Wilson, Elser, Moskowitz, Edelman and Dicker is the last company to be representing insurance companies defending companies from employment lawsuits. They have been sued for unlawful termination, harassment, discrimination ... and they have settled. In the case below they were basically caught lying in court documents. The Judge sanctioned them. Wilson, Elser, Moskowitz filed motion to reargue and lost.

Dean Rocco chose to work at this company. He obviously agrees with these things. He's an attorney and could have researched them. No wonder this firm supports Dean rocco when he lies in court documents. I'm glad I found this because now I can file a motion for sanctions because attorneys Dean Rocco and Katherine M McSweeney violated California Code of Civil Procedure Section 128.7 by providing knowingly false statements to the court.

Attorney Katherine M McSweeney stated June 12, 2013 in her declaration pg 2 item 12 "Attached hereto as Exhibit "L" is a true and correct copy of an excerpt from a Texas hearing on a motion for protective order wherein Cummins accuses Randy Turner of placing incendiary devices under her car." 

Exhibit L page two states "And not only that but six weeks ago I find an M80 under the front of my car. And about four weeks ago you may have heard in the news about all the arson in LA, Beverly Hills. Someone tried to throw a Molotov cocktail under the front of my car. But it looks like they had bad aim, it hit the curb and broke off and ended up in the street. So a container with gasoline and some sort of solvent ended up in the front of my car."

No where does it state that I accuse Randy Turner of placing an incendiary device under my car. Attorney Dean Rocco and attorney Katherine M McSweeney violated Cal Code of Civ Proc Sec 128.7 by knowingly providing false statements to the court.

