From two letters apparently inadvertently (or purposely?) attached to the latest lawsuit against Keith Henson.
Please comment if you have any ideas on the disturbing implications of this letter. Also note in the Cc:s our old friend William Hart, Esq.
who you might recall from the dwarf deposition, in which he was not well shaved, looked like a ruffian, and was causing a disruption of the deposition.
The precedent cited in the letter is a deCSS case in which Pavlovich, an out-of-state student was sued in a California court despite not living there.
The cult may intend to play more of their fun forum-shopping games by suing out-of-state critics in California courts at tremendous expense to the critics, forcing them either to lose and accept a default judgment, or else lose their jobs from having to spend all their time in court in California while attempting to live elsewhere.
Consdiering the total corruption of California courts, extending their sordid corruption to the rest of the country seems an entirely possible action for the cancer these courts have become on the nation's jurisprudence. After all, when a cancer fully corrupts its own organ, it metastasizes.
God save the planet from these criminals.
[letter 1]
Paul, Hastings, Janofsky & Walker LLP 75 East 5% Street, New York, New
York 1D022-.205 telephone 212.'.18-6000 / facsimile 212-339-9150 /
internet www.paulhasting.com
399 Park Avenue. 31st Floor. New York, New York 10022-4697
Pa u l Hastings telephone 212.316-6000 / facsimile 212.',19-4090 /
internet wvvw.paulhastings com
Atlanta / Costa Mesa / London / Los Angeles / San Francisco / Stamford
/ Tokyo I Washington, D.C.
(212) 318-6020 samuelrosen@paulhastings.com 24437.03000 August 9, 2001 VIA FACSIMILE Mr. Neil Levin Church of Scientology International Office of Special Affairs 6331 Hollywood Boulevard, Suite 1200 Los Angeles, California 90028-6329 Re: FACTNer II et al.
Dear Neil:
Although I have not yet seen the decision, I am told that on August 7, a California Court of Appeal issued a decision in a case, in which the defendant is Pavlovich, upholding jurisdiction over him, an out of state student, for operating a web site that allowed users to pirate films. Apparently the Court's key holding is that Pavlovich "knew or should have known" that his web activities could injure the California plaintiff and therefore upheld a personal jurisdiction over him on claims of trade secret theft and copyright infringement. We obviously need to study this decision, but if it is as cracked up to be in the report, this is the one which would be very important both to the captioned case as well as to a lot of the domain name disputes that we deal with daily.
Very truly yours,
(signed)
Samuel D. Rosen
SDR:dm
cc: Warren McShane
William Hart, Esq.
FACSIMILE TRANSMISSION to: from:
SEE DISTRIBUTION LIST Samuel D. Rosen company/office: facsimile:
(212) 230-7783
facsimile: telephone: (212) 318-6020 telephone: Initials: SDR date:
client name: August 9, 2001 (3-.16pm) pages (with cover):
client/matter number: 24437.03000
From: Paul, Hastings, Janofsky & Walker LLP
DISTRIBUTION LIST.
to:
company: facsimile: phone no.:
name:
Mr. Neil Levin CSI (323) 960-3508 or 3509 323) 960-3500 Warren McShane Religious Technology (323) 667-0960 (323) 663-3258 Center William Hart, Esq (212) 969-5050 (212) 969-3095 [letter 2] Paul, Hastings, Janofsky & Walker LLP 75 East 55th Street. New York, New York 10022-3205 telephone 212•318-6000 / facsimile 212 339-9150 / internet www.paulhastings.com 399 Park Avenue. 31st Floor, New York, New York 10022-4697 Hastings telephone 212-3ie-6000 / facsimile 212-319-4090 / Internet www.paulhastings.com Atlanta / Costa Mesa / London / Los Angeles / San Francisco / Stamford /Tokyo / Washington, D.C.
(212) 31.8-6020 samuelrosen@paulhastiilgs.cntn 28886.00400 August 9, 2001 VI FACSIMLE Daniel Leipold Leipold, Donahue & Shipe, LLP 960-A West Seventeenth Street Santa Ana, California 92706 Re: Lopez Dear Mr. Leipold:
Just to follow up on my previous letter confirming the deposition of Dr. Fretheim, I don't know which conference room on which floor in my offices we will be assigned for the deposition so the best thing for you and the witness to do is to come to the main reception on the 23rd floor where the receptionist will direct you to the proper floor and conference room.
As you can well appreciate, we've got an awful lot of ground to cover
with Dr. Fretheim. I would certainly like to finish it in one day
rather than carrying it over and towards that end, I am certainly
willing to go a bit beyond 5:00 p.m. if that is what it will take to
finish it. Assuming you and the witness are of the same mind as I am,
perhaps you
Paul Hastings
Daniel Leopold August 9, 2001 Page 2
can alert Dr. Fretheirn to the possibility that we might need to go a
bit past 5:00 p.m.
Very truly yours,
(signed)
Samuel D. Rosen
SDR:dm
cc Gerald L,. Chaleff, Esq.
Paul Hastings
Daniel Leipold August 9, 2001 Page 3
bcc: Mr. Neil Levin