Most of us expect that Wilma Vicedomine or her alias of Wilma Vice is present in a deposition today. However, I have some questions and would like to have your input.

Who is there today, we know Lin Wood is there and any lawyer that Mr. Wood picks to be there to represent Howard K. Stern. We know that Rita Cosby’s lawyer is there, Elizabeth McNamara, and Hachette Books lawyer Douglas Maynard is probably there as well. Wilma Vice is being represented by Neil McCabe now as an “agent” [employee and therefore a party in the Florida lawsuit], of the O’Quinn Law Firm and Neil McCabe can invite any other lawyer that is listed to be there for the deposition from The O’Quinn Law Firm.

However is Robert Klein there, since he is not representing anyone in the New York case? His September 29 letter to Lin Wood said he would be in Houston this past weekend to prep for Don Clark’s deposition on October 14, but if that deposition is ONLY about Cosby’s book will Mr. Klein be allowed to sit in on these depositions.

The main parties have a right to be present also, that would be Rita Cosby and Howard K. Stern, would they show up? We know that Howard K. Stern loves Texas, NOT, so my bet is he is not there and would not step foot in Texas not even to look the woman in the eye that spent over a year trying to destroy him. My bet is that he will watch the video of this deposition to “meet” Wilma and not be there today. However, will Rita Cosby be there to support Wilma Vicedomine and Don Clark? Why did Cosby who fought so hard to keep everything she said and all of her documents in the New York suit to be held as confidential and never shared with anyone else or in any of the other lawsuits, suddenly changed her mind about handing all of that over to The O’Quinn Law Firm? The fact that her lawyer was willing to do that, addresses the Amended Complaint that Stern filed in Florida in which he alleged in part that people in The O’Quinn Law Firm “conspired” with Cosby on her book. Did Cosby and her lawyer prep for this deposition over the weekend with Wilma Vice? Was Wilma shown the video deposition of Cosby and all of Cosby’s confidential documents to prep for today? I am still amazed that Cosby would take a chance of handing over everything to the O’Quinn Law Firm in regards to her suit in New York, could this end up biting Cosby.

What are your thoughts on is Cosby there today to encourage her source for her book? Did Cosby hand over everything to help her sources? Who do you think are in that room today during the deposition?

Give us your thoughts we want to hear what you think is going on today behind those close doors in Houston Texas?

Then there is the question all of us would love to see the answer to, will Wilma throw any of her alleged email, chat buddies, or blogging buddies under the bus today? Will she hand over those that Wood alleges she gave instructions to post certain things on TMZ.com? Will we know their names as the Florida Suit and New York suit goes forward? How did those excerpts of Cosby book find its way to TMZ.com before the book was even released?

©Rose Turner
October 13, 2008
All Rights Reserved, do not reproduce in whole or in part without the express written consent of the author.

This article is the sole property of Rose Speaks unless otherwise stated. This article as with other articles is based on the opinion of Rose Turner, or our guest authors if so indicated. Please remember we are not lawyers and those opinions expressed here are each of our individual opinions and should not be taken as legal advice and/or legal opinions. The comments following this article are the opinions and sole property of the site members and do not necessarily reflect those of the site owners.

Please also read our Terms of Use and our Privacy Policy.

Tags: Anna Nicole Smith, Daniel Smith, Dannielynn, Howard K Stern, Larry Birkhead, Lin Wood, Rita Cosby, Wilma Vice, Wilma Vicedomine

On Monday, October 13 and Tuesday, October 14, in Houston Texas all of the big gun lawyers in the Rita Cosby suit will meet and deposed Wilma Vicedomine and Don Clark. Those that will have the right to be present during the depositions is Elizabeth McNamara for Rita Cosby, Douglas Maynard for Hachette Books, Lin Wood, and any of the lawyers he decides that can be present that are on record in the Cosby suit for Howard K. Stern. Neil McCabe for Wilma Vicedomine and Don Clark and for some reason when you review the letters filed and dated September 29, Robert Klein will be present, unless Wood excludes him because the depositions are ONLY about the Cosby suit. I did notice that in Robert Klein’s letter he stated that he would be in Houston this whole weekend to “prep” Don Clark for his deposition. I am not sure why Robert Klein would have access to this deposition unless as I state below after the 7 hours allowed for the Cosby suit, Clark agrees to extend the deposition into late that night for the O’Quinn suit. However, my prediction is since the Court will not Compel the deposition in the Florida suit, the Clark/Vicedomine will be only 7 hours each and only address the Cosby suit.

Below is an outline of what Lin Wood has access to in documents from Wilma Vicedomine in regards to her conversations with Rita Cosby, her postings on the internet and in a chat channel, and any “orders” she directed other posters to go out to sites like TMZ.com to allegedly promote Wilma Vicedomine’s agenda to destroy Howard K. Stern.

Per the Civil Rules, Lin Wood has one day of 7 hours with Wilma Vicedomine. Let us “assume” that Lin Wood has prepared for this deposition for several months, based on the fact he has “thousands of messages in an online chat room dedicated to discussion of Ms. Smith’s death. In these alleged postings, Vicedomine allegedly discussed aspects of Defendants’ investigation, including strategy, efforts to have Plaintiff prosecuted, and conversations that she had with Arthur. Id. Further, Plaintiff alleges that Vicedomine directed chat room members to post specific statements regarding Plaintiff on the website TMZ.com.” If that allegation were true, I would bet that Lin Wood has a top forensic computer expert, which has tracked IP’s in the records subpoenaed from the chat room owner. If those IP’s track back and can be proved it came from Vicedomine via Moody International computers, home computers that Vicedomine owns, and any IP’s that track back to the O’Quinn law firm.

Below are excerpts from the Omnibus Order issued about Vicedomine and Don Clark’s deposition, which now can ONLY relate to the Rita Cosby suit and not the Florida suit. This is unless because Robert Klein is “prepping” Don Clark all weekend for the deposition on October 14, they can do the seven-hour deposition of the Rita Cosby suit, and then go into the night on the O’Quinn suit if Klein and Clark “volunteer” since they cannot be made to compel now.

So based on this, pull the subpoena for Wilma Vicedomine and decide if you were Lin Wood and had seven hours to depose Wilma about her information she gave Rita and put on the internet, what would you ask Wilma Vicedomine (Vice) during that seven hours?

Omnibus Order page 5
Thus, on October 9, 2007, Plaintiff filed a libel lawsuit against Cosby and Hachette, which is currently pending in the United States District Court for the Southern District of New York, Howark K. Stern v. Rita Cosby, et al., Case No. 07-Civ-8536 (“Blonde Ambition Litigation”). D.E. 64 at 74; D.E. 121 at 6. Through the Blonde Ambition Litigation, Plaintiff discovered that Defendants’ investigator Clark, as well as another investigator assisting Clark, Wilma Vicedomine (“Vicedomine”), served as the source for many of the statements contained in Blonde Ambition.D.E. 121 at 6.

