July 20, 1998 MOTION TO SUPPLEMENT THIS DECLARATORY JUDGMENT ACTION/COMPLAINT PURSUANT TO FRCP 15 (a), in LAMBROS vs. FAULKNER, Civil No. 98-1621. EXHIBITS NOT INCLUDED.
John Gregory Lambros
Reg. No. 00436-124
P.O. Box 1000
Leavenworth, Kansas 66048-1000
Clerk of the Court
District of Minnesota
U.S. Federal Courthouse
316 North Robert Street
St. Paul, Minnesota S5101-1460
U.S. CERTIFIED MAIL NO. Z-109-977-380
RE: LAMBROS vs. FAULKNER, et al., Civil File No. 98-1621(DSD/JMM)
Attached for filing is one original and one copy of:
1. MOTION TO SUPPLEMENT THIS DECLARATORY JUDGMENT ACTION/COMPLAINT PURSUANT TO FRCP 15(a)for filing.
On July 15, 1998 I wrote you as to the problems I am having serving all parties within this action, as to mailings returned. Would it be possible for the U.S. Marshals to serve all parties with copy of the attached FRCP 15(a)?
Please inform me if you would like me to forward copies for service or if you will make copies of the attached FRCP 15(a), as per U.S. Magistrate Judge Mason July 10, 1998 ORDER, in serving my Complaint, Summons and July 10, 1998 ORDER.
As soon as I receive copy of the parties receipt of my original complaint from the U.S. Marshals, I will serve them directly from that point on, as I will have verified addresses from the U.S. Marshals.
Thanking you in advance for your continued support.
John Gregory Lambros, Pro Se
Reg. No. 00436-124
P.O. Box 1000
Leavenworth, Kansas 66048-1000
CERTIFICATE OF SERVICE
I hereby state under the penalty of perjury that a true and correct copy of the attached:
1. MOTION TO SUPPLEMENT THIS DECLARATORY JUDGMENT ACTION/COMPLAINT
PURSUANT TO FRCP 15(a).
dated July 20, 1998, to the following person. SERVED ON 22nd day of July, 1998.
1. CLERK OF THE COURT DISTRICT OF MINNESOTA
U.S. Federal Courthouse
316 North Robert Street
St. Paul, Minnesota 55101-1460
One original & one copy
U.S. CERTIFIED MAIL NO. Z-109-977-380 , RETURN RECEIPT REQUESTED.
2. President Fernando Henrique Cardoso & Brazil's Supreme Court Justices
c/o Ambassador of Brazil, USA
3006 Massachusetts Avenue, N.W.
Washington, D.C. 20008 USA
U.S. Certified Mail No. Z-109-977-381
3. Global internet release to human rights groups and universities as will as supporters of BOYCOTT BRAZIL. Please study RICO STATUTES for further global use. THANK YOU.
John Gregory Lambros Pro Se
Reg. No. 00436-124
P.O. Box 1000
Leavenworth, Kansas 66048-1000
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MINNESOTA
JOHN GREGORY LAMBROS, #00436-124,
P.0. Box 1000
Leavenworth, Kansas 6604-1000, USA
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
COMPANION CASE NO. U.S. vs. LAMBROS
File No. CR-4-89-82(05), District of Minnesota, Eighth Circuit Court of Appeals No. 65 -3d 698 (1995)
MOTION TO SUPPLEMENT THIS DECLARATORY ACTION/COMPLAINT PURSUANT TO FRCP 15(a).
COMES now JOHN GREGORY LAMBROS, (hereinafter Plaintiff), in propria persona, and moves this Court to permit the filing of the following SUPPLEMENTAL INFORMATION pursuant to Federal Rules of Civil Procedure 15(a).
1. Plaintiff originally filed this action on June 17, 1998.
2. Plaintiff served Attorney Sheila Regan Faulkner on June 17, 1998 via U.S. Certified Mail with return receipt.
3. Plaintiff received the return of his June 17, 1998 service on Attorney Sheila Regan Faulkner on July 14, 1998. The envelope which contained copy of this action and Admissions was stamped "REFUSED" & "UNCLAIMED."
