The document is a transcript from the confidential oral and videotaped deposition of Wilma Vicedomine on October 13, 2008 related to a civil action. In the deposition, Vicedomine discusses meeting with two former nannies of Anna Nicole Smith, and being told details about a video the nannies said Smith liked to watch of Howard Stern and Larry Birkhead engaged in a sexual act. Vicedomine questions the nannies further on this claim.
This document appears to be a transcript from a legal deposition involving Stancil Ford Shelley Jr. regarding a case from 2009. In the deposition, Shelley is asked questions about his involvement with various individuals related to the case, including Larry Birkhead, John O'Quinn, Neil McCabe, and Don Clark. Shelley admits to trying to help Larry Birkhead obtain custody of his child and staying away from lawyers involved in the case. He also denies currently possessing any items taken during the case proceedings.
Rex plays through multiple generations of the Whitehall family in an apocalyptic setting. He summarizes progressing the careers and lives of family members like Judith, Justin, Jonah, and James. Babies are born and family members attend college, unlocking new career paths. Rex lifts restrictions like alien technology and paranormal to continue advancing the generations.
This document is a motion for a stay of the mandate pending a petition for certiorari to the Supreme Court. It was filed by Howard K. Stern on behalf of Vickie Lynn Marshall's estate following the 9th Circuit's denial of rehearing. The motion argues that substantial questions will be presented in the cert petition regarding the scope of bankruptcy courts' power over compulsory counterclaims. It contends the 9th Circuit's new test conflicts with other circuits and Supreme Court precedent. The declaration also asserts the petition raises important issues of bankruptcy practice that require uniformity.
CA Verdicts - incomplete (partial consensus on TWO COUNTS)JRachelle
This document contains verdicts from a jury trial in Superior Court of California, Los Angeles County. The jury found defendant Sandeep Kapoor not guilty on all 10 counts. The jury found defendant Khristine Eroshevich guilty on Counts 1, 3, 7, and 9, and found defendant Howard K. Stern guilty on Count 1. The verdicts specify the charges and time periods for each count.
SC Opinion and Order - motion for comtemptJRachelle
The court granted in part and denied in part the plaintiff's motion for contempt and sanctions. The court found Susan Brown, the attorney, in contempt for violating a consent order requiring her to turn over all copies of estate property. However, the court did not find Ben Thompson, Brown's former client, in contempt as there was no clear evidence he violated the order. As a sanction, the court ordered Brown to pay the plaintiff's reasonable attorney's fees and costs for bringing the contempt motion, but no other punitive sanctions. The court also ordered Brown and Thompson to turn over any remaining estate property.
Marshall v Living Trust Fund status conferenceJRachelle
The document is an order from a United States District Court judge rescheduling the status conference date in the case Marshall v. Hilliard, et. al. from June 14, 2010 to December 13, 2010 at 8:30 am. The order stipulates that the new date may need to be changed within 30 days of the U.S. Supreme Court's decision on whether to grant certiorari in a related case. If no action is taken by December 6, 2010, the parties must either attend the status conference on December 13 or file another stipulation to continue the date.
The impact of innovation on travel and tourism industries (World Travel Marke...Brian Solis
From the impact of Pokemon Go on Silicon Valley to artificial intelligence, futurist Brian Solis talks to Mathew Parsons of World Travel Market about the future of travel, tourism and hospitality.
We’re all trying to find that idea or spark that will turn a good project into a great project. Creativity plays a huge role in the outcome of our work. Harnessing the power of collaboration and open source, we can make great strides towards excellence. Not just for designers, this talk can be applicable to many different roles – even development. In this talk, Seasoned Creative Director Sara Cannon is going to share some secrets about creative methodology, collaboration, and the strong role that open source can play in our work.
This document appears to be a transcript from a legal deposition involving Stancil Ford Shelley Jr. regarding a case from 2009. In the deposition, Shelley is asked questions about his involvement with various individuals related to the case, including Larry Birkhead, John O'Quinn, Neil McCabe, and Don Clark. Shelley admits to trying to help Larry Birkhead obtain custody of his child and staying away from lawyers involved in the case. He also denies currently possessing any items taken during the case proceedings.
Rex plays through multiple generations of the Whitehall family in an apocalyptic setting. He summarizes progressing the careers and lives of family members like Judith, Justin, Jonah, and James. Babies are born and family members attend college, unlocking new career paths. Rex lifts restrictions like alien technology and paranormal to continue advancing the generations.
This document is a motion for a stay of the mandate pending a petition for certiorari to the Supreme Court. It was filed by Howard K. Stern on behalf of Vickie Lynn Marshall's estate following the 9th Circuit's denial of rehearing. The motion argues that substantial questions will be presented in the cert petition regarding the scope of bankruptcy courts' power over compulsory counterclaims. It contends the 9th Circuit's new test conflicts with other circuits and Supreme Court precedent. The declaration also asserts the petition raises important issues of bankruptcy practice that require uniformity.
CA Verdicts - incomplete (partial consensus on TWO COUNTS)JRachelle
This document contains verdicts from a jury trial in Superior Court of California, Los Angeles County. The jury found defendant Sandeep Kapoor not guilty on all 10 counts. The jury found defendant Khristine Eroshevich guilty on Counts 1, 3, 7, and 9, and found defendant Howard K. Stern guilty on Count 1. The verdicts specify the charges and time periods for each count.
SC Opinion and Order - motion for comtemptJRachelle
The court granted in part and denied in part the plaintiff's motion for contempt and sanctions. The court found Susan Brown, the attorney, in contempt for violating a consent order requiring her to turn over all copies of estate property. However, the court did not find Ben Thompson, Brown's former client, in contempt as there was no clear evidence he violated the order. As a sanction, the court ordered Brown to pay the plaintiff's reasonable attorney's fees and costs for bringing the contempt motion, but no other punitive sanctions. The court also ordered Brown and Thompson to turn over any remaining estate property.
Marshall v Living Trust Fund status conferenceJRachelle
The document is an order from a United States District Court judge rescheduling the status conference date in the case Marshall v. Hilliard, et. al. from June 14, 2010 to December 13, 2010 at 8:30 am. The order stipulates that the new date may need to be changed within 30 days of the U.S. Supreme Court's decision on whether to grant certiorari in a related case. If no action is taken by December 6, 2010, the parties must either attend the status conference on December 13 or file another stipulation to continue the date.
The impact of innovation on travel and tourism industries (World Travel Marke...Brian Solis
From the impact of Pokemon Go on Silicon Valley to artificial intelligence, futurist Brian Solis talks to Mathew Parsons of World Travel Market about the future of travel, tourism and hospitality.
We’re all trying to find that idea or spark that will turn a good project into a great project. Creativity plays a huge role in the outcome of our work. Harnessing the power of collaboration and open source, we can make great strides towards excellence. Not just for designers, this talk can be applicable to many different roles – even development. In this talk, Seasoned Creative Director Sara Cannon is going to share some secrets about creative methodology, collaboration, and the strong role that open source can play in our work.
This document is the transcript of a deposition of Don Clark taken on October 14, 2008 in connection with two lawsuits: Howard K. Stern v. Rita Cosby and Hachette Book Group USA, Inc. and Howard K. Stern v. John M. O'Quinn and John M. O'Quinn & Associates, PLLC. The deposition covers Clark's background, career history including 27 years with the FBI, work as an investigative strategist and jury consultant with The O'Quinn Law Firm since retiring from the FBI in 2000, and investigative work related to the Anna Nicole Smith case that began in February 2007.
DEPOSITION OF DEFENDANT / JON GREENAWALT DIRECTOR OF WEB DEVELOPMENT GAP INT...Gérard Angé
DEPOSITION OF DEFENDANT / Jon Greenawalt DIRECTOR OF WEB DEVELOPMENT GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
OTHER DEFENDANTS:
=========================
ANTHONY TEMPLER /
CURRENTLY RESIDING AT:
Zille Str. 69, 10575
BERLIN, GERMANY
LAST KNOWN USA ADDRESS: ANTHONY TEMPLER/
ATANDA WEB PRESENCE SERVICES
939 61ST STREET, SUITE #13
OAKLAND, CA 94608-1301
-------------------------------------------------------------
GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
----------------------------------------------------------
MORE INFORMATION ON THE THEFT:
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
----------------------------------------------------------
CIV214702 Sulphur Mountain/Gaggero v Redmonds Relevant Case Record 1jamesmaredmond
This document is the transcript of a deposition of Geraldine Redmond taken on August 6, 2003 in a case between Somerset Farms LLC and others. In the deposition, Geraldine Redmond discusses personal agreements made between Laurie Canty, Kim Cruiser, Jenny Martin and the owner of the property, Steve Gaggero, after Redmond gave them eviction notices on behalf of Somerset Farms LLC. Redmond questions the honesty and credibility of Canty, Cruiser and Martin due to these personal agreements.
Depostion "Live" of Houston Scrooge Attorney Harry C. Arthur Attroney at Law
Cmdr. Bluefin "Sherlock Holmes Case of: "The Talking Treasure Box" Aronold Anderson (Andy) Vickery & Andrew T. Mc.Kinney,
This document summarizes a deposition transcript involving John O'Quinn. O'Quinn was deposed regarding his representation of Vergie Arthur in legal matters related to the death and estate of Anna Nicole Smith. O'Quinn stated that he was engaged by Arthur to help her obtain the right to bury her daughter and raise her granddaughter. He met with Arthur's Florida lawyer, Steve Tunstall, in Fort Lauderdale to discuss assisting in the case in Florida. The scope of O'Quinn's engagement was limited and did not include facilitating media contacts or book deals for Arthur.
The transcript summarizes a preliminary hearing involving the State of Oklahoma vs Tyreek Hill. The State's first witness, Crystal Espinal, testified that on December 11, 2014 she was spending time with her boyfriend Tyreek Hill at his apartment when an altercation occurred. She stated that Hill took her phone without permission, punched her in the left eye, and put her in a chokehold for over a minute, restricting her breathing and causing her to fear for her safety.
The transcript summarizes a preliminary hearing involving the State of Oklahoma vs Tyreek Hill. The State's first witness, Crystal Espinal, testified that on December 11, 2014 she was spending time with her boyfriend Tyreek Hill at his apartment when an altercation occurred. She stated that Hill took her phone without permission, punched her in the left eye, and put her in a chokehold for over a minute, restricting her breathing and causing her to fear for her safety.
