Howard K. Stern Ready for Trial, is John O’Quinn?
Posted by: Rose in All Things Anna Nicole Smith, Anna Nicole Smith, Celebrity Trials, Daniel Smith, Daniel Smith's Inquest, Dannielynn, Debunking the myths on ALL cases related to Anna Nicole, Don Clark, Don Clark ex-FBI, Geraldo FOX News, Greta -On The Record, High Proflie Trials, Howard K Stern, John O'Quinn, Krista Barth, Larry Birkhead, Lin Wood, O'Quinn's Don Clark Ex-FBI, Rita Cosby, The John O'Quinn Law Firm, Virgie Arthur, Wilma Vice, Wilma Vicedomine
On September 12, the Southern District Florida Court U. S. District Judge William P. Dimitrouleas under “sua sponte”, “Latin for “of one’s own will,” meaning on one’s own volition, usually referring to a judge’s order made without a request by any party to the case”. The Court Issued an Order to Show Cause why the case should not be dismissed for lack of prosecution directed to Howard K. Stern. In part the Court said, “According to Federal Rule of Civil Procedure 12(a)(4)(A), the Defendants had ten (10) days since the denial of last Motion to Dismiss to file an answer, but they have yet to do so.” The Court therefore ordered Howard K. Stern that “on or before September 26, 2008, shall show cause why this case should not be dismissed for want of prosecution.”
On the same day, U. S. District Judge William P. Dimitrouleas denied the Joint Motion to Extend Discovery Deadlines. The Court noted in the Order denying the Motion that, “However, neither party indicated to this Court their decision to forego discovery until the instant Motion. …The parties have been aware of the discovery cutoff since the Scheduling Order from this Court on August 23, 2007. The Court finds no compelling reason to enlarge time for discovery. The Court did say however, whatever the parties decide to do in the discovery between the cut off date of September 19 to the Calendar Call on December 24, could be ongoing at the agreement of the parties. “However, the parties will not be able to involve the Court in discovery disputes arising after the deadline.” What the Court is saying here, in my opinion, is that the sides can continue discovery until the Calendar Call on December 24, 2008 but neither side can file any Motions to Compel any of the parties or non-party witnesses or involve the court. In other words if it is not done by September 19, or a Motion is not pending before the Court by September 19, then don’t come to the Court any time after September 19 to attempt to get any help or rulings from the court in any disputes about discovery including depositions and production of documents, interrogatories, etc.
Instead of waiting until the date of September 26, 2008 that the Court ordered Howard K. Stern to Show Cause why the case should not be dismissed due to the Defendant’s failing to file an Answer to Stern’s Amended Complaint and/or Stern’s failure to prosecute the case, (I. E. go forward with discovery under the Court’s Order from August 2007), Stern filed his Response to the Court on September 15. In his Response, Stern stated that he had, “propounded jurisdictional discovery; issued subpoenas to third-parties; and issued multiple discovery requests and notices of depositions to Defendants. Plaintiff filed multiple motions to compel when Defendants avoided fully responding, objected or moved for a protective order in response to such discovery. In short, as shown below, Stern has attempted to use discovery to discover the facts supporting Defendants’ libelous statements and the defenses hinted at in his responses to interrogatories. Defendants, however, have resisted discovery at every turn.”
In one of the most startling statements in Stern’s Response, he goes on to state about defendants, John O’Quinn and the O’Quinn Law Firm, “…Defendants have not issued any discovery requests to Stern. They have issued no notices of deposition”. Stern again points out that the defendants “filed a motion for a protective order asking that Plaintiff be prohibited from deposing a witness, investigator Wilma Vicedomine, at all”.
Howard K. Stern gives us a glimpse as to what he has been doing to prepare for the trial and I found it very interesting to see whom all he had served Subpoenas Duces Tecum (requests for needed documents), on including the following:
* Broward County Medical Examiner’s Office (October 25, 2007);
* Seminole Police Department (October 25, 2007);
* Wilma Vicedomine (November 10, 2007) (As is detailed in Stern’s various discovery motions, Vicedomine also acted as a purported agent of The O’Quinn Law Firm and is, therefore, also considered a party in this action);
* Wilma Vicedomine (November 14, 2007);
* ABC News, Inc. (December 6, 2007);
* Melinda Burleson (December 6, 2007);
* Fox News Network, LLC (December 6, 2007);
* American Media, Inc. (December 14, 2007);
* California Department of Justice (December 14, 2007);
* Florida State Attorney (December 14, 2007);
*Wilma Vicedomine (April 30, 2008).
