My Subpoena From Teamsters Local 115 (Don Adams Case)

Self / Thomas H. Kohn, Esq. | 1/14/2002 | Thomas H. Kohn, Esq.

[Physicist]

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF PENNSYLVANIA

DON ADAMS, et al., Plaintiffs v. TEAMSTERS LOCAL 115, et al, Defendants

SUBPOENA IN A CIVIL CASE Case Number: 99 CV 4910

To:	Kevin Sterner ### NNNNNNN Rd. Lansdowne, PA

X    YOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the taking of a deposition in the above case.

PLACE OF DEPOSITION Markowitz & Richman 1100 North American Building 121 South Broad Street Philadelphia, PA     19107

DATE AND TIME January 31, 2002 - 10:00 a.m.

X    YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or objects at the place, date, and time specified below (list documents or objects):

All documents that refer or relate to: (a) Don and Teri Adams; (b) any events that occurred during President Clinton's visit on October 2, 1998; and (c) John P. Morris, Teamsters Local 115 or any other Teamster entity.

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PLACE OF DEPOSITION Markowitz & Richman 1100 North American Building 121 South Broad Street Philadelphia, PA     19107

DATE AND TIME January 31, 2002 - 10:00 a.m.

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Any organization not a party to this suit that is subpoenaed for the taking of a deposition shall designate one or more officers, directors, or managing agents, or other persons who consent to testify on its behalf, and may set forth, for each person designated, the matters on which the person will testify. Federal Rules of Civil Procedure, 30(b)(6).

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ISSUING OFFICER=S SIGNATURE AND TITLE (INDICATE IF ATTORNEY FOR PLAINTIFF OR DEFENDANT)

Thomas H. Kohn        DATE 1-14-02
Attorney for Defendant, Local 115

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ISSUING OFFICER=S NAME, ADDRESS AND PHONE NUMBER
THOMAS H. KOHN, Esquire
Markowitz & Richman
1100 North American Building
121 South Broad Street
Philadelphia, PA     19107

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ATTACHMENT

Kevin Sterner

Please provide the following documents¹:

1. All documents that refer or relate to Don Adams.
2. All documents that refer or relate to Teri Adams.
3. All documents that refer or relate to any events that occurred during President Clinton visits to Philadelphia on October 2, 1998.
4. All documents that refer or relate to any demonstration or event that you organized, attended, where [sic] invited to attend or in which you otherwise participated, which Don Adams, Teri Adams, anyone acting in support or on behalf of Don Adams or Teri Adams, Judicial Watch, Larry Klayman, Esq., Paul Orfanedes, Esq., Thomas Fitton, any representative of Judicial Watch or Brian Buckley, Esq. organized, attended or in which any of the above participated.
5. All documents that refer or relate to John P. Morris, Teamsters Local Union 115 or any other Teamsters entity.
6. All documents that refer or relate to any communications with Don Adams, Teri Adams, Brian Buckley, Esq., Larry Klayman, Esq., Paul Orfanedes, Esq., anyone associated with Judicial Watch, or anyone else regarding Don Adams, Teri Adams, the events of October 2, 1998.
7. All documents that refer or relate to any other communication you had with anyone regarding Teamsters Local Union No. 115 or any other Teamster entity.
8. All documents that refer or relate to any communication you had with anyone member, officer or representative of Teamsters Local Union 115 or any other Teamster entity.

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¹ "Document" means any written, printed, typed, recorded, filmed or graphic matter (whether produced on paper, cards, tapes, film, electronic facsimile, computer storage devices or any other medium), including, but not limited to, memoranda, e-mail, computer disks, chat room postings, audio tapes, photographs, videotapes, audio or video transcripts, correspondence, telegrams, posters, leaflets, signs, charts, graphs, notebooks, handwritten or typed notes, pamphlets, periodicals, work papers, and also including, but not limited to, originals, drafts and duplicates which are different from the original because of written and typed notations, or by the attachment or enclosure of other documents, exhibits or appendices.

[Physicist]

I was served with this subpoena on January 21st. I will appear for my deposition on January 31st.

I publish this here in order to make it part of the permanent public record.

Please read my Judicial Watch affadavit for this case.

[Physicist]

Is it something you can share with us? I'm not sure what I'm walking into, here.

[Physicist]

FYI

[Militiaman7]

Better start printing up those archived FR threads about Don and Teri.

I still remember meeting Don and Teri at the March for Justice, 31 October 1998.

[Physicist]

If I recall, that firm has produced a number of the Judges in the Philadelphia court system...

That fits with Ed Rendell telling John Fund that the Teamsters control the Philadelphia court system. Thanks for the heads-up.

[Physicist]

Better start printing up those archived FR threads about Don and Teri.

I'll give them what I happen to have. They can do their own research.

[spunkets]

In a civil case like this the teamster's atty's are going to attempt to paint the Klintoon protesters as a near riotous, disorderly crowd that taunted the teamsters into reflexive action. In this type of case it's the preponderance of the "truth" that carries weight. In other words, the one that tells the best story to gain sympathy wins.

Is that correct?

[Physicist]

A good source of background for the Don Adams case is my series of notes taken at the pretrial hearing of Teamsters Kevin McNulty and Marc Nardone, on February 10, 1999.

Part 1

Part 2

Part 3

Part 4

[basil]

My prayers will be with you.

[xm177e2]

It looks like you have to print out EVERY SINGLE FR thread involving you and the Adamses in order to satisfy the subpoena... (do you have to deliver them in any order, or can you mix all of your documents up? what is legal/illegal in your state? Consult a lawyer to see how big of a prick you can be to the Teamsters' lawyer)

[STD]

They probably monitor this site to see if you comply with the supeona.

[STD]

BTW, how have you been feeling?

[Free the USA]

bump

[connectthedots]

Thanks for posting it. It will save me a lot of time in trying to draft the proper language for issuing my subpoena to the State of Washington Gov, AG, and Chief Justice of the state supreme court, and several other racketeers in my federal lawsuit.

[gonzo]

I've been deposed seven times, Physicist, and all for bullshit-lawyers, and the last time, I couldn't remember anything!

I had sold the aeroplane and hangar four years before, and I promised that lawyer that I would blow his goddam brains out, if he won any action against me!

Use Razors on Lawyers! They understand razors!

[bvw]

You are bringing a lawyer to the deposition?

[Physicist]

No, I can't afford one, really. Don and Teri's lawyer, Paul Orfanedes of Judicial Watch will be there, I'm told.