June 11, 1998
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 Johnsonís Durable Power of Attorney (DPOA) intents and wishes
were well founded concerning her negative appraisal of her daughterís
intentions and her positive intents and wishes concerning her son.
* Can speak. for group
2. *Francis Champoux can
be designated to represent Estherís 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 Harrietís
deceitful and avaricious ways evident since childhood and were all aware
of Estherís 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 Nurseís
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 Estherís 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 Estherís
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
Wardís home. Many of the valuable antiques In the Wardís 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
Estherís 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 Estherís
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 Estherís 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 motherís estate. None of these close acquaintances of the
Ward were ever contacted by the GAL or Attorney for the Ward Geraldine
10. Roberta Brooks
11. *Alfonso Corvera can
speak for Elsa Bradley. They were the upstairs tenants placed in 410
Lexington St. in 1994 at Harrietís 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 Harrietís husband John Moore's signature as witness. Esther did
sign a medical proxy in March of 1995 witnessed by a Visiting Nurse and
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 guardianís first husband and father to her two surviving sons
Francis No. 16 and Andrew No. 17. Harrietís 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 Estherís 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
19. John Higgins, Esq.-
Esther Johnson's Estate Attorney was retained at Estherís 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 Estherís 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 Estherís 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 Esterís
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
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
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
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
Nurseís 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
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 Harrietís
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 Harrietís 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 Aptakerís
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 wasnít any
housework done and Estherís rear end was all broken out and red raw
which led her to believe the other aids were not changing her diaper
41. Rose Franciosa -
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
46. Janice Silverman,
Social Worker was monitor for Taylor Johnsonís 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
45. Alan Brown - Not on my
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
.(was tape recorded harassing and
distressing Ward on instruction of guardian)
Taylor Johnson reserves his right to add
c.c. Attorney Valerie Jacoby