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2009-07-12_opposition_to_motion_to_seal_redacted

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					             IN THE KING COUNTY DISTRICT COURT - WEST DIVISION
                 STATE OF WASHINGTON - SEATTLE COURTHOUSE


GLENN HAGELE - “COUNCIL FOR )              SMALL CLAIM NO. 85-11924
REFRACTIVE SURGERY              )
QUALITY ASSURANCE”              )
                                )          DEFANDANT'S OPPOSITION TO
Plaintiff,                      )          PLAINTIFF'S MOTION TO SEAL COURT
                                )          DOCUMENTS FILED BY DEFENDANT,
v.                              )          SEAL ALL SUBSEQUENT DOCUMENTS
                                )          FILED BY DEFENDANT, REQUIRE
BRENT HANSON                    )          DEFENDANT FILE ALL FUTURE
                                )          DOCUMENTS UNDER SEAL
Defendant                       )
_______________________________ )          Portions of this document are protected from
                                           public disclosure by order of the Sacramento
                                           Superior Court in California


INTRODUCTION                                                                              3

GLENN HAGELE HAS BEEN A PUBLIC FIGURE SINCE 2000                                          3

Media Representative for TLC Laser Eye Centers in a Public Dispute with the Defendant 3

Media Representative for Alcon to Conceal Reports of Malfunctioning Lasers                 3

Scheme to Publicly Represent the Worst Lasik Surgeon in Chicago, for Homegrown Lasers
Used in Hair Removal                                                                8

Media Representative for Two of the Worst Surgeons in California                           9

GLENN HAGELE'S PRIOR MIS-USE OF COURT DOCUMENTS AND PROTECTIVE
ORDERS FOR CREATING SELF SERVING PRESS RELEASES               12

GLENN HAGELE'S PRIOR MIS-USE OF COURT DOCUMENTS AND PROTECTIVE
ORDERS TO SHUT DOWN WEB SITES                                 14

Scheme to Shut Down Defendant's Web Site at LasikFraud.com in 2006                        14

Scheme to Shut Down Lasik-Flap.com, LasikFraud.com, and LasikDisaster.com in 2007 15

GLENN HAGELE'S TRUE OBJECTIVE IN FILING A MOTION TO SUPRESS PUBLIC
DOCUMENTS                                                        18
Suppress Information Regarding His Advertisements that Falsely Represent Dr. Michael
Mockovak and Dr. Joseph Kings are Members of CRSQA in Washington                     18

DEFENDANT'S SUBMISSION OF ALTERNATE DOCUMENTS TO THE COURT
WITH REDACTED CONTENT                                                               19
Introduction

        Defendant, Brent Hanson opposes Plaintiff's Motion to Seal Court Documents Filed by
Defendant, Seal All Subsequent Documents Filed by Defendant, Require Defendant File All
Future Documents Under Seal. Defendant does not object to sealing quotations of Glenn Hagele
in documents that originate from protected depositions of Glenn Hagele. However, Defendant
opposes the efforts by the Plaintiff to seal all documents, or any portions of documents that are
not protected by the Superior Court of Sacramento. Defendant opposes Plaintiff's motion on the
basis that the Plaintiff is a public figure, and that the suppression of criminal activity performed
by the Plaintiff does not serve the best interest of the public.

Glenn Hagele Has Been a Public Figure Since 2000

Media Representative for TLC Laser Eye Centers in a Public Dispute with the
Defendant

        In September 2000 Defendant, Brent Hanson, began publishing web sites which
criticized TLC Laser Eye Centers for damaging his vision, concealing the malpractice that was
committed by TLC, and refusals to honor an advertised “Lifetime Commitment”.1 Defendant,
Brent Hanson, later had to undergo a cornea transplant to repair some of the damage that was
committed by TLC. The Vice President for Clinical Affairs of TLC, Dr. David Eldridge, was on
the Board of Trustees of CRSQA at the time, 2 and made various misrepresentations to Brent
Hanson regarding obligations and promises to repair the damage caused by TLC.3

         The media began writing stories about the web sites, including one at DavidEldridge.com
that criticized Dr. Eldridge. Glenn Hagele began a campaign to publicly discredit Brent Hanson
on behalf of Dr. David Eldridge. Glenn Hagele subsequently began publishing articles in which
he falsely claimed that TLC had “successfully sued” Brent Hanson. TLC currently has a stock
price of .18 cents per share, and appears to be preparing for bankruptcy and liquidation, due to
mismanagement by company executives.