4. Plaintiff received copy of U.S. Magistrate Judge Mason's ORDER ON APPLICATION TO PROCEED WITHOUT PREPAYMENT OF FEES, filed on July 10, 1998.
5. Magistrate Judge Mason's ORDER stated that the Clerk will issue Summons and the U.S. Marshals will serve copy of the Complaint, Summons July 10, 1998 ORDER upon Defendant's as directed by the Plaintiff.
6. Plaintiff wrote the Clerk of the Court on July 15, 1998 to verify if copy of ADMISSIONS ~ ~Sheila Regan Faulkner would be included within service.
7. Plaintiff respectfully requests the following issue to SUPPLEMENT his already pending above-entitled action as to guarantee the payment to repair damages/injuries caused to Plaintiff, by Defendant's, as to LEGAL MALPRACTICE which included claims of (a) breach of duty; (b) failure to exercise due diligence; (c) negligence; (d) improper advice; (e) failure to interview and/or subpoena witnesses; (f) failure to consult with and/or communicate regularly with client; and (g) failure to understand or know or apply the law.
8. The U.S. Supreme Court made it clear that federally appointed counsel is subject to suit for MALPRACTICE. See, FERRI vs. ACKERMAN, 444 US 193, 62 L. Ed. 2d 355, 100 S.Ct. 402 (1979).
9. The following issue was the foundation of Plaintiff's conviction, which was built on a criminal violation of law by the United States Government and AUTHORIZED by Attorney Charles W. Faulkner, Attorney Sheila Regan Faulkner, FAULKNER & FAULKNER and JOHN & JANE DOE'S.
SUPPLEMENTAL ISSUE AND INFORMATION:
10. Attorney Charles W. Faulkner and Defendant's failed to (1) file motion(s) suppressing testimony obtained in VIOLATION OF TITLE 18 U.S.C. SECTION 201(c)(2) and MINNESOTA RULES OF PROFESSIONAL CONDUCT. Therefore denying Plaintiff a judgment of acquittal on all criminal charges due to legally insufficient evidence to support Plaintiff's conviction, a new trial would of been prohibited by double jeopardy principles.
11. The issues before this Court and Jury are (1) whether the government's conduct during the criminal trial of Plaintiff was prohibited either by Title 18 U.S.C. §201(c)(2) or Minnesota Rules of Professional Conduct; (2) if it was, whether the testimony of the following witnesses should have been suppressed:
a. Lawrence Pebbles, transcript testimony on pages 48 thru 189;
b. Tracy Greer, transcript testimony on pages 245 thru 347;
c. Pamela Lemon, transcript testimony on pages 382 thru 467;
d. Michael Ayd, transcript testimony on pages 581 thru 607.
and (3) whether the record contains sufficient evidence to remand for a new trial.
STATUTORY CONSTRUCTION OF TITLE 18 U.S.C. ~201(c)(2):
12. Section 201(c)(2) could not be more clear. It says:
Whoever . . . directly or indirectly, gives, offers or promises anything of value to any person, for or because of testimony under oath or affirmation given or to be given by such person as a witness upon a trial, hearing, or other proceeding, before any court . . . authorized by the laws of the United States to hear evidence or take testimony . . . shall be fined under this title or imprisoned for not more than two years, or both.
(Title 18 U.S.C. §201(c)(2))(quoting U.S. vs. SIN&LETON, NO. 97-3178, Tenth Circuit Court of Appeals, page 7, filed and published on July 1, 1998)
13. The class of persons who can violate the statute is not limited. "WHOEVER" completes the following elements commits a crime. 18 U.S.C. §201(c)(2). First, the statute requires a gift, offer, or promise, either direct or indirect, to a person. Second, the gift, offer or promise must be "of value." Third, the gift, offer, or promise must be made "for" or "because of" the person's sworn testimony at trial or other proceeding before an authorized court. The state of mind required to violate the statute is knowledge that the thing of value is given for or because of testimony. See, U.S. vs. CAMPBELL, 684 F.2d 141, 150 (D.C. Cir. 1982)(construing parallel subsection); U.S. vs. BREWSTER, 506 F.2d 62, 82 (D.C. Cir. 1974)(quoting U.S. vs. BREWSTER, 408 U.S. 501, 527 (1972))(same).(quoting SINGLETON, at 8)
14. The Tenth Circuit stated in SINGLETON, at 8 - 22, that the United States Assistant Attorney, acting on behalf of the government, is within the statutory class "WHOEVER" as covered by the plain language and meaning of Title 18 U.S.C. Section 201(c)(2).