Stern goes on to outline for the court the numerous occasions sought to take the deposition of Wilma Vicedomine as a third party in this action. Stern recounts how Defendants met him with repeated obstruction. Stern states in his filing that he served subpoenas to take the deposition testimony of Vicedomine on multiple occasions including:
* November 10, 2007;
* November 14, 2007; and
* April 30, 2008.
Stern refers back to the Court’s Omnibus Order dated August 29, 2008, stating that the Court has resolved the issues surrounding the document production from and deposition testimony of Vicedomine by explicitly outlining the documents Vicedomine is required to produce and the areas on which Vicedomine is required to testify.
Stern in his filings goes on to give us a look at to the other discovery he has sought against the parties, including written discovery and by noticing the depositions of the Defendants and their agents. These include written discovery on Defendants:
* First Set of Continuing Interrogatories to O’Quinn (April 4, 2008);
* First Request for Production of Documents to O’Quinn (April 4, 2008);
* First Request for Production of Documents to The O’Quinn Law Firm (April 4, 2008);
* First Requests for Admissions to O’Quinn (April 4, 2008).
* Second Set of Continuing Interrogatories to O’Quinn (August 19, 2008);
* Second Requests for Production to O’Quinn (August 19, 2008);
* First Set of Continuing Interrogatories to The O’Quinn Law Firm (August 19, 2008);
* Second Requests for Production to The O’Quinn Law Firm (August 19, 2008);
* Second Set of Continuing Interrogatories to The O’Quinn Law Firm (September 5, 2008);
* Third Requests for Production to The O’Quinn Law Firm (September 5, 2008). The written discovery propounded by Stern on September 5, 2008, was specifically limited to documents and information the Court held Stern was entitled to in the August 29, 2008 Omnibus Order. The Court did allow an extension of time on these financial documents until September 26.
Looking at that Ex Parte hearing Order about the documents that defendants asked to be looked at in camera and I see there were about 950 pages of which the Court ordered that the defendants turn over in excess of 300+ pages by Wednesday September 17. This should not have been affected by Hurricane Ike, because the both the Court had copies of these pages as well as in the Notice of Ex Parte Hearing the Court asked the defendants to bring copies of the disputed 900+ pages with them.
Stern acknowledges in his filing that discovery in this action is to close on September 19, 2008; he states that on August 20, 2008, well within the discovery deadline, that Stern noticed the depositions of Defendant John M. O’Quinn, Don Clark, and Wilma Vicedomine to take place prior to the close of discovery:
* John M. O’Quinn for September 18, 2008;
* Don Clark for September 8, 2008; and
* Wilma Vicedomine for August 28, 2008.
Stern says that although O’Quinn, Clark, and Vicedomine were under valid notice of deposition, at the request of counsel for Defendants, Stern agreed to postpone the taking of these three depositions until counsel for Defendants could identify dates that worked better for them. Stern finishes with the statement that as of the date of this filing on September 15, he still waits for those dates of convenience from the last three depositions he needs to take before trial from counsel for Defendants.
In the most stunning statement in the filings, Stern says for a second time that the “defendants have not served Stern with any written discovery or a notice of deposition”.
Stern goes on to say that, “Once Defendant John M. O’Quinn, Don Clark, and Wilma Vicedomine are finally deposed after months of their attempts to avoid being deposed and once Defendants fully comply with this Court’s August 29, 2008 Omnibus Order regarding written discovery, Stern will be ready for trial on December 29, 2008.”
My question to all of you is Howard K. Stern ready to go to trial on December 29, 2008? Are John O’Quinn and the O’Quinn law firm going to be able to get any of the discovery they seek if any is needed by December 29, 2008? Finally why do you think the lawyers for O’Quinn and his law firm failed to ask Stern for documents or to sit for a deposition when the documents and depositions for the Howard K. Stern vs. Rita Cosby and Hachette Books can NOT be shared with any of the other pending litigations? My final question is how far reaching is Wilma in the Florida case and New York case and why fight so hard for her not to sit for a deposition nor share all of her own blogging and that of her “fellow bloggers”? Do you think Wilma will throw her online “friends and cohorts” under the bus?