Media Representative for Alcon to Conceal Reports of Malfunctioning Lasers

        In 2004, reports of malfunctioning lasers manufactured by Alcon Laboratories began
surfacing in the media. Plaintiff, Glenn Hagele, began to issue a variety of press releases
claiming that the reports were false, and that Alcon's lasers were “safe”.4 Fox News
subsequently published audio tapes of telephone conversations between various surgeons,
including two CRSQA surgeons, with the CEO of Alcon, in which the surgeons complained of

       1
         Exhibit 201 – Globe and Mail (Toronto). Unhappy Laser Vision Customer Uses Web
Sites Against TLC. July 20, 2000.
       2
       Exhibit 202 – CRSQA's Tough Questions For Your Doctor.
       3
       Exhibit 203 – LASIK VISION CANADA INC., PLAINTIFF vs. TLC WEST INC., TLC
LASER CENTERS INC., ELIAS VAMVAKAS, JEFFERY MACHAT, PAUL DAME, BART
MCROBERTS, AND MICHAEL MELENCHUK, DEFENDANTS, AFFIDAVIT OF BRENT
HANSON.
     4
       Exhibit 204 – Hagele, Glenn. Patient Advocates: No Unusual LASIK Problems With Alcon
LADARVision. USENET: September 1, 2004.
erratic behavior by Alcon's lasers.5 Fox News showed the web sites of two CRSQA surgeons,
Dr. David Dulaney and Dr. Joseph Dello Russo. The web sites shown by Fox News clearly
showed the CRSQA logo, which demonstrated the surgeons were members of CRSQA. Fox
News also showed evidence of poor outcomes with Alcon lasers by another CRSQA surgeon,
Dr. Kent Kirk.

        The Plaintiff previously received funding from Alcon to perform a marketing study that
was distributed to LASIK surgeons.6 The Plaintiff's motive in issuing press releases to cover up
reports of malfunctioning lasers, was to curry favor with Alcon executives, and to obtain a high
paying job with the company.

Excerpts from a deposition taken on September 17, 2007 in Sacramento, California, are provided
as follows:

      Excerpt #17
      Jim Donahue          Do you provide consulting services to nonphysicians?
      Glenn Hagele         Of course.

      Jim Donahue          Who?
      Glenn Hagele         To manufacturers, to providers, to insurance companies.

      Jim Donahue          Have any manufacturers, providers or insurance companies retained
                           your services as a consultant in the past five years?
      Glenn Hagele         No.

      Jim Donahue          Do you have any information that any insurance companies,
                           manufacturers or providers have declined to utilize your services as a
                           consultant due to alleged activities of Mr. Hanson?
      Glenn Hagele         Yes.

      Jim Donahue          Who?
      Glenn Hagele         Alcon.

      Jim Donahue          Alcon? What is Alcon?
      Glenn Hagele         Alcon is a laser manufacturer. They're owned by Nestle.


      David Foos           Maybe you better spell that for the record.
      Glenn Hagele         A-L-C-O-N.

      Jim Donahue          And when did you approach Alcon for consulting service?
        5
           Exhibit 205 – Fox Chicago News. Living with LASIK, Part 2. December 21, 2004. Video is
on a supplemental CD with a filename of “Exhibit 205 - Fox Chicago News.mpg”.
         6
           Exhibit 206 – Hagele, Glenn. Targeting Patients with Precision. A look at the most detailed
refractive marketing data ever collected. Ophthalmology Management. March 2002.
         7
           Exhibit 207 – Hagele vs. Hanson. Deposition of Glenn Hagele by James R. Donahue on
September 17, 2007. Video excerpt is on a supplemental CD with a filename of “Exhibit 207 -
Deposition of Hagele on 2007-07-17.mpg”.
Glenn Hagele   Alcon and I worked on a joint project about five years ago.

Jim Donahue    What project was that?
Glenn Hagele   It was analysis -- it was a psychodemographic analysis of people who
               are getting refractive surgery.

Jim Donahue    What was your role in that analysis?
Glenn Hagele   Our organization had demographic data of patients that had received
               surgery. They paid for a outside company to analyze that data and to
               coordinate that data with their predefined psychodemographic
               categories.

Jim Donahue    What -- what --
Glenn Hagele   So what I did is I provided the data to the third company, they
               generated the reports, and we both got copies of the reports.

Jim Donahue    All right. So your role was to provide data that you had in your system.
Glenn Hagele   Yes.

Jim Donahue    And what data did you provide concerning the patients?
Glenn Hagele   I believe that the only thing that they needed was Zip Codes, but I we
               also had provided sex and age.

