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Last-Minute Filings from Judge Stewart, SCO, Novell
Monday, March 08 2010 @ 04:45 PM EST

My, if we think we're having trouble keeping up, how'd you like to be Judge Ted Stewart? Or Sterling Brennan, for that matter? So many filings already, and more today. Proposed exhibit and witness lists, a Memorandum of Authorities Regarding Excusing Potential Jurors Having Knowledge Pertaining to this Dispute -- the one I'm going to read first -- and another responding to SCO's Objection to Board Minutes and a letter from Brennan to the court. And then one more motion in limine denied. Judge Stewart has denied Novell's motion asking for a further, and broader, ruling on its already successful motion in limine #4. He views is as rearguing a point Novell lost already in the denied Request for Judicial Notice of Prior Factual Findings, and he's not going to change his mind. Of course, that's what appeals are for. And now Novell is fully positioned.

Here they are:

03/07/2010 - 776 - Memorandum of Authorities Regarding Excusing Potential Jurors Having Knowledge Pertaining to This Dispute filed by Counter Claimant Novell, Inc., Defendant Novell, Inc.. (Brennan, Sterling) (Entered: 03/07/2010)

03/08/2010 - 777 - Proposed Exhibit List by Plaintiff SCO Group.. (Hatch, Brent) (Entered: 03/08/2010)

03/08/2010 - 778 - Proposed Witness List (Will Call) by SCO Group. (Hatch, Brent) (Entered: 03/08/2010)

03/08/2010 - 779 - Proposed Witness List (May Call) by SCO Group. (Hatch, Brent) (Entered: 03/08/2010)

03/08/2010 - 780 - Proposed Witness List (Depositions) by SCO Group. (Hatch, Brent) (Entered: 03/08/2010)

03/08/2010 - 781 - MEMORANDUM DECISION denying 775 Motion in Limine. Signed by Judge Ted Stewart on 03/08/2010. (asp) (Entered: 03/08/2010)

03/08/2010 - 782 - DOCUMENTS LODGED consisting of Letter from Sterling A. Brennan. (asp) (Entered: 03/08/2010)

03/08/2010 - 783 - Memorandum of Point and Authorities Responding to SCO's Objection to Board Meeting Minutes filed by Defendant Novell, Inc.. (Brennan, Sterling) (Entered: 03/08/2010)

