UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA
ERIC J. BONETTI, Plaintiff,
CIVIL Case No.:
vs. EPISCOPAL DIOCESE OF VIRGINIA, ROBERT HILLER MALM, CITY OF ALEXANDRIA, COMMONWEALTH OF VIRGINIA EPISCOPAL DIOCESE OF MASSACHUSETTS ST. GABRIEL’S EPISCOPAL CHURCH Defendants
PLAINTIFF’S FIRST SET OF INTERROGATORIES TO DEFENDANT ROBERT HILLER MALM
COMES NOW Plaintiff, Eric J. Bonetti, and files these interrogatories pursuant to the Federal Rules of Civil Procedure to Defendant Robert H. Malm. 1. In your responses to Plaintiff’s request for an injunction, you, Robert Hiller Malm, state through counsel that Plaintiff’s blog “continues to harm defendants.” In light of this statement, state why you have not sought protective orders against the following online publications or their publishers, which have covered perjury, witness tampering, concealment of evidence, and other misconduct by you and Grace Episcopal Church: The Wartburg Watch, located at www.thewartburgwatch.com; Surviving Church, located at www.survivingchurch.org; Wondering Eagle, located at https://wonderingeagle.wordpress.com/2018/01/10/additionalallegations-of-abuse-arise-at-grace-episcopal-church-in-alexandria-virginia/ ; or Blake Writes, presently located at http://www.selfimprovement.com. RESPONSE:
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2. State under oath how many times in the past six months you and Leslie Malm, Lindsey Malm Anders, or any person acting on your behalf, have accessed Plaintiff’s blog, located at www.gracealexwatch.org. RESPONSE: 3. In yes or no fashion, state under oath whether your statement in prior interrogatories, promulgated during litigation before the Alexandria VA Circuit Court, that Sigrid Yahner contacted you repeatedly to set up appointments, is truthful.
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RESPONSE: 4. In yes or no fashion, state under oath whether your statement in prior interrogatories, promulgated during litigation before the Alexandria VA Circuit Court, that you made no false statements in conjunction with your application for a protective order, is truthful. RESPONSE: 5. In yes or no fashion, state under oath whether your statement in prior interrogatories, promulgated during litigation before the Alexandria VA Circuit Court, that you have not committed perjury in proceedings against Plaintiff, is truthful. RESPONSE:
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6. In yes or no fashion, state under oath whether your statement before the Wareham District Court, in which you stated that you did not commit perjury in proceedings before the Alexandria Circuit Court by virtue of the fact that you “didn’t even know his mother’s name,” is truthful.
RESPONSE:
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7. In yes or no fashion, state under oath whether you lied to Bishop Shannon Johnston when you told him via email dated November 22, 2017, that Plaintiff ceased employment with RPJ Housing prior to joining Grace Episcopal Church. Because you have denied in the Alexandria litigation having seen the email in question, a copy is included below for your reference.
RESPONSE:
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8. In yes or no fashion, state under oath whether you have stated to Massachusetts law enforcement officials that Plainitff has “stalked,” “threatened” and “harassed” you and your family. RESPONSE: 9. In yes or no fashion, state under oath whether you concealed evidence from Plaintiff and his attorney during prior litigation before the Virginia courts. RESPONSE: 10. In yes or no fashion, state under oath whether you have made any false or misleading statements to any law enforcement officers or judicial officials in the course of proceedings against Plaintiff. RESPONSE: 11. In yes or no fashion, state under oath whether your actions were authorized by the vestry of Grace Episcopal Church RESPONSE: 12. State under oath why you did not provide 16 emails, including the one supra, which you sent to Bishop Shannon Johnston accusing Plaintiff of having embezzled from a previous employer, during previous discovery. RESPONSE:
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I, Robert Hiller Malm, state under penalty of perjury, including but not limited to the provisions of 18 U.S. Code § 1623, that my responses to these interrogatories are true and accurate, dated this ______ day of ______, 2021. Signature: _______________________ Attorney signature: _____________________ Date: ______________ Please notarize your responses below: You are requested to return these interrogatories, signed under oath and notarized, within 30 days of receipt, and to file a copy with the clerk of court. In the event you do not file a copy with the clerk of court for the Federal District Court for the Eastern District of Virginia, be advised that Plaintiff will do so.
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A copy of this request is being sent to defense counsel by email this 17th day of April per the following and will be notarized and filed with the court. The case number is left blank as the Plaintiff understands that his amended case will be assigned a new docket number. Craig D. Roswell, Esquire (VSB No.: 33901) Matthew J. Youssef, Esquire (VSB No.: 85339) NILES, BARTON & WILMER, LLP 111 S. Calvert Street, Suite 1400 Baltimore, Maryland 21202 (410) 783 –6357 (410) 783 –6452 cdroswell@nilesbarton.com mjyoussef@nilesbarton.com Counsel for Defendant, Grace Episcopal Church and Episcopal Diocese of Virginia Wayne F. Cyron, Esquire (VSB No. 12220) CYRON & MILLER LLP 100 N. Pitt St., Suite 200 Alexandria, VA 22314 703-299-0600 703-299-0603 (fax) wcyron@cyronmiller.com Counsel for Defendant, Robert H. Malm Alexandria City Attorney 301 King Street, Suite 1300 P. O. Box 178 Alexandria, Virginia 22313 George.mcandrews@alexandriava.gov Respectfully submitted, Eric J. Bonetti Pro se plaintiff 4129 Fountainside Lane 203 Fairfax VA 22030 703-973-4984 Eric.bonetti@protonmail.com
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