Motion to Strike - SLAPP:
Defendant's, Mary Day's, Memorandum of Points and Authorities in Support of Motion to Strike - SLAPP Suit
"A. Introduction
Long after this action was originally filed in state Court in January of 1999, Defendant, DAY, was brought in as a party Defendant on July 22, 1999, pursuant to Plaintiffs' Second Amended Complaint. The Second Amended Complaint set out eleven (11) claims all of which named DAY as a principle wrongdoer as well as a co-conspirator of co-Defendant, MICHELANGELO DELFINO (hereinafter DELFINO).
Plaintiffs have now filed their Third Amended and Supplemental Complaint alleging claims designed to chill DAY's exercise of her First Amendment rights and prevent her from speaking out about the injustice of being sued on meritless claims.
As will be seen, infra, there is no factual basis for any of the claims brought against Defendant, DAY, whether they be based on her acting as a principal and engaging directly in wrongdoing, or whether acting as a co-conspirator of Defendant, DELFINO. None of the Plaintiffs can state any facts short of conjecture to support their claims of liability and damages against DAY. Rather, by inuendo alone, they have included DAY in this action. The lawsuit brought against DAY is a classic example of a SLAPP action.
B. STATEMENT OF FACTS
Plaintiffs filed this action originally in this court in January of 1999. On March 25, 1999, the matter was removed to Federal District Court by the then only named Defendant, MICHELANGELO DELFINO (hereinafter DELFINO). It was not until July 22, 1999, that DAY was served with a copy of the Second Amended Complaint and of which DAY requests this court take judicial notice, naming her for the first time as a party defendant.
Prior to DAY'S being named as a party in the underlying action, the Plaintiffs had obtained an Order from the District Court entering a preliminary injunction against DELFINO. Immediately after DAY made her pro se appearance by filing her Answer to the Second Amended Complaint, the Plaintiffs sought to have the Court find DELFINO in contempt of Court for violating the original preliminary injunction. In reliance on the District Court Orders excluding DAY from the briefing schedule relieving her from the need to file any opposition, DAY did not file any opposition to the Plaintiffs' Motion.
Thereafter, without any further notice the District Court imposed preliminary injunctive relief against Defendant, DAY, which was the subject of an appeal before the Ninth Circuit Court of Appeasl and of which DAY requests this court take judicial notice. Last week, DAY received notice that she prevailed on appeal and that the injunction has been dissolved.
Subsequently, on December 23, 1999, Defendant, DAY filed her Motion for Summary Judgment or in Lieu Thereof Summary Adjudication in Federal District Court. On April 7, 2000, the District Court granted DAY'S Motion and of which DAY requests this Court take judicial notice and found that the Plaintiffs could not, under any circumstances, even those the Plaintiffs did not argue, state a claim unde the Lanham Act and that neither DAY nor DELFINO competed with the corporate Plaintiffs. The Court also found that it lacked subject matter jurisdiction and remanded the case to state court. The Court deferred ruling on the balance of DAY's Summary Adjudication Motion as well as other motions then pending before it in remanding the case.
While DAY'S Motion for Summary Judgment or in Lieu Thereof Summary Adjudication was under submission to the District Court, Plaintffs brought yet another Motion seeking to impose another temporary restraining order and preliminary injunction against Defendants, DELFINO and DAY. It should be noted that Plaintiffs used virtually the identical postings they had used previously in their Motion to find DELFINO in contempt of Court which resulted in the injunction being imposed as against DAY. This time however, DAY was on notice and filed her opposition. DAY'S opposition is attached to the Declaration of Randall M. Widmann and marked Exhibit G.
DAY argued strenuously in her opposition that Plaintiffs had continuously and consistently argued, without any basis in fact, that everything DELFINO did DAY did - that DELFINO and DAY were joined at the hip. DAY asked the Court to take the time to look at each of the postings. In short, she implored the Court not to assume that she and DELFINO were "joined at the hip." This time around, while the District Court granted Plaintiffs' Motion and imposed a restraining order on Defendant, DELFINO, it denied the Motion as to DAY. DAY requests that this Court take judicial notice of Judge WHYTE'S finding. (See fn 4 Exhibit H to the Declaration of Randall M. Widmann).