Indeed, in the Blonde Ambition Litigation, Cosby and Hachette list Vicedomine in their Initial Disclosures as an individual likely to have discoverable information. Specifically, the Initial Disclosures state that Vicedomine has information regarding the “truth of statements in Blonde Ambition, facts refuting Mr. Stern’s allegations of fault, [and] Mr. Stern’s conduct and reputation.” See Exhibits G & H to D.E. 121. Likewise, the Initial Disclosures identify Clark as having similar information. Id. Plaintiff asserts that while the investigation was ongoing, Clark and Vicedomine revealed information from their investigation to third parties such as Cosby. D.E. 133 at 3. Additionally, Plaintiff contends that Clark attempted to persuade the Federal Bureau of Investigation (“FBI”) and Florida Attorney General to re-open the investigation into Ms. Smith’s death. See D.E. 133.

Omnibus Order page 5 and 6
Also during this same time frame, according to Plaintiff, Vicedomine posted her investigative progress on the Internet. Id. In this respect, Plaintiff asserts that Vicedomine, under various pseudonyms, shared intimate details of the Clark/Vicedomine investigation in Internet chat rooms. D.E. 121 at 10. Specifically, Plaintiff asserts that Vicedomine posted thousands of messages in an online chat room dedicated to discussion of Ms. Smith’s death. In these alleged postings, Vicedomine allegedly discussed aspects of Defendants’ investigation, including strategy, efforts to have Plaintiff prosecuted, and conversations that she had with Arthur. Id. Further, Plaintiff alleges that Vicedomine directed chat room members to post specific statements regarding Plaintiff on the website TMZ.com. Id. at 11.

Omnibus Order Page 31
Next, the Court considers Plaintiff’s additional assertion that Defendants committed disclosure waiver. Under the theory of disclosure waiver, a party waives work-product protection by disclosing to third parties information otherwise protected by the work-product doctrine. Specifically, Plaintiff contends that even if work-product protection existed for the details surrounding the investigation conducted by Vicedomine and Clark, any such protection was waived when Clark and Vicedomine disclosed details of the investigation to Rita Cosby, the author of Blonde Ambition. Further, Plaintiff argues that Vicedomine also divulged information gathered by the investigation to “countless people” via the Internet and in Internet chat rooms. D.E. 121 at 17; 133 at 14.

Omnibus Order Page 32
Instead, with respect to the argument that Vicedomine’s alleged disclosure of investigatory details to Cosby and over the Internet effectuated a waiver, Defendants argue that any waiver must be limited to the information actually disclosed, and not to the entire subject matter allegedly discussed. D.E. 142 at 13. Put simply, Defendants contend that Vicedomine’s actions at most waived protection for actual facts that Vicedomine revealed to Cosby which were also published in Blonde Ambition, or statements actually posted by Vicedomine on the Internet. Since that information is available to Plaintiff, however, Defendants contend that Plaintiff should not be permitted to depose Vicedomine in order to discover all of what Vicedomine told Cosby or all of the Firm’s or Vicedomine’s work product. Additionally, Defendants argue that any waiver of the work-product protection by Vicedomine and Clark with regard to their investigation on behalf of the Firm would not constitute a waiver on the part of Arthur, its client in the related Texas Lawsuit.

Omnibus Order Page 34
While situations exist where a disclosure is essentially compelled or made through excusable inadvertence, and courts are sometimes willing to maintain the work-product protection under such circumstances, see id., this is not one of those cases. Instead, Defendants point to nothing to suggest that Vicedomine and Clark did not purposefully and voluntarily make their statements to Cosby and on the Internet. Moreover, the types of disclosures made (i.e., to the author of a book and on the Internet) are entirely inconsistent with a desire to maintain the privacy of the information disclosed. Rather, books are published and statements are posted on the Internet precisely for the purpose of making them accessible to anyone and everyone. Certainly, at a minimum, the disclosures substantially increased the opportunity for a potential adversary to obtain the protected information.

10Although Defendants have suggested Vicedomine could not have waived the work product protection by engaging in her personal capacity (as opposed to her role as an agent of Defendants) in disclosures of information from the investigation, Defendants have not asserted that Clark and Vicedomine were not acting as agents of Defendants when they spoke to Cosby or made postings of information on the Internet.

Omnibus Order Page 35
Particularly under these circumstances, it is difficult to conceive of how Vicedomine could not have intended that her Internet statements be made available to anyone who wished to view them. Such behavior plainly increased the risk that Plaintiff would learn of Vicedomine’s disclosed work product materials. In fact, Plaintiff did find such materials.

Similar reasoning applies to the disclosures made with respect to Rita Cosby, the author of Blonde Ambition. Cosby interviewed Vicedomine for the purpose of writing a book, in significant part, about the very subject matter of Vicedomine’s interview, and nothing suggests that Vicedomine did not know this. In fact, Blonde Ambition published much of what Vicedomine told Cosby. There is nothing about divulging facts to an author writing a book about the information being disclosed that is consistent with guarding the privacy of information that is otherwise protected by the work product doctrine. Obviously, such conduct increased the possibility that Plaintiff would obtain and use the material. Under the circumstances where Vicedomine voluntarily spoke to a journalist seeking to write a book on the very subject for which information was provided, there could be no expectation that Cosby would maintain the secrecy of any of the information. And, significantly, much of the information conveyed was apparently used and published in the book.

Omnibus Order Page 35 and 36
The Court therefore finds that Vicedomine’s and Clark’s actions, as agents of Defendants, are inconsistent with the maintenance of secrecy of otherwise-work-product protected materials from their adversary. The disclosures were neither involuntary nor compelled, and they were not made to sources that were assisting Defendants in advancing their case. Instead, Vicedomine and Clark made the disclosures at issue to third parties and did so in such a way as to create a substantial risk that information would be received by Defendants’ adversary. Vicedomine and Clark’s actions waived the work product protection since they could not reasonably expect that future use of the information could be limited. Finally, it is significant that Plaintiff did, in fact, learn much of the information disclosed. See Continental Casualty Co., 537 F.Supp.2d at 761 (once an adversary has become aware of information disclosed, it cannot purge that information from its mind). For all of these reasons, Defendants have waived work-product protection in these instances.

Omnibus Order Page 36 and 37
The Court agrees with Defendants to the extent that the disclosures by Vicedomine (and Clark) do not extend so far as to effectuate a waiver of the entire subject matter of the investigation. Due to the sensitive nature of work-product materials and the policy behind maintaining their secrecy, generally speaking, when work-product protection has been waived, it is “limited to the information actually disclosed, not subject matter waiver.”