#	Docket Text
09/19/1995	1	COMPLAINT filed; Summons issued and Notice pursuant to 28 U.S.C. 636(c); FILING FEE $ 120.00 RECEIPT # 246325 (mb) (Entered: 09/20/1995)
11/21/1995	7	NOTICE OF MOTION by Elser & Dicker, Glenn Fuerth, Mark Anesh to dismiss all claims for relief against defendants Glenn Fuerth and Mark Anesh pursuant to Rule 12(b)(6) , to dismiss the second , fourth, fifth, sixth and seventh claims for relief in the first amended complaint pursuant to 12(b)(1) , Return date 12/15/95 (rag) (Entered: 12/01/1995)
11/21/1995	8	MEMORANDUM by Elser & Dicker, Glenn Fuerth, Mark Anesh in support of [7-1] motion to dismiss all claims for relief against defendants Glenn Fuerth and Mark Anesh pursuant to Rule 12(b)(6), [7-2] motion to dismiss the second , fourth, fifth, sixth and seventh claims for relief in the first amended complaint pursuant to 12(b)(1) (rag) (Entered: 12/01/1995)
12/12/1995	10	REPLY MEMORANDUM OF LAW by Elser & Dicker, Glenn Fuerth, Mark Anesh IN SUPPORT OF re: [7-1] motion to dismiss all claims for relief against defendants Glenn Fuerth and Mark Anesh pursuant to Rule 12(b)(6), [7-2] motion to dismiss the second , fourth, fifth, sixth and seventh claims for relief in the first amended complaint pursuant to 12(b)(1) (ae) (Entered: 12/15/1995)
12/12/1995	11	AFFIRMATION of James D. Harmon, Jr. by Elser & Dicker, Glenn Fuerth, Mark Anesh IN SUPPORT OF Re: [7-1] motion to dismiss all claims for relief against defendants Glenn Fuerth and Mark Anesh pursuant to Rule 12(b)(6), [7-2] motion to dismiss the second , fourth, fifth, sixth and seventh claims for relief in the first amended complaint pursuant to 12(b)(1) (ae) (Entered: 12/15/1995)
12/14/1995	12	MEMORANDUM by Mary Ruth Wright in opposition to [7-1] motion to dismiss all claims for relief against defendants Glenn Fuerth and Mark Anesh pursuant to Rule 12(b)(6) (cd) (Entered: 12/18/1995)
12/22/1995		Memo endorsed on motion; denying [7-1] motion to dismiss all claims for relief against defendants Glenn Fuerth and Mark Anesh pursuant to Rule 12(b)(6), denying [7-2] motion to dismiss the second , fourth, fifth, sixth and seventh claims for relief in the first amended complaint pursuant to 12(b)(1) ( signed by Judge Miriam G. Cedarbaum ); Copies mailed. (kg) (Entered: 12/27/1995)
01/17/1996	13	ANSWER to Complaint by Elser & Dicker, Glenn Fuerth, Mark Anesh (Attorney James D. Harmon); by attorney James D. Harmon for defendants (emil) (Entered: 01/22/1996)
01/17/1996	13	COUNTERCLAIM by Glenn Fuerth against Mary Ruth Wright (emil) (Entered: 01/22/1996)
01/29/1996	14	NOTICE OF MOTION by Mary Ruth Wright for assessing sanctions against The Harmon firm; James Harmon, Jr., Esq.; Wilson Elser Moskowitz Edelman & Dicker; Glenn fuerth; and Mark Anesh prusuant to f.R.C.P. 11 and assessing sanctions against James Harmon, Jr. Esq. pursuant to 28 U.S.C. 1927`1 , Return date 1/12/96 (dkt. & fld. as per instr. of chambers on 1/29/96) (pl) (Entered: 01/31/1996)
01/29/1996	15	MEMORANDUM by Mary Ruth Wright in support of [14-1] motion for assessing sanctions against The Harmon firm; James Harmon, Jr., Esq.; Wilson Elser Moskowitz Edelman & Dicker; Glenn fuerth; and Mark Anesh prusuant to f.R.C.P. 11 and assessing sanctions against James Harmon, Jr. Esq. pursuant to 28 U.S.C. 1927`1 (pl) (Entered: 01/31/1996)
02/01/1996	16	REPLY by Mary Ruth Wright to [13-1] counter claim ; by attorney Susan R. Ritz for counter-defendant Mary Ruth Wright (kw) (Entered: 02/02/1996)
02/06/1996	17	Transcript of record of proceedings filed for dates of 12/15/95 (cd) (Entered: 02/06/1996)
03/21/1996	19	NOTICE by Elser & Dicker, Glenn Fuerth, Mark Anesh to take deposition of Mary Wright on 4/22/96; subpoena(s) issued. (emil) (Entered: 03/25/1996)
06/27/1996	20	Order referring action to the Clerk to assign the above-entitled action to mediation, all issues are eligible...SO ORDERED... ( signed by Judge Miriam G. Cedarbaum ) (ls) (Entered: 06/28/1996)
07/30/1996	21	Notice of selection of mediator. (sc) (Entered: 07/30/1996)
08/08/1996	22	Letter filed to Judge Cedrbuam from Susan Ritz dated 12/19/95 re reply memorandum (djc) (Entered: 08/08/1996)
08/08/1996	23	AFFIRMATION in opposition of Susan Ritz Re: [7-2] motion to dismiss the second , fourth, fifth, sixth and seventh for relief in the first amended complaint pursuant to 12(b)(1) (djc) (Entered: 08/08/1996)
08/08/1996	24	MEMORANDUM OPINION AND ORDER # 77100 granting [14-1] motion for assessing sanctions against The Harmon firm; James Harmon, Jr., Esq.; Wilson Elser Moskowitz Edelman & Dicker; Glenn fuerth; and Mark Anesh prusuant to f.R.C.P. 11 and sanctions against James Harmon, Jr. Esq. pursuant to 28 U.S.C. 1927`1 ( Signed by Judge Miriam G. Cedarbaum ); (ae) (Entered: 08/09/1996)
08/22/1996	25	STIPULATION and ORDER, that the time within which the defendants, James D. Harmon, Jr. and the Harmon Firm have to serve a motion to reargue this Court's Order dated August 7, 1996 directing that sanctions be imposed on the defendants and their atty is hereby extended, subject to to this Court's approval, and IT IS FURTHER STIPULATED that such motion to reargue shall be served no later than on August 30, 1996 (signed by Judge Miriam G. Cedarbaum). (djc) (Entered: 08/22/1996)
08/22/1996	26	CONFIDENTIALITY STIPULATION and ORDER, between all the parties, either party may designate testimony & documents, of an kind or description as containing privileged and confidential etc. (see doc.) ( signed by Judge Miriam G. Cedarbaum ). (lam) (Entered: 08/22/1996)
08/30/1996	27	NOTICE OF MOTION by Elser & Dicker, Glenn Fuerth, Mark Anesh for reargument of [24-1] this Court's Order imposing sactions. Return date 9/30/96. (ae) (Entered: 09/04/1996)
08/30/1996	27	AFFIDAVIT of James D. Harmon, Jr. by Elser & Dicker, Glenn Fuerth, Mark Anesh in support of Re: [27-1] motion for reargument of [24-1] this Court's Order imposing sactions. (ae) (Entered: 09/04/1996)
08/30/1996	28	MEMORANDUM by Elser & Dicker, Glenn Fuerth, Mark Anesh in support of [27-1] motion for reargument of [24-1] this Court's Order imposing sactions. (ae) (Entered: 09/04/1996)
09/05/1996	30	Amended Affidavit of service of Susan D. Ritz, Esq. of motion to reargue and for permission to file out of time by U.S. Postal Service on 9/3/96. Service not executed on 8/30/96 due to Labor Day Holiday..... (pl) (Entered: 09/10/1996)
09/06/1996	29	Transcript of record of proceedings filed for dates of 12/15/96 (cd) (Entered: 09/06/1996)
10/02/1996	31	ORDER denying [27-1] motion for reargument of [24-1] this Court's Order imposing sactions. ( signed by Judge Miriam G. Cedarbaum ); Copies mailed (cd) (Entered: 10/03/1996)
10/30/1996	32	STIPULATION OF DISMISSAL; that the above-entitled action and counterclaims are hereby dismissed voluntarily w/prejudice and w/o costs ot attorneys' fees to either party. (signed by Judge Miriam G. Cedarbaum ) (kg) (Entered: 10/30/1996)
10/30/1996		Case closed (kg) (Entered: 10/30/1996)