Jim Donahue    You didn't provide names or addresses?
Glenn Hagele   Oh, no, no, no. Heavens no.

Jim Donahue    So your role in this psychodemographic analysis was to provide Zip
               Codes, sex and age of patients to the third party?
Glenn Hagele   If -- well, actually, I put the whole thing together. I -- I went to them
               with the idea of getting the microvision psychodemographics
               completed. The – it would be very beneficial for our organization to
               better understand who the patients were but we couldn't afford to have
               Claritas, that's C-L-A-R-I-T-A-S, do the analysis.

               They felt the information would be beneficial to them as well. I did
               analysis of the report and presented theanalysis based upon the data
               that we -- or the feedback we received from Claritas.

Jim Donahue    Were you compensated in any way for this activity involving your -- the
               psychodemographic report?
Glenn Hagele   I didn't -- this was all done through CRSQA, so my compensation was
               CRSQA salary.
      Excerpt #28
      Jim Donahue        Now, have you ever been paid by Alcon or has CRSQA ever been paid
                         by Alcon for any services provided?
      Glenn Hagele       No.

      Jim Donahue        You said that you were declined some type of consulting relationship
                         with Alcon; is that correct?
      Glenn Hagele       Correct.

      Jim Donahue        Who did you speak with from Alcon?
      Glenn Hagele       And as a potential employee.

      Jim Donahue        Who did you speak with at Alcon?
      Glenn Hagele       Laurent, and I can't remember his last name.

      Jim Donahue        Laurent?
      Glenn Hagele       Yeah, L-A-U-R-E-N-T. He is the head of refractive surgery for Alcon.

      Jim Donahue        And you don't recall his last name.
      Glenn Hagele       No, sorry, I don't.

      Jim Donahue        Did you apply for employment with Alcon?
      Glenn Hagele       No, I discussed employment possibilities with Alcon.

      Jim Donahue        What did you discuss, specifically?
      Glenn Hagele       Where I might fit with Alcon with my talents, and it really didn't get
                         beyond that.

      Jim Donahue        Were they -- did they post some kind of job opening?
      Glenn Hagele       No, I was talking with the director who knows the work that I do. It
                         wasn't, you know, showing up for an application.

      Jim Donahue        Well, did Alcon express some indication to you there was some open
                         position at the company?
      Glenn Hagele       Again, it wasn't that I was applying for an existing position, I was
                         discussing with the head of refractive surgery where I might be able to
                         fit in with Alcon if I were to need employment.

      Jim Donahue        Well, that's what I'm trying to understand. Did you raise that question
                         with them or did they say, "We have some openings, we're looking for
                         some people"
      Glenn Hagele       Well, I raised it with him. He -- he would have had no idea that I may
                         need employment, uh --

       8
         Exhibit 208 – Hagele vs. Hanson. Deposition of Glenn Hagele by James R. Donahue on
September 17, 2007. Video excerpt is on a supplemental CD with a filename of “Exhibit 208 -
Deposition of Hagele on 2007-07-17.mpg”.
Jim Donahue    When did you --
Glenn Hagele   -- if I hadn't have brought that up.

Jim Donahue    When did you raise it with him?
Glenn Hagele   Uh, let's see. It was either in April in San Diego or it was the
               conference before that which would have been October or November of
               last year. Might have been in Europe. It was at one of the conferences.
               I'm try – I don't remember which one.

Jim Donahue    And --
Glenn Hagele   But it's within the last year.

Jim Donahue    And what did he say in response to your inquiry?
Glenn Hagele   That I come with baggage with Brent Hanson. Hanson has attacked
               Alcon claiming that I'm a representative of theirs, he's gone to
               shareholder bulletin boards and made accusations about me and them,
               and they don't want a target painted on them.

Jim Donahue    And is Alcon -- when you raised this question about possible
               employment, did Mr. Laurent or --
Glenn Hagele   Laurent.

Jim Donahue    Laurent. You don't know his last name; correct?
Glenn Hagele   Correct.

Jim Donahue    Did he indicate to you that there is an open position but he doesn't want
               to give it to you? I mean did he give you any indication they're looking
               for somebody for an employment position?
Glenn Hagele   He didn't say there's an open position, he simply expressed very politely
               that it wouldn't be in Alcon's best interest to hire someone who's going
               to make them a target.

Jim Donahue    And if you, let's say, theoretically went to work for Alcon, do you have
               an understanding as to where you would -- you would be working?
Glenn Hagele   No, I -- I don't know specifically where they would -- where my unique
               set of talents would be best utilized.

