I'll will post her pack of lies, harassment and threatening
posturing later today.
According to a high ranking member of the ARSCC, I am now to
be recognized as an SP4...
Now to work out my snappy retort to the 'ho's missive.
Neil Woods
I'm Woodsy...
Still actively soliciting a 'Legally' obtained copy of NOTs.
Acting in concert with nobody.
njw...@erie.net (NJWoods) wrote:
>..Did you get your official 'Ho Gram?
>
>I'll will post her pack of lies, harassment and threatening
>posturing later today.
>
>According to a high ranking member of the ARSCC, I am now to
>be recognized as an SP4...
>
>Now to work out my snappy retort to the 'ho's missive.
"Rearrange these words to form a well-known saying: OFF, FUCK."
Should cover it.
- --
Steve: SP4 and Clam Cluster, KoX, KOh
Minister in the First Electronic Church of SCAMIZDAT,
High Grand Pappadum of the Church of the SubGenius.
I thought...Bob had fallen and he couldn't get up? [on Bob Penny, MS victim]
-- "Vera Wallace", official CoS stooge showing Scientology's caring side.
A good home awaits a NOTS pack available for legal adoption. Apply by email...
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[posted and emailed to the lying ho' of babble-on the
fraud who exists at h...@netcom.com even though it's been
proven that more than one person uses that account, thus
by simple logic, at least one of those people is NOT
helena kobrin, and email is still NOT a legal method to
serve notice.]
In article <4jecjl$be4...@news.erie.net>, NJWoods <njw...@erie.net> wrote:
>..Did you get your official 'Ho Gram?
>I'll will post her pack of lies, harassment and threatening
>posturing later today.
this really pisses me off. not only did i post a request
for a NUTS pack, but i even emailed it to the lying ho'
of babble-on, a barrator fined $20,000 for filing a frivolous
RICO suit against david mayo. i've seen nothing from this
proven liar. no threats, no nothing. perhaps she's too
much of a cowardly slut to do it, or maybe she's too busy
auditing gene engram's 'body thetan.'
i'll email her THIS message, too, because i feel snubbed.
why no threats, ho'?
>According to a high ranking member of the ARSCC, I am now to
>be recognized as an SP4...
i'm ALREADY SP5. i just want to collect more of these things
than anyone else. so far i think i've gotten at least three
and maybe four of them. it depends on whether you count
threats to ISPs as actual ho' notes.
>Now to work out my snappy retort to the 'ho's missive.
>Neil Woods
>I'm Woodsy...
>Still actively soliciting a 'Legally' obtained copy of NOTs.
>Acting in concert with nobody.
apparently, according to an actual lawyer, an order like
this basically means that if you even KNOW about it you're
liable. so basically, since you've seen the order, you're
ORDERED to DESTROY ANY COPIES OF NUTS materials you see.
of course, you're ALSO ordered NOT to destroy any NUTS
materials you see.
this is in judge whyte's fantasy-land of lunacy, of course,
which ought to be in NUTS itself:
Destroy a NUTS pack.
Do not destroy a NUTS pack.
Create a NUTS pack.
Do not create a NUTS pack.
h
- --
fuckfuckfuckfuckfuckfuckfuckfuckfuckfuckfuckfuckfuckfuck
f f
u "When you can't say 'fuck,' you can't say u
c 'FUCK THE CDA!' -- Lenny Bruce rephrased c
k k
fuckfuckfuckfuckfuckfuckfuckfuckfuckfuckfuckfuckfuckfuck
ObURL: http://www.cybercom.net/~rnewman/scientology/erlich/defense-fund
[ For Public Key: finger he...@netcom.com ]
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>..Did you get your official 'Ho Gram?
>
>I'll will post her pack of lies, harassment and threatening
>posturing later today.
>
>According to a high ranking member of the ARSCC, I am now to
>be recognized as an SP4...
>
>Now to work out my snappy retort to the 'ho's missive.
>
>Neil Woods
>I'm Woodsy...
>Still actively soliciting a 'Legally' obtained copy of NOTs.
>Acting in concert with nobody.
Ditto. I got mine too. Does this make me a SP2, 3, or 4?
To: bra...@ix.netcom.com
Subject: Your solicitation
From: Helena Kobrin <h...@netcom.com>
Date: Sat, 23 Mar 1996 21:38:48 -0800 (PST)
Dear Mr. Braden,
I represent Religious Technology Center ("RTC"), the owner
of the confidential Advanced Technology of the religion of
Scientology, and the holder of exclusive rights under the
copyrights applicable to the Advanced Technology materials.
Among these copyrighted, confidential, unpublished materials are
the Advanced Technology materials of the works included in a
level known as "NED for OTs Series" or "NOTs".
I have seen your posting soliciting copies of the NOTs pack
to be sent to you. You are apparently under the mistaken
impression that it is possible to obtain a "legal" copy of these
materials. This is false. The only way that these materials
have *ever* left the custody of the few advanced Scientology
churches which are licensed to have them is through outright
*theft* for which the thief was arrested, convicted, and served
time in jail in Denmark.
In suits brought subsequent to that theft, courts ordered
all copies of those materials to be turned in to the courts. If
anyone still has a copy of those materials, it is the fruit of
that theft and in violation of those court orders. There is no
*legal* copy of these materials in existence.
You are hereby put on notice that because these materials
are protected not only under copyright, but also trade secret
law, your *solicitation* of these materials is in violation of
the law, as would be your disclosure of them to others by
whatever means. By your solicitation, you are also inducing
violation of the law by others.
I am including at the end of this message the notice that I
posted to several newsgroups on March 22, 1996, containing the
TRO that was issued by the United States District Court for the
Northern District of California on March 21, 1996 against Grady
Ward and those acting in concert with him. I repeat here that
you are on notice of this TRO. If you engage in actions
prohibited by this TRO, you do so at your peril. While we would
rather not have to litigate, we will take all necessary legal
actions to protect these intellectual properties.
Sincerely,
Helena Kobrin
henri...
Maybe it's the way you asked?
I've always believed that you could attract more flies with honey than you
could with vinegar. You know, it worked too...
Now I've got this fuckin' big, fat, ugly, shit eating fly buzzing around here
waitin' to get swatted...
Neil
1
I'm Woodsy...
Still actively soliciting legal copies of NOTs.
Acting in concert with no one but myself.
: >..Did you get your official 'Ho Gram?
