The Honorable Robin S. Rosenbaum
United States District court
Southern District of Florida
299 East Broward Boulevard, Room 205E
Fort Lauderdale, Florida 33301
Re Howard K. Stern v. John K. O’Quinn and John O’Quinn & Associates PLLCd/bja The O’Quinn Law Firm
United States District: Court for the Southern District of Florida
Civil Action No. 07-60534•-CIV-DIMITROULEAS
Dear Judge Rosenbaurn:
The Omnibus Order entered by the Court on August 29, 2008 (“the Order”), made, clear that no work-product protection existed for pre-March 27, 2007 ‘t’Quinn Materials and Investigation Materials” withheld by Defendants Pursuant to the Order, Defendants produced previously withheld documents to Plaintiff’s counsel on September 5, 2008. When comparing the produced documents to the latest privilege log submitted by Defendants to the Court, however, it appears that a number of pre-March 27, 2007 “O’Quinn Materials and Investigation Materials” are still being withheld by Defendants Missing from the production are the following Bates range of documents:
2998-3003 3803-3830
3013-3017 3832-3949
3040-3041 3951
3104-3105 (3105 is neither 3972-4018
produced nor on log) 4023-4044
3108-3182 4050-4079
3185 4083-4084
3227-3340 4088-4153
3550 4157-4163
3554-3568 418&4190
(3555-68 neither produced nor 4196-4213
on priv log) 4252-4294
3572-3628 4361-4382
3633-3638 4396-4397
3640-3801 4401-4473
The Honorable Robin S. Rosenbaum
September 12, 2008
Page 2of2
We believe that the documents contained in the Bates range listed above should be addressed during the cx parte hearing calendared for September 15, 2008.
In addition, the Order directed Defendants to: (i) verify that Defendants have produced all non-privileged documents relating to the underlying facts (Order at 54); (ii) verify that Defendants’ interrogatory responses are complete and Defendants do not rely on any facts not mentioned in their interrogatory responses (Order at 60), (iii) verify all screen names and pseudonyms used by Wilma Vicedomine on the Internet when discussing the deaths of the Smiths, the paternity of Dannielynn, or Mr Stern (Order at 38), (iv) produce copies of all postings wade by Vicedomine on the Internet that relate to the underlying investigation conducted in furtherance of the Broward County proceedings (Order at 38); and (v) produce all “source materials” regarding the deaths of Anna Nicole Smith and Daniel Smith (Order at 57) to date, we have not received these items, we therefore respectfully submit that these issues should be addressed during the ex parte hearing calendared for September 15, 2006
Thank you for your attention to this matter,
Respectfully yours,
L Lin Wood
LLW/b
cc: Robert Klein, Esq. (By Email and Fax)
Neil McCabe, Esq. (By Email and Fax)
I hear Howie is suing more people. Busy boy.
I read somewhere (do not recall where) that Lin Wood was 16, his father beat his mother to death. I wonder if he put on a defense lawyer's hat then and there and supported his father. Would say much re his character.