenting what the Petitioner actually wrote and did.

149. In simple terms, the Respondents have wasted the Court’s time and resources,

as well as the Petitioner’s time and resources, by necessitating a response to the ex

parte temporary injunction, which took time and resources away from the core

purpose of the Petitioner’s efforts: to uncover the truth about what the Church of

Satan has done over the preceding decades.

150. The fact that the Court granted the relief requested is absurd on its face, given

the reality that the Petition contained every bit of exculpatory evidence within itself

necessary to establish the Petitioner’s complete innocence on the stalking allegation.

151. As a matter of fact and law, the Verified Petition did not establish that stalking

had occurred, or even that it was likely to occur, as a result of the Petitioner’s acts.

152. The Verified Petition did establish that the Respondents and their counsel were

willing to resort to deceit and misrepresentation to obtain relief from legal acts,

which were transmogrified into stalking through selective and misleading quotes and

illogical arguments, even as the Respondents managed to refute their own position

by including explicit statements and admissions which established that the Petitioner

had not stalked them and had not encouraged anyone else to stalk them.

153. Petitioner’s actions do not constitute stalking under 76-5-106.5, his actions are

exempted (6)(a)(ii) of the same statute as a legitimate business purpose, and his

speech is protected under the First Amendment as a journalist and as a private

citizen.

25
154. Respondent’s claim of stalking is clearly debunked by their own Verified

Petition, and should never have been granted. Specifically, the Respondents admit

the following:

a) Petitioner encouraged his ““acolytes” “to never directly contact or harass

any alleged member of the CS.””

b) Respondents claim to have received harassing messages, but they include

no police reports to substantiate their claims, and they admit that “none of

the individuals who have harassed the Petitioners have explicitly indicated

whether they are affiliated with or taking cues from Respondent.”

c) Respondents have shown no connection between the Petitioner and the

alleged egging incident of Horseshoe Mountain Pottery before the 2024

Heritage Day celebration.

d) Respondents have not shown that Petitioner alone would bear sole or

exclusive responsibility for such acts, given that the allegations against

them in the Hamblin Victims Statements have been covered by multiple

other podcasters, bloggers, and journalists, as well as being discussed

among the members of their community and other private citizens.

e) The only proof that the Respondents presented was the Petitioner’s explicit

discouragement of direct contact or harassment of any alleged member of

the Church of Satan, which completely disproves their assertion that the

Petitioner stalked them or encouraged others to stalk them.

f) Respondents claim that they have suffered emotional distress, but they

have presented no medical reports, diagnoses, affidavits, or testimony to

substantiate their claims, nor have they connected that emotional distress

to any stalking they falsely claim the Petitioner engaged in.

g) Respondents make no effort to deny the allegations against them, nor do

they refute any of the specific accusations as false in their Verified Petition.

h) Respondents have not sued Rachel, Eliza, and Katherine Hamblin for

defamation; moreover, they have not sued the Petitioner for defamation.

26
 i) Respondents’ children submitted no affidavits denying or disputing the

allegations made by Rachel, Eliza, and Katherine Hamblin, nor did the

Respondents’ children dispute the allegations covered on Investigations in

Ritual Abuse. When given a chance to comment, Zina Bennion declined to

respond.

j) Respondents cite the satirical videos in which Petitioner utilized AI and

voiceovers to ridicule Respondent Joseph Wood Bennion for his alleged

role in the Church of Satan’s activities as evidence of stalking, which is

objectively absurd, given that Petitioner explicitly stipulated that the

accusations were allegations, that Satanists and other like-minded

occultists were encouraged to patronize and even purchase wares from the

Respondent’s business. Ridicule and censure are not stalking, and they

are protected speech under the First Amendment, and this is a long-settled

issue in our jurisprudence. Hustler Magazine, Inc. v. Falwell, 485 U.S. 46

(1988).27

k) If Hustler Magazine’s satirical advertisement campaign alleging an

incestuous relationship between Jerry Falwell and his mother in an

outhouse constitutes protected speech under the First Amendment, the

Petitioner’s AI videos are squarely within the protections of the First

Amendent as well. Jerry Falwell vociferously denied any incestuous

encounters with his mother in an outhouse; Respondents do not deny any

of the allegations against them in the Hamblin Victims Statements or in the

Petitioner’s AI videos, even as incestuous sexual relationships among

Church of Satan are recounted in graphic detail within the Victims

Statements.

