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UNITED STATES DISTRICT COURT for the NORTHERN DISTRICT OF TEXAS DALLAS DIVISION R. Lance Flores, Vicki Clarkson, Plaintiffs, v. Scott Anthony Koster, et al. Defendants. ¹ 3:11-cv-00726-M -BH CIVIL ACTION

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VERIFIED MOTION TO STRIKE BRUCE H. HAGLUND’s ANSWER for FRAUD UPON THE COURT BY THE PERJURY AND FALSE STATEMENTS OF 1 BRUCE H. HAGLUND

Plaintiffs mutually file their Verified Motion to Strike RICO Defendant Bruce H. Haglund’s ANSWER OF DEFENDANT BRUCE H. HAGLUND TO PLAINTIFFS’ RICO COMPLAINT (hereinafter, the Defendant’s “Answer”). Plaintiffs’ shall separately file their Motion for Sanctions against Defendant Haglund unless Court has so moved sua sponti. Plaintiffs respectfully move the Court to strike RICO Defendant Bruce H. Haglund’s Answer, pursuant to FRCP 12(f) subject to the Court’s discretion and inherent powers including that of the Court’s dispositive authority.
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Hereinafter, “Bruce Haglund,” or “Haglund” or the “Defendant” RULE 12(f) Motion to Strike. The court may strike from a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter. The court may act: (1) on its own; or (2) on motion made by a party either before responding to the pleading or, if a response is not allowed, within 21 days after being served with the pleading.
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§ I. PROCEDURAL HISTORY 1.1 On April 8, 2011 Plaintiffs filed their Original Complaint, petition for

injunctive relief and other equitable relief in this matter. (Doc. 1, 1-1, 1-2) 1.2 On March 19, 2012, Plaintiffs amended their Original Complaint with their First Amended Complaint (Doc. 36) in behalf of the Plaintiffs, and in the national economic and general public interests. Plaintiffs amended, adding additional RICO Defendants, and Nominal Defendants and removing others into statuses in delayed discovery. Plaintiffs petition for compensatory damages including a plea of a damages amount directly related to Defendant’s acts in violation of 18 U.S.C. 1962, et seq., (“RICO” violations) exceeding not less than Two-hundred Twenty Million Dollars (Doc. 36 at 187) subject to mandatory treble award, notwithstanding other compensatory, exemplary, and injunctive relief, or further calculation of damages in prove-up motions or damages affidavit. 1.3 Plaintiffs additionally support their claims pled in conformance of FRCP Rule 9(b), with two-hundred seventy-two (272) verified exhibits, or exhibits entered as manifest fact by judicial notice, to evidence their claims. 1.4 Plaintiffs’ FAC pleads RICO Defendant jointly and severally liable for damages.
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Section 1964(c), title 18, provides that “[a]ny person injured in his business or property by reason of a violation of section 1962 of this chapter may sue therefor in any appropriate United States district court and shall recover threefold the damages he sustains and the cost of the suit, including reasonable attorney’s fees.” 18 U.S.C. § 1964(c). 4 See, e.g., United States v. Oreto, 37 F.3d 739, 752 (1st Cir. 1994) at 751-53 (finding that Congress intended to reach all who participated in the conduct of the enterprise, whether they were “generals or foot soldiers” and holding that the “Reves test” (Reves v. Ernst & Young, 507 U.S. 170 (1993) was satisfied by evidence that the defendant collected extortion payments under the direction of leaders of an extortion collection enterprise); Napoli v. United States, 32 F.3d 31, 36 (2d Cir. 1994) (overwhelming evidence that attorneys, although “of counsel” to the law firm enterprise, were not merely providing peripheral advice, but participated in the core activities that constituted the affairs of the firm), cert. denied, 513 U.S. 1110, reh'g granted, 45 F.3d 680, 683 (2d Cir.) (upholding convictions of law firm investigators who were “lower-rung participants” whose racketeering activities were conducted “under the direction of upper management”), cert. (continued...) 20120912210015 Motion to Strike BRUCE HAGLUND's Mtn Dismiss.wpd