Here's a bit of Judge Stewart's reasoning about why he doesn't agree that Novell's law of the case argument is correct:
Defendantís law of the case argument fairs no better. The cases cited by Defendant in support of its argument address the issue of collateral estoppel. Collateral estoppel will bar a claim if four elements are met:
(1) the issue previously decided is identical with the one presented in the action in question, (2) the prior action has been finally adjudicated on the merits, (3) the party against whom the doctrine is invoked was a party or in privity with a party to the prior adjudication, and (4) the party against whom the doctrine is raised had a full and fair opportunity to litigate the issue in the prior action.
Here, the first element is not met because the issue previously decided is not identical to the issue in the action in question. As indicated, the ruling upon which Defendant relies dealt with unfair competition and breach of the implied covenant of good faith and fair dealing, it did not concern Plaintiffís slander of title claim. Therefore, Defendantís collateral estoppel claim fails.
He cites Moss v. Kopp, 559 F.3d 1155, 1161 (10th Cir. 2009). I wonder if that's the case he meant. It was a case about judicial immunity, as best I can see. A bit comical he's reading up on that. I think he means another case, Dodge v. Cotter, which is quoted in Amigos Bravos -- a ruling written by Justice Lucero, one of the judges who handled SCO's appeal, and note what it says just before the part Judge Stewart quoted:
We review de novo a district court's determination that collateral estoppel bars a plaintiff's claims. See Dodge v. Cotter Corp., 203 F.3d 1190, 1197 (10th Cir. 2000). Under the doctrine of collateral estoppel, "once a court has decided an issue of fact or law necessary to its judgment, that decision may preclude relitigation of the issue in a suit on a different cause of action involving a party to the first case." Ag Servs. of Am., Inc. v. Nielsen, 231 F.3d 726, 732 (10th Cir. 2000) (quotations and citations omitted). As applied in the Tenth Circuit, the elements of collateral estoppel are:
(1) the issue previously decided is identical with the one presented in the action in question, (2) the prior action has been finally adjudicated on the merits, (3) the party against whom the doctrine is invoked was a party, or in privity with a party, to the prior adjudication, and (4) the party against whom the doctrine is raised had a full and fair opportunity to litigate the issue in the prior action.
That's Dodge, 203 F.3d at 1198. So I read it that the issue must be the same, and the parties, but not the cause of action. And here's what the issue is that was decided on summary judgment by Judge Dale Kimball:
This matter is before the Court on Defendantís Motion for Further Ruling on its Motion in Limine No. 4. In its Motion in Limine No. 4, Defendant sought to preclude Plaintiff from contesting that Defendant had an objectively reasonable, good faith basis for its statements regarding copyright ownership. Defendantís Motion was based on the Courtís summary judgment ruling wherein the Court held, in relation to Plaintiffís unfair competition and breach of the implied covenant of good faith and fair dealing claims, that Defendant had an objectively reasonable, good faith basis for its statements regarding copyright ownership. The Court granted Defendantís Motion in Limine No. 4 to the extent that it sought to preclude Plaintiff from pursuing the copyright ownership portion of its breach of the implied covenant of good faith and fair dealing claims. Defendantís current Motion seeks to clarify that Plaintiff should not be 1 allowed to contest, as to any claim, that Defendant had an objectively reasonable, good faith basis for its statements regarding copyright ownership.
Here, Judge Stewart is citing the difference being a difference in causes of action. Now, I hasten to add, I'm just a paralegal, and he's a judge, so he's more likely to be right. But I don't quite see the hair he is splitting. If Novell had a good faith basis for stating it thought it owned the copyrights, how can it not have a good faith basis for stating it thought it owned the copyrights in every and all conceivable causes of action? The unchangeable issue is not the cause of action but the issue, the issue being, did Novell have a good faith basis for thinking it owned the copyrights? A child on the street with these facts in hand would say yes, obviously.

I'm just asking. Like I say, things are flying by really fast, so mistakes can happen and they do, but little by little they tend to get addressed. But here's another case that seems to draw the line at identical issue, not identical cause of action, Sack v. St. Frankcis Hospital:

Under the doctrine of collateral estoppel, "once a court has decided an issue of fact or law necessary to its judgment, that decision may preclude relitigation of the issue in a suit on a different cause of action involving a party to the first case." Murdock v. Ute Indian Tribe of Uintah and Ouray Reservation, 975 F.2d 683, 686 (10th Cir.) (quoting Allen v. McCurry, 449 U.S. 90, 94 (citation and footnote omitted)). In the Tenth Circuit collateral estoppel requires that the following four criteria be met:
"(1) the issue previously decided is identical with the one presented in the action in question, (2) the prior action has been finally adjudicated on the merits, (3) the party against whom the doctrine is invoked was a party or in privity with a party to the prior adjudication, and (4) the party against whom the doctrine is raised had a full and fair opportunity to litigate the issue in the prior action."
Id. at 687 (citations omitted).
I hasten to mention that I'm working only with cases that are available online for free, so you can follow along, and if one were really working on the case, you'd have to do things differently, checking to make sure the case is still good law, and I'm not doing that because for our purposes, it's enough to show that my question is at least a reasonable one. And finally there can be elements to various causes of action, whereby it is conceivable that you'd be fine on meeting all the elements in one cause of action but not another. So with all those disclaimers, I suggest you read Dodge v. Cotter, because it will give you the clearest picture of that they are discussing. It was also about a dispute on what the jury should be allowed to hear, and here's what happened in that case:
After hearing the arguments, the court ruled the "pure issue of negligence" had been decided and would not be relitigated, emphasizing the ruling did not affect liability, proximate cause, the negligence of another party, or willful and wanton conduct, all of which "certainly is going to be litigated." At the close of five weeks of trial in Dodge, the court then instructed the jury,
The Court already has determined that defendant was negligent. The Court's determination that the defendant was negligent must not influence you in determining any of the remaining issues in this case. As you will be instructed further at the end of this case, a finding of negligence is not a finding of liability. You must still determine whether defendant's negligence caused any of the injuries or damages alleged by plaintiffs, whether defendant's conduct constituted gross negligence, and other issues that will affect the liability, if any, of the defendant.
That's pretty much what Novell is asking for, no more.

