UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
Case no. 2:04-cv-03632 WMB-FMO
LAWRENCE HARVEY ZEIGER aka LARRY KING; CABLE NEWS NETWORK, LP, LLLP.; TURNER BROADCASTING SYSTEM, INC.;
Does 1 thru 10 INCLUSIVE
TRIAL BY JURY DEMANDED
VERIFIED COMPLAINT FOR DEFAMATION
ASSAULT, LIBEL AND SLANDER
Judge: Hon. William Matthew Byrne Jr.
COMES NOW Plaintiff, John Clark, appearing pro se, and respectfully states his (second amended) Complaint for Defamation against Defendants, Lawrence Harvey Zeiger, which was his birth name and is believed to be his legal name, now better known under the name believed to be possibly his alter ego Larry King (“Larry”); Cable News Network, LP, LLLP. (“CNN”), Turner Broadcasting System, Inc. (“TBS”); and does 1 thru 10.
This Complaint is asserted by Declaration, and is verified as to its truth.
THE PARTIES, JURISDICTION, VENUE, & SERVICE
1. I, John Clark, Plaintiff, was the spouse and manager of celebrity actress Lynn Redgrave (“Lynn”) for 32 years, and the father of our three children. I have resided in Los Angeles County since 1981, and currently reside in Hollywood, California. Lynn abandoned the marriage and the home in February 1999 and secured a divorce from me in December 2000. I am 71 years old, and have been a United States citizen since 1965. I am now remarried, and live only on my pension. I consider myself to be a “private person” and not a “celebrity,” as are my children, within the meaning of that phrase as it applies to the laws of libel.
2. Defendant Lawrence Harvey Zeiger aka Larry King, hereinafter referred to as Larry King (“Larry”), is believed to live and reside in Washington, D.C. He is the host inter alia of a television interview show, LARRY KING LIVE, the vehicle which carried the offensive material. He is regularly traveling away from his hometown, believed to be Washington, D.C. and broadcasts from various places around the world.
3. Defendant CABLE NEWS NETWORK, LP, LLLP. (“CNN”) has its main office, according to its website, at 1 CNN Center, 100 International Blvd., Atlanta, GA 30348. It is a “Limited Partnership, Limited Liability Limited Partnership.”
4. Defendant TURNER BROADCASTING SYSTEM, INC. “TBS” has its main office, according to its website, at 1 CNN Center, 100 International Blvd., Atlanta, GA 30348. TBS is a division, I believe, of the Time-Warner Corporation, or owned by them.
5. Defendants “Does 1 thru 10″ consist of the producers and miscellaneous support for the program LARRY KING LIVE. Their names and identities are not known at this time, but it is possible that my ex-wife may be a Doe, and that Time Warner may be a Doe, and they are not being pursued at this time.
6. The program “LARRY KING LIVE” is seen almost every evening, and I believe broadcast all over the world, and is often repeated. Furthermore, transcripts of the offensive material are published and remain available on the website of CNN. The program is carried by the facilities of CNN, which is owned and operated under the direction of TBS and possibly Time Warner, and possibly broadcast in foreign countries under license.
7. These parties are subject to the jurisdiction of this Court with proper venue. This is a Federal Question. [Fed. Ch. 28: 1331]. I live in the Central District, Western Division, of California.
8. Service of process is being perfected upon CNN and TBS by service upon their registered agent, CT Corporation, at their registered office, at 1201 Peachtree Street NE, Atlanta, GA 30361
9. Service of process is being attempted personally upon Larry King, who is slippery, for his attorney Mark Adam Barondess has told me that he would not accept service of process. Substitute service may have to be attempted.
CAUSES OF ACTION
10. This case is being brought for Defamation, Assault, Libel, Slander, and Interference of Judicial Processes, tortious acts performed upon me, stemming from the effects and results of a broadcast carried to millions of viewers in North America and I believe worldwide, with the cooperation of, under the direction of, and through the facilities of, CNN and TBS and possibly Time Warner on the LARRY KING LIVE television show, on the evening of May 22, 2003. No relationship existed between me and defendants, and there was no contract involved.
11. The acts of defendants alleged in this complaint are in the nature of a tort, and whether this was an intentional tort or a negligent tort will be decided by a jury when the facts are presented.
12. Defendants may claim 1st Amendment Rights of free speech and fair comment, freedom of the press and so forth. But this freedom is restricted as it applies to what has become known as an “all-news” channel. FCC regulations are required to allow REPLY time to individuals who have been personally attacked on the air under the fairness doctrine.
13. Title 47, Chapter 5, §558 (Criminal and Civil Liability), a provision of the United States Code, recognizes that Defendants, as cable programmers or cable operators, are subject to the provisions of and pursuant to “Federal, State, or local law of libel, slander, obscenity, incitement, invasions of privacy, false or misleading advertising, or other similar laws.” Plaintiff will show in court proceedings that defendants were in fact in violation of all or some of these laws.
14. I was denied Due Process and Equal Protection of the Law guaranteed by Article XIV, Section 1 of the United States Constitution, by the State of California. Defendants should have been aware of my battle with the State of California, and my past, current and future battles. By their offensive broadcast, they became an influence upon its outcome, thus interfering with my rights guaranteed by the Fourth Amendment.
15. Also violated were protections afforded me as a senior citizen under Title 42. The Public Health and Welfare Chapter 35. PROGRAMS FOR OLDER AMERICANS Subchapter I. DECLARATION OF OBJECTIVES AND DEFINITIONS § 3001, as well as local and state laws protecting me as a senior citizen.
16. The United States Constitution was created, as it says in its opening words, to “establish Justice, insure domestic Tranquility . . . . and secure the Blessings of Liberty to ourselves and our Posterity . . .” [Article 1, U.S. Constitution]. Defendants, in my case, have helped California Family Court to insure that I and my children get none.
DISCUSSION OF CASE
As Plaintiff, it is my hope that Defendants will be punished for their alleged offenses, and that they will take due care before someone else falls into their trap. And if by the efforts of their powerful lawyers I am unable to make my case, then at least, by this Complaint, I have no choice but to state the truth now so as to get the true story out, revealing that which Defendants should have discovered with minimal research, or did, and ignored or suppressed it. Shakespeare put it well, “…he that filches from me my good name….makes me poor indeed.”
Herein are the true story, and background, to the issues which will be presented for consideration by a jury, the sine qua non of this case. The jury will hear, view and review the evidence and decide whether these facts should have been known to Larry King and his producers at CNN and TBS.
They will learn what took place in the events of my life leading up to my being thrown out of our debt-free beloved home for 21 years, and escorted off the premises by armed police on September 13, 2001, onto the street, while I was still on the telephone inquiring as to the lives of three of my children who I knew were situated in New York City at the time of the 9/11 terrorist attacks and remained silent to me.
This event happened as a result of bizarre rulings sought and obtained by my wife from now retired Family Court Judge Arnold H. Gold, which caused me to investigate the judge from public record sources. Judge Gold’s breakdown of his own marriage, and the reasons behind his fighting for a divorce from his own wife for about five years back in the sixties shocks the conscience, and is revealed later in this document. Terrorism comes in many forms.
The circumstances of the breakup instigated by my wife with the aid of a Hollywood “Divorce Designer” attorney and leading up to this event are well documented in the continuing public records of the Los Angeles Family Court, four different Courts of Appeal, and the California Supreme Court.
I heard through a friend on the morning of May 22, 2003 that it was advertised that my ex-wife would be interviewed for an hour by Larry King that very evening.
Fearful of what she might say, and assuming from its title that the broadcast would be live, I walked down to CNN’s studios at 6430 Sunset Boulevard in Hollywood, a few blocks from my nearby home and presented myself to the staff there for the purpose of being included in the show which I had been on before, and particularly so that I could have some input and control over what my extremely hostile ex-wife might say or not say in the interview.
I had reason to worry at that time of her Larry King Live interview, and I have even more reason to worry at this time. I have just discovered that she and my photographer daughter have a book advertised on Amazon.com, not yet available, and ready to promote, that deals with her breast cancer.
In past years, I had met Larry on more than one occasion when I brought my wife to those same studios for purposes of promoting her, her career and to talk of our future projects, and I expected to be welcomed.
I was especially worried that things would be said that would have an adverse effect on the outcome of several Civil Court cases which were at that time before the California Court of Appeal, Second District, in Los Angeles, and also two Family Court cases still active even now before the Los Angeles Superior Court.
