IN THE CIRCUIT COURT FOR THE CITY OF ALEXANDRIA ERIC J. BONETTI, Plaintiff, vs.
CIVIL ACTION NUMBER: 2020 06480
ROBERT H. MALM, Defendant
PRAECIPE
The Clerk is requested to issue a Subpoena Duces Tecum to Grace Episcopal Church Alexandria, with offices located at 3601 Russell Road, Alexandria VA 22305 requesting the following: 1. All records, including but not limited to, emails, phone records, memos, notes, calendars, or correspondence in which Sigrid Yahner or someone purporting to be her requested a meeting or with Defendant Robert H. Malm or any employee or agent of Grace Episcopal Church, from January 1 2015 to the present. 2. All records, including but not limited to, emails, phone records, memos, notes, calendars, or correspondence in which Sigrid Yahner or someone purporting to be her contacted Defendant Robert H. Malm or any employee or agent of Grace Episcopal Church, from January 1 2015 to the present. 3. Any and all records or documentation not identified above that support Defendant Robert H. Malm’s statement made in interrogatories sworn and subscribed to on or about April 5, 2018, and notarized by Jane Rosman, in which Defendant Robert H. Malm stated that Sigrid Yahner repeatedly set up meetings with Defendant Robert H. Malm, only to cancel. (Exhibit A, attached, page 5).
4. The identity of any person or persons known to the agents, employees, clergy, or volunteers of Grace Episcopal Church who can confirm Defendant Robert H. Malm’s claim that Sigrid Yahner or someone purporting to be her repeatedly set up appointments with Defendant, only to cancel. 5. Plaintiff requests that records be forwarded via electronic mail within thirty days of service.
The Clerk is asked to forward the requested subpoena to the Alexandria sheriff for service upon Grace Episcopal Church. Respectfully submitted,
Eric J. Bonetti Pro se plaintiff 4129 Fountainside Lane 203 Fairfax VA 22030 eric.bonetti@protonmail.com
CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was emailed on December 25, 2020 to counsel for the defendant per the following: Wayne Cyron, Esq. Bankers Square Office Building 100 North Pitt Street, Suite 200 Alexandria, Virginia 22314 Cml@cyronmiller.com Matthew J. Youssef, Esq. 111 South Calvert Street Suite 1400 Baltimore, MD 21202 mjyoussef@nilesbarton.com
Exhibit A