July 28, 1998 REQUEST FOR ADMISSIONS FROM: LARRY PEEBLES, c/o BURNETT REALITY, 13608 - 80TH CIRCLE, MAPLE GROVE, MINNESOTA 55369, in LAMBROS vs. FAULKNER, Civil No. 98-1621.


CERTIFICATE OF SERVICE

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

a. REQUEST FOR ADMISSIONS FROM: LARRY PEEBLES, c/o BURNETT REALTY, 13608 - 80th CIRCLE, MAPLE GROVE, MINNESOTA 55369, dated July 28, 1998;

was served on July 29, 1998, to the following persons:

1. Larry Peebles
c/o Burnett Realty
13608 - 80th Circle
Maple Grove, Minnesota 55369
U.S. Certified Mail No. Z-574-066-824
RETURN RECEIPT REQUESTED

2. Clerk of the Court
District of Minnesota
U.S. Federal Courthouse
316 North Robert Street
St. Paul, Minnesota 55101-1460
U.S. Certified Mail No. Z-574-066-825

Dated: July 29, 1998

Signed:

John Gregory Lambros, Pro Se
Reg. No. 00436-124
USP Leavenworth
P.O. Box 1000
Leavenworth, Kansas 66048-1000 USA

FOR FILING IN LAMBROS vs. FAULKNER, CIVIL NO. 98-1624 (DSD-JMM)


IN THE UNITED STATES DISTRICT COURT
FOR THE STATE OF MINNESOTA

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

Plaintiff

vs.

ESTATE/WILL/BUSINESS INSURANCE OF DECEASED ATTORNEY CHARLES W. FAULKNER, 2680 Sumac Ridge, St. Paul, Minnesota 55110 USA

ATTORNEY SHEILA REGAN FAULKNER, 2680 Sumac Ridge, St. Paul, Minnesota 55110 USA

FAULKNER & FAULKNER, Attorneys-at-Law, 2680 Sumac Ridge, St. Paul, Minnesota 55110 USA;

JOHN & JANE DOE'S, persons employed by Attorney C.W. Faulkner, Sheila Regan Faulkner and Faulkner & Faulkner in the representation of John Gregory Lambros;

Defendants (Severally and jointly liable).

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

DEMAND FOR TRIAL BY JURY, Title 28 USC Rule 38 & 39.

COMPANION CASE NO.
U.S. vs. LAMBROS
, Criminal File No. CR-4-89-82(05), District of Minnesota, Eighth Circuit Court of Appeals No. 65 F.3d 698 (1995).

REQUEST FOR ADMISSIONS FROM:

LARRY PEEBLES, c/o BURNETT REALTY,
13608 - 80th CIRCLE, MAPLE GROVE, MINNESOTA A 55369

Plaintiff Lambros requests LARRY PEEBLES, within thirty (30) days after service of this request to make the following admissions for the purposes of this action.

 

after service of this request to make the following admissions for the purpose of this action.

A. Each of the following statements are TRUE.

1. John Gregory Lambros was a indicted by the Federal Grand Jury in Minnesota due to testimony from Larry Pebbles.

2. I Larry Pebbles was also indicted by the Federal Grand Jury in Minnesota on the same indictment as John Gregory Lambros.

3. I Larry Pebbles told the Federal Grand Jury in Minnesota that I sold marijuana to John Gregory Lambros.

4. I Larry Pebbles told U.S. Drug Enforcement Agents that I sold marijuana to John Gregory Lambros.

5. I Larry Pebbles told U.S. Assistant Attorney Douglas Ray Peterson that I sold marijuana to John Gregory Lambros.

6. Attorney Charles W. Faulkner and/or employees of Attorney Faulkner, who represented John Gregory Lambros during his trial that I testified against John Gregory Lambros, did not interview me before or during John Gregory Lambros trial.

7. I Larry Pebbles was an Attorney in Brazil.

8. I Larry Pebbles was an Attorney in the United States.

9. U.S. Attorney Heffelfinger made promises to Larry Pebbles for testimony against John Gregory Lambros, that included promises not to prosecute for certain criminal offenses and a limit as to the maximum sentence Larry Pebbles could receive.

10. U.S. Assistant Attorney Douglas Ray Peterson made promises to Larry Pebbles for testimony against John Gregory Lambros, that included promises not to prosecute for certain criminal offenses and a limit as to the maximum sentence Larry Pebbles could receive.

11. U.S. Drug Enforcement Agents and Federal Bureau of Investigation Agents made promises to Larry Pebbles for testimony against John Gregory Lambros, that included promises not to prosecute for certain criminal offenses and a limit as to the maximum sentence Larry Pebbles could receive.

12. I Larry Pebbles was a licensed practicing attorney that owned and managed a law firm in St. Paul, Minnesota in the 1980's.

13. I Larry Pebbles as a past licensed practicing attorney in St. Paul, Minnesota, knew and enforced the Minnesota Professional Rules of Conduct of "NEVER OFFERING AN INDUCEMENT TO A WITNESS FOR TESTIMONY AT TRIAL, during the time he legally practiced law.

14. I Larry Pebbles as a past licensed practicing attorney in St. Paul, Minnesota understands that Section 201(c)(2) of Title 18 of the United States Code prohibits giving, offering, or promising anything of value to a witness for or because of his testimony.

15. I Larry Pebbles was told by the United States Attorney's Office in the District of Minnesota, specifically U.S. Assistant Attorney Douglas Ray Peterson, that the maximum sentence Larry Pebbles could receive on Count 1, the conspiracy count, in criminal file No. CR-4-89-82(05), the same indictment that John Gregory Lambros was indicted on in Count 1, was a MAXIMUM OF A LIFE SENTENCE and not a MANDATORY LIFE SENTENCE WITHOUT PAROLE.

Dated: July 28, 1998

Signed:

John Gregory Lambros, Pro Se
Reg. No. 00436-124
USP Leavenworth
P.O. Box 1000
Leavenworth, Kansas 66048-1000


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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.