JANUARY 28, 2011.
The following is a replica of a document from the Minnesota defamation lawsuit David McKee M.D. V. Dennis K Laurion.
STATE OF MINNESOTA
DISTRICT COURT, COUNTY OF ST. LOUIS
Case Type: Defamation, Court File No.: 69 DV-CV-10-1706
David McKee, M.D., Plaintiff,
Dennis Laurion, Defendant.
STATE OF MINNESOTA )
COUNTY OF HENNEPIN )
CHARLES PAYNE, being first duly sworn under oath, states as follows:
1. My name is CHARLES PAYNE. I am a licensed private investigator in the State of Minnesota, License Number 261. I have been licensed since 1978. I have been involved in the investigations industry since 1971.
2. My work includes a variety of investigations for various purposes, including civil litigation.
3. I do not know any of the parties in this lawsuit. I do not have any financial stake in the outcome of this case, except I am being paid my normal hourly rate for my work in this matter.
4. I have been asked to locate an individual who was identified as a “friend” nurse of Defendant Dennis Laurion, to whom Laurion attributes the statement “He is a real tool,” in reference to Dr. David McKee. Defendant Laurion used this phrase in his website postings and various correspondence that he wrote to professional organizations, colleagues, and peers of Dr. McKee, which I understand form the basis for this lawsuit.
5. Having been asked to locate this individual, the only criteria provided by Mr. Laurion of his “friend” nurse is less than minimal. Mr. Laurion maintains that she was someone with whom he worked while he was a part-time employee for about seven years at St. Mary’s Medical Center in outpatient records, but he does not know her name. He gave a very limited physical description of her as in her 50’s, about 5’6″ tall, dark blond or light brunette hair, graying, with a “trim” build. The representation that he does not even recall her first name makes this search virtually impossible.
6. Mr. Laurion was not able to identify any particular unit of the hospital she worked, other than she had some outpatient position. He gave the names of some other personnel with whom he worked.
7. I have instituted efforts to begin to try to locate this person. I am severely handicapped by the very limited information furnished by Mr. Laurion, which is surprisingly sparse for a person whom he said was a “friend,” and whom he worked with for some seven years.
8. My efforts to locate this person included the following:
• I have instituted research with the Minnesota Board of Nursing, located at 2829 University Ave. SE, Minneapolis, MN to determine the number of nurses that are currently and had historically been licensed with the State of Minnesota since 01/ 01/ 2000 in St. Louis County. Our preliminary research determined that in St. Louis County there are 4048 current licensees that are female. Using the event of Mr. Laurion meeting this individual at the Lakeside Post Office which is located at 4427 E. Superior Street, Duluth, MN 55804, I have begun to have the search narrowed to the 55804 zip code. At the time of this writing, it is believed there are 560 licensees in that zip code having held a nursing license since 01/ 01/ 2000.
• With the gross absence of any identifying information and without access to the Human Resources at St. Mary’s Hospital, these reasonable efforts are the only avenue of research currently underway.
• As this research has only recently begun, extensive further research needs to take place in addition to contacts with these prospective individuals to identify the “friend” nurse. If the person exists, which is uncertain, it will require more detailed information from Mr. Laurion in order to find her. I am told that Mr. Laurion has made no efforts to find her himself. If she does exist, Mr. Laurion presumably has more information about her that would allow us to locate her.
The above is true and correct to the best of my knowledge.
Dated: January 28, 2011
/S/ CHARLES PAYNE
Subscribed and sworn to before me
This day of January 2011
/S/ Notary Public [ Seal ]