In the divorce case, case no. BD296320 filed by Lynn in March 1999, I still have to go back to show the court that I should be reimbursed for the costs of many thousands of dollars borne by me since she abandoned the family back in February 1999; and in a paternity case filed by my child’s mother, BF013155, I still have to go back to find out where the mother and her attorney are hiding my son, and to get visitation for him.
I had made oral argument before the Court of Appeal’s Division 1 in the Dissolution proceeding on April 22, 2003, just one month prior to the broadcast, and was awaiting a decision. I received news of the justices affirming the decision of the lower court on April 29, and on June 9, I filed for review by the California Supreme Court.
On the same day of the broadcast, an opinion came down from Division 3 in a separate Quiet Title action brought by the attorneys for me and Lynn working together, which was affirmed in our favor.
As for the two derivative cases that were currently before the California Court of Appeal, I have had to plead for dismissal of their review because of this defamatory broadcast.
Here in Footnote 1. I give the text of my Motion for Dismissal dated August 30, 2004, which was immediately granted for the reasons given and in the manner stated, [footnote 1]
CALIFORNIA COURT OF APPEAL Case No. B 165744; “JOHN CLARK, Plaintiff/Appellant vs. MELISSA OLIVER, EMILY EDELMAN, JAMES ELIASER, MICHAEL KATLEMAN, ALLYN KATLEMAN, COLDWELL BANKER REAL ESTATE CORPORATION, COLDWELL BANKER REAL ESTATE HOLDINGS, INC, COLDWELL BANKER RESIDENTIAL BROKERAGE COMPANY, COLDWELL BANKER RESIDENTIAL REAL ESTATE, INC., STONERIDGE ESCROW CORPORATION and DOES 1-30 inclusive,
APPELLANT’S MOTION TO DISMISS,
I, John Clark declare
1. I am the Appellant. I am 71 years old. I am not an attorney.
2. I brought this Complaint against Defendants in Santa Monica Superior Court in April 2002.
3. The Complaint was for
A.BREACH OF FIDUCIARY DUTY
4. On September 6, 2002, I brought and declared in open court an Affidavit of Peremptory Challenge before Judge Paul G. Flynn under the code provisions of the CCP [§170.6(5)] which I also filed with the court.
5. I believe this was done properly, but it did not prevent Judge Flynn from making certain rulings and sanctions adverse to me, when I believe he no longer had the standing and power to do so, and out of my presence.
6. However, certain events have happened since that time which I believe has polluted this case, so that even if I were successful in my appeal and this court were to remand it back to the lower court, I believe I could not get a fair or meaningful trial.
7. In May of 2003, my ex-wife celebrity actress Lynn Redgrave (after a marriage lasting 32 years), post divorce, gave an interview to Larry King where, throughout his one hour “Larry King Live” show on CNN (“All The News You Can Trust”), my name and likeness, and that of my small child Zachary and his mother Nicolette, was plastered on the screen in a banner by Larry King and his producers, filled with innuendo and denigration of my character and reputation, and aired before millions throughout the world, while my court cases are still alive.
8. This interference of continuing judicial processes and its effect upon me and my ability to make a living in film and theatre in my professional capacity as a long
time member of the Directors Guild of America, The Society of Stage Directors and Choreographers, the Screen Actors Guild, the American Federation of Television and Radio Artists and Actors Equity has caused me to file a lawsuit against Mr. King and CNN in Federal District Court for liability for Defamation and related issues [case
been illegal activity by Respondents and other persons and organizations, particularly those involved in real estate deals, yet to be proved but unable to be proved in the California State Civil Court system, leading to the loss of more than two million dollars of my family’s and especially my children’s and grand-children’s savings and family estate, and I believe there may have been violations of US Code Title 18, Part 1, ch. 96, § 1961-68 (Racketeer Influenced and Corrupt Organizations act). Judge Flynn in my civil case before the Santa Monica court would not allow me to pursue defendants and conduct discovery and depositions in order to investigate what happened to bring about these horrendous losses to my family’s investments, and also the theft of several hundred thousand dollars worth of my family’s possessions.
10. That was 2001/2. This is 2004/5. My family and American society has changed. Now we both need to know.
11. Therefore, I respectfully request that this honorable court dismiss my appeal in this case, and that it be on record that this was done at my (at appellant’s) request.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and was executed this 30th day of August, 2004, at Los Angeles, California. (Signed) John Clark, Appellant [end of fn 1]
On arrival early in the afternoon on May 22, 2003 at the CNN studios, I was told to use the telephone on the ground floor to state my business, which I did. I then took the elevator to their floor, where I was told by security to wait outside. Eventually a Mr. Hunter Waters (“Waters”), an employee of TBS, appeared. He stated that it would be impossible for me to appear on the show, because it had been pre-taped on the East Coast believed to be in Washington, D.C. about three weeks previously.
I asked for, and received, Water’s e-mail address, and thereupon walked home and immediately composed and sent the following e-mail to Waters, which I quote verbatim:
“Thursday, May 22, 2003
I shall be watching tonight with a great deal of interest. Regardless of what I see, I can’t help wondering why you did not attampt [sic] to contact me. My input would have made for a better and more balanced show.
Are you aware that all of her career development through the last 32 years culminating in her Golden Globe award and Academy recognition was designed by me? Are you aware of her own 26 year affair with Brandon Maggart since 1977, by whom she got pregnant? Her affair with Brian Dennehy? I may have to ask for equal time. Anyway, I expect you will be hearing from me again. I live just down the road in the Hollywood Hills, on San Marco Drive. You can check me out on IMDb, from Lynn Redgrave’s site.
The attachment lets you know that once upon a time, my visibility was greater than hers. [There followed several picture attachments]
“A long long time ago. And here’s a shot of my last sight of Lynn, giving orders to try to get me arrested when I went back to our Topanga Canyon home to retrieve my possessions after she got me evicted 2 days after 9/11. There she is back with Brandon Maggart and his goon sons and the real estate agents. And one of his sons knocked me to the ground. The police are on their way, but refused to help me after talking with her. There’s a lot you can learn about me, this is just a hint, you missed the big story! But I’ll know just how much, later tonight. And I expect you’ll hear from me again.
[There were 6 files attached to this e-mail, being digital photographs of Redgrave together with agents of Coldwell Banker who in court recommended Plaintiff's eviction, her boyfriend Brandon Maggart and his 2 sons, Spencer Brandon Maggart and Garrett Maggart.
Brandon Maggart's face is covered by a video camera successfully preventing Plaintiff's recognition of him, but Plaintiff had never met and was unaware of the identities of the 2 younger sons, who Redgrave, having secured possession of the house, had put in charge of Plaintiff's house and home.
His job was to keep Plaintiff away, and prevent him from collecting his belongings. One of the pictures depicts the moment before Plaintiff was assaulted by Spencer.
Plaintiff called the police, and 2 officers arrived. They did not file a police report after they spoke with Redgrave. At the station-house, officers refused to accept an assault charge.
Another attachment was a video news clip from the web-based archives of Pathé Pictorial in the United Kingdom, a file that showed Plaintiff at that time was a big child star in London entertaining U.S. and British troops in the closing stages of World War II. On May 4, 1945, he was asked to perform for the King and Queen and the two princesses, at a private function of celebration immediately preceding VE Day]
That evening, May 22 2003, I sat and watched and taped the broadcast, which purported to be a discussion of Lynn’s treatment of her breast cancer. I had and still have no problem with this theme, for it is a matter of great public concern.
The broadcast, however, became something else. Defendants, including Larry King and the producers of Larry King Live, had created an elaborately planned and scripted show which sought to reveal that Redgrave somehow is surviving her illness, the implication being that this is because of, or in spite of, the stress caused by the behavior of her husband which drove her to psychiatrists and so on. It is a well-known fact that stress can contribute to the onset of the disease.
The truth however is much different, and is a truth that I, not just a husband and manager, but also a father, have always sought to keep private, not just because of my children’s safety and privacy, but also because it involved our family’s, including Lynn’s and our son’s, green card scam, which is a federal offense. I have since discovered that the Immigration and Naturalization Service is not proceeding against phony marriages after the passage of two years of time, and will not now prosecute.
The Larry King Live interview, about one hour in length with commercials, had the following elements:
After each commercial, at least three times, the network’s logo appears “CNN – NEWS YOU CAN TRUST” before starting the next part of the interview.
Remaining on the bottom of the screen at all times, there is a descriptive caption, the wording slightly changed for each segment.
