Go back: Todd v. Reichweinn
Original: https://storage.courtlistener.com/recap/gov.uscourts.cand.340308/gov.uscourts.cand.340308.20.3.pdf
My legal name is Isis Agora Lovecruft. I am transgender nonbinary; my pronouns are they/them/their. I am the defendant in the above-captioned case. I have personal knowledge of the facts contained herein and, if called as a witness, I could and would testify competently thereto.
I am a cryptographer and computer security expert. I provide expertise and consultancy services to clients. I frequently attend, and sometimes speak at, cryptography and digital privacy and security conferences. For example: I formerly worked as a senior developer for The Tor Project, a non-profit digital privacy organization whose main mission is to provide a means of browsing the internet anonymously. I also worked on Signal, one of the most widelyused end-to-end encrypted messaging applications. And I volunteered for the Electronic Frontier Foundation, arguably the premier law firm in the world specializing in digital privacy and internet freedom.
I have been acquainted for years with Peter Todd, the plaintiff in this matter. We work in overlapping fields and sometimes attend the same conferences and meetings, and we used to communicate extensively. Prior to the incidents which gave rise to this lawsuit, I considered him a professional acquaintance, but not a close friend. At no time were we ever romantically or sexually involved
In 2014, Mr. Todd began making explicit, verbal sexual advances toward me during conferences and meetings, such as at the Tor Developer Meeting in Paris, France in early July 2014, sometimes in front of colleagues and peers—though he typically did so quietly in order not to be heard by others present. I found his behavior flagrantly inappropriate and demeaning, and I expressly and repeatedly informed him that his advances were unwelcome. At first, I did so politely and professionally. However, as that did not seem to deter him, I proceeded to respond more derisively, even insultingly. However, this did not stop him either.
On or about September 5, 2015, Mr. Todd emailed me saying he was coming to San Francisco where I was living at the time, and he wanted to consult with me on a computer security question regarding the Bitcoin core daemon. I agreed to and did meet with him in at Workshop Café in San Francisco. During that encounter, Mr. Todd repeatedly interrupted our meeting to make explicit, verbal sexual advances on me, stating (but not asking) what he was going to do to me sexually, such as (approximately, but close to verbatim): ‘I’m going to shove my cock in you so hard and beat you until you beg for more.’ Sometimes, he would utter these things under his breath while appearing just to be on his computer.
I found Mr. Todd’s sexual statements to and about me in Workshop Café offensive and degrading. I was there for a meeting, not to be treated like a sex object. Trying to avoid further unpleasantries, I told Mr. Todd I was hungry and was going to get food. I got up to go, upon which Mr. Todd followed me, without my invitation and without asking.
I walked from the café to Taqueria Cancun, at 6th and Market Streets in San Francisco. Mr. Todd followed me, continuing to make unwanted verbal, sexual advances along the way, harping on his explicit sexual fantasies about me (such as how he intended to tie me up), repeatedly asking/insisting that I go back to his hotel with him. My body language and actual language all conveyed that I was not interested. I escalated my responses from ignoring him and striding on, to saying I was not interested, to rebuking him and telling him to stop.
Mr. Todd followed me into the taqueria, where we both ordered food. Inside the restaurant, he took a break from his advances. Afterward, he followed me out the door. Unnerved, and increasingly scared, I set out in a direction away from my home to prevent Mr. Todd from gaining any clue about where I lived. Mr. Todd continued making advances, trying to get me to go back to his hotel with him. I told him I wasn’t interested and to “f–k off.”\ He didn’t stop. As we walked along Mission Street, at about 7th Street, in front of one of the\ San Francisco Federal Buildings, Mr. Todd said we were headed toward his hotel. Exasperated, I did an immediate about face and started to head in the opposite direction, saying ‘bye’ or ‘see you later,’ or words to that effect. At that moment, Mr. Todd grabbed my arm and spun me around to face him. In defense, I shoved his chest with both hands, open palmed, causing him t stumble back but not fall. I said, approximately, ‘I’m going home; don’t follow me.’ To my knowledge, Mr. Todd then finally stopped following me.
Nevertheless, scared and traumatized, I did not go directly home, but walked randomly and aimlessly around San Francisco for several hours, sat in lower Golden Gate Park for a time, and took a circuitous route home, in order both to collect myself and reduce my anger and anxiety, and to make absolutely certain that Mr. Todd was not still following me. Although this may seem like excessive evasion under the circumstances, that’s how upset I was. Also, I thought at the time that Mr. Todd might try to follow me in a Lyft or Uber.
From that day forward, I sought to avoid Mr. Todd, going so far as to purposefully misstate my physical geographical locations when he inquired and sought me out. For example, on or about May 25, 2016, I responded to a message from Mr. Todd—over pond, an anonymous messaging application—saying he was in Amsterdam and would be in Utrecht the next day, that I was in Berlin, even though I was actually in Utrecht. I did so resentfully, as I neither appreciated having to feign friendliness and professionalism toward Mr. Todd, nor feeling made to respond untruthfully.
