Saturday, February 4, 2017

Sandy Hook: Wolfgang Halbig gains the right of discover because of Lenny's "no show" in court


Wolfgang Halbig

[Editor's note: Because Lenny Pozner declined to show up in Court on 13 December 2016 in response to his lawsuit against Wolfgang Halbig, Wolfgang has the right of discovery for the jury trial that now appears virtually certain to occur. Here is the first set of discovery demands Wolfgang has served upon Pozner. We all owe Wolfgang our congratulations for carrying this case into Court.]

IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA
LEONARD POZNER, Individually,                                     CASE NO.: 2015 CA 001693
            Plaintiff,
V.
WOLFGANG HALBIG, Individually
            Defendant
__________________________________/
WOLFGANG W. HALBIG’S FIRST REQUEST FOR PRODUCTION TO
LEONARD POZNER

COMES NOW, Defendant, Wolfgang W. Halbig, (“Defendant”), Pro Se, and pursuant to Florida Rule of Civil Procedure 1.350 herby serves his first request for production on Plaintiff, LEONARD POZNER, (“Plaintiff”). 

INSTRUCTIONS
1__You are to produce your responses to this First Request for Production within thirty (30) days from service to the US Postal Mail address of the Defendant.  That address is Wolfgang W Halbig, 25526 Hawks Run Lane, Sorrento, Florida 32776.

2__The relevant time period referred to in this Request for Production is from January 1, 2011 through the date of your response to this Request unless otherwise indicated.

3__You are to produce all of the documents in the manner in which you maintain them for your business purposes or in an order corresponding to each of the requests numbered below.

4__These requests for production are continuing in nature.  You are required to supplement this production as soon as practicable after you obtain new or additional documents.

5__If you object to producing any document in whole or in part based upon a privilege, state the nature of the privilege you claim including any attorneys' work product or trial preparation materials and your basis thereof.  Identify and describe each document and the reason for which it was created.  Identify the nature, date, subject matter and author of the document as well as the identity of all persons to whom the document was directed, addressed or received, and the paragraphs of the discovery requests to which the document corresponds.  For each such document, you are further required to state the basis for your claim of privilege, attorneys' work product or trial preparation materials. Set forth this information on a “Privilege List”.

6__You are to answer separately, forthrightly, fully and completely each request and part thereof without reference to any answer of any other request.

DEFINITIONS

A__ The term “you,” “your,” “Plaintiff,” refers to the Plaintiff LEONARD POZNER, Individually named in this complaint and /or any alias he may have used or be using such as but not limited to Len Pozner,  Eliezer Pozner, Lenny Pozner or Lenny Osner etc.

B__ The term "Complaint" means the original complaint E-filed 9/11/2015, at 10:11:51 AM as case #2015CA001693 in the circuit court of the fifth judicial circuit in and for Lake County, Florida

C__ The term "document" means the original and any copy whether different from the original by reason of any notation made on such copies or otherwise, regardless of the origin or location, of any written, recorded, transcribed, punched, taped, filmed or graphic matter, however produced or reproduced, including but not limited to any correspondence, telegram, book, letter, memorandum, notes, diaries, statistics, minutes, contracts, studies, checks, statements, receipts, returns, summaries, pamphlets, prospectuses, interoffice and intra office telephone calls, meetings or other communications, bulletins, printed matter, computer printouts, teletypes, telefax, invoices, worksheets (and all drafts, alterations, modifications or changes to any of the foregoing); graphic and AURAL records or representations of any kind, including without limitation, photographs, charts, graphs, microfiche, microfilm, video tape recordings, motion pictures, electronic, mechanical or electrical records or representations of any kind, including without limitation, tapes, cassettes, discs, recordings and saved Internet pages.

D__ The term "all documents" means any document as above defined known to you and every such document that can be located or discovered by reasonably diligent efforts.

E__ The term "communication" means any oral or written utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including, but not limited to, correspondence, conversations, dialogues, discussions, interviews, meetings, consultations, agreements, and other understandings between or among two or more people.