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1.5 This matter is brought pursuant to, inter alia, Section 901(a) of the Organized Crime Control Act of 1970 (Pub.L. 91-452, 84 Stat. 922, enacted October 15, 1970), and codified as Chapter 96 of Title 18 of the United States Code as 18 U.S.C. § 1961–1968; 1.6 On July 10, 2012, Haglund, who was added to this action by the Plaintiffs in their First Amended Complaint (“FAC”), was properly and timely served. (Doc. 130) 1.7 On July 31, 2012, Haglund’s appearance and answer were due. 1.8 On July 31, 2012, RICO Defendant Bruce H. Haglund did not timely file an Answer nor otherwise responded to the First Amended Complaint, or make an appearance in any manner. 1.9 On August 8, 2012, Plaintiffs filed Application for Clerk’s Entry of Default and Memorandum of Law & Verified Motion for Default Judgment Against RICO Defendant Bruce H. Haglund. (Doc. 155) 1.10 On August 9, 2012, the Clerk of the Court entered Bruce H. Haglund into default. (Doc. 157-1)

(...continued) denied, 514 U.S. 1084 (1995); United States v. Urban, 404 F.3d 754 (3d Cir. 2005) at 769-70 (stating that “the ‘operation or management’ test does not limit RICO liability to upper management because ‘an enterprise is operated not just by upper management but also by lower-rung participants in the enterprise who are under the direction of upper management’”; and holding that Reves liability encompassed city employees who performed plumbing inspections and related work for the city’s Construction Services Department, the alleged enterprise) (internal quotation marks and citations omitted); United States v. Delgado, 401 F.3d 290 (5th Cir. 2005) at 297-98 (same); First Capital Asset Mgmt. v. Satinwood, Inc., 385 F.3d 159, 176 (2d Cir. 2004) (“‘RICO liability is not limited to those with primary responsibility for the enterprise’s affairs’” (citation omitted)); Baisch v. Gallina, 346 F.3d 366, 376 (2d Cir. 2003) (same and adding that “[o]ne is liable under RICO if he or she has ‘discretionary authority in carrying out the instructions of the [enterprises’] principals’”) (citations omitted); DeFalco v. Bernas, 244 F.3d (2d Cir. 2001) at 309 (ruling that RICO liability “is not limited to those with primary responsibility” or “to those with a formal position in the enterprise,” and finding that there was sufficient evidence to satisfy the Reves test where the defendant instructed others to facilitate commission of racketeering activity) (internal quotation marks and citations omitted); United States v. Posada-Rios, 158 F.3d 832, 857 (5th Cir. 1998) (finding that Reves does not require that the defendant have decision-making power, only that defendant “take part in” the operation of the enterprise, and holding that the defendant was liable under Reves since he bought multi-kilogram amounts of cocaine from the drug enterprise on a regular basis); United States v. To, 144 F.3d 737, 747 (11th Cir. 1998) (holding that Reves test was satisfied by evidence that the defendant planned and carried out a robbery with other members of an Asian crime gang that committed a series of robberies targeting Asian-American business owners and managers). 20120912210015 Motion to Strike BRUCE HAGLUND's Mtn Dismiss.wpd

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1.11 On August 10, 2012, ten days into default, Haglund filed his untimely answer, disingenuous, verified Answer under pain of perjury. (See, Doc. 164 at 16): “VERIFICATION OF BRUCE H. HAGLUND TO PLAINTIFF’S FIRST AMENDED COMPLAINT I have read the foregoing Answer to Plaintiffs’ First Amended Complaint, and verify that the responses given in the Answer are true and correct to the best of knowledge, information and belief. I declare under penalty of perjury of the laws of the United States and the State of California that the foregoing is true and correct. Executed this 6th of August, 2012 at Los Angeles, California s/Bruce H. Haglund” 1.12 On August 13, 2012, Hon. Irma Carrillo Ramirez, USMJ, Referring, issued an order for scheduling proposals due on September 4, 2012 no later than 5:00 PM CST. 1.13 On August 20, 2012, Plaintiffs filed a joint Scheduling Proposal and attached a proposed Scheduling Order. 1.14 On September 4, 2012, RICO Defendant Bruce H. Haglund failed to file a scheduling proposal.

