Rule 60 Opposition
Just picked this up from Hogan's office late today. I know a bunch of
people wanted to see it, and I can use suggestions on how to reply.
The section near the end trying to get me declared a "vexatious
litigant" is particularly twisted. One would think that *I* had filed
a whole series of cases against RTC instead of them filing no fewer
than 4 against me. I have never filed a case against any scientology
operation -- though the one I filed against the IRS might have much the
same effect. (The ARSCC awards committee agreed that filing against
the IRS to get the courts to support the Supreme Court and revoke
scientology's tax status rated me an SP 7.)
Another point to ponder is the description in this opposition paper
of Mr. Cipriano "retaining" Mr. Moxon. (Compare with the declaration.)
I believe such behavior is grounds for disbarment.
RTC's oppostion is remarkable for what is *not* in it. There are no
declarations from Mr. Moxon, Mr. Rosen, Mrs. Kobrin, or even Mr. Hogan
denying declarations from Mr. Cipriano, Mr. Ward, or Mr. Berry.
However, if you grep on "false" you will find that RTC generally denies
the declarations: "a series of allegations that are irrelevant, immaterial,
inflammatory, and indeed fantastic, not to mention false."
Does this set up the necessary contested facts for an evidentiary hearing?
I believe June 16 is an open date for everyone--though I would be open to
other offers.
Keith Henson
Samuel D. Rosen
PAUL, HASTINGS, JANOFSKY & WALKER LLP
399 Park Avenue, Thirty-first floor
New York, NY 10022-4697
(212) 318-6000
Helena K. Kobrin, SBN 152546
MOXON & KOBRIN
3055 Wilshire Blvd., Suite 900
Los Angeles, CA 90010
(213) 487-4468
Eric M. Lieberman
RABINOWITZ, BOUDIN, STANDARD,
KRINSKY & LIEBERMAN, P.C.
740 Broadway, 5th Floor
New York, New York 10003
(212)254-1111
Attorneys for Plaintiff
RELIGIOUS TECHNOLOGY CENTER
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
RELIGIOUS TECHNOLOGY CENTER, ) CASE NO. C-96-20271 RMW (EAI)
a California non-profit corporation )
) PLAINTIFF'S OPPOSITION TO
Plaintiff, ) DEFENDANT'S MOTION UNDER
) RULE 60(b)(3), RULE 60(b)(6)
AND
vs. ) FRAUD ON THE COURT
)
H. KEITH HENSON, an individual, )
)
Defendant. )
INTRODUCTION
Henson's motion for relief under Fed. R. Civ. P.60(b) is
nothing more than a continuation of his frivolous litigation
misconduct. The motion merely rehashes unfounded allegations, none of
which have anything to do with the judgments in this case, or come
anywhere close to impigning the underlying copyright and contempt
judgments. Henson's motion is symptomatic of his entire history of
litigation misconduct, throughout which he has burdened this Court and
the Court of Appeals, as well as RTC and its attorneys, with numerous
frivolous filings, including a motion to recuse Judge Whyte, baseless
counterclaims that were dismissed, motions for summary and declaratory
judgment that were denied, motions to modify or vacate the
preliminary injunction that were also denied, and four appeals to the
Ninth Circuit.[1] His other meritless conduct has included forcing this
Court to issue a contempt sanction for violation of a court order,
and to expand on the preliminary injunction order on numerous
occasions due to Henson's violations or threatened violations. This
latest Rule 60(b) motion must be seen in the light of this long line
of earlier abusive litigation tactics. As Henson has boasted, his
misconduct has been intentionally aimed at squandering judicial and
RTC resources. RTC specifically requests that this Court take
measures to put an end to Henson's wasteful misconduct now.
L THE MOTION FAILS TO MEET THE STANDARDS FOR RELIEF UNDER RULE
60(b) (3), BECAUSE IT IS UNTIMELY AND NONE OF ITS ALLEGATIONS ARE
RELEVANT TO THE GROUNDS FOR THE UNDERLYING JUDGMENT.
A motion under Rule 60(b) (3) must be made within "one year
after the judgment, order, or proceeding was entered or taken."
Fed.R.Civ.P. 60(b). There are no exceptions to this rule. Thus, as a
matter of law, under Rule 60(b) (3), Henson may not request relief
from the substantive judgment in the copyright case, which was entered
more than a year ago (on May 14, 1998); rather, he can only request
relief from the contempt judgment.