Update: I came across another case that cites Moss regarding collateral estoppel, so maybe he did mean this case, but notice what the decision in Gibson v. Campbell, another 10th Circuit case from October of 2009, says:

As a general rule, a litigant is prohibited from bringing a claim that has already been decided in a prior case by the twin doctrines of preclusion: res judicata and collateral estoppel. See San Remo Hotel, L.P. v. City and County of San Francisco, Cal., 545 U.S. 323, 336-37 (2005). However, for preclusion to apply, the litigant must seek to litigate either the same claim, see, e.g., Lewis v. Circuit City Stores, Inc., 500 F.3d 1140, 1147 (10th Cir. 2007), or the same issue, see, e.g., Union Telephone Co. v. Qwest Corp., 495 F.3d 1187, 1195 (10th Cir. 2007), that was decided in the prior proceeding. Further, res judicata may also bar a litigant from bringing a claim that was not-but could have been-brought in a prior proceeding that generated a final, valid judgment on the merits. See Pelt v. Utah, 539 F.3d 1271, 1281 (10th Cir. 2008). Finally, in order to preclude relitigation of a particular issue under collateral estoppel, the prior determination of that issue must have been necessary to the judgment. See Moss v. Kopp, 559 F.3d 1155, 1161 (10th Cir. 2009).
Emphasis added. So according to this, it's either or, either the same issue or the same claim.

  


Last-Minute Filings from Judge Stewart, SCO, Novell | 205 comments | Create New Account
Comments belong to whoever posts them. Please notify us of inappropriate comments.
Corrections Thread
Authored by: bugstomper on Monday, March 08 2010 @ 04:54 PM EST
Corrections here, summary in the title as error->correction or
s/error/correction/

[ Reply to This | # ]

Off Topic threads
Authored by: bugstomper on Monday, March 08 2010 @ 04:55 PM EST
Please stay off topic and on clicky

[ Reply to This | # ]

News Picks Thread
Authored by: bugstomper on Monday, March 08 2010 @ 04:56 PM EST
Please put the title of the News Pick article in the title of your post and use
HTML clickable links

[ Reply to This | # ]

COMES goes here
Authored by: bugstomper on Monday, March 08 2010 @ 04:58 PM EST
If you have any more COMES transcriptions please post them here using HTML
markup but posted as Plain Old Text to make it easy for PJ to copy and paste.

[ Reply to This | # ]

Last-Minute Filings from Judge Stewart, SCO, Novell
Authored by: Tufty on Monday, March 08 2010 @ 04:58 PM EST
Well, they had wanted more time to prepare a complex case.


---
Linux powered squirrel.

[ Reply to This | # ]

Petition for a writ of certiorari filed. (Response due April 7, 2010)
Authored by: Anonymous on Monday, March 08 2010 @ 05:06 PM EST
http://origin.www.supremecourtus.gov/docket/09-1061.htm

Not making this clicky, as PJ has asked before for everyone not to click it. No
real information beyond the title of this post.

[ Reply to This | # ]

Even in the pre-trial fileings...
Authored by: Anonymous on Monday, March 08 2010 @ 05:18 PM EST
I can see grounds for appeal.

[ Reply to This | # ]

Last-Minute Filings from Judge Stewart, SCO, Novell
Authored by: Anonymous on Monday, March 08 2010 @ 05:27 PM EST
If Judge Stewart leaves Novell this much room for appeal, the appeals process
will surely drag on until SCO cannot continue to pay salaries and wages.