Omnibus Order Page 37 and 38
Applying this principle of law to these facts, the Court finds that although several disclosures have occurred, any waiver of the work-product protection does not extend beyond those discrete disclosures. Put more simply, the Court finds that Vicedomine (and Clark) waived any work-product protection for anything they said or gave to Cosby in her accumulation of information for Blonde Ambition, and Vicedomine waived the protection for any statements she actually posted or caused to be posted on her behalf on the Internet.

Omnibus Order Page 38
(THIS IS NO LONGER AN ISSUE BECAUSE THE COURT WILL NOT COMPEL VICEDOMINE FOR A DEPOSITION IN THE FLORIDA SUIT EXCEPT AS IT APPLIES TO RITA COSBY’S SUIT. HOWEVER THE ORDER ABOUT SUPPLYING ALL PSEUDNYMS HAS BEEN ORDER BY THE COURT AND SO CAN BE ASKED IN MY OPINION DURING THE SEVEN HOUR DEPOSITION) With respect to the allegation that Vicedomine disclosed otherwise-work-product protected information in Internet chat rooms, the particular statements that can be attributed to Vicedomine in this respect are not entirely clear, as the poster or posters of many of the statements at issue used pseudonyms. Therefore, Vicedomine shall verify all screen names and pseudonyms that she used on the Internet while discussing in public fora matters pertaining to the deaths of the Smiths, the paternity of Dannielynn, or Plaintiff. Defendants shall also be entitled to obtain copies of all postings that Vicedomine made in these public fora that relate to the underlying investigation conducted in furtherance of the Broward County proceedings. Furthermore, Defendants will be permitted to ask Vicedomine about these Internet postings during her deposition.

Omnibus Order Page 38 and 39
Additionally, with respect to Vicedomine’s (and Clark’s) statements made to Cosby, the Court finds that any actual statements made by Vicedomine or Clark to Cosby regarding the investigation have been waived and, thus, are discoverable. As for Defendants’ contention that discovery of this information is limited to statements that were actually published by Cosby in Blonde Ambition, the Court concludes to the contrary. Instead, Defendants are entitled to discovery of all statements Vicedomine and Clark made to Cosby relating to the investigation. Although some of the information provided by Vicedomine and Clark may not have been incorporated into Blonde Ambition, such a fact has no bearing on the scope of the waiver in this case. As noted above, Vicedomine voluntarily spoke to a journalist seeking to write a book on the very subject for which information was provided, and Defendants have not suggested that she had any expectation that Cosby would maintain the secrecy of any of the information conveyed. Consequently, Vicedomine made disclosures to Cosby in such a way as to create a substantial risk that information would be received by Defendants’ adversary.

Omnibus Order Page 39
The fact that all of the information provided by Vicedomine and Clark was not included in Blonde Ambition also refutes Defendants’ contention that the information is readily available to Plaintiff and, therefore, should not be compelled to be disclosed. See D.E. 142 at 13-14. In making this argument, Defendants contend that Plaintiff should not be allowed to depose Vicedomine in order to discover the “full gamut of her work product.” Id. Although the Court agrees that Plaintiff is not entitled to discovery of all of Vicedomine’s work product, he is entitled to information disclosed to Cosby, whether included in Blonde Ambition or not. In this regard, the Court will permit Plaintiff to ask questions during Vicedomine’s deposition about what she told Cosby relating to her investigation.

Omnibus Order Page 45
Attorney-Client Privilege
With respect to the issue of attorney-client privileged information, Defendants conceded that no such privileged materials responsive to the subpoena duces tecum directed to Vicedomine exist. See D.E. 150 at n. 2. Defendants clarified that they inadvertently discussed attorney-client privilege in their objections to discovery. After further review of the documents at issue, however, Defendants realized that only the work-product doctrine protects the information listed on the Vicedomine privilege log. Id. Defendants stated, “At this time, there do not appear to be any documents protected by the attorney-client privilege.” D.E. 152 at n. 9.

Omnibus Order Page 51 and 52
Vicedomine Deposition Duces Tecum
Defendants’ Motion for Protective Order [D.E. 111] seeks for the Court to issue a protective order precluding Plaintiff from deposing Wilma Vicedomine. According to Defendants, the investigation conducted by Vicedomine, as the Firm’s agent, and at the direction of the Firm, is subject to work-product protection. Hence, Defendants argue that Plaintiff should not be permitted to invade that privilege by deposing Vicedomine about the fruits of her investigation.

Omnibus Order Page 52
Plaintiff, in response, asserts that he should be permitted to take Vicedomine’s deposition for various reasons. First, Plaintiff argues that Defendants failed to satisfy their burden under Rule 26, Fed. R. Civ. P., to demonstrate good cause precluding the requested discovery. Second, Plaintiff contends that Defendants waived any applicable work- product protection by placing the investigation at issue. Third, Plaintiff urges that Vicedomine waived any applicable work-product protection by disclosing details of the investigation to third-parties, and finally, Plaintiff claims entitlement to discovery of the underlying facts supporting or contradicting O’Quinn’s statements.

Omnibus Order Page 52 and 53
After careful consideration of these issues, including the briefs presented and the arguments made during the August 13, 2008, hearing, the Court has made a determination with respect to the scope of Vicedomine’s deposition duces tecum. As discussed previously, the Court finds that Defendants put at issue the investigation conducted by Vicedomine and Clark and, thus, waived any work-product protection associated with those materials through the date of O’Quinn’s last alleged statement on March 27, 2008. Likewise, the Court finds that Vicedomine (and Clark) waived any applicable work product protection when they disclosed certain details of her investigation to Rita Cosby and third-parties on Internet web-sites. This waiver applies to all materials actually disclosed by Vicedomine or Clark, including information disclosed after the date of O’Quinn’s last alleged statement on March 27, 2008. Finally, the Court concludes that Plaintiff is entitled to discover the underlying facts that pertain to the truth or falsity of any of the alleged statements set forth in the First Amended Complaint. If, however, these underlying facts are set forth in work-product protected documents that were created after O’Quinn’s last alleged statement on March 27, 2007, Plaintiff must obtain the information through means other than document production. Consequently, Plaintiff may inquire into these materials during Vicedomine’s deposition, but Vicedomine is not required to provide any work-product protected documents created after March 27, 2007, that contain underlying facts.

Omnibus Order Page 53
Accordingly, Defendants’ Motion for Protective Order [D.E. 111] is denied, at least to the extent that it seeks a wholesale ban on Vicedomine’s deposition. With respect to the duces Tecum attachment to the Vicedomine subpoena, the Court acknowledges that some of the document requests are extremely over broad. Indeed, at the August 13, 2008, hearing, Plaintiff’s counsel conceded that the requests were overly broad. Nevertheless, it is undeniable that certain documents that fall within a narrower subset of the requests are discoverable. To summarize, Plaintiff may proceed with the deposition of Vicedomine and may pursue the following areas of inquiry:

(1) All underlying facts regarding the truth or falsity of the eight statements allegedly made by O’Quinn (i.e., the causes of the Smiths’ deaths and other allegations pertaining to Stern made in the statements at issue);
(2) All information (including work-product materials) regarding the Firm’s investigation up through March 27, 2008 (the date of O’Quinn’s alleged last challenged statement); and
(3) With respect to investigative materials or information gathered after March 27, 2008, Plaintiff may inquire about any otherwise-work-product-protected information where, as determined by the Court, a waiver of the protection has occurred through disclosure to third-parties. These categories include (a) anything disclosed by Vicedomine to Rita Cosby (whether or not such information was ultimately published in Blonde Ambition) and (b) any statements regarding the investigation, Stern, or the Smiths, as disclosed by Vicedomine on publicly accessible Internet websites.

