(Update: 7th October, 1998)
Chapters 1 to 7 were put together very quickly in January of 1998 for the purpose of getting the actual judgements onto paper to act as a ready reference of court documents.
This chapter is similarly to put onto the Internet the Summary of Argument which the High Court of Australia require when making a Special Application for Leave which became necessary when Justice Peter Hidden brought down his judgement on 1 March, 1998 denying me the right to a jury trial. Here is his judgement:
THE SUPREME COURT OF NEW SOUTH WALES - COMMON LAW DIVISION
Monday 16 March 1998
THE PROTHONOTARY v John WILSON JUDGEMENT
HIS HONOUR: The defendant, John Wilson, is alleged to have thrown paint at Murray AJ after his Honour delivered a judgement adverse to him on 5 September 1997. As a result, the Chief Judge at Common Law, pursuant to Pt 55 r 11(1) of the Supreme Court Rules, directed the Prothonotary to commence proceedings against the defendant for contempt. On 14 October 1997 the Prothonotary, as plaintiff, issued a summons against the defendant seeking a declaration that he was in contempt and an order that he be dealt with accordingly.
On 5 September 1997, the day of the incident, the defendant was also charged by police with an offence under s 326(1) of the Crimes Act of threatening injury or detriment to a judicial officer. The Director of Public Prosecution assumed the conduct of those proceedings on 21 October 1997, and they have been adjourned at the Downing Centre Local Court to abide the outcome of the proceedings in this court.
The contempt proceedings are to be dealt with summarily and are now for hearing on Thursday next, 19 March 1998. On 13 February 1998 I heard an application by the defendant that the alleged contempt be subject to trial by jury. I should record that on 24 November 1997 the defendant issued a summons in the Court of Appeal seeking the same order, and the matter was listed for hearing in that court on 15 December. On 3 December the defendant sought from Dunford J a stay of proceedings upon the Prothonotary's summons pending the hearing in the Court of Appeal, but his Honour refused to grant a stay on the basis that any submission that he was entitled to trial by jury for contempt was without substance: The Registrar of Court of Appeal v Willesee & Ors (1984) 2 NSWLR 378. In the event, on 15 December the summons in the Court of Appeal was withdrawn.
The application before me must also be dismissed for the same reason that Dunford refused to grant a stay. Willesee is clear authority for the proposition that trial by jury for contempt is obsolete and that summary trial is now the normal procedure. Before me, the defendant was represented by counsel who tried valiantly, but unsuccessfully, to find some way around that decision. He referred to Cap. 29 of Magna Carta, affirming the right to trial by one's peers, and its incorporation into the law of New South Wales by s 6 of the Imperial Acts Application Act 1969. However, by that section, various imperial enactments have the force of law in New South Wales "except so far as affected by ... State Acts from time to time in force in New South Wales"; s 6(b). In Galea v New South Wales Egg Corporation (C of A, unreported, 21 November 1989) Kirby P (at p 11) observed that this "would appear to envisage the affectation and modification of the continuing application of the enumerated Imperial Acts by ordinary legislation enacted by the State Parliament." Accordingly, any guarantee of trial by jury in Magna Carta can be, and has been, overridden by the Supreme Court Act and Rules as far as contempt is concerned.
Counsel made reference to the guarantee of trial by jury in respect of indictable offences against any Federal law in s 80 of the Commonwealth Constitution. In oral argument he acknowledged that s 80 is concerned only with Commonwealth offences and, as I understand it, his reference to the section was merely as part of the history of the development of trial by jury in this country, and as an indication of the respect afforded to that method of trial. For the plaintiff, the Crown Advocate queried whether any submission based on s 80 might involve a matter arising under the Constitution so as to require the procedure under s 78B of the Judiciary Act 1903 to be followed. When I reserved judgement I invited counsel for the defendant to provide submissions in writing if he wished to develop an argument founded upon s80, in which event the necessity to proceed in accordance with s78B of the judiciary Act would be considered. As it happened, Mr. Wilson withdrew his instructions from his legal advisers shortly thereafter. He has since forwarded some written material to me which refers to s 80 of the Constitution, but takes the matter no further. I am satisfied that the proceedings before me do not involve a matter arising under the Constitution, or involving its interpretation, and s 78B of the Judiciary Act has no application.
