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Case number 14-7211, invariant W.A.R.

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LLP Wade Robertson, appellant V. William C. Hardenauer Jr.

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Mr. Robertson, pro se, appellant, and Mr. Bloom for the appellate.

[00:00:26] Speaker 04:
Good morning, Your Honor.

[00:00:27] Speaker 04:
Wade Robertson, attorney appearing in pro cur may close the court.

[00:00:31] Speaker 04:
This is going to go over four points that I think would be helpful to clarify some of the issues that were raised in the brief.

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The first point was the jurisdictional issue.

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I would raise that first because it's de novo and it's a little easier perhaps for the court to sort out.

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There's been, Mr. Kartenhauer's made an argument that the court, the Judge Lambert's court did, the district court did actually have jurisdiction under an exception to the jurisdictional rule.

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He's also at the same time argued that there were exigent circumstances.

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In this particular case, this court waited two years, over two years between the time that it issued its show cause order and the time that it actually issued its injunction.

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Yeah, I've made it clear in the brief that I've raised that there's no finding of any exigent circumstances.

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There's not even a mention.

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I don't believe the court even addressed the point.

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If there had been exigent circumstances, Judge Lamberth would not have had to wait two years.

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I think what happened, there's an inference here that I would just suggest to the court, is that Judge Lamberth most likely thought that he didn't have jurisdiction.

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Well, can I ask you about this?

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The order, suppose the order said, suppose there were two separate orders.

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Suppose there's first an order that said, I'm entering an injunction that has to do with further proceedings in this case.

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And then a separate order that said, and I'm also entering an injunction that has to do with any additional filings in any related cases.

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So your jurisdictional argument is he can't do the first because that was sufficiently bound up in what was going on in the appeal that he had to wait until the mandate issued.

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I believe that's correct.

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But the second one, there would be no problem with issuing that injunction because that didn't have anything to do with what was pending.

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I believe that's correct.

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But that was actually the conclusion to the point that I was making.

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For instance, if he was concerned about something that was happening, some exigent circumstances, maybe something happening in his particular case.

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Exigent doesn't mean immediate.

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I mean, it could mean, but it doesn't have to mean that.

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Okay.

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That's not what exigent.

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Exigent can perfectly mean just significant.

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Can it mean significant over a two-year period where nothing has happened, Your Honor?

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Sure.

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Okay.

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My point might be a little bit different, which is that maybe I'm not following.

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If he has jurisdiction to enter an injunction that covers all related proceedings except whatever is bound up in the appeal, and your argument, let's just give you the benefit of the doubt on this for purposes of this question, is that what he didn't have jurisdiction to do is to enter an injunction that enjoined further proceedings in this case because, i.e.

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the sanctions issue, because that's what's pending on appeal.

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Well, if you look at his injunction

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He does say, I'm entering an injunction that covers four categories of things.

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And it seems to me that at least with the three categories of things that are not bound up in the current appeal, the injunction's fine.

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So the best you can do is the argument that he didn't have jurisdiction to enter an injunction barring further filings in connection with this case, i.e.

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the sanctions order.

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If I understand the question correctly, I believe the answer is yes, because that was what I was going to suggest.

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He could have, on his own docket, issued a series of orders that were cabin in a very narrow fashion to deal with anything that he felt was inappropriate or needed to be stopped, and perhaps on a temporary basis at a time, but that's not what he did.

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He's affected a large swath of cases.

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He's actually altered the status quo between the parties.

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The bankruptcy case is closed.

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The judgment in the jury trial has been affirmed.

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What's left?

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What is he prohibiting you from filing?

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OK, so then that, if I understand you, then that question goes to the question of both.

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You say you've been enjoined from filing, quote, a wide range of other possible files.

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But what is there left given, as I said, the fact that we've affirmed the jury award and the bankruptcy cases?

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What's left?

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So the issue is the over-breath, which is the constitutional argument of the injunction.

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And with respect to what was left.

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Over-breath for what?

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With respect to what was left.

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You mean for you filing a new lawsuit against Cardinal or for something having nothing to do with this?

