# Opposition Brief — Halvorsen v. Ferguson

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Opposition Brief
- **Published:** January 1, 1988
- **Citation:** 484 U.S. 1078

## Text

Supreme Court, U.S,
a3) 2:
JAN 20 1988
No. 87-1109
JOSEPH F. SPANIOL, JR,
IN THE CLERK

Supreme Court of the United States

MARY CATHERINE HALVORSEN,

Petitioner,
Vv.

FERGUSON & BURDELL, A FIRM
CONSISTING OF THE PARTNERS OF
WILLIAM H. FERGUSON, WILLIAM
WESSELHOEFT, DONALD MCL.
DAVIDSON, EDWARD HILPERT, JR.,
THOMAS J. GREENAN, HENRY W.
DEAN, WILLIAM B. MOORE, C. DAVID
SHEPPARD, W.J. THOMAS FERGUSON,
JAMES E. HURT, WILLIAM D.
STITES, BRUCE P. BABBIT, E.P.
SWAIN,JR., CHRISTOPHER KANE, and
HENRY C. JAMES; and WILLIAM
WESSELHOEFT and MARGARET
WESSELHOEFT and THEIR MARITAL
COMMUNITY,

Respondents.

BRIEF OF RESPONDENTS IN OPPOSITION TO
PETITION FOR WRIT OF MANDAMUS TO THE
UNITED STATES COURT OF APPEALS FOR THE

EIGHTH CIRCUIT

DAVID F. ROSS

1111 Third Ave. Of Karr, Tuttle, Koch,

Suite 2500 Campbell, Mawer, Morrow

Seattle, WA 98101 & Sax, &.S8.,

(206) 223-1313 Attorneys for
Respondents

aBCD Legai Printers. Seattie. Washington

Questions Presented for Review

(1) Where the United States District Court
for the Western District of Washington at
Seattle dismissed petitioner's complaint for
legal malpractice because it had already
been concluded adversely to her in previous
state and federal court actions and the
District Court imposed sanctions against her
pursuant to Fed. R. Civ. P. 11, was the
United States Court of Appeals for the
Eighth Circuit correct in refusing
petitioner's Notice of Appeal?

(2) Should the Court impose’~ sanctions
against petitioner pursuant to Rule 49.2 and
26 U.S.C. § 1912 for filing a frivoious
appeal?

es ae

Parties to This Proceeding

Petitioner is Mary Catherine Halvorsen.

Respondents are the law firm of Ferguson &
Burdell and the partners of the firm and
their marital communities.

- ili -

Table of Contents

Questions Presented for

Review ..

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Parties to the Proceedings

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Teme GL AMEMOTiCLes .icciccces

A. OPINION OF COURTS BELOW

B. STATEMENT OF JURISDIC-

TIONAL GROUNDS ...........

Cc. STATUTES AT ISSUE IN THE

CASE

ns 2S 8 @€ 228 @€.9 8646 68 86.0666 6 806 6

D. STATEMENT OF THE CASE

E. REASONS WHY A WRIT SHOULD

NOT BE ALLOWED ...........

(1)

(2)

(3)

Appendix

Halvorsen Failed to

State a Claim Below

The Eighth Circuit
Properly Refused
Halvorsen's Notice of

re

Halvorsen's Petition
Is Frivolous and
Sanctions Should be
Imposed Against Her

N

10

10

13

18

- iv -

Table of Authorities

Page
Table of Cases
Balise v. Underwood, 62 Wn.2d
195, 381 P.2d 966 (1963) ...... 12
Clark v. State of Florida,
U.S. s Bs See , 90
L. Bd. 24 330 (1986) .cseccccces 1l
Clark v. Watchie, 513 F.2d 994
(9th Cir. 1975), cert. den.,
423 U.S. 641, 96 Ss CG. 7a, 46
Le BG. 24 6O (1978)

for the Western District of Washington
dismissed Halvorsen's complaint and
imposed sanctions against her. She sought
review by the Eighth Circuit rather than
the Ninth Circuit, generally alleging that
the Ninth Circuit discriminated against
women. The Eighth Circuit Clerk refused
her Notice of Appeal. She now seeks a
writ of mandamus to the Eighth Circuit
from this Court.

