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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
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Rafael I. PINKHASOV PINCHAS,
Plaintiff,
v. Civil Action Number:
WMN 01CV2758
Jerald M. JORDAN,
Donalda K. AMMONS and
John M. LOVETT,
Defendants.
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STANDARD DOCUMENT REQUESTS
Pursuant to Fed.R.Civ.P. 34, and L.R. 104, Rafael I. Pinkhasov Pinchas ( "Pinchas" ), the undersigned plaintiff and pro se, requests that defendants Jerald M. Jordan ( "Jordan" ), Donalda K. Ammons ( "Ammons" ) and John M. Lovett ( "Lovett") respond to this Request within the time prescribed by the Scheduling Order of United States District Judge William M. Nickerson dated May 13, 2002, and produce the following documents for inspection and copying on the 10th day of September, 2002, at 10.00 o'clock, a.m., and continuing from day to day thereafter, until completed, at the offices of Rafael I. Pinkhasov Pinchas 76-54 168 Street Hillcrest New York 11366 USA, or at such time and place as may agreed upon by the parties.
In accordance with the above, please produce the following documents:
1. Resume of Jordan.
2. Resume of Ammons.
3. Resume of Lovett.
4. Complete copies of "Call for Nomination for Comite International des Sports des Sourds ( "CISS" ) Executive Committee 2001-2005" nomination form submitted by the respective National Sports Associations on behalf of the following candidates:
a) Lovett of Australia
b) Ammons of the USA
c) Renzo Corti of Italy
d) Ole Artmann of Denmark
e) Isabelle Malaurie of France
f) Vojtech Volejnik of the Czech Republic
g) Dogan Ozdemir of Turkey
h) Harpalis Alwi of Indonesia
i) Pinchas of Uzbekistan.
5. Resume of all persons named below who were listed as candidates for the CISS Executive Committee Member positions for the year period of 2001-2005:
a) Renzo Corti of Italy
b) Isabelle Malaurie of France
c) Vojtech Volejnik of the Czech Republic
d) Dogan Ozdemir of Turkey
e) Harpalis Alwi of Indonesia
f) Pinchas of Uzbekistan.
6. Videofilm of the proceedings of the 2001 CISS Workshop and 37th CISS Congress
held in Rome, Italy, during the days of July 19, 20 and 21, 2001.
7. All correspondence, including via the e-mail, facsimile, USA and International mail, between Jordan and Pinchas.
8. All correspondence, including via the e-mail, facsimile, USA and International mail, between Ammons and Pinchas.
9. All correspondence, including via the e-mail, facsimile and International mail, between Lovett and Pinchas.
10. All communication related to the Verified Complaint and Amended Complaint ( "lawsuit" ), including via the e-mail, facsimile, USA and International mail, between Jordan and all CISS Nation Members.
11. All communication related to lawsuit, including via the e-mail, facsimile, USA and International mail, between Ammons and all CISS Nation Members.
12. All communication related to lawsuit, including via the e-mail, facsimile, International mail, between Lovett and all CISS Nation Members, International Deaf Sports Organizations, International Olympic Committee and World Federation of the Deaf, and non-party individuals, which Jordan, Ammons and Lovett intend to present as evidence during the trial.
13. All correspondence related to Pinchas between Jordan, a member of the CISS Legal Commission, and the National Sport Associations of the USA and Uzbekistan.
14. All correspondence related to Pinchas between Ammons, a CISS Secretary General, and the National Sports Associations of the USA and Uzbekistan.
15. All correspondence related to Pinchas between Lovett, a CISS President, and the National Sports Associations of the USA and Uzbekistan.
16. All communication related to lawsuit, including via the e-mail, facsimile, USA and International mail, between the CISS Home Office and all CISS Nation Members, including International Deaf Organizations.
17. All correspondence related to Pinchas and lawsuit between Jordan and Ammons.
18. All correspondence related to Pinchas and lawsuit between Jordan and Lovett.
19. All correspondence related to Pinchas and lawsuit between Ammons and Lovett.
20. All communication related to Pinchas and lawsuit between Ammons and the CISS Executive Committee.
21. All communication related to Pinchas and lawsuit between Lovett and the CISS Executive Committee.
22. All documents showing that Pinchas was eligible to be nominated as a representative of the National Sports Association of Uzbekistan for the position of the CISS Treasurer for the year period of 1997-2001.
23. All documents showing that Pinchas was ineligible to be nominated as a representative of the National Sports Association of Uzbekistan for the position of the CISS Executive Committee Member for the year period of 2001-2005.
24. All documents that "Plaintiff ( Pinchas ) published information on the Internet through the use of e-mail and his website, www.deafsportlawsuit.com" as allegedly stated in Answer and Counterclaim by Jordan, Ammons and Lovett.
25. All documents supporting the statement allegedly made in Answer and Counterclaim by Jordan, Ammons and Lovett,
"The Plaintiff was disqualified by the organization as a whole specifically
by the Legal Commission."
26. All documents showing that Pinchas' "term as Chair ( of the CISS Awards Commission )
had expired and was not renewed" as allegedly stated in Answer and Counterclaim by Jordan, Ammons and Lovett.
27. All documents supporting the following statements allegedly made in Answer and Counterclaim by Jordan, Ammons and Lovett,
a) "Plaintiff intruded and pried into the private affairs of the Defendants".
b) "Plaintiff published information regarding the private affairs of the Defendants".
c) "As a direct and proximate result of Plaintiff's actions, Defendants suffered
inconvenience, embarrassment, humiliation, emotional distress, pain, anxiety,
trauma, and the indignity and stigma".