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No, Your Honor.

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So answering the first question that you just asked, there were still pending matters and there are still pending matters.

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For instance, the bankruptcy matters are not entirely resolved yet.

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And this was an issue which was raised in the brief.

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Something other than the sanctions is unresolved?

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What's unresolved other than the bankruptcy judge's sanctions?

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I've cited in my brief to the bankruptcy proceedings below Judge Lambert with Judge Teel.

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They're still ongoing, in which there are still orders that have to be complied with.

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And so what he's done, Judge Lambert's order is so broad that it's actually affected that jurisdiction of that court.

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If I can't even appeal from an order of the bankruptcy court to the district court, then I can never even get to this court.

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So it's, and he didn't even address that in his brief.

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I'm sorry, what's appealable other than the sanctions, the bankruptcy section?

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You haven't told me what's up.

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The docket's not closed yet.

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It was closed on the merits.

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Didn't he close the bankruptcy case?

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OK, so.

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And isn't the jury verdict final?

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So the issue of jury.

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Yes or no?

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Is the jury verdict final in which case, Your Honor?

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Robertson 1?

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The first case that was before Judge Uvelle?

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Yeah.

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The answer is yes.

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Okay.

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Is the jury verdict, there was no jury verdict in Robertson 2, which was transferred from Southern District of New York to Judge Uvelle, which was dismissed on Res Judicata collateral stopple grounds.

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And is there something left in that case?

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There's nothing left in that case.

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Okay.

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Give me something else.

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There's something left in.

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So the bankruptcy case, there's still something left in that.

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Other than the sanction?

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At this time, not other than the sanctions, but just Teal still has jurisdictions of other things.

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I thought he dismissed the bankruptcy case.

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He closed it on the merits.

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Closed it on the merits.

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The dock is still open.

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That's what I meant.

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I understand, Your Honor, and I certainly respect that position.

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What position?

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the position that perhaps there's nothing else.

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And so therefore, if there's nothing else, then why does it matter?

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But there is still something else.

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But more importantly, the question is, did he or did he not infringe upon this court's jurisdiction?

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On the jurisdiction, though, we have an exception for when appeals are taken interlocutorily.

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are from non-appealable orders.

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That seems to fit this case.

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Well, this court actually, that's never been determined.

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And this court actually, it actually asked for a jurisdictional argument.

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Actually, I mentioned this in the brief.

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It actually asked for supplemental argument regarding whether or not the court has jurisdiction.

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So that decision, I mean, the implied finding from this court is that it did.

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So it was never, it was never.

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It's just a one sentence judgment, correct?

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I don't recall if it's just one sentence or not.

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It was perfunctory.

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But you asked for it.

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I think that if that had been an issue, it would have said something.

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So the implied finding was that that was not a problem.

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That the appeal that was taken to this court was a valid appeal.

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It's just that you disagreed with the grounds that were raised.

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The argument on the other side, in part, was that that was an improper interlocutory appeal.

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No one ever found that to be true.

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That's an argument that Mr. Kartenhauer's made in his brief, but there was never any finding of that.

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I think when this court asked for supplemental briefing on the jurisdiction issue, I think that if that had been an issue, you would have said something.

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This question of jurisdiction actually, to some extent, dovetails to the next point, which is the relitigation issue, because that's what Judge Taylor has asked me about.

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Mr. Cartin, however, in his brief, in literally seven pages, pages 26 to 23, repeatedly said that this injunction is supposed to stop relitigation.

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It serves a purpose in relitigation.

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This entire section in his brief, Judge Lambert never said anything about relitigation in his case, in his decision.

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There's not a single mention anywhere in that memorandum that actually uses the word relitigation.

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That's not what it's about.

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What he said can be summarized most poignantly on page 5, where he starts off when he says the legal standard here.

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The legal standard for Judge Lamberth was, quote, repeated frivolous and meritless filings will not be tolerated by this court.