l) The standard in Hustler is simple: whether or not a reasonable person

would have believed that the advertisement in Hustler magazine was

actually Jerry Falwell, and it is the same here: the AI videos were clearly

27
Available at: https://www.oyez.org/cases/1987/86-1278

27
 satirical, and obviously not Joseph Wood Bennion. Additionally, the

articles in which the AI videos appeared explicitly referenced the use of

HeyGen AI and clearly stipulated that the videos were derived from

headshots and did not consist of actual remarks or conduct on the part of

the subjects of the satire.

m) It is impossible to believe that Respondents counsel, Caleb Proulx, is

unaware of the First Amendment’s protections for satirical speech, but if he

is, his ignorance and incompetence do not suffice as a justification for his

frivolous filing on the part of his paramour’s parents, which references

those satirical videos as evidence of stalking.

n) Writing about those allegations using Police Reports and Victims

Statements and utilizing investigative journalist techniques and methods to

uncover corroborating evidence, do not constitute stalking under 76-5-

106.5.

o) In 35 pages of rambling, often incoherent, and illogical arguments, the

Respondents and their counsel failed to establish a single instance of the

Petitioner following, monitoring, observing, photographing, surveilling,

threatening, communicating to or about the Respondents for the purpose

of stalking or harassing them, or interfering with Respondents’ property

directly, indirectly, or through any third party, or by any action, method,

device, or means, nor did they demonstrate that the Petitioner approached

or confronted the Respondents, appeared at their workplace, contacted

their employers or coworkers, appeared at their residence or made contact

with their neighbor, or entered property owned or leased or occupied by

the Respondents, or that Petitioner sent material to the Respondents, their

friends, their associates, or a member of their household, or that Petitioner

ever placed an object on or delivered an object to the Respondents’

property or places of employment with the intent that the object be

delivered to the Respondents.

28
 p) Respondents did not-and cannot-show that the single text to Zina Bennion

sent by Petitioner was sent for the purpose of obtaining or disseminating

information about the Respondents, and even if it was, if the text occurred

in the course of business as part of an effort to cover the Hamblin case and

related matters, it fits within the legitimate business purpose exception of

76-5-106.5(6).

q) Respondents lied to the Court about the ownership of the former Hamblin

home in Spring City located at 95 S 400 E, and they knew or should have

known that Andi Pitcher Davis was not the legal owner, which gives rise to

the possibility that they deliberately lied to the court in order to make it

appear as though Petitioner trespassed on the property and harassed the

tenants, who voluntarily consented to his search and photography of the

property and its structures.

r) Either through incompetence or deliberate deception, the Respondents

attempted to obtain a stalking injunction against Petitioner bereft of any

legal or factual basis. The fact that they were successful in obtaining a

Temporary Injunction is absurd for the reasons stated in the preceding

paragraphs.

PRAYER FOR RELIEF

Based on the foregoing the Petitioner respectfully requests that the ex-parte stalking

injunction be lifted immediately, expunged from the record entirely, and that appropriate

sanctions be entered against the Respondents and their Counsel, Caleb Proulx. Petitioner

requests that the Court determine if the Respondents’ assertions in their Verified Petition

rise to a violation of U.C.A. 78B-18a-101 et. al., in that the assertions were intentional

misrepresentations intended to obtain injunctive relief the Respondents were not legally

29
entitled to, and would never have received, had they not knowingly misrepresented both the

facts and the law in their Verified Petition. Petitioner further requests criminal referrals to the

appropriate prosecuting agency if the Court finds that the Respondents violated U.C.A. 78B-

18a-101 et. al., as well as referral to the bar for disciplinary proceedings against

Respondents’ counsel Caleb Proulx, whose filing was frivolous, dishonest, and completely

without merit as a matter of fact and law.