This document summarizes a hearing that took place regarding a motion for leave to add a claim for punitive damages in a case between Terry Gene Bollea (Hulk Hogan) and Gawker Media. At the hearing, plaintiff's counsel argued they had provided reasonable basis and proffer to allow an amendment for punitive damages based on evidence that Gawker knew the sex tape of Bollea was recorded surreptitiously without his consent and that he objected to its publication, yet they published a play-by-play description of it anyway without consent or newsworthiness. Defense counsel argued Gawker had a good faith belief the tape was newsworthy due to Bollea's past discussions of his sex life,
The United States Court of Appeals for the Ninth Circuit granted Howard K. Stern's motion to stay the mandate in the case of Elaine Marshall v. Howard K. Stern pending a petition for certiorari to the Supreme Court. The case involved the bankruptcy and estate of Vickie Lynn Marshall (aka Anna Nicole Smith).
The Supreme Court granted certiorari for Howard K. Stern, Executor of the Estate of Vickie Lynn Marshall v. Elaine T. Marshall, Executrix of the Estate of E. Pierce Marshall, limiting the questions to be considered to Questions 1, 2, and 3 in the petition for a writ of certiorari. The case is from the Ninth Circuit Court of Appeals and involves a dispute over the estates of Vickie Lynn Marshall and E. Pierce Marshall.
The Supreme Court clerk notified the Ninth Circuit Court of Appeals clerk that a petition for a writ of certiorari was filed regarding the case of Howard K. Stern, Executor of the Estate of Vickie Lynn Marshall v. Elaine T. Marshall, Executrix of the Estate of E. Pierce Marshall. The petition was docketed as case number 10-179 by the Supreme Court on August 5, 2010.
The document is an order from a United States Bankruptcy Court case dismissing an adversary proceeding with prejudice. The order approves a stipulation between the plaintiff Virgie Arthur and defendant Bonnie Gayle Stern to dismiss the adversary proceeding, with each party bearing their own costs and fees. The court retains jurisdiction over the interpretation and enforcement of the order.
This document is a stipulation to dismiss an adversary proceeding filed in bankruptcy court. It summarizes that the plaintiff filed a complaint against the defendant seeking to prevent discharge of a debt. The case was then stayed pending resolution of a related state court lawsuit. That state court lawsuit was then dismissed. The parties now wish to dismiss the adversary proceeding with prejudice, with each party bearing their own costs and fees. The court will retain jurisdiction to enforce the terms of the dismissal.
This document provides a status report regarding a motion for contempt and sanctions filed by Howard K. Stern as executor of Vickie Lynn Marshall's estate against several defendants, including Susan M. Brown and G. Ben Thompson. It summarizes the procedural history of the motion, noting that it has been fully briefed but not yet heard by the court. The parties state they are ready to proceed with a hearing once the court resets it.
Brown reply memo support motion to dismissJRachelle
This document is the Brown Defendants' reply memorandum in support of their motion to dismiss portions of Howard Stern's amended complaint. It argues that the motion to dismiss is not precluded by the court's prior ruling allowing the amended complaint. It also argues that California procedural law, including its probate code and publicity rights statute, does not apply in this South Carolina district court case. Finally, it asserts that the publicity rights statute is not applicable to the Brown Defendants' alleged actions of providing materials to another law firm.
Stern Response to motion to dismiss 8-20-10JRachelle
This document is the Executor's response in opposition to a motion to dismiss filed by Susan M. Brown and The Law Offices of Susan M. Brown. The Executor argues that the motion to dismiss should be denied for three reasons: 1) Brown is raising the same arguments that the court already rejected in granting leave to amend the complaint, 2) the Executor has properly stated claims for both statutory and common law misappropriation of publicity rights, and 3) even if the motion to dismiss is granted, there are six other valid causes of action against Brown that would remain in the case.
This document is a memorandum in support of a motion to dismiss claims against defendants Susan Brown and The Law Offices of Susan Brown. It argues that (1) claims based on California procedural law cannot be brought in South Carolina court, (2) the relevant California statute only applies to acts occurring in California, and (3) the principle of res judicata bars re-litigating issues already decided in a prior motion for sanctions. The memorandum provides background on the representation of defendant Ben Thompson by Susan Brown and the limited allegations against Brown in the amended complaint.
This order from a district court concerns a motion to dismiss or for summary judgment that has been filed in a civil case. As one of the defendants is representing himself without an attorney, the court directs the clerk to send him materials to explain summary judgment procedure and relevant extracts from Rules 12 and 56. The defendants have 34 days to respond to the motion. The order also provides guidance on the requirements for affidavits submitted in opposition to summary judgment.
Defendants Susan M. Brown and The Law Offices of Susan M. Brown, P.C. filed a motion to dismiss the allegations directed against them in the First Amended Complaint of the lawsuit Howard K. Stern, as Executor of the Estate of Vickie Lynn Marshall, a/k/a Vickie Lynn Smith, a/k/a Vickie Lynn Hogan, a/k/a Anna Nicole Smith vs. Stancil Shelley, et al. The motion argues that the allegations in the First Amended Complaint fail to state a claim against Susan M. Brown and The Law Offices of Susan M. Brown, P.C. upon which relief can be granted. The motion was filed on
This document is a court filing with a case number 4:08-cv-02753-TLW-TER that was filed on July 22, 2010 as entry number 135. It contains 11 pages of text but no other discernible information about the contents or purpose of the filing.
Shelleys - 7-19-2010 Answer to 1st amended complaintJRachelle
This document is an answer filed by defendants Stancil Shelley and Gina Thompson Shelley in response to a first amended complaint. It denies many of the allegations against them, such as wrongfully entering a property and taking property without authorization. It admits some factual allegations, such as names and events, but denies violating any laws or conspiring against the plaintiff. Overall, the document raises various defenses in response to the claims in the first amended complaint.
This document is the transcript of a deposition of Don Clark taken on October 14, 2008 in connection with two lawsuits: Howard K. Stern v. Rita Cosby and Hachette Book Group USA, Inc. and Howard K. Stern v. John M. O'Quinn and John M. O'Quinn & Associates, PLLC. The deposition covers Clark's background, career history including 27 years with the FBI, work as an investigative strategist and jury consultant with The O'Quinn Law Firm since retiring from the FBI in 2000, and investigative work related to the Anna Nicole Smith case that began in February 2007.
DEPOSITION OF DEFENDANT / JON GREENAWALT DIRECTOR OF WEB DEVELOPMENT GAP INT...Gérard Angé
DEPOSITION OF DEFENDANT / Jon Greenawalt DIRECTOR OF WEB DEVELOPMENT GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
OTHER DEFENDANTS:
=========================
ANTHONY TEMPLER /
CURRENTLY RESIDING AT:
Zille Str. 69, 10575
BERLIN, GERMANY
LAST KNOWN USA ADDRESS: ANTHONY TEMPLER/
ATANDA WEB PRESENCE SERVICES
939 61ST STREET, SUITE #13
OAKLAND, CA 94608-1301
-------------------------------------------------------------
GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
----------------------------------------------------------
MORE INFORMATION ON THE THEFT:
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
----------------------------------------------------------
CIV214702 Sulphur Mountain/Gaggero v Redmonds Relevant Case Record 1jamesmaredmond
This document is the transcript of a deposition of Geraldine Redmond taken on August 6, 2003 in a case between Somerset Farms LLC and others. In the deposition, Geraldine Redmond discusses personal agreements made between Laurie Canty, Kim Cruiser, Jenny Martin and the owner of the property, Steve Gaggero, after Redmond gave them eviction notices on behalf of Somerset Farms LLC. Redmond questions the honesty and credibility of Canty, Cruiser and Martin due to these personal agreements.
Depostion "Live" of Houston Scrooge Attorney Harry C. Arthur Attroney at Law
Cmdr. Bluefin "Sherlock Holmes Case of: "The Talking Treasure Box" Aronold Anderson (Andy) Vickery & Andrew T. Mc.Kinney,
This document summarizes a deposition transcript involving John O'Quinn. O'Quinn was deposed regarding his representation of Vergie Arthur in legal matters related to the death and estate of Anna Nicole Smith. O'Quinn stated that he was engaged by Arthur to help her obtain the right to bury her daughter and raise her granddaughter. He met with Arthur's Florida lawyer, Steve Tunstall, in Fort Lauderdale to discuss assisting in the case in Florida. The scope of O'Quinn's engagement was limited and did not include facilitating media contacts or book deals for Arthur.
The transcript summarizes a preliminary hearing involving the State of Oklahoma vs Tyreek Hill. The State's first witness, Crystal Espinal, testified that on December 11, 2014 she was spending time with her boyfriend Tyreek Hill at his apartment when an altercation occurred. She stated that Hill took her phone without permission, punched her in the left eye, and put her in a chokehold for over a minute, restricting her breathing and causing her to fear for her safety.
The transcript summarizes a preliminary hearing involving the State of Oklahoma vs Tyreek Hill. The State's first witness, Crystal Espinal, testified that on December 11, 2014 she was spending time with her boyfriend Tyreek Hill at his apartment when an altercation occurred. She stated that Hill took her phone without permission, punched her in the left eye, and put her in a chokehold for over a minute, restricting her breathing and causing her to fear for her safety.
This document summarizes a hearing that took place regarding a motion for leave to add a claim for punitive damages in a case between Terry Gene Bollea (Hulk Hogan) and Gawker Media. At the hearing, plaintiff's counsel argued they had provided reasonable basis and proffer to allow an amendment for punitive damages based on evidence that Gawker knew the sex tape of Bollea was recorded surreptitiously without his consent and that he objected to its publication, yet they published a play-by-play description of it anyway without consent or newsworthiness. Defense counsel argued Gawker had a good faith belief the tape was newsworthy due to Bollea's past discussions of his sex life,
The United States Court of Appeals for the Ninth Circuit granted Howard K. Stern's motion to stay the mandate in the case of Elaine Marshall v. Howard K. Stern pending a petition for certiorari to the Supreme Court. The case involved the bankruptcy and estate of Vickie Lynn Marshall (aka Anna Nicole Smith).
The Supreme Court granted certiorari for Howard K. Stern, Executor of the Estate of Vickie Lynn Marshall v. Elaine T. Marshall, Executrix of the Estate of E. Pierce Marshall, limiting the questions to be considered to Questions 1, 2, and 3 in the petition for a writ of certiorari. The case is from the Ninth Circuit Court of Appeals and involves a dispute over the estates of Vickie Lynn Marshall and E. Pierce Marshall.