Under Rule 60(b) (3), "a party has no right to relief." 12 J.
Moore, Moore's Federal Practice 60.22 (3d ed. 2000), at 60-65.
Rather, "[m]otions for relief from judgment pursuant to Rule 60(b) of
the Federal Rules of Civil Procedure are addressed to the sound
discretion of the district court."
----------------
Footnote
1 We have chosen not to further burden the Court with
declarations, affidavits and attachments of documents with which it is
well acquainted. All factual references are to matters in the record.
--------------------
Ailmerica Financial Life Insurance and Annuity Co. V. Llewellyn, 139
F.3d 664, 665 (9th Cir. 1997) (emphasis added). The moving party has
the burden of establishing, "by clear and convincing evidence," that
the judgment was obtained through fraud, misrepresentation, or other
misconduct of an adverse party. De Saracho v. Custom Food Machinery,
Inc., 2000 WL 235304, *5 (9th Gr. March 3, 2000). A causal nexus must
be established, such that the conduct complained of actually
"prevented the losing party from fully and fairly presenting his
[case]." Id. The alleged misconduct must always pertain to the
litigation process itself, whether during trial or in pretrial
proceedings. See, e.g., In re MA' Peacock, 809 F.2d 1403, 1405 (9th
Cir. 1987) (failure to disclose material issue did not support relief
because moving party had incentive to investigate the issue and could
have done so notwithstanding the failure to disclose); De Saracho,
2000 WL 235304 at *5 (withholding of information called for in
discovery); Diaz v. Methodist Hosp., 46 F.3d 492, 497 (5th Cir. 1995)
(willful perjury at trial); Londorf V. Seefeldt, 47 F.3d 893, 897-88
(7th Cir. 1995) (defense in employment discrimination action based on
falsified documents).
The litigation misconduct, moreover, must have been "harmful"
to the extent of "affect[ing] the substantial rights" of the movant in
that litigation. Anderson v. Beatrice Foods Co., 862 F.2d 910,924 (9th
Cir. 1988). In Anderson, the movant requested relief under Rule 60(b)
(3) on the ground that the adverse party had withheld material called
for in discovery. The court held that relief would only be appropriate
if "the challenged behavior... substantially... interfered with the
aggrieved party's ability fully and fairly to prepare for and proceed
at trial." Id. (emphasis added); see also West v. Love, 776 F.2d 170,
176 (7th Cir. 1985) (although misconduct was clear, it did not prevent
plaintiff from fully and fairly presenting his case because it was
irrelevant to the incident at issue at the trial).
None of Henson's allegations could possibly be a ground for
relieving him from :he con tempt judgment, let alone constitute "clear
and convincing evidence."2 As the Court will recall, Henson was held
in contempt for his admitted posting on the internet of testimony
sealed by court order. Henson offers no evidence -- let alone clear
and convincing evidence -- of any fraud, misrepresentation, or
---------
Footnote
2 Nor, for that matter (and for the same reasons), could they
possibly be grounds for relief from the copyright judgment, even had
Henson's motion been timely.
------------
misconduct by RTC remotely related to the contempt sanction, but only
a series of allegations that are irrelevant, immaterial, inflammatory,
and indeed fantastic, not to mention false.3 They are precisely the
same type of irrelevant allegations that Henson has been reiterating
throughout this proceeding, and which led this Court, during the
hearing of May 5, 1998, to admonish that "this is not a case about
whether or not... Scientologists are good or bad people or have proper
or improper beliefs or have done good or bad things in various parts
of the country."
