Perjuring Priest Bob Malm Served Interrogatories in Pennsylvania Lawsuit

PENNSYLVANIA:

IN THE COURT OF COMMON PLEAS FOR VENANGO COUNTY

ERIC J. BONETTI, Plaintif,

CIVIL ACTION NUMBER: 806-2020

vs.

ROBERT H. MALM, Defendant

PLAINTIFF’S FIRST INTERROGATORIES TO DEFENDANT COMES NOW Plaintif, ERIC J. BONETTI, in the above-titled action and, pursuant to the Rules of the Supreme Court of Pennsylvania, and hereby requests that Defendant, ROBERT H. MALM, answer fully, in writing, and under oath the following interrogatories in accordance with the Pennsylvania Rules pertaining to discovery.

INSTRUCTIONS A.

Answer each Interrogatory separately and fully in writing and under oath, unless

it is objected to, in which case the reasons for objections must be stated. You are requested to serve a copy of your answers upon plaintif within twenty-one (21) days at 4129 Fountainside Lane #203, Fairfax VA 22030.

B. These Interrogatories are continuing in nature and require you to update and/or correct the information given pursuant to Rule 4:1(E).

C. Produce all documents that were used in preparation of your answers to Interrogatories or that are relevant to the matters addressed by the Interrogatories or your answers.

D.

If any document to which you refer in your answers to these Interrogatories will

be withheld because of claimed privilege or work-product rule, the identity and fact of existence of such document, and specifically why you claim it should be exempt from your production,

including the nature of the privilege being claimed, must still be set forth. Unless divulging such information would cause disclosure of the allegedly privileged information, the following information should be provided in the objection, if known or reasonably available. a.

For oral communications, the name of the person making the communication and the names of the persons present while the communication was made, and, where not apparent, the relationship of the persons present to the person making the communication; the date and place of the communication; and the general subject matter of the communication. b.

For documents, the type of document; the general subject matter of the document; the date of the document; and such other information as is sufficient to identify the document, including, where appropriate, the author, addressee, custodian, and any other recipients of the document, and were not apparent, the relationship of the author, addressee, custodian, and any other recipient to each other.

E. These instructions and definitions should be construed to require answers based upon the knowledge of any information available to you, as well as your agents, representatives, and, unless privileged, attorneys. Any requested information, unless privileged, which is known by any of your attorneys, accountants, or other agents, acquired while acting on your behalf, shall be given in response to these Interrogatories.

F. No part of an interrogatory should be left unanswered merely because an objection is interposed to another part of the interrogatory. If a partial or incomplete answer is provided, you shall state that the answer is partial or incomplete. If, in answering these Interrogatories, you encounter any ambiguity when construing a question, instruction, or definition, your answer shall set forth the matter deemed in the construction used in answering.

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To the extent you do not know the precise information requested, provide your best estimate thereof.

DEFINITIONS A.

The term “date” means the exact day, month, and year, if ascertainable, or, if not,

your best approximation thereof.

B. The word “person,” used in these Interrogatories, includes both the singular and plural, and includes legal, business, or governmental entities and organizations as well as individual, natural persons.

C. Where the name or identity of a person is requested, state full name, home address, telephone number, and also business address and telephone number, if known. When referring to a person, to “identify” means to state the person’s full name, present or last known address, relationship to you, and, when referring to a natural person, additionally, the present or last known place of employment. If the business and home telephone numbers are known, and if the person is not a party or present employee of a party, said telephone numbers shall be provided. Once a person has been identified in accordance with this subparagraph, only the name of the person need be listed in response to subsequent discovery requesting the identification of that person.

D. Where referring to documents, to “identify” means to state the: (i) type of document; (ii) general subject matter; (iii) date of the document; (iv) the author(s), addressee(s), and recipient(s); and (v) its present or last known location and custodian, or, alternatively, to produce the document. If pursuant to Rule 4:8(f) you elect to specify and produce records in answer to any Interrogatory, the specification shall be in sufficient detail to Bonetti v. Malm Interrogatories to Defendant Page 3 of 10

permit us to locate and identify the records from which the answer may be ascertained.

E. The term “communication” means the transmittal of information by any means.

F. When referring to communications, to “identify” means to state the: (i) description of the subject matter communicated; (ii) the date it took place; (iii) the means of communication; (iv) the place when it occurred; (v) who initiated the communication; and (vi) the identity of each person who sent, received, participated in, or has knowledge of it.

G. The term “document” and “documents” are defined to be synonymous in meaning and equal in scope to the usage of the term “documents” in Rule 4:9(a) and include(s) the term “writing”. Electronic mail is included within the definition of the term “document”. A draft or non-identical copy is a separate document within the meaning of the term “document”.

H. The term “concerning” means relating to, referring to, describing, evidencing, or constituting.

I. The terms “you” or “your” include the person(s) to whom these Interrogatories are addressed, and all of that person’s agents, representatives, and attorneys.

J. The term “Plaintif” refers to ERIC BONETTI. K. The terms “and” and “or” shall be both conjunctive and disjunctive.

L. Where appropriate, the masculine gender may be considered to be substituted for the feminine gender, and vice versa, and the singular may be considered substituted for the plural and vice versa.