F__ The term "person" means any natural person, corporation, partnership, proprietorship, unincorporated association, organization, government agency or division or group of natural persons.

G__ The term "relating to",  "relates to" or “refers to” means in any way directly or indirectly, concerning, referring to, disclosing, describing, confirming, supporting, evidencing, or representing.

H __The term "representative" means any and all present and former agents, employees, servants, officers, directors, attorneys, or other persons acting or purporting to act on behalf of the person in question.
           
I __The terms "and" and "or", as used herein, are both conjunctive and disjunctive.
           
J __All singular words include the plural, and all plural words include the singular.     
           
K __All words in the present tense include the past, and all words in the past tense include the present.
L __The term “and” is used in its inclusive sense; that is “and” shall be read as “and / or”.

M __The term “any” is used in its inclusive sense; that is “any” shall be read as “any and all”.

N __The phrase “Sandy Hook Shooting” shall refer to the news media reports of a gun shooting incident at the Sandy Hook, Connecticut elementary school, 12 Dickenson Drive, Sandy Hook, Connecticut on December 14, 2012.


DOCUMENTS REQUESTED

1.    State your name, each name you have used since arriving in the United States with a Tourist Visa. 



2.    State your given name at birth.



3.    If you are born outside the United States/other foreign country please provide a true and accurate copy of your birth certificate from that foreign country.


4.    Provide a copy of your Naturalization paper showing your United States Citizenship.



5.    State your current residence address, your residences addresses for the past five years, and the dates that you lived at each address.



6.    Provide photocopies of your New York Driver License, Florida Driver License and your CT Driver License.
  


7.    Provide copies of all your business licenses and corporate filings for all companies opened in the United States by you, showing the proper name as the owner or registrant of license/corporate filings.




8.    8.  At the time PRIOR to and during the INCIDENT were you acting as an agent or employee for any PERSON or Government Agency? If so, state:
 (a) The name, ADDRESS, and telephone number of that PERSON and or   Government Agency:
 (b) And the description of your duties.




  
9.    Describe your formal education, including the name of each school attended, the dates when you attended each school and whether any degrees or certificates were obtained from each school.






10. Identify with specificity and detail any expert witnesses whom you expect to call as witnesses at the trial.





11. Identify with specificity and detail all documentary evidence in your possession, custody or control related to the claims alleged in this Complaint. For each item identified, state the full name and address of the record custodian, the location of the document, and the name(s) of all person(s) who have been provided with a copy.






12. Please list each and every exhibit that you intend to have admitted into evidence at the time of the trial and for each exhibit please state;

a.    The name, professional status, job title, and address of each individual who presently has custody of the original of the exhibit.
b.    The name, address, job title and professional status of each and every witness from whom you will. At the time of the trial, elicit testimony to admit the exhibit as evidence.




13.  Identify each person, other then counsel, who provided information or assisted you with respect to the preparation of the answers to the foregoing interrogatories, and identify the specific interrogatories for which each person provided information or assistance, and the substantive information provided by each person and/or the type of assistance each person rendered.





14.  Do you attribute any physical, mental, or emotional injuries to the claims made in your complaint. If yes, identify with specificity each injury you attribute to the conduct alleged in your complaint.






15. If you attribute any physical, mental, or emotional injuries to the conduct alleged, please state whether you have sought treatment for those injuries.






16. If you have sought treatment for any physical, mental, or emotional injuries related to the conduct alleged in your complaint, please identify by name and address each treatment provider, the dates of treatment received.






17. For each item claiming physical, mental, or emotional injuries in this action, identify all persons upon whom you will rely on to support your damages in this claim.





CERTIFICATE OF SERVICE

I HERBY CERTIFY that I sent a true and accurate copy of the foregoing via US Postal Mail to Alan K. Marcus, Esq. at the Marcus Law Center, LLC, 2600 Douglas Road, Suite 1111, Coral Gables, Florida  33134 this __ day of December, 2016.