The Supreme Court clerk notified the Ninth Circuit Court of Appeals clerk that a petition for a writ of certiorari was filed regarding the case of Howard K. Stern, Executor of the Estate of Vickie Lynn Marshall v. Elaine T. Marshall, Executrix of the Estate of E. Pierce Marshall. The petition was docketed as case number 10-179 by the Supreme Court on August 5, 2010.
The document is an order from a United States Bankruptcy Court case dismissing an adversary proceeding with prejudice. The order approves a stipulation between the plaintiff Virgie Arthur and defendant Bonnie Gayle Stern to dismiss the adversary proceeding, with each party bearing their own costs and fees. The court retains jurisdiction over the interpretation and enforcement of the order.
This document is a stipulation to dismiss an adversary proceeding filed in bankruptcy court. It summarizes that the plaintiff filed a complaint against the defendant seeking to prevent discharge of a debt. The case was then stayed pending resolution of a related state court lawsuit. That state court lawsuit was then dismissed. The parties now wish to dismiss the adversary proceeding with prejudice, with each party bearing their own costs and fees. The court will retain jurisdiction to enforce the terms of the dismissal.
This document provides a status report regarding a motion for contempt and sanctions filed by Howard K. Stern as executor of Vickie Lynn Marshall's estate against several defendants, including Susan M. Brown and G. Ben Thompson. It summarizes the procedural history of the motion, noting that it has been fully briefed but not yet heard by the court. The parties state they are ready to proceed with a hearing once the court resets it.
Brown reply memo support motion to dismissJRachelle
This document is the Brown Defendants' reply memorandum in support of their motion to dismiss portions of Howard Stern's amended complaint. It argues that the motion to dismiss is not precluded by the court's prior ruling allowing the amended complaint. It also argues that California procedural law, including its probate code and publicity rights statute, does not apply in this South Carolina district court case. Finally, it asserts that the publicity rights statute is not applicable to the Brown Defendants' alleged actions of providing materials to another law firm.
Stern Response to motion to dismiss 8-20-10JRachelle
This document is the Executor's response in opposition to a motion to dismiss filed by Susan M. Brown and The Law Offices of Susan M. Brown. The Executor argues that the motion to dismiss should be denied for three reasons: 1) Brown is raising the same arguments that the court already rejected in granting leave to amend the complaint, 2) the Executor has properly stated claims for both statutory and common law misappropriation of publicity rights, and 3) even if the motion to dismiss is granted, there are six other valid causes of action against Brown that would remain in the case.
This document is a memorandum in support of a motion to dismiss claims against defendants Susan Brown and The Law Offices of Susan Brown. It argues that (1) claims based on California procedural law cannot be brought in South Carolina court, (2) the relevant California statute only applies to acts occurring in California, and (3) the principle of res judicata bars re-litigating issues already decided in a prior motion for sanctions. The memorandum provides background on the representation of defendant Ben Thompson by Susan Brown and the limited allegations against Brown in the amended complaint.
This order from a district court concerns a motion to dismiss or for summary judgment that has been filed in a civil case. As one of the defendants is representing himself without an attorney, the court directs the clerk to send him materials to explain summary judgment procedure and relevant extracts from Rules 12 and 56. The defendants have 34 days to respond to the motion. The order also provides guidance on the requirements for affidavits submitted in opposition to summary judgment.
Defendants Susan M. Brown and The Law Offices of Susan M. Brown, P.C. filed a motion to dismiss the allegations directed against them in the First Amended Complaint of the lawsuit Howard K. Stern, as Executor of the Estate of Vickie Lynn Marshall, a/k/a Vickie Lynn Smith, a/k/a Vickie Lynn Hogan, a/k/a Anna Nicole Smith vs. Stancil Shelley, et al. The motion argues that the allegations in the First Amended Complaint fail to state a claim against Susan M. Brown and The Law Offices of Susan M. Brown, P.C. upon which relief can be granted. The motion was filed on
This document is a court filing with a case number 4:08-cv-02753-TLW-TER that was filed on July 22, 2010 as entry number 135. It contains 11 pages of text but no other discernible information about the contents or purpose of the filing.
Shelleys - 7-19-2010 Answer to 1st amended complaintJRachelle
This document is an answer filed by defendants Stancil Shelley and Gina Thompson Shelley in response to a first amended complaint. It denies many of the allegations against them, such as wrongfully entering a property and taking property without authorization. It admits some factual allegations, such as names and events, but denies violating any laws or conspiring against the plaintiff. Overall, the document raises various defenses in response to the claims in the first amended complaint.
(1) This document is an order continuing the status conference in the bankruptcy case of Bonnie Gayle Stern.
(2) The previous status conference was set for July 27, 2010. This order continues the status conference to October 26, 2010 at 10:00 am due to the ongoing related litigation in state court.
(3) No appearance is necessary at the July 27 conference, as it has been continued by this order until October 26, 2010 to allow the state court litigation regarding liability and damages against the debtor to continue.
S Carolina - first amended complaint 7-1-2010JRachelle
This document appears to be a court filing that spans 59 pages. It includes header information that indicates it was filed on July 1, 2010 as entry number 122 in case 4:08-cv-02753-TLW in the court. However, as the document only includes page numbers and headers, its specific contents or purpose cannot be determined from the information provided.
This document is an order from a bankruptcy court case staying an adversary proceeding pending resolution of a related state court case. The order schedules a continued status conference in the bankruptcy court for October 6, 2009 and every 90 days thereafter until judgments on liability and damages are issued in the state court case, or until further court order. The parties must submit a joint status report 14 days before each conference.
1) The parties submitted a joint status report in accordance with local bankruptcy rules regarding an adversary proceeding between Virgie Arthur and Bonnie Gayle Stern.
2) Discovery is ongoing, with the plaintiff anticipating completion in 8-10 months, while the defendant believes discovery could be completed sooner in 3 months if permitted.
3) The plaintiff estimates needing 10-14 days to present their case at trial plus rebuttal, while the defendant anticipates needing 2 days, with the plaintiff intending to call approximately 12 witnesses and the defendant 3-4 witnesses.
Order Granting Addition Of Susan Brown As DefendantJRachelle
This order grants the plaintiff's motion to amend his complaint to add new parties and factual allegations learned during discovery. The plaintiff seeks to add three individuals ("Doe defendants") identified during depositions as being involved in removing property from the estate. The plaintiff also seeks to add an attorney and her law firm who received estate property from one of the defendants. The only opposition comes from the attorney and law firm, but the court finds that allowing the amendments would not be prejudicial or futile. Therefore, the plaintiff's motion to amend is granted.
This document provides a summary of a court opinion from the United States Court of Appeals for the Ninth Circuit regarding a longstanding dispute between the estates of Vickie Lynn Marshall and E. Pierce Marshall. The court is revisiting the case after the Supreme Court determined the Ninth Circuit had construed the probate exception too broadly. The case involves a tortious interference claim by Vickie Lynn Marshall against Pierce Marshall regarding a substantial gift from Vickie Lynn's late husband J. Howard Marshall II. The summary is in 3 sentences:
The Ninth Circuit concludes that the findings of an earlier Texas probate court proceeding regarding J. Howard Marshall II's estate plan and intent should be given preclusive effect. The court also finds that the
This document provides a summary of a court case regarding a tortious interference claim by Vickie Lynn Marshall against Pierce Marshall. The summary discusses the background of the case, including the relationships and estates of Vickie Lynn Marshall, J. Howard Marshall II, and Pierce Marshall. It also notes that the tortious interference claim was adjudicated in bankruptcy court, while a probate court in Texas was simultaneously administering J. Howard Marshall II's estate. The court must determine which ruling should be given preclusive effect.
Breast cancer: Post menopausal endocrine therapyDr. Sumit KUMAR
Breast cancer in postmenopausal women with hormone receptor-positive (HR+) status is a common and complex condition that necessitates a multifaceted approach to management. HR+ breast cancer means that the cancer cells grow in response to hormones such as estrogen and progesterone. This subtype is prevalent among postmenopausal women and typically exhibits a more indolent course compared to other forms of breast cancer, which allows for a variety of treatment options.
Diagnosis and Staging
The diagnosis of HR+ breast cancer begins with clinical evaluation, imaging, and biopsy. Imaging modalities such as mammography, ultrasound, and MRI help in assessing the extent of the disease. Histopathological examination and immunohistochemical staining of the biopsy sample confirm the diagnosis and hormone receptor status by identifying the presence of estrogen receptors (ER) and progesterone receptors (PR) on the tumor cells.
Staging involves determining the size of the tumor (T), the involvement of regional lymph nodes (N), and the presence of distant metastasis (M). The American Joint Committee on Cancer (AJCC) staging system is commonly used. Accurate staging is critical as it guides treatment decisions.
Treatment Options
Endocrine Therapy
Endocrine therapy is the cornerstone of treatment for HR+ breast cancer in postmenopausal women. The primary goal is to reduce the levels of estrogen or block its effects on cancer cells. Commonly used agents include:
Selective Estrogen Receptor Modulators (SERMs): Tamoxifen is a SERM that binds to estrogen receptors, blocking estrogen from stimulating breast cancer cells. It is effective but may have side effects such as increased risk of endometrial cancer and thromboembolic events.
Aromatase Inhibitors (AIs): These drugs, including anastrozole, letrozole, and exemestane, lower estrogen levels by inhibiting the aromatase enzyme, which converts androgens to estrogen in peripheral tissues. AIs are generally preferred in postmenopausal women due to their efficacy and safety profile compared to tamoxifen.
Selective Estrogen Receptor Downregulators (SERDs): Fulvestrant is a SERD that degrades estrogen receptors and is used in cases where resistance to other endocrine therapies develops.
Combination Therapies
Combining endocrine therapy with other treatments enhances efficacy. Examples include:
Endocrine Therapy with CDK4/6 Inhibitors: Palbociclib, ribociclib, and abemaciclib are CDK4/6 inhibitors that, when combined with endocrine therapy, significantly improve progression-free survival in advanced HR+ breast cancer.
Endocrine Therapy with mTOR Inhibitors: Everolimus, an mTOR inhibitor, can be added to endocrine therapy for patients who have developed resistance to aromatase inhibitors.
Chemotherapy
Chemotherapy is generally reserved for patients with high-risk features, such as large tumor size, high-grade histology, or extensive lymph node involvement. Regimens often include anthracyclines and taxanes.
