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UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
BEFORE THE HONORABLE ARTHUR S. WEISSBRODT, JUDGE
In Re: ) Case No. 98-51326-ASW
) Chapter 13
)
HOWARD KEITH HENSON, )
) TRIAL
) Volume IV
Debtor. ) Pages 493 to 725
)
)
) Wednesday, October 2, 2002
) San Jose, California
Appearances:
For the Debtor: Law Offices of Stanley A. Zlotoff
By: Stanley A. Zlotoff, Attorney at Law
300 South First Street, Suite 215
San Jose, California 95113
For Creditor Religious Moxon & Kobrin
Technology Center: By: Helena K. Kobrin, Attorney at Law
3055 Wilshire Boulevard, Suite 900
Los Angeles, California 90010
McPharlin, Sprinkles & Thomas
By: Elaine M. Seid, Attorney at Law
10 Almaden Boulevard, Suite 1460
San Jose, California 95113
Paul, Hastings, Janofsky & Walker LLP
By: Samuel D. Rosen, Attorney at Law
75 East 55th Street
New York, New York 10022-4597
For Witness Lucas: Howard Hibbard, Attorney at Law
Electronic Court United States Bankruptcy Court
Recorder: Clerk of the Court
Liz Armendariz
280 South First Street, Room 3035
San Jose, California 95113
(408) 535-5003
Certified Electronic Palmer Reporting Services
Transcriber: P. O. Box 30727
Stockton, California 95213-0727
Proceedings recorded by digital recording;
transcript produced by federally-approved transcription
service. I N D E X
Debtor's Objections to Creditor's Exhibits: page 495
Court's Decision on Debtor's Objections and
Creditor's Exhibits: page 506
Agreements of the Parties: page 595
Witnesses:
Direct Cross Redirect Recross
Victoria Arel Lucas
By Mr. Rosen:
(Resumed): 540
605
By Mr. Hibbard: 689
By Mr. Zlotoff: 689
By Mr. Rosen: 709
Exhibits: Received in Evidence
Creditor's Exhibit 290: page 523
Creditor's Exhibit 292: page 671
Debtor's Exhibit R: page 534
Debtor's Exhibit S: page 535
Debtor's Exhibit O: page 536
Debtor's Exhibit P: page 536
Debtor's Exhibit Q: page 537
495
1 Wednesday, October 2, 2002 9:13 o'clock a.m.
2 P R O C E E D I N G S
3 THE CLERK: Please rise. This is the United States
4 Bankruptcy Court for the Northern District of California. Court
5 is now session.
6 THE COURT: Good morning, ladies and gentlemen. Sorry
7 for the brief delay. I had something I had to take care of.
8 This is the case of Keith Henson.
9 May I have appearances of counsel?
10 MR. ZLOTOFF: Stan Zlotoff for debtor.
11 MR. ROSEN: For Religious Technology Center, Samuel D.
12 Rosen, Paul, Hastings, Janofsky and Walker.
13 MS. KOBRIN: Also for Religious Technology Center,
14 Helena Kobrin, Moxon and Kobrin.
15 MS. SEID: Elaine Seid of McFarland, Sprinkles and
16 Thomas, also for Religious Technology Center.
17 THE COURT: Good morning.
18 Are you ready to present your argument?
19 MR. ZLOTOFF: Yes, Your Honor. I think the easiest
20 way to do this would be if you - if you have a copy of Mr.
21 Rosen's brief.
22 THE COURT: I do.
23 MR. ZLOTOFF: Okay. And then we have certain
24 headings. And so the first headings is at page 6. And actually
25 the first exhibits of interest are on page 7. There's nothing
496
1 that's really stated before page 7 that's of any pertinence at
2 all to the exhibits.
3 On page 7, these are - these are all objectionable
4 with the exception of 168. They're - all of these references,
5 that is Exhibits 121, 124, 140, 142, 159, 230, 231, 232, 266,
6 267, 268, those of the ones that I had objected to. And all of
7 those represent postings at one time or another by Mr. Henson.
8 And you can gather from certain quotations set forth here the
9 general tenor of those postings.
10 For example 140: The excerpt is "Killing the
11 organization off entirely is the best way to change the future
12 of Scientology."
13 Number 230, Exhibit 230: "Activities of Henson and
14 his cronies will only end when Scientology is ground into the
15 dirt or spent its last dollar on lawyers."
