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