September 15, 1998 and September 17, 1998, MOTION BY PLAINTIFF FOR SUBSTITUTION OF PERSONAL REPRESENTATIVE OF THE ESTATE OF CHARLES W. FALCONER FOR DECEASED DEFENDANT CHARLES W. FALCONER. [F.R.C.P. Rule 25 (a) (1)] (two (2) pages) and PLAINTIFF'S AFFIDAVIT IN OPPOSITION TO DEFENDANT'S ANSWER. (Eleven (11) pages), both documents served on September 18, 1998, in LAMBROS vs. FALCONER, Civil No. 98-1621. Five (5 pages in length).


CERTIFICATE OF SERVICE

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

a. MOTION BY PLAINTIFF FOR SUBSTITUTION OF PERSONAL REPRESENTATIVE OF THE ESTATE OF CHARLES W. FALCONER FOR DECEASED DEFENDANT CHARLES W. FALCONER. [F.R.C.P. Rule 25 (a) (1)]
dated September 15, 1998;

b. PLAINTIFF'S AFFIDAVIT IN OPPOSITION TO DEFENDANT'S ANSWER.

was served on the following persons this 18th day of September, 1998

1. CLERK OF THE COURT
U.S. DISTRICT COURT
DISTRICT OF MINNESOTA
U.S. Courthouse
Warren E. Burger Federal Building
316 North Robert Street
St. Paul, Minnesota 55101-1460
U.S. CERTIFIED MAIL NO. Z-109-977-401 , 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
U.S. CERTIFIED MAIL NO. Z-109-977-402 , RETURN RECEIPT REQUESTED.

3. INTERNET RELEASE TO ALL HUMAN RIGHTS GROUPS

4. President Fernando Henrique Cardoso & Brazil's Supreme Court Justices/o Ambassador of Brazil, USA
3006 Massachusetts Avenue, N.W.
Washington, D.C. 20008 USA
U.S. Certified Mail No. Z-109-977-381

5. Inter-American Commission on Human Rights
Organization of American States
1889 F. Street, N.W.
Washington, D.C. 20006 USA
U.S. CERTIFIED MAIL NO. Z-109-977-408
RE: TO BE FILED WITH: JUNE 30, 1998, Complaint and released to all 35 countries that are members of the Organization of American States.

John Gregory Lambros, 00436-124
P.O. Box 1000
Leavenworth, Kansas 66048-1000
USA

End of page 1


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. FALCONER, 2680 Sumac Ridge, St. Paul, Minnesota 55110 USA

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

FALCONER & FALCONER, 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;

Defendant's (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).

MOTION BY PLAINTIFF FOR SUBSTITUTION OF PERSONAL REPRESENTATIVE OF THE ESTATE OF CHARLES W. FALCONER FOR DECEASED DEFENDANT CHARLES W. FALCONER. [F.R.C.P. Rule 25 (a) (1)]

Attorney Charles W. Faulkner, the above-named defendant, died on October 6, 1997,

End of page 2

and the estate of defendant has passed into the control of Defendant Sheila Regan Faulkner, the widow of Defendant Charles W. Faulkner, the Personal Representative of the Estate of Charles W. Faulkner, and the partner of Faulkner and Faulkner, Attorneys at Law, as stated in Sheila Regan Faulkner's ANSWER, dated September 8, 1998.

WHEREFORE, Plaintiff moves for an order, if legally correct, substituting Defendant Sheila Regan Faulkner, the PERSONAL REPRESENTATIVE OF THE ESTATE OF CHARLES W. FALCONER, in place of ESTATE/WILL/BUSINESS INSURANCE OF DECEASED ATTORNEY CHARLES W. FALCONER. Plaintiff read Rule 25(a)(1) and the above does not make sense to him as the estate lives on and Defendant Sheila Regan Faulkner would in this Plaintiff thoughts automatically represent the estate. Plaintiff requests the Courts ASSISTANCE in this matter as Plaintiff is trying to follow the rules. THANK YOU. Plaintiff still wants the ESTATE/WILL/BUSINESS INSURANCE.

