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B EXHIBIT E ATTACHED TO MOTION FOR SUMMARY JUDGMENT – Affidavit of O’Q Defendant, John M. O’Quinn, having first been sworn, upon oath, deposes and states:  1. I have known Don Clark for a number of years, dating back to his tenure as Special Agent In Charge of the FBI Offices in Houston, Texas. 2. I knew that he was a highly trained and highly respected FBI Agent and Manager, and was always impressed by his investigative thoroughness and his intellect.  3. I asked Don Clark to come to work with the Firm a number of years ago. Since that time, I have been thoroughly impressed with his integrity and his extraordinary investigative skills. 4. Don has maintained many contacts throughout the law enforcement community, including the International Association of Chiefs of Police , and is often able to piece together information about particular cases that go far beyond what I would  ordinarily expect from a law firm investigator. I have also come to rely highly upon his integrity. Don will simply not give me an opinion on a matter until he is absolutely convinced that he has gotten to the truth.  5. With the exception of matters that I observed directly in the Courtroom, such as the suspicious fax date on Anna Nicole’s Will, which I referred to during one of my interviews, the overwhelming majority of the information that I relied upon, during the various interviews that are quoted in the Complaint, came directly from Don Clark. I had asked Don to get involved in the investigation of Anna Nicole Smith and her son, Daniel, the moment that I was asked by Virgie Arthur to represent her in fighting to secure custody of her daughter’s body in the Florida proceedings. From that point on, Don was investigating the death of both Anna Nicole Smith and her son, Daniel on virtually a daily basis over the course of the next several weeks. 6. As part of Don’s investigation he would communicate with me concerning interviews that he had conducted or research that he undertaken or that had been undertaken at his request. He summarized news articles for me, on line literature and the results of his interviews, and other investigation on virtually a nightly basis. Among other things, Don made it quite clear to me that he felt that Mr. Stern was criminally responsible for the death of Anna Nicole Smith and her son, Daniel, and that he had either  deliberately brought about the death of one or both of these individuals, through the administration of inappropriate quantities of prescription drugs or that he had facilitated their deaths, by providing them with prescription drugs without any real medical training or background and without regard to the amount of the doses of various medications that were being administered.  I became quite convinced from my conversations with Don that Mr. Stem had to be criminally implicated in the death of my client’s daughter and her grandson, and that Mr. Stem’s involvement with the procuring and administration of prescription drugs was not simply a coincidence. 7. Regarding the interview of me summarized in the Complaint and what I said, Mr. Clark was my investigator and was doing, an ongoing daily and nightly investigation to help me in my representation of Mrs. Virgie Arthur. Mr. Clark daily told me what his investigation was revealing to him and causing him to conclude what had occurred with regard to everything that I said in all of the interviews about which the plaintiff is complaining in his Petition. I discussed all of that information with Mi. Clark, and particularly what he had uncovered, before I made any of the statements attributed to me to confirm what I was stating was true. I felt fully comfortable relying on what Mr. Clark had told me in making those statements. In addition, I came to believe that some portions of those statements were accurate based on part upon what I heard, saw and observed in the courtroom during the legal proceedings in which I represented Ms. Virgie Arthur as her counsel.  I was in the Courtroom at the time that Mr. Stem identified Anna Nicole’s Will, which had been faxed to him some four days prior to her death. While Mr. Stem’s attorney attempted to explain the discrepancy, I did not accept that at the time, and do not accept it now. It was my impression at the time that I heard the explanation concerning the inappropriate fax dates that the entire claim had been fabricated to cover up the fact that Mr. Stem had actually sought and procured a copy of Ms. Smith’s Will within a matter of days prior to her death. While Mr.Stern’s attorney attempted to explain the discrepancy, I did not accept their explanation. I believed that the explanation of Stern and his attorney regarding the faxing of Anna Nicole’s will was false. In particular, I heard their explanation concerning the inappropriate fax dates and strongly believed that this explanation had been fabricated to cover up the fact that Mr. Stern had actually sought and procured a copy of Ms. Smith’s will within a matter of days of her death. In addition, Don Clark advised me that if anyone plugged in a telephone/fax line in to a socket in the United States, it would automatically calibrate the date and time of the service provider.  