[ Reply to This | # ]

783 - Memorandum of Point and Authorities Responding to SCO's Objection to Board Meeting Minutes
Authored by: bugstomper on Monday, March 08 2010 @ 05:32 PM EST
Here it is as HTML to make it easy to read. I'll post it in HTML markup as Plain Old Text as a reply to this to make it easy for PJ to copy and paste.

NOVELL'S MEMORANDUM OF POINTS AND AUTHORITIES RESPONDING TO SCO'S OBJECTION TO BOARD MEETING MINUTES

I. INTRODUCTION
SCO objects to the introduction of minutes of a meeting of Novell' s Board of Directors that state, in pertinent part:

Then, upon motion duly made, seconded, and unanimously carried, the following recitations, and resolutions were adopted:

RESOLVED: ... [∂] ... [∂] Novell will retain all of its patents, copyrights and trademarks (except for the trademarks UNIX and UnixWare) ...

According to SCO, the minutes constitute inadmissible hearsay within hearsay. As explained below, SCO is wrong.

II. ARGUMENT
First, "minutes themselves plainly are admissible as a business record under Rule 803(6)." Major League Baseball v. Salvino, 542 F.3d 290, 314 (2d Cir. 2008). As explained by one of SCO's own authorities,

Meeting minutes may fall under the hearsay exception in Rule 803(6) of the Federal Rules of Civil Procedure for records of regularly conducted activities, if the document is authenticated "by the testimony of the custodian or other qualified witness." Fed.R.Evid. 803(6); Lloyd v. Profl Realty Servs., Inc., 734 F.2d 1428, 1433 (lIth Cir. 1984).
Bookworld Trade v. Daughters of St. Paul, 532 F. Supp. 2d 1350, 1354 (M.D. Fla. 2007). The only reason Bookworld Trade held the minutes there under consideration inadmissible was the proponent of the evidence did not "propose[] a 'qualified witness'" to authenticate the minutes "and the identity of the author of the minutes is not apparent from the document." Id at 1355. Here, by contrast, Novell has proposed two qualified witnesses to authenticate the minutes: Mr. Frankenberg, identified on the face of the document as the presiding officer of the meeting; and Mr. Bradford, identified on the face of the document as its author. Thus the minutes are admissible to prove that at the meeting, "upon motion duly made, seconded, and unanimously carried," it was "RESOLVED" that Novell would enter into a transaction whereby "Novell will

1

retain all of its patents, copyrights and trademarks (except for the trademarks UNIX and UnixWare )."

Second, there is no nested hearsay problem because Novell is not offering the minutes as (direct) evidence that Novell did retain the copyrights. Rather, Novell is offering the minutes as evidence of(l) what Novell's Board approved and (2) what Novell's intent was in entering into the transaction. With regard to the former, the 1972 Advisory Committee notes to Federal Rule of Evidence 801(c) explain:

If the significance of an offered statement lies solely in the fact that it was made, no issue is raised as to the truth of anything asserted, and the statement is not hearsay. ... The effect is to exclude from hearsay the entire category of "verbal acts" ... in which the statement itself affects the legal rights of the parties or is a circumstance bearing on conduct affecting their rights.
The resolution of Novell's Board was a verbal act, not subject to exclusion by the hearsay rule. With regard to the latter purpose, Federal Rule of Evidence 803 expressly provides:
The following are not excluded by the hearsay rule, even though the declarant is available as a witness: ... (3) A statement of the declarant's then-existing state of mind ... (such as intent ... ) ...
Third, the other two cases cited by SCO are, likeBookworld Trade, inapposite. In Simmons Foods v. Capital City Bank, 58 Fed. Appx. 450, 453 (10th Cir. 2003), the statement "Per Randy Hart, Jeff Willis advised Brock Snyder ... " was characterized as hearsay within hearsay. Here, by contrast, Novell is not offering the minutes to prove that events transpiring outside of the meeting occurred, because they were reported in the meeting; but only to prove what happened in the meeting itself.

