The similarity between the plaintiff's preoccupations in reality and the preoccupations of the same character in the book, "The Villain", is clear. An acquaintance of the plaintiff who is aware of his occupations and activities will not need to dive into the depths of his memory in order to identify the "villain" with the plaintiff. The defendant, who denies the plaintiff's claims, made no attempt at all to show that these information details are not unique to the plaintiff.
During his cross-examination, the defendant mentioned the character of a certain person "who is also a lecturer who deals with secret organizations and espionage, and he also deals with real estate" (p. 81; paras. 14-18 in prot.), but there was no mention of this claim in the defendant's affidavit and it is not clear why it was first claimed in his testimony. Although it is possible that in Europe there are many who teach at the Academy in Sofia, many who are experts in intelligence research, many who are connected to a company that deals in computer crime, and many who also invest in real estate businesses in Bulgaria , the defendant did not show that there is not a single person, except the plaintiff, who has all the same characteristics together.
Not only that. The plaintiff, in his personal life, presents himself as an overweight person (the plaintiff's testimony at p. 16; para. 23 in prot.), as a diabetic and as someone who underwent gastric bypass surgery (paragraph 12 of the plaintiff's affidavit). The same character, "the villain", was also presented by the defendant as follows (the chapter in the book entitled: "The Russian Conspiracy" dated August 17, 2015 - pp. 14-15 in the appendices to the plaintiff's affidavit):
"His fat fingers trembled as if during one of his bouts of diabetes...
0The conversation ended but the oil felt terrible pain, the most horrible he had felt since gastric bypass surgery a few years ago..."
Thus, it turns out that the fictional character in the book is also presented with reference to details parallel to the plaintiff's: as someone who is overweight, as someone who suffers from diabetes, and as someone who has undergone gastric bypass surgery. Again, such information may seem esoteric to the reasonable reader, but not to the plaintiff's close acquaintances. Those who may and some, if not all, are also aware of the state of his health and personal affairs.