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And the distinction between

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An injunction that is intended to stop re-litigation of matters versus one that's arguably punitive to punish meritless or what the judge considers repeated frivolous findings is an important distinction because it goes all the way back to the first case of the trilogy of cases that have established a jurisprudence on this issue in this court.

[00:09:34] Speaker 03:
Can I ask just one other question on the jurisdiction?

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We have another exception when appeals are frivolous.

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And I don't disagree that there are exceptions to the jurisdiction.

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I haven't.

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I simply said to the court.

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You don't think the prior appeal was frivolous, even though it was taken.

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Not this appeal, Your Honor.

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The prior appeal.

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There was a bankruptcy appeal that was deemed frivolous.

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The appeal that was pending at the time when Judge Lamberth issued his order that resulted in a one sentence judgment.

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So there has been more than one appeal that has come up in the bankruptcy case.

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So the first one, which was on the merits, in which both Mr. Attorney Ty Clevenger and myself had arguments, that one was determined to be frivolous.

[00:10:22] Speaker 02:
No, I think Judge Kavanaugh is talking about the appeal from the district court to our court.

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Yes.

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For the case that, for the case, this case.

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For the case that you said divested the District Court of Jurisdiction to impose the sanctions order at the time it did because the mandate did not issue.

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But that's this case.

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Yeah.

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And this case there's never been any determination, this appeal has never been, that particular appeal.

[00:10:47] Speaker 05:
Are you done?

[00:10:47] Speaker ?:
Yeah.

[00:10:49] Speaker 05:
Okay.

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Mr. Robert Chief, time's up.

[00:10:50] Speaker 04:
Yes.

[00:10:51] Speaker 04:
Thank you.

[00:11:00] Speaker 01:
May it please the Court, my name is Jeff Blum on behalf of the appellee, William Cardenhauer, to take up the most recent argument that was being discussed.

[00:11:08] Speaker 01:
What happened in the jurisdictional issue is in the earlier appeal, what Mr. Robertson did all the way back in the bankruptcy court is he essentially filed a motion for reconsideration pursuant to bankruptcy rules.

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He then noted de novo review, in a case where you can't have de novo review, to the district court, a second level appeal.

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When that appeal was transferred, Judge Thiel in the bankruptcy court said, he transferred it, but he said this is premature and invalid.

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It's not the right way to do it.

[00:11:37] Speaker 01:
Then the bankruptcy or the district court made the same finding in its final order dismissing the case.

[00:11:43] Speaker 01:
So there has been a determination that that appeal was completely wrong taken.

[00:11:47] Speaker 01:
The word frivolous was not used, but it's elementary if you just look at the rules.

[00:11:52] Speaker 02:
If you take out frivolity, so you have an argument that then the subsequent appeal to our court from that order by the district court was frivolous because you say it was completely lacking in merit, completely lacking in merit is basically frivolous and therefore that was frivolous and therefore there's an exception to jurisdiction.

[00:12:10] Speaker 02:
But let's just suppose for a second that frivolousness is not in the equation.

[00:12:15] Speaker 02:
then if a district court enters an order before the mandate issues in our court that says no further filings in this case, i.e.

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the case that's up on appeal, does the district court have jurisdiction to do that?

[00:12:27] Speaker 01:
Yes, it does.

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Even before the mandate is issued.

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Absolutely.

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And the reason why is because the issues that were being addressed in this court on appeal had absolutely nothing to do with the anti-filing injunction that was issued in the district court.

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But if the appeal goes against you, the pending appeal goes against you, and it goes back down, there's going to be further filings in that case.

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Correct?

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Ultimately, not in that case, because it would have to go back down a level, essentially, sir.

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It would have to go back down to the bank.

[00:13:03] Speaker 03:
But that's that case.

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I mean, I think you need frivolousness here, or the interlocutory exception.

[00:13:10] Speaker 01:
And I think that we have that.

[00:13:12] Speaker 03:
But yeah, the hypothetical took those out.

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I mean, I think you're checkmated if you took those out, but your argument is you can't take those out.

[00:13:20] Speaker 02:
I think that's what we're... Well, I just want to make sure that you are checkmated.

