GAS:SJB:js
F .#2000R00027
Leonard. Cmp
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
- - - - - - - - - - - - - - - - - - - - X
00-0021M
UNITED STATES OF AMERICA
SEALED AFFIDAVIT IN
- against- SUPPORT OF ARREST
WARRANTS
JAMES LEONARD T. 1S, U.S.C., SS371,
also known as "John Lawrence," 1621(1), and 3551
URSULA SPRACHMAN, et seq.
Defendants,
- - - - - - - - - - - - - - - - - - - - X
JOHN McDERMOTT, being duly sworn, deposes and says that he is a Postal Inspector with
the United States Postal Inspection Service, duly appointed according to law and acting as such.
COUNT ONE
1. Upon information and belief, in or about and between January 1996 and the
present, both dates being approximate and inclusive, within the Eastern District of New York, the
defendants JAMES LEONARD, aka "John Lawrence," and URSULA SPRACHMAN
unlawfully, wilfully, and knowingly did combine, conspire, confederate, and agree together and
with each other to commit an offense against the United States, to wit, to violate Section 1341 of
Title 18, United States Code.
2. It was an object of the conspiracy that the defendants, JAMES LEONARD, aka
"John Lawrence," and URSULA SPRACHMAN and others known and unknown, would and did
unlawfully, wilfully, and knowingly devise and intend to devise a scheme and artifice to defraud
and for obtaining money by means of false and fraudulent pretenses, representations and
promises, and for the purpose of executing such scheme and artifice and attempting so to do,
would and did knowingly cause items, to wit, check& made payable to the Woodside
International Literary Agency, "John Lawrence" and "James Leonard," to be delivered by the
United States Posta1 Service, according to the direction thereon, in violation of Title 18, United
States Code, Section 1341.
OVERT ACTS
3. In furtherance of said conspiracy and to effect the objects thereof, the following overt acts
were committed in the Eastern District of New York and elsewhere:
a. In or about March 1996 the defendant JAMES LEONARD, also known as "John
Lawrence," received a manuscript at 33-29 th Street, Woodside, New York.
b. In or about March 1996, the defendant JAMES LEONARD, also known as "John
Lawrence," deposited a check in the amount of $75 made payable to "James Leonard," into an
account maintained at Citibank in the vicinity of Queens, New York. c. On or about
March 3, 1997, the defendant URSULA SPRACHMAN deposited a check in the amount of $150
made payable to Lawrence," into an account at First Union Savings Bank, in Florida, which had
been opened in the names of "Ursula Sprachman" and "James Leonard."
(Title 18, United States Code, Sections 371 and 3551 et seq.)
COUNT TWO
1. Upon information and belief, in or about and between January 1999 and March
1999, both dates being approximate and inclusive, within the Eastern District of New York, the
defendants JAMES LEONARD, aka John Lawrence," and URSULA SPRACHMAN,
unlawfully, wilfully, and knowingly did combine, conspire, confederate, and agree together and
with each other to commit an offense against the United States, to wit, to violate Section 1621(1)
of Title 18, United States Code.
2. It was an object of the conspiracy that the defendant, URSULA SPRACHMAN
having taken an oath, before a competent tribunal in a case in which the law of the United States
authorized an oath to be administered that she would testify truly, would and did unlawfully,
willfully, knowingly and contrary to such oath, state material matters which she did not believe to
be true, to wit the defendant URSULA SPRACHMAN while testifying under oath in a deposition
before a United States Magistrate Judge a civil matter pending in the United States District Court
for the Eastern District of New York, would and did identify "John Lawrence" as a friend who
owned and operated the Woodside Literary Agency, and identified the defendant, JAMES
LEONARD, also known as "John Lawrence," as her companion and someone who worked for
the Woodside Literary Agency as an independent contractor, when in fact, as she then and there
well knew and believed, there was no such individual by the name of "John Lawrence," and that
"John Lawrence" was an alias created
and used by the defendant JAMES LEONARD, also known as "John Lawrence," in violation of
Title 18, United States Code, Section 1621(1)
OVERT ACTS
3. In furtherance of said conspiracy and to effect the objects thereof, the following
overt acts were committed in the Eastern District of Nev York:
a. On or about January 22, 1999 in the vicinity of
225 Cadman Plaza East, Brooklyn, New York, the defendant URSULA SPRACHMAN
answered questions during a deposition before a United States Magistrate Judge.
b. In or about March 1999, in the vicinity of Naples, Florida, the defendant JAMES
LEONARD, also known as "John Lawrence," applied for a Florida Driver's License in the name
of James C. Leonard.