Plaintiffs filed a motion in this Court for leave to file a Third Amended and Supplemental Complaint which was opposed by Defendants. As is required by law, Plaintiffs attached their proposed Third Amended and Supplemental Complaint as an exhibit to their motion. However, after this Court granted Plaintiffs' motion, Plaintiffs filed a different Third Amended and Supplemental Complaint than they attached to their motion.
Many of the allegations made by Plaintiffs contain their interpretation of what the numerous messages mean which are attached as Exhibits, interpretations which are not borne out by reviewing the messages themselves. This is not just confusing, but contradictory for in par. 63 of the pleading, Plaintiffs aver that the attached e-mails are "clearly libelous in nature without reference to any extrinsic materials." The amorphous pleading filed by Plaintiffs replete with conclusory statements of defamation or other wrongdoing, without factual basis, in e-mails which they claim are attached (usually without specifying which messages they are talking about) are not borne out by the messages themselves if they can be found.
Of course, the attached Exhibits to the Third Amended and Supplemental Complaint, are, on their face, merely fair comment about this lawsuit itself and other matters of public concern and are therfore priviliged. What is important and what DAY urges this Court to do when reviewing the Third Amended and Supplemental Complaint is not to take the characterizations of the attached messages which Plaintiffs make in their pleading as being true, but to rather, review the messages themselves.
C. DISCUSSION AND AUTHORITIES
A cause of action against a person arising from any act of that person in furthereance of his or her right of petition or free speech under the United States or California Constitution in connection with a public issue is subject to a special motion to strike, unless the court determines that the plaintiff has established that there is a probability that the plaintiff will prevail on the claim [Code Civ. Proc. ß 425.16(b)(1)].
In enacting this special motion to strike, the Legislature noted that there had been a disturbing increase in lawsuits brought primarily to chill the valid exercise of the constitutional rights of freedom of speech and petition for the redress of grievances, commonly known as SLAPP suits (that is, strategic litigation against public participation)[Code Civ. Proc. ß 425.16(b)(1)]. The purpose of this legislation is to encourage continued participation in matters of public significance without this participation being chilled through abuse of the judicial process [Code Civ. Proc. ß 425.16(b)(1)] and to eliminate meritless litigation at an early stage [ Macias v. Hartwell (1997) 55 Cal. App. 4th 669, 672, 64 Cal. Rptr. 2d 222; Bradbury v. Superior Court (1996) 49 Cal. App. 4th 1108, 1113, 57 Cal. Rptr. 2d 207 ]. Thus Code Civ. Proc. ß 425.16 was enacted to curtail SLAPP suits [ Bradbury v. Superior Court supra 1111 ] by providing an economical and expeditious remedy to SLAPP suits [ Church of Scientology v. Wollersheim (1996) 42 Cal. App. 4th 628, 647 n. 3, 49 Cal. Rptr. 2d 620 ]. The anti-SLAPP suit statute is designed to protect the speech interests of private citizens, the public, and governmental speakers. The identity of the speaker is not a decisive factor in determining whether the speech activity is protected under the First Amendment. [Bradbury v. Superior Court supra 1117; see Mission Oaks Ranch, Ltd, v. County of Snata Barbara (1998) 65 Cal. App. 4th 713, 730, 77 Cal. Rptr. 2d 1 ( county; dissapproved on other grounds in Briggs v. Eden Council for Hope and Opportunity (1999) 19 Cal. 4th 1106, 1123, n.10, 81 Cal Rptr. 2d 471, 969 P.2d 564)]. At the same time, the protection of the stature is not limited to activities that go to the heart of self-government [ Briggs v. Eden Council for Hope and Opportunity supra at 1116]
In very general terms, a SLAPP suit has been described as a meritless suit filed primarily to chill the defendant's exercise of First Amendment rights [ Macias v. Hartwell supra at 672; Wilcox v. Superior Court (1994) 27 Cal. App. 4th 809, 815-816, 33 Cal. Rptr. 2d 446 ]. The actions falling within this category have been generally recognized as civil lawsuits aimed at preventing citizens from exercising their political rights or at punishing those who have done so. The paradigm SLAPP is a suit filed by a alrge land developer against environmental activists or a neighborhood association intended to chill political or legal opposition to the developer's plans, but SLAPPs are not limited to environmental issues or to defendants who are local organizations with limited resources [ Wilcox v. Superior Court, supra 815; see Conroy v. Spitzer (1999) 70 Cal. App. 4th 1446, 1448 (SLAPP suits by definition ar aimed at chilling valid exercise of political rights, particularly right of freedom of speech and right to petition government for redress of grievances); see also Sipple v. Foundation for Nat. Progress (1999) 71 Cal. App. 4th 226, 240) Code Civ. Proc. ß 425.16 is not limited to paradigm SLAPP suits filed by powerful and wealthy developers against impecunious protestors, and applies to media defendants in libel actions)].