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I guess my question is, if you take frivolousness out, do you have anything left?

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And I guess...

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I'm not saying that you're wrong on frivolousness necessarily.

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I'm just saying so that I can understand the whole issue before us.

[00:13:34] Speaker 02:
If you don't have the point that the appeal taken was frivolous, then why is it the case that the district court retains jurisdiction to enter an order barring further filings in the matter that's upon appeal?

[00:13:47] Speaker 01:
Because the appeal wasn't taken appropriately, and therefore it's a nullity.

[00:13:51] Speaker 01:
The original appeal is a nullity.

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So what happens, and this was not something that was subject to any kind of question.

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So I understand your hypothetical.

[00:13:58] Speaker 03:
So that's the other exception, I think.

[00:14:00] Speaker 03:
I'm sorry to interrupt.

[00:14:01] Speaker 03:
Takes an interlocutory appeal from a non-appealable order?

[00:14:04] Speaker 01:
Exactly.

[00:14:04] Speaker 01:
Yes, sir.

[00:14:06] Speaker 02:
And if that were true, then would, in our decision, would we have, I think what we did was we affirmed

[00:14:12] Speaker 01:
you affirmed and part of what you had a firm was that we have to find that it was premature session if it was a procedure part of field and should we have dismissed because i would have interest that yes sir i think you should but it was and maybe we should have but it was also a non-poster because you have a bankruptcy p uh... court appeals district court which is then appeal to us like to see why the word of firm might have been used in that positive mister robertson the fact that the briefing was ordered it took me months to figure out how we ended up in this

[00:14:39] Speaker 01:
procedural posture.

[00:14:41] Speaker 01:
I mean, it's a mess.

[00:14:41] Speaker 01:
And so I can see a lot of judges, a lot of attorneys who were involved in this not understanding how we got here.

[00:14:47] Speaker 02:
Sure.

[00:14:47] Speaker 02:
I mean, there's a lot of reasons.

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I don't mean to suggest that something was obvious.

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But I'm saying in terms of if everybody had dotted their i's and crossed their t's in the optimal way, you think what should have happened, it should have been dismissed.

[00:14:58] Speaker 01:
Absolutely.

[00:14:59] Speaker 01:
And under the court's prior jurisprudence in the Saravia case, which I've cited in my brief.

[00:15:06] Speaker 01:
The other thing, Your Honor, is

[00:15:07] Speaker 01:
Mr. Robertson says that the district court made no finding of exigency.

[00:15:12] Speaker 01:
A finding of exigency is not required.

[00:15:14] Speaker 01:
What is required under Powell, Urban, and Green, which are the three cases that deal with anti-filing injunctions in the circuit, what is required is that exigent circumstances exist.

[00:15:24] Speaker 01:
That is what is required.

[00:15:26] Speaker 01:
Now, what has happened, and I don't want to spend too much time going through the procedure as to how we got here.

[00:15:32] Speaker 01:
But Mr. Robertson initiated bankruptcy proceedings in Tennessee.

[00:15:36] Speaker 01:
It was determined that his arguments were flat out wrong.

[00:15:39] Speaker 01:
Judge Huvel in the district court in the original jury verdict case determined that those very same arguments were wrong.

[00:15:46] Speaker 01:
Mr. Robertson then appealed the Tennessee matter.

[00:15:50] Speaker 01:
Again, the appellate court determined he was wrong.

[00:15:53] Speaker 01:
Now, he has three forewarnings.

[00:15:56] Speaker 01:
The bankruptcy case gets transferred to the District of Columbia Bankruptcy Court, where

[00:16:00] Speaker 01:
the same arguments are now being reasserted and continue to be wrong.

[00:16:05] Speaker 01:
And that's what Judge Lambert's order goes through one by one.

[00:16:08] Speaker 01:
Simply put, saying you can't in the face of multiple warnings just continue to pursue something that is so frivolous.

[00:16:15] Speaker 01:
And the reason why it was frivolous is essentially that what occurred factually speaking at the beginning is Mr. Robertson entered into partnership agreement with my client.

