Free Notice (Other) - District Court of Federal Claims - federal

Case 1:94-cv-00518-EGB

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Case 1:94-cv-00518-EGB

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UNITED STATE COURT OF FEDERAL CLAIMS

MONARCH ASSURANCE P.L.C. Manxonia House, Bay View Road Port St. Mary Isle of Man, and No. 94-518 C THOMAS PATRICK DENTON TAYLOR, Manxonia House, Bay View Road Port St. Mary Isle of Man, Plaintiffs, v. THE UNITED STATE OF AMERICA, Defendant. (Judge Bruggink) Request for Issuance of Letters Rogatory

Request for Issuance of Letters Rogatory

Plaintiffs respectfully request this Court to issue the attached 3 letters rogatory. The purpose of the first is to acquire the testimony of Mr. Sima Malkowich, of Cheltenham, England, who allegedly has knowledge of the alleged relationship and role Mr. John Patrick Savage had in the Central Intelligence Agency. All attempts to acquire Mr. Malkowich's assistance through other means have been futile.

The purpose of the second letter is to acquire the testimony of Detective (Ret.) Hulse of the Staffordshire Police. Mr. Hulse was present with Special Agent Wayne Stockley of the Internal Revenue Service during taped interviews of Mr. John Patrick

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Savage held in 1994 immediately prior to Mr. Savage's reported death. All attempts to acquire copies of the tapes and unedited transcriptions have been refused. All attempts to acquire Mr. Hulse's assistance through other means have been futile.

The purpose of the third letter is to acquire the testimony of Sarah Savage, the wife of Mr. John Patrick Savage. Savage=s assets disappeared during the time prior to his reported death. After the death, Mrs. Savage also disappeared from her Colorado home. All attempts to acquire Ms. Savage's assistance through other means have been futile.

Respectfully submitted:

s/Raphael S. Moore__________________________ Raphael S. Moore, Attorney for Plaintiffs Moore & Moore Attorneys at Law Phoenix House, 413 F Street Davis, California 95616 Tel: (530) 758-8317 Fax: (530) 758-8318 [email protected]

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MONARCH ASSURANCE P.L.C. Manxonia House, Bay View Road Port St. Mary Isle of Man, and No. 94-518 C THOMAS PATRICK DENTON TAYLOR, Manxonia House, Bay View Road Port St. Mary Isle of Man, Plaintiffs, v. THE UNITED STATE OF AMERICA, Defendant. (Judge Bruggink)

TO: The High Court of Justice, England The United States Court of Federal Claims, Washington, D.C., presents its compliments and requests the following assistance: This action is pending in the United States Court of Federal Claims, in Washington, D.C.. The plaintiffs are Monarch Assurance PLC, and Thomas Patrick Denton Taylor; the defendant is the United States of America. This court has determined that in the interest of justice and to assure a complete record, the person named in Exhibit A, which is attached herein and incorporated by reference, is within your jurisdiction, and needs to be examined as a witness under oath. This court respectfully requests that:

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1. You cause this witness to be summoned to attend an examination at a time and place you determine and before you or another person who is authorized and appointed by you to administer oaths and to preside over the examination. 2. You permit this witness to be examined by counsel for all parties in this matter, allowing full examination and cross-examination with regard to whether Mr. John Patrick Savage had the requisite authority to bind the United States Government in contract. 3. You order this witness to produce before, during, or immediately after the examination specific documents or other tangibles relevant to the subject matter of this case, the existence of which are made known to the witness in anticipation of the examination, or which become known during the course of the examination and which are requested by counsel. 4. You cause a verbatim transcript of the testimony of the witness to be taken and reduced to writing. 5. You authenticate by a seal of your court (or by such other way in accordance with your procedures) the record of the transcript and documents and return all, together with a note of the changes and expenses incurred in carrying out this request, to this court.

