http://www.prouty.org/s2k.html IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA JURY TRIAL DEMAND Case #: 98-CV-740 U.S. District Court Northern District of Oklahoma (Tulsa) Assigned to Cheif Judge Terry C. Kern Lindsey K. Springer, Plaintiff, vs. Hustler Magazine, a foreign corporation and, LFP INC., a foreign corporation, Defendants. PETITION 1. Plaintiff, Lindsey K. Springer, ("plaintiff") complains for Declaratory Judgment against Hustler Magazine and LFP, Inc. ("defendants"), due to Breach of Contract involving a public offer of "$ 1,000,000.00" Reward ("Reward") involving information associated with helping bring defendants' identify the killer[s] of the 35th President of the United States, John F. Kennedy. PARTIES 2. Plaintiff, Lindsey K. Springer, is natural Citizen of Oklahoma, with the principal address of 5147 S. Harvard, Suite 116, Tulsa, Oklahoma, 74135. 3. Defendant Hustler Magazine is a non-resident corporation and a medium of communication as defined by 12 O.S. _ 2506, with a principal address of 8484 Wilshire Blvd, Suite 900, Beverly Hills, California, 90211. 4. LFP. Inc., the owner of Hustler Magazine, on information and belief, is a foreign Corporation, distributing Hustler Magazine in Tulsa Oklahoma, with a principal business address of 8484 Wilshire Blvd, Suite 900, Beverly Hills, California, 90211 and is owned by Larry Flint. 5. Agent for both Hustler Magazine and LFP Inc., on information and belief is Alan Isaccman of Isaccman, Kaufman and Tainter, with an address of 8484 Wilshire Blvd, Suite 850, Beverly Hills California 90211. JURISDICTION AND VENUE 6. This Court has Jurisdiction over this action pursuant to 12 O.S. _ 1651. Venue is proper pursuant to 12 O.S. __ 137 and 187 as both defendants are foreign corporations currently doing business through their local distributor, Anderson News Corporation, with a distribution address of 909 W. 23rd, Tulsa Oklahoma, 74107. Jury Trial is Demanded. BACKGROUND 7. On November 22, 1963, the Thirty Fifth President of the United States of America, President John F. Kennedy was assassinated on tape, in Dallas Texas. 8. In June of 1964, then Chief Justice of the Supreme Court, Chief Justice Warren, pursuant to Executive Order of then President Lyndon B. Johnson, was ordered to head a commission empowered to determine what happened involving the slain president on November 22, 1963. 9. This report by the Chief Justice is known as the Warren Commission Report on the Assassination of John F. Kennedy and Lee Harvey Oswald ("Warren Report") to which identifies whom the Commission believes assassinated the late President. 10. Defendant Hustler Magazine communicated a public offer of reward, with no limitation of time, for "$ 1,000,000.00" (One Million) for information identifying the Killers of deceased President John F. Kennedy after the published Warren report. 11. On April 17, 1998, plaintiff was requested by Joanna Massey ("Joanna M.") to deliver what information plaintiff had and that someone would get back to plaintiff within a few days. 12. On April 18, 1998, plaintiff, by private courier, Fed. Ex Tracking Number 803550299982, delivered to defendant Hustler Magazine, addressed to Larry Flint or Joanna M., by and through Andrea Daily, Security Officer on duty located at the Building which houses both defendants and their agent Mr. Isaccman, a copy of the information plaintiff chose to submit in support of plaintiff's claim for the Reward. 13. Between April 18, 1998 and May 18, 1998, plaintiff attempted telephonic communication with defendants and/or their employees, only to be told that plaintiff needed to contact Hustler and LFP., Inc.'s Attorney and Agent Alan Isaccman for any further communication on the issues plaintiff presented. 14. Plaintiff contacted defendants' Attorney and Agent, Mr.Isaccman, to whom failed to return any calls to plaintiff. 15. On May, 20, 1998, after 4 weeks had passed and silence was the result of plaintiff's claims and defendants' refusing to return plaintiff's property associated with plaintiff's claim, plaintiff delivered copies of the information plaintiff relied upon in support of his claim for the Reward, mailed by U.S. Certified Mail and U.S. Express Mail. Express Mail Numbers were EI754401743US to Larry Flint and LFP. Inc., and Express Mail Number EI754401757US to Alan Isaccman as agent for the defendants. COUNT I 16. Paragraph 1 through 15 are reallege and incorporated herein by reference. 17. Plaintiff has presented reasonable facts associated with the identification of those responsible for final shots that killed the 35th President of the United States, John F. Kennedy, including specific facts documented within the Warren Commission findings, sufficient enough to claim defendants' published Reward offering. 18. Plaintiff has reasonably identified the Killer of John F. Kennedy to the defendants, and defendant has demonstrated refusal to tender the public offered Reward to plaintiff for such information as published in Hustler Magazine owned by LFP. Inc. 19. Defendants and each of them have breached their Contract as published in Hustler Magazine and are indebted to plaintiff for "$ 1,000,000.00." 20. This Court should enter final judgment in plaintiff's favor and against defendants for "$ 1,000,000.00." WHEREFORE, plaintiff Lindsey K. Springer respectfully request this Court find judgment and issue a final Order, in plaintiff's favor and against Hustler Magazine and LFP. Inc., for "$ 1,000,000.00" Reward associated with the presentation of information which reasonably leads defendants to the identification of whom Killed the 35th President of the United States of America, John F. Kennedy. Respectfully Submitted Lindsey K. Springer 5147 S. Harvard, Suite 116 Tulsa, Oklahoma, 74135
