1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

STEVEN H. HALL , Plaintiff,

v. Civil Action No. 1 6
- 1471 (J E B) DEPARTMENT OF HOMELAND SECURITY , et al. , Defendant s .

MEMORANDUM OPINION In the American judicial system, l awyer s must act both as zealous advocate s for their
clients and a s officer s of the court

. When an attorney loses sight of both duties in pursuit of his
own ill

- conceived personal objectives , however, the c ourt must act in defense of the system’s integrity

. This Court, unfortuna tely, now finds itself in such a position with regard to a ttorney Glenn Stephens . Stephens briefly intervened in this case after its termination and, in so doing,
filed numerous fri volous pleadings , many in direct violation of court orders

. These actions, as

we ll as the content of his filing s, clearly and convinc ing ly show that his true aim in pursuing this

matter was the advancement of his own personal vend etta against pro se Defendant Rosemary Dettling , his former employer

. As she has now reasonably responded by moving for sanctions against him, the Court will grant her Motion

. I. Background The proof of this Motion’s success lies in its factual pudding. For ease of digestion, in the first two sections, the Court lays out the pre

- litigation relationship between Stephens and Dettling2 that spurred his decision to intervene here . The next two sections explai n the procedural history
of this action before and then after his ill

- fate d appearance
. A. Employment Dettling is an attorney who specializes in plaintiff

- side employment cases, and her firm is called the Federal Employee Legal Services Center (FELSC) . Stephens is a lawyer who also represents that he has a Ph.D. The origins of their feud are hardly sensational. For fewer than
three weeks in June 2015 , Dettling paid Stephens to return phone calls and assist prospective
clients i n retain ing her as counsel. See ECF No. 26, Exh. A (Affidavit of Rosemary Dettling), ¶ 8; ECF No. 26

- 1 (Motion to Disqualify) at 2. She quickly decided to part ways w ith Stephens , however, when he began complaining about his pay

. See Mot. to Disq. at 2.
At the same time , Dettling was also representing Plaintiff Steven Hall with several claims
he was pursuing against t he Department of Homeland Security

– his former employer

– over his
own removal from service in November 2013

. See ECF No. 30 (Motion for Sanctions) ; ECF No. 36, Exh

. 4 at 9, Exh. 5 at 3 (MSPB Billing Records) ; ECF No. 1 (Complaint) at 4

. B. Post

- Employment
This tale might reasonably have ended there , but , alas, reason has not been the driving
force behind the even ts that gave rise to this Opinion

. The Court must reconstruct what happened next, though, almost exclusively from Dettling’s proffered record evidence , as Stephens does not bother to contest most of the facts that she has provided

. Instead, in his Response, he spends his time attacking her character, rather than defending his conduct that is
the s ubject of Dettling’s Motion

. A fter his termination, Stephens immediately began cyber stalking Dettling , seeking to
entice her clients to dump her as counsel, and posting negative reviews about her and her firm on3 the internet

. See Mot. to Disq. at 2

- 3

. For example, he posted the follo wing review of FELSC on Google : Worked for FELSC as a consultant for two plus weeks. When Rosemary Dettling started trying to nickel and dime me, in violation of our contract, I protested, Rather than honoring the terms of our contract, she said my service s were no longer needed. I made somewhere in the neighborhood of $24

- $36k for her in those weeks ($6 a retainer). And yet she was trying to cheat me out of a dozen dollars by claiming she would not pay for administrative tasks that were expressly part of o ur contract. So many federal employees are under siege but Rosemary only wants to help those who can afford her steep $6 retainer and $350 an hour. She loses clients left and right because of this. [ sic ]
I d. at 2. On other web sites , Stephens ma de little effort to be professional, instead electing to
d enigrate Dettling as “ dishonest, ” “ greedy, ” “creepy,” and a “ slimeball. ” Id. at 2

- 3 (citing
attached exhibits ). He also claimed to have taken over representation of at least one of her
clients. Id. at 3. Stephens, moreover, did not re strict himself to such public critiques

. When he found
information about Dettling’s representatio n of other client s through internet searches, he
sometimes r eached out to her personally to pan her handling of the case. Id. In one instance , Stephens discovered that Dettling had withdrawn from a case transferred by this Court to a
federal dist rict court in Florida. See ECF No. 17 at 2