Dated: September 15, 1998

Signed:

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

End of page 3


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://members.aol.com/BrazilByct
http://adpages.com/usal/brazilct.htm
http://adpages.com/andreaci.htm
http://members.aol.com/LambrosLDF
http://members.aol.com/BraziLien
http://members.aol.com/Lambrosb1 (final digit number 1)
http://www.brazilboycott.org

Plaintiff

vs.

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

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

FALCONER & FALCONER, 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).

PLAINTIFF'S AFFIDAVIT IN OPPOSITION TO DEFENDANT'S ANSWER


COMES NOW, John Gregory Lambros, Plaintiff in the above-entitled action, stating in affidavit form, opposition to Defendant's ANSWER dated September 8,1998, filed September 9, 1998, and served on Plaintiff by Leavenworth police at U.S.P. Leavenworth, Kansas on September ll, 1998.

End of page 4

 

John Gregory Lambros declares under penalty of perjury:

1. I am the plaintiff in the above-entitled case. I make this declaration in the opposition to defendants' ANSWER as to all pleadings filed by Plaintiff to the clerk of court in this above-entitled case.

2. Plaintiff denies each and every material allegation contained in DEFENDANTS ANSWER, except as hereinafter may be expressly and specifically admitted.

3. Attorney Sheila Regan Faulkner states that she is responding for the ANSWER to Plaintiffs complaint. Attorney Sheila Regan Faulkner did not sign the ANSWER nor is the ANSWER verified. Attorney Donna Rae Johnson signed the ANSWER and did not offer a declaration under the penalty of perjury that it was true and correct. As this Court knows,"statements by counsel in brief's or in en court are not part of the record and will not be treated as such by the Courts of Appeals unless stipulated to or the statements are matters of public record, and cannot be bases of summary judgment." See, KAUFFMAN vs. JOHNSTON, 454 F.2d 264, 266 (3rd Cir. 1972.

4. Plaintiff places all Defendant's and Attorney Johnson on NOTICE as to Attorney Johnson's fiduciary relationship and obligation of diligent and faithful service in connection with the preparation and expeditious disposal of this action and to review the options this Plaintiff has in requesting MOTIONS FOR SANCTIONS, based on violations of 28 U.S.C. §1927 and Federal Rules of Civil Procedure, Rule 11.

5. Defendant Attorney Sheila Regan Faulkner, (hereinafter S.R. Faulkner) states that she is the widow of Charles W. Faulkner, the personal representative of the Estate of Charles W. Faulkner, and the partner of Faulkner and Faulkner, Attorneys at Law, and that she makes the ANSWER for all four defendants above named.

End of page 6

6. Plaintiff accepts S.R. Faulkner is the widow of C.W. Faulkner.

7. Plaintiff has been notified correctly on the record that S.R. Faulkner is the "personal representative of the Estate of Charles W. Faulkner," thus it is Plaintiff's assumption that Defendant's attorney will be submitting a motion for CORRECT SUBSTITUTION of the deceased party under Rule 25(a)(1). Plaintiff, not legally trained, has attached a "MOTION BY PLAINTIFF FOR SUBSTITUTION OF PERSONAL REPRESENTATIVE OF THE ESTATE OF CHARLES W. FALCONER FOR DECEASED DEFENDANT CHARLES W. FALCONER. [F.R.C.P. RULE 25(a)(1)]." Plaintiff believes that such a motion is required within 90 days. Plaintiff also requests this Court to notify this Plaintiff if the language is not correct as the rules were confusing as to if the PERSONAL REPRESENTATIVE IS AUTOMATICALLY THE CORRECT SUBSTITUTION. Thank you.

8. Plaintiff accepts S.R. Faulkners' response that she is the personal representative and a partner of Faulkner and Faulkner.

