Lawyer Richard Keegan, who is being paid by Kerry Stokes’ Seven West Media, has been caught lying in written submissions to the High Court of Australia in the matter known as Jane Doe & Ors v Shane Dowling. Kerry Stokes’ lawyers and barristers have a long history of lying and deceiving in the Supreme Court of NSW but lying to the High Court of Australia is a new low even for them and explains why barrister Sandy Dawson refused to sign the written submissions.
Kerry Stokes has 3 outstanding frivolous and vexatious lawsuits against me pending in the Supreme Court of NSW and I have filed 3 Applications for Removal in the High Court of Australia which are still pending and will hopefully they will be heard soon.
My Applications for Removal to the High Court of Australia is what has brought Kerry Stokes and lawyers undone as they lie to the High Court trying to make sure the matters are not removed to the High Court, as their SLAPP lawsuits would be exposed, while at the same time lying and deceiving in the Supreme Court of NSW. They get confused trying to remember which lies they told where.
Mr Keegan told the High Court of Australia in written submissions on the 17th of July 2019 that there was still more evidence to be filed so the matter should not be removed to the High Court. But on Friday (26/7/19) their barrister, Sandy Dawson, confirmed they would not be filing more evidence which is consistent with their previous SLAPP Lawsuit strategy of not filing any evidence for the final hearing.
One reason for my applications is they are SLAPP Lawsuits “A strategic lawsuit against public participation (SLAPP) is a lawsuit that is intended to censor, intimidate, and silence critics by burdening them with the cost of a legal defense until they abandon their criticism or opposition.” (Click here to read more)
And a second reason is that Chief Justice Tom Bathurst ordered court staff in September 2016 to stitch me up for jail for an email that I sent the court so I have argued I will not receive natural justice in the Supreme Court of NSW.
The Jane Doe matter relates to: “In December 2016 Seven West Media, on the instructions of Kerry Stokes, paid lawyers to sue me on behalf of a well-known female Channel 7 on-air presenter and a well-known Channel 7 actress. It was because I reported that they had been named by Amber Harrison in a legal document before the Australian Human Rights Commission that they had affairs with Seven West Media CEO Tim Worner.” Two other former female staff were added to the proceedings a few weeks later. (Click here to read more)
The real reason for the Jane Doe court case is to hide Seven West Media CEO Tim Worner’s numerous sexual relationships with Seven employees and to cover-up his fraudulent use of $millions of shareholder’s money in legal fees and payoffs to help facilitate and cover-up the affairs.
The documents relating to the application to have the matter removed to the High Court of Australia are below.
(Click here to read my Application for Removal and click here to read the supporting affidavit) (Click here to read their response and click here to read their supporting affidavit) (Click here to read my reply)
They then decided they had a right to file another affidavit to correct one of their lies that I had pointed out in my reply. (Click here to read their follow-up affidavit) So I filed another affidavit as well pointing out their latest lie and asking the High Court of Australia to charge Richard Keegan with criminal contempt. (Click here to read my follow-up affidavit)
Supreme Court Judge Desmond Fagan was also working overtime last Friday trying to make sure that the matters are not removed to the High Court of Australia as it would expose corruption in the Supreme Court of NSW.
I was in court on Friday (26/7/19) before Justice Desmond Fagan for direction hearings in 2 matters. The Capilano Honey & Ors v Shane Dowling matter and the Jane Doe & Ors v Dowling matter and it didn’t take long to realise Justice Fagan was acting on instructions to have the matters progressed as fast as possible to make sure they were not removed to the High Court of Australia.
Some of my notes from Fridays (26/7/19) hearing are:
- Justice Fagan was doing what he could to make sure that the matters weren’t removed so their Slapp Lawsuits wouldn’t be removed to the High Court and exposed
- Justice Fagan did not even try and hide the fact that he has predetermined his judgment in a Notice of Motion filed by Capilano to have my defence knocked out. The Notice of Motion wasn’t even set down for hearing but he decided it on the day anyhow.
- He denied me natural justice given he had already decided their Notice of Motion in their favour and he wasn’t going to let me have a say until I complained about his conduct.
- Justice Fagan said he wouldn’t publish a judgment. Common law dictates he has to publish a judgment which is what is meant to keep the judges honest.
- He threatened me with contempt when I was explaining why I spent 4 months in jail last year for contempt.
- Justice Fagan was in a hurry to set down the Capilano matter for hearing. Obviously to avoid the High Court removing it.
- I asked Justice Fagan if he had spoken to Chief Justice Tim Bathurst before the hearing and he refused to answer.
- Justice Fagan ordered that witness statements be filed and served for the Capilano Honey matter. I asked for Justice Fagan to order them to be filed in affidavit form but he refused.