(Title 18, United States Code, Sections 371 and 3551 et seq.)
COUNT THREE
1. Upon information and belief, on or about January 22, 1999, within the Eastern
District of New York, the defendant URSULA SPRACHMAN having taken an oath, bef ore a
competent tribunal in a case in which the law of the United States authorized an oath to be
administered, that she would testify truly, did knowingly, willfully and contrary to such oath state
material matters which she did not believe to be true, to wit: the defendant URSULA
SPRACHMAN, while testifying under oath in a deposition before a United States Magistrate
Judge a civil matter pending in the United States District Court for the Eastern District of New
York, identified "John Lawrence" as a friend who owned and operated the Woodside Literary
Agency, and identified the defendant, JAMES LEONARD, also known as "John Lawrence," as
her companion and someone who worked for the Woodside Literary Agency as an independent
contractor, when in fact, as she then and there well knew and believed, there was no such
individual by the name of "John Lawrence," and that "John Lawrence" was an alias created and
used by the defendant JAMES LEONARD, also known as "John Lawrence."
(Title 18, United States Code, Sections 1621(1) and 3551 et seq.) The source of your deponent's
information and the grounds for his belief are as follows:
Introduction
1. I am an Inspector with the United States Postal Inspection Service ("USPS"), and
have been so employed for approximately 16 years. I have been assigned to the
investigation of numerous cases involving mail fraud and false statements and I have received
special training in conducting such investigations.
2. I respectfully submit this affidavit for arrest warrants in connection with the
investigation of the above-named defendants JAMES LEONARD, also known as "John
Lawrence," and URSULA SPRACHMAN. This affidavit is based, in part, on my personal
participation in this investigation, which has included, among other things, interviews, and an
examination and analysis of documents, including bank records, and a copy of a certified
transcript of deposition testimony. In addition, this affidavit is based on reports made to me by
others. Since this affidavit is being submitted for a limited purpose, I have not included details of
every aspect of this investigation. Where actions, conversations or statements of others are
related herein, they are related in substance and in part, unless otherwise indicated.
THE WOODSIDE INTERNATIONAL LITERARY AGENCY
3. I have reviewed advertisements posted on the Internet by the Woodside Literary
Agency and the Woodside International Literary Agency, hereinafter collectively referred to as
the "WLA." The WLA has advertised itself as a "New York based international literary agency . .
. seeking new and previously published authors" and requesting such persons to submit writing
samples to the WLA. I have also reviewed correspondence from the WLA to consumers. On
certain of the WLA's letterhead, the following addresses and phone numbers have appeared: (i)
33-29 58th Street, Woodside, New York, (hereinafter referred to as "WLA's Woodside
Premises"), telephone:718-651-8145 (hereinafter referred to as "WLA' s Woodside Telephone");
(ii) 1190 North Collier Boulevard, Marco Island, Florida, (hereinafter referred to as "WLA's
Florida Premises"), telephone: (941) 642-9660 (hereinafter referred to as "WLA's Florida
Telephone") and (iii) 34 Beaver Pond Road, Adirondack, New York, (hereinafter referred to as
"WLA's Adirondack Premises"), telephone: (518) 494-4196 (hereinafter referred to as ‘WLA's
Adirondack
Telephone").
4. The defendant URSULA SPRACHMAN is the owner of WLA's Woodside Premises,
according to publicly filed documents, as well as her own testimony in the deposition described
in paragraph 21. below. WLA's Woodside Telephone is listed to "John Lawrence." The records
of the New York State Department of Motor Vehicles indicate that an individual identified as
"James Leonard" and an individual identified as "John Lawrence" hold an identification card and
a driver's license, respectively, bearing the address of WLA's Woodside Premises.
5. The defendant URSULA SPRACHMAN is the owner of WLA'S Florida Premises,
according to publicly tiled documents, as well as her own testimony in the deposition described
in paragraph 21 below. WLA's Florida Telephone is listed to both "John Lawrence" and "Ursula
Sprachman." The records of the
State of Florida Department of Highway Safety and Motor Vehicles indicate that an individual
identified as "James C. Leonard" holds a Florida driver's license and an identification card
bearing the address of WLA's Florida Premises.