Read the documents in this case which are open to ALL not just members of Rose Speaks.com and then let’s discuss your take on all of this and what you think is going to happen.
The password protected part of the blog for regular posters at Rose Speaks.com for this article can be found here.
©Rose Turner
September 22, 2008
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Tags: Anna Nicole Smith, Daniel Smith, Don Clark, Howard K Stern, John O'Quinn, Rita Cosby, Virgie Arthur, Wilma Vice, Wilma Vicedomine
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Thanks for the article Rose, and so fast. So glad you understand all the legal papers and can explain them to us. I like that picture of Howard too.
HELP.I am not understandingsome of this article,Is the court going to force
I too like the picture of Howard. I am glad he is taking this all the way to trial and I feel he is ready. By taking this case to trial, Howard is proving he has nothing to hide. Howard is an Attorney himself and knows exactly what is expected when taking a case to trial.
My computer keeps cuting out.Is the court going to force Don Clark and Wilma to comply and give there depo?OQ is going to continue to stall.Howard looks sexy in that picture,You can see by the list of subpoenas,Howard is not at all concerned about what any one has to say about him,
Did the court agree that Howard has Prosecuted the case or is the defendant stonewalling going to cause the case to fall over?
Are they even thinking that they are going to court? They haven’t asked Howard for depositions, have they asked anyone yet? Have they done any?
Bev, that is the picture taken of him when he was walking into the supreme court with Anna.
And you bet, he looks sexy and confident. IMO intelligence is very sexy.
Anyway, I was talking to someone over the weekend about what an important witness Wilma
is going to be and IMO she is going to help Sterns case. I really hope she just goes in there
and tells the truth, protects herself and stops being used. She seems smart enough to figure
out what they are doing to her. Now it’s time to go knock it out of the ball park. I don’t know
if she will have to make a type of immunity deal to protect herself and her friends but if I were
her, well it’s game time.
I will have an article up tonight or first thing in the morning explaining this entire flurry of filings for a Default with the jury only deciding the damages to be awarded to Howard K. Stern. Scanning this new filing, it confirms my initial take of “my dog ate my homework” defense.
September 22, 2008 Howard K. Stern’s Expedited Reply to Response of John O’Quinn. This was ordered to be expedited by the Court in regards to Stern’s Motion for Default Judgment after O’Quinn failed to file his Answer on time.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=933
Wow this is sure a fine case of Wilma playing hide and seek. I don’t understand why the courts are not going after Quinn and gang and putting a stop to their games. I truly don’t think Quinn thought how much of a bull dog Howard was, and is seeing he is one smart attorney. I bet Quinn is seating in his office just shaking his head. Howard is 1000 times smarter then Quinn ever thought he would be. As for Quinn not asking Howard for his depo and written discovery I don’t think Quinn knows what to ask Howard since Quinn is the one that made up alll the lies about Howard. JMO…
BE SURE AND TAKE THE ATTACHED POLL WITH THIS ARTICLE BY CLICKING ON THE COMMENTS SECTION BELOW THIS ARTICLE! On the front page of this site, we have added a poll to the article about Stern’s filing today
Beverly
My understanding of is that if the request have been made before Sept. 19 then YES the judge will involve the court in those. Like having to file a motion to compel a witness to sit for a deposistion. But, if no request for a depo was made by O’Quinn before Sept. 19 (and none was to my knowledge) then the court wouldn’t get involved and force HKS to sit for a depo or settle any motions to compel them to hand over papers or whatever. My interpretation is that HKS is basically ready once those 3 sit for their depos and O’Quinn is basically screwed.
Roxanne—This basically screwed,sounds so good to me. I DO want there depo in Rita,and hatchette publishing is concerned,After all this time I want to know who the sourse was,Don Clark or Wilma or both.You know,Howard does not seem to have a nasty bone in his body.With all this trying to cover wilma,s butt,I think there was a whole lot of underhanded stuff going on OQ,IS MORE THAN AFRAID OF WHAT SHE IS GOING TO SAY.
ok where is the poll? I can’t find it.
Bad to say but I think all the cases kept Howard alive.He is a good attorney and we will have the prouf.He is ready for Florida,he know his case.
i agree intelligence is sexy! I like ‘em smart and funny! Gotta laugh. I figured the judge would make sure hks depo request follow thru. I believe wilma did what she did on her own free will and wasnt forced to do anything. She continued despite the facts. She deserves everything coming to her IMO
Oh really butterfly, I never thought about it that way. But how would she get the money to go to
the Bahamas to interview the nannies with Don Clark?