: >
Yo folks! Another letter from Helena showed up in my mailbox.
[posted and mailed, cc to Judge Whyte]
>Dear Mr. Henson,
>
> I represent Religious Technology Center ("RTC"), the owner
>of the confidential Advanced Technology of the religion of
>Scientology, and the holder of exclusive rights under the
>copyrights applicable to the Advanced Technology materials.
>Among these copyrighted and confidential materials are the
>Advanced Technology materials of certain levels known as "NED for
>OTs Series."
Boilerplate. Do you have a macro programmed with this introduction?
> I have been informed that you have posted NOTs Series 34 to
>the Internet without the authorization of my client, who, of
>course, would not have given such authorization had it been
>requested.
That I did. In particular the HCOB of Nov. 14, 1978. I presume by
your complaining that RTC acknowledges this material to be an official
copyrighted, trade secret, instruction manual for criminal activities?
No wonder you want to keep it from being discussed!
> I also see that you are claiming that you have talked
>to the court and that this justifies your posting.
You would have to be exceptionally dense to avoid noticing that the
quoted document was right in the middle of a letter to Judge Whyte.
> I am hereby placing you on notice that NOTs Series 34 is a
>copyrighted, unpublished work.
And I am hereby placing RTC on notice that the HCOB of Nov. 14, 1978
contains claims and instructions which seem to me to be both criminal
in nature and in violation of certain court orders against the
"Church" of Scientology.
> Not only is it subject to the TRO
>issued by Judge Whyte against Grady Ward (and will be subject to
>the preliminary injunction once issued), it is also subject to a
>preliminary injunction issued by Judge Whyte in Religious
>Technology Center v. Netcom On-line Communications, Inc. against
>Dennis Erlich. In both instances, the injunction is against Ward
>or Erlich and their "agents, servants, and employees, and all
>persons acting or purporting to act under his authority,
>direction or control, and all persons anyone acting in concert or
>in participation with any of them who receive notice of this
>Order." These injunctions were issued on the basis that RTC was
>likely to succeed on the merits of its claims.
Well, lets see. I am certainly not any kind of "agent, servant or
employee" of either Dennis Erlich or Grady Ward, nor do I act under
any kind of direction or control. Now, you can go argue with Judge
Whyte that all persons who happen to read a.r.s, agree with Grady or
Dennis that CoS is a scam of a cult, and take independent action are
"acting in concert or in participation." Lots of luck.
>
> You have also included in your notice a request for people
>to send you the NOTs materials.
I am not interested in just *any* old NOTs materials. I asked for
NOTs materials which amounts to instructions for criminal acts, such
as those found in the HCOB of Nov. 14, 1978, or fraud. I believe
discussion of this subset(?) of these materials is in the public
interest. I am prepared to go to court to defend my right to quote
from and discuss the criminal acts and policies of the "Church" of
Scientology.
> Please be informed that the
>California Uniform Trade Secrets Act prohibits even the
>*acquisition* of materials containing trade secrets.
I simply do not believe that anything which can be found by a few
seconds of searching on any one of a hundred thousand computers all
over the world can be considered a "trade secret." What is a
non-profit *Church* doing with trade secrets anyway? Trade secrets
are for *profit* making commercial companies. Or perhaps fraudulent
scams.
> It is for
>this reason that Mr. Ward was enjoined under trade secret law.
>Your solicitation of these materials is a violation of that law
>and an inducement to others to do so.
As I pointed out above, I asked for material which amount to criminal
instruction manuals or material which shows evidence of fraud on the
part of Scientology. It will be very interesting to be enjoined in a
First Amendment pursuit which is so clearly in the public interest.
You really should try.
You don't even have to hire a process server. Give me a call, beeper
# 408-521-0614, and I will come down to Mr. Hogan's office and pick up
my papers.
> I am setting forth below the TRO issued by Judge Whyte and
>the notice which I posted after the TRO was issued. I hereby
>demand that you cease and desist from any and all further
>posting, reproduction, display, distribution, solicitation or
>acquisition of NOTs Series 34 or any of the Advanced Technology
>works of the Scientology religion.
>
> Sincerely,
> Helena K. Kobrin
Well, Helena, I am going to put it a little nicer than Grady would,
but you can take your demand, fold it till it is all corners, and
stick it where "the Sun don't shine." And, just to show I mean it, I
am *again* asking for NOTs or any other Scientology "AT" materials,
acquired by legal, or *illegal* means which describe criminal acts,
amount to criminal instruction manuals, or show the fraudulent bait
and switch nature of Scientology. It is my intent to comment on and
post this material in the public interest. I do not believe that
either copyright law or trademark law will prevent the publication of
information relating to unlawful acts. If you think otherwise, I
suggest you check with a couple of tobacco companies.
> NOTICE TO READERS:
>
> On March 6, 1996, Grady Ward posted a message to the
>Internet soliciting a NOTs pack. In a later posting, Ward
[snip for bandwidth]
Keith Henson
SP 4, bucking for SP 6
[posted and mailed]
In <315f0260...@nntp.ix.netcom.com> bra...@ix.netcom.com
(Pat Braden) writes:
[snip]
>Ditto. I got mine too. Does this make me a SP2, 3, or 4?
It makes you an SP4. Look at the very end:
[snap]
>prohibited by this TRO, you do so at your peril. While we would
>rather not have to litigate, we will take all necessary legal
>actions to protect these intellectual properties.
> Sincerely,
> Helena Kobrin
This is pretty obviously a threat, which is the requirement for SP Level
Four. In fact, there's a formal ARSCC decision on that (see ARS CCB
#96-23a). Congratulations on your new suppressive level!
Taneli, aka spud-tane
ARS CSCI Eur
Disclaimer: The rules of the ARS Central Committee require me to deny
its existence. In fact, there is no such thing.
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--
T. Huuskonen | All messages will be PGP signed, | L Ron Hubbard started the
----------- | encrypted mail preferred. Keys: | most pernicious cult I know.
3863@twwells | finger huus...@karhu.helsinki.fi | Form your own opinion, read
134839@penet | http://www.helsinki.fi/~huuskone/ | alt.religion.scientology.
>>..Did you get your official 'Ho Gram?
>this really pisses me off. not only did i post a request
>for a NUTS pack, but i even emailed it to the lying ho'
>of babble-on, a barrator fined $20,000 for filing a frivolous
>RICO suit against david mayo. i've seen nothing from this
>proven liar. no threats, no nothing.