6. The defendant URSULA SPRACHMAN is the owner of WLA's Adirondack
Premises, according to her own testimony in the deposition described in paragraph 21 below.
WLA"s Adirondack telephone is listed to "John Lawrence."
7. A confidential source ("CS-1") providing information to the USPS advised the
USPS of the following, in substance and in part;
a. In or about January of 1996, CS-l was contacted by an individual who identified
himself as "James Leonard" of the "Woodside Literary Agency" located at WLA's Woodside
Premises, and told CS-1, in substance and in part, that in exchange for a "reading fee" of $75, the
WLA would review portions of CS-1's manuscript and evaluate it for publication potential.
b. On or about March 7, 1996, CS-1 sent CS-1's manuscript to the WLA by United
States mail at WLA's Woodside Premises to the attention of "James Leonard," along with a
check for $75 made payable to ‘James Leonard."
c. Subsequently, CS-1 received a letter dated March 25, 1996 from "James
Leonard," which letter identified "James Leonard" as the owner of the WLA, and provided, in
substance and in part, that CS-1 was accepted by the WLA as a client and that CS-1 should send
$250 to the WLA at WLA's Woodside Premises as a "contract fee," to "secure one year of (the
WLA's) time and effort . . . ." The letter also provided that "(a)ccording to the agent in charge of
your manuscript, your book stands a strong chance of selling quickly."
d. CS-1 decided not to send the $250 contract fee to the WLA and instead asked for
the manuscript to be returned. CS-1's manuscript was returned by the WIA in the same sealed
envelope in which CS-1 had sent it, appearing never to have been opened or read.
8. A confidential source ("CS-2") providing information to the USPS advised the
USPS of the following, in
substance and in part:
a. In or about February 1996, CS-2 received an electronic mail message from an
individual identifying himself as "James Leonard," of the WLA soliciting a synopsis of CS-2's
manuscript. After sending such a synopsis to the WLA at WLA's Woodside Premises, CS-2
received a letter from "James Leonard" of the WIA which provided, in substance and in part, that
in exchange for a $75 reading fee, an agent would review and evaluate CS-2's entire manuscript.
The letter also provided:
"Please be advised that only 5% of the authors who Contact us are asked to submit their entire
manuscript."
b. In response to the above-described letter, CS-2 sent an international money order
in the amount of $75 to WLA's Woodside Premises, along with CS-2's complete manuscript.
Shortly thereafter, CS-2 received a letter dated April 4, 1996 from "James Leonard," which letter
identified "James Leonard" as a Manager of the WLA, and provided, in substance and in part,
that CS-2 was accepted by the WLA as a client and that CS-2 should send $250 to the WLA at
WLA's Woodside Premises, as a contract fee. The letter also provided that "(a)ccording to the
agent in charge of your manuscript, your book stands a strong chance of selling quickly." CS-2
decided not to send the requested contract fee to the WLA.
9. A confidential source ("CS—3") providing information to the USPS advised the
USPS of the following, in substance and in part:
a. In response to a solicitation posted on the Internet by "John Lawrence," of the
WLA, CS-3 sent a small portion of CS-3's manuscript to the WLA at WLA's Woodside
Premises. CS-3 then received a letter from the WLA stating, in substance and in part, that the
WLA was interested in reading CS-3's entire manuscript and would do so in exchange for a
check in the amount of $150. The letter also stated: "Please be advised that only a small
percentage of the authors contacting us are asked to submit their entire manuscript."
b. In response to the above-described letter, CS-3 sent CS-3s complete manuscript
along with a check for $150 to the WLA at WLA's Florida Premises.
c. Thereafter, CS-3 received a letter from the WLA dated July 3, 1997, which
provided, in substance and in part, that CS-3 was accepted by the WLA as a client and that CS-3
should send a $200 contract fee to the WLA. CS-3 sent a check payable to the "Woodside
International Literary Agency," in the amount of $200 to WLA's Florida Premises.
Approximately one year 3ater, CS—3 sent a check payable to the "Woodside International
Literary Agency" in the amount of $250 to WLA's Woodside Premises as a contract renewal fee.
10. I have been informed by several other people who received correspondence from
the WLA similar to that described above, that in reliance on the WLA's representations, they sent
the WLA material they wished to have published, along with fees ranging from $75 to $250.