Omnibus Order Page 54
With respect to the duces tecum demand attached to the Vicedomine subpoena, Plaintiff can obtain documents that fall within the categories announced above, except for facts which may be set forth in work-product protected documents that were created after O’Quinn’s last alleged statement on March 27, 2007, and which were not otherwise disclosed by Vicedomine to Cosby. Plaintiff must obtain this category of information through means other than document production (i.e., interrogatories or depositions).

Omnibus Order Page 55
Defendants must produce responsive documents that would otherwise be protected as work product if such documents were created after March 27, 2007, if the documents were disclosed to Rita Cosby or on the Internet.

Omnibus Order Page 56
Although the Court recognizes Defendants’ objection on the basis of work product, as noted above, the Court finds that Defendants waived any such protection by placing the investigation at issue in this case. Therefore, the Court finds that Plaintiff is entitled to discover all Investigation Materials and O’Quinn Materials through the time of O’Quinn’s last statement (i.e., March 27, 2007). Additionally, Plaintiff is entitled to discover any Investigation Materials and O’Quinn Materials created after March 27, 2007, if such documents have been disclosed to Rita Cosby or on the Internet.

Omnibus Order Page 56 and 57
With respect to Firm Requests for Production 15 and 16 (O’Quinn Requests 20 and 21), Plaintiff seeks documents concerning communications with Rita Cosby or her representatives, as well as all documents concerning Blonde Ambition. Defendants object to the requests as overly broad with respect to the time frame involved and assert that the request is not limited in scope to this litigation. Defendants also object to the requests on the grounds that the requests seek to breach the work-product protection. The Court agrees that the request is overly broad in scope since it is not limited to issues presented in this case. However, the Court finds that Defendants have waived some of the work-product protection when Vicedomine disclosed facts of the Firm’s investigation to Rita Cosby, the author of Blonde Ambition.

Omnibus Order Page 57
Based on this waiver by disclosure, the Court finds that Plaintiff is entitled to discover any communications made to Rita Cosby regarding the investigation conducted by the Firm, whether or not those communications or materials were included in the Blonde Ambition book.

Omnibus Order Page 58
Therefore, the Court finds that Plaintiff is entitled to discover all of the Investigation Materials and O’Quinn Materials through the time of O’Quinn’s last statement. Additionally, Plaintiff is entitled to discover any of the Investigation Materials and O’Quinn Materials created after O’Quinn’s last statement if they have been disclosed to Rita Cosby or on the Internet.

Omnibus Order Page 59
Although the Court recognizes Defendants’ objection on the basis of work product, as noted above, the Court finds that Defendants waived any such protection through March 27, 2007, by placing the investigation at issue in this case. Therefore, the Court finds that Plaintiff is entitled to discover all of the Investigation Materials and O’Quinn Materials through the time of O’Quinn’s last statement. Additionally, Plaintiff is entitled to discover any Investigation Materials and O’Quinn Materials created after O’Quinn’s last statement if they have been disclosed to Rita Cosby or on the Internet.

So with the highlights here of the August 29, Omnibus Order outlining the context of the depositions, what would you ask Wilma Vicedomine in those seven hours? In addition, state in priority what those should be and why. Remember 7 hours with Wilma Vicedomine, make the questions count and tell us what you would ask her. If you cannot download the documents that you need email me and I will email these documents to you so you can participate this weekend in this “game”.

©Rose Turner
October 11, 2008
All Rights Reserved, do not reproduce in whole or in part without the express written consent of the author.

This article is the sole property of Rose Speaks unless otherwise stated. This article as with other articles is based on the opinion of Rose Turner, or our guest authors if so indicated. Please remember we are not lawyers and those opinions expressed here are each of our individual opinions and should not be taken as legal advice and/or legal opinions. The comments following this article are the opinions and sole property of the site members and do not necessarily reflect those of the site owners.

Please also read our Terms of Use and our Privacy Policy.

Tags: Anna Nicole Smith, Daniel Smith, Dannielynn, Don Clark, Howard K Stern, John O'Quinn, Larry Birkhead, Lin Wood, Rita Cosby, Wilma Vice, Wilma Vicedomine

Adult Video News latest article features Paul Barresi’s latest film, Bear Club for Men, offers a look at what happens when buttoned-down, suited-up corporate types strip down and let the “bear” in them go wild. The movie stars Josh West, Roman Anthony, Freddie Resik, Leed Scott, Anthony Mengetti, Park Wiley, Mark Slade and - making his return to the XXX screen after a brief hiatus - Dillon Press.

Bear Club for Men has wrapped and is in the editing bay. It is due for release in September.

To read more about the gay porn producer catch him on the AVN site. WARNING THE BELOW SITE ONLY DEALS WITH XXX ADULT NEWS ON VIDEOS.

http://avn.com/gay/articles/31968.html.

All of here at Rose Speaks.com wishes Paul the very best in his latest endeavors.

Tags: AVN, Paul Barresi, Paul Barresi adult films

The “self styled investigator”, shorthand for no P. I. license, Paul Barresi tells Fox News, that most of us try NOT to watch, that “he is working with federal authorities so they can understand how the tabloids work and gather “news.”” Do federal authorities like for you to be giving interviews about cases you are working on with them? Anyone know the answer to that perplexing question. Barresi allegedly just had to release a statement about his latest gig to Fox News this morning as they recycled the Edwards story.

He goes on to recall his past and the times he worked with his old boss Anthony Pellicano. ROSE SPEAKS.COM CORRECTION: Baressi, has those tapes of those calls, BUT DID NOT PARTICIPATE IN THE TAPIING OF THOSE CALLS. NOR HAS HE FELT THE DESIRE TO SHARE HOW HE CAME INTO POSSESSION OF THOSE TAPES. You might recall that Pellicano is in prison at the moment for wire taping. Barresi admits he HAS THE TAPES OF the late tabloid reporter Jim Mitteager with Pellicano. What is nice it seems to me is to talk about “HAVING THE TAPES” of the “late tabloid reporter” who cannot dispute you, like the poor reporter is DEAD, have you no shame??? However, not to let death get in his way of cashing in on the Edwards story of how the National Enquirer “works”, you know with payoffs for snitches, called “sources”. Seems Barresi seems to know a lot about selling “stories to rags”, remember Travolta and the Enquirer in 1990 and the Globe with the 1993 story during the Jackson trial?