§ II. BACKGROUND 2.1 RICO Defendant Bruce H. Haglund, is a California lawyer, admitted to The State Bar of California on May 30,1980, is presently “Not Eligible To Practice Law” and lost his eligibility to practice law on July 3, 2012. 2.2 In Haglund’s Answer to the SEC v. Wilde, et al. Complaint Haglund admitted he received funds from investors, and transmitted funds to other Defendants and Relief
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United States Securities and Exchange Commission vs. Francis E. Wilde, et al., 8:11-cv-00315-DOC -AJW, U.S. Dist. Ct. CD Cal. 05/13/11 (Document 1, the “SEC Complaint”; all proceedings thereto related, cumulatively, the “SEC Action”), also (Document 4, the “Haglund’s SEC Comp. Answer”). 20120912210015 Motion to Strike BRUCE HAGLUND's Mtn Dismiss.wpd

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Defendants.

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2.3 In SEC v. Wilde, et al., Haglund admitted that he resides, conducted transactions, and maintains his [IOLTA] trust account in the Central District of California.
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2.4 In SEC v. Wilde, et al., Haglund admitted that he made use of the means of instrumentalities of interstate commerce in connection with the acts and courses of business alleged in the [SEC] Complaint.
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2.5 Plaintiffs incorporate by reference from the Court Record, the averments, facts, allegations, and statements contained in 2.5.1 Plaintiffs’ FIRST AMENDED COMPLAINT (Doc. 36), and 2.5.2 Plaintiffs’ Exhibit 272 (Doc. 200-1) “DEFENDANT BRUCE H. HAGLUND’S ANSWER
TO COMPLAINT” in SEC v. Wilde, et al., (See also, Plaintiffs’ Motion for Judicial Notice,

Doc. 200), all which are hereby re-averred and re-alleged, for all purposes, and with the same force and effect as if set forth verbatim herein. 2.6 Plaintiffs attest that RICO Defendant’s motion was supported by false statements by and through perjury, sent over the interstate wires in a deliberate and wanton attempt to obstruct justice. 2.7 The Defendant Haglund’ false statements were submitted with scienter, knowingly made, in a material declaration by oath made under pain of perjury, and
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See, Haglund’s SEC Comp. Answer, Doc. 4, ¶ 1, at 2. id., ¶ 7, at 2. 8 id., ¶ 8, at 2. 9 United States v. Gorman, 613 F.3d 711, 715-16 (7th Cir. 2010)(“To support a conviction for perjury beyond a reasonable doubt, the government had the burden of proving that (1) the defendant, while under oath, testified falsely before the grand jury; (2) his testimony related to some material matter; and (3) he knew that testimony was false”); United States v. Hasan, 609 F.3d 1121, 1134 (10th Cir. 2010)(“To establish guilt under the statute, the government must prove beyond a reasonable doubt that: (1) the defendant made a declaration under oath before a grand jury; (2) such declaration was false; (3) the defendant knew the declaration was false and (4) the false declaration was material to the grand jury’s inquiry”); United States v. (continued...)
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submitted in a proceeding before this Court. Haglund’s fraud upon the Court was intentional, willfully blind to the truth, and fraught with Defendant’s reckless disregard for the law. 2.8 Defendant’s fraud upon the Court is found in his claims that contradict manifest fact, previous declaration and physical evidence where such perjury and false statements are evident on the face of his Answer. Haglund knew, that his verified Answer submitted to the Court was material to the First Amended Complaint and issues at hand. Haglund intended his false statement to become the gravamen of his denials, and these most serious disputes would give grave concern to the Court and alter the outcome of the case against him. Haglund was well aware that his false statements and perjury would have a natural tendency to influence, or was capable of influencing, the decision of the fact finder, in this instance, the Magistrate Judge (referring) and the Presiding Judge. patently offensive to the Court’s bench and bar. 2.9 With respect to all RICO Defendants, the well-established and verified manifest fact in the Plaintiffs’ First Amended Complaint and the Record of the Court, give historical evidence to an unmistakable pattern of mutual and complotted conduct replete with fraud, lies, misinformation, purposeful misdirection, and concealment by the RICO Defendants.
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Haglund’s Answer is

