Subpoena Duces Tecum
The State of Florida
TO ALL POSTERS TO AND LURKERS ON THE USENET NEWSGROUP
YOU ARE COMMANDED to appear at 4256 Marcab Ave North, Clearwater, FL for testimony and for the production of documents on April 18, 2000, at 10 am and to have with you at that time and place the documents and things identified hereinafter.
It is the intent of this subpoena that each and every such 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.
TO COMPLY WITH THIS SUBPOENA, YOU ARE TO PRODUCE EACH AND EVERY DOCUMENT OR THING WHICH HAS EVER BEEN A PART OF YOUR FILES.
If any document or thing is not produced you are to identify that document or thing by date, title, author, and recipient and identify the person pursuant to whose instructions those documents or things were not produced by name, address and employer.
List of documents to be produced:
1. Any and all records in your possession , custody, or control containing comm, including emails with any or each of the following people:
Patricia Greenway Ken Dandar Dan Leipold Robert S. Minton Dell Liebreich Liebrich family members David Minkoff Ray Emmons Mike Garko Robert Vaughn Young.
Jesse Prince Grady Ward Keith Henson Steve Hassan Bill Zizic (Chicago) Hana Whitfield Richard Hoffmann Mike McClaughry Mary Fitzpatrick Ingrid Wagner James Siegelman Brian Haney Kathy Skelton Little Lee Skelton Sam Davis Paul Maser Wayne Andrews Bonita Porelano (sp?) Mark Fabyianic Lois Molandes Roger Weller Deneen Phillips Peter Alexander Duncan Pierce Bob Peterson Frank Oliver Tim Walker Joe Cisar David Cecere Steven Fishman Gabe Cazares Gerry Armstrong Any Persons listed on the LMT flyer 2. All audio and video tapes of demonstations, or pickets of any Church of Scientology organization (?) or member thereof.
3. All audio and video tapes relating to Lisa McPherson.
4. All audio and video tapes relating to Scientology.
5. All audio and video tape recordings of any building and conversations outside any buildings believed by you to be owned by any Church of Scientology organizations (?).
6. All audio and video tape recordings of any person believed by you to be a Scientologist.
7. All audio and video tape recordings of any person believed by you to be a FORMER Scientologist.
8. All audio and video tape recordings of statements of any officer, director, employee or volunteer of the LMT, including each person listed on the LMT promotional flier attached hereto.
9. All records relating to the purchase, lease or acquisistion or attempted acquisition of property for the use of any person listed on Exhibit A hereto or any other employee or volunteer of the LMT.
10. All financial records reflecting the reciept by you of funds from Robert Minton, the LMT, Daniel Leipold, the firm of Leipold , Donohue and Shipe, Ford Greene, Kennan Dandar, and the firm of Dandar and Dandar.
11. All financial records reflecting the receipt by you of expense funds or reimbursement for expenses from Robert Minton, the LMT, Daniel Leipold, the firm of Leipold, Donohue and Shipe, Ford Greene, Kennan Dandar and the firm of Dandar and Dandar.
12. Copies of any Scientology unpublished material in your possession.
13. All documents reflecting contacts and communications with the media.
14. A deposition duly notarized detailing (1) all critical or hostile thoughts you have had concerning L. Ron Hubbard; his writings and other works; Dianetics; Scientology; the Church of Scientology; David Miscavige; and Helena Kobrin, and (2) all knowledge you have as to the identities and addresses of posters to the Usenet newsgroup Alt.Religion.Scientology who post under assumed names.
If you fail to appear with all relevant documents as specified you may be in contempt of court.
You are subpoenaed by the attorney whose names appear on this subpoena and unless excused from the subpoena by the attorneys of the court you shall respond to this subpoena as directed.
April 19, 2000
Squiggle, Squirm and Weasel