Most of the fees were paid in the form of checks made payable to "James Leonard", "John
Lawrence" and/or the "Woodside International Literary Agency" and most were mailed to WIA's
Woodside Premises. My review of such checks revealed that prior to in or about March 1996, the
checks were made payable to "James Leonard." Thereafter, the checks were made payable to
"John Lawrence" or the "Woodside International Literary Agency."
11. On or about March 4, 1996, an account in the name of "John Lawrence"
(hereinafter the "Lawrence Account") was opened at the Independence Savings Bank located in
Jackson Heights, New York. On or about April 11, 1997, an account in the name of the
"Woodside International Literary Agency" (hereinafter the "WLA Account") was opened at the
Independence savings Bank located in Woodside, New York. Many of the checks referenced in
paragraph 10 above were deposited into the Lawrence Account and/or the WLA Account. It
appears that the funds in the WLA Account and the funds in the Lawrence Account were used to
pay the personal debts of the defendants JAMES LEONARD, also known as "John Lawrence,"
and URSULA SPRACHMAN, and were not used to pay any business expenses of WLA..
Specifically, my review of the records of the Lawrence Account and the WLA Account failed to
reveal any checks payable to any of the individuals identified in WLA's correspondence as
employees. Such bank record: contain many checks drawn against the WLA account and the
Lawrence account made payable to various credit card companies, in payment of credit card
accounts in the name of the defendants JAMES LEONARD, also known as "John Lawrence,"
and or URSULA SPRACHMAN.
12. Some of the checks referenced in paragraph 10 above were endorsed over to the
defendant URSULA SPRACHMAN, and deposited into a joint account under the names of
"Ursula Sprachman" and "James Leonard." For example, the $75.00 check sent to the WLA by
CS-1 (referenced in paragraph 7(b) above) was made payable to the order of "James Leonard"
and deposited by the defendant JAMES LEONARD, also known as "John Lawrence," into a joint
account at Citibank, located in Queens, New York. Said joint account had been opened in the
names of "Ursula Sprachman" and "James Leonard," and listed WLA's Woodside Premises as the
account holders' mailing address. In addition, a check in the amount of $150 made payable to
"John Lawrence," and mailed to WLA's Florida Premises as a reading fee to WLA, was endorsed
over to the defendant URSULA SPRACHMAN, and deposited on or about March 3, 1997, into a
joint account at First Union Savings Bank in Florida. Said joint account had been opened in the
names of "Ursula Sprachman" and "James Leonard," and listed WLA'; Florida Premises as the
account holder's mailing address.
13. None of the individuals with whom I have spoken in connection with this
investigation1 or whose complaints I have reviewed ever had their submissions published as a
result of the WLA's efforts. In fact, I have been unable to locate anyone
whose submissions were published as a result of the WLA's efforts. Moreover, many of the
individuals with whom I have spoken stated, in substance and in part, that after paying the WLA,
he or she did not receive any promotional information, marketing evaluations, critiques of their
work, or information regarding potential publishers.
14. Despite WLA's representations regarding its selectiveness as described in
paragraphs 8(a) and 9(a) above, my review of numerous submissions selected by WLA reveals
that regardless of the quality of such submissions, every author was told by the WLA that the
small portion or summary of his or her manuscript was good enough to warrant the WLA's
evaluation of the entire manuscript in exchange for a reading fee. For example, even the
individual who submitted a piece entitled "Even Hitler Got the Blues," a copy of which is
attached hereto as Exhibit A. was advised by WLA that it was good enough to warrant the WLA
evaluation of the entire manuscript in exchange for a reading fee of $150. The individual who
submitted Exhibit A received a letter from WLA representing the following; "The agent I
assigned your submission is very interested in reading the entire manuscript. Along with your
manuscript, kindly include a check for $150.00 made out to Mr. John Lawrence . . . Please be
advised that less than 5% of the authors contacting our agency are invited to submit their entire
manuscript."
15. I have reviewed an affidavit filed by a reporter in connection with the Hitchcock
Lawsuit, referenced in paragraph 20 below. In such affidavit, the reporter disclosed that in
January 1997, he telephoned WLA's Woodside Telephone. Pursuant to the reporter's standard
procedures, the reporter recorded this
telephone call. The reporter's call was answered by a woman who professed to be unable to
provide any information concerning the WLA. I have listened to this tape recording. I have also
spoken by telephone several times to a woman who identify herself as "Ursula Sprachman." In
my opinion, the woman on the reporter's tape recording is the same woman with whom I spoke,
who identified herself as "Ursula Sprachman."