RULE 11. SIGNING PLEADINGS, MOTIONS, AND OTHER PAPERS; REPRESENTATIONS TO THE COURT; SANCTIONS

(a) Signature. Every pleading, written motion, and other paper must be signed by at least one attorney of record in the attorney's name—or by a party personally if the party is unrepresented. The paper must state the signer's address, e-mail address, and telephone number. Unless a rule or statute specifically states otherwise, a pleading need not be verified or accompanied by an affidavit. The court must strike an unsigned paper unless the omission is promptly corrected after being called to the attorney's or party's attention.

(b) Representations to the Court. By presenting to the court a pleading, written motion, or other paper—whether by signing, filing, submitting, or later advocating it—an attorney or unrepresented party certifies that to the best of the person's knowledge, information, and belief, formed after an inquiry reasonable under the circumstances:

(1) it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation;

(2) the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law;

(3) the factual contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery; and

(4) the denials of factual contentions are warranted on the evidence or, if specifically so identified, are reasonably based on belief or a lack of information.

(c) Sanctions.

(1) In General. If, after notice and a reasonable opportunity to respond, the court determines that Rule 11(b) has been violated, the court may impose an appropriate sanction on any attorney, law firm, or party that violated the rule or is responsible for the violation. Absent exceptional circumstances, a law firm must be held jointly responsible for a violation committed by its partner, associate, or employee.

(2) Motion for Sanctions. A motion for sanctions must be made separately from any other motion and must describe the specific conduct that allegedly violates Rule 11(b). The motion must be served under Rule 5, but it must not be filed or be presented to the court if the challenged paper, claim, defense, contention, or denial is withdrawn or appropriately corrected within 21 days after service or within another time the court sets. If warranted, the court may award to the prevailing party the reasonable expenses, including attorney's fees, incurred for the motion.

(3) On the Court's Initiative. On its own, the court may order an attorney, law firm, or party to show cause why conduct specifically described in the order has not violatedRule 11(b).

(4) Nature of a Sanction. A sanction imposed under this rule must be limited to what suffices to deter repetition of the conduct or comparable conduct by others similarly situated. The sanction may include nonmonetary directives; an order to pay a penalty into court; or, if imposed on motion and warranted for effective deterrence, an order directing payment to the movant of part or all of the reasonable attorney's fees and other expenses directly resulting from the violation.

(5) Limitations on Monetary Sanctions. The court must not impose a monetary sanction:

(A) against a represented party for violating Rule 11(b)(2); or

(B) on its own, unless it issued the show-cause order under Rule 11(c)(3) before voluntary dismissal or settlement of the claims made by or against the party that is, or whose attorneys are, to be sanctioned.

(6) Requirements for an Order. An order imposing a sanction must describe the sanctioned conduct and explain the basis for the sanction.

(d) Inapplicability to Discovery. This rule does not apply to disclosures and discovery requests, responses, objections, and motions under Rules 26 through 37.

Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the California Department of Fish and Game and the USDA. Mary Cummins is also a licensed real estate appraiser in Los Angeles, California.

• Mary Cummins LinkedIn
• Mary Cummins Meet up
• Animal Advocates custom Facebook name
• Mary Cummins Real Estate blog
• Animal Advocates on Google maps
• Mary Cummins of Animal Advocates
• Mary Cummins biography resume short
• Mary Cummins Real Estate Services
• Animal Advocates fan page at Facebook.com
• Mary Cummins Animal Advocates Squirrel Rescue
• Mary Cummins Animal Advocates on Flickr photos
• Mary Cummins Animal Advocates on Twitter.com
• Mary Cummins on Picasa web photo albums
• Mary Cummins on MySpace.com
• Mary Cummins on Google Blogger Blogspot
• Mary Cummins on YouTube.com videos
• Mary Cummins of Animal Advocates on Classmates
• Mary Cummins of Animal Advocates on Google+

Google+