A submission was also made that the prosecution under s 326 of the Crimes Act, which would be on indictment, should proceed in advance of (or perhaps instead of) the contempt proceedings, so as to afford the defendant the benefit of trial by jury. This argument also is without substance. As the Crown Advocate pointed out, the deferral of the prosecution under s 326is a legitimate exercise of prosecutorial discretion and this court could not compel the Director to take some other course.
Accordingly, the application for trial by jury in respect of the alleged contempt must be dismissed.
I certify that this and the 2 preceding pages are a true copy of the judgement ........ herein of the Honourable Justice Peter Hidden
16/3/98 P. Garrett
I should explain that the reason for issuing a Summons in the Court of Appeal on 24 November 1997 was that in the Supreme Court of New South Wales on 17th November when I said to Judge Studdert that I "insiston a trial by jury" the judge replies "You do not get a trial by jury.". I replied to him, "Yes I do. The Magna Carta and the Constitution of Australia says so.".
I believe that was a denial of my right and promptly filed in the Court of Appeal against that denial.
When, on 3 December 1997, Judge Dunford dealt with my application for a stay of proceedings until after the Court of Appeal his comment in his Judgement was: "...it is claimed in the Court of appeal summons that Studdert J denied the applicant a trial by jury on the contempt charges. However, a reading of the transcript of what occurred on 17 November makes it clear that, although Mr. Wilson made an oral application that the matters be heard by a jury, his Honour did not determine such application, and in particular said at p 5, "I am not dealing with any question of trial by jury".".
On 15 December 1997, outside the court and before going in, a solicitor whom I was employing at the time said that I should have made a written application called a "Requisition" according the rules. On that advice I withdrew the action in the Court of Appeal and went back to my source of legal information, the Law Library at Macquarie University. There I found the precedent forms and put it together to file back in the Supreme Court on 23rd January, 1998 the Notice of Motion asking for leave to file a Requisition for Trial By Jury.
As already said, Justice Peter Hidden eventually dismissed the application for a jury trial on 16th March, 1998. The following day I filed a Notice of Appeal in the Court of Appeal. Two days after that, in the Downing Centre Local Court, the Public Prosecutor withdrew the first charges under section 326 of the Crimes Act 1900 (which was to have had a jury trial at my insistence and when I had told the court I would subpeona judges) because it now looked assured that I would not be getting a jury through the Supreme Court and that an appeal to the Court of Appeal would similarly fail.
Without going into the written argument in the Affidavits nor the verbal argument which transpired in the Court of Appeal on 24th August, here is the Judgement of Handley JA and Stein JA:-
THE SUPREME COURT OF NEW SOUTH WALES COURT OF APPEAL
Monday 24 August 1998
JOHN WILSON v THE PROTHONOTARY JUDGEMENT
HANDLEY JA: This is an application by Mr. John Wilson for leave to appeal against a decision of hidden J on 16 March 1998. Hidden J held that Mr. Wilson had no right to trial by jury in proceedings pending in the Common Law Division against him for contempt of court arising out of incidents on 5 September 1997.
The question whether a person accused of the offense of contempt of court is entitled to a trial by jury is obviously an important one. However, a consistent course of decision of this Court establishes that there is no right to trial by jury in such cases. The earliest of these decisions is The Registrar of the Court of Appeal v Willesee & Ors (1984) 2 NSWLR378. Mr. Willesee sought special leave to appeal from the High Court of Australia from that decision which was refused on 7 December 1984. This Court followed that decision in Galea v New South Wales Egg Corporationon 28 November 1989 and again in United Telecasters Sydney Limited v Hardiein 1991.
In view of that consistent body of decision extending back over some fifteen years, and the refusal of special leave to appeal by the High Courton 7 December 1984, the proposed appeal of Mr. Wilson has no prospects of success. For that reason leave to appeal is refused and it must be refused with costs.
I Certify that this and the one (1) preceding pages are a true copy of the reasons for judgement herein of The Honourable Mr. Justice Handleyand of the Court.
I have now filed an Application for Special Leave to Appeal in the High Court of Australia on 11th September 1998 and a Summary of Argument on 2nd October,
IN THE HIGH COURT OF AUSTRALIA SYDNEY OFFICE OF THE REGISTRY
No. S 127 of 1998
BETWEEN JOHN WILSON
APPLICANT'S SUMMARY OF ARGUMENT
Part I: The Special Leave Questions arising in this case are those of:
Part II: The Applicant was served with a Summons on 20th October, 1997 to appear in the Supreme Court of New SouthWales. The Summons contained a Statement of a Charge alleging Contempt of Court over an incident which happened on 5th September, 1997.