- 3 & Exh. F. T he Florida court had notified Dettling that she needed to apply for pro hac vice admission before the case could proceed

. Id.
S tephens , having discovered this notification, emailed it to Dettling and her former clients, as well as to a District of Columbia Bar representative , with a narrative indicating that Dettling may have violated the professional code of conduct p rohibit ing the unauthorized practice of law. Id.
H e also copied Dettling and the D.C. Bar on a later single

- line email to the same former clients
he was now representing, stating only: “You should file your eth ics complaint against Rosemary if you haven’t already.” ECF No. 26, Exh. E.4 Stephens continued this conduct in 2016 , and on May 11 , Dettling filed a complaint against him with the D.C. Bar’s Office of Disciplinary Counsel

. See Mot. to Disq. at 3.
C. Proc edural History Prior to Stephen s ’ s Intervention
While Stephens was waging t his campa ign against Dettling , Hall continued to pursue a legion of employment

- related claims against DHS that were pending before the Equal Employment Opportunity Commission and the Merit Systems Protection Board. See Compl. at
2

- 3. Dettling represent ed him in these administrative cases and , in November 2015, negotiate d a
sett l ement of his claims , allegedly with some prodding from the presiding administrative law judge at the MSPB

. See ECF No. 36 (Opposition) at 3. Hall, however, felt the settlement was unfair and fired Dettling for pressuring him to agree to it

. Id. at 4. While the record is a bit hazy
on the timing of this termination , Plaintiff , around this same time, nevertheless signed the
settlement agreement and finalized it before the agency

. See Opp. at 4

- 7.
Hall quickly came down with a bad case of buyer’s remorse, however , and revoked hi s assent shortly thereafter

. See ECF No. 1, Exh. A (MSPB Final Order) at 2. H e later changed his mind again , though, and rescinded that revocation , too

. Id. By the time of this rescission, the record is clear that he had already fired Dettling

. Id. In other words, Hall eventually decided to proceed with the settlement after he had terminated Dettling’s representation

. See Reply, Exh.
A

. But, a t some later point, Hall changed his mind yet a third time and petitioned th e MSPB to
review the validity o f the settlement , claiming that he had been misled into signing it and that the presiding administrative law judge had shown bias in pushing him to do so

. See MSPB Final
Order at 2.
The Board disagreed and dismissed his claim in June 2016 as being previ ously settled

. Id. In so doing, the MSPB hel d t hat Hall could not show that he had been misled about the5 settlement terms by a ny alleged misrepresent at ion from DHS because he had revoked the agreement and then changed his mind only after “carefully considering [his] options.” Id. at 4.
The Board went on to conclude that Hall’s bias claim also failed because it was rooted in a theory that the ALJ had improperly discussed the weakness of his case with Dettling, despite the
fact that such convers ations are within the Board’s applicable rules for such proceedings

. Id. at
5.
Dissatisfied with this resolution , on July 15, 2016, Hall filed this pro se suit against DHS,
the att orney who represented the agency in th e administrative proceed ings, FELSC, Dettling, and
another FELSC attorney . In his Complaint, Hall alleged that the attorneys had misrepresented the terms of the settlement he signed. See Compl. at 1. He further accused Dettling and her firm of incompetence , asserting she had failed to fully explain a clause that restricted his ability to renege on the agreement, fraudulently executed the agreement papers , a nd coerced him into signing the settlement

. Id. at 1, 5. Finally, he accused DHS of violating the Americans with
Di sabil ities Act and other federal laws during his employment

. Id. at 11

- 14.

Before Defendants could answer the Complaint , however, Hall filed a motion revising his initial claims and seeking to cancel his “demand for a jury trial and damages from” Defendants
DH S and FELSC. See ECF No. 7. The Court interpreted this motion as seek ing a voluntar y dismissal of all D efendants except Dettling and grant ed his request via Minute O rder on August
18 , 2016

. The Court further ordered Hall t o show cause why it retained su bject

- matter jurisdiction over his remaining claims against Dettling. Id. Four d ays later, Hall responded by request ing that portions of the case be remanded to the MSPB, while other portions be sent to the Superior Court for the District of Columbia , most notably his ineffective