Not to be deterred that he did not have this story to sell to a rag, Barresi has once again planted himself firmly in a scandal in which he has no roll about selling stories to his old friend the Enquirer. Barresi is not ashamed to tell Fox that he has the 1992 (in addition to the 1994 tapes of Jim Mitteager by Pellicano) tapes of tabloid reporter David Shoemacher about “running gags” on multiple famous people like Michael Douglas and his wife at that time. What are gags for money called to the Globe and Enquirer, would that be a scoop?

My question for today if you are working with the feds against the rags you have always sold your own stories too, while talking to Fox News about working with the feds; what does that make you? Perhaps a poll is in order here on Rose Speaks.com for that very question, feel free to email or send us your multiple choice words for this poll. I have to say with the flood (a/k/a felt kind of like spamming) of emails I received from Paul offering me his number, checking in before and after he went to dinner, telling me I better grab this exclusive while I could because he was leaving for 3 weeks etc. By the way, how is he traveling for 3 weeks while dialing into Fox with his “take” on the latest tabloid sensation? I am sure glad I never picked up the phone and let my fingers do any dialing. This guy seems to have a fetish for phone calls and then selling them and/or the story about them. Or was this perhaps not for a story but for his “friend” or is she a friend, Wilma?

However when I would not be bullied, the “self style investigator”, shorthand for not having a private investigator license, macho man, sent me an email before dawn yesterday morning. The equivalent, in my opinion, of what Barresi hope was the horse’s head in the God Father movie, perhaps with a little help from his newfound Texas buddy, you just have to ask, Oh Really? He was more then happy to share with me his friendship with Wilma Vicedomine (a/k/a Vice) and about them comparing “notes”. Makes you feel all warm to know Barresi is on duty with the feds to explain how tabloids gather news, while telling Fox News what he is doing with the feds, are we all lost yet in Barresi newest endeavor? I am how about you?

A final note, we did not bury Barresi at the end of an article like the one Fox News did, we gave him his own headline, anything to help a friend continue to climb in google ratings. Rose Speaks.com the blog that Barresi can count on. I also found all of my notes on Barresi’s life story from last fall, on a slow day; I will get an article up on the life and tales of Paul Barresi.

Please note Mr. Barressi, we do correct errors here at Rose Speaks.com once we are made aware of them, our apology for implying you did anything illegal like actually taping the calls instead of just HAVING the tapes. A special thanks to one of our favorite writers Mr. Nazarian for pointing that error out.

The password protected blog is at: http://www.rosespeaks.com/rose-blog/?p=496.

©Rose Turner
August 14, 2008
All Rights Reserved, do not reproduce in whole or in part without the express written consent of the author.

This article is the sole property of Rose Speaks unless otherwise stated. This article as with other articles is based on the opinion of Rose Turner, or our guest authors if so indicated. Please remember we are not lawyers and those opinions expressed here are each of our individual opinions and should not be taken as legal advice and/or legal opinions. The comments following this article are the opinions and sole property of the site members and do not necessarily reflect those of the site owners.

Please also read our Terms of Use and our Privacy Policy.

The answer to the first question is that Peter Letterese is suing them all in the Southern District Federal Court in Florida for allegedly committing Civil RICO.

The answer to the second question is that this “bombshell” was brought to the world of media tabloidism by a “self-styled investigator”, shorthand for a PI without a license, Paul Barresi when he released some of the papers to the New York Daily News last month. Barresi was kind enough to offer us first option on his “exclusive statement” about the subject of the lawsuit, but we declined. I believe after you read it at Mediabistro.com you will see why Rose Speaks.com elected not to publish it for Baressi, [ADDITIONAL DISCLAIMER: Rose Speaks.com and its owners DO NOT AGREE with Mr. Baressi’s take on Tom Cruise or The Church of Scientology as Mr. Baressi stated to Mediabistro.com.] but hopefully he will keep our number handy for future takes on strange happenings Hollyweird style.

You might remember Paul Barresi, the “self-styled investigator” that appeared on Geraldo at Large with the nannies tapes or some sort of “evidence” on his way to his “buddy’s” office, A. G. Jerry Brown of California. I am not sure of the date or exactly what the evidence Barresi was traveling with but I do remember Geraldo introducing Barresi as “Geraldo’s investigator”, but could not pronounce his name. Barresi was very patient in correcting Geraldo’s faux pas by both spelling his last name and phonetically pronouncing it for Geraldo. There is an important saying in Hollyweird it appears of, “Just make sure you spell my name right”.

If you google Mr. Barresi he is allegedly the ex bagman/enforcer for Anthony Pellicano, something that Baressi vehemently denied to me. Mr. Barresi says he got that titled because; “There is only one article titled BAGMAN, written by Mark Ebner and Jack Cheevers and a book chapter I personally wrote with author Raymond Straight, titled PELLICANO’S ENFORCER. NOBODY and I mean NOBODY has ever “interviewed me” on these two subjects.” However, Bert Fields threatened to sue Barresi if the book was published.

Mr. Baressi did not discuss his alleged association with Anthony Pellicano when he contacted me last April 15 saying, “We should chat sometime. Please feel free to give me a call anytime. I am a fan of your site”. He did tell me back in April 2008, that Rita Cosby had not been honest about him and something about not being paid by Cosby so he turned over some records via a record subpoena to the attorneys for Howard K. Stern. Now do not misinterpret that as Baressi having a change of heart about Howard K. Stern, whom he still does not like. Baressi just did not like being stiffed more than his dislike for Stern, for money he says was owed him by Cosby.

Now about him meeting Debra Opri and Rita Cosby at the Michael Jackson trial in 1993, Baressi in a haughty email to me wanted to make sure we corrected the “supposition that he met Opri and Cosby during the Michael Jackson trial”. HE DID NOT “have sex with that woman” (1). Ooooooopppppppssssss wrong, HE DID NOT “meet Debra Opri and Rita Cosby at Michael Jackson’s trial in 1993”, they just seemed to have all been at the same place at the same time and Paul loves Debra Opri, just ask him. So consider that corrected Mr. Baressi.