16 266: "We are out to break the COS."
17 268: "The annihilation of COS and all its fronts is a
18 worthy goal."
19 All those to my mind are free speech. I mean they
20 might be cartoonish. To my mind it's a bit like the Wiley
21 Coyote complaining that the Roadrunner - or I guess the reverse
22 - the Roadrunner complaining the Wiley Coyote's after him, but
23 it's cartoonish.
24 I mean to me it makes no difference; except the only
25 way it could possibly be relevant is if these are supposed to be
497
1 bad acts and based upon these bad somehow we're supposed to
2 infer some kind of what? Bad faith Chapter 13 character that is
3 somehow relevant to the issue of confirmation.
4 In other words, none of these postings have anything
5 to do with the debt that RTC holds. None of them have to do
6 with any kind of budgetary analysis. None of them have to do
7 with any net worth. They're just ramblings by somebody on the
8 Internet.
9 168 was also objectionable, but that's not a posting.
10 That's the protective order. And again it was a protective
11 order entered in either the District Court case or related
12 District Court case. And the protective order was granted, I
13 believe, to exclude Mr. Henson from the deposition because of
14 some alleged threats that someone had perceived had been made.
15 And again to the extent it has any interest it's to
16 approve an alleged bad act or conduct on behalf of Henson at
17 some time in the past, utterly unrelated to either the debt
18 that's before the Court or anything having to do with the
19 Chapter 13. And it's totally irrelevant for that purpose.
20 THE COURT: Why don't you complete your argument as to
21 all the exhibits?
22 MR. ZLOTOFF: Okay. I'm going forward.
23 Number 257. If you down the page under the next
24 heading, "Contempt and threatened contempts." 257 is just
25 another internet posting, which to me is nothing other than free
498
1 speech and not objectionable for the same reasons I indicated.
2 I didn't have - a lot of these I didn't have any
3 objection to. Can I just state the ones I have objection to?
4 THE COURT: Sure.
5 MR. ZLOTOFF: Because they pretty much wrote out a
6 trial brief rather than just limiting their objections to the
7 ones that I had a problem with.
8 Number 22. At the bottom, Exhibit 22, I withdraw - I
9 withdraw any objection for that.
10 THE COURT: What page of their brief is Exhibit 22?
11 MR. ZLOTOFF: I'm sorry. What page of their brief?
12 It's page 7.
13 THE COURT: Yeah. You're asking me to follow their
14 brief, and I'm trying -
15 MR. ZLOTOFF: Yeah, I'm sorry.
16 THE COURT: - trying to follow.
17 MR. ZLOTOFF: That's page 7 at the bottom.
18 THE COURT: Oh, yes, I see it. Excuse me a second.
19 Ms. Lucas, I noticed that you just came into the
20 courtroom. We are going to be dealing with these legal issues
21 about the exhibits for at least another 20, 25 minutes. So if
22 you need to make calls or do anything, we can come out in the
23 hall and find you.
24 MR. ROSEN: Your Honor, may I refer you to the back of
25 the brief which has the equivalent of the table of authorities -
499
1 THE COURT: You need your mic, to be at your mic.
2 MR. ROSEN: - which has the equivalent of a table of
3 authorities, functionally. So, for example, on the question you
4 just asked, obviously if after - when you consider these in your
5 chambers, if you have any questions of the kind that was just
6 asked, you'll see that Exhibit Number 22 appears on page 7.
7 That's what the table in the back is for. So Your Honor can
8 locate it in the brief.
9 MR. ZLOTOFF: Your Honor, actually you don't even know
10 the ones that I made objection to. So it's - why don't I just
11 not even mention 22 and you just assume that there's no issue on
12 that. I think that would be easiest way to proceed.
13 THE COURT: I do know from a footnote.
14 MR. ZLOTOFF: Oh, that's right, you're right. Okay.
15 I withdraw any objection to 22.
16 On the next page, page 8, Exhibit 80 - I'm sorry
17 Exhibit 25 is withdrawn. No objection as to 25.
18 Exhibit 80, Exhibit 269, 270, 274 are still
19 objectionable on relevance grounds. They're postings. And
20 again to me they just evidence free speech. Or if they suggest
21 bad conduct, it's irrelevant to prove some kind of character
22 that's wrongful with regard to Chapter 13.
23 Exhibit 274. I have no objection to 274. I'm not
24 sure whether that was one of the ones I objected to or not.