- representation claims against Dettling

. See ECF No. 8. This Court, accordingly, dismissed the entirety of the case on6 August 25, explaining that Hall had implicitly conceded tha t the Court lacked jurisdiction over
his extant claims against Dettling by his latest filing and his concomitant failure to provide any potential basis for such jurisdiction. See ECF Nos. 9, 10.
D. Stephens’ s Entrance Meanwhile, Stephens had caught wind of the existence of this suit and began m aking

mov es to interv ene in it

. See Mot. to Disq. at 4. On August 4, he ema iled Dettling to say that
Hall’s C omplaint

– which he also attached

– showed that there were more cases that she and her
firm had “botched.” Id. , Exh. F. That very same day, Stephens als o copied her on another brief email, asking her to forward Hall’s email address so that he could offer to represent Hall in the
suit for free. See Mot. to Disq. at 4 (citing exhibit). At the time, Stephens had not yet been admitted to practice before this Court. Id.
A few d ays after the Court t erminated this case, Hall suddenly moved to withdraw his previous request s for a dismissal ; almost simultaneously, Ste phens sought leave to fil e an amicus
curiae brief to establish that this Court did have jurisdiction

. See ECF No s
. 11, 13

. The Court
denied the latter motion , stating in the plainest of terms that it could not b e granted as the “[c]ase
has been dismissed .” See ECF No. 13. In t he interests of justice , however, the Court also ordered that the parties in the case appear for a status hearing in late September. See 9/6/ 16
Minute Order. Prior to this hearing, Stephens filed an appearance to represent Hall, s ee ECF No. 15, which Dettling quickly responded to with her own sealed motion requesting that Stephens be disqualified from serving as counsel given that he had been cyberstalking her and that she had paid him to process the retainer agree ments that were at issue in the case , thus creating a conflict
of interest

. See ECF Nos. 16, 17 ; Mot. at 7. Because Dettling filed her motion under seal and7 Stephens failed to properly register an email with the Court t o receive a copy of such motion s electronically, sh e also overnighted a paper copy to him. See Mot. at 7 & Exh. K. This bevy of motions was only the tip of t he disturbing iceberg to follow. Stephens next contacted the D.C. Bar several times on September 24 to lodge ethics complaint s against Dettling
for an email she copied Hall on to seek his approval to file the motion for disqualification under
seal. Id. , Exhs. L, M. The n , r ather than seek to vacate the dismissal of the case or wait for the
i mminent hearin g to discuss the same , Stephens filed a motion to a mend the Complaint on September 26, though he failed to attach a n y such revised complaint to the motion , as required by the local rules

. See ECF No. 18. Stephens instead spent a significant amount of space in this purported motion laying out f acts related to Dettling’s allegedly poor representation of other
client s
. Id. He also referred to her previous motion to disqualify him as an ex parte communication with this Court, even though he had been mailed a copy, and oddly attached an
unrelated bar complaint against Dett ling that he had encouraged her former clients to file. Id. at
7 & Exh. 3

. Steph ens also sent an email to the Chief Judge of the MSPB around this time ,

a ccusing Dettling of lying about her interactions with the ALJ in Hall’s case. See Mot. to Disq.,
Exh. O

. Days later, a t the scheduled hearing , this Court sought to straighten out the growing mess created by Stephens ’ s frenetic intervention in this case
. T he Court , in particular, asked Stephens

to articulate why it would ha ve jurisdiction over Hall’s claims a nd, as later memorialized in a
Minute O rder, explained to him that he would need to move on Plaintiff’s behalf to vacate the
dismissal before proceed ing with any other motions activity in the suit

. See 9/28/ 16 Minute
Or der. In addition, the Court denied Stephens’s motion to amend without prejudice, directing8 him that Plaintiff could “not move to amend his complaint until he has obtained a vac atur of the
dismissal.” 9 /30/ 16 Minute Order

. Despite these admonitions, t hat very same day, Stephens mailed Dettling a Memorandum
of Law Supporting Motion for Lien. See Mot., Exh. R. This “ motion ” purported to seek a lien
for atto rney fees in the amount of $15,5 00 , though Stephens failed to se nd it to any other
D efendants and did not file it with the Court

. Id. H e also later file d a motion seek ing to
establish jurisdiction, but did not explain why vacatur of the dismissal would be appropriate , despite this Court’s direction to do so

