December 11, 1999. PLAINTIFF'S MOTION REQUESTING COURT TO COMPEL DEFENDANTS TO DISCLOSE NAMES AND ADDRESSES OF ALL INSURANCE COMPANIES THAT MAY HAVE LIABILITY FOR CLAIMS WITHIN THIS ACTION, SO PLAINTIFF MAY FILE ATTACHMENTS ON INSURANCE CONTRACTS. FEDERAL RULES OF CIVIL PROCEDURE, RULE 64. Total of three (3) pages including CERTIFICATE OF SERVICE.

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

JOHN GREGORY LAMBROS

Plaintiff

vs.

CHARLES W. FAULKNER, SUED AS ESTATE/WILL/BUSINESS INSURANCE OF DECEASED ATTORNEY CHARLES W. FAULKNER

ATTORNEY SHEILA REGAN FAULKNER

FAULKNER & FAULKNER

JOHN & JANE DOE'S

Defendants

CIVIL CASE NO.
98-1621 (DSD-JMM)

VERIFIED MOTION

PLAINTIFF'S MOTION REQUESTING COURT TO COMPEL DEFENDANTS TO DISCLOSE NAMES AND ADDRESSES OF ALL INSURANCE COMPANIES THAT MAY HAVE LIABILITY FOR CLAIMS WITHIN THIS ACTION, SO PLAINTIFF MAY FILE ATTACHMENTS ON INSURANCE CONTRACTS. FEDERAL RULES OF CIVIL PROCEDURE, RULE 64.

COMES NOW, JOHN GREGORY LAMBROS, Plaintiff, Pro Se, requesting this Court to ORDER Defendants:

a. Estate of Charles W. Faulkner;
b. Will of Charles W. Faulkner;
c. Business Insurance of Charles W. Faulkner;
d. Sheila Regan Faulkner;
e. Faulkner & Faulkner.
to disclose names and addresses of all insurance companies that maintained

insurance contracts with each defendant, individual or joint capacity, from the
years 1992 thru present, so Plaintiff Lambros may seize the insurance policies
under which insurer may be liable for a claim asserted against its insured.

LAW:

1. RINTALA vs. SHOEMAKER, 362 F.Supp. 1044, 1045 (District of Minnesota 1973) (Head Note 9, Insurance), Under Minnesota garnishment statute providing

Page 1.

that garnishment shall be permitted BEFORE JUDGEMENT for purpose of establishing quasi- in rem jurisdiction when garnishee and debtor are parties to a contract of insurance because of which the garnishee may be held to respond to any person for claim asserted against the debtor in main action, insurance contract is attachable if all or any part of it may be used to ultimately satisfy the judgement, but there may be no recovery in excess of face amount of the policy.

CONCLUSION:

2. Plaintiff Lambros respectfully requests that this Court ORDER the above named five (5) defendants to disclose all names and addresses of all insurance companies that have individual or joint insurance policies with the above named five (5) defendants from the years 1992 thru present, so Plaintiff may serve and insurance companies as to garnishment of those policies.

DATED: December 11, 1999.

JOHN GREGORY LAMBROS, Pro Se
Reg. No. 00436-124
USP Leavenworth
PO Box 1000
Leavenworth, Kansas 66048-1000

CERTIFICATE OF SERVICE

LAMBROS vs. FAULKNER et al., CIVIL CASE NO. 98-1621 (DSD/JMM)

I hereby state under the penalty of perjury that a true and correct copy of the following:

a. PLAINTIFF'S MOTION REQUESTING COURT TO COMPEL DEFENDANTS TO DISCLOSE NAMES AND ADDRESSES OF ALL INSURANCE COMPANIES THAT MAY HAVE LIABILITY FOR CLAIMS WITHIN THIS ACTION, SO PLAINTIFF MAY FILE ATTACHMENTS ON INSURANCE CONTRACTS. FEDERAL RULES OF CIVIL PROCEDURE, RULE 64. Dated December 11, 1999.

was served on the following persons this 13th day of December, 1999, via U.S. Mail through the USP Leavenworth mailroom, to:

1. CLERK OF THE COURT
U.S. DISTRICT COURT
DISTRICT OF MINNESOTA
316 North Robert Street
St. Paul, Minnesota 55101-1460
U.S. CERTIFIED MAIL NO. Z-233-381-481 , RETURN RECEIPT REQUESTED.
One original and one copy

2. Attorney Donna Rae Johnson
Attorney No. 50945
Attorney for Defendant's
700 St. Paul Building
6 West Fifth Street
St. Paul, Minnesota 55101

3. INTERNET RELEASE TO ALL HUMAN RIGHTS GROUPS

4. Inter-American Commission on Human Rights
Organization of American States
1889 F. Street, N.W.
RE: TO BE FILED WITH: JUNE 30, 1998, Complaint and released to all 35 countries that are members of the Organization of American States.

5. Judge Baltasar Garzon of the National Court of Madrid, Spain
Audiencia National
Garcia Gutierrez, #1
Madrid, Spain 28004
RE: TO BE FILED WITH: January 5, 1999, REQUEST FOR ADMISSIONS, mailed on January 7, 1999 and received by Judge Garzon on January 25, 1999.

JOHN GREGORY LAMBROS, #00436-124
USP Leavenworth
PO Box 1000
Leavenworth, Kansas 66048-1000, USA
Web site: www.brazilboycott.org

End of Certificate of Service

 

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For more information write (snail mail) JOHN GREGORY LAMBROS directly at:

JOHN GREGORY LAMBROS
Prisoner No. 00436-124
U. S. Penitentiary Leavenworth
PO Box 1000
Leavenworth, KS 66048-1000
USA

THANK YOU FOR YOUR SUPPORT AND ASSISTANCE IN MY BOYCOTT OF BRAZILIAN PRODUCTS.