This letter is part of the Record On Appeal and can be found  at

Exhibt #11, Docket #70.

                                    ARGUMENT

I.    Did the District Court incorrectly decide the facts?

	(a)    It is a fact that Judge Jarvis issued a fraudulent  Memorandum

Opinion on August 10, 1992 stating on page 13 that: "...Moose concludes

that all of Mr. Oliver's allegations were "groundless"..."(emphasis

added).  No where in the record of this case is there any evidence

whatsoever to even remotely support such a statement. In order for Judge

Jarvis to be able to support his injunction  preventing

Plaintiff/Appellant from refiling his lawsuit, Judge Jarvis had to create

a myth which would suggest that Plaintiff/Appellant was  absolutely wrong

in his actions of filing a citizen's suit against 82 companies. Judge

Jarvis had to show that not even one allegation made by

Plaintiff/Appellant was true.  To do so, Judge Jarvis had to enter into

a conspiracy with defense Attorneys William Colvin, Frederick Hitchcock,

James Gentry, and State Solid Waste Manager Guy Moose, to ignore the

overwhelming facts and documents signed by Moose and his office, which

Plaintiff/Appellant submitted as evidence. All four (4) men and Judge

Jarvis were fully aware that Judge Jarvis's statement: "...Moose concludes

that all of Mr. Oliver's allegations were "groundless"..." (emphasis

added) was and is A BLATANT MISSTATEMENT OF THE TRUTH !

    (b)   It is a fact that Judge Jarvis only allowed sanctions against

Plaintiff/Appellant  for Count I and he specifically states these orders

at page 3, lines 2 and 3 of the transcript located at Docket #100. It is

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