Shit henry - take a valium. She's simply trying to enturbulate you.
Don't let her get you down.
If you *really* want to get another Ho' Gram the way to do it is to
*not* ask for it. Make it clear that you would rather undergo a root-canal
than get a Ho' Gram. *THEN* you'll get one. Proof? Well, the other day
hkk@netcom pissed me off enough that I wrote some gibberish which
included a bit about "I wasn't going to do this, but now you've done it. Send
me NOTS." And lo' and behold - I received my Ho' Gram this morning.
545 fuckin' lines of it. What a waste of bandwidth.
BTW Helena - why do you figure that Judge Whyte's order applies to
Canadians?
-BRAD-
--
Brad Wallace, SP4, KoX, br...@ras.ucalgary.ca - Read alt.religion.scientology
"You have the right to free speech, as long as | FUCK!
you are not dumb enough to actually try it" | the
- "The Clash," paraphrasing Church of $cientology doctrine | CDA
"Rather not have to litigate!!?? HAHAHAHAHAHAHAHAHAHA!
That's like Hitler saying, "Gee, I'd rather NOT have to kill Jews...."
Look lady, the horse is LONG gone out of the barn and has reproduced himself a
thousand times OVER! Give it UP! Anybody with the slightest curiosity can
find out ALL your deep dark "secrets." (Silly and BORING as they may be).
Why not spend your money trying to do some GOOD and rehabilitate your
"church's" reputation as a psuedo-Nazi-like CULT!! If you don't you'll drown
in your own venom.
What am I saying, you're a LAWYER! You have no interest whatsoever in any of
this being settled because then the money STOPS, doesn't it! Evil pays well,
always has.
--
AVE ATQVE VALE
CENT...@hooked.net
How NICE for you.
>That I did. In particular the HCOB of Nov. 14, 1978. I presume by
>your complaining that RTC acknowledges this material to be an official
>copyrighted, trade secret, instruction manual for criminal activities?
>No wonder you want to keep it from being discussed!
Indeed.
>You would have to be exceptionally dense to avoid noticing that the
>quoted document was right in the middle of a letter to Judge Whyte.
Well, yes. But....
>And I am hereby placing RTC on notice that the HCOB of Nov. 14, 1978
>contains claims and instructions which seem to me to be both criminal
>in nature and in violation of certain court orders against the
>"Church" of Scientology.
I doubt it's the only one, too. Gotten any more goodies?
>I am not interested in just *any* old NOTs materials. I asked for
>NOTs materials which amounts to instructions for criminal acts, such
>as those found in the HCOB of Nov. 14, 1978, or fraud. I believe
>discussion of this subset(?) of these materials is in the public
>interest. I am prepared to go to court to defend my right to quote
>from and discuss the criminal acts and policies of the "Church" of
>Scientology.
If you get raided, go buy a new toothbrush! I'm sure I can find
someone who wants your old one. A friend in Berkeley told me, by the
way, that sie saw, at a rave, someone selling "scientology
toothbrushes". Even far from the net, the degraded joke-cult of
scientology is providing amusement for those fortunate enough to be
outside its clutches.
>As I pointed out above, I asked for material which amount to criminal
>instruction manuals or material which shows evidence of fraud on the
>part of Scientology. It will be very interesting to be enjoined in a
>First Amendment pursuit which is so clearly in the public interest.
>You really should try.
YESSSSS!
Do it, Helena! Sic 'im!
<Helena squawks>
>> I am setting forth below the TRO issued by Judge Whyte and
>>the notice which I posted after the TRO was issued. I hereby
>>demand
My daddy, before he went there for personal experience with the place,
was fond of saying, when people expressed wants, that "People in hell
want ice water." Helena, the toothpaste is out of the tube, the genie
out of the bottle. The scam and coverup of your corrupt cult is
unravelling as inexorably as Watergate. Blow the scamcult, blow Gene,
or blow the case.... You don't get to close your mouth, but you might
still be able to choose the flavor. Do you like the taste in your
mouth when you wake up? Only you can change it.
>Well, Helena, I am going to put it a little nicer than Grady would,
>but you can take your demand, fold it till it is all corners, and
>stick it where "the Sun don't shine." And, just to show I mean it, I
Is Helena responsive, Keith? Or is she just shifting tenderly from
cheek to cheek, uncomfortable at the position she's in and unable to
see a way out?
>am *again* asking for NOTs or any other Scientology "AT" materials,
>acquired by legal, or *illegal* means which describe criminal acts,
>amount to criminal instruction manuals, or show the fraudulent bait
>and switch nature of Scientology. It is my intent to comment on and
>post this material in the public interest. I do not believe that
>either copyright law or trademark law will prevent the publication of
>information relating to unlawful acts. If you think otherwise, I
>suggest you check with a couple of tobacco companies.
Good luck, Keith! I'm watching with great (and public) interest.
The degraded joke-cult of scientology reminds me of nothing more than a
puppy that tipped over the trash, tried to lick out a can, and got its
head caught. In panic flight, it charges around, bashing into things,
and creating for itself consequences it can neither see nor
understand. Blind agitation and some yelping....
How degrading, and what a joke....
SP7-48
1. Find some Scientologists and communicate to them
individually until you know they received your communication.
2. Go to a newsgroup or a place with many types of kooks and communicate
with each of them until you know the communication is received
and, if possible, returned.
-- jeff_...@rbcbbs.win.net
: [snip]
: >Ditto. I got mine too. Does this make me a SP2, 3, or 4?
: It makes you an SP4. Look at the very end:
: [snap]
: This is pretty obviously a threat, which is the requirement for SP Level
: Four. In fact, there's a formal ARSCC decision on that (see ARS CCB
: #96-23a). Congratulations on your new suppressive level!
^^
I looked it up, it is #95-23a. Keith Henson
: Taneli, aka spud-tane
: ARS CSCI Eur
: As of Tue, April 2, 1996, the first of these letters has been canceled
: twice. Is CoS going to do something more effective? I doubt it. In
: the mode of Grady Ward I proclaim the "Church" of Scientology to be
: degraded and criminal, a nearly helpless cult of fools. I invite their
: lawyers to get an injunction to prevent me from posting their criminal
: instruction manuals which are also violations of court orders.
: Will Judge Whyte prevent quoting and discussion of materials showing
: contempt and illegal intent?