Similarly, in New York ex rei. Spitzer v. St. Francis Hospital, 94 F. Supp. 2d 399,404 n. 2 (S.D.N.Y. 2000), "[d]efendants ... cite[d] minutes prepared by defendants of meetings between the hospitals and the DOH which report that division of services between the hospitals was discussed." The court concluded: "to the extent that these minutes record defendants' own

2

statements, they are self-serving hearsay and can be accorded no weight." Id. There is no further information available in the opinion, but from what is stated, it appears that--as in Simmons Foods--the defendants were offering the minutes to prove the truth of statements reported in the minutes. That is not the case, here. Here, Novell is offering the minutes as proof of what its Board approved and intended.

III. CONCLUSION
The proffered minutes "plainly are admissible as a business record under Rule 803(6)," Major League Baseball, 542 F.3d at 314, to prove that at the meeting the resolution was presented and adopted; and the introduction of those minutes for the non-hearsay purposes of establishing (1) what Novell's Board approved and (2) its intent in entering into the transaction presents no nested hearsay problem.

DATED: March 8,2010

Respectfully submitted,
By: /s/ Sterling A. Brennan
WORKMAN NYDEGGER

MORRISON & FOERSTER LLP

Attorneys for Defendant and
Counterclaim-Plaintiff Novell, Inc.

[ Reply to This | # ]

Last-Minute Filings from Judge Stewart, SCO, Novell
Authored by: Leg on Monday, March 08 2010 @ 05:36 PM EST
Frankly, I don't think that the appeals court allowed for Judge Stewart to do
this...

[ Reply to This | # ]

Summary of 776 - Memorandum of Authorities Regarding Excusing Potential Jurors Having Knowledge
Authored by: bugstomper on Monday, March 08 2010 @ 05:54 PM EST
Here is my non-lawyer summary of what 776 says:

Novell discusses four classes of reasons for dismissing jurors: 1) bias in
general; 2) independent knowledge related to the issues at trial; 3) exposure to
prior media coverage; 4) preconceived opinions.

Novell cites cases for all of those that show that the standard for excluding a
potential juror for any of those reasons is that the person says that they
cannot set aside their bias or knowledge in order to decide a verdict based just
on the evidence presented to them in the trial. It is possible for the judge to
decide that such a juror cannot set aside their bias, but the standard for that
is high, such as if they have a financial interest in the outcome or if they are
an employee of a party to the lawsuit.

Specifically, Novell cites cases showing that jurors were accepted who had
knowledge of the subject of the trial through their profession, had been exposed
to media reports about the trial, and even already had an opinion about the
case, as long as the juror attested that they could put that aside to form a
verdict based only on evidence presented in trial.

It looks to me as if they want to preclude SCO from getting potential jurors
dismissed for cause just for knowing anything at all about linux, unix, or about
SCO vs Novell.

[ Reply to This | # ]

Novell Bleeding Employees?
Authored by: Anonymous on Monday, March 08 2010 @ 07:43 PM EST
Just had a friend at Novell (in Sales) leave the company. He said that there is
a lot of jumping off the ship talk going on internally due to the hedge fund
making a play for it. Says it isn't good. Hedge fund's don't run businesses.
They chop them up and sell the pieces. Lot's of concern going on there right
now. Makes me wonder that if the hedge fund is successful that it will likely
settle all lawsuits including SCO, Microsoft (WordPerfect) and others.

[ Reply to This | # ]

Why Judge Stewart might be splitting hairs
Authored by: jbb on Monday, March 08 2010 @ 08:25 PM EST
What if Judge Stewart is merely trying to ensure that the case goes to a jury and is not (effectively) decided by summary judgment? What would happen if Judge Stewart ruled that Novell had an "Objectively Reasonable, Good Faith Basis for its Statements Regarding Copyright Ownership" in SCO's slander of title claim? He has already granted Novell's MiL#2 and MiL#3 which require that SCO prove malice to win their SoT claim. Wouldn't that combination require Judge Stewart to find for Novell in SCO's SoT claim by summary judgment (if asked)? There would be no factual issues for the jury to decide because Judge Stewart would have ruled that SCO had to prove malice and he also would have ruled that Novell had no malice.