The program proceeded as follows:
Throughout the one hour interview, the captions at the bottom of the screen changed between the following versions, which is not revealed in the written transcript (to this day still available on CNN and Larry King’s website). They all read “LYNN REDGRAVE TELLS ALL.” and then
Caption #1 “ON HER SHOCKING DIVORCE, HER FAMILY AND CAREER.”
Caption #2 “IN 1998 HER HUSBAND ADMITTED FATHERING LOVE CHILD.”
Caption #3. “LYNN REDGRAVE TELLS ALL, HER HUSBAND FATHERED A BOY W/HIS THEN ASSISTANT IN 1991″.
At this point the camera zooms in on a National Enquirer headline and various pictures of Plaintiff, Redgrave and Nicolette, the boy’s mother.
The boy Zachary is also identifiable (he was then about seven years old.)
The caption changes to “HER HUSBAND’S OTHER WOMAN LATER WED AND DIVORCED THEIR SON.”
And caption #6 read “DIVORCED HUSBAND IN 2000 AFTER 33 YEARS OF MARRIAGE.”
Larry King ends his interview looking into Lynn’s eyes with the heartfelt words “You are a survivor.”
After the broadcast, I sent the following email to CNN headquarters on their website, again quoted verbatim:
“I am Lynn Redgrave’s ex husband of 32 years. I am also a director and actor, and you can check me out on IMDb [International Movie Data base IMDb.com], and I’m older than Larry King.
I have already spoken to Hunter about this. Your taping of the Lynn Redgrave interview on May 22, commenting on our divorce with slanderous comment on me without having the courtesy, indeed the ethical and legal requirement, to get input and corroboration first from me is despicable.
I have always respected and have even been interviewed (with Lynn) by Larry, and I know him to be fair minded.
I can understand his avoiding controversy in a puff piece, I can understand he would not ask Lynn about her 25 year affair with actor Brandon Maggart by whom she got pregnant (later aborted), nor ask Lynn how much she paid her Jehovah’s Witness assistant to marry our son so that she could get a green card and the little boy could stay in this country (yes, this is all in the court record which has been going on now for four years) nor ask about her love affair with Brian Dennehy (which he admits to) [he corroborated this to the London Sunday Mirror, and they published that tidbit] but at the least, he could have asked simple, positive questions, like:
Do you have any kind words to say about your husband?
Do you feel you owe him something for the career you enjoy today?
Didn’t he help you put together, produce and direct your Tony nominated play “Shakespeare For My Father”?
As well as “Saint Joan” for Broadway?
Do you look toward healing of your family relationships, or have you decided to continue to ostracize him from his own family I understand he’s yet to meet his six grandchildren?
Why did you evict him from his home?
Are you punishing him?
It’s all very well for her to play the “No fair, I have cancer” victims’ game, but her shameless behavior today puts Joan Crawford in the shade. And your sensationalistic behaviour makes the National Enquirer (they never go to press without corroboration of their stories) look like the Washington Post.”
These messages were ignored. I believe they refused what was clearly my demand for correction by defendants, an opportunity for me or them to correct the record. I hoped for a subsequent interview, as is covered by Cal. Civ. Code §48a(2).
I believe that Defendants’ response will be based on the premise that they were telling and reporting on the truth, since that is the basis for a defense in libel.
If I am deemed to be a private person, I believe that Defendants will have the burden of proving that what they said was true, and whether the insinuations casting aspersions on my character and reputation were true.
In court I will show that the truth was always available in the public record, and that I will have to put that truth before the jury to prove that defendants are lying, and how I have been damaged.
As broadcasters on the public airwaves, and as a cable operator, under the law and FCC regulations, they have a duty to report the truth, or at least not to dispense lies and suggestive material to the detriment of a person’s reputation.
I believe that this is actual or de facto malice. I was held up to scorn, ridicule and contempt. My reputation was harmed with the result that persons in my community have been deterred from associating or dealing with me.
Defendants CNN and TBS have a legal department and a department of Standards & Practices set up to make sure they comply with the law.
One can assume that this time they thought they could get away with it, and that I would not take it upon myself to spend the remaining years of my life setting the record straight. To continue with the true story:
At a pre-trial Hearing the day before trial was due to start, Judge Gold said I was slow producing discovery, although my wife’s attorney agreed with the court that by then she had all she had asked for.
But Judge Gold set out to punish me anyway, and suggested I should spend the night in prison, unless I craved mercy in some way. I said I felt as Kafka might have felt. “I’ve done nothing wrong, you wouldn’t do that, and besides it’s my 68th birthday today!”.
I was led out of the courtroom in handcuffs immediately. My parting shot was “Well your Honor, we survived the Battle of Britain.”
It was the night before I was due to start my trial representing myself, “pro se”.
It was also the night Lynn raided my private office in the house, with its sign saying “Keep Out, War Room” which contained my trial preparation because she knew I would not be there. This account is not only in the court records, but was published as a headline in the Pasadena Star News a few days later.
I am a life member of New York’s famed Players Club of Anglo/American theatre in Gramercy Park where I helped to change the club’s policy of no female members, and arranged for my wife to become the first female President of the club. I am not now welcome at the club, partly because we saw irregularities over the handling of their priceless historical library and long dead actors’ Foundations under their control and tried to clean it up, resulting in the fact that the New York District Attorney has been watching them for a few years, and the club is now thriving (Lynn was ousted).
I am a member of the Pacific Pioneer Broadcasters club, and we hold a lunch each month at the Sportsman’s Lodge in Studio City. People turn away from me.
I am a longtime member of the Directors Guild of America. I am not deemed acceptable to serve on a committee.
I am a member of Hollywood’s Magic Castle. I am ignored by all except the help when I go there.
Lynn and Annabel have a book coming out next month, telling of her experiences having her breast removed with pictures taken by my daughter Annabel. It is titled “JOURNAL. A MOTHER AND DAUGHTER’S RECOVERY FROM BREAST CANCER.” by Lynn Redgrave and Annabel Clark.
We are told by Amazon.com that the book is not yet available, but will be coming out next month, in October. I believe that the New York Times owns the copyright in the pictures, which were published in their Sunday Magazine a while back, because picture credits stated “Copyright NY Times.”
It is now obvious to me that I have been set up as a promotional lure for the book marketing people to obtain talk show exposure.
I can see it now, Lynn and my daughter sitting with Katie Couric on the “Today Show”. They will need to say nothing about me at all, not even engage in that part, and Larry King and CNN’s work will be referenced by the interviewer.
I can imagine their sitting with Dan Rather on CBS 60 Minutes, or with any of the folks on “Entertainment Tonight”, who deliberately trashed me when the news of our breakup first came out, and set the tone.
Such is the power of celebrity in Hollywood.
But here I remind Defendants that they will be liable for every single utterance made by another broadcaster as a result of their defamatory treatment of me.
It is now more than five years since Lynn abandoned the marriage. I have been offered but turned away money for stories by all television and print media.
This true story is free. Public record.
MY (PLAINTIFF’S) BACKGROUND
I have been a professional actor since 1944, and married Lynn in 1967. We have three children, now all grown. I always considered our family to be a pillar of strength and stability, and unusual in the sense that we became well-known in the Hollywood community as activists for women’s rights, stemming from Lynn’s taking on Lew Wasserman’s Universal Studios in 1981 when she was fired from her successful series House Calls on CBS.
The issue then was whether a new mother and actress should be allowed to bring her baby to the lot to be able to breast-feed the baby between 6a.m. and going home late in the evening.
We started with Gloria Allred and wound up with the corrupt and later bankrupted New York Finley Kumble law firm, and the less said about them the better. It never got heard. But as a result, the studios now have child care centers where actresses can bring their babies to work.
We were married in Sidney Lumet’s living-room on April 2, 1967 after a whirlwind courtship. Pictures were taken for Life Magazine by Michael Crawford, and there was a Time Magazine cover picture of the two famous sisters.
I tried to continue my acting career, but unsuccessfully, and in 1972 I gave it up in support of Lynn, and so she became my career, at her bidding and wishes.
At that time, my first marriage had unexpectedly produced a son literally on our last day together, and was for years troubling because she refused to allow visitation with Jonathan.
They lived up in Canada, and Lynn was hugely supportive and appeared with me in family court up in Toronto on many occasions. I was forever grateful to Lynn for this.
After an eight year sojourn back in my old hometown of London and then Dublin, we moved to New York, where I wanted to turn her into an acting icon for America, to be perceived as a separate person from her sister Vanessa and her loathed left-leaning politics, and to be more available for Jonathan.