He did.
(as you might have noted on other threads and in **BJ**)
If this sticks (and it might) then copyright/trade secret can be used
to prevent disclosure of illegal acts and to cover up contempt of court
acts, a situation worth noting, and a clear case of commercial interest
being found to be more important than the public interest. (This *has*
been a trend lately.)
: Stay tuned, and watch the criminal cult crumble
: before the distributed corrosive power of the Net.
The "Church" of Scientology is hosed even if I go down in flames.
: And, yes, I am still looking for NOTs or AT materials which show the
: criminal or fraudulent nature of Scientology.
Not until the TRO is lifted. Even if someone sent me an official CoS
manual on how to murder (with case examples) I could not disclose it.
Keith Henson SP5
http://www.cybercom.net/~rnewman/scientology/henson/home.html
Where you can read about my case, and
http://www.cybercom.net/~rnewman/scientology/grady/home.html
where you can read about Grady Ward's case.
Keith Henson
[snip]
: : Will Judge Whyte prevent quoting and discussion of materials showing
: : contempt and illegal intent?
: He did.
Folks, this is fun! Finally found a good use for my new Xerox
WorkCenter.
To bring you up to date, I filed a letter Monday with the Court
asking Judge Whyte to recuse himself because he or his clerk are
likely to be called as witnesses. Judge Whyte could have acted on
that letter and recused himself on his own motion, but he decided it
would be better to have me make the motion, and kindly pointed me to
the correct section of the United States Code. His clerk informed me
late Tuesday afternoon. So here it is Wed. morning, and I have these
printed up on the *nicest* crisp legal paper you can imagine.
Hacking the legal system is *fun*, much like finding bugs in software.
Keith Henson
PS, I would have called it a motion to recuse, but hey, who am I to
argue with *Benders Federal Forms*? They call it a motion to dismiss.
---------
Thomas R. Hogan, SBN 042048
LAW OFFICES OF THOMAS R. HOGAN
60 South Market Street, Suite 1125
San Jose, CA 95113-2332
(408) 292-7600
Roger M. Migrim
William M. Hart
PAUL, HASTINGS, JANOFSKY & WALKER
399 Park Avenue Thirty-first floor
New York, New York 10022-4697
(212) 318-6000
Helena K. Kobrin, SBN 152546
7629 Fulton Avenue
North Hollywood, CA 91605
(213) 960-1933
Attorneys for Plaintiff
RELIGIOUS TECHNOLOGY CENTER
H. Keith Henson
799 Coffey Ct.
San Jose, CA 95123
(408) 521-0614
pro se
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
RELIGIOUS TECHNOLOGY CENTER, a ) Case No. C-96-20271RMW
California non-profit corporation, )
Plaintiff, )
)
v. ) MOTION TO
) DISMISS
H. KEITH HENSON, an individual, )
Defendant. )
)
____________________________________
Defendant shows that the Honorable Ronald M. Whyte
is disqualified from presiding as judge at the trial of the
above numbered and entitled cause under the provisions of
Title 28, United State Code, Section 455, due to his
knowledge that he or his clerk are likely to be called as a
material witness in the proceeding, as more fully set forth
in the affidavit attached hereto and made a part hereof.
Wherefore, Defendant moves that the Honorable Ronald
M. Whyte declare himself disqualified to sit on the hearing
of this cause and that another judge be assigned to hear
this action.
Dated April 9, 1996
H. Keith Henson
799 Coffey Ct.
San Jose, CA 95123
[boilerplate parties copy cut]
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
RELIGIOUS TECHNOLOGY CENTER, a ) Case No. C-96-20271RMW
California non-profit corporation, )
Plaintiff, )
) AFFIDAVIT--IN SUPPORT
) OF MOTION TO DISQUALIFY
v. ) JUDGE [28 USCS SECTION
) 455(a)]
H. KEITH HENSON, an individual, )
Defendant. )
)
____________________________________
I am the Defendant in the above numbered and
entitled cause.
Judge Ronald M. Whyte or his clerk are likely to be
called as material witnesses in the above numbered and
entitled cause and is therefore disqualified to act in the
above numbered and entitled cause under the provisions of
Title 28, United Stated Code, Section 455(a)(iv).
Plaintiffs filings in this case makes note of events
involving Judge Whyte or his court throughout.
Judge Whyte is known to have been aware of the only
substantive matter Plaintiffs raise (the letter to Judge
Whyte of March 26, 1996 posted to the Internet on March 30,
1996). Judge Whyte did not object to letter when defendant
presented himself to Judge Whyte's clerk after the TRO
hearing for Grady Ward (C-96 20207 RMW) on March 29, 1996.
This may not imply approval, but it certainly is a material
fact in determining Defendants state of mind and motive at
the point Defendant posted letter.
Additionally, Defendant would like to bring up the
point that while Defendant could not show Judge Whyte to be
biased toward Plaintiffs in his rulings, Judge Whyte has not
been effective in enforcing Court orders of many months
standing for the Plaintiffs to relinquish the fruits of the
writ of seizure Judge Whyte later decided was an
unconstitutional violation of Mr. Erlich's rights in case
C95-20091 RMW.
Unfortunately, Judge Whyte is far from being the
only Judge who has had great problems in bringing Church of
Scientology Plaintiffs into line.
Dated April 9, 1996
H. Keith Henson
799 Coffey Ct.
San Jose, CA 95123
Sent by email to
h...@netcom.com
hkhe...@netcom.com (Keith Henson) wrote:
>H Keith Henson (hkhe...@shell.portal.com) wrote:
>
>: And, yes, I am still looking for NOTs or AT materials which show the
>: criminal or fraudulent nature of Scientology.
>
>Not until the TRO is lifted. Even if someone sent me an official CoS
>manual on how to murder (with case examples) I could not disclose it.
I am not (AFAIK) subject to the terms of any such TRO. If anyone wants
to supply me with Scientology documents which advocate criminal acts,
I will do what I can to publicise them, subject to the appropriate
copyright laws, but bearing in mind that, in the UK at least, public
interest considerations can override such things.
Legitimately obtained NOTs materials will, of course, still be equally
welcome.
- --
Steve: SP4 and Clam Cluster with Bar, KoX, KOh, Institutional Case #364
Minister in the First Electronic Church of SCAMIZDAT,
High Grand Pappadum of the Church of the SubGenius.