[00:16:25] Speaker 01:
My client invested $3.5 million into that partnership.

[00:16:30] Speaker 01:
Mr. Robertson lent himself that money, found his way into his personal brokerage account.

[00:16:35] Speaker 01:
Almost all of it disappeared.

[00:16:37] Speaker 01:
My client's left without any real remedy.

[00:16:39] Speaker 01:
So this very narrow transaction is how this all started.

[00:16:42] Speaker 01:
All these bankruptcy cases, he's arguing that the funds that landed in his personal brokerage account

[00:16:48] Speaker 01:
are funds of the partnership, notwithstanding the fact that they've been taken completely out of the partnership and sit in a personal brokerage account.

[00:16:57] Speaker 01:
The other thing that was continually argued in the bankruptcy courts is that the automatic stay would have precluded Mr. Cardin, however, from continuing his claims against Mr. Robertson personally, not against war LLP partnership, which was removed by my predecessor counsel so as to not have issues with an automatic stay.

[00:17:16] Speaker 01:
But he continued to press and press and press.

[00:17:18] Speaker 01:
Judge Lambert's order specifically cites the many occurrences of appeals in this case, which he did not consider.

[00:17:25] Speaker 01:
And similar findings were found in this case.

[00:17:28] Speaker 01:
In terms of whether or not an anti-filing injunction is necessary, it absolutely is based on this record.

[00:17:34] Speaker 01:
Mr. Robertson indicated to the court that he has a whole host of cases that he wants to file.

[00:17:39] Speaker 01:
Whole host.

[00:17:40] Speaker 01:
Can't, for the life of me, figure out what they are, but I know I'll see them at some point.

[00:17:45] Speaker 01:
Judge Lamberth noted that not only was there one case, the original case, in the DC District Court, where we got a $7 million jury verdict, when that, in an attempt to obstruct that, Mr. Robertson then goes to New York, where he files a case based on the same general set of facts.

[00:18:02] Speaker 01:
That fails.

[00:18:04] Speaker 01:
Judge Lamberth again notes, well, he's now gone to California and filed a very similar case there.

[00:18:09] Speaker 01:
Because the original transaction was so narrow, it's a basic partnership dispute.

[00:18:15] Speaker 01:
involving really two or three critical facts.

[00:18:18] Speaker 01:
Because it was so narrow, there could be nothing more that Mr. Robertson could file that would not simply put the harassment.

[00:18:26] Speaker 01:
And in Judge Hubell, Judge Hubell did a very nice memorandum order to the extent that

[00:18:31] Speaker 01:
the court needs guidance on the background of how we ought to do this.

[00:18:35] Speaker 01:
Judge Juvel's memorandum of order cites why he's claim-procluded from really filing anything else related to this transaction, but that doesn't stop him.

[00:18:52] Speaker 05:
OK, thank you.

[00:18:53] Speaker 05:
Mr. Robertson used up all time, but you can have one minute.

[00:18:59] Speaker 04:
The question, the issue that I want, the last issue I want to raise is the overbreath question.

[00:19:06] Speaker 04:
It's constitutionally overbought.

[00:19:08] Speaker 04:
The one point that I would focus the court on the most is that if in fact there was a fraud on the court, I've mentioned this in my brief,

[00:19:15] Speaker 04:
And how am I supposed to go back and say that any of these districts got a fault in the court?

[00:19:19] Speaker 04:
And by the way, if there was a fault in the court, then it might actually affect this appellate court because a fault in the court in the district court could never, you know, a decision was affirmed here.

[00:19:31] Speaker 04:
might have been affirmed on false evidence or false testimony or something that arises to the court.

[00:19:36] Speaker 04:
So if it's so broad that it prevents that, if it's so broad as it's constructed, I can't even petition the court, perhaps they're pre-filing a review of some sort and say there's a problem, then we're out.

[00:19:51] Speaker 04:
Thank you.

[00:19:52] Speaker 05:
Thank you, Your Honor.

[00:19:53] Speaker 05:
Thank you.

[00:19:53] Speaker 05:
The case is submitted.