The Applicant filed a Requisition for Trial by Jury on 23rd January, 1998 and hearings were held before Justice Peter Hidden on 9th and 13th February, 1998. Judgement was reserved and handed down on 16th March, 1998 dismissing the Requisition.
The Applicant filed a Notice of Appeal in the Court of Appeal on 17th March, 1998. The call-over was on 4th June, 1998 and the hearing was on 24th August, 1998.
The Applicant filed a Notice of Motion for a Trial by Jury on 25th May, 1998 to determine the Application for Leave to Appeal in the Court of Appeal. On 6th July, 1998 Registrar Jupp dismissed the application.
In the Court of Appeal on 24th August, 1998 Handley JA and Stein JA dismissed the Application for Leave to Appeal.
The Applicant filed in the High Court of Australia on 11th September, 1998 an Application for Special Leave to Appeal.
A BRIEF STATEMENT OF THE APPLICANT'S ARGUMENT
1. MAGNA CARTA & REASONS FOR GRANTING SPECIAL LEAVE
CAP XXIX of the Magna Carta 1297 says: "To no one will we sell, to no one will we deny or delay, Right or Justice." and the reasons for granting leave to appeal, as stated in Supreme Court Procedure (NSW) Part7 - Appeal to the Court of Appeal, s. 101.4 Appeal from interlocatory order at 1164.1 Butterworths, are (a) "the determination of substantive rights" and (b) to avoid "a substantive injustice".
2. THE PROTECTION OF MAGNA CARTA
Magna Carta is protected by section 43 of the Imperial Acts Application Act 1969 No. 30 which says: "Any person guilty of any offence under any Imperial enactment included in Part 1 of the Second Schedule for which no punishment is otherwise provided is liable to imprisonment for a term of not more than five years or to a fine not exceeding 20 penalty units, or to both imprisonment and fine.". Justice Peter Hidden has denied the applicant the right to trial by jury and should be indicted to face trial by jury for that offence. Handley JA and Stein JA have endorsed Justice Peter Hidden's actions by refusing leave to appeal and have made them selves party to the offence.
3. ABSOLUTE POWER OF JUDGES
Judges must never be given nor allowed to assume absolute power whereby they can conceal their own incompetence and their own corruption. Judges are not above the law nor are they unaccountable to the people.
4. JUDICIAL OATH & SAVING RIGHTS
Judges swear before God an Oath to "well and truly serve" Her Majesty Queen Elizabeth II who has sworn, also before God, to govern the people of Australia in Law and Justice and with Mercy. She cannot extinguish the rights of Her subjects and nor can judges. To extinguish or override the rights of the people is an act of tyranny and oppression. Not even the repealing of legislation can extinguish the rights of the individual and proof of this reality is seen in the "Savings" section of the Imperial Acts Application Act 1969 No. 30 which says: "9. (1). The repeal by this Act of any Imperial enactment does not: ..(c) affect any right, privilege, obligation, or liability acquired, accrued, or incurred under any Imperial enactment so repealed:".
5. TRIAL BY JURY IN THE U.S.A.
Article the eighth (Amendment VI) of the United States of America's Bill of Rights says "the accused shall enjoy the right to a speedy and public trial, by an impartial jury" and Article the ninth (AmendmentVII) similarly says that "the right of trial by jury shall be preserved". Is an Australian less equal before the law than an American?
6. MAGNA CARTA & THE RIGHT TO TRIAL BY JURY
CAP XXIX of the Magna Carta 1297 says: "NO freeman shall be taken, or imprisoned, or be disseised of his freehold, or his liberties, or free customs, or be outlawed, or exiled, or in any other wise destroyed, nor will we pass upon him nor condemn him unless by the lawful judgement of his Peers or by the law of the land.".
7. THE LAW OF THE LAND
The law of the land is the Commonwealth of Australia Constitution Act 1900 which says, in clause 5 that "This Act, and all laws made by the Parliament of the Commonwealth under the Constitution, shall be binding on the courts, judges, and people of every State and of every part of the Commonwealth, notwithstanding anything in the laws of any State:".