I thought...Bob had fallen and he couldn't get up? [on Bob Penny, MS victim]
-- "Vera Wallace", official CoS stooge showing Scientology's caring side.
A good home awaits a NOTS pack available for legal adoption. Apply by email...
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> hkhe...@netcom.com (Keith Henson) wrote:
>
> >H Keith Henson (hkhe...@shell.portal.com) wrote:
> >
> >: And, yes, I am still looking for NOTs or AT materials which show the
> >: criminal or fraudulent nature of Scientology.
> >
> >Not until the TRO is lifted. Even if someone sent me an official CoS
> >manual on how to murder (with case examples) I could not disclose it.
>
I thought the TRO only concerned AT and NOT stuff. If documents detailing
criminal actions came out of the law office of Scientology, would the TRO
cover that? Assuming it was not labeled part of NOTs. What if you got
a memo detailing the actions that Ingram should take when he visits the
home of Grady's mother?
--
John "don't send me NOTs, send the juicy stuff" Drake
[snip]
: PS, I would have called it a motion to recuse, but hey, who am I to
: argue with *Benders Federal Forms*? They call it a motion to dismiss.
[snap]
To keep you up on the saga, I got the expected reply to my motion to
recuse Judge Whyte. So, I responded at length. Here it is for your
enjoyment. If the scanner works smoothly, I might be able to post
what I was responding to. Otherwise, I am off to bed, let you know
how things go tomarrow. Keith Henson
[snipped boilerplate]
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
RELIGIOUS TECHNOLOGY CENTER, a ) Case No. C-96-20271RMW
California non-profit corporation, )
Plaintiff, )
) REPLY TO PLAINTIFF'S
) OPPOSITION TO MOTION TO
) RECUSE (WAS "DISMISS")
v. )
)
H. KEITH HENSON, an individual, )
Defendant. )
)
____________________________________
Defendant apologies for the inaccurately titled
"Motion to Dismiss," and attaches a copy of page 222 in
*Benders Federal Forms* on which may be found what defendant
suspected was a typographical error.
Defendant agrees in part with Plaintiff's council.
Per the claim by plaintiffs that "the court itself
apparently did not speak with Henson," defendant concurs.
However, the court's clerk did indicate before witnesses
that Judge Whyte had read defendant's letter of March 26,
and accepted the letter from Arnie Lerma which was promised
in the next to last paragraph of the "Open Letter" as if it
were expected.
The clerk took the Lerma letter to Judge Whyte, and
returned after five to ten minutes.
Defendant understands the reluctance of the Court to
provide guidance to those who seek it, since Courts would be
overwhelmed with such requests. This is, however, an
unusual case, as the Court must know by now, and in that
letter, defendant raised serious constitutional issues.
Defendant, and thousands of others on the Internet,
would have been very interested in either a "Yes copyright
or trade secret law can be used" or "No such laws cannot be
used," answer to the question implied at the end of the
second paragraph after defendant's fair use quoting of NOTs
34:
"Forbidding discussion of this particular document,
including quoting it entirely, is clearly against the
public interest, as well a violation of my First
Amendment rights. Unless, of course, copyright law can
be used to prevent disclosure of instructions for
criminal activity."
Defendant will again seek the guidance of the court
in open hearing because Defendant and many others are
confused and in need an answer to the above question.
However, the clerk of the court answered to
defendant's satisfaction by declaring that defendant (at
that time) was emphatically *not* a defendant, and therefore
not covered by the TRO issued against Grady Ward. Defendant
therefore made the assumption that defendant could post NOTs
34 which amounts to criminal instructions, *and* is a clear
violation of Judge Gesell's order from 1971 (333 F. Supp
357), and seek similar material, if any exists, as an
exercise of defendant's rights under the First Amendment.
It was, therefore, a considerable surprise for
defendant to be served by plaintiffs for activities which
were sincerely believe by defendant to be protected under
the provisions of the First Amendment.
What defendant is alleged to have done is entirely
contained within the pages of the pleadings, attached to the
declaration of Warren McShane as Exhibits 1 and 3. In
addition, exhibit 1 was hand delivered to the court four
days before being posted, and exhibit 2 was copied to the
court on the day it was posted. Plaintiff's pleadings are
*quite* at odds with what is contained in exhibits supplied
by Plaintiffs.
For example, Warren McShane's declaration, page 2
lines 11 and 12 quote defendant as "publicly seeking more
NOTs material, *stolen or not*" while leaving off the rest
of the sentence "which describe criminal activities."
Compare line 24 of page 2 and line 1 of page 3, with
the edited deposition "to show that plaintiffs is 'criminal'
. . 'overrides commercial copyright considerations'" with
what defendant wrote:
"It is my intent to POST and discuss any part of NOTs
which amount to manuals for criminal activities. Such
discussions are in the public interest, which overrides
commercial copyright considerations."
The other substantive accusations are of the same
caliber. Defendant has been posting on the internet for
some years and knows that selectively cut, out-of-context
quoting of others writing such as has been done in pleadings
would cause the perpetrator to be "flamed."
(Defendant wonders if plaintiff's strategy of
burying defendants words in a two inch stack of paper was
designed to discourage the court from comparing defendants
Internet postings with plaintiff's accusations?)
Plaintiff claims that defendant has solicited the
remaining 49 (or 47) NOTs. Plaintiff may be correct, since
plaintiff knows the contents of this material and defendant
does not, but it should be noted that defendant is not even
slightly interested in receiving, posting, or commenting on
NOTs or other "AT" materials which are non-criminal in
nature.
It should not take a Supreme Court appeal to decide
that First Amendment exercise of free speech, and free
press, explicitly for the exposure of criminal activities
such as those described in NOTs 34, takes precedence over
copyright and trade secret laws.
In spite of Plaintiff's effort to make this a
copyright/trade secret case, it is *not* one.
With respect to defendants claim this Court "has not
been effective in enforcing court orders to return materials
to Dennis Erlich," defendant suggest the court ask Mr.
Erlich or his attorneys what has yet to be returned to him.
Mr. Erlich thinks he is entitled to the return of notes
taken during the seizure, video tape of the seizure, a tape
of a KFI debate, his January 1995 bank statement, an
original disk and hard copy of "Class A Assist," and about
half dozen other items. Mr. Erlich did not ask for the
return of hair taken from his hairbrush.