Petitioner also seeks injunctive relief barring the Respondents from further dishonest

efforts to obtain injunctive relief for non-existent stalking threats and all other matters the

Respondents may attempt to mislead this and other Courts about in the future. Petitioner

requests that the injunction be final and permanent in order to prevent further frivolous filings

by the Respondents, and Petitioner requests any other relief that is equitable and just under

the circumstances and which is otherwise authorized by law.

DATED the 7th day of August 2024. /s/Jamin Darcy

Pro Se

VERIFICATION

Pursuant to U.C.A. 78B-18a-101 et. al., the undersigned state as follows:

I declare under criminal penalty of the State of Utah that the foregoing factual
assertions contained herein are true and correct to the best of my knowledge or belief. I
acknowledge that I may be guilty of a Class B misdemeanor if I knowingly make a false
written statement in an unsworn declaration.

/s/Jamin Darcy August 7, 2024

Pro Se, Petitioner

30
EXHIBIT A
EXHIBIT B
EXHIBIT C
EXHIBIT D
EXHIBIT E
LDS Church of Satan Members

Aidukatis, Nelson and Julie- VS1 pg.30, VS2 pg. 136, VS3 pg.
142-43,
Allen, Mike and Rebecca -VS2 pg. 14, 15, 42, 43, VS3 pg. 12-13,
VS4 pg. 30-31, 60-61,
Allred- VS1 pg. 24
Allred, Bobette- VS1 pg. 3, 46,
Allred, Hugh (“therapy”) - VS2 pg. 130, 131
Allred, Jeff- VS1 pg. 45,
Allred, Linda- VS1 pg. 3, 46,
Anderson, -VS2 pg. 37, 39,
Anderson, Agnes (Richard Anderson’s mother)- VS3 pg. 81,
Anderson, Gerrit and Carol- VS3 pg. 59, 142-43, VS4 pg. 20-24,
42-43, 59-60, 72,
Anderson, Nathan- VS3 pg. 142-43, VS4 pg. 19-21, 24, 45-46
Arrington, James and Lisa- VS2 pg. 130, VS3 pg. 11, 12-13, 35,
38-39, 46-47, 123-24, VS4 pg. 32, 37,
Baird, Dr.- VS3 pg. 92,
Bennion, Joe and Lee-VS1 pg. 3, pg. 5, 7, 13, 24, 25, 29, 36, 40,
44, 45, 48,49, 51,VS2 pg. 16, 21, 22, 27, 28, 33, 34, 37, 39, 41, 42,
43, 44, 48, 51, 52, 53, 56, 57, 58, 60, 61, 63, 64, 66, 67, 68, 78, 82,
83,87, 90, 104, 108, 111, 112, 115, 116, 120, 121, 124, 134, 135,
136, 139, VS3 pg. 7, 8, 21, 26,39-40, 43-44, 50-51, 53-54, 61, 63,
66, 79, 88-91, 95-96, 98-100, 111-112, 114-15, 118-20, 122-128,
129-41, 144-45, 148-50, VS4 pg. 4, 32-35. 42, 53-54, 57, 59-63,
67-68, 70-71, 76-78