WHEREFORE, the grounds for Plaintiffs’ Motions are set forth in the facts argument, and law below:
(...continued) Safa, 484 F.3d 818, 821 (6th Cir. 2007)(“To convict an individual of a violation of 18 U.S.C. 1623, the government must prove beyond a reasonable doubt that the defendant: (1) knowingly made, (2) a materially false declaration (3) under oath (4) in a proceeding before or ancillary to any court of the United States”); United States v. Pagan-Santini, 451 F.3d 258, 266 (1st Cir. 2006); United States v. Hirsch, 360 F.3d 860, 864-65 (8th Cir. 2004). 10 See, United States v. Brown, 459 F.3d 509, 529 (5th Cir. 2006), citing, United States v. Gaudin, 515 U.S. 506, 509 (1995), and Kungys v. United States, 485 U.S. 759, 770 (1988); see also United States v. Benkahla, 530 F.3d 300, 310 (4 Cir.2008); United States v. McKenna, 327 F.3d 830, 839 (9th Cir. 2003); United States v. Lee, 359 F.3d 412, 417 (6 Cir.2003); United States v. Durham, 139 F.3d 1325, 1329 (10th Cir. 1998). 20120912210015 Motion to Strike BRUCE HAGLUND's Mtn Dismiss.wpd
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§ III. PLAINTIFFS’ MOTION TO STRIKE FOR DEFENDANT’S/COUNSEL’S FRAUD UPON THE COURT 3.1 The question before the Court is whether RICO Defendant Haglund has engaged in conduct by the extensive fraud exhibited by his false statements and perjury, and whether Defendant Haglund is deserving of having his Answer stricken and due additional sanctions. 3.2 The Court may impose further sanctions on a latter motion from the Plaintiffs or on the Court’s own motion. Plaintiffs’ statement of fact and argument will show, unambiguously, that Haglund’ Answer is intentionally false, willfully blind to the truth and misleading, and deserving of sanction. 3.3 Because Defendants Haglund’ actions are directed at the judicial machinery, and that they demonstrate, at a minimum, a reckless disregard of the truth, the Plaintiffs request an expedited action to address these serious issues, by striking Defendant’s Answer which has severely prejudiced, harassed, and oppressed the Plaintiffs. 3.4 In support thereof Plaintiffs show the following: 3.5 FRAUD UPON THE COURT – COUNT 1 PERJURY – COUNT 1 OBSTRUCTION OF JUSTICE – COUNT 1 3.5.1 RICO Defendant’s Haglund’ Answer. Doc. 164 at 5, lines 5-8 “Defendant denies the allegations contained in Paragraphs 5.13, 5.13.1 through 5.13.4.” Referring to Plaintiffs’ FAC (Doc. 36 at 79, 80): 5.13 DEFENDANTS MISAPPROPRIATE INVESTOR FUNDS FOR UNAUTHORIZED AND UNDISCLOSED PURPOSES 5.13.1 Wilde exhausted all $6.3 million of the investors' funds through attempts to acquire "bank guarantees," brokers' fees paid to Gelazela and Woods, fees to Haglund for "legal services," some Ponzi-like payments to prior investors, and personal expenses.
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5.13.2 Each investor's money was wired out of the trust account soon after it arrived. In some instances, fees to Wilde, Gelazela, Woods and/or Haglund equaled a majority of the associated investment, and each of the individual Defendants personally profited from the scheme. 5.13.3 The majority of investors' funds in the trust account were transferred on direction by Wilde and executed by Haglund as follows: • Approximately $2,170,000 was claimed to be paid to over thirty different intermediaries, advisors, and business consultants for the purpose of acquiring purported bank instruments. • Over $1,500,000 went to pay for Wilde's personal expenses, including: • Approximately $800,000 to the bank account of Wilde's wife, Maureen Wilde †11, †12, †14, †15; • $323,500 to Shillelagh Capital Corporation †11, †12, †14, †15, another corporate entity under Wilde's control; • $200,000 to Wilde's bank account in Europe †11, †12, †14, †15; • $55,000 to the assisted living facility of Wilde's parents †11, †14; • $1,150,000 in fees to Gelazela (to a bank account in the name of IBalance LLC †11, †12, †14, †15, a corporate entity for which Gelazela serves as a managing member); • $565,000 in fees to Woods, which equaled roughly half of the total investor money Woods brought in to the scheme †11, †12, †14, †15; and • $472,500 in fees to Haglund †11, †12, †14, †15. 5.13.4 Relief Defendants Maureen Wilde, Shillelagh Capital Corporation, and IBalance LLC had and have no right or legitimate claim to any investor funds that they received. 5.13.5 In early May 2010, less than $200 (two hundred dollars) of the $6.3 million raised for the Bank Guarantee Scheme remained in the trust account. IMPEACHMENT OF RICO Defendant Haglund’s Answer. Doc. 164 at 5, lines 5-8: The aforementioned is impeached by Defendant Haglund’s declaration made in Haglund's SEC Comp. Answer, SEC Action (Doc. 4 at 10), Pla. Exhibit 272 (Doc. 200-1 at 10). ¶ 79. “In answer to ¶ 79, Answering Defendant [Haglund] admits that all $6.3 million of the investors' funds were exhausted by attempts to acquire "bank guarantees," fees paid to or for the benefit of Wilde, Woods, Gelazela, fees to Answering Defendant, and payments of $1 0,000 to each of two separate investors.