E. REASONS WHY A WRIT SHOULD NOT BE
ALLOWED

A writ of mandamus’ should not be
allowed in this case and sanctions should
be imposed by this Court against Halvorsen
for filing a frivolous petition.

(1) Halvorsen Failed to State a Claim
Below

From a substantive standpoint, the
District Court was correct in dismissing

Halvorsen's complaint. Halvorsen failed

to establish a prima facie case of legal

|

- ll -

- malpractice against Ferguson & Burdell,

Daugert v. Pappas, 104 Wn.2d 254, 704 P.2d

600 (1985); Halvorsen v. Ferguson, 46 Wn.

App. 708, 735 P.2d 675 (1986), rev. den.,

108 Wn.2d 1008 (1987).
All of Halvorsen's claims have pre-
viously been adjudicated against her. She

cannot, under the doctrine of res judi-

cata, re-litigate them in the federal

courts. See, e.g., Williams v. State of

Washington, 554 F.2d 369 (9th Cir. 1977);

Clark v. Watchie, 513 F.2d 994 (9th Cir.

Ae7ety. Gere. Gen., 423 U.S. 841, 96 S. Ct.

72, 46 Lb. Ba. 24 60 (1975).

Further, her claim is barred by the
applicable Washington statute of limita-
tions. In 1976, the Washington Supreme
Court adopted the discovery rule in a

statute of limitations case in Peters v.

Simmons, 87 Wn.2d 400, 406, 552 P.2d 1053,

1056 (1976), stating:

a

[Wje hold that the statute of

limitations for legal malprac-

tice should not start to run

until the client discovers, or

in the exercise of reasonable

diligence should have discovered

the facts which give rise to his

or her cause of action.
The statute of limitations for legal mal-
practice is three years. RCW 4.16.080.
Halvorsen "knew" of her cause of action at
least by October 22, 1980 when she filed a
virtually identical lawsuit in state
court. The present federal action is

filed more than six years after her origi-

nal lawsuit against Ferguson & Burdell was

filed, and more than nine years after her

divorce action which allegedly gave rise
to the claim.

Finally, under Washington law, sum-
mary judgment is appropriate to avoid a

useless trial, Balise v. Underwood, 62

Wn.2d 195, 381 P.2d 966 (1963). The Wash-

ington Supreme Court has concluded that a

—: a

plaintiff was not deprived of her right to
a trial by jury by granting summary judg-

ment, Nave v. City of Seattle, 68 Wn.2d

721, 415 P.2d 93 (1966), appeal dismissed,

365 U.S. 450, 87 S$. Ct. 614, 17 L. Ba. 2a

513 (1967), rehearing den., 386 U.S. 929,

67 S. Ct. 853, 17 bs Ba. 26° 801i: (1967).

The substantive aspects of
Halvorsen's third action against Ferguson
& Burdell are patently meritless.

(2) The Eighth Circuit Properly Refused
Halvorsen's Notice of Appeal

With respect to the ostensible rea-
sons for Halvorsen's present petition,
Halvorsen has not demonstrated that any of
the criteria set forth in Rule 17 are
applicable in this case.

The Clerk of the United States Court
of Appeals for the Eighth Circuit merely

complied with 28 U.S.C. § 1294. It is

error for a Circuit to accept a case from

- 14 «

outside its territorial jurisdiction,

Preston Co. v. Raese, 335 F.2d 827 (4th

Cir. 1964); Roofing & Sheet Metal Ser-

vices, Inc. v. La Quinta Motor Inns, Inc.,

689 F.2d 982 (llth Cir. 1982).

Halvorsen also asserts that the broad
power of the federal courts to transfer a
case, 28 U.S.C. § 1404, should be invoked,
but 28 U.S.C. § 1404 only provides that
the district courts may transfer cases and
makes no reference to Circuit Courts of
Appeals. 28 U.S.C. § 1404 does not sus-
tain her position. First, the power to
transfer could only have been invoked by
the United States District Court for the
Western District of Washington and not a

Circuit Court of Appeals. Norwood v.

