June 11, 1998

Your Honor.

In the interest of conserving court time and expense, I will pare down my witness list to the bare minimum needed to prove my case beyond any shadow of doubt. The witnesses will bear testimony in support of the medical records and give ample evidence that Esther Johnson’s Durable Power of Attorney (DPOA) intents and wishes were well founded concerning her negative appraisal of her daughter’s intentions and her positive intents and wishes concerning her son.

* Can speak. for group

1. Removed

2. *Francis Champoux can be designated to represent Esther’s cousins and nieces. Both male cousins have military medical corps training and saw Esther heavily drugged in November of 1995. All cousins and nieces saw Esther shortly before the signing of the DPOA and noted her extremely astute mental acuity. All of the Champoux family are keenly aware of Harriet’s deceitful and avaricious ways evident since childhood and were all aware of Esther’s concerns and fears that Harriet would attempt to seize control of her person and estate for her own ends.

3. Jackie Champoux

4. Marcia Como

5. Kathleen Quirk, Waltham Visiting Nurse Supervisor - She was present when Catherine Smith and I queried R. N. Como as to why she had deliberately prevented medical attention at the early onset of the June 14, 1995 stroke. She became aware that Harriet had been deliberately giving the Visiting Nurse’s medical misinformation concerning their patient Esther Johnson. Kathleen Quirk instituted the rescue of Esther when she was six hours from death August 28, 1995. Dying of thirst and starvation.

6. Catherine Smith, Advocate for Esther Johnson was denied access to the Ward against the wish of the Ward and court order.

7. Margaret (Peg) Snow was a teaching colleague, and travel companion of Esther for thirty (30) years. She spoke to the GAL on four (4) occasions as opposed to the ten (10) times listed in the GAL billing records. She supplied the GAL with accurate first hand, eye witness testimony regarding the temporary guardian's behaviors toward her mother. She expressed her first hand, knowledge of Esther’s legitimate fears and concerns regarding her daughters behaviors and clear malicious intents. She holds two (2) masters degrees, largely in psychology and expressed her concerns that Harriet was emotionally unstable and a distinct danger to Esther. She also expressed her belief that Esther was not a candidate for a guardianship takeover due to a mental Illness. The GAL deliberately misrepresented her in his GAL report.

8. Sandy Wertz is Esther’s cousin by marriage and a life long companion and confidant. She is a notary public and is the head of the Shipping and Delivery Dept. of New England Medical Center. In addition to corroborating Peg Snow's testimony she has first hand eye witness knowledge of the jewelry theft by the guardian and the subsequent theft of the entire contents of the Ward’s home. Many of the valuable antiques In the Ward’s home came there via inheritance from the Taylor family which is her direct lineage. Her concerns and fears were expressed to the GAL and he deliberately misrepresented her in the GAL report. She can also confirm Esther’s living trust intentions which were prevented by the guardian.

9. *Roberta Johnson can be designated to speak for Roberta Brooks No.10 and Rose Franciosa No. 41. Roberta Johnson is my second wife of ten (10) years and has been very close to the Ward. She and the Ward still wish to continue their personal friendship. The guardian has precluded them from contact in person or by phone. All the above visited with the Ward shortly before June 5, 1995. All concur with the other witnesses of the same time period as to Esther Johnson's clear mental state and her legitimate concerns about her daughter's behavior. They all knew of Esther’s intentions as to the disposition of her personal and estate property. In 1984 Esther gave Roberta her own wedding ring as an engagement gift. All of the above know of Esther’s displeasure at the alterations Harriet had caused at 410 Lexington St. All have written notarized affidavits concerning their knowledge that the psychiatric evaluation of me conducted by Dr. Anthony VanNeil at the GAL purported behest, is a fraud. All had first hand knowledge of the guardian's avaricious intents toward her mother’s estate. None of these close acquaintances of the Ward were ever contacted by the GAL or Attorney for the Ward Geraldine Foley.

10. Roberta Brooks

11. *Alfonso Corvera can speak for Elsa Bradley. They were the upstairs tenants placed in 410 Lexington St. in 1994 at Harriet’s insistence. They related private conversation between mother and son to Harriet. In late July 1995 Alfonso admitted that Elsa had signed as witness to the Medical Proxy in early July 1995 but stated that Elsa didn't know what she was signing. The medical proxy presented to the court is dated November 1994 and bears Harriet’s husband John Moore's signature as witness. Esther did sign a medical proxy in March of 1995 witnessed by a Visiting Nurse and myself.