Jim Donahue    What -- what is your unique set of talents, by the way?
Glenn Hagele   Well, last ten years I've been running a refractive surgery patient
               advocacy, the first time a patient group has evaluated and certified
               doctors based on patient outcomes; I have been recognized by a
               lot of media as an expert in this area [emphasis added]; I have a
               background in healthcare reimbursement; I have a background in
               healthcare marketing and structure; recreated IPA's; director of
               provider relations for a health maintenance organization. So there's a
               lot of areas that would be consistent with what Alcon does.
Scheme to Publicly Represent the Worst Lasik Surgeon in Chicago, for
Homegrown Lasers Used in Hair Removal

        The Plaintiff monitors patient web sites that identify the worst LASIK surgeons. The
Plaintiff systematically attempts to recruit the worst LASIK surgeons into CRSQA, and create
business partnerships with them. One such example is the case of Dr. Nicholas Caro, a surgeon
in Chicago who has been the target of criminal investigations, television reports, and other news
reports.910,11

        The Plaintiff first identified Dr. Caro as a potential business partner after reading
complaints about him on LifeAfterLasik.com, which included information that Dr. Caro was a
defendant in about 60 medical malpractice lawsuits. The Plaintiff then began publishing articles
on various web sites in which he began defending Dr. Caro, and criticizing the owner of the web
site, Dean Kantis.

Excerpts from a deposition taken on September 17, 2007 in Sacramento, California, are provided
as follows:

      Excerpt #312
      Jim Donahue         Have you ever solicited to seek employment outside CRSQA in the past
                          five years?
      Glenn Hagele        I discussed with Alcon the possibility of working with them, yes.

      Jim Donahue         Okay. Other than that.
      Glenn Hagele        Nicholas Caro was putting together a company that he wanted someone
                          to manage and we discussed that, but because it's healthcare related,
                          because we expect that Hanson would be attacking it, he felt that that
                          wasn't going to work.

      Jim Donahue         Did he put together a company?
      Glenn Hagele        I believe they're in the financing stages right now. I know he has a
                          board.

      Jim Donahue         What's the name of that company?
      Glenn Hagele        Oh, gees. I don't remember. And I -- I'm not sure if the name of the
                          product which is what I would know is the same as the name of the
                          corporation.

       9
          Exhibit 209 – Losing Sight. NBC 5 Chicago. Video excerpt is on a supplemental CD with a
filename of “Exhibit 209 - NBC 5 Chicago.mpg”.
        10
           Exhibit 210 – Anonymous tip received via e-mail regarding a criminal indictment of Dr.
Nicholas Caro for the theft of 64,000. The accuracy of the tip was confirmed by Dean Kantis who
contacted the Chicago Police Department.
        11
           Exhibit 211 – Lasik lawsuits: Disciplinary proceedings lag against Chicago doctor. TRIBUNE
WATCHDOG: State lets Dr. Nicholas Caro practice despite lawsuits, more than $1 million in damages.
Chicago Tribune: July 5, 2009.
        12
           Exhibit 212 – Hagele vs. Hanson. Deposition of Glenn Hagele by James R. Donahue on
September 17, 2007. Video excerpt is on a supplemental CD with a filename of “Exhibit 212 -
Deposition of Hagele on 2007-07-17.mpg”.
      Jim Donahue       What's the product?
      Glenn Hagele      The product is a cosmetic laser. And then there was a second product
                        that is a – it's actually a procedure for glaucoma that can be used for
                        surgical reversal of presbyopia.

      Jim Donahue       Did you have discussions with Dr. Caro about some hypothetical
                        position with that company?
      Glenn Hagele      Yes.

      Jim Donahue       And what specific discussions did you have?
      Glenn Hagele      He -- any physicians that would be utilizing their -- their product or be
                        a part of their service would need to be credentialed and evaluated, and
                        he felt that I would be a good one to do that.

      Jim Donahue       So some kind of -- again, some kind of credentialing service.
      Glenn Hagele      Yeah, exactly. Credentialing, not certification. I wouldn't be certifying
                        the doctors, I would be evaluating their existing credentials and looking
                        for potential problems in the services that they provide.

      Jim Donahue       Did you ever talk with him in terms of what the -- what your specific
                        position would be, title, anything of that nature?
      Glenn Hagele      No, we discussed what needed to be done, things that I would be able to
                        do; but again, there's no reason to assess specifics like salary if you
                        can't hire the person.