Rirkpetrick, 349 U.S. 29. 75 S. Ct. $44,

99 L. Ed. 2d 789 (1955), cited by peti-

tioner, clearly confirms this view. This

case pertains to the authority of a dis-

» 38 «

trict court to transfer a case under 28
U.S.C. § 1404(a). Halvorsen thus cites no
authority for extraterritorial jurisdic-
tion of the Circuit Courts of Appeals.

Second, even if transfer were somehow
appropriate under federal law, Halvorsen
has failed to set forth proper grounds for
transfer. She asserts in her Petition at
4:

The Ninth Circuit is very

male chauvinist; denied women

comparable worth; upheld a state

award to an ex-husband to search

his ex-wife's home four times a

year; and never allows women

oral argument. Petitioner's

appeal would be doomed before

she even files her Brief if she

must file in the Ninth Circuit.

This is unsupported.

She also alleges in her Petition at

The defendants petitioner
is suing and the attorneys rep-
resenting defendants are weal-
thy, influential law firms with
franchise offices in Washington,
D.C. and possibly other places
as well. One of the defendants

o 16 «

as well as one of the attorneys
representing the defendants is a
past president of the Washington
State Bar Association. In addi-
tion, the attorneys for defen-
dants also have a partner who
serves in the state legislature
as Chairman of the State Senate
Judiciary Committee and = who
raised every judge's salary in
the state of Washington while
continuing to practice before
the same judges whose salaries
he had raised. Another partner
in this same firm headed the
Judicial Qualifications Commis-
Sion, the discipline Commission
in this state, serving at the
same time these other partners
served in the aforementioned
capacities.

This is simply erroneous. Karr, Tuttle,
Koch, Campbell, Mawer, Morrow & Sax, P.S.,
counsel for Ferguson & Burdell, has no
"franchise office" or any other office in
Washington, D.C. F. Lee Campbell of that
firm is a past president of the Washington
State Bar Association and a past chair of
the Washington Judicial Qualifications

Commission; he is not involved with this

litigation. Philip A. Talmadge of that

a 29a

firm is a past chair of the Washington
State Senate Judiciary Committee. He did
not "raise every judge's salary in the
state of Washington" because prior to
1987, that required an act of the full
Legislature, signed by the Governor.
Since 1987, Washington state judicial
salaries have been set by a citizens com-
mission independent of the Legislature in
accordance with a constitutional amendment
adopted by Washington voters at the polls
in November, 1986. See, RCW 43.03.300 et.
seq.

William Wesselhoeft of Ferguson &
Burdell is a past president of the Wash-
ington State Bar Association, but
Ferguson & Burdell does not have a branch
office in Washington, D.C.

Halvorsen obviously —impugns the

integrity of the Washington State judi-

ciary and the judges of the Ninth Circuit,

—° 2

but all of this, of course, is thoroughly
irrelevant as to the independent federal
judges of the Ninth Circuit Court of
Appeals. ~Halvorsen simply failed to dem-
onstrate that transfer to the Eighth Cir-
cuit is appropriate.

(3) Halvorsen's Petition Is Frivolous and

Sanctions Should Be Imposed Against
Her

This Court should impose sanctions
against Halvorsen pursuant to Rule 49.2
and 28 U.S.C. § 1912. The District Court
properly determined that Halvorsen's case
was groundless.

The imposition of sanctions is appro-
priate where the action is clearly and
fundamentally without merit in law or in

fact. Cook v. Peter Kiewit Sons Co., 775

F.2d 1030 (9th Cir. 1985). In Cook, an
employee filed several actions in federal
court after his identical state court

action was dismissed. The court found

o £2 :=

that the federal actions were "a carbon
copy of Cook's previous lawsuits, raising
the identical cause of action..." The
court affirmed the imposition of reason-
able attorneys' fees.

The chastisement given to Halvorsen
by the Ninth Circuit Court of Appeals in

Halvorsen v. State, supra, rings true for

the present action:

The only possible defense
against the charge that this is
vexatious litigation and_ the
prayer for resulting financial
sanctions would be the ignorance
of the law that a pro se liti-
gant may claim. In dragging
one's adversaries into court and
running up legal fees and costs,
however, no person has the right
to a free ride. Somebody has to
pay for these excursions. Going
into court is serious business.
A brief visit to a competent
lawyer would have provided
Halvorsen with the advice that
an appeal would be expensive and
frivolous. We do not think
conscious ignorance of this kind
is a defense.