12. Elsa Bradley

13. Cheryl Underhill was the upstairs tenant from 1989 - 1993. She never witnessed any inebriate behavior of Esther Johnson and her fiancee who is a licensed electrician rewired the second floor and installed a 220 electric service, This fact flies in the face of the guardian's assertion that the Ward's house required extensive electrical work.

14. Gerald McCarty - I did not list him.

15. Attorney Bernard Shadraway is the guardian’s first husband and father to her two surviving sons Francis No. 16 and Andrew No. 17. Harriet’s two sons have already testified to police, the GAL, Attorney Segalini and their father Attorney Shadraway that they were privy to the planning stage of the estate takeover by John Moore and Harriet as early as 1987, when their first attempt to take over failed and the subsequent planning refinement including prevention of medical attention and falsifying medical records. They also reported that Harriet and John intended to divert the funds to their own use and claim that Esther had never paid taxes and that the valuable antiques and jewelry didn't ever exist. When the sons raised the question about possible investigations the response of John and Harriet was "We've got that covered".

16. Francis Shadraway

17. Andrew Shadraway

18. Attorney Peter Hardy was the first attorney to enter the picture on Esther’s behalf. He saw her at Waltham Deaconess Hospital on April 12,1995. Esther told him of what she believed her daughter was up to and asked for legal protection. At the time he thought that this was paranoid delusion as Dr. Ryan had told him. After what Esther had warned him about actually occurred on July 7, 1995, he realized that her warning had been not paranoid but prophetic. As a trustee of the hospital he later looked at the medical record and reported that there was no terminal illness of any kind in Esther.

19. John Higgins, Esq.- Esther Johnson's Estate Attorney was retained at Esther’s request on April 24, 1995 with $500.00 cash. On May 25, 1995 Esther instructed him to provide, her with a document which would insure that John and Harriet Moore could never be able to got control of her person and property ever again. He and his law partner, Attorney McDonough drew up the DPOA and instituted it on June 5, 1995. On that date the stolen jewelry was brought up and also Esther’s intent to institute a LIVING TRUSTS in the near future for further protection. After perjuriosly obtaining the temporary guardianship on July 7, 1995, Harriet, Dr. Ryan and Attorney William Brisk told Attorney Higgins that there was no need to oppose the illegal takeover because Esther was terminally ill with very short life expectancy. On July 10, 1995, Attorney Higgins demanded another $2,000.00 allegedly for the purpose of opposing the take over. The money was supplied to him by Catherine Smith at Esther’s earnest request. Attorney Higgins took no action on his client, Esther Johnson's behalf as he was instructed to do. He refused to act as co-counsel with Attorney Roland Segalini on August 7, 1995 and was discharged. He has refused to return the $2,000.00.dollar retainer and has refused to provide an accounting.

20. Attorney Roland Segalini took over as Estate Attorney on August 7, 1995 upon the warning from Attorney Shadraway of Esther being in imminent danger. He received a retainer of $500.00 from Taylor Johnson, again at Esther's insistence. Attorney Segalini came to realize that Attorney Brisk, Foley and Aptaker were acting in collusion to defraud and resigned on November 15, 1995. He never appeared at motion hearings or filed any motions on Ester’s behalf.

21. Geraldine Foley was appointed as Attorney for the Ward September 4,1995. She did not inform the court of possible conflict because she was a personal friend of Harriet and John Moore. She misrepresented her client and has falsified her billings.

22. Dr. Robert Karr is a personal friend of John and Harriet Moore. He deliberately falsified the discharge summary of HRI hospital and declared medical and psychiatric ailments which were physiologically impossible to be present in Esther Johnson.

23. Philip Wang MD can speak for No's 24, 25, 26, 27 and 28. Dr. Wang was the intake medical doctor for Esther on July 22, 1995. He can verify that the discharge summary is a fabrication and he concurred with R. Ns Greg McNabb, Sandy Hannon, Gerri Butler, Marcia Chan and Dr. John Temte that Esther was suffering from mild post stroke confusion and was not demented in any way and that she demonstrated extraordinary, higher brain mental ability.