      Jim Donahue       I'm not asking if there was a reason, I'm simply asking did you discuss -
                        -
      Glenn Hagele      There was no --

      Jim Donahue       -- salary?
      Glenn Hagele      -- reason to, therefore it was not discussed.

      Jim Donahue       Do you know if he's actually done anything to get this company off the
                        ground? Dr. Caro.
      Glenn Hagele      Every once in a while he mentions things are progressing but I don't
                        know the details. I'm not involved in it, so I don't. And I don't converse
                        with him all that often.


Media Representative for Two of the Worst Surgeons in California

         The American Society of Cataract and Refractive Surgery (ASCRS) published an article
in the September 2000 issue of EyeWorld, titled “A Black Eye for Refractive Surgery”, in which
they exposed unsafe surgical practices utilized by Dr. Jay Bansal and Dr. Swati Singh. The
article stated that:
“The case, which has received national media attention, came to light after a former employee
alerted California public health officials that LaserVue physicians were using the same
microkeratome blade on consecutive patients and reusing microkeratome heads, including
suction rings, without autoclaving them between procedures.”13




       13
            Exhibit 213 – A Black Eye for Refractive Surgery. EyeWorld: September 2000.
        Following publication of the article by ASCRS, the Plaintiff then began publishing
advertisements for Dr. Bansal and Dr. Singh with a statement of “Why this may be the best Lasik
doctor for you.”14




       14
          Exhibit 214 – Hagele, Glenn. Jay Bansal, MD and Swati Singh, MD, Lasik Doctors Certified
By Patient Advocacy. http://www.usaeyes.org/lasik/doctor/california/santa-rosa/lasik-laservue.htm
Glenn Hagele's Prior Mis-use of Court Documents and Protective
Orders for Creating Self Serving Press Releases

        Glenn Hagele has a history of using court orders for the sole purpose of issuing self-
serving “Press Releases”, which quote himself as the source. For example, Glenn Hagele
obtained a TRO prohibiting publication of so-called “private” information from various public
documents, by Defendant Brent Hanson, and others on December 10, 2007. One day later,
Plaintiff began issuing “Press Releases” such as the one on Reuters with a large headline of
“Whistleblower's Social Security Number Published; Court Orders Internet Data Blocked”.15




       15
          Exhibit 215 – Hagele, Glenn. Whistleblower's Social Security Number Published; Court
Orders Internet Data Blocked. Reuters: December 12, 2004.
http://www.reuters.com/article/pressRelease/idUS199302+12-Dec-2007+PRN20071212
       It was only after the Plaintiff issued the “Press Release” that Plaintiff served the
Defendant with a copy of the TRO. Ten days after the Plaintiff issued his “Press Release” the
judge reversed his TRO after discovering that the Plaintiff was a bad actor who had mislead the
Court.16




        16
          Exhibit 216 – State of North Carolina, County of Wake. Glenn Hagele, Plaintiff, v. Lauranell
Burch a/k/a Nell Burch, Defendant. Order Denying Motion for Preliminary Injunction. December 20,
2007.
Glenn Hagele's Prior Mis-use of Court Documents and Protective
Orders to Shut Down Web Sites

Scheme to Shut Down Defendant's Web Site at LasikFraud.com in 2006

On May 18, 2006 Plaintiff, Glenn Hagele published a message for Alcon investors on Yahoo that
stated:

       LasikFraud Website Removed

       Brent Hanson of LasikFraud.com has frequented this bulletin board with rather wild
       accusations about Alcon. Due in part to apparent illegal activity and investigation of
       federal fraud, the LasikFraud.com website had been removed. This may be a
       temporary change, however it appears that this may be a permanent removal of the
       website at this domain.17




       17
          Exhibit 217 – Hagele, Glenn. LasikFraud Website Removed. May 18, 2006.
http://messages.finance.yahoo.com/Business_%26_Finance/Investments/Stocks_%28A_to_Z%29/Stocks
_A/threadview?bn=26978&tid=2369&mid=3408
        Defendant performed research to learn how and why the web site had been shut down.
Defendant's attorney contacted Tucows; a domain registrar in Canada after Defendant had
learned that Tucows had deactivated the domain name of LasikFraud.com. Tucows informed the
attorney that they had received communications from Plaintiff falsely claiming that a bankruptcy
court had ordered the domain name to be turned over to Plaintiff, as the result of a bankruptcy
fraud investigation. Tucows reactivated the domain name after learning that it had been mislead
by Plaintiff, Glenn Hagele.