25 MR. ROSEN: Yeah.
500
1 MR. ZLOTOFF: It was? I withdraw objection to 274.
2 Then the next batch is Number 3 on page 8: "Henson's
3 repeated efforts to derail the copyright trial." I don't have
4 any objections in that category - in that - under that heading.
5 So either I didn't make objections as to the ones indicated or I
6 withdraw whatever objections I may have had.
7 Is that clear, Your Honor?
8 THE COURT: I guess so. It's 9 and 4.
9 MR. ROSEN: And 6, Judge.
10 THE COURT: Yes.
11 MR. ROSEN: He didn't object to any of those. And
12 also 7, I see. It's on line 14 under - in that heading. No
13 objection to that one either. And 8 on line 16, no objection to
14 that one either.
15 MR. ZLOTOFF: The next heading, Number 4, on page 8.
16 No objections in that category. So I did have an objection to
17 256 earlier; that's withdrawn. And the other exhibits indicate
18 I never objected to in the first place.
19 The next heading on page 9 is Heading Number 5. And
20 this gets into - the first paragraph Exhibits 5 and 258 are
21 exhibits pertaining to other trials or orders made in other
22 cases. And to me for that reason they lack relevance to this
23 particular case.
24 Exhibit 96 is a posting that to me again is nothing
25 other than free speech posting and doesn't suggest one thing or
501
1 the other. And for that reason it is irrelevant, as with the
2 next paragraph on page 9. So that would include Exhibits 94,
3 93, 81 and Exhibits 147 to 158. They're all free speech
4 postings. And, you know, he's talking about the amusement value
5 of the litigation and explaining his picketing activities and so
6 forth. And it's, you know, it's - it's irrelevant. I don't see
7 any point to - it has to the trial.
8 The last paragraph are a series of exhibits that
9 pertain to the criminal trial. And, remember, the criminal
10 trial happened postpetition. I think a couple of years
11 postpetition, regarding postpetition conduct. Mr. Henson at
12 some kind of a Scientology or RTC headquarters, I think, in
13 Riverside. It's irrelevant.
14 I don't understand why any kind of - it was a
15 misdemeanor conviction, as I recall. So, in the first place, I
16 don't think misdemeanor convictions are admissible. It's
17 irrelevant because it doesn't bear on either the debt or assets
18 or any pertinent confirmation standard. To the extent that it
19 shows anything that RTC is trying to squeeze into a relevancy
20 category, it's that he was a bad person, he committed a bad act,
21 therefore he again has some kind of character flaw that carries
22 into Chapter 13. And so he must be doing bad things while in
23 Chapter 13. To me it just doesn't follow.
24 And you - as a matter of law, as I recall - Mr. Rosen
25 I'm sure will correct me on my evidence, but I don't think you
502
1 can prove character from an instance of bad conduct.
2 So, anyway, we were talking here about again the last
3 paragraph on page 9. This will be Exhibit 183, misdemeanor
4 complaint; 129 a docket sheet; 260, again having to do with the
5 criminal trial. And also 134. I'm on page 10 now.
6 THE COURT: Um-hum.
7 MR. ZLOTOFF: Exhibits 133, 134, 135, 141, they're all
8 postings. And to me, looking at them without any narrative
9 supplied by RTC, they're just postings, again free speech. RTC
10 tries to tie them in by saying, 'Well, they were part of the
11 criminal trial.' And again I say so what. They were a part of
12 the criminal trial, not relevant.
13 On that line, line 8, page 10, 164 to 167 and 261 to
14 262. Again I read them and I - I just see free speech. I don't
15 even see context to them. I mean they're just - some of are
16 just two sentences long that don't have any significance to me
17 at all - except RTC supplies a context and says they were used
18 in the criminal trial. And I say, okay, if they were used in a
19 criminal trial, so what, they're still irrelevant.
20 The next line down, 273, is the dismissal of his
21 criminal appeal. And I say so what. It's irrelevant. I don't
22 care about the criminal appeal or that it was dismissed based on
23 the fugitive disentitlement doctrine. We've already talked
24 about fugitive disentitlement in the Degan case and how that's
25 not - it's not relevant in our circumstance here.
503
1 The next paragraph, again Exhibit 250. It's something
2 from the criminal case. Not relevant for that reason.