I don’t know and will wait and see how this plays out. Maybe it is a little bit of both.
I just got done reading Wood’s support of a motion for default. IMO it’s very impressive. But the obvious question is how could O’Quinn and company screw up so totally? Was it arrogance that made them think they called the shots in what they thought it was necessary for them to file? Were they playing too close to the edge in their delay/stonewall tactics? Were they so caught up in keeping Wilma under wraps that they didn’t keep their eye on the ball? Could it be that the O’Quinn law firm is not exactly a “well oiled machine” in its daily operations? Is McCabe incompetent? (Wood points out that “McCabe, in particular, had the independent duty to ensure compliance with deadlines for his client”….Ouch!!)
Or is it all of the above?
Ann I think it is all of the above.IMO they thought they did not have to worry about complying.they forgot Florida is not texas which is o’Quinns home ground.Now they nare trying to cover it up by having people swear that it was a mistake LOLIn this kind of case You don’t make those kinds of mistakesand they are throwing everyone and anyone under the bus in their effort to avoid this.Can’t blame this one on Ike!
Ann, my impression of OQ is he got rich but being a thug, not with his brains.
lol daisy. Well said about oq. Wilma continued blogging..was source for ritas book etc long after the facts were clear. They had an agenda for the marshall money and didnt care who they hurt in the process
i can just see wilmas depo…. There is no evidence of the acusations. We made it all up!! Lmao. not funny but probably the sick truth!
ann i think all of the above. IMO the last year+ of fighting was going thru the motions trying to fight it thru the legal system b4 it got to this point. With so much secretive confidential stuff going on there is no way they want the info in front of a jury. I thought a portion of ritas depo was filed in this court so it was used for something??
Also that is a VERY good point by lin wood as if mccabe is trying to blame its own klein lawfirm for it losing??? Which could potentially cause future probs except it seems this is oquinns style and heavily documented in the past. Being that they have requested nothing from their side hardly constitutes the klein firm being esponsible for one filing out of dozens IMO
Just wondering …
If this Default order is upheld by the court, O’Quinn etc. still get to fight the amount of damages, and they still get to keep Wilma’s depo from happening because there will be no need for it.
Was this tardy filing of a response an oversight … or another tactic?
#6 Daisy,
I love the look Anna gives him in this picture, same place same time.
http://www.koat.com/image/13321871/detail.html
#14 I agree Butterfly, LOL
#17 hmm
You’re right about that!! His real howdy attitude, thinks he can get away with anything. In Lin Wood’s latest filing he is not going to let him get away with it. WOW GRRRRRR! OUCH!!!!! Go get them LIN!!!
sun, they were all so happy that day. Anna so proud of Howard and Howard so proud to be making her happy.
Oh, now I’m gonna cry.
Butterfly, I love to read your take on this.
Lizzie, maybe that is their intentions. Wilma’s depo may very well lead to criminal charges if you think about it.
Never thought about it to I read your comment.
Sun, let me follow up the reason it is so sad to me is because Anna was finally finding happiness
and IMO her mom just couldn’t stand it and the damage she did to her after Daniel’s death…
oh my head can’t go there right now. Got to keep moving forward, that is done, can’t
change it.
All I can do is stay out of the way of God’s lessons. He teaches us those
lessons to bring us to him. Let’s pray Anna’s mom opens her heart, realizes what she did and
goes to Him and does as he commands. I have seen prayers answered over and over again
and I’m not going to give up on her changing her heart. She just needs to listen to the
right voice in her head because we all know how the devil operates and he will plant all kinds
of seeds of evil and if you let him those seeds can take root and grow deeper and deeper.
Good news is they can be cut out and replaced with God’s loving words and seeds of doing
good.
DAISY—-I believe,with all my heart the Good Lord,chose the correct way,I do not believe Howard and Anna could have lived with this lie,As much as I have felt so very sorry for Anna,she created a HUGE problem.Larry had every right to his child.and I am of the belief, you cannot build a life on a lie,Dannielynn,would have been in between,I do not even want to think,the turmoil,for years that would have gone on.Now I want for Howard to win these cases,and as the years pass,he will find a love that will,give him children,and a life free of stress.