Because of my varied background in show-business and in the real world, it was easy for me to become her full time director, writer, drama teacher, coach, photographer, publicist, manager, negotiator and contract maker and paralegal. We had learned to distrust lawyers and agents too.
I was also very happily the family’s driver, pilot with two family planes, caretaker and maintenance man for our properties, horse feeder and general do-it-yourself head cook and bottle washer, while she was out and away making pictures and television series. And by all accepted standards I was good at it, and a great husband and father, and manager too, (although I have since learned that I should have spent more personal time in raising my kids).
I had a hand in every single one of her projects since 1968 to after her abandonment of me in 1999. Our son is now a pilot for Delta, one of our daughters is now a professional photographer shooting pictures for the New York Times, and our proud lesbian daughter Kelly is a teacher in London.
Prior to meeting my then wife in 1966, I had been a New York-based actor, a photographer and with some success a stock market technical analyst and investor, which became my hobby. I learned all about the technical approach to investing with the aid of charts.
We kept, and now she has, my co-op apartment in the historic “Osborne,” across from Carnegie Hall in New York, but because of long-term television series contracts and movie offers in Los Angeles, in 1981 I decided we should move our base to the West Coast, and so I found and created our 5-acre permanent home alongside the State Park in Topanga Canyon, fenced it around for privacy and security, bought two trained guard dogs, and rebuilt and designed it with the help of our old friend Trevor Williams, an award winning movie production designer.
At great cost, I built a custom designed swimming pool with waterfalls, and a Jack Kramer fake grass tennis court (I once played tennis at Wimbledon as a junior), a writing studio for my wife to write, a corral for my show-jumper wife and daughter’s horses, a tack room, garage space for four cars and parking for 40 cars (yes, we held great parties and social gatherings), an Extenderhoe Case backhoe, 2 twelve foot C-band satellite dishes, a website “redgrave.com” before anyone else was doing it, arranging for a web-designer to create her history on it, and a rehearsal studio where I and my wife could plan and create our future projects, and I could help her write her books.
Together we wrote “Shakespeare For My Father”, and her Weight-Watchers book, dedicated to me, “This Is Living”.
Her success was mine too, and because we had a stable marriage, I had made no effort to be on any of the copyrights.
I was happy to be the engine behind her work, and it was a combination that led to many awards and a lot of creative work.
This office space with 18 file cabinets of all of our history, her contracts, huge press clippings, and work, dating from 1963, kept all of the business away from the residence. It also housed my photographic equipment, for future use as a video and film studio.
I began to build a darkroom in the garden for our youngest daughter. I had installed an antique 12 x 6 foot English Burroughs & Watts slate billiard table, a present from my wife for she knew I had once been a boy’s billiards champion back home in England.
I bought a Chickering grand piano which I loved to play on, and helped to teach my children on this piano.
I had stored my photo equipment which included my three working Nikons, their multiple lenses, nine other professional still and video cameras and darkroom and recording equipment from my past part-time profession, for the time when my youngest daughter could use them responsibly – and now she can – except that all of my equipment was stolen from the house when my ex-wife took it over courtesy of Family Court Judge Arnold H. Gold.
I bought a Twin Comanche airplane so my son could get his multi-engine license and develop his passion for flying, and incidentally get out of the drug culture he showed signs of getting involved with as a student. I sent him away to the University of Colorado, and he straightened up.
And I kept company with my little son Zachary every single day of the year until he disappeared into the hands of our notorious Topanga Mexican plumber Ernesto who was married, as a result of the court action of Judge Gold, at the impressionable age of eight.
The so-called “scandal” retailed by the media with the blessing of my wife, was that Nicolette was falsely described as my mistress, that I impregnated her with a “love-child”, that my son married her and thought that the child was his while I kept her on as my secret mistress, or as a “piece of meat” as Nicolette informed the press.
The true story was as follows, again available in court records, but essential to recount here.
In 1990, I was on a business trip to London to secure rights to a television property controlled by the BBC starring Lynn, and which had won her the BBC award as the best TV actress of the year 1989 (“Death of a Son”). I wanted it to be seen in the USA, and bought the property to remake and edit it into a theatrical film with new music, which I did. I thought Lynn’s performance was Oscar material.
We had regularly kept in touch with our old Beverly Hills nanny, now Mrs. Adeline Procter in Palmers Green, who had helped with our children when we first moved to L.A. She was and still is an avid Jehovah’s Witness.
I called her from my hotel as I always did when in London, but this time she was in tears, her mother had just the day before dropped dead in the street from an embolism, and she couldn’t meet me. But she said her sister Nicolette Hannah worked as a consular assistant around the corner from my hotel at the Finnish Embassy, and she would drop by for a cup of tea and give me the details.
This she did, and what I found was a very distraught lady, with an extra reason to be. I learned that the Elders of the Jehovah’s Witnesses’ cult program had “disfellowshipped” her for reasons I won’t go into here, and under their strict rules this meant that she was ignored and isolated by her family and friends. Her only friend and life support had been her mother.
Our London daughter Kelly befriended her, and a few weeks later brought her to New York where Lynn and I were appearing on Broadway in “Love Letters” for a couple of weeks.
There, she lost her British passport when out with Kelly having lunch at Macy’s, her purse was stolen. Waiting for a replacement, she flew home to L.A. with us, because Lynn was contracted to do a play in La Jolla, near San Diego.
Nicky and I were left alone at the house, with Annabel still at school and Nicky soon to return to her home.
As a result of her huge depression and spiritual crisis and deep sense of guilt, I suggested to her that she should bear a child because a new life of her own would give her a reason for living.
I recalled Lynn and my appearance in a game show “Tattletales” telecast the week of January 18, 1982, with Bert Convy, Dick and Dolly Martin, and Steve Lawrence and Eydie Gormé.
In that show, we were asked whether I would provide sperm to a friend of my wife if asked, and would my wife object? I said given the right circumstances, certainly I would. I guessed right, Lynn when asked said she wouldn’t object too much, but there could be problems down the road. So she guessed right too. I still have that tape.
Yes, Nicky and I decided it was a sperm bank or me, and that was not a difficult choice. Together we decided that I should be the father, and I truly believe this saved her life.
The idea was that she should return to London when the baby was born, and there meet and marry some nice man, up to which time I would support the child. He need never know who his father was, and thus was born a romantic story.
I was with her at the birth in St. John’s Hospital in Santa Monica, the very same day I had to decline attending Jonathan’s wedding in Dublin, and the expectation was that she would go back to England when the baby was a few months old and her visitor’s visa expired.
The plan went awry when – we should have known – we all fell in love with the little boy, whom we had named Zachary John Hannah.
I do not think for one moment that people did not know I was the father, because we look alike, I had a Danish mother, meaning unusual looks for California. Just that it was never mentioned, and the boy called me Dad anyway.
He became part of our family, as did Nicky, and we all hoped she would find and marry a nice rich Jewish lawyer in Beverly Hills and also thereby get her green card and stick around, and meanwhile, Lynn and I set up a trust fund for him, and Nicky put my name in a written agreement that should anything happen to her, I would take custody, and Annabel was over the moon knowing that she had a little brother.
We paid for the child’s education and Nicky was paid a salary, she paid her taxes, and she helped the family run smoothly as my and Lynn’s assistant.
I invested her money, her inheritance from her mother, and made $36,000 profit for her in the stock market.
She lived nearby in a tiny cottage that we had bought for the use of our children as they got older, and from there she had her own life and boyfriends.
But when the boy was two years old, a nice Jewish lawyer it was not.
Instead I found that she had taken up with a friend of ours, Al Goldstein, publisher of New York’s Screw Magazine, and she told me she wanted to marry him and live in Florida.
I was aghast. But he wanted her, he told me, as his West Coast woman, to live in his Hollywood apartment with little Zachary.
He told me, and I have the evidence, that if I stood in his way, he would call the Enquirer and Lynn’s reputation would be ruined. So for a while Nicky got to go to the Mansion and drive his Porsche.
And that’s what can happen to the best laid plans. Thankfully I was able to convince Nicky that she should immediately stop seeing Goldstein because of his threats and what it would do to Lynn’s career, and so she did.
As it was obvious that a Green Card was the key to all of these problems, a plan was hatched by Lynn, Benjy, Nicolette, Annabel and me.
Our son Benjy married her, and he got motivated by the money she paid him which he needed to get out of his waiter career at California Pizza Kitchen and into his professional pilot licenses and a new career,(he is still a pilot for Delta – good luck!).
I have the video of their Vegas marriage, Lynn there, and me, and little Zachary, with the bride and groom, all smiles.