IM(IANAL)O the 10th Circuit remand contradicts itself. They want the copyright issue (and hence SCO's slander of title claim) to be decided by a jury but there were enough rulings in the remand and in Kimball's summary judgment (that were not overturned) to still find in favor of Novell via summary judgment even if the copyright ownership issue is undecided.

Therefore, if Judge Stewart doesn't unfairly rule against Novell on some issues, such as their exceedingly reasonable request that their lack of malice be recognized in SCO's SoT claim, then the need for a jury trial could disappear. Maybe Judge Stewart is trying to be as fair as possible without negating the need for a jury trial. Sure, by being unfair he is giving Novell ammunition for appeal. But they are only going to appeal if they lose. OTOH, if he essentially rules in Novell's favor from the bench, SCO will have plenty of ammunition to appeal if they lose. I think Novell is going to win and if SCO appeals, the 10th Circuit will deny the appeal with as little fanfare as possible.

---
You just can't win with DRM.

[ Reply to This | # ]

query: appeal time limits? and is this usual fed court behaviour?
Authored by: Anonymous on Monday, March 08 2010 @ 10:59 PM EST

just curious as to whether there's a time limit or decision point at which Novell is unable to include the In Limine decisions in any appeal (assuming the worst and the jury decides in opposition to Novell)?


Also, is it usual for a US Federal court to allow a complainant (such as SCO) to effectively expand an appeal into matters not directly raised in the appeal court decision?

My limited understanding of the Australian legal system is the appeals process whittles down matters for re-adjudication unless there has been a fundamental flaw in the original case - thus preserving the principal of economy of justice and avoiding double-jeopardy

[ Reply to This | # ]

Doctrine of Collateral Estoppel
Authored by: Anonymous on Tuesday, March 09 2010 @ 12:01 AM EST
Under the doctrine of collateral estoppel, "once a court has decided an issue of fact or law necessary to its judgment, that decision may preclude relitigation of the issue in a suit on a different cause of action involving a party to the first case."

Does this mean that if "someone" manages to walk off with the assets (under the loan deal, sale, liquidation, etc.), that he can't re-litigate the same issues against Novell (or its successor in interest) again? Novell would be "a party to the first case", and the quote doesn't appear to require both original parties to be involved.

Furthermore, would someone who acquired SCO's assets be a successor in interest, and therefor also effectively be "a party to the first case"? If so, would that not mean that once an issue is resolved in one of these cases, it is resolved once and for all even if the assets change hands?

That may not stop someone from trolling for small fry (such as Autozone) again, but if anyone is planning to resurrect the lawsuits from the ashes of SCOG, then how would this point affect him?

[ Reply to This | # ]

When ownership was established is irrelevant
Authored by: Anonymous on Tuesday, March 09 2010 @ 10:46 AM EST
If IBM buys the copyrights in question Scog is toast since you can't be found
guilty of infrindging your own copyrights regardless of when they became yours.


Note, that presumes that something in Linux infrindges which hasn't been proven
and likely won't be.

[ Reply to This | # ]

Question for PJ
Authored by: Anonymous on Tuesday, March 09 2010 @ 10:54 AM EST
Will you or Groklaw be testifying at this trial?

I thought I saw something about SCO does not want groklaw being mentioned during
the trial.

[ Reply to This | # ]

My plan for now
Authored by: inode_buddha on Tuesday, March 09 2010 @ 12:27 PM EST
My plan for the time being, is to simply hunker down and wait. It's completely
up to the judge and jury at this point. I'll check in once or twice a week
maybe. All along, I've figured that SCO would lose in several different ways,
but they wouldn't lose all at once. Meanwhile it sounds like PJ needs some rest
anyway.

---
-inode_buddha

"When we speak of free software,
we are referring to freedom, not price"
-- Richard M. Stallman

[ Reply to This | # ]

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