Joe Bennion was “The Punisher” in the group VS2 pg. 61

Bennion, Lucy- VS1 pg. 51, VS4 pg. 77
Bignees, - VS3 pg. 118-19,
Bonnie- VS2 pg. 126,
Bowen, Gordon- VS2 pg. 4, 5, 6, 7, 8, 80, 88 , VS3 pg. 45-46, 65,
99, 124, VS4 pg. 4-5, 34, pg. 48,
Bunting, John- VS3 pg. 102-103, VS pg. 48,
Bushmans- VS pg. 22
Capener, Brian-VS2 pg. 73, 74, 82, VS3 pg. 95-98 (as Kapener),
VS4 pg. 43,
Carpenter, Jan- VS1 pg. 3, VS2 pg. 120, 08,
Carson, Evan- VS4 pg. 68,
Carson, Kathy- VS4 pg. 68,
Cliffany- VS1 pg. 45 (Hamblin neighbor in Provo), VS2 pg. 133,
Coleman, Dr. (Veterinarian)- VS3 pg. 94,
“Cory”- VS2 pg. 14, 39, 40, 41, VS4 pg. 60,
Christensen, Craig and Susan (Suki)-VS1 pg. 19, 30, 31, 38, 39,
40, 42, VS2 pg. 16, 37, 42, 43, 52, 65, 75, 79, 91, 111, 120, VS3
pg. 15, 17, 18, 20, 88-89, 99-100, 109-110, 129-30, 140-41, 144-
45, 149-50, VS4 pg. 27-28, 34, 44, 47, 52, 57, 60-63,
Dangerfield, Clyde and Carol- VS3 pg. 20, 24, 26, 41-42, 109-110,
149-50, VS4 pg. 27, 57-58,
Davis, Marc- VS4 pg. 77,
de Jong, Belle (and Dean?)-VS1 pg. 30, 36 VS2 pg. 73,
de Jong Anderson, Carma and Richard Lloyd- VS1 pg. 2
(secretary desk), pg. 4, pg. 7, 9, 30, 50, 51,VS2 pg. 23, 24, 35, 63,
106, VS3 pg. 4, 6, 9, 10, 26, 28, 36, 45-46, 54-55, 58-59, 73-74,
78-81, 87-89, 98-99, 101-110, 114-118, 120-23, 142-44, VS4 pg.
3, 12-14, 17-26, 40, 44-46, 56-60, 65-66, 69-76, 81-82, 86,
de Jong, Gerrit-VS1 pg. 4, VS2 pg. 45, 48, 130, 137, VS3 pg. 16,
23, 37, 81
de Jong, Nola- VS1 pg. 7, VS2 pg. 73, 130, 138,
de Jong, Rosabelle Winegar- VS1 pg. 2, VS2 pg. 53,
Dee, Elsie-VS2 pg. 35,
Fa, Xiao- VS2 pg. 129,
Fenton, Angela (CJ) (Jeffrey) (Tara)- VS1 pg. 6, VS2 pg. 54, 55, 88,
89, 90, 93, 94, 95, 126, VS3 pg. 5, 25, 66-67, 123, VS4 pg. 43, 49-
50, 77,
Ford- VS1 pg. 5,
Gerrit and Carol- VS1 pg. 19, 30, 31, 34, 39, 48 VS2 pg. 39, 40, 41,
46, 136, 137, 138, 142,
Gottfordson, Conrad (Con)-VS2 pg. 55, 74, 90, 93, 94, 95, VS3 pg.
25, 26, 67-68, 122-23, VS4 pg. 43,
The Greens- VS3 pg. 135,
Greenauches- VS3 pg. 129-130
Green, Tom- VS3 pg. 133,
Greg- VS2 pg. 106
Gregersen, Ann- VS3 pg. 50-51, 53-56, 89, 132,
Hamblin, David Lee and Rosie-VS2 pg. 39, 64, 65,66,67, 68, 95,
126, VS3 pg. 3, 4, 5, 6, 7, VS3 pg. 7, 8,9, 10, 11, 12, 13, 17, 18,
19, 20, 21, 22, 24, 25, 26, 27, 28, 29, 30, 31, 33, 34, 35, 36, 37,
38-78, 81-150, VS4 pg. 2-17, 23-24, 26-27, 29-32, 34-86, VS5 pg.
1-3, VS6 pg. 1-3, VS7 pg. 1-8, VS8 pg. 1-3.
Hamblin, Robert and June- VS1 pg. 38, 39, 40, VS3 pg. 15, 16, 67,
70-71, 78, 146, 54, 57-58, 62, 70,