Some time after the marriage, Ben obtained an expedited U.S. citizenship so that he could get the green card for Nicolette.
As I show later, it is in the public record that Lynn went down with Ben to the INS, she signed autographs for the staff, and the green card was secured without further question. Hollywood privilege.
After the green card came in, they got a mail-order Dominican Republic divorce two years later, which may in fact threaten the validity of both of their new marriages, my son to a lawyer and Nicky to our plumber.
Nicolette had restarted the affair she began years before with Ernesto when I paid him to re-pipe the cottage where she lived, and court papers much much later show that she and the plumber forged a plot to take away from us our little cottage, a property worth about $300,000. They now claim to be married, and have disappeared with Zachary.
Now, finally, it’s time to reveal Lynn’s true story, the story which I took care to tell by filings available in court records among other sources.
While we had a long and successful partnership in marriage, the intimate side of it had faded many years before. Beginning back in 1977, Lynn began an affair with actor Brandon Maggart while they were both on the road with Jerry Lewis in “Hellzapoppin’”, and has maintained it ever since. I was appearing in a small part on Broadway in “Comedians” at that time, directed by Mike Nichols.
Shortly after, I was busy producing and directing Shaw’s Saint Joan, her dream part, to star Lynn on Broadway, and during rehearsal, Lynn had an abortion of a fetus that I had good reason to believe, because of the time factor, had not been put there by me.
I was not too bothered about the moral side of it, but I did ask her to consider what this would do to our impending production, to cancel or not to cancel. It was her decision to have the abortion.
It was our nanny at that time, Ada, an English girl now married and living in Brooklyn and available to give evidence, who observed Brandon Maggart visiting my wife’s bedroom after the show and staying all night.
She did not tell me of this until later when she left our employ. And in 1998, Lynn revealed to me that Maggart had wanted to take her away from me because they were in love, and how she decided against it for the sake of our small children.
But by now I was beyond caring, except I thought that we could go forward on a better footing, now that the children had left home, and Zachary’s parentage was now in the open.
In 1989, Lynn brought Brandon to Hollywood for him to play her brother in a sitcom for ABC with a 5-year contract (“Chicken Soup” opposite Jackie Mason) and I did not care then either. And so she maintained the relationship.
We had a quiet but open marriage, perhaps the secret to a long Hollywood marriage.
She, in her quest for truth in her acting roles, had a habit, I believe, to be intimate with some of her willing co-stars.
For example, one of them, star Brian Dennehy with whom she has worked on three occasions, has cheerfully admitted to their affair to the press “a long time ago.” I subpoenaed him to come to court.
Judge Gold continued the hearing until Dennehy left town. Hollywood privilege. Public record.
Lynn is from a strange and talented family, perhaps those qualities go together.
Her mother actress Rachel Kempson had a secret lover for 50 years (we started to write a play about this, “The Mandrake Root”, but then she left before it was finished), her father Sir Michael picked up boys off the street, and her sister Vanessa’s husband Tony Richardson died of Aids. Hollywood behavior? Public record.
The innuendos of Larry King and the National Enquirer and other tabloids are entirely incorrect, but the press appears to have much more fun preserving Lynn’s icon status while maintaining the fiction that their son married their assistant and thought that my child was his.
That is a shocking and disgusting thought, but because there was a federal offense involved, I never could correct it to the press. But I did take care to reveal the truth during the trial, and my letter confessing to the INS is on the record.
I was evicted on September 13, 2001. I was given an hour to collect my things, hook up my old Scout to my trailer, charge the battery and leave, and I lived in that trailer for the next six months.
Lynn secured a restraining order against me so that I have been unable to communicate with her, and abandoned all of the contents of our home to me, even though much of it belongs to her and the Redgrave family, and our children.
I now see that was good divorce designer tactics. (Hollywood’s Family Court attorneys are now called “specialists”. Good word).
The court, giving me a few days but no money, ordered me to retrieve all of the contents of the house the office, the farm equipment, and all of my cars and the backhoe.
I went to get a car, at least, so I could have wheels, but in trying to do that, I was prevented from doing so by Lynn who I thought was away filming in London, and Brandon Maggart and his two sons, and two agents of Coldwell Banker who had taken over possession of my home, and then the police who I called.
Photographs of this event are available as exhibits for the court trial. Lynn effectively took possession of everything at the house, and I found out much later she had destroyed many documents, including much of the history of my childhood career, including autographs personally signed to me as a child actor, by Glen Miller, Tommy Handley, Arthur Askey, Tommy Trinder, Will Hay and other luminaries of Britain’s past entertainment world with whom I had worked alongside for the BBC in the forties.
Lynn sealed everything in seven foot crates, and everything was hauled away to be stored in facilities under her name.
She put our three Rottweilers, Portia, Hermia and Puck, to be boarded at a filthy pet-care facility in Burbank. I was able to rescue them, and they are now in the care of our next-door Topanga neighbor.
I still pay for their food, and she, to her lasting credit, loves them, and they have a familiar home, and I have visitation with them regularly.
I did not retrieve all of my belongings until April 2004, and I now find that some documents are missing, as well as most of the record of my past career.
I also observed huge truckloads of material hauled away from the premises by local Topanga contractors, feeding at the trough.
I have three independent inventories of what was left and I now have, which reveal what has been lost or stolen or sold off, more than $250,000 worth. Evidence filed with the court.
I also found that our frozen stock market holdings had fallen precipitously in value (example: Migratec (MIGR), worth $1 million at its height in 1999 is now worth nothing), and that our debt-free real estate was sold under the court’s signature at the start of an unprecedented rise in real estate values by order of Judge Gold. I had no recourse.
Her and Nicky’s lawyers got paid out of escrow in the form of sanctions against me, awarded to them by Judge Gold.
My home and prime 5-acre estate was sold for an unbelievable $1,700,000. I received an unbelievable check for $2,616.03.
My house is now owned by a fellow director member of the DGA, and my studio/office is now owned by a real estate agent friend of the Coldwell Banker agent who represented both buyer and seller.
And I suppose that Lynn remained confident that with her Golden Globe statue, her SAG award, and Academy Award nomination which I helped her obtain through energetic marketing, she was now firmly in the hands of powerful agents and attorneys who would help her become a really big star, with ample cash flow to take care of her future needs, children to adore her for moral support, and a staff of the usual handlers on retainers of manager/agent/publicist/accountant and of course attorney.
She certainly didn’t need me for that any longer, and I have no problem with that. Her present uninsurable condition is ironic.
However, there exist Community Property laws in the State of California. I should not be broke.
The damage done to my reputation and ability to earn a living in the small world of Hollywood and New York entertainment has been perhaps irreparably damaged, and incalculable in terms of lost creativity.
I maintain my active membership with the Directors Guild of America, the Society of Stage Directors and Choreographers, Actors Equity, Screen Actors Guild, and AFTRA. But nobody comes knocking.
I defended myself in the courts, because my lawyers took more than $600,000 cash from me before trial started, and bankruptcy loomed.
And CNN, “THE MOST TRUSTED NAME IN NEWS” claims to tell the truth of what really happened, and spreads it around the world.
DEFENDANT LARRY KING’S BACKGROUND
And who is Larry King, and why should anyone believe what he has to say?
We are about the same age. I have been a professional in the entertainment business longer than he has. Research gleaned from several sources on the web reveals that he regularly interviews senators, former presidents, current presidents, Kings, Queens, heads of state, and enjoys enormous respect in the news business. He needs no introduction here. Everybody I know sees him as the top interviewer in the business. Everybody seeks to be his friend and to get on his show, wrongly titled, as I found out, “Larry King Live.” He sets the trend in interview technique.
We are told by his publicists that he has been inducted into five of the nation’s leading broadcasting halls of fame and is the recipient of the prestigious Allen H. Neuharth Award for “Excellence in Journalism.”
In celebration of his 40th anniversary in the broadcasting industry, Hollywood honored King in 1997 with a star on the Hollywood Walk of Fame for his life’s work.
Larry’s reported salary for the year 2000 was 7 million dollars. His fees for speaking engagements are said to be $50,000 apiece. Public record.
He is married for the fifth time, to actress Shawn Southwick, and is the father of Andy, Larry Jr., Chaia, Chance and Cannon.
He is fortunate, he must see them often.
Contrast this with my life, the father of Jonathan, Benjy, Kelly, Annabel and Zachary, and the grandfather of six. I was allowed to meet them but once. I do not know where they all live, and they support their mother exclusively, moving East to be with her.
