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Subject:  Motion to Order Subpoeana of Records...
   From:  Michael Williams 100705,1252
     Date:  03-Sep-95 12:31

IN THE UNITED STATES COURT OF APPEALS
FOR THE SEVENTH CIRCUIT
EASTERN DIVISION

UNITED STATES OF AMERICA,       )
                                                )
                        Plaintiff.              )       CASE NO. 94 24 83
                                                )
                v.                              )       JUDGE LEINENWEBER
                                                )
MICHAEL WILLIAMS,                       )
                                                )
                        Defendant.              )

MOTION TO ORDER THE SUBPOENA OF RECORDS AND RECEIPTS
PURSUANT TO CIVIL RULE 56
AND FOR AN ORDER PROHIBITING THE GOVERNMENT'S 
CONTACT WITH BEARERS OF RECORDS AND RECEIPTS 
FOR THE DURATION OF THESE PROCEEDINGS
PRO SE APPELLANT


TO:     United States Court of Appeals          Carol A. Davilo 
        ATTN: Paula Zapaniac                    Assistant United States Attorney        
        219 S. Dearborn, 27th Fl.                       219 S. Dearborn, 20th Fl.
        Chicago, IL   60604                             Chicago, IL   60604
        
        Mr. Thomas F. Strubbe                   SA Richard Loyd
        Clerk of the U.S. Court of Appeals              FBI - Room 905
        219 S. Dearborn, 20th Fl.                       219 S. Dearborn
        Chicago, IL   60604                             Chicago, IL   60604

        Juleann Hornyak                         Mary Robinson
        Clerk of the Supreme Court                      Administrator
        Supreme Court Building                  A.R.D.C. 
        Springfield, IL   62706                 One Prudential Plaza
                                                        130 E. Randolph Drive
        Tebo's Coins                                    Chicago, IL   60601-6219
        2863 28th 
        Boulder, CO   80301                             F.D.I.C.
                                                        Washington, DC   20429-9990
        Columbine National Bank
        6900 E. Hampden Ave.
        Denver, CO   80224      
                
I, Michael Williams, declare that I am the Defendant in the above-entitled
proceeding. I 
am not an attorney, do not have the funds necessary to retain one, have not
been 
appointed one despite my many persistent requests, and am thus being forced to
prepare 
this motion myself, even though I am not qualified to do so.

1.)     On 18. March 1988, agents of the Federal Bureau of Investigation (F.B.I.), 
        apparently led by Special Agent Richard C. Loyd, placed Defendant under arrest
        at his home at 27810 Pine Drive in Evergreen, Colorado.
2.)     At the time of Defendant's arrest, the F.B.I. unlawfully seized significant
assets
        and personal property from Defendant, Defendant's family members, and Pioneer
        America Corporation, where Defendant served as President.

3.)     The unlawful seizure of said property is the subject of this appeal.

4.)     Included in the F.B.I.'s unlawful seizure were records and receipts proving
the 
        rightful legal ownership of the unlawfully seized property.

5.)     The F.B.I. and U.S. Attorney's Office, in their zeal to cover up and
"legalise"      
        said unlawful seizure, in order to avoid the criminal prosecution of those
agents 
        involved in the unlawful seizure and its subsequent and continuing cover up,
and 
        deprive Defendant, the rightful owner, of the just return of his
legally-purchased 
        property, are attempting to withhold evidence from Defendant and the Court 
        which would prove the rightful legal ownership of said unlawfully seized 
        property.

6.)     Included in the unlawfully seized records and receipts were records and
receipts
        from Tebo's Coins, 2863 28th, Boulder, Colorado   80301   which prove that
        Defendant and Pioneer Corporation legally purchased a significant amount of
        gold coins from Tebo's Coins.
        
7.)     In their concerted efforts to deny Defendant his rights, and deny Defendant
and 
        the Court access to the records and receipts which would serve as prima facie 
        evidence of rightful ownership, and therefore deprive Defendant of his rights
and 
        defraud the Court, the  F.B.I. and U.S. Attorney's Office have wrongfully 
        withheld, and are continuing to wrongfully withhold this evidence.

8.)     In his sincere and diligent efforts to obtain copies of these records and
receipts,
        which are essential to the defence of this case, Defendant has written to
Tebo's
        Coins, requesting copies of the receipts, and explaining the reason for their
        urgent need.

9.)     Defendant's letters and the requests contained therein, have been ignored,
and he
        has received no reply to them, nor acknowledgment of their receipt.



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10.)    In his last letter to Tebo's Coins dated 4. July 1995 and sent via
registered air 
        mail, Defendant wrote that "In the event you choose to continue to ignore my 
        request to furnish me with this information, I will ask the Court to subpoena
it."
        A copy of this letter is Attachment No. 1.

11.)    As of today, 13. July 1995, Tebo's Coins has still failed to respond to 
        Defendant's correspondence.

12.)    Defendant's attempts to contact the United Bank of Boulder, in Boulder, 
        Colorado, in order to request canceled cheques and other records and receipts
        proving he legally paid for purchases of gold coins from Tebo's coins with
        funds from his account there, proved futile, as Defendant is unable to locate
the
        bank. 