As part of the public debate about Appelbaum, some people on Twitter began to question my veracity, in part by questioning where I was on various dates. Todd participated in this effort, including as reflected in the true and correct excerpt of a Twitter exchange, which is attached hereto as Exhibit 10.
Todd injected himself into the public controversy about Appelbaum, expressing repeated doubt about the allegations against Appelbaum. Todd acknowledges one such expression in his complaint: “In August 2016, Todd publicly stated that he did not know what was true regarding Defendant’s and others’ allegations against Appelbaum.” (Complaint, ¶ 31.) Todd acknowledges that I asserted that Todd “publicly, repetitively defended” Mr. Appelbaum
Exhibit 2, hereto, contains true and correct excerpts (screenshots) of my December 5, 2018 Twitter direct message exchange with a person whom I had been helping to mentor (with their twitter icon redacted) in which I described how Mr. Todd had stated the graphic, sexual things he was going to do to me. In that same exchange, I also referenced having learned worse things he had done to women. (See below.)
Despite all of this, in order to avoid further personal tension or professional drama, I did not publicize Mr. Todd’s harassing and assaultive behavior toward me.
Beginning in late May 2016, allegations of sexual assault against Jake Appelbaum, a famous digital privacy and internet freedom advocate, began coming out publicly. I participated extensively in this process, in calling for accountability for Mr. Appelbaum, and I participated in the broader discussions around predatory male behavior in my field—a field dominated by men—not least because Mr. Appelbaum had sexually harassed and assaulted me, along with other victims who began coming forward. My experiences with Mr. Appelbaum are documented in my detailed and widely read and discussed internet post of June 13, 2016, entitled “The Forest for the Trees,” a true and correct copy of which is attached hereto as Exhibit 3.
Mr. Appelbaum had, and still has, many vocal defenders. I have been subjected to extensive and ongoing harassment and threats, in many forms, resulting from my public callouts of Mr. Appelbaum. Exhibit 7 hereto is a true and correct copy of a tweet (Twitter post) I made on October 11, 2016 referencing the retaliation I have experienced. It was just the tip of the iceberg.
Exhibit 8 hereto contains true and correct copies of two tweets posted by Peter Todd, on June 9, 2016 and on June 26, 2016, respectively, concerning the controversy surrounding Mr. Appelbaum
On or about May 5, 2017, Mr. Todd contacted me through Github saying he wanted to discuss with me a software issue in a repository of professional cryptographic work. The issue he raised was extraneous and clearly concocted as pretext to interact with me. I responded by chastising him for defending Mr. Appelbaum, telling him:
“First things first: @petertodd, you’ve publicly, repetitively defended a man who raped me and several other people, and disparaged the victims who were brave enough to come forward with their stories. Do not speak to me. Do not use work as an excuse to speak to me. Do not use cryptography as an excuse to speak to me.”
I also responded, indirectly, by writing just a few lines of source code as a means of showing that his so-called issue was not real.
On July 10, 2017, my friend, colleague, and fellow cryptographer Bryce Wilcox, whom I know as Zooko, visited me at my house in San Francisco. The topic of predatory male behavior in our professional community came up (as it so often does among me and colleagues/friends, in the wake of my outspokenness on the subject), and I relayed my some of my negative experience with Mr. Todd to Zooko.
In or around February 2018, Zooko connected me with two women whom I came to understand also had stories of being sexually harassed, and in one case, raped by Peter Todd. The woman who said Mr. Todd raped her reached out to me over the Signal messaging platform on February 10, 2018. I will refer to, at her request, by the pseudonym Jane Doe. On February 15, 2018, we discussed in detail: our bad experiences with Mr. Todd; our anger and despair generally over the epidemic of sexual harassment and assault by men against women, femininepresenting, and nonbinary people (such as myself) in our professional, tech communities; how hard it is to be believed; the sorry state of German law related to rape; and our fears of retaliation and experiences thereof.
After we eased into the conversation on February 15, 2018, touching on mathematics and academics, Jane Doe told me explicitly that Mr. Todd raped her. Then she provided details. She told me that Mr. Todd went to visit her while she was studying abroad in a town in Germany, and that he took sexual advantage of her while she was in a compromised mental and physical state resulting from a sleep disorder she suffers from. She told me that she was sleep deprived after taking a midterm the day he arrived. She told me that they walked around town after she met him, but her knees buckled as she began to suffer an attack of her condition. She told me that she told Mr. Todd the symptoms he could expect to see, which she told me included cognitive deficits and temporary paralysis. She told me that Todd expressed concern and suggested they go to the nearest hotel where she could sleep off the symptoms, which she agreed to do because she was not near home. She told me that when they got to the hotel and up to Mr. Todd’s room, she tried to sleep on the couch so as not to send him any wrong signals, but he crowded her space on the couch and insisted she sleep in his bed. She told me that after she did, he got into bed with her. She told me she fell asleep and woke up some time later still under the effects of her sleep condition. She told me that she let Mr. Todd take her to dinner, where he tried to impress her, and that afterward, she felt obligated to spend some more time with him because he had paid for dinner. She told me that back up in his hotel room, Mr. Todd began pushing physical boundaries with her again. She told me that she tried to get up several times to leave, but each time, he pulled her back down onto his lap. She told me that she realized she could not leave and therefore surrendered. She said that she considered what happened next as rape. She told me that afterward she locked herself in the bathroom and cried for hours, until she left and walked home at 5:00 am, crying the whole way. She referenced three or four other people who have accounts of being sexually harassed by Mr. Todd.