3 Exhibit 249, the next sentence again, that's from the
4 criminal case and not relevant to this proceeding.
5 The next paragraph at line 15 of page 10, Exhibit 114
6 pertains to a tax case that Mr. Henson filed against RTC. It
7 may be interesting, but I don't see the relevance at all. I
8 mean certainly someone has got a constitutional right to file a
9 lawsuit, rightly or wrongly. I don't see what it proves one way
10 or the other.
11 Exhibit 233, the same thing. It has to do with R- -
12 with Henson's action against the RTC.
13 The next batch is headed Number 6, "Inaccurate
14 Schedules." I have no objection to anything in that category -
15 I'm sorry - on that page. On page 10, on that category, I don't
16 have any objection. In fact, I don't have anything in that
17 whole heading except for Number - this is on line 6 of page 11,
18 215 and 216 just appear to be postings without free - again free
19 speech postings without any particular context that makes any
20 significance, so far as I can see.
21 But except for those two, the remainder of the
22 exhibits noted, if I had an objection I withdraw the objection,
23 otherwise I didn't have objection. And RTC just chose to ramble
24 on about the - about these exhibits.
25 THE COURT: Okay.
504
1 MR. ZLOTOFF: Turning to page 12, the next heading is
2 Number 7. I have no objection to anything - any evidence or any
3 exhibit mentioned in that heading, nor did I ever.
4 Down the page on heading 8, there's nothing on page
5 12.
6 On page 13, there's a footnote, which is footnote 11,
7 in which is noted Exhibit 95. I withdraw the objection I had to
8 Exhibit 95. I didn't - I don't think I ever had an objection to
9 Exhibit 98 mentioned right next to it. Nor did I to the other
10 exhibits noted.
11 Back to the top of the page on page 13 -
12 THE COURT: 14?
13 MR. ROSEN: No, page 13, the top of the page 13.
14 Again, we're on -
15 THE COURT: I see. Yeah, because you went to the
16 footnote.
17 MR. ROSEN: - Heading 8. Exhibits 125 and 126 pertain
18 to model plans. And to me those are irrelevant. And they're
19 irrelevant because I could take a model plan, I could cross out
20 lines and add lines. And, you know what, I'd end up with our
21 model plan. And what difference does it make? What does it
22 prove? What does it show?
23 You could do anything with the plan and the issue is
24 what's in a plan and was it objected to? And that's all. I
25 mean the fact that somebody uses one form or another doesn't
505
1 mean you can't add or delete to a model plan. And so the issue
2 is really what's before the Court; and the others are utterly
3 irrelevant. They don't prove anything. The other exhibits
4 noted I had no objection to, in any event.
5 Going to the next heading, Number 9, "Misconduct." No
6 objections to anything in that batch. I had objected to 222 and
7 224 to 226. I withdraw my objections to those. The others
8 noted, I don't think I had any objection to, to begin with.
9 Page 14, the next heading, Heading 10. No objections.
10 Again, I don't think I had any to begin with in that - in that
11 series. Oh, I'm sorry, except for again at the bottom, 215 and
12 216. I previously noted as they were in another - another
13 heading. So except for Exhibits 215 and 216, which are noted at
14 the bottom of page 14, I don't have any objection to any of the
15 other exhibits noted. And the 215 and 216 were postings,
16 Internet postings which I contend are just free speech.
17 Page 15, Heading 11, I have no objections to anything
18 in that. If I objected to 272, I withdraw that. The others I
19 don't think I objected to, to begin with.
20 Heading Number 12, I had no objection, to begin with,
21 with anything in that column.
22 Heading 13 on page 15, the last one. Again, all of
23 these indicated here have to do with - I think almost all of -
24 are more recent postings. And to me they're just free speech
25 postings. We're talking about 2- - Exhibit 253, 254, 188, 238,
506
1 251, 255, and 265. And those are all again free speech postings
2 and not relevant. And that's...
3 THE COURT: I know you are ready to argue, Mr. Rosen.
4 Are you finished, Mr. Zlotoff?
5 MR. ZLOTOFF: I think so, yes.
6 THE COURT: But I intended to admit almost all of
7 these documents. Maybe you ought to hear my decision before you
8 make an argument.
9 Essentially all of the exhibits - and I'm not able to
10 switch back and forth between what was in the footnote, what
11 RTC's brief says, and what you just said. So I'm going to have
12 to do this more broad brush. But essentially they're almost all
13 admitted.