9. Plaintiff stated on the cover-page of this action that all defendants were SEVERALLY AND JOINTLY LIABLE.

10. Plaintiff believes that Defendant S.R. Faulkner has only the legal right to ANSWER for the following defendant's due to the agency relationship and fiduciary relationship of defendant's JOHN AND JANE DOE'S that Plaintiff has not been offered the opportunity to complete discovery and Defendant S.R. Faulkner has not yet complied with Plaintiff's discovery requests:

a. S.R. Faulkner;

b. Faulkner and Faulkner;

c. Charles W. Faulkner's Estate/Will/Business Insurance.

11. Defendant S.R. Faulkner states that Defendant Charles W. Faulkner

End of page 7

was appointed, individually, as a public defender, to represent Plaintiff, and that neither S.R. Faulkner, individually, nor Faulkner and Faulkner, were appointed in that capacity. Neither has any knowledge or any involvement in the litigation described in Plaintiff's complaint, and the action must be dismissed against them forthwith. In fact, liability does extend to S.R. Faulkner and Faulkner & Faulkner.

12. Plaintiff Lambros states that Charles W. Faulkner and S.R. Faulkner were partners in the law firm of FALCONER & FALCONER. Plaintiff's research with the Minnesota Secretary of State indicates that Faulkner & Faulkner was not a registered Minnesota corporation and no records exist within the Minnesota Secretary of State's Office.

13. Plaintiff Lambros and the Lambros family attorneys were all advised that Charles W. Faulkner and Faulkner & Faulkner represented Plaintiff Lambros. All correspondence to Plaintiff Lambros and Lambros' family attorneys where on FALCONER AND FALCONER stationary. See, EXHIBIT H in original complaint and EXHIBIT M-1 in original complaint as to correspondence to Defendant C.W. Faulkner of FALCONER & FALCONER. Plaintiff also states that he consulted with agents and/or employees of FALCONER & FALCONER during the time of his legal representation by Defendant C.W. Faulkner as to Plaintiff's legal proceedings.

14. Clearly, FALCONER & FALCONER has not established that it owed no duty to Plaintiff. Defendant's dream of a "Chinese Wall" preventing fiduciary or trustee duty to Plaintiff is nonexistent. Plaintiff had and did have the absolute right to FALCONER & FAULKNER'S undivided loyalty as a law firm. This Court only has to ask one question: If FALCONER & FALCONER had sued or attempted to sue a client on behalf of another client, would they not have been disqualified? See, CONNELLY vs. WOLF, BLOCK, SCHORR AND SOLIS-COHEN, 463 F. Supp. 914 (D.C. Pa. 1978)

End of page 6

(In order for a plaintiff to recover against a defendant law firm in a legal malpractice case, it is generally essential that an attorney-client relationship have existed between parties.); FUND OF FUNDS, LTD. vs. ARTHUR ANDERSEN & CO., 567 F.2d 225 (C.A.N.Y. 1977)(Law firm's duty to client was tantamount to that of fiduciary or trustee.)

15. Plaintiff states that Defendant S.R. Faulkner admitted, RULE 36, within the attached "REQUEST FOR ADMISSIONS FROM DEFENDANT SHEILA~ REGAN FALCONER," dated June 15, 1998, and served by the U.S. Marshals on July 21, 1998, that FALCONER & FALCONER represented Plaintiff Lambros. See, STATEMENT 5. (EXHIBIT A)

16. Plaintiff states Defendant S.R. Faulkner also admitted, RULE 36 within Plaintiff's June 15, 1998, request for ADMISSIONS that she worked at and was a partner in the law firm FALCONER & FALCONER. See, (EXHIBIT A)

17. Plaintiff respectfully requests this Court to enter into the Court record ALL TRUTHFUL ADMISSIONS from Defendant S.R. Faulkner, as per F.R.C.P. Rule 36, as submitted within Plaintiff's "REQUEST FOR ADMISSIONS FROM DEFENDANT SHEILA REGAN FALCONER," dated June 15, 1998. See, (EXHIBIT A)(25 admissions total)

18. In Defendant S.R. Faulkner's ANSWER, statement #3, states: That defendants deny each and every allegation set forth in Plaintiff's complaint, and hold the Plaintiff to strict proof thereof. In fact, Plaintiff is confused, as Defendant S.R. Faulkner is now making a false statement and/or perjury due to her ADMISSIONS.

