THE STATE OF NEW HAMPSHIRE
LACONIA DISTRICT COURT BELKNAP COUNTY
STATE V JEAN ALLAN
SUPPLEMENTAL MOTION WITH ATTACHED AFFIDAVIT PURSUANT TO RULE 17 STATING FINANCIAL CONDITION OF PETITIONER AND ATTACHED TO
PETTION TO SUBPOENA DUCES TECUM ROBERT J MAC LEOD, DHA, DIRECTOR, OFFICE OF FORENSIC EXAMINIER, STATE OF NEW HAMPSHIRE TO PROVIDE DOCUMENTS AS DESCRIBED HEREIN, AND TO APPEAR PERSONALLY AS WITNESS TO TESTIFY IN HIS CAPACITY AS DIRECTOR/SUPERVISOR RSPONSIBLE FOR THE COMPETENCY REPORT ISSUED BY THE OFFICE OF FORENSIC EXAMINERS ON OCTOBER 13, 2009, AND THAT IS MATERIAL TO THE RESTORATION HEARING SCHEDULED FOR DECEMBER 20, 2010
NOW COMES, Jean E. Allan aka Allan Sovik, [fka Jean E. Quinn, Jean E. Vorisek and Jean E. Vorisek Quinn], pro se defendant, in re the above captioned matter, and in further support of this Supplemental Motion and attached Affidavit states as follows:
- On October 15, defendant filed the above cited Petition with this Court, and additionally mailed a true copy to State’s Prosecutor Robert Libby. As of this writing defendant has not had any response, or communication, from Prosecutor Libby.
- The Petition for subpoena duces tecum was required due to the fact that defendant had no voluntary response to her letter, dated October 7 2010, to Robert J. McLeod, DHA, Director, NH Office of Forensic Examiners, 105 Pleasant Street, 4th Floor, PO Box 1806, Concord, NH 03302. [A copy of this letter is already in the above captioned file.]
- Rule 17 (e) Pro se Defendants Unable to Pay, states: "The court may order that a subpoena be issued for service upon a named witness on an ex parte application of a pro se defendant upon a satisfactory showing that the pro se defendant is financially unable to pay the fees of the witness. If the court order the subpoena to be issued, the costs incurred by the process and the fees of the witness so subpoenaed shall be paid through the clerk’s office."
- The prior related case of criminal trespass [09-cr-1293-4 Laconia District Court State v Jean Allan had been designated as a Criminal A misdemeanor and therefore defendant was allowed to have a public defender represent her.
- Defendant met all the financial qualification to allow a public defender to be appointed by the state. The attached Affidavit states that the financial condition of defendant has not materially changed, and if anything it has it has gotten worse. [See attached Affidavit of Financial Condition].
- As the Court will note in the 8/14/09 Affidavit of Financial Condition, defendant states that she applied for a letter from US DOJ in 2003 in order to get a resolution to the issue of her stolen ID, and the corruption of her social security number in the name of Jean E. Vorisek- Vorisek Quinn. [Please see attached correspondence with respect to the current status of defendant’s request to US DOJ].
Therefore, for all the reasons stated above, and with no apparent objection from the State, defendant requests that the Court:
- Order the subpoena requested in the October 15, 2010 Petition under its terms and conditions be served upon Robert J. McLeod at the court’s expense; and for
- Any other relief that it just and met.
Respectfully Submitted: Date: 10/26/10
Jean E. Allan aka Jean E. Allan Sovik, [REDACT]
(603)-581-6183
Certification of Delivery
Defendant, Jean E. Allan aka Jean E. Allan Sovik, hereby certifies that one true copy of this Motion has been delivered to State’s Prosecutor Libby in care of Clerk of Court on this 26 day, Ocotber, 2010
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