Don advised me of several statements confirming my suspicions, all of which predated my statements to the media. Further, I already knew based on Clark’s investigation that Anna Nicole’s will was created before Daniel’s death, that the will named Daniel as her sole heir and that the will named Howard Stem as the executor of her estate. From Clark, I learned that Mr. Stern’s sister had discussed the will that showed up in the courtroom on the Larry King show and that she was aware of the content of the will. Mr. Clark also advised me that Ron Rale had also discussed the contents of the will during a nationally televised interview, before the will appeared in the courtroom. Thus, when Stem testified under oath in Judge Seidlin’s court that he did not know the location or the content of the will, I believed then and now that his testimony was false and that Ron Rale had in fact faxed the will from his home to Mr. Stem on February 3, 2007 as was reflected on the copy of the will that, was introduced in the courtroom.  Despite these public statements concerning the content of the will which were made prior to the trial, I did not then and do not now believe that Mr. Stern was unaware of the content of the will. I found that statement to be incredible, given Mr. Stem’s professed relationship with Anna Nicole, as her chief financial, advisor and her lawyer, and his professed role as her lover and the father of her daughter. Thus, I believe that Mr. Rale faxed the will from his home on February 3, 2007. 8. Any information that I may have imparted concerning the existence of life insurance policies was based upon discussions which I had with a producer and reporters for the Greta Van Susteren show, who advised me that while I was in Florida for the custody proceedings that they had determined that those policies existed, and were investigating the issue further. I was told that the information was accurate, and presumed that I would not have been told that information if it had not been fully developed, given all of the other events that were unfolding, I had absolutely no reason to believe that this information was untrue, in light of what I had learned from Mr. Clark and from what I had observed during the custody hearing, which certainly supported what I was being told by members of Greta Van Susteren’s crew.  Further, given the fact that Anna Nicole has a well publicized endorsement contract and was receiving a fair amount of income given her notoriety, and particularly in light of the fact that she had a son and a new daughter, I felt that it was quite likely that she did maintain life insurance. Under the circumstances, I truly believed that the information that was imparted to me was legitimate before I mentioned the existence of the life insurance policies during one of the interviews.  9. The truth of each statement that I made during the various interviews about which I am being falsely sued, are based upon solid intelligence and investigation developed by Mr. Clark. This is also true with regard to Mr. Stem’s involvement with the provision of prescription drugs to Ms. Smith and his procuring of those drugs through  the use of varying names was confirmed for me by Mr. Clark based upon research that he had either conducted directly or had been conducted at this request, and interviews which he had conducted personally, and various comparisons that I had been shown of discrepancies in testimony or interviews that were given by Mr. Stern on numerous occasions both before and after the death of Anna Nicole Smith. In addition, my comments were based upon my own assessment of Mr. Stem’s complete lack of credibility, and some of the extraordinary admissions that he had made, even prior to my involvement as counsel for Virgie Arthur. Those admissions included the fact that he had slept with a client whom he purported to represent, which I found to be both remarkable and offensive, and his own admission that they kept the “relationship” a secret because he was her attorney and the fact that he was essentially living off income that was being generated by Anna Nicole Smith, my client’s daughter. I could not overlook the fact that Stern claimed to be the father of my client’s granddaughter, and that he refused to take a paternity test and offered no reasonable explanation for that refusal,. Further, according to Mr. Clark, multiple friends of Anna Nicole Smith had stated publically that they knew that Anna had never slept with Mr. Stern, including Mr. Larry Birkhead, who testified that he was the legitimate father of Anna Nicole’s daughter at the custody hearing.. This and other information that Mr. Clark developed for me made it difficult to believe virtually anything that Mr. Stern might say or claim.  10. I believed to be clearly true each and every statement that is attributed to me in the Complaint, before I made those statements. Further, each statement I made was based upon based upon an extraordinary amount of investigation and information that had been gathered and summarized for me during literally dozens of conversations with Mr. Clark, as well as what I had seen during the Court proceedings.  11. Before the Court proceedings, however, I want to point out that I harbored absolutely no malice toward Mr. Stern. I never had met or dealt with Mr. Stern. I simply believed both personally and as an advocate for my client, and based upon what I truly believed---and still believe--that he needed to be prosecuted because of his role in both the deaths of Anna Nicole Smith and her son, Daniel. Prior to the representation of my client Ms Arthur, I had absolutely no idea whom Mr Stern was, and had paid virtually no attention to the life and times of Anna Nicole Smith.FURTHER AFFIANT SAYETH NAUGHT.JOHN M.O’QUINN
O Quinn Affidavit Exhibit E
O Quinn Affidavit Exhibit E