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¶ 80. “In answer to ¶ 80, Answering Defendant admits the allegations of this paragraph.” [“80. Each investor's money was wired out of the trust account soon after it arrived. In some instances, fees to Wilde, Gelazela, Woods and/or Haglund equaled a majority of the associated investment, and each of the individual Defendants personally profited from the scheme.”] (SEC v. Wilde, et al., ¹ 8:11-cv-00315-DOC-AJW, CD Cal. Feb 24, 2011 at 14)

¶ 81. “In answer to ¶ 81, Answering Defendant admits that (i) approximately $2,170,000 was paid to over 30 different intermediaries, advisors, and business consultants for the purpose of acquiring bank instruments, (ii) approximately $1,500,000 was paid to Wilde, Maureen Wilde, Shillelagh, law firms that represented Wilde, and to the assisted living facility of Wilde's parents, (ii) approximately $1,150,000 was paid to Gelazela and/or IBALANCE, (iv) approximately $565,000 was paid to Woods, and (v) approximately $472,500 was paid to Answering Defendant in fees. Other than as expressly admitted herein, Answering Defendant denies each of the remaining allegations of ¶ 81.”

3.6 Haglund’ statement is wholly fraudulent, unsupported by any verifiable material evidence, lacks authentication and is wholly and unquestionably controverted, thusly impeached, by his own declaration entered in the Record of the United States District Court for the Central District of California.

3.7 FRAUD UPON THE COURT – COUNT 2 PERJURY – COUNT 2 OBSTRUCTION OF JUSTICE – COUNT 2 3.7.1 RICO Defendant’s Haglund’ Answer. Doc. 164 at 11, line 25: “Defendant denies the allegations contained in Paragraphs 9.5, 9.5.1 through 9.5.7.” Referring to Plaintiffs’ FAC (Doc. 36 at 111):
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“9.5.3 The Defendants, directly and indirectly, made use of the means and instrumentalities of interstate commerce and extensively used the domestic communication wires in connection with the Defendants acts, practices, and courses of business alleged herein within the Northern District of Texas, Calgary Alberta, Canada, and elsewhere.” IMPEACHMENT OF RICO Defendant Haglund’s Answer. Doc. 164 at 11: The aforementioned is impeached by Defendant Haglund’s declaration made in Haglund's SEC Comp. Answer, SEC Action (Doc. 4 at 2), Pla. Exhibit 272 (Doc. 200-1 at 2). ¶7. “In answer to ¶ 7, Answering Defendant admits that he resides, conducted transactions, and maintains his trust account in the Central District of California.” ¶ 8. “In answer to ¶ 8, Answering Defendant admits that he made use of the means of instrumentalities of interstate commerce in connection with the acts and courses of business alleged in the Complain[t].” 3.8 Haglund’ statement is wholly fraudulent, unsupported by any verifiable material evidence, lacks authentication and is wholly and unquestionably controverted, thusly impeached, by his own declaration entered in the Record of the United States District Court for the Central District of California.