U.S. ATTORNEY THOMAS B. HEFFELFINGER AND ASSISTANT U.S. ATTORNEY DOUGLAS R. PETERSON MADE "AT LEAST" THE FOLLOWING PROMISES IN CRIMINAL VIOLATION OF TITLE 18 U.S.C. SECTION 201(c)(2):
15. U.S. Attorney's Heffelfinger and Peterson made at least the following promises to Lawrence Pebbles for his testimony against Plaintiff Lambros:
a. the promise not to prosecute Mr. Pebbles for certain offenses;
b. the promise to inform U.S. Chief Judge Diana Murphy of his cooperation;
c. maximum sentence of eighteen (18) years from a potential life sentence on drug charges and unknown amount on tax charges.
(Attached are pages 56, 57, & 58 of criminal trial transcripts to prove above statements) 16. U.S. Attorney's Heffelfinger and Peterson made at least the following promises to TRACY GREER for her testimony against Plaintiff Lambros:
a. the promise not to prosecute Ms. Greer for certain drug and possibly tax offenses;
b. payment of money;
c. the promise to inform the district court of her cooperation;
d. the promise of a maximum sentence of five (5) years from a potential sentence of fifteen (15) years on drug charges. (transcript page 287);
e. Plaintiff Lambros consulted the legal statute which states that Ms. Greer could of received more than one (1) life sentence. Therefore, Ms. Greer lied to the court.
(Attached are pages 286, 287, & 288 of criminal trial transcripts to prove above statements)
17. U.S. Attorney's Heffelfinger and Peterson made at least the following promises to PAMELA LEMON for her testimony against Plaintiff Lambros:
a. the promise not to prosecute Ms. Lemon for certain offenses, both drug and tax;
b. the promise to inform the district court of her cooperation;
c. Ms. Lemon only served two (2) months in a halfway house (jail?) from a maximum sentence of more than one (1) life sentence. Ms. Lemon was listed in three counts within the drug conspiracy indictment.
(Attached are pages 443, 444, & 445 of criminal trial transcripts to prove above statements)
18. U.S. Attorney's Heffelfinger and Peterson made at least the following promises to MICHAEL AYD for his testimony against Plaintiff Lambros:
a. the promise to inform the district court of his cooperation;
b. "a new plea agreement under which he testified against a co-defendant and a defendant [Plaintiff Lambros] in another trial in exchange for a substantial sentence reduction - a recommended 188-month sentence instead of MANDATORY LIFE." See, U.S. vs. AYD, 25 F.3d 624, 627 (8th Cir. 1994);
c. possibly the promise not to prosecute Mr. Ayd for certain offenses.
(Attached is page 600 of criminal trial transcripts to prove above statements)
19. Total pages of Plaintiff Lambros' trial transcript is approximately 959 pages.
20. Total pages of testimony from PEBBLES, GREER, LEMON, and AYD is approximately 354 pages. Therefore, U.S. Attorney's Heffelfinger and Peterson obtained in violation of Title 18 Section 201(c)(2), 354 pages of testimony that was to be SUPPRESSED in trial. "[T]he principle reason behind the adoption of the exclusionary rule was the Government's 'failure to observe its own laws." U.S. vs. RUSSELL, 411 U.S. 423, 430 (1973)(quoting MAPP vs. OHIO, 367 U.S. 643, 659 (1961).
21. The exclusionary rule has been applied to constitutional, statutory, and procedural rule violations to deter unlawful conduct. See, U.S. vs. BLUE, 384 U.S. 251, 255 (1966). The Supreme Court itself has applied the rule to various STATUTORY VIOLATIONS, see SABBATH vs. U.S., 391 U.S. 585, 586, 588-90 (1968); MILLER vs. U.S., 357 U.S. 301, 313-14 (1958); NARDONE vs. U.S., 302 U.S. 379, 380-84 (1937), and has held open this application while denying use of the rule for certain regulatory violations, see U.S. vs. CACERES, 440 U.S. 741, 754-55 & n.21 (1979). Like wise the EIGHTH CIRCUIT COURT OF APPEALS has held suppression appropriate where FEDERAL STATUTES HAVE BEEN VIOLATED. See, U.S. vs. MARTS, 986 F.2d 1216, 1218-19 (8th Cir. 1993).