It is worth noting that plaintiff's council makes no
comment about the problems Judges have in bringing Church of
Scientology plaintiffs into compliance with their orders.
If the Court needs an additional reason to recuse
under the provisions of Title 28, USC Section 455(b), the
Court could consider the potential consequences of Title 42
Sections 1983, 1985, and related civil rights laws. This is
a difficult area of the law, certainly beyond defendant's
competence, but judicial immunity under such statues may not
be absolute when it involves deprivation of a
constitutionally protected interest.
Finally, a "Church" which is reputed to spend over
$10,000,000 a year in court fights has a lot of gall
claiming that *defendant* is imposing on judicial resources.
The motion to recuse should be approved.
DATED: April 12, 1996
>Not until the TRO is lifted. Even if someone sent me an official CoS
>manual on how to murder (with case examples) I could not disclose it.
If you have a copy of El Cagon's "How to murder" pamphlet, or know
where I can get my hands on one, please rush the info to me.
Other wierdo's hate materials not desired.
Rev. Dennis L Erlich * * the inFormer * *
<dennis....@support.com>
<inF...@primenet.com>
That's her office address and phone? I hope no one decides to abuse that information. I don't
know if filling out those response cards in the back of magazines in order to send a ton of junk
mail (which I read about on S. Fishman's "real" home page) but it certainly is harassment and
I would hope no one on this group would sink to that level.
John Drake <j...@pell.interpath.com> wrote:
>
>
>> hkhe...@netcom.com (Keith Henson) wrote:
>>
>> >H Keith Henson (hkhe...@shell.portal.com) wrote:
>> >
>> >: And, yes, I am still looking for NOTs or AT materials which show the
>> >: criminal or fraudulent nature of Scientology.
>> >
>> >Not until the TRO is lifted. Even if someone sent me an official CoS
>> >manual on how to murder (with case examples) I could not disclose it.
>>
>
>I thought the TRO only concerned AT and NOT stuff. If documents detailing
>criminal actions came out of the law office of Scientology, would the TRO
>cover that? Assuming it was not labeled part of NOTs. What if you got
>a memo detailing the actions that Ingram should take when he visits the
>home of Grady's mother?
Well, since a) I'm not subject to the TRO, and b) (as you say) not all
incitements to commit criminal acts are necessarily contained within
the NOTS materials, I can't see a problem.
Although IANAL (how could I be, between representing the cabal of
Black Lesbian Jewish Psychs, ARSCC, and Suppressives Anonymous), it is
my belief that in the UK, such incitements would be themselves
criminal acts, defined as procuring or inciting an offence to be
committed. I suspect the English courts would be less than sympathetic
to an organisation which attempted to use them to cover up evidence of
such criminal intent.
- --
Steve: SP4 and Clam Cluster with Bar, KoX, KOh, Institutional Case, Member
of the Golden Gate Bridge Club #6, Minister in the First Electronic Church
of SCAMIZDAT, High Grand Pappadum of the Church of the SubGenius.
I thought...Bob had fallen and he couldn't get up? [on Bob Penny, MS victim]
-- "Vera Wallace", official CoS stooge showing Scientology's caring side.
A good home awaits a NOTS pack available for legal adoption. Apply by email...
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Thomas R. Hogan, SBN 042048
LAW OFFICES OF THOMAS R. HOGAN
60 South Market Street, Suite 1125
San Jose, California 95113-2332
(408) 292-7600
Roger M. Mugrim
William M. Hart
PAUL, HA~NGS, JANOFSKY & WALKER
399 Park Avenue Thirty-first floor
New York, New York 10022-4697
(212) 318-6000
Helena K. Kobrin, SBN 152546
7629 Fulton Avenue
North Hollywood, California 91605
(213) 960-1933
Attorneys for Plaintiff
RELIGIOUS TECHNOLOGY CENTER
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
RELIGIOUS TECHNOLOGY CENTER, a ) CASE NO. C96-20271 RMW
California non-profit corporation, )
OPPOSITION TO DEFENDANT'S )
Plaintiff, )
) "MOTION TO DISMISS"
) (IN REALITY,
) MOTION TO RECUSE)
H.KEITH HENSON, an individual,
Defendant.
Plaintiff Religious Technology Center opposes defendant
Henson's motion to recuse, inaccurately denominated a "Motion to
Dismiss." Mr. Henson fails to state a colorable ground for recusal of
the Court, and his motion should be rejected.
Mr. Henson bases his motion on his conclusory, and seemingly
wholly erroneous, claim that the Court or the Court's clerk are likely
to be called as a material witness in this proceeding because the
subject matter of this case involves, inter alia a posting to the
Internet of one of RTC's unpublished copyrighted works in the context
of what Henson denominated an "open letter to Judge Whyte." Henson
also states that "he presented himself to Judge Whyte's clerk after
the TRO hearing" on March 29, 1996 in the pending case of RTC V. Grady
Ward, Case No. C96-20207 RMW EAI, and that "Judge Whyte did not object
to letter [sic]." The court itself apparently did not speak with
Henson or accept the letter. Henson's attempt to bootstrap his effort
to file a non-party communication to the Court in the War a
basis for recusal in the case against him is frivolous. All the more
so where it is based on the premise that Mr. Henson could lawfully
subpena the Court or that testimony other than Mr. Henson's as to his
own conduct and state of mind is needed.
This case, of course, has nothing to do with Henson's
"presentation" of himself to the Court's clerk, nor with the
Henson chose to denominate his posting as an "open letter to Judge
Whyte." Rather, the case concerns Henson's actual posting
proprietary materials to the Internet and with his open solicitation
on the Internet of additional RTC trade secret and copyright
materials, coupled with his threat to post them to the Internet.
Neither the Court nor the Court's clerk are potential witnesses to the
act of which RTC complains.
Mr. Henson also claims that this Court "has not been effective
in enforcing court orders" requiring RTC to return materials to Dennis
Erlich in RTC v. Erlich, Case No. C 95-20091 RMW EAI. His claim is
both irrelevant and incorrect. RTC has, in accordanceourt's
order, returned all required materials to Erlich's cou
Exhibit A, letter of transmittal.
This Court is familiar with the issues in this case precisely
because they are similar to those in the Ward and Erlich cases. Mr.
Henson's effort to recuse the Court is an obvious effort to impose on
judicial resources.
The motion to recuse should be denied.