Scheme to Shut Down Lasik-Flap.com, LasikFraud.com, and LasikDisaster.com in
2007

       On December 12, 2007, the same day Plaintiff issued his “Press Release” titled
“Whistleblower's Social Security Number Published; Court Orders Internet Data Blocked” he
also began issuing demands to domain registrars and web hosting services to completely shut
down web sites at Lasik-Flap.com, LasikFraud.com, and LasikDisaster.com.18




        18
          Exhibit 218 – State of North Carolina, County of Wake. Glenn Hagele, Plaintiff, v. Lauranell
Burch a/k/a Nell Burch, Defendant. Motion to Dissolve Temporary Restraining Order and Disburse
Bond.
      Plaintiff was able to successfully shut down all three web sites until the judge reversed
his TRO, which Plaintiff had mis-used. Plaintiff is now being sued for mis-using his TRO.19




        19
          Exhibit 219 – State of North Carolina, County of Wake. Glenn Hagele, Plaintiff, v. Lauranell
Burch a/k/a Nell Burch, Defendant. First Amended Answer and Counterclaims, p. 23.
Glenn Hagele's True Objective in Filing a Motion to Supress Public
Documents

Suppress Information Regarding His Advertisements that Falsely Represent Dr.
Michael Mockovak and Dr. Joseph Kings are Members of CRSQA in Washington

        On February 9, 2009, Defendant filed a counterclaim against Glenn Hagele, Dr. Michael
Mockovak, and Dr. Joseph King. On June 26, 2009, Dr. Joseph King provided to Brent Hanson
a copy of an e-mail sent to Glenn Hagele, which demonstrated that Dr. Michael Mockovak and
Dr. Joseph King had completely terminated their support for Glenn Hagele's activities. The e-
mail stated the following:20

       Subject: Removal of our names from your websites
       From: "Joseph King" <jking@clearlylasik.com>
       Date: Fri, 26 Jun 2009 17:46:07 -0700
       To: <glenn.hagele@usaeyes.org>
       CC: "Michael Mockovak" <michaelm@clearlylasik.com>, "Christian Monea"
       <cmonea@clearlylasik.com>
       Glenn,

       At least several weeks ago we asked that you remove our names and
       any references to our medical practices from your websites. This
       request was communicated to you both verbally and in writing.

       To date, you have not respected our request. As of today we are
       still listed on your usaeyes.com website. As we communicated to
       you previously, we have resigned from CRSQA and we do not want to
       be listed as members.

       If our names and practice are not removed promptly we may have no
       alternative but to request the assistance of our attorney. We have
       no desire to become involved in any dispute that exists between
       you and Mr. Hanson or anyone else. I ask that you please respect
       our request.

       Thank you.
       Sincerely,
       Joseph King

       However, Plaintiff continues to publish advertisements in Washington designed to
mislead consumers into believing that Dr. Michael Mockovak and Dr. Joseph King are members
of CRSQA.21




       20
           Exhibit 220 – King, Joseph. Removal of our names from your websites. E-mail to Glenn
Hagele. June 26, 2009.
        21
           Exhibit 221 – Hagele, Glenn. Lasik – Seattle Lasik Doctors Approved By Patient Advocacy
(WA). http://www.usaeyes.org/lasik/doctor/washington/lasik-seattle.htm
        Defendant has full knowledge of Plaintiff's fraudulent advertising and has filed court
documents that show the history of how this fraud has occurred. Defendant believes that the
Plaintiff desires to seal court documents in order to continue his fraudulent advertising, without
fear of discovery by regulatory agencies.

Defendant's Submission of Alternate Documents to the Court with
Redacted Content

       Defendant inquired with the Court on the procedure for filing documents under seal, and
was informed that no such procedure exists. In order to assist the Court implement the order
issued by Sacramento Superior Court, the Defendant asks that the Court seal only the documents
which are specifically identified with the following text: “Portions of this document are
protected from public disclosure by order of the Sacramento Superior Court in California”. In
order to protect the public's right to know about the Plaintiff's criminal activities, the Defendant
will provide within two weeks, alternate copies of documents in which excerpts of depositions
have been redacted. The court can then maintain the alternate copies of documents in the public
files, while simultaneously implementing the protective order issued by the Superior Court of
Sacramento.

       Submitted this 12th day of July, 2009.



                       _________________________________
                       Brent Hanson

                       P.O. Box 1261
                       Olympia, WA 98507-1261

                       Telephone:     (919) 323-6030
                       Facsimile:     (425) 650-3711

				
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