high. "While there is no bright line rule as to what constitutes 'repeatedly', most cases affirming the vexatious litigant designation involve situations where litigants have filed dozens of motions either during the pendency of an action or relating to the same judgment." Repeated motions must be "so devoid of merit and be so frivolous that they can be described as a flagrant abuse of the system, have no reasonable probability of success, lack reasonable or probable cause or excuse, and are clearly meant to abuse the processes of the courts and to harass the adverse party than other litigants." Evidence that a litigant is a frequent plaintiff or defendant alone is insufficient to support a vexatious litigant designation. The moving party, in addition to demonstrating that the plaintiff is vexatious, must make an affirmative showing based on evidence that the case has little chance of prevailing on the merits. If the plaintiff is so determined, a bond may be required, and if the bond requirement is not met within a specified time period, a judgment of dismissal is ordered. A finding of vexatiousness is not an appealable order, but a dismissal for failure to post a bond requirement based on a judgment of vexatiousness is appealable. Habeas petitions do not count towards vexatious litigant determination. Vexatiousness in Probate Actions have a lower standard. Notable vexatious litigants Lawrence Bittaker, who together with his partner Roy Norris was convicted of torturing, raping and murdering five young girls in 1979, filed 40 separate frivolous lawsuits against the state of California, including one claiming "cruel and unusual punishment" after being served a broken cookie. In 1993, he was declared a vexatious litigant and was forbidden from filing lawsuits without the permission of a lawyer or a judge. Alexander Chaffers, a solicitor whose actions led to the first British law against vexatious litigation, the Vexatious Actions Act, 1896. Chaffers became notorious after accusing the wife of Travers Twiss of being a prostitute, and subsequently issued 48 proceedings against leading members of Victorian society in the 1890s. Costs awarded against Chaffers were never paid. After the act was passed, he became the first person to be declared a habitually vexatious litigant and barred from future litigation without judicial permission. Valery Fabrikant, a former Concordia University professor serving a life sentence for the murders of four colleagues in 1992. Julian Knight, convicted of the Hoddle Street massacre