SLAPP suits are likely to involve alleged causes of action for defamation, various business torts (such as interference with prospective economic advantage), nuisance, and intentional infliction of emotional distress [Church of Scientology v. Wollersheim, supra at 652; Wilcox v. Superior Court supra 816]. The Legislature, however, did not limit application of the provision to such actions, recognizing that all kinds of claims could achieve the objective of a SLAPP suit, that is to interfere with and burden the defendant's exercise of his or her rights [Church of Scientology v. Wollersheim, supra at 652; see also Foothills Townhome Assn. v. Christiansen (1998) 65 Cal. App. 4th 688, 696, 76 cal. Rptr. 2d 516 (SLAPP suits can conceivably be pleaded in terms of breach of contract or other valid actions)]. In Code Civ. Proc. ß 425.16(a) the Legislature has declared that it is in the public interest to encourage continued participation in matters of public significance, and that this participation should not be chilled through abuse of the judicial process. To this end, the section shall be construed broadly [ Code Civ. Proc. ß 425.16(a) (last sentence added by Strats. 1997 amendment to section 425.16 mandates broad construction of that section); accord Sipple v. Foundation for Nat. Progress supra at 236-240]
Code Civ. Proc. ß 425.16(b)(1) (formerly Code Civ. Proc. ß 425.16(b)) contains a two part test to determine whether an action is a SLAPP suit subject to a special motion to strike. The first part tests whether the action is a SLAPP suit; the second decides whether, if it is a SLAPP suit, it may nonetheless survive the motion to strike because the plaintiff has established a probability of prevailing on the complaint. The second part need not be addressed if the action is determined not to be a SLAPP suit [ Ericsson GE Mobile Communications, Inc. v. C.S.I. Telecommunications Engineers (1996) 49 Cal. App. 4th 1591, 1601, 1603, 57 Cal. Rptr. 2d 491 (disapproved on other grounds in Briggs v. Eden Council for Hope and Opportunity supra at 1123 n. 10]
A SLAPP suit is a cause of action against a person arising from any act of that person in furtherance of the person's right of petition or free speech under the United States or California Constitution in conncection with a public issue [see Code Civ. Proc. ß 425.16(b)(1)].
As used in Code Civ. Proc. ß 425.16, an act in furtherance of a person's right of petition or free speech under the United States or California Constitution in connection with a public issue includes [Code Civ. Proc. ß 425.16(e)]:
(1) Any written or oral statement or writing made before a legislature, executive, or judicial proceeding, or any other official proceeding authorized by law;
(2) Any written or oral statement or writing made in connection with an issue under consideration or review by a legislative, executive, or judicial body, or any other official proceeding authorized by law;
(3) Any written or oral statement or writing made in a place open to the public or a public forum in connection with an issue of public interest; or
(4) Any other conduct in furtherance of the exercise of the constitutional right of free speech in connection with a public issue or an issue of public interest.
These four clauses operate independently [Briggs v. Eden Council for Hope and Opportunity supra at 1117]
In addition, even if statements are not expressly covered under Code Civ. Proc. ß 425.16(e), the categories enumerated there are not all-inclusive. The acts in furtherance of a person's right to free speech specified by the statute is preceded by the word 'includes' which is ordinarily a term of enlargement rather than limitation. The use of 'includes' implies that other acts which are not mentioned are also protected under the statute [Averill v. Superior Court (1996) 42 Cal. App. 4th 1170, 1175, 50 Cal. Rptr. 2d 62].
The first two subdivision of subd. (e) of Code Civ. Proc. ß 425.16 define an act in furtherance of a person's right of petition or free speech under the United States or California Constitution in connection with a public issue to include the following:
(1) Any written or oral statement or writing made before a legislature, execuitve, or judicial proceeding, or any other official proceeding authorized by law.
