Ida got a note from the court that for some reason they were not accepting either the answer or the notice of service. Have to sort it out tomorrow. ------------------------ H. Keith Henson
2237 Munns Ave
Oakville, Ontario L6H 3M9
Canada
Telephone: (905) 844-6216 Pro Se

SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF RIVERSIDE HILLARY DEZOTEL, KEN HODEN, and BRUCE WAGONER,
Plaintiffs, vs.H. KEITH HENSON Defendant.
))))))))))))))))))) CASE NO.: 009673DEPT. H5ANSWER TO ADVERSARY
COMPLAINT OF HILLARY DEZOTEL, KEN HODEN, and BRUCE WAGONER,
AFFIRMATIVE DEFENSE, COUNTERCLAIM AGAINST DOES 1-10(REAL PARTIES OF
INTEREST RTC, CSI, DAVID MISCAVIGE, SEA ORG. I.E., SCIENTOLOGY)DEMAND
FOR JURY TRIALTime: NADATE: NA ) PARTIES H. Keith Henson, an individual for his ANSWER to the adversary Complaint above, responds and alleges as follows: 1. Defendant DENIES that this Court has jurisdiction over this action because: Defendant denies, generally and specifically, each and every allegation in the Complaint and denies that Plaintiffs sustained any damage whatsoever due to omission or breach on the part of Defendant. 2. Responding to Paragraph 2 of the Complaint, Defendant has no opinion. 3. Responding to Paragraph 3 of the Complaint, Defendant has no opinion. 4. Responding to Paragraph 4 of the Complaint, Defendant has no opinion. 5. Responding to Paragraph 5 of the Complaint, Defendant has not lived in Palo Alto California since May 12, 2001. The court and counsel for the plaintiffs should take notice that the defendant does not live in California, not even in the US but resides at the above address. Defendant has been declared eligible by Immigration Canada to present a case to the Immigration and Refugee Board based on human rights violations by the government and courts of Riverside County, acting for the so called "Church" of Scientology. 6. Responding to Paragraph 6 of the Complaint, Defendant has no opinion. 7. Responding to Paragraphs 7-13 of the Complaint, Defendant denies the allegations. 8. Responding to Paragraph 14 of the Complaint, Defendant admits the allegations citing credible threats of being killed in jail as good cause. 9. Responding to Paragraph 15 of the Complaint, Defendant notes that the judgment and sentence is on appeal. 10. Responding to Paragraph 16-30 of the Complaint, Defendant issues a general denial of the allegations. AFFIRMATIVE DEFENSES 11. Responding to Paragraph 1 of the Complaint, Defendant denies that all the events occurred in Riverside County or even in the United States. SEPARATE AND AFFIRMATIVE DEFENSES 12. In further Answer to the Complaint, and for his separate and Affirmative Defenses, Defendant/Counter-Claimant alleges as follows: FIRST AFFIRMATIVE DEFENSE (Good Faith) 13. Plaintiff's causes of action are barred in whole or in part because any actions taken by Defendant were fair and reasonable and were performed in good faith based on all relevant facts known to Defendant at the time. In particular the acts alleged are constitutionally protected as free speech under the First Amendment or are protected by other principles such as the right to move freely and observe or report. SECOND AFFIRMATIVE DEFENSE (Comparative Fault) 15. To the extent Plaintiff has the right of recover any amount from Defendant (which right Defendant denies), such recovery must be reduced by the amount of damage attributable to Plaintiff's own negligence and fault. THIRD AFFIRMATIVE DEFENSE (Abuse of Process) 16. Plaintiff's Claim for relief is barred because of his abuse of process including corruption of the District Attorney's office. FORTH AFFIRMATIVE DEFENSE (Failure to Mitigate or Avoid Damages) 17. Defendant is informed and believes and thereon alleges that Plaintiffs have failed or refused to make the full and timely efforts required to mitigate or avoid any injury or damage Plaintiffs allegedly suffered. FIFTH AFFIRMATIVE DEFENSE (Unclean Hands) 18. Plaintiff's Claim for relief is barred, in whole or in part, by the doctrine of unclean hands. SIXTH AFFIRMATIVE DEFENSE (Equitable Estoppel) 19. Plaintiff is equitably estopped from asserting each and all of the purported causes of actions by reason of his own acts, omission and conduct, or that of his agents. SEVENTH AFFIRMATIVE DEFENSE (Offset and Reduction) 20. Plaintiff should be barred from recovery in whole or part, in proportion to the fault attributed to him or his agents. EIGHTH AFFIRMATIVE DEFENSE (Constructive Fraud) 21. At all times relevant, Plaintiff or his agents failed, concealed and/or refused to disclose certain material documents and facts to Defendant, thus misleading Defendant to his extreme prejudice. Plaintiff's or his agent's constructive fraud/unclean hands serves as a bar to the entire action and as to Plaintiff's claims as against Defendant. NINTH AFFIRMATIVE DEFENSE (Fraud) 14. Plaintiff and his agents recovery, if any, should be barred by Plaintiff's and his agents' deceitful/illegal conduct perpetrated on Defendant and upon the courts in the underlying actions giving rise to the amount of monies in controversy and by its deceitful conduct in connection therewith. COUNTERCLAIM 15. Counterclaim for damages due to plaintiffs and their principals and agents conspiracy to deprive defendant of his civil and constitutional rights, abuse of process, intentional infliction of emotional distress. PRAYER FOR RELIEF WHEREFORE, on all causes of action Defendant requests: 1. That Plaintiff's adversary complaint(s) be dismissed with prejudice. 2. General damages in an amount to be determined at trial; 3. Punitive and exemplary damages in an appropriate amount; 4. Costs of suit incurred herein; and 5. That the Plaintiff/Counter-Defendant take nothing by his complaint; 6. Sanctions against Plaintiffs or real parties of interest and such other and further relief as may be just and proper. Respectfully submitted,
H. Keith Henson, pro se
Dated September 17, 2001