Patrick Timothy Bolen, an internet pest, is in deep, deep ka-ka.

There are still quite a few people waiting in line to sue him and
others for "malicious prosecution" over his "Nuremburg 2000" piece of
frivoloty.

And now the big players are getting in the game ... and poor little
Assama bin Blowpipe is whining. It was a race to see who got him
first, private lawyers or the IRS, or the FBI.

Consider the following, part of a public document:

As the Happy Crack says: Stay tuned ....
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56. In exchange for unspecified "information," Cavitat also promised a

percentage of the anticipated recovery to Timothy Bolen ("Bolen"), who

portrays himself on the Internet as a 'Crisis Management Consultant."

Bolen, acting with his wife, Jan, and their company “JuriMed," have

been attempting to promote the business of Cavitat for some time. As

Cavitat's agent, Bolen, his wife, and company have engaged in a venal

and systematic campaign to attack Aetna and persons whom Cavitat

alleges are associated with Aetna, all for the purpose of his making

money for himself and the others he has acted in concert with in

advancing the baseless claims asserted against Aetna in this lawsuit.

Bolen has a history of advocating for the sale of holistic and

alternative medical products and concepts and of attacking

evidence-based mainstream medicine. He has been "hired," "retained" or

"consulted" in the past by attorneys and for individuals accused of

medical fraud, malpractice and quackery. He also has provided crisis

management services for medical practitioners accused of unethical

conduct. Indeed, Cavitat and Jones rewarded Bolen for his actions in

connection with "public relations" provided to Cavitat and for his

"consulting contributions to the partnership" between Cavitat, Jones,

Bolen and others. It is clear that these services were intended by

Jones and Cavitat to include the ongoing and orchestrated personal

attacks and intimidation of witnesses in this action as well as

continuing to abuse the Courts and Aetna for their mutual economic

profit and ambitions.



57. Even a cursory effort at ascertaining the past activities of Bolen

would have revealed to Cavitat and its representatives the

disreputable tactics engaged in by Bolen on behalf of his "clients."

Bolen has been in frequent and collusive contact with Jones, his

attorneys and others for the improper purpose of advancing the

meritless claims against Aetna. This has included public meetings in

Dallas, Texas in March 2005 where Jones, his agents and Bolen falsely

stated that Aetna was involved in a "conspiracy" to harm Cavitat and

biological or homeopathic dentists.



58. Additionally, Cavitat, Jones, Bolen and others have engaged in a

campaign to intimidate and obstruct testimony of witnesses under

subpoena in this case by various means including the posting of false

representations on the Internet and physical stalking of witnesses in

this case. Aetna incorporates by reference its Response to Plaintiffs'

Motion for Protective Order or To Quash Subpoenas filed in this case

and attached as Exhibit 1 to this Counterclaim.



59. Cavitat and Jones, while admitting that they were in contact with

Bolen, attempted to hide from Aetna and the Court the fact that Bolen

was a participant in the Cavitat Legal Fund and had a known and

demonstrable economic self-interest in improperly influencing this

litigation until the Court ordered production of documents reflecting

this fact. Although Cavitat and its agents also concealed Bolen's

ongoing role as agent provocateur, which discovery has now revealed to

be covertly described as "public relations services." In open Court,

Cavitat and Jones described Bolen as a "loose cannon" and described

his accusations as often false and wrong, and yet failed to admit that

Bolen was agent-in-fact for the Cavitat Legal Fund, Cavitat and Jones.

Such conduct is direct evidence of the fact that Cavitat and Jones

lacked substantial justification to bring suit against Aetna.



70. Cavitat and Jones, along with other persons such as Sarah Jones,

Robert Y. Jones, Dr. Bouquot, Dr. Shankland, Dr. Margolis, Dr. Haley,

Bolen and others, had a meeting of the minds to work together jointly

to profit, legitimize or otherwise disguise the use of the Cavitat

device; gain the approval of mainstream dentistry for the use of the

Cavitat device in the diagnosis and treatment of NICO; and, have the

condition known as NICO accepted by mainstream medicine and dentistry.



71. Cavitat, Jones and those with whom they had a meeting of the

minds, conspired to accomplish their objectives through unlawful acts,

including by committing, or causing to be committed, the unlawful acts

described herein, including: insurance fraud; illegal and unauthorized

research activities; the unauthorized practice of medicine and

dentistry; misrepresenting that the Cavitat device was exempt from FDA

regulations; misrepresenting that the Cavitat device was approved by

the FDA and, specifically, approved by the FDA for detecting diseased

bone; obstruction of justice; witness tampering; and barratry.



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80. The conduct of Jones and Cavitat as well as Bolen and their other

agents was intentional, willful, wanton, malicious, reckless, grossly

negligent and deserving of punishment.



81. Aetna is therefore entitled to exemplary or punitive damages in

the maximum amount allowed by law to punish Jones and Cavitat and to

deter other similarly-situated persons from engaging in like conduct

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