- Justice Fagan issued no orders for the filing of witness statement in the Jane Doe matter even though it is set for hearing on the 26th and 27th of August 2019.
On Saturday I sent the below email to their lawyer Richard Keegan and others:
From: SHANE DOWLING
Sent: 27 July 2019 11:39
To: Richard Keegan <email@example.com>; Alexander Latu <firstname.lastname@example.org>; Sandy Dawson <email@example.com>; Martin O’Connor <Martin.OConnor@addisonslawyers.com.au>; firstname.lastname@example.org
Cc: Kieran Smark <email@example.com>; firstname.lastname@example.org
Subject: Jane Doe & Ors v Dowling
Dear Mr Keegan
Can you explain why you lied to the High Court of Australia in your submissions filed on the 17th of July 2019 when you said at paragraph 3 that “the filing of evidence has yet to be concluded” when:
- There are no court orders for any filing of evidence or further filing of evidence even though there is no evidence before the court supporting your client’s claim except hearsay evidence by you, filed years ago, which is inadmissible at the final hearing?
- Yesterday, Friday the 26th of July 2019, when the matter was in court, at my request, there were no orders issued for the filing of evidence?
- Yesterday, you nor your barrister Sandy Dawson SC, sought to have any further evidence filed?
- Yesterday Sandy Dawson SC made it clear he had no intention to file any further evidence in the matter?
- Yesterday Sandy Dawson SC played stupid in court and pretended he knew nothing about what you wrote in the submissions to the High Court of Australia, especially paragraph 3?
- Why did Sandy Dawson SC, yesterday in court, at one point try to contradict me when I pointed out that he had not signed off on the submissions to the High Court of Australia but you had signed off on the submissions?
Please reply ASAP so I can advise the High Court of Australia.
I had no response to the above email so I sent another email today (30/7/19) as per below:
From: SHANE DOWLING
Sent: 30 July 2019 13:35
To: Richard Keegan <email@example.com>; Martin O’Connor <Martin.OConnor@addisonslawyers.com.au>; Alexander Latu <firstname.lastname@example.org>; email@example.com; firstname.lastname@example.org; email@example.com; firstname.lastname@example.org; Kieran Smark <email@example.com>
Subject: High Court of Australia – Jane Doe & Ors v Dowling
Dear Mr Keegan
Attached is the affidavit I filed in the High Court of Australia yesterday (29/7/19).
The working title of my next article is “Kerry Stokes’ lawyers caught lying to the High Court of Australia to cover-up fraud and theft at Seven” and I have a few questions:
- Are you still in regular contact with Kerry Stokes in relation to the Jane Doe & Ors v Dowling matter?
- Are you still in regular contact with Kerry Stokes regarding other matters?
- Who instructed you to lie in the written submissions to the High Court of Australia you filed and signed on the 17th of July 2019 in the Jane Doe & Ors v Dowling matter?
Also, I have not had a response to the attached email I sent to you on the 27th of July 2019. Can you please respond to this email and the attached email by 5pm today so I can publish.
Richard Keegan did respond but not to the second email above but to the first one I sent on Saturday the 27/9/19 as per below:
From: Richard Keegan <firstname.lastname@example.org>
Sent: 30 July 2019 15:17
To: ‘SHANE DOWLING’
Subject: RE: Jane Doe & Ors v Dowling
Dear Mr Dowling
Your email below misstates the situation as it relates to further evidence in this proceeding. It is true that there are no orders in place for the filing of further evidence in the proceeding. However, it is open to either party to file and serve evidence before the final trial. Whether there is further evidence filed is a matter for the respective parties to the litigation, including yourself, to determine. We note for example at Friday’s hearing that you foreshadowed various applications to be heard at the final hearing. It is of course a matter for you, but we accept you would be entitled to file evidence in support of what you are seeking and the position is likewise for the plaintiffs.
Richard Keegan | Special Counsel
D +61 2 8915 1075 | M +61 410 554 357 | F +61 2 8916 2075
Level 12, 60 Carrington Street, Sydney NSW 2000
Richard Keegan’s response does not answer the questions I asked, and he ducks and weaves.
The way Kerry Stokes and his lawyers run their SLAPP lawsuits is that they institute proceedings using an affidavit by one of the lawyers which only has hearsay evidence to back up their claim. They initiate the proceeding at an ex parte hearing (only they are in court) so I am not there to argue against it.
They then drag out the proceeding for years and get dodgy judges to knock out my defence on technical grounds. They then go to the final hearing with no evidence to support their claim and argue they do not need to provide evidence as they knocked out my defence and that is what they are doing again in this matter. It is exactly what they did in the Munsie v Dowling matter that lasted 5 years from April 2014.
Some big cracks are starting to open up in Kerry Stokes’ SLAPP lawsuit strategy which he has used for years against many people.
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