Travel vaccination in Manchester offers comprehensive immunization services for individuals planning international trips. Expert healthcare providers administer vaccines tailored to your destination, ensuring you stay protected against various diseases. Conveniently located clinics and flexible appointment options make it easy to get the necessary shots before your journey. Stay healthy and travel with confidence by getting vaccinated in Manchester. Visit us: www.nxhealthcare.co.uk
The Children are very vulnerable to get affected with respiratory disease.
In our country, the respiratory Disease conditions are consider as major cause for mortality and Morbidity in Child.
Giloy in Ayurveda - Classical Categorization and SynonymsPlanet Ayurveda
Giloy, also known as Guduchi or Amrita in classical Ayurvedic texts, is a revered herb renowned for its myriad health benefits. It is categorized as a Rasayana, meaning it has rejuvenating properties that enhance vitality and longevity. Giloy is celebrated for its ability to boost the immune system, detoxify the body, and promote overall wellness. Its anti-inflammatory, antipyretic, and antioxidant properties make it a staple in managing conditions like fever, diabetes, and stress. The versatility and efficacy of Giloy in supporting health naturally highlight its importance in Ayurveda. At Planet Ayurveda, we provide a comprehensive range of health services and 100% herbal supplements that harness the power of natural ingredients like Giloy. Our products are globally available and affordable, ensuring that everyone can benefit from the ancient wisdom of Ayurveda. If you or your loved ones are dealing with health issues, contact Planet Ayurveda at 01725214040 to book an online video consultation with our professional doctors. Let us help you achieve optimal health and wellness naturally.
How to Control Your Asthma Tips by gokuldas hospital.Gokuldas Hospital
Respiratory issues like asthma are the most sensitive issue that is affecting millions worldwide. It hampers the daily activities leaving the body tired and breathless.
The key to a good grip on asthma is proper knowledge and management strategies. Understanding the patient-specific symptoms and carving out an effective treatment likewise is the best way to keep asthma under control.
“Psychiatry and the Humanities”: An Innovative Course at the University of Mo...Université de Montréal
“Psychiatry and the Humanities”: An Innovative Course at the University of Montreal Expanding the medical model to embrace the humanities. Link: https://www.psychiatrictimes.com/view/-psychiatry-and-the-humanities-an-innovative-course-at-the-university-of-montreal
Travel Clinic Cardiff: Health Advice for International TravelersNX Healthcare
Travel Clinic Cardiff offers comprehensive travel health services, including vaccinations, travel advice, and preventive care for international travelers. Our expert team ensures you are well-prepared and protected for your journey, providing personalized consultations tailored to your destination. Conveniently located in Cardiff, we help you travel with confidence and peace of mind. Visit us: www.nxhealthcare.co.uk
Know the difference between Endodontics and Orthodontics.Gokuldas Hospital
Your smile is beautiful.
Let’s be honest. Maintaining that beautiful smile is not an easy task. It is more than brushing and flossing. Sometimes, you might encounter dental issues that need special dental care. These issues can range anywhere from misalignment of the jaw to pain in the root of teeth.
2. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 84 of 99
Confidential
Page 1
1 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2
HOWARD K. STERN, §
3 §
Plaintiff, §
4 §
VS. § Civ. Action No.
5 § 07-CV-8536 (DC)
RITA COSBY and HACHETTE §
6 BOOK GROUP USA, INC., §
d/b/a Grand Central §
7 Publishing, and JOHN OR §
JANE DOE §
8 §
Defendants. §
9
10
********************************************************
11 CONFIDENTIAL ORAL AND VIDEOTAPED DEPOSITION OF
WILMA VICEDOMINE
12 OCTOBER 13, 2008
********************************************************
13
14 ORAL DEPOSITION OF WILMA VICEDOMINE, produced as a
15 witness at the instance of the DEFENDANT, and duly
16 sworn, was taken in the above-styled and numbered
17 cause on the 13th of October, 2008, from 9:20 a.m. to
18 7:15 p.m., before Linda A. Rayburn, CSR, RPR, CLR in and
19 for the State of Texas, reported by machine shorthand,
20 at the offices of The O'Quinn Law Firm, 2300 Lyric
21 Centre Building, 440 Louisiana, Houston, Texas, pursuant
22 to the Federal Rules of Civil Procedure and any
23 provisions stated on the record or attached hereto.
24
25
TSG Reporting - Worldwide 877-702-9580
3. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 85 of 99
Confidential Confidential
Page 34 Page 35
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 on phone that they had a huge amount of evidence. And, 2 no, she liked to watch a particular movie of Mr. Stern
3 you know, so she was going to show us some of this 3 and Mr. Birkhead doing that thing.
4 evidence. And when we got there, there was just 4 Q And did you say anything or ask any further
5 nothing. 5 question after that comment?
6 Q And so after -- after that, after you said, 6 A I asked, "What do you mean 'that thing'?"
7 "What information do they have," then what occurred, if 7 You know, so they started giggling even
8 anything? 8 more. And then they said, "You know, two men doing that
9 A Liz Thompson said that I could ask a pretty 9 thing."
10 generic question. Which I did. I asked them, "Well, if 10 And I'm like, "You mean like gay people?"
11 Anna wasn't doped up, you know, what did she do?" 11 And they said, "Yeah, that thing."
12 You know, and they said that she liked to 12 And I'm like, "Oh, let it go. I've had
13 lie in bed and watch TV, you know, and watch movies." 13 enough."
14 And I said, "Well, what did she like to 14 Q When you say "they," were both of the nannies
15 watch?" 15 speaking at the same time relaying this information or
16 And they said -- they mentioned some show, 16 was one of them speaking and the other confirming? What
17 I don't know what it was. They mentioned that she liked 17 was the situation?
18 to watch movies. 18 MR. WOOD: Objection to the form of the --
19 I asked them what kind of movies, whether 19 A One --
20 it's home movies or Blockbuster movies. 20 MR. WOOD: Excuse me. Objection to the
21 They asked me -- well, they didn't know 21 form of the question as compound, multiple.
22 what Blockbuster movie thing was, so I had to explain 22 A Both of them confirmed that there was this
23 it's when you go to the store and you pay for the movie 23 video that they watched. Both of them was constantly
24 versus a home movie is something that you made yourself. 24 saying, "Yes." You know, one will say something and
25 They started giggling and telling me that, 25 then the other one will back it up and that way around.
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 36 Page 37
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 That's how it went. 2 obviously only there about money, nothing else. She
3 Q (BY MS. MCNAMARA) Did you learn from them any 3 couldn't care less about the nannies. That was my
4 more details about what was on the video? 4 impression.
5 A Heck no. I don't want anything to know about 5 Q And what was your impression of the nannies?
6 the rest of that. 6 A I found them to be really credible.
7 Q Did you learn any information as to when Anna 7 Q Did you find their statements concerning the
8 Nicole was watching this video? 8 videotape to be credible?
9 A She happened to do it several times, according 9 MR. WOOD: Objection to the form of --
10 to them. 10 A I did at the time.
11 Q Now, if I understand your testimony, I don't -- 11 MR. WOOD: Excuse me, Ms. Vicedomine.
12 did you -- what was your impression of Elizabeth 12 You're going to have to let me object. I know your
13 Thompson? 13 anxious to get these answers out. Y'all have talked
14 A I absolutely did not care for her. 14 about it before.
15 Q And why did you not care for her? 15 MR. MCFALL: When he starts to object,
16 A She was really interestingly pleasant on the 16 you've got to let him make his objection.
17 phone with me when we originally started talking, you 17 THE WITNESS: Sure.
18 know, very, very kind and sweet and want us to come 18 MR. WOOD: Let me object to the form of
19 there, you know, because they have all of this 19 the question as leading and suggestive of an answer.
20 information. 20 Q (BY MS. MCNAMRA) Do you recall the question?
21 The minute she walked in the conference 21 I think the question was did you find their statements
22 room, it's like she was just cold and ugly, you know, 22 concerning the videotape to be credible?
23 towards me. It was clear she couldn't care less if I 23 MR. WOOD: Objection to the form of the
24 was -- I might as well not even been there. She just 24 question as leading and suggestive of an answer.
25 focused on Mr. Don Clark, you know, and she was 25 Q (BY MS. MCNAMARA) You can answer it.
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
4. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 86 of 99
Confidential Confidential
Page 38 Page 39
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 A Yes. 2 said -- the lawyer apparently told them that she had to
3 Q Did you find them to be truthful? 3 do that. So they just took it. They lived clear the
4 A Yes. 4 other side of the island. And that was it.
5 MR. WOOD: Same objection, leading and 5 Q And this was in your meeting in the Bahamas
6 suggestive of an answer. 6 they explained about the payment on the affidavits?
7 Q (BY MS. MCNAMRA) Did you at any point in time 7 A Yes.
8 become aware that the nannies had signed affidavits? 8 MR. WOOD: Objection to the form of the
9 A Yes. 9 question as leading.
10 Q Did -- did -- do you know whether they signed 10 Q (BY MS. MCNAMRA) Did they -- did you have any
11 more than one affidavit? 11 dialog with them concerning the content of those
12 A Yes. 12 affidavits and whether they were changed?
13 Q Tell me what you know about their affidavits. 13 A Not really.
14 A There were original set of affidavits, it was 14 Q Did you question them about any changes in the
15 pretty well publicized, because they were supposedly 15 affidavits?
16 paid for those affidavits. They made claims that those 16 A No, not really.
17 affidavits had been changed from what they originally 17 Q Were you aware that these affidavits were
18 said. They were pretty upset about that. 18 subsequently changed by the nannies?
19 That was one of the questions I asked them 19 MR. WOOD: Objection to the --
20 in the meeting, to explain to me this whole controversy 20 A Yes.
21 about a paid affidavit. That's when I discovered they 21 MR. WOOD: -- form of the question as
22 were just paid $50 each, you know, for their time. 22 leading and suggestive of an answer.
23 They explained that Tracy Ferguson, the 23 Q (BY MS. MCNAMRA) What do you know about that?
24 lawyer that did the affidavit, gave them the hundred 24 A They explained that they went back and -- to
25 dollars and they were shocked what it was for. And they 25 this lawyer and they had redone the affidavits.
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 40 Page 41
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 Q And do you know what information was redone or 2 Q (BY MS. MCNAMRA) Were you also aware that the
3 changed? 3 nannies had given certain interviews to a place called
4 A I believe there was some issue surrounding 4 Controversy TV?
5 Shane Gibson that was in there, you know. I know that 5 A Yes.
6 there was significantly more information in the second 6 Q Do you know Controversy TV?