. See ECF No. 19 (self

- titled “Motion for this Court find Subject Matter Jurisdiction, Motion to Vacate Order on Sealed Motion for Leave to File Document Under Seal”). Stephens also failed to wait for the Court to rule on this motion before inexplicably filing a motion for d efault j udgment against De ttling on October 8 , 2016

. See ECF
No. 20. It bears restating that h e filed this latter motion even though the dismissal had not yet been vacated and Dettling was under no duty whatsoever to respond to the still

- dismissed Complaint. Id. Worse still , th ree days later, he filed yet another motion, this time seeking to disqualify Dettling from representing herself as a pro se defendant

. See ECF No. 21.
This unbelievable motions activity

– typically seen only by pro se litigants with no conception of the rules of civil procedure

– forced the Court to issue another Minute O rder on October 11 , again rep eating that the previously filed mot ions must be denied as Hall would first
need to succeed in vacating the dismissal bef ore he could seek any other affirmative relief

. See 10/11/16 Minute Orders. In a separate Minute O rder , the Court also point ed out that Stephens
should be well aware that a pro se litigant like Dettling could not be disqualified from representing herself

. Id. The next day, the Court was obliged to ho ld a second status conference
in this still

- terminated case to try to impose some sense of order on the proceedings . As9 memorialized in a Minute O rder after that hearing , the Court clearly instructed all of the parties
that the case would proceed in the following manner: Dettling would first file a supplemental motion renewing her request for Stephens’ s disqualification , and “ no further motion may be fi led

un til the Court rules on [that] disqualification mot ion

. ” 10/12/ 16 Minute Order (emphasis added)

. The Court might as well have saved its breath rather t han issue this second admonition , as the O rder had no apparent effect on Stephens’ s improper conduct. Just four days later, he filed
another motion for entry of default aga inst Dettling

. See ECF No. 23. The Court denied his
motion again , pointing out that it violated the O rder not to file further motions before a ruling on Dettling’s motion for disqualification

. See 10/17/ 16 Minute Order. Stephens , however, immediately filed another response to “clarify” that he thoug ht this motion for default was an
appro priate supplement to the first motion for the same , which, a s a reminder , the Court had already denied as inappropriate weeks earlier

. See ECF No. 24.
Still u ndeterred, Stephens then filed a notice to withdraw his motion to disqualify Dettling , despite the fact that this motion , too , had already been denied weeks earlier

. See ECF
No. 28. In th is new filing , Stephens also inexplicably co ntinued t o argue that Dettling should be disqualified from representing herself , ignoring the Court’s p revious explanation that a pro se litigant could not be so disqualified

. Id. Beyond all reason, he also attempted to file another
amended com plaint six days later, which this Court again struck

. See ECF No. 29; 10/27/ 16
Minute Order. To cap things off , on October 30, perhaps fearing his disqualification was imminent, Stephens moved to withdraw his appearance in the case , claiming that Plaintiff could no lo nger

“ afford counsel

. ” See ECF No. 31. In response, this Court granted the request, denied as moot10 Dettling’s motion for his disqualifica tion, and ordered a third status hearing to determine whe ther
Plaintiff ( pro se once again) still planned to seek vac atur of the dismissal

. See 10/31/16 M inute
Order. Before that hearing, however, Stephens filed yet another motion, this time to purportedly supplement the amended complaint that the Court had already stricken from the record. See ECF
No. 32. The Court struck this new motion, too, “as it was inexplicably filed by counsel who has
withdrawn from the case.” 11/1/16 Minute Order. At the subsequent hearing, Hall expressed a desire to return the case to the posture it had
been in before Stephens’ ill

- fated intervention so that he could p ursue his claims in other fora

. See 11/14/2016 Minute Order. As a result, t he last m otion left to be resolved in this still

terminated case is the intact M otion for S anctions ag ainst Stephens that Dettling press ed in the
mi dst of his final flurry of activity

. See ECF No. 30

. True to form, Stephens has not respond ed appropriately to the accusations leveled against
him , first requesting a 24

- day extension for leave to file hi s response , see ECF No. 35, and then filing two s eparate responses within three days thereafter

. See E CF Nos. 36, 38 . The Court, accordingly, denied his request for an extension as moot and struck his latter response as improper ly duplicative