22. Suppression is a judicially fashioned rule whose primary purpose is to deter official misconduct. See, U.S. vs. PELTIER, 422 U.S. 531, 542 (1975);
U.S. vs. CALANDRA, 414 U.S. 338, 347-48 (1974).
THE STRUCTURE OF SECTION 201:
23. The statute at issue in this case, §201(c)(2), is a gratuity prohibition, and like other gratuity provision in §201(c)(2), IT CONTAINS NO REQUIREMENTS OF CORRUPTNESS OR INTENT TO INFLUENCE. See, JOHNSON, 621 F.2d at 1076; BREWSTER, 506 F.2d at 71-72; IRWIN, 354 F.2d at 197; GOLDEN DOOR JEWELRY CREATIONS, INC. vs. LLOYDS UNDERWRITERS NON-MARINE ASS'N, 865 F. Supp. 1516, 1523 (S.D. Fla. 1994), aff'd in part, rev'd in part, and remanded, 117 F.3d 1428 (llth Cir. 1997); (quoting SINGLETON, 97-3178, July 1, 1998, 10th Cir.)
THE LAW ENFORCEMENT JUSTIFICATION:
24. In SINGLETON, 97-3178, July 1, 1998, "[T]he government asserts WITHOUT ARGUMENT OR AUTHORITY, that agreements for testimony between the government and a witness are not contemplated by this statute [§201(c)(2)]." (Singleton at 26).
25. The Tenth Circuit stated in SINGLETON, 97-3178, July 1, 1998, at 29 &
30, "[B]ut we have found no case in which prosecutors, in their role as lawyers representing the government after the initiation of criminal proceedings, have been granted a justification to violate generally applicable laws." See, U.S. vs. RYANS, 903 F.2d 731, 739-40 (lOth Cir.)(holding that disciplinary rule applies to prosecutors upon commencement of criminal proceedings), cert. denied, 498 U.S. 855 (1990). "[B]ecause the government's STATUTORY VIOLATION occurred not in a field investigation but in the context of testimony which was to be presented to the court, we further hold its action was not "reasonable." BROGAN, 118 S. Ct. at 811.
26. The Tenth Circuit concluded in SINGLETON, at 31, "[W]e conclude the government's violation of §201(c)(2) was NEITHER "REASONABLE" NOR AN "ENFORCEMENT ACTION." BROGAN, 118 S. Ct. at 811.
MINNESOTA PROFESSIONAL RULES OF CONDUCT FOR ATTORNEY'S:
27. Plaintiff Lambros does not have a copy of the Minnesota Professional Rules of Conduct for Attorney's.
28. Plaintiff Lambros argues that the government violated the Minnesota Professional Rules of Conduct for Attorney's, as the Kansas Professional Rule 3.4(b), adopted by the Supreme Court of Kansas, provides, "A lawyer shall not . . . offer an inducement to a witness that is prohibited by law." Kansas Rule of Professional Conduct 3.4(b)(1997). Commentary to the Model Rules, as adopted by the Supreme Court of Kansas, states, "The common rule in most jurisdictions is that it is improper to pay an occurrence witness any fee for testifying . . ." Kansas Rule of Professional Conduct 3.4(b) cmt. (1997). We have already established, in agreement with our sister circuits, that intangible value can be equivalent to financial value, and that the promise of leniency is an equal or greater incentive to lie than is cash. SINGLETON, 97-3178, July 1, 1998, 10th Cir., page 45.
DEFENDANT'S DID NOT REQUEST OR SUBMIT A MOTION TO SUPPRESS TESTIMONY FROM WITNESSES PEBBLES, GREER, LEMON, OR AYD:
29. Defendant Charles W. Faulkner, Attorney Sheila R. Faulkner, Faulkner & Faulkner and John and Jane Doe's did not request or submit a motion to the Court to suppress the testimony of witnesses PEBBLES, GREER, LEMON, or AYD FOR A JUDGMENT OF ACQUITTAL AS TO ALL COUNTS WITHIN PLAINTIFF'S CRIMINAL INDICTMENT.