8. THE CONSTITUTION & THE JUDICIARY ACT & THE CRIMES ACT
The Constitution says in section 80, about trial by jury, that: "Thetrial on indictment of any offence against any law of the Commonwealth shall be by jury," and contempt of court is an offence against a Commonwealth law, being section 24 of the Judiciary Act 1903, and section 4A of the Crimes Act 1914 (a Commonwealth law) says that: ""indictment" includesan information and a presentment".
9. SECTION 109 OF THE CONSTITUTION
The Constitution says in section 109 that: "When a law of a State is inconsistent with a law of the Commonwealth, the latter shall prevail, and the former shall, to the extent of the inconsistency, be invalid.". Therefore, because contempt of court shall have trial by jury under a Commonwealth law, contempt of court shall have trial by jury under a State law.
10. THE IMPERIAL ACTS APPLICATION ACT & GALEA
As far as section 6 of the Imperial Acts Application Act 1969 No. 30 is concerned, any State law which is invalid by virtue of being inconsistent with a Commonwealth law cannot affect an Imperial enactment such as Magna Carta. Therefore, Justice Peter Hidden's referral to Galea v New South Wales Egg Corporation (C of A, unreported, 21 November 1989) has no substance and his argument that "any guarantee of trial by jury in Magna Carta can be, and has been, overridden by the Supreme Court Act and Rules as far as contempt is concerned." is wrong.
The Galea proceedings were to do with a "Motion for leave to appeal out of time against the orders of Needham J dated 9 February 1988" (with no mention of the right to trial by jury) and to an "Appeal from the orders of Needham J of 19 August 1988" as to whether the Egg Industry Act 1983 met the requirements of s. 5 of the NSW Constitution Act 1902 in regard to the counting of hens and eggs.
11. THE INTERPRETATION ACT SAVING RIGHTS
The Galea judgement did quote section 30 of the Interpretation Act 1987 No.15 which says: "(1) The amendment or repeal of an Act or statutory rule does not: ... (c) affect any right, privilege, obligation or liability acquired, accrued or incurred under the Act or statutory rule,". This restates the same protection of rights found in section 9 of the Imperial Acts Application Act 1969. Therefore, the Supreme Court Act and Rules cannot take away the right of the individual to trial by jury.
11. THE CONSTITUTION & STATE JUDICIAL PROCEEDINGS
Section 118 of the Australian Constitution says that: "Full faithand credit shall be given, throughout the Commonwealth to the laws, the public Acts and records, and the judicial proceedings of every State.", and section 51 (xxiv) says the Federal "Parliament shall, subject to this Constitution, have power to make laws ... with respect to ...The service and execution throughout the Commonwealth of the civil and criminal process and the judgements of the courts of the States:".
These reinforce sections 80 and 109 of the Constitution which ensure that contempt of court shall proceed by trial by jury.
12. SECTION 5 OF THE NSW CONSTITUTION & TELECASTERS
Handley JA, on 24 AUG 1998, was wrong when he said that: ".. in the Constitution nor in an Act made in Canberra is there a law, ...., that is a Commonwealth law, which says there must be trial by jury for state offences. That's a matter which under our federal system is left to the states.". The New South Wales Constitution Act 1902 No. 32, General legislative powers, section 5. says: "The Legislature shall, subject to the provisions of the Commonwealth of Australia Constitution Act, have power to make laws for the peace, welfare, and good government of New South Wales in all cases whatsoever:". Because of section 109 and 80 of the Australian Constitution, New South Wales cannot make a law to deny trial by jury for contempt of court. Therefore, such "a matter" is not" left to the states" and when in United Telecasters Sydney Limited v Hardie (1991) 23 NSWLR 323 Meagher JJA said; "Contempt committed in the face of a State court, whatever jurisdiction is being exercised, isa matter for State law.", the State law must be consistent with Commonwealth law, i.e.: there must trial by jury for both the Commonwealth offence of contempt of court and the State offence of contempt of court to be consistent (section 109 of the Australian Constitution).
13. COURTS DECLARING LAWS VOID
In the Annotated Constitution of the Commonwealth of Australia, p. 791,John Quick and Robert Randolph Garran say: "In the exercise of the duty of interpretation and adjudication not only in the High Court, but every court of competent jurisdiction, has the right to declare that a law of the Commonwealth or of a State is void by reason of transgressing the Constitution. This is a duty cast upon the courts by the very nature of the judicial function. The federal Parliament and the State Parliaments are not sovereign bodies; they are legislatures with limited powers; and any law which they attempt to pass in excess of those powers is no law at all it is simply a nullity, entitled to no obedience.".