Hamblin, Steven and Jeannie- VS1 pg. 19, 21, 22, 38, 39,40, 41,
42, VS2 pg. 39 41, 52, 53, 60, 64, 65, 82, 87, 112, 136, VS3 pg.
15, 19, 20, 21, 22, 23, 24, 67, 99-100, 109-115,125, 138-142, 144-
146, VS4 pg. 11-12, 26-29, 57-59, 63, 74-75,
Hancock, -VS2 pg. 14, VS3 pg. 142,
Hansen, Gary and Bonnie- VS2 pg. 9, 45?, VS3 pg. 32, 36, 78, 90,
102,
Harmston, James-VS2 pg. 9, 19,31, 43, 44, 51, 139, VS3 pg. 126-
27, 130, 133-34, VS4 pg. 8, 39, 61, 66-67, 69-72,
Harmston, Elaine- VS4 pg. 66
Howard, - VS2 pg. 139,
Howards- VS3 pg. 129, VS4 pg. 70,
Huichal tribal chief- VS3 pg. 131-32
Inoway, President (NY member of the Hamblin ward)- VS pg. 63,
Jan (NY)- VS2 pg. 126, 127, 133, VS4 (father of girl in apartment
building where Hamblins lived) pg. 31-32
Jenna- VS3 pg. 32,
Jimison, Carla-VS2 pg. 57, 58, 104, VS3 pg. 12-13, 89, 130, VS4
pg. 49, 60-61,
Stake President Johansen- VS3 pg. 7, 8, 112, 118-19,
Jones, Janae- VS3 pg. 31, 32, 33, 78, VS4 pg. 35-37
Jones, Ashley (Janae’s daughter)- VS4 pg. 36,
June- VS2 pg. 106,
Kelly, Ian- VS pg. 46,
Kelly, Kevin and Khaliel- VS1 pg. 20, 46, VS2 pg. 63, 120, VS3 pg.
12-13, 63, VS4 pg. 51-52
Kershisnik, Brian and Susanne -VS2 pg. 57, 58, 82, 92, 104, 139,
VS3 pg. 12, 13, 53-54, 62-64, 89, 123-24, 129-30, VS4 pg. 44, 51,
63,
Kershisnik, Noah- VS3 pg. 62-65
“Kim” (Nola’s daughter)-VS2 pg. 22
“Kissy”- VS3 pg. 129-30,
Krii Tuttle (Hamblin)- VS1 pg. 38,
Lake, Randall-VS2 pg. 26, 27, 28, 51, VS3 pg. 43, 44, 50-51, 56,
99, VS4 pg. 42,
Larsen, Ann and Paul-VS1 pg. 40, 49, VS2 pg. 15, 28, 33, 37, 42,
43, 51, 57, 66, 73, 74,82, 120, 135,136, 139, VS3 pg. 7, 8, 43-44,
89, 96-97, 99, 111-112, 118-19, 124, 144-46, VS4 pg. 30-31, 42-
44, 61, 70,
“Linda”-VS2 pg. 39,
Lundberg, Gary? and Joy- VS2 pg. 45, VS3 pg. 32, 36-38, 73, 90,
102, 104,
Leavitt, David and Chelom (Shalom)- VS2 pg. 96, 126, 139, VS3
pg. 49-51, 63, 89, 91-92, 135-36, 139-140, VS4 pg. 31, 34, 51, 76,
Shalom Leavitt’s sister- VS3 pg. 63,
Madsen, Ann- VS3 pg. 10,
McDonald, Jim- VS2 pg. 63
Melanie (sister of ?, who was a Peacemaker in her family)- VS2 pg.
102
Meyers, Dr.- VS3 pg. 92,
Mitton, Ewon (married to Jay Mitton’s brother)- VS2 pg. 63, 64,
Mitton, Jay- VS2 pg. 63, 91
Mooney, James and Linda-VS2 pg. 20, 56, 57, 58, 64, 66, 67, 68,
VS3 pg. 7, 8, 26, 27, 28, 66, 81-82, 122-23, 130-32, 139-40, VS4
pg. 8-9, 68, 77,
“Nathan” and Linda-VS1 pg. 19, 25, 31, VS2 pg 39, 40, 71, 72, 88,
107, 125, VS3 pg. 3, 58 , 142,
Nathan developed the child porn photos and made copies VS2 pg.
72.
Nelson, Conrad- VS2 pg. 103,

