August 24, 1998 REQUEST FOR ADMISSIONS FROM: RICHARD STARK, PRESIDENT OF SmartAds AND STARK COMMUNICATIONS, 6094 PERIMETER LAKES DRIVE, DUBLIN, OHIO 43016, in LAMBROS vs. FAULKNER, Civil No. 98-1621.


LAMBROS vs. FAULKNER, CIVIL CASE NO. 98-1621 (DSD-JMM)
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: RICHARD STARK, PRESIDENT OF SmartAds AND STARK COMMUNICATIONS, 6094 PERIMETER LAKES DRIVE, DUBLIN, OHIO 43016
Dated August 13, 1998.

was served via first class mail, postage paid, to the following persons on August 26, 1998.

1. Clerk of the Court
District of Minnesota
U.S. Federal Courthouse
316 North Robert Street
St. Paul, Minnesota 55101-1460

2. Richard Stark, President
SmartAds & Stark Communications
6094 Perimeter Lakes Drive
Dublin, Ohio 43016
U.S. Certified Mail No. Z-138-670-638, RETURN RECEIPT REQUESTED

3. Attorney Sheila Regan Faulkner
2680 Sumac Ridge
St. Paul, Minnesota 55110

4. Legal Department
America Online
8619 Westwood Center Drive
Vienna, VA 22182-2285
RE: CROSS REFERENCE LETTERS FROM JOHN GREGORY LAMBROS TO AOL'S CUSTOMER SERVICE.

Signed:

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


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).

SECOND MOTION TO SUPPLEMENT THIS DECLARATORY JUDGMENT
ACTION/COMPLAINT PURSUANT TO FRCP 15(A).

REQUEST FOR ADMISSIONS FROM:

RICHARD STARK, PRESIDENT OF SmartAds AND STARK COMMUNICATIONS
6094 PERIMETER LAKES DRIVE, DUBLIN, OHIO 43016

Plaintiff Lambros requests LAW OFFICE MANAGEMENT INCORPORATED, within thirty (30) after service of this request to make the following admissions for the purpose of this action.

A. Each of the following statements are TRUE.

 

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

A. Each of the following statements are TRUE.

1. Richard Stark is President of SmartAds (TM) and Stark Communications, companies that specialize in advertising packages for the internet with placement in newsgroups, web sites, internet classified ads and e-mailing lists.

2. Richard E. Stark contacted Plaintiff Lambros on February 20, 1997, thanking Plaintiff for the purchasing of an advertising package.

3. Plaintiff Lambros has purchased advertising several times from Richard E. Stark, President of SmartAds and Stark Communications.

4. Plaintiff Lambros sent Richard E. Stark, President of SmartAds and Stark Communications a check for approximately $60.00 in payment of a one (1) year America Online account at $4.95 per month, on or about October 1997.

5. Plaintiff Lambros spoke with Richard E. Stark, President of SmartAds and Stark Communications on the telephone at approximately ten (10) A.M. from USP Leavenworth as to his firm(s) coordinating the marketing of the 'LEGAL DEFENSE FUND FOR JOHN GREGORY LAMBROS.' Stark agreed to the marketing and full coordination of the 'LEGAL DEFENSE FUND FOR JOHN GREGORY LAMBROS.' Lambros followed up the telephone conversation with a three (3) page letter to Stark on July 28, 1997, the day of the telephone conversation.

6. Plaintiff Lambros letter to Stark dated July 28, 1997, as described in paragraph five (5) above, stated agreed upon duties to be performed by Stark, SmartAds and Stark Communications. Duties included establishing of web site for LEGAL DEFENSE FUND FOR LAMBROS, promoting of LEGAL DEFENSE FUND web site via the internet, responding to all inquiries, publishing of 'BASIC AGREEMENT FOR INDEPENDENT CONTRACTOR(S) TO RAISE FUNDS FOR THE LEGAL DEFENSE FUND FOR PLAINTIFF LAMBROS' within web site, establishing of digital payment resources within the web site and various other duties. The July 28, 1997, letter was sent U.S. Certified Mail No. P-386-224-223, with copy to Attorney Jeff Orren in St. Paul, Minnesota and Lambros family.

7. Richard E. Stark, President of SmartAds and Stark Communications established a web site for Plaintiff Lambros for the purpose of Plaintiff Lambros' 'LEGAL DEFENSE FUND.

8. Plaintiff Lambros telephoned Richard E. Stark on January 8, 1998. Stark and Plaintiff Lambros agreed to establish a game site for advertising BOYCOTT BRAZIL. Stark stated it would cost $300.00 for the development of the game site and agreed to develop and manage the site to promote the BOYCOTT OF BRAZIL and Plaintiff Lambros' 'LEGAL DEFENSE FUND.

9. Plaintiff Lambros wrote Richard E. Stark on January 8, 1998, confirming the telephone conversation in paragraph eight. The letter also advised Richard E. Stark that Pat Lambros, mother of John Gregory Lambros, would forward a check in the amount of $300.00 for the development of the GAME BOYCOTT BRAZIL WEB SITE. Lambros also advised Stark to review the ROLLING THUNDER GAMES, Inc. web site, specifically there WORLD WAR IV GAME, for ideas in the development of the game site for BOYCOTT BRAZIL. Lambros also advised Stark that John W. Lambros, the father of John G. Lambros, established a legal defense bank account, that is identified as: LEGAL DEFENSE FUND FOR JOHN GREGORY LAMBROS, TCF NATIONAL BANK, MINNESOTA, 2100 North Snelling, Roseville, Minnesota 55113-6090.

10. Richard E. Stark received a check from S.A. Lambros in the amount of $300.00, for the game web site. The check was numbered 6671 and made out to Richard Stark/SmartAds and dated January 13, 1998. The check was cashed on January 22, 1998.

11. Lambros wrote Stark on June 11, 1998 regarding the contract in establishing the Boycott Brazil Game Site and the LEGAL DEFENSE FUND web site that Lambros has been promoting globally in conjunction with National Legal Professional Associates.

12. Lambros wrote Stark on July 29, 1998, regarding the contract as to the BOYCOTT BRAZIL GAME SITE.

13. Richard E. Stark, President of SmartAds and Stark Communications, 6094 Perimeter Lakes Drive, Dublin, Ohio 43016, established a web site on American Online for the sole purpose of the 'LEGAL DEFENSE FUND FOR JOHN GREGORY LAMBROS,' that used the America Online web address: http://members.aol.com/LambrosLDF

14. Richard E. Stark and employees of Stark, have reviewed the America Online web site established for Lambros, named "BOYCOTT BRAZIL, located at: http://members.aol.com/BrazilByct

15. Richard E. Stark and/or employees of Stark, SmartAds and Stark Communications established a web site on America Online as to the $300.00 payment for the BOYCOTT BRAZIL GAME SITE.

16. Richard E. Stark and/or employees of Stark, SmartAds and Stark Communications have promoted the LEGAL DEFENSE FUND FOR JOHN GREGORY LAMBROS and sent funds raised to John Gregory Lambros and/or to TCF NATIONAL BANK, MINNESOTA, 2100 North Snelling, Roseville, Minnesota 55113-6090, that manages the LEGAL DEFENSE FUND FOR JOHN GREGORY LAMBROS.

DATED: August 24, 1998

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


The address for the Boycott Brazil homepage is:
http://www.brazilboycott.org

Return to Boycott Brazil Homepage


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.