14 I'm faced with the totality-of-the-circumstances test
15 which I have to apply. And that includes Mr. Henson's alleged
16 motive for filing bankruptcy. RTC says it's not to reorganize
17 but to continue to harass the creditor and to try to destroy the
18 creditor by stopping the District Court trial, and running up
19 the creditor's expenses, et cetera, et cetera, is alleged
20 manipulation of the bankruptcy law to suit his own alleged
21 purposes of destroying the church, his alleged overall disregard
22 of the law.
23 And so essentially all of this comes in under the
24 totality-of-the-circumstances test, both the prepetition conduct
25 and the postpetition conduct, under the caselaw.
507
1 Mr. Zlotoff has alleged that certain, especially
2 postings, but perhaps other documents are free speech. And I
3 make no ruling on Mr. Henson's free speech. The fact that it
4 may be - Mr. Henson may be entitled under the free speech
5 doctrine to write something really is not what I'm focusing on.
6 What I'm focusing on is whether or not, under the
7 totality-of-circumstances test, a statement, a posting, a
8 writing, essentially any - any of these documents come in under
9 the totality-of-the-circumstances test, and I think that they
10 do.
11 There - and I can go through some of these, but
12 certainly what happened vis-a-vis the criminal trial, what
13 happened in these postings, and what happened in the District
14 Court are admissible under the totality-of-the-circumstances
15 test. The weight is a different matter, but I'm not going to
16 the weight at this point. I'm only talking about what's
17 admissible.
18 Exhibits 125 and 126 are model plans from other
19 districts and information regarding those model plans. Those
20 aren't relevant to whether the debtor acted in bad faith by
21 using the model plan that he's required to use in this district.
22 And efforts to avoid a lien as an impairment of a homestead
23 objection - homestead exemption, which the Bankruptcy Code
24 specifically permits, is not relevant to whether bankruptcy was
25 filed in bad faith. So those don't come in. In fact, there's
508
1 no knowledge that Mr. Henson even knew about the model plans in
2 any other district.
3 MR. ROSEN: What exhibit are you referring to?
4 THE COURT: I think they're 125 and 126.
5 MR. ROSEN: No, I know those as the model plans. But
6 you then said efforts to avoid a lien. Do you have an exhibit
7 that you are referring to, Your Honor?
8 THE COURT: I don't have a number. I think it's 122
9 and 187, and the claims filed by the creditor, 194 and 195. But
10 I believe 122 and 187 involve efforts to avoid the creditor's
11 lien.
12 MR. ROSEN: I don't - I don't believe so, Judge.
13 THE COURT: Well, we'll check.
14 MR. ROSEN: Okay.
15 THE COURT: We'll check. But, in any event, the - and
16 again, Mr. Zlotoff, I'm not able to go through all of the ones
17 that you've withdrawn. So I may discuss some of the ones that
18 you've withdrawn an objection to, or which were not listed in
19 your footnote but were referred to in RTC's brief. But under
20 the time I did the best that could.
21 The - Exhibit 275, page - is submitted to show the
22 debtor allegedly knew before publishing the creditor's work,
23 that it was copyrighted, and someone else had been enjoined from
24 publishing it, but went ahead and published it anyway.
25 Exhibit 1 is a de- - cease-and-desist letter to the
509
1 debtor. 2 is his refusal to stop. 99 is the District Court
2 summary judgment for the creditor. 3 is the June '97 permanent
3 injunction.
4 The District Court trial was May 5th, '98. Exhibit 20
5 are trial excerpts of a tape played for the jury. 213 is a tape
6 and transcript of excerpts played.
7 21 is debtor's answer to his attorney's question as to
8 whether he had been deterred from doing it again, "At least I
9 wouldn't do it openly."
10 36 is jury instruction regarding willfulness. 18 is
11 the jury's special verdict finding, willfulness. 173 is the
12 District Court judgment. 115 is the Ninth Circuit order
13 affirming.
14 100 is the Ninth Circuit order awarding creditor fees
15 for deterrence purposes.
16 Exhibits 112, 113, 116, 121, 124, 140, 142, 159, 168,
17 184, 213, 229, 230, 231, 232, 266, 267, 268, 275, and 279 are
18 statements by the debtor introduced to demonstrate his desire to
19 destroy the Scientology religion by various means.