M. Unless otherwise indicated, these Interrogatories refer to the time, place, and circumstances of the subject matter mentioned or complained of in the pleadings.

INTERROGATORIES

1.

Explain in detail the date when you first learned about Plaintif’s alleged blog and

when you first began reading entries in Plaintif’s alleged blog.

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ANSWER:

2.

Explain in detail the circumstances around your claim, made in writing, under

oath, and while advised by legal counsel in the previous litigation involving this matter that Sigrid Yahner or someone claiming to be her contacted you repeatedly to set up appointments, only to cancel. Include the means by which she or this other individual contacted you (email, phone, letter, in-person, fax, or other), the topic of the conversation; what Ms. Yahner or this other individual requested from you; the specific email addresses, phone numbers, or other means you used when speaking with Ms. Yahner or this individual; and the names and contact information for any witnesses who can corroborate your claim.

ANSWER:

3.

Explain in detail the blog entry or entries in which Plaintif allegedly used the

word “terrorist” or the words “terrorist attacks,” as you stated in your answer to question six of your petition for a protective order, including the date(s) of the blog entry or entries, the full sentence in which the word(s) were used, and the name of the signing author(s).

ANSWER:

4.

Explain in detail the blog entry or entries in which Plaintif allegedly used the

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words “psychological torture, murder,” “psychological torture,” and/or “psychological murder,” as you stated in your answer to question six of your petition for a protective order, including the date(s) of the blog entry or entries, the full sentence in which the word(s) were used, and the name of the signing author(s).

ANSWER:

5.

Explain in detail any meetings, conversations, or discussions you had with any

official or representative of the Episcopal Diocese of Virginia regarding your eforts to subpoena Ms. Yahner.

ANSWER:

6. Explain in detail any discussions you or any agent/representative acting on your behalf had with Sigrid Yahner’s legal counsel regarding her health or her ability to respond to your subpoena.

ANSWER:

7.

Pennsylvania Rule 1930.5 provides that there that there shall be no discovery in a

simple support, custody or Protection from Abuse proceeding unless authorized by court.

Explain why you ignored this rule in issuing a subpoena against Ms. Yahner, including why you Bonetti v. Malm Interrogatories to Defendant Page 6 of 10

did not seek leave of court once you received her legal counsel’s pleading opposing your subpoena.

ANSWER:

8.

Explain why you stated in your Virginia pleadings that you were unaware that Ms.

Yahner was terminally ill.

ANSWER:

9.

Did your petition for a protective order against the Plaintif or your arguments or

testimony in subsequent hearings or discovery relating to the protective order contain any false information? If yes, explain in detail what you stated or said was false.

ANSWER:

10.

Is it your position that you did not commit perjury when you claimed in writing,

under oath, while advised by attorney Jefery Chiow, that Sigrid Yahner or someone purporting to be her contacted you repeatedly to set up meetings, only to cancel? If so, state your reasoning for this position.

ANSWER:

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11.

For any person who possesses knowledge of the facts and circumstances related

to these proceedings or whom you identified in your answers to these interrogatories, provide a summary of his or her knowledge thereof, address, and telephone number, including the Rev. Leslie Stefensen, Ms. Lee Larkin, and Mr. Jef Aaron, and the Episcopal bishops of Virginia.

ANSWER:

12. Explain in detail your decision to subpoena Plaintif’s mother, Sigrid Yahner, your reasons for doing so, why you did not seek leave of court to do so as required by Pennsylvania law, and why you did not seek leave of court when you learned that this was required by law?

ANSWER:

13. Explain in detail why you ofered to settle this matter in exchange for Plaintif’s agreement not to further criticize you, particularly in light of your previous claims that Plaintif threatened you.

ANSWER:

14. Explain in detail why you approached Plaintif on or about June 2019 on Russell Road in Alexandria, stopped your vehicle, and began threatening Plaintif at a time when you Bonetti v. Malm Interrogatories to Defendant Page 8 of 10

allegedly feared for your physical safety due to Plaintif’s actions.

ANSWER:

Respectfully submitted, ERIC BONETTI Pro Se Plaintif 4129 Fountainside Lane 203 Fairfax VA 22030 Eric.bonetti@me.com

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing First Interrogatories to Defendant was emailed and mailed, via USPS First Class mail, to Counsel for Defendant on Monday, September 20, 2020 per the following: Rachel Wenger, Esq. Cozen O’Connor One Oxford Centre 301 Grant St 41st floor Pittsburgh, PA 15219 Email: rwenger@cozen.com Phone: +1(412)620-6547

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ATTEST: COMMONWEATH/STATE OF _______________ COUNTY OF _______________________ I, ________________________, a Notary Public in and for the County and Commonwealth/State aforesaid, whose commission expires on the ___ day of _____________, 20___, do hereby certify that _______________________, whose name(s) is/are signed to the foregoing writing bearing date of the ___ day of ___________, 20___, has acknowledged the same before me in the County and Commonwealth/State aforesaid.

GIVEN UNDER MY HAND THIS ___ day of _______________, 20___. ________________________ NOTARY PUBLIC My commission expires: ____________________________ Notary Registration Number: ________________________ NOTARIAL SEAL REQUIRED

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