7 affidavit than what was in the original. 7 A I do now.
8 Q Okay. And what content or what do you recall 8 Q Did you watch any of those interviews given by
9 the content from the second affidavit that the nannies 9 the nannies on Controversy TV?
10 gave? 10 A I did.
11 A They talked about the drugs in the house, they 11 Q What do you recall about those interviews?
12 talked about, you know, underfeeding the baby. It's 12 A They talked about the Shane Gibson situation,
13 just a lot -- a lot of information. 13 about him coming to the house, about their immigration
14 Q Do you recall anything else? 14 status in the Bahamas. They talked about the baby, you
15 A They talked about the checks that was signed by 15 know, taking care of the baby. They talk about the drug
16 Mr. Stern and Dr. Erosovich. They talked -- you know 16 use, that Anna was constantly being fed drugs. They
17 what, right this second it's -- 17 talked the fact that she slept days on end. They talked
18 Q I'm just asking whatever you recall, that's 18 about Anna screaming at Mr. Stern that he needed to get
19 all. 19 out of there.
20 MR. WOOD: Let her finish, if you don't 20 I don't know, it's long video. It's three
21 mind, Ms. McNamara. 21 long sessions.
22 MS. MCNAMARA: No, absolutely. 22 Q When you say that they talked about Shane
23 MR. WOOD: What were you going to say, 23 Gibson, what do you recall that they said about Shane
24 Ms. Vicedomine, right this second what? 24 Gibson?
25 A It's just I can't think of all of it. 25 A That he came to the house quite often and he
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
5. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 87 of 99
Confidential Confidential
Page 54 Page 55
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 A Yes. 2 A The fact that she kept calling back, going back
3 Q Did you understand she was investigating the 3 over the same things that I told her, so I thought that
4 Anna Nicole Smith story for some journalistic purpose? 4 she's definitely doing -- whatever she's doing, you
5 A Something. I didn't know what. 5 know, she's doing it right.
6 Q Did you know she was writing a book? 6 Q Did you -- did she ever call you back and try
7 A Absolutely not. 7 to verify quotes or information, specific information
8 Q What was your impression of Ms. Cosby as a 8 you had given to her?
9 journalist, from dealing with her? 9 A Yes.
10 A I liked her. She was pretty thorough. She 10 MR. WOOD: Objection to the form of the
11 constantly asked same questions over and over again. 11 question as leading.
12 You know, she called back quite frequently to reconfirm 12 Q (BY MS. MCNAMRA) Did she do that on --
13 things. I thought she was pretty good. 13 MR. WOOD: Y'all need to slow down just a
14 Q Did you have a sense that she was trying to get 14 little bit on this dog-and-pony here. I need to get my
15 as much detail as she could about the information she 15 objections on the record, if you don't mind.
16 was asking you? 16 Q (BY MS. MCNAMRA) Did she do that on more than
17 A Yes. 17 one occasion?
18 MR. WOOD: Objection to the form -- 18 A Yes.
19 Ms. Vicedomine, just give me a second. Objection to the 19 Q Now, when "Blonde Ambition" was published, did
20 form of the question as leading. 20 you read the book?
21 A Yes. 21 A Yes.
22 Q (BY MS. MCNAMRA) Did you have a sense as to 22 Q Did you understand in a number of places there
23 whether she was trying to be accurate? 23 is information attributed to either investigators or
24 A Yes. 24 case investigators or investigators to an interested
25 Q What was your sense? 25 party, did you understand those attributions to be
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 56 Page 57
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 referring to you or Mr. Clark? 2 A Yes.
3 A Yes. 3 Q And what was that -- tell me what you recall
4 MR. WOOD: Objection to the form of the 4 about that understanding or communication with
5 question. And also, it fails to identify what 5 Ms. Cosby.
6 statements you're referring to. I think the testimony 6 A To the -- I recall she brought up the issue if,
7 establishes that "other investigators" were referred to 7 you know, it ever had to be validated or verified, would
8 as investigators in the book also. 8 I back it up. And I said, "Absolutely."
9 Q (BY MS. MCNAMRA) Did you understand -- did you 9 Q I'd like to direct your attention to -- if I
10 have any understanding with Ms. Cosby as to whether she 10 can have a copy of "Blonde Ambition" given to you. And
11 could identify you as a source at the time you were 11 I'm going to direct your attention to certain pages of
12 speaking with her? 12 the book. And first I'd like you to look at Page 2 of
13 A Say that again. 13 the book.
14 Q Did you have any understanding with Ms. Cosby 14 MS. MCNAMARA: And I assume, Lin, you have
15 as to whether she could identify you as a source of 15 a copy of the book that you can look at?
16 information when you were speaking with her? 16 MR. WOOD: Let me take a moment to get it,
17 A No. 17 if you don't mind.
18 Q You didn't have any understanding -- 18 MR. MCFALL: May I look at this one?
19 MR. WOOD: She's answered -- 19 MS. MCNAMRA: Yes.
20 A No. 20 MR. WOOD: All right. I have it. Thank
21 MR. WOOD: -- the question. 21 you.
22 Q (BY MS. MCNAMRA) Did -- if -- did you have any 22 Q (BY MS. MCNAMRA) Okay. I'm first going to
23 understanding with her that if a lawsuit occurred as a 23 direct your attention to Page 2 of the book under the
24 result of the information that you gave her, as to 24 heading, "Three days earlier, Monday, February 5th."
25 whether you would stand behind your information? 25 I'd like you to read the first two sentences of that
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
6. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 88 of 99
Confidential Confidential
Page 110 Page 111
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 information to Ms. Cosby, did you believe it to be 2 five-minute break. I may be almost done.
3 honest and accurate? 3 THE VIDEOGRAPHER: We're going off the
4 A Yes. 4 record. The time is 11:27.
5 Q Now, on Page 199, in the second full paragraph, 5 (A recess was taken.)
6 the first sentence reads, "Mark Speer told me he loaned 6 THE VIDEOGRAPHER: We're back on the
7 Larry his cell phone during this time period, resulting 7 record. The time is 11:53.
8 in two phone bills totaling $3,100, which normally 8 MS. MCNAMRA: I can state for the record
9 averaged $150 a month in usage." 9 that I have completed my examination of Ms. Vicedomine
10 Did you receive such information from 10 for now and reserve the right to ask some questions
11 Mr. Speer in the course of your conversations with him? 11 later, following Mr. Woods' examination, if necessary.
12 A Yes. 12 MR. WOOD: All right. Good. Anything
13 Q And at the time you received that information, 13 else?
14 did you believe it to be accurate? 14 EXAMINATION
15 A Yes. 15 BY MR. WOOD:
16 Q And did you communicate that information to 16 Q Ms. Vicedomine, you understand I represent
17 Ms. Cosby in the course of your conversations with her? 17 Mr. Stern?
18 A I might have. 18 A Yes.
19 Q You don't specifically recall communicating 19 Q You indicated that you were employed by The
20 that? 20 O'Quinn Law Firm in early February of 2007; is that
21 A No. 21 right?
22 Q But if you had communicated it, you would have 22 A No.
23 believed it to be accurate; is that right? 23 MS. MCNAMRA: Objection, mischaracterizes
24 A Yes. 24 her testimony.
25 MS. MCNAMRA: Why don't we take a 25 A No.
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 112 Page 113
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 Q (BY MR. WOOD) When did you become employed by 2 Q What date?
3 the law firm of John -- 3 A I guess around the 16th, around there.
4 A I'm not employed by the law firm. 4 Q Well, what is your best recollection as to the
5 Q Have you ever been employed by the law firm? 5 date when you first undertook your own investigation
6 A No. 6 efforts in conjunction with Mr. Clark?
7 Q So you've never been an employee of the John 7 A I'll say the 16th.
8 O'Quinn law firm? 8 Q February 16th of 2007?
9 A No. 9 A Yes.
10 Q Have you ever been an employee of Don Clark? 10 Q And you were at all times acting independent of
11 A No. 11 Mr. Clark and The O'Quinn Law Firm --
12 Q So all of your actions with respect to the 12 A Yes.
13 investigation into the matters that you discussed with 13 Q -- is that true?
14 Ms. McNamara have been undertakings on your own? 14 A Yes.
15 A Yes. 15 Q And that would have been true from February
16 Q When did you first start working with John 16 16th of 2007, through today --
17 Clark? 17 A True.
18 A In -- on this case? 18 Q -- right?
19 Q Yes. 19 A Yes.
20 A February '07. 20 Q You have never been an agent or employee of The
21 Q Was that early February of '07? 21 O'Quinn Law Firm, true?
22 A No. 22 A No, I have not.
23 Q When exactly in February did you begin to work 23 Q And while -- I assume that your involvement was
24 with Mr. Clark? 24 such that it was what you wanted to do and not what you
25 A In the custody hearing in Florida. 25 were told to do; is that right?
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
7. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 89 of 99
Confidential Confidential
Page 134 Page 135
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 A Yes. 2 think four or five other investigations with Mr. Clark?
3 Q Who did you understand Paul Porter to be? 3 A Yes.
4 A Agent for Moe. 4 Q For the O'Quinn firm or in the same scenario as
5 Q Did you do any background research on 5 what you did with the Anna Nicole Smith case, where you
6 Mr. Porter? 6 were just involved on your own helping him investigate?
7 A A little bit. 7 A The same scenario.
8 Q When? 8 Q Okay. Not paid?
9 A Months later. 9 A No.
10 Q "Months later" meaning when? 10 Q Not an employee?
11 A In June -- 11 A No.
12 Q June of two thousand -- 12 Q And not under their control?
13 A -- July '07. 13 A No.
14 Q '07? 14 Q Not an agent?
15 A Yes. 15 A No.
16 Q Okay. And this -- now, this is when you went 16 Q Now, I guess we could describe you -- and I
17 down to Florida, then, on the second trip and you had 17 don't mean this in anything other than trying to be
18 this interview that you describe to Ms. McNamara where 18 accurate. Would you describe yourself as an amateur
19 you and Don Clark were there, Moe and Tas were there. 19 investigator?
20 After about an hour Moe left, Don went out and spoke 20 A Yes.
21 with him, you stayed in for another couple hours talking 21 Q And have you tried to develop, Ms. Vicedomine,
22 to Tas -- 22 a methodology for your investigative work?