(2) Any written or oral statement or writing made in connection with an issue under consideration or review by a legislative, executive, or judicial body, or any other official proceeding authorized by law.
Under the plain and unambiguous language of the statute, an action may be a SLAPP sit under clauses (1) and (2) without any separate deomonstration by the defendant that the statement concerned an issue of public significance [Briggs v. Eden Council for Hope and Opportunity supra at 1113; [Sipple v. Foundation for Nat. Progress supra at 237]. Clauses (3) and (4) include an express limitiation to 'issue[s] of public interest' and that limitation is not read into clauses (1) and (2) [Briggs v. Eden Council for Hope and Opportunity supra at 1117 - 1118]
Earlier cases that more narrowly construed Code Civ. Proc. ß 425.16 have been disapproved [Briggs v. Eden Council for Hope and Opportunity supra at 1123 n.10]. Thus, as to acts covered by the first tow clauses of Code Civ. Proc. ß 425.16(e), the statute requires simply any writing or statement made in, or in connection with an issue under consideration or review by, the specified proceeding or body [Briggs v. Eden Council for Hope and Opportunity supra at 1116-1117; Braun v. Chronical Publishing Co. (1997) 52 Cal. App. 4th 1036, 1046-1047]. Nothing in Code Civ. Proc. ß 425.16(e) confines free speech to speech which furthers the exercise of petition rights [Braun v. Chronical Publishing Co. supra at 1046]. Under the statute's plain terms it is the context or setting itself that makes the issue a public issue; all that matters is that the First Amendment activity take place in an official proceeding, or be made in conection with an issue being reviewed by an official proceeding [Braun v. Chronical Publishing Co. supra at 1047]. Thus, news reports published by media defendants made in connection with an issue under consideration or review by an authorized official proceeding fall within the scope of Code Civ. Proc. ß 425.16(e)(2) [Braun v. Chronical Publishing Co. supra at 1046; see Lafayetter Morehouse, Inc. v. Chronical Publishing Co. (1995) 37 Cal. App. 4th 855, 862-864, 44 Cal. Rptr. 2d 46; see also Sipple v. Foundation for Nat. Progress supra at 237-238 (article, insofar as it discussed statements made during deposition or at hearing at child custody trial, was within Code Civ. Proc. ß 425.16(e)(1))].
Becasue the categories enumurated in Code Civ. Proc. ß 425.16(e) are not all-inclusive, private conversations regarding a public issue are protected under the statute [Averill v. Superior Court supra at 1174-1176]. For example, in Averill, the appellate court issued a writ of mandate directing the trial court to strike the complaint when the defendant homeowener, a critic of the plaintiff's plan to covert a house in defendant's neighborhood into a shelter, opposed the plan before the city council and in a letter to the local newspaper, and on discovering that defendant's employer intended to support plaintiff as a charity, opposed the employer's support for the project through internal channels. Although the plaintiff's only cause of action against the defendant was based on the comments defendant made in private to defendant's employer, the court indicated that they might be considered within the enumerated protected acts of section 425.16(e), and that given the 'includes' language, private conversations could not be excluded from protection. The court noted that even though plaintiff carefully crafted the lawsuit to exclude the public comments and limit it tot the private comments to the defendant's employer, the suit appeared to have been filed solely to punish the defendant for criticizing the project and to impose litigation costs on plaintiff for having exercises the right of free speech and to petition the government [Averill v. Superior Court supra at 1172-1173; see also Dove Audo, Inc. v. Rosenfeld, Meyer & Susman (1996) 47 Cal. App. 4th 777, 784, 54 Cal. Rptr. 2d 830 (fact communications were made to other private citizens rather than to official agency does not exclude it from protection of anti-SLAPP suit statute)].
Commercial conduct and speech made in connection with an issue of public concern under consideration by a legislative body are subject to the SLAPP statute. Thus, protection may apply in an action by a developer against a paid environmental consultant that had been hired by a county to evaluate the developer's proposed project in connection with an environmental impact report [ Mission Oaks Ranch, Ltd. v. County of Santa Barbara supra at 728, (disapproved by Briggs v. Eden Council for Hope and Opportunity supra at 1123 n.10 to extent it suggests statement must concern issue of public significance to be protected under Code Civ. Proc. ß 425.16(e)(1) or (2) )].