19. Plaintiff states that Defendants have already agreed with each and every allegation set forth in Plaintiff's Declaratory Judgment Action/ Complaint that was served on July 21, 1998, by the U.S. Marshals Service with copy of Plaintiff's June 15, 1998, REQUEST FOR ADMISSIONS FROM DEFENDANT SHEILA REGAN FALCONER, that was also served with the Plaintiff's June 15, 1998, Plaintiff's Declaratory Judgment Action/Complaint. Please refer to statement number 25:

end of page 7

"Sheila Regan Faulkner, Defendant in this action agrees with all statements within Plaintiff's initial Declaratory Judgment Action/Complaint filed and served to the United States District Court for the District of Minnesota in this action and all statements within the Commercial Lien filing she has received to date."

20. Defendant's state Plaintiff fails to state a cause of action against Defendants upon relief can be granted, and this action must be dismissed. In fact, Plaintiff filed numerous causes of action contained within:

a. Plaintiff's June 15, 1998, DECLARATORY JUDGMENT ACTION/COMPLAINT;

b. Plaintiff's July 20, 1998, MOTION TO SUPPLEMENT THIS DECLARATORY JUDGMENT ACTION/COMPLAINT PURSUANT TO FRCP 15(a);

c. Plaintiff's August 20, 1998, SECOND MOTION TO SUPPLEMENT THIS DECLARATORY JUDGMENT ACTION/COMPLAINT PURSUANT TO FRCP 15(a).

21. Plaintiff's stated causes of action as outlined in paragraph 20, Defendant S.R. Faulkner's ADMISSIONS and forthcoming responses to INTERROGATORIES will clearly prove all allegations within Plaintiff's complaint, thus this action may not be dismissed and must proceed to jury trial.

22. Defendant S.R. Faulkner states that the Court does not have jurisdiction over the subject matter. In fact, this Court does have jurisdiction "even if the only claim that is 'completely preempted' by Federal Law, federal subject matter jurisdiction exists." See, METROPOLITAN LIFE INS. CO. vs. TAYLOR, 481 U.S. 58, 63-64 (1987) ("Complete Preemption Doctrine," provides that "Congress may so completely preempt a particular area that a civil complaint raising this select group of claims is necessarily federal in character.") Plaintiff offered his jurisdictional statements on pages 2, 3, 4, and 5 of his June 15, 1998, DECLARATORY JUDGMENT ACTION/COMPLAINT. In addition, Federal subject matter jurisdiction is conferred by section 1964(c), which creates the civil RICO cause

end of page 8

of action. Personal jurisdiction is conferred by section 1965, which authorizes nationwide service of process. See, LISAK vs. MERCANTILE BANCORP, INC., 834 F.2d 668 (7th Cir. 1987), cert. denied, 485 U.S. 1007 (1988). Section 1965(a), the principle venue provision, permits a party to institute a civil RICO action in any district in which a defendant "resides, is found, has an agent, or transacts his affairs." Section 1965(b) provides that as long as one defendant is subject to service in a district, additional parties residing in other districts may be brought before the forum court, in the court's discretion, to the extent that "THE ENDS OF JUSTICE REQUIRE." State courts have concurrent jurisdiction over civil RICO claims under the Supreme Court's decision in TAFFLIN vs. LEVITT, 493 U.S. 455 (1990).