30. The record does not contain sufficient other evidence upon which a jury could find guilt beyond a reasonable doubt. If the evidence, excluding the testimony of PEBBLES, GREER, LEMON, and AYD, is legally insufficient to support Plaintiff Lambros' convictions, a new trial is prohibited by double jeopardy principles. See, U.S. vs. McAleer, 1998 WL 101804, at *4 (lOth Cir. 1998)(citing BURKS vs. U.S., 437 U.S. 1, 18 (1978)). If, however, the record contains sufficient evidence to support a conviction without PEBBLES, GREER, LEMON, or AYD's testimony, then justice requires a new trial. See, U.S. vs. TATEO, 377 U.S. 463, 465 (1964) (quoting SINGLETON, 97-3178, July 1, 1998, 10th Cir., page 52).
PLAINTIFF LAMBROS HAS BEEN ILLEGALLY INCARCERATED SINCE JANUARY 1993:
31. Plaintiff Lambros states that due to the LEGAL MALPRACTICE of all Defendant's, which includes claims of (a) breach of duty; (b) failure to exercise due diligence; (c) negligence; (d) improper advice; (e) failure to interview and/or subpoena witnesses; (f) failure to consult with and/or communicate regularly with Plaintiff; and (g) failure to understand or know or apply the law, Plaintiff has been illegally incarcerated since January, 1993, the month Plaintiff Lambros' trial concluded.
ADDITIONAL CAUSE OF ACTION
EIGHTH CAUSE OF ACTION
RACKETEER INFLUENCED AND CORRUPT ORGANIZATION ACT
TITLE 18 U.S.C. S1962(d)
TITLE 18 U.S.C. 1964(c)
32. From on or about June 17, 1992, to on or about February, 1994, Defendant's Attorney Charles W. Faulkner, Attorney Sheila Regan Faulkner, Faulkner & Faulkner, John & Jane Doe's, and other unknown persons acting in association knowingly, intentionally, and willfully, joined, agreed and conspired to, and did so, form an enterprise made up of Attorney Charles W. Faulkner as its leader, and various named and unknown named employees of Faulkner & Faulkner, and others, as members of said enterprise, with its principle purpose to function as an enterprise through the organizational structure of Faulkner & Faulkner, to by and through its members carry out a pattern of racketeering activities as a common scheme to intimidate, corruptly coerce, and corruptly persuade witnesses and clients in official proceedings to withhold, fabricate and falsify evidence, information, testimony, and AUTHORIZED and/or ALLOWED predicate acts of racketeering, Title 18 U.S.C. §201(c)(2) (relating to bribery), Title 18 U.S.C. §1503 (relating to Obstruction of Justice), and Title 18 U.S.C. §1512 (relating to tampering with a witness, victim, or an informant), as defined within "racketeering activity" under Title 18 U.S.C. §1961, to cover-up certain legal and illegal activities of other acting in aid thereof, all in violation of Title 18 U.S.C. §1962(d), the CONSPIRACY CLAIM WITHIN RICO.
33. Plaintiff claims that each Defendant by WORDS or ACTIONS, conspired to engage in a pattern of racketeering activities in violation of Title 18 U.S.C. §1962. Plaintiff also alleges the seven constitutional elements: (1) that the Defendant's (2) through the commission of two or more acts (3) constituting a 'pattern' (4) of racketeering activity (5) directly or indirectly invests in, or maintains an interest in, or participates in (6) an 'enterprise' (7) the activities of which affect interstate or foreign commerce. See, IN RE CRAZY EDDIE SECURITIES LITIGATION, 812 F.Supp. 338, 347 (E.D.N.Y. 1993).