By its terms, Code Civ. Proc. ß 425.16 applies to persons who act in furtherance of their own right of petition or free speech [see Code Civ. Proc. ß 425.16(a), (b)(1) ]. A defendant moving to strike a SLAPP suit need not, however, demonstrate that its protected statements or writings were made on its own behalf, as opposed to on behalf of its clients or the general public [see Briggs v. Eden Council for Hope and Opportunity supra at 1116]. Code Civ. Proc. ß 425.16 expressly applies to any writing or speech made in connection with an issue under consideration or review by a legislative, executive, or judicial proceeding, or any other official proceeding authorized by law, but there is no requirement that the writing or speech be promulgated directly to the official body [Ludwig v. Superior Court (1995) 37 Cal. App. 4th 8, 17, 43 Cal. Rptr. 2d 350 ]. A person can exercise his or her own rights by supporting the forceful activities of others. Thus, both a confident opponent who takes the public podium and a shy opponent who prefers to lend moral support by standing silently in the audience are protected under the statute. Furthermore, there is no meaningful difference between a person who supports and encourages the filing of a lawsuit, and one who supports and encourages a third party to speak out publicy at a public hearing on a matter of public interest [ Ludwig v. Superior Court supra at 18].
Examples inculde the following:
A defendant who has instigated and funded litigation involving a colorful claim brought by others, for example, antidevelopment, environmentally based litigation, or has encouraged others to speak out publicly at a public hearing on a matter of public interest, may be protected [ Ludwig v. Superior Court supra at 17-18].
A defendant that counseled a tenant in a dispute with a landlord in anticipation of litigation may be protected [Briggs v. Eden Council for Hope and Opportunity supra at 1115].
As the undisputed facts reveal, Defendant, DAY, did not personally post any e-mails or make any postings on any Internet posting board that could possibly be construed as defamatory or unlawful. She did not even start to post anything, as the undisputed facts reveal, until August 13, 1999, after she was sued by Plaintiffs and eight (8) months after Plaintiffs filed an action. The only posingts DAY made from the exhibits attached to the Third Amended Complaint have been attached to her Declaration and can be reviewed by the court which can then ascertain whether they are defamatory on their face.
The undisputed facts reveal that Ms. DAY at no time intercepted any e-mails nor did she impersonate any VARIAN employeees, either past or present.
Not only does the deposition of Ms. DAY taken in this matter, and the Declarations of Defendants, DAY and DELFINO, suppirt the undisputed facts, (See Exhibit A to the Declaration of R. WIDMANN) but even the Plaintiffs themselves admit that there are no facts that show hat Ms. DAY personally, or acting in concert with DELFINO, wrote any of the postings which are alleged to have been defamatory or which are alleged to be unlawful or engaged in ny of the alleged unlawful acts. That is, a review of the deposition testimony of SUSAN FELCH and GEORGE ZDASIUK reveals that they have no knowledge of whether Ms. DAY personally posted any e-mail messages, whether the information concerned themselves or VARIAN. Furhter, neither has any knowledge of any interception of e-mails or impersonation of themn or others by Ms. DAY (See Exhibits B and C to the declaration of R. WIDMANN)
As for the evidence of an alleged conspiracy, put simply, there is none. All that the Plaintiffs can show is that Ms. DAY was present at Kinko's on May 5, 1999, when Mr. DELFINO allegedly posted an e-mail on a posting board that was allegedly unlawful. There is no showing that Ms. DAY was anything other than a casual observer. That certainly does not give rise to liability for being a co-conspirator or, for that matter, for any other wrongdoing.
Indeed, the only other things that the Plaintiffs have to show to support their theory of liability against Ms. DAY, either that she acted directly and personally or that she acted as a co-conspirator is the fact that hse is a friend of Mr. DELFINO, a business associated of Mr. DELFINO, and was present at Kinko's when DELFINO allegedly engaged in unlawful activity. They also assert that around the time DELFINO was notified of the instant action, DAY disposed of a computer. Of course, they fail to note as the Undisputed Facts show, that the computer had never worked properly, that DAY disposed of it on her birthday and that DAY knew nothing of the lawsuit at the time. (See Dep. of DAY, pp. 143:13-:14, 623:24-625:21, Exhibit A to Declaration of R. WIDMANN) If that is enough to support liability against DAY, then in any civil matter a party Defendant's boyfriend, girlfriend, wife, husband, extended family members, including parents and friends, would all be liable. The mere idea is ridiculous.