Memo. Op. at 3-4.

The present action is indeed frivo-
lous for all of the reasons set forth
above. Halvorsen is the classic abusive
litigant about whom this Court should be
concerned. Note, “Abusive Pro Se Plain-
tiffs in Federal Courts: Proposals for

Judicial Controls," 18 U. Mich. J.L. Ref.

93 (1984). See, Clark vv. State of

Florida, is # , 8. Ce. , 90

L. Ed. 2d 330 (1986) (C.J. Burger concur).

CONCLUSION

The petition for a writ of mandamus
should be denied. Sanctions for the fil-
ing of a frivolous petition should be

imposed against petitioner Halvorsen, Rule

49.2; 29 U.S.C. § 1912.

~ wh «

DATED this “£7;/ day of January,
1988.

Respectfully submitted,

spo OM] JZ] L- ra

sats F. Ross we Ce oes
Of Karr, Tuttle, a c
Campbell, Mawer, Morrow
& Sax, P.S.

Attorneys for Respondents

1111 Third Avenue

Suite 2500

Seattle, Washington 98101
(206) 223-1313

BEST AVAILABLE COPY

APPENDIX

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

MARY CATHERINE HALVORSEN)

JUDGMENT IN
A CIVIL CASE

)

Plaintiff, )

)

Vv. )

)
FERGUSON & BURDELL, ) NO. C87-617R
et al., )
)
)

Defendants.

Jury Verdict. This action came before
the Court for a trial by jury. The
issues have been tried and the jury
has rendered its verdict.

X Decision by Court. This action came
to trial or hearing before the Court.
The issues have been tried or heard
and a decision has been rendered.

{IT IS ORDERED AND ADJUDGED

that this action is dismissed with
prejudice.

Da*e August 5, 1987 Clerk Bruce Rifkin

(Signature)

(By) Deputy Clerk

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

MARY CATHERINE HALVORSEN,

Plaintiff, NO. C87-617R
Ve.
FERGUSON & BURDELL, A FIRM ORDER
CONSISTING OF THE PARTNERS GRANTING

WILLIAM WESSELHOEFT, DONALD MOTION TO
McL. DAVIDSON, EDWARD DISMISS
HILPERT, JR., THOMAS J. AND FOR
GREENAN, HENRY W. DEAN, SANCTIONS

WILLIAM B. MOORE, C. DAVID
SHEPARD, W.J. THOMAS
FERGUSON, JAMES E. HURT,
WILLIAM D. STITES, BRUCE P.
BABBIT, E.P. SWAIN, JR.
CHRISTOPHER KANE, and HENRY)
C. JAMES, and WILLIAM )
WESSELHOEFT and MARGARET )
WESSELHOEFT and THEIR MARI-)
TAL COMMUNITY, )

)
)
)
)
)
)
)
)
OF WILLIAM H. FERGUSON, ) DEFENDANTS
)
)
)
)
)
)
)
)
)

)
Defendants. )
)

The Court, having considered the motion
of defendants filed on June 3, 1987 seeking

an order dismissing the above-captioned

ORDER GRANTING DEFENDANTS MOTION
TO DISMISS AND FOR SANCTIONS - 1

cause of action; the Affidavit of David F.
Ross with attached exhibits 1-9; the
memorandum of authorities filed in support;
the responses of plaintiff; and having
considered the files and pleadings herein;
and

The Court having concluded that there
are no genuine issues of material fact with
respect to the motion; and

The Court having concluded that the
above-captioned cause of action was filed
in violation of Rule 11, Federal Rules of
Civil Procedure:

NOW THEREFORE, IT IS ORDERED THAT:

1. Defendants motion to dismiss is
granted;

2. Plaintiff's cause of action is
dismissed with prejudice;

3. Sanctions are awarded to defendants

ORDER GRANTING DEFENDANTS MOTION
TO DISMISS AND FOR SANCTIONS - 2

and against plaintiff for costs’ and
reasonable attorney's fees upon proper
substantiation.