34. Plaintiff states that Supreme Court Justice J. Kennedy stated in SALINAS vs. U.S., No. 96-738, 62 CrL 2010, 12/03/97, "To be convicted of conspiracy to violate RICO under §1962(d), the conspirator NEED NOT HIMSELF HAVE COMMITTED OR AGREED TO COMMIT THE TWO OR MORE PREDICATE ACTS, such as bribery, requisite for a substantive RICO offense under §1962(c). Section 1962(d) - which forbids "any person to conspire to violate" §1962(c) - is even more comprehensive than the general conspiracy provision applicable to federal crimes, §371, since it contains no requirement of an overt act or specific act to effect the conspiracy's object . . . it suffices that he adopt the goal of furthering or facilitating the criminal endeavor, and he need not agree to undertake all of the acts necessary for the criminal completion."
35. Plaintiff states that he was INJURED "by reason of a violation of Section 1962." Title 18 U.S.C. S1964(c).
36 Defendants used the U.S. POSTAL SERVICE to commit mail fraud, that is defendant's knowingly or intentional participation in scheme, the use of inter state mails and/or wire communications in furtherance of all court proceedings in the criminal trial of Plaintiff Lambros, (1) plea bargain negotiations, (2) Court Motions, (3) Freedom 0f Information Act requests, etc. Title 18 U.S.C.A. §§ 1341 & 1343.
37. Defendant's false and/or fraudulent information as to the actual legal sentence(s) Plaintiff could receive during plea bargain negotiations was neither isolated, nor sporadic, and constitute a pattern of racketeering activity.
38. Plaintiff relied on Defendant's misrepresentation. Therefore, injury occurred by reason of Defendant's actions. Defendant's supplied false and/or fraudulent information for the guidance of Plaintiff, thus subject to liability to loss caused by Defendant's. Plaintiff's justifiable reliance upon the information caused injury.
39. BROWN vs. LaSALLE NORTHWEST NATIONAL BANK, 820 F.Supp. 1078, 1079, Key Note 5 (N.D. Ill. 1993) (Borrower sufficiently alleged pattern of RICO activity to support civil RICO claim against bank which lent her money for automobile purchase by claiming that bank used numerous insurance agents and numerous automobile dealers to defraud numerous customers of their RIGHT TO NOTICES OF DEFENSES TEEY HAD UNDER FEDERAL LAW AGAINST BANK'S COLLECTION OF LOANS ON AUTOMOBILE TRANSACTIONS THAT WENT BAD. 18 U.S.C.A. §1961 et seq.; Fed . Rules Civ.Proc.Rule 9(b), 28 U.S.C.A.)
40. Under these circumstances, there exists an almost certainty that said enterprise will attempt to obstruct justice and further impact on interstate commerce.
41. During the course and in furtherance of said conspiracy and enterprise, Plaintiff incorporates all pleadings within this action and all pleadings within companion case U.S. vs. LAMBROS, Criminal File No. CR-4-89-82(05), District of Minnesota, and Eighth Circuit Court of Appeals case U.S. vs. LAMBROS, 65 F.3d 698 (1995), among others, were committed under racketeering acts.
DAMAGES UNDER TBE EIGHTH CAUSE OF ACTION - RICO - 18 U.S.C. S1962(d) CONSPIRACY CLAIM - PROVIDES FOR CIVIL REMEDIES IN FORM OF TREBLE DAMAGES. TITLE 18 U.S.C. S1964(c).
DAMAGE PRAYER - 8th CAUSE OF ACTION
42. For Eighth (8th) Cause of Action $1 Billion U.S.;
For pain, suffering, and actual injuries to Plaintiff's body, enjoyment of use, loss of wages, residual pain, etc., as to the 8th cause of action $1 Billion U.S.
43. Plaintiff requests the Court and jury to adjust/recalculate TOTAL DAMAGES, DUE TO RICO TREBLE DAMAGE EXPOSURE, AND SUM CERTAIN ACTUAL AND PUNITIVE DAMAGES FROM EACH DEFENDANT DUE TO INJURIES SUSTAINED HEREIN.
44. I hereby certify that the above is true and correct pursuant to Title28 U.S.C.A. §1746.
DATED- July 20, 1998
John Gregory Lambros, Pro Se
Reg. No. 00436-124
P.O. Box 1000
Leavenworth, Kansas 66048-1000 USA
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
THANK YOU FOR YOUR SUPPORT AND ASSISTANCE IN MY BOYCOTT OF BRAZILIAN PRODUCTS.