16. I have reviewed an affidavit filed by Forensic Document Examiner John Paul
Osborn in connection with the Hitchcock Lawsuit, referenced in paragraph 20 below. In such
affidavit, Mr. Osborn stated that he compared the known handwriting of the defendant URSULA
SPRACHMAN with the questioned handwriting of "Rita Maldonado." The defendant URSULA
SPRACHMAN testified that "Rita Maldonado" is an employee of the WLA and the secretary to
"John Lawrence." Mr. Osborn concluded that the defendant URSULA SPRACHMAN was
probably the author of the documents signed in the name of "Rita Maldonado." I have also noted
the similarities between the handwriting of the defendant URSULA SPRACHMAN and the
handwriting of "Rita Maldonado." In addition, it should be noted that the defendant URSULA
SPRACHMAN has refused to provide handwriting exemplars to the USPS based upon a letter
from a doctor claiming that the defendant URSULA SPRACHMAN should not be put in any
stressful situations.
THE IDENTITIES OF LEONARD AND LAWRENCE
17. I have reviewed the records of the New York State Department of Motor Vehicles
pertaining to the New York State identification card issued to an individual identified as "James
C. Leonard" on or about January 9, 1998 (hereinafter referred to as the "NY Leonard ID Card")
and the New York State driver's license issued to an individual identified as "John Lawrence" on
or about April 12, 1994 (hereinafter referred to as the "NY Lawrence License." I have also
reviewed the records of the State of Florida Department of Highway Safety and Motor Vehicles
pertaining to (i) an identification card issued to an individual identified as "James C. Leonard" on
or about March 7, 1997 (hereinafter referred to as the "Florida Leonard ID Card"); (ii) a duplicate
of said identification card issued on or about February 3, 1998 (hereinafter referred to as the
"Duplicate Florida Leonard ID Card"); and (iii) a driver's license issued to an individual
identified as "James C. Leonard" on or about March 9, 1999 (hereinafter referred to as the
"Florida Leonard License"). The photographs of the holders of the identification cards and
licenses referenced above (the NY Leonard ID Card, the NY Lawrence License, the Florida
Leonard ID Card, the Duplicate Florida Leonard ID Card, and the Florida Leonard License)
appear to be photographs of the same individual.
18. The applications for the NY Leonard ID Card and the NY Lawrence License each
set forth the following address of the applicant: 33-29 58th Street, Woodside, New York, which
is WLA's Woodside Premises. No change of address has been reported by the holder of the NY
Lawrence License or the NY Leonard ID Card.
19. The date of birth set forth on the applications of the NY Leonard Card ID and the
Florida Leonard License is May 11, 1947. The date of birth set forth on the application for the
NY Lawrence License is May 10, 1946. All three applications indicate that the applicant is 5'11."
The applications for the NY Leonard ID Card and the NY Lawrence License both indicate that
the applicant has hazel eyes, and appear to be in the same handwriting. The middle name printed
on each such application is "Charles," however this printed middle name is crossed out on the
application for the NY Leonard ID Card.
THE HITCHCOCK LAWSUIT
20. In or about January 1997, a civil action was commenced in the United States
District Court for the Eastern District of New York entitled Jayne Hitchock v. Woodside Literary
Agency et al., civil docket number 97-0166, hereinafter referred to as the "Hitchcock Lawsuit."
The second amended complaint was filed on or about August 27, 1998, against the Woodside
Literary Agency, James Leonard, John Lawrence and Ursula Sprachman, and is still pending in
the United States District Court for the Eastern District of New York. In the Second Amended
Complaint, the plaintiff, Jayne Hitchcock alleged, among other things, that the WLA is an
enterprise owned and operated by James Leonard, John Lawrence and Ursula Sprachman.
Hitchcock also alleged that after reporting the activities of the WLA to the Office of the Attorney
General of the State of New York, the WLA, John Lawrence, JamesC.Leonard and Ursula
Sprachman engaged in actions againstHitchcock constituting defamation and intentional
infliction of emotional distress.