I believed the foregoing account by Jane Doe because: I believe rape victims—on several lines of reasoning, including reports and studies by reasonably neutral entities, such as the BBC, FBI, CDC, concluding that false rape allegations are as low as 1.5% of total rape allegations; because she told me plainly that Mr. Todd raped her; because she provided extensive details of her encounter with Mr. Todd; because she corroborated my awareness that others, besides the two of us, had accounts of being sexually harassed by Mr. Todd; because of my own such experience with him; and because of some of the similar aspects, such as trying to get us to go to his hotel rooms; persistent advances while ignoring obvious verbal and body language that we were not interested; invading our personal and physical spaces; and resort to physical coercion.
Exhibit 9 hereto contains true and correct copies (screenshots) of part of my February 15, 2018 Signal message exchange with Jane Doe, including her statement to me, “he [Peter Todd] raped me. My messages are in the light gray bubbles aligned on the left margin, and Jane Doe’s messages are in the blue bubbles aligned on the right margin.
On or about February 20, 2019, based on both my personal experiences and the information recounted above, I made a Twitter post in which I obliquely referred to Peter Todd as a rapist. I sincerely believed then that that statement was true, and I continue to believe it today.
Indeed, at the time that I made each of the statements about Todd that are quoted in the complaints, I sincerely believed it to be true, and I continue to believe it today.
I swear under penalty of perjury that the foregoing is true and correct, except as to any information stated on information and belief, and as to such information, I believe that it is true.
Not present in submission.
Screenshots of a text message conversation captured from a cell phone, with any identifying details scrubbed out from the telephone, particularly the profile photo and name of the correspondent. The messages in blue on the right indicate the sender of the message is the person making the capture, and it’s implied that this was captured by Reichwein. If this was claimed to be captured by Reichwein, the filer of this report, there is no potential of validating authenticity of the conversation, or that both sides of the conversation were not phones owned by Reichwein.
It stands to reason that this follows the pattern of relaying anonymous accusations by 3rd parties as identified in the Wilcox filing.
Screenshots of Reichwein’s blog post on Jacob Appelbaum revealing that Reichwein was the author of one of the anonymous accusations published in the website jacobappelbaum.net, using the alias Forest.
Goes on to provide apologist arguments for the bypassing in these campaigns of due process and foregoing of contests of material facts in situations involving accusations of sexual abuse.
No portion of this exhibit provides context or relevance to the Peter Todd accusation and appears merely to position Reichwein as a pattern crusader against sexual abuse to muddy the waters when weighing the case.
For brevity, we can confirm the exhibit is accurately submitted and represented in entirety at the link in the capture section below.
Internet Archive copy of Original
Not present in submission.
Not present in submission.
Not present in submission.
Screenshot capture of twitter posts by Reichwein using the Lovecruft alias, captured faithfully at:
These refer to many posts by Reichwein accusing Appelbaum of sexual assault, as well as many acts of threatening of doxing, gasligting reporters, etc.
This appears to be an attempt to discredit material witnesses anticipating that Appelbaum will provide supporting testimony for Todd and not to be relevant in any way at all to the Peter Todd case.
Screenshot of several tweets by Peter Todd.
In one, he states that wikileaks is usually helpful in verifying the authenticity of leaks, and that this would be difficult with the claims against Appelbaum.
In another he expresses a desire to see audio/video published with victim consent.
In another he expresses a desire to be neutral in the controversy.
In another he hypothesizes that future privacy projects may exclude women as a result of the controversy.
Screenshots of a text message conversation captured from a cell phone, with no identifying details scrubbed out from the screen.
The messages in blue on the right are from the sender of the messages on the right. The messages in grey on the left are from the party on the other end.
This is submitted and referenced by Reichwein as Reichwein’s conversation with an unnamed 3rd party, yet the screenshot would had to have been captured by whoever was sending the messages in blue for that to be accurate.
If Reichwein took this screenshot, then reichwein is the party stating that they were raped in the conversation and not whoever is on the other line.
The grey text on the left indicates the party on the other phone and show reichwein recounting reichwein having lied about being in berlin to Todd during the appelbaum issue, meaning that Reichwein was the the party on the left in grey.
It is either that the person in blue on the right submitted the screenshot, or that reichwein submitted the screenshot from the wrong phone.
The screenshot also shows the party on the other end to be Lovecruft, meaning this screenshot could not have been captured by Lovecruft’s phone, but was submitted by Lovecruft of evidence of the conversation with Jane Doe.
Screenshots of a tweet by an uninvolved third party asking why reichwein was pretending not to be in berlin during the appelbaum campaign; peter todd corrects this person to say that reichwein had sent him a message claiming to be in berlin at the time.
Relevance unclear.