24. Greg Butler, R. N.

25. Sandy Hamom R.N.

26. Gerri Butler, RN

27. Marcia Chan, R. N.

28. John Temte, MD

29. Rahda Agarwal MD was a fill in doctor for Dr. Ryan when Esther was rescued by the Visiting Nurse’s on August 28, 1995. She stopped the illegal and dangerous Haldol use and declared that Harriet was emotionally unstable. She has since disassociated herself from Dr. Ryan.

30. Dr. Frank Davidson filled in for Dr. Ryan April 14 - 19, 1995. Esther tried to persuade him to take over her case from Dr. Ryan. He noted no mental problem of any sort.

31. Jean Tolan is a personal friend of John and Harriet Moore. She was the original person which Harriet knew would be contacted by Elder Affairs. She was the one Harriet had in place to cover up the initial investigation while Esther was being killed from thirst and starvation as clearly shown in the medical records of Waltham Deaconess Hospital.

32. Jay Casalini conducted the only cursory investigation from West Suburban Elder Services. She took over when Tolan was discharged and recommended to Attorneys Brisk, Foley and Aptaker that a neutral re-evaluation of the Ward should be conducted. She filed no report of what she saw in late February 1996.

33. Lois Piso was the Marist Hill Nursing Home intake person who stated in the Medical record that Esther was fully accepted in April of 1995 proving Harriet’s perjury of August 1, 1996.

34. Judith Kapuscinski is the Newton Wellesley Hospital attorney who sided with the DPOA over the medical proxy dated March 1995 but is constrained from disclosure by the guardian's order of privilege.

35. Attorney Joan Chaisson purported to represent me March 1996 - August 8, 1996. I only discovered too late that she was a friend of Attorneys Brisk, Foley and Aptaker and personally related to John and Harriet’s good friend Frank Chaisson who lives two houses away from their home on Plympton Street, Waltham.

36. Kevin Comick, Head Administrator at Briarwood, confirmed to Catherine Smith and me that we were not a disruption to Esther Johnson but in fact were very attentive and helpful to her, contrary to Attorneys Brisk and Aptaker’s accusations.

37. *Dr. Bueckler was in the Emergency Room when Esther was brought in and Nancy Richmond was the nurse on duty and heard what the doctor had to say. Dr. Bueckler stated on October 19, 1995 that never under any circumstances should Esther he discharged to the custody of Harriet ever again and that the guardian should be vacated immediately.

38. Nancy Richmond, RN

39. Carol Williams M. D. filed an abuse complaint on December 19, 1995 but it was not investigated. The medical records show that Dr. Williams spoke with the GAL and he lied to Judge Boorstein on January 30, 1996 as to what Dr. Williams told him. Dr. Williams is not mentioned in the GAL report.

40. Shirley Vargas an aid from Griswald stated to Catherine Smith and me that the other aids from Griswald were not doing their job properly as there wasn’t any housework done and Esther’s rear end was all broken out and red raw which led her to believe the other aids were not changing her diaper often enough.

41. Rose Franciosa - already mentioned.

42. Anthony Van Neil, M. D. , gave the fraudulent psychiatric report.

43. Brenda Bemporad, PHD - Was monitor for Taylor Johnson's visits with his mother and approved by the guardian. She gave written statements that Taylor DID NOT violate the visitation order but later declined the position for reasons unknown.

46. Janice Silverman, Social Worker was monitor for Taylor Johnson’s visits with his mother and was approved by the guardian. She gave written statements that Taylor DID NOT violate the visitation order and was later discharged by Harriet.

45. Alan Brown - Not on my list.

46. Rabinah Katumba - Griswald Aid then later hired by the guardian. She stated to Catherine Smith that Carol Mackay was crazy

(was tape recorded harassing and distressing Ward on instruction of guardian)

47. Liz Samantha-- Filled in for Rabinab Katumba when she took some days off. Her last name unknown.

.(was tape recorded harassing and distressing Ward on instruction of guardian)

Taylor Johnson reserves his right to add further witnesses.

Taylor Johnson