O Quinn Affidavit Exhibit E

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O Quinn Affidavit Exhibit E

  • 1. B EXHIBIT E ATTACHED TO MOTION FOR SUMMARY JUDGMENT – Affidavit of O’Q Defendant, John M. O’Quinn, having first been sworn, upon oath, deposes and states: 1. I have known Don Clark for a number of years, dating back to his tenure as Special Agent In Charge of the FBI Offices in Houston, Texas. 2. I knew that he was a highly trained and highly respected FBI Agent and Manager, and was always impressed by his investigative thoroughness and his intellect. 3. I asked Don Clark to come to work with the Firm a number of years ago. Since that time, I have been thoroughly impressed with his integrity and his extraordinary investigative skills. 4. Don has maintained many contacts throughout the law enforcement community, including the International Association of Chiefs of Police , and is often able to piece together information about particular cases that go far beyond what I would ordinarily expect from a law firm investigator. I have also come to rely highly upon his integrity. Don will simply not give me an opinion on a matter until he is absolutely convinced that he has gotten to the truth. 5. With the exception of matters that I observed directly in the Courtroom, such as the suspicious fax date on Anna Nicole’s Will, which I referred to during one of my interviews, the overwhelming majority of the information that I relied upon, during the various interviews that are quoted in the Complaint, came directly from Don Clark. I had asked Don to get involved in the investigation of Anna Nicole Smith and her son, Daniel, the moment that I was asked by Virgie Arthur to represent her in fighting to secure custody of her daughter’s body in the Florida proceedings. From that point on, Don was investigating the death of both Anna Nicole Smith and her son, Daniel on virtually a daily basis over the course of the next several weeks. 6. As part of Don’s investigation he would communicate with me concerning interviews that he had conducted or research that he undertaken or that had been undertaken at his request. He summarized news articles for me, on line literature and the results of his interviews, and other investigation on virtually a nightly basis. Among other things, Don made it quite clear to me that he felt that Mr. Stern was criminally responsible for the death of Anna Nicole Smith and her son, Daniel, and that he had either deliberately brought about the death of one or both of these individuals, through the administration of inappropriate quantities of prescription drugs or that he had facilitated their deaths, by providing them with prescription drugs without any real medical training or background and without regard to the amount of the doses of various medications that were being administered. I became quite convinced from my conversations with Don that Mr. Stem had to be criminally implicated in the death of my client’s daughter and her grandson, and that Mr. Stem’s involvement with the procuring and administration of prescription drugs was not simply a coincidence. 7. Regarding the interview of me summarized in the Complaint and what I said, Mr. Clark was my investigator and was doing, an ongoing daily and nightly investigation to help me in my representation of Mrs. Virgie Arthur. Mr. Clark daily told me what his investigation was revealing to him and causing him to conclude what had occurred with regard to everything that I said in all of the interviews about which the plaintiff is complaining in his Petition. I discussed all of that information with Mi. Clark, and particularly what he had uncovered, before I made any of the statements attributed to me to confirm what I was stating was true. I felt fully comfortable relying on what Mr. Clark had told me in making those statements. In addition, I came to believe that some portions of those statements were accurate based on part upon what I heard, saw and observed in the courtroom during the legal proceedings in which I represented Ms. Virgie Arthur as her counsel. I was in the Courtroom at the time that Mr. Stem identified Anna Nicole’s Will, which had been faxed to him some four days prior to her death. While Mr. Stem’s attorney attempted to explain the discrepancy, I did not accept that at the time, and do not accept it now. It was my impression at the time that I heard the explanation concerning the inappropriate fax dates that the entire claim had been fabricated to cover up the fact that Mr. Stem had actually sought and procured a copy of Ms. Smith’s Will within a matter of days prior to her death. While Mr.Stern’s attorney attempted to explain the discrepancy, I did not accept their explanation. I believed that the explanation of Stern and his attorney regarding the faxing of Anna Nicole’s will was false. In particular, I heard their explanation concerning the inappropriate fax dates and strongly believed that this explanation had been fabricated to cover up the fact that Mr. Stern had actually sought and procured a copy of Ms. Smith’s will within a matter of days of her death. In addition, Don Clark advised me that if anyone plugged in a telephone/fax line in to a socket in the United States, it would automatically calibrate the date and time of the service provider. Don advised me of several statements confirming my suspicions, all of which predated my statements to the media. Further, I already knew based on Clark’s investigation that Anna Nicole’s will was created before Daniel’s death, that