November 19, 1999, and November 20, 1999. PLAINTIFF LAMBROS' OBJECTION TO THE ORDER OF U.S. DISTRICT COURT JUDGE DAVID S. DOTY, DATED NOVEMBER 15, 1999, AS TO PLAINTIFF'S MOTION FOR SANCTIONS AGAINST DEFENDANTS' ATTORNEYS UNDER FEDERAL RULE OF CIVIL PROCEDURE 11 AND 28 U.S.C. 1927 BEING DENIED. Total of one (1) page. Also, SUPPLEMENTAL INFORMATION AS TO PLAINTIFF LAMBROS' REQUEST FOR SANCTIONS AGAINST DEFENDANTS ATTORNEYS UNDER A COMBINATION OF RULE 11 AND SECTION 1927. Total of four (4) pages. Combined total of both documents with CERTIFICATE OF SERVICE is six (6) pages. NO EXHIBITS SCANNED.
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 attached:
a. PLAINTIFF LAMBROS' OBJECTION TO THE ORDER OF U.S. DISTRICT COURT JUDGE DAVID S. DOTY, DATED NOVEMBER 15, 1999, AS TO PLAINTIFF'S MOTION FOR SANCTIONS AGAINST DEFENDANTS' ATTORNEYS UNDER FEDERAL RULE OF CIVIL PROCEDURE 11 AND 28 U.S.C. 1927 BEING DENIED.
b. Exhibit A, attachment, "SUPPLEMENTAL INFORMATION AS TO PLAINTIFF LAMBROS' REQUEST FOR SANCTIONS AGAINST DEFENDANTS ATTORNEYS . . ." Dated November 19, 1999
was served the 22nd day of November, 1999, via U.S. Mail through the USP Leavenworth mailroom, to:
1. CLERK OF THE COURT
DISTRICT OF MINNESOTA
316 North Robert Street
St. Paul, Minnesota 55101-1460
One original and one copy
U.S. CERTIFIED MAIL NO. Z-233-380-976
2. Attorney Donna Rae Johnson
Attorney Donna Ellis
700 St. Paul Building
6 West Fifth Street
St. Paul, Minnesota 55101
3. INTERNET RELEASE TO BOYCOTT BRAZIL SUPPORTERS AND HUMAN RIGHTS GROUPS GLOBALLY
4. Inter-American Commission on Human Rights
Organization of American States
1889 F. Street, N.W.
Washington, D.C. 20006 USA
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
End of Certificate of Service
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 LAMBROS' OBJECTION TO THE ORDER OF U.S. DISTRICT COURT JUDGE DAVID S. DOTY, DATED NOVEMBER 15, 1999, AS TO PLAINTIFF'S MOTION FOR SANCTIONS AGAINST DEFENDANTS' ATTORNEYS UNDER FEDERAL RULE OF CIVIL PROCEDURE 11 AND 28 U.S.C.§1927 BEING DENIED
COMES NOW, JOHN GREGORY LAMBROS, Plaintiff, Pro Se, requesting to object to this Courts ORDER dated November 15, 1999, as to Plaintiff's motion for sanctions against defendants' attorneys under FRCP 11 and Title 28 U.S.C.
§1927 being denied, due to NEWLY DISCOVERED INFORMATION.
1. Plaintiff received this Courts November 15, 1999, ORDER on November 19, 1999, at 4:30 P.M.
2. Plaintiff completed the attached motion entitled, "SUPPLEMENTAL INFORMATION AS TO PLAINTIFF LAMBROS' REQUEST FOR SANCTIONS AGAINST DEFENDANTS' ATTORNEYS UNDER A COMBINATION OF RULE 11 AND SECTION 1927, DATED SEPTEMBER 4, 1999," at approximately 2:45 P.M. EXHIBIT A.
3. Plaintiff submits EXHIBIT A. for this courts review.
EXECUTED: November 20, 1999.
JOHN GREGORY LAMBROS, Pro Se
Reg. No. 00436-124
USP Leavenworth
PO Box 1000
Leavenworth, Kansas 66048-1000
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
SUPPLEMENTAL
INFORMATION AS TO PLAINTIFF LAMBROS' REQUEST
FOR SANCTIONS AGAINST DEFENDANTS ATTORNEYS UNDER A COMBINATION OF
RULE 11 AND
SECTION 1927, DATED SEPTEMBER 4, 1999.
COMES NOW, JOHN GREGORY LAMBROS, Plaintiff, Pro Se, requesting to
SUPPLEMENT INFORMATION as to his
September 4, 1999, "PLAINTIFF LAMBROS' REQUEST FOR SANCTIONS AGAINST
DEFENDANTS ATTORNEYS UNDER A
COMBINATION OF RULE 11 AND SECTION 1927." Plaintiff Lambros thinks
that criminal charges may be appropriate
against Defendant Sheila Regan Faulkner for lying to this court
within her
December 14, 1998,
AFFIDAVIT,
paragraph three (3), which states:
I am also an attorney, and I have never been employed as a Federal
Public Defender, but I am employed part time by Hennepin County as a
Public Defender. We both pr practice in these fields separately,
AND WE WERE EACH PAID SEPARATELY, UNDER OUR OWN SOCIAL SECURITY
NUMBERS, NOT THE FEDERAL ID NUMBER OF FAULKNER & FAULKNER.