23. Defendant's state Charles W. Faulkner died on October 6, 1997, and this pretended cause of action died with him. In fact, this cause of action is not "PRETENDED," as the statutory limitation have either resurrected or never died. Legal Malpractice actions in the State of Minnesota have a statutory life of six (6) years. See, DUNNELL MINNESOTA DIGEST, 4th Edition, Vol. 4, Butterworth Legal Publishers, ATTORNEYS §11.00(f). Civil RICO actions are subject to a four year statute of limitations. See, AGENCY HOLDING CORP. vs. MALLEY-DUFF & ASSOCS, INC., 483 U.S. 143 (1987); or six (6) years, §1346(a)(2), where said Defendants have willfully violated Plaintiffs CONSTITUTIONAL RIGHTS. Plaintiff suggests that Defendants start studying the duration of the RICO statute of limitations, as AGENCY HOLDING CORP. does not address when a civil RICO claim ACCRUES.

24. Plaintiff states that the Minnesota Survival of Action for legal malpractice, by statute, claim survives the death of either party. See, JACKSON vs. TAYLOR, 435 N.W.2d 127 (Minn. Ct. App. 1989); Minnesota statute §573.01.

25. Defendants state in paragraph seven (7) that they have no information with which to form a belief as to the accuracy of any of Plaintiff's

End of page 9

allegations and claims, and Plaintiff failed to initiate his action within the appropriate Statute of Limitations period and is therefore precluded from bringing this action.

26. Plaintiff can only respond with a smile on his face, as this court is too, as Defendants only need to go to the Clerks office and the U.S. Attorneys Office and request all records in this case. In fact, all records are available at no cost if they scan the records into there lap top computer. Plaintiff would strongly suggest the use of the AD~BE ACROBAT 3.0.1 software program which enables you to retain the exact format of any document and allows the document to be searched. Currently the Los Angeles Times and the IRS use the ADOBE ACROBAT 3.0.1 software for converting electronic files and paper documents to publish on-line into web sites because they're always exact, can't be altered, and look just like the original forms. The software cost is only $190.00. Plaintiff has addressed the Statute of Limitations in the above paragraphs.

27. On July 22, 1998, Plaintiff Lambros served the Court with his "MOTION TO SUPPLEMENT THIS DECLARATORY JUDGMENT ACTION/COMPLAINT PURSUANT TO FRCP 15(a)," dated July 20, 1998. Within Plaintiff's SUPPLEMENTAL filing, Plaintiff offered information and facts as to DEFENDANT'S FAILURE TO MOVE THE COURT TO SUPPRESS TESTIMONY OF PERSONS TESTIFYING AT PLAINTIFF'S TRIAL IN VIOLATION OF TITLE 18, U.S.C. § 201(c)(2). Plaintiff also cited the recent ruling in U.S. vs. SINGLETON, 144 F.3d 1343 (lOth Cir. 1998), in support of same. On July 10, 1998, the Tenth Circuit vacated the SINGLETON opinion and granted a rehearing en banc. Although SINGLETON is no longer of precedential value, THIS PLAINTIFF ADOPTS IN ITS ENTIRETY the reasoning of the SINGLETON court.

28. This Plaintiff also adopts in its entirety the reasoning and ORDER dated August 4, 1998, of U.S. District Judge William J. Zloch, Southern District

End of page 10

of Florida, in U.S. vs. LOWERY, No. 97-368 CR-ZLOCH, 1998 WL 493818. Judge Zloch issued an ORDER as to Defendant Lowery's "MOTION TO SUPPRESS THE ANTICIPATED TESTIMONY OF HIS THREE CO-DEFENDANTS, AS THE PLEA AGREEMENT IN THIS MATTER SECURED SUCH TESTIMONY IN VIOLATION OF TITLE 18, U.S.C., Section 201(c)(2)."