Of course everybody listens to Larry King. They believe what he has to say, and they believe he asks all the questions there are to be asked.
As he said at the start of the program, “For the first time, the shocking details of the scandalous divorce that set off a tabloid frenzy. She opens up about everything. She’s been through it all. A no-holds-barred hour with Lynn Redgrave. Exclusive.”
Thank you, Mr. King.
And now, let’s reveal your under-belly, published by E-Online on the web. Call this sauce for the gander:
Birth Name: Lawrence Harvey Ziegler; Birthdate: November 19, 1933. Birthplace: Brooklyn, NY; Occupation: TV/radio host; Significant Other(s): Wife: Frada Miller; married after high school graduation 1953, marriage annulled; Wife: Alene Akins, former Playboy bunny, married 1961 divorced 1963 remarried 1967, divorced 1971; mother of Chaia and Andy; Wife: Mickey Sutphin, married 1964, divorced 1968, mother of Kelly; Wife: Sharon Lepore, production assistant, former math teacher, married 1976, divorced 1983; Angie Dickinson, actress, together 1983-88; Wife: Julia Alexander, married 1989, separated 1990, divorced 1992; King later sued her for slander, case settled in 1994 with order to seal court records; Next, Rama Fox, minister, announced engagement 1992, separated 1995. King and Fox later entered into litigation over financial matters. Next, Deanna Lund, former actress, announced engagement 1995, no longer together. Current wife: Shawn Southwick, singer, model, TV host, met in early 1997, married September 5, 1997, former wife of public-relations executive Michael Levine. Has son (born 1981) from first marriage.
PENDING JUDICIAL MATTERS
My ex-wife sought to influence the justice system in Los Angeles, and has succeeded very well with the assistance of defendants. I have only my pension to live on now, because I got re-married and lost my wife’s lifetime support of $3,000 per month which the court ordered I should be paid, befitting my customary standard of living(!).
I believe there was and still is a RICO game going on, and I intend to prove it.
And what are the Lawsuits which are part of the public record?
Lawsuits, begun against me by Lynn and Nicolette, all in the Los Angeles courts, are as follows:
Nicolette Hannah Clark v. John Clark (Paternity issues) BF 013155 (filed January 1999)
Lynn Redgrave Clark v. John Clark BD 296320 (Dissolution of Marriage, filed March 1999)
Defendant John Clark’s WRIT to DISQUALIFY Judge Arnold H. Gold in Division 1, COA (denied); John Clark and Lynn Redgrave Clark v. Nicolette Hannah SC 063529 (Quiet Title to house in which she lived with her now husband Ernesto Hernandez) denied as to Nicolette by Judge Reid (surprise, but Redgrave was on my side and the judge wasn’t Arnold Gold, and I used a lawyer).
Kellybee Enterprises, Inc. v Illyria Enterprises, Inc. SC 063527 over fraudulent transfer of funds by Redgrave to her new corporation [Not prosecuted, and rulings were made by Judge Gold without attorney representation of a corporation which is mandated by law].
John Clark v. Spencer Brandon Maggart, et al SC 070226 [Judge Flynn as of 8/8/02, to be heard in Civil Court with John Clark v. Melissa Oliver, Coldwell Banker Companies BC 273790 (Judge Chalfant].
Disso Appeal of Dissolution decision to evict me from my home to release funds to pay Redgrave’s attorney fees and other expenses from escrow B151350 [DIV. 1] Consolidated with BOND appeal (bond was set at well over a million dollars, beyond defendant’s ability to raise) case B152947. Affirmed.
Appeal re. Decision to sell guest house below market to release more funds to escrow (within the dissolution case) B159545; APPEAL B151269 [DIV. 3.] of paternity decision of Judge Gold, to pay attorney fees out of escrow; Nicolette Hannah Clark Hernandez APPEAL of Quiet Title Case B157749 in DIV. 3 (denied as to Nicolette); Nicolette’s Writ to deny Judge Reid’s findings in LASC B163150 (denied).
On June 10, 2004, my appeal re. eviction from my home was upcoming, and the theft of much of my belongings, to be presented to the 4th. and 7th Divisions. The suits had been dismissed by Judge Flynn. I have now withdrawn them, as shown in footnote 1.
For the future I am bringing complaints before the appropriate authorities regarding Judge Arnold H. Gold, and his application for a judgeship. He retired immediately after hearing my cases, and inquiries are being made as to what happened to the funds he awarded to several attorneys, one of whom, Nicolette’s attorney James Eliaser, worked with him in Judge Gold’s law firm Pachter, Gold and Schaffer (this being concealed by Judge Gold during pre-trial motions) amounting to several hundred thousand dollars as sanctions against me, to be taken out of the escrow upon sale of my debt-free home after my eviction, under the court’s signature, and with no recourse by me and supported by Family Court rules.
After Judge Gold made his rulings, he then retired from the public bench; his current wife runs a charity. The Commission on Judicial Performance tells me that it has no oversight on retired, or re-assigned retired judges. I have been informed that the District Attorney’s policy is not to get involved with domestic issues in divorces and family court, and they have shown no interest. Where does the buck stop?
“We the people” place our trust in a system which supports clean judges. We are reasonably confident they are free from corruption, as they are appointed by our governors and stay with the approval of, and under the watchful eye of, our Chief Justice, Ronald George. It’s a serious and solemn business.
A request to review Judge Gold’s application to the governor to become a judge has been refused by the authorities, deemed “confidential”. Applying my due diligence, I have learned from public records that he was awarded a judgeship by Governor Deukmejian on 9/13/88, despite the record in his own nearly 5 year long dissolution proceedings (in LASC case number D718500) where he was found by Family Court at that time to be guilty of domestic physical violence, maintaining a mistress, and mismanagement of his wife’s personal funds. He also took custody of their 3 children, and lived in the house owned by his wife, and stopped paying her support, and she just “gave up” as she is quoted, at the time of her agreeing to settle after nearly five years of litigation. He has sat on the bench for years, he has sat on the Court of Appeal, he has written arcane legal books, he is hugely respected by the legal community, and the legal community came to his farewell banquet in droves in 2002 after his “retirement”, from probate and family court.
It is my belief that he acts out his own personal feelings in his rulings towards victims from the bench. He has been deeply involved in the now celebrated case of courageous pro se litigator (“vexatious litigant” they made her) Idelle Clarke, whose daughter was removed from her custody and placed with her ex-husband whom authorities in Children’s Court had found to be sexually molesting her. She’s been fighting for ten years, all the way to the U.S. Supreme Court (case no. BD108528). Denied, of course. And a similar fate happened to Janette Katz in Katz v. Katz (case no. BD231366), again Gold’s case.
Judge Gold’s background information is available at the Los Angeles Hall of Public Records, if it hasn’t been removed.
After his retirement, Chief Justice Ronald George directed him to stay in charge of my case, despite my letter to him in protest. I have the letter giving full details and the response from his office. “The appeals court will take care of it”, I was told. They sure did. The L.A. Court of Appeal Division 1 in case B151350, despite my submission from the public record, refused to take notice of Judge Gold’s past and unfitness for family court proceedings in my documents filed with them, and refused to set aside his judgments. I was, in fact, reprimanded, and reminded that Lynn had taken a restraining order against me, so I must be a bad person. The Appeals Court, where, it is said, they “shoot the wounded”. My submission for review from the California Supreme Court was then denied.
I am still working towards having the result set aside.
Judge Gold had acceded to Lynn’s demand that I be jailed for 24 hours on the day before I was to begin the trial proceedings, so at the opening of the trial, just before it began, I read a motion for “disqualification for cause”. CCP 170.3 et seq. This effectively stopped the proceedings. There was delay of several weeks while this motion was considered by Judge Horne, a supervisory judge in Orange County who was in the position of securing votes from all of his judges in order to stay in his position. I didn’t know it at the time, and he wrote that there was no breach of judicial power.
I conducted my own defense at the eventual trial before, yes, Judge Gold. I put Lynn in the witness box. It was there and then that I first heard, under my questioning, that she and persons unknown had entered my office and gone through my paperwork and computer that night, Watergate style, knowing I was in jail, despite my notice “WAR ROOM” on the door of my office to stay out. I immediately moved for a mistrial. Denied by Judge Gold.
Then in the middle of trial, which was held on dates calendared by the court at her request, she surprised me and the court. She abruptly left for England, beyond the arm of the court to recall her for my rebuttals of her lies, and so the trial became a charade. When Judge Gold made his punitive rulings against me, he then retired. He is now a “rent-a-judge”, available, as I overheard him say, for celebrities who would pay more than he was paid by the State judicial system, and advertised to consumers by the ARC (Alternative Resolution Centers, a Limited Liability Company).
