March 12, 2001, PLAINTIFF'S OBJECTIONS TO ATTORNEY STENMOE'S NOTICE OF MOTION AND MOTION FOR WITHDRAWAL OF COUNSEL WITHOUT SUBSTITUTION, DATED MARCH 6, 2001. This document is a total of three (3) pages which includes a one page certificate of service.
CERTIFICATE OF SERVICE
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 OBJECTIONS TO ATTORNEY STENMOE'S NOTICE OF MOTION AND MOTION FOR WITHDRAWAL OF COUNSEL WITHOUT SUBSTITUTION, DATED MARCH 6, 2001.
Dated March 12, 2001.
was served on the following this 14th day of March, 2001, via U.S. Mail through the prison authorities, to:
1. Clerk of the Court,
District of Minnesota, 316 North Robert Street, St.
Paul, Minnesota 55101. One original and one copy.
2. Attorney Gregory J.
Stenmoe, BRIGGS & MORGAN, 2400 IDS CENTER. 80 South
Eighth Street, Minneapolis, Minnesota 55402.
3. Attorney Donna Rae Johnson and Attorney Deborah Ellis, 700 St. Paul Bldg., 6 West Fifth Street, St. Paul, Minnesota 55102.
4. Internet release to
BOYCOTT BRAZIL SUPPORTERS and HUMAN RIGHTS GROUPS
5. LAMBROS family members.
Signed: John Gregory Lambros
End of Certificate of Service
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
JOHN GREGORY LAMBROS
CHARLES W. FAULKNER, SUED AS ESTATE/WILL/BUSINESS INSURANCE OF DECEASED ATTORNEY CHARLES W. FAULKNER
SHEILA REGAN FAULKNER
FAULKNER & FAULKNER, Attorneys at Law
JOHN & JANE DOE
CIVIL FILE NO. 98-1621 (DSD/JMM)
PLAINTIFF'S OBJECTIONS TO ATTORNEY STENMOE'S NOTICE OF MOTION AND MOTION FOR WITHDRAWAL OF COUNSEL WITHOUT SUBSTITUTION, DATED MARCH 6, 2001.
COMES NOW, JOHN GREGORY LAMBROS, Plaintiff, Pro Se, (hereinafter Movant) offering OBJECTIONS to Attorney Gregory J. Stenmoe and Briggs and Morgan's "NOTICE OF MOTION AND MOTION FOR WITHDRAWAL OF COUNSEL WITHOUT SUBSTITUTION," dated March 6, 2001.
Movant states the following facts in support of his OBJECTIONS to Attorney STENMOE and BRIGGS AND MORGAN withdrawal from this case:
1. This Court has a pending "MOTION TO ALTER OR AMEND JUDGMENT AND/OR HAVE JUDGMENT VACATED UNDER FEDERAL RULES OF CIVIL PROCEDURE RULE 59(e)," dated February 23, 2001 before it that offers excellent reasons as to having this above-entitled action proceed to trial. Therefore, Movant will require an attorney.
2. Movant does not have access to State of Minnesota Law books. The United States Penitentiary Leavenworth Law library is not required to index State Law books and doesn't.
3. Attorney Stenmoe has resources available from over 150 lawyers at BRIGGS and MORGAN to assist him.
End of page 1
4. Movant has fulfilled all obligations requested by Attorney Stenmoe and has never been given any type of warning that Attorney Stenmoe would withdraw if the obligation was not fulfilled. There was only one misunderstanding between Attorney Stenmoe, and Movant as to the signing of a waiver during our initial meeting that was resolved via Magistrate Judge Mason.
5. Movant has assisted Attorney Stenmoe in the writing of briefs, researching, and offering legal theory as to criminal law, an area of law Attorney Stenmoe has little background. Therefore, a positive mix in talents in presenting facts and law to this court in a professional manner.
6. Movant enjoys working with Attorney Stenmoe due to his professional and intellectual skills that are open to complex legal theory involving Brazilian Law and application of Extradition Law.
7. Attorney Stenmoe stated Movant LAMBROS was one of the best legal researchers he has ever had. Movant then asked Attorney Stenmoe what Movant was worth on the open market in the area of legal research. Attorney Stenmoe replied, approximately $90,000.00 a year." Therefore, Movant believes that the honest open communication that exist between between himself and Attorney Stenmoe is a factor that must be considered before replacing Attorney Stenmoe and BRIGGS and MORGAN with another attorney.
8. Movant believes that BRIGGS and MORGAN has a corporate policy that requires all of their attorneys to extend there arm of PHILANTHROPY to citizens. To the best of Movant's knowledge, Attorney Stenmoe does not have any other charity cases at this time. Therefore, Movant LAMBROS fills the required void.
9. Movant LAMBROS respectfully requests this Court to deny Attorney STENMOE and BRIGGS and MORGAN'S request to withdraw from representing this Movant.
DATED: March 12, 2001
Signed: John Gregory Lambros, Pro Se
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.