29. Judge Zloch ORDER in LOWERY offered an excellent overview on Title 18, U.S.C., Section 201(c)(2), including the following quotes:

a. Moreover, the Constitutional form of Government which has guided this country for over two-hundred and twenty years demands that the Executive Branch be subject to the laws enacted by the United States Congress. At last glance, the United States was a democracy - not a monarchy. Thus, neither the United States Attorney, the Department of Justice nor the Executive Branch is above the law, but is subject to it in the same manner and to the same degree as an ordinary citizen. That is, the Executive Branch may not pick and choose which laws it will follow and which it will disregard. Accordingly, the Court finds that the Executive Branch and its agents are unquestionably subject to the provisions of Section 201(c)(2). (page 4)

b. In addition, to the extent that one may argue that this Court's interpretation of Section 201(c)(2) is at odds with the legislative scheme of the Statute, this argument is easily dismissed. Section 201(c)(1) expressly EXCLUDES the Executive Branch from its reach. Section 201(c)(2) DOES NOT. Therefore, reading both Sections together leads to the obvious conclusion that Congress intended one Section to include the Executive Branch and the other to exempt the Executive Branch. Why Congress chose to differentiate between these two Sections is not for this Court to surmise. That Congress explicitly did so, however, is a clear indication that this Court has given the terms in Section 201(c)(2) their proper scope. (page 5)

c. Ordinarily, courts should not create a remedy where Congress has already provided one. . . . However, "[f]ederal courts sit to enforce federal law." U.S. vs. CHEMALY, 741 F.2d 1346, 1354 n.2 (11th Cir. 1984). Therefore, there must be some means by which the Court may compel obedience to Section 201(c)(2). Accordingly the Court is left to fashion an appropriate judicial remedy. See, U.S. vs. CALANDRA, 414 U.S. 338, 347-48 (1974) (page 8)

End of page 11

d. *13 Further, if, as the Executive Branch asserts, Section 201(c)(2) obviously excludes the Executive Branch, the Court feels compelled to question the need for legislation, hurriedly introduced in the wake of SINGLETON on July 15, 1998, TO AMEND THE STATUTE. See, S. 2314, 105th Cong. (1998). BY SUCH ACTION, CONGRESS HAS REINFORCED THE CONCLUSION THAT SECTION 201(c)(2) PRESENTLY INCLUDES THE EXECUTIVE BRANCH. (page 9)

30. Plaintiff reminds Defendant's that summary judgment is only appropriate "if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law." Fed.R.Civ.P. 56(c); accord ANDERSON vs. LlBERTY LOBBY, INC., 477 U.S. 242, 247 (1986). The moving party has the initial burden of showing that there is no genuine issue of material fact. CELOTEX CORP. vs. CATRETT, 477 U.S. 317, 323 (1986). Plaintiff strongly suggests that Defendant's have showed no genuine facts to contest the factual record and reasonable inferences therefrom in the light most favorable to Plaintiff for this Court to dismiss this action.

31. Plaintiff again states to the Court that he has not had an opportunity to complete discovery and the Defendant's have not yet complied with this Plaintiff's discovery requests.

32. Plaintiff requests that this Court deny, or at least stay, the Defendant's request to dismiss this action until Plaintiff has obtained the necessary information.

33. These factual disputes cannot be resolved without a jury trial.

WHEREFORE, Defendant's request to dismiss this action within Defendant's September 8, 1998, ANSWER should be denied.

End of page 12

Plaintiff also informs this Court and the Defendant's in this case that he is still being tortured and controlled daily due to his depatterning and forced implantation of brain control implants by Brazilian Government Officials, that monitor and control this Plaintiff's mental functions, thoughts, and deeds. Please review all Internet web sites listed within the heading of this action, as they are incorporated within this cause of action.

DATED: September 17, 1998

John Gregory Lambros, Pro Se & Supporters of "BOYCOTT BRAZIL"
Reg. No. 00436-124
USP Leavenworth
P.O. Box 1000
Leavenworth, Kansas 66048-1000
USA

I declare under penalty of perjury that the foregoing is true and correct. Title 28 U.S.C.A. 1746.

Signed this 17th day of September, 1998

John Gregory Lambros

End of page 13

 


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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.