Moreover, many of Henson's allegations (for example, that
Scientologists, including Mr, Ingram, engaged in various forms of
illegal conduct, or that Mr. Rosen threatened and bullied Mr. Berry
during trial) were already specifically argued by Henson before this
Court. And Henson and Berry were obviously aware before trial in 1998
of any alleged distractions caused by lawsuits against Henson 4 or
Berry's own lawsuit against Cipriano, including any alleged conduct of
Mr. Moxon or Mr. Ingram. Indeed, Henson admits that he was at that
time engaged in picketing against Scientology. Thus, these stale,
rehashed allegations prove nothing more than Henson's willingness to
impose additional costs on
--------------
Footnotes
3 Henson also sought to introduce the declaration of Robert
Cipriano in support of his appeal to the Ninth Circuit of this
Court's contempt judgment. RTC moved to strike the declaration on the
grounds that it had "no bearing" on any of the issues before the Court
and was not part of the record below. By Order of December 3,1999, the
Court granted the motion. As to that Declaration, the Court should
note that, by his own admissions, Cipriano is a convicted criminal and
an admitted parole violator, who has been repeatedly involved with
business frauds (for which he, of course, claims never to be
responsible) and drug abusers. Moreover, the Declaration is explicit
that the only involvement of Mr. Moxon or Mr. Ingram with Berry during
the period Berry represented Henson in the copyright and contempt
proceedings resulted because Berry sued Cipriano, and Cipriano
retained Mr. Moxon to defend him. Thus, any claim that Mr. Moxon or
Mr. Ingram were responsible for any distraction of Berry is absurd&
4 Indeed, Henson asserted that it was on account of
"distraction" that he needed to dismiss the bankruptcy case he had
brought in February 1998, the day before trial was to commence, in
order to obtain the automatic stay.
5 If Berry was so distracted by litigation he had commenced
against Cipriano that he could not competently perform his
professional obligations, it was his professional responsibility, of
course, to remedy the situation, including, if necessary, by declining
to take the case. The notion that a Rule 60(b) motion is Henson's
proper remedy for Berry's alleged incompetence or professional
misconduct is frivolous. Moreover, if Berry believes he was libeled,
the proper remedy is for him to bring an action for libel, and not for
Henson to bring the present Rule 60(b) motion.
-----------------
the courts and RTC in a frivolous attempt to reopen and relitigate
issues decided in the copyright and contempt proceedings. See, e.g.,
11 Wright, Miller & Kane, Federal Practice and Procedure Civil 2d SS
2860 at 314 (1995) (the motion will be denied if it is "merely an
attempt to relitigate the case").6
Even if these frivolous allegations were true, they would
still be irrelevant, for none of them even remotely establishes fraud,
misrepresentation, or misconduct of an adverse party in the
litigation itself that undermines the contempt sanction. Henson
simply offers no evidence or reason to conclude that the alleged
third-party misconduct prevented him from fully and fairly presenting
his defense to the contempt proceeding. As for Henson's allegation -
completely unsupported by any evidence regarding the relevant time
periods - that his attorney was the victim of a campaign of libel that
"prevented" him from preparing for trial, there is no reason
whatsoever to believe that, in the absence of the alleged campaign,
the merits of the contempt issue would have been decided in any other
manner. Henson's "evidence" is simply not exculpatory, is wholly
unrelated to the litigation and has no relevance to Henson' 5 admitted
misconduct in posting sealed testimony to the Internet, the subject of
the contempt proceeding.1 None of his allegations, for example, even
remotely hint at a reason to believe that he did not conduct himself
in a negligent and inexcusable manner when he distributed documents
that were sealed under a court order. Therefore, Henson's request for
relief under Rule 60(b) (3) should be denied.
IL THE MOTION FAILS TO MEET THE STANDARDS FOR RELIEF UNDER RULE
60(b) (6), BECAUSE NONE OF ITS ALLEGATIONS CONTAIN ANY INDICATION
THAT THE UNDERLYING JUDGMENTS WERE ERRONEOUS.
Relief from judgment under Rule 60(b) (6) is an extraordinary
and rare remedy. Such relief is granted only "sparingly as an
equitable remedy to prevent manifest injustice... where extraordinary
-----------------
footnotes
6 The only example that Henson provides regarding the alleged
effect of the alleged distraction is that Berry missed the
"transforming" argument. The "transforming" argument is frivolous on
its face, and there is no evidence of even the remotest causal nexus
between Henson's allegations and the failure to raise this meritless
argument.
7 As this Court recognized, "[m]uch of what Henson tried to
do throughout the case was to turn the lawsuit into a trial of
Scientology. Therefore, many of the positions he took before trial and
much of what he and his counsel wanted to do, and to some extent did
do, during trial had no relevance to the pertinent issues." Order of
September29, 1998, at 2.