My pleadings, made properly in court according to courtroom procedures and the California Code of Civil Procedure and the California Rules of Court and the Local Rules and judges’ personal rules, were many over a period of the last 6 years. A partial flavor of what I have been put through in the several and ongoing cases is listed consecutively in the following defensive pleadings. Many of these pleadings had to be prepared twice, one for each case. Here some of them are, as footnote2.
- RESPONDENT’S RESPONSE TO PETITIONER’S MOTION FOR BIFURCATION OF THE MARITAL STATUS AND JUDGMENT THEREON. REQUEST THAT THEIR MOTION BE DENIED.
- PETITION FOR PEREMPTORY WRIT OF MANDATE/PROHIBITION FROM ORDER DENYING DISQUALIFICATION OF JUDGE ARNOLD GOLD; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; EXHIBITS
- REQUEST TO CONTINUE TRIAL DATE BASED UPON PENDING DISQUALIFICATION OF JUDGE GOLD FOR CAUSE IN RELATED CASE NO. BD 296 320 (IN RE. MARRIAGE OF CLARK) BECAUSE OF THIS PENDING MATTER
- REQUEST OF THIS COURT TO TAKE JUDICIAL NOTICE UNDER EVIDENCE CODE OF LETTER SENT TO IMMIGRATION AND NATURALIZATION SERVICE ALLEGING FRAUD
- REQUEST FOR STATEMENT OF DECISION ON CONTROVERTED ISSUES
- REQUEST FOR TRIAL COURT TO STAY ENTRY OF JUDGMENT PENDING RESOLUTION OF MATTERS IN CURRENT TRIAL OF RELATED CASE NUMBER BF 013 155 SO AS TO COORDINATE THE RESULTS
- RESPONDENT’S OBJECTION TO PROPER JUDGMENT IN RESPECT OF KELLYBEE ENTERPRISES, INC. WHICH WAS NOT REPRESENTED
- REQUEST FOR TRIAL COURT STAY OF IMPLEMENTATION OF JUDGMENT
- RESPONDENT’S OBJECTION TO JUDGMENT AND/OR ENTRY OF SAME
- MOTION TO DISQUALIFY JUDGE GOLD AND TO ASSIGN ACTION TO ANOTHER JUDGE (CCP SECTION 170.6)
- RESPONDENT’S REQUEST FOR RULING
- OBJECTIONS TO [PROPOSED] STATEMENT OF DECISION; POINTS AND AUTHORITIES;
- NOTICE OF MOTION AND MOTION FOR A NEW TRIAL; MEMORANDUM OF POINTS AND AUTHORITIES
- SUPPLEMENT TO NOTICE OF MOTION AND MOTION FOR A NEW TRIAL; MEMORANDUM OF POINTS AND AUTHORITIES; ADDITION OF CITATION OF RULE 14.4(F) EX PARTE COMMUNICATION (FOR ATTACHMENT)
- EX PARTE APPLICATION FOR ORDER SETTING AMOUNT OF BOND ON COLINA DRIVE PROPERTY;
- DECLARATION OF JOHN CLARK IN SUPPORT THEREOF
- OBJECTION TO LISTING OF MARITAL HOME FOR SALE PENDING CURRENT SETTLEMENT NEGOTIATIONS; DECLARATION OF JOHN CLARK
- EX PARTE APPLICATION FOR 30 DAY STAY OF ORDER TO LIST AND SELL MARITAL RESIDENCE PENDING RESOLUTION OF CURRENT SETTLEMENT NEGOTIATIONS AND LEGAL PROCEDURES
- SUPPLEMENTAL GROUNDS IN SUPPORT OF MOTION FOR NEW TRIAL; POINTS AND AUTHORITIES
- RESPONSE TO PETITIONER’S REQUEST FOR ORDER SHORTENING TIME;
- RESPONSIVE DECLARATION IN OPPOSITION TO PETITIONER’S MOTION TO EVICT RESPONDENT FROM HOME; NOTICE AND APPLICATION FOR COURT TO ENFORCE SETTLEMENT OFFER MADE BY PETITIONER ON JULY 5, 2001;POINTS AND AUTHORITIES;
- EX PARTE APPLICATION SEEKING THIS COURT’S PERMISSION TO ALLOW RESPONDENT TO TAKE UP (cont’d) RESIDENCE AT 21122 ENTRADA ROAD, TOPANGA, PENDING POSSIBLE EVICTION FROM HIS HOME TODAY; OR, IN THE ALTERNATIVE, ORDERING 21122 ENTRADA ROAD TO BE SOLD TO SATISFY ATTORNEYS’ CLAIMS FOR APPROXIMATELY $350,000 IN FEES AND SANCTIONS WHICH WERE APPROVED AND ENTERED BY THIS COURT;
- EX PARTE APPLICATION FOR THIS COURT TO SET AMOUNT OF WASTAGE BOND IN ACCORDANCE WITH CCP 917.4 FOR MANDATORY INJUNCTIVE ORDER MADE 8/24/01 BY THIS HONORABLE COURT (IF APPROPRIATE) SO THAT RESPONDENT WILL NOT BE EVICTED PURSUANT TO MARKETING OF HOUSE
- RESPONDENT’S OBJECTION TO PETITIONER LYNN REDGRAVE’S EX PARTE APPLICATION TO FORCE SALE OF FAMILY HOME AT REDUCED PRICE;REQUEST FOR OSC STATUS;REQUEST FOR RIGHT OF FIRST REFUSAL
- EX PARTE APPLICATION FOR COURT APPROVAL TO MOVE MY POSSESSIONS FROM THE MAIN HOUSE TO THE GUEST HOUSE, AND TO PURCHASE THE GUEST HOUSE
- RESPONSIVE DECLARATION TO PETITIONER’S EX PARTE FILED DECEMBER 19, 2001
- RESPONSE TO NOTICE OF RELATED CASES
- RESPONSIVE DECLARATION TO DECLARATIONS OF LYNN REDGRAVE AND HER ATTORNEY EMILY SHAPPELL EDELMAN
- RESPONSIVE DECLARATION TO PETITIONER’S EX PARTE APPLICATION FOR THE SALE OF RENTAL PROPERTY AT 21122 ENTRADA ROAD, TOPANGA
- RESPONSIVE DECLARATION TO PETITIONER’S EX PARTE APPLICATION FOR LISTING OF JOINTLY OWNED GUEST HOUSE FOR SALE APPOINTING COLDWELL BANKER AS AGENTS
- MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANT’S AND CROSS-COMPLAINANT’S MOTION FOR NEW TRIAL
- POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR ORDER FOR PAYMENT OF EXPENSES AS SANCTIONS
- NOTICE OF MOTION AND MOTION FOR ORDER FOR PAYMENT OF EXPENSES AS SANCTIONS; POINTS AND AUTHORITIES IN SUPPORT THEREOF AND DECLARATION OF JOHN CLARK IN SUPPORT OF MOTION FOR ORDER FOR PAYMENT OF EXPENSES AS SANCTIONS
- DECLARATION OF JOHN CLARK IN OPPOSITION TO ORDER TO SHOW CAUSE OF PETITIONER
- DECLARATION OF INCOME AND EXPENSES OF RESPONDENT JOHN CLARK
- FIRST AMENDED COMPLAINT FOR: 1. CONVERSION 2. BREACH OF CONTRACT 3. NEGLIGENCE 4. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 5. ABUSE OF PROCESS 6. ASSAULT 7. BATTERY 8. ACCOUNTING
- APPELLANT’S SECOND REQUEST FOR EXTENSION OF TIME; ORDER THEREON
- POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR RECONSIDERATION OF RULING FOLLOWING
- APPELLANT’S FIRST REQUEST FOR EXTENSION OF TIME; MOTION TO AUGMENT RECORD; ORDER THEREON
- NOTICE OF MOTION AND MOTION FOR RECONSIDERATION OF RULING RE. SALE OF COMMUNITY ASSETS AT REDUCED VALUE; POINTS AND AUTHORITIES; DECLARATION OF JOHN CLARK
- DECLARATION OF JOHN CLARK IN OPPOSITION TO MOTION TO DISMISS BASED ON FRAUD ON THE COURT, FRAUDULENT AND INCONSISTENT ALLEGATIONS
- NOTICE OF RESPONDENT’S ADDRESS AND TELEPHONE AND FAX NUMBER
- NOTICE TO COURT THAT THE MAY 24, 2002 FILING FOR RECONSIDERATION OF ITS RULING MADE MAY 13, 2002 WAS NOT FILED LATE; POINTS AND AUTHORITIES; DECLARATION OF JOHN CLARK; DECLARATION OF MIYUKI TSUNODA
- PLAINTIFF’S CORRECTION TO DECLARATION FILED APRIL 26, 2002, ONLY WITH ADDITION OF OMITTED VERIFICATION
- PLAINTIFF’S RESPONSE TO DEFENDANTS NICOLETTE AND ERNESTO HERNANDEZ’ OPPOSITION TO PLAINTIFF’S MOTION FOR RECONSIDERATION; POINTS AND AUTHORITIES; DECLARATION OF JOHN CLARK
- APPELLANT’S RESPONSE TO DECLARATION OF JAMES R. ELIASER DATED MAY 30, 2002 OBJECTING TO APPELLANT’S FIRST REQUEST FOR EXTENSION OF TIME TO FILE OPENING BRIEF
- NOTICE OF INCORRECT NOTICE OF THE COURT GIVEN BY DEFENDANT KATLEMAN’S ATTORNEY ABRAHAM M. RUDY
- APPELLANT’S NOTIFICATION OF NEW ADDRESS; APPELLANT’S CORRECTION: THIS IS APPELLANT’S SECOND APPLICATION FOR EXTENSION