3.9 FRAUD UPON THE COURT – COUNT 3 PERJURY – COUNT 3 OBSTRUCTION OF JUSTICE – COUNT 3 3.9.1 RICO Defendant’s Haglund’ Answer. Doc. 164 at 5, line 7: “Defendant denies the allegations contained in Paragraphs 5.14, 5.14.1 through 5.14.11.” Referring to Plaintiffs’ FAC (Doc. 36 at 81): “5.14.5 In 2007, Haglund served as an escrow attorney for another prime bank investment scheme that failed and resulted in nearly all investors losing their money. As a result of his involvement in that
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investment program, an investor filed a complaint against Haglund with the State Bar of California.” IMPEACHMENT OF RICO Defendant Haglund’s Answer. Doc. 164 at lines 7-8: The aforementioned is impeached by Defendant Haglund’s declaration made in Haglund's SEC Comp. Answer, SEC Action (Doc. 4 at 12), Pla. Exhibit 272 (Doc. 200-1 at 12). ¶ 101. “In answer to ¶ 101, Answering Defendant admits that a party who deposited funds into his trust account filed a complaint with the Sate Bar of California …” 3.10 Haglund’ statement is wholly fraudulent, unsupported by any verifiable material evidence, lacks authentication and is wholly and unquestionably controverted, thusly impeached, by his own declaration entered in the Record of the United States District Court for the Central District of California.

SUMMARY & CONCLUSION 3.11 IN SUMMARY, the record evidence clearly and convincingly establishes that Bruce H. Haglund has engaged in a pattern of misconduct in this litigation that includes making false statements to the Court by means of his overt act of perjury. There is no escaping that when Haglund signed his Answer to this Court under pain of perjury, that he knew he was about to file a perjured document. He was well aware that his answer to this Court contradicted what he declared in the U.S. District Court in California. 3.12 The record evidence shows clearly and convincingly that Haglund was not truthful and knowingly made misrepresentations in his pleadings, i.e. false statements within his Answer, and deliberately presented a perjured instrument, in order to explain away his commission of predicate crimes and participations in the actions of the various criminal enterprises. The record unequivocally establishes by clear and convincing

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evidence that Haglund committed fraud upon the Court by overt acts of perjury. 3.13 Accordingly, Haglund's conduct falls squarely within the definition of “fraud on the court”
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and is a clear abuse of the judicial process.

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An appropriate sanction is

warranted

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as there is no question that Haglund's conduct constitutes a serious abuse of

the litigation process. 3.14 The inherent authority of a court to impose sanctions for bad-faith, if not criminal conduct, reaches RICO Defendant, where Haglund in his Answer presents extensive fraud to the Court. Were the rule otherwise, a charging party would have a powerful incentive to commit fraud, perjury, and to suborn that perjury, for in that event, a charging party could engage in discovery fraud with impunity and if successful the charging party would obtain an unfair advantage in the litigation.

§ IV. PRAYER It is Plaintiffs’ belief and contention that additional sanctions should be awarded for reasonable costs associated with preparing and tiling this Motion to Strike. Plaintiffs shall effect notice of sanctions for which they shall separately file pursuant to the Rules unless Court has spoken to such as the Court has the inherent authority to award costs or other sanction when a party has “acted in bad faith, vexatiously, wantonly, or for oppressive

See, e.g., Nichols v. Klein Tools, 949 F.2d 1047, 1048-49 (8th Cir. 1991) (imposing sanctions for "fraud on the court" where plaintiff concealed a material fact); Yanez v. America West Airlines, 2004 U.S. Dist. LEXIS 20706, at *19 (D. Md. Oct. 13, 2004) (holding that plaintiff perpetrated a "fraud on the court" by providing intentionally false deposition testimony and deliberately failing to meet discovery obligations to hide evidence of obvious high relevance to his claim for damages). 12 A federal court has the inherent authority to impose sanctions for fraud on the court or abuse of the litigation process. See, United Slates v. Shaffer Equip. Co., 11 F.3d 450,462 (4th Cir. 1993) ("[W]e recognize here that when a party deceives a court or abuses the process at a level that is utterly inconsistent with the orderly administration of justice or undermines the integrity of the process, the court has the inherent power to dismiss the action.") 13 Cf. Chambers v. NASCO, Inc., 501 U.S. 32 (1991). 20120912210015 Motion to Strike BRUCE HAGLUND's Mtn Dismiss.wpd

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reasons.”

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Moreover, it appears that Haglund has the financial means to pay an award of

monetary sanctions for this Motion. Further, permitting such an award would likely dissuade Haglund and other defendants that have demonstrated the same conduct identified in the Plaintiffs’ First Amended Complaint from pursuing similar conduct and demeanor in these proceedings.