However, with that correction I dived into my best friend these days google to find that Baressi was possibly being honest about that. He was around during the Michael Jackson trial in 1993, but was probably not with the “A-Team” of Cosby and Opri, but with the “D-Team” of “doing an end around” on his clients of the day, per an article by The Smoking Gun. They described Barresi as “a self-styled investigator, [short hand again for having no PI license], who often turns up on the periphery of the tawdriest tabloid stories (part snoop, snitch, and fixer, Barresi is the Zelig of Hollywood’s seamy underbelly).” The Smoking Gun goes on to say Barresi “attempted to broker a deal” for two of the prosecution’s witnesses, the Lamarques.” However, per The Smoking Gun’s article; “While it is unclear if the Lemarques ever consummated a tabloid deal, Barresi himself pulled an end-around on the couple, selling their story to the Globe after surreptitiously taping a meeting during which the pair laid out their charges against Jackson (the resulting piece was headlined “We Saw Michael Molesting Child Star”). Barresi made sure to have a photographer secretly memorialize an August 1993 chat with the Lemarques at an outdoor café”. So our apology to Mr. Barresi for thinking he was hobnobbing with Cosby and Opri, obviously he was hobnobbing instead with the National Enquirer, Globe, Splash news service and Ms. Cosby’s current employer, Inside Edition.

However, back to google since they are named in this Civil RICO suit also, continuing to search I found the following. There is the statement on the IMDB.com bio page for Barresi it states, “Sold a story to the “National Enquirer” in 1990 for $100,000 about his alleged longtime love affair with John Travolta.”

Finally there is, “Paul Barresi - This guy claimed he had an affair with John Travolta! Both men have had run-ins with the Church of Scientology over the years. Barresi, who once told the National Enquirer he had a two-year affair with actor John Travolta, was harassed by the sect’s army of private eyes until he recanted the story.”

That might explain why Paul Barresi seems to have a real beef with the Church of Scientology and perhaps his desire to educate the public is a sincere one. Our society has many “religions” referred to as “cults”. We have one that many refer to here in Texas known as the FLDS, which resulted in some indictments of men having children with underage girls. Few of us will forget the Branch Davidian Waco, Texas compound that resulted in the death many of the members not by the alleged “cult” but by a disastrous assault of the compound by the FBI and ATF, which resulted in the death of over 70 people with 21 of them children and 2 of them pregnant women. Then there is of course the most infamous and tragic result involving a “cult” called Jones Town in the late 70’s.

The problem in attempting to go after “religions” as “cults” is that we have that pesky First Amendment that gives us all the freedom of and from religion. However, because of this being filed in a federal court and a high profile case we will be following this latest lawsuit against the Church of Scientology. Mr. Letterese, however, has until August 22 to file the correct paperwork required in an allegation of CIVIL RICO or the suit will be dismissed from the Florida Federal Court and all of this will become a moot point.

We will have all of the paperwork filed in the Southern District Federal Court in Florida up today for you to download and read through.

On a side note, I have an observation here. No wonder Baressi has turned up in the Anna Nicole Smith saga, now what is the bet Baressi probably knows Wilma Vicedomine? For the record, Baressi neither confirmed nor denied any friendship with Wilma. For some reason the Globe, National Enquirer and Splash News continues to circle these cases so I guess with that comes Baressi automatically.

We will end with a final quote from Baressi. “Rose, why don’t you print this for your readers. COWARD

…IMPORTANT: May I have final approval to what you will print before you print it? Best Paul B. YOUR REPLY: Oh course you will Paul, I do that with everyone I talked with and do an interview and article on….I will send you a copy of the raw data I have bio wise on you, and we will go from there this weekend… Thanks, Rose.

I stand corrected and have added the email quote that Mr. Baressi requested I put here tonight, perhaps when he gets back from his three-week holiday he will grant us an update. Please note that I did say on his “bio” not on the article itself. Now the rest of the emails, well we will just save those as a token of appreciation between Baressi and me.

©Rose Turner
August 11, 2008
(1) Written as a pun and take off of Clinton’s statement in the 1990’s.

All Rights Reserved, do not reproduce in whole or in part without the express written consent of the author.

This article is the sole property of Rose Speaks unless otherwise stated. This article as with other articles is based on the opinion of Rose Turner, or our guest authors if so indicated. Please remember we are not lawyers and those opinions expressed here are each of our individual opinions and should not be taken as legal advice and/or legal opinions. The comments following this article are the opinions and sole property of the site members and do not necessarily reflect those of the site owners.

Please also read our Terms of Use and our Privacy Policy.

Local South Carolina attorneys, Karl Alan Folkens and Louis David Nettles with Folkens Law Firm in Florence, SC., represent the Estate of Anna Nicole and Executor Howard K. Stern. L. Lin Wood, Luke Lantta, and Nicole Jennings Wade of Powell Goldstein of Atlanta Georgia have pending Motions to Appear Pro Hac Vice for Anna Nicole Smith’s Estate and Executor of the Estate, Howard K. Stern. In filings on August 4, 2008, the court was also notified that M. Krista Barth of Florida would be filing for Pro Hac Vice status before the South Carolina Federal Court.

The Original Complaint filed on August 4 also indicates that other persons will be added to the lawsuit at a future date.

The lawsuit is also asking for compensatory, which normally refers to the money sought in a lawsuit to compensate the plaintiff for injury or economic loss such as lost profits from the use of the property from the Estate to go to the sole heir of the Estate Dannielynn Birkhead. The lawsuit is also asking for equitable, which normally means fair and just, and punitive, an amount intended to punish outrageous conduct, against the defendants.

The lawsuit filed goes through the alleged history leading up to this lawsuit included that G. Ben Thompson had an eviction notice served on Ms. Smith on October 20, 2006, the day after the funeral of Ms. Smith’s son, Daniel. After Thompson and Ms. Smith filed counterclaims against each other in the Bahamas. In mid-November 2006. Thompson had the power at Horizons turned off while Ms. Smith was in the home with her newborn daughter.

On November 20, 2006 the court in the Bahamas entered an injunction against G. Ben Thompson and his agents, which prohibited Thompson and his agents from entering Horizons. A true and correct copy of the Injunction was posted prominently on both gates at Horizons. If I remember correctly this was also posted in the local Myrtle Beach Newspaper at the time which would make it impossible for Thompson and Ford Shelley to say they did not know about it.

Ford Shelley and G. Ben Thompson publicized the contentious dispute with Ms. Smith in the international media, including holding a press conference in early November 2006. Ford Shelley and G. Ben Thompson also appeared on the Fox News Network, On the Record with Greta Van Susteren on January 30, 2007 to publicize the contentious dispute with Ms. Smith.

On or about February 9, 2007, the day following Ms. Smith’s sudden death, Ford Shelley and others entered Horizons without authorization and in violation of the Injunction.

The suit further alleges that Ford Shelley and his accomplishes acting on the directions of G. Ben Thompson removed the following items:

1. Numerous paintings and drawings created by Ms. Smith, including paintings painted specifically for her daughter’s nursery.

2. Documents pertaining to Ms. Smith and her daughter, Dannielynn, including legal contracts, residency certificate, banking information, attorney-client privileged documents and Dannielynn’s birth certificate, first footprint, hospital records and ultrasound photographs.

