======== Subject: served subpoena as I was returning to my home From: Grady Ward Date: Tue, 07 Dec 1999 09:43:47 -0800 Message-ID: <5kRNOMX7cI05c+blU4c+XEYANvwN@4ax.com> In the Court of the Thirteenth Judicial Circuit in and for Hillsborough County, Florida Civil Division Dell Liebreich, as Personal Representative of the Estate of Lisa McPherson, Plaintiff, v. Church of Scientology Flag Service Organization, Janis Johnson, Alain Kartuzinski and David Houghton, D.D.S. Defendants. Case No. 97-01235 Division H Subpoena Duces Tecum The State of Florida: To: Grady Ward 3449 Martha Court Arcata, CA 95521-4884 You are commanded to appear at the offices of the undersigned counsel, for testimony and for the production of documents, on January 20, 2000, at 10:00 a.m., and to have with you at that time and place the following: 1. Your curriculum vitae. 2. Any contacts or agreements entered into with Robert (Bob) Minton, Stacy Brooks, Kennan Dandar of Dandar and Dandar, Larry Wollersheim, FACTNet, Michael Garko, Thomas (Thom) Haverty, Ray Emmons, Rod Keller, Vaughn Young, Dan Leipold or Leipold, Donnahue and Shipe. 3. Any letters, notes, documents, internet postings, e-mail or other computer records related to or concerning the Estate of Lisa McPherson v. Church of Scientology Flag Service Organization lawsuit. 4. Checks of other financial statements or records including but not limited to bank records, wire transfer, receipts, stocks received from Robert Minton, Stacy Brooks, Ken Dandar, Dan Leipold, FACTNet or Brian Haney. 5. Any letters, notes or other documents or photos received from or sent to Fannie McPherson, Dell Liebreich, Ann Carlson, Lee Skelton, Sam Davis. 6. Phone records of conversations with Robert Minton, Brian Haney, Michael Garko, Thomas Haverty, Ken Dander, Dan Leipold, Rod Keller, Jeff Jacobsen. 7. Copies of any materials on Scientology you have provided to anyone related to or concerning the Estate of Lisa McPherson v. Church of Scientology Flag Service Organization lawsuit. It is the intent of the subpoena that each and every document and thing in your care, custody, or control, or available to you, no matter how insignificant that item might appear to the party to whom this subpoena is directed, be produced. (more boilerplate) dated December 4, 1999 signed Lee Fugate for Morris Weinberg, Jr. Florida Bar No. 0486401 Zuckerman, Spaeder, Taylor & Evans, LLP 401 East Jackson Street Suite 2525 Tampa, Florida 33602 (813) 221-1010 #### Of course I know no material facts relevant to the Lisa McPherson litigation. More harassment by another arm of the cult. However you and infer the upcoming legal strategy by the nature of the questions and the names involved. Grady Ward grady@gradyward.com http://www.gradyward.com/ voice (707) 826-7712 fax (413) 832-2600 PGP! 7E0E EF0E 613D CEB8 6E8D 9D57 069F 8BC0 8C88 EB82 MESSAGES NOT CRYPTOGRAPHICALLY SIGNED MAY NOT BE AUTHENTIC ======== Subject: Re: served subpoena as I was returning to my home From: Grady Ward Date: Tue, 07 Dec 1999 14:25:59 -0800 Message-ID: On Tue, 07 Dec 1999 09:43:47 -0800, Grady Ward wrote: > >To: Grady Ward 3449 Martha Court Arcata, CA 95521-4884 > >You are commanded to appear at the offices of the undersigned >counsel, for testimony and for the production of documents, on >January 20, 2000, at 10:00 a.m., and to have with you at that >time and place the following: > Here is my response to the subpoena: Grady Ward 3449 Martha Court Arcata, CA 95521-4884 Telephone (707) 826-7712 (413) 832-2600 facsimile E-mail : grady@gradyward.com http://www.gradyward.com/ December 7, 1999 VIA FACSIMILE AND U.S. MAIL Lee Fugate for Morris Weinberg, Jr. Zuckerman, Spaeder, Taylor & Evans, L.L.P 401 East Jackson Street, Ste. 2525 Tampa, FL 33602 (813) 221-1010 voice (813) 223-7961 fax Re: Estate of Lisa McPherson v. Scientology, et. al., Case No. 97-01235 Dear Mr. Fugate, I was given a subpoena in the above matter on the morning of December 6, 1999. Fla. R. Civ. P. 1.410e(2) provides : "A person may be required to attend an examination only in the county wherein the person resides or is employed or transacts business in person or at such other convenient place as may be fixed by an order of court." I work and reside in the city of Arcata, County of Humboldt, State of California. You are aware and acknowledged this fact on the face of the subpoena. I therefore am treating your demand that I appear at your offices in Tampa, Florida as a nullity. See for example, Calvaneso v. Neal, 678 So. 2d 366 (1996). Despite the above and despite the fact that I have no material knowledge that might lead to admissible evidence in the referenced action, I am willing to be deposed at your office in Florida if you pre-pay lodging and first-class transportation for myself to Florida. If this is acceptable to you, I will then submit my particular objections to your request for document production and we can proceed from there. Very truly yours, (signed) Grady Ward, in pro per Grady Ward grady@gradyward.com http://www.gradyward.com/ voice (707) 826-7712 fax (413) 832-2600 PGP! 7E0E EF0E 613D CEB8 6E8D 9D57 069F 8BC0 8C88 EB82 MESSAGES NOT CRYPTOGRAPHICALLY SIGNED MAY NOT BE AUTHENTIC