-----------------
circumstances prevented a party from taking timely action to prevent
or correct an erroneous judgment." United States',. State of
Washington, 98 F.3d 1159, 1163 (9th Cir. 1996) (emphasis added)
(quoting United States',. Alpine Land & Reservoir Co., 984 F.2d 1047,
1049 (9th Cir. 1993)). Thus. to qualify for Rule 60(b) (6) relief, the
moving party must demonstrate both injury in the form of an erroneous
judgment, and "that circumstances beyond its control prevented timely
action to protect its interests. Alpine Land, 984 F.2d at 1049. Here,
there has been no injury, for there has been no erroneous judgment.
None of Henson's allegations provide any reason whatsoever to believe
that he did not violate copyright law when he willfully distributed a
copyrighted, unpublished work on the internet (conduct this Court had
enjoined on the previous day in the Ward case). Moreover, as noted
supra, relief under Rule 60(b) is discretionary with the court.
Since Henson's allegations cannot possibly lead this Court to
conclude that it (or the jury) erred in ruling on the underlying
copyright and contempt issues, this is "not one of those rare cases
where 'extraordinary circumstances' warrant vacating an 'erroneous
judgment."' State of Washington, 98 F.3d at 1163. Moreover, where
parties have made deliberate litigation choices, Rule 60(b) (6)
should not provide a second chance." In re Pacific Far East Lines,
Inc., 889 F.2d 242, 250 (9th Cir. 1989). Henson's actions, as well as
his attorney's, were "free, calculated and deliberate," 11 Wright &
Miller, Federal Practice and Procedure: Civil 2d SS 2864 at 359
(1995), and nothing in Henson's motion or accompanying affidavits even
remotely indicates the contrary. Therefore, Henson's request for
relief under Rule 60(b) (6) should also be denied.
III. THE MOTION FAILS TO MEET THE STANDARDS FOR RELIEF UNDER 28 U.S.C.
SS 1655, BECAUSE IT DOES NOT ALLEGE ANY ATTEMPT TO IMPROPERLY
INFLUENCE THE COURT.
Finally, Henson appears to request relief for "fraud upon the
court" under 28 U.S.C. SS 1655. To qualify as "fraud upon the court,"
the alleged misconduct must "harm the integrity of the judicial
process [or the] administration of justice." In re Intermagnetics
America, Inc., 926 F.2d 912, 916 (9th Cir. 1991) (quoting Hazel-Atlas
Class Co. v. Hanford Empire Co., 322 U.S. 238, 246 (1944)). As the
Ninth Circuit has recently reiterated, "'[f]raud upon the court'
should... embrace only that species of fraud which does[,j or
attempts to, defile the court itself, or is a fraud perpetrated by
officers of the court so that the judicial machinery can not perform in
the usual manner its impartial task of adjudging cases that are
presented for adjudication." In re Levander, 180 F.3d 1114,1120 (9th
Cir. 1999) (emphasis added) (quoting 7 J. Moore &J. Lucas, Moore's
Federal Practice 60.33, at 515 (2d ed.1978). This "fraud upon the
court" exception is aimed at egregious and severe misconduct directed
against the very integrity of the Court, such as perjury where the
opposing party has no opportunity to challenge the truth of the
testimony. In re Levander, 180 F.3d at 1119. Here, Henson's motion
provides no reason or evidence to believe that the alleged actions
were "designed to improperly influence the court in its decision."
Alexander v. Robertson, 882 F.2d 421, 425 (9th Cir. 1989), 882 F.2d at
424 (emphasis added) In fact, none of the alleged actions had anything
to do with the grounds for this Court's decisions in the copyright and
contempt trials. It follows that the alleged actions could not have
"harmed the integrity of the judicial process." Therefore, Henson's
request for relief under 28 U.S.C. SS 1655 should also be denied.
IV. THE COURT SHOULD SANCTION HENSON, TO DETER HIM FROM FUTURE
ABUSIVE LITIGATION MISCONDUCT.
It should now be apparent that Henson has no intention to
cease his abusive litigation tactics. Neither repeated rulings against
Henson by this Court, the appellate courts, and a jury, nor a contempt
sanction, damages, injunctions and attorney's fees awards have had the
slightest impact on his willingness to abuse the judicial system. His
public statements that he views litigation against RTC and the
consumption of judicial resources as "entertainment," his abusive
taunts of this Court, and RTC's counsel, throughout the underlying
proceedings (among other instances, he boasted, after releasing sealed
documents on the internet in violation of this Court's order, that
RTC's attorney 'should now sue the Judge'), and this latest motion are
all part of a piece, with no end in sight.