13.)    It appears that the United Bank of Boulder has either changed its name,
gone out
        of business, or been taken over by another bank.

14.)    In his sincere and diligent efforts to obtain copies of these records and
receipts,
        which are essential to the defence of this case, from the United Bank of
Boulder, 
        Defendant has written to the Federal Deposit Insurance Corporation (FDIC) in 
        Washington, DC   20429-9990, requesting information as to the present 
        whereabouts of said bank, and explaining the reason for his urgent need for
this 
        information.

15.)    Defendant's letters to the FDIC and the requests contained therein, have
been 
        ignored, and he has received no reply to them, nor acknowledgment of their 
        receipt.

16.)    In his last letter to the FDIC. dated 4. July 1995 and sent via registered
air 
        mail, Defendant wrote that "In the event you choose to continue to ignore my 
        request, I will notify the court and ask that the information be subpoenaed."
        A copy of this letter is Attachment No. 2.

17.)    As of today, 13. July 1995, the FDIC. has still failed to respond to
Defendant's 
        correspondence.



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18.)    In his sincere and diligent efforts to obtain copies of these records and
receipts,
        particularly canceled cheques, which are essential to the defence of this
case, 
        Defendant has written to the Columbine National Bank, 6900 E. Hampden Ave., 
        Denver, CO   80224, where Pioneer America Corporation maintained a chequing 
        account, since on or about 23. June 1990, requesting copies of the records and

        receipts, and explaining the reason for their urgent need.

19.)    Defendant's letters and the requests contained therein, have been ignored,
and he
        has received no reply to them, nor acknowledgment of their receipt.

20.)    In his last letter to the Columbine National Bank, dated 4. July 1995 and
sent via 
        air mail, Defendant wrote that "In the event you choose to continue to ignore
my 
        request to furnish me with this information, I will ask the Court to subpoena
it."
        A copy of this letter is Attachment No. 3.

21.)    As of today, 13. July 1995, the Columbine National Bank has still failed
to 
        respond to Defendant's correspondence.

22.)    The F.B.I. has previously contacted all parties known to possess records,
receipts
        or information pertaining to this case, and has terrorised such parties into
unlawful
        cooperation, as well as manipulation and supply of said records.

23.)    Prior to Defendant's arrest and the unlawful seizure of his assets and
property,
        which took place on 18. March 1988, Defendant was contacted by a high
        official of one bank at which Defendant maintained a personal chequing account
        and credit cards. The official stated that his bank had received a request
from a
        Special Grand Jury in Chicago, Illinois to supply them with all records
pertaining
        to Defendant, Defendant's family members, and other names unknown to
        Defendant, which seemed to be aliases Defendant was being accused of using.
        The gentleman informed Defendant that he deemed it highly improper of the
        Special Grand Jury to make such requests without allowing Defendant his right
        to a hearing, and he advised Defendant to consult with an attorney in order to
        attempt to quash what he considered to be an improper request.





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24.)    After a lengthy conversation with the bank official, Defendant soon
obtained
        representation by Chicago attorney Michael Monico, who agreed to move to
        quash the improper request.

25.)    Due to highly unusual behaviour by Michael Monico and numerous false 
        statements recently made by him after Defendant filed a formal complaint
        against him with the Attorney Registration and Disciplinary Commission
        (A.R.D.C.) of the Supreme Court of Illinois, Defendant is unsure of
        what, if any measures, were taken by Mr. Monico to quash the improper
        request.

26.)    Defendant's correspondence to Mr. Monico has been completely ignored.

27.)    Attorney Michael Monico possesses copies of records, receipts and other
        information pertaining to Defendant's rightful ownership of the unlawfully
        seized property, the improper Special Grand Jury request, his allleged
        attempts to quash the improper request, and multiple conversations he claims 
        to have had with Assistant U.S. Attorney Laurie Barsella, Chicago F.B.I.
        Special Agent Richard C. Loyd, Denver F.B.I. Special Agent Charles W.
        Stuber, Jr., and others.

28.)    The copies of records, receipts, notes detailing conversations with took
place
        between Attorney Michael Monico and Assistant U.S. Attorney Laurie Barsella, 
        Chicago F.B.I. Special Agent Richard C. Loyd, Denver F.B.I. Special Agent 
        Charles W. Stuber, Jr., and others are urgently required by Defendant for the
        proper defence of this case.

29.)    In a letter written to Defendant dated 24. February 1992, F.B.I. Special
Agent in 
        Charge Delbert Dilbeck admitted that the F.B.I. had seized a portion of 
        Defendant's computer equipment on 18. March 1988.

30.)    After receiving the letter from Agent Dilbeck, Defendant contacted his
court-
        appointed attorney, William J. Stevens, who immediately offered to fetch the
        computer equipment. At this time, Mr. Stevens also stated that someone in the 
        F.B.I. had made a major error in finally admitting that any property had been 
        seized, and stated that he would use the invaluable opportunity to immediately
        

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        demand the prompt return of the remainder of Defendant's unlawfully seized
        assets and property. 