DONE IN OPEN COURT this 4th day

of August, 1987.

(Signature)
HONORABLE BARBARA ROTHSTEIN

Presented by:

(Signature)
David F. Ross
Karr, Tuttle, Koch, Campbell,
Mawer, Morrow & Sax P.S.
Attorneys for Defendants

ORDER GRANTING DEFENDANTS MOTION
TO DISMISS AND FOR SANCTIONS - 3

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON

MARY CATHERINE HALVORSEN

Plaintiff, SUPPLEMENTAL
JUDGMENT IN

)
)
)
)
Vv. ) A CIVIL CASE
)
)
)
)

FERGUSON & BURDELL,
et al.,

NO. C87-617C
Defendants.

Jury Verdict. This action came before
the Court for a trial by jury. The
issues have been tried and the jury
has rendered its verdict.

X Decision by Court. This action came
to trial or hearing before the Court.
The issues have been tried or heard
and a decision has been rendered.

IT IS ORDERED AND ADJUDGED

that defendants shall have of plaintiff
the sum of $2,111.00 for reasonable
| attorneys' fees.

Date 9 September 1987 Clerk BRUCE RIFKIN

(Signature)

(By) Deputy Clerk

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

MARY CATHERINE HALVORSEN,

Plaintiff, NO. C87-617C

V.
FERGUSON & BURDELL, A FIRM ORDER AND
CONSISTING OF THE PARTNERS JUDGMENT RE
OF WILLIAM H. FERGUSON, ATTORNEYS '

McL. DAVIDSON, EDWARD
HiLPERT, JR., THOMAS J.
GREENAN, HENRY W. DEAN,
WILLIAM B. MOORE, C. DAVID
SHEPARD, W.J. THOMAS
FERGUSON, JAMES E. HURT,
WILLIAM D. STITES, BRUCE P.
BABBIT, E.P. SWAIN, JR.
CHRISTOPHER KANE, and HENRY)
C. JAMES, and WILLIAM )
WESSELHOEFT and MARGARET )
WESSELHOEFT and THEIR MARI-)
tal community, )

)
)
)
)
)
)
)
)
)
WILLIAM WESSELHOEFT, DONALD) FEE’S
)
)
)
)
)
)
)
)

)
Defendants. )
)

The Court, having considered _ the
Affidavit of David F. Ross’7 regarding

attorneys' fees filed pursuant to the Court's

Order Granting Sanctions filed on August

ORDER AND JUDGMENT RE
ATTORNEYS' FEES - 1

5S, 1987; and having considered the files
and pleadings herein and being fully advised

AND having further determined that the
attorneys' fees in the amount of $2,111.00
as set forth in the affidavit are reasonable;

NOW THERFORE:

IT IS HEREBY ORDERED, ADJUDGED AND
DECREED that defendants have judgment
against plaintiff in the sum of $2,111.00
for reasonable attorneys' fees.

DONE IN OPEN COURT this 8th day

of September , 1987.

(Signature)
JUDGE BARBARA ROTHSTEIN

ORDER AND JUDGMENT RE
ATTORNEYS' FEES - 2

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

MARY CATHERINE HALVORSEN,
Plaintiff, NO. C87-617R

NOTICE OF
APPEAL

V.

FERGUSON & BURDELL,
et al.,

Defendants.

Rd

Notice is hereby given that Mary
Catherine Halvorsen, plaintiff above-named,
hereby appeals to the United States Court
Of Appeals for the Eighth Circuit from the
Order dismissing plaintiff's case against
Ferguson & Burdell, dated August 4, 1987,
entered August 4, 1987, and received by
plaintiff August 7, 1987.

Plaintiff is appealing to the Eighth

Circuit because it ~sS common knowledge women

NOTICE OF APPEAL - 1

= © _—

Cannot obtain a fair hearing from the Ninth
Circuit. Witness the comparable worth
decision.

DATED this lst day of September 1987.

