Documentation to "My Case"

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
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TIBOR GASPARIK,
.......................................................................................CV-05-03817 (SJF/ARL)
Plaintiff,

-against-.........................................................................SUPPLEMENTARY EXPLANATION
.......................................................................................TO THE MOTION TO COMPEL
.......................................................................................PRODUCTION OF DOCUMENTS
STONY BROOK UNIVERSITY,

Defendant.
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I, Tibor Gasparik, the plaintiff pro se in the above captioned case, provide the following supplementary explanation to the motion to compel answers to interrogatories and production of documents, submitted on March 14, 2006, to this Court. The need for this supplementary explanation was identified in the Order issued on March 30, 2006, by the United States Magistrate Judge, Honorable Arlene R. Lindsay, in response to the plaintiff’s motion, and specific to the relevance of the documents resulting directly or indirectly from the “probe users’ meeting” called by professor Donald H. Lindsley on October 19, 1999 (docketed entry 27). In support of this motion, plaintiff states as follows:

1. On February 10, 1999, professor Liebermann sent to plaintiff a cryptic e-mail asking him to call a meeting of microprobe users that would exclude the microprobe specialist, Dr. Robert P. Rapp. At that time, the plaintiff was temporarily his supervisor, because the previous supervisor, professor Lindsley, was on a sabbatical leave in Brussels. The plaintiff took on this extra duty in the summer of 1998 with the understanding that this was just a formality, with nothing more than signing purchase orders. He believes that the Lieberman’s e-mail was meant to prepare grounds for a similar meeting called by professor Lindsley on October 19, 1999.

2. On August 31, 1999, professor Lindsley, after his return from the sabbatical leave in Belgium, made the first attempt to call a meeting of microprobe users. Plaintiff did not attend the meeting, which apparently took place on September 3, 1999, because he was not comfortable with the stipulation that excluded the microprobe specialist, Dr. Rapp, from the meeting.

3. Plaintiff suspects that his absence at the meeting on September 3, 1999, was the cause that the meeting did not to fulfill its intended purpose, and professor Lindsley called the same meeting again for October 19, 1999. This time, he also sent a separate e-mail invitation to the plaintiff. To assure plaintiff’s participation at the meeting, Liebermann visited the plaintiff in the high-pressure lab and used his utmost charm and power of persuasion to convince him to attend, although the plaintiff hesitated to do so again because of the exclusion of Dr. Rapp. The unusual extraordinary efforts by Liebermann and Lindsley to assure plaintiff’s participation at the said meeting made him suspicious that he was being lured into a trap.

4. At the meeting on October 19, 1999, plaintiff was provoked by Lindsley into an ugly confrontation by being accused of mismanaging the probe. The plaintiff suspects that Dr. Rapp was excluded from the meeting so he would not be able to come to the plaintiff’s defense, and that the true purpose of the meeting was to initiate some kind of a due process against the plaintiff.

5. The admission by the defendant that there are documents in existence resulting directly or indirectly from the said meeting suggests the possibility that these documents contain false accusations or fabricated evidence, and that the faculty members, and potentially other members of the research staff, may have been manipulated, duped or blackmailed by Liebermann and Lindsley to support and sign these documents in order to initiate the suspected due process, which may have eventually resulted in plaintiff’s dismissal, blacklisting and, as is evident now, has destroyed his scientific career.

6. Therefore, the requested documents may represent the key evidence in support of the plaintiff’s allegation of persecution.

7. The plaintiff also believes that a fair trial would not be possible if the evidence potentially present in the requested documents is not considered by the Court.

8. Additional information and documentation in support of this motion are available on the plaintiff’s Web site: http://suny-stonybrook.blogspot.com/, and are posted under Links in the entry “Account of my persecution.”

WHEREFORE, plaintiff respectfully requests from this Court to enter an order granting the following relief:

A. Compelling the defendant to produce the requested documents.
B. Any further relief that this Court determines is just and necessary.

Dated: Holtsville, New York
April 4, 2006

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Tibor Gasparik, plaintiff pro se
352 Plad Blvd
Holtsville, New York 11742
(631) 447-2168


TO: Lori L. Pack
Office of the Attorney General
300 Motor Parkway, Suite 205
Hauppauge, NY 11788