In these circumstances, the Court should exercise its power to
impose sanctions under Rule 11 and 28 U.S.C. SS 1927. Under Rule
11(b), when a party signs a written motion and presents it to the
court, that person is representing that:
(1) it is not being presented for any improper purpose, such as to
harass or to cause unnecessary delay or needless increase in the cost
of litigation;
(2) the claims, defenses, and other legal contentions therein are
warranted by existing law or by a nonfrivolous argument for the
extension, modification, or reversal of existing law or the
establishment or new law; [and]
(3) the allegations and other factual contentions have evidentiary
support or, if specifically so identified, are likely to have
evidentiary support after a reasonable opportunity for further
investigation or discovery.
Fed. R. Civ. P.11(b).
Because Henson's Rule 60(b) motion is clearly frivolous,8
clearly without basis in law, and clearly lacking in any evidentiary
support, and was obviously filed for the improper purpose of harassing
RTC by increasing the cost of litigation, the Court may "[on] its own
initiative... enter an order describing the specific conduct that
appears to violate subdivision (b) and directing [a] party to show
cause, why it has not violated subdivision (b)." Fed. R. Civ. P.11(c)
(1) (B) .9 Under Rule 11(c) (2) Henson's violations of any of the
paragraphs of Rule 11(b) could, on the Court's initiative, be remedied
through the imposition of attorney's fees payable to RTC,'0 of a
penalty to be paid into the Court, or through "directives of a
nonmonetary nature."
Under these circumstances, nonmonetary directives should
include an order "restricting [Henson's right to file any further
civil actions or documents without this court's specific-. prior
approval or unless represented by a licensed attorney." Schweitzer v.
Maxwell, 1994 WL 780699, *2 (D. Mont. 1994). Such an order is clearly
called for in this case and is proper against litigants whose abuse of
this system will not be quelled in any other fashion. See, e.g.,
Weissman v. Quail Lodge i"c., 179 F.3d 1194,1197 (9th Cir. 1999)
(approving curtailing vexatious litigation through restrictive
pre-filing orders); Villar v. Crowley Maritime Corp., 990 F.2d
1489,1499 (5th Cir. 1993) (barring afl future
---------------
Footnotes
8 The word "frivolous" denotes a filing "that [is] both
baseless and made without a reasonable and competent inquiry." Buster
V. Oreisen, 104 F.3d 1186,1190 (9th Cir. 1997) (internal quotation
omitted). The standard applied when determining whether or not a
filing is frivolous is an "objective" one. In The Keegan Management
Co., 78 F.3d 431, 434 (9th Cir. 1996) (internal quotation omitted).
Under this standard, Henson's Rule 60(b) motion is plainly frivolous.
See also Townsend',. Holman Consuhing Corp., 929 F.2d 1358,1362 (9th
Cir. 1991) (noting that "[e]ither the improper purpose or
frivolousness ground is sufficient to sustain a sanction").
9 On account of time constraints under the briefing schedule,
RTC is unable to meet the 21- day safe-harbor provision of Rule 11(c)
(1) (A). Therefore, RTC urges that the Court should impose sanctions
on its own initiative.
10 Rule 11(c) (2) (A) states that "[m]onetary sanctions may
not be awarded against a represented party for a violation of
subdivision (b) (2)"; this clause, however, does not apply to Henson,
who is proceeding pro se. 1
----------------
litigation based on the same facts as within power of federal courts
"to enjoin plaintiffs who abuse the court system and harass their
opponents"), cert. denied, 510 U.S. 1044 (1994), abrogated on other
grounds by Marathon Oil Co. v. Pedergas, 145 F.3d 211 (5th Cir. 1995);
DeLong v. Hennessy, 912 I'.2d I 144, 1147 (9th Cir. 1990) (recognizing
strong precedent establishing the inherent power of federal courts to
regulate the activities of abusive litigants.. ., [including]
enjoining litigants with abusive and lengthy histories [as] one such
form of restriction that the district court may take."); In re
Martin..Trigona, 737 F.2d 1254,1261-63 (2d Cir. 1984) ("United States
Courts are not powerless to protect the public, including litigants...
from the depredations of those... who abuse the process of the Courts
to harass and annoy others with meritless, frivolous, vexatious or
repetitive ... proceedings.") (citations and internal quotes
omitted).