. See 11/7/16 Minute Order. At the same time, Stephens also filed a request for transcripts from a ll previous status hearings in the case, and the Court instructed him that he could obtain such transcripts directly from the court reporter. See 11/9/16 Minute Order.
Since then, he has also filed a third response, focused almost exclusively on attacking both Dettling and this Cour t, including, e.g. , a lengthy footnote on “misplaced empathy” that quotes questions and answers given during the Court’s Senate confirmation hearings. See ECF No. 42 ; Id. at 4

- 5 n.4 . This third Response was struck as Stephens had never sought leave to supplement his initial response before filing it

. See 11/29/2016 Minute Order

. The Motion for S anctions11 against him is now ripe , regardless, and the Court finds ample grounds upon which sanctions
should b e imposed

. II. Legal Standard In seeking sanctions here, Dettling principally invokes 28 U.S.C. § 1927. That section provides that “any attorney .

. . who so multiplies the proceedings in any case unreasonably and vexatiously may be required by the court to satisfy personally the excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct.” To qualify as unreasonable and
vexatious behavior , there must be “evidence of recklessness, bad faith, or improper motive” present in the attorney’s conduct. LaPrade v. Kidder Peabody & Co., Inc. , 146 F.3d 899, 906 (D.C. Cir. 1998) ( quoting Travelers Ins. v. St. Jude Hosp. of Kenner, La

. , 38 F.3d 1414, 1416

- 17 (5th Cir

. 1994) )

. A court may infer this malicious intent “from a total lack of factual or legal basis” in an attorney’s filings. Knorr Brake Corp. v. Harbil, Inc. , 738 F.2d 223, 227 (7th Cir.
1984 ). The issuance of such an award is ultimately vested in the dis cretion of the district court. See, e.g. , Lipsig v. Nat’l Student M ktg. Corp. , 663 F.2d 178 , 181

- 82 (D.C. Cir. 1980). This statutory sanction supplement s , but do es not displace, the court’s inherent authority to impose sanctions necessary to achieve the orderly and expeditious disposition of cases before
it. See Chambers v. NASCO, Inc. , 501 U.S. 32, 46

- 47 (1991). U nder this broader authority, which Dettling also cites, a federal court may sanction an attorney who has “acted in bad faith, vexatiously, w antonly, or for oppressive reasons.” Id. at 45 (quoting Aleyska Pipeline Serv. Co. v. Wilderness Soc’y , 421 U.S. 240, 258

- 59 (1975) ) . Actions that “ evince [] bad faith or an egregious disrespect for the Court or judicial process ” may garner sanctions, inc luding contempt
citati ons, fines, awards of attorney fees, and such other orders and sanctions as the court finds12 necessary. Ransmeier v. Mariani , 718 F.3d 64, 68 (2d Cir. 2013); see also Shepherd v. Am.
Broad. Cos. , 62 F.3d 1469, 1477 (D.C. Cir. 1995)

. III. Analysis
The facts underlying this Motion largely speak for themselves. Dettling requests that this
Court sanction Stephens for his frivolous pleadings, misrepresent ations , contemptuous behavior , and failure to abide by the Court’s orders. See Mot. at 2

- 3. She asks, in particular, that this
Court refer his conduct to the D.C. Bar , find him in contempt , enjoin him from filing further pleadings in this matter , and order him to pay costs and expenses that resulted from his improper
behavior in this case

. I d. at 33. As mentioned above, r ather than seek to justify his conduct , Stephens double s down in
his R esponse on his attacks against Dettling’s characte r
. See Resp. (focusing exclusively on Dettling’s honesty, billing practices, and past performance in other cases). In essence, he seems

to argue that the Court should discount her accounting of his misdeeds in this litigation because
she is untrustworthy. But t he Court need only look to the record to find clear and convincing
evidence that Stephens intentionally and maliciously disregarded his professional duties here. Although the bar for imposing Section 1927 sanction s is high, his conduct rises to the challenge . Stephens’s filings did not merely seek the advancement of meritless positions, but they were also composed of largely irrelevant diatribes against Dettling that “ utterly ” lack ed a ny “colorable basis” in law

. See Patton Boggs, LLP v. Chevron Corp. , 825 F. Supp. 2d 3 5, 42 (D.D.C. Aug. 8, 2011) (quoting Kassatly v. Dynaco Acquistion Corp. , 1997 WL 31104, at *3 (D.D.C. Jan. 22, 1997)). I n several instances , he filed motions to allegedly supplement filings that this Court had already denied or stricken from the record a s improper