Section 31 of the Interpretation Act 1987 No. 15 says: "(1) An Actor instrument shall be construed as operative to the full extent of, but so as not to exceed, the legislative power of Parliament.".
Parliament does not have the power to extinguish the right to trial by jury which is an integral part of the common law which "was assumed by, and controlled, the Constitution" (Sir Owen Dixon - Jesting Pilate,pp 198 - 202, 203 - 13) ( from The High Court and the Constitution by LeslieZines p 400 ).
14. JUDGES DON'T MAKE LAWS & THE REFERENDUM OF 1988
Nor is the judiciary a sovereign body having the ultimate authority to make and impose laws. They must comply with the law of the land, being the Australian Constitution, which embodies the will of the people. Article 21. 3 of the United Nation's Universal Declaration of Human Rights says that:" The will of the people shall be the basis of authority of government:" and the will of the people was expressed in Referenda before the Constitution Bill could be made the law of the land and again in 1988 when a proposed law to alter section 80 of the Constitution to exclude contempt of court from trial by jury was defeated in every State. The published "WHY YOU SHOULD VOTE 'NO' - ON TRIAL BY JURY" in newspapers at the time immediately prior to the referendum said that the proposed law "would undermine our existing rights enshrined for seven centuries since Magna Carta. At present, a person charged with any serious offence has the right to a jury trial.".". The voters rejected excluding contempt of court from trial by jury. Government and the judiciary must obey the will of the people.
15. JUDGEMENTS REPUGNANT TO MAGNA CARTA ARE VOID
CAP II of the CONFIRMATIO CARTARUM 1297 says that "AND we will, that if any Judgement be given from henceforth contrary to the Points of the Charters aforesaid by the Justices, or by any other Officers that hold Plea before them against the Points of the Charters, they shall be undone, and holden for nought.". Therefore, no court has jurisdiction to conduct a trial for contempt of court against me unless it accords me my right to a jury trial.
"The consent to be tried summarily must be clear and unequivocaland a failure to carry out the procedures for obtaining the consent will deprive the court of jurisdiction to determine the matters summarily."- Halsbury's Laws of Australia, para (130 - 13460) at 250,997.
16. TRIAL BY JURY NOT "OBSOLETE" ...... WILLESEE
Justice Peter Hidden was wrong when on 16 MAR 98 he said, when referring to The Registrar of Court of Appeal v Willesee & Ors (1984) 2 NSWLR378, that: "Willesee is clear authority for the proposition that trial by jury for contempt is obsolete ..." because Magna Carta, in CAP I, granted that right "for evermore" -which means it can never become "obsolete".".
17. FAILURE TO INFORM OF RIGHTS
Justice Peter Hidden went on to say: "..and that summary trial is now the normal procedure.". But if summary trial was not elected by the accused because he/she was not informed of their inalienable rights, then those judgments (no matter how many) are "to be undone and holden for nought".
18. HANDLEY JA & NORMAN GALLAGHER
Handley JA (24 AUG 98) said of a case against Norman Gallagher ""about 10 or 12 years ago", "he was tried for contempt of the Federal Court by the federal Court and without a jury.". I replied: "Was he given the choice, was he given an election?". Handley JA said: "I don't believe he was given any choice.". I said: "Well, I'd say his rights were infringed if he wasn't.". Handley JA said: "He didn't argue, his counsel didn't argue that he was entitled to a trial by jury.".
19. FAILURE TO INFORM OF RIGHTS
This is the deplorable situation of Australian citizens not knowing of their Constitutional and inherited rights and, at the same time, judges and lawyers being equally ignorant or else failing to advise the accused person of their rights.
20. WORKING TO IMPOSE A SUBSTANTIVE INJUSTICE
Besides "the determination of a substantive right", the other main criterion for granting leave to appeal is that the judgement appealed from "must also work to impose a substantive injustice:" ( (Supreme Court Procedure, Part 7, s.101.4 Appeal from interlocatory order) .. The injustice which would result if leave to appeal is not granted is that bank fraud, in the form of variable interest rate loans, would continue to be concealed by the corrupt practices of the judiciary which presently places the entire system of justice in Australia in jeopardy.
