HomeMy WebLinkAbout96-00174
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY. PA
ROBERT ALLEN KEMP
PlaintifT - Petitioner.
SUPERIOR COURT OF
DEKALB COUNTY, GEORGIA
CIVIL ACTION
FILE NO : 95-15208-2
vs.
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CUMBERLAND COUNTY. PA
NO, (,'~. /7'/ {i;x:i '/..l.'~
KAREN KNOX KEMP (LEHMAN)
Defendant - Respondent
ORDER
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AND NOW, January ~. 1996, the Petition for Issuance ofa Subpoena is granted;
the
Prothonotary is directed to issue a subpoena in the limn attached hereto as exhibit A; and the
records requested in said subpoena are to be forwarded to Robert Allen Kemp at 4611 South
University Drive Suite # 180 Davie. Florida 33328, in order thatPlaintin:I'etitioner may
properly prepare for the above referenced case on or before the 26th day of January, 1996.
By the Court:
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7. The records omilled from the Plaintiff. Petitioner's employee file are pertinent evidence
in the above referenced case, The records omilled are specifically as follows:
a, One leller which was sent to L. B, Smith, Inc, or one of its branches form a fictitious
detective agency which falsely stipulated that the Plaintiff.Petitioner had severnl drinking
and driving offenses, was convictcd of one or more Iclonies, and other various slanderous
implications,
b, One or more pages oflhlsified and misleading court documents relating to previous
charges against the Plaintiff.Petitioner which were in reality dismissed,
c, One letter addressed to the President of L, B. Smith, Inc, wrillen by the
Plaintiff.Petitioner in regards to his termination of employment form L, B, Smith, Inc.
WHEREFORE, Plaintiff. Petitioner prays:
(a) That Court Order and the Subpoena issued against L, B, Smith, Inc. be complied with
immediately.
(b) That ifL, B. Smith, Inc, has failed to comply in full by the 7th day of February, 1996 a
representative from L. B. Smith, Inc" specifically Mr, Daniel Bobik of the Fort Lauderdale
Branch is ordered to personally appear on the 13th day of February, 1996 at the Superior Court
of Dekalb County, Room 404 of the Dekalb County Courthouse, Decatur, Georgia at 9:30 a.m,
and bring with you the aforementioned records and documents and be prepared to testilY.
(c) That if L. B. Smith, Inc, continues to disregard this Court Order and Subpoena, they
be held subject to the sanctions authorized by Rule 234,5 of the Pennsylvania Rules of Civil
Procedure, including but not limited to damages, costs, allorney fees and imprisonment,
Respectfully Submilled,
f2.0--f ?
Robert Allen Kemp
4611 S, University Dr, #180
Davie, Florida 33328
(954) 436.1217
,
COMMONWEALTH OF PENNSYL VANIA
COUNTY OF CUMBERLAND
ROBERT ALLEN KEMP
Plaintiff. Petitioner,
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SUPERIOR COURT OF
DEKALB COUNTY, GEORGIA
CIVIL ACTION
FILE NO : 95.15208.2
VS,
KAREN KNOX KEMP (LEHMAN)
Defendant. Respondent
CUMBERLAND COUNTY, PA
NO: 1996-174
MOTION FOR COMPI~IANC~
WITH COURT ORDERED SUBPOENA
The Plaintiff. Petitioner, Robert Allen Kemp, submits this his Motion for Compliance with
Court Ordered Subpoena and states the following:
I, The Plaintiff.Petitioner and the Defendant.Respondent are parties to civil litigation in
the Superior Court of Dekalb County in the State of Georgia with Civil Action File no.
95.15208.2,
2. The Plaintiff. Petitioner recently submilled a Petition for Issuance of a Subpoena, a
Court Order and a self styled Subpoena to the Court of Common Pleas, Cumberland County,
Pennsylvania on January 12th, 1996.
3. The Honorable Judge Harold E. Sheely approved the Order for said Subpoena on the
18th day of January, 1996,
4. The subpoena requested from L. B. Smith, Inc" a corporation located in Cumberland
County, Pennsylvania, that any and all employee records pertaining to the Plaintiff.Petitioner
records be sent to the Plaintiff.Petitioner.
S. The Plaintiff-Petitioner received above referenced records on the I st day of February,
1996 and found relevant portions of the records had been omilled,
6. L, B. Smith, Inc, is in noncompliance of the above referenced Court Order and by doing
so is showing complete disrespect for the Court and Judges Order,
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7. The records omilled from the Plaintiff.Petitioner's employee tile are pertinent evidence
in the above referenced case. The records omilled are specifically as follows:
a, One leller which was sent to L, 8, Smith, Inc, or one of its branches form a fictitious
detective agency which falsely stipulated that the Plaintil1:Pelitioner had several drinking
and driving offenses, was convicted of one or more felonies, and other various slanderous
implications,
b. One or more pages of falsified and misleading court documents relaling to previous
charges against the Plaintiff-Petitioner which were in reality dismissed,
c. One leller addressed to the President of L. 8, Smith, Inc. wrillen by the
Plaintiff-Petitioner in regards to his teonination of employment form L, 8, Smith, fnc.
WHEREFORE, Plaintiff-Petitioner prays:
(a) That Court Order and the Subpoena issued against L, 8, Smith, fnc, be complied with
immediately.
(b) That ifL, 8, Smith, fnc, has failed to I;omply in full by the 7th day of February, 1996 a
representative from L, 8, Smith, fnc,. specifically Mr. Daniel 80bik of the Fort Lauderdale
Branch is ordered to personally appear on the 13th day of February, 1996 at the Superior Court
ofDekalb County, Room 404 of the Dekalb County Courthouse, Decatur, Georgia at 9:30 a,m.
and bring with you the aforementioned records and documents and be prepared to testifY.
(c) That if L. B, Smith, fnc. continues to disregard this Court Order and Subpoena, they
be held subject to the sanctions authorized by Rule 234.5 of the Pennsylvania Rules of Civil
Procedure, including but not limited to damages, costs, allomey fees and imprisonment.
Respectfully Submilled,
~~
Robert Allen Kemp
4611 S. University Dr. #180
Davie, Florida 33328
(954)436-1217