. See, e.g. , ECF No. 28 (Motion to Withdraw). He also used these motions to insert extraneous attacks against Dettling ’s13 character back into the public record

– in open defiance of the Court’s prior orders d enying or striking his previous motio ns
. Id. His filings, in short, were not germane to the merits of this

case and easily constituted “a path that a reasonably careful attorney would have known, after appropriate inquiry, to be unsound.” In re TCI Ltd. , 769 F.2d 441, 445 (7th Cir. 1985) ; see also
Robertson v. Cartinhour , 883 F. Supp. 2d 121 (D.D.C. 2012) (collecting D.C. Circuit precedents supporting imposition of Section 1927 sanctions for attorney’s filing of frivolous or harassing motions); Walter v. Fiorenzo , 840 F.2d 427, 432

- 33 (7th Cir. 1988) (affirming Section 1927 sanctions imposed for “repeatedly raising arguments previously found to be meritless”)

. Nor does the Court have any difficulty finding bad faith or improper motive. Stephens’s
eff orts did not stem from his desire to z ealously represent his client , but rather from an intent to harm Dettling and smear her reputation. That purpose motivated his entry in to this case as “amicus” all the way through his sudden and voluntary withdrawal. In sum, the Court find s by
clear and convincing evidence that Stephens improperly sought to hijack this terminated suit solely to advance his own personal vendetta against Dettling

. See Oliveri v. Thompson , 803 F.2d 1265, 1273 (2d Cir.1986) (“Like an award made pursuant to the court's inherent power, an award under § 1927 is proper when the attorney's actions are so completely without merit as to require the conclusion that they must have been undertaken for some improper purpose such as delay.”). This is the definition of bad faith. So what is the appropriate remedy? The most obvious in this type of case is to reimburse the opponent’s attorney fees. The difficult y here is that Dettling proceeded as a pro se litigant
and thus did not incur such fees . S he nevertheless likely expend ed some money i n having to defend against Stephens’ s frivolous motions and the ir attacks on her character. See Manion v. Am. Airlines, Inc. , 395 F.3d 428, 432

- 33 (D.C. Cir. 2004) (rejecting sanction s a warding14 defendant lost income for cost of attending he aring under Section 1927, but upholding sanctions for other related costs and expenses). The Court will thus impose sanctions against Stephens, pursuant to Section 1927 , in the amount of any costs and expenses t hat Dettling , in an affidavit,

can establish arose from Stephens’ s filing of ECF Nos. 20, 21, 23, 24, 28, 29, and 32 , as well as those associated with her preparation of her own motion for sanctions

. See First Bank of
Marietta v. Hartford Underwriters Ins. Co. , 307 F.3d 501 (6th Cir. 2002) (affirmi ng sanctions for fees associated with filing successfu l motion for sanctions). These cited moti ons obliged the
Court to call Defendants back into co urt several times in this terminated case, and Dettling is
entitled to receive expenses related to these co nferences as well

. The Court is aware that these sums are not likely to be substantial, but it believes such sanctions will have some deterrent effect on Stephens and others who would conduct themselves in similar fashion. The harassing and repeated nat ure of Stephens’ s filings , as well as his open disregard of
the Court’s repeated and clear orders to cease such behavior , justify the imposition of further
sanctions under the Court’s inherent authority as well

. As a result, the Court will, in addition,

s ubmit this Opinion to the D.C. Bar and the District Court’s Committee on Grievances, either of which may take disciplinary action. Should th is Court’s sanction s fail to deter him, it may need to consider additional measures to protect the institutional integrity of its proceedings and the interests of the litigants that appear before it. See Eash v. Riggins Trucking Inc. , 7 57 F.2d 557, 561 (3d Cir. 1985) (“C ommentators have also note d occasions in which, under its inherent power, a court has disbarred, suspended from practice, or reprimanded attorneys for abuse of the judicial process. ”).15 IV. Conclusion
For the reasons explained above, the Court will issue a contemporaneous Order referring this matter to the D.C. Bar and the District Court’s Committee on Grievances and requiring Stephens to pay any documented expenses arising from Dettling’s defense against his earlier improper actions.

/s/ **James E. Boasberg**  JAMES E. BOASBERG United States District Judge Date: December 1 , 2016