Draft for comments H. Keith Henson P.O. Box 60012 Palo Alto, CA 94306 (650) 423-4040 (pager) UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA RELIGIOUS TECHNOLOGY CENTER, a ) Case No. C-96-20271RM ) California non-profit corporation, ) Plaintiff, ) REQUEST FOR ) CLARIFICATION OF v. ) ORDER OF ORDER ) DENYING RULE 60(b) H. KEITH HENSON, an individual, ) MOTION ) Defendant. ) ___________________________________) Defendant request clarification of certain points in the Court's order dated May 11, 2000. 1. The name "Ingram" (an agent of Mr. Moxon) appears 105 times in the Cipriano declaration while Mr. Moxon's name appears over 240 times. More meetings and other contacts with Moxon than with Ingram are reported. "Moxon" appears in defendant's papers more than "Cipriano" and "Ingram" combined, and co-equal with Ingram in the opposition paper. Yet "Ingram" appears and "Moxon" is not mentioned at all in the order of the court. Why was Counsel for RTC Mr. Kendrick Moxon not mentioned in the order? (And for the first time, not even on the service list.) 2. The court mentions Ingram's relation to Scientology twice in the past tense: ". . . meetings with Eugene Ingram, a one-time private investigator for the Church of Scientology . . ." and "Even if an investigator once affiliated with Scientology . . . ." Defendant has diligently searched th moving and responding papers and can discern no such information within them. Was this mention inadvertent or did the court have actual knowledge of Mr. Ingram's current status? 3. Defendant did not ask for Rule 60(b)(3) in the copyright judgment, so denial of an unrequested remedy is hard to understand. Defendant did ask for Rule 60(b)(3) relief in the contempt judgment which occurred less than a year ago. Was relief from the contempt judgment denied? 4. Defendant also asked for an evidentiary hearing if the court had any doubts as to the factual nature of the exhibits. The court expressed doubt. Was the evidentiary hearing also denied? 5. Finally, the court states: "Nor is this the exceptional case warranting relief under Rule 60(b)(6) or the court's inherent powers." If several dozen felonies by opposing counsel directed toward defendant's counsel are not "the exceptional case," defendant would be greatly interested in what would comprise an "exceptional case." Respectfully submitted, H. Keith Henson, pro se (date)