DATED: April 11, 1996 Thomas R. Hogan
LAW OFFICES OF THOMAS R. HOGAN
Roger M. Mugrim
William M. Hart
PAUL, HASTINGS, JANOFSKY
& WALKER
-and-
Helena K. Kobrin
> Mr. Henson also claims that this Court "has not been effective
>in enforcing court orders" requiring RTC to return materials to Dennis
>Erlich in RTC v. Erlich, Case No. C 95-20091 RMW EAI. His claim is
>both irrelevant and incorrect. RTC has, in accordanceourt's
>order, returned all required materials to Erlich's cou
>Exhibit A, letter of transmittal.
Dennis, is this true?
Has it been returned?
-Jeff Bell
hkhe...@shell.portal.com (H Keith Henson) wrote:
>This is being posted out of order. Sorry, I am still getting used to this
>scanner. Keith
>
[snip]
>
>UNITED STATES DISTRICT COURT
>NORTHERN DISTRICT OF CALIFORNIA
>RELIGIOUS TECHNOLOGY CENTER, a ) CASE NO. C96-20271 RMW
> California non-profit corporation, )
>OPPOSITION TO DEFENDANT'S )
>Plaintiff, )
> ) "MOTION TO DISMISS"
> ) (IN REALITY,
> ) MOTION TO RECUSE)
[and then]
> Plaintiff Religious Technology Center opposes defendant
>Henson's motion to recuse, inaccurately denominated a "Motion to
^^^^^^^^^^^^^^^^^^^^^^^^^
>Dismiss." Mr. Henson fails to state a colorable ground for recusal of
>the Court, and his motion should be rejected.
What sort of "religion" is it whose dupes and lawyers have to stoop to
cheap shots like this? H Keith may possibly, in someones opinion at
least, have been foolhardy to face the legal steamroller of
Scientology, but one cannot but admire the moral purpose of one who
makes such a stand.
- --
Steve: SP4 and Clam Cluster with Bar, KoX, KOh, Institutional Case, Member
of the Golden Gate Bridge Club #6, Minister in the First Electronic Church
of SCAMIZDAT, High Grand Pappadum of the Church of the SubGenius.
"I thought...Bob had fallen and he couldn't get up?"
[on Bob Penny, MS victim]
-- "Vera Wallace", CoS stooge, showing Scientology's caring side.
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[snip boiler plate]
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
RELIGIOUS TECHNOLOGY CENTER, a ) Case No. C-96-20271RMW
California non-profit corporation, )
Plaintiff, ) AFFIDAVIT IN
) SUPPORT OF
) REPLY TO PLAINTIFF'S
) OPPOSITION TO MOTION TO
) RECUSE (WAS "DISMISS")
v. )
)
H. KEITH HENSON, an individual, )
Defendant. )
)
____________________________________
1. Defendant incorporates defendant's filing
of April 12 as if April 12 filing were fully set forth
herein.
2. Defendant places objection on the record to
Plaintiff's failure to notify re related cases. Had
defendant known the location and time of Grady Ward
deposition in a case Plaintiff related, defendant would have
attended as pro se for defendant's related case.
3. Defendant calls the Court's and council's
attention to an error in plaintiff's motion to relate. The
motion has an incorrect party named in case C-96-20291 RMW.
4. Defendant further calls the Court's and
council's attention to the postmark time and date of the
notification by mail of related cases sent by plaintiff.
5. Defendant requests that Grady Ward be
notified as to time and place of defendant's deposition.
Mr. Ward's attendance at that deposition (if Mr. Ward
chooses to attend) will not be considered to be the person
of defendant's choice whom the court has permitted to attend
defendant's deposition.
6. Defendant seeks the Court's indulgence to
call the Court's attention to the words RTC President Warren
McShane spoke before witnesses, including plaintiff's
council Thomas Hogan after April 12 hearing. Defendant
spoke at April 12 hearing of deposing person defendant
believes to be the *real* head of RTC, David Miscavage. Mr.
McShane approached defendant at the point defendant and
plaintiff's council Thomas Hogan had agreed upon a time for
defendant's deposition stating: "You're dreaming if you
think you will depose Miscavage!" Defendant immediately had
Mr. McShane confirm these words before witnesses, including
a journalist and a law student. Affidavits will be obtained
from these persons if the Court finds these affidavits are
required to establish this event on the record.
7. Defendant's ex-wife reports contact with
plaintiff's investigative operatives who were attempting to
obtain "dirt" on defendant. An affidavit will be obtained
from defendant's ex-wife if the court finds an affidavit is
required to establish this event on the record.
8. Plaintiff's family of organizations is well
known for attacking defendants outside the legal system, a
policy of unknown name, formerly known as "fair game." That
this policy exists or has existed in the past is a fact well
established in a long list of court cases. Defendant would
quote from court documents the copyrighted policy letters of
plaintiff on plaintiff's "fair game" policy within this
affidavit if defendant were not concerned about possible
violations of the preliminary injunction issued against
defendant by this Court.
Defendant feels the need to request a protective
order from this Court that plaintiff, and those acting in
concert with plaintiff, particularly Gene M. Ingram and
those under his control, refrain from harassing defendant,
organizations profit and non-profit in which defendant is an
officer or board member, defendant's friends, defendant's
neighbors, defendant's clients, defendant's family members,
including but not limited to parents, children minor and
adult, and former wife, and from engaging in character
assassination of defendant during the pendency of this case.
Defendant is confused by the bewildering array of
legal forms and does not wish to make legal errors. Thus
defendant seeks the indulgence of the Court as to the name
of the appropriate form recognized by this Court for this
purpose which defendant should file to obtain such a
protective order.
I declare under penalty of perjury under the laws of
the United States that the foregoing is true and correct.
Signed this 16th day of April, 1996 at San Jose,
California.
H. Keith Henson
[from scientology motion]
: > Plaintiff Religious Technology Center opposes defendant
: >Henson's motion to recuse, inaccurately denominated a "Motion to
: ^^^^^^^^^^^^^^^^^^^^^^^^^
: >Dismiss." Mr. Henson fails to state a colorable ground for recusal of
: >the Court, and his motion should be rejected.
: What sort of "religion" is it whose dupes and lawyers have to stoop to
: cheap shots like this?
Not just the cult, legalesse is just like this. The amusing thing is that
I was nearly certain it should have been "recuse," and that it was a typo
in *Benders Federal Forms.* When I replied, I stuck on a copy of the page.