20 107, 257, and 10 are debtor's alleged threats to
21 violate the injunction. Exhibit 109 is the District Court's
22 order expanding the injunction.
23 210 is this Court's order of relief from stay to allow
24 the creditor to go to state court regarding debtor's alleged
25 contempt of the injunction.
510
1 12 is the District Court order granting emergency
2 relief to stop threatened violation. 111 are findings of fact
3 by the District Court regarding contempt.
4 22 is the District Court contempt order. 25 is the
5 Ninth Circuit Court order affirming. 80 is debtor's statement
6 blaming other parties for those orders.
7 269, 270, and 274 are recent statements by the debtor
8 allegedly showing violation of injunction and intent to drive up
9 creditor's cost to enforce.
10 Exhibit 4 allegedly shows the District Court trial was
11 originally set for 12-97. And the debtor originally dated his
12 bankruptcy petition 12-1-97.
13 Exhibit 4 is the District Court's continuation of
14 trial due to its own schedule. Exhibit 6, 7, and 8 are debtor's
15 attempts to continue the trial again. 9 is the bankruptcy
16 petition filed after the continued efforts - the efforts to
17 continue failed.
18 256, the debtor's Bankruptcy Court notice to the
19 District Court within a very short time after filing bankruptcy.
20 209 is the Bankruptcy Court's March 23, 1998 relief-from-stay
21 order permitting the District Court to proceed.
22 211 is the debtor's notice of voluntary dismissal of
23 the bankruptcy case on March 24, '98.
24 5 and 28 - 5 and 258 are restraining orders issued
25 October '97 and December '97 to prevent the debtor from
511
1 harassing and picketing.
2 96 and 91 are the debtor's expression of appreciation
3 to those who supported picketing, and requests for additional
4 help.
5 94 and 93 are debtor's statements about amusing
6 himself and others at creditor's expense.
7 Exhibits 279 is his deposition about his picketing.
8 Exhibits 147 through 158 are statements by the debtor about his
9 picketing.
10 Exhibit 183 is a misdemeanor complaint which, of
11 course, isn't for the truth, but is relevant. 129 is a docket
12 sheet from that criminal case.
13 269 is part of the trial transcript from that case of
14 what the debtor did and why he did it. Exhibits 133, 34, 35 and
15 141, and 164 through 167 and 261 and 262 are published
16 statements by the debtor that were exhibits at the criminal
17 trial.
18 273 is a dismissal of the debtor's appeal from
19 conviction. 250 and 264 showed jury conviction of a hate crime.
20 249 shows sentencing.
21 114 is the District Court's dismissal of the debtor's
22 suit against IRS seeking to revoke Scientology Church tax-exempt
23 status. 233 is the Ninth Circuit's order affirming.
24 Exhibit 16 is the debtor's original schedules. 2 - 27
25 are amended schedules. Other information - other exhibits
512
1 attack the information in the schedules.
2 Exhibit 16 and 277 allegedly show that the house - the
3 value of the house is the purchase price. 91 is an appraisal
4 purporting to show it to be worth less - I'm sorry - more on the
5 date of bankruptcy.
6 81 through 83 and 93, 94, 96, 189, 215, 216, 276, 277,
7 278, and 279 are statements by the debtor that he's received
8 money from others that allegedly were not scheduled as assets.
9 279 and 179 allegedly show that the daughter's school
10 expenses are much higher than scheduled, which - and which were
11 paid by a credit card.
12 98, 278 - 98 and 278 are offered to show that the
13 scheduled phone expense is 50 percent of what it really is.
14 Exhibits 35, 47, 56, 67, 177, 178, 191, 286, 278
15 allegedly show that he denied having a life insurance policy
16 with cash value.
17 Exhibit 276 is allegedly his denial that he owns
18 artwork, but Exhibit 89, 160, 234 allegedly show that he does.
19 Exhibit 221, 89 show - allegedly show that he owns
20 stock bought shortly prepetition that isn't scheduled. 276 and
21 279 are his admissions that he had a credit card or credit cards
22 when he filed - or credit card. And allegedly shows that he
23 purposely didn't disclose it.
24 Exhibit 278 and 279 are tax returns, allegedly without
25 certain information. 171 is his effort to explain.
513
1 174 is an application to the District Court for pauper
2 status. 277 is - allegedly is Mr. Henson's admission that the
3 information - that it isn't correct.