23 A Yes. 23 A Yes.
24 Q -- is that right? 24 Q And does that investigative methodology include
25 And you said you had been involved in I 25 that when you interview witnesses such as Moe and Tas,
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 136 Page 137
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 you take notes? 2 A I don't know.
3 A Yes. 3 Q Well, you say "months ago." I need to try to
4 Q And I would take it that you take meticulous 4 get your best recollection of when you gave Mr. Clark
5 notes? 5 your boxes.
6 A I'd like to think so. I don't feel like I'm 6 A Well, I give Don Clark my research or my notes
7 always that great. 7 or everything that I have, I just give it to him.
8 Q But when -- 8 Sometimes I keep copies of my stuff and I had it in
9 THE COURT REPORTER: I don't feel like... 9 boxes. And I just gave them all, because I didn't know
10 THE WITNESS: ... I'm always that great. 10 what they had and what they didn't have. So, go.
11 Q (BY MR. WOOD) But you clearly took notes from 11 Q Well, if you gave them your research and your
12 the interview conducted in April of 2007 with Moe and 12 notes, did you keep copies for yourself?
13 Tas? 13 A Of certain things, I did, yes.
14 A I did. 14 Q Did you keep a copy of the Moe and Tas notes?
15 Q Where are those notes? 15 A Yes.
16 A Mr. -- Don -- it's here somewhere. 16 Q And where are those?
17 Q Well, they're your notes, aren't they? 17 A At my house.
18 A Uh-huh. 18 Q Here in Houston?
19 Q Is your answer yes? 19 A Yes.
20 A Yes. 20 Q What is your residence address?
21 Q And you say "they're here somewhere"? A
22 A I gave them to Don.
23 Q When? Q And how many pages of notes do you have with
24 A I gave them all my boxes of stuff months ago. 24 respect to the April interview with Moe and Tas?
25 Q When? 25 A Several. I don't know exactly the number.
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
8. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 90 of 99
Confidential Confidential
Page 142 Page 143
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 just give it to him as it happens. 2 A I don't recall it.
3 Q How many murder investigations have you ever 3 Q Did you pay for your hotel room?
4 been involved in as an amateur investigator? 4 A No.
5 A This would be my first. 5 Q Mr. Clark paid for it?
6 Q This being the Anna Nicole Smith case? 6 A Yes.
7 A Yes. 7 Q So you didn't have to get reimbursed for that
8 Q And you are not a licensed private investigator 8 room or for any of your meals?
9 or a licensed investigator under the laws of the state 9 A Correct.
10 of Florida, were you? 10 Q Correct. All right. So tell me now, you said
11 A No. 11 that you also traveled to, was it the Bahamas?
12 Q And did you represent yourself when you 12 A Yes.
13 traveled to the Bahamas as going there on business as an 13 Q And South Carolina?
14 investigator? 14 A Yes.
15 A No. 15 Q Anyplace else?
16 Q Were you in any way licensed or authorized to 16 A No.
17 conduct any type of investigation -- private 17 Q All right. When did you first travel to South
18 investigation in the Bahamas? 18 Carolina?
19 A No. 19 A I believe it was in October '07.
20 Q On the second trip to Florida, where did you 20 Q October of '07?
21 go, Ft. Lauderdale? 21 A Uh-huh.
22 A Yes. 22 Q And who did you travel with to South Carolina?
23 Q And where did you stay? 23 A Don Clark and Tom Pirtle.
24 A The same hotel. 24 Q And what was the purpose of going to South
25 Q Do you know the name of the hotel? 25 Carolina in October of '07?
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 144 Page 145
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 A To talk with Ford Shelley and G. Ben Thompson. 2 Q Susan Brown from Atlanta?
3 Q Did you interview anyone at that time in South 3 A Yes.
4 Carolina other than Ford Shelley and Ben Thompson? 4 Q Or Peachtree City?
5 A No. 5 A Yes.
6 Q How many days were you in South Carolina? 6 Q Tell me what y'all discussed in that meeting.
7 A We flew in that day and we flew out that day. 7 MR. KLEIN: Excuse me. I'm going to --
8 Q Is that on Mr. O'Quinn's plane? 8 Counsel, I'm going to insert a privilege on behalf of
9 A Yes. 9 the firm.
10 Q So you didn't have any expenses to be 10 Q (BY MR. WOOD) I'd like to know what y'all
11 reimbursed for that trip, true? 11 discussed in that meeting.
12 A No, I did not. 12 A I can't tell you.
13 Q And how -- did you say -- do you recall when in 13 MR. WOOD: Well, what privilege can you
14 October? 14 assert? She doesn't work for your law firm. She's a
15 A I don't recall at all, no. 15 third party. So if you had a privilege, it's waived.
16 Q If today is October the 13th, you think it was 16 MR. KLEIN: We never maintained that she
17 the middle of the month? About a year ago? 17 worked for the law firm. We maintain that she did
18 A Yeah, I don't recall at all what time it was. 18 investigation with the firm. She's clearly an
19 It was a very quick arranged trip, so. 19 independent contractor, I don't care that she doesn't
20 Q How long did y'all meet there? 20 work for the firm. An we've already had a ruling on
21 A The entire day. 21 this --
22 Q Who all was present, other than -- if anyone, 22 MR. WOOD: No, you haven't either, because
23 other than Ben Thompson, Ford Shelley, Tom Pirtle, Don 23 the ruling -- I would -- I would challenge that your
24 Clark and you? 24 ruling was based on what I believe now to be a
25 A And Susan Brown, their lawyer. 25 misrepresentation to the Court about her status.
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
9. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 91 of 99
Confidential Confidential
Page 206 Page 207
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 conversation? 2 about the nannies and Anna Nicole allegedly watching the
3 A No. 3 sex tape?
4 Q And then I believe you told Ms. McNamara that 4 A No.
5 after that initial conversation, that prior to the 5 Q Why not?
6 publication of the book, you had between 10 and 20 6 A I don't know, I didn't think it was important.
7 telephone conversations with Ms. Cosby? 7 Q Why did you not think it was important?
8 A After? 8 A I didn't think that I had any information there
9 Q Yes, ma'am. 9 to talk about.
10 MS. MCNAMRA: After what? 10 Q What do you mean?
11 MR. WOOD: After the initial telephone 11 A I said, they didn't have any information. I
12 conversation. 12 came out empty-handed from the Bahamas.
13 MS. MCNAMRA: And before the publication 13 Q Well, when did you learn about the sex tape?
14 of the book? 14 A The original meeting with the nannies.
15 MR. WOOD: And before the publication of 15 Q But you didn't feel -- but that's the one you
16 the book. 16 felt like you came away empty-handed?
17 A Yeah. Okay. Yeah. 17 A Right.
18 Q (BY MR. WOOD) Is that right? 18 Q You didn't have an opportunity to get the
19 A Yes. 19 information from the nannies about the sex tape?
20 Q And would you call her or would she call you? 20 A I did.
21 A Both -- I'll call her and she'll call me. 21 Q You just didn't feel like it was adequate
22 Q What was the -- after you had the first call 22 enough, that you still came away feeling like you were
23 with her, when did the next call take place? 23 empty-handed?
24 A I don't know. Few days later, I guess. 24 A It wasn't important. Who cares about that. It
25 Q Was it in the first call that you told her 25 wasn't important to me.
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 208 Page 209
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 Q So you didn't mention it to Ms. Cosby in that 2 Q Did Donna Kauffman tell you when she first told
3 first three- to five-hour conversation? 3 Rita Cosby about the nannies and the sex tape story?
4 A No. 4 A No.
5 Q How many conversations into y'all's discussions 5 Q So if I understand it correctly, when you told
6 do you think it was when you decided to tell her about 6 Rita in July, did she ask you about it or did you
7 it? 7 volunteer it at that time?
8 A I think it's closer to the end of our 8 A I think she asked me about it.
9 conversations that it came up. 9 Q And was it your understanding from Rita that
10 Q When did you have the last conversation with 10 she had heard this story from Donna Kauffman and was
11 her before the publication of the book? 11 asking you if you knew anything about it?
12 A I think it was in July. 12 A I don't think she ever mentioned Donna Kauffman
13 Q So you believe you told her about the nannies 13 at all. I think she just said, you know, that I hear
14 in July of 2007? 14 something like this.
15 A Right. 15 Q Now, are you telling me -- Don Clark had never
16 Q Was it news to her? Had she heard it before? 16 discussed it with her, had he?
17 A She heard it before. 17 A I don't know.
18 Q From whom? 18 Q Did you ever ask him?
19 A I believe it came from Donna Kauffman. 19 A No.
20 Q Donna Kauffman? 20 Q At any time as we sit here today, did you ever
21 A Uh-huh. 21 ask Mr. Clark if he had any discussions with Rita about
22 Q Did she tell you that? 22 the nannies before the publication of the book?
23 A Donna Kauffman told me that. 23 A No.
24 Q When did Donna Kauffman tell you that? 24 Q Did you take notes about your meetings -- this
25 A After the book came out. 25 meeting with the nannies where you say you came away
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
10. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 92 of 99
Confidential Confidential
Page 214 Page 215
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 A Yes. 2 house or whatever the case --
3 Q And then it was after that conversation that 3 Q Or whether it even existed?
4 this information about a videotape was in some fashion 4 A No, I believed the nannies.
5 disclosed? 5 Q Had you ever spoken to the nannies before that
6 A Yes. 6 day?
7 Q Which you took as insignificant? 7 A No.
8 A Correct. 8 Q And this "videotape" discussion took about how
9 Q Didn't follow up on any details? 9 long? Sounds like something less than 15 seconds.
10 A No. 10 A It was only few minutes.
11 Q Didn't take any efforts in your own to try to 11 Q Few minutes or 15, 30 seconds?
12 verify whether such a tape existed? 12 A I don't know. Between a few seconds and a
13 A It was irrelevant. 13 minute or so.
14 Q Did Ms. Cosby ask you if you had ever seen the 14 Q Okay.
15 videotape? 15 A It wasn't long.