H Keith may possibly, in someones opinion at
: least, have been foolhardy to face the legal steamroller of
: Scientology, but one cannot but admire the moral purpose of one who
: makes such a stand.
Don't make that big a deal out of it. Defending Constitutional rights
may be a high moral purpose, but it is also a lot of fun. Compared to
my other past and present hobbies, it fits right in. Keith Henson
In the grand and glorious net tradition of posting abusive mail (and
mail from opposing lawyers is often abusive) try this on for size.
Keith Henson
>LAW OFFICES OF
>Thomas R. Hogan
>60 SOUTH MARKET STREET, SUITE 1125
>SAN JOSE, CALIFORNIA 95113-2332
>
>April 17, 1996
>
>Via Facsimile and U.S. Mail
>
>Randoif J. Rice, Fsq.
>The Genesis Law Group, LLP
>160 West Santa Clara Street, Suite 1300
>San Jose, California 95113
>
>Re:
>Religious Technolo~v Center, et al., V. Netcom, et al.
>
>Dear Randy:
>
> This responds to your letter of April 9, 1996, addressed to Judge
>Whyte. Although we did supply you with copies of the moving papers in
>both the Ward and Henson cases, we acknowledge that service of the
>Notice Of Related Case upon all parties may not have been as prompt as
>contemplated by Rule 3-12, with proper service effected on all parties
>on April 11, 1996.
That's interesting. My copy of the notice is dated Friday, April 12,
and postmarked the afternoon after the morning where I brought up the
matter of notice up in front of the Judge Whyte. Looks like Tom's
office staff is unwilling to backdate legal notices. I am more than a
little amazed that Hogan would put the 11th in writing after I asked
the Judge Whyte to make note of the date on the form, and gave Judge
Whyte the envelope with the postmark on it. Is there a limit on how
far a lawyer can abuse his good relations with a judge?
By the way, Hogan really should correct the parties on the notice.
RTC is not suing Bridge Publication, at least not yet.
Notice Of Related Case was filed in Ward on
>March 21, and in Henson, on April 4, 1996.
>
> With respect to discovery in these related cases, we have begun
>the deposition of Grady Ward on April 8 and 9, with the expectation
>that an additional day may be required. As you know, we expect the
>deposition of Mr. Henson will be ordered on a date in early May, 1996.
What kind of a game is Mr. Hogan playing here? He has known since a
few minutes after the hearing that the date for my deposition is set
for May 8, at his office. He sent me a copy of the page we signed
with this date on it several days ago. It make me wonder if he is
trying to give so little notice that the other interested parties
cannot clear the time to come.
>We will certainly supply you with the names of the reporting services
>should you wish to obtain copies of the transcripts.
>
> In the future, as we have advised Judge Whyte at the hearing in
>the Henson matter on Friday, we will provide notice to all parties of
>any notices, motions or discovery requests that may be filed in these
>related cases.
Right. Hogan could see me leading into the question of why if *I* had
to notify the other related parties, why had RTC and their pack of
lawyers not notified the other parties as the rules of the court
require?
If Hogan were not being such a weasel with this letter, I would not
bring up his giving Judge Whyte a letter at the hearing explaining why
NOTs 34 is not a criminal instruction document, and not providing *me*
a copy. Well, I asked for it yesterday, Mr. Hogan said he would put
it in the mail that day, and *this* letter from him *did* get here.
Guess I will have to stop in at his office and get a copy tomorrow.
I am *sure* the ars folks will find this document of considerable
interest.
>Very truly yours,
>
>Thomas R. Hogan
>cc:
>
>Hon. Ronald M. Whyte
>Daniel A. Leipold
>Carla B. Oakley
>Melissa A. Burke
>Grady Ward
>H.Keith Henson
H Keith Henson (hkhe...@shell.portal.com) wrote:
[...]
:
: Notice Of Related Case was filed in Ward on
And Hon. Ron Whyte accepted evidence relating to the prosecution of you,
and allowed the plaintiff not to provide you with it? Is this not
judicial misconduct?
I think--as the 9th Circuit Court of Federal Appeals wrote "[the Church
of Scientology has been playing] fast and loose with the judicial system."
The scary part is that Hon. Ron Whyte is sitting back letting it all
happen.
Keith, I think you should appeal the restraining order, and possible
courtroom misconduct to the 9th Circuit.
Tom Klemesrud SP5
KoX
: H Keith Henson (hkhe...@shell.portal.com) wrote:
: [...]
[snip]
: : If Hogan were not being such a weasel with this letter, I would not
: : bring up his giving Judge Whyte a letter at the hearing explaining why
: : NOTs 34 is not a criminal instruction document, and not providing *me*
: : a copy. Well, I asked for it yesterday, Mr. Hogan said he would put
: : it in the mail that day, and *this* letter from him *did* get here.
: : Guess I will have to stop in at his office and get a copy tomorrow.
: : I am *sure* the ars folks will find this document of considerable
: : interest.
: And Hon. Ron Whyte accepted evidence relating to the prosecution of you,
: and allowed the plaintiff not to provide you with it? Is this not
: judicial misconduct?
: I think--as the 9th Circuit Court of Federal Appeals wrote "[the Church
: of Scientology has been playing] fast and loose with the judicial system."
: The scary part is that Hon. Ron Whyte is sitting back letting it all
: happen.
: Keith, I think you should appeal the restraining order, and possible
: courtroom misconduct to the 9th Circuit.
Tom, I think you put your finger on the proper course for me to try.
I dug up the forms involved, and it doesn't look all that complicated.
I suspect that the 9th Circuit is a bit more familiar with the CoS
having just issed the Mayo decision. If any of you net.lawyers have
a sample appeal of an injunction, let me know and I will give you
my fax machine #. Also, I am going to file a motion to suspend part
of the Rule 30 conditions to take into account the barbaric behavior
of CoS investigators such as Gene Ingram. I will post a draft for
comment before I file it, but I know I am going to need hardcopy
signed affidavits from people who have been hasseled by the likes
of Gene Ingram.
Final point, is there any way I can use the judicial discovery
process to find out about the missing people in Scn? I suspect I
can tie it into my defense. I am aledging criminal behavior on the
part of CoS, so I should be able to investigate through discovery
and deposition the fate of Annie and Pat, not to mention -AB-. It
also seems like anything I find out this way should go directly to
a grand jury. Keith Henson