June 30, 2000, DEFENDANTS' (Faulkners') COMPREHENSIVE MOTION TO DISMISS OR FOR SUMMARY JUDGMENT. Total two (2) pages.
JOHN GREGORY LAMBROS
Plaintiff
vs.
CHARLES W. FAULKNER, SUED AS ESTATE/WILL/BUSINESS INSURANCE OF DECEASED ATTORNEY CHARLES W. FAULKNER
SHEILA REGAN FAULKNER
FAULKNER & FAULKNER, Attorneys at Law
and
JOHN & JANE DOE
Defendants
CIVIL CASE NO.
98-1621 (DSD-JMM)
DEFENDANTS'COMPREHENSIVE MOTION TO DISMISS OR FOR SUMMARY JUDGMENT
Defendants, through counsel Deborah Ellis and Donna Rae Johnson, move the court for dismissal, pursuant to Rule 12(b)(6), Fed.R.Civ.P., and alternatively for summary judgment pursuant to Rule 56, Fed.R.Civ.P.
Defendants' motion is based upon the entire record, file and proceeding, Memorandum In Support of Defendants' Comprehensive Motion to Dismiss or For Summary Judgment, the affidavits and attachments thereto of Deborah Ellis, Donna Rae Johnson and Joseph S. Friedberg.
Dated: June 30, 2000
RESPECTFULLY SUBMITTED,
Signed: Deborah Ellis
Attorney Lic No. 14616X
Donna Rae Johnson
Attorney Lic. No. 50945
Six West Fifth Street
Suite 700
Saint Paul, MN 55102
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
USATHANK YOU FOR YOUR SUPPORT AND ASSISTANCE IN MY BOYCOTT OF BRAZILIAN PRODUCTS.