Paul- VS2 pg. 116,

Paxman, Shirley and Monroe -VS2 pg. 69, VS4 pg. 57,
Peacock, Ella (artist and neighbor in Spring City)- VS1 pg. 46,
Peel, Dale- VS3 pg. 89,
Pratley, “Sister” and Husband (unnamed and in 14th Ward)- VS3
pg. 32
“Richard and Robert- VS1 pg. 14, 30, VS2 pg. 39, 41, 100
(Richard as High Council Peacemaker), 106
“Renee”- VS pg. 37, 43,
Rosie- VS1 pg. 15
Rytting, Lysa- VS1 pg. 9,
“Sara” (Lee Bennion’s sister and Nola Sullivan’s daughter in law)-
VS2 pg. 21, 37, ]
Schroder- VS2 pg. 120,
Schulte, Mike and Paula- VS2 pg. 18, 21, 37, 42, 43, 51, 82, 104,
139, VS3 pg. 99, 124, 129-30, VS4 pg. 63-64,
Schulte, Tom- VS3 pg. 125,
“Shawnee”-VS2 pg. 23, VS3 pg. 89,
Sheepdog- VS4 pg. 3,
Sheets, David and Deborah- VS1 pg. 30, VS2 pg. 14, 22, 42, 51.
104, VS3 pg. 12-13, 89, 99, 123-124, VS4 pg. 34, 59-61,
Sheranne aka ShaRane (Former Spring City client of DLH?)- VS2
pg. 126, VS3 pg. 5,
Smith, Joseph Alvin- VS2 pg. 49,
Staples, Julie Mitton- VS2 pg. 63, 91
Stevens, Kim and Craig- VS3 pg. 142, VS4 pg. 44,
Sullivan, Clyde and Nola-VS1 pg. 15, 30, 36, 47, 48, VS2 pg. 21,
37, 86, 126, 136, VS3 pg. 5, 33, 57-59, 81, 142-43, VS4 pg. 24-26,
59-60, 69, 72,
Sullivan, Michael and Christine (Nola’s son and daughter in law)-
VS2 pg. 22
Susan (possibly Suki)- VS2 pg. 139,
“The Three Graces”- VS2 pg. 73,
Tom- VS2 pg. 116,
Turkish man- VS4 pg. 37,
Tuttle, Tim and Krii (Hamblin)- VS1 pg. 38, VS3 pg. 20, 21, 109-
110, 149-50, 57,
Uncle Craig- VS1 pg. 16
Uncle Greg-VS1 pg. 16, pg. 20, 26,
Van Wagenen, Norman and Cindy (Belle’s son and daughter in
law)- VS2 pg. 14, 21,
Walker, Ellen-VS1 pg. 7, VS2 pg. 19, VS4 pg. 72,
Waltons- VS3 pg. 89,
Warner, Terry- VS3 pg. 130
Watson, Andy (art teacher in VS3)- VS3 pg. 34
Whitesides, Lynn VS2 pg. 14, 66, 139, VS3 pg. 26, 131-32, 144-46,
VS4 pg. 63, 77,
Wilkinson (Redacted, unnamed friend of one of the victims in
VS3)-VS3 pg. 35,
Wilson, Daryl- VS4 pg. 69,
Wilson, David- VS4 pg. 69,
Wolf, Alyssa-VS2 pg. 57, VS3 pg. 26, 131-32
Yorgason, Josh and Melanie-VS2 pg. 91, 102 (Melanie Yorgason
is Peacemaker in her family),
EXHIBIT F