Ya know what Bev, I believe the Good Lord always finds the best way even though we may not agree
with what he does sometimes I always believe he does what he does for his reasons and it is up to
us to learn from his lessons. Taking Daniel was his choice, one I will never understand but have peace
in my heart he always does things out of love.
About Larry, Anna made that choice for a reason, one in which I believe she was doing out of the best
interest of her child and from the what Larry has been doing lately, I see why.
Finally, I do pray Howard moves on with his life, finds love, children and all that life has to offer but
never forgetting his duty to Anna’s wishes and looks out for her child and ensures her assets are protected.
It may sound harsh but I wish HKS would get everything set up for Dannielynn and make sure it’s protected and then walk away. I don’t think he will do that but I think it’s the only way he will ever be able to truly move on with his life once this is over.
what is larry doing now daisy? Thats bad? I liked the US mag spread with all te pics! There was actually a good photo of hks there..best one IMO i believe it was outside the bahamas courthouse. Was trying to see the color of ties to see whee it was lol.
I agree Rox and it doesn’t sound harsh,it is the right thing to do.
I pray he does just that, I want him to have a happy life and leave all of this behind him.
He can have it set up where it is in a trust and the trust will take care of it. And really
trust are handled. The only responsibility for him will be is to get a statement
and review the trust to ensure her money is earning.
I will hold my opinion on that Butterfly.
My opinion is Anna did not want Larry to raise DL, she wanted
HKS and I can understand why.
I too enjoy the pictures don’t get me wrong.
However, she might becoming over exposed and is this in the best
interest of the child?
My bottom line is always in the best interest of the children and the
way she is being exploited and yes I said exploited I am concerned about.
Now don’t all yell at me for expressing my feelings, it is just the way I feel.
The only child star I know of that has become a successful adult is Reese Witherspoon and Jody Foster.
I realize it is all in the up bringing but I don’t know if Larry has the knowledge to raise her under these
circumstances in her best interest. It’s beginning to appear as a exploitation.
And you have to ask yourself would Anna want this? Didn’t she protect Daniel from the media?
But whatever, it’s Larry’s child but with all this talk about his reality show, it is making me nervous.
Roxanna, I too hope he can walk away from all of this when it’s over and have a life. BUT, I would love to see Howard go and be the attorney for the breast plant people that Quinn just decided he didn’t have to pay them. Howard would sure knows how Quinn tries to play the game. I think he would be great and thorn in Quinns side. Like Virgie said on TV, HOWARD I’M COMING AFTER YOU, well Howard can say that back. LOL
I will be glad when all the cases are over and Howard can take the time to grieve Anna and Daniel’s deaths as he should, but hasn’t had time too. I hope and pray that Howard will have a normal life someday without the media involved. I also hope he will find the love of his life again.
Daisy you are right Anna didn’t want Larry to raise Dannielynn but maybe God did as you said we don’t know what would have happened if Anna had lived. And we can’t go back and change history only go forward. Dannielynn is so beautiful like her Mama and Larry seems to be doing his very best to do a good job of raising her.
very good point Sunflower.
I pray he does the right thing.
And don’t get me wrong I know he loves her very, very, very much.
You know everyone,I feel sorry for Larry as well as Howard,Larry is a NEW YOUNG FATHER,give him some room ,I have said this many times before,Anna should have went to a sperm bank,SHE DID NOT,You cannot expect Larry to forget his daughter,I dare say,Larry has been picked on from the day he got Dannielynn,Lets just say,Anna,and daniel did not die,what a god awfull mess,the years to come would have brought.I still have a hard time understanding how Anna could play ahaoward and L arry at the same time,either she loved Howard,in which case,
she should have told Larry,not lead them both on,NOT FAIR TO hOWARD,
I agree Beverly, but we don’t know the details of the arrangement.
Florida Court Rules Against Stern I should have got my article up earlier today… LOL
September 23, 2008, the Florida Southern District Federal Court issues Order Denying Stern’s Motion for Default Judgment.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=934
Daisy [32] I agree with every bit of your post.
32. Actually according to an interview that she had on LKL, she stated that she wanted another child but wanted NO father involved in the raising of the child. I may be old fashion but my mother told me not to have sex with someone you would not want to get pregnant by. If she really wanted a child with no father attachments, she should have been artifically inseminated.
