How Meryl Dorey lied under oath.

Meryl Dorey, the president of the Australian Vaccination Network has lied under oath and I have the evidence to prove this. Meryl Dorey sought to remove a government letter from the internet in an effort to avoid some well deserved criticism. Here is a copy of a DMCA notice that she filed to have the following document removed from the internet: Letter from the OLGR revoking the AVNs charity status.

This is the complaint she filed:


Pursuant to 17 USC 512(c)(3)(A), this communication serves as a statement that:

I am the exclusive rights holder for material held at and;

These exclusive rights are being violated by material available upon your site at the following URL(s):


I have a good faith belief that the use of this material in such a fashion is not authorized by the copyright holder, the copyright holder’s agent, or the law;

Under penalty of perjury in a United States court of law, I state that the information contained in this notification is accurate, and that I am authorized to act on the behalf of the exclusive rights holder for the material in question;

I may be contacted by the following methods (include all): Australian Vaccination Network, PO Box 177, BANGALOW NSW 2479, AUSTRALIA; Phone – 612 6687 1699 – FAX 612 6678 0894 – Mobile 61414 872 032 – email

I hereby request that you remove or disable access to this material as it appears on your service in as expedient a fashion as possible. Thank you.


Meryl Wynn Dorey

Meryl Dorey,


The Australian Vaccination Network, Inc.

[I omitted her absurdy long signature]


The result of this notice is that Ken McLeod who had originally uploaded the document to Scribd received a notice stating that the content had been removed.

Hello, ken_mcleod —

We have removed your document, “OLGR Letter to AVN Advising of Revocation 14-10-10” (id: 51133133) in response to a third-party notification or other indicia that this document was uploaded to without the authorization of the copyright owner. If you believe the removal of this document is the result of a mistake or misidentification, please visit our Scribd Support Desk to access the instructions for providing a counter-notification.

For more information, read about our Copyright Management System or contact us through

Please note that under Section 512(f) of the Copyright Act, any person who knowingly materially misrepresents that content was removed or disabled by mistake or misidentification may be subject to liability. Please also be advised that we enforce our policy that provides for the termination of users who are identified as repeat infringers.

Thanks for your cooperation.

-Scribd Customer Care

So Meryl’s complaint resulted in the removal of the document. She swore under penalty of perjury that the complaint was true and accurate, not only that but she also consented to the jurisdiction of the United States. The problem with this is that her complaint wasn’t valid and she therefore has committed an offense within the United States.

Scribd, Inc.

Attn: Jason Bentley, Copyright Agent

539 Bryant St, Suite 200

San Francisco, CA 94107

Dear Mr. Bentley:

This letter is a formal response to a claim of copyright infringement against one or more of the documents that I’ve uploaded and published on I believe the claims of copyright infringement are wrong and vexatious and should be rejected because:

1. The material in question is not copyrighted. The letter which I posted was from an Australian government department, (The New South Wales Office of Liquor Gaming and Racing) reporting its findings of their investigation of a fraudulent “charity”, the so-called “Australian Vaccination Network” and its Public Officer, Ms Meryl Dorey, who I believe to be your complainant. The letter is a public document, and was first posted by Meryl Dorey on her Scribd account. Indeed, the letter and all the other material has been lodged in the New South Wales Supreme Court as part of the Discovery process, see the attached Court Lisiting. It is therefore in the public domain and may be reproduced by anyone.

2. The complainant has provided no copyright registration information or other tangible evidence that the material in question is in fact copyrighted, and I have a good faith belief that it is not. The allegation of copyright violation is therefore in dispute, and at present unsupported.

3. The complainant does not hold the copyright to the material in question, is not the designated representative of the copyright holder, and therefore lacks standing to assert that my use of the material is a violation of any of the owner’s rights. If copyright ownership was to be asserted by anyone, it would have been asserted by the author, and it was not.

4, My use of the material is legally protected because it falls within the “fair use” provision of the copyright regulations, as defined in 17 USC 107. The “fair use” provisions allow for reproduction for the purposes of reporting, research, satire, and so on, and my post conformed to the Act. If the complainant disagrees that this is fair use, they must work directly with me, though legally viable channels, to resolve the dispute. Ms Dorey and the New South Wales Government have never contacted me to express any concerns they may have. Scribd and its employees under no obligation to settle this dispute, or to take any action to restrict my speech at the behest of this complainant.