None of the postings made by Ms. DAY since August 13, 1999 are defamatory. Further , it is highly questionable that even DELFINO's postings were defamatory. In Ferlauto v. Hamsher (1999) 74 Cal. App. 4th 1394, the court dealt with a case involving First Amendment rights as opposed to alleged defamation. Among the many alleged defamatory statements made by the Defendant in Ferlauto were statements that the Plaintiff was a 'Kmart Johnnie Cochran'; a 'loser wannabe lawyer'; a 'creepazoid attorney'; a 'little fucker'; and among the 'meanest, greediest, low-blowing motherfuckers'. (id. at 1398).
The court, in ruling that the statements which were alleged to be libelous were not actionable, held that in order to overcome the freedom of speech protections of the First Amendment, a Plaintiff must allege a statement that is provably false. Statements do not imply a provably false factual assertion and, thus, cannot form the basis of a defamation action if they cannot reasonably be interpreted as stating actual facts about an individual. Thus, a rhetorical hyperbole, vigorous eptithets, lusty and imaginative expressions of contempt and language used in a loose and figurative sense have all been accorded constitutional protection. (id. at 1401)
The court went on to analyze the language used on a point by point basis and found that none of it overcame the protection of the First Amendment. The court held that one must examine the totality of the circumstances under which the statements were made (id. at 1401-1405) and that the names used by the Defendant were either common characterizations, caricature, imaginative expression, rhetorical hyperbole or simple name calling, ie. of the 'Sticks and stones may break my bones......' variety. (id. at 1403-1404; See also, Nicosia v. DeRooy, (1999 N. Dist. Cal.) 72 F. Supp 2d 1093)
None of the statements that DAY has posted on the Internet can be held to be defamatory, nor can the Plaintiffs show that Ms. DAY was part of a conspiracy to post defamatory statements or otherwise engaged in unlawful acts. In order for Plaintiffs to establish that DAY was part of a conspiracy with DELFINO, they must show tha she acted in pursuance of a common plan or design to commit a tortious act, actively took part in it, furthered it by cooperation or request and aide or encouragement to the wrongdoers or ratified and adopted the acts done for her benefit. (Cully v. Bianca (1986) 186 Cal.App.3d 1172, 1176) A Defendant in a conspiracy must share a common purpose with another person, not merely suspect or have knowledge of the other person's private purpose. (Harris v. Capitol Records, Etc. Corp. (1966) 64 Cal.2d 454, 462) She must have united or cooperated with another in inflicting a wrong on the Plaintiffs. (Mocks Inc. v. Woods (1927) 202 Cal. 675, 677-678)
Thus, the liability of a Defendant as a conspirator is limited to only those hwo in pursuance of a comnmon plan or design to commit a wrong, actively take part in it, further it by cooperation or request, lend encouragement to the wrongdoer or ratify or adopt his/her acts done for their benefit. Again, mere knowledge by one party of wha the other is doing is not sufficient concert to make her liable for the acts of the other since one person ordinarily owes no duty to take affirmative steps to interfere with another's activities in the absence of some special relationship. Thus, in seeking to impose liability on the co-conspirators as joint tortfeasors, that is, with intent to commit a tort or with negligence, because one who innocently does an act that furthers the tortious purpose of another is not acting in concert with him/her. (Saunders v. Superior Court (1994) 27 Cal.App.4th 832, 846)
The Plaintiffs must also, in a cause of action for conspiracy, show not only the formation of the conspiracy, but also its operation, that is, an overt wrongful act or acts committed by one or more of the conspirators pursuant to the common design that result in a damage to the Plaintiff. (Unruh v. Truck Insurance Exchange (1972) 7 Cal.3d 616, 631)
It is self evident that suit was originally brought against DAY to pressure DELFINO and to ensure that DAY would not speak out against the Plaintiffs. The fact that Plaintiffs do not like what DAY publishes is not grounds to maintain an action against her. As the messages themselves reveal, all DAY is doing is speaking out, something all citizens of the country are allowed to do.
DAY respectfully requests this Court to put an end to the Plaintiffs' campaign to silence her and punish her for perceived but unfounded wrongs.
Dated: September 25, 2000
RANDALL M. WIDMANN
Attorney for Defendant, MARY DAY"
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