Reading the answer: what the opposition to the vexatious-litigant motion argues
The record of the pending request to restrict this litigant's court access was one-sided, and the reason was a file format. The motion asking a federal court to declare him a vexatious litigant, and the memorandum supporting it, arrived as documents with searchable text and were read and summarised here last week. His answer to them arrived as a scan - a photograph of paper, with no text a computer can read - so this site carried the case against him and nothing of his reply.
That has been corrected. The five pages were converted to images and read by eye, and what they argue is now recorded alongside the motion they answer. He denies that the legal standard for restricting a litigant is met, and makes a point that this project's own records independently confirm: no court, state or federal, has ever declared him a vexatious litigant. He says the defendant who brought the motion has never had a case tried against him in that court at all; that his lawsuits arise from things he says were done to him; that where cases were duplicated or delayed it was because a defendant living abroad could not be served; and that the count of fifty-five lawsuits is asserted without proof, because no judgment has ever found any of those claims meritless. The brief attached to his answer argues the law, citing the Supreme Court's rule that a litigant without a lawyer is held to a less demanding standard of drafting, accepting the three-part test the moving party itself proposed, and arguing the first part of it fails. He asks that the motion be struck, or else heard by a jury rather than decided by one judge.
Neither side's account is a finding. Nothing in either has been ruled on, and the motion remains undecided.
How the reading was done matters, because it sets a limit on what it can be used for. Nothing was transcribed by software; the pages were rendered as images and read, which keeps any misreading visible instead of turning it into confident-looking text. The summary published here is this project's reading, not a transcript, and nothing from those documents is quoted anywhere on this site - reading a rendered page is not the same as a person opening the court's own copy. No image or text from it is kept. The answer also contains accusations about the opposing lawyer's professional conduct; no court has examined them, and they are deliberately not recorded.
The same change makes this repeatable. A little over half of the court documents collected for this research - 458 of 858 - are scans with no readable text, and until now each attempt to read one rebuilt the method from scratch. The tool that rendered these pages is now kept, together with a rule about when it may be used: to check a claim already published, and to read a filing in which someone answers a motion made against them. The second of those is new, and it exists so that a case like this one - where the accusation is readable and the defence is not - does not stay one-sided.
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Note
No court has declared this litigant a vexatious litigant, and the motion asking one to do so has not been decided. The claims summarised here, on both sides, are things the parties have asserted in their filings. Reading a scanned filing as an image is not the same as reading the court's own copy, so nothing from these documents is quoted on this site and the summary should be read as this project's account of them rather than as their words.