28. All documents showing that "Plaintiff's claims, or portions thereof, are barred by statue of limitations or laches" as allegedly stated in Answer and Counterclaim by Jordan, Ammons and Lovett.
29. All documents showing that "Plaintiff's claims, or portions thereof, are barred to the extent that the Plaintiff has not yet exhausted procedures for resolving disputes through the organization as required by the organization's constitution" as allegedly stated in Answer and Counterclaim by Jordan, Ammons and Lovett..
30. All Press Releases related to the lawsuit and issued by attorney of Jordan, Ammons and Lovett.
31. All Press Releases, included published materials related to the lawsuit, issued by non-party individuals, media and organizations and which may be in the possession of Jordan, Ammons and Lovett.
32. All communications, letters, notes related to the lawsuit and received from the National Sports Associations by Jordan, Ammons and Lovett from October, 2001, and to now,
33. All communications, letters, notes related to the lawsuit and received from the non-party individuals by Jordan, Ammons and Lovett from October 2001, and to now.
34. All complaints related to Pinchas, including the Securities Exchange Commission disciplinary case against Pinchas, that Jordan, Ammons and Lovett intend to present as evidence during the trial.
35. Complete copy of the Minutes Report of the 37th CISS Congress held in Rome, Italy.
36. Complete copy of the 2001 CISS Workshop Report held in Rome, Italy.
37. Complete copy of the Minutes Report of the CISS Legal Commission held on July 21, 2001, in Rome, Italy.
38. Complete copies of the CISS Executive Committee meetings held in 2000
a) Lausanne, Switzerland
b) Taipei, Taiwan.
39. Complete copies of all CISS Executive Committee meetings held in 2001.
40. Complete copy of the CISS Executive Committee meeting held in 2002.
41. Complete copy of the list of the names of all nations and delegates who took part at the 36th CISS Congress.
42. Complete copy of the list of the names of nations and delegates who took part at the 37th CISS Congress.
43. Resume of Rebecca Adam, a member of the CISS Legal Commission.
44. Resume of Knud Sondergaard, the Chairman of the 2001 CISS Awards Commission.
45. Resume of all candidates for the position of the CISS Sports Director for the year period of 2001-2005.
46. Resume of all members of the 2001 CISS Media Team.
47. All receipts submitted by Pinchas to the CISS Treasurer for payment
a) as Member of the CISS World Records Commission between 1979 and 1981
b) as the Chairman of the CISS Awards Commission between 1996 and 2001
c) as Paper Co-Presenter on behalf of the CISS at the International Deaf History Conference in 2000.
48. All receipts for food, lodgings and postage of Pinchas as the Member of the CISS World Records Commission covered by the CISS between 1979 and 1981 and during the Deaflympic Summer Games in 1981.
49. All receipts for food and lodgings of Pinchas as the CISS Awards Commission Chairman and CISS Bulletin writer covered by the CISS during the Deaflympic Summer Games in 1997 and Deaflympic Winter Games in 1999.
50. The CISS Constitution produced following the end of
a) 36th CISS Congress
b) 37th CISS Congress
51. The Deaflympic Games Regulations produced following the end of
a) 36th CISS Congress
b) 37th CISS Congress
52. The Deaf World Championships Regulations produced following the end of
a) 36th Congress
b) 37th CISS Congress
53. Updated version of the CISS By-Laws as mentioned in the CISS Constitution Rule 17.
54. All issues of the CISS Bulletin between 1981 and 1986.
55. All issues of the CISS Bulletin between 1995 and 2001.
56. All issues of the CISS e-News Magazine between December, 2001, and now.
57. All documents in the CISS Home Office file related to Pinchas.
58. All documents in the CISS Home Office file bearing the signature of Pinchas.
59. CISS Bi-annual Report for 1999 and 2000 which was presented to the delegates of the 37th CISS Congress on Friday, July 20, 2001.
60. List of the names of all members of the 2001 CISS-Widex Deaf World SportsMan and
SportsWoman of the Year Selections Commission.
61. List of the names of all members of the 2001 CISS-Widex Deaf World SportsMan and SportsWoman of the Year Screening Commission.
62. List of scoring point system utilized by the CISS Awards Commission regarding the 2001 CISS-Widex Deaf World SportsMan and SportsWoman of the Year Selections.
63. Complete copy of the scoring sheet summary produced by the Chairman of the CISS Awards Commission regarding the 2001 CISS-Widex Deaf World SportsMan and SportsWoman of the Year Selections.
64. All contracts and agreements signed for the year periods of 1997-2001 and
2001-2005 between
a) CISS and each CISS Executive Committee Member
b) CISS and each CISS Technical Director
c) CISS and each CISS Legal Commission Member
d) CISS and CISS Home Office Administrative Assistant
c) CISS and Pinchas.
65. Letter signed by Nikolay Klimov and Vladimir Galchenko of Russia, which was published in the CISS e-News Magazine, Number 206, June, 2002.
66. Resume, curriculum vitae or other written credentials for any expert witness whom Jordan, Ammons and Lovett intend to call at the trial.
Dated: Queens, New York, USA
July 10, 2002
____________________________
Rafael I.Pinkhasov Pinchas
Plaintiff and Pro Se
TO: Kelby N. Brick
Attorney for Defendants
Jerald M. Jordan,
Donalda K. Ammons,
John M. Lovett.
VIA USA REGISTERED MAIL
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