I do not feel like Larry has exploited his daughter either. Do you consider the selling of DL’s birth exploiting? How about the last pictures of Daniel alive that have been sold? Or would you consider this to be necessary in order for Anna to have paid her bills, bury Daniel?
You forgot to mention Shirley Temple who was a child star and became a successful adult. Dannielynn is not a star. She was made famous by the circumstances surrounding her birth, not by what she has accomplished. Don’t get me wrong, I think Anna loved Daniel so very much, but I don’t see how she protected him from the media. She had him on her show. Something that Daniel did not want to do according to a video that I saw a long time ago.
I think Larry will do just fine. And as long as I get to see a picture or two of her in the future, that is fine with me.
New York Issues New Order
September 24, 2008 New York Southern District federal Court issues Order on Wilma Vicedomine, Don Clark, Mark Speers, and the nannies deposition to be done by October 20, and on documents that Howard K. Stern’s lawyers were and are asking to look at.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=935
#41
Daisy ITA but I do think that Anna did have to sell something to get some money coming in at the time. When we buried my mother almost 3 years ago her funeral was $23k and we didn’t even have to fly her anywhere. I can’t imagine what Daniels cost and I also think they had to pay even more to bury Daniel there because he wasn’t a resident of the Bahama’s.
43. Actually I wrote #41. I don’t doubt that Anna needed to sell something and I am not knocking her for doing so. I wanted to find out where the line gets drawn in peoples eyes. Was it ok when Anna sold the birth video, last pictures of Daniel but Larry sells some photo spread and now he is exploiting his child? I am one that does not care for the double standards that are applied to each and every one in this mess. Team Texas would love to see pictures of Virgie and Dannielynn, would they then consider Virgie to be “pimping” Dannielynn if Virgie sold pictures of her. Does that mean that Virgie pimped out Daniel?
At one time, I think we heard what it had cost to bury Daniel and what the cost was to hold his body in storage for all that time, but I can’t remember what that amount was. Could it have been close to the 40 grand mark? But I do believe that Anna did not intend to move back to the States. She would have fought that DNA testing for as long as she could.
How in the world did I get Daisy? I guess I saw the D. I think to a point it is ok for Larry to sell photo’s of Dannielynn. I think it was ok for Anna to do it. I think, however, that a reality show IS exploiting her and I don’t agree with that but I am also not her parent. VA in my opinion wouldn’t have caught so much flack for selling Daniel’s pictures if she had been a part of his life all those last years and if she hadn’t lied about selling them originally.
In the Howard K. Stern vs. John O’Quinn lawsuit in the Southern District of Florida, there were a flurry of filings by O’Quinn’s Florida lawyers. These filings were for a Motion for Protection right after they had filed for an extension of time through today to produce the very documents because of Hurricane Ike that they are now not wanting to hand over.
In a surprise with the filing is an Affidavit by Rusty Harding, we always wondered if this was about the Marshall money and not Dannielynn, well perhaps that “rumor” can now be put to rest.
September 25, 2008 John O’Quinn and the O’Quinn Law Firm Motion for Protective Order and Memorandum of Law in Support of Protective Order.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=936
September 25, 2008 Exhibit A with Motion for Protective Order is Stern’s Second set of ongoing interrogatories.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=937
September 25, 2008 Exhibit B of Motion for Protection copy of Second set of Request for Production of Documents.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=938
September 25, 2008 Exhibit C filed with Motion for Protection, first set of interrogatories for the O’Quinn Law Firm.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=939
September 25, 2008 Exhibit D filed with Motion for Protection, copy of second set of request for documents sent to the O’Quinn Law Firm.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=940
September 25, 2008 Exhibit E filed with Motion for Protection, a letter from Robert Klein to Lin Wood dated September 17, 2008.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=941
September 25, 2008 Exhibit F filed with Motion for Protection, a copy of a letter from Lin Wood to Robert Klein dated September 19, 2008.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=942
September 25, 2008 Exhibit G filed with Motion for Protection, Affidavit of Rusty Harding with a non-authenticated page from the Texas Probate Hearing and part of Stern’s deposition from the Houston Arthur vs. Stern suit.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=943
September 25, 2008 Exhibit H filed with Motion for Protection, a copy of Judge Chin’s Memorandum of Law filed on December 13, 2008.
http://www.rosespeaks.com/modules.php?name=Downloads&op=getit&lid=944