5. The complaint does not follow the prescribed form for notification of an alleged copyright violation as set forth in the Digital Millennium Copyright Act, 17 USC 512(c)(3). Specifically, the complainant has failed to:

a.. Provide a complaint in written form. [17 USC 512(c)(3)(A)]

b.. Include a physical or electronic signature of the complainant. [17 USC 512(c)(3)(A)(i)]

c.. Identify the specific copyrighted work claimed to be infringed, or, if multiple copyrighted works are covered by a single complaint, provide a representative list of such works. [17 USC 512(c)(3)(A)(ii)]

d.. Provide the URLs for the specific files on my web site that are alleged to be infringing. [17 USC 512(c)(3)(A)(iii)]

e.. Provide sufficient information to identify the complainant, including full name, mailing address, telephone number, and email address. [17 USC 512(c)(3)(A)(iv)]

f.. Include a written statement that the complainant has a good faith belief that use of the disputed material is not authorized by the copyright owner, its agent, or the law. [17 USC 512(c)(3)(A)(v)]

g.. Include a written statement that the information in the notification is accurate, and under penalty of perjury, that the complainant is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed. [17 USC 512(c)


6. The complainant Meryl Dorey or her legal representatives, have never contacted me with their concerns, although they have my postal and email address.

7. The complaint is vexatious in that Ms Dorey is embarrassed to have been exposed in breaches of Australian legislation by the letter, and is attempting to prevent evidence from being published. She is attempting to prevent many documents from being published, and I ask that you regard her as a vexatious complainant and ignore her.

This communication to you is a DMCA counter notification letter as defined in 17 USC 512(g)(3):

I declare, under penalty of perjury, that I have a good faith belief that the complaint of copyright violation is based on mistaken information, misidentification of the material in question, or deliberate misreading of the law.

I ask that Scribd, upon receipt of this counter-notification, restore the material in dispute, unless the complainant files suit against me within ten (10) days, pursuant to 17 USC 512(g)(2)(B).

My name, address, and telephone number are:

FULL NAME: Kenneth Vincent McLeod

I hereby consent to the jurisdiction of the Federal District Court for the San Francisco, California judicial district).

I agree to accept service of process from the complainant.

Best regards,

(the above is the genuine signature of me, Kenneth Vincent McLeod)

This counter notification by Ken McLeod saw the Letter from the OLGR revoking the AVNs charity status restored to the internet by Scribd who were hosting it at the time. Now of course there are many of us hosting this document, ensuring that it will always remain online despite Meryl Doreys best attempts to remove content that is not hers from the Internet. Meryl is so determined to silence her critics that she is prepared to lie under oath. I wonder if she will do the same in a court of law?

Don’t just take my word for it. Here’s the original document of evidence collected by Ken: HERE’S PROOF THAT MERYL DOREY LIED UNDER OATH.

Case Closed…? (Or does the saga continue)

7 thoughts on “How Meryl Dorey lied under oath.

  1. Gib

    So, who is the party who can take action against Meryl for purgury?
    Is it the subject of the complaint? Ie. Ken McLeod
    Or is it the service provider? Ie. Scribd?

    And do we know if Meryl takes frequent trips to the USA so she can be served there?

  2. Dan Buzzard

    Meryl Dorey is a US citizen and does travel to the US to attend anti-vaccination seminars. She also consented to the jurisdiction of the United States when she sent the notice.

    There was a case a few years ago where a YouTube nut by the name of VenomFangX was force to apologise for false DMCA complaints to avoid legal action being taken against him by the person whose videos he took down

    So it would seem that the subject of the complaint would have to initiate legal action, I'm not sure what this would involve but I expect the cost to be quite high considering the action would need to be taken in a US court. I live in hope that Meryl will someday be prosecuted for her crime.

  3. Gib

    I understand it might not be cheap, but if Ken is keen, perhaps we can investigate the price and have a whip-around to raise some cash….

    Although it might backfire, since the effect might be to get Meryl to avoid the USA for a while and stay in Australia….. I'd much prefer she be not here.

  4. Dan Buzzard

    In the event that she were to be charge with perjury in the US she would be forced to defend the charges or forever avoid entering US jurisdiction.

    However I don't know what it would take to bring such charges. It's one thing for the laws to be on the books, quite another to convince authorities to act. I believe she's hit quite a few people from Stop the AVN with false notices.


    Sorry Macca, that's old and tired and well worn .. have anything new?

    The sure things in life are death, taxes and Meryl Dorey telling lies.

  6. Harry Phillips

    Oh Macca, that is not a very nice thing to say about Meryl, just because she files false DCMA to hide the truth does not mean she is the pocket of Big Pharma.

    Do you really think that all this time she has been playing both sides? Getting cheques from Big Pharma AND hitting up her subscribers to fight Big Pharma?

    I really don't think she has the intelligence for it.


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