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All complained-of material has been removed
"In view of Lubomyr Prytulak's total expurgation of all material complained of by plaintiff in Rambam v Prytulak BC271433, further action against UKAR by the instant Court is unwarranted." � Lubomyr Prytulak

Lubomyr Prytulak
UKAR the Ukrainian Archive at www.ukar.org
[Address]
[Telephone]
[Email]

28 March 2003


James R. Dunn
Los Angeles Superior Court
111 North Hill Street
Los Angeles, CA
USA     90012


Re: Rambam v Prytulak   BC271433   James R. Dunn

James R. Dunn:

Lubomyr Prytulak protests the Court's methodical and systematic denial of information to the defense.  Specifically, the most recent three entries under Proceedings Held in the Los Angeles Superior Court online Case Summary make reference to motions which Lubomyr Prytulak has never been served, and which are alluded to stripped of information as to what might be their intent:

Proceedings Held (Proceeding dates listed in descending order)

03/25/2003 at 09:00 am in department 26, James R. Dunn, Presiding Motion for an Order - Proceeding continued

03/19/2003 at 09:00 am in department 26, James R. Dunn, Presiding Motion for an Order - Granted

02/21/2003 at 09:00 am in department 26, James R. Dunn, Presiding Motion for an Order - Granted

Furthermore, as Lubomyr Prytulak was not given prior notice of the dates of the above proceedings, and as these dates were not announced online, he was unable even to ask acquaintances in the Los Angeles area to attend them as observers.  Lubomyr Prytulak, in short, is being kept totally in the dark as to what is going on in Rambam v Prytulak BC271433.

Most ominous is the most recent of the above entries (dated 03/25/2003), as it is post-default judgment, and may be aimed at suppressing the entire Ukrainian Archive (UKAR) web site at www.ukar.org.  This proceeding had been unannounced, and is presently marked as Proceeding continued, whereas Future Hearings on the same page specifies "None" � which constitutes the most recent demonstration of how Lubomyr Prytulak is denied knowledge of the dates of scheduled proceedings, and is thus unable even to ask acquaintances to attend as observers.  Rambam v Prytulak, then, has become totally ex parte, and can make no claim to even attempting to maintain the appearance of being adversarial.

On top of that, eight days after default judgment, Lubomyr Prytulak remains to be served with a copy of the judgment, having only the information in the following online statement:

Documents Filed (Filing dates listed in descending order)

03/20/2003 Judgment (entered for pltiff Steven Rambam and against Lubomyr Prytulak aka Lubomir Prytulak in the amount of $75,000, consisting of 50,000 in special damages and $25,000 in general damages plus cost;) Filed by Attorney for Pltf/Petnr

Without seeing this judgment, Lubomyr Prytulak's ability to initiate his appeal is blocked.  More importantly, Lubomyr Prytulak fears that whereas Plaintiff complained only of some statements within two files on UKAR, the above judgment has been worded so as to appear to apply to the entire web site, with the danger that the judgment could be shown to the UKAR web site host, and to search engine providers, with the demand that they take action against the web site as a whole.  This would be unjust, as the two files (in which only certain statements are complained of) occupy 0.068 mb of memory, whereas the entire web site occupies 107.47 mb � thus, the two files occupy only 0.06% of the entire web site.  Suppressing the entire web site, or blocking search-engine access to the entire web site, would constitute an egregious and gratuitous encroachment on Lubomyr Prytulak's right of free expression, and on the public's right to access information which is vital to the public interest.

In order to prevent such feared action, Lubomyr Prytulak has � pending outcome of his appeal � deleted all material complained of by Steven Rambam from the two documents in question, namely from:

www.ukar.org/abella05.html
www.ukar.org/rambam01.html

The location of the deleted material within the two documents is clearly marked as follows:

[MATERIAL NORMALLY APPEARING HERE HAS BEEN REMOVED PENDING APPEAL OF LOS ANGELES SUPERIOR COURT CASE NO. BC271433]

So thorough has been Lubomyr Prytulak's expurgation of complained-of material that he has even removed a quotation from the California Court of Appeal decision Jewish Defense Organization v Superior Court (85 Cal Rptr 2d 611, California 1999) which makes reference to Steven Rambam's origins, even though this same material continues to be available on the Internet, apparently without complaint by Steven Rambam, in such locations as caselaw.lp.findlaw.com/data2/californiastatecases/b129319.pdf.

In view of Lubomyr Prytulak's total expurgation of all material complained of by plaintiff in Rambam v Prytulak BC271433, further action against UKAR by the instant Court is unwarranted.




Lubomyr Prytulak

cc:

James A Bascue, Judge • LASC • 111 North Hill Street • Los Angeles, CA • USA 90012
John A Clarke, Executive Officer/Clerk • LASC • PO Box 151, Main Post Office • Los Angeles, CA • USA 90053
Robert A Dukes, Presiding Judge • LASC • 111 North Hill Street • Los Angeles, CA • USA 90012
Gary Klausner, Judge • USDC • 255 East Temple Street, Courtroom 850 • Los Angeles, CA • USA 90012
Carolyn B Kuhl, Supervising Judge, Civil Departments • LASC • 111 North Hill Street • Los Angeles, CA • USA 90012
Gary Kurtz, Esq • 20335 Ventura Boulevard, Suite 200 • Woodland Hills, CA • USA 91364
William A MacLaughlin • Assistant Presiding Judge • LASC • 111 North Hill Street • Los Angeles, CA • USA 90012
S James Otero, Judge • USDC • 312 North Spring Street, Courtroom 1600 • Los Angeles, CA • USA 90012
Barry A Taylor, Judge • LASC • 6230 Sylmar Avenue • Van Nuys, CA • USA 91401
Bernadette Torivio, Executive Secretary • CJP • 455 Golden Gate Avenue, Suite 14400 • San Francisco, CA • USA 94102-3660
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