16 A I believe she did. 16 Q And that was part of -- I think you said you
17 Q Did you tell her that you had not? 17 stayed there about two more hours with the nannies.
18 A I said, "Hell no," quite frankly. 18 A No. The first hour we sat down and did the
19 Q Did you tell her you didn't know whether the 19 introductions and started talking about the money issue.
20 tape existed or not? 20 Then we broke -- we broke for the lunch break. And then
21 A I -- that -- I did say that. 21 after that for another hour or so, they kept talking
22 Q You told her you didn't know whether there was 22 about the money. And then after that, we just discussed
23 an actual tape or not, right? 23 a little bit about the so-called evidence that she
24 A No, I said that I didn't know where it was 24 claimed she had. And then talked about the -- there
25 if it -- you know, where it was, whether it's in her 25 were some pleasantries in there, you know, just talking
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 216 Page 217
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 about non-related stuff, Bahamas life, things like that. 2 A I just said it was a waste of time, got
3 Q And how long did that last? 3 nothing.
4 A Probably about an hour. A half an hour or so. 4 Q Got nothing of any substance from the nannies,
5 Q Now, Ms. Cosby did in fact ask you to give her 5 is that what you told her?
6 the circumstances around the meeting with the nannies, 6 A Yes.
7 did she not? 7 Q And you didn't tell her you thought the nannies
8 A Yeah, I believe she did. 8 were credible? She didn't ask you that, did she?
9 Q And did you give her the circumstances of how 9 A She did.
10 y'all talked for three hours? 10 Q And you told her they were?
11 A Oh, no, circumstances. I thought you meant 11 A I thought they were, yes.
12 what got us to go there in the first place. 12 Q And did you tell her what -- did she say, "What
13 Q No, I'm asking when you gave this information 13 do you base that on?"
14 to Ms. Cosby, you say she asked you about it, did you 14 A I just said like, for instance, I asked the
15 have any information about the nannies and the 15 nannies about the affidavits, what was the issue about
16 videotape, right? 16 this -- these affidavits that was paid for. You know,
17 A Yes. Well -- 17 and they corrected that issue for me. I asked them what
18 Q In July? 18 was the discrepancies, you know, that upset them so
19 A No. Let me say this. I know that she asked if 19 much, what did they do to follow up. And that's why I
20 I heard something like this. And that's what prompted 20 found them credible.
21 me to mention about the tape. But did she ask me about 21 Q And did you tell that to Ms. Cosby?
22 how long the meeting lasted and what's going on, I just 22 A Yes.
23 told her it was a waste of time, that was it. 23 Q So she was aware of affidavits and the
24 Q And did she say, "What do you mean by that when 24 discrepancies and inconsistencies in the affidavits,
25 you say waste of time?" 25 wasn't she?
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
11. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 93 of 99
Confidential Confidential
Page 222 Page 223
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 call me up. 2 Q I'm asking you about how it came up had you had
3 Q For you to get a quote for her to use in an 3 the conversation with her in October about her telling
4 article? 4 you that she had told Rita Cosby about the videotape?
5 A Yes. 5 A We were talking about all this media hoopla
6 Q And who did you understand that she worked for? 6 that was going on about the tape, you know, and she said
7 A I believe she's an independent journalist. 7 that she told Don -- Rita about it.
8 Q Yeah. And who -- where are her articles 8 Q Told who about it?
9 generally published? 9 A Donna told Rita about it.
10 A I believe it's in the National Inquirer and the 10 Q And did she tell you a timeframe that led you
11 Globe. 11 believe that she had told Rita about it before you
12 Q Two tabloids? 12 talked to Rita in July about it?
13 A Yes. 13 A No, but I understood it was much earlier.
14 Q Do you know of any other publications where 14 Q You understood from talking to Donna Kauffman
15 Ms. Kauffman's articles have been published with quotes 15 that she had told Rita about the videotape much earlier
16 from Don Clark, other than either the National Inquirer 16 than July of 2007?
17 or the Globe? 17 A Yes. I believe that Donna Kauffman was trying
18 A No. 18 to write an article or do a deal with the nannies. And
19 Q And so calling you to ask for a quote from 19 that's when the nannies told her about it and that they
20 Mr. Clark. How did it come up about the videotape and 20 just didn't do it.
21 Rita Cosby? 21 Q She was trying to work some sort of a deal with
22 A We debated a lot about the drugs. You know, 22 the nannies to do an article about the videotape?
23 she is obviously acquainted with Dr. Perper. And, you 23 A Yeah, pay them a --
24 know, I wanted to know what was the deal with the drugs, 24 MS. MCNAMRA: Object to form.
25 you know. And so we debated that quite a bit. 25 Q (BY MR. WOOD) Let me restate it. Did Donna
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 224 Page 225
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 Kauffman tell you that she was trying to work some sort 2 July of 2007 --
3 of deal with the nannies to do an article about the 3 A Yes.
4 videotape? 4 Q -- is that right?
5 A No. 5 A Yes.
6 MS. MCNAMRA: Same objection. 6 Q Did she tell you why she never did an article
7 Q (BY MR. WOOD) What did she tell you in terms 7 about it?
8 of what -- you said that she was trying to do an article 8 A Apparently her editors just didn't want to go
9 or do a deal with the nannies. What did you mean? 9 there.
10 A About what was going on in the house in the 10 Q That would have been months earlier, right?
11 Bahamas. 11 A Yes, I believe it was early -- it was in May or
12 Q Well, did that include the videotape? 12 something.
13 A I don't know. 13 Q In May of -- she told you that at least May of
14 Q Well, what brought up the videotape? 14 2007, she had pitched the videotape story about the
15 A The national media was going crazy about this 15 nannies and the sex tape to others and they didn't want
16 book that has this tape in it. And that came up. And 16 to go there?
17 she just said, you know, that I mentioned that to Rita 17 A Actually, it's earlier than that, because it's
18 much earlier. 18 Donna Kauffman that gave me the -- Liz Thompson's phone
19 Q And when she said she mentioned that to Rita, 19 number. So I went to see Liz Thompson on May 5th, so it
20 she mentioned that she had information that the nannies 20 was definitely a couple weeks earlier than she -- that
21 had seen a videotape of Larry Birkhead and Howard Stern 21 she told me that, yes.
22 engaging in sex? 22 Q So before you went to see the nannies on May
23 A Yes. 23 the 5th, Donna Kauffman had already told you about this
24 Q And that she had conveyed that to Rita Cosby 24 alleged story that the nannies had seen a sex video of
25 months earlier than when you discussed it with Rita in 25 Howard Stern and Larry Birkhead?
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
12. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 94 of 99
Confidential Confidential
Page 226 Page 227
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 A No. 2 she heard that from the nannies or that --
3 Q What did she tell you about the videotape? 3 A Yes.
4 A Nothing. 4 Q -- she had heard someone say the nannies had
5 Q Did she just give you the number to the 5 said it?
6 nannies? 6 A No, she said she got that directly from the
7 A She just said, "Look, I tried to talk to 7 nannies.
8 the nanny" -- you know, we tried to do this article. 8 Q In the Bahamas?
9 It's not working out. And she said -- she e-mailed me 9 A I don't know where she was when she got it.
10 her phone number, she said, "You might give it a try." 10 Q Months before Rita Cosby learned about it from
11 That's it. 11 you?
12 Q Did she tell you anything about the article 12 A Months before Rita --
13 including any reference to the videotape? 13 Q Well, some couple of months.
14 A Nothing. 14 A Yeah, it must have been in April, because
15 Q When did she first tell you about the videotape 15 that's when the deal with the nannies fell through.
16 being known to her? When did she tell you she learned 16 Q So she went down -- or she interviewed the
17 about it? 17 nannies and that's when she learned about the videotape,
18 MS. MCNAMRA: Objection, asked and 18 right?
19 answered. 19 A That's what I understand, yes.
20 A I don't know. 20 Q From her, Don Kauffman. And she pitched that
21 Q (BY MR. WOOD) Did she ever tell you how she 21 story to her editor at either the National Inquirer or
22 heard the allegation? 22 the Globe. And they wouldn't go there with the story,
23 A Know it just came from the nannies. That's all 23 they didn't publish the story. Is that what you
24 I know. 24 understood?
25 Q Did she actually get that -- did she tell you 25 A I don't know what she pitched to them. She
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 228 Page 229
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 told me she was trying to do a story on the nannies and 2 MR. WOOD: Why don't we take a break.
3 especially about the drugs and everything that was going 3 THE VIDEOGRAPHER: We're going off the
4 on in the house. She never mentioned the videotape. 4 record. The time is 2:42.
5 Q She didn't tell you that -- well, she did 5 (A recess was taken.)
6 mention the videotape to you -- strike that. Am I right 6 THE VIDEOGRAPHER: We're back on the
7 that what she said to you is that after the book came 7 record. The time is 3:00 o'clock.
8 out and it had this story in it about the videotape, 8 Q (BY MR. WOOD) Ms. Vicedomine, let me make sure
9 that you were talking to her about another matter and it 9 I'm clear. You told me, I believe, that you went down
10 came up from her that, "You know, I heard that from the 10 in April of 2007 with Mr. Clark and that's when you
11 nannies and tried to pitch that story, but my publishers 11 interviewed Moe and Tas?
12 wouldn't go with it." Is that the way it came out, 12 A No, I think it was in March.
13 ma'am? 13 Q I thought you said you went down in March and
14 MS. MCNAMRA: Objection, form. 14 interviewed the sea captain and you went down in April
15 A Not at all. 15 and you interviewed Moe and Tas.
16 Q (BY MR. WOOD) Well, why did she bring it up to 16 A Yes, that's right. I'm sorry.
17 you? 17 Q All right. So let's -- just so that's clear,
18 A Like I said the third time now, this came up on 18 the first time you interviewed Moe and Tas would have
19 the national media. Everybody was going crazy about 19 been April of 2007, right?
20 this tape. And Donna just made an offhand comment that, 20 A Around there, yes.
21 you know, she told Rita about that. That's it. We 21 Q And you had not spoken with them by telephone
22 never discussed it, nothing. 22 prior to meeting them at the interviews in Florida,
23 Q Some months before you told Rita, she told 23 true?
24 Rita? 24 A Only with Paul Porter.
25 A Yes. 25 Q Well, I'm talking about with Moe and Tas now,
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
13. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 95 of 99
Confidential Confidential
Page 286 Page 287
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 her about it? 2 video?
3 A No. 3 A No.
4 Q What did she say when you told her? 4 Q Did that come up later in the conversation?
5 A Oh, I don't recall what she said, but I know we 5 A Yes.
6 just talked about it, I said what happened, and that was 6 Q Tell me how it came up in terms of how it was
7 it. 7 broached by her.