31.)    Although Mr. Stevens failed to demand the return of the remaining
property, he
        did arrange for the computer equipment to be fetched and sent to Defendant via
        Federal Express.

32.)    When Defendant received the Federal Express delivery, it contained not
only the
        computer equipment mentioned in Agent Dilbeck's letter, but a cable TV control
        which had been connected to Defendant's television at his home in Colorado.

33.)    Said cable TV control was not mentioned in Mr. Dilbeck's letter, and was 
        obviously released to Defendant in error.

34.)    At the time of Defendant's arrest and the unlawful seizure of his assets
and
        property on 18. March 1988, one F.B.I. agent took one of Defendant's
        television sets and the cable TV control which was connected to it. When
        Defendant's wife questioned the value of the television set and cable TV
        control to the F.B.I., the agent responded: "To show the whole set up here -
        besides, I like this TV".

35.)    Defendant would like to submit the cable TV control as an exhibit in this
case,
        to demonstrate that the F.B.I. has only admitted to a small, insignificant
        portion of his unlawfully seized property.

36.)    Defendant's television set had only been purchased shortly before his
arrest and
        the unlawful seizure.

37.)    Defendant believes the television set had been purchased at Sears
Department
        Store, in Boulder, Colorado, and was charged to Defendant's Sears credit card.

38.)    Defendant requires records and receipts of any and all of his credit card
accounts, 
        including, but not limited to department store account, particularly for his
Sears
        account, in order to demonstrate that said television set was legally
purchased by
        Defendant and illegally seized by the F.B.I. and to further demonstrate that
the 
        F.B.I. has only admitted to a small, insignificant portion of his unlawfully
seized 
        property.

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WHEREFORE, Defendant, Michael Williams, Pursuant to Civil Rule 56, respectfully

requests entry of an Order subpoenaing all records pertaining to Defendant,
Defendant's 
family members and Pioneer Corporation from Tebo's Coins; the United Bank of 
Boulder; the FDIC, the Columbine National Bank; Attorney Michael Monico; Sears,

Roebuck & Company; and an Order subpoenaing any related records, receipts or
files the 
F.B.I. or U.S. Attorney's Office has in its possession and Order prohibiting
the 
government's contact with bearers of records and receipts for the duration of
these 
proceedings, including, but not limited to Tebo's Coins; the United Bank of
Boulder; the 
FDIC; Columbine National Bank; Attorney Michael Monico; Sears, Roebuck & 
Company, or any other individual or entity possessing such records, receipts or

information.
                                                
                                                
                                                Respectfully submitted,



                                                                                        
                                                MICHAEL WILLIAMS, in Pro Se
                                                Postfach 20
                                                CH-3112 Allmendingen bei Bern
                                                Switzerland






























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AFFIDAVIT OF MAILING

CANTON OF BERNE                 )
                                                )       
COUNTRY OF SWITZERLAND  )


MICHAEL WILLIAMS swears that on the 13th day of July, 1995, he placed a copy of

MOTION TO ORDER THE SUBPOENA OF RECORDS AND RECEIPTS 
PURSUANT TO CIVIL RULE 56 AND FOR AN ORDER PROHIBITING THE 
GOVERNMENT'S CONTACT WITH BEARERS OF RECORDS AND RECEIPTS 
FOR THE DURATION OF THESE PROCEEDINGS - PRO SE APPELLANT in 
envelopes addressed to the following named individuals and caused the envelopes
to be 
deposited in the Swiss mail depository located at the PTT Post Office in
Allmendingen bei 
Bern, Switzerland on said date at or before the hour of 5:00 p.m.


        United States Court of Appeals          Carol A. Davilo 
        ATTN: Paula Zapaniac                    Assistant United States Attorney        
        219 S. Dearborn, 27th Fl.                       219 S. Dearborn, 20th Fl.
        Chicago, IL   60604                             Chicago, IL   60604
        
        Mr. Thomas F. Strubbe                   SA Richard Loyd
        Clerk of the U.S. Court of Appeals              FBI - Room 905
        219 S. Dearborn, 20th Fl.                       219 S. Dearborn
        Chicago, IL   60604                             Chicago, IL   60604

        Juleann Hornyak                         Mary Robinson
        Clerk of the Supreme Court                      Administrator
        Supreme Court Building                  A.R.D.C. 
        Springfield, IL   62706                 One Prudential Plaza
                                                        130 E. Randolph Drive
        Tebo's Coins                                    Chicago, IL   60601-6219
        2863 28th 
        Boulder, CO   80301                             F.D.I.C.
                                                        Washington, DC   20429-9990
        Columbine National Bank
        6900 E. Hampden Ave.
        Denver, CO   80224      

                                                Respectfully submitted,



                                                                                        
                                                MICHAEL WILLIAMS, in Pro Se
                                                Postfach 20
                                                CH-3112 Allmendingen bei Bern
                                                Switzerland


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