- APPELLANT’S NOTIFICATION OF NEW ADDRESS
- ARGUMENT ON MOTION TO RECONSIDER FILED MAY 24, 2002; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF JOHN CLARK
- NOTICE OF MOTION AND MOTION TO ALLOW TESTIMONY FROM BUILDING AND SAFETY RE. NON-PERMITTED CHANGES AT 21342 COLINA DRIVE TOPANGA; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF JOHN CLARK;
- COURT’S APPROVAL OF RESPONDENT’S UNDERTAKING
- EX PARTE APPLICATION FOR COURT TO INVALIDATE UNTIMELY CLOSE OF ESCROW ON RESPONDENT’S REAL PROPERTY; REQUEST FOR SANCTIONS; POINTS AND AUTHORITIES; DECLARATION OF JOHN CLARK
- CASE INFORMATION STATEMENT (CIVIL APPEALS) COURT OF APPEAL, SECOND APPELLATE
- APPELLANT’S ADDENDUM OF EXHIBITS TO CLARIFY CASE INFORMATION STATEMENT FILED YESTERDAY JULY 8, 2002
- APPELLANT’S APPLICATION FOR FURTHER EXTENSION OF TIME TO FILE OAB
- ADDENDUM TO APPELLANT’S APPLICATION FOR FURTHER EXTENSION OF TIME TO FILE OAB
and LETTER DATED JULY 10, 2002, (EXHIBIT 1)
- APPELLANT’S EX PARTE MOTION FOR COURT’S INTERVENTION TO STAY PROCEEDINGS IN OTHER CASES AND GRANT FURTHER EXTENSION OF TIME FOR APPELLANT’S FILING OF OAB DUE 7/15/02
- EX PARTE APPLICATION FOR CONTINUANCE OF THIS MATTER IN THE INTERESTS OF JUSTICE; DECLARATION OF JOHN CLARK
- RESPONDENT JOHN CLARK’S NOTIFICATION OF NEW ADDRESS
- AFFIDAVIT, PEREMPTORY CHALLENGE, CCP 170.6
- RESPONDENT’S BRIEF IN SUPPORT OF EXPUNGEMENT OF LIS PENDENS; DECLARATION OF JOHN CLARK
SUPPORT OF RELEASE OF FUNDS FROM SALE OF REAL PROPERTY
- APPLICATION FOR EXTENSION OF TIME
- NOTICE OF APPEAL
- APPLICATION FOR EXTENSION OF TIME
- NOTICE OF ELECTION TO PREPARE APPENDIX
- NOTICE DESIGNATING PAPERS TO BE INCLUDED IN CLERK’S TRANSCRIPT
- NOTICE OF ELECTION TO PREPARE APPENDIX
- NOTICE DESIGNATING PAPERS TO BE INCLUDED IN CLERK’S TRANSCRIPT
- EX PARTE NOTICE FOR 30 DAY CONTINUANCE
- RESPONSE TO PLAINTIFF’S ORDER TO SHOW CAUSE
- RESPONDENT’S INCOME AND EXPENSE DECLARATION
- NOTICE TO THE COURT OF RESPONDENT’S INABILITY TO FILE BRIEFS DUE TODAY BECAUSE OF THE LOS ANGELES FIRE AND RESULTANT UNAVAILABILITY OF LEGAL AND OTHER SUPPORT; DECLARATION OF JOHN CLARK
- DEFENDANT JOHN CLARK REQUESTS PERMISSION TO FILE DOCUMENTS IN COURT TODAY
NOVEMBER 7, 2003
- SUPPORTING DOCUMENTS TO COMBINED IDENTICAL RESPONSE AND RESPONSIVE DECLARATION IN BOTH RELATED CASES OF DEFENDANT JOHN CLARK
[end of footnote 2]
And I’m not through yet.
The dates are not important, but they started in December of the year 2000 when, pursuing California’s proud liberal penchant for allowing sound heterosexual marriages to be broken up by a dissenting spouse without effort to repair the problems, I was fired by my wife and off-loaded with ease and approval by the courts on December 20, 2000. Public record.
All of these submissions, requests, pleadings, motions and responses are easily available to be read by anybody, especially the research facilities of the “Larry King Live” production staff, and the inquiries undoubtedly made by the Standards and Practices departments of CNN and TBS who regularly check with their legal departments.
Perhaps, given the chance, I could have persuaded them to stay away from the entire subject of our divorce, and stuck with the serious side of women’s breast cancer.
I declare under penalty of perjury according to the laws of the State of California and the United States, that the foregoing is true and correct except to those facts which I believe to be true to the best of my information and belief, and would so swear to in court.
Executed at Los Angeles, California. Dated: September 23th, 2004
John Clark, Plaintiff, pro se
1. Lynn Redgrave, using Defendant Larry King’s status and credibility, set out to influence the course of Public Opinion and American Justice in Hollywood’s courts at the time that the justices were making their deliberations. Larry King fell for it. CNN fell for it. TBS fell for it. They should be punished. I should be made whole.
2. I needed to get on the air with a rebuttal to the insinuations and harm done to me by Larry King and Lynn Redgrave. I am now the object of scorn in my home town. My ability to make a living seems to be nil.
3. This clearly is a case of de facto slander and libel upon my reputation, accompanied by actual slander and libel on the false information broadcast which was a lie, that should have been uncovered with minimal research which I believe the station and the broadcast facility had a duty to undertake. I believe that the Limited Liability partnership of Cable News Network and the TBS Corporation had a duty to take proper care through their Standards and Practices and legal departments.
4. I believe I am a private person, and I believe that my experiences are a matter of Public Concern, and CNN has a greater duty to report on my experiences in the Los Angeles Family Court system than to suppress the information in order to help promote Lynn Redgrave’s book and career at the expense of her ex-husband and supporter for 33 years.
5. If I am found to be a “public person” and therefore with a higher standard of proof, I believe that I can show through discovery that this invasion of my and my children’s privacy was done with actual malice, that is with knowledge that it was false, or with reckless disregard of whether it was false or not, in order to provide entertainment and ratings to a hungry public and demanding sponsors.
6. I believe this has had a direct and adverse effect upon my ability to restart my acting, producing and directing career, as well as an adverse influence upon future trial court proceedings, and my constitutional right to due process and the pursuit of happiness in my golden years.
7. As for my glorious son Zachary John Clark – who knows – her lawyer has illegally hidden him somewhere. The broadcast tends to approve his being kept away from me.
TRIAL BY JURY DEMANDED
I, John Clark, demand that this case be presented to, and decided by, a jury.
Wherefore, I, John Clark, demand:
(A) Trial by jury.
(B) That judgment be entered against defendants, Lawrence Harvey Zeiger aka Larry King, Cable News Network LP, LLLP, and Turner Broadcasting News, Inc., severally and jointly, for actual damages in an amount not less than Ten Million Dollars, with punitive damages assessed by the court.
(C) That all costs of my action be assessed against Defendants.
TRIAL BY JURY DEMANDED
Dated this the 23nd day of September, 2004
JOHN CLARK, PLAINTIFF