8 Q What did she -- do you recall anything she said 8 A I can't recall.
9 in response to your telling her about this -- 9 Q You don't recall what she said in terms of
10 A No. 10 asking --
11 Q -- alleged sex video? 11 A I don't know how it came up. I can't remember.
12 A No, I don't. 12 Q And tell me again, you said you had the hour
13 Q But she asked you about it? 13 lunch with Don, didn't buy you a glass of wine. And
14 MR. MCFALL: Objection, asked and 14 then you went back and you spent another hour with the
15 answered. 15 nannies and Liz Thompson and Lincoln Bain?
16 Q (BY MR. WOOD) Is that right? 16 A About an hour and a half.
17 A She asked if I knew something about it, 17 MR. MCFALL: Objection, asked --
18 something like that. 18 Q (BY MR. WOOD) About another --
19 Q Tell me exactly what you recall her asking you. 19 MR. MCFALL: -- and answered.
20 A I just did. 20 Q (BY MR. WOOD) About another hour and a half?
21 Q Tell me your opinion -- in her words, what did 21 A Yeah.
22 she say to you? 22 Q And how much of that hour and a half was taken
23 A I can't recall her words exactly. 23 up with the continued discussions about payments to the
24 Q Did she call you and start right away talking 24 nannies?
25 about whether or not you knew anything about a sex 25 A About an hour.
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 288 Page 289
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 Q And then it was after that hour that Liz 2 payments they were demanding?
3 Thompson said what? 3 A That's it, correct, yes.
4 A About what? 4 Q Y'all had that discussion at lunch?
5 MR. MAYNARD: Objection to form. 5 A No, we didn't really talk about it at lunch.
6 Q (BY MR. WOOD) Well, I mean you had not in that 6 Q When did you talk about it?
7 next -- that first hour after lunch didn't have the sex 7 A We talked about it when we got back.
8 video discussion, did you? 8 Q Got back from when?
9 A In the first hour, no. 9 A From the Bahamas.
10 Q Right. So you've been with the nannies for an 10 Q I'm talking about had you and Don at lunch
11 hour, then you break for lunch for an hour, then you 11 talked about, "We need to try to find out what these
12 come back, and an hour goes by and you've not been told 12 people know that would justify some type of payment"?
13 anything about a sex video up to that point in time, 13 A No.
14 right? 14 Q Well, why were you allowed to ask a generic
15 A Correct. 15 question?
16 Q And tell me how it came up. 16 MR. MAYNARD: Objection.
17 A After discussions concluded about the money 17 A I said that it's really fine that we're sitting
18 issue, I wanted to know what can they testify to, you 18 here talking about money and I have no idea what you can
19 know, what do they know about what went on in the house. 19 testify to. I need to know something that you can
20 And Liz Thompson wouldn't let them ask -- wouldn't let 20 testify to.
21 them answer anything that she considered to be evidence, 21 Q (BY MR. WOOD) And you said that?
22 so she said I could only ask a generic question. 22 A I did.
23 Q Well, let me ask you this. Had you and Don 23 Q And did then -- you were asking for some sort
24 talked about trying to get them to give you some 24 of a preview as to what they could testify to --
25 indication of what they knew that would justify the 25 A Yes.
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
14. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 96 of 99
Confidential Confidential
Page 366 Page 367
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 source? 2 A Thirty-seven something, yes.
3 A I don't have to answer that question. 3 Q That Tas allegedly saw on Mr. Stern's computer?
4 Q Yes, you do. You put it out there -- 4 A Yes.
5 A I don't have to tell you -- 5 Q Did she tell you where that computer was
6 Q -- on the blogs -- 6 located?
7 A -- the results of what I -- 7 A Yes.
8 Q I can get the judge to order you to answer. I 8 Q Did she tell you how long she had looked at it?
9 don't think we really need to go there, ma'am. You put 9 A No.
10 information about the wire transfer on the blogs that 10 Q Did she -- did you ask her what it said other
11 you had obtained from your investigation, right? 11 than some $37,000 wire transfer?
12 A Yes. 12 A Yes.
13 Q And you did it to see if you could get 13 Q Who was it a transfer from?
14 corroboration from any other source, right? 14 A She couldn't remember.
15 A Yes. 15 Q Who was it a transfer to?
16 Q Did you get corroboration from any other 16 A She couldn't remember.
17 source? 17 Q When had the transfer taken place?
18 A I do not recall. 18 A That day.
19 Q As you sit here today, you don't recall getting 19 Q Did Tas tell you that she had learned that her
20 any corroboration from any other source about the wire 20 husband had been with another woman in the hotel room
21 transfer, do you? 21 the night before?
22 A I don't recall. 22 A Only after the book came out.
23 Q You don't recall getting any, do you? 23 Q When did she tell you about that?
24 A No, I don't. 24 A Several months after the book came out.
25 Q That was the $37,000. 25 Q And did she in fact tell you that she learned
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 368 Page 369
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 it first in the book? 2 MR. MCFALL: Here's the problem I'm
3 A I didn't ask her where she learned it. 3 asking. You didn't ask her if she's learned on the
4 Q What was her reaction to it? 4 Internet that Moe was trying to shop a book. She could
5 A I just asked her whether she was okay. 5 have learned it somewhere else as part of her
6 Q And what did she tell you? 6 investigation.
7 A She says they're fine. 7 MR. WOOD: I said, "When did you hear
8 Q Did you ever learn that Moe was out trying to 8 that?"
9 shop a book deal? 9 MR. MCFALL: All right. Was that before
10 A I did hear that. 10 or after March 27?
11 Q Huh? 11 THE WITNESS: That's just it, I can't
12 A I did. 12 answer the question.
13 Q When did you hear that? 13 Q (BY MR. WOOD) You can't answer when you heard
14 MR. MCFALL: Is that before or after 14 it?
15 March 27? 15 A Correct.
16 MR. WOOD: Public domain, Don. She's been 16 Q Could it have been before March 27th?
17 on the Internet -- she's been on the Internet -- look, 17 A No.
18 she -- 18 Q Was it something you learned from your Internet
19 MR. MCFALL: Are you answering -- 19 research?
20 MR. WOOD: Let me explain it to you, I 20 A No.
21 mean, because I know you're new to the case. She comes 21 Q Was it something you learned from an interview?
22 in here and she's the person going out and getting all 22 A Yes.
23 this information from the Internet that is in the public 23 Q Was it an interview of Moe or Tas?
24 domain. I'm entitled to know what she learned from that 24 A No.
25 public domain source. 25 MR. MCFALL: Don't answer that, if you
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
15. Case 1:07-cv-08536-DC Document 149-6 Filed 09/28/2009 Page 97 of 99
Confidential Confidential
Page 410 Page 411
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 A True. 2 MR. MAYNARD: Objection, form.
3 Q No -- none -- none of the authorities that have 3 MR. MCFALL: Objection, mischaracterizes
4 investigated the deaths of Anna Nicole Smith or Daniel 4 testimony.
5 Smith have found any criminal involvement on the part of 5 A Yes.
6 Howard Stern, true? 6 Q (BY MR. WOOD) Did you call Larry Birkhead in
7 A Yes. 7 May of 2000 [sic.] and state to him that you thought he
8 Q And what do you believe that they didn't do 8 was a good guy, but he needed to get rid of Howard Stern
9 that you did? 9 as a --
10 A I don't know how to answer that question, 10 MR. MCFALL: As part of your investigation
11 because there is just so much information that's 11 after --
12 contradictory to what, for instance, Dr. Perper wrote 12 MR. WOOD: Not asking about the
13 here. 13 investigation, I'm asking --
14 MR. MCFALL: I want to remind you that 14 MR. MCFALL: -- March 27, 2007, don't
15 information is what you found out after March 27, 2007, 15 answer --
16 so I would instruct you not to answer the question. 16 MR. WOOD: -- asking if she said that to
17 Q (BY MR. WOOD) Do you think you did a more 17 him.
18 thorough and complete investigation into the deaths of 18 Q (BY MR. WOOD) Did you call Larry and tell him
19 Anna Nicole Smith and Daniel Smith than the authorities 19 that?
20 in the Bahamas or the authorities in Florida? 20 A Yes.
21 A Yes. 21 MR. MCFALL: If it -- if it was after
22 MR. MAYNARD: Objection to form. 22 March 27 --
23 Q Do you base that primarily on your extensive 23 MR. WOOD: And did he --
24 and exhaustive and comprehensive search of materials 24 MR. MCFALL: Shut up.
25 online and on the Internet? 25 MR. WOOD: She's already answered -- what
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580
Confidential Confidential
Page 412 Page 413
1 WILMA VICEDOMINE 1 WILMA VICEDOMINE
2 did you just say to me? 2 ethics.
3 MR. MCFALL: I said shut up. Let me -- 3 MR. MCFALL: May I make my statement now?
4 MR. WOOD: Let me tell you something, old 4 MR. WOOD: Yes, sir, but you watch your
5 man. Don't -- don't say that to me, that's 5 mouth when you talk to me like that.
6 inappropriate. I'm not going to yell at you, you're 6 MR. MCFALL: Will you let me finish this
7 not -- 7 time?
8 MR. MCFALL: You keep interrupting my 8 If this occurred after March 27, 2007, I
9 objection. 9 instruct you not to answer the question.
10 MR. WOOD: No, sir. No, sir. She 10 THE WITNESS: Okay.
11 answered the question. Don't you look over at me and 11 Q (BY MR. WOOD) You just answered it, didn't
12 tell me to shut up. You may be old enough to be my 12 you?
13 father, but you're not. 13 A I guess I did.
14 MR. MCFALL: God, this is -- 14 Q Yeah.
15 MR. WOOD: No, sir. That's 15 MR. MCFALL: In the middle of my
16 unprofessional. 16 objection, she answered it. That's right.
17 MR. MCFALL: You keep interrupting me when 17 You let me finish my objection before you
18 I try to make an objection. 18 answer.
19 MR. WOOD: It is unprofessional for you to 19 Q (BY MR. WOOD) And Larry Birkhead, when you
20 sit on this record and tell me to shut up. 20 said that to him, refused to say that he would get rid
21 MR. MCFALL: It's unprofessional -- 21 of Howard, didn't he?
22 MR. WOOD: Maybe that's the way you do 22 MR. MCFALL: And I'm going --
23 things down here in Texas with a bunch of unprofessional 23 A Apparently I'm not talking about that.
24 lawyers and unethical lawyers, but that's not the way we 24 MR. MCFALL: I'm going to make the same
25 do it in Georgia where we have professionalism and 25 objection.
TSG Reporting - Worldwide 877-702-9580 TSG Reporting - Worldwide 877-702-9580