The Court is well aware of Henson's open admissions that he
finds litigation against RTC to be screamingly funny,"
"entertainment," and "a great game," and that his purpose is to
impose maximum litigation costs upon RTC. Henson continues to abuse
the judicial process in pursuit of this improper purpose with this
frivolous Rule 60(b) motion. He should not be permitted to do so in
the future.
Indeed, in state court proceedings against RTC, Henson's
occasional attorney Graham Berry has been declared a "vexatious
litigant" subject to pre-filing restrictions. See Order Finding Graham
E Berry To Be a Vexatious Litigant, Sup. Ct. Cal. No. BC 184355
(August 20, 1999).
Sanctions should also be imposed under 28 U.S.C. SS 1927,
which provides that:
Any attorney or other person admitted to conduct cases
in any court of the United States or any Territory thereof who so
multiplies the proceedings in any case unreasonably and vexatiously
may be required by the court to satisfy personally the excess costs,
expenses, and attorneys' fees reasonably incurred because of such
conduct.
Under Civil L. R, 3-9 (a), a party who is appearing pro se is bound by
the same rules that govern the conduct of attorneys appearing in this
Court. See Wages v. I.R.S., 915 F.2d 1230, 1235-36 (9th Cir. 1990) pro
se plaintiff sanctioned, because, "[he] evidenced bad faith in
multiplying the proceedings in this case 'unreasonably and
vexatiously"'); Eisen v. Curry, 14 F.3d 469, 471(9th Cir. 1994)
(same).
Finally, the Court clearly "has the inherent power to restrict
a litigant's ability to commence abusive litigation." Demos v. United
States District Court for the Eastern District of Washington, 925 F.24
1160, 1161(9th Cir.1991) (citing In re Mcdonald, 489 U.S. 180 (1989)).
"[D]istrict courts.. . bear an affirmative obligation to ensure that
judicial resources are not needlessly squandered on repeated attempts
by litigants to misuse the courts. Frivolous and harassing claims
crowd out legitimate ones and need not be tolerated repeatedly by the
district courts." O'Loughlin v. Doe, 920 F.2d 614, 18 (9th Cir
1990).11 Here, Henson's accumulated misconduct has plainly reached the
point of unreasonable vexatiousness, and the Court should deal with it
accordingly.
CONCLUSION
For the reasons stated herein, Henson's motion should be
denied, and appropriate sanctions should be imposed, including an
order prohibiting Henson from filing any further civil actions,
motions, or pleadings against RTC, or any Scientology-related entity,
without prior court approval. Dated: April 14, 2000 Respectfully
submitted,
LAW OFFICES OF THOMAS R. HOGAN
Thomas R. Hogan
Attorneys for Plaintiff
RELIGIOUS TECHNOLOGY CENTER
-------------
Footnotes
11 Beyond these federal authorities, the state of California
has provided a legislative mandate against tolerating abusive
litigation. California Code of Civil Procedure, section 391(b),
defines "vexatious litigant" as including two categories that clearly
describe Henson's conduct:
(2) After a litigation has been finally determined
against the person, repeatedly relitigate or attempts to relitigate,
in propria persona, either (i) the validity of the determination
against the same defendant or defendants as to whom the litigation was
finally determined...
(3) In any litigation while acting in propria
persona, repeatedly files unmeritorious motions, pleadings, or other
papers, conducts unnecessary discovery, or engages in other tactics
that are frivolous or solely intended to cause unnecessary delay.
Section 391.7(a) of the C.C.P. authorizes a court to issue a
"prefiling order requiring a person determined to be a vexatious
litigant to obtain leave to file new litigation from the presiding
judge of the court where litigation is proposed to be filed. In such
an instance, leave is to be granted, "only if it appears that the
litigation has merit and has not been filed for the purposes of
harassment or delay," and filings may be conditioned on the posting
of security. (Id., SS391.7(b).)
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Keith Henson <hkhenson@netcom3.netcom.com>
THOMAS R. HOGAN
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Sanjose,CA 95113
(408) 292-7600
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