This court is ready and willing to render similar assistance to your court when required and takes this opportunity to extend to you its highest consideration. Dated: ________

________________________ Judge Bruggink

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Exhibit A

Detective Inspector William Hulse (retired), previously of c/o Staffordshire Police HQ Cannock Road Stafford Staffs ST 17 oQG United Kingdom

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MONARCH ASSURANCE P.L.C. Manxonia House, Bay View Road Port St. Mary Isle of Man, and No. 94-518 C THOMAS PATRICK DENTON TAYLOR, Manxonia House, Bay View Road Port St. Mary Isle of Man, Plaintiffs, v. THE UNITED STATE OF AMERICA, Defendant. (Judge Bruggink)

TO: The High Court of Justice, England The United States Court of Federal Claims, Washington, D.C., presents its compliments and requests the following assistance: This action is pending in the United States Court of Federal Claims, in Washington, D.C.. The plaintiffs are Monarch Assurance PLC, and Thomas Patrick Denton Taylor; the defendant is the United States of America. This court has determined that in the interest of justice and to assure a complete record, the person named in Exhibit A, which is attached herein and incorporated by reference, is within your jurisdiction, and needs to be examined as a witness under oath. This court respectfully requests that:

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1. You cause this witness to be summoned to attend an examination at a time and place you determine and before you or another person who is authorized and appointed by you to administer oaths and to preside over the examination. 2. You permit this witness to be examined by counsel for all parties in this matter, allowing full examination and cross-examination with regard to whether Mr. John Patrick Savage had the requisite authority to bind the United States Government in contract. 3. You order this witness to produce before, during, or immediately after the examination specific documents or other tangibles relevant to the subject matter of this case, the existence of which are made known to the witness in anticipation of the examination, or which become known during the course of the examination and which are requested by counsel. 4. You cause a verbatim transcript of the testimony of the witness to be taken and reduced to writing. 5. You authenticate by a seal of your court (or by such other way in accordance with your procedures) the record of the transcript and documents and return all, together with a note of the changes and expenses incurred in carrying out this request, to this court.

This court is ready and willing to render similar assistance to your court when required and takes this opportunity to extend to you its highest consideration. Dated: ________

________________________ Judge Bruggink

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Exhibit A

Mr. Sima Malkowich, previously of: Partners in Trade, Ltd. 136 Bath Road Chltenham Glos GL53 7JX United Kingdom

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MONARCH ASSURANCE P.L.C. Manxonia House, Bay View Road Port St. Mary Isle of Man, and No. 94-518 C THOMAS PATRICK DENTON TAYLOR, Manxonia House, Bay View Road Port St. Mary Isle of Man, Plaintiffs, v. THE UNITED STATE OF AMERICA, Defendant. (Judge Bruggink)

TO: The High Court of Justice, England The United States Court of Federal Claims, Washington, D.C., presents its compliments and requests the following assistance: This action is pending in the United States Court of Federal Claims, in Washington, D.C.. The plaintiffs are Monarch Assurance PLC, and Thomas Patrick Denton Taylor; the defendant is the United States of America. This court has determined that in the interest of justice and to assure a complete record, the person named in Exhibit A, which is attached herein and incorporated by reference, is within your jurisdiction, and needs to be examined as a witness under oath. This court respectfully requests that:

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1. You cause this witness to be summoned to attend an examination at a time and place you determine and before you or another person who is authorized and appointed by you to administer oaths and to preside over the examination. 2. You permit this witness to be examined by counsel for all parties in this matter, allowing full examination and cross-examination with regard to whether Mr. John Patrick Savage had the requisite authority to bind the United States Government in contract. 3. You order this witness to produce before, during, or immediately after the examination specific documents or other tangibles relevant to the subject matter of this case, the existence of which are made known to the witness in anticipation of the examination, or which become known during the course of the examination and which are requested by counsel. 4. You cause a verbatim transcript of the testimony of the witness to be taken and reduced to writing. 5. You authenticate by a seal of your court (or by such other way in accordance with your procedures) the record of the transcript and documents and return all, together with a note of the changes and expenses incurred in carrying out this request, to this court.

This court is ready and willing to render similar assistance to your court when required and takes this opportunity to extend to you its highest consideration. Dated: ________

________________________ Judge Bruggink

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Exhibit A

Ms. Sarah Savage, previously of: West Horsley Surrey KT24 6LQ United Kingdom