WHEREFORE, the Plaintiffs pray an appropriate Order will issue from this Court striking completely, RICO Defendant Bruce H. Haglund’s ANSWER OF DEFENDANT BRUCE H. HAGLUND TO PLAINTIFFS’ RICO COMPLAINT with prejudice and for any other sanction or relief the Court deems appropriate .

Respectfully Submitted on Friday, September 14, 2012.

s/ R. LANCE FLORES Lead Attorney 3314 Pleasant Drive Dallas, Texas 75227 USA Tel. (Dallas): +1 (214) 272-0349 Tel. (Fax): +1 (210) 519-6528 ECF & Case Management E-mail: LF_legaldept@MockingbirdFilms.com Attorney for the Plaintiff

s/ VICKI CLARKSON 2416 - 36 Street SW Calgary, AB T3E 2Z5 Tel. (Calgary): +1 403-244-9980 Tel. (Fax:) +1 (403) 246-3331 ECF & Case Management E-mail: VC_LegalDept@MockingbirdFilms.com Attorney for the Plaintiff

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Id., at 45-46.

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VERIFICATION OF CLARKSON I, Vicki Clarkson hereby declare, verify and certify under penalty of perjury as provided by 28 U.S.C. § 1746 that I am a Plaintiff in the above-styled and -numbered cause of action, that I have read the foregoing motions to strike Defendant’s pleadings for fraud upon the Court and perjury, that I am familiar with the contents therein, and that the matters contained in the motions are true and correct to my own knowledge, except those matters herein stated to be alleged on information and belief and, as to those matters, I believe them to be true and correct. SUBSCRIBED AND EXECUTED on Friday, September 14, 2012 pursuant to 28 U.S.C. § 1746:

s/ VICKI CLARKSON

VERIFICATION OF FLORES I, R. Lance Flores hereby declare, verify and certify under penalty of perjury as provided by 28 U.S.C. § 1746 that I am a Plaintiff in the above-styled and -numbered cause of action, that I have read the foregoing motions to strike Defendant’s pleadings for fraud upon the Court and acts of perjury, that I am familiar with the contents therein, and that the matters contained in the motions are true and correct to my own knowledge, except those matters herein stated to be alleged on information and belief and, as to those matters, I believe them to be true and correct. SUBSCRIBED AND EXECUTED on Friday, September 14, 2012 pursuant to 28 U.S.C. § 1746:

s/ R. LANCE FLORES

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CERTIFICATE OF SERVICE On Friday, September 14, 2012, I electronically submitted the foregoing document with the Clerk of Court for the U.S. District Court, Northern District of Texas, using the electronic case filing system (CM/ECF) of the Court. I hereby certify that I have served all counsel and/or pro se parties of record electronically or by another manner authorized by Federal rule of Civil Procedure 5 (b)(2). For the Plaintiffs:

s/ R. LANCE FLORES

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Case 3:11-cv-00726-M-BH Document 201 Filed 09/14/12

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CERTIFICATE OF CONFERENCE Plaintiff Flores certifies that on Friday, August 31, 2012, Plaintiffs jointly attempted to confer with Bruce H. Haglund. Plaintiffs called the phone number provided by RICO Defendants John Divens, Bruce Haglund, Francis Wilde, and Nominal Defendant Maureen Wilde. Mr. Divens answered the Plaintiff’s phone call, however, he refused to speak with Plaintiffs after being informed that Plaintiffs were calling to confer with him, Bruce Haglund, Francis Wilde, and Maureen Wilde, concerning Plaintiffs’ motion for extension of time and their sanctions motions. None of the aforementioned Defendants came to the phone. Mr. Divens placed the call on hold and a Mr. Irving Parchman took the call. He was informed of Plaintiffs’ need to speak and confer with the defendants whose phone numbers given in their answers as (310) 601-3168, the number which Plaintiffs had called. Mr. Parchman spoke with Plaintiffs and stated he would leave messages with defendants Bruce H. Haglund, Francis E. Wilde, and Maureen Wilde, but did not call the defendants to the phone. Since that time Plaintiffs have not been able to contact any of the aforementioned defendants, nor have the aforementioned defendants returned Plaintiffs’ calls or responded to Plaintiffs’ request for conference. For the Plaintiffs: Friday, September 14, 2012 s/ R. LANCE FLORES

20120912210015 Motion to Strike BRUCE HAGLUND's Mtn Dismiss.wpd

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