Wolfgang W Halbig, Pro Se
25526 Hawks Run Lane
Sorrento, Florida 32776
Phone:  352-729-2559



____________________________________________

-->
Wolfgang W. Halbig



LATEST DEVELOPMENT:

From: Wolfgang Halbig <wolfgang.halbig@comcast.net>
Date: Sat, 04 Feb 2017 12:31:21 -0500
Subject: Please follow the Florida Civil Procedures as directed by our Judge on Dec 13, 2016 in producing documents in a timely manner.

Mr. Allen:


This will serve again as your Notice to follow the Florida Civil Law Procedures as directed by our Judge during our Dec 13, 2016 Special Hearing, so please comply as required by Florida laws.

You, as today have not received the courts permission on your Motion for an Extension of Time to Produce Leonard Pozner's first set of Interrogatories.

Therefore you are in direct violation of the Florida Civil procedures as of Jan 21, 2017 and I urge you to immediately comply with the production of Leonard Pozner's Interrogatories on my Motion to Compel filed with the Clerk of the Court and showing that you received it on Jan 31, 2017.

The court has not approved your Motion for an Extension of time in producing Leonard Pozner's first set of Discovey Documents so again you are intentionally violating the Florida Civil Procedures since we all have email, iPhones, land line phones, faxes and even Skype to communicate with.

You state that you have not been able to meet or confer with your client in 30 days is absolutely in my opinion questionable and the courts should also question your statement since it is your lawsuit and you should have been prepared to have that information readily available.

I will request that you and your client reimburse me all expenses in this frivolous and harassing lawsuit as you must know.

Please comply.

DEFENDANT’S MOTION TO COMPEL DISCOVERY RESPONSES 

Court:
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA
Case No.
2015 CA 001693
Case Style
Pozner v. Halbig
Document(s)  Served



DEFENDANT’S MOTION TO COMPEL DISCOVERY RESPONSES



Sending Pro Se
Wolfgang W Halbig
25526 Hawks Run Lane
Sorrento, Florida 32776
Sender Phone Number:



Wolfgang W Halbig

10 comments:

  1. I was going to post that this is encouraging news with the caveat that now his lawyer will now begin the usual delay tactics and then I read the final part where they have already begun. Do not expect any meaningful information anytime soon. These delays and obstructions may go on for years. Efforts will need to be made to compel production of information through orders of a judge. It is likely Wolfgang will not be able to accomplish this on his own and will likely have to have a very good lawyer to make things happen. He must be very careful in choosing the lawyer to insure he won't be sold out to the other side. Don't get your hopes up yet on this. It is possible Lenny has left the jurisdiction and even the country. The fact that he failed to show up at the other hearing is likely an indication of fear. He likely feared being served with other lawsuits or papers or being asked rude questions. Hope for the best in this but expect the worst.

    ReplyDelete
  2. My guess is that because this is a civil case with little if any cash value. the defendant probably cannot be arrested. If not, this is likely the end of this case unless Wolfgang wants to begin spending large amounts of dinero on lawyers.

    ReplyDelete
  3. Halbig is completely delusional if he actually believes that he is getting ANY of the bullshit, harassing, request he submitted.

    They are not relevant in any way to the case.

    Halbig is being sued for publishing Pozner's personal information in violation of the laws.

    That's the ONLY question which is going to be addressed.
    He did, or he didn't.
    Period.

    None of Halbig's request have anything to do with it.

    Unless his defense is going to be: "Yeah, I did it, and here's why."

    Good luck with that one.

    ReplyDelete
  4. This is really promising. Best of luck Wolfie!

    ReplyDelete
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  6. so Sandy Hook happened or Naw..like just figure it out already the fuck????

    ReplyDelete
  7. Fetzer is inventing ridiculous nonsense. Lenny was present as he is being represented and it is Halbig who is refusing to answer discovery.
    Halbig was sued for invasion of privacy and now he is demanding MORE private information.
    Halbig has all the opportunity he needs by answering his discovery and proving hoax.

    http://www.jimfetzer.info/holocaust-denier-james-fetzer/

    ReplyDelete
    Replies
    1. Hey, dimwit, by law a defendant has every right to question the validity of the plaintiff.

      Delete
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