(Signature)
Mary Catherine Halvorsen, plaintiff
8234 N.E.Hidden Cove Road
Bainbridge Island, Washington 98110
Telephone: (206) 842-5439

NOTICE OF APPEAL - 2

-10-

8324 N.E. Hidden Cove Road
Bainbridge Island, Wash. 98110
September 3, 1987

Clerk of the Court

United States District Court
1010 Fifth Avenue

Seattle, Washington

RE: NO. C87-617R
Dear Clerk of the Court:

Pursuant to our conversation this
morning wherein you informed me that you
could not process an appeal to the Eighth
Circuit Court of Appeals, I am writing this
letter.

I will send my appeal directly to the
Eighth Circuit myself.

Thank you for your attention to this
matter.

Sincerely yours,

(Signature)
Mary Catherine Halvorsen
plaintiff

2)
2)

David W. Ross

Karr, Tuttle et al.,

2500 Third Avenue Building
1111 Third Avenue

Seattle, Washington 98101

8324 N.E. Hidden Cove Road
Bainbridge Island, Wash. 98110
September 3, 1987

Clerk of the Court

United States Court of Appeals
Eighth Circuit

511 U0. S. Court and Customs House
St. Louis, Mo. 63101

RE: C87-617R
Dear Clerk of the Court:
Enclosed herewith are the following:

NOTICE OF APPEAL
CERTIFICATION OF MAILING
LETTER TO CLERK OF THE COURT,
U.S. DISTRICT COURT, SEATTLE.

As per my letter to the Clerk of the
District Court in Seattle, I am sending my
appeal directly to you for processing.

Thank you for your attention in this

matter.
ery truly yours,
(Signature)
Mary Catherine Halvorsen
V 5

S
e ef Ale,

Avenue

UNITED STATES COURT OF APPEALS
For the Eighth Circuit
U.S. Court and Custom House
1114 Market Street
St. Louis, Missouri 63101

Robert D. St. Vrain 314-425-5600
Clerk FTS: 279-5600

Ms. Mary Catherine Halvorsen
8324 N.E. Hidden Cove Rd.
Bainbridge Island, WA 98110

Re: No. Mary Catherine Halvorsen,
vs. Ferguson & Burdell, et al.

Dear Ms. Halvorsen:

Receipt is acknowledged of your letter
of September 3, 1987, and enclosures. Your
notice of appeal is being sent back to the
Western District of Washington for
processing in compliance with the rules.
This court does not have jurisdiction to
hear appeals from courts outside this
circuit.

Sincerely

(Signature)

Robert St. Vrain

Clerk of Court
jh

Enclosures

CC;

- 34°

Bruce Rifkin, Clerk,

U.S.
308

District Court
U.S. Courthouse,

Seattle WA 98104
(Dist. Ct. No. C87-617R)

1010 5th

Ave.

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

MARY CATHERINE HALVORSEN,

Plaintiff, NO. 87-617R

Vv. NOTICE OF
FERGUSON & BURDELL, THE UNITED
et al., STATES

_ SUPREME
Defendants. COURT

)
)
)
)
)
) APPEAL TO
)
)
)
)
)

Notice is hereby given that Mary
Catherine Halvorsen, plaintiff above-named,
hereby appeals to the United States Supreme
Court the issue of jurisdiction of filing
an appeal in an Appellate Court of another
Circuit when the regular Circuit Appellate
Court is notably biased against women
appellants.

DATED this 2lst day of September 1987.

(Signature)

Mary Catherine Halvorsen, Appellant
8324 N.E. Hidden Cove Road
Bainbridge Island, Wash. 98110
Telephone: (206) 842-5439

- 16-

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

MARY CATHERINE HALVORSEN,

Plaintiff, NO. C87-617R

APPEAL
FERGUSON & BURDELL,
a | eo

)
)
)
)

Vv. ) AMENDED
)
)
)
Defendants. )
)

Notice is hereby given that Mary
Catherine Halvorsen, plaintiff above-named,
hereby amends her appeal to include the
award of attorneys' fees and judgment filed
September 9, 1987.

Since the exact court in which to file
the appeal is itself on appeal, plaintiff
assumes that her appeal will be held in
abeyance until further direction of a higher

court.

DATED this 21st day of September 1987.

(Signature)
Mary Catherine Halvorsen,
Plaintiff/Appellant

ee creme a hagay

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