21. CONCEALING JUDICIAL CORRUPTION
Justice Peter Hidden's judgement imposes "a substantive injustice" in that it serves to protect the concealing of extensive judicial corruption which was the subject of the proceedings heard by Acting Justice Brian Murray and which gave rise to the incident of the 5th of September, 1997.
Judicial corruption comes under Part III of the Crimes Act 1914 which is a Commonwealth law "binding on the courts, judges, and people of every State and of every part of the Commonwealth, notwithstanding anything in the laws of any State;".
22. CONCEALING FRAUD
The injustice also extends to victims of bank fraud in the form of variable interest rate loan contracts being denied restitution because corrupt judges refuse to declare that variable means uncertain and certain means not variable and, therefore, variable interest rates render a loan contract void for uncertainty. This is the claim which originally drew me to the courts in 1996 to establish this simple truth.
23. JURIES DO WHAT JUDGES DON'T FOR JUSTICE
"For more than six hundred years 0 that is, since Magna Carta, in 1215 -- there has been no clearer principle of English or American constitutional law, than that, in criminal cases, it is not only the right and duty of juries to judge what are the facts, what is the law, and what was the moral intent of the accused; but that it is also their right, and their primary and paramount duty, to judge the justice of the law, and to hold all laws invalid, that are, in their opinion, unjust or oppressive, and all persons guiltless in violating, or resisting the execution of, such law." -An Essay on The Trial By Jury by Lysander Spooner, 1852.
"Trial by jury has long been considered a fundamental safeguard off airness and impartiality in the administration of justice, especially of criminal justice. Jury trial stemmed from a deep-seated conviction about the exercise of judicial power, that it should not in matters affecting the liberty of the subject be entrusted unchecked to any official, judge or administrator but should be vested in ordinary citizens." - The Laws of Australia 21.6, Part D, (38), p. 47.
24. JUDGES OUGHT NOT HEAR THIS CASE
Under the Supreme Court Rules, Part 51, rule 23.8, it says that "A judge ought not hear a case if there is a reasonable apprehension that an impartial mind will not be brought to bear on the resolution of proceedings.". I have already expressed such an apprehension when I filed an Affidavitin the Court of Appeal to support a Notice of Motion to that effect on 26 JUN 98 to which I annexed one of my leaflets entitled "BANK FRAUD & CORRUPT JUDGES".
25. WITHDRAWAL OF FIRST CHARGE GOING TO A JURY & INJUSTICE
The first charge imposed on the Applicant, under section 326 of the Crimes Act 1900, over the incident of 5 SEP 97 was withdrawn by the Public Prosecutor on 19 MAR 98 in the Downing Centre Local Court when it was proceeding to trial by jury. I had made it clear in the Downing Centre that I would be presenting evidence of judicial corruption to a jury and that a jury should hear "The truth, the whole truth and nothing but the truth". During those proceedings, on 26 SEP 97, the magistrate in the Downing Centre imposed additional and oppressive terms to the bail to imprison me in the Silverwater Remand Centre for the period 26 SEP 97 to 28 SEP 97 when a friend guarantied surety for me. I truly believe this action also constitutes a violation of my human rights by wrongful imprisonment.
26. THE INJUSTICE IS THE PERVERSION OF JUSTICE
Whilever the right to trial by jury, which is the tribunal of the people, is denied and judges continue to use their authority to perpetuate the lie that "the rate itself is indeed certain" and to protect themselves, there can be no justice.
27. INALIENABLE RIGHTS
Rights granted by Imperial enactments such as Magna Carta cannot be taken away or "overridden" by politicians, bankers or judges.
Special leave to appeal should be granted because there must be a full examination as to the determination of a substantive right, i.e.: the right to trial by jury, and as to the reasons behind the judgement appealed from, and as to whether a substantive injustice has been imposed.
An order for costs should not be made in favour of the respondent in the event that the application is refused because counsel for the respondent have, with the knowledge of the respondent, fraudulent made out that they represent the Crown whereas they are, in fact, merely private solicitors, i.e: they have indulged in deceit.
TABLE OF AUTHORITIES, ETC.
The applicant seeks to supplement this summary with oral argument.
Dated the day of , 1998.
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