3. Two computers containing Ms. Smith’s personal files and images.

4. One external hard drive containing Mr. Smith’s personal files and images.

5. Approximately twenty-five miniDV tapes containing Ms. Smith’s personal home movies.

6. In excess of one hundred DVDs containing thousands of images and videos, including Ms. Smith’s personal pictures, and a DVD of Ms. Smith’s last movie, “Illegal Aliens, which had not be released.

7. Approximately 30 pair of sunglasses, if I remember correctly these were not cheap sunglasses but very expensive designer sunglasses that Anna Nicole Smith were known for wearing.

8. Three cellular telephones, including a U. S. cell phone that had voice messages on it and a local cell phone [Bahamian] that contained video of Ms. Smith’s commitment ceremony to [Howard K.] Stern.

Among the personal and private items allegedly taken without authorization was a video. “The clown video”, the “Christmas video”, a private video of Ms. Smith and Shelley discussing ownership of Horizons “Horizons video”, “The Wedding video”, “The Gibson Images”, “The Gibson messages”, “The Certificate of Permanent Residence”, and “The Western Union Receipts”. All of these the lawsuit alleges were made available to the media by Ford Shelley and Ben Thompson for the sole purpose of gaining advantage of getting Horizons back from the Estate. “The Estate”, in this instant would be for the use of the sole heir, Dannielynn Birkhead. Dannielynn is the daughter of Anna Nicole Smith and Larry Birkhead. Mr. Birkhead is the guardian of the Estate for his daughter.

The lawsuit also states that there is still ongoing investigation regarding the actions of Ford Shelley with others pending in the Bahamas.

I found it very interesting that the lawsuit states that Ford Shelley met with Larry Birkhead and “his lawyer”, to show them certain items he had taken from Horizons. I wonder if this was Debra Opri or Larry Birkhead’s Florida attorneys. The lawsuit alleges that “pecuniary gain” were given to Ford Shelley and Ben Thompson by media outlets for these tapes. You have to wonder how much money they did made off of all of these media sales, including to Splash and TMZ.com.

The other thing that caught my eye in the filings is that most of the items first found their way on the Fox News Network, On the Record with Greta Van Susteren. The dates are staggering by themselves; January 30, 2007, February 12, 15, and 19, March 5, 12, 15, 22, and 23. That has always led me back to the question of who edited the Clown Video for the television show. In Addition, why did the media never interview Tara and Rune Grinna with their daughter as well as any other guests at that party where the “Clown Video” was taped? More serious though in my opinion was why weren’t they interviewed by any of the agencies investigating, especially the A. G. office in California. Didn’t Geraldo interview Paul Baressi about taking the nannies tape as well as the “Clown video” to A. G. of California Jerry Brown?

The lawsuit gets into the forensic analysis of the computers that were turned over to the Horry County Sheriff’s office once they were delivered to Broward County and the fact that copies were made and apparently kept before turning them over on February 12 after having them from February 9. The lawsuit gives us our first glimpse that “certain files had been deleted”, I wonder which ones and why, when so many sensational and damning things later appeared in the media. I remember Larry Birkhead testifying how shock he was when he saw Anna Nicole Smith’s messenger from her computer appear online after her death. I also remember Ford Shelley appearing apparently to brag to Geraldo on March 31, 2007 about Howard K. Stern would be surprised to learn how many copies of Anna Nicole’s computers and hard drives had been made and kept by various people. It was nice that Ford Shelley gave L. Lin Wood’s office a “copy of the clown video” on November 7, 2007 AFTER appearing with the video on Geraldo in October 2007. Also interesting is that Ford Shelley is alleged to have not yet turned over any of the “originals” shown on media outlets, I wonder if he sold those originals or where they are now.

I found particularly interesting the following parts of the lawsuit that alleges that; [Ford] “Shelley’s conduct in using, displaying, transferring, and selling or attempting to sell the clown video, Christmas video, Horizons video, Wedding video, Gibson photographs, Gibson messages, Certificate of Permanent Residence, and Western Union receipts, as set forth above, constitutes “use” of Ms. Smith’s name, voice, likeness and photograph within the meaning of California Civil Code § 3344.1.” The lawsuit goes on to allege that, “As a direct and proximate result of Shelley’s use of Ms. Smith’s name, voice, photograph and likeness, the Estate has been damaged with respect to business opportunities with entities interested in entering into licensing agreements with respect to certain Estate property. As a direct and proximate result of Defendants’ unlawful business practices, the Estate has been damaged with respect to business opportunities with entities interested in entering into licensing agreements with respect to certain Estate property.”

This next set of allegations in the lawsuit I found interesting as well. [Ford] “Shelley knowingly caused the transmission of the “copy” and other commands to a protected computer, and as a result of such conduct, intentionally caused damage without authorization. Shelley accessed a protected computer without authorization, and as a result of such conduct, recklessly caused damage. Shelley intentionally accessed a protected computer without authorization, and as a result of such conduct, caused damage. As a direct and proximate result of Shelley’s unlawful access of Ms. Smith’s computers and external hard drives, the Estate has been damaged with respect to business opportunities with entities interested in entering into licensing agreements with respect to certain Estate property. As a direct and proximate result of Defendants’ conspiracy that resulted in the conversion and wrongful taking of Estate property, the Estate has been damaged with respect to business opportunities with entities interested in entering into licensing agreements with respect to certain Estate property.” Translated that appears to be saying that the selling of these things to the media deprived Dannielynn Birkhead of making the money she was entitled to as the sole heir of her mother’s estate.

I am left asking what kind of “good friend” as the media especially Fox described Ford Shelley and Ben Thompson of being serves an eviction notice to a mother the day after she buries her son. What kind of “good friend” has the power cut off in a home where a young baby is living? What kind of a “good friend” cheats a baby out of the things Dannielynn is entitled to including her birth certificate. Finally, I ask what kind of a “good friend”, sales the things that belong to a child? With “good friends” like that, I would think you would always have to watch your back.

The first seven documents are:

Original Complaint of Estate of Anna Nicole Smith vs. Stancil Ford Shelley, G. Ben Thompson et. al.

Exhibit 1 Letters of Testamentary appointing Howard K. Stern as the Executor of the Estate of Anna Nicole Smith in California.

Exhibit 2 Letters of Testamentary of Howard K. Stern listing Dannielynn Birkhead as the heir, Larry Birkhead as the guardian, and a copy of Anna Nicole Smith’s Will.

Exhibit 3 a copy of the Injunction from 2006 about Horizons filed in the Bahamas.

Exhibit 4 Written Demands of attorneys to Ford Shelley and G. Ben Thompson demanding of property to be return.

Exhibit 5 Copies of Emails from Larry Birkhead regarding getting the property back.

Executor Howard K. Stern’s Response for Rule 26.1 Interrogatories.

The documents are up to download for All, not just members of Rose Speaks.com at this URL:

The password locked part of this blog for regular members is at this URL: http://www.rosespeaks.com/rose-blog/?p=434.