(EXHIBIT A, December 14,
1998, AFFIDAVIT)
NEWLY DISCOVERED INFORMATION:
1. On November 17,
1999, Plaintiff
received copy of the "Instructions
Page 1
for Completing the
CJA Form 20: APPOINTMENT OF AND AUTHORITY TO PAY COURT APPOINTED
COUNSEL," for the United States District Court, District of
Minnesota, c/o Federal Defender Office, Suite 107, U.S. Courthouse,
300 South Fourth Street, Minneapolis, Minnesota 55415, Tel. (612)
664-5858, dated 03/22/99. (EXHIBIT B, Cover page and pages one
(1), two (2), and three (3).)
2. Page two and three of INSTRUCTIONS FOR COMPLETING THE CJA FORM
20, clearly states the procedure for REPORTING CJA INCOME AS FIRM
INCOME RATHER
THAN PERSONAL INCOME OF THE ATTORNEY AS THE FINANCIAL
RELATIONSHIP
OF THE ATTORNEY
WITH THE FIRM DICTATES HOW THE INCOME SHOULD BE REPORTED.
3. BLOCK 16A: states, "Check 'Yes' -- If you have a
preexisting agreement with a corporation, including a
professional corporation, that CJA EARNINGS BELONG TO THE
CORPORATION, CHECK THE BOX "YES", you are then required to
complete boxes 16C and 16D -- firm tax id number, name and
address."
4. BLOCK 16B: states, "Enter your social security number
EXCEPT if you have a preexisting agreement with a law firm or
corporation, including a professional corporation, that CJA earnings
belong to the law firm or corporation. If the social security number
is entered, leave items 16C and-D blank and proceed directly to Item
17."
5. BLOCK 16C: states, "Enter the law firm's employer identification
number if you have a preexisting agreement with a law firm (or a
corporation) that the CJA earnings belong to the law firm (or
corporation)).
ATTORNEY CHARLES W. FAULKNER'S CJA FORM 20, DATED FEBRUARY 17,
1994, VOUCHER NO. 0380221, FOR TOTAL COMPENSATION OF $16,560.00
6. Defendant Charles W. Faulkner stated within his CJA Form 20
the following facts:
a. BLOCK 16A: YES, that he has a preexisting agreement within a
corporation, including a professional corporation.
Page 2.
b. BLOCK 16B: This blank
was not typed in, as it requested Defendant Charles Faulkner's SOCIAL
SECURITY NUMBER, if the earning were to belong DIRECTLY of
Defendant Charles Faulkner.
C.
BLOCK 16C: Defendant
Charles Faulkner entered the law firm FAULKNER & FAULKNER'S
employer I.D. Number 41-153-4878. Therefore, all CJA EARNINGS
BELONG TO THE CORPORATION AND/OR PARTNERSHIP FAULKNER & FAULKNER,
IN THE REPRESENTATION OF JOHN GREGORY LAMBROS.
d. BLOCK 16D: Defendant Charles Faulkner entered the name
and mailing address of the law firm, FAULKNER & FAULKNER, Suite
500, 701 Fourth
Avenue South, Minneapolis, Minnesota 55415. Again requesting the CJA
earnings
in the representation of John G. Lambros to belong to the law firm
and not
Defendant Charles Faulkner in an individual capacity.
7. EXHIBIT C, is copy of Attorney Charles W. Faulkner's CJA
form, dated February 17, 1994, voucher number 0380221, for a grand
total compensation of $16,560.00.
8. Therefore, Defendant Attorney Sheila Regan Faulkner, committed
FRAUD in lying to this court within her December 14, 1998,
AFFIDAVIT in an attempt to have this court dismiss her and
the law firm of FAULKNER & FAULKNER, as defendants from this
action.
ATTORNEY DONNA RAE JOHNSON, Attorney I.D. #50945
9. Attorney Donna Rae Johnson also committed fraud and made
false statements as to Defendant Charles Faulkner being paid
individually under his own social security number, not the Federal ID
number of FAULKNER & FAULKNER in the following motions to this
court, in an attempt to have this court dismiss this action
against Defendant Attorney Sheila Regan Faulkner and FAULKNER &
FAULKNER:
a. MEMORANDUM IN OPPOSITION TO PLAINTIFF'S MOTIONS AND IN
Page 3.
SUPPORT OF DEFENDANTS
MOTIONS, dated December 12, 1998, on the following pages:
1. Page 2: "Each practices in these fields separately, and each is
paid separately, under their own social security numbers, not the
Federal ID No. of Faulkner & Faulkner." Of interest on this page
is the sentence, "Sheila Faulkner acted in an ADMINISTRATIVE
CAPACITY FOR THE LAW FIRM, and occasionally as a
consultant, after her automobile accident in April, 1988."
2. Page 6: "Charles Faulkner was appointed by the Federal Public
Defender's office to represent John Lambros, and he was paid,
INDIVIDUALLY, an hourly rate to do so."
3. Page 7: "She was a partner in Faulkner & Faulkner, which
was also NOT INVOLVED IN THE REPRESENTATION OF PLAINTIFF,
10. Therefore, Attorney Donna Rae Johnson committed FRAUD and
made
false statement to this court in an attempt to have her clients
dismissed from
this action. t
11. Plaintiff hereby states under the penalty of perjury that the
foregoing is true and correct. Title 28 USC Section 1746.
DATED: November 19, 1999
JOHN GREGORY LAMBROS, Pro Se
Reg. No. 00436-124
USP Leavenworth
PO Box 1000
Leavenworth, Kansas 66048-1000
Web site: www.brazilboycott.org
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.