the will named Daniel as her sole heir and that the will named Howard Stem as the executor of her estate. From Clark, I learned that Mr. Stern’s sister had discussed the will that showed up in the courtroom on the Larry King show and that she was aware of the content of the will. Mr. Clark also advised me that Ron Rale had also discussed the contents of the will during a nationally televised interview, before the will appeared in the courtroom. Thus, when Stem testified under oath in Judge Seidlin’s court that he did not know the location or the content of the will, I believed then and now that his testimony was false and that Ron Rale had in fact faxed the will from his home to Mr. Stem on February 3, 2007 as was reflected on the copy of the will that, was introduced in the courtroom. Despite these public statements concerning the content of the will which were made prior to the trial, I did not then and do not now believe that Mr. Stern was unaware of the content of the will. I found that statement to be incredible, given Mr. Stem’s professed relationship with Anna Nicole, as her chief financial, advisor and her lawyer, and his professed role as her lover and the father of her daughter. Thus, I believe that Mr. Rale faxed the will from his home on February 3, 2007. 8. Any information that I may have imparted concerning the existence of life insurance policies was based upon discussions which I had with a producer and reporters for the Greta Van Susteren show, who advised me that while I was in Florida for the custody proceedings that they had determined that those policies existed, and were investigating the issue further. I was told that the information was accurate, and presumed that I would not have been told that information if it had not been fully developed, given all of the other events that were unfolding, I had absolutely no reason to believe that this information was untrue, in light of what I had learned from Mr. Clark and from what I had observed during the custody hearing, which certainly supported what I was being told by members of Greta Van Susteren’s crew. Further, given the fact that Anna Nicole has a well publicized endorsement contract and was receiving a fair amount of income given her notoriety, and particularly in light of the fact that she had a son and a new daughter, I felt that it was quite likely that she did maintain life insurance. Under the circumstances, I truly believed that the information that was imparted to me was legitimate before I mentioned the existence of the life insurance policies during one of the interviews. 9. The truth of each statement that I made during the various interviews about which I am being falsely sued, are based upon solid intelligence and investigation developed by Mr. Clark. This is also true with regard to Mr. Stem’s involvement with the provision of prescription drugs to Ms. Smith and his procuring of those drugs through the use of varying names was confirmed for me by Mr. Clark based upon research that he had either conducted directly or had been conducted at this request, and interviews which he had conducted personally, and various comparisons that I had been shown of discrepancies in testimony or interviews that were given by Mr. Stern on numerous occasions both before and after the death of Anna Nicole Smith. In addition, my comments were based upon my own assessment of Mr. Stem’s complete lack of credibility, and some of the extraordinary admissions that he had made, even prior to my involvement as counsel for Virgie Arthur. Those admissions included the fact that he had slept with a client whom he purported to represent, which I found to be both remarkable and offensive, and his own admission that they kept the “relationship” a secret because he was her attorney and the fact that he was essentially living off income that was being generated by Anna Nicole Smith, my client’s daughter. I could not overlook the fact that Stern claimed to be the father of my client’s granddaughter, and that he refused to take a paternity test and offered no reasonable explanation for that refusal,. Further, according to Mr. Clark, multiple friends of Anna Nicole Smith had stated publically that they knew that Anna had never slept with Mr. Stern, including Mr. Larry Birkhead, who testified that he was the legitimate father of Anna Nicole’s daughter at the custody hearing.. This and other information that Mr. Clark developed for me made it difficult to believe virtually anything that Mr. Stern might say or claim. 10. I believed to be clearly true each and every statement that is attributed to me in the Complaint, before I made those statements. Further, each statement I made was based upon based upon an extraordinary amount of investigation and information that had been gathered and summarized for me during literally dozens of conversations with Mr. Clark, as well as what I had seen during the Court proceedings. 11. Before the Court proceedings, however, I want to point out that I harbored absolutely no malice toward Mr. Stern. I never had met or dealt with Mr. Stern. I simply believed both personally and as an advocate for my client, and based upon what I truly believed---and still believe--that he needed to be prosecuted because of his role in both the deaths of Anna Nicole Smith and her son, Daniel. Prior to the representation of my client Ms Arthur, I had absolutely no idea whom Mr Stern was, and had paid virtually no attention to the life and times of Anna Nicole Smith.FURTHER AFFIANT SAYETH NAUGHT.JOHN M.O’QUINN