©Rose Turner
August 7, 2008
All Rights Reserved, do not reproduce in whole or in part without the express written consent of the author.

This article is the sole property of Rose Speaks unless otherwise stated. This article as with other articles is based on the opinion of Rose Turner, or our guest authors if so indicated. Please remember we are not lawyers and those opinions expressed here are each of our individual opinions and should not be taken as legal advice and/or legal opinions. The comments following this article are the opinions and sole property of the site members and do not necessarily reflect those of the site owners.

Please also read our Terms of Use and our Privacy Policy.

It has been passed around in court filings from last June in California, to Florida, to New York that Mark Speer(s), a/k/a Speer, Spear and Spears, seems to have almost as much connection to all of the lawsuits in differing jurisdictions as does Wilma Vicedomine, which leads to the question of why?

In the California dueling banjos of the Birkhead sues Opri sues Birkhead cases there are a few facts they did agree on. The main one being that a disagreement over money given to Opri on or about March 2, 2007, which ended up in her client trust fund, caused a disagreement on March 13 following a hearing in California.

After that the tale gets hazy, Larry Birkhead has always claimed he fired Opri on March 13, Opri has maintained she fired Birkhead on March 15 and released a statement stating that right before a hearing in the Bahamas on the morning of March 16, 2007.

Court Filings by Opri shows she filed on March 20, 2007 to be released as Birkhead’s attorney of record in California and that the court granted that on April 23, 2007.

We have many allegations if you all remember of whether Rita Cosby secured Opri for Birkhead and if Opri then released confidential information to Cosby as a thank you for the high profile client. That is a lot of he said, she said, except that Cosby does say in her book she did introduce them but did not know of any financial arrangements. Greta of Fox, during a L. A. Times article on the woes of Debra Opri did recount a conversation she had with Birkhead in September 2006 in which she said Birkhead told her Opri was going to represent him free. Opri, Cosby and Paul Barresi all agree they met and became friends during the Michael Jackson Criminal Trial in California in 1993.

Then there are all of those people in all of these suits, especially the lawyers of Cosby, Opri, Arthur tend to keep mentioning the Marshall monies Dannielynn might get one day, which seems to be an ongoing current in all of these cases and with all of these people.

In Opri’s filings, and statements made by both Ford Shelley and Ron Rale there was a meeting in Rale’s hotel room between Shelley, Birkhead and Howard K. Stern about funeral arrangements for Anna Nicole Smith as well as attempting to reach agreements on all disputed facts including Horizons and a private DNA test for Larry Birkhead. This meeting occurred the night of the last day of hearings in Florida in February 2007. However, until Cosby’s book was published that is the only meeting anyone has ever talked about other than Opri thanked Stern on the last day of hearings for Stern agreeing to allow Birkhead permission to see Dannielynn during Birkhead’s next visit to the Bahamas.

In Court Filings in California, Opri seems to “believe and states” that Birkhead and Harvey Levin of TMZ.com were “good friends”. Larry Birkhead bragged about that per Opri’s filings, including releasing her bill to TMZ.com, and it does appear that TMZ.com had the exclusive following Birkhead’s ten-hour deposition this week. So perhaps that allegation is true, after all it would appear that possibly TMZ.com might have bought some of Birkhead’s celebrity pictures over the years to me, what do y’all think?

Then comes the surprise why did John O’Quinn’s law firm claimed “privilege” on all third party correspondence that ended up with Wilma Vicedomine to “check out” but not those that ended up with the rest of the firm including Don Clark. Thus, the law firm released the long rambling email of Carolyn Herring, which several thought was hiney einy of Florida only after reading that email it is clear that Ms. Herring lives in Texas in the Dallas Fort Worth area. There is a long rambling correspondence with a Howard Lynn, which is just that. Then there are emails from a Joyce Cornwell of Florida that is interesting, as well as a nurse from Denton Texas offering her service “pro bono” to Virgie Arthur. Many of you have pointed out the interesting email from someone claiming to be with the Montel Williams show, which is interesting only in that Cosby ended up on that show with Don Clark and others selling her book in the fall of 2007.

There is a fan email from Marilyn Williamson of Fenandina Beach Florida, dated March 28, 2007. Ms. Williamson is proud to say she figured out John O’Quinn’s strategy in getting Howard K. Stern to file a slander suit against O’Quinn for the “m” word so O’Quinn could get jurisdiction over Stern in Texas, now that is an interesting email since it now appears to have a ring of truth to it.

However, I found three emails of particular interest, one from Virgie Arthur’s Bahamian lawyer, Debra Rose. That email states to Don Clark the following:

“Debra Rose wrote:

Don,
We are aware of the Bahamian connection; add to that the son of Roger Gomez, Roger Gomez, Jr., was recently an associate of the law firm of Lockhart and Munroe, Howard Stern’s attorneys.

DEBRA”

You have to wonder why O’Quinn did not claim attorney-client privilege on that one for Virgie Arthur.

But then there are some interesting letters and two very interesting emails, the letters are to and from Brian Cavanagh in Florida as well as the FBI in Miami asking for a more thorough investigation into Anna Nicole’s death.

The letter to the FBI states in part the following:

Dated April 16, 2007

“[A]n expert, Mr. David Liebman, a two time president of the National Association of Document Examiners, says the signature appears to be a forgery is also enclosed. Additionally I [Clark] have enclosed a copy of a magazine article that identifies the expert who says he believes the signature of the Will is a forgery.

Based on the investigation conducted by this law firm, the media and private citizens, we strongly believe that Anna’s death was anything but an accidental overdose. We believe that there should be a thorough investigation into Ms. Smith’s death, which would not be complete without including the circumstance surrounding the death of her son, Daniel smith, who died in the Bahamas on September 10, 2006 under almost identical circumstances…

Don Clark then names both DEA agents and telephone numbers in California that are conducting an investigation, Lisa Troncoso and Alma Tongson, as well as Jon Genens an “investigator” for the State of California Medical Board, are investigating the methods of procuring prescription drugs”.

Clark thanks SSA Patrick G. Brodsky, for taking the time and meeting with him [Clark] on “April 11, 2007 to discuss what I [Clark] believe to be severe mis-steps and incomplete investigations conducted by the Seminole Police Department”, (OUCH!), “surrounding the death of Anna Nicole Smith. I am available to provide you with any assistance I can to ensure justice is done as it relates to Ms. Smith’s death and the death of her son Daniel. I can be contacted at any time at the below numbers…”

Don Clark sends a CC to Valerie Parlave, Assistant Special Agent In charge, FBI, Miami Division.

Then we have the letter dated August 2, 2007 from Brian T. Cavanagh to Don Clark that states in part:

“August 2, 2007

From Brian T. Cavanagh

“…letter dated July 23, 2007, and our follow-up telephone conversation this week with a “representative of your firm”.”

No date but in response to the August 2, 2007 letter Don Clark makes some interesting statements