21. On or about January 22, 1999, in the United States District Court for the Eastern
District of New York, located in Brooklyn, New York, the Honorable Joan M. Azrak, United
States Magistrate Judge for the Eastern District of New York, presided over a deposition (the
"Deposition") of the defendant URSULA SPRACHMAN in connection with the Hitchcock
Lawsuit.
22. During the Deposition, the defendant URSULA SPRACHMAN made many
statements to the effect that John Lawrence and James Leonard were two different individuals.
Specifically, the defendant URSULA SPRACHMAN represented, in substance and in part, that
the individual identified as "John Lawrence" was a friend of hers who rented various premises
from her, and who owned and operated the WLA, and that the defendant JAMES LEONARD,
was her "companion," and someone who worked for the WLA as an independent contractor. Set
forth below are certain questions asked during the Deposition and the answers given by the
defendant URSULA SPRACHMAN
Q. When did Mr. Lawrence begin to use part of the property [located at WLA's Woodside
Premises]?
A. He rented the place in January of 1996.
Q. What did [Mr. Lawrence] say about what kind of business he would be opening at the
Woodside Premises]?
A. That he is going on the Internet and opening up a literary agency, and that the work would
be conducted exclusively on his computer.
Q. You said you have known Mr. Lawrence for twenty-five years?
A. No, that is my companion, James Leonard.
Q. How long have you known Mr. Lawrence?
A. Longtime [sic].
Q. How long?
A. Over ten years.
Q. How did that come to be that Lawrence's answer (to the complaint in the Hitchcock
Lawsuit] is the same [as your answer to the complaint in the Hitchcock Lawsuit]?
A. Because we wrote it . . . James [Leonard] and I wrote the answer and send [sic] it to John
[Lawrence].
Q. You are saying, I'm just Ursula Sprachman and my companion is James Leonard, and we
were just — — I owned that house and I rent the defendant premises to Lawrence and I had
nothing to do with (the WLA)
A: Yes.
Q. Why would. you then go to the lengths of preparing legal papers for Lawrence when you
A: Because of James, James [Leonard] worked for the [WLA]
. . . Two years ago, James very briefly worked for the
[WLA].
Q: What did he do?
A: He read a couple of manuscripts, edited them and then decided he didn't like it. He was an
independent contractor and by the end of 1996 he gave up.
Q: What does [Mr. Lawrence] look like? Is he tall7 short? Is he dark, is he light?
A: About six feet, dark hair, round eyes; that's just about it
Q: What does Mr. Leonard look like?
A: Mr. Leonard is blondish gray. He has a beard.
Q: How tall?
A: Maybe five-foot-eight.
Q: I need you to convince me that Mr. Lawrence and Mr. Leonard aren't the same person.
A: How do you want me to do that?
Q: I have a suspicion that Mr. Leonard and Mr. Lawrence
are the same person; that there is no Mr. Lawrence. So
I want you to convince me that is not so.
A: That is trying the impossible.
Q: You find an old snapshot of Mr. Lawrence from your days when you socialized, you find
a snapshot of Mr. Leonard and a xerox copy of his Florida driver's license and send me all
three.
A: Be happy to.
23. The records of the Florida Department of Highway safety and Motor Vehicles
indicate that approximately 6 weeks after the above—described deposition, in the vicinity of
Naples, Florida, the defendant JAMES LEONARD, also known as "John Lawrence," applied for
the Florida Leonard License referenced in paragraphs 5, 2.7 and 19 above. Consistent with the
description given by the defendant URSULA SPRACHMAN during the Deposition, the
defendant JAMES LEONARD, also known as "John Lawrence," had a beard in the photograph
submitted in connection with the application for the Florida Leonard License, unlike the
photographs for the New York Lawrence License, and the Florida Leonard ID Card.
WHEREFORE, it is respectfully requested that arrest warrants issue for the
apprehension of the defendants JAMES LEONARD, also known as "John Lawrence," and
URSULA SPRACHMAN, so that they may be dealt with according to law.
JOHN MCDERMOTT
U.S. Postal Inspector
U.S. Postal Inspection Service
Sworn to before me this
6th day of January, 2000
UNITED STATES MAGISTRATE JUDGE
EASTERN DISTRICT NEW YORK
Return to the story of Abuse of Usenet: